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United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
~tr r1J
EP AiRODiA03-90J099 t
September 1990
P~q, - q~/Lf-/-D
oEPA
Superfund .
Record of Decision: .
Osborne Landfill, PA
Hazardous Waste Collecfion
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
U.S. Environmental Protection Agency
Region III Information Resource
Center (3PM52)
841 Chestnut Street
. . .
Philadelphia, PA 19107 -.' !O.~.
u . S. Environmental Protection Agency
Region III Hazardo~s Waste .
Technical InformatIon Center
841 Chestnut Street, 9th Floor
Philadelphia. PA 19107
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EPA Report Collection ;
Information Resource Center:
i US EPA Region 3 '
~ Philadelphia, PA 19107
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REPORT DOCUMENTATION 11. REPORTNO. I ~ 3. Reciplenfa Ac:ceulon No.
PAGE EPA/ROD/R03-90/099
4. TI1Ie and Sub1I1Ie 5. Report Date
SUPERFUND RECORD OF DECISION 09/28/90 .
Osborne Landfill, PA .
So
First Remedial Action
7. AuIhor(a) 8. Performing Orllanlza1lon Aept. No'
1. .Perfonnlng Orgalnlza1lon Name and Add.... '10. ProjectlTuk/Wortt UnIt No.
11. Contrac:t(C) or Grant(G) No.
(C)
(G)
1~ 8ponaorIng Organization Name and AdIhu 13. Typa of Raport. P8r1od Cowrad
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SuppIemantary NoI88
.
1So Aba1rac:t (Umlt: 200 _rda)
The IS-acre Osborne Landfill site is an inactive abandoned coal strip mine in Pine
Township, Mercer County, Pennsylvania. The site is in a semi-rural area with a large
natural pond, woodlands, and wetlands bordering the site to the west. The shallow-
Clarion aquifer is present east of the strip mine high wall. The portion of the aquifer
that formerly overlaid the site was excavated during stripping activities. After the
mine was abandoned, the strip mine pit filled with ground water. From the late 1950s to
1978, contaminat~d spent foundry sand and other industrial and municipal wastes were
disposed of into the pit~ Other wastes including trash and drums containing solvents,
wastewater, and coolants, were disposed of onsite, gradually filling the strip mine and
displacing the water. The site holds an estimated 233,000 cubic yards of fill material.
In 1983, Cooper Industries, an operator of the site, removed approximately 600 drums of
waste and 45 cubic yards of soil from the site and installed a fence to restrict site
access. EPA has divided the remedial action into five operable units. Operable Unit 2
(OU2), which addresses contaminated wetland sediment, and OU5, which addresses the
contaminated Homewood aquifer will be implemented in a subsequent Record of Decision
(ROD). This ROD addresses the remaining three operable units. OUI addresses solid
(See Attached Page)
17. DcIc:unwIt An8IyaIa L DHc:rIplDra
Record of Decision - Osborne Landfill, PA
First Remedial Action .
Contaminated Media: sediment, gw
Key Contaminants: VOCs (benzene, TCE), other organics (PCBs, PAHs), metals (arsenic,
chr6mium, lead)
b. Iden~Tenna
c:. COSA TlI'IeIcIIGrcqt
8. AVllIabIIty St8tement 11. Sec:urtty CIu8 (ThIs Report) 21. No. of Pages
None 174
I 20. Sec:urtty CIu8 (1hIa Page) 22. PrIce
!\Tnn...
.,.
,'"/ ~
50272-101
~a ANSl-Z3I.18)
See m.tructIona on Re-
(Formetty NTlS-35)
Deperlment of Commerce
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EPA/ROD/R03-90/099
Osborne Landfill, PA
First Remedial Action
Abstract (Continued)
waste fill material including foundry sand and other onsite pond sediment, OU3 addresses
leachate associated with the onsite water table, and OU4 addresses the Clarion aquifer.
The primary contaminants of concern affecting the sediment and ground water are VOCs
including benzene and TCE; other organics including PCBs and PAHs; and metals including
a~senic, chromium, and lead.
The selected remedial action for this site is comprised of three operable units. The
primary remedy for OU1 includes constructing a slurry wall barrier around the perimeter
of the fill, constructing a clay cap over the fill material, ground water pumping and
treatment using equalization, pH. adjustment, chemical precipitation, clarification, sand
filtration, and carbon adsorption, followed by injection into the onsite mine pit;
offsite disposal of ground water treatment residues; ground water monitoring; and
implementing institutional controls including deed restrictions. A contingency remedy
for OU1 will be implemented if performance standards cannot be met during the pre-design
stage of remedy implementation and includes regrading the site, excavating and placing
solid waste in a RCRA Subtitle-C onsite landfill; long-term ground water monitoring; and
implementing institutional controls. If the primary remedy for OU1 is implemented, no
additional action, other than the primary OU3 remedy of ground water monitoring, is
necessary for OU3. If the contingency remedy for OU1 is implemented, the contingency
remedy for OU3 also must be implemented. The contingency remedy for OU3 includes.
dewatering the site during excavation; isolating the fill area from the onsite mine
pools; treating the ground water using equalization, clarification, and sand filtration
for solids removal, and carbon adsorption for organics removal, followed by onsite
discharge; and ground water monitoring. The selected remedy for OU4 includes pumping
and treatment of ground water in the Clarion Formation using air stripping, onsite air
emissions treatment, onsite injection of treated ground water, and ground water
monitoring. The estimated present worth cost for the primary remedies is $18,681,000
with an annual O&M cost of $904,000 for 30 years. If the contingency remedies are
implemented, the estimated present worth cost is $17,811,000, which includes an annual
O&M cost of $940,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: The selected source remedy will not reduce the current
level of contamination in the fill area, but will maintain an average PCB concentration
level of .23 mg/kg. EPA's PCB Spill Cleanup Policy for a reduced access area is met by
this alternative. Ground water contaminants will be remediated to the following
background levels: TCE 0.2 ug/l, benzene 0.2 ug/l, PCBs 1 ug/l, chromium 50 ug/l, lead
15 ug/l, and arsenic 22 ug/l. If any ground water contaminants exceed SDWA MCLs or
MCLGs, the remedy will continue until these goals are met.
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DECLARATION FOR THE
RECORD OF DECISION
,
SITE NAME AND LOCATION
Osborne Landfill site
pine Township
. Mercer County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected Remedial Action for
the Osborne Landfill Site in Pine Township, Mercer County,
Pennsylvania. This Remedial Action was developed in accordance
with the Comprehensive Environmental Response, Compensation, and
LiabilLty Act (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency' Plan (NCP). The decisions herein have been based on
the Administrative Record for this site (index attached).
. .
The Commonwealth of Pennsylvania concurs with the selected
remedy.
ASSESSMENT OF THE SITE
. .
Pursuant to duly delegated authority, and pursuant to Section 106
of CERCLA, 42 U.S.C. Section 9606, I hereby determine that
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 public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
Five operable units were identified at the Osborne Landfill site
in the Feasibility study. These operable units (OU) include:
. The solid waste fill material (OU1)
. Wetland sediments (OU2) - Decision deferred
. The onsite water table (OU3)
. The Clarion Formation (OU4)
. The Homewood Formation (OU5) - Decision deferred
EPA is deferring'selection of a remedy for Operable Units Two and
Five, and will address these operable units in a subsequent ROD.
In this ROD, BPA ha. selecte4 a primary ...e4ial Alternative and
a contingency Alternative for the operable units relate4 to the
fill material (fill) &D4 the onsite .ater table (001 &D4003).
This ROD contains performance stan4ar4s that must ~e met before
4esiqn, 4uring 4esiqn, &D4 after construction of the primary
...e4ial Alternative for 001. If the Primary ...e4ial
Alternative for 001 fails to meet these stan4ar4s, the
Contingency Alternatives for 001 and 003 vill then be
implement.eeS.
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2
, .
The major components of each remedy are discussed below:
Operable Unit One - Pill Material
Primary Alternative
Slurry Wall/Pump arid Treat Al~ernative (512)
, -
This alternative consists of construction of a slurry wall
barrier around the perimeter of the fill. Water will be pumped
out of this containment and treated to produce a negative
pressure, effectively trapping the fill contaminants and removing
the threat to ground water from foundry sands contaminated with
polychlorinated biphenyls (PCBs), solvents, metals and
polyaromatic hydrocarbons (PAHs). The major components of this
alternative "include: -
. Run-on and run-off control systems including a clay cap,
onsite drainage and erosion controls
Grouting and bulkhead installation to .seal openings or
cracks linking the fill to the mine pool
. Construction of a slurry wall around the perimeter of the
fill area and installation of a clay cap and revegetation
.
. Installation and operation of extraction wells, treatment
of the extracted water and subsequent injection into the
onsite mine pool
. Institutional controls and ground water monitoring.
Continqencv Alternative
. RCRA Subtitle C Landfill Alternative (S5)
Excavation and placement of the solid wastes in
landfill will remove the threat to ground water
sands contaminated with PCBs, solvents, metals,
PAHs. The major components of this alternative
an onsite
from foundry
and carcinogenic
include:
. Runon controls and runoff control systems including a
cap, on-sit~ drainage and erosion controls
. Excavation af approximately 233,000 cubic yards of fill and
placement of this waste in a RCRA Subtitle C onsite
landfill
. 'Regrading and revegetation of the site area and
. Institutional Controls.
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3
,
Operable UDi~ ~bree - Onsite Water Table
PrimarY Alternative
If the slurry wall implementation is effective, no additional "
action will be required for the Onsite Water Table.
Continaencv Alternative
Collection and Treatment of Onsite Water Table Alternative
(G03)
This alternative must be selected if the Contingency Alternative
for OU1(S5 - RCRA Subtitle C Landfill) is implemented. The majo~
components of this alternative include:
. Collection (or dewatering of the fill) of the water removed
during excavation activities ' ,
. Chemical and physical treatment of collected ground water
and subsequent onsite injection into the mine pool
. Groundwater monitoring.
ODerable Oni~ Pour - Clarion Aauifer
Selected Alternative
Extraction, Physical Treatment, and Onsite Injection
Alternative (GC3)
This alternative will reduce the level of vinyl chloride
contamination in the Clarion Formation and reduce potential human
health risks associated with the use of this aquifer. The major
components of this alternative include: '
. Construction of' extraction wells in the Clarion'Formation
. Pumping of ground water for onsite removal of contaminants
by air st~~pping of volatile organic hydrocarbons
. Injection of treated ground water onsite into the mine pool
. Groundwater monitoring.
DBCLARATIOIf
The primary remedy and the contingency remedy selected for
Operable Unit One (fill material) are protective of human health
and the environment, comply with Federal and State requirements
that are legally applicable or relevant and appropriate, and are
cost- effective. , ,These remedies utilize permanent solutions and
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4
alternative treatment technologies , to the maximum extent
practicable for this site. However, because treatment of the
principal threats at the site was not practical, these remedies
do not satisfy the statutory preference for treatment as a
principal element of each remedy. Because the selected remedies
for Operable Unit One will result in hazardous substances
remaininq on site above health-based. .cleanuplevels, a review of
the site will be conducted every five years after commencement of
remedial action to ensure that the remedy implemented continues
to provide adequate protection of human health and the
environment.
The primary remedy and the continqency remedy for Operable
Unit Three (Onsite Water Table) are protective of human health
and the environment, comply with Federal and state requirements
that are leqally applicable or relevant and appropriate and are
cost effective. These remedies utilize permanent solutions and
alternative treatment technoloqy to the maximum extent
practicable, and satisfy the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element.
The selected remedy for Operable unit Four is protective of human
health and the environment, complies with Federal and state .'
requirements that are leqally applicable or relevant and
appropriate for this remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative
treatment technoloqy to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a .
principal element.
~~~.
Edwin B. Erickson
Reqional Administrator
Reqion III
SEP 28 1990
Date
. .
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TABLE OF CONTENTS
"
-
SITE LOCATION AND DESCRIPTION. . .'. .
. . . . . . . .
. . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES
. . . . .
. . . . . .
COMMUNITY RELATIONS HISTORY. . ."".
. . . . .
. . . . . . . .
SCOPE AND ROLE OF RESPONSE ACTION
. . . . . . . . . . . . . .
"
SUMMARY OF SITE CHARACTERISTICS
. . . . . . . . . . . . . . .
. '.
SUMMARY OF RISKS
. . . . . .
. . . .
. . .
. . . . .
. . . .
HUMAN HEALTH RISKS
. . . . . .
. . . . .
. . .
. . . . .
ENVIRONMENTAL RISKS. .
. . . .
. . .. ..
. . . .
. . . . .
DESCRIPTION OF ALTERNATIVES.
. . . . .
. . . . . .
. . . . .
SOLID WASTE/FILL MATERIAL (OPERABLE UNIT 1)
. . . . . . .
ONSITE WATER TABLE (OPERABLE UNIT 3)
. . . . .
. . . . .
CLARION FORMATION
(OPERABLE UNIT 4)
. . .
. . . . . . .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
. . . . . . .
SELECTED REMEDY.
. . . . . . .
. . . . . . . . . .
. . . . .
. ..
Operable Unit 1 Solid Waste Fill Material. . . .
. . .....
Operable Unit 3 - Onsite Water Table
. . . . .
. . . . .
Operable Unit 4 - Clarion Aquifer excludinq the deep mine
pool. . ..... . . . . . . . . . . . . . . . . . . . . .
STATUTORY DETERMINATION
. . . . .
. . . . . . . . . .
. . . .
EXPLANATION ,OF SIGNIFICANT CHANGES FROM THE PROPOSED PLAN
1
6
.7
9
10
17
. .
18
21
22
24
48
53
57
71
~
73
74
75
76
86
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REMEDIAL ALTERNATIVE
RECORD OF DECIS+pN SUMMARY
OSBORNE LANDFILL SITE
SITE LOCATION AND DESCRIPTION
.. The Osborne Landfill Site is locat~d in Pine Township, Mercer
County, Pennsylvania (see Figure 1). Located approximately
1 mile..east of Grove City, Pennsylvania, the site is an abandoned.
coal strip mine that encompasses approximately 15 acres.
Throughout the period late-1950s to 1978, contaminated spent
foundry sand and other industrial and municipal wastes (wood,
plastic, scrap metal, debris, etc.) were disposed at the site.
into a strip mine pool (figures 2 and 3) that was present at the
base of the highwall. The highwall is undisturbed rock and earth
that forms the uphill side of the strip mine pit. The earth and
rock that was removed to reach the coal was piled up downhill and
is known as'nspoil". This spoil forms the downhill side of the
nino, pit. After the mine was abandoned, the pit filled with ..
~ro~nd water. Wastes were disposed into this pit and gradually
filled in the strip mine displacing the water. It is estimated
that 233,000 cubic yards of fill material Was taken to the former
landfill during this period. In addition to the trash and
foundry sand, drums containing various industrial wastes--
(solvents, coolants, wastewater, etc.) have been disposed at the
site. The total number of drums taken to the site is unknown.
Drums have been observed on the surface and within the fill
material. Most. of the drums that are buried are most likely
crushed, based on the depth of the fill (42 feet maximum) and the
age of the drums. .'
The site is located in a semi-rural area along East Pine Street
Extension, which borders the site to the south. The closest
residence. is located approximately 1,000 feet west of the site.
However, most of the residential homes in the area are located
about 1/4 mile north of the site along Enterprise Road and east
of the site along Diamond Road. Most of the homes along Diamond
Road and Enterprise Road are dependent on groundwater as a source
of potable water. Grove City, the largest municipality near the
site, has a population of 8,162 based on u.S. Census Bureau
records for 1980. .
As shoWn on Figure 2, the site is bordered to the east and south
by farmland. To ~e north is a wooded area which separates the
site from residential homes along Enterprise Road. A large
natural pond, woodlands, and wetlands border the site to the
west. Mine spoil piles are situated between the pond and the
actual disposal area. A 6-foot high security fence surrounds the
site. The entrance 'gate is located along East pine Street
Extension.
1
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FIGURE I
SITE LOCATION
OSBORNE LANDFILL SITE GRO E
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G[NERAl ARRANGEMENT OF THE SITE
OS . ~NE LANOAll SITE. GROVE CITY. .
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F.UIIE I
GEOlOGIC CROSS SECTION
ACROSS THE OSBORNE SITE
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FRED C. HART AaaOCIATea. .INC.
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The disposal area is situated between the strip mine highwall and
the mine spoil piles. Three pon~s (mine pools) are located in
the center of the disposal area at: the base of the highwali.
These ponds were formed by the d1sposal practice of dumping
foundry sand (and other materials) directly into.. the original
strip mine pool. Because of this, most of the fill material is
below the water table. The dumping of materials has filled the
original 6-acre strip mine pool ex~ept for. three small ponds,
which are referred to as Ponds 1, 2, and 3. Numerous drum
fraqments are littered throughout the site and' along the banks of
L'1ese ponds. However, all of the drums appear to be empty"
JiLscellaneous foundry equipment and municipal refuse (washing
machines, paint cans, etc.) are also present on the surface of
the site. .
The fill material consists primarily of spent foundry sand. The
foundry sand that is currently generated by Cooper Industries is
not a hazardous waste under the Resource Conservation and
Recovery Act, 42 U.S.C. section 6901 et seq.(RCRA), and can be
disposed of in a residual w~ste landfill. Although not a
hazardous waste, foundry sand does contain hazardous substances
as defined by in section 101(14) of CERCLA, 42 USC section
9601(14) including pOlyaromatic hydrocarbons (PARs) and low
levels of metals. Based on boring logs, historical aerial
photographs, and site mapping, it is estimated that the former
disposal area contains approximately 233,000 cubic yards of solid
waste. . Drum fraqments have been observed in the fill material,
suggesting that drums were cO-disposed with the spent foundry
sand. Subsurface samples collected from the fill area indicated
that the foundry sand is oily in appearance, which may be the
result of liquid wastes disposed at the site or from the contents
of leaking or crushed drums. Samples collected from the fill
material contained polychlorinated biphenyls (PCBs), PARs, and
metals. Onsite pond sediment samples and offsite sediment
samples (collected from a portion of the wetland) have also
exhibited these contaminants. Volatile organics (vinyl chloride
and trichloroethene) have been detected at levels above drinking
water standards (i.e. Maximum contaminant Levels(MCLs», as set
forth in 40 CFR 141.60-63 in the onsite ponds, the- water table,
and in the underlying flow systems.
The coal formation that was strip mined at the Osborne site was
deep .mined to the northeast of the site. EPA has been unable to
determine the extent of the deep mines but general information
indicates that th~y run for miles. The' deep mines have filled
with water, forming a very large underground reservoir that is
connected with the fill area at the Osborne Site.
Five flow systems have been studied at the Osborne Landfill Site.
These flow systems, in descending order, include: the water
table; the Homewood Formation, which underlies the water table
and the disposal area; the Clarion Formation, which is present
,east of the strip mine highwall and overlies the Homewood
Formation (it does not overlie the site since it was excavated
during the stripping activities); the Connoquenessing Formation,
5
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which underlies the Homewood Formation; and the Burgoon
Formation, the deepest formatio~ studied during the remedial
investigation. EPA's Ground Water Protection strategy" (198'4)
classifies water sources according to vulnerability an usage.
Class I aquifers are the sole source of water, for a, community,
and are very vulnerable to pollution. Class IIa aquifers have
potable water currently used for drinking water. Class lIb
aquifers could potentially be used. for drinking water and class
III aquifers contain water unsui table for domestic uses. The
Homewood Formation and Clarion Formation are -- used by some local
residents as a source of potable water. These flow systems are
classified as Class IIa because of this usage. The
Connoquenessing and Burgoon Formations are also classified as
Class IIa since they are used as a source of water by the Grove
City Water Authority. The intake supply wells are located about
1 mile northwest of the site. The onsite water table surrounding
the fill is classified as a Class lIb aquifer, since it is
potentially.available as a source of drinking water.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Brookville Coal seam had been mined extensively in the region
since the beginning of the 20th century. , During the 1940s, the
coal was strip mined at the site to the limits of the remaining
highwall, located along the eastern boundary of the site. '.
. -
From the late-1950S until 1963, the site was operated as a waste
disposal area by Mr. Samuel Mohney. Disposal activities
continued under. Mr. James Osborne, the owner of the site, from
1963 until 1978, when the site was closed by the pennsylvania
Department of Environmental Resources (PADER). The site property
is now owned by Mr. Edwin McDougal. An April 7, 1978 letter from
the PADER Division of Solid Waste Management to Mr. James Osborne
stated that the dump was said to be in violation of "Act 241"
(The Pennsylvania Solid Waste Management Act) and that no permit
was on file which would permit waste disposal activities at the
site. The letter also indicated that the site should immediately
stop accepting wastes with the exception of the - spent foundry
sand, which was to be used to fill the mine pool. .It is believed
that foundry sand was landfilled for a short period after 1978 in
an attempt to fill in the remaining mine pool.
The site was investigated by the EPA and the PADER following its
closure as a non-permitted landfill. In July, 1982, the site was
placed on the National Priorities List (NPL), 40 C.F.R. Part 300,
App. B. Various site investigations were conducted between 1982
and 1989 by the PADER, EPA, and Cooper Industries Inc.. The major
studies, including some initial cleanup efforts by Cooper
Industries, are listed below in chronological order.
. 1983 - Installation of a security fence around the site and
the removal of over 600 drums and 45 cubic yards of
contaminated soil by Cooper Industries.
. 1983 - Cooper Industries conducted a remedial investigation
6
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,-
at the site, in accordance with a Consent Order and
Agreement between Cooper Industries and the PADER. The
remedial investigation involved a study of groundwater and
surface water at the site. Residential wells north of the
site were sampled (these wells were not contaminated). The
volume of waste material was also estimated" to be 233,000
cubic yards. '
. 1985 - EPA conducted an investigation of the disposal area
, ,to determine the contents of the fill material.
Approximately 18 test pits were randomly excavated
throughout the si te area. Samples were collected for
limited organic and inorganic analysis from selected test
pi ts. Two intact drums and numerous drum remnants were
encountered during the test pit operations. The intact
drums were sampled and found to contain ethylbenzene and
xylene.
.
1988 to 1989 - EPA conducted a Remedial Investigation (RI)
to assess offsite groundwater contamina-=ion and to"
determine the extent of contamination in the fill material.
A Feasibility Study (FS) was conducted concurrently with
the remedial investigation. The feasibility study
identified an array of' alternatives for remediating the
media of concern at the Osborne Landfill Site. (These'
alternatives are identified in this Record of
Decision(ROD).) ,
. 1989 - EPA conducted an evaluation of the slurry wall
alternative that was proposed by Cooper Industries. An
addendum to the FS was prepared to document the evaluation
of this al ternati ve. EPA issued its proposed plan which
indicated a preferred alternative (RCRA landfill) for the
site and sent special notice letters to Potentially
Responsible Parties (PRPs) in August. During the comment
period and afterwards, EPA received and reviewed numerous
comments from Cooper Industries, the public and elected
representatives regarding the slurry wall alternative. The
slurry wall was one of the alternatives discussed in the
proposed plan.
. 1990 - EPA organized a slurry wall review group, composed
of individuals with substantial knowledge of slurry wall
technology.
A number of PRPs' 'have been identified for this Superfund site.
These PRPs include: Cooper Industries Inc, Castle Iron & Steel
Co., Ashland Chemical Inc., and General Electric Co. Special
notice letters were sent to these PRPs on September 13, 1989.
COMMUNITY RELATIONS HISTORY
A Community Relations Plan (CRP) was prepared in May 1983 to
identify the concerns of local residents and government officials
regarding the Osborne Landfill Site. The primary goals of the
7
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cap was to establish and maintain open communication among
Federal, state, and local offici~ls, and the residents of the
Grove city area. EPA gained insight Qn.community concerns from
attendance at public meetings held in January and May of 1983,
and from telephone discussions with persons interested in the
site.
,
The primary issue of public interest is. the potential for
groundwater contamination. The public is also. concerned with air
and surface water contamination~ Cooper Industries is a major
employer" in the area and the public is concerned about the
company's role in the problems at the Osborne Landfill Site.
Presently, this concern may be partially mitigated since Cooper
Industries has spent a large sum of money to remove drums and
contaminated soil from the site and has been involved with the
RIfFS. The cap was updated in August 1989, and interviews were
conducted with local representatives, the municipal water
authority ~nd some residents.
The RIfFS and Proposed Plan for the Osborne Landfill Site were"
made available for public comment in August 1989. These
documents were contained in the administrative record which was
placed in an information repository maintained at the Grove City
Community Library. The notice of availability for these
documents was published in the Sharon Herald on August 2S, 1989"..
A public comment period was held from August 2S, 1989 through
October 23, 1989. In addition, a public meeting was held on
September 14, 1989. At this meeting, representatives from EPA
answered questions about problems at the si te and the remedial
alternatives under consideration. Public comments favored
allowing Cooper Industries to implement the slurry" wall
alternative. A response to the public comments received during
this period is included in the Responsiveness Summary, which is
part of this ROD. Because of the large volume of technical
comments received from Cooper Industries and the resulting
extensive EPA response to those comments, EPA has included these
comments in the Administrative Record which is available for
public review, but not in the Responsiveness Summary. This
decision document presents the selected remedial actions for the
Osborne Landfill Site in Mercer County, Pennsylvania, chosen in
accordance with CERCLA, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) and the National oi1 and
Hazardous Substances Pollution Contingency Plan (NCP), SS Fed.
~ 8666-886S(March 8, 1990) (to be codified at 40 C.F.R. Part
300).
8
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SCOPE AND ROLE OF RESPONSE ACTION
In 1983, Cooper Industries, under"a Consent Order with the state
of Pennsylvania, removed approximately 600 drums of waste that
were stored on the surface of the Osborne site and installed a
fence to restrict site access. These actions substantially
reduced the risk of contact with concentrated wastes and
prevented additional contamination o~ the ground water.
As with many Superfund sites, "the problems at the Osborne
Landfill, 'site are complex. As a result, the EPA has divided the
remediation efforts into five manageable components called
"operable units. n The FS developed remedial al ternati ves for
each of these operable' units. These operable units are as
follows:
. Operable Unit 1 (OU1): The solid waste (includes the
, onsi t,8 pond sediments since they are essentially foundry
sand).
. Operable Unit 2 (OU2):
Wetland sediments.
. Operable Unit 3 (OU3):
associated with fill).
Onsite ,water
table
(leachate
.
Clarion aquifer(excluding the mine
Operable unit 4 (OU4):
pool)
. Operable unit 5 (OU5):
Homewood aquifer
Alternatives developed for the solid waste (OU1) focused on
either containing, treating, or landfilling the solid waste. The
role of this operable uni t is to prevent contact wi th the
relatively immobile PCBs and PARs present in the waste and to
prevent additional contamination of ground water from the metals
and organic hydrocarbons present in the fill which are the
principal threat at the site. The selected alternative for this
uni t must also prevent migration of the foundry sands to the
wetlands from surface water runoff.
Selection of a remedial alternative for the wetlands (OU2) has
been deferred for the following reasons:
a) The contamination of the wetlands is minimal.
b) Construction of the selected remedy for the fill will
probably have an impact on the adjacent wetlands that will be
defined during the design of the slurry wall alternative.
c) Additional biological tests are needed to assess whether
we~lands biota have been effected by site contaminants.
The role of the operable unit for the onsite water table OU3 is
to prevent the migration of contamination present in the ground
water that is in contact with the fill from leaching into the
9
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aquifers that supply drinking water to area
principal threats are dissolvect PCBs, metals
hydrocarbons.". ,
The role of the operable unit for the Clarion Aquifer (OU4) is to
prevent migration of the chlorinated solvents in this aquifer to
nearby residential wells that use this aquifer as a domestic
water supply. The principal threat is vinyl chloride present
(6ppb) above the MCLs(2 ppb) allowed by the Safe Drinking Water
A~... .'
residents. The
and chlorinated
. .
Selection of alternatives for the Homewood Aquifer (OU5) has been
deferred. contamination has been detected at levels near the
MC~ for vinyl chloride and TCE. A very large mine pool is
located above the Homewood Aquifer to the north of the site and
is contaminated with up to 47 ppb of vinyl chloride. If water
from the mine pool is seeping into the Homewood formation, any
remedy that, does not address this source of contamination is
likely to be unsuccessful. For this reason, EPA is deferring a
decision on this operable unit until after completion of a-
subsequent Ground Water Verification Study as further explained
in the Description of Alternatives section of the ROD.
SUMMARY OF SITE CHARACTERISTICS
Previous investigations conducted by either the PADER, Cooper
Industries, or EPA have focused on determining the nature and
extent of contamination at the Osborne Landfill Site. The
various media investigated include:
. The solid waste fill material.
.
The water table.
. The Clarion Formation (including the flooded deep mine
which is present at the base of the Clarion Formation).
. The Homewood Formation.
. The Connoquenessinq Formation.
. The Burgoon Formation. -
. The surface waters and sediments (the onsite ponds, the
offsite wetland pond, the wetlands to the southwest of the
site, the offsite strip mine pond, and various intermittent
streams).
The source of contamination is the solid waste fill material,
which primarily consists of 233,000 cubic yards of contaminated
foundry sand. The contaminants of concern in the fill material
include: PCB-1254 (410 mq/kq, maximum, 23 mq/kq averaqe): the
PAHs benzo(a)pyrene (59 mq/kq, maximum, 13 mq/kq averaqe), and
dibenzo(a,h)anthracene (27 mq/kq, maximum, 4 mg/kq averaqe): and
10
-------
the metals chromium (1,630 mg/kg, maximum, 258 mg/kg average),
lead (223 mg/kg, . maximum, 83 "mg/kg average) , and nickel
(1,270 mg/kg, maximum, 134 mg/kg average). With the exception of
a few highly-concentrated samples,. the horizontal and vertical
distribution of contamination is homogeneous.. in nature.
Contamination has been detected within the entire disposal area
where the characteristic black foundry sand was present. Table 1
summarizes' the distribution of these contaminants of concern in
soils, the mine spoil piles and the:!ill material. The level of
contamination in the fill material is greater. than the level of.
contamination in either the mine spoils or soils.
Sediment contamination was observed in all three of the onsite
ponds and in the portion of the wetland that borders the site to
the. southwest. Because the sediments are essentially
contaminated foundry sands, they are also contaminated with the
same compounds that were detected in the fill material
(i.e., PCB-1254, PABs, and metals) but at lower levels.
Generally,onsite pond sediments exhibited higher levels of
contamination than the wetland sediment. Bioassay tests..
performed on the wetland sediment were inconclusive with respect
to the potential impact on wetland biota. Table 2 provides a
comparison of contaminant levels in the onsite ponds, the offsite
pond, and in wetland sediments.
Because the fill material was deposited into the strip mine pool,
most of the fill is now situated below the water table. Thus,
the onsite water table is contaminated with the same contaminants
that are presen~ in the fill material (PCBs, PABs, and metals).
Additionally, low levels of vinyl chloride (2.6 ~g/l, maximum, to
below detection limits) and trichloroethene (3.3 ~g/l, maximum,
0.6 average) have been detected in the water table during
previous investigations. These volatile organics may have
resulted from leaking drums of waste which were disposed on site.
Table 3 provides a summary of contaminants that were detected in
the various flow systems.
The leaking drums were removed and contaminated soils were
excavated during a 1983 removal action. Thus, tQe presence -of
volatiles in the water table (and other flow systems) may only be
reflective of residual soil contamination. . Low levels of
volatile contamination were detected in the solid waste fill
material during the most recent investigation conducted by EPA.
The RI suggests that most of the volatile contaminated soils may
have been removed.Quring the 1983 removal action.
11
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.,
w
w
.
..
...
o
TABLE I
COMPARISON OP CONTAMINANTS OP CONCERN IN SOILS, MINB SPOILS, AND POU~DRY SANDS
OSBORNB LANDPILL SITB
GROVE CITY, PBNNSYLVANIA
Sou. Mine SpoUs Poundry Sands
Contaainant8 ...xt.u. Ar ith8etic Max i.u. Arith.e~ic Maxi.ua Ar ith.etic '
. Average Average Average
Conoentratlon Concent ration Concentration Concentration Concentration Concentr..tion
PCB-US. (1) lID NO ND ND U 0,000 2),))0
Benao'a)pyren. (I) 200 " 1,100 510 59,000 12,915
Dibenao,a,h)anthracp" 110 22 UO 192 27,000 .,Ul
Chroeiu. (2) J1 20 25 17 1,6]0 2S9
Lead (2) 2. 16 20 16 221 8]
Nickel (2) 2' 18 2' 21 1,270 114
--.-
NDI
Denote. not det.cted above 1aborator, lnatru.ent detection levela.
Values are reported in US/kS.
Values are reported 1n 8S/kS.
(I)
(2)'
-------
TABLE 2
COUPAHISON Of CONTAMINANTS Of CONCKHN IN ONSITI AND OWSlTt fiRDINCNTS
OflBORNE LANDFILL 8ITI
OROVI CITY. riNNflVLVANIA
laflaaal Ureaa
All!*.
At Ilk.
**
Ac Ilk.
(Ilk.
Olltll*
Alllk.
**>(
KflMMI ((
(Ilk.
«!(
CAM.
*!
>*
M
IM
m
14*
4t
It.
II.
M.
IM
It.
II.
l.
14
01
«t
II.
J.4»«
Ck.aal.aOI
II
II
U
III
IM
M
II
at
I*
taae-OI
IM
1
1
*
14
II
ais
44
alekall*)
1
ai
1
II
It
ai
11
It
Ml Valuea ara reported la acj/kf.
HI Valuaa ara reported la
MOl ......
-------
The Clarion Formation has also, been impacted by the site
contaminants', as discussed above. The highest level - of
contamination, however, was detected in the flooded deep mine
that forms the base of this formation. The deep .mine acts as a
migration pathway via the connection with the onsite water table.
Vinyl chloride was detected in mine void wells as high as
47 micro grams per liter (~g/l) do~gradient from the high wall
area. Wells installed further offsite in this . flooded mine (east
and southeast of the site) exhibited vinyl chloride ranging from
"none detectable" to 7 ~g/l. Wells installed above the mine void
(in .the Clarion Formation) exhibited lower levels of vinyl
chloride contamination. Additionally, contamination in the
Clarion Formation above the mine void was limited to the area
near the leaking drums that were taken offsite in the 1983
removal action. Groundwater flow is believed to be to the
southeast. Residential wells located east of the site did not
exhibit any.contamination. These wells obtain potable water from
either the Clarion Formation or the Homewood Formation.
Ground water from the Homewood aquifer contained low levels of
TCE (5.8 ~g/l, maximum, 0.4 average) and vinyl chloride (1 ~g/l,
maximum, 0.4 average). This contamination was limited to
monitoring wells located near the boundary of the former disposal
area (within the site security fence). The presence of volatile
contamination in these wells may be due to vertical migration of
contaminants in the fill material via the seepage of the water
table, which is separated from the Homewood Formation by a semi-
impermeable clay layer. The clay layer, however, may have been
breached during previous strip mining activities. Therefore, it
is possible that contaminants may migrate from the disposal area
to the Homewood Formation. No offsite groundwater contamination
was detected in this formation. Groundwater flow is from a mound
located onsite and probably flows predominantly to the southeast.
Residential wells located north and east of the site, which
obtain potable water from the Homewood Formation, are not
contaminated.
contamination in the Connoquenessing Formation was limited to-low
levels of trichloroethene (1.2 ~g/l) found in one monitoring well
located in the area above the highwall. No other monitoring well
in the Connoquenessing Formation exhibited contamination. Based
on the location of the monitoring well, it appears that the
vertical migration of contaminants in the Clarion and Homewood
Formations may.. be the source of contamination in the
Connoquenessing Formation. Groundwater in this aquifer flow is
towards the northwest, probably due to the influence of the
municipal wells.
14
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'I'ABLB J
CQ8PA8I~} 0' GROUNDWA'I'U CON'I'AMIIWI'I'S OP COIIC88N BY POIUIA'I'IOII
OSBORN. LANDFILL 61'1'8
GRO₯8 CI'I'Y, PENNSYLVANIA
...,.. ".... .... w." C...I.. ......... c............I., Du.,oo.
C..,......u ."&II88Uo ..lthoeUc ..lthoe"c ..Uhoe"c A.1t hoeU.o ..It..."o
....- ....... ...1- .....,. ...1- .....,. ....- ."...,.. ....- .....,. ... ,-
C888. c.... COlIC. COHo C.ao. C..C. .......
C888. C.IIC. CO". C.... .' C.... C.ao.
.,..,. c....... - - n I. . 2 . .. .. 8D. 2 .
I'.Iell..."'H" » .' .J .. .' .2 ' . . . II. ..
c'.-I.I-.'o......,.... .. - , 1.1 1 . .. ..81 .. 8D .56 .21
.....-1.1-.'0...'''''''' '.J .' .. .. .1 .81 .. .81 .. .. ... .2.
ICe-nit .. . .. - - - .. - .. - .. ..
!M.a.....,.... JJ . " - - .. .. 8D .. .. .. ..
.......I.I.)-c.'."." 18 1 .. - - II. - .. .. .. II. liD
All r..u1t...,e r.portod in '9/1.
ND. Denote. not d.tected above 1.borator, in.tr...nt detection 10vo1..
. ~.
-------
TABLE 4
COMPARISON OF CONTAMINANTS OF CONCERN IN STUDY AREA SURFACE WATER BODIES
OSBORNE LANDFILL SITE
CROVE CITY, PENNSYLVANIA
Pond 110. 1 "ateI' Pond 110. 2 "ateI' Olhite Pond "~ter
Conta.inant Arith..tic AI' hh.et ic AI' i th..t ic
....i8u. Average 1I..i.u. Average 11.81 au.
Concentration Co.ncentr.tion Concentration Average
Concentration Concentration Concentration
!
Vin,l chloride a.ll a.n NO 110 110 NO
'trichloroethene 2..a 2.10 NO II') 110 110
Ci8-1,2-0ichloroethene 2..a 2.10 110 I!D 110 110
trans-l,2-0ichloroethene a.26 O.U 110 110 110 110
1,1-Oichloroethene 0.33 o.n 110 110 110 110
1,1-0ichloroethane 10.10 6.15 0.26 0.1) 110 110
1, 1, 1-7richloroethane ..10 a.tO 110 110 110 110
All results are reported in ~g/l.
NDr Denotes not detected above laboratory instr,ument detection levels.
-------
Contamination in the Burgoon Formation was also detected in only
one monitoring well. Ground water from this well, contained
2.2 p.g/l of vinyl chloride and it is located in the same well
cluster that showed high levels of vinyl chloride in the flooded
mine. Cooper Industries resampled this well in october 1989 and
did not detect vinyl chloride at that time. No other Burgoon
Formation monitoring well exhibited this contaminant. Groundwater
in this aquifer flow is towards the northwest, probably due to
the ~nfluenceof the municipal wells.
The Grove City Water Authority's intake supply wells, which are
located about 1 mile northwest of the site, obtain water from the
Connoquenessing Formation and the Burgoon Formation. Samples
were not collected. from these supply wells, however, the Grove
City Water Authority has its analytic testing program and has not
detected site contaminants. A Groundwater Verification Study
(GVS) will be conducted, as a separate focused Remedial
Investigation, that will determine if the contamination detected
in these formations is limited to the immediate site area and.
whether it could impact the Water Authority's supply wells.
A subsequent ROD will then be issued which addresses the
contamination in the deeper aquifers.
Residents to the north and west of the site and the one resident
to the south of the site use the public water supply, but
residents to the east and northeast use the Homewood and Clarion
aquifers. The GVS will also clarify any potential risks to these
residential wells.
Surface water contamination is limited to the onsite ponds. Most
of the contaminants were detected in the largest of the ponds
(Pond 1), which is located at the northernmost point of the site.
Contaminants include trichloroethene (2.8 p.g/l, maximum, 2.1
average), vinyl chloride (1 p.g/l, maximum and average), and 1,1-
dichloro-ethane (11 p.g/l, maximum, 6 ug/l average). The source
of .,=ontamination in the onsite ponds could be from the onsite
water table, which is hydraulically connected with the ponds.
Tab!"; 4 provides a summary of the contaminant levels in. onsite
and offsite ponds.
SUMMARY OF RISKS
During the RI/FS, an evaluation of public health and
environmental risks was performed. The purpose of this
evaluation, which" is referred to as a risk assessment, was to
estimate the potential impacts to the public health and
environment that the site presents without performing any further
remedial action. In conducting this assessment, the focus was on
the health and environmental effects that could result from
exposure to site contaminants in the solid waste fill material,
surface water, sediments, and groundwater.
Risk is a function of both contaminant toxicity and exposure.
Therefore, when assessing risks, three aspects of chemical
17
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contamination and environmental fate and transport must be
considered: (1) contaminants of, some defined toxicity .must. be
detected in" environmental media,. released by some natural .or
manmade processes; (2) pathways by which actual or potential
exposure occur must be present and: (3) human or. environmental
receptors must be present to complete the exposure route.
The risk assessment estimates the p~tentialfor human health and
environmental risks at the site by combining. information on the
toxicity of the compounds detected with the site specific
exposure. scenarios. The basis for the risk assessment is the
validated chemical-analYtical data base for environmental samples
collected during the most recent remedial investigation.
HUMAN HEALTH RISXS
Contaminants such as trichloroethene, vinyl chloride, PCB-1254,
and PARs, which were all found at the site, are either suspected
or kno:wn carcinogenic compounds. Other contaminants such as'
chromium, mercury, and lead, which were primarily detected in the
fill material, are noncarcinogenic but could result in long-term
adverse health effects if excessive exposure occurs. Risks to
the public health from carcinogens are measured relative to an
acceptability range. This acceptability range is 1 x 10-4 to
1 x 10.6 (See (NCP) at 40 C. F. R. 300.430). A 10-4 risk equates to
1 additional case of cancer per 10,000 people exposed to site-
related, cancer-causing contaminants. A 10.6 risk equates to
1 additional case of cancer per 1,000,000 people exposed to the
site contaminants. A "hazard index" is used to assess the impact
of noncarcinogenic compounds such as lead and chromium. .If the
hazard index is less than 1.0, no long-term adverse heal th
effects are anticipated via exposure to noncarcinogenic
compounds. If the hazard index is greater than 1.0, then
excessive exposure to noncarcinogenic site contaminants may cause.
adverse chronic health effects.
The exposure routes applicable to the Osborne- Landfill Site
include: direct contact with the contaminated fill material;
residential use of contaminated groundwater including (ingestion
and showering); direct contact with onsite surface waters; and
direct contact with pond or wetland sediments. Remedial
Alternatives that involve excavation pose the potential for
inhalation of particulates. Table 5 summarizes these site-related
exposure pathways and presents the estimated health risks for
each of these pathways. A discussion of the more relevant risks
follows.
The carcinogenic risk of direct contact with the fill material
has been estimated to be 2.8 x 10-5. This average-case risk
18
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TABLE 5
POTENTIAL SITE-RBLATED EXPOSURE PATHWAYS AND ASSOCIATED ESTIMATED HEALTH RISKS
OSBORNE LANDPILL SITE
GROVE CITY, PENNSYLVANIA
A".~a,. Ca..U) Wont-Ca..U)
..dla ..po.ur. Ic.narlo
"..rd Inc~..ntal .a.a~d Inc~..ntal
Ind.. Canc.r 818. Ind.. Canc.~ ah.
