United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91M16
June 1991
Superfund
Record of Decision:
Strasburg Landfill, PA
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50272-101
I REPORT DOCUMENTATION
1 PAGE
1. REPORT NO.
EPA/ROD/R03-91/116
3. Recipient1 a Accession No.
Tine and Subtitle
SUPERFUND RECORD OF DECISION
Strasburg Landfill, PA
Second Remedial Action
5. Report Dite
06/28/91
7. Author(e)
8. Performing Organization RepL No.
9. Performing Organization Name and Address
10. Proiect/Tssk/Work Unit No.
11. Contract(C) or Gr«rrt(G) No.
(C)
(0
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umit: 200 words)
The 22-acre Strasburg Landfill site is an inactive landfill located within a 220-acre
tract of land in Newlin and West Bradford Townships, Chester County, Pennsylvania. The
site is characterized by hills draining toward Brandywine Creek and its floodplain,
which forms the southern and western site boundaries. The nearest wetland is the Briar
Run watershed located 600 feet east/southeast of the site. The 201 single-family
residences that surround the site use ground water as a source of drinking water.
Before landfilling operations began in 1973, the site was used as farmland. From 1978
to 1983, the landfill accepted industrial and heavy metal wastes and sludges. State
investigations in 1979 determined that landfill operations had resulted in excessive
siltation of Briar Run. In 1980, the State permanently prohibited the landfill from
receiving industrial waste. In 1983, the owners were cited for violations, which they
failed to correct, and the State ordered the landfill closed. Closure involved
constructing a PVC cover and soil and vegetation layer. Subsequent studies detected
VOCs in both onsite monitoring wells and offsite residential wells. The State
initiated an interim action to control the leachate, which included collection and
offsite treatment of leachate at a nearby municipal sewage plant and installing
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Strasburg Landfill, PA
Second Remedial Action
Contaminated Media: debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene), metals (arsenic, chromium)
b, Identifiers/Open-Ended Terms
c. COSATI Reid/Group
B. Availability Statement
18. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
58
22. Price
(See ANSI-Z39.18)
See Instruction* on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-91/116
Strasburg Landfill, PA
"Second Remedial Action
Abstract (Continued)
diversions to halt leachate flow. A 1989 Record of Decision (ROD) addressed
contaminated residential wells and exposure pathways, and provided an interim remedy to
limit site access. The purpose of this ROD is to limit direct contact and exposure to
contaminants using site access restrictions, and to reduce further degradation of the
landfill cover. Remediation of the landfill will be addressed in a future ROD. The
primary contaminants of concern affecting this site are VOCs including benzene, PCE,
TCE, and toluene; and metals including arsenic and chromium.
The selected interim remedial action for this site includes implementing site access
restrictions including fencing that will encompass the insnediats landfill area, access
roads, the sediment pond, air stripping building, and monitoring wells; and maintaining
the fence and the existing cap. The estimated total present worth cost for this
remedial action is $823,020, which includes an annual O&M cost of $55,405.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
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RECORD OF DECISION
Strasburg Landfill
DECLARATION
SITE NAME AND LOCATION
Strasburg Landfill
Newlin Township, Chester County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Strasburg Landfill in Newlin Township, Pennsylvania, which
was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (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), 40 C.F.R. Part 300. This decision
document explains the factual and legal basis for selecting the
remedy for this site. The information supporting this remedial
action decision is contained in the Administrative Record for
this site.
The Commonwealth of Pennsylvania agrees with the selected interim
remedy.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority/ I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. Section 9606, that
actual or threatened releases of hazardous substances from this
site, as discussed in the Summary of Site Risks in this document,
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 07 THE SELECTED REMEDY
This Operable Unit is the second of three Operable Units for the
site. The remedy for the first Operable Unit consisted of <,
construction of a leachate collection and treatment system and
the installation of filtration systems on two home drinking well
systems. The first Operable Unit addressed the principal exposure
pathway/ and as a result the two affected homes were supplied
with filtration systems and the landfill leachate was diverted
from a direct discharge to Briar Run and into a collection and
treatment system.
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Since the time of the first Record of Decision (Operable Unit 1)
the amount of unauthorized recreational activity and vandalism on
the landfill appears to have increased and damage to the cap and
to the leachate collection and treatment system has been
observed. This second Operable Unit consists of construction of
approximately 7500 linear feet of chain link security fencing
around the immediate perimeter of the landfill portion of the
site. This action addresses the limitation of access to the
landfill area and will result in reducing public exposure to
hazardous chemicals that are present on the surface of the
landfill, as well as reducing damage to the landfill cap.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technology to the maximum extent practicable for this
site. However, because treatment of the principal threats of the
site was not contained within the limited scope of this interim
action, this remedy does not satisfy the statutory preference for
treatment as a principal element.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted
within five years after commencement of remedial action and every
five years thereafter, as required by Section 121 (c) of CERCLA,
42 U.S.C. § 9621(c), to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Edwin B. Erickson Date
Regional Administrator
Region III
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STRASBURG LANDFILL
Decision Summary for the Record of Decision
1. Site Name. Location, and Description
The Strasburg Landfill is a 22-acre inactive facility
located within a 220-acre tract of land south and slightly
east of Strasburg Road in both Newlin and West Bradford
Townships, Chester County, Pennsylvania. The coordinates of
the site are North 39° 56' 35" latitude and West 75° 46'18"
longitude. The entrance to the landfill is on Strasburg Road
and is controlled by a locked gate. The gate, however, is
across the road entrance only and access to the site is
essentially unrestricted (Fig 1).
The topography of the area is characterized by a
combination of steep and gentle hills. All the land in the
area is sloped towards, and drains to, the Brandywine Creek
which forms the southern and western boundaries of the site
area.
The highest elevation of hills south of the site in
Newlin Township approaches 550 feet above mean sea level
(MSL). The landfill itself resembles a steep hill. The peak
elevation of the landfill, from ground control survey, is
474 feet above MSL. The south and east sides of the landfill
have a much steeper slope than the north and western sides.
The slope along the eastern side is approximately 60 degrees
in some locations. Surface drainage from the site flows to
the south and southwest toward the Brandywine Creek and to
the east and southeast toward Briar Run which flows into the
Brandywine.
The elevation of the Brandywine Creek floodplain to the
south is approximately 250 feet above MSL. There are no
wetlands either on the landfill, or within 300 feet of the
landfill in any direction (Fig 2). The nearest wetland is
the Briar Run watershed which is approximately 600 feet east
and southeast of the landfill.
Land use in the area is primarily suburban residential,
with some residual agricultural areas. There are 201 single
family residences within a one mile radius of the site. All
the drinking water to these residences is supplied from
groundwater. Most of the homes are served by private home
wells. There is a private water company, approximately one
mile east and slightly north of the landfill, that provides
drinking water from deep wells to several residences
radiating away from the site area.
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SLA PROPERTY
INCLUDING
LANDFILL AREA
AREA OF
CONTAMINATED
RESIDENTIAL WELLS
NEWLIN TOWNSHIP, CHESTER CQUMTV PA
l SITE LOCATION MAP
2
•
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fOf OP LANDFILL SURFACE
LIACHATE
COLLECTION
TANK!
Figure 2 SCHEMATIC SITE MAP OF STRASBURG LANDFILL
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According to the closure plan, the landfill was closed
by covering the fill material with two feet of soil, a poly
vinyl chloride (PVC) cover, and an additional two feet of
soil and vegetation. Grasses are growing on approximately
70% of the landfill cap. The remaining areas are barren
because of one or more of the following reasons: poor
quality of the soils, the steepness of the slopes, exposure
of the PVC cover, or leachate seeps. One of the primary
purposes of this Record of Decision is to reduce further
degradation of the landfill cover and resulting
environmental impacts.
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2. Site History and Enforcement Activities
According to EPA's records, prior to 1973, some of the
property was used for farming and a large portion of the
property was undeveloped.
Strasburg Associates (SA) was formed in September 1973
and purchased the property in December 1973. In August 1975,
SA received a Pennsylvania Department of Environmental
Resources (PADER) permit to accept municipal wastes at the
22-acre facility.
From 1976 through 1978, opening of the 22-acre facility
was delayed by issues between SA and the West Bradford'
Township concerning:
o Use of residentially zoned roads;
o Proposed sale of the landfill to Strasburg Landfill
Associates (SLA); and
o Permitting of a proposed 200-acre facility expansion.
In May 1978, SLA was formed. In August 1978, SLA
acquired the landfill from SA. In October 1978, SLA applied
to PADER for a proposed 200-acre landfill expansion.
In February 1979, the 22-acre landfill was opened. In
the spring of 1979, new PADER permits were granted to SLA to
receive certain industrial and heavy metal wastes. By
December 1979, more than 1,000 cubic yards of PVC wastes,
2,052 cubic yards of industrial wastes and sludges, and
35,000 gallons of heavy metal sludge had been accepted at
the landfill.
In December 1979, PADER charged SLA with excessive
siltation of Briar Run. Also, PADER prohibited SLA from
accepting additional PVC waste for disposal. In August
1980, PADER permanently prohibited the landfill from
receiving industrial wastes.
In April 1983, PADER conducted an unannounced
inspection at the landfill and found four major operating
violations: improper run-off control, slopes in excess of
allowed limits, failure to cover compacted wastes, and^
inadequate sedimentation and erosion control. PADER issued
a notice of violation that required the landfill owners to
correct the violations within 30 days. The violations were
not corrected within that time frame; therefore, PADER
suspended the landfill operating permit and ordered the
landfill closed. The landfill expansion plans were shelved.
-5-
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As part of the closure plan, the landfill was regraded,
covered with 2 feet of soil, and topped with a PVC cover.
Another 2 feet of soil was placed on the PVC cover and
vegetation planted. The leachate collection and storage
system were also installed as part of the closure plan.
In August 1983, volatile organic contaminants (see
Tables 1 and 2) were detected in an on-site monitoring well,
M-2, and in the landfill witness system drain pipe. In
September 1983, volatile organic contaminants (see Table 1)
were detected in Briar Run east of the landfill. PADER
required SLA to conduct a periodic monitoring program and a
hydrogeologic study. In October 1983, volatile organic
contaminants, in excess of drinking water standards, (see
Table 3) were detected in an off-site residential drinking
water well southwest of the landfill.
In February 1984, SLA installed four monitoring wells
(M-2A, M-2B, M-2C, and M-5) and began a sampling and
analysis program (see Table 2). SLA submitted the
hydrogeologic investigation to PADER in July 1984.
In July 1984, the hydrogeologic/engineering report
evaluating the extent of groundwater contamination was
completed. The six corrective measures delineated in the
report included:
o Extending the PVC liner;
o Installing new leachate collector drains;
o Installing a 15 - mil PVC membrane cap;
o Regrading soil to attain 2-1/2:1 or 3:1 final outslopes;
o Revegetating the sides and the top of the landfill; and
o Regrading soil to divert surface water away from the fill.
Implementation of these measures was never completed.
Additionally, the eastern side of the landfill is very steep
(estimated 60% slope) in areas, and erosion is occurring
such that the original PVC liner is exposed and torn in
numerous locations. Vegetation is non-existent or extremely
sparse over approximately 1/3 of the landfill.
PADER has conducted periodic monitoring of residential
drinking water wells, on-site monitoring wells, sediment
pond outfall, leachate seeps, and Briar Run from September
1983 to the present (see Appendix A of the Remedial ^
Investigation (RI): Summary of PADER Residential Well
Sampling). The monitoring program results showed two
residential wells southwest of the landfill contaminated
with volatile organics. In August 1983, PADER analyses of
water from well M2 and of leachate from the witness drain
revealed organic and inorganic contamination (see Table 1).
In September 1983, analyses of water samples collected from
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Table 1
SUMMARY OF ANALYTICAL RESULTS FOR SAMPLES
COLLECTED FROM WELL M2 AND
WITNESS DRAIN PIPE,
PADER, AUGUST 1, 1983
(ug/L)
Compound
Chloroethane
Chloroethene
1 , 2-Dichloroethene
1, 1-Dichloroethene
1, 2-Dichloroethene
1, 1-Dichloroethene
1,1, 1-Trichloroethane
Trichloroethene
Tetrachloroethane
Chi orome thane
Dichloromethane
Dichlorofluoromethane
Trichlorofluoromethane
Benzene
Toluene
Ethyl benzene
Chlorobenzene
Witness Drain
Pipe
27
126
11
109
140
-
6
9
-
2
86
-
Trace
34
76
12
4
well
M2
7
8
-
16
3
10
47
3
14
2
3
Trace
9
2
Trace
- * -
_
-7-
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Table 2
SUMMARY OF ANALYTICAL RESULTS FOR SAMPLES
COLLECTED FROM WELL M2, THE WITNESS DRAIN PIPE,
AND BRIAR RUN,
PADER, SEPTEMBER 6, 1983
(ug/L)
Compound
Chloroethane
Chloroethene
1 , 2 -Dichloroethene
1 , l-Dichloroethene
1 , 2 -Dichloroethene
1, l-Dichloroethene
1,1, 1-Trichloroethane
Trichloroethene
Tetrachloroethane
Chi or ome thane
Dichloromethane
Dichlorofluoromethane
Trichlorofluoromethane
Benzene
Toluene
Ethyl benzene
Chlorobenzene
Well
M2
8.7
18
1.2
22
9
8.4
65
4.1
18
-
4.6
Trace
3.7
6.2
1.0
-
_
Witness Drain
Pipe
6.7
Estimate 180
13
Estimate 150
100
2.1
16
2.4
5.8
.
34
-
-
47
97
19
3.8
Briar
Run
-
2.2
-
1.5
1.7
-
1.5
Trace
Trace
-
-
-
-
1.0
1^0
-
-
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Table 3
ANALYTICAL RESULTS OF THE SAMPLES
COLLECTED FROM AN OFF-SITE
RESIDENTIAL WELL
PADER, OCTOBER 14, 1983
(ug/L)
Compound
Residential
Well
Chloroethane
Chloroethene
1,2-Dichloroethene
1,1-Dichloroethene
1,2-Dichloroethene
1,1-Dichloroethene
1,1,1-Trichloroethane
Trichloroethene
Tetrachloroethane
Chloromethane
Dichloromethane
Dichlorofluoromethane
Trichlorofluoromethane
Benzene
Toluene
Ethyl benzene
Chlorobenzene
0.9
7.8
3.4
3.3
5.8
9
8.5
Trace
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well M2, the witness drain, and Briar Run (see Table 2)
revealed significant levels of organic chemicals.
A Hazard Ranking System (HRS) scoring package was
prepared by EPA for the Strasburg Landfill site in April
1987, receiving a score of 30.71. The site was proposed for
inclusion on the National Priorities List (NPL) in update
number 7, released in June 1988. The Strasburg Landfill was
added to the NPL in March 1989.
As a result of the leachate, coming from the landfill,
flowing directly into Briar Run, and the failure of the
operator to take any corrective actions, PADER initiated an
action to collect this leachate and haul it, for treatment,
to a nearby municipal sewage treatment plant. Prior to the
installation of the leachate collection system, surface
water runoff and leachate from the landfill were directed
into the unlined sediment ponds located southwest and east
of the landfill. EPA has seen evidence of many different
groups of people utilizing the property, and specifically
the landfill for various recreational activities. These
include the following:
o people using horses whose tracks are seen adjacent to, and
on the lower slopes of the landfill, local residents
indicate that there is both random horseback riding and
also organized fox hunts involving large numbers of
riders and accompanying hounds;
o hikers, who occasionally build campfires on the slopes and
top of the landfill;
o vandals who have attempted to dismantle parts of the
leachate treatment system;
o joggers; and most particularly,
o riders of motorcycles and "all terrain vehicles" (ATVs)
whose tire tracks are wearing grooves into the sides
of the landfill.