Solid "'at. Pi 11 Dlr.ct contact elnclud.. the total .11 2.1 . 10-5 ..12 2.6 . 10-41
Mat.rlal .ff.ct 01 d.r..l contact and
accid.ntal in,.'tion)
Inhalation of fu,lti.,. du.t. <.01 1.01 . 10-1 <.01 1.1 . 10-6
Groundwat.r-Onatte In,.atton bJ an adult 0.22 ..0 . 10-] o.n 2.18 . 10-2
..at.r "abl.U) Ing..tion bJ a child o.n 1.2] . 10-] 1.5 5.U . 10-2
Inhalation of .,olatil.. whU. <0.01 1.12 . 10-] 0.01 1.0 . 10-2
.how.rln,
G~oundwat.~-Clarlon I....tlon bJ an adult o.lt 1.51 . 10-. 0.10 . .06 . 10-.;
For_tlon e]) In,..tio. bJ a child 0.51 1.11 . 10-. .61 . 1.31 . 10-41
Inhalation 01 volatil.. whU. 0.02 1.05 . 10'4 0.05 . 3.1' . 10.4
.how.rin,
Groundwater-80.-00d In,..tion bJ a. adult 0.15. 2.11 . 10-5 0..5 1..0 . lo~5
For_tlone]) Ing.gtlon bJ a child 0.10 5.15 . 10-5 0.'1 1.52 . 10-4
Inhalation 01 volatll.. whU. <0.01 3.00 . 10" <0.01 f. '0 . 10"
.how.ring
On.h. Pond. 08,_1 contact bJ a child 0.012 2.16 . 10-' 0.015 ].55 . 10-9
On.h. Pond Sedl..nt. O8r_l contact bJ a child 0.16 ..0] . 10-5 0.1' ..15 iI 10-5
118tland S.d'.ent. O8r_l contact br a child 0.0. 1.26 . 10-1 o. It 2.15 Ii 10-6 I
(1)
12)
U)
Average-case risk calculations are based on the arithmetic average concentration level
Worst-case risk calculations are based on the maximum concentration level
Exposure scenario represents a future potential scenario since there are no groundwater
users in the affected a~ea.
-------
estimate equates to almost 3 additional cases of cancer per
100,000 children directly exposed to the fill material. The
hazard index was estimated to be less. than 1.0 (0.8) but the
worst case shows the potential for harm from systemic effects.
The carcinoqenic risk of using contaminated groundwater varied
depending on the . source geologic formation. Use of the onsi te
water table may result in excess~ve carcinoqenic risks (one
additional cancer case per 100 people using this flow system as a
potable water supply). However,. since no one uses the onsit.e
water table as a source of potable water, this risk reflects a
future potential exposure scenario. Use of the Clarion Formation
very close to the site area also results in an excessive
carcinoqenic risk upon exposure (ingestion by children) This risk
has. been calculated to be 0.84 X 10.3, which equates to
approximately 1 additional case of cancer per 1,000 people
exposed. As with the onsite water table, there are no known users
of this f~ow system in the area where this formation is
contaminated. The average case risk from ingestion by children
gives a risk of 3.1 x 10.4 or about three additional c~ses of"'
cancer per 10,000 people exposed. The worst case of groundwater
(ingestion by children) from the Homewood Formation may result in
an estimated carcinogenic risk of 1.5 x 10.4 (approximately two
additional cases of cancer per 10,000 individuals exposed).
Because there are no known users of either the Clarion or
Homewood flow systems adjacent to the site and since nearby
residential wells in these formations were not contaminated,
these risk estimates reflect a future potential exposure
scenario.
Future residential development of land near the site (assuming
wells are installed for each household) could result in excessive
health impacts with long-term exposure to either the water table,
Clarion Formation, or Homewood Formation.
Although it is unlikely that children would use the onsite ponds
for recreational purposes, a risk assessment was performed to
evaluate direct contact with the surface water and sediments.
Because of low concentrations of contaminants in the ponds and
because the exposure would be limited, the estimated carcinogenic
risk for surface water equates to about three additional cases of
cancer per 100,000,000 people exposed to the onsite ponds.
Exposure to contaminated onsite pond sediments equates to about
four additional cases of cancer per 100,000 people exposed. The
hazard index associated with exposure to surface water was less
than 0.02. Exposure to onsi te pond sediments resul ted in a
slightly higher hazard index, but it was still less than the
target level of 1.0.
In summary, .moderate-to-low carcinogenic health risks exist for
exposure to the contaminated- fill material and onsite pond
sediments. Additionally, the worst case for systemic effects
. indicates the potential for harm from noncarinogenic contaminants
in the fill. Future use of the onsite water table or the Clarion
Formation near the site could result in excessive carcinogenic
20
. .
. .
-------
health risks. Health risks associated with dermal exposure to
onsite surface water are very low,.
ENVIRONMENTAL RISKS
The Osborne Landfill site is overgrown with grasses, shrubs, and
trees. Woodlands are present directly north and due west of the
site. These forested areas provid~. habitat for whitetail deer,
grouse, and other wildlife. According to the u.s. Fish and
wildl-ife Service, endangered species do not. inhabit the study
area. ..
Properties surrounding the site are agricultural in nature but
several wetland communities exist in the region including the
wetland which borders the site to the southwest. A large offsite
pond exists beyond the forested area to the west of the landfill.
This offsite natural pond, and the wetland adjacent to the study
area, provide sui table habitat for migratory waterfowl. The
offsite pond is of sufficient size and consistency to support
fish populations~ however, only sunfish, turtles, and frogs have""
been observed. The depth of the offsite pond is only about 2 to
3 feet.
Terrestrial wildlife could be exposed via direct contact (dermal
exposure and ingestion) or indirectly via the food chain. Biota
could be exposed to both organic and inorganic constituents
detected in surface soils (fill material), surface water, or
sediments. Since quantitative environmental surveys were not
conducted durinq the RI, limited conclusions regarding changes in
the area ecosystem (species abundance or-diversity) can be made.
Terrestrial biota may bioaccumulate PCBs, inorganics (e.g.,
lead), and to a lesser extent, PARs. PCBs are of concern because
of their presence in soils and sediments at the site. Any
predator species that are exposed may be at risk because of their
position in the food chain.
Aquatic biosystems potentially affected by site-associated
contaminants include the onsite leachate ponds aDd the offsite
natural pond. Aquatic biota are likely to be exposed via direct
contact, ingestion of contaminants in sediments or surface
waters, or through the food chain. consti tuents that
bioaccumulate in the food chain have the potential to affect
aquatic receptors. Bioaccumulative substances such as PCBs and
inorganic consti tuents (e. g. , lead, copper) were detected in
sediment samples. Biota at risk may include bottom-dwelling
macro invertebrates or bottom-feeding species. Terrestrial biota
that frequent surface-water bodies may also be exposed.
To assess the environmental impacts associated with the Osborne
Landfill Site, sediment samples were collected from Wetland
Area 1 (theoffsite pond), the influent stream (background), and
Wetland Area 2, which borders the site to the southwest. The
sediment samples were leached to produce an extract
representative of potential wetland surface waters. These
21
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extracts were then used in Ceriodaphnia (a tiny aquatic animal)
and Fathead Minnow toxici ty test~. Surface water samples were
also collected from these areas and subjected to bioassay testing
(fathead minnow and ceriodaphnia). Based on the results, no
conclusions can be made with any certainty as to whether site
contaminants detected in Wetland Area 2 are impacting the biota.
In summary, aquatic and terrestrial biota. could potentially be
affected by contaminants in the onsite ponds, the fill material,
or the wetland that is located southeast of the site. The level
of the contaminant of concern (PCBs) in the southeast wetlands ..
is; however, very low (less than 1 ppb). These areas have
exhibited orqanic and inorganic contamination. Biota that
inhabit the offsite pond are unlikely to be impacted, since no
contamination was detected in the surface water or sediment in
the pond.
,
DESCRIPTION OF ALTERNATIVES
Actual or threatened releases of hazardous substances from the".
site, if not addressed by implementation of the response action
selected in this ROD, may present an imminent and substantial
endanqerment to public health and the environment.
Remedial al ternati ves were developed durinq the FS for each o.f
the five operable units described previously. with the exception
of the "no action" alternative, which is always considered as a
baseline for comparison against other alternatives, the
development of alternatives was based on the results of the risk
assessment discussed previously. The~ alternatives that were
proposed for each operable unit focused on (1) preventing
exposure to site contaminants, (2) reducinq the toxicity of the
contaminants to acceptable levels, and/or (3) preventinq the
miqration of contaminants. EPA has deferred makinq a decision on
the Wetlands Sediments (OU2) and the Homewood aquifer (OU5).
Additional chronic bioassay tests will be performed to determine
if ~here is any bioaccumulation of PCBs occurring. This testing
will be part of a focused RI/FS that will also include a Ground
Water Verification study of the deeper aquifers at the site. If
there is not an impact on the wetlands biota it is not prudent to
destroy this mature wetlands area to remediate the very low level
of PCB contamination. The contamination in the Homewood,
Connoquenessinq and Burqoon aquifers is relatively low and has
been detected sporadically. EPA believes additional testing is
required to bett~r characterize these flow systems prior to
selection of a Remedial Alternative for these operable units.
After completion of the focused RI/FS, a subsequent ROD will be
issued for operable units OU2-Wetlands Sediments, OU5-Homewood
aquifer, the mine pool, the Connoquenessing and Burqoon aquifers.
Summarized below. are the al ternati ves that were considered for
operable units OU1 Solid Waste Fill Material, OU3 Onsite Water
Table, and OU4 Clarion Aquifer.
customarily,
Remedial
each
Alternative
selects
for
SPA
one
22
. .
. .
-------
operable UDi~, from ~he poten~ial remedies lis~ed in ~he P8. In
~hi. ROD, BPA has selec~ed a primary Remedial Al~era~iv. and a
con~ingeney -A1~erna~ive for ~he 'operable uni~s rela~ed "~o ~he
fill &Dd i~. leacha~. (001 and 003). A slurry vall con~aiDJDen~ ~
a RCRA sUb~i~le C landfill would sa~isfy ~he ~hreshold cri~eria
for OVerall Pro~ec~ion of Human Heal~h and ~h". Bnviromaent
~ecause of tbe lov to moderate risks posed ~y ~he fill. BPA's
proDosed Plan listed ~he RCRA landfill as the Dreferred
al terna~i ve: however. durina the cOlIIJDen~ Deriod BPA received
co-ents vhich stronalv 8uDDor~ed the slurrv" vall remedY. '1'h.
public 8uppor~ed the 8lurry wall remedy ~ecaus. the community was
concerned about the economic impact of the bigb capital costs on
Cooper Indu8tries, a PRP for this site, if Cooper vas required to
implement &Dd finance the landfill alternative. Cooper i8 a major
employer in the area. The public vas a180 concerned ~u~ the
potential for ezposure of residents to PCBs during ezcavation if
tbe landfill option vas chosen.
In response" to these cOlIIJDents, EPA organized a panel of .zperts
to appraise this technology at the os~orne Site. The panel's..
reviev generally supported the viability of a slurry vall at the
Os~rne Site, ~ut identified the need for measures to isolate the
fill area from the deep mine pool and to prevent subsidence near
the high vall. In response to these Deeds, a more detailed
proposal for implementation of the slurry wall remedy vas
submi tted to the panel of slurry vall ezperts. This panel
included m8Jl!)ers from BPA' s Office of Research and Development
and the o.s. Army Corps of Engineers. The m~ers of this panel
agreed that if appropriate testing was performed prior to the
design phase and if tbe detailed proposal submi tted ~y Cooper
Industries vas implemented with proper quality control, the
slurry vall remedy should ~e effective. This technical
information and their review cOlIIJDents are included in the
administrative record.
EPA has considered the modifying criteria of Community'
Acceptance, and tbe nev technical information o~tained during the
slurry vall review to select the slurry wall alternative as the
primary remedy for 001. This is acceptable to the State of
PeDDsylvania if tbe landfill is included in the ROD as a
" contingency remedy.
A contingency remedy format is usually associated vith the use of
iDDovative technology that needs actual field application to
assess it. success. Al though slurry vall installation is not
"iDDovative technology", its successful application in the
os~rne field setting requires the iDDovative application of mine
bulkheading techniques related to slurry vall installation.
These techniques CaDDot be jUdged in pilot studies and depend OD
the actual field conditioDs encountered. Therefore, the use of
the contingency format related to the use of an iDDovative
application of established technology is appropriate. BPA has
included performance standards that must be met to consider the
slurry vall remedy appropriate and successful. 80me ot the
standards must be met prior to the design of the slurry vall and
23
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other specific standards vill be developed during the desiqn of
the R..edial Action. The specifi9 standards vill be des~qned. to --
mate .ure tbat the folloving goals are clearly met: .
. 1) nat tbe slurry vall installation is implementable at
reasonable costs in this field setting.
2) That tbe .ater level inside. the slurry .all contaiDlDent
CaD be 10.ere4 by reasonable pumping rates to a level that
create. a negative average pressure in the containment of at
lea.t one foot of bead (.4 psi) .itb respect to the a4jacent
Clarion and Home.004 aquifers. Tbis .ill be monitored by
.ell pair. located in tbe fill and adjacent aquifers.
3) That future subsidence .ill not impact the integrity of
tbe slurry vall.
If tbe p.~formaDce standards CaDDot be met at tbe pre-desiqn,
design or implementation stages of the remedy, the landfill
alternative .ill be implemented in place of tbe slurry .ali'
alternative. If after implementation of the slurry vall
alternative, tbe performance standards CaDDot be met, a maximum
of three montbs (90 days) .ill be allo.ed to demonstrate that a
minor modification of the alternative can correct the problem and
a maximum of siz months vill be allo.ed to implement and asse..
the success of the modification. The performance standards for
the slurry .all are given in greater detail UDder Alternative 812
belove
SOLID WASTE/FILL MATERIAL (OPERABLE UNIT 1)
Initially, eleven alternatives were identified during the
feasibility study. Two of the eleven alternatives that were not
cost effective were eliminated during the screening process
(Alternatives S8 and S10). The details relating to S8 and S10
are given in the FS. Neither of these alternatives are presented
below. Cooper Industries proposed an alternative ~or remediatinq
the solid waste (OU1), and the onsite water table (OU3) before
EPA issued the Proposed Plan and draft FS which was presented in
the Proposed Plan. This alternative has been included and is
referred to as Alternative S12. A description of the
alternatives for Operable Unit 1 are provided below.
Alternative Sl:
No Action
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$0
$0
$41,000
None
The no action alternative provides a baseline for comparing other
alternatives. Because no remedial activities would be
implemented with the no action alternative, long-term human
health and environmental risks for the site essentially would be
24
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the same as those identified in the baseline risk assessment (see
Summary of Risks). Under the no ,action alternative, -leachinq.of
contaminants. from the solid waste fill. . material to the water
table would continue, since much of the fill material is below
the water table. OVerland transport of contaminants to the
wetland area would also continue.
This al ternati ve does not reduce the.. current level of
contamination in the fill area. The averaq~ concentration of
PCBs "in the fill is 23 mq/kq. EPA's PCB Spill Cleanup Policy (40
CFR Part. 761.120) -for an unrestricted access site (maximum PCB
concentration of 10 mq/kq) is not met by this alternative. EPA's
PCB spill Cleanup Policy for a reduced access area (maximum PCB
concentration of 25 mq/kq) is met by this alternative.
Since the fill is not a hazardous waste by definition, RCRA
closure requlations are not an ARAR. This alternative would not
meet PACER municipal waste requlations.
This alternative does not meet one of the qoals of CERCLA/SARA:
. to utilize treatment that permanently reduces the volume,
toxicity, or mobility of the contaminants. This remedy is not
protective of human health and the environment. As mandated by
section 121 (c) of CERCLA for sites where the waste is left on
site above health-based levels, a 5-year site review (for
30 years) would be performed to ensure that the alternative is
protective of human health and the environment.
Alternative S2:
Soil Cover
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$849,000
$30,000
$1,367,000
2 months
This alternative would consist of reqradinq the site area to
create a stable site confiquration that would result in the
elimination of the onsite ponds, and divertinq most of .the
offsite run-on, which presently enters the. site via the influent
stream and discharqes to Pond 1. This run-on is from the land
which borders the north.and northeast portions of the site. It
is proposed that the influent stream would be diverted to
discharqe to the offsite pond, which is located to the west of
the site. Other run-on that enters the site area is from the
mine spoil piles.~nd the hiqhwall area. However, most of this
run-on would be eliminated durinq site reqradinq since the spoil
piles and unconsolidated soils above the hiqhwall would be used
to reqrade the site. .
Coverinq the. site with six inches of soil would require that the
three onsite ponds be eliminated. Initially, the volume of water
in the ponds would be reduced by divertinq the influent stream to
. .the offsite pond. Followinq this action, the ponds would be
completely covered with soil from the spoil piles. Water
remaininq in the ponds would be absorbed by the backfill
25
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material. Materials from the spoil piles could be used as a
source of the borrow material to backfill the onsite - ponds.
Regrading the site would be necessary -to prevent ponding of
surface runoff and diversion of- the influent stream. Following
regrading, the site would be covered with sufficient soil to
enable the establishment of a permanent vegetative cover that
would be more resistant to water and wind erosion than at
present. . A chain-link fence woul~ then -be reconstructed to
reduce onsite trespassing activities.
To moni tor the effectiveness of this al ternati ve, groundwater
monitoring would be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
samples biannually until the first five year review and on an
annual basis afterwards. Samples would be analyzed for Target
Compound List (TCL) organics and Target AnalYte List (TAL)
inorganics. Three residential wells at highest risk would also
be sampled -at this time for VOCs.
Major items of work include:
. .
. Rough grading, 35,500
. Soil cover, 15,600 cy
. Topsoils, 14,500 cy
. Seeding, 18 acres
cubic yards (cy)
Infiltration would be slightly reduced by the soil cover;
however, because the fill material is below the water table,
contaminants would continue to leach into the onsite water table.
Volatile organics would most likely continue to migrate
vertically (to the Homewood Formation) or horizontally to the
Clarion Formation. However, PCBs and PARs are not expected to
migrate due to their high soil adsorption coefficients.
Regrading would prevent offsite migration (i.e., overland
transport) of contaminants to the wetland.
This alternative is easy to implement but is not a permanent
solution to the problems at the si te because the contaminated
materials would remain. Covering and revegetating would reduce
the transport of the soil contaminants, but the toxicity,
mobility and volume would be unchanged.
The goal of regrading and covering the site wi th soil is to
significantly reduce or eliminate the risks from dermal contact,
accidental soil ingestion, and inhalation because the contaminant
source would be covered. The cover proposed under this
al ternati ve would not be constructed in accordance wi th RCRA
closure requirements of 25 fA Code Chapter 264, for closure by
capping. The fill material is not a RCRA hazardous waste and
since the purpose of the cover is to isolate the waste from
dermal contact, capping regulations are not appropriate for this
alternative. Since the fill is not a hazardous waste by
definition, RCRA closure regulations are not applicable but some
elements of RCRA closure will be relevant and appropriate.
26
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This al ternati ve does not re~uce the current level of
contamination in the fill area. The average concentration of
PCBs in the fill is 23 mg/kg. EPA's PCB Spill Cleanup Policy (40
CFR Part 761.120) for an unrestricted access site (maximum PCB
concentration of 10 mg/kg) is not met. by this alternative. EPA's
PCB Spill Cleanup Policy for a reduced a~cess area (maximum PCB
concentration of 25 mg/kg) is met by. this alternative.
EPA does not consider this alternative to be protective of human
health and the environment. This alternative does not meet one of.
the goals of CERCLA/SARA: to utilize treatment that permanently
reduces the volume, toxicity, or mobility of the contaminants.
As mandated by section 121(c) of CERCLA for sites where the waste
is left on site above health-based levels, a 5-year site review
(for 30 years) would be performed to ensure that the alternative
is protective of human health and the environment.
Post-closure use of the property must be restricted, as
necessary, to pr~vent damage to the cover and to prevent contact --
with the waste. A security fence would be maintained around the
site to reduce access.
Alternative S3:
Clav Cap
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$1,926,000
$32,000
$2,468,000
12 months
This alternative would consist of construction of a low
permeability clay cap on the site that would significantly reduce
surface water infiltration. This alternative would include
similar site regrading, stream diversion and vegetation work as
described previously in Alternative S2 (Soil Cover).
. .
A drum staging area would be constructed in the event that newly-
discovered drums are uncovered during the excavation activities.
Any drums or concentrated wastes found during excavation must be
tested to determine if the contain hazardous wastes that require
treatment under the land disposal regulations would be sent
offsite to an appropriate treatment or disposal facility. If the
wastes are hazardous, the regulations contained in 25 PA Code
Chapter 264, Subp~rt I, relating to the management of containers
apply.
The only difference between the cap for this al ternati ve and
Alternative S2 is that a 2-foot thick clay cap would be included
to reduce the amount of surface water infiltrating through the
site. The clay would be obtained from an offsite borrow source.
To monitor the effectiveness of this alternative,. groundwater
monitoring would be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
27
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samples biannually until the first five year review and on an
annual basis afterwards. Sampl~s would be analyzed for Target.
Compound List (TCL) organics and Target Analyte List- (TAL)
inorganics. Three residential wells at highest risk would also
be-sampled at this time for VOCs.
Major items of work include the 'following:
. Rough grading, 35,500
. -Clay, 15,000 cy
. Soil cover, 15,600 cy
. Topsoil, 14,500 cy
. Seeding, 18 acres
cy
Capping would remove the risks from dermal contact, accidental
ingestion, and inhalation of particulates because the contaminant
source would be covered. Capping would also reduce infiltration
through the disposal area and reduce the leaching of soil
contaminants into groundwater. Capping would prevent the
migration of contaminants via runoff and overland transport to.
the wetland area. However, shallow groundwater flows
horizontally through the site from the offsite ponds to the mine
pool. Therefore, capping alone is not - completely effective in
reducing leaching of the wastes, since a majority of the waste is
already in contact with the water table.
The technologies proposed for this alternative are demonstrated
and commercially available. The technologies are expected to be
technically feasible and readily implementable. Periodic
maintenance of the cap would be required.
The goal of regrading and covering the site with a clay cap is to
significantly reduce or eliminate the risks from dermal contact,
accidental soil ingestion, and inhalation because the contaminant
source would be covered. The cover proposed under this
alternative would not be constructed in accordance with RCRA .
closure requirements of 25 PA Code Chapter 264, to the extent
that they are relevant and appropriate to capping. The fill
material is not a RCRA hazardous waste anq since the purpose-of
the cover is to isolate the waste from dermal contact, capping
regulations are not appropriate for this alternative. Since the
fill is not a hazardous waste by definition, RCRA closure
regulations are not applicable ARARs, but some elements of RCRA
closure will be implemented to the extent that they are relevant
and appropriate...
This alternative does not reduce the current level of
contamination in the fill area. The average concentration of
PCBs in the fill is 23 mq/kq. EPA's PCB Spill Cleanup Policy (40
CFR Part 761.120) for an unrestricted access site (maximum PCB
concentration of 10 mq/kq) is not met by this alternative. EPA's
PCB Spill Cleanup Policy for a reduced access area (maximum PCB
concentration of 25 mq/kq) is met by this alternative.
EPA does not
consider
this
alternative
protective
of public
28
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health and the environment. Because wastes are left on site
without treatment, this alternat~ve does not meet the goals of
CERCLA/SARA -to utilize treatment that permanently reduces the
volume, toxicity, or mobility of the site contaminants. As
mandated by Section 121(c) of CERCLA for sites whe~e the waste is
left on site above health-based action levels, a 5-year review of
the site would be required to assess the effectiveness of this
alternative.
Post-closure use of the property must be restricted, as
necessary, to prevent damage to the cover and contact with the
fill. A security fence would be maintained around the site to
reduce access. .
Alternative S4:
Multimedia CaD
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$1,741,000
$32,000
$2,282,000
6 months
A multimedia cap consisting of soil,sand, and a synthetic
membrane, such as high density polyethylene (HDPE) or polyvinyl
chloride (PVC) , would be constructed over the former disposa-l
area. As with the soil cover and clay cap alternatives discussed
previously, si te regrading would be necessary, along with the
construction ot a drum staging area. Any drums or concentrated
wastes found during excavation must be tested to determine if the
contain hazardous wastes that require treatment under the land
disposal regulations would be sent offsite to an appropriate
treatment or disposal facility. If the wastes are hazardous, the
regulations contained in 25 PA Code Chapter 264 relating to the
management of containers apply. In summary, the only difference
is that the cap design would allow for less infiltration than
soil or clay. The cap design meets RCRA requirements 25 PA Code
Chapter 264.110-119 and 310 for caps used in closure of a
landfill.
The cap shall be designed and constructed according to the RCRA
closure requirements of 25 PA Code Chapter 264.110 - 119, 228,
258, and 310. The cap design also meets RCRA requirements of
25 PA Code Chapter 264. Placement of a cap over waste requires a
cover designed and constructed to accomplish the following:
. Provide long-term
capped area.
. Function with minimum maintenance.
minimization
of
liquids
through
the
. Promote drainage and minimize erosion and abrasion of the
cover.
. Prevent run-on and runoff from damaging the cap.
29
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. Accommodate settling and subsidence so that
integrity is maintained. ,
. Have a permeability less than or equal to the permeability
of any bottom liner system or natural subsoils present.
the cover's
To moni tor the effectiveness of this al ternati ve, groundwater
monitorinq" would be required for the,~nsite water table, Clarion,
and Homewood Formations. Ten monitorinq wells would collect
samples biannually until the first five year review and on an,
annual basis afterwards. Samples would be analyzed for Tarqet
Compound List (TCL) orqanics and Tarqet AnalYte List (TAL)
inorqanics. Three residential wells at highest risk would also
be sampled at this time for VOCs.
Major items of work include the following:
. Rough"qrading, 35,500 cy
. Soil covers, 23,080 cy
. Synthetic membrane, 200,000 sf
. Topsoil, 14,500 cy
. Seeding, 18 acres
A multimedia cap would result in no direct contact to the si t~
wastes. Therefore, risks to human health are minimized. Capping'
would also eliminate surface runoff of site contaminants to the
wetland area. A multimedia cap would significantly reduce the
amount of infiltration throuqh the fill material and leaching of
contaminants would be reduced. However, as with the other two
capping alternatives (52 and 53), leaching of the fill may
continue, since a majority of the waste is already in contact
with the water table. Consequently, qroundwater monitoring is
required.
Technoloqies proposed for this alternative are demonstrated and
commercially available. The technoloqies are expected to be
technically feasible and are proven. This alternative should be
implementable at the Osborne Landfill Site. It is anticipated
that this al ternati ve could be completed' in one construction
season.
As wi th the previous al ternati ves, offsi te run-on enterinq the
site would be diverted to the offsite pond. Additionally,
consideration of mine reclamation requirements would be required.
The mul timedia cap proposed under this al ternati ve would be
constructed in accordance with RCRA closure requirements or PADER
requirements of 25 PA Code Chapter 264, for closure by capping.
The fill material is not a RCRA hazardous waste and since the
purpose of the cover is to isolate the waste from dermal contact,
RCRA cappinq requlations are not applicable ARARs for this
alternative. Since the fill is not a hazardous waste by
, . definition, RCRA closure requlations are also not applicable
ARARs, but some elements of RCRA closure requlations will be
ARARs to the extent that they are relevant and appropriate.
30
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!-
Althouqh not an ARAR, RCRA landfill closure cappinq requlations
would be substantially met by this, alternative.
This alternative does not .reduce the current. level of
contamination in the fill area. The averaqe concentration of
PCBs in the fill is 23 mq/l. EPA's PCB Spill Cleanup Policy (40
CFR Part. 761.120) for an unrestricted access site (maximum PCB
concentration of 10 mq/kq) is not mat by this alternative. EPA's
PCB Spill Cleanup Policy for a reduced access. area (maximum PCB
concentr~~ion of 2S mq/kq) is met by this alternative.
Because wastes are left on site without treatment, this
alternative does not meet one of the qoals of CERCLA/SARA to
utilize treatment that permanently reduces the volume, toxicity,
or mobility of the contaminants. As mandated by Section 121(c)
of CERCLA for sites where waste is left on site, a S-year site
review would be performed to ensure that cappinq is protective of
human health and the environment.
Post-closure use of the property must be restricted, as
necessary, to prevent damaqe to the cover and contact with the
fill. The security fence would be maintained around the site to
reduce access. .
Alternative S5:
Excavation and Onsite DisDosal
Estimated Construction Cost
Annual O&M Costs
Present Worth.
Estimated Time to Complete
$10,418,000
$36,000
$10,785,000
24 months
The construction of an onsite landfill would initially require
the excavation of approximately 233,000 cubic yards of
contaminated fill material and surficial debris (plastic, wood
pallets, drum fraqments, metal components from foundry
operations, etc.). As mentioned previously, more than one half
of the fill is below the water table. Consequently, dewaterinq
of the fill would be required prior to placinq it in an onsite
landfill. Excavation of the fill material would also require
the collection and treatment of the water table and onsite ponds
as the site is excavated. Wastes would be excavated until the
underclay, mine spoil or bedrock is encountered. The fill
material is very distinctive in color and composition from the
spoil material. Leachate qenerated durinq the dewaterinq process
would be treated. .wi th the water table since they are basically
the same. For purposes of simplicity, remediation of the water
table and leachate are discussed separately (see
Alternative G03). Therefore, costs for qroundwater remediation
are not included u~der this alternative, but rather with
Alternative G03.
Excavated wastes would be placed in an onsite RCRA subtitle C
31
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landfill that meets Minimum Technology Requirements as defined in
Section 3004(0) of RCRA, 42 U.S.C. S6924(0) and regulations
thereunder at 40 CFR Part 264. This is relevant and appropriate
for the PCB concentrations in the landfill and is protective of
human health and the environment. In order to keep. the wastes
above the water table, borrow (soil) from the spoil piles and
highwall area would be used to backfill the bottom of the
excavated area. The onsite landfill. would then be constructed on
the original location and the site regraded_. t.o promote drainage
off ~ite. . .
The design of the onsite landfill would include a double liner, a
low permeability cap, and a leachate collection system. The
preliminary design is detailed in the FS. Leachate collected in
-the tank would be trucked off site for treatment at an
appropriate treatment or disposal facility. A study to define the
potential for subsidence would be conducted before the design of
the landfill and would be reviewed by the PADER and the state
Bureau of Mines. NPDES tank standards are relevant and
appropriate for the leachate tank.
Design and construction of the onsite landfill shall comply with
the minimum technology requirements of 25PA Code 264.301 through
264.304 that are summarized as follows:
.
. Install two or more liners, a top liner that prevents
infiltration and a bottom liner that prevents waste
migration to the underlying flow system. The bottom liner
must be 30 mil or greater in thickness to comply with PADER
solid waste regulations.
. Install leachate collection systems above and between the
liners.
. Construct run-on and runoff control systems capable of
handling the peak discharge of a 25-year storm.
. Control wind dispersion of particulates.
. Operation and maintenance.
The landfill design should also comply with RCRA requirements in
25 PA Code chapter 264. The temporary waste stockpile (s) must
have a liner and leachate collection system as specified in 25 PA
Code 264.251. These requirements are relevant and appropriate.
A drum staging area would be constructed in the event that newly-
discovered drums are uncovered during the excavation activities.
Following the con~truction of the onsite landfill, any uncovered
drums along with the two drums which are presently on site can be
securely placed in the onsite landfill. Any drums or
concentrated wastes found durinq excavation must be tested to
determine if the contain hazardous wastes that require treatment
under the land disposal regulations 40 C.F.R Part 268. If any
required such treatment they would be sent offsite to an
32
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appropriate treatment or disposal facility.
Samples from the area that showed the highest level of PCBs (4io
ppm) will be collected and tested for PCBs. The exact plan for
sampling this area will be developed during the Remedial Design.
Fill material that contains PCBs above 500 ppm will be sent off
site for. appropriate treatment. Additionally, since there is
some uncertainty as to what may be ,~ncovered during excavation,
EPA may sample and analyze additional areas to determine if
treatment of some areas is appropriate."
As described previously under Alternatives S2, S3, and S4,
offsite runon from the stream would be diverted to the offsite
pond and the site would be revegetated.
During Remedial Design of this alternative, an air monitoring
program would be developed to detect releases of volatile
organics or particulates during excavation. If substantial
released are detected, the wastes that are the source of the
release will be tested.
To moni tor the effecti veness of this al ternati ve, groundwater
monitoring would be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
samples biannually until the first five year review and on an'
annual basis afterwards. samples would be analyzed for Target
Compound List (TCL) organics and Target AnalYte List (TAL)
inorganics. Three residential wells at highest risk would also
be sampled at this time for VOCs.
Major items of work include:
. Waste excavation, 233,000 cy
. Soil backfill, 223,000 cy .
. Synthetic membranes, 568,000 sf
. Sand monitoring zones, 21,200 cy
. Waste backfill,' 233,000 cy
. Soil/sand covers, 50,750 cy
. Synthetic membrane, 390,000 sf
. Topsoil, 17,000 cy
. Seeding, 21 acres
Excavation, processing, and backfilling of the wastes require
considerable stockpiling and rehandling of material. These
activities, combined with the relatively restricted site area and
the rate at which waste can be handled, would limit the rate of
construction. This alternative would take two construction
seasons to complete. Addi tional factors that would slow the
progress of the work include the collection (i.e., lowering the
water table) and treatment of the water table and stabilizing
offsite groundwater flow to the excavated area. This flow would
be from the deep mine. Grouting of the highwall area may be used
to limit offsite groundwater flow into the fill area during
excavation.
33
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Securinq the wastes in an onsite landfill would eliminate human
exposure to the wastes and miqratjon of the waste to the wetland
area via overland transport. This alternative is also effective
in that the source of qroundwater contamination would be removed
from the water table. By removinq the source .ofqroundwater
contamination, no further leachinq of contaminants. to the water
table is anticipated. This alternative, however, does not reduce
the toxicity of the waste left in t~~ landfill.
Several problems could be encountered if' this remedy is
implemented. The slurry wall review panel members indicated that
it miqht be more difficult to de-water the site durinq excavation
than anticipated in the FS. Because of the adj acent deep mine
pool, dewaterinq miqht actually require the installation of a
slurry wall before excavation of the fill, substantially
increasinq costs. The use of the mine spoil would have to be
carefully controlled to avoid usinq material qreater than about
6" to properly backfill the area. It could be difficult to find
an adequate clay source close to the site at a reasonable cost.
Part of the landfill would extend over the mined area with-.
potential subsidence problems that could impact the liners and
landfill cap. A pre-desiqn study would be conducted to assess
the potential for subsidence and the effect of implementation of
this remedy on the mine pool. This study would be reviewed by
EPA and the PADER. '.
This alternative would not meet the CERCLA/SARA qoal of using
treatment to permanently reduce the toxicity mobility or volume
of the waste, but it would successfully contain the contaminants
and is consistent with EPA's interim Guidance on Preparing
Superfund Decision Documents (OSWER Directive 9355.3-02) for
larqe sites that contain hiqh volume low toxicity sites with
contamination that is marqinally above health based limits.
This remedy would meet EPA's PCB Spill Cleanup Policy (40 CFR
Part 761.120) for soils contaminated with PCBs below 500 mq/l.
.The landfill proposed under this alternative would be closed in
accordance with PACER requirements of 25 PA Code Chapter 264.
Since the fill is not a hazardous waste by definition, RCRA
closure and post closure requlations are not an applicable ARAR
but to the extent that they are relevant and appropriate would be
met by this alternative. .
EPA considers this alternative to be protective of public health
and the environment. This alternative does not meet one of the
qoals of CERCLA/SARA: to utilize treatment that permanently
reduces the volume, toxicity, or mobility of the contaminants.
As mandated by CERCLA for sites where the waste is left on site
above health-based levels, a 5-year site review (for 30 years)
would be performed to ensure that the alternative is protective
of human health and the environment.
post-closure use of the property must be restricted, as
necessary, to prevent damaqe to the cover and contact wi th the
34
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fill. Institutional controls such as deed restrictions and local
ordinances would be used to help, reduce exposure to the site.
These restrictions, for the most part, would not allow the site
area to be used for any purpose~ The state of Pennsylvania
requires a restriction on mining or mineral removal. . within one
half mile of the site. A prohibition on new wells located within
1/2 mile of the site would prevent exposure to high levels of
vinyl chloride present in the Clar:i,on Formation. The existing
site fence, which has been vandalized and repaired several times
would. be maintained. A fence will restrict access to the site.
Addi tional warning. signs near the entrance gate would also be
posted. Post-closure use of the property must be restricted
indefinitely.
Alternative S6:
Excavation and Offsite DisDosal
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$107,343,000
None
$104,770,000
24 Months
This alternative would consist of excavation of the solid waste
and onsite pond sediments. Excavated material would be disposed
of in an offsite commercial hazardous waste landfill. Borrowed
soil from the spoil piles and highwall area would be used to
backfill the bottom of the excavated area. The final site
configuration and the borrow area would be graded and the stream
diverted to promote drainage, but would be lower than the
existing grade. Both the regraded site and the borrow area would
be vegetated to prevent erosion. .
Dewatering of the fill would be required prior to offsite
disposal. Excavation of the fill material would also require the
collection and treatment of the water table and onsite ponds as
the site is excavated. Leachate generated during the dewatering
process would be treated with the water table groundwater since
they are basically the same. . For purposes of simplicity,
remediation of the water table, leachate. and onsite ponds is
discussed separately (see Alternative G03). Therefore, costs for
groundwater remediation are not included under this alternative,
but rather with Alternative G03.
A drum staging area would be constructed in the event that newly-
discovered drums. are uncovered during the excavation activities.
Following the construction of the onsite landfill, any uncovered
drums along with the two drums which are presently on site can be
securely placed in the onsite landfill. Any drums or
concentrated wastes found during excavation must be tested to
determine if the contain hazardous wastes that require treatment
under the land disposal regulations would be sent offsi te to an
appropriate treatment or disposal facility.
Long term groundwater monitoring would not be necessary since
this alternative would result in the complete removal of the
35
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source area and would meet RCRA clean closure requirements.
Major items of work include:
,
, . Waste excavation, 233,000 cy
. Haul/dispose offsite, 233,000 cy
. Soil backfill, 223,000 cy
. Grading, 43,600 cy
. Topsoil, 17,000 cy -
.' 'Seeding, 21 acres
'This alternative is effective in that all
contaminant migration routes would be eliminated.
Federal and state guidance for allowable levels of
met.
exposure and
Additionally,
PCBs would be
Excavation, processing, and disposal of the wastes would require
considerable stockpiling and movement of material because a
majority of the waste is below the water table. This alternative
would be relatively easy to implement. The waste would have to.
be stored and drained prior to sending offsite. These activities
along with the relatively restricted site area and the rate at
which waste can be handled, would limit, the construction rate.
This alternative would take two construction seasons to complete.
Addi tional factors such as collecting and treating the
groundwater would slow the progress of the work.' There is also a
need to separate large pieces of slag, drums, and other debris
from the waste. Also, offsite disposal would require a staging
and loading area. for trucks.
The waste would be transported to a commercial hazardous waste
landfill in compliance with standards applicable to generators
and transporters of hazardous waste promulgated under RCRA,
delegated to the state of Pennsylvania and found in 25 PA Code
S262 and S263 regulations governing the generation and
transportation of hazardous materials, a"s appropriate and the
u. S. and State Department of Transportation (DOT) regulations
pertaining to transportation of hazardous materials. The
facility receiving the waste will be. in cOlDpliance with
applicable state and Federal permit requirements relevant to
hazardous waste disposal facilities.
During Remedial Design of this alternative, an air monitoring
program would be developed to detect releases of volatile
organics or particulates during excavation. This remedy will
comply with PA Air Pollution Control regulations 25 PA Code 121-
143.
This alternative does not meet the CERCLA/SARA goal of treatment
to permanently and 'significantly reduce a waste's toxicity,
mobility, or volume. However, offsite disposal would reduce the
toxicity, mobility, and volume of the waste at the Osborne
Landfill site itself.
TSCA and State PCB regulations and closure requirements (25 PA
36
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Code 264.310) would be met. Since all wastes would be removed the
five year review of CERCLA section, 121(c) would not be-necessary
-- and site access would not need to be restricted.
Alternative S7: Excavation. Onsite
Incineration. and Onsite DisDosal
Estimated Construction Cost
Annual O&M Costs -
Present Worth -
Estimated-Time to Complete
$55,937,000.
$36,000
$54,022,000
36 months
This alternative would consist of excavating all of the solid
waste, including the onsite pond sediments. Excavated material
would be incinerated in a mobile type incinerator. The residue
would be disposed in an onsite landfill as described in
alternative S5. In order to keep the treated waste residue above
the water table, borrow from the spoil piles at the west side of
the site and the highwall area would be used to backfill the..
bottom of the excavated area. The final site configuration and
the borrow area would be graded to promote drainage and the
stream that drains into the site diverted to the adjacent
wetlands. Both the regraded site and the borrow area would be
vegetated to prevent erosion.
As mentioned previously in the other alternatives which involve
excavation, the leachate generated during dewatering and the
lowering and collection of the water table would require
treatment (see Alternative G03). Intact drums encountered during
excavation would be placed in a drum ~ staging area and would
require sampling. Any drums found containing waste that fails
the Toxici ty Characteristic Leaching Procedure (TCLP) and any
liquids that would be classed as California wastes or any other
wastes that require treatment under the land disposal regulations
other than incineration would be sent offsite to an appropriate
treatment or disposal facility. If not sent offsite, wastes
would be incinerated and treated onsite.
To monitor the effectiveness of this alternative, groundwater
monitoring would be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
samples biannually until the first five year review and on an
annual basis afterwards. Samples would be analyzed for Target
Compound List (TCL) organics and Target AnalYte List (TAL)
inorqanics. Three. residential wells at highest risk would also
be sampled at this time for VOCs.
Major items of work include the following:
. Waste excavation, 233,000 cy
. Soil backfill, 223,000 cy
. Waste incineration, 322,000 cy
. Synthetic membranes, 568,000 sf
. Sand monitoring zone, 21,200 cy
. Incineration ash backfill, 322,000 cy
37
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. Soil/sand covers, 50,750 cy
. synthetic membrane, 390,000,~f
. Topsoi~, 17,000 cy
. Seeding, 21 acres
If excavation, material handling, and decontamination activities
are performed in. a controlled manner, air emissions can be
minimized 'CPA Air regulations, supra). During Remedial Design of
this alternative, an air monitoring program would be developed to
detect releases of volatile organics or particulates during
excavation. The use of incinerator air pollution control
equipment would remove potential contaminants from the gaseous
discharge. Air monitoring would be required during onsite
remedial activities because of the onsite incinerator.