EPA's concern for both the health of these people and
the integrity and security of the existing cap and leachate
systems leads EPA to propose an action to minimize or
eliminate the potential exposures to contaminants on the
site.
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3. Highlights of Community Participation
The current Proposed Plan for the Strasburg Landfill
site was released for public comment on April 18, 1991. A
draft RI and FFS, summarized in the Proposed Plan, were also
made available for public comment. These two documents, with
other site related documents, were made available to the
public in both the administrative record and an information
repository maintained at the EPA Docket Room in Region III
and at the Coatesville Area Public Library. The notice of
availability for these two documents was published in the
Daily Local News on April 18, 1991. In accordance with
CERCLA Sections 113 (k)(2)(B)(i=v) and 117, a public comment
period was held from April 18, 1991 to May 18, 1991. In
addition, a public meeting was held on April 30, 1991 at the
Dnionville Presbyterian Church. At this meeting,
representatives from EPA and PAOER answered questions about
problems at the site and the remedial alternatives under
consideration. A response to the comments received during
this period is included in the Responsiveness Summary, which
is part of this ROD.
This decision document presents the selected remedial
action for the Strasburg Landfill site, in Newlin and West
Bradford Townships, Pennsylvania, chosen in accordance with
CERCLA, as amended by SARA, and to the extent practicable,
the National Contingency Plan. The decision for this site is
based on the administrative record.
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4. Scope and Role of Operable Unit (OU 2) or Response Action
Within Site Strategy
As with many Superfund sites, the problems at the
Strasburg Landfill site are complex. As a result, EPA has
organized the remedial work into three separate planned
actions.
This ROD addresses the second planned remedial action
at the site. The first planned action (OU 1) addressed
contaminated residential wells and leachate releases into
surface water ways and ground water near the landfill. Under
this first action, leachate is now collected, treated,, and
discharged on site. OU 1 has been fully implemented. A'
future action (OU 3) will address the landfill itself, the
condition of the existing containment system (i.e. the cap),
additional leachate issues, and potential groundwater
impacts.
This remedial action (OU 2) for restricted access, as
summarized in the proposed plan, addresses a principal
threat at the site of direct contact contamination posed by
the leachate seeps on the landfill. This remedy will
minimize or eliminate the exposure pathways of people coming
into contact with these substances, for example, by slipping
and falling or by having these materials splashed up on
them. In addition it has a significant secondary impact to
reduce traffic on the landfill cap which is already
inadequate and deteriorating. Further deterioration will
allow more water to infiltrate, causing more leachate.
A draft remedial investigation is completed and is
contained in the public record as support for this second
action. A Focused Feasibility Study (FFS) is also contained
in the public record as support for OU 2. The RI and the
Feasibility Study for the third planned action were
finalized in June, 1991.
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5. Summary of Site Characteristics
In August 1975, PADER granted SA a permit to operate a
22 acre landfill. The opening was delayed until February
1979 because of local concerns over the use of residentially
zoned roads, the proposed sale of the landfill to SLA and
permitting of a proposed 200 acre expansion.
In the Spring of 1979 new PADER permits were granted to
receive certain industrial wastes. By July 1979, SLA was
accepting sewage treatment plant sludge and PVC
manufacturing wastes. In December 1979, PADER prohibited
the disposal of certain industrial wastes because the waste
characteristics did not match those on the approved waste
disposal application module. Also in December 1979, PADER
fined SLA for improper surface run-off and sediment control.
PADER temporarily suspended industrial waste disposal at the
site in March 1980, and permanently prohibited industrial
waste disposal in August 1980. Between January and June
1981, PADER cited SLA for operational problems (dust
control, daily cover, and litter control) at the landfill.
PADER conducted periodic inspections, both announced
and unannounced, during the landfill operation. During an
unannounced inspection in April 1983, PADER found four major
operating violations: improper run-off control; slopes in
excess of allowed limits; failure to cover compacted waste;
and inadequate sedimentation and erosion control. PADER
issued SLA a notice of violation and required that the
violations be corrected within 30 days. The violations were
not corrected within the specified time. In May 1983, PADER
suspended the landfill operating permit and ordered the
landfill closed. SLA closed the landfill in May 1983, by
providing a final soil cover, a PVC cover, stabilized the
site with an additional layer of soil, planted vegetation,
and installed a leachate storage tank system. PADER also
issued an order requiring SLA to remove collected leachate
for off-site treatment and disposal.
During sampling by PADER in October 1983, volatile
organic compounds were detected in off-site residential
drinking water wells. Based on their findings, PADER
implemented a periodic monitoring program of the residential
drinking water wells.
In August 1986, EPA prepared an HRS package to
determine the Strasburg Landfill site eligibility for
proposal to the NPL. The Strasburg Landfill was proposed to
the NPL on Update #7, in May 1988. Since that time, EPA has
continued to conduct a potentially responsible party (PRP)
search.
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Nature and Extent of Contamination
This section will focus on the contaminants that may
pose hazards, through inhalation and direct contact, to the
public health due to the release of leachate from seep areas
located throughout the landfill area but most notably on the
southeast corner and eastern side of the landfill. Leachate
streams flow from landfills which have been improperly
capped or where the landfill cap has been somehow
compromised. Leachate, as used in this document, refers to
the liquid and semi-liquid substances particularly hazardous
chemicals that seep from the ground surface of the landfill,
either onto other ground surface areas, ground or surface
waters.
While EPA and PADER have observed contamination from
the site in other areas, such as groundwater, the focus of
this interim action remedy is the surface areas of the
landfill and the immediate surrounding areas.
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Leachate Seep
There are a number of leachate streams evident on all
but the small northern slope of the landfill. The largest
and most notable leachate streams are located on the eastern
and southeastern portions of the landfill. Data are
available on landfill leachate collected from a manhole near
the sediment pond and a seep located between the sediment
pond and Briar Run Creek. Recent analytical results for
samples of these materials are given in Table 4. These
materials are presumably derived from the same general
source as the liquid from the other seeps at the southeast
corner of the landfill and may exhibit similar contamination
patterns.
The liquid discharging from some of the southeast seeps
flow overland and eventually discharge directly to Briar Run
or flow in a northeasterly direction to be collected and
treated in the leachate collection system (OU 1), or to a
drainage ditch that empties into the sedimentation pond
immediately east of the landfill. During heavy rains, the
sedimentation pond (prior to the implementation of OU 1)
used to overflow and discharge via an overflow stack running
eastward from the pond through the woods and into Briar Run,
which in turn flows into Brandywine Creek. Liquid
discharged from the some of the southeast seeps also may
migrate to groundwater via infiltration at various points
along the overland flow pathway. Groundwater movement in
the area is mainly via fractures in the Peters Creek Schist
Formation.
Potential pathways of exposure to the leachate seep
material include the following:
o Direct contact (including dermal and oral exposure)
with the seep material by members of the general
population (adults and children) who might enter the
site for miscellaneous recreational purposes; for
example, children playing in the area;
o Inhalation of volatile organics, emitted from the
leachate and soils along the overland flow pathway, by
representatives of the general population that may come
into close proximity to the seeps or their overland
flow pathways; and ^
o Dermal, oral, and inhalation exposure to contaminants
that might reach Briar Run or the Brandywine Creek.
This is a concern for members of the general population
using the Brandywine for recreational purposes such as
canoeing, tubing, swimming, bathing, wading, fishing,
or as a drinking water source.
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Table 4
SUMMARY OF ANALYTICAL RESULTS FOR
SEEP AND LANDFILL LEACHATE SAMPLES
(ug/L)
Seep East of
Compound Sediment Pond
Vinyl Chloride
1, 1-Dichloroethane
trans-1 , 2-Dichloroethylene
1 , 2-Dichloroethane
1 , 2-Dichloropropane
Trichloroethylene
Benzene
Toluene
Chlorobenzene
Xylenes
cis-1 , 2-Dichloroethylene
1 , 4-Dichlorobenzene
1 , 2-Dichlorobenzene
Chi or oe thane
Ethylbenzene
Source: PADER, March 9, 1988.