Excavation, processing, incineration, and backfilling of the
wastes requires considerable stockpiling and rehandling of
material. .These activities, along with the relatively restricted
site area and the rate at which waste can be treated, would limit
the ccnetruction rate. It is estimated that this alternative-
would take three construction seasons to complete. Addi tional
factors such as the need to separate large pieces of slag, drums,
and other debris from the waste, would slow the progress of the
work.
This alternative would reduce the risks from direct contact
because most of the organic contaminants would be detoxified.
The incineration ash would be secured in an onsite landfill, an
action that would reduce remaining risks from inorganics and
metals associated with the treated material. Offsite migration
of contaminants to the wetland area and leaching of contaminants
to the water table would also be eliminated by placing the ash in
the landfill above the water table.
The state regulations for hazardous waste incineration at
25 PA Code Chapter 264, are relevant and appropriate. The state
regulations are similar to the Federal requirements. The fill
material will be analyzed in accordance with 25 PA Code Chapter
264.341. All residues from the incineration process will - be
disposed in an approved manner as stated at 25 PA Code 264.351.
This alternative would meet the CERCLA/SARA goal of using
treatment to permanently reduce the toxicity, volume, or mobility
of the waste.
EPA's PCB Spill Cleanup Policy C40 CFR Part 761.120)
PCB guidance would be met by this alternative.
The landfill proposed under this alternative would be constructed
and closed in accordance with PADER requirements of 25 PA Code
Chapter 264. Since the fill is not a hazardous waste by
definition, RCRA closure regulations are not an applicable ARAR
but to the extent that they are relevant and appropriate, they
would be met by this alternative.
and State
38
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This alternative does not meet one of the goals of CERCLA/SARA:
to utilize treatment that permanently and significantly reduces
the volume,. toxicity, or mobility of the contaminants. "As
mandated by CERCLA Section 121 for sites where the waste is left
on" site above health-based levels, a 5-year site review (for
30 years) would be performed to ensure that the alternative is
protective of human health and the environment.
. .
Post-closure use of the property must be restricted, as
necessary, to prevent damage to the cover and contact with the
fill. A security fence would be maintained around the site to
reduce access.
Alternative S9:
Excavation. Soil Washina. and Onsite DisDosal
Estimated Construction Cost
Annual O&M" Costs
Present Worth
F~timated Time to Complete
$62,140,000
$36,000
$59,859,000
36 months
This alternative would consist of excavation of all of the solid
waste including the onsite pond sediments. Excavated material
would be treated by soil washing to reduce the toxicity of the
waste. The treated waste would be disposed of in an onsite
landfill as described in alternative S5 and would meet the same
ARARs as S5. To keep the treated waste residue above the water
table, borrow from the spoil piles at the west side of the site
and from the highwall area would be used to backfill the bottom
of the excavated area. The final site configuration and the
borrow area would be graded and the stream diverted to promote
drainage. Both the regraded site and the borrow area would be
vegetated to prevent erosion.
The waste material would need to be screened to separate large
materials such as slag boulders, wood, and possibly drum
fraqments or intact full drums. The solid waste would then be
taken to the processing. area for soil washing. It is estimated
that 250 cy of waste can be washed per day. The.washing fluid
generated by this process must be treated to remove the
contaminants. Based on the results of the treatability study,
the contents of the wastewater would include the same
contaminants that have been" detected in the water table (i.e.,
PCBs, PABs, and metals) and therefore, this wastewater could be
treated along ..with the contaminated water table (see
Alternative G03). It is estimated that 750 qpm of contaminated
fluids would be generated by the soil washing operation. Based
on the amount of wastewater generated, it would be feasible to
treat the wastewater on site with the contaminated water table
rather than transporting it offsite for treatment.
Following the soil washing process, treated soil would be
disposed onsite. Based on the results of the treatability study,
only a 60 percent reduction in PCB concentration is expected.
Therefore, the treated waste be contained in a secure onsite RCRA
39
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subtitle C onsite landfill that meets all ARARs listed in 55.
During Remedial Desiqn of this alternative, an air monitoring
program would be developed to detect releases of volatile
orqanics or particulates during excavation.
To moni tor the effectiveness of this al ternati ve, groundwater
monitoring'would be required for th. onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
, samples biannually until the first five year' review and on an
annual basis afterwards. Samples would be analyzed for Target
Compound List (TCL) organics and Tarqet Analyte List (TAL)
inorganics. Three residential wells at highest risk would also
be sampled at this time for VOCs.
Major items of work include the following:
. Waste excavation, 233,000 cy
. Soil backfill, 223,000 cy
. So~,J, washing. 2:;:;,000 cy
. Synthetic membr~nes, 568,000 sf
. Sand monitoring zones, 21,200 cy
. Landfill treated soil, 233,000 cy
. Soil/sand covers, 50,750 cy
. Synthetic membrane, 390,000 sf
. Topsoil, 17,000 cy
. Seeding, 21 acres
This alternative would reduce the risks from direct contact and
inhalation of particulates because most Df the contaminants would
be removed. It is anticipated that the toxici ty of the waste
would be reduced and the leaching of contaminants would be
correspondingly reduced. Because the treated soil would be
contained (via landfilling) overland transport of contamination
would be eliminated.
Thi~ alternative satisfies the CERCLA/SARA goal of utilizing
treatment to reduce the toxicity, mobility or volume of a waste.
Excavation, processing, and backfilling of the site requires
considerable stockpiling and rehandling of material. These
activities along with the relatively restricted site area and the
rate at which waste can be treated, would limit the construction
rate. This alternative would take approximately three
construction seasons to complete. Additional factors such as the
need to separate large pieces of slag, drums, and other debris
from the waste would slow the progress of the work.
A drum staging area would be constructed in the event that newly-
discovered drums are uncovered during the excavation activities.
Following the construction of the onsite landfill', any uncovered
drums along with the two drums which are presently on site can be
securely placed, in the onsite landfill. Any drums or
concentrated wastes found during excavation must be tested to
determine if they contain hazardous wastes that require treatment
40
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under the land disposal regulations would be sent offsite to an
appropriate treatment or disposal, facility.
The reduction in PCB concentration may meet EPA' s PCB Spill
Cleanup policy (40 CFR Part 761.120) for allowable levels of PCBs
at a site with unrestricted site access. The metals
concentrations and PAR concentration would be only slightly
reduced. . .
The landfill proposed under this alternative, to contain the
remaininq contaminants, would be constructed in accordance with
RCRA closure requirements delegated to the state under PADER
requirements of 25 PA Code Chapter 264. These requirements are
relevant and appropriate. Since the fill is not a hazardous
waste by definition, RCRA closure and post closure regulations
are not applicable but to the extent that they are relevant and.
appropriate would be met by this alternative.
This alternative does not meet one of the goals of CERCLA/SARA:..
to utilize treatment that per~anently and significantly reduces
the volume, toxicity, or mobility of the contaminants. As
mandated by CERCLA section 121(c) for sites where the waste is
left on site above health-based levels, a5-year site review (for
30 years) would be performed to ensure that the alternative il?
protective of human health and the environment.
Post-closure use of the property must be restricted, as
necessary, to prevent damage to the cover and contact with the
fill. The security fence would be maintained around the site to
reduce access.
Alternative Sll: Excavation. Thermal StripDina.
Solidification. and Onsite DisDosal
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$91,000,000
$36,000
$87,392,000
24 months..
This alternative would consist of excavation of all of the solid
waste including the onsite pond sediments. Excavated material
would be treated by thermal processing (low-level thermal
stripping) to reduce the concentration of volatile organics and
oils, to facilitate the solidification process. The residual
material would be fixated and the residue disposed in an onsite
landfill as described in alternative S5 and will meet the ARARs
described in S5. To keep the treated waste residue above the
water table, borrow from the spoil piles at the west side of the
site and the highwall area would be used to backfill the bottom
of the excavated area. The final site configuration and the
borrow area would be graded and the stream diverted to promote
drainage. Both the regraded site and the borrow area would be
vegetated to prevent erosion.
41
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This alternative consists of the installation of volatilization
equipment to treat the solid waste prior to solidification.
Thermal treatment of the solid waste is recommended to volatilize
or remove organics which may impede the solidification process.
Volatile and semi-volatile organics would be collected and
condensed in a separate vessel for subsequent- - treatment or
disposal. The treated waste would then be fed to the onsi te
treatment plant, where stabilizing mixtures- would be added. The
treated waste would then be taken - back to the former disposal
area -and allowed to cure or complete the solidification process.
Backfilling of the site area prior to placement of the solidified
waste would be necessary so that the waste is landfilled above
the water table. The site would then be regraded, covered with
soil, and revegetated.
Excavation of the entire disposal area would require the
lowering, collection, and treatment of the onsite water table and
ponds. Leachate collected during dewatering of the fill would
also require treatment. For purposes of simplicity, groundwater
and surface water treatment are discussed separately under-
Alternative 003.
During Remedial Design of this alternative, an air monitoring
program would be developed to detect releases of volatile
organics or particulates during excavation.
To monitor the effectiveness of this alternative, groundwater
monitoring would be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells would collect
samples biannually until the first five year review and on an
annual basis afterwards. Samples would be analyzed for - Target
Compound List (TCL) organics and Target Analyte List (TAL)
inorganics. Three residential wells at highest risk would also
be sampled at this time for VOCs.
Major items of work include:
. Waste excavation, 233,000 cy
. Soil backfill, 223,000 cy
. Waste treatment, 233,000 cy
. Synthetic membranes, 568,000 sf
. Sand monitoring zones, 21,200 cy
. Landfill treated soil,-233,000 cy
. Soil/sand covers, 50,750 cy
. Synthetic membrane, 390,000 sf
. Topsoil, 17;000 cy
. Seeding, 21 acres
The effectiveness of this alternative would be verified by
treatability studies.- However, if thermal stripping is used to
pretreat the solid waste, cement or lime-based solidification may
be effective in stabilizing the contaminants in the waste.
Weathering and aging of the solidified material may reduce the
effectiveness of the process and leaching of contaminants would
recur. This alternative would require monitoring of the
42
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qroundwater to ensure that contaminants are not leachinq from the
waste material.
This alternative is not a permanent solution because some of the
contaminants would remain at the site. However, the ~obility of
the contaminants would be reduced, since orqanics would be
removed and contaminants remaininq in the treated material would
be stabilized and contained by the. landfill. The increase in
waste volume may be siqnificant, which -. could make this
alternative difficult to implement. .
The technoloqies proposed for excavation and material handlinq
are all demonstrated and 'commercially available. The
volatilization and stabilization technoloqies are anticipated to
be technically feasible: however, bench- and/or pilot-scale
studies would need to be conducted.
Excavation,. processinq, and backfillinq of the wastes requires
considerable stockpilinq. and rehandlinq of material because of..
the constraints of the site. These activities, alonq with the
relatively restricted site area and the rate at which waste can
be treated, would limit the construction rate. This alternative
would take three construction seasons to complete. Addi tional
factors that would slow the proqress of the work include the nee~
to separate larqe pieces of slaq, drums, and other debris from
the waste prior to processinq.
A drum staqinq area would be constructed in the event that newly-
discovered drums are uncovered durinq the excavation activities.
Followinq the construction of the onsite landfill, any uncovered
drums alonq with the two drums which are presently on site can be
securely placed in the onsite landfill. Any drums or
concentrated wastes found durinq excavation must be tested to
determine if the contain hazardous wastes that require treatment
under the land disposal requlations would be sent offsite to an
appropriate treatment or disposal facility.
EPA's PCB Spill Cleanup Policy (40 CFR Part 761.120) is met by
this alternative. .
The landfill proposed under this alternative would be constructed
in accordance with RCRA closure requirements or PACER
requirements of 25 PA Code Chapter 264. Since' the fill is not a
hazardous waste by definition, RCRA closure requlations are not
an applicable ARAR but to the extent that they are relevant and
appropriate they would be met by this alternative.
This alternative may not meet one of the qoals of CERCLA/SARA:
to utilize treatment that permanently reduces the. volume,
toxicity, or mobility of the. contaminants. As mandated by CERCLA
121(c) for sites where the waste is left on site above health-
based levels, a 5-year site review. (for 30 years) would be
performed to ensure that the alternative is protective of human
health and the environment.
43
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Post-closure use of the property must be restricted, as
necessary, to prevent damage to ,the cover and contact with the
fill. A security fence would be' maintained around the .site .to
reduce access. . .
Alternative S12:
SlurrY Wall. Clav CaD. and Groundwater PumDina
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$7,432,000.
$817,000 .
$16,976,000
30 years or
more
This al ternati ve involves the construction of a clay cap and
slurry wall around the entire fill area of the site. This area
is approximately six acres. The site would be regraded and the
stream diverted to the offsite pond to promote drainage.
Appropriate drainage and erosion controls will be developed
during the .remedial design of the alternative. The technical
details of the scoping design of the slurry wall installation
have been approved by a technical panel of slurry Wi:-.:.J. experts:'
The scoping design that was reviewed is contained in the memo
"Response to EPA Comments, Proposed Remedial Action Plan, Osborne
Landfill Site, CEC Project 89190", from civil and Environmental
Consultants, Inc.(CEC), addressed to Mr. Michael J. O'Brien, and
dated May 22, 1990. The technical details and comments from the
technical panel are contained in the Administrative Record. The
eastern boundary of the site is especially critical since the
Clarion Formation and the deep mine pool, which are present east
of the site, provide a pathway for offsi te migration of the
contaminated water table. The slurry wall would be installed at
an elevation of approximately 1,300 feet to 1,260 feet.. This
barrier would be keyed into the clay layer and sandstone beneath
the deep mine.
The PADER cap requirements, 25 PA Code 271-285, for municipal.
waste landfills are relevant and appropriate and would be met by
this Remedial Action. The cap would consist of two feet of clay
with a permeability of . less than 10-7, a twelve inch sand and
geotextile drainage layer, and two feet of. soil with a vegetative
cover.
A drum staging area would be constructed in the event that newly-
discovered drums are uncovered during the excavation activities.
Any drums or concentrated wastes found during excavation must be
tested to determine if they contain hazardous wastes that require
treatment under the land disposal regulations would be sent
offsite to an appropriate treatment or disposal facility. If
drums, concentrated wastes or new fill areas are discovered
during the slurry wall installation, it will be necessary to
relocate the position of the wall so that all waste areas are
encompassed.
containment wells would be installed onsite to prevent vertical
migration to the underlying Homewood Formation and horizontal
migration to the Clarion Formation. The water level inside the
44
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containment would be lowered to an elevation of approximately
1272 feet above mean sea level. ,Durinq this staqe a hiqh rate
of pumpinq and treatment would be. required. Then these wells
would pump continuously at a rate of approximately 30 qallons per
minute. The exact pumpinq rate will depend on the rate of
infiltration of qround water.
At this rate, no horizontal or vertical migration of the water
table is anticipated. The contaminated qroundwater would be
treated onsite and discharqed to the deep mine (via injection
wells). .'
Treatment of the water table would consist of equalization, pH
adjustment/chemical precipitation, clarification, sand
filtration, and carbon adsorption. This treatment would be able
to reduce orqanic and inorqanic contaminants to acceptable
levels. The water injected into the mine pool must comply with
PA Clean .streams Law for discharqe limits and federal
requirements reqardinq class IV well inj ection. This includes..
frequency of samplinq and concentration limits for disct4ar~-=;~.
Contaminant levels will at least meet MCLs prior to injection.
Additionally, the NPDES standards, 25 PA Code Chapter 92, for
treatment systems are relevant and appropriate. Treatment
residues and sludqes will be sent offsite to an appropriat..
treatment or disposal facility in compliance with state and
federal requlations for disposal and transportation.
One uncertainty reqardinq this alternative is the inteqrity of
the clay underlayer beneath the fill material. If this clay
layer has been breached or if a major hydroloqical connection
exists between the mine pool and the fill area, it may not be
possible to lower the water level enouqh to assure that all flow
from adjacent aquifers is .int.Q the containment at a reasonable
pumpinq rate and cost. The desiqn must demonstrate that the fill
can be compacted enouqh to avoid subsidence and damaqe to the
cap. If subsidence. of the fill occurs, the cap and any
mon:to~inq wells impacted by the subsidence must be repaired.
This remedy must meet the followinq performance standards at the
followinq milestones:
Pre-Desiqn - Borinqs would be performed every 100 feet alonq
the perimeter of the planned location of the slurry wall to
assess the thickness of the clay layer and other qeoloqic
condi tions. The" need for a pump test to help determine the
inteqrity of the clay layer beneath the fill would be
assessed. A study Qf the potential for subsidence to affect
the inteqrity of the slurry wall must be conducted and
approved by EPA and submitted to the PADER. The effect of
this remedy on the mine pool would also be evaluated before
the desiqn. The pre-desiqn study would address all of the
items identified by the slurry wall review panel and outlined
in the scopinq study from CEC.
Design - Detailed performance standards would be developed to
45
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assure that the following broad goals are accomplished by the
Remedial Action:
,
1) That the slurry wall installation is
implementable at reasonable costs. in this field
setting. . .
2) That the water level inside the slurry wall
containment can be lowered by .reasonable pumping
rates to a level that creates a negative pressure
of at least one foot of head (0.4 psi) with
respect to the adjacent Homewood and Clarion
aquifers along the entire perimeter of the fill.
The average target elevation for ground water
level, in the fill, to achieve a pressure
differential that prevents seepage from the
containment has been proposed as 1272 feet MSL.
The exact level to achieve this would be
finalized during the desiqn phase of this
Remedial Action. Pairs of wells inside and-
outside the fill area would be installed around
the perimeter of the site in each of the adjacent
aquifers to verify that the performance standards
are met. The exact number and placement would
also be established during the desiqn phase. The
frequency of measuring the water level in the
well pairs will also be established during the
desiqn. Quarterly monitoring of the wells
outside the containment for TCL and TAL
contaminants is required to detect an increase in
contamination associated with leakage. ..
3) That future subsidence will not impact the
integrity of the slurry wall or the clay cap.
Implementation of the Alternative - The alternative must meet
the detailed performance standards established during the
desiqn.
If 1:h8 p8rformanc8 81:an4ar48 CaDDo1: b8 m81: a1: 1:h8 pr8-48.iqn,
488iqn or iapl..eD1:a1:ioD 81:aqe8 of 1:h8 r..e4y, 1:h8 lan4fill
al1:erDa1:iv8 mU81: b8 implemeD1:e4 iD plac8 of 1:he slurry vall
al1:erDa1:iv8. If af1:8r implemeD1:a1:ioD. of 1:h8 8lurry vall
al1:erDa1:iv8, 1:h8 performance s1:an4ar4. CaDDo1: be me1:, a maximum
of 1:hr88 mOD1:h8 .(90 4ays) vill b8 allove4 1:0 4emoD.1:ra1:e 1:ha1: a
miDor m04ifica1:ioD of 1:h8 al1:erDa1:ive can correc1: 1:h8 problem an4
a maximum of siz mOD1:h8 vill be allo.e4 1:0 implemeD1: an4 a..e..
1:h8 succe.8 of 1:h8 m04ifica1:ioD. The performance s1:an4ar4s for
1:h8 8lurry vall ar8 qiveD iD qrea1:er 4e1:ail un4er al1:erDa1:iv8 812
belove
To monitor the effectiveness of this alternative, groundwater
. monitoring will be required for the onsite water table, Clarion,
and Homewood Formations. Ten monitoring wells in these
formations will collect samples quarterly for the first year
46
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after completion of the remedy and biannually thereafter until
the first five year review and on an annual basis afterwards.
, The locations of these wells will be finalized during the
, Remedial Desiqn. Samples will be, analyzed for Target Compound
Lis1; (TCL) organics and Target AnalYte List (TAL) inorganics.
Three residential wells at highest risk, as determined by EPA
will also be sampled at the same interval as the monitoring wells
time for VOCs.
The ~egrading and capping technologies wiil prevent direct
contact with the solid waste fill material and overland transport'
of foundry sand to the wetland area. Groundwater
pumping/treatment will prevent the migration of the contaminated
water table to the Homewood and Clarion Formations, which' are
used in the local area as a source of potable water. The slurry
wall will virtually eliminate the horizontal flow of groundwater
across the site and thereby reduce the pumping rate required to
prevent offsite groundwater contamination.
This option will not reduce the toxicity mobility or volume of
the waste. The intent of this option is to reduce the transport
of contaminants, by containing the source and eliminating
pathways of migration. Infiltration of surface water (rainfall)
will be reduced, and ultimately recovered and treated. OVerland
transport of contaminated materials will be eliminated. With the.
implementation of an active water extraction system wi thin the
waste mass, flow will be into the containment and the potential
for groundwater contamination and migration will be virtually
eliminated.
This alternative does not reduce the current level of
contamination in the fill area. The average concentration of
PCBs in the fill is 23 mq/kg. EPA's PCB Spill Cleanup Policy (40
CFR Part 761.120) for an unrestricted access site (maximum PCB
concentration of 10 mg/kg) is not met by this alternative. EPA's
PCB Spill Cleanup Policy for a reduced access area (maximum PCB
concentration of 25 mg/kg) is met by this alternative.
The clay cap proposed under this alternative would be constructed
in accordance with RCRA requirements of 25' PA Code Chapter 264
for closure by capping. Since the fill is not a hazardous waste
by definition, RCRA landfill closure requlations are not an
applicable ARAR, but to the extent that they are relevant and
appropriate, they will be met by this alternative. The
groundwater monitoring of the fill area would fulfill the
appropriate monitdring requirements of RCRA landfill closure.
This remedy does protect human health and the environment by
containing site contaminants, but does not meet CERCLA/SARA goals
for treatment to permanently and significantly reduce toxicity
mobility or volume of the material. The CERCLA section 121(c) 5
year review and assessment of the effectiveness of this
alternative will be required since, the wastes will remain on
site.
47
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The pennsylvania ARAR for groundwater for hazardous substances
states that all ground water must be remediated to "background"
quality a8 specified by 25 Pa. Code Sections 264.90 - 2'64.100,
and in particular, by 25 Pa. Code Sections 264.97 (i), (j) and
264.100(a) (9). The Commonwealth of Pennsylvania ,also maintains
that the requirement to remediate to backqround is'also found in
other leqal authorities. Therefore, the negative pressure between
the containment and the adjacent aqqifer must be maintained until
the contaminant levels in the ground water in contact with the
fill are below the fOllowing levels that EPA considers background
at the Osborne site: '
. .
TCE - 0.2 ug/l
Vinyl Chloride - 0.2 ug/l
cis - 1,2 Dichloroethylene
Benzene - 0.2 ug/l
Benzo(a)Pyrene - 10 ug/l
PCBs - 1 u9/1
- 0.2 ug/l
'.
Arsenic - 22 ug/l
Berylium - 2 ug/l
Chrome - 50 uq/l
Lead - 15 ug/l
Nickel - 15 uq/l
The point of compliance is the influent to the treatment system.
In addition to the specific qoals listed above, if any other
compound exceeds its MCL or non-zero MCLGs 40 CFR 1141.50-52,
the negative pressure must be maintained.
The mandated 5-year review and assessment of the effectiveness of
this alternative will be required since the wastes will remain
onsite.
Post-closure use of the property must be restricted, as
necessary, to prevent damage to the cover and contact with the
fill. The cap will be checked biannually for damage and the need
for repairs.
Institutional controls such as deed restrictions and local
ordinances would be used to help reduce exposure to the site.
These restrictions, for the most part, would not allow the site
area to be used for any purpose. The State of pennsyl vania
requires a restri.ction on mining or mineral removal wi thin one
half mile of the site. A prohibition on new wells located within
1/2 mile .of the site would prevent exposure to high levels of
vinyl chloride present in the Clarion Formation. A fence will
restrict access to the site and additional warning signs near the
entrance gate would also be posted. Post-closure use of the
property must be restricted indefinitely.
ONSITE WATER TABLE (OPERABLE UNIT 3)
The Onsite Water table is the water present in the fill material
48
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below the ground water level. The ground water al ternati ves
presented below were developed separately from the alternatives
for the fill material. For instance if a cap is chosen, either
nO,action (G01) or containment of fill contaminants by pump and
treatment (G02) could be chosen. G03, howeveri is only
associated with excavation options since this alternative
represents treatment of water collected during excavation.
Contaminated water would be collected" during excavation;
Therefore, this al ternati ve lmU!.t be selected, if any excavation
,option (S5,S6,S7,S9 or Sll) is selected. The Alternative S12 for
the fill' material would collect and treat most of the ground
water in contact with the fill and would continue to pump and
treat the water table inside the slurry wall indefinitely.
Therefore, if alternative S12 is chosen, the onsite water table
will be treated as an integral part of this fill remedy and a
separate OU3 remedy will not need to be selected.
Alternative G01:
No Action
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$28,000
$12,000
$71,000
1 month
The no action alternative is considered in the FS to provide a
baseline to which other remedial alternatives can be compared.
Groundwater monitoring would consist of sampling three wells
biannually until the first five year review required by CERCLA
Section 121(c) and annually afterward. The groundwater would be
analyzed for TCL organics and TAL organics. The wells would be
constructed to monitor the water table.
The no action alternative could be easily implemented. It may be
possible to use existing monitoring wells unless remedial action
is taken on the disposal area, which may result in the removal of,
a certain number of monitoring wells. Groundwater use
restrictions could be implemented by state and local officials
using state water pollution control requlations and requirements
related to well drilling and groundwater use.
The no action al ternati ve would not prevent future potential
risks associated with groundwater consumption. It would not
prevent offsite migration of contaminated groundwater.
Monitoring of the-groundwater would act as a detection method to
determine whether the concentration of soluble contaminants in
groundwater were increasing or migrating over time. If
concentrations were to significantly increase, then preventive
methods could be implemented. .
This alternative would not comply with either contaminant-
specific ARARs, such as drinkinq water standards 40 C.F.R. Part
141, or location-specific ARARs, such as the EPA Groundwater
Protection Strategy.
49
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Alternative G02: Containment of the Contaminant Plume bv PumDina
. Phvsical/Chemical Treatment. and Onsite Iniection of Ground
Water
.
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$2,627,000
$817,000
$17,894,000
30 y~ars or more
. This 'alternative could not be employed with any excavation
alternative (i.e., Alternatives S5 through Sll) that is
associated with the fill material, since the water table would be
remediated during excavation. Therefore, this alternative is
applicable only to those alternatives that do not .involve
excavation of the waste material (~.e., Alternatives Sl
through S4).
This alternative would consist of methods that would contain the
contaminated water table and prevent vertical and horizontal
migration. containment wells would be installed onsite to"
prevent groundwater migration. It is estimated that 15 wells,
pumping at a combined rate approximating groundwater. recharge in
the affected area (270 gpm), would be required.
The contaminated groundwater would be treated on site using a'
combination of physical and chemical processes to treat the water
table to acceptable levels. Following treatment, the water would
be' inj ected into the deep mine pool. Because the mine pool
covers over 1 square mile in area and the effluent discharge
would be approximately 270 gpm, no significant change in water
levels is expected to occur in the mine pool. . .
Treatment of the water table would consist of equalization, pH
adjustment/chemical precipitation, clarification, sand
filtration, and carbon adsorption. This treatment would be able
to reduce organic and inorganic contaminants to acceptable'
lev~ls. The water injected into the mine pool must comply with
PACER discharge and federal requirements regarding class IV well
injection. contaminant levels must be treated to below MCLs
prior to injection. Additionally, the NPDES standards for
treatment systems are relevant and appropriate. Treatment
residues and sludges will be sent offsi te to an appropriate
treatment or disposal facility in compliance with state and
federal regulations for disposal and transportation.
Groundwater monitoring would consist of sampling three wells
biannually until the first five year review under CERCLA Section
121(C) and annually afterward. The groundwater would be analyzed
for TCL organics and TAL organics. The wells would be
constructed to monitor the water table including the compounds
listed below as cleanup goals.
This alternative should be
migration of contaminants
Additionally, the level of
effective in preventing offsite
from the onsi te water table.
contamination in the onsite water
50
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~
I
I
table could potentially decrease over time. since the waste
would remain in place, it is diff~cult to estimate how lo~g this
alternative would need to be implemented. .
The Pennsylvania ARAR for groundwater for hazardous. substances is
that all ground water must be remediated to "background" quality
as specified by 25 Pa. Code sections 264.90 - 264.100, and in
particular~ by 25 pa. Code . sections 264.97(i), (j) and
264.l00(a) (9). The Commonwealth of Pennsylvania also maintains
that the requirement to remediatento background is found in otheJ;'
legal authorities. Pumping must continue until contaminant
levels are below the fOllowing limits as measured in the three
monitoring wells and the influent to the treatment system:
TCE - 0.2 ug/l
Vinyl Chloride - 0.2 ug/l
cis - 1,2 Dichloroethylene
Benzene - 0.2 ug/l
- O. 2 ug/l
B~nzo(a)I'y:c~u~ - 10 ug/l
PCBs - 1 ug/l
Arsenic - 22 ug/l
Berylium - 2 ug/l
Chrome - 50 ug/l
Lead - 15 ug/l
Nickel - 15 ug/l
The point of compliance is throughout the contaminated plume.
In addition to the specific goals listed above, if any other
compound exceeds its MCL or non-zero MCLG, the remedy must
continue.
The exact placement of the monitoring wells would be finalized
during the Remedial Design. Groundwater monitoring of the water
table would provide information to assess the effectiveness of
this alternative. Because this alternative is designed to only
contain the migration of contaminants, future use of the onsite
water table would not be possible (because the source is not
removed). .
The technologies and process options associated with groundwater
extraction, treatment, and discharge are demonstrated and
commercially available. The proposed treatment scheme is capable
of reducing contaminant levels to drinking water standards
eventually. Operation and maintenance of the pumping system and
treatment plant would be required for as long as the waste
remains on site and background ground water levels are exceeded.
An state permit not be required for discharging the treated
groundwater since it would be injected onsite, but permit levels
must be met.
51
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Alternative G03: Collection. Phvsical/Chemical Treatment.
Onsite Iniection of Ground Water ~~nerated Durina Excavation
and
Estimated Construction Cost
Annual O&M Costs
Present Worth
Estimated Time to Complete
$2,627,000
$817,000
$5,321,000
36 months maximum, depending on
which solid waste alternative is
chos.en
This al ternati ve would only be implemented if the source o.f.
contamination is excavated (see Alternatives 55 through 512).
Because the source would be removed, remediation of the water
table would be a permanent solution. Groundwater would be
collected during excavation using extraction wells (most likely
well points), trenches, or subsurface drains. The contaminated
water would be pumped to an onsite treatment plant consisting of
both physical and chemical processes for treating the water to
drinking water standards. Treated groundwater would be injected
into the mine void, ~ince there are no other available discharge-.
points and to maintain the hydrostatic pressure in the mine pool
The effluent would need to be monitored periodically to ensure
that the treatment process was operating effectively. The
technologies and process options associated with the treatment
and disposal of the water table are demonstrated and commercially.
available. Treatment/disposal of the fill material is expected
to take anywhere from 1 to 3 years, depending on the alternative
selected for excavation and treatment/disposal of the solid
waste. For example, excavation and onsite disposal
(Alternative 55) would take approximately 2 years as opposed to
excavation and soil washing (Al ternati ve 59), which would take
about 3 years. Consequently, the treatment plant would operate
concurrent with the excavation activities. Once the source was
completely removed the treatment of groundwater can be
discontinued'soon afterward.
This alternative should be effective in reducing contaminant
levels to drinking water standards (MCLs) and eventually to
background levels. Treatment will most likely b~ conducted in
batch quantities as opposed to a constant flow, since the
collection of groundwater would be performed concurrent with the
excavation of solid waste. Monitoring of the effluent should be
conducted to ensure that the treatment process is effective in
reducing the level of contamination to acceptable levels. If the
wastes are removed, long-term groundwater monitoring would not be
required, however; since (1) the contaminated water table would
be collected, permanently remediated, and discharged and (2) the
source of contamination would be removed (and possibly treated)
and disposed offsite. Therefore, additional flow of water across
the remediated site area would not be in contact with the waste.
If- a secure landfill option is selected, monitoring wells in the
onsite water table and Clarion formation would detect leaks into
the shallow groundwater.
Treatment of the water table will consist of equalization, pH
52
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adjustment/chemical precipitation, clarification, sand
filtration, and carbon adsorption~ This treatment will be able
to reduce organic and inorganic contaminants to acceptable
leyels. The water injected into the mine pool must comply with
PACER discharge levels and federal requirements regarding class
IV well injection. This includes frequency of sampling and
concentration limits for discharges. Contaminant levels must be
below MCLS prior to injection. Additionally, the NPDES
standards (25 PA. Code Chapter 92) for treatment systems are
relevant and appropriate. Treatment residues and sludges will be
sent offsite to an-appropriate treatment or disposal facility in
compliance with state and federal regulations for disposal and
transportation.
This alternative would comply with the EPA Groundwater Protection
strategy, since it will result in the complete treatment of the
l~achate in contact with the fill. Since significant
contamination has not been detected in the overburden wells
outside of the fill area, collection and treatment of the..
leachate and the containment of the excavated fill will protect
the class II overburden aquifer adjacent to the fill. As
previously stated, this aquifer is not currently used, but could
be used in the future. . .
CLARION FORMATION EXCLUDING THE MINE POOL (OPERABLE UNIT 4)
Alternative GC1:
No Action
Estimated Construction Cost $33,500
Annual O&M Costs $12,000
Present Worth $277,000
Estimated Time to Complete 1 month
The no action al ternati ve is considered in the FS to provide a
baseline to which other remedial alternatives can be compared.
Groundwater monitoring would consist of sampling three wells
biannually until the first five year review under CERCLA Section
121(c) and annually afterward. The wells would be placed at~e
boundary of the plume and the samples would be analyzed for TCL
organics and TAL inorqanics.
The no action al ternati ve would not prevent future potential
risks associated with the consumption of contaminated
groundwater. Additionally, it would not prevent the migration of
contaminants in the Clarion Formation. Monitoring of the Clarion
Formation would act as a detection method to determine whether
the concentration of soluble contaminants in groundwater were
increasing and migrating over time. If the migration was such
that downgradient wells would be impacted, then it might be
necessary to implement preventive measures. .
The no action alternative could be easily implemented.
In the event that residential wells are installed in the area of
concern, this alternative would not meet those requirements for
drinking water standards, since the level of vinyl chloride in
53
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the groundwater exceeds the MCL of 2 ~g/l. Because the Clarion
Formation is considered a Class, ,IIA aquifer, this alternative
does not meet the policy of the EPA Groundwater protection
strategy or Pennsylvania clean up levels for ground water.
Alternative GC2: Containment of the Contaminant Plume
PumDina. p~vsical Treatment. and Injection of Ground Water
Estimated Construction Cost $603,000'
Annual, O&M Costs $87,000 .
Present Worth approximately $1,992,000
Estimated Time to Complete 30 years or
By
more
This alternative would consist of methods that would contain the
contaminant plume at its current location and prevent further
horizontal migration. Extraction wells would be employed to
prevent groundwater migration. It is estimated that three wells,
pumping at. a rate approximating groundwater recharge in the
affected area (36 gpm), would be required. These wells would be
positioned near the boundary of the site. The number of wells,"
their position and pumping rates will be finalized during the
Remedial Design.
The Pennsylvania ARAR for groundwater for hazardous substances is
that all ground water must be remediated to "background" quality
as specified by 25 Pa. Code Sections 264.90 - 264.100, and in
particular, by 25 pa. Code sections 264.97(i), (j) and
264.100 (a) (9). The Commonwealth of Pennsylvania also maintains
that the requirement to remediate to background is found in other
legal authorities. The contaminated groundwater would be treated
on site using an air stripper to treat the contaminated plume to
acceptable levels. The groundwater would be pumped and treated
until the following cleanup levels are obtained (a Pennsylvania
ARAR) as measured by the monitoring wells and the influent to the
air stripper:
TCE - 0.2 ug/l
Vinyl Chloride - 0.2 ug/l
cis - 1,2 Dichloroethylene
Benzene - 0.2 ug/l
The point of compliance is throughout the contaminated plume.
- 0.2 ug/l
In addition to the specific goals listed above, if any other
compound exceeds. its MCL or non-zero MCLG, the remedy must
continue.
After these levels are attained, testing must be
annually for three years to detect groundwater rebound.
Following treatment, the water would be injected - into the deep
mine pool. This would help maintain the hydrostatic equilibrium
in the Clarion formation to prevent subsidence. Because the mine
pool covers over 1 square mile in area and the effluent discharge
would be approximately 36 gpm, no significant change in water
conducted
54
".
.
. .
-------
level is expected to occur in the mine pool.
the deep mine are anticipated.
The water injected into the mine pool must comply with PADER
Clean streams Law regarding discharge levels- - and federal
requirements regarding class IV well injection. This includes
frequency of sampling - and concentration limits for discharges.
contaminant levels must be at least below MCLs. Additionally,
the NPDES standards (PA. Code Chapter 92) fo~ treatment systems
are releyant and appropriate. -
No other impacts to
Groundwater monitoring would consist of sampling three wells
biannually until the first five year review and annually
afterward. The wells would be placed at the boundary of the
plume and in the area of highest contamination. The exact
locations would be finalized during the Remedial Design. The
samples would be analyzed for TCL organics and TAL inorganics.
This alternative should be effective in preventing further.,
offsite migration in the Clarion Formatior.. Air stripping is
expected to be effective in treating the vinyl chloride that is
present in the Clarion Formation (6 #g/l maximum ).Because this
alternative is designed only to contain the migration of
contaminants, future use of the Clarion Formation near the sit~
would not be possible. The State of Pennsylvania has required
the use of "Best Available Technology" to prevent the release of
volatile organic hydrocarbons to the air. The rate of emission
of vinyl chloride is expected to be extremely low ( one millionth
of a pound per hour). The most cost effective method to capture
this emission would be evaluated during the design of the
remedial action. -
The technologies and process options associated with groundwater
extraction, treatment, and discharge are demonstrated and
commercially available. The proposed treatment scheme is capable
of reducing contaminant levels to drinking water standards.
Ope':-ation and maintenance of the pumping system and treatment
plant would be required for as long as the waste remains onsite
and continues to leach contaminants (this alternative is only
employed to "contain" the plume). Additionally, an permit would
not be required for discharging the treated groundwater since the
water would be discharged within the site boundary. The
contaminant levels in the discharged water would meet state
requirements and federal standards for a class IV injection well.
"
Because this alternative is not a permanent solution, it does not
meet the EPA Groundwater Protection strategy for a Class IIA
EH"JUifer. Additionally, if someone were to construct a well
wi~hin the zone of contamination, drinking water standards (i.e.,
MCLs) would be exceeded for vinyl chloride.
55
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Alternative GC3: Extraction. Physical Treatment.
Ground Water Collected durina Excavation
In; ection of
.
Estimated Construction Cost $603,000
Annual O&M Costs $87,000
Present Worth approximately $2,500,000
Estimated~ime to Complete 30 years or more
This alternative would only be achievable if the source (solid
waste)"of contamination is effectively removed or isolated from
the water table. Because the source would be effectively
contained remediation of the Clarion Formation would be a
permanent solution.
Groundwater would be extracted using several wells wi thin the
plume. The contaminated groundwater would be treated onsite
using an air stripper to treat the contaminant plume to
acceptable ~evels (at least non zero MCLs) before discharge to
the mine pool in the Clarion formation. The P~nnsylvania ARAR.
for groundwater for hazardous substances is that all ground water'
must be remediated to "background" quality as specified by 25 Pa.
Code Sections 264.90 - 264.100, and in particular, by 25 pa. Code
Sections 264.97(i), (j) and 264.100(a) (9). The Commonwealth of
Pennsylvania also maintains that the requirement to remediate tc;>
background is found in other legal authorities. This remedy must"
continue until the following cleanup levels are obtained as
measured in the monitoring wells and the influent to the air
stripper:
TCE - 0.2 ug/l
Vinyl Chloride - 0.2 ug/l
cis - 1,2 Dichloroethylene - 0.2 ug/l
The point of compliance is throughout the contaminated plume.
In addition to the specific goals listed above, if any other
compound exceeds its MCL or non-zero MCLG, the remedy must
continue.
When these levels are obtained, annual testing for three years is
required to detect groundwater contaminant rebound.
Groundwater monitoring would" consist of sampling three wells
quarterly during the first year, then biannually until the first
five year review. .and annually afterward. The wells would be
placed at the boundary of the plume and in the area of highest
concentration. The exact placement of the monitoring wells will
be determined during the Remedial Design. The samples would be
analyzed for TCL organics and TAL inorganics.
FOllowing treatment, the water will be injected into the deep
mine pool. This will help maintain the hydrostatic equilibrium
in the Clarion formation to prevent "subsidence. Because the mine
pool covers over 1 square mile in area and the effluent discharge
would be approximately 92 gpm, no significant change in water
56
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level is expected to occur in the mine pool.
The water injected into the mine pool must comply with the PADER
Clean streams Law regarding discharge limits and federal
requirements regarding class IV well injection. .. This includes
frequency of sampling and concentration limits for discharges.
contaminant levels must be below MCLs prior to injection.
Additionally, the NPDES standards.. for treatment systems are
relevant and appropriate.
The state of Pennsylvania has required the use of "Best Available
Technology" to prevent the release of volatile organic
hydrocarbons to the air. The rate of emission of vinyl chloride
is expected to be extremely low ( less than one millionth of a
pound per hour). The most cost effective method to capture this
emission will be evaluated during the design of the remedial
action.
This alternative should be effective in remediating the
groundwater contamination in the Clarion Formation. Air""
stripping is expected to be effective in treating the vinyl
chloride that is present in the Clarion Formation (47 ~g/l
maximum - mine pool). The technologies and process options
associated with groundwater extraction, treatment, and discharge
are demonstrated and commercially available. The proposed
treatment scheme is capable of reducing contaminant levels to
below drinking water standards. Operation and maintenance of the
pumping system and treatment plant would be required. An permit
will not be required for discharging the treated groundwater into
the mine. void, since the discharge point will be onsite. The
discharged water will meet state standards and federal
requirements for class IV injection wells.
This alternative is a permanent solution and therefore meets the
EPA Groundwater Protection Strategy for a Class IIa aquifer.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives assembled for each of the five operable units
were evaluated based on the following nine criteria:
. Overall protection of human health and the environment.
. Compliance with all Federal and state applicable
relevant and appropriate requirements (ARARs).
. Reduction o~ toxicity, mobility, or volume.
. Short-term effectiveness. .
. Long-term effectiveness.
. Implementability.
. Cost.
. Community acceptance.
. state acceptance.
Table 1 describes the above criteria and a summary of the
relative performance of the alternatives with respect to each of
the nine criteria follows:
or
57
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TABLE 1
GLOSSARY OP EVALUATION CRITERIA
OSBORKE LANDFILL SITE
Overall Protection of Human Health and Environment
addresses whether or not a remedy wiili cleanup a
site to within the risk range; result in any
unacceptable impacts; control the inherent hazards
(e.g., toxicity and mobility) associated with a site
or operable unit; and minimize the short-term impacts
associated with cleaning up the site.