10
30
1.0
4.3
2.9
3.4
2.2
8.4
26
2.0
35.0
7.8
1.0
—
—
Landfill
Leachate
20
—
—
—
—
—
10
280
15
Est. 950
13
Est. 50
—
12
130
\
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Table 5
LIST OF CONTAMINANTS FOUND IN
RESIDENTIAL DRINKING WATER WELLS
(ug/L)
Compound
Maximum Detected
Contaminant
Concentration
Levels
Maximum .
Allowable'
Contaminant
Levels (MCLs)
Benzene
Chlorobenzene
Chloroform
1, 1-Dichloroethane
1 , 2-Dichloroethane
cis-1 , 2-Dichloroethylene
1 , 2-Dichloropropane
1,1, 1-Trichloroethane
Trichloroethylene
1,1,2, 2-Tetrachloroethylene
vinyl chloride
3.4
1.4
1.7
16.0
1.3
413.9
1.2
2.5
35.8
3.5
2.5
5
100
-
-
5
7
5
200
5
5
2
Source: PADER 1987-1988.
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The leachate has also infiltrated the ground and
reached the groundwater that is used as a water supply
source by 203 residences in the vicinity of the landfill.
Public Health Evaluation
The contaminants in the landfill leachate and seeps
(Table 4) and in the residential water supplies of the
affected homes (Table 5) consist of a variety of hazardous
volatile organic compounds. This section provides a summary
of the potential risks to human health from these
contaminants in the absence of any remedial action.
It should again be noted, that, although we have taken
time to evaluate risks posed by the site contaminants, the
stability and integrity of the existing cap is a significant
concern to be addressed by this remedial action. Further
degradation of the cap may lead to increased leachate
production, greater number of seeps and more potential
exposure risks. Additionally, the security of the existing
collection and treatment system is impacted by trespassers
and vandals. Failure of this system could cause large
releases of contaminated water directly to Briar Run and
then to the Brandywine Creek. Lastly, the trespassers have
started small fires on the site which, so far, have been
controlled. The landfill, however, emits methane gas which
can ignite. There is a possibility of a landfill fire fueled
by methane, if the trespassers light their fires in a
methane rich area.
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6. Summary of Site Risks
The Strasburg Landfill is an open 22 acre landfill
located on an open 220 acre tract of land. The only
access restriction is a locked gate across the main access
road.
There is much evidence of on-site recreational
activities. "Dirtbike" and "All Terrain Vehicle" (ATV)
tracks crisscross the property and are especially prevalent
on the landfill. Evidence of recent campfires is also seen
on the landfill, as are horseshoe prints, shotgun shells,
and clay pigeons. The neighborhood around the landfill is
relatively stable in terms of development; however, similar
areas, in locales as close as four miles away are
experiencing a considerable amount of development of single
family housing. It is expected that this type of development
will, in a reasonably short time, occur in this area. At the
time the site was first visited by EPA, private surveyors,
apparently contracted by the owners, were on the property
working on a plan to develop part of the property for
executive homes. While this action immediately ceased,
additional development in the area may bring more people,
particularly children, into contact with the landfill.
The exposure pathways that appear to have the greatest
potential to produce adverse human health effects at
Strasburg Landfill are:
o Migration of volatile contaminants via soil gas to the
air in the vicinity of the landfill, where they could be
inhaled by site visitors;
o Migration of contaminants within landfill leachate to the
ground surface in seep areas and the sediment pond, where
site visitors could be accidentally exposed to the
contaminants through direct dermal contact, incidental
ingestion, and inhalation of volatiles emanating from the
leachate.
The pathways were quantitatively evaluated in the Risk
Assessment section of the draft Strasburg Landfill Remedial
Investigation report. Although the groundwater pathway was
found to pose the greatest potential risks of the three
pathways, the impact of groundwater on people has beei^
addressed in past actions at the site. The final RI/FS for
this site will also consider and address, as appropriate,
remedial alternatives for groundwater. Control of site
access does not affect this pathway. Therefore, in the
Focused Feasibility Study, groundwater was not considered
further. Using site contaminant concentrations presented in .
the tables above, a reasonable maximum exposure (RME)
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estimate was developed based on estimated frequency and
exposure duration that the. receptor population (site
visitor) is likely to experience. Various physiological
parameters (e.g., breathing rate, ingestion rate, body
weight, etc.) were incorporated to obtain an estimate of
the lifetime average daily dose of a contaminant. For the
inhalation pathway, site visitors come in contact with
volatile contaminants on site by inhalation only. For the
accidental contact pathway, site visitors could be exposed
to contaminants by direct dermal contact, incidental
ingestion, and by inhalation of vapors from leachate.
A brief review of the key parameters for the two .
pathways follows:
For the inhalation pathway: Since site visitors
evidently walk, jog, and ride horses, motorcycles or ATV's
on site, an inhalation rate corresponding to light to
moderate activity was used. The exposure time, the expected
duration of a site visit, was assumed to be one hour per
day. The exposure frequency, the number of days per year
during which site visits might occur, was assumed to be 100
days/year. Averaging time, the period over which the
estimated exposure is averaged, was taken as 30 years for
noncarcinogens (90 percentile for time spent at one
residence) and 70 years for carcinogens, corresponding to
the carcinogenic potency slope factors which are based on
lifetime exposures.
For the accidental contact pathway, two exposure
scenarios were evaluated in the risk assessment. The first
exposure scenario involved a site visitor and accidental
contact with the seep material by partial or total emersion.
The second exposure scenario involved accidental contact
with the seep material by having the seep material splashed
on a site visitor after riding a motorcycle, ATV, or horse
through a leachate seep. Dermal absorption of contaminants
depends on the dermal permeability constant of the specific
chemical compound. Since specific data for this constant
were not available for most chemicals found in the seep
areas, constants for organic compounds were assumed and
chosen to reflect an inverse relationship to the
octanol/water partitioning coefficient for that compound.
For the first exposure scenario, skin surface are^a was
taken as equivalent to the area of the arms, legs, hands,
and feet that would likely come into contact with seep water
or sediment. The exposure frequency for the first
accidental contact exposure scenario was assumed to be four
times per year, because of the accidental nature of the
exposure.
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For the second exposure scenario, skin surface area was
taken as equivalent to the area of the hands, and one half
the area of the arms and legs. The exposure frequency was
assumed to be 50 times per year.
Exposure time for each accidental exposure scenario was
assumed to be one hour, the estimated time for a site
visitor to return home and remove wet clothing. Incidental
ingestion by hand-to-mouth contact was included in each
accidental contact exposure scenario and was taken as 100
mg/day based on EPA guidance. Inhalation rates for the
accidental contact exposure scenarios were the same as used
for the inhalation pathway, other values were also the same.
Using the estimates of a lifetime average daily dose of
a particular chemical under the RME scenario and assumed
values for key parameters, risks posed by the chemical
contaminants are then evaluated. Noncarcinogenic risks are
assessed by calculating a hazard index, the ratio of
estimated average daily dose to the reference dose, which is
considered an allowable daily intake. A hazard index
greater than 1.0 indicates that adverse effects may be
possible. A hazard index value less than 1.0 indicates that
adverse effects would not be expected. For carcinogenic
compounds, a linearized multistage model is used to estimate
the carcinogenic potency slope factor. The lifetime average
daily dose is multiplied by the low-dose slope factor for
each route of exposure to a particular compound;
carcinogenic risk is then estimated by adding the risks due
to oral, dermal, and inhalation routes.
The remedial investigation was designed to characterize
the nature, extent, and limits of contamination originating
at the Strasburg Landfill. The possible source areas were
identified based on a review of past activities at the site
and previous sampling activities. All of the potential
source areas and migration pathways were investigated using
various field techniques and by collection and laboratory
analysis of samples. In this way, the nature of the
contamination was characterized and its extent defined.
Given the information available about the site, it seems
unlikely that any significant source areas or migration
pathways were overlooked. Since samples were collected from
a variety of media encompassing all of the likely source
areas and migration pathways, and samples from most o$ the
media except soil gas were analyzed for the full Target
Compound List (TCL) plus any non-TCL organics that were
found, it is also unlikely that any significant contaminants
would have been missed.
EPA has recently adopted a policy that acceptable
exposures to known or suspected carcinogens are generally
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those that represent an excess upper bound lifetime cancer
risk to an individual of between 10"4 and 10*. In addition,
EPA will use the 10"8 risk level as the point of departure
for determining remediation goals for NPL sites. For
systemic toxicants (noncarcinogens) EPA defines acceptable
exposure levels as those to which the human population,
including sensitive subgroups, may be exposed without
adverse effects during a lifetime or part of a lifetime,
incorporating an adequate margin of safety (EPA 1990). This
acceptable exposure level corresponds to hazard index of 1.
If the hazard index is less than 1, no adverse effects would
be expected. If the hazard index is greater than 1, adverse
effects could be possible.
Based on the human health risk assessment presented in
the Draft Strasburg Landfill Remedial Investigation report,
estimate hazard indices for systemic toxicants did not
exceed 1 (the largest was 0.15) for any the pathways.
Therefore, the remainder of this discussion focuses on the
sources of the potential cancer risks.
The magnitude of the potential cancer risks posed by
site contaminants are summarized in Table 8. Estimates of
reasonable maximum exposure and risks potential residential
receptors are based on 30-year exposures, since that is the
90th percentile amount of time an individual lives at a
single residence (EPA 1989b).
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Table 6
CONTAMINANT CONCENTRATIONS IN WATER AND
SEDIMENT IN SEEP AREAS USED FOR EVALUATING
ACCIDENTAL CONTACT WITH THESE AREAS
UCL* Concentration = Upper 95th % Confidence Limit on
Arithmetic Mean
Chemical (yg/kg-soil ug/L-water)
ORGANIC8 (Mg/kg-soil; M9/I<-vater)
Benzene 6.1
bis(2-Ethylhexyl)phthalate 280
Chlorobenzene 20.8
Chloroethane 4.85
1,2-Dichlorobenzene 3.98
1,4-Dichlorobenzene 16
1, l-Dichloroethane 24.8
1,2-Dichloroethane 2.94
1,2-Dichloroethene 22.2
1, 2-Dichloropropane 4.43
Ethylbenzene 39.5
Naphthalene 38.9
Toluene 1.4
Trichloroethene 4.97
Vinyl chloride 19.1
Xylenes 104
INORGANICS (mg/Jcg-aoil; mg/L-water)
Antimony 15.6
Arsenic 15.9
Barium 257
Beryllium 1.31
Chromium 66.9
Mercury - .000475
Nickel 20.6
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Table 7
STRASBURG LANDFILL
SUMMARY OF CONTAMINANTS FOUND IN SOIL GAS AND AMBIENT AIR
COMPOUND AMBIENT AIR SOIL GAS FLUX BOXES
Concentration Concentration Concentration
Range/Detection Range/Detection Range/ Detect ion
Frequency ( ppb ) Frequency ( ppb ) Frequency ( ppb )
Benzene
D i bromomethane
1 , 1 -0 i ch I oroethene
1 , 2 -0 i ch I oroethene
0 i ch I orot et raf I uoroethane
Ethylbenzene
Tetrach I oroethene
Toluene
Trichloroethene
Trichlorof luoromethane
1 , 3 , 5 - T r i methy I benzene
Vinyl Chloride
m/p-Xylena
o-Xylene
24/91
3 - 150
0/91
4 - 224
40/91
2 - 840
0/91
2 - 11,000
N/A
N/A
17/91
1 - 567
N/A
30/91
3 • 84
N/A
N/A
44/91
1 - 129
N/A
N/A
2 - 10,000
0/10
0/10
17 - 1,700
0/10
2/10
3/10
1/10
10 - 4,400
1/10
1/10
80 - 5,400
1/10
3/10
1/10
60 - 11.000
1/10
3/10
2/10
9/10
6/10
5/10
7/10
0.08 - 0.64
N/A
0.03 - 0.06
N/A
0.29
7/10
0.09
N/A
1.53
3/10
0.14
N/A
0.46 - 1.65
N/A
0.04
. 6/10
0.4*
N/A
0.23 - 0.57
N/A
0.10 • 0.18
N/A: Not analyzed.
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Table 8
SUMMARY OF ESTIMATED EXCESS LIFETIME CANCER RISKS
TO 8TRASBUR6 LANDFILL SITE VISITORS
Key:
RNE = Reasonable Maximum Exposure
PCE 3 Tetrachloroethene
TCE * Trichloroethene
VC > Vinyl chloride
Receptors
Pathway Case
Inhalation RNE to
of Airborne Site
Contaminants Visitors
Accidental RNE
Contact with
Seep Areas
8X
Total Risks RNE
to Site
Visitors
Children
Composite
Adults Child/Adult Contributions
30-Year 1-6 6-12 12-18 1-31 by Exposure
Exposure Years Years Years Years Route
5.6 x 10~7 •- 2.5 x 10~7 1.3 x 10~7 6.4 x 10~7 Inhalation - 100X
(IX) (IX)
5.* x 10~6 -- 2.0 x 10'6 1.2 x 10'6 6.5 x 10~6 Dermal - SOX
8X 8t Ingestion - 7X
Inhalation - 44X
6.0 x 10*6 -- 2.3 x 10~6 1.3 x 10'6 7.1 x 10~6
Risk
Risk
Contributions
by Chemical
VC - SIX
1.1 -OCE - 44X
Benzene - 4X
TCE - 3X
Arsenic - BOX
VC - 9X
Beryllium -
1.1 -DCA - 2X
BEHP - IX
BEHP *Bis(2-ethylhexyl)phthalate
1.1-OCA » 1,1-Oichloroethane
t.Z-OCA = 1,2-Oichloroethane
1,1-DCE » 1,1-Oichloroethene
1.2-OCP = 1.2-Dichloropropane
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Among 30-year residents, the greatest exposure and
risks would accrue to an individual living at a residence
from birth through early adulthood, since children tend to
experience greater exposure than adults in the same setting.
This occurs for two main reasons: children engage in more
exploratory behavior than adults, thereby increasing their
potential contact with contaminants, and children have
greater ingestion-rate-, inhalation-rate-, and skin-area- to
body-weight ratios than adults, thus increasing the
intensity of their exposure in a given situation. For these
reasons, potential risks to a composite child/adult
receptor, age 1 to 31 years, were estimated by summing' risks
for age groups explicitly evaluated.
For on-site air exposure and accidental contact with
seep areas, the risk for children 6 to 12 years old and 12 -
to 18 years old, were combined with adult risks representing
18 years of exposure to complete the 30-year exposure
period. Children 1 to 6 years old would be unlikely to
wander onto the landfill unaccompanied by an adult; thus,
omission of the age group from these pathways would be
unlikely to affect the estimated composite risks. Using the
risk estimates for the composite child/adult population, the
most sensitive population, as shown in Table 8, the
magnitude of potential cancer risks to site visitors posed
by site contaminants was estimated to be 6.5 x 1Q for
accidental contact with seep areas and 6.4 x 10 for
inhalation of airborne contaminants. The excess lifetime
cancer risk for a site visitor exposed for 30 years to the
site contaminants in the air and seep areas is 7.1 x 10** .
This means that an individual visiting the site for the
recreational purposes described (walking, jogging riding
horses, ATVs or motorcycles) has a little more than one
chance in a million of developing a cancer that otherwise
would not have developed. This is the health risk that
would be prevented by eliminating visitor access to the
site.