Compliance with ARARs addresses whether or not a
remedy will meet all of the applicable or relevant
and appropriate requirements of other environmental
statutes and/or provide grounds for invoking a
waiver.
. .*
Lveness and permanence refers to the
ability of a remedy te» maintain reliable protection
of human health and the environment over time once
cleanup goals have been met.
Reduction of toxicitv, mobility, or volume throi
treatment Is the anticipated performance oZ the
treatment technologies that may be employed in a
remedy.
Short-term effectiveness refers to the period of time
needed to achieve protection, and any adverse impacts
on human health and the environment that may be posed
during the construction and implementation period
until cleanup goals are achieved.
Implementability is the technical and administrative
feasibility of a remedy, including the availability
of materials and services needed to implement the
chosen solution.
Cost includes capital and operation and maintenance
costs.
State Acceptance indicates whether, based on its
review of the RI/PS and Proposed Plan, the State
M _ _ *. A L» -^.
concurs with, opposes,
preferred alternative.
or has no comment on the
community Acceptance will be assessed in the Record
of Decision following a review of the public comments
received on the RI/FS report and the Proposed Plan.
-------
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Solid Waste -(ODerable Unit 1)
Alternative 56 (offsite disposal) provides the greatest
protection to the public health and the environment at the site
because all of the contaminated fill material would be excavated
and taken" offsite to a licensed hazar~ous waste disposal
facility. Alternatives 57(onsite incineration/disposal), 59 (soil
washing/onsite disposal), and 511(thetmal stripping,
solidific~tion and onsite disposal) would offer a very high level
of protection also, since the wastes are treated to reduce the
mobility and toxicity of the wastes with the final disposal of
the treated fill material in an onsite RCRA landfill.
S5(excavation and disposal in an onsite subtitle C RCRA landfill)
provides more than adequate protection from the low toxicity fill
material. With proper construction and maintenance of the
landfill, the threat of contaminant migration to the underlying
flow systems should be eliminated. Additionally, direct contact
with the waste would be eliminated by implementing these--
alternatives since the wastes would be covered.
Alternative 512(slurry wall containment) also provides adequate
protection from the high volume relatively low toxicity fill
material. Alternative 512 will also eliminate any direct contact
with the solid waste since the waste will be capped. This
alternative leaves the waste in place (i.e., below the water
table) but sUbstantially reduces or eliminates the migration of
contaminants by. constructing an underground barrier around the
entire site. Additionally, groundwate~ pumping of the onsite
w~~er table will create a lower pressure inside the containment
than in the outside aquifer. Therefore, any leakage will be into
the containment, virtually eliminating any migration from the.
containment to the adjacent aquifers. Most of the water
initially in the containment would be removed and treated and tha
additional pumping and treatment of the groundwater will
gradually lower the toxicity of the fill. This alternative is
protective of human health and the environment considering the
relatively low toxicity of the wastes.
Alternatives 52 (soil cover), 53 (clay cap), and 54 (multimedia cap)
would result in the elimination of any direct contact with the
solid waste and would prevent migration of contaminants to the
wetland area, as with the other alternatives. However, migration
of contaminants from the disposal area to the underlying flow
systems would continue because no barrier would be constructed.
Containing the migration of contaminants to adjacent flow systems
would be possible by groundwater pumping (discussed later), which
would prevent the onsite water table from migrating either
horizontally or vertically.
Alternative 51 (no action) would result in no action at the site
and the risks to human health and the environment would remain
unchanged. This alternative is not protective of human health
and the environment.
59
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. -
Onsite Water Table (ODerable Unit.3}
Alternative G03 (treatment of ground water collected during
excavation) provides the greatest protection to the. public health
and environment since it results in the total remediation of the
onsite water table. Alternative G03 can only be implemented if
the wastes. are excavated or containe~ since. over one-half of the
waste is below the water table (e.g., wastes will have to be
removed or isolated from the water table in order to prevent
contaminant leaching).
The 512 (slurry wall containment) alternative will address the
onsite water table as an integral part of the alternative. This
remedy is protective of human health and the environment since
most ot the onsite water table will be removed and treated during
the first year of implementation of this remedy. The thirty
years of pump and treatment of ground water that leaks into the
containment will gradually reduce the remaining fill contaminants,
and prevent seepage from the onsite water table to the adjacent'
aquifers.
Alternative G02(plume containment by pump and treatment) provides
protection to the public health and environment by containing th~
flow system from migrating vertically or horizontally. This
alternative, however, would not result in the complete
restoration of the Class IIB flow system since it could only be
employed with alternatives that leave the waste in place (i.e.,
Alternatives 52 (soil cover), 53 (clay cap), and 54 (multimedia
cap».
Alternative G01(no action) does not provide adequate protection
to the public health and environment since no action (other than
groundwater monitoring) is performed. Under a no action
alternative, contaminants could potentially migrate from the
onsite water table to the Homewood and/or Clarion Formations.
Clarion Formation (ODerable Unit 41
Alternative GC3 (extraction and treatment of contaminated qround
water) provides the greatest protection to the public health and
environment because it will result in the complete restoration of
the formation (the solid waste is removed or contained and the
onsite water table is remediated). Alternative GC2 (plume
containment-pump .and treat) provides limited protection to the
public health since it will contain the plume from migrating
further offsite. Alternative GC2 would not restore the formation
since it would only be selected with an alternative that leaves
the waste in plac~. Thus, the waste would continue to leach to
the underlying flow systems.
Alternative GC1(no action)- provides no additional protection to
the public health and environment since no action is performed.
Risks to the public health and the environment would remain the
same. This alternative is not protective of public health since
60
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vinyl chloride levels are above MCLs.
COMPLIANCE WITH ARARs
Solid Waste CODerable Unit 1)
All alternatives, with the exception"of the no action alternative
(Alternative Sl - no action), would meet risk~pased action levels
"since""the waste would either be capped or landfilled, and the
exposure'pathway would be subsequently eliminated. Additionally,
TSCA guidance for allowable levels at a site with restricted site
access would be met for all alternatives since the averaqe
concentration of PCB at the site is less than 25 mq/kq. TSCA
quidance for a site with unrestricted site access (10 mq/kq)
would only be met by Alternatives S6 and S7. The state's
backqround cleanup level for qround water is an applicable ARAR,
but the PCB's are immobile and have not been detected in the
aquifers at the site. Additionally, EPA's Vertical/Horizontal..
spreadinq model predicts that the level of contamination in the
fill presents a risk to the offsi te Homewood aquifer at the
facility boundary less than 10-6. The risk levels in the
facility are hiqh enouqh: however, to require corrective action.
Desiqn of the landfill under Alternatives S5 (onsite disposal);-
S7(incineration/onsite disposal), S9(soil washinq/onsite
disposal), and S11(strippinq/solidification/onsite disposal)
would substantially meet the RCRA and PADER requirements for
landfillinq hazardous wastes althouqh the fill material is not
hazardous by definition.
Alternative S12 (slurry wall) includes a cap that meets PADER
requirements for municipal landfill closure. Alternative
S4(multimedia cap) would also meet these requirements that have
been identified by the state as an ARAR. Alternative S2 would not
meet this requirement. "
Landfill closure where wastes are left in place requires a RCRA
multimedia cap and qround water monitorinq for thirty years.
Cappinq Alternatives S2(soil cover), S3(clay cap) and S12(slurry
wall/clay cap) do not meet RCRA requirements for closure of
hazardous waste landfills. However, the primary purpose of these
alternatives, at this site, is primarily to prevent dermal
contact with the fill and not to prevent infiltration. Ground
water flows later-ally throuqh the fill so that leachinq would
still occur with' a cap in place. The PADER requirements for a
cap are primarily desiqned to prevent infiltration and leaching
of wastes that are capped. Since, the purpose is different, and
the wastes are not RCRA hazardous wastes, this requirement is not
an applicable ARAR and is not relevant and appropriate.
Alternative "S4(multimedia cap) does meet the site closure
requirements for cappinq RCRA wastes.
61
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Onsite Water Table (ODerable Unit 31
The Onsi te water table would be removed. and treated during the
implementation of the slurry wall alternative, but is considered
as an integral part of 512 and was not evaluated separately under
this operable unit. The slurry wall alternative will remediate
the ground water inside the containment as an integral part of
the Remedial Action. The pump and, treatment of ground water
inside the containment will continue until the ground water meets
EPA's' ground water protection standards for a' Class IIb aquifer
and the' state of pennsyl vania I s ground water cleanup standard"
(background).
Alternative G03 will result in the reduction of groundwater
contaminants to Federal and state standards. Alternative G02
could not meet these ARARs since this alternative does not
involve total remediation of the flow system, but rather
containment of the plume. Alternative G03 will also meet the
intent of the EPA Groundwater Protection Strategy for a Class IIb
ac;.-.:i.fer.
.
If G02 or G03 is implemented, the treated water will be injected
into the mine pool. This will meet the requirements of a Class
IV injection well under the Safe Drinking Water Act. The level
of contaminants will meet PADER and EPA requirements. '.
Clarion Formation (ODerable Unit 4)
Alternative GC3 will result in the reduction of groundwater
contaminants to Federal and State drinking water standards.
Alternative GC3 will also meet the intent of the EPA Groundwater
Protection strategy for a Class IIA aquifer. Alternative GC2
could not meet these ARARs since this alternative does not
involve total remediation, but rather containment of site
contaminants.
If GC2 or GC3 is implemented, the treated water will be injected
into the mine pool. This will meet the requirements of a Class
IV inj ection well under the Safe Drinking. Water Act. The air
stream from the stripper will use "Best Available Technology" to
reduce emissions from the stripper. .
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
THROUGH TREATMENT
Solid Waste lOcerable unit 1)
Alternatives that propose
(Alternatives 57-incineration,
solidification) would result
reduction.
treating
59-soil
in some
the solid waste
washing and 511-
degree of toxicity
Alternative 57 provides the greatest degree of toxicity reduction
since incinerating the solid waste could potentially remove over
99 percent of the organic contaminant level of toxici ty, but
62
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would not destroy the metal and inorganics present. The
principal threats at the site, are PCBs, and halogenated
hydrocarbons. The volume of waste would not be reduced and the
mobility of the metals would not be reduced.
Soil washing pilot studies only reduced PCB levels by about sixty
percent and produced large volumes of contaminated water
increasing" the volume of waste that would need to be treated.
The mobility of the remaining contaminants would be the same and
the volume of solid waste would not be reduced.
The solidification alternative 511 is not very effective for
organics and would require pilot or field tests for the large
volume of heterogeneous material present. The volume of waste
would increase but the mObility of the hazardous constituents
would be reduced. pilot tests or field tests would be needed to
determine the effectiveness of this alternative.
S12 - The slurry wall pump and treat alternative has a component..
of soil washing since the water in contact with the fill will be
removed and treated and since water will slowly seep into the
containment, absorb contaminants in the fill and will be
subsequently removed and treated. The speed of treatment,
however, is very slow and the primary goal of this alternative i~
containment, not treatment.
The other alternatives do not involve treatment.
Onsite Water Table (ODerable Unit 3)
Alternative G03 (collection and treatment) will result in a
reduction of toxicity, volume, and mobility of the groundwater
contaminants by physical and chemical treatment. Alternative G02
(plume containment) would result in some contaminant reduction,
but would not be capable of complete reduction since this
alternative would be employed if the solid waste is left in place
(below the water table). Alternative G02 would reduce the
transport of the contaminants through containment wells and would
treat the contaminants captured, but the .volume of groundwater
contamination would essentially remain the same.
Clarion Formation (Operable Unit 4)
Alternative GC3 (extraction and treatment) will result in a
reduction of toxicity, volume, and mobility of the groundwater
contaminants. Alternative GC2 (plume containment) would result
in some contaminant reduction, but would not be capable of
complete reduction since this alternative would be employed if
the solid waste .is left in place (below the water table).
Alternative GC2 would reduce the transport of the contaminants
through containment wells and would treat the contaminant
captured, but the volume of groundwater contamination would
essentially remain the same.
63
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SHORT-TERM EFFECTIVENESS
Solid Waste (Onerable Unit l)
Potential risks to the local residents and to the onsite workers
include exposure to site particulates generated .during the
construction activities. Alternatives that result in the waste
remaining in place provide less of a short. term risk than those
alternatives that result in excavating. the solid waste.
Excav.ation of the solid waste could potentially result in the
generati~n of more particulates. However, engineering measures
to reduce the amount of dusts generated during remedial
activities can be easily employed. Air monitoring will also be
employed during remedial action regardless of the alternative
selected (except the no action alternative).
,
Construction workers will be required to wear proper dermal
protection during site activities. Respiratory protection may
also be required for those alternatives that involve excavating
the sol id waste. . .
Al ternati ves that leave the waste in place can generally be
completed in less time than those alternatives that involve
excavation and treatment of the wastes. Some damage to the local
roadway (East Pine Street Extension) will probably result with
any of the alternatives (except no action) because of heavy
vehicular traffic.
The waterfowl o);>served in the wetland pond mayor may not be
effected by the onsite activities. Although no construction
activity will directly involve workers or construction equipment
in the wetland area, the nearby activity itself (noise, movement,
etc.) may cause the waterfowl to temporarily find another
habitat. On the other hand, in some cases construction
activities have caused no impact to wetland habitat during.
construction. Specific measures to prevent impacts on the
wetlands,will be developed during Remedial Design.
Onsite Water Table (Onerable Unit 3).
Clarion Formation (Onerable Unit 4)
These operable units were combined for this evaluation criterion
since the short-term effectiveness of the proposed alternatives
do not differ much between each operable unit. Regardless of the
alternative employed, there should be no unacceptable risk to the
local residents, based on the level of contamination detected to
date. Risks to the onsite workers would include direct contact
with groundwater during installation of monitoring, extraction,
of containment wells, and sampling of monitoring. wells and
treated effluents. Proper selection of protective clothing
should eliminate or reduce exposure to contaminated groundwater.
A health and safety plan will be prepared to identify potential
contaminants as well as construction risks associated with the
64
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groundwater remedial alternatives. The health and safety plan
will also identify the require~, protective clothing for the
various remedial activities. Alternatives that employ an ciir
stripper would employ "Best Available Technology" to capture
contaminants leaving the stripper in the air stream~
LONG-TERM EFFECTIVENESS
Solid Waste lOcerable Unit 1}
Alternative S6 provides the greatest amount of long-term
effectiveness, since the waste would be completely removed from
the site and potential contamination of the underlying flow
systems would no longer be a problem. Alternatives S7 and S11
would also provide long-term effectiveness since the level of
organic contamination would be significantly reduced and the
treated waste would be secured in an onsite landfill.
Alternatives that employ landfilling of the treated or untreated
waste (S5, S7, S9 and S11) would provide long-term effectiveness
if the landfill is properly designed, constructed and maintained. ".
Maintenance of the onsite landfill would be required, but this
should be minimal.
Containment alternatives (S2-Soil Cover, S3-Clay Cap, S4-
Multimedia Cap, and S12-S1urry Wall/Clay Cap) would provide a"
good degree of long-term effectiveness with proper construction
and maintenance, to prevent dermal contact with the fill. The
long-term effectiveness of containment option S12 is not much
different from the long-term effectiveness of the landfill
option. The landfill construction is .-designed to last for 30
years and provides positive containment of wastes, but is subject
to liner failure if subsidence occurs. It would be difficult and
expensive to repair this problem if it occurs. Successful
installation of a slurry wall containment is more difficult to
verify but can be maintained or repaired by grouting if defects
are detected. The construction methods that will be employed by
the- slurry wall installation will reinforce the supporting
structures in the adjacent mine making subsidence ~roblems much
less likely. The pump and treatment of the water in the slurry
wall containment will prevent leaching as long a the pumping
continues.
However, al ternati ves that invol ve only capping the waste are
less reliable with respect to the migration of wastes from the
solid waste to tqe underlying flow systems, since about half of
the fill is in the water table.
containment options must employ a groundwater containment option
to prevent migration of contaminants from the water table to the
adjacent flow systems. The long-term effectiveness is a function
of the maintenance of these systems. Alternative S12, proposed
employs groundwater containment to prevent offsite migration of
contaminants. Additionally, Alternative S12 includes a
subsurface barrier (slurry wall) to reduce the migration of
contaminants offsite.
65
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with the exception of Alter~ative 56 (Offsite Disposal),
groundwater monitoring would be employed to evaluate the
effectiveness of the solid waste' alternatives. The monitoring
we1ls would be installed in the water table, Cla~ion. Formation,
and Homewood Formation. .
Onsite Water Table (Operable Unit 3).
Clarion Formation lOcerable Unit 4)"
Two operable units have been combined for this evaluation
criterion since the long-term effectiveness of the proposed
alternatives do not differ much between each operable unit.
Groundwater alternatives that result in total remediation of the
flow system (G03 and GC3-extraction and treatment) provide the
greatest degree of long-term effectiveness. Following the
implementation of these alternatives (and the removal of waste
from the water table), the flow systems could be used as a source
of potable water. The treatment scheme proposed for the onsite
water table and Clarion flow systems would be effective in-
reducing contaminants to acceptable drinking water standards.
Groundwater monitoring would be required to ensure that the
treatment is effective.
Groundwater containment alternatives (G02 and GC2) provide lonq-
term effectiveness to some degree because they would prevent
further migration of the plume. However, they must be operated
indefinitely. The long-term effectiveness of these alternatives
is dependent on maintaining the containment wells and treatment
plant.
IMPLEMENTABILITY
Solid Waste (Ocerable Unit 1)
Implementation of Alternative 51 would be the easiest since it .
only requires repairing the site fence and posting warning signs
along the fence and other institutional controls. Capping
Alternatives 52, 53, and 54 are about equal. with respect to their
implementability. These alternatives should not be diffic\llt to
implement at the site since they only require regrading and
cappinq. Alternative 512, which also employs containment, will
be somewhat more difficult to implement effectively because of
the construction of the slurry wall around the site. The major
difficulty antic~pated with the installation of the slurry wall
will be alonq the eastern boundary of the site, where the slurry
wall will have to be constructed through 40 feet of shale and
sandstone next to a larqe mine pool. EPA convened a panel of
slurry wall experts to evaluate the implementability of this
alternative. Althouqh the installation will require extensive
measures to' isolate the mine pool, the panel believes that this
alternative is implementable. .
Alternatives which involve excavation of the solid waste
(55, 56, 57, 59, and 511) would be difficult to implement.
66
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. .
Although these alternatives may be more difficult compared to the
simple containment alternatives, they can be implem~nted using
standard construction methods. The lowering of the water table
during excavation and the sealing of the deep mine would be the
most. difficult tasks. The latter can be performed since
dewatering is a common practice in excavation practices. Sealing
of the flooded deep mine is also implementable and has been done
at other 'construction projects involving . flooded deep mines.
Storage of fill during construction'would pose some problems that
can be overcome by the proper engineering methods.
Alternatives S6, S9 and Sll may be the most difficult to
implement because they involve treatment of the waste prior to
placing the treated waste in an onsite landfill. Incineration
(employed in S6), soil washing (employed in Alternative S9) and
solidification (employed in Alternative S11) would be the most
difficulty since they require considerable handling of the
heterogeneous fill material. This fill is composed of foundry
sand "boulders", iron bars, wood, wire, miscellaneous scrap and
fine foundry sand. The foundry sand varied in composition from-
soil consistency to boulder several feet in diameter. These
"boulder would have to be broken up by some method before
treatment. Substantial quantities of metal and trash would need
to be separated from the sand and soils and cleaned. This
material could not be treated and would probably be disposed of
onsite. Small pieces of debris left in the fill could pose
processing problems to whatever treatment process was selected.
The limited site area would also impact the implementability of
these two alternatives since a considerable area would be needed
for the separation operations concurrent with draining the
excavated fill. .
Onsite Water Table (ODerable Unit 3)
Alternative G02 can be easily implemented. The technologies
proposed for treating the contaminated water table are
commercially available and proven. Alternative G03 will be more
difficult to implement since it involves lowering the water table
(and onsite ponds) during the excavation activities. ~he
treatment portion of this alternative is identical to
Alternative G02, and therefore can be easily implemented.
Lowering the groundwater will be implemented by using a
combination of subsurface drains, well points, and trenches.
These technologies, however, will be effective and have been
proven.
Clarion Formation (ODerable Unit 4)
Alternative GC2 involves the following: containment of the plume
via pumping wells: the treatment of contaminated groundwater via
air stripping: and injection of treated groundwater to the deep
mine. Technologies proposed for these two alternatives are
demonstrated and commercially available. Discharging the treated
groundwater into the flooded deep mine should not present a
problem due to the size of deep mine, which is approximately
67
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1 square mile in total area.
not be difficult to implement.
Therefore, this alternative should
-
Alternative GC3 should also be easy to implement. The only
difference between this alternative and the "containment"
alternative (GC2) is the rate of pumping and the fact'that GC2 is
associated with leaving the fill in place and GC3 is associated
with alternatives' that remove or isolate the fill from the water
table
All of. the al ternati ves proposed for these two operable uni t.s
are implementable.
C05T
...
501id Waste (Operable Unit 1)
Table 2 summarizes the capital, annual, and present worth costs
for each of the alternatives. The present worth costs for the
capping alternatives (Alternatives 52, 53, and 54) range from-.
approximately 1.3 million to 2.5 million dollars. The 51urry
Wall Alternative 512 is considered a containment alternative.
The present worth cost estimate for this alternative is
17 million dollars. The cost estimate for Alternative 512 also
includes the cost to remediate the onsite water table whereas the.
other containment alternatives only consider the solid waste
operable unit. The capping alternatives were generally lower in
cost when compared to the onsite disposal alternative
(Alternative 55, 10.8 million dollars) and much less expensive
than those alternatives that involve treatment as a component.
The present worth costs for the treatment al ternati ves ranged
from approximately 54 million to 87 million. The high cost of
the treatment alternatives which is based on the large volume of
material for which treatment is required (approximately
233,000 cubic yards).
The most expensive alternative is Alternative 56 (offsite
disposal) at over $100 million. This cost is hig.h because the
solid waste would be transported to a licensed hazardous waste
landfill in New York. The cost of landfilling waste at such a
facili ty is approximately $200 per ton of material. This cost
could escalate drastically if a large number of intact drums were
encountered. The transportation cost is also responsible for the
high cost of this alternative.
Onsite Water Table (Ocerable unit 3)
Al ternative G03 has an estimated present worth cost of
approximately 5.3 million dollars . Although the capital and
annual operating costs for Alternatives G02 and G03 are the
same, Alternative G02 has a higher Present Worth cost because the
duration of the remedial action for Alternative G02 is 30 years.
Alternative G03 can be completed in approximately 3 years, which
makes it less expensive.
68
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TABLE 2
SUMMARY OP ALTERNATIVES AND COSTS
OSBORNE LANDFILL SITE
GROVE CITY, PENNSYLVANIA
Altornativo Muabor
ad Doscriptioad)
SI - Vo Action
S2 -Soil Cower
S3 - Cl«y Cap
S4 - Multimedia Cap
SS - Onsite Disposal
S6 - Offsito Disposal
S7 - Oasito
Zaeiaoratioa
St - Soil Washing
Sll - Solidification
S12 - Clay Cap/Slurry
Wall/Grouadvator
puap and troat
Ml - Vo Aetioa
W2 - Oasito Disposal
*3 - Offsito Disposal
GO1 - »o Action
GO2 Coataiaaeat/
TroatMBt
GO3 - Collection/
TroatasAt
GC1 - »o Aetioa
GC2 - CoataiasNat/
Troataoat
GC3 - latraction/
TroatJMiat
Capital Cost
(I)
0
949,000
1,926,000
1,741,000
10,411,000
107,343,000
33,f37,OtO
62,140,000
91,000,000
$4,731,000
0
342,000
1,139,000
21,000
2,627,000
2,627,000
33,300
603,000
603,000
Aaaual Cost
(!)
0
30,000*
32,000*
32,000*
36,000*
0
36,000*
36,000*
36,000*
$670,000*
0*
0
0
12,000*
17,000
17,000
12,000*
7,000*
7,000
Prosoat Worth
Cost
(I)
41,000
1,367,000
2,461,000
2,282,000
10,793,000
104,770,000
34,022,000
39,999,000
7-, 392, 000
$16,976,000
36,000
342,000
1,139,000
71,000
17,994,000
9,321,000
277,000
1,992,000
1,703,000
An addition*! $20,000 to y«»r« 5, 10, 13, 20, 25, and 30 to
perform a 5-year review of- the alternative (per requirements
of SARA) is not reflected in the annual costs. Present
worth costs, however, take into account this cost.
-------
Clarion Formation (ODerable unit 4\
The no action alternative is the least expensive remedial action
to implement because it only involves groundwater moni~oring. As
shown on Table 2, Alternative GC3 has a slightly "lower Present
Worth cost than Alternative GC2. The reason for this has to do
with the total duration of the project. Alternative GC2 would be
operating for 30 years compared to only 20 years (or less) for
Al ternative GC3. . . .
COMMUNITY ACCEPTANCE
The majority of comments received by EPA at the public meeting
and during the comment period strongly favored the slurry wall
alternative (S12). The community is very concerned about the
financial impact of the remedy identified in the Proposed Plan
(S5-RCRA landfill) as stated in the proposed plan, on Cooper
Industries, a party who will be responsible for performing or
financing the remedy. This company is one of the largest..
employers in the area. Residents adjacent to the site also
favored the slurry wall remedy because it would involve much less
excavation and the resulting potential exposure to wastes that
accompanies an excavation remedy.
. .
STATE ACCEPTANCE
The State's comments were limited to the slurry wall remedy S12,
the RCRA landfill, the contamination of the aquifers and the pump
and treat remedial actions. The state's comments on the Proposed
Plan, dated October 12, 1989, expressed concerns about the
contamination of the deep aquifers. EPA' s Groundwater
Verification Study will address those concerns in a separate ROD
that will be issued after a focused RI/FS has been completed.
The letter also expressed a maj or concern about the lack of
treatment of the fill material if the landfill or the slurry wall
al ~'=rnative was implemented.. EPA' s Interim Final ROD guidance
(June 1989 OSWER Directive 9355.3-02) indicates that
containment remedies are appropriate for large sites that have
contamination marginally above health based limits or large sites
with widely dispersed contaminants mixed with debris. The
Osborne landfill has both of these characteristics. The state was
concerned about technical problems related to implementation of
the RCRA landfill including subsidence, discharge to the mine
pool, disposal o£.drums of concentrated wastes and the permanence
of the alternative. This ROD addresses the state's major
concerns listed in their letter.
The State also sent EPA a letter, dated December 7, 1989, that
identified. state ARARs. . This letter listed technical
requirements for the landfill alternative and requested more
detailed study and state review of issues such as subsidence
discussed in the state's previous letter to EPA. EPA has
addressed these concerns in the ARARS section of this ROD and in
the modified description of each affected alternative. One new
condition for instance, is a limitation on mining within 1/2 mile
70
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of the site. The State also requested that "Best Available
Technology" be utilized on any air strippers. EPA will comply
with this ARAR. The State al~o identified ground water .to
background levels as an ARAR.. EPA. considers cleanup of
groundwater to background to be an applicable ARAR.
Since a long period of time passed since the Proposed Plan was
issued, EPA requested an ARARs update from. the State. The ARAR
that was emphasized by the State was the cleanup of ground water
to background level. The Pennsylvania ARAR for groundwater for
hazardou~ substances is that all ground water must be remediated
to "background" quality as specified by 25 Pa. Code Sections
264.90 - 264.100, and in particular, by 25 pa. Code Sections
264.97(i), (j) and 264.100(a)(9). The Commonwealth of
Pennsylvania also maintains that the requirement to remediate to
background is found in other legal authorities.
The goal of this remedial action is to restore ground water to
its beneficial use, which is, at this site, used as a drinking
water source. Based on information obtained during the remedial--
investigation and on a careful analysis of all remedial
alternatives, EPA believes that the selected remedy will achieve
this goal. It may become apparent, during implementation or
operation of the ground water extraction system and its
modifications, that contaminant levels have ceased to decline and
are remaining constant at levels higher that the remediation goal
over some portion of the contaminated plume. In such a case the
system performance standards and / or the remedy may be
reevaluated.
The Commonwealth of Pennsylvania has reviewed the RI/FS and this
ROD and concurs with the Selected Alternative.
SELECTED REMEDY
Rationale for selection of Remedv
A slurry wall containment (S12) or a RCRA subtitle C landfill
(S5) would satisfy the threshold criteria for Overall Protection
of Human Health and the Environment because of the low to
moderate risks posed by the fill. EPA's Prooosed Plan listdd the
RCRA landfill as the oreferred alternative: however. EPA received
comments from the oublic which stronalv suoDorted the 3lurrv wall
remedv. Addi tionally, EPA convened a panel of slurry wall
experts to review Alternative S12, and their review supported the
selection of the slurry wall alternative and identified
additional problems regarding successful installation of the
landfill alternative (S5). This is discussed in more detail in
the Description of Alternatives section above.
EPA has considered the modifying criteria of
Acceptance, and the new technical information obtained
slurry wall review to change its preference and select
wall alternative. This is acceptable to the
Pennsylvania if the landfill is included in the
community
during the
the slurry
state 0 f
ROD as a
71
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continqency remedy.
Five operable units have been identified at the Osborne Landfill
site in the Feasibility Study., These operable units (OU)
include:
.
. The solid waste fill material (OU1)
. Wetland sediments (OU2)
. The onsite water table (OU3) "
. The Clarion Formation (OU4)
~ 'T~e Homewood Formation (OU5)
Remedial alternatives have been selected for the above operable
units with the exception of the Wetlands Sediments (OU2) and
Homewood Formation (OU5) . Because the extent and degree of
contamination in the Homewood Formation is not clearly defined,
and it is a source of potable water in the local area, a
Groundwater Verification study (GVS) will be conducted subsequent
to this Record of Decision (ROD). Two other flow systems, the
Connoquenessing and Burgoon Formations, will also be investigated.
as part of the GVS since they are a source of water for the Grove
City Borough Water Authority. These two flow systems exhibited
low levels of vinyl chloride at or slightly below the Maximum
contaminant Level (MCL) of 2 ppb within the study area. The GVS
will include re-sampling of selected existing monitoring ano
residential wells, the installation of one or more wells between
the Osborne Landfill Site and the Water Authority's pumping wells
and possibly strategically placed wells between the site and
potential areas of development in the Homewood aquifer. The GVS
will also require additional wells to define the vinyl chloride
plume in the mine pool associated with the Clarion Formation.
This is a potentially severe threat to public health at the site.
After completion of the GVS which will serve as a focused RI/FS,
EPA will issue a ROD for these operable units.
The selected remedial
units are:
alternatives
for the
remaining
operable
. operable Unit 1 (The Solid Waste Fill'Material):
primary Alternative
Onsite Water Table)
S12
(Slurry
Wall/Pump
and
Treat
contingency
Disposal)
. Operable Unit 3 (The Onsite Water Table):
Alternative 55 (Excavation
and
Onsite
primary - No a~ditional action necessary
Contingency Alternative G03 ( Collection,
Physical/Chemical Treatment, and Onsite Injection)
. Operable Unit 4 (The Clarion For~ation):
72
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Alternative GC3 ( Extraction', Physical Treatment , and
onsite Injection) .
operable Onit 1 Solid Waste rill Material
Primary RemedY
Slurry Wall/PumD and Treat Alternative
Alternative S12 - This alternative consists of construction of a
slurry wall barrier around the perimeter of the fill and
construction of a clay cap. At the bottom of this containment is
a naturally occurring clay layer. Water will be pumped out until
a negative pressure is obtained, effectively containing the fill
contaminants and removing the threat to groundwater from leaching
of the fill. material contaminated with PCBs, VOCs, metals and
PAHs.
The two foot thick clay cap will prevent dermal contact with PCB
contaJTIinated foundry sand. The purpose of the cap is not to
prevent leaching through the waste but to prevent dermal contact
and to limit the amount of water that must be removed and treated
to maintain the proper negative containment pressure. Overland
transport of foundry sand to the wetlands area will also be
eliminated by the clay cap.
The major components of this alternative include:
. Runon controls (the intermittent influent stream will be
diverted to a 3-acre offsite pond).
. Grouting and bulkheading techniques will be used to seal
openings or cracks linking the fill to the mine pool.
. Construction of a slurry wall around the perimeter of the
fill area and installation of a clay cap and revegetation.
. Installation and operation of extraction wells to lower the
water table with treatment of the extracted water and
subsequent injection into the onsite mine pool.
. Institutional controls
. Groundwater monitoring
Continqency RemedY
Alternative 55 (Excavation and Onsite Disposal)
This
alternative
would
prevent
hU-r.\an
exposure
to
site
73
-------
contaminants because the solid waste would be excavated and
secured in an onsite landfill. ~he design of the landfill would
meet both the PADER and RCRA criteria for construction and site
closure. Because the waste would no .longer be in contact with
the water table flow system, no further leaching or migration of
site contaminants to the water table or other f16w systems are
expected to occur. Additionally, overland transport of
contaminants to the adjacent wetland would be eliminated because
the wastes would no longer be exposed to surface runoff. The
major. components of this alternative includei .
.
. Elimination of onsite ponds via regrading.
. Runon controls (the intermittent influent stream would be
diverted to the 3-acre offsite pond).
. Excavation of approximately 233,000 cubic yards
waste.
of solid
. Placement
landfill.
of
solid
waste
in
a
RCRA
Subtitle C
onsiteo.
. Regrading and revegetation of the site area.
.
Institutional Controls.
i
I .
. Long-term groundwater monitoring.
ODerable Unit 3 - Onsite Water Table
Primary Remedy
No additional action is necessary since S12 (Slurry wall/Clay
Cap/Pump and Treat) will extract and treat most of the water ir.
contact with the fill and will continue to treat the water tha~
infiltrates the containment.
o.
Continqency RemedY
:
Alternative G03 (Collection.
Onsite In;ection)
Physical/Chemical
Treatment.
and
This alternative would eliminate a source of contamination (the
conta~inated water table) because the site would have to be de-
:.;atered during the excavation of the sol id waste (see
Al ternati ve S5). Dewatering of the site would be required to
excavate the waste since over one-half of the waste is situated
below the nater table. By collecting, treating, and discharging
the water table flow system, future potential migration of
groundwater contaminants would be eli~inated. Additionally, this
alternative is a permanent remedy and would satisfy the
Groundwater Protection Strategy for a Class IIB aquifer. Once
the site is de-watered and the !~;aste is placed in an ons1 t~
74
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landfill, the water table would be allowed to retain equilibrium.
Since the intent of this alternat~ve is to construct the landfill
above the natural water table, no contaminant leaching iri~o t~is
flow system would occur with proper maintenance and
design/construction of the onsite landfill. The major components
of this alternative include:
. Coll~ction of the water tabl~- (or dewatering of the site)
during excavation activities via well - points, subsurface
--drains, and trenches. ---
. Isolation of the fill area from the onsite mine pools (the
mine pools and the onsite water table are hydraulically
connected) .
. Groundwater treatment (solids removal via equalization,
clarification, and sand filtration, and organics removal
via carbon adsorption).
Cnsite discharge (injection) into a flooded deep mine to
maintain the existing hydrostatic pressure in the mine.
. Groundwater monitoring.
Operable Unit 4 - Clarion ~quifer excluding the deep mine 0001
Alternative GC3 (Extraction, Physical Treatment, and Onsite
Injection) will reduce the level of contamination in the Clarion
Formation and reduce human health risks - associated with the
future potential use of this flow system. (At the present time,
no residential wells are impacted by contamination in this
formation due to their location.) Because the source of
contamination will be eliminated by implementing Alternative S12
, this alternative can be considered a permanent remedy upon
cc .-lete restoration of the Clarion Formation. This alternative
wi_. also meet the objectives of the Groundwater Protection
Strategy for a Class IIa aquifer. The major components of this
alternative include:
Construction of extraction wells in the Clarion Formation
downgradient from the disposal area where the highest
levels of contamination have been detected.
. PU!':lping of '-groundwater to an onsite treatment plant
treatment via air stripping and treatment of the
jischarge with Best Available Technology. -
for
alr
. Injection of treated groundwater onsite to a flooded dee~
. ~ine, ~hich is part of the Clarion Formation~
. Groundwater monitoring
this alternative.
to
evaluate
the
effectiveness
c:'
75
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If implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence that it
will be technically impracticable to achieve and maint.ain .the
remediation goals throughout the area of attainment, the EPA, in
consul tation with the Commonwealth of pennsyl vania, . intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals.
STATUTORY DETERMINATION
section 121 of SARA requires that the selected remedy:
. be protective of human health and the environment:
. attain ARARs (or explain rationale for invoking a waiver);
. be cost-effective:
. utilize permanent solutions and alternative treatment-
technologies or resource recovery technologies to the
maximum extent practicable: and
. address whether the preference for treatment that reduces
toxicity, mobility, or volume as a principal element is
satisfied.
A description of how the selected remedies satisfy each of the
above statutory requirements is provided below.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative S12(Slurry Wall - Primary Alternative) will eliminate
the known human health exposure pathways that exist at present.
No unacceptable short-term risks to the community or onsite
workers exist that could not be controlled by engineering
practices during the remedial action. This alternative will
virtually eliminate the ongoing leaching of contaminants from the
fill material to the underlying flow systems, since a negative
pressure will be maintained inside the slurry wall containment.
EPA uses the vertical and Horizontal Spreading (VHS) model to
estimate how contamination concentrations decrease with distance
from an area of contamination. The risks' at the site are
relatively low and the VHS' model predicts, at the facility
border, a less that 10-6 risk from ground water contaminated by
the uncontained' 'fill material. The VHS model cannot, however,
consider the very complex hydrogeology at the site. The clay cap
will prevent dermal contact with contaminated foundry sands.
Alternative S5 (RCRA landfill contingency alternative) would
eliminate any human health exposure pathways that exist at
present. No unacceptable short-term risks to the community or
onsite workers exist that could not be controlled by engineering
practices during the remedial action. Alternative S5 would also
el iminate the ongoing leaching of contaminants from the f i 11
76
-------
material to the underlying flow systems,
be excavated from the water table and
.' landfill.
since the wastes would
secured in an . ons i t.e
Alternative G03 (required by contingency alternative - landfill)
would result in the complete restoration of the onsite water
table. Although the onsite water table is not used as a source
of potable water in the local area, it. is hydrologically
connected with the Clarion and Homewood Formations which are used
by some residents in the local area. Once this flow system is.
remediated, the water table in the local area could potentially
be used for other purposes such as irrigation. Also, the water
table discharges to the wetland area, and implementation of
Alternative G03 will be protective of the environment.
Alternative GC3(extraction and treatment) will result in the
complete restoration of the Clarion Formation, which is used in
the local area by residents as a source of potable water.
Al though no residential wells in this formation have indicated
contamination, future development of land near the site is-'
probable. Several homes are under construction in the area.
Therefore, this alternative is protective of public health for
future potential scenarios. Additionally, remediation of the
Clarion Formation via Alternative GC3 will prevent potential
migration of contaminants to unaffected residential wells. ..
No unacceptable short-term risks or cross-media impacts will be
caused by implementation of the remedy.
ATTAINMENT OF ARARs
RCRA Land Disposal Restriction - The Osborne Landfill accepted
many different wastes during the long time period of its
operation. The landfill closed in 1978, before the effective
date of the RCRA regulatory program (November 19, 1980). Wastes
disposed prior to such' date are not regulated under RCRA unless
they are excavated and subsequently treated, stored or disposed
of. Since the slurry wall remedy will not involve any placement
of wastes, the RCRA land ban requirements do not apply to the
primary remedy, S12 - slurry wall containment.
The material placed in the landfill was primarily foundry sand
that is not regulated as a subtitle C waste under RCRA. This
material can be disposed of in a residual waste landfill in
Pennsylvania. The material consists of primarily sand with a
light coating of "soot like" polyaromatic hydrocarbons similar to
those found in the asphalt used in roads and found in coal. The
coating contains low levels of metals from the foundry
operations. EPA considers this material to be "soil like". This
material is also mixed with steel scrap wire and other debris.
Many other industrial wastes were disposed of in the landfill by
Cooper Industries. Although definitive proof of disposal. of
listed wastes has not been identified, it is possible that some
of these "pre - RCRA" wastes would be considered listed wastes if
77
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more information were available. Undefined solvent wastes
aci~s, lubricating oils and p1ati~g wastes were all disposed of
prior to the effective date of the RCRA. Current 'solvent
contamination levels are very low and the volume of wastes very
large (233,000 cu. yds). EPA does not consider, the land ban
applicable to the fill material.
The AgencY is undertaking a rulem~king that will specifically
apply to soil and debris. Since 'that rulemaking is not yet
complete, EPA does not consider LOR to' be relevant and
appropriate at this site to the soil and debris (fill) that does
not contain RCRA restricted wastes. This is discussed in detail
in the fOllowing memo: "Land Disposal Restrictions as Relevant
and Appropriate Requirements for CERCLA contaminated Soil and
Debris. ", from Henry L. Longest to Directors of Hazardous Waste
Manaqement Divisions, and dated June 5, 1989.
-
EPA also does not consider the Land Disposal Requlations to be
relevant and appropriate for the treated qround water that will
be injected into the deep mine pool. The basis for this decision-
is contained in Oswer Directive # 9334.1-06. This memo from Don
R. Clay and dated Dec. 27, 1989 states that MCLs or risk based
levels should qovern treated qround water,and that the RCRA Land
Ban requlations are not relevant and appropriate for Remedial
Actions under CERCLA. "
Ooerable unit 1 - Fill Material
Primary Alternative S12(Slurry Wall/Pump and Treat) will attain
the followinq ARARs:
ARARs identified by
Environmental Resources
the
pennsvlvania
DeDartment
of
A. Chapter 269, Sections 269.13 and 269.41 269.50 of the
Pennsylvania Hazardous Waste Management Regulations-Hazardous
Waste Sitinq criteria. Althouqh the wastes at the site are not
hazardous by definition, EPA considers the followinq specific
requlations from this section to be relevant and appropriate:
These criteria provide for DER review of pre-design and remedial
desiqn information to assess the probability and deqree of
possible subsidence. Additionally, removal of minerals providing
structural support at the site is prohibited.
B. If containers of hazardous waste or excavated hazardous
wastes are manaqed onsite, during construction activities,
Chapter 264, Subchapters I and L would be applicable.
C. If any hazardous waste discovered or generated on-site and
transported off-site for treatment, storaqe or disposal should be
managed pursuant to Chapters 262(qenerators), 263(transporters),
and 264 (hazardous waste manaqement facilities, if those
facilities are located in the state) or if not, managed pursuant
the requlations of the state receiving this waste. Waste
excavated for offsite manaqement should be identified as required
78
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in chapter 261, subchapter C or D as appropriate.
applicable.
D. . section 273.29 of the DER Municipal Waste Regulations are
applicable. This section relates to coal 'removal, mine
discharges and subsidence.
This ARAR is
E. pennsylvania NPDES requirements (Chapter 92 of the
pennsyl vania DER Rules and regulations: . Toxics Management
strategy~ . These requirements regulate surface water discharges.,
F. Chapter 127 of the Air Quality Regulations requires the use of
Best Available Technology for control of new emissions sources.