Also shown in Table 8 are the risk contributions
attributable to the different chemical contaminants and to
the different routes of exposure. For the inhalation
pathway, all of the exposure is attributed to inhalation
with the greatest risk posed by vinyl chloride (51%)
followed by 1,1-dichloroethene. For the accidental contact
pathway, half of the exposure is attributed to dermal route,
44% to inhalation, and the remainder to ingestion; most of
the risk (80%) is attributed to arsenic exposure.
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Cancer potency factors (CPFs) have been developed by
EPA's Carcinogenic Assessment Group for estimating excess
lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are
expressed in units of (mg/kg-day) ', are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime
cancer risk associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of
the risks calculated from the CPF. Use of this approach
makes underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are
estimates of lifetime daily exposure levels for humans,
including sensitive individuals, that is not likely to be
without an appreciable risk of adverse health effects.
Estimated intakes of chemicals from environmental media
(e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the
RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur.
Excess lifetime cancer risks are determined by
multiplying the intake level with the cancer potency factor.
These risks are probabilities that are generally expressed
in scientific notation (e.g., 1x10"" ). An excess lifetime
cancer risk of IxlO* indicates that, as a plausible upper
bound, an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
Potential concern for noncarcinogenic effects of a
single contaminant in a single medium is expressed as ,the
hazard quotient (HQ) (or the ratio of the estimated intake
derived from the contaminant concentration in a given medium
to the contaminant's reference dose). By adding the HQs for
all contaminants within a medium or across all media to
which a given population may reasonably be exposed, the
Hazard Index (HI) can be generated. The HI provides a
useful reference point for gauging the potential
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significance of multiple contaminant exposures within a
single medium or across media.
As discussed above, the incremental cancer risk, using
all these conservative assumption factors is 7.1 X 10"*.
While this [risk] is within the 10* to KT1 risk range that
EPA uses to initiate remedial action, it is above the 10"*
"starting point" the EPA uses as a baseline for decisions.
When this is considered along with the threat of
continuing degradation of the cap due to ATV and other
traffic, we are making the following statement: Actual or
threatened releases of hazardous substances from this .site,
if not addressed by implementing the response action
selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
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7. Description of Alternatives
The intent of this interim action is to reduce the
health risk to people through inhalation and direct contact
that utilize the landfill site for recreational activities
such as motorcycle or all terrain vehicle riding, walking,
jogging, or hunting. The health risk will also be reduced by
providing protection for the existing cap. Furthermore,
health risks will be minimized by maintaining the integrity
of the existing cap. This means preventing people from
wearing "tire track" grooves in the existing cap or using
the landfill as a location for bonfires, shot gun shooting
and other recreational activities. The objective will ,be met.
by restricting access to the immediate landfill area. '
The following alternatives which were identified and
evaluated in the FFS, will be developed and discussed using
the following sequence: identification of remedial action
objectives; identification, effectiveness, implementability,
costs. Note: the costs presented in this decision document
are different than those presented in the FFS. The cost
figures have been revised to reflect the fact that costs
associated with operation and maintenance of the leachate
collection system are not included in this OU 2 remedy.
These costs were originally included in the FFS (see
Documentation of Significant Changes).
Alternative 1; No Action
Pursuant to the NCP, this alternative was developed to
provide a baseline to which the other remedial alternatives
can be compared. This alternative involves taking no action
at the site to restrict access. In 1989, the EPA issued the
first Record of Decision for this site which called for
collection and treatment of leachate emanating from the
landfill. This action continues to be implemented. A true
"no action" as described in CERCLA, would imply shutting
down this system, something, EPA would not consider at this
time because of the adverse health risks associated with
this action. The "no action" alternative considered under
this study is actually a "no further action11 and includes,
as part of the costs, maintenance of the landfill cap. This
on-going cost is also included in the other alternatives
described below. Under this alternative, action would only
occur in a reactive manner to either continual repair .damage
to the landfill areas by the grooving or tracking in the
existing landfill or, potentially, extinguishing landfill
fires.
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Effectiveness
Since no "further" action would be taken to restrict
access to the landfill area, not only would the current
human health risks remain, but risks would expect to
markedly increase as the grooving began to cut through the
PVC cap and expose more of the hazardous substances buried
there.
Implementability
No action is probably easier to implement than some of
the alternatives listed below. However, as the incidence of
site traffic increases, the amount of landfill and cap'
repair will also have to increase, and there is the real
potential that maintenance costs could become very high.
Costs
The costs to date are approximately $500 for the
existing signs, projected annual operation and maintenance
for the cap (0 & M) costs of $54,964 which includes $1,800
for an annual inspection and $52,914 for mowing, revegation,
erosion control, drainage and freeze-thaw damage repair.
This cost does not take into account the cost of controlling
and extinguishing a landfill fire, which is a real concern
based on the current uses of the landfill. The present worth
cost estimate for this alternative is $682,550. The costs
for 5-year site reviews are included in the Operation and
Maintenance (0 & M) and present worth costs for this
alternative. (Note: 5 year reviews are required by CERCLA
whenever hazardous wastes are left on site.)
Alternative 2; Additional Warning Signs
This alternative includes procuring either readily
available or custom-made signs, and posting these signs at
likely points of entry on to the landfill property. This
alternative was not considered as a "stand alone"
alternative, but rather something that would be considered
in addition to one of the other considered options. The
reason for no further consideration is that EPA has already
posted 12 signs around the property at all probable site
access points and it appears that they have been largely
ignored.
Effectiveness
There are twelve signs posted by EPA around the
property at all of the likely points of entry. Signs are
often effective in warning people of the real and potential
dangers associated with places and situations. In this
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case, it appears that the present signs have been
ineffective in preventing trespass or in decreasing any of
the recreational activities on the site.
Implementability
Signs are readily available in either standard or
custom made versions. Posting of additional signs would be
easily accomplished both around the landfill and at other
locations around the property.
Costs
The cost of additional signs for this site has been
estimated to be $500 per year (replacement costs). 0 & M
costs associated with replacing signs destroyed or damaged
due to weathering or vandalism is estimated at $250. per
year. The estimated time to purchase and install addition
signs is one month. The present worth estimate for this
alternative (by itself, no 5-year site reviews) is $3,602.
Alternative 3; Security Fence
This alternative includes the installation of a metal
fence, chain link, eight feet high, topped with barbed wire.
The fence would encompass the immediate landfill area
including most of the access road on the east, south, and
west sides of the landfill, the sediment pond, air stripping
building, and monitoring well 31. Four gates with locks
would be installed to allow authorized personnel to enter
other parts of the property to perform site related
activities. Access would also be given to emergency vehicles
and police. Maintenance of the fence and the existing cap is
included in this alternative.
Effectiveness
Access controls such as fences are widely used at many
types of hazardous activity sites, including construction
sites, industrial facilities, and waste disposal sites.
Security fences provide effective barriers in preventing
unauthorized personnel and various types of animals from
accessing the site. Furthermore, even if a fence is breached
(i.e., cut), the fence line defines a visible boundary line
beyond which it is clear to the public that further trespass
is not permitted.
Implementability
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Security fencing is a common and widely used technology
to restrict access to specific areas. Equipment and skilled
workers are readily available to implement this technology.
Since the only remedial action involved with this
alternative is the installation of a fence, protection of
workers and the community from exposure to contaminated
materials during remediation is not a major consideration
since this action will not require contact with the leachate
substance. A fence, even of this magnitude, could be
installed in approximately five weeks, once a field crew and
equipment are mobilized.
Costs
Capital cost for the installation of approximately 7500
linear feet of eight foot high security fence with four
lockable gates and warning signs is approximately.$135,500.
The annual O & M costs associated with this alternative is
projected at $55,405 of which $8,000 is projected for actual
fence maintenance, and the remainder ($47,155) for the
existing cap and additional warning signs($250). The present
worth estimate for this alternative is $823,020 and includes
the costs of 5-year site reviews.
Alternative 4; Security Fence With Remote Sensing
Capabilities
This alternative is similar, in terms of size and
scope, to alternative 3. However, in addition to the
security fence, electronics would be added to detect where
and when the fence was being compromised. In the event such
a breaching was effected, a signal would be sent either to
the local or state police office notifying these officials
that such an event had occurred. Maintenance of the fence,
in addition to the electronic sensing system(s), is included
in this alternative.
Maintenance of the existing cap and the installation of
additional warning signs is also included in this
alternative.
Effectiveness
All of the effectiveness of the fence listed in v
alternative 3 (above) would be incorporated in this
alternative. In addition, this alternative would be more
effective in that there would be a quick alarm in the event
a fence intrusion was sensed. There are two concerns with
sensing devices; first, a number of sensing devices would be
activated in the event an animal ran into the fence, or a
tree branch fell onto the fence. In addition, responders,
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such as local or state police, to the alarm may have
difficulty in accessing parts of the property where a fence
would be located.
Iroplementability
Security fences with remote sensing are widely used at
various types of locations. As with "unsensed" fences,
equipment and skilled workers are readily available to
implement this technology.
As with alternative 3, the only remedial action
involved with this alternative is the installation of a
fence, protection of workers and the community from exposure
to contaminated materials during remediation is not a major
consideration. However, since this alternative calls for a
response (to the alarm) by enforcement officials, and some
response intrusion onto the landfill is expected to be made,
on occasion, by these enforcement individuals, hazardous
waste training will have to be provided in terms of
personnel protection. The estimated time for installation of
a fence with remote sensing capabilities is eight weeks.
Costs
Costs for implementation of this alternative are
projected to be 37% higher than those for alternative 3.
This cost increase is all for the addition of the remote
sensing and alarm features. Therefore, the capital cost for
this alternative is projected to be $185,500. The annual 0 &
M costs associated with this alternative is projected to be
$65,405 and is based on a $10,000 annual increase over
alternative 3 for O & M of the remote sensing system. As
with alternative 3, the remainder of the 0 & M costs are
dedicated to the maintenance of the landfill cap and the
additional warning signs.
The total estimated present worth of this alternative
is $997,110 and includes the cost for 5-year site reviews.
Alternative 5; 24 hr. On-Site Security <5uard
This alternative would involve bringing someone on-site
on a permanent basis to serve as a sentry to keep
trespassers from accessing the landfill area. A commaiyi
post, or sentry station would have to be erected on the
property along with the appropriate utility connections.
Under this alternative O & M of the landfill cap would
continue.
Effectiveness
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Security Guards have been shown to be very effective in
numerous situations. On-site presence is usually an
effective deterrent, especially to acts of theft and
vandalism. Unlike electronic systems, guards are able to
distinguish between natural events, such as deer movement,
and unauthorized trespass. In addition, guards (and
guardposts) are visually less obtrusive than security
fences. However, it is difficult to get around on the
landfill because of the steep terrain and the poor condition
of the roads. Because of the topography of the landfill
area, no more than 20% of the landfill area is visible from
any one location. Since the guard would need some sort of
vehicle to patrol the site, it is anticipated that this
guard vehicle would add to the destruction of the existing
cap.
Implementability
Security Guards are commonly used to screen and
restrict access to specific controlled areas. A number of
local companies providing skilled guards are available.
There are hazardous materials on the landfill, and the guard
would be in relatively close contact with these substances.
The guards would have to receive training in personnel
protection and be included in a medical monitoring program.
The estimated time to erect a sentry post with utilities and
obtain qualified guards is eight weeks.
Costs
Capital costs would involve construction of a sentry
post with utilities, which are projected at $30,000. Annual
0 & M costs would include the security guard labor ($87,600)
along with utilities for the sentry post. 0 & M costs for
the landfill cap ($54,964) and warning signs would also
continue. Total annual O & M costs are projected to be
$144,314. Total present worth of this alternative is
estimated to be $1,821,292 and includes costs for 5-year
site reviews.
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8. Summary of Comparative Analysis of Alternatives
An analysis was performed on all of the alternatives
using the nine criteria specified in the NCP in order to
select a remedy for OU 2. An explanation of the nine
criteria is attached as Exhibit A. These nine criteria are
organized according to the group below:
THRESHOLD CRITERIA
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate
requirements (ARARs)
PRIMARY BALANCING CRITERIA
Long-term effectiveness
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
MODIFYING CRITERIA
Community acceptance
State acceptance
These evaluation criteria relate directly to
requirements in Section 121 of CERCLA, 42 U.S.C. Section
9621, which determine the overall feasibility and
acceptability of the remedy.
Threshold criteria must be satisfied in order for a
remedy to be eligible for selection. Primary balancing
criteria are used to weigh major trade-offs between
remedies. State and community acceptance are modifying
criteria formally taken into account after public comment is
received on the Proposed Plan.
The following is a summary of the comparison of each of
the alternative's strengths and weaknesses with respect to
the nine criteria.
Overall Protection of Human Health and Environment
All of the alternatives evaluated for this remedy^ are
considered to prevent contact with contaminated surface soil
and leachate, thereby limiting human exposure and reducing
future risks. Alternatives 3 and 4 provide the maximum
protection in that they provide a physical barrier to the
leachate seeps. Alternative 1 provides very little
protection, and Alternative 5 is only somewhat protective
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since it is impossible for a Security Guard to view the
entire site from any one vantage point.
Compliance with ARARs
CERCLA requires that remedial actions meet applicable
or relevant and appropriate requirements (ARARs) of other
federal and state environmental laws. These laws may
include, but are not limited to : the Toxic Substances
Control Act, the Clean Water Act, the Safe Drinking Water
Act, and the Resource Conservation and Recovery Act.
A "legally applicable" requirement is one which would
legally apply to the response action if that action were not
taken pursuant to Sections 104, 106, or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while
not "applicable", is designed to apply to problems
sufficiently similar that their application is appropriate.
The purpose of this ROD is to provide access control as
an interim action. Under the NCP, an alternative that does
not meet an ARAR may be selected where the alternative is an
interim measure, as here, and will become part of a total
remedial action that will attain the ARAR. Therefore, this
interim action is not required to specifically address ARARs
for such media as groundwater, air, or soil, since those
will be addressed in the next OU.
With respect to this interim action, PADER has,
however, cited their Municipal Waste Management Regulations,
specifically Section 277.212, as being relevant and
appropriate for this type of action. That Section (which
applies to Construction/Demolition Waste Landfills) provides
for access control in the nature of a gate, fence, and an
attendant for operating landfills. PADER has further
clarified this citation as only applying to the portions
regarding a gate and fence and not for having an attendant
on duty. In as much as these regulations pertain to active
landfills, EPA disagrees that these regulations are relevant
and appropriate. Under the National Contingency Plan, this
action is being undertaken to reduce the human health risk
from both the physical and chemical hazards of being on the
closed landfill and to minimize further damage to the ^
existing closed landfill cap. This situation does not
involve an active operating landfill, where much more
stringent controls are required.
Even if the Municipal Waste regulations cited were
ARARs, which they are not, a waiver of those ARARs would be
justified under Section 121 of CERCLA because the State has
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not consistently applied (or demonstrated the intention to
consistently apply) this regulation in similar
circumstances. That is, PADER has not consistently required
fences (or attendants) at closed, inactive landfills such as
this site. Not withstanding the above, EPA has addressed
PADER's concerns regarding access control, in the form of a
fence, by the interim action addressed in this ROD.
Loncr-Term Effectiveness and Permanence
The access controls are effective as long as they, are
enforced by EPA, or State and/or local authorities. Because
this is an interim remedial action, these measures are not
intended to be permanent, but only to prevent exposure
during selection and implementation of the final remedial
measures. The selected alternative may become permanent, if
it is selected as part of the final remedy.