G. The Pennsylvania Clean Streams Law, PA Code Title 25, and the
Solid Waste Management Act, 25 PA Code 260, have been cited as
the basis for cleanup levels to background levels for ground
water. The Pennsylvania ARAR for groundwater for hazardous
substances is that all ground water must be remediated to..
"background" quality as specified by 25 Pa. Code Sections 264.90
- 264.100, and in particular, by 25 Pa. Code sections 264.97(i),
(j) and 264.100(a)(9). The Commonwealth of Pennsylvania also
maintains that the requirement to remediate to background is
found in other legal authorities. EPA considers the cleanup.
level of ground water to be applicable at this site.
H. Chapter 105 of the Dam Safety and Waterway Management Rules
and Regulations. This applies to stream relocation and any other
stream encroachments during site remedi~~ion.
I. 25 PA Code, Chapter 89 of the PADER rules and regulations as
it applies to subsidence and hydrogeologic balance.
ARARs Identified bv EPA
. RCRA Subtitle C, Hazardous Waste Management Requirements,
25 PA Code 264, which govern the transportation, treatment,
storage, and disposal of hazardous' wastes (this is a
relevant and appropriate ARAR since by definition, the
solid waste is not hazardous).
. Toxic Substances and Control Act (TSCA) of 1976, 40 CFR
Part 761, which establishes regulations for disposal and
storage of PCB-contaminated materials (this is an relevant
and appropriate ARAR since the solid waste is contaminated
with PCBs from an unknown source).
. Underground Injection Control Program 40 C.F.R. 144-148
. Pennsylvania Solid Waste Disposal Regulations, PA Code,
Title 25, Chapters 260 -264), which govern the generation,
transportation, storage, and disposal of hazardous waste
(this is an applicable ARAR ).
79
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. Pennsylvania storm Water Management Act, Act 167, which
requires measures to control storm-water runoff"during
development or alterations of land. This ARAR will be
applicable to the site remediation activities.
. Pennsylvania Erosion Control Regulations, PA Code,
Title 25, Chapter 102, which govern erosion and
sedimentation control resulting from 'remedial actions that
may involve earth-moving acti vi ties. , This ARAR is
"applicable to the regrading and excavation activities
associated with this alternative.
. The Occupational Health and Safety Act (OSHA), (29 CFR,
Parts 1904, 1910, and 1926, which provide occupational
safety and health requirements for workers engaged in
onsite field construction or operation and maintenance
activities. This ARAR is applicable to this alternative.
. .
Continqency Alternative: S5 (RCRA subtitle C landfill)
ARARs Identified by
Environmental Resources
the
PennsYlvania
Department
of
A. Chapter 269, Sections 269.13 and 269.41-269.50 of the
Pennsylvania Hazardous Waste Management Regulations-Hazardous
Waste Siting Criteria. Although the wastes at the site are not
hazardous by definition (RCRA), EPA considers the following
specific regulations from this section to be relevant and
appropriate: These criteria provide for DER review of pre-
design and remedial design information to assess the probability
and degree of possible subsidence. Additionally, removal of
minerals providing structural support at the site is prohibited
to the extent that this could affect the remedy.
EP~ considers the siting criteria for new hazardous waste
la.~.jfills to be relevant and appropriate. If the slurry wall
alternative is not successful, EPA will apply for a waiver of
the Pennsylvania exclusionary siting criteria for landfills at
that time.
B. The state requirements for design, construction, operation
and maintenance, ground water monitoring, preparedness and
prevention, closure, post-closure, reporting and other criteria
set forth in Chapter 264, Subchapters A through G for new
hazardous waste disposal facilities are relevant and appropriate.
If containers of hazardous waste or excavated hazardous wastes
discovered during excavation and are managed onsite, during
construction activities, Subchapters I and L would be
applicable. The design criteria for PA Municipal Waste
Regulations (Chapter 75, sections 273.251-264) that are more
stringent than PA hazardous waste regulations are applicable. A
30 mil bottom liner would be required to meet this regulation.
The following municipal waste regulations would also be
applicable at the site: Section 273.242 (erosion and
80
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sedimentation control), sections 273.281-288 (Water
monitoring) and Section 273.259 (construction criteria).
C. Any hazardous waste generated on-site and transported off-
site for treatment, storage or disposal should be managed
pursuant to Chapter 262(generators), 263(transporters), and
264 (hazardous waste management facilities;if those facilities are
located in the state). Waste excavated for offsite management
should be identi f ied as required in Chapter 26,1, Subchapter C and
D as 'appropriate. This ARAR is applicable.
quality
D. Section 273.29 of the DER Municipal Waste Regulations is
applicable. This section relates to coal removal, mine
discharges and subsidence. section 273.120 is applicable and
requires a subsurface survey to determine the impact of
subsidence.
E. Pennsylvania
Pennsylvania DER
Strategy) .
NPDES
Rules
requirements (Chapters 91 of the
and regulations; Toxics Managemen~.
F. Chapter 127 of the Air Quality Regulations requires the use of
Best Available Technology for control of new emissions sources.
G. The Pennsylvania Clean Streams Law, supra, and the Solid Waste
Management Act, supra, have been cited as the basis for cleanup
levels to background levels ground water. The Pennsylvania ARAR
for groundwater for remediation of hazardous substances is that
all ground water must be remediated to "background" quality as
specified by 25 Pa. Code Sections 264'.90 - 264.100, and in
particular, by 25 Pa. Code Sections 264.97(i), (j) and
264.100(a)(9). The Commonwealth of Pennsylvania also maintains
that the requirement to remediate to background is found in other
legal authorities. EPA considers the cleanup level of ground
water to be relevant and appropriate at this site.
H. Chapter 105 of the Dam Safety and Waterway Management Rules
and Regulations. This applies to stream relocation and any otper
stream encroachments during site remediation.
I. 25 PA Code Chapter 89 of the PADER rules and regulations as
it applies to subsidence and_hydrogeologic balance.
ARARs Identified bv EPA
. RCRA Subtitle C, Hazardous Waste Management Requirements,
40 CFR 264, which govern the transportation, treatment,
storage, and disposal of hazardous wastes (this is a
relevant and appropriate ARAR since by definition, the
solid ,waste is not hazardous).
. Toxic Substances and Control Act (TSCA) of 1976, 40 eFR
Part 761, which establishes' regulations for disposal and
storage of PCB-contaminated materials (this is relevant and
appropriate ARAR since the solid waste is contaminated with
81
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PCBs from an unknown source).
. Pennsylvania Solid Waste D1sposal.. Regulations, PA Code,
Title 25, Chapters 260 - 264)i which govern the generation,
transportation,. storage, and disposal of hazardous waste
(this is a Relevant and Appropriate ARAR). .
. Pennsylvania Storm Water Man?lgement . Act, Act 167, which
requires measures to control' storm-water runoff during
'development or alterations of land. This ARAR would be
applicable to the site remediation activities. .
. Pennsylvania Erosion Control Regulations, PA Code,
Title 25, Chapter 102, which govern erosion and
sedimentation control resulting from remedial actions that
may involve earth-moving activities. This ARAR is
applicable to the regrading and excavation activities
associated with this alternative.
..
. Underground Injection Control Program 40 CFR 144-148
. The Occupational Health and Safety Act (OSHA), (29 CFR,
Parts 1904, 1910, and 1926, . which provide occupational
safety and health requirements for workers engaged in
onsite field construction or operation and maintenance
activities. This ARAR is applicable to this alternative.
EPA considers ground water cleanup levels of background to be an
ARAR: however, it should be noted that PCBs have not migrated
into the aquifers and therefore are already at background "levels
outside of the fill.
ODerab1e Units 3 and 4
The fOllowing ARARs have been identified for Alternatives G03
(collection and treatment of the onsite water table), GC3
(extraction and treatment of the Clarion aquifer) and the
groundwater treated as an integral part of S12 (the slurry
wall/pump and treat alternative).
ARARs identified bv
Environmental Resources
the
PennsYlvania
DeDartment
of
..
A. Pennsylvania NPDES requirements (Chapters 91 of the
Pennsylvania DER Rules and regulations: Toxics Management
strategy). These requirements regulate surface water discharges.
B. Chapter 127 of the "Air Quality Regulations requires the use of
Best Available Technology for control of new emissions sources.
C. The Pennsylvania Clean streams Law, supra, and the Solid Waste
Management Act, supra, have been cited as the basis for cleanup
levels to background levels for ground water. The Pennsylvania
82
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ARAR for groundwater for hazardous substances is that all ground
water must be remediated to "backg~ound" quality as specified by
25 Pa. Code Sections 264.90 - 264.100, and in particular," by '25
pa. Code Sections 264.97(i), (j) and 264.100(a)(9). The
Conunonwealth of Pennsylvania also maintains that the requirement
to remediate to background is found in other legal authorities.
EPA considers the background cleanup level of ground water to be
applicable' at this site. '. .
ARARs Identified bv EPA
. The Safe Drinking Water Act, 40 CFR Part 141 and Part 143,
which identify enforceable standards (MCLs) and
nonenforceable standards (secondary MCLs) for contaminants
in a public drinking water supply system. This ARAR is
applicable since these flow systems (near the site) can be
used as a source of potable water.
. EPA Ambient Water Quality Criteria (AWQC), which are
nonenforceable standards for protection of human health. .
from exposure to contaminants in drinking water as well as
the consumption of aquatic biota. This ARAR is releva~t
and appropriate since treated groundwater will be injected
back into the formation.
. Pennsylvania Wastewater Treatment Regulations, PA Code,
Title 25, Chapter 95, which regulate water quality and
include treatment requirements and effluent limitations
based on the best practical control technologies. This
ARAR is "applicable" to the treatment of wastewater
proposed under Alternative G03 and GC3 and S12. "
. The Clean Water Act (CWA) 33 U.S.C. 1251, as
governs point-source discharges through the
Pollutant Discharge Elimination System (NPDES).
is applicable.
. Underground Injection Control Program 40 C.F.~. 144-148
amended,
National
This ARAR
. The Occupational Health and Safety Act (OSHA 29 !J.S.C.
651), (29 CFR, Parts 1904, 1910, and 1926, which provide
occupational safety and health requirements for workers
engaged in onsite field construction or operation and
maintenance activities. This ARAR is "applicable" to both
groundwater. alternatives.
To Be Considered
. EPA Health Advisories, which are nonenforceable guidelines
that may be encountered in pUblic water supply systems.
Heal th advisories cover those contaminants that are not
regulated by the SDWA (some PAH compounds are not regulated
by the SDWA). This ARAR is " to be considered" since these
flow systems (near the site) can be used as a source of
potable water.
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. EPA' s Groundwater Protection Strategy. This -policy was
formed to protect groundwater for' its highest present or
potential beneficial use.
COST-EFFECTIVENESS
The alternatives selected for the three operaple units afford a
high d'egree of overall effectiveness in not only protecting human
health, but also the protection of the environment (wetlands and
groundwater) . The EPA has determined that the costs of the
selected remedies are proportional to the overall effectiveness
it affords to protecting the public health and environment.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATE
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
TREATMENT
The selected alternatives for the fill material, Alternative S12..
(Slurry Wall/Pump and Treat) and Alternative S5 (RCRA landfill),
are containment remedies that do not involve significant
treatment of wastes. The extremely high costs of the treatment
alternatives for the large volume of wastes that pose relatively
low risks to the public are inappropriate. The primary,
alternative, the slurry wall/pump and treat remedy, will contain
fill contaminants as long as necessary. Over a very long time
period (30 years or more) the most mobile contaminants will be
removed and treated. The concentration of PCBs will also decline
eventually to levels that do not pose a threat to human health
and the environment. The RCRA double lined landfill also ,offers
a high degree of long term effectiveness for the low level of
contamination in the fill material. EPA has determined that the
selected remedies represent the maximum extent to which
permanent solutions and treatment technologies can be utilized
in a cost effective manner OU1 (fill) at the Osborne site.
These alternatives are protective, implementable, and cost
effective. They are also consistent with current EPA's Interim
Final, ROD Guidance (OSWER Directive 9355.3-02) which recomme~ds
containment remedies for sites with large 'volumes-of waste that
is contaminated marginally above health based limits or large
sites with heterogeneous wastes. The Osborne Landfill exhibits
all of these characteristics.
Alternatives G03 (Collection and Treatment of the Onsite Water
Table) and GC3 (Collection a~d Treatment of the Contaminant Plume
in the Clarion Aquifer) are permanent solutions that involve
treatment of the principal threats present in the ground water at
the site.
PREFERENCE FOR TREATMENT THAT REDUCES
TOXICITY, MOBILITY, OR VOLUME
Alternatives S12 and S5 do not satisfy this statutory preference.
Treatment technologies were not determined to be practicable/and
or cost effective, based on the large volume of waste material
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and the moderate risks posed by the site. Several treatment
technologies were considered, but"were not selected.
If ,cost effectiveness, as related to risk reduction, was not a
consideration, the following remedy might be appropriate:
a) incineration would destroy the organics in the fill at a cost
of about 49 million dollars; stabilization would immobilize the
metals in the fill at a cost of about 11 million dollars and
placement in a RCRA landfill at a cost of 11 ,million dollars to
satisfy state requirements. The average baseline risk of contac~
with the' fill is 'within EPA's acceptable risk range and the
Remedial Action at this site is taken primarily to protect
offsite ground water. The total cost of this hypothetical remedy
of 71 million dollars is not justified by the risk posed by the
fill.
Every treatment technology would require significant material
handling, pre-treatment, and post-treatment of wastes. The fill
at the Osborne site contains drum fragments, municipal debris and.
foundry sand boulders. Pre-treatment such as screening,'
segregation and removal of larger objects would be necessary.
Soil Washing: A treatability study was performed that reduced
PCB levels by approximately 62% and PAHs by about 29-40 %. Even
after treatment, the levels would still be high enough to require
subsequent containment of the washed fill and would generate
large amounts af water and some sludge that would need to be
stored, treated and discharged. The consistency of the fill would
make processing difficult. The cost of this alternative is about
66 million dollars.
Incineration: This has the potential to reduce all organic
contaminants to acceptable health based levels for carcinogens
but would not address the inorganic contamination in the fill.
The consistency of the fill would make processing difficult and
th~ volume of waste would not be reduced. The residual material
re:.:..dning after incineration would have to be contained or
treated because of its hazard index. The metals content of the
fill was relatively high and most of the metals would remain in
the fill after treatment. The cost of this alternative would be
about 60 million dollars. '
Bioremediation: This technology was screened out early by the
Feasibility Study. The biological treatment would not address
inorganic contamination in the fill which produced the relatively
high hazard index (0.8 average, 4.0 maximum). Bioremediation may
address the PAHs but not the PCBs. Under good conditions, PAHs
have been degraded in land treatment units. Bioremediation
techniques are still in the early stages of development.
Therefore, the use of bioremediation in the extremely complex
field environment is inappropriate.
Stabilization: This technology was evaluated in conjunction with
a thermal treatment step to remove organics that could interfere
with the solidification reaction. This alternative would cost
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L
approximately 90 million dollars to
several sequential treatment steps
evaluated with pilot or field testing.
implement,
that would
and involves
have. .to . be
Alternatives G03 and GC3
treatment technologies.
statutory preference.
Exclanation of Significant Chanaes From the ProDosed Plan
are permanent solutions' 'and employ
These two alternatives satisfy this
As discussed previously in the ROD,
different from the preferred remedy in
following additional changes have also
issuance of the Proposed Plan:
The State of pennsylvania subsequent to issuance of the Proposed
Plan identified the need for "Best Available Technology"
emissions control from any air stripper used at the site.
the selected remedy is
the Proposed Plan. The
been made subsequent to
The state of pennsylvania also requires a 30 mil bottom liner for
the RCRA landfill alternative to satisfy the requirements of the
municipal landfill regulations. These regulations also require a
modification of the cap design to be installed as an element of
S12, the selected remedy for the fill. '.
The State of pennsylvania also requires an institutional control
on mineral removal near the site.
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1-
,
. .
.
OSBOIUnlLAlm.ILL
USPOlrSIVBIIBSS StJXK1Ity
. .
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ResDonsiveness Summary
Public Meetina ReSDonse Cards
and Letters Received Durina
Public Comment period
SWllJDary: In general, the comments ..received during the public
comment period questioned whether the risk at ~he site justified
the cost of EPA' s preferred al terriati ve. In general, the publ ic..
comments received supported allowing Cooper Industries to implement
their proposed alternative (slurry wall). The comments also
reflected concern about the economic impact on Cooper Industries
and consequently on the local economy.
Issue: Several residents asserted that they had experienced
significant contact with the landfill with no ill effects and that
no unusual health problems were observed in the community. One
resident mentioned that he and his family had used a well near the -.
landfill for many years as proof of the low risk.
SPA Response: Some exposures to chemicals do not produce immediate
effects but are still of concern to EPA. Toxicologists are experts
that study the effects of chemicals on the human body. Their.'
studies regarding cancer causing chemicals have shown that there
is often a 20 to 30 vear delay between exposure to a chemical and
the incidence of cancer. Additionally, EPA has taken a very
protective stance regarding public health risks form cancer causing
chemicals. In general, EPA sets risk levels so low, that if one
million people were exposed routinely (used well water with low
levels of chemicals) for their entire life, no more than one person
could contract cancer from this source without EPA taking action
to reduce this risk. EPA would therefore not expect to to see the
effects from exposure in a small number of residents unless the
risk from the site was disastrously high, which it is not.
Issue: Several comments were received that asked if EPA is
attempting to have other Potentially Responsible Parties pay a
fair share of the cost.
SPA Respon..s EPA has investigated the sources of wastes at the
Osborne landfill since placement on the National Priorities List.
The Osborne landfill unfortunately was not managed as a modern
landfill and records and invoices are not in EPA's posession. It
is very clear; however, that Cooper Industries was the major source
of the wastes at the landfill. Records indicate that at one point
in time Cooper Industries considered buying the landfill and had
a study done on feasibility of upgrading the landfill to meet DER
standards. The Cooper Industries records also show that they sent
large volumes of various wastes to the landfill in addition to
foundry sand, including solvents, plating sludges and cutting oils.
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EPA tentatively identified three Potentially Responsible Parties
in addition to Cooper Industries' that were sent Special .Notic.e
Letters that stated EPA's belief that they may have liability for
the. site and offered them the opportunity to conduct the cleanup
under EPA's supervision. Those PRPs are General' Electric Co.,
Ashland Chemical Co., and Castle Iron and Metals Co..
In summary, although Cooper Industries may obtain some assistance
from other Responsible Parties, Cooper Industri~s was responsible
for a 'large portion of the problem at the site. If other viable.
Potentially Responsible Parties are identified, EPAmay pursue them
for recovery of costs and Cooper Industries can sue these parties
for a share of the monies they expend in conducting the cleanup.
Xssue: Several commenters were concerned about the economic impact
of the Superfund cleanup on Cooper Industries and the local
economy.
BPA aeSpODSe: The liability for the Osborne site is the.
responsibility of the Cooper Industries Corporation, not just the'
Grove City plant. Cooper Industries had revenues of over four
billion dollars in 1988 and a net income of about 250 million
dollars. The EPA's preferred remedy is estimated to cost about
tweny million dollars or about ten percent of one years net income.
This cost would be incurred over several years. Closing the Grove"
City plant would not remove this Superfund liability from the
corporation or improve Cooper's financial si tuation unless the
plant were losing money. Congress has created a Superfund law that
mandates pursuing responsible parties to pay cleanup costs rather
than passing the costs on to the public. .
Issue: One commenter didn't think that EPA should hold Cooper
Industries liable for practices that were not illegal at the time
of disposal. This commenter was also concerned that EPA let the
costs accumulate interest over the years.
BPA aeSpODSel Under Superfund, liability is apprortioned
regardless of illegal practices or faul t io' The Superfund law
requires EPA to pursue responsible parties at Superfund sites for
recovery of costs. The cost in real dollars of the remedy is not
greater due to inflation.
Issuel One commenter thought that it was unfair for "EPA to take
11 years to make a.decision" and then charge Cooper industries for
the the accumulated costs(inflation).
BPA aespoDse: EPA has not taken eleven years to make a decision
at the Osborne site. The site was listed on the National
Priorities List in 1982, eight years ago. Cooper Industries did
not complete their investigation of the Osborne site until 1985,
five years ago. This investigation did not contain all of the
elements required prior to making a decision. This made it
necessary for EPA to conduct further studies at the Osborne site
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r
and to perform a Feasibility Study of remedial alternatives. This
study was completed in July, 1989 and a tentative decision m~de in
one month after EPA received all of the' required information.
Cooper has requested and received. an extension of the comment
period and the negotiation moratorium. EPA has. delayed its
decision on the. site to address several issues raised by Cooper
.. Industries and to further appraise their proposed al ternati ve
(slurry wall). The cost in real dollars of the remedy is not
greate~ due to inflation~
Isaue: One commentor thought 2 parts per billion was
insiqnificant. They asked "what was the tolerance for the data
presented in the study".
EPA a.sponse: The tolerance is different for different chemicals,
but EPA' s central lab checks all data for accuracy. When the
tolerance becomes large enough to make the value questionable, the
data is footnoted with a "j" qualifier. The 2 parts per billion
probably refers to the vinyl chloride detected in the deep aquifer. ..
Vinyl Chloride is such a potent human carcinogen that EPA set an
enforceable Maximum contamination Limit of 2 parts per billion for
this contaminant.
Issue: Several reviewers were concerned that EPA could increase""
the hazard to the public by digging up the fill to implement the
landfill option.
EPA a.spons.: This was one of the factors in EPA's decision to
select the Slurry Wall remedy as the primary remedy in the Record
of Decision and use the Landfill Option as a contingency remedy.
If it is necessary to implement the Landfill Option because the
Slurry Wall remedy is not successful, EPA will take adequate
precautions to protect the public during implementation of the
remedy.
. .
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.
,
OSBORNE LAJlDFILL
PROPOSBD PLAH
PUBLIC MEBTING SUMMARY
. .
"
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Section I.
Section II.
Section III.
Section IV.
Section v.
OSBORNE LANDFILL SUPERFUND SITE
MEETING, SUMMARy
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLE OF CONTENTS
Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Site Background..................................
Background on Resident Involvement
and Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Summary of Major Comments Received
During the Comment Period and EPA
Responses to Those Comments .....................
A.
Heal th Ri sks .0.. 1. . . . . . . . . . . . . ~ . . . . . . . . . . . . . . "
..- . -""
1.
The Proposed RemeJy .........................
B.
1.
2.
3.
4.
5.
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .". . .
ReliabilitY/Suitability.................
Implementation Effects..................
Payment Responsibilit~es................
Timing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
C.
Nature and Extent of Contamination ..........
1.
2.
3.
Mines. . . . . . . . . . . . . . . . .'. . . . . . . . . ." . . . . . . . .
Wetlands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Groundwater Flow/Drinking Water.........
D.
Public Involvement/Dissemination
of Information ..........................~...
E.
'Miscellaneous. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.
2.
3.
The Superfund Program...................
LilI1d tJse...................... .'. . . . . . . . .
New Information.........................
Remaining concerns..............................
~
1
1
3
3"
3
4
4
4
5
5
6
6
6
7
7
8
9
9
9
9
9
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Osborne Landfill Superfund Site
Meeting Summary Regarding the Proposed Remedial Action Plan
I. Overview
This Meeting Summary has been prepared by the U.S.
Environmental Protection Agency, Region ill, in order to
document the Agency's response to public comments regarding
the Osborne Landfill Superfund site (Osborne) in Grove City,
Pennsylvania. Comments discussed in this summary are those
received during two meetings hosted by EPA on September 14,
1989: a meeting with local officials and a public meeting
with community residents and other interested parties. The
comments are organized into relevant topics and similar
comments are summarized together to facilitate Agency
response.
II. Site Background
The Osborne site is a 15-acre abandoned waste disposal
area located on the East Pine Street Extension in Pine
Township, Mercer County, Pennsylvania. The site lies
approximately one-half mile east of the Borough of Grove
City. Several intermittent streams flow through the site.
A 1,500-foot long pit that was excavated during strip mining
operations begins nefer Diamond Road and extends in a
southeast-to-northweft direction,' Three small ponds are also
located on site. **
The Osborne site originally was developed as an
underground coal mine during the 1800s, and then as a strip
mine in the 1940s. From the 1950s through the early 1960s,
the site was operated as a waste disposal area. Beginning in
1963, the site was used as a landfill. Throughout the
remainder of the 1960s and most of the 1970s, the Osborne
site received industrial, hazardous, and municipal wastes,
largely from the Cooper-Bessemer Company, a division of
Cooper Industries Inc. (Cooper), Grove City plant but also
from other local manufacturing facilities. Wastes accepted
during this period included paints, asbestos, solvents, waste
coolants, spent foundry sand, acid, scrap metal, cooling
system sludge, slag, and waste oils.
The Pennsylvania Department of Environmental Resources
(PADER) inspected the landfill operations on several
occasions during the site's active period. Samples collected
from the mine ponds and surface water runoff contained iron
in all three pools and phenols in the strip mine pool. PADER
closed the site in 1978 for accepting hazardous wastes for
disposal without an appropriate permit. At the time of
closure, the site contained numerous drums, most of which
were empty and crushed, while others contained liquids and
solids. The site also had areas of contaminated soil.
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As a result of later investigations by PADER, the site
was added to EPA's Interim Priorities List, the Agency's
initial listing of sites eligible to receive Federal cleanup
funds/ and was eventually added to the National Priorities
List in November 1962.
Sampling conducted by PADER and EPA subsequent to site
closure showed the presence of contamination. Samples were
taken from the two larger ponds and from the stream off site;
these were tested for phenyls, cyanides, and heavy metals.
Test resulsts from surface water samples showed elevated
levels of managanese and iron as well as selenium. PADER
also tested the water in seven nearby private, residential
wells. Analyses on these samples did not detect the presence
of priority pollutants and residents were informed that the
water was safe to drink.
In response to an EPA recommendation, in May 1983,
Cooper initiated construction of a security fence,
installation of warning signs, and removal and disposal of 45
cubic yards of contaminated soils and 603 drums on site.
These actions were completed in the summer of that year.
Cooper, PADER, and EPA also negotiated a settlement
concerning the Osborne Landfill site and executed a Consent
Order and Agreement on September 20, 1983. In the Order,
Cooper agreed to quantify wastes it had sent to the site,
complete fehe initial actions it had begun, and conduct a
Remedial Investigation and Feasibility Study (RJ/FS) and
follow-up Remedial activities to characterize the nature and
extent of contamination at the site.
Cooper began RI site sampling work in Fall 1983 and
installed monitoring and test wells in late 1983 and early
1984 to determine the extent of contamination. Cooper
submitted its Draft RI Report to PADER and EPA in June 1984.
Findings indicated low-level ground- and surface-water
contamination and concluded that the site posed little
environmental risks. A final report was submitted in
September 1984.
Because of remaining concerns, in September 1985 PADER
and EPA collected additional environmental samples from the
site ponds, adjacent stream, neighboring property, and swamp.
Soils also were sampled. Samples were analyzed for
polychlorinated biphenyls (PCBs), volatile organic compounds
(VOCs), and heavy metals. In April 1987, EPA completed a
technical review of Cooper's RI Report, which found that the
existing information should be supplemented by additional
environmental sampling and characterization of the underlying
groundwater.
EPA conducted its RI/FS from Spring 1988 through Summer
1989.
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III. Background on Resident Involvement and Concerns
Interest in the Osborne site,began in Summer 1982, when the
site was ranked the third most hazardous site in
Pennsylvania. Media, residents', and local officials'
concerns began at this time. The announcement brought the
site to the attention of local residents and several
community groups began to form to consider the site. Most
notable among these groups are the Western Pennsylvania
Residents for Safe Communities and Pennsylvanians United to
Rescue the Environment.
In 1983, EPA and the PADER held two public meetings to inform
the public about activities at the Osborne site. Cooper
Industries, the site operator, conducted several activities
to mitigate an immediate threat from the site. In 1985, EPA
entered into negotiations with Cooper to conduct further
studies. Concern about the site remained high during this
time.
Recently, concern appears to have subsided. In the last two
years, residents have been concerned primarily with the
possibility of contamination in the drinking water and the
effect of the remedy on neighboring properties.
IV. Summary of Major Comments Received During the Public Meeting
and EPA Responses to Those Comments
f
A. ' ealth Risks
Several attendees inquired about the potential health
effects of the groundwater contamination. Specifically,
residents wanted to know what the current health risks
are, given that the landfill was closed in 1978.
EPA Response; The extent of groundwater contamination
that has been discovered through well sampling is
generally at very low levels. Higher levels of
contamination have been detected in groundwater located
on site, away from water supply sources. The low levels
of vinyl chloride, a known carcinogen, will not produce
excessive instances of cancer; however, the Agency is
taking precautions to limit exposure.
An attendee asked if this site was considered one of the
nation's worst toxic waste dumps* as he read in the
local newspaper; information about the Hazardous Ranking
System ranking for the site was also requested.
EPA Response* Since the completion of the removal
action and based on sampling results, this is not one of
the worst hazardous waste sites. Many of the problems
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at the site have been resolved by the removal and the
current level of contamination is not a cause for alarm.
B. The Proposed Remedy
1. Cost
Both residents and officials expressed concern because
if the Osborne site is considered to present a low risk,
it is not serious enough to warrant the cost of the
remedy.
EPA Response; The remedy selection process always takes
into consideration the costs and the benefits of each
possible remedy; selection is based, in part, on the
best remedy for the cost. EPA establishes maximum
contaminant levels for groundwater based on the cost of
a response relative to the potential risk to human
health or the environment. In this case, the presence "
of vinyl chloride, one of the few proven human
carcinogens, is a factor in determining the potential
risk. It was noted that EPA tends to be conservative in
determining the level of risk, preferring to err on the
side of public health.
A local official asked what the cost of both the initial
and the long-term groundwater treatment systems will beJ
He also asked who was responsible, for paying for the
systems.
EPA Response* The cost of the initial treatment is
estimated to be $6 million and the long-tern system will
cost approximately $1.5 million. Whoever undertakes the
cleanup will be responsible for these costs. If EPA
undertakes the cleanup with public funds, they will seek
recovery of cleanup costs from the responsible parties.
2. Reliability/Suitability
A local official asked for EPA's assessment of the
overall reliability of Cooper's proposed remedy, the use
of a slurry trail around the site in combination with
pumping and treating the groundwater inside the wall.
One resident questioned whether a slurry wall that is
only 42 'feet deep will be effective. The resident also
asked whether it will always need be necessary to pump
groundwater from the site.
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EPA Respongg? The remedy proposed by Cooper is to
encompass the contamination by the slurry and pump out
contaminated groundwater from within that slurry wall.
Under their plan, groundwater will be pumped as long as
necessary. It was noted that PADER prefers incineration
as an alternative to the slurry wall.
A resident asked whether remedial actions similar to
EPA's proposed preferred alternatives for Osborne had
been recommended at other sites.
EPA Response* A similar remedy involving on-site
solidification of the contaminated material and
construction of a landfill was selected for the Craig
Farms site, which is also in western Pennsylvania.
3. Implementation Effects
Several people asked whether the pumping of groundwater.
planned during the remedy would affect the environment.
Specific concerns included the possibility of spreading
contamination by disturbing the groundwater and the
possibility that the water-filled mines underlying the
site might cave in if the groundwater is disturbed.
EPA Response? During the pumping and treatment of
groundwater, contaminated water will be replaced with
treated water as it is extracted. Therefore, changes in
the hydrologic balance in the area are not anticipated.
One resident asked what the effect of the remedy would
be on the landowners of the area.
EPA Response* EPA will do whatever is possible to
minimize the effect of the remedy on landowners;
however/ the construction necessary to implement the
proposed remedy may require some temporary .
inconvenience. It will also be necessary to take some
of the land adjacent to the site for implementation of
the proposed remedy. EPA has procedures to compensate
landowners for their property.
A resident noted that some of the possible remedies made
* more land unusable than others. He wanted to be certain
that all.landowners would be advised of how the remedy
would affect their land.
EPA Response; The landfill option would use more land
than the slurry wall. Landowners can refer to site
documents, such as the Feasibility Study, for further
information about the effects of proposed alternatives.
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4. Payment Responsibilities
Attendees at the public meeting and local officials
wanted to know who is ultimately responsible for paying
the cost of implementing the remedy. Specifically, a
resident asked whether the public would pay if Cooper
was unable to complete its cleanup.
EPA Response; EPA is currently negotiating with Cooper
to reach an agreement about the company's liability in
this cleanup. If an agreement cannot be reached, or if
Cooper becomes unable to pay, Superfund money will be
used to pay for the cleanup. In no case will the
residents or the municipality be held financially
responsible for implementing the remedy.
A Cooper employee asked whether Cooper could be held
responsible for treble damages (three times actual
costs) if the site is shown to be dangerous to public
health.
EPA Response? Treble damages are assessed where: a) EPA
finds that the level of contamination at the site
presents an imminent danger to human health and b) the
responsible party refuses to obey a cleanup order from
EPA. EPA has not made a finding of imminent and
substantial endangerment at the Osborfte ~si:re~r~ [However,
EPA could make, this determination in the future.]
If there is not an imminent and .substantial endangerment
to human health and the environment, EPA [usually]
cleans up the site and later attempts to recover the
costs from the responsible parties. [A finding of.
imminent and substantial endangerment is not absolutely
necessary to collect treble damages. EPA is empowered,
under section 107(c) of CERCLA, to collect treble
damages for failure to obey an order to provide remedial
action under section 104 of CERCLA, if a person is
liable for a release or threatened release of a
hazardous substance.]
5. Timing
Residents asked for more information about the Agency's
overall timeframe for implementation of the remedy.
EPA Respanfie* EPA will send letters to potentially
responsible parties (PRPs) to initiate negotiations for
cleanup liability. The PRPs must negotiate a consent
order by the end of January 1990 or EPA will begin the
design work with public funds. The design for the
construction will take approximately one year to
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finalize. Actual construction should begin in Spring
1991.
f ~
A local official asked whether the site would become a
long-term groundwater treatment facility.
EPA Response There will be a long-term treatment
system to strip volatile organics from the Clarion
aquifer. The initial groundwater treatment system will
be more intensive than this long-term system and will
also remove metals and PCBs.
C. Nature and Extent of Contamination
1. Mines
A resident asked whether sampling has shown
contamination in the mine pool.
EPA Rgsponsg; Contamination has not been found in
[residential wells that use the shallow aquifers
connected with] the mine pool. Sampling has shown high
levels of contamination in one area of the mine pool;
the aquifers are insulated by (clay or] shale. This
"insulation" inhibits drainage from the mine pool.
An attendee stated that he had heard that the mines were
six. or seven miles deep and wondered if that was
correct.
EPA Response* The extent of the mine system is not
currently known. The groundwater verification study
will help to determine the extent of the mine system.
*
A resident expressed concern that the contamination may
be able to move long distances underground through the
Burgeon aquifer. *
EPA Response; The contamination found in the Burgoon
aquifer is localized. The area around the aquifer is
being monitored; wells placed to intercept the
groundwater flow are showing diluted levels of
contamination. Based on these test results, the Agency
thinks that there is some hydrogeologic linkage between
the Osborne Landfill and the Burgoon aquifer, but that
it is not a major linkage.
2. Wetlands
A local official asked what will happen to the wetlands
during implementation of the remedy. A resident also
expressed concern that the remedy be implemented so that
this area can be preserved.
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EPA Rggpfmcjp. Any remedy that may affect the wetlands
will be reviewed carefully by the Agency. For example ,
the regrading will be , conducted in such a way as to not
extend to the wetlands; the area to the south of the
wetlands is more likely to be affected. While the
remedy is being designed, EPA will be attentive to the
existence of the wetlands and a game preserve.
3. Groundwater /Drinking Water
A resident expressed concern that Grove City will draw
contaminated water from the Burgoon aquifer.
EPA Rggponso; Samples of the Burgoon aquifer have not
shown it to contain a significant level of
contamination. A well pumping water from the Burgoon
Aquifer showed very low levels of one constituent of
vinyl chloride; that level is not enough to characterize
the Burgoon as contaminated. Based on sampling/ it will
be necessary to continue monitoring this aquifer.
One attendee asked when and why the test wells were
installed and how often they were monitored.
EPA Response? Cooper installed some test wells after
the site became a Superfund .site in 1982. EPA installed
additional monitpring wells to support the Remedial
Investigation and Feasibility Study. i-
A local official asked whether the deeper aquifers,
under the contaminated aquifers, also are contaminated.
EPA Ftesponsg; NO significant levels of contamination
exist at that deeper level. EPA will continue to test
the deeper aquifers using the monitoring wells in the
area.
D. Public Involvement/Dissemination of Information
Several attendees asked how EPA plans to notify persons
owning property adjacent to the site regarding the
effect of the remedy.
EPA Response; Some of the key community leaders have
been contacted to discuss potential effects. The
Remedial Project Manager for the site has personally
contacted the resident whose land will be most affected
by the proposed remedy. The diagrams shown at the
public meeting indicate boundaries of the property that
vill be affected; copies of these diagrams will be
available at the information repository. Prior to
implementing the remedy, EPA will discuss with
8
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landowners procedures for obtaining compensation for any
land taken.
An attendee asked whether EPA is coordinating with the
local government.
EPA Response* The Remedial Project Manager and
Community Relations Coordinator have met with local
government officials to hear their concerns and keep
them informed about ongoing and planned site activity.
A resident expressed concern that more communication
with EPA is necessary and that there had been little
contact from EPA in the past year.
EPA Response: EPA is making a concerted effort to
involve and inform the members of the site community.
A new Remedial Project Manager and Community Relations
Coordinator have been assigned to the site and have met
with local officials and talked on an individual basis
with several interested parties regarding proposed
activity at the site.
E. Miscellaneous
1. The Superfund Program
An attendee noted that an article in New..week magazine*
criticized the success of the Superfund program. The
attendee requested EPA to respond to this criticism.
EPA Response; Any program as large as Superfund will be
criticized. A recent "90-day study" of the
effectiveness of Superfund made recommendations such as
keeping the public informed, using new technologies, and
extending public comment periods on proposed activities.
These recommendations have begun to be implemented at
the Osborne site, through efforts such as the meeting
with local officials and by community relations
activities.
2. Land Use
An attendee asked how the land can be used after the
remedy is complete.
EPA Response* The land will continue to be part of the
Osborne Superfund site. None of the options under
consideration will clean up the site to the point where
th landowner can use it for other purposes. Access to
the area around the cap (a proposed remedy outlined in
the RI/FS) will be restricted.
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3. New Information
A resident informed EPA-of a system of old mines in the
area that may be affected by the remedy or may affect
its implementation.
V. Remaining Concerns
Response cards received during and immediately following the
public meeting reflect residents' concern about the following
issues:
Whether EPA will purchase the properties adjacent to the
site that will be affected by implementation of the
remedy. A resident expressed concern that he was paying
taxes on land to which he did not have access.
Cooper's ability to pay for the EPA remedy; several
residents want EPA to reconsider allowing Cooper to
implement Cooper's alternative in order to minimize
costs to the company. Residents are concerned that
Cooper/ a key employer in the area, will close local
operations if remedial costs are too high.
Whether EPA will ask other responsible parties to pay
part of cleanup costs; residents do not feel that Cooper
is the only PRP and that EPA should consider requiring
'those other firms pay for the remedy.
The significance of the level of contaminant found in
the area compared to the cost of the remedy; this
continues to be a concern in the community, partly based
on the low level of contamination and the concern about
Cooper bearing the cost of the remedy.
A local official expressed his concern that EPA will be
creating another landfill and not solving the problem.
Several residents did not receive a copy of the handout
materials; EPA will send this packet to the information
repository to facilitate getting the information to the
community in an efficient manner.
10
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-
,
OSBORHB LAHDPILL
SPA RESPORS. '1'0
COMMBIfTS SUBIIIT'l'SD BY
COOPSR IIfDUS'l'RISS AIfD 'l'HBIR CONTRACTORS
'.
. .
. .
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INTRODUCTION
This Responsiveness Summary was prepared in response to comments
submitted by Cooper Industries, Incorporated and their
subcontractors/ Fred C. Hart Associates/ Incorporated (Hart) and
International Technology Corporation (IT) during the public
comment period. Comments submitted by Cooper Industries pertain
to the Osborne Landfill Site Final Remedial Investigation Report
(August 1989) and the Draft Feasibility Study Report
(September 1989) prepared by the REM III Team for EPA
Region I.II.
Because there was no numbering system to identify the comments/
and because many of the comments were repetitive in nature/ the
EPA and REM III Team agreed to focus on responding to major
issues that were identified by Cooper Industries through their
comments. A total of 13 major issues have been identified by
the REM III Team and addressed in this report.
Various comments which pertain to each of the major issues have"
been either individually identified or a summary of comments was
provided and subsequently addressed. Thus/ the format of this
Responsiveness Summary identifies the major issue/ provides a
narrative summary of the comments or lists the individual
comments which reflect to the major issue/ and provides the
subsequent response.
Issue No. 1: The risks are overstated because of erroneous use
of data and erroneous assumptions.
Numerous comments were submitted by the PRP and their
consultants with respect to the risk assessment. The most
frequent and significant comments relating to the above issue
(No. 1) are given below along with the response.
Comment:
There should be an evaluation of the data .regarding its
accuracy/ quality and validity (particularly PAHs). Data
validation qualifiers dp not appear on data tables or i-n the
text of the main narrative report. In one of the comments/ the
commenter specifically cites the following table and states that
all data presented should be qualified with a "J." The
commenter also specifically comments on the validity and
accuracy of all foundry sand chemical analyses.
D331191 -1-
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, RI Report RI Report
Constituent RI Report
(~9/L) Appendix F Table G-ll
(~g/L) (ug/L)
Chloroethane 7.1 1.6 1.5
l,l-Dichloroethane 6.3 10.9 10.9
1,1,1~Trichloroethane 1.0 4.8 4.8
Trichloroethene 1.0 1.4 2.8
Lead 10.0 (3.7)B Not Reported
Nickel 10.0 Not Reported Not Reported
Response:
The data presented in the RI report and used in the risk"
assessment have been reviewed and validated according to EPA
protocol, therefore, the quality of the data is known. (Data
validation reports are available). All appropriate qualifiers
have been assigned to the data as presented in Appendix F of
the RI Report. Although qualifiers are not carried through to..
the summary tables and main narrative, it should be noted that
only data considered acceptable for riSk assessment through the
validation process (i.e., unqualified, J, K, L data) are
included in the summary tables and narrative and used in risk
assessment calculations.
Regarding the table specifically cited by the commenter, the RI
values should not be "J." The data in question was provided
(and validated) by the U.S. EPA Central Regional Laboratory
(CRt). A review of their data package indicates the values are
not qualified. The first column of data presented in the table'
is taken from a previous investigation report; we can not
comment on the qualifiers. (Note that one can not directly
compare data presented in column 1 to columns 2 and 3; the data
are from two different investigations.)
Regarding the validity and accuracy of all of the foundry sand
chemical analyses, the data used in the risk assessment may not
always show J, K, or L qualifiers; however, none of the data
used were rejected data. Pinally, although the commenter states
that the QA/QC of. the initial RI data (previous investigation
data) were in accordance with u.S. EPA guidelines and CLP
protocol. The level of the QA/OC is not known with any
certainty. Only recent data of known aualitv were used in the
risk analysis. .
Comment:
Cancer risks should not be calculated for PARs that are
classified as Class C and Class D carcinogens. Modification of
the comparative CPFs based on Thorslund (Thorslund, 1988) while
D331191
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still continuing the u~~ of the original CPF of 11.5 for
benzo(a)pyrene in place of the value of 3.22 developed in the.
evaluation may not be a proper use of the comparative potencies.
pyrene, a Class D carcinogen, and anthracene, an unclassif ied
compound, should not be used in quantifying risk at this time.
Response:
The following guidance is provided." by the'U. S. EPA (51 FR 185,
page 33996): "Agents that are judged to be in the EPA
weight-of-evidence stratification Groups A and B would be
regarded"as suitable for quantitative risk assessments. Agents
that are judged to be in Group C will generally be regarded as
suitable for quantitative risk assessment, but judgments in this
regard may be made on a case-by-case basis. Agents that are
judged to be in Groups D and E would not have quantitative risk
assessments. " Contrary to the commenter I s statement, cancer
risks may be calculated for Class C carcinogens on a case-by-
case basis." However, the commenter is correct in stating that
anthracene is an unclassified compound and should not have been.
included in the risk analysis. pyrene, a Class D compound, was
included in the risk analysis since it was reviewed in the
ICF-Clement Associates report and assigned a relative potency
factor. A review of the risk analysis results presented in
Appendix I of the RI Report indicates that the
inclusion/exclusion of either compound in the risk analysis does
not substantially affect the final risk analysis results.
Conservatively and at the suggestion of the EPA Region III
toxicologist, cancer risks were calculated using the Clement
Associates proposed relative potency estimates and the existing
benzo(a)pyrene potency slope factor of 11.5. Carcinogenic
potency factors and relative potency factors for PASs are
currently under review internally by the EPA. The use of the
proposed 2.33 q* for benzo(a)pyrene instead of the existing
11.5 q* was considered premature.
.
The commenter alsQ states that "the comparative potencies (i.e.,
relative potency estimates [RPE] presented in Clement
Associates, 1988) are based on animal studies in which the PAH
was administered in every mode other than ingestion.
Consequently, the premise that all toxicity parameters are based
on intake, thus justifying the use of 100 percent absorption,
may not be supportable." The RI does !lQ! assume that all
toxicity parameters are based on intake. The 100 percent
absorption factor' is used as a conservative upper-bound value.
Addi tionally, the statement that the RPEs are based on animal
studies in which the PAR was administered in every mode other
than ingestion is similar to a discussion presented in Clement
Associates (April 1988): "This chapter (Chapter II, page III-I)
describes eleven experiments in which B[a]P and other PABs were
tested concomitantly for carcinogenesis using several animal
species and different methods of administration, as well as two
experiments in which the levels of these chemicals that interac:
with cellular DNA were determined. Unlike the experiments using
D331191
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B[a]P described in Section II, most of these studies used
methods of administration that cannot be quantitatively compared
to those by which humans would be, expected to be exposed. As. a
resul t, dose response. relationships for these PARs cannot be
descr ibed mathematically in a manner that is useful for the
prediction of human risk unless they are express.edrelative to
B[a]P. Cancer potencies relative to B[a]P are derived for each
PAR from each experiment in the following section and are
summar ized at the end. II .
Comment:
Correct risk assessment protocol dictates that chemical
analytical data in which the highest observed concentration is
below the Contract Detection Limit (CDL) not be used in the
quantification of risk. Addi tionally, a worst case scenario
that assumes a uniform distribution of infrequently detected
contaminants is highly conservative. The evaluation of all
chemicals regardless of the detection frequency and the use of
data that is below the Contract Required Detection Limit (CRDL)..
is an extreme worst case.
Response:
The commenter states that "postulating a worst case scenarip
that assumes uniform distribution of an unverified constituent.
(unverified, in that it was detected only once in the media) is
overly conservative and will greatly exaggerate the health
risks." We believe the term "unverified" is misleading as used
by the commenter. Unless a contaminant identification/
quantification is rejected through the validation process, the
risk assessor must evaluate the detection as real.. The
frequency of detection certainly influences the interpretation
of the risk analysis results. Additionally, as sampling and
analysis programs for Superfund sites are often restricted by
time and budget constraints, the investigator's ability to
define (without question) the vertical and horizontal extent of
contamination is limited. Consequently, infrequently detected
contaminants should not be dismissed automatically as
insignificant. The evaluation of infrequently detected data for
the Osborne Landfill Site does not impact the bottom line risk
analysis results. The major risks at Osborne are attributable
to PAH and PCB contamination in the onsi te groundwater (the
overburden aquifer) and volatile organics in the onsite and
offsite groundwater. Surface media (soil, fill, and mine
spoils) contamination is also a concern. PASs were frequently
detected in surface and subsurface media. PCBs were frequently
detected in subsurface media. Low level volatile organic
contamination was detected in samples collected from various
onsite/offsite a~ifers at the site.
The commenter's statement that "correct risk assessment protocol
dictates that chemical analytical data in which the highest
observed concentration is below the CDL not be used in the
quantif ication of health risks" is not in accordance with EPA
D331191
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Region III guidance. Although designated as a quantitative
estimate/ "J" data (estimated data) may be used in risk
assessment (EPA Region III policy). The "J11 qualifier
designates an estimation in quantification and not a contaminant
identification problem. Regarding the surface water data
specifically cited by the commenter, the significance of finding
volatile organic contamination in the onsite pond is that the
detections are evidence of contaminant migration. The risk
analysis/ although conservative/ does not overestimate risk and
in the case of the onsite surface waters indicates that surface
water contamination does not present significant carcinogenic or
noncarcinogenic risks.
Regarding the surface water data/ the commenter states that
"selecting the chemical maximum observed concentration
(particularly for "J" data)/ assuming that the maximum
concentration is uniformly described over the entire site
environmental medium is a too conservative and unrealistic
approach in quantifying risks in an evaluation ..." As stated
earlier/ the maximum and average contaminant concentrations are--
evaluated in the risk assessment. The evaluation of the maximum
concentration defines the worst case scenario as typically
considered in a Superfund risk assessment.
Comment:
The exposure scenarios involving children swimming or fishing in
the onsite/offsite ponds are not plausible.
Response:
The RI (page 183/ 4th paragraph) agrees that "it is extremely
unlikely that the onsite ponds will ever be used for
recreational activities." However/ the opportunistic use of the
ponds for swimming or wading (a more likely scenario) by
adolescents hiking in the area or trespassing across the site is
certainly within the realm of possibility. Consequently/ dermal
contact with and accidental ingestion of (hand to mouth contact)
surface water contaminants is possible even under a wading
scenario (however contaminant intake rates are predicted .to be
less for a wading scenario than for a swimming scenario). The
results of the risk analysis indicate to all interested parties
that even under the conservative conditions specified in the
risk assessment/ adverse health effects are not anticipated.
This conclusion can be drawn with a great deal of certainty and
is useful to anyone responsible for making health or remediation
decisions for the site.
Comment:
Carcinogenic and noncarcinogenic exposure doses should be time
weighted in terms of days/year exposed or years/lifetime exposed
as appropriate. The cancer risk calculations for a 17 kg child
ingesting affected groundwater should prorate the exposure over
a lifetime. Inorganics account for a large percentage of the
0331191 -5-
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chronic toxicity
concentrations.
risk, however,
they may all be at background
,
Response:
Th~ risk analyses results present~d in the RI' 'aie based on
exposure dose expressions that, conservatively, do not time-
weight exposures that occur on a less than daily basis. The
following exposure scenarios are 'potentially impacted by the
time .weighting issue: . . .
. Dermal contact with contaminated onsite/o~te sed~ments
The risk analysis results for this scenario are presented
on Table 6-6 of the RI. The cancer exposure dose
calculations were time weighted; the noncancer exposure
dose calculations were not time weighted. 'However, as the
maxi~m Hazard Index presented is 0.39, time weighting
would not alter the conclusion of the risk analysis
resul ts . . . significant adverse noncarcinogenic health.
effects are not predicted by this exposure scenario.
. Dermal contact and accidental inQestion exposures
contaminated foundry sands, mine speils, and soils.
See Comment/Response on page 11.
to
. Accidental inQestion of or dermal contact with onsi te or
offsite surface waters (Onsite Pond No.1, Onsite Pond
No.2, Offsite Pond).
The risk analysis results for this scenario are presented
on Table 6-12 of the RI. The cancer exposure dose
calculations were time weighted; the noncancer exposure
dose calculations were not time weighted. However, as the
maximum Hazard Index presented is 0.1, time weighting
would not alter the conclusion of the risk analysis
results. . . significant adverse noncarcinogenic health
effects are not predicted by this exposure scenario.
The commenter's statement that acute exposures should be
evaluated using acute toxicity criteria is correct. The RI
statement cited by the commenter (page 178, fourth paragraph)
does not state otherwise; however, the phrase "Doses can be
calculated. . . for single exposures (for
noncarcinogens) .". ." may be interpreted by the readers as
meaning that "time weighting" is not necessary. It is agreed
that time weighting of exposure doses for noncarcinogenic risk
assessment is technically correct.
Thecommenter's statement that the cancer risk calculation for
the 17 kg child ingesting groundwater should prorate the
exposure over a lifetime is correct. Consequently, the cance r
risks presented for a child (Tables 6-9 and 6-10), should be
reduced by a factor of 6/7D.
D331191
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Comment:
The following comments were received on the statistical
treatment of the data:
"Use of a statistical analyses applied to the chemical
analytical data to determine the most appropriate
distribution was inappropriate."
"In the final analysis, the site was evaluated on a
'worst-case1 basis only, using the maximum observed
concentrations in the risk assessment."
"Since the data did not exhibit a random distribution, it
is unclear why the use of an arithmetic average was chosen
when it is widely understood that arithmetic averages are
only applicable when the distribution is random."
"The result of this statistical methodology error (i.e.,'
use of the arithmetic mean versus geometric mean) is an
estimated arithmetic average concentration of PCBs, within
the fill, which is 50 times greater than the more
representative geometric average. This ultimately affects
the risk assessment and the selected alternatives within
the final PS report."
"The general practice in the field of risk assessment has
been to use geometric means for the 'most probable case.'"
Response:
Statistical analyses were applied to the data in an effort to
determine which distribution (normal, lognormal) was most
representative of the site data and thus most useful in the risk.
assessment. The analyses were conducted by the contractor at
EPA's request.
A "worst case" AND a plausible case scenario were evaluated for
all exposure scenarios presented for the Osborne Landfill .Site.
Maximum and average contaminant levels defined the worst case
and plausible case scenarios. This is common practice in EPA
superfund risk assessments and is required by at least one EPA
Region (Region I). Because worst case and plausible case
scenarios are presented in the risk assessment, it is incorrect
to state that the* site was evaluated on a "worst-case" basis
only.
The arithmetic mean was utilized in the risk assessment for the
following reasons:
Statistical analyses (W-test) on the analytical results
for 20 foundry sand samples indicate that PCB-1254 data
may be drawn from an underlying lognormal distribution.
PAH data had characteristics of both normal and lognormal
D331191 -7-
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distributions and'could be assessed using either a
geometric mean or an arithmetic average. In summary, the
statistical analyses did not conclusively indicate. .ei ther
a normal or lognormal distribution.
. The EPA (53 FR 196, (page 39722]) retains' the' assumption
of normality. in the groundwater data distribution
(rule {ss264.97 [i] [l]}) . because. many statistical
procedures reviewed were "not. robust for data that, while
. not normally distributed, do not significantly violate the
. n~~mal distribution assumption." '.
. The use of the ar i thmetic mean versus the geometr ic mean
avoids the need to identify the sample specific detection
limits for each analyte in each sample which substantially
increases the time allowed for RI database preparation.
. The use of zero for nondetect values serves to reduce or
eliminate any bias toward unreasonably large average
concentrations.
. .
. The use of either arithmetic averages or geometric means
often has little effect on risk estimates that are
essentially order-of-magni tude indications of public
health and environmental threats.
The use of the geometric mean would indeed decrease the risk
attributed to the average PCB levels detected within the fill.
However, Feasibility Study decisions were also based on TSCA
regulations which specify the PCB levels not also exceed 10 ppm
and 25 ppm for nonrestricted and restricted access sites,
respectively, as well as risk analysis results. A few onsite
detections (hot spots) exceeded the TSCA criteria.
Additionally, the state of Pennsylvania (PADER) recommendation
for the site is that PCB contamination should be reduced to
background concentrations (i.e., nondetect).
.
The commenter states that the general practice in the field of
risk assessment has been to use geometric means for the "most
probable case." The most recent guidance from EPA Region III is
that the statistical distribution of the data be considered when
calculating most probable exposure and plausible upper bound
exposure. The guidance does not state or assume that the
geometric mean be used for the most probable case.
Comment:
This risk assessment quantified the absolute health risks rather
than the incremental health risks since background was not
subtracted from the. concentrations used to calculate cancer
risks and hazard indices. The metals concentration, which
account for the majority of the risk in many scenarios, are
typically background levels.
D331191
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Response:
The purpose of the risk assessment is.to calculate the tofal
risk to a receptor from exposure to site consti tuents. The
percentage of that risk that can be attributed.. to background
levels is certainly not important to the receptor. However,
background levels should be considered in the indicator chemical
selection process and in the determination of whether or not
remediation is necessary at the site. Traditionally,
constituents that are present in site media at background levels
are not.. included. as indicator chemicals. In addi tion~
background levels are usually taken into consideration in the
decision on whether or not remediation is necessary at a site.
Although some of the metal concentrations used in risk
calculations for some of the exposure scenarios may not have
been greater than background levels, the calculated hazard
indices for all exposure scenarios except for one (exposure to
groundwa ter from the onsi te overburden aquifer) were less than
unity. Ih addition, the inorganics did not contribute
significantly to any of the cancer risks.
For the exposure scenario in which the hazard index was greater
than 1.0, it is the metals which account for the majority of the
noncarcinogenic risks. However, it is not the metal
concentrations in this aquifer that are of greatest concern at.
the site. The elevated concentrations of PABs and PCB-1254
detected in the onsi te water table were major factors in the
determination that remediation is warranted at this site.
Co_en t :
The use of analytical data from unfiltered samples is not proper
when calculating drinking water health risks, because drinking
water wells that experience high sediment loads would be fitted
with particle filters that remove suspended colloidal particles.
Response:
Unfiltered inorganic sample results were not used in the risk
assessment calculations. On page 118, paragraph 2 of the RI
report, it clearly states that dissolved inorganic results would
be used in the risk assessment calculations to simulate
conditions "at the. tap." However, in accordance with EPA
Region III policy, unfiltered organic analyses were used in the
risk assessment.
.'
Comment:
Missing from the dose-response evaluation is the explanation of
the rationale that presumes 100 percent absorption of all
consti tuents., ostensibly based on the premise that all of the
toxicity parameters (reference doses, cancer potency factors)
. .are intake. derived. Not all of the intake parameters for all of
the compounds are based on uptake. Also missing from the
dose-response evaluation is the justification for the
D33l1.~'
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assumptions made regarding' the dermal absorption rates for the
various constituents.
,
Response:
It is recognized that an explanation of the rationale that
presumes 100 percent ingestion absorption for all consti tuents
was not included in the dose-response evaluation section of the
RI report. The rationale behind .this assumption is that the
refer.ence doses are developed based on the' dose to which the
study . a~imal was exposed and not on the amount that the study
animal absorbed. In the risk assessment, the dose to which a
receptor could be exposed under various scenarios is calculated.
Therefore, the determination of the hazard' index is based on a
comparison of a calculated exposure dose with an acceptable
exposu~e dose (reference dose). Consequently, it is valid to
assume 100 percent ingestion absorption. In addition, the use
of 100 percent absorption is in keeping with EPA Region III
guidance on 'this issue.
.
Most t"oxici ty parameters used in the risk assessment are based
on intake. However, even if they were not intake derived, this
is taken into consideration in the development of the reference
doses and cancer potency factors. Therefore, for this reason
also, it is acceptable to assume 100 percent ingestion.
absorption.
It is recognized that the justification for the assumptions
regarding the values of the dermal absorption rates for the
various constituents was not included in the RI report.
Absorption rate values of 10 percent lor volatiles,S percent
for PABs and PCBs and 0.5 percent for inorganics were utilized
in the risk assessment because these are typical values used in
risk calculations. There is no formal EPA policy regarding
absorption rate values. There is not a consensus in the
literature on the best dermal absorption rates. The absorption
rate values used in this risk assessment are acceptable to EPA.
Therefore, it is justified to use the dermal absorption values
given above.
Comment:
The RI recognizes that there is a soil matrix effect but does
not apply any reduction factor when calculating risks from
dermal contact with and accidental ingestion of soil.
. The 5 percent dermal absorption rate for PABs and PCBs is
too high. A dermal absorption range of 0.3 and 3 percent
has been suggested by Clement (Clement, 1987).
. PABs in the foundry sands are not bioavailable due to the
process (in the metal pour ing) that transferred them to
the ,foundry sand.
D331191
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. Both PCBs and PABs behave similarly to dioxin in the
environment (wi th regard to soil adsorption). Umbr ient
(Umbrient, 1986) reports 'ingestion absorption - rates for
dioxin in soil as low as 0.5percerit.
. PABs must be dissolved in a
absorbed by the study animal.
absorption character.
Res~nse:
carrier iri- order to be
The carrier changes their
A more conservative approach was taken in the risk assessment
and assumes a 5 percent dermal absorption rate for both PCBs and
PASs. This is a typical value used in risk calculations.
Presently there is no formal EPA policy regarding absorption
rate values; however, EPA has approved the use of a 5 percent
dermal absorption rate for the risk assessment for this site.
Even if the dermal absorption rates of 0.3 and 3 percent (for
PCBs and PARs) were used in the risk assessment, the decrease in
the risk for the worst case scenario would not be significant.--
For the more plausible case scenario, the calculated risks would
decrease by a factor of approximately 16.
There is no data available to confirm that PABs in foundry sand
are not bioavailable: therefore, it is assumed that the PABs in
the foundry sand are bioavailable.
A reduction factor has not been applied in the risk calculations
to account for possible soil matrix effects because there is no
widely accepted method provided in the literature to account for
soil matrix effects in risk assessment calculations. Therefore,
a 100 percent absorption rate for PCBs and PABs was assumed in
ingested soils.
It is agreed that by dissolving a PAR in a carr ier (in order
that it can be absorbed by the study animal), the absorption
character of the PAR is changed. However, by assuming a dermal
absorption rate of 5 percent, this is accounted for in the risk
calculations and in the development of th~ reference doses a-nd
potency factors.
Comment:
It is erroneous to use analytical results from subsurface soil
to characterize the risks associated with direct contact with
and accidental ingestion of site soils. Deep foundry sands
(below 4 feet from the surface) are not available for direct
contact unless excavation takes place. Only the surface soil is
subject to direct contact with subsequent ingestion and dermal
absorption.
Response:
The risks associated with dermal absorption and accidental
ingestion of surface materials (soil, mine spoils, and foundry
D331191
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sands) have been recalculated using surface media concentrations
rather than the subsurface concentrations that were used in the
oriqinal calculations. The samp~e results listed in Appendix G
(Tables G-1 and G-2) were used to' calculate the risks for both
the "worst case" and "more plausi}:)le case" (averaqe) scenarios.
These tables do not provide the sample results fQr each of the
specific surface media but rather they provide a single value for
each specific contaminant detected in the site surface material
as a whole. The risks have been recalculated.
CommeD~:
I :
The assumptions reqardinq the bioavailability of inorqanics
(100 percent inqestion absorption, 0.5 percent dermal) are more
than conservative.
."
. Toxicity parameters are unique to the particular compound
administered in the study. Soil or foundry sand was not
evaluated.
. The inorqanics are present in the soils and residues mainly"
as part of the mineral context of the sand or soil
particles and are not absorbed.
RespoDse:
It is agreed that toxicity parameters are unique to the
particular compound administered in the study. However, since
specific toxicity parameters are not available for foundry sand
and soil, the toxicity parameters available in the toxicoloqical
data base IRIS were utilized. The toxicity parameters found in
IRIS have been approved by EPA for use in risk calculations.
These toxicity parameters are presently the best available and
most widely used toxicity parameters.
It is possible that the inorqanics in the soils and residues are
present mainly as a part of the mineral content of the sand or
soil and are therefore not absorbed. However, there are no site-
specific data available to confirm that this is the case. The
absorption values used in the risk as~essment (100 percent
inqestion absorption, 0.5 percent dermal absorption) are typical
values used for risk calculations. EPA confirmed that these
absorption values were acceptable to use in risk calculations.
When these values were used in the risk assessment for the site,
the results revealed that all the hazard indices (for the
accidental inqestion and dermal absorption of site surface media
exposure scenarios) were less than one and the contribution of
metals to the total cancer risk was insiqnificant.
D331191
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, .
. .
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C8
101
101
...
...
\0
...
I
~
.AI
I
TABLE 1
"
'HAZARD INDICES AND INCREMENTAL CANCER RISKS FOa"
DERMAL CONTACT AND ACCIDENTAL INGESTION EXPOSURES TO SITE &URFACE MATERIAL
, OSBORNE LANDFILL SITE
GROVE CITY PENNSYLVANIA
'-
, .' ,~,
Hazard Index Incremental Cancer Risk
Exposure Scenario
" Worst Case Average Case Worst Case Average Case
Dermal Contact with Site 9.79 x 10-] 1.83 x 10-3 9.43 x 10-6 1.67 x 10-6
Surface Media by a Child
Dermal Contact with Site 6.29 x 10-] 1.17 X 10-] 6.06 X 10-6 1.07 X 10-6
Surface Media by an Adult
Accidental Ingestion of
Site Surface Media by a ' 5.17 x 10-2 9.65 x 10-] 5.50 x 10-6 1.20 x 10-6
Child
Accidental Ingestion of 6.21 x 10-]
Site Surface Media by an 3.32 x 10-2 3.53 X 10-6 7.74 X 10-1
Adult
Total - Child 6.15 x 10-2 1.15 x 10-2 1.49 x 10-5 2.87 x 10-6'
Total - Adult 3.95 x 10-2 7.38 x 10-3 9.59 x 10-6 1.84 x 10-6
" .,..........'
-------
c~
ent:
The calculated risks from arsen'i-c associated wi th exposure '-to
groundwatQ"'~from the overburden aquifer are overstated.
. It i. questionable whether arsenic is pre'sent at levels
abov~ background.
I'
. Arsenic levels are below 'the Primary Drinking Water
, Standard Maximum Contaminant Level (PDWS-MCL), the only
'e~forceable Applicable or Relevant and Appropriate
Requirement (ARAR).
. The EPA Risk Assessment Forum has recommended reducing the
calculated risks associated with arsenic by one order of
~gnitude due to the nonlethal nature of the cancer caused
by exposure to arsenic in drinking water.
The '~stimated cancer risk from arsenic is based on
analytical data of questionable quality, since only a..
'single groundwater sample revealed the presence of arsenic
above the Contract Detection Limit (CDL).
. The only positive result for arsenic above the CDL "
questionable because a duplicate sample from the s~
monitoring well showed no detectable arsenic. ~
.
Response:
Because of the nature of the site (a former strip mine), it is
difficult to accurately determine background conditions in the
water table aquifer. Therefore it is possible that the arsenic
detected in samples from this aquifer may not be present at
levels that exceed background levels. However the spreadsheets
in Appendix I for the onsite groundwater ingestion scenarios
(Pp. 27-30) demonstrate that the contribution of arsenic to the,
total risk is insignificant compared to the contribution of
polycyclic aromatic hydrocarbons (PABs). A decision about the
need for remediation at the site was not based solely on tJ'le
presence of arsenic in the water table' aquifer at a maximum
concentration (14.2 J&g/L), which is below the currently
enforceable Met.
It is not the policy of the REM III Team to reduce the
calculated cancer risks associated with arsenic by one order of
magni tude due to-' the nonlethal nature of the cancer caused by
exposure to arsenic in drinking water. Presently, there are
some data available that suggest a link between human ingestion
of arsenic and the occurrence of internal cancers: therefore, we
believe it is not prudent to reduce the risks from arsenic by an
order of magnitude. A list of relevant studies and references
that suggest this link between arsenic and internal cancer can
be found i~,the following EPA document (pages C-l and C-2):
"
D331l91
-14-
. .
, ,
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In addit,
contribut
insignifi '
Special ReOort on Inaestee! Inorqanic Arsenic -
r., Mutr i tional Essentialit. EPA/625/J-87 /013,
.:
~ it should be noted that as previously stated, the
~: of arsenic to the total cancer' risk is
t.
It is our policy to utilize sample --results that are below the
CDL in, the risk assessment. For ,a more detailed explanation of
the reaSO,1) for utilizing such data, see the response on page 4. "
l.t was incorrect of the reviewer to state that a duplicate
sample from the same monitoring well showed no detectable
ars~ic. The duplicate groundwater samples from monitoring well
MWLWl-~ revealed the pr~sence of arsenic at 14.2 ~g/L and
12. 2 ~g/L. These sample ,esults can be found in Appendix F of
the RI Report.
" t.
C088eDt:
The calculated risks associated with PCBs and PABs from exposure
(via ingestion and inhalation) to groundwater from the site are
overstated. \
. The low solubility of the carcinogenic PASs could be ..
strong indicator that they are not present in dissolve8
form.
. PABs in groundwater were probably adsorbed onto colloidal
particles that were able to get through the monitoring
well screen.
. PCBs and PABs detected in groundwater from the Overburden
Aquifer would not be present in the water delivered to the
tap because the sand filter pack installed on every
drinking water well (to reduce turbidity) would remove
them. '
. The chemical analytical results from unfiltered
sampl.. should not be used in quantifying risks.
. .
. All".' ,- the PABa were found in groundwater taken
Sin~80ftitoring well (MNLWl).
. PCB-'" 4 vas' detected at concentrations below CDLs.
;urbid
from a
Response:
PABs, have a low water solubility and therefore, it is possible
that: PABs could be adsorbed to colloidal particles ~ however,
there is presently no conclusive site-specific information
available ~o determine the percentage of the PABs that are
dissolved /in the overburden aquifer versus the percentage of
PABs that are adsorbed to particulate matter. The RI (page 4)
D331191
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recognizes the possibility that PCBs and PABs may be adsorbed to
suspended paJ:ticulate matter and that the use of the onsi te
overburd.D.~..quifer as a domestic ,water supply source may. be . an
unlikely ~sure scenario. Additionally, the modeling effort
pre.sented .;.~n Sections 5 and 6 of the RI do not predict
significan~ offsite migration of PCBs/PABs. The. risk analysis
appropriately and conservatively evaluates the use of the onsite
overburden aquifer.
In addi tion, even if PABs were adsorbed onto colloidal
particles, there is no site evidence available to suggest that
such particles would not be delivered to the tap of a consumer
utilizing the onsite overburden aquifer as a domestic water
supply source. A sand filter installed on the well may reduce
the .'amount of PABs that reach the tap, however there is no
guarantee that PABs would be completely or sufficiently removed
from the "at tap" water so as to reduce the risks to more
acceptable levels. Also, it is incorrect to assume that every
drinking wai~r well would be installed with a sand filter pack.
Therefore, the more conservative approach has been taken by,.
assuming that the PABs in the groundwater may be delivered to
the tap and therefore could pose a health risk.
It is typically not EPA policy to filter .organic samples. Ev~
if the PABs were found not to be dissolved in the groundwater -
PABs would still be included in the risk assessment calculatio
for the previously stated reasons.
PABs were not only found in monitoring well MWLW1, as stated by
the commenter, but were also detected in monitoring well MWLW2.
It is EPA Region III policy to use sample results that are below
CDLs in the risk assessment. Por a more detailed explanation of
the reasons for utilizing such data, see the response on page 4.
COIII88Dt:
Exposure to airborne particulates migrating from the site is
implausible. Consequently, the use of the Cowherd model is
highly conservative. Input variables and. the evaluation af the
contaminants (e.g., chromium) are also highly conserv~tive.
RespoDse:
This is an' irrelevant comment. The RI report states that cancer
risks are below l.x 10-7 and hazard indices are less than unity,
even under the conservative scenarios used.
COJI8eDt:
There is a basic
constituents like
using the/'shower
paramete~s used in
flaw in the use of
the carcinogenic PABs
model. Divergences
the calculations.
extremely non-volatile
to calculate exposure
were noted in input
D331191
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RespODse:
" PAHs are not extremely non-volatile; they are semi-volatile
compounds with intermediate vapor pressUres and Henry's Law
constants. While the model does not specifically state that the
use of semi-volatile compounds is appropriate, ne'i ther does it
prohibit the application or state that such an application is
inappropriate. Estimation of contaminant release into the air is
based on the two-film gas-liquid mass,transfer theory that is the
basis "for an overall mass transfer coefficient. The mass
, transfer" may be limited by both liquid- and gas-phase.
resistances, but mass transfer of volatile organics with Henry's
Law constants greater than 10-3 atm-m3/mol-K is limited by only
liquid-phase resistance. Nothing in the equations makes them
inappropriate for use with semi-volatile compounds.
Several shower scenarios have been re-examined using the Foster
and Chrostowski model with more appropriate input parameters. It
was found that variations in shower room volume were most
significant in the final calculations. Revised calculations have..
been prepared an incorporated in the FS. EPA comment:
[Subsequent to development of this document, EPA's toxicologist
Mr. Roy Smith found an numerical error in NUS's showering model.
The corrected numbers are shown in tableS of the ROD were used
in EPA's decision for the Osborne Site. This change in th~.
numbers did not substantially affect EPA's decision since
contamination in the Clarion aquifer is above MCLs and the fill
contamination requires remediation for PCBs, PARs and metals]
CommeDt:
The whole section (Section 6.4 of the RI)' does not provide a
clear exposition of the uncertainties (and limitation) that are
inherent in the Risk Assessment. There are uncertainties
associated with: the chemical analytical data (there was no
evaluation of its quality); toxicological parameters:
pharmacokinetics; and extrapolation to human health.
RespoDse:
The uncerta1nty section of the RI (Section 6.4) included
discussion pertaining to the following sources of uncertainty:
. The potential error in the estimations (e.g., contaminant
intake levels, exposure time frames) used to calculate
exposure doses for the worst-case and plausible-case
scenarios.
a
. Reliance upon models used to predict contaminant levels and
exposure doses.
. Limitations of the toxicological data base used to derive a
Cancer Potency Factor or Reference Dose.
D331191
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Contrary to the commenter' s statement, the chemical analytical
data were evaluated through the EPA-required validation pro~ess.-
Only data accepted through the validation process (unqualified
data, J, K, L, or [ ] data) were used in the risk analysis.
Additionally, sampling and analytical uncert-a-inties were
discussed. in section 6.4.1.
To the extent possible, toxici ty criteria available on IRIS or
the Health Effects Assessment Summary Tables (third quarter
FY1989)" were used in the Risk Assessment. As these values are-
peer reviewed and take into account the uncertainty in the
available toxicological data base, a detailed contaminant
specific discussion of the basis of the toxicological parameters,
pharmacokinetics, etc., is unwarranted and beyond the scope and
purpose of the Risk Assessment.
Comment:
The use of the OLM to predict the leachate concentration using.
fill material chemical analytical concentrations is not-
appropriate for determining source loading. Consequently, the
resultant OLM and VHS modeling results are highly uncertain.
. The OLM was not developed using field lysimeter
measurements and TCLP data as stated in the RI report. .
. For very low solubility compounds the OLM model will over-
predict the leachate concentrations by 2 to 3 orders of
magnitude.
. Use of the OLM to predict the leachate concentration using
fill material chemical analytical concentrations is not
appropriate for determining source loading.
. Comparison of risks generated using a theoretical leaching
and groundwater model and those estimated for the average
observed concentrations is meaningless.
. Use of the OLM concentrations in this-model (VHS) would be
subject to the same objections as listed above.
Response:
The original OLM used a factor of 0.00211, while the revised
version used a factor of 0.00221 in the regression analysis.
This different value incorporates the revised leaching data base,
which includes data developed during lysimeter tests and during
the development of the Toxicity Characteristics Leachate
Procedure (TCLP) (51 FR 41088). This slight variation will make
no "significant difference in the final leachate concentrations
predicted by this model.
The commenter indicates that the OLM will overpredict leachate
concentrations for low solubility compounds by 2 to 3 orders of
D331191
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magnitude. The EPA states' that (51 FR 41089) lithe observed low
(coefficient for multiple correlation) R2 for the very insoluble
'. compounds is probably due to the inherent inaccuracies and
variabilities of analytical results at very low concentrations
rather than an inaccuracy in the empirical equation."
The commenter also states that the model is conservative for the
purpose for which it was intended, i.e., to evaluate leachate
concentrations from waste. While it is true that the OLM was
developed for actual waste delisting activity,. the EPA also must
assess the hazards due to disposal of the waste in a non~
Subtitle' C setting where no requlation occurs or has occurred.
There is no quarantee, as the commenter implies, that waste
materials become strongly adsorbed to a solid matrix material
over time. It is possible that as the wastes age, that they
become more soluble. At any rate, EPA is charged with protecting
human health and the environment, and preferentially errs on the
conservative side.
Actual contaminant concentrations are useful in predicting health
effects resulting from existing groundwater contamination. The""
data generated from the leaching/groundwater modeling are used in
predicting future risks in a scenario where the groundwater may
be remediated while the source material. remains on site. The
risks are not directly comparable and actually serve two distinct
purposes in the RI/FS process. . . -
The VHS model is used to estimate the ability of an aquifer to
dilute the toxicants from a specific volume of waste. The entire
model is based on contaminant concentrations in leachate.
Comment:
This position (the inclusion of the majority of site contaminants
as indicators) is an extreme "worst case" where maximum observed
concentrations are presumed to be uniformly distributed over the
site. Prevalence should be considered in the inclusion or
exclusion of data. A single positive detection is not a verified
finding. This "worst case" position is further exaggerated- by
inclusion of constituents that were found below the COLs at the
maximum observed concentration. We believe that an adequately
conservative "worst case" evaluation is one that: uses maximum
observed concentration above the COLs: maximum reported (in the
toxicological literature) absorption factors, both dermal and
ingestion: for .an upper bound exposure scenario where the
exposure parameters are higher than those postulated for the most
probable case. This would result in a conservative estimation of
health risks that is still overstated because upper bound
parameters' are used for water and soil ingestion rates,
carcinogenic potency and the uncertainty factors integrated into
the RfOs.
D331191
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Response:
The conservative worst case exposure scenario may certainly be
defined by manipulating exposure. parameters such as ingestion
rates, absorption factors as well as by the evaluation of maximum
contaminant levels. The RI evaluated the worst case scenario by
using maximum contaminant levels, which is a well accepted
methodology for Superfund risk assessments.. The evaluation of
maximum contaminant levels errs on the side of safety by focusing
on "hQt spots" of contamination to which receptors may be
exposed. ..
The statement that upper bound parameters are used for water and
soil ingestion rates that are typically cited in EPA references
and the scientific literature is not necessarily true. For
example, the 2 liter per day water ingestion rate is generally
described as an averaqe water ingestion rate.
Comment:
'.
The PCBs found in the onsite surface and subsurface soil should
be separated into those two potential exposure classes. In
addition, the data are not further characterized by prevalence,
i . e., number of posi ti ve detections above CDLs per number of
samples analyzed, as a measure of the probability of exposure...
This is especially important in presenting a balanced evaluation
when employing such conservative protocols as assuming uniform
distribution of a toxic constituent over the entire media at the
maximum observed concentrations. It is our understanding that
the constituent values cited in this statement originated in the
data obtained in previous RIs. The report should clearly state
this fact and its meaning in the context of present day exposure.
Response:
It is agreed that analYtical data found in surface and subsurface
soil be separated. However, the data presented and discussed in
this section of the RI (1.2) are from previous investigations as
clearly stated on page 18 of the RI. It is presented as "site
background information." A detailed prese~tation (including
statistics) was never the intent of this section.
Comment:
The following remedial investigation/risk assessment terms,
phrases, or concepts were unclear or improperly defined or
utilized in the RI report:
. Weight of evidence
. Fingerprint
. Risk characterization
. The basic cancer risk equation
. The use of standards/criteria
characterization
in
risk
assessment/risk
D331191
-20-
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Response:
The "weiaht of evidence"phrase presented on page 158 of the RI
Report, second paragraph, is descriptive of the toxicity profiles
in that the profiles briefly summarize available toxicity data
from the literature for an indicated compound. Given that the
weight of evidence term is most commonly used in the context of
classifying carcinogens, alternative wording may eliminate any
confusion for the reader. . .
. .
The term. "finaerDrint" as used in the RI is a reference to the,
compounds most representative of contamination at or migrating
from the site. The term is not indicative of a particular
product such as gasoline or diesel fuel.
As discussed in SPHEM (EPA, 1986), risk characterization
estimates potential noncarcinogenic and carcinogenic health risks
associated with contaminant exposures. It is agreed that risk
characterization (formally) does not compare actual or predicted
toxicant concentrations to standards/criteria although such..
comparisons are frequently made (e.g., regulators use such
comparison to determine compliance/noncompliance) as a less
formal indication of the potential for adverse effects.
The statement presented on page 155, third paragraph, indicating,
that the comparison of predicted doses to reference doses
provides a semiquantitative indication of the likelihood of
threshold effects is a reference to the fact that the predicted
dose/reference dose ratio is not a mathematical prediction of the
severity or probability of toxic effects, it is simply a
numerical indicator of the potential for adverse effects.
Regarding the cancer risk eauation presented on page 186, second
paragraph, SPHEM (EPA, 1986) indicates that "for relatively low
intakes it can be assumed that the dose-response relationship
will be in the linear portion of the dose response curve. Under
this assumption, the slope of the dose-response curve is
equivalent to the carcinogenic potency factor and risk will be
directly related to intake at low levels of exposure." The
carcinogenic risk equation is as presented on page 185 of the RI
and page 77 of SPHEM (EPA, 1986). This expression will produce
incremental cancer risk in excess of unity when large doses are
evaluated.
The equation (RI, page 195) is valid only at low risk levels.
For sites where 'Chemical intakes may be large, an alternative
model should be considered. For example, the one hit equation
which is consistent with linear low dose model may be useful.
The carcinogenic risk equation is as presented on page 186 of the
RI and page 77 of. SPHEM (EPA, 1986). The wording presented in
SPHEM (EPA, 1986) agrees with wording presented in the RI
page 185 and 1986.
D331191
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Comment:
The following inconsistencies
and/or spreadsheets:
exi'st between the
text,
.tables
Tables ES-2 and 6-9 are identical and purport to tabulate
the cancer risks and chronic toxicity health risks
associated with future domestic use of groundwater under
the site (for the Overburden Aquifer). The text in
.Section 6 indicates that the detailed. calculations are
presented in Appendix I: however, the Lotus spreadsheets do.
not agree with the values shown in Tables ES-2 and 6-9.
. Bis(2-ethylhexyl)phthalate was not listed in the chemical
analytical data base as a contaminant in the Homewood
Aquifer yet it was used in the risk calculations associated
with domestic use of on-site groundwater from this aquifer.
.
. Di-n-butyl phthalate was not detected in the OVerburden
Aquifer.
.
. Pentachlorophenol was
OVerburden Aquifer: it
Aquifer.
erroneously
was found
ascribed to the
in the Mine Spoils
. Benzene. was
this RI.
not detected in the samples. obtained during
. The Mine Void is not part of the Clarion Formation.
Consequently, the values reported for vinyl chloride and
TCE on page 20 of the text do not agree with Table G-~3.
. The concentrations of several contaminants detected in site
groundwater, soils, surface water, etc. are summarized on
pages 19-21. In several cases, some of the sample results
do not agree with the value result given in Appendix F
and/or tables found in Appendix G.
Responses:
It is recognized that there are some discrepancies between the
spreadsheets in Appendix J and Tables ES-2 and 6-9. A new table
has been developed for the final FS. The risk calculations that
were originally summarized in Tables ES-2 and 6-9 have been
recalculated to incorporate changes in some of the input
parameters for th~ shower model. The following changes were made
to this model, which resulted in a lower risk estimate.
D331191
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I
P
spreadsheets.
tables.
Bis(2-ethylhexyl)phthalate is listed in the chemical analytical
data base as a contaminant in the Bomewood Aquifer. . This
compound can be found on pages 48 and 52 of Appendix P.
, Oriqinal COrrected
-, , parueter Value Value
~-----
Calibrati~ .ater temperature, Tl 298 K 293 It
Shower wate~ temperature, Ts 323 K 318 ~
, '
Water viscosity at Tl 1.002 cpo 0.982
Water viscosity at Ts 0.5996 cp 0.616 cp
~hower water droplet diameter 0.25 II1II 1.0 II1II
Shower droplet drop time 0.5 see 2 sec
. r
Showe~ water flow rate 0.3 L/min 10 L/min
Shower room air volume 1 m3 10 m3
Air exchange 'rate 0 . 011 min-l 0.0083 min-l
Shower duration 20 15
Total duration in shover room 50 20
n addition, the cancer risks from exposure to anthracene al: ~
yrene have been subtracted from the total risk. listed on tt ~
These values have been listed in the new summary
Di-n-butyl phthalate was detected in the Overburden Aquifer.
The sample data can be found on page 40 of Appendix P.
The Mine Spoils Aquifer and the Overburden Aquifer are the same
aquifer. Therefore, pentachlorophenol can b. ascr ibed to the
Overburden Aquifer .".n though it va. li.ted in the chemical
analytical data b... .. . contaminant detected' in the.. Mine
Spoils Aquif.r.
. .
Benzene va. detected in samples that vere obtained ~during the
previous and mo.t recent RI. Positive results for benzene can
be found ln Appe~lx P, page 35. Benzene vas detected in
monitoring well MWLWl at concentrations of 3.2 \19/L and
3.5 IAg/L.
The - REM III Team considers the Mine Void to be part of the
Cla~ion Formation based on the geologic conditions at -the site.
It is recognized that some sample results summarized on
pages 19-21' "do not agree vith the sample results given in
Appendix p' and tables found in Appendix G. The reason that they
do not agree is because these pages summarize sample results
...,....".
-~"t-
-------
from previous studies, spe~ifically the initial RI and the EPA
FIT investigation. On page 19, paragraph five, it clearly states
that the findings from these two, ,(previous) investigations are
summarized in the following sections~ . . .
Issue No.2: There is no evidence that vinyl chloride detected
in the Clarion Pormation comes from the Osborne Landfill site.
,
Comment:
Numerous comments were submitted by the PRP's and their
consul tants regarding statements made in the RI and FS reports'
. that the source of vinyl chloride is believed to be the Osborne
Landfill Site. Commenters indicated that little (i.e., below
detectable levels or below the Contract Detection Limit) vinyl
chloride contamination was detected either along the perimeter of
the landfill or within the landfill itself and that higher levels
of vinyl chloride were, detected offsite. The conunenters also
believed that offsite sources of groundwater contamination could
be responsible for the vinyl chloride contamination in the mine
void and Clarion Formation. Commenters stated that there was no "
significant vinyl chloride contamination (or its parent product
such as trichloroethene or related constituents) detected in soil
samples collected from the fill area, which would not support
statements that the site is the source of the vinyl chloride
contamination. . Additionally, one comment indicated that chemical"
data do not support statements in the RI and FS that drums atop
the highwall may be responsible for the vinyl chloride
contamination. .
Response:
The fact that vinyl chloride was detected at the maximum observed
levels in a well location (MWV2) on the eastern property boundary
of the site is one possible indication that the site may be the
source of the vinyl chloride contamination. This conclusion is
further supported by the fact that vinyl chloride was not
detected or was found in only trace amounts in the Clarion or
mine void wells located at greater distances from the site. The
absence of vinyl chloride in onsite monitQring wells does not
necessarily mean that vinyl chloride is not present onsite (vinyl
chloride was detected onsite during the PRPs 1984 RI and was
detected in onsite surface water samples). This absence may
easily be accounted for by taking into account the size of the
site versus the number of monitoring points. A single discrete
release area of v~~yl chloride may easily have been missed by the
network of monitoring wells, which was intended to characterize
general groundwater quality rather than provide blanket coverage
of the entire site. If for example vinyl chloride had been
disposed of in the southeastern corner of the site or atop the
highwall, none of the monitoring wells other than the ones that
did show significant levels of contamination (MWV2, MWVS) would
be expected to detect the release.
Another indication that the site may be the source of vinyl
D33l19l
-24-
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chloride contamination is the past history of materials taken to
the site. These materials include large quantities of spent
"spirits" which could potentially"be the parent product of the
vinyl chloride contamination. It is possible that a reservoir of
volatiles does exist at the site, but was not detected during the
RI (low levels of TCE were detected in a limited amount of soil
samples). Another possibility is that the reservoir of volatile
contamination was previously remediated during the 1983 removal
action. (No analytical data could.. be found for the 45 cubic
yards .of soil that were excavated during this removal action.)
It is be:J..ieved that these soils were excavated as a result of.
leaking drums that were present above the highwall, contrary to
comments indicating that the chemical data do not support this
possibility.
Issue Ho. 3: The information within the RI Report fails to
provide an accurate and consistent assessment of groundwater flow
associated with the overburden and underlying aquifers.
Inaccuracies in the interpretation of vertical flow into the
underlying aquifers affects the evaluation of potential
contamination migration from the site. "
Comment:
Various comments on the RI Report indicated that the
hydrogeologic assessment was based on incorrect assumptions and'
interpretations of data, and that potential receptors or
migration pathways could not be properly identified. Comments
submitted by Fred CHart & Associates stated that the RI report
had numerous contradictions within the report with respect to the
Clarion and Mine Void flow systems. The most significant comment
pertained to whether there was a clear understanding of the
relationship (groundwater flow) between the onsite water table,
the mine void, and the Clarion Formation. Similar comments were
submi tted that questioned the interpretation of data for the
Homewood Formation and whether the doming (mounding)
characteristic of this formation was due to leakage along the
well bore rather than 'leakage through the underlying clay layer.
Commenters also questioned whether there was a clear
understanding of the site geology, based on inconsistencies,
deficiencies, and inaccuracies within the RI Report.
Response:
The interrelationships among aquifers in the site. vicinity have
been well established through the remedial investigation.
Intervening confining units have been identified and
characterized to the extent required to evaluate the site
impacts. The findings of the RI represent a significant advance
in understanding site conditions relative to the pre-
investigation extent of understanding, which was presented by
Cooper Industries and their consultant (Fred C. Hart, Inc.) as
being adequate.
It
is
unclear
how the
commenter
determined
that the
report
D33ll9l
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implies that groundwater may flow preferentially into the mine
void (specific page references ~ould facilitate response) when
the commenter later quotes the RI report as saying "the. large
head difference between the overburden and Clarion/mine void flow
system suggests that the hydraulic connection and leakage rate
across the highwall are limited." It is clear from this text of
the report that preferential flow into the mine is not implied.
The commenter's conclusion relative to. limited flow from
overburden into the mine void is the' same as' is presented in the
report. The commenter perceives an incorrect. implication where'
there is. none. .
Overall flow directions within the mine void are ultimately
controlled by the location (s) of groundwater discharge points.
As the strip mine pond east-southeast of the site is the nearest
obvious discharge point for the mine void, interpreting
groundwater flow within the mine to migrate towards this pond is
appropriate. This is verified by the slightly lower water
elevation in the pond than in the mine void, and the observed
distribution of vinyl chloride. The suggestion for determinin~-
flow directions by using electronic water level indicators would
be extremely costly, may not provide any conclusive definition to
flow directions, and ignores the use of the simpler, more
straightforward evidence available. . .
With respect to comments pertaining to the spoil material acting
as an impermeable or low permeability barrier, the mine spoil
and fill mat,,~rials that comprise the overburden aquifer
throughout the site can both be expected to have overall
moderately high permeabilities. Along the southwest edge of the
si te, however, the overburden thickness is greater due. to the
ridge of mine spoil. This greater thickness of overburden above
the water table results in greater lithostatic pressure on the
aquifer, which would serve to decrease porosity and hence
permeability to some degree. This decrease in permeability is
probably not great: however, even a moderate decrease will be
sufficient to deflect or refract the flow pattern along the
slightly more permeable central portion of the site.
Potentiometric surface maps support this idea. -The mine spoil
ridge is not presented as an impermeable or low permeability
barrier as interpreted by the commenter.
In response to comments regarding inconsistencies associated with
water level measurements in the Homewood Aquifer, examination of
the water levels in the Homewood wells reveals that between the
October 20, 1988;" and February 21, 1989, a consistent 1.5-3 foot
rise in water levels was noted, except in well UMW5. It appears
that a 10-foot error was probably made in recording the water
level in this well, as an increase in 10 feet would make this
change in water levels fit in with the other data. All other
water levels have been checked to identify any outliers (none
have been found).
The commenter questions the presence of mounding on the basis of
possible leakage along the well bore of monitoring well MWH4.
D331191
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This is extremely unlikely' as significant shrinkage cracks are
uncommon and, if present, can be expected to be very localized
especially where the cement is below the water table, -as is the
. case for MWH4. Also, the highest water. level was not measured in
MWH4, but in UMW5, a well installed during a previous Hart
investigation. Of the nine Homewood wells, UMWS, MWH4, and MWH2
all had water levels consistently several feet higher (5 feet or
more) than the other wells. These wells also lie along a linear
trend, which supports the RI report conclusions in preference to
. the commenter's interpretation. Pumping test. data conclusively
shows"a greater hydraulic connection among these wells that.
exists between these wells and the six outlying wells.
The latter portion of the comment is also inaccurate as follows:
The commenter states that the report describes the mound as a
zone of increased transmissivity without increased recharge. The
axis of the mound is considered to be an area of increased
transmissivity; however, the report does not state anywhere that
increased recharge is not occurring. In fact, increased recharge
is fundamental to the existence of the mound. This recharge may..
be occurring near the offsite pond, as evidence by the highest
observed hydraulic head being measured in UMW5. The highest
hydraulic head will be found closest to the area of greatest
recharge; therefore, UMWS is the closest. well to the recharge
zone. The low gradient observed along the axis of the mound,
coupled with the steep gradients away from the mound, support the-
RI conclusions as opposed to the commenter's assessment.
steepening of flow gradients can be a general indication of
decreased permeability; therefore, the mound axis is a reflection
of localized higher permeability instead of lower permeability as
the commenter contends.
With respect to the comment that the Homewood Formation short-
term pumping test was invalid, the short-term pumping test was
designed to provide a general approximation of the Homewood
aquifer characteristics. The results are considered to be a good
estimation (much better than averaging slug test data but
definitely not sufficient for final design of a groundwater
extraction system). It would be premature to . go through the
considerable time and added expense to perform a long-term test
before a determination is made whether remediation is likely to
be required. Such a long-term test may require that a new
pumping well be drilled and the addition of several more
observation wells, along with additional manpower and equipment
costs. The possible magnitude of error of the values calculated
is greatly overstated by the commenter, as quasi-steady state
conditions were being approached by the conclusion of the test.
The probable range of error is less than one-hal f order of
magnitude, in contrast to the commenter's contention of several
orders of magnitude.
The commenter also presents a series of calculations intended to
prove that the observed cone of influence could not have been
created by the pumping test. The approach used by the commenter
is totally inappropriate for the situation, as the fact that the
D331191
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aquifer is semi-confined is "ignored in the analysis. A review of
the summary of calculations reveals that porosities of 10 percent
and 1 percent were used and that the approach taken assumes that
the aquifer is dewatered (area of. 2-foot drawdown contour is
approximately 500 feet x 150 feet, 500 feet x 150 feet x 2 feet
drawdown x 0.10 porosity = 15,000 ft3 = 112,200 gal"lons). This
ignores the fundamental fact that the aquifer is semi-confined
and as such, was not dewatered at all during the test. As no
dewatering occurred, the only release of water was from storage.
AccorQ~ng to Freeze and Cherry (1979), storativities in confined
aquifers.~ypically range from 0.005 to 0.00005. This release of.
water "only from storage is why much larger, extensive cones of
depression develop due to pumping from confined aquifers versus
pumping from an equally permeable and porous unconfined aquifer
(which would release water both from storage and due to draining
of the interstitial pores). Substituting a range of storage
values for the porosity values used in the commenter's analysis
will result in an excellent match between the volume of water
pumped and the observed cone of depression.
.
With respect to the comment that actual hydrologic values
(Homewood Formation) cannot be determined using the data
presented in the RI Report, the rapid drawdown observed is a
characteristic response to pumping from a confined or semi-
confined aquifer. Fracture controlled flow within the formatio~
will further enhance this response, but does not by itself.
explain the drawdown patterns observed at UMW3 and UMW4. The
proximity of these wells to the subcrop of the Brookville
underclay, as mentioned in the RI report, is a more likely
explanation for the non-characteristic responses observed in
these two wells. The data were not made to fit any preconceived
conclusions as suggested by the commenter, but was interpreted
using an approach consistent with accepted analysis techniques.
As "ideal" conditions and responses are rarely observed in actual
field tests, especially in an aquifer wi th both primary and
secondary permeabilities, an approximate fit rather than exact
fit of the data is common and is routinely used in the analysis
of pumping tests.. The occurrence of varying rates of leakage
from an overlying aquifer and the subcrop of the pumped formation
in the vicinity of the test further complicate the situation,
calling for a best fit approach rather than hoping for (and
almost certainly never obtaining) an exact fit.
. "
The analysis of the test data used is consistent with generally
accepted practices, as sufficient pumping was performed to offset
any early-time iRconsistencies in the data, and quasi-steady
state conditions were being approached. If remediation is
required and a more elaborate pumping test is performed,
alternate methods of analysis can be explored. The data obtained
should be of greater detail due to the addition of additional and
closer," observation .wells, and thus appropriate for a more
detailed analysis. "
with respect to the comment" that the RI Report attempted to
substantiate the results of the pump test by performing a water
D331191
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balance, the analysis presented in the RI Report estimates the
rate of leakage through the Brookvi1le underclay by calculating
discharge rates from the Homewood Formation along the site
boundary. This approach assumes that the recharge to the
Homewood Formation is due to vertical leakage from the..overburden
through the underclay onsite, which is consistent with the
presence of a groundwater mound in the Homewood Formation onsite.
The comment appears to have little or no relationship to this
analysis. Ei ther the comment represents a misunderstanding on
the reviewer's part or additional clarification of the comment is
needed. .Groundwater discharge from the overburden into the mine
void and the subsurface location of the Brookvil1e underclay crop
line have no bearing on the analysis, as the comment attempts to
indicate.
wi th respect to comments regarding inaccuracies in the
evaluations of site geology, and specifically the observed
variability in the Clarion Formation thickness, it is obvious
from examination of the boring logs and topography that the
reported variation in thickness of the Clarion Formation is due..
to erosion of the upper portion of the Clarion Formation near the
site. This is and has been understood all along: however, it
does not alter the 'fact that the observed thickness of the
formation ranged from 15 feet (where eroded) to 73 feet in the
study area.
With respect to the comment pertaining to inaccuracies in the
thickness of the Brookvil1e underclay, the thickness on page 49
is reported to range from 0.1 to 9 feet, while on page 63, the
thickness is reported to range fro~ less than 1 foot to
approximately 10 feet. It can be argued that 9 feet versus
approximately 10 feet and 0.1 feet versus less than 1 foot
represent somewhat of an inconsistency; however, it is obvious
that the significance of this is minimal, if any. The range
reported on page 63 is a generalization of the more precise
numbers given on page 49. The implication that defining the
thickness to within one inch is critical to understanding
vertical migration rates is an oversimplified treatment of the
actual conditions. In reality, the thickness varies considerably
across the site due to depositional, erosional, and man-induced
(mining) factors, thus leakage rates will vary considerably
across the site and surrounding area. In some areas, the clay
may be totally absent and in others it may exceed 9 (or 10) feet.
The accuracy of any calculations must be considered approximate
due to the variations in thickness and also the probable wide
variations in permeability within the Brookville underclay. The
commenter implies that a much greater degree of accuracy would be
gained by a more precise definition of the underclay thickness,
when in fact, the improvement in accuracy that is implied would
actually be minimal due to other variations in physical
characteristics.
with respect to the comment pertaining to consistencies and
inaccuracies of Figures 3-4, 3-5, and 3-7 (in the RI report), the
water levels appear inconsistent because they were recorded on
D331191
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different dates. Figure 3-5 water levels were taken
August 5, 1988, and can be added to the legend of this figure.
Figure 3-7 water levels were taken on. February 21, 1989, as
indicated. Due to the scale of Figure 3-5~ the screened interval
at MWV2 and MC3 was not indicated. .This interval could be added
to the figure. Furthermore, well construction diagrams, which
can be found in the appendices, indicate the screened intervals
of all wells. The Upper Burgoon sandy shale shown for MWB2 is
shown to be the same thickness on both Figures 3-4 and 3-5. This
thickness is scaled off to be approximately 29 feet. The total
thickness. of the Burgoon formation at MWB2, as shown on both.
figures is approximately 110 feet. It does appear that there is
a slight drafting error on Figure 3-1 showing the placement of
the top of the open borehole, which should start just below the
gray sandy shale. This can be corrected: however, the thickness
of the Burgoon Formation at this well is depicted correctly on
both figures.
In response to the comment pertaining to inconsistent water level
measurements between Figure 3-6 and Figure 3-7, water levels..
depicted on these two figures were measured on separate days.
Those water levels shown on Figure 3-6 were taken March 3, 1989,
and the water levels depicted on Figure 3-7 were taken
February 21, 1989. Both figures do indicate the date of the
water level measurement event.
With respect to the comment that states that various figures do
not display the water levels by which those figures were derived,
pages 55 and 56 of the RI report (Table 3-1) display all water
levels from various dates of all the monitoring wells at the
site. It is from this table that the contour maps were
constructed. A reference to this table could be inserted under
the legend of the above noted figures.
In response to the comment that the water level for MWU2 was
deleted in the interpretation of the potentiometric surface and
that that this may affect the depicted direction of flow, the
water level elevation for MWU2 was not deleted in the
interpretation of the potentiometric surface and flow directions
are not affected (see Table 3-1 for water level elevations).
However, no contour lines were drawn at MWU2 due to the lack of
data points near this well and due to the distance of MWU2 from
the other 3 wells. Water level elevations of MWU2 on the 3 dates
used to construct the potentiometric surface maps are lower that
the 3 upqradient wells, indicatinq a qeneral flow direction
towards MWU2, i.~., a northwesterly flow direction as mentioned
on paqe 71 of the RI report.
Issue No.4: The evidence does Dot show that vinyl chloride has
miqrated to the Bomewood or Burgoon pormations from the site, and
therefore further study to moni tor the levels iD those wells
should not be assessed aqainst the Osborne Landfill site.
D33ll9l
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Comment:
i'
The most significant comment pertained to whether the Homewood
.. Formation, which has exhibited low levels of trichloroethene at
one. well near the boundary of the fill material, is a receptor of
contamination from the above disposal area (onsite. .water table).
Commenters indicated that they felt that the low levels of TCE
were due to leakage along the well bore rather than from leakage
between the formations. Similar co~ents were made with respect
to the Burgoon Formation, which exhibited low levels of vinyl
chloride. Commenters also indicated that the vinyl chloride
contamination in the Burgoon could be the result of improper well
construction. Comments submitted by the PRPs indicated that
resampling of these wells (which exhibited contamination during
the RI but not during the resampling) proved that the
contamination detected during the RI was probably due to leakage
along the well bore.
Response:
No elaborate theories regarding groundwater migration from the <,
site to the Burgoon aquifer were presented in either the RI or FS
reports for the site. The Fred C Hart sampling of the wells in
1989 does not provide any evidence to support the contention that
leakage along the well bore annulus is responsible for
contaminants found in deeper aquifers. Extended pumping of th~
wells prior to sampling would serve to increase any leakage rates
from overlying aquifers to the well, as the greatest drawdown due
to pumping would occur in the immediate vicinity of the well.
This would accelerate any leakage that might be occurring:
therefore, if leakage is occurring, contaminant levels in the
well could be expected to rise due to the pumping.
The Hart idea that shrinkage cracks may be a migration pathway
is an extremely remote possibility at best, as the shrinkage
cracks would have to propagate vertically for great distances or
be found as a network of closely spaced, interconnecting
fractures throughout the length of the cased-off borehole. This
is extremely unlikely, especially in solid rock and under
saturated conditions.
..
The well construction techniques used during the field activities
conform to the current guidelines for monitoring well
installation through a confining layer (using steel casing set
and grouted in place through the confining layer). The sampling
performed by Cooper did nothing to substantiate the potential for
leakage along the. casing annulus, as the extended pumping would
serve to accelerate any leakage that may be occurring instead of
negating the leakage effects. The Cooper sampling actually
confirmed the presence of TCE in the Homewood monitoring well
MWH4. The sample collected (MWH4-2) after pumping the well for
an extended period actually exhibited low levels of TCE (2 ~g/l),
based on the laboratory backup sheets that were submitted to EPA
by Cooper Industries.
D331l91
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Issue 110. 5: serious deficiencies in sampling procedures were
noted, which call into question the validity of some analytical
test results. ,
co_ent:
Numerous comments were' received, that identified alleged
deficiencies during the various sampling activities. The most
frequent comment pertained to imprope~ or lack of decontamination
procedures during the field investigation., other comments
pertained to improper sample preservation procedures, inadequate
mixing of 'groundwater for sample splitting, inconsistent sampling'
procedures during the soil gas study, improper backfilling
procedures of test borings, improper sample collection, with
respect to the sampling interval, inconsistent use of latex
gloves during sampling, potential contamination of wells due to
polyethylene shavings being observed falling into some wells, and
improper collection of one residential sample. Another comment
indicated that a metal sampling device was (accidentally) dropped
into one of the monitoring wells.
Response:
The deviations from the Field Operations ,Plan (FOP) were minor
and appropriate safeguards were taken to ensure that quality data
were gathered. As invariably occurs with any field investigation'
of this magni tude, unexpected condi tions are encountered and
situations develop which require field modifications to planned
procedures. The stated magnitude of the potential problems
described by the PRP is greatly overstated. The procedures
employed, in general, conform to currently acceptable
methodologies for field work. The levels of contaminants
detected in moni toring wells and the close agreement between
analyses of samples obtained from the same wells over multiple
sampling rounds is a clear indication of the overall high quality
of the data gathered.
It is important to additionally note that the PRP oversight
personnel were present during all activities and did not express
concern regarding any of the field ,procedures or minor
modification of procedures at that time. In' fact, certain
modifications (e.g., soil boring sampling intervals) were
modified at the request of the oversight personnel in order to
accommodate their requirement to split samples.
with respect to.. the comment regarding the use of "dirty"
polyethylene (PE) tubing, REM III field personnel rely on purging
procedures to guard against contamination due to unanticipated
field events such as small amounts of dust on the PE tubing. Our
procedure is to lower the tubing a short distance below the water
surface prior to purging. This minimizes contact between the PE
tubing. and sampling media. Near the end of a purge, the tubing
-is slowly withdrawn to insure that water, which has contacted the
. PE tubing, is removed. If the portion of the tubing that will
enter the well is visually dirty, it is wiped off prior to use.
D331191
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i
I
I'
with respect to the comment that samples collected from two
, , monitoring wells (SW2 and UMW3) were not filtered or acietified
until the following day, this occured only due to problems with
obtaining electric power in the field trailer and problems with
the gas generator, which is the alternate source of power. Due
to this occurrence and the approach of darkness, REM III
" personnel were forced to filter the remaining samples the
following morning. A review of the analyses for the two samples
in qu~stion do not appear to be significant,ly different from
other wells in their respective formations. Thus, the effect of,
filtering' 'and preserving the two samples on the following day
does not appear to have impacted the usage of these results.
The use of latex gloves was found to be ineffective when raising
or lowering the submersible pump and were not always used as the
commenter stated. The weight of the submersible pump shredded
the latex gloves, making their use irrelevant. As stated above,
our purging procedures should protect against the chance of
contamination caused by hand contact with the PE tubing or rope
used for lowering the submersible pump. Latex gloves were used
when handling the submersible after deconning and prior to entry
in the well, unless it could be placed in the well without hand
contact.
With respect to the comment that inadequate mixing of split'
samples sometimes occurred, not inverting a mixing bottle was an
oversight that had a negligible effect on sample mixing due to
the homogeneous nature of the sample media (groundwater) and the
mixing that occurs during the' introduction of the sample from
each bailer into the mixing bottle. The REM III Team was never
informed that the PRP split sample results were not similar in
nature.
With respect to the comment that the amount of preservative added
was not always measured and that the use of pH paper is a
subjective way to measure pH, the amount of preservative used
will vary slightly from person to person. The reauirement during
preservation is to meet a specified pH, not to use a specified
amount of preservative. Unless an excessive amount '- of
preservative is used to reach a pH level, then the amount of
preservative used is inconsequential. The subjectiveness
involved when two people compare colors of pH paper in the
process of preserving samples is trivial to the resulting
analysis.
In response to the comment that PE shavings were observed falling
into monitoring wells MWH2, there is always a possibility of PE
shavings entering a well when introducing or removing PE tubing.
The sampling practice of using bottom loading bailers (lowered
5 feet to 6 feet below the surface of the water) should minimize
PE shavings being introduced into the sample. When PE shaving
are found in the sample, the labs are notified to take corrective
action. No shavings were observed in any of the samples
themselves.
D331191
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In response to the comment that dirty nylon rope was used to
lower the pump at well MWBl, it is not clear what Hart me~ns by
"dirty." It is REM III policy to use clean PE rope at each well.
Prior to purging MWBl, it was established that the recharge rate
was greater than the purge rate. The submersible pump was
lowered to just below the water's surface minimizing any chance
of contamination even if the rope was "dirty". The well results
came back clean, again proving that. .the purging techniques were
sound ~ .
With respect to the comment that the Framus (a Framus is a small'
sampling device) was dropped into well MWV2, the framus is made
of stainless steel and it is of no consequence that the Framus
was left in the well. This well was found to be contaminated
with vinyl chloride and not metals.
In response to the comment that water samples were collected from
a garden hose at the Breese residence, sample 05-RW2-l was taken
directly from the spigot located on the outside wall of the.
Breese residence and not from the hose as implied by the.
commenter. The garden hose was only used to divert water away
from the house while purging.
Issue No. ,: Serious deficiencies in the drilling procedures
were noted which call into question the validity of som."
analytical results.
Comment:
A number of comments were generated by the PRP's consultant that
pertained to alleged deficiencies during both the Phase I and II
drilling programs. The most frequent comment pertained to
whether some of the wells were properly installed (specifically,
wells MWV2 and MWH4, which exhibited low levels of volatile
organics). The commenters questioned whether some of the casings
were properly decontaminated, whether the wells were properly
grouted, or whether bentonite was used in the grout at all of the
well locations. Other comments pertained to the integri ty of
well MWC1, since it was constructed near another monitoring well
(MWOl) that was suspected of vandalism by the PRP's consultant.
Response:
The deviations from the Field Operations Plan (FOP) were
necessary in a .few situations due to unanticipated geologic
conditions, which is not uncommon when installing monitoring
wells. The modifications (or deviations) from the FOP were most
often standard and acceptable practices for installing monitoring
wells at hazardous waste sites. In some instances, what appeared
to be a serious deficiency by the PRP oversight contractor was
often ei ther a minor issue, which had no consequence on the
validity of the data, or was a misunderstanding of what was
actually being done in the field. overall, procedures employed
during the drilling program conformed to acceptable practices for
D331191
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installation of monitoring wells.
In a few instances temporary surface casings were dragge~ oyer
the site due to problems with site access in the early stages of
the job. The casings were subsequently cleaned at the drill site
by flushing with potable water and wiping away visible dirt, to
the approval of the Site Geologist. All other permanent casings
were decontaminated and moved to well locations on a skid. All
further moving of temporary and permanent casing from the decon
area to the drill site was performed by using a skid pulled by a
small 'dozer.
The soil borings (i.e., test. borings) were not grouted with a
cement-bentonite slurry, but were backfilled with the cuttings as
per the Field Operations Plan. Since the borings were advanced
only to the confining layer, no migration from the upper horizons
to the deeper horizons is likely and backfilling with grout is
not warranted.
The decontamination procedure performed on the sampling equipment. .
by NUS personnel was in accordance with the EPA-approved Field
Operations Plan (FOP). This is the accepted decontamination
procedure for Region III. The acid rinse step was omitted due to
the leaching ability of nitric acid on stainless steel. As per
the EPA REM III Program Guidelines -- liThe acid rinse step is to
be omitted if a stainless steel sampling device is being used and"
metals analysis is required with detection limits less than
approximately 50 ppb. II A ni tric acid rinse was used on the
filtering equipment glassware, as required in the FOP.
In response to the comment that sampling over a 4-foot interval
is not an accepted practice for this type of study, this was not
the original intention of the sampling program but rather, it was
necessary to use this interval in order to collect a sufficient
sample volume to split with the PRP's oversight contractor per
their request.
In response to the comment questioning the integrity of well MW02
because it is located adjacent to a well that was suspected of
tampering, the monitoring well (MW02) was installed according to
specifications outlined in the FOP. This was a shallow (23-
foot) well which required a flush mount construction. When
installed this well did produce water, but later upon sampling,
this well was dry and no chemical data was obtained.
Furthermore, it is not known for certain' the nature of the
damaged well (MWC1), which could have been the result of a
construction problem, rather than that of vandalism. A
replacement well for the original MWC1 was installed as mentioned
above. However, there is no evidence that the original well was
vandalized and damage is most likely the result of a construction
problem. In any event, the chemical data from well MWC1 showed
no contamination (further indication that vandalism as described
above did not occur).
With respect to the comment pertaining to not decontaminating
D331191
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water level indicators prior to inserting them into the borehole,
the water level indicator in question was used to determine depth
to gravel packs and bentonite during well construction a.nd was
used exclusively for measuring these depths, as this device had a
weighted end and was graduated in 5-foot intervals. This device
was sprayed with DI water between boreholes. In addition, most
measurements were made above the water table. A seDarate water
level indicator was used to record water level measurements upon
completion of the well. This instrument was also sprayed with DI
water. between boreholes. Additionally, it must be noted that the
sampling. procedure requires that' wells be purged between 3 to.
5 well volumes prior to sampling, to insure that an unbiased
"representative" sample is obtained.
In response to the comment suggesting that a small fire may have
contaminated well MWB1, the fire in question was built by the
drilling subcontractor and not under the supervision of the site
Geologist, as indicated by the commenter. The fire was built
away' from the well (MWB1) and all equipment. Furthermore,
chemical results of the groundwater at this location showed no..
contamination.
With respect to the comment that an 8-inch temporary steel casing
was not steam-cleaned and was visibly dirty prior to installing
it in boring MWB2, an 8-inch casing was not set in well MWB2. ~
series of casings were set in this well to get below the coal'
seam and included a 12-inch temDorarv casina to 20 feet and a 10-
inch temDorarv casina to 57 feet. A 6-inch Dermanent casina was
ultimately set at 190 feet. The 10-inch casing was
decontaminated at the subcontractor's shop -- as this casing had
to be set quickly in the field, due to placing it below the mine
void opening (i.e., to prevent almost immediate hole collapse).
The permanent 6-inch casing was decontaminated properly and was
grouted in according to the specifications. It should be noted
that groundwater from the sampled zone does not at any point
contact the 10-inch casing.
The commenter stated that the 6-inch casing (set to 205 feet in
borehole MWB1) had small gaps due to the re-welding and re-
setting of this casing. In response to this allegation, no gaps
were observed by the REM III field representative and as
mentioned earlier, .a 4-inch casing was set to 210 feet within
this 6-inch casing and properly grouted as return of grout was
evidence at the surface, ensuring a complete grouting operation.
Furthermore, as mentioned earlier, ~he chemical results of the
groundwater from ~his well showed no contamination.
In response to the comment that stated that bentonite was not
used in the grout mixture at wells MWB1, MWB2, and MWH2 and that
this increases the probability for shrinkage cracks, bentonite
was 'used in the grout mixture for all of the permanent casing
installations. The drilling subcontractor was informed of this
prior to initiation of work. It may have been possible that for
a temporary installation -- even though grouting was not required
-- the subcontractor elected to use a cement-only grout so that
D331191
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. .
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the outer casing did not become dislodged during drilling.
. With respect to the comment that Pennsylvania Drilling personnel
were seen dragging a compressor hose' across the site without
decontaminating it before use, the dragging of the compressor
hose over the ground may have occurred on one or two .occasions.
However, the subcontractor was instructed to decontaminate the
" development hose before inserting it into the ,well. Furthermore,
in most cases, the hose was not. completely submerged. In
addition, prior to sampling, all wells were purged of 3 to
5 volumes. according to EPA protocol.
In response to the comment that the annular space between the
casing and the borehole was insufficient to insure proper grout
placement (MWB2), the annular space between casing and borehole
involving permanent installations was properly achieved. In
instances where temporary casing was installed, it was not
required to have an annular space and in some cases the casing
did have to be driven in place as the commenter indicated.
Monitoring well MWB2 had 3 different size casings set in place, --
two of which were temporary. The permanent 6-inch casing, which
was set to 234 feet, was set in a 10-inch hole drilled to
190 feet, then due to drilling difficulties, was reduced to an 8-
inch hole from 190 to 234 feet. Nevertheless, the entire string
of 6-inch casing was set without difficulty to 234 feet and..
properly grouted. In addition, the entire 6-inch casing from
57 feet to 234 feet was set and grouted in bedrock, which ensures
a more competent annular space than for example an overburden
situation.
Xssue Ho. 7: The data do Dot show that PABs or PCBs
dissolved in the onsite water table and are not mobile.
are
Comment:
Numerous comments were submitted by the PRP and their consultants
on whether PAH and PCB constituents are present in the water
table. The major point of these comments is that it has not been
analytically proven that these constituents are in soluble form,
but rather that they are suspended particles and, would not be
able to migrate offsite. Commenters also indicated that the
supplemental groundwater sampling performed by Cooper Industries
did not detect any contamination in the onsite monitoring wells
(with the exception of low levels of naphthalene) and that the
presence of PAHs and PCB in the "RI" samples may be due to
improper well development or purging. other comments indicated
that due to the low water solubility of PAHs and PCB, these
contaminants are not likely to leach into the groundwater.
Response:
The sampling of the onsi te water table monitoring wells (i. e. ,
the LW series wells) was conducted in accordance wi th proper
sampling protocols. The commenters indicate that the presence of
PAHs and PCBs in the groundwater analytical results may be due to
D33ll9l
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improper well development or purging. The wells were developed
by the PRP's consultant when they were installed in 1984 and no
information is available regardinq' the procedures used to devel-op
the wells. It was assumed that these wells were properly
developed when they were constructed. The sampling of the LW
series wells during the REM III RI followed- - EPA-approved
protocols. The wells were purged of 3 to 5 well volumes except
in the case of monitoring LW-4, which was purged dry and left to
recover (per the requirements of EPA guidelines). A comparison
of fi~ld notes between the REM III Team sampling (1988) and the
PRP's supplemental sampling (1989) revealed no differences in
either sampling procedures (wells were sampled using either a
stainless steel bailer or a teal pump) or purging procedures (the
PRP's purging procedures were very similar to REM III's
procedures) . Additionally, no comments were submitted by the
PRP's oversight contractor that implied that the wells were
improperly purged. In summary, it is unknown why there were such
extreme differences in the analyses. One may need to examine the
analytical procedures to answer this question (the RI samples
were analyzed by the EPA Central Regional Laboratory in..
Annapolis, Maryland).
Because the wells were properly purged, there was no reason to
suspect that the PAHs or PCBs were not-. present in the onsite
water table given the fact that the waste is below the wate:r
table and the waste is contaminated with both PCBs and PAHs:
Additionally, data received by the laboratory did not indicate
any problems with either the samples or the analysis of those
samples. Split sample analyses for the most recent sampling
(i.e., October 1989) revealed low levels of PAHs in Well LW-l.
These PAHs included naphthalene (20 ~-q/L), fluorene (5 ~g/L),
phenanthrene (8 ~g/L), and pyrene (2 ~g/L). This confirms that
PAH compounds are present in the onsite water table.
Other comments indicated that the PCBs and PAHs were most likely
the result of suspended material because the samples were turbid.
In response to this, some of the groundwater samples were turbid,
which was not surprising since the wells do monitor the actual
disposal area. However, samples collected from monitoring well
LW-2 were reported as clear (i.e., not turbid) and this well was
also found to contain PCBs and PAHs. Additionally, split sample
analyses that were filtered -in the laboratory (October 1989)
revealed low levels of phenanthrene (2 ~g/L), pyrene (0.3 ~g/L),
fluorene (2 ~g/L), and naphthalene (10.3 ~g/L), which suggests
that these contaminants may be in the dissolved state.
Various comments indicated that the concentration levels found in
the onsite water table samples were above the water solubility
(in some cases) for those contaminants, indicating that the
results are most likely representative of suspended particles.
This was pointed out as a possibility in the RI. However, other
groundwater contaminant levels were not above the water
solubility and therefore, could not be ruled out as being
representative of suspended particles especially since the wells
are monitoring a flow system in which the waste is in direct
D331191
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. .
. .
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contact with the groundwater and there is a potential for
leaching. As noted above, lab-filtered samples revealed low
levels of PAHs, which may indicate' that some of the PAHs are not
suspended, but rather dissolved. ..
Regarding those comments that indicated that the -PAHs and PCBs
are probably not mobile and would not be expected to migrate from
the site, the REM III project team concurs with this. This was
stated in the RI. . -
Issue-.o. 8: Inaccuracies in sample collection and evaluation of-
analy1:icai results qreatly impact the final conclusions within
the public health assessment and the selection of remedial
alternative. in the FS Report.
Co_ent:
A number of comments pertained to inaccurate assessments of the
data base and the conclusions drawn from the these data. The
most significant comment identified by the PRP pertained to the
distribution of PCBs and PAHs throughout the fill material...
Commenters stated that the limited amount of data from the
disposal area were not sufficient to draw the conclusion that the
entire fill area was for the most part -similar and that only
general statements could be made with respect to the distribution
of contamination. One comment suggested that the data indicate"
that areas of potential concern are localized within the fill.
Commenters also indicated that it was not valid to state that a
single sample collected from the bottom of the fill is
representative of the entire bottom portion of the disposal area.
Another major comment was whether there was any potential for
future contaminant releases due to potentially buried drums at
the site. Commenters indicated that the potential for buried
drums was overstated and unfounded and it was unlikely that
intact drums (with liquids) are present due to the age of the
drums and the depth of the fill. One comment stated that liquid
observed flowing from the drum during the - 1985 test pit
investigation was most likely water and not a liquid waste. A
few comments also focused on the fact that over 600 drums have
been removed from the site, and most of these drums contained
solids, which would not move from the burial location by way of
some environmental transport process.
Commenters also disagreed that the foundry sand exhibits an oily
appearance, as stated in the RI and FS Reports. According to
these comments, the oily appearance is due to coke breeze, which
is a very fine material that is found in the cores.
A few comments dealt with the interpretation of the bioassay
resul ts (the RI Report indicated that the resul ts were
inconclusive) . These comments suggested that the contaminated
sediments were not impacting wetland biota, based on the results
of the bioassay.
D331191
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Response:
with respect to comments regarding-the extent and characteristics
" of contamination throughout the fill material, based on the data
collected during the REM III RI, it was apparent through boring
logs that the entire fill material (from the surface to the base
of the disposal area) was similar in physical appearance.
Although the data base consisted of samples representing the top
portion of the fill material (i.e., "the top "15 feet), the sample
analyses were similar in that both PARs and -PCB-1254 were often
present. The one sample that was collected from the bottom of
the fill"material also exhibited these contaminants and the PAH"
concentration was similar to those samples collected from the top
portion of the fill. Additionally, samples collected from the LW
series wells exhibited PCB and PARs, which indicates their
presence at the bottom portion of the fill. Based on these"
facts, one could draw a conclusion that PAHs and PCBs are present
throughout the entire disposal area. If more samples were
collected, especially from the base of the disposal area, it is
likely PAHs and PCB would be detected at similar concentrations.
With respect to those comments indicating" the unlikelihood that
future releases would occur at the site due to buried intact or
crushed drums, there is sufficient evidence to not rule out this
possibility. Based on the fact that 2 drums were uncovered
during the EPA FIT investigation in 1984 and that numerous drum'
fragments were uncovered during the REM III test pit
investigation, there is a possibility that a future (or most
likely ongoing) release is possible. Information obtained from
EPA files on the quantity of waste products taken from the Cooper
foundry to the site also supports the potential for future
releases from the si te area. This was proven by the EPA FIT
investigation when a leaking drum was detected. The contents of
the material leaking from the drum was sampled and found to
contain xylene and ethylbenzene and not water as stated by the
commenter.
.
Several commenters indicated that the oily appearance of the
foundry sand is due to "coke breeze" rather than o~l (the RI and
FS reports describe the foundry sand" "as having an oily
appearance). This mayor may not be true. Examination of boring
logs indicate that those samples that exhibited an oily
appearance often exhibited a fuel-like odor. This was also true
of boring logs that were submitted by Hart during the 1984
Remedial Investigation. Based on this description, along with
information pertaining to the types of materials disposed of at
the site (scrap oils, etc.),. it was not unreasonable to state
that the foundry sand exhibits an oily appearance. It is the
opinion of REM III personnel that the foundry sand was oily in
appearance because of substances disposed of at the site. The
fact that not all of the foundry exhibited an oil appearance does
not support the PRP's theory that coke breeze is responsible for
the oily appearance.
various comments indicated that the source of volatile organics
D331191
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is not supported by the data. Groundwater samples collected
during the 1984 RI from the LW series wells, which monitor the
.. onsite water table, exhibited low levels of vinyl chloride..
Samples collected from the Clarion Formation (during both of the
RIs) also exhibited vinyl chloride. The source of this vinyl
chloride is suspected to be the site based on the history of
waste disposal at this site, and the high levels of vinyl
chloride in the near vicinity of the site (near the highwall).
Although soil contamination did not exhibit any significant
level~ . of volatile contamination, this may be '.due to anyone of
the foll~wing situations:'
. The source within the fill material was not detected (the
soil data .base is small compared to the total size of the
site).
. The source of volatile contamination may have been
remediated during the earlier removal action, when 45 cubic
yards of stained soil were removed by the PRPs (no full
chemical analysis of these soils could be found in any. .
report) .
wi th regard to comments suggesting that the bioassay results
indicate no impact to the wetland biota, one cannot conclude that
the bioassay tests are representative or accurate because o~.
major problems with the control samples. It is agreed that those
samples collected from the wetland sediment did not indicate
significant impacts to the wetland biota, however, the accuracy
of the tests are questionable and that as a whole, the results of
the tests are inconclusive because of control sample (QA/QC)
problems.
Issue Ifo. 9: Based OD the analytical and empirical results
presented in the Pinal RI Report, the RI oJ:»jectives were only
partially achieved. Much of the resultant investiqation did not
further expand on the analytical evaluation provided J:»y Cooper in
their 1984 RI Report..
Couent:
various comments indicated that the RI performed by EPA failed to
demonstrate a more accurate approximation of. contaminant
distribution throughout the fill area: failed to identify
contaminant pathways, which are required to support the report's
conclusions in a logical manner: and it failed to identify an
onsite source for-the vinyl chloride contamination in the Clarion
Formation and mine void. One commenter indicated that the
initial RI did adequately characterize the fill material in the
context of evaluating health risks and developing remedies.
Response:
The RI conducted under the REM III Program was by far a more
thorough and accurate assessment of the site than what was known
beforehand. Previous studies conducted by the PRP were limited
D331191
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in data collection such that it was difficult if not impossible
to meet the requirements of SARA. For example, the RI performed
in 1984 did not result in the collection any soil samples for
chemical analysis. Addi tional1y , after' determining that the
Clarion Formation and onsite water table were contaminated, no
further samp1inq was performed to determine the 'extent of the
groundwater contamination. The risk assessment performed under
the PRP's RI was inadequate in that it did not include
quantitative assessments of carcinogenic' risks or calculate
hazar~. indices. OVerall, the Risk Assessment did 'not meet EPA
requirem~nts under SARA. .'
For the most part, the REM III RI resulted in characterizing the
fill material and the extent of groundwater contamination.
.
Issue _0. 10: CBRCLA 40es not require removal or treatment of
the onsite material.
Comment:
.
A lengthy comment was submitted by the PRP with respect to
whether the intent of CERCLA was to prefer treatment alternatives
over containment alternatives. The comment also indicated that
the calculated public health risks were within the range of 10.'
to 10.7, which (according to the PRP) is "defined as acceptabl~
for a CERCLA site by long-standing EPA policy." The comment also'
states that the FS goals (with respect to PCB action levels) are
inconsistent and that the PADER goal of cleaning up PCBs to
background levels is not an ARAR. Objections were also made with
respect to whether TSCA was an ARAR, since TSCA was intended for
spills which occurred prior to 1987.
Response:
Under SARA, there is definitely a preference to select, to the
maximum extent practicable, remedial actions that utilize
permanent solutions and alternative treatment technologies or
resource recovery alternatives.
The range of carcinogenic health risks (i..e., 10.4 to 10.7) do'es
not imply that if a certain risk estimate falls irito this range
then no action is appropriate. The goal of EPA is to reduce
carcinogenic risks to the 10.' risk level.
In response to the comment that the FS goals (for remediating
PCBs) are inconsistent, a broad range of cleanup objectives (and
not "goals" as stated by the commenter) are appropriate since
there is more than one ARAR that deals with PCBs (e. g., TSCA
provides various cleanup levels depending on the site
conditions). In addition, risk-based action levels were
considered, . which resulted in other action levels. The PADER
ARAR for cleaning up PCBs was also considered in the FS since it
differed from TSCA. PADER has indicated that the cleanup of PCBs
. to background level is a state ARAR.
0331191
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Issue No. 11: Groundwater within the Overburden Formation was
erroneously considered to be Class IIB.
Comment:
Commenters questioned whether the overburden and deep mine void
flow systems were Class lIB aquifers as opposed to Class III.
Commenters also objected to these flow systems being treated as
viable potable water resources for which public health risks were
estimated. One commenter indicated that the .RI report failed to
show any analysis or justification for the classification of . the.
various flow systems.
I.
Response:
Several of the groundwater flow systems in the site vicinity are
somewhat unusual and do not fall into rigid categories. The
determination of the classification in these cases is somewhat
subjective. The approach taken in the RI was to take the more
conservative of two options, if the aquifer fell into a "gray"_-
area according to the EPA guidelines. This approach is
consistant with the intent of the guidelines, as environmental
protection is the goal of the guidelines. A synopsis of the
considerations used in the classification process was provided in
the RI.
The commenter also seems to use a more restricted definition of
the aerial extent of the aquifers in his assessment then was used
in the RI. While the commenter apparently tries to limit the
Clarion and overburden aquifers to within the site boundaries for
classification purposes, the RI classification was based on these
aquifers extending beyond the site boundaries and being used or
potentially used offsite.
The Clarion aquifer is used in the area as a potable water
source, while the overburden flow system could be developed for
small scale use in the areas surrounding the site. Thus, both
should be considered Class II. The RI executive summary was
somewhat misleading relative to the actual assessment, as the
evaluation of the overburden flow system was not limited to the
onsite area as implied (nor should it have been) but was expanded
to include the local area surrounding the site.
The Class II B classification for overburden groundwater is
appropriate. While an argument can be made for onsite overburden
groundwater to .be assigned a Class III designation, the
overburden aquifer in the area surrounding the site could
.potentially be used for small scale water supply. Offsi te
overburden groundwater is not substantially degraded and could be
used either as is, or at worst, with some minor, easily
implemented treatment system.
D331191
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Issue )10. 12: "For the most part, the mechanics of the
[Feasibility] study have been undertaken properly with the
exceptions noted... The followin~,paragraphs highlight specific
area of concern and shortfalls. of the 1'8 evaluations and
recommendations."
Comment:
Specific FS comments were:
. . The solidification technology should have been eliminated
from consideration since the site wastes were not EP toxic'
and the contaminants were not subject to extensive movement
due to leaching.
. Based on the results of the bioassay, the wetland sediments
should be eliminated from consideration for remediation.
. Piping of treated water for discharge to surface streams at
an offsite location should be considered as an alternative
to reinjection to the mine pool.
. Diversion of offsite flows away from the site and into the
adj acent wetlands needs further consideration because of
the potential adverse impacts.
. It is economically infeasible to pump and treat the Clarion
Aquifer and associated mine pool.
. Removal or treatment of all of the wastes onsite was
considered in most of the alternatives in the Feasibility
study.
Partial excavation or treatment should be considered since
only some of the wastes are sufficiently contaminated to
require remediation.
. An incomplete understanding of groundwater conditions at
the site was used in formulating remedial options in the
Feasibility study. The selection of remedial options for
groundwater should be deferred until. after a more detailed
study and analysis of groundwater conditions is performed.
. The Feasibility study does not focus on a single set of
remediation goals, but rather presents a broad set of goals
that are sometimes conflicting.
Response:
Solidification technology was included for consideration because
of its ability to reduce migration of the site contaminants
through leaching and erosion. Evaluation of the site and
possible remedial alternatives was based on reducing risk and
environmental impacts. Whether the wastes are EP toxic was not a
sufficient criteria for immediate elemination of solidification
technologies.
D33l191
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The bioassay was conducted to determine if there were any
environmental impacts to wetland ~iota other than those revealed
by other methods of analyses used in the investigation.
Including alternatives to remediate the wetland sediments was
also based on the Commonwealth of Pennsylvania criteria that PCB
contamination should be remediated to background levels.
Piping of treated water for discharge to surface streams at an
offsite location was considered as an alternative to reinjection
, to the' m~ne pool. This approach would require construction of,
several thousand feet of discharge pipel ine. However,
reinjection to the mine pool was judged to be feasible from a
technical and regulatory standpoint. Since reinjection would not
require constructing the longer discharge pipeline, it was
apparently the less expensive approach. From a technical
standpoint, discharge to surface streams is acceptable as an
alternative to reinjection. .
The potential adverse impacts of diverting offsite flows away.
from the site and into the adjacent wetlands was considered. .
Presently, the flow is ponded onsi te where it slowly leaches
through the waste deposit into groundwater and the mine pool.
This situation is clearly unacceptable. Restoring the flow to its
original (premining) course was selected as an alternative. The
plan was reviewed with EPA and judged as not adversely affecting"
the offsite pond or wetlands. However, if a more detailed review
indicates otherwise, construction of stormwater retention ponds
to reduce peak flows may be needed.
It is economically feasible to pump and treat the Clarion Aquifer
and associated mine pool. The fact that the mine pool is a large
storage reservoir does not mean that remediation is impractical.
Only a limited portion of the mine pool is currently
contaminated. Assuming an average thickness of the mine void of
4 feet, a porosity of 50 percent (half the coal extracted), and a
contaminated area of 50 acres, the total water volume is about
30 million gallons. This volume could be extracted by pumping at
60 gallons per minute above the recharge rate for a period of one
year. Additional calculations are included in Appendix B of the
Feasibility Study report.. The Fred C. Hart pump test has no
bearing on the above conclusion other than to illustrate that
the mine void contains a large volume of water and is relatively
permeable. '
Removal or treatment of all of the wastes onsite was considered
in most of the alternatives in the Feasibility Study because
partial excavation or treatment of only some of the more
contaminated wastes was judged impractical. As described on
page 83 of the draft, Feasibility Study report, results of the
chemicat analyses were reviewed to determine if there was a
discernible pattern of contamination. Based on the physical and
chemical characteristics of the waste, it is very likely that all
of the foundry sand is contaminated with PCBs and PARs.
Therefore all remedial alternatives were based on dealing with
D331191
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all 233,000 cubic yards of' waste material. It is agreed that
only two sample locations exhibi ted high PCB levels. However,
there is also the likelihood tha't additional areas exist. that
have not been detected. .
The Feasibility study does not focus on a single set of
remediation goals, but rather presents a broad set of goals
because of the need to address ARAR criteria, PADER criteria, and
the generally more stringent risk-based criteria. Table 2-4 on
pages.8l and 82 of the draft Feasibility study report lists the
remedial .action objectives for the various site media.
Xssue 110. 13: "One of the most viable options for
remediation of this si te, the use of vertical Barriers I
prematurely eliminated from consideration."
the
was
CODlJDent:
Several comments were directed toward the use of a slurry wall to
partially contain the site. An alternative using a slurry wall.
was developed by the PRP and included in an addendum to the EPA .
draft feasibility study report.
Comments regarding the slurry wall alternative can be grouped
into two categories. Some comments were directed toward the
reasons that the slurry wall was originally eliminated from-
consideration. Other comments were directed toward the
assessment of the slurry wall alternative as considered in the
addendum to the draft feasibility report. Specific points raised
in comments were: .
. The slurry wall permeability will be lower than that used
in assessing this alternative. Using a higher permeability
resul ts in higher estimated pumping rates and therefore
higher water treatment costs.
. The slurry wall alternative is less disruptive than other
alternatives such as onsite landfilling. This comment
applies both during and after construction.
. The slurry wall will be as effective as other containment
alternatives in preventing offsite migration of
contaminants.
Response:
Elimination of vertical barriers during initial screening in the
feasibility study was based on the need to extend the slurry wall
several tens of f~et through rock and through an abandoned mine.
No record of previous construction under these types of adverse
conditions were found. The alternative was reinstated after
discussions with staff of Geo-Con Inc., a major slurry wall
contractor. Based on using newly developed equipment that has
been further modified by Geo-Con, they believe that construction
D33ll9l
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. .
. .
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under site conditions is feasible.
EPA orqanized a panel of experts- to appraise the 51 urry wall
technoloqy in this unusual field. environment. Their review
supported the selection of the slurry wall alternative if proper
studies are made before the desiqn of the wall and .if .appropriate
quality controls and quality assurance proceedures are followed.
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OSBORNE LANDFILL SITE
ADMINISTRATIVE RECORD. FILE *
INDEX OF DOCUMENTS
I.
SITE IDENTIFICATION
1)
Memorandum to File, re: Investigation of Osborne Site,
4/18/80. P. 100001-100002. Photographs of the site are
attached.
2)
Technical Direction Document, prepared by Ecology and
Environment, Inc., 5/22/81. P. 100003-100003.
3)
u.S. EPA Potential Hazardous Waste Site Identification,
6/14/81. P. 100003a-100003a.
Technical Direction Document, prepared by Ecology and
Environment, Inc., 6/16/81. P. 100004-100017.
The following are attached:
4)
a)
b)
c)
d)
e)
5)
an Acknowledgment of Completion for TOO form;
a handwritten revised summary;
a Model Worksheet form;
six groundwater data sheets;
a handwritten model justification.
Memorandum to Mr. Gary Bryant, U.S. EPA, from Mr. Ron
Naman, Ecology and Environment, Inc., re: Comments on
Sampling of the Osborne Landfill, 6/30/81. P. 100018-
100018.
6)
File Inventory List, 7/8/81.
The following are attached:
P. 100019-100060.
a)
b)
c)
d)
e)
f)
g)
h)
i)
. .
a U.S. Government Bill of Lading;
a U.S. Government Freight Waybill;
seven Volatile Organics L55 forms;
seven Organics Characterization L55;
handwritten sample notes;
two Chain of Custody Records;
a handwritten packing list;
six Quality Control reports;
an Inorganics Analysis data sheets for sample
numbers 17C-IM, 17C-2M, 17C-3M, 17C-4M, 17C-5M,
17C-6M and 17C-M7;
five Inorganics Quality Assurance sheets.
j)
*
Administrative Record File available 8/22/89.
Updated 9/18/90.
Note: Company or organizational affiliation is identified in
the index only when it appears in the file.
-
. .
. .
-------
. 9)
15)
7)
Official Osborne Waste Site Sampling Data for Sample
Numbers 17C-3, 17C-4, 17C~5, and 17C-6, 7/16/81. P.
100061-100064. . '.
8)
Memorandum to Mr. R. W. Schrecongost, U. S.. .EPA, from Mr.
Gary Bryant, U.S. EPA, re: Dump Site Investigation, Trip
Report, 7/16/81. P. 100065-100067. A sketch of Sample
Points is attached.
Organics Analysis Data Sheets for Sample Numbers 17C-1,
" 17C-2, 17C-3, 17C-4, 17C-5, 17C-6, and 17C-7, 7/22/81. P~'
100068-100105. A history of the Osborne Dump is
attached.
10)
U.S. EPA Site Inspection Report, 7/29/81.
100119. The following are attached:
P. 100106-
a)
b)
c)
d)
a site location map;
an Application for a Waste Disposal
a Ground Water Module sheet;
a Technical Direction Document.
".
Permit;
11)
Report: Hazard Ranking System Model of Osborne Dump,
prepared by Ecology and Environment, Inc., 7/29/82. P.
100120-100175.
12)
U.S. EPA Site Inspection Report, 11/17/81.
100194. The following are attached:
P. 100176-
a)
b)
a RCRA Checklist for Surface Impoundments;
a memorandum regarding a trip report to the
site; ".
a sketch of sample points;
Official Data Sheets for Sample Number 17C-3,
17C-4, 17C-5, and 17C-6;
a map of the Grove City Quadrangle.
c)
d)
e)
13)
u.S. EPA Site Inspection Report, 7/2/82.
100200. A site location map is enclosed.
P. 100195-
14)
Memorandum to Mr. Steve Jarvella, 'from Mr ~ Lanny Doan,
and Mr. Bruce Doremus, re: Osborne Dump Sampling,
11/10/82. P. 100201-100204. A site map and two Chain of
Custody records are attached.
Memorandum to Mr. Daniel K. Donnelly, u.S. EPA, from Mr.
Rick Dreisch, U.S. EPA, re: Analysis of water samples
from sample series 821108-11-13 for volatile organic
compounds, 12/6/82. P. 100205-100243. The following are
attached:
a) .
Volatile sample results for Sample Numbers
822108-12 and 8211-01-13;
a Quality Assurance Summary form;
b)
2
-------
c) a memorandum regarding soil samples analyzed by
GC/MS for volatile organic compounds;
d) Volatiles sample results for Sample Number
821108-02, 821108-03, 821108-04, 821108-07, and
821108-09;
e) a Quality Assurance Summary;
f) a memorandum regarding the organic compound
sample results;
g) a list of sample descriptions;
h) a list of Base/Neutral Extractable Priority
Pollutant Compound Detection Limits;
i) Base/Neutral Extractable Priority Pollutant
Compounds for Sample Numbers 821108-11, 821108-
12, and 821108-13;
j) twenty pages of Base/Neutral and Acid sampling
results;
k) Surrogate Spike Recoveries for Sample Numbers
821108-11, 821108-12, and 821108-13;
1) a Quality Control Sheet;
m) two Chain of Custody Records;
n) two Technical Direction document forms;
o) an Acknowledgement of Completion form;
p) two Federal Express airbills receipts.
16) Memorandum to Ms. Margot Hunt, U.S. EPA, from Mr. Joseph
P. Dugandzic, U.S. EPA, re: Laboratory Analyses of water
samples from Wells 1-3, 12/27/82. P. 100244-100244.
17) Memorandum to Mr. Steve Jarvella, U.S. EPA, from Mr.
Daniel K. Donnelly, re: Osborne Data Reports, 1/5/83.
P. 100245-100249. The following are attached:
a) a list of sample numbers and descriptions;
b) a memorandum regarding the metals results of
the Osborne Dump Sample;
c) metals results for Sample Numbers 8921108-06,
8921108-07, 821108-08, 821108-09, 821108-10,
821108-01, 821108-02, 821108-03, 821108-04, and
821108-05.
18) Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from Ms.
S. Rosemary Kayser, U.S. EPA, re: Pesticide and PCB
Analysis of Osborne Dump, 1/10/83. P. 100250-100252.
The Pesticide/PCBs results for Sample Numbers 321108-02,
821108-03, 821108-04, 821108-05, 821108-06, 821108-07,
821108-08, 821108-09, 821108-10, 821108-11, 821108-12,
821108-12, 821108-13, Blank, Spike, Sox Blanks, and Sox
Spike are attached.
19) Letter to Mr. Russell H. Wyer, from Mr. James A. Rogers,
Skadden, Arps, Slate, Meagher, & Flom, re: Transmittal
of comments on the Osborne Site's inclusion on the
proposed National Priorities List, 2/2/83. P. 100253-
100264. The comments are attached.
-------
20)
21)
22)
Memorandum to File from M~. Edward Shoener, U.S. EPA, re:
Site Inspection of August 17, 1983. P. 100265-100267. ""A
memorandum regarding the site inspection of Osborne Dump
on June 9, 1983 is attached.
Inorganics Analysis Data Sheet for Sample Numbers 17C-3M,
17C-4M, 17C-5M, 17C-6M, 17C-7M, 17C~3, 17C-4, 17C-5, 17C-
6, and 17C-7. P. 100268-100299. A handwritten note on
items discussed at the meeting is attached.
A National Priorities List Site Informational Sheet for
Osborne Landfill, prepared by the U.S. EPA, (undated).
P. 100300-100300.
4
-------
II.
REMEDIAL ENFORCEMENT PLANNING
,
7)
1)
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: Review of the Draft
Remedial Investigation Report for the Osborne Landfill
Site, 7/31/89. P. 200001-200009. The following are
attached:
a)
a handwritten data sheet for the calculation of
the geometric mean of PCB concentrations;
a graph of the lognormal probability
distribution;
a handwritten sheet of calculations;
a facsimile cover sheet.
b)
c)
d)
2)
Micael Steiner, Pennsylvania Department of "
Resources (PADER), from Mr. Edward Shoener,
A "sumphole" at Osborne Landfill,
200010-200010.
Letter to Mr.
Environmental
U.S. EPA, re:
11/28/83. P.
'.
3)
Report: Annual Report to Shareholders, Cooper
Industries. 1988. P. 200011-200075.
4)
Letter to Mr. Frank Vavra, U~S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: Good faith offer to
perform remedial design/remedial action for Osborne
Landfill, 10/27/89. P. 200076-200104. The Remedial
Action Plan is attached.
. "
5)
Letter to Mr. Robert W. Teets, Cooper Industries, Inc.,
fromm Mr. Abraham Ferdas, U.S."~EPA, re: 104(e) request
for information, 11/16/89. P. 200105-200107. ""
6)
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: 104(e) response, 12/6/89.
P. 200108-200110.
Letter to Mr. Stephen R. Wassersug, u.S. EPA, from Mr.
Matthew P. Drain, General Electric, 12/12/89. P. 200111-
200111.
8)
"Letter to Ms. Patricia Tan, U. S. EPA, from Mr. John"
Gorgol, EBASCO Services, Inc., re: Contaminated soils
and debris, 1/20/89. P. 200112-200120.
9)
Letter to Mr. Stephen R. Wassersug, u.S. EPA, from Mr.
Robert .W. Teets, Cooper Industries, re: Communication
Problems, 4/9/90. P. 200121-200122.
10)
Mr. Keith McDougall, from Mr. Frank Vavra, U.S.
Telephone Conversation on April 10, 1990,
P. 200123-200125. An article concerning
defense is attached. "
Letter to
EPA, re:
4/16/90.
landowner
5
-------
11)
12)
13)
Letter to Mr. Robert W. Teets, from Mr. Frank Vavra, U.S.
EPA, re: Gate at the site, 4/16/90. P. 200126-200127.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Richard H.
Ober, Cooper Industries,re: Damaged gate, 5/16/90.
P. 200128-200129. A photo is attached. ..
Letter to Mr. Robert W. Teets, from Mr. Stephen R.
Wassersug, U.S. EPA, re: .Review of rem~dy, 5/17/90.
P. 200130-200132.
.'
6
-------
III. REMEDIAL RESPONSE PLANNING
1) Report: Remedial Action 'Master Plan, Osborne Site, Pine
Township, Mercer County, Pennsylvania, prepared by NUS
Corporation, 3/83.P. 300001-300120. References are
listed on P. 300090-300092.
2) Report: Summary of Surface Waste Sampling Operations at
the Osborne Landfill, prepared by Fred C. Hart
Associates, Inc., 5/11/83. P. 300121-300142.
3) Report: Osborne Site Remedial Investigation Report,
prepared by Fred C.Hart Associates,Inc.,6/84.P.
300143-300303. References are listed on p. 300270-
300273. A report entitled "Final Evaluation Report,
Review of Remedial Investigation Report" is attached.
4) Report: A Field Trip Report for Osborne Disposal,
prepared by NUS Corporation, 9/11/86.P. 300304-300632.
5) Memorandum to Ms. Pat [sic] Tan, U.S. EPA, from Mr. H.
Ronald Preston, U.S. EPA, re: Recommendations for the
Remedial Investigation made by the Bioassessment Task
Group, 10/14/86. P. 300633-300634.
6) Report: Second Draft Feasibility Study Work Plan,
Osborne Site, prepared by Dynamac Corporation, 6/18/87.
P. 300365-300769. References are listed on P. 300735-
300736.
7) Report: Draft Evaluation Report, Review of the RPs
Feasibility Study Work Plan (Second Draft), prepared by
Ebasco Services Incorporated, 8/3/87. P~7~300770-300784.
8) Memorandum to Ms. Pat [sic] Tan, U.S. EPA, from Mr. H.
Ronald Preston, U.S. EPA, re: Changes requested in the
environmental assessment of the draft Work Plan, 2/25/88.
P. 300785-300786.
9) Letter to Mr. Frank Simunic, Cooper Industries, Inc.
[sic], from Ms. Patricia Tan, U.S. EPA, re:- Transmittal
of responses to comments made on the Remedial
Investigation/Feasibility Study Work Plan and Field
Operations Plan, 7/15/88. P. 300787-300788. A
Memorandum of the Call is attached.
10) Letter to Mr. Abraham Ferdas, U.S. EPA, from Mr. Stephen
D. Von Al-lmen, U.S. Department of Health & Human
Services, re: Transmittal of the Draft Preliminary
Health Assessment for review, 10/13/88. P. 300789-
300793. The Draft Preliminary Health Assessment is
attached.
-------
11)
12)
13)
14)
15)
16)
17)
18)
Letter to Ms. Patricia Tan, U.S. EPA, from Mr. John
Gorgol, Ebasco Services !~corporated, re: Soil treatment
alternatives at the Osborne Landfill Site, 1/20/89. P.
300794-300808. The following are attached:
a)
a table entitled "Public Health Assessment,
Adverse Health Effects of Contaminated Site
Soils"; --
a table entitled "Treatment Levels for
Treatability Variances for Contaminated Soil
and Debris, Organics";
a table entitled "Superfund Guidelines on
Response Actions for PCB-Contaminated Soil";
a map of the Disposal Area Boundary at the
Osborne Landfill Site;
a Routing and Transmittal Slip.
b)
c)
d)
e)
Letter to Ms. Patricia Tan, U.S. EPA, from Mr. John F.
Gorgol, Ebasco Services Incorporated, re: Potential
remedial alternatives for the Osborne Landfill Site,
3/30/89. P. 300809-300815. A Summary of Potential
Alternatives is attached.
Report: Draft Remedial Investigation Report (Volume I of
III), prepared by NUS Corporation, 5/89. P. 300816-
301042. References are listed on p. 301040-301042.
Report: Draft Remedial Investigation Report (Volume II
of II), prepared by NUS Corporation, 5/89. P. 301043-
301427.
Report-: Draft Remedial Investigation Report (Volume III
of III), prepared by NUS Corporation, 5/89. P. 301428-
301687.
Letter to Ms. Patricia Krantz, U.S. EPA, from Mr. Eric L.
Blischke, Ebasco Services Incorporated, re: Transmittal
of the NUS Resubmittal Data Validation package, 7/20/89.
P. 301688-301689. An envelope is attached.
Report: Draft Feasibility Study Re~, prepared by NUS
Corporation, 7/89. P. 301690-302161.
List of Exposure Pathways and Receptors, (undated).
302162-302187. The following are attached:
P.
a}'-
a table entitled "Comparison of Existing
Surface Water Data and ARAR's";
a map of Surface Water Sampling Results;
a table entitled "Comparison of Existing
Groundwater Data and ARAR's";
a report entitled "Osborne Landfill Site, Grove
City, Pennsylvania, RIIFS Scoping Meeting".
b)
c)
d)
8
-------
19 )
20)
21)
22)
23)
24)
25)
26)
27)
Table: Site Associated Contaminants Exceeding Pertinent
ARARs in Onsite Groundwaters, (undated). P. 302188- ..
302193. A table entitled "Site-Associated Contaminants
Exceeding Pertinent ARARs In Onsite and Offsite Surface
Waters" and a table entitled "Site-Associated
Contaminants Exceeding Pertinent ARARs in Study Area
Offsite Groundwater" are attached.
Table: Hazard Indices and Incremental Cancer Risks for
Exposures to Contaminated Foundry Sands, Mine Spoils, and
Soils, (undated). P. 302192-302199. The following are
attached:
a)
a table entitled "Hazard Indices and
Incremental Cancer Risks for Exposure to
Contaminated Surface Water During Recreational
Activities";
a table entitled "Hazard Indices and
Incremental Cancer Risks Associated With the
Domestic Use of Groundwater Within the Site"; '.
a table entitled "Hazard Indices and
Incremental Cancer Risks Associated With the
Domestic Use of Groundwater Outside of the Site
Boundary" ; . .
a table entitled "Hazard Indices and
Incremental Cancer Risks for Exposure to
Contaminated Fugitive Dusts Emanating From
Surface Soils, Foundry Sands, and Mine Spoils";
a table entitled "Hazard Indices and
Incremental Cancer Risks for Dermal Contact
With Contaminated Onsite and Offsite
Sediments".
b)
c)
d)
e)
Report section: Identification and Screening, prepared
by the U.S. EPA, (undated). P. 302200-302217.
Map of the Osborne Landfill Site, (undated).
302218.
P. 302218-
Table: Summary of Alternatives and Costs,-Osborne
Landfill Site, Grove City, Pennsylvania, (undated).
302219-302219.
P.
Handwritten Notes, re:
302220-302220.
Telephone numbers, (undated).
Map of'Approximate Limits of Study Area, Osborne Landfill
Site, (undated). P. 302221-302221.
Map of Conceptual Diagram of Contaminant Migration
Routes, (undated). 302222-302222.
Routing and Transmittal Slip, re:
to do the PRAP [sic], (undated).
Contractor's ability
P. 302223-302223.
9
.
. .
P.
-------
28)
*29)
30)
31)
. 32)
33)
34)
35)
36)
37)
38)
Map of Site Location, Osborne Landfill Site,
P. 302224-302224.
(undated) . '.
Letter to Mr. Frank Kocevar from Mr. Rudy L. Davis, re:
List of Waste Materials, 8/18/67. P. 302225-302234. A
report entitled "Feasibility Report for the Cooper-
Bessemer Landfill" is attached. ".
Report: Draft Feasibility StUd) Addendum, prepared by
EBASCO Services Incorporated, 8 89. P. 302235-302296.
Report: Final Remedial Investigation Report, Volume 1-
III, Osborne Landfill, Grove City, Pennsylvania, 8/89.
P. 302297-303222. References are listed on P. 302527-
302529.
Report: Superfund Program Proposed Plan, EPA Region III,
prepared by u.S. EPA, 8/89. P. 303223-303245.
Report: Summary of Cooper Industries, Inc. I~volvement
in the Investigation of the Osborne Landfill Remedial
Investigation/Feasibility Study, prepared by Cooper
Industries, Inc., 9/1/89. P. 303246-303609. References
are listed on P. 303508-303509.
Report: Processes, Procedures, and Methods to Control
Pollution from Mining Activities, prepared by U.S. EPA,
10/73. P. 303610-303617.
Letter to Mr. Thomas C. Voltaggio, U.S. EPA, Mr. Dwight
D. Worley, Pennsylvania Department of Environmental
Resources, and Mr. Edgar A. Bircher, Cooper Industries,
Inc, from Mr. Edward L. McDougall and Ms. Janet L.
McDougall, re: Consent to enter premises, 8/11/83.
P. 303618-303618.
Report: Design of Bulkheads for Controlling Water in
Underground Mines, prepared by U.S. Department of
Interior, 1985. P. 303619-303659. -
Paper: "Gravel Bulkheads for Confining Hydraulic
Backfilling of Abandoned Underground Coal Mines,"
presented at Society of Mining Engineers of AIME prepared
and presented by M.S. Van Dyke, 10/16-18/85. P. 303660-
303662.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: Review comments for the
RI, 7/31/89. P. 303663-303667.
* This document is located in the confidential portion of
Administrative Record File at EPA Region III, Philadelphia, PA.
the
-------
39)
40)
41)
42)
43)
44)
45)
46)
47)
48)
49)
50)
Letter to Mr. Thomas C. Voltaggio, U.S. EPA, from Mr.
Robert W. Teets, Cooper ~ndustries, re: Concerns .over.RI
and FS reports, 8/18/89. . P. 303668-303669. .'
Letter to Mr. Frank Vavra, U.S. EPA, from .Mr.' .Michael J.
O'Brien, Cooper Industries, re: Request for
authorization to implement a sampling program, 9/19/89.
P. 303670-303685. A lette~ concerning a proposal for
groundwater sampling and Analytical Results of
Residential Well Sampling are attached.
Report: Appendices A - F, prepared by Fred C. Hart
Associates, Inc., 10/89. P. 303686-303876.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: Comments on the U.S. EPA
proposed plan, 10/20/89. P. 303877-303911. A letter
concerning corrections and the comments are attached.
Lette~.to Mr. Frank Vavra, U.S. EPA, from
C~rar, Squire, Sanders, and Dempsey, re:
comments on the proposed plan, 10/23/89.
303914.
Mr. Jeffrey O. .
Supplemental
P. 303912-
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, Cooper Industries, re: Good faith offer for
Remedial Design/Remedial Action (RD/RA) , 10/27/89.
P. 303915-303946. A Remedial Action plan is attached.
Letter to Mr. Roy Shrock, U.S. EPA, from Mr. Michael J.
O'Brien, Cooper Industries, re: U.S. EPA "preferred
alternative", 11/9/89. P. 303947-303948. .
Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Daniel
K. Donnelly, U.S. EPA, r~: Analytical reports for
Osborne Landfill, 11/9/89. P. 303949-303995. Three
organic reports are attached.
Report: Final Feasibility Study Report, (Volume I of
II), 12/89. P. 303996-304287.
Report: Final Feasibility Study Report (Volume II 'of
II), prepared by EBASCO Services Incorporated, 12/89.
304288-304598.
P.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Mark D.
Gorman,. for Mr. Donald J. Benczkowski, PADER, re:
Summary of State ARAR's 12/7/89. P. 304599-304602.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Roy
Wattras, Cooper Industries, re: Requested response,
12/7/89. Y. 304603-304610. The response and a letter
regarding the RI/FS are attached.
11
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51)
52)
-53)
54)
- 55)
56)
57)
58)
59)
60)
61)
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Jeffrey O.
Cerar, Squire, Sanders and Dempsey, re: Negotiations for
consent agreement, 12/15/89. -
P. 304611-304611.
Letter to Mr. F-ank Vavra, U.S. EPA, from Mr. Jeffrey O.
Cerar, Squire, anders and Dempsey, re: Comments on
MAR's, 1/2/90. P. 304612~304613.--
Letter to Mr. Gene Harris, U.S. EPA, from Mr. Frank
Vavra, U.S. EPA, re: Technical assistant, 2/13/90.
P. 304614-304615.
Memorandum to Ms. Anita Miller, U.S. EPA, and Ms. Alyce
Fritz, U.S. EPA, from Mr. Jeffrey Pike, U.S. EPA, re:
Status of EPA activities, 2/16/90. P. 304616-304616.
Letter to Mr. Michael O'Brien, Cooper Industries, from
Mr. Kenneth B. Andromalos, re: Information on the
installation of a temporary deep mine bulkhead, 2/20/90. "
P. 304617-304640. A report on subsidence control by high
volume grouting and a letter concerning technical
information on deep mine bulkheads is attached.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Michael J.
O'Brien, Cooper Industries, re: Information on mine void'
bulkhead installation, 2/26/90. P. 304641-304665. A
letter concerning temporary deep mine bulkhead proposed
remediation methods, a report on subsidence control by
high volume grouting, and a letter concerning a request
for information are attached. ~
Letter to Cooper Industries from Mr. Kenneth B.
Andromalos, Geo-Con Inc., re: Three technical papers for
references, 2/28/90. P. 304666-304719. The papers are
attached.
Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Scott
A. Fritzinger, U.S. EPA, re: Osborne Landfill Slurry
Wall Alternative, 3/9/90. P. 304720-304721.
Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Walter
E. Grube, U.S. EPA, re: Comments on bulkhead proposal
from Geo-Con, 4/4/90. P. 304722-304723.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Robert W.
Teets, ~ooper Industries, re: Technical report, 4/9/90.
P. 304724-304725.
Handwritten notes on 4/16/90 conversation with Dr.
Kimborough, U.S. EPA PCB expert. P. 304726-304727. A
letter regarding Weston comments on Evaluation of the
Toxicology of PCB's report is attached.
12
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62)
63)
64)
65)
66)
67)
68)
69)
70)
71)
Letter to Mr. Robert W. Teets,
Hr. Frank Vavra, U.S. EPA, re:
4/24/90.
P. 304728-304728.
Cooper Industries, from
Weston review ~f reports,
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Michael J.
O'Brien, Cooper Industries, re: Potential design and
construction problems, 5/10/90. P.304729-3304735. A
letter regarding estimate of costs to be incurred is
attached. ..
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Michael J.
O'Brien, Cooper Industries, re: Summary letter from Mr.
Ken Miller, 5/22/90. P. 304736-304750. The letter is
attached.
Letter to Mr. Thomas Voltaggio, U.S. EPA, from Ms.
Bridget Hofman, PADER, re: Delegation of functions,
7/16/90. P. 304751-304763. A memorandum concerning
department participatio9~in the Federal NPL program and
an memorandum concerning NPL enforcement sites are
attached. P. 304751-304763.
Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Roy L.
Smith, U.S. EPA, re: EPA assessment of cancer risk,
5/24/90. P. 304764-304766.
Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Donald J.
Benczkowski, PADER, re: ARAR's for Osborne Landfill
Site, 7/17/90. P. 3304767-304768.
Letter to Mr. Thomas Vo1taggio, U. S. EPA, from Ms...
Bridget Hofman, PADER, re: Submittal of ROD, 7/24/90.
P. 304769-304770.
Letter to Mr. Donald Becker, PADER, from Mr. Frank Vavra,
U.S. EPA, re: Record of Decision for Osborne Landfill,
8/24/90. P. 304771-304772. A letter regarding review of
the ROD is attached.
Report: Osborne Landfill EPA Response to.Comments
Submitted by coober Industries and Their Contractors,
(undated). P. 3 4773-304823.
Report: Appendix E - Subsidence Control by High
Grouting, prepared by Mr. Kenneth B. Andromalos,
Inc., and Mr. Christopher R. Ryan, Geo-Con Inc.,
(undated). P. 304824-304841.
Volume
Geo-Con
13
'.
..
'.
.
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
.
1)
2)
Aerial Photograph, 7/28/84..
Aerial Photograph, 7/28/84.
P.500001-500001.
P. 500002-500002~
3)
Report:. Draft Community Relations Plan, Osborne Landfill
Site, Pine Township, Pennsylvania, .prepared by Booz,
Allen & Hamilton Inc., 7/21/88. P. 500003-500045. The
following are attached:..
a)
a report entitled "Information on Grove City
Public Water Supply";
the handwritten notes regarding public affairs
issues;
a marked-up copy of a list of interested
parties for the Osborne Landfill Site.
b)
c)
4)
Report: Final Draft Community Relations Plan, Osborne
Landfill Site, Pine Township, penns)lvania, prepared by
COM Federal Programs Corporation, 8 24/89. P. 500046-
500075.
5)
Memorandum to Mr. Hamid Saebfar,..U. S. EPA, from Mr.
Edward Shoener, U.S. EPA, re: Notice letters for Osborne
Dump, 12/17/82. P. 500076-500076.
6)
Letter to Mr. Thomas C. Voltaggio, U.S. EPA, from Mr.
Edgar A. Bircher, Cooper Industries, re: Remedial
measures, 4/28/83. P. 500077-500079.
7)
Report: Final Title Report, Osborne Landfill, prepared
by COM, 4/10/89. P. 500080-500144.
8)
Report: Final Draft Community Relations Plan, Osborne
D~mp Site, prepared for U.S. EPA, 8/24/89. P. 500145-
5 0174.
9)
Letter to Mr. John Claussen, General Electric Corp., from
Mr. Stephen R. Wassersug, U.S. EPA, re: Notification._of
potential responsibility, 9/8/89. ..P. 500175-500180. A
. copy of the letter and a certified mail receipt are
attached.
10)
Letter to Mr. John Burnstein, Castle Iron & Metals Co.,
-from Mr. Stephen R. Wassersug, U.S. EPA, re:
Notifi~ation of potential responsibility, 9/8/89. P.
500181-500186. A copy of the letter and a certified mail
receipt are attached.
14
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11)
12)
13)
14)
15)
16)
17)
18)
19)
Letter to Mr. Edwin H. Bircher, Cooper Industries, from
Hr. Stephen R. Wassersu9, U.S. EPA, re: Notification of
potential responsibility,9/8/89~ P. 500187-500192. A
copy of the letter and a certified mail receipt are
attached.
Letter to Mr. Thomas F. Davis, Ashland Chemical Co., from
Mr. Stephen R. Wassersug, ~.S. EPA;.re: Notification of
potential responsibility, 9/8/89. P. 500193-500197. A
copy of the letter is attached. .
Osborne Landfill Superfund Site Public Meeting Response
Card from Mrs. Kris Lambert to Ms. Barbara Brown, U.S.
EPA, 9/14/89. P. 500198-500228. Nineteen additional
Response Cards from the following are attached:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
1)
m)
n)
0)
p)
Mr David J. Berry;
Mr. Paul J. Shimek;
Mr. Thomas C. Ponceroff;
Ms. Betty Lingle;
Mr. Lee McCoy;
Ms. Nancy J. Parker;
T.W. Kearns;
Chris Wright;
Mr. Jerry D. Weis;
Ms. Darla Royer;
Mr. Michael Orange;
A.K. Rao;
Ms. Roxann Sansotta;
Mr. Bill Ryan;
Mr. Michael Orange (duplicate);
Ms. Darla Royer (duplicate).
....
U.S. EPA Region III Public Information Meeting for the
Osborne Landfill Superfund Site list of meeting
attendees, 9/14/89. P. 500229-500238.
Transcript of Public Meeting, re: Osborne Landfill
Superfund Site, 9/14/89. P. 500239-500315.
Handwritten sign-in sheet for meeting with local
officials; Osborne Landfill Site, 9/14/89. P. 5003i6-
500316.
Memorandum to Mr. Stephen R. Wassersug, U.S. EPA, from
Mr. Thomas C. Voltaggio, U.S,. EPA, re: Special notice
lette~s) 10/10/89. P. 500317-500317.
Letter to U.S. EPA Region III, from Mr. Charles W. Smith,
re: Proposals for cleanup, 10/13/89. P. 500318-500318.
Handwritten notes from PRP-requested meeting to organize
a steering group, 10/13/89. P. 500319-5~0320.
15
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20)
21)
.22)
23)
24)
25)
26)
27)
28)
29)
30)
31)
Notes from meeting requested by Cooper Industries to
determine if additional PRP's will participate in the ..
remedial design/remedial action at the Osborne Superfund
Site, 10/13/89. P. 500321-500321.
Letter to U.S. EPA, Region III from Mr. Joseph and Ms.
Janice Kopnisky, re: Questions about EPA site plans,
10/15/89. P. 500322-500322. ..
Handwritten notes on Congressman Ridge's Office,
10/17/89. P. 500323-500323.
Handwritten letter from Mr. and Mrs. Walter Sloan and
Family, re: Site cleanup, 10/21/81 [sic]. P. 500324-
500330. The following are attached:
a)
b)
c)
d)
an envelope;
a routing slip;
a copy of the letter;
a copy of the 10/13/89
W. Smith.
letter from Mr. Charles..
Grove City Allied News article entitled, "Unless Somebody
Listens to Reason, We'll Have to Spend $100 Million to
Solve a Problem that ISN'T," 10/25/89. P. 500331-500331..
Routing and Transmittal Slip ,to Mr. Tom Voltaggio, Mr.
Roy Schrock, and Mr. Frank Vavar from Mr. Don Welsh, re:
Letter from Pennsylvania Chamber of Commerce, 10/31/89.
P. The letter is attached. 500332-500336.
Meeting on Osborne Landfill-Mercer County list of
participants, 11/2/89. P. 500337-500337.
Report: Meeting Summary for the Proposed Remedial Action
Plan at the Osborne Landfill Superfund Site, prepared by
Booz, Allen & Hamilton, Inc., 11/9/89. P. 500338-500349.
Letter to Ms. Nancy Breese from Mr. Frank Vavra, U.S.
EPA, re: Quality of well water, 11/28/89. P. 500350-
500350.
Letter to Mr. and Mrs. Kopnisky from Mr. Frank Vavra,
U.S. EPA, re: Information concerning Osborne remedial
alternative, 11/28/89. P. 500351-500353.
Letter"to U.S. EPA Region III from Mr. Charles Flynn, re:
Letter to PADER, 12/12/89. P. 500354-500355. The letter
.is attached.
RQuting and Transmittal Slip to Mr. Frank Vavra from Kim,
re: Outgoing Congo [sic] file, 1/11/90. P. 500356-
500362. The following are attached:
16
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32)
33)
34)
35)
36)
a)
b)
a copy of a r9uting slip;
a letter concerning Cooper-Bessemer IndUstries
remedial action;
a meeting participant list; .
a letter concerning an Osborne Landfill
meeting. .
c)
d)
Letter to Mssrs. Harold E.' Bell, Joseph F. Fragle, and
Wil.liam M. Reznor, from Mr. Edwin B. Erickson, re:
Financial effects on the Grove City community, 2/26/90. .
P. 500363-500367. A letter concerning support of Cooper-
Bessemer cleanup effort and a letter concerning financial
effects on the Grove City community are attached.
Correspondence Control Slip from Mr. John Heinz, re:
Cooper Reciprocating/Osborne Landfill, 3/5/90.
P. 500368-500373. The following are attached:
a)
b)
a routing slip;
a control slip of the office of congressional
correspondence; .
a letter concerning the attached communication;
a letter concerning the Cooper reciprocating
action;
a newspaper article regarding the Osborne Plan.
c)
d)
e)
Letter to the Honorable John Heinz, U.S. Senate, from Mr~
Guerne DeJones for Mr. Edwin B. Erickson, re: Cooper
reciprocating's liability, 3/16/90. P. 500374-500375.
Routing slip to Ms. Kim Lonasco from Mr. Arlen Spector,
re: Response for R.A.'ssignature, 3/19/90. P. 500376-
500386. The following are attached: .
a)
a control slip for the office of congressional
correspondence;
a letter concerning U.S. EPA remedial
alternative for Osborne Landfill;
a second copy of the letter concerning U.S. EPA
remedial alternative for Osborne Landfill;
a letter regarding a concerned citizen;
a letter concerning the' controversy of the
Osborne Landfill;
a newspaper article;
a third copy of the letter concerning U.S. EPA
remedial alternative.
b)
c)
d)
e)
f)
g)
Lette~.to Mr. Robert W. Teets from Mr. Stephen R.
Wassersug, U.S. EPA, re: Concerns about proposed plans
for remediation, 5/17/90. P. 500387-500393. A copy of
the letter and a letter concerning failed communications
is attached.
17
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37)
38)
39)
Letter to the Honorable Howard Fargo, Pennsylvania Hou'se-
of Representatives, fro~'Mr. Stephen R. Wassersug, U.S~
EPA, re: Remediation of the Osborne Superfund Site,
5/17/90. P. 500394-500399~ A copy of the letter and a
letter concerning a slurry wall and dewatering system
remedy are attached.
Routing and transmittal slip to Mr~ Frank Vavra from Kim,
re: Outgoing congo [sic] for file, 5/24/90. P. 500400-
500412. The following are attached:
a)
b)
a routing slip;
a letter concerning the remediation of the
Osborne Site;
a second copy of the letter;
a letter concerning a remedy for the Osborne
Site;
a letter addressing the viability of a slurry
wall;
- le~~pr regarding U.S. EPA consideration of
J0uper Industries proposed remedy.
c)
d)
e)
f)
Fact Sheet, Osborne Landfill, Grove City, PA,
P. 500413-500422.
(undated) .
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