The fence alternatives should remain effective as long
as the fence structures are maintained, although it is
expected that, over time, the remote sensing units as
discussed in Alternative 4 would experience a number of
electrical problems during to the variations in weather
conditions. One concern with the security guard option would
be that, over time, the guard traversing over the landfill
would tend to accelerate the degradation of the cap. The "no
action" alternative would result in a significant shortening
of the limited usefulness of the existing cap.
It is anticipated, however, that the selected
alternative would continue to be implemented as long as the
current site conditions persist.
Reduction of Toxicity.Mobility, or Volume Through Treatment
In as much as this is a interim measure for site access
control, no "treatment" is proposed as part of any of the
alternatives. Over time, contaminant levels in the present
areas of contamination may gradually decrease through
natural dilution, although the current extent of surface and
ground water contamination may spread into uncontaminated
areas.
Toxicity, as it applies to trespassers coming into
contact with the leachate substances, will be reduced as all
of the alternatives, except alternative 1, look to reduce
the instances of direct contact. The fence alternatives,
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both with, and without remote sensing, perform best in
achieving this goal. The physical barrier will immediately
eliminate contact with the contaminants in the leachate. The
security guard is less effective since a security can only
see a small part of the site from any one point.
Short-Term Effectiveness
Since the only remedial action involved with any of the
proposed alternatives is light construction (either fox a
fence or a sentry post) off of the landfill, protection of
workers and the community from exposure to contaminated
materials during remedial actions is not a major
consideration. Any of the alternatives can be completed
within six weeks once a field crew and equipment are
mobilized on site. One disadvantage of an on-site security
guard is that the guard will be exposed on a daily basis to
the leachate contaminants, whereas, fences minimize the need
for on-site security presence.
Implementability
All of the remedies evaluated for this Decision have
been proven reliable and are readily available. Security
fences are one of the most commonly implemented security
access controls in the world. Because of the length of the
fence and the vegetated state of the property, remote
sensing units, as discussed in Alternative 4, would probably
require more maintenance than would be expected in a more
developed area. In addition, the remote sensing units'would
have to be selected to sense only human intrusions. All of
the access controls will be implemented within the central
area of the property and will not impact any of the existing
public access roads in the area. Adequate equipment and
personnel are available to construct any of the remedies
from a number of sources located within a few miles of the
site.
With regard to permits, no permits would be required to
implement any of the alternatives.
Cost
Estimated Costs for the various alternatives are presented
in the table below:
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Estimated Remedial Action Costs
(in Dollars)
Alternative Capital O & M PresentWorth(Tot.Prs.Wt.1
1. No Action $500. $54,964. $682,050.($682,550)
2. Additional Signs $500. $250. $3,102.($3,602)
3. Security Fence $135,500. $55,405. $687,520.($823,020)
4. Scrty. Fence w/ $185,500. $65,405. $811,610. ($997,110.)
Remote Sensing
5. Security Guard $30,000. $134,705. $1,790,792.($1,821,292)
Based on the above cost comparison, the present worth
cost of installing a fence is less than one percent more
than no action. Based on the considerations discussed under
the other criteria, EPA concludes that the installation of
the fence identified in Alternative 3 is cost effective and
considerably less expensive than either the fence with
remote sensing capabilities or the security guard option.
State Acceptance
The Commonwealth of Pennsylvania agrees with the selected
interim remedy.
Community Acceptance
Community Acceptance is assessed in the attached
Responsiveness Summary. In general, the resident community
is very much concerned over the continued, and increasing
recreational use of this abandoned property. The community
also agrees that security access controls (such as a fence
or security guards) are needed to restrict access to the
landfill area. Furthermore, there is general community
agreement that Alternative 3 is both practical and will
restrict access to at least some of the trespassers. There
is concern by both the resident community and the
responsible parties that the fence will be vandalized ,and
recreational activities will continue on the property. If
this happens EPA will work to target individuals or groups
of individuals to educate them as to the hazards associated
with this site, and, as needed, look to incorporate parts of
some of the other alternatives, including additional signs.
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'ROPOSED FENCE LINE
PROPOSED GATE LOCATIONS (4)
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9. Selected Remedy
EPA expects to issue a proposal for the final remedial
action for the full site, including potential remedial
alternatives, by the fall of 1991. While additional
information is collected and analyzed, however, the
potential risk to exposure to contaminated surface soil and
leachate remains and it is necessary to protect human health
and the environment while further information for OU 3 is
collected and analyzed. Therefore, to eliminate the
potential for exposure to contaminants from the site, EPA
has selected this access control action as an interim •
remedial action.
The remedy selected is alternative 3, described above,
which calls for the installation of a security fence around
the perimeter of the landfill. As described in the proposed
plan, this fence will consist of cyclone wire fencing to a
height of eight feet and a top barrier of three strands of
barbed wire (or the like.) The specifics of this fence,
including the gauging of the support piping, the location
and widths of the gates etc., will be developed during the
remedial design phase of this remedy.
The site access restrictions are necessary to prevent
current access to the site by trespassers, particularly
children who live near the site. EPA has observed that the
incidence of trespassing has increased significantly in the
past six months. During the public meeting to discuss this
remedy, there was general and unanimous agreement by the
public in attendance, that trespassing is a serious problem
at this site, especially on the portion of the site
containing the landfill. The levels of volatile organic
compounds and heavy metals identified as present on the
landfill pose an unacceptable risk to such trespassers.
Additionally, worsening of the site conditions occur when
vehicular or equestrian traffic destroys the sparse soil
cover and (already torn) liner on top of the landfill.
In addition, in response to the comments raised by the
public, EPA will look to do the following:
1) Conduct an education session at local schools,
2) Speak to some nearby residents who have been identified
as frequenting the site for recreational purposes,
3) Discuss the issue of trespass enforcement with the
personnel in the local State Police barracks.
The total Capital cost for the security fence and
additional signs is estimated at $135,500., the total on-
going annual 0 & M costs for this alternative is $55,405.,
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of which approximately $8,000. is estimated for actual fence
maintenance. The estimated present worth of this alternative
is $823,020.
During the public comment period, a number of residents
and potentially responsible parties expressed doubt that the
fence would serve as a suitable deterrent to keep
trespassers out. In the event that the fence is not
successful in restricting access to trespassers, EPA, in
consultation with PADER, will evaluate some of the other
alternatives, such as posting an on-site security person
during periods of increased trespassing activity as may
occur on week ends or during hunting seasons.
If implementation of the selected remedy demonstrates,
in corroboration with physical and chemical evidence, that
it will not be possible to meet the interim remediation
goals for this action, and it is thus technically
impracticable (either technically infeasible or unreliable)
to achieve and maintain the security access controls
throughout the landfill area, the EPA, in consultation with
the Commonwealth of Pennsylvania, would intend to amend this
ROD or issue an Explanation of Significant Differences to
inform the public of alternative access controls.
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10. Statutory Determinations
The selected remedy is protective of human health and
the environment as required by Section 121 of CERCLA.
Potential risks from exposure to contaminated surface soil
and leachate are prevented by the installation of physical
barriers that restrict access to the landfill area.
The selected remedy is the most cost-effective interim
action approach available to protect human health and the
environment. The selected remedy uses security access
control to eliminate the potential for direct (inhalation
and immediate contact) human exposure to contaminated .
surface soil and landfill leachate. The selected remedy is
also protective of the existing cap and the leachate
collection and treatment system, which was installed as part
of OU 1.
The five-year review required by Section 121 of CERCLA
is applicable to the selected remedy. This review will be
conducted in conjunction with the other remedial actions
developed and specified for this site.
Protection of Human Health and the Environment.
The security access control proposed prevents contact
with contaminated surface soil and landfill leachate,
thereby limiting human exposure and reducing potential
future risks below the level of concern.
The installation of the fence will not pose a
significant health problem to the workers, nor will it
enhance, or otherwise promote air or groundwater
contamination.
Compliance with Applicable or Relevant and Appropriate
Requirements.
As stated above there are no ARARs, criteria, or
guidance that apply to this type of security access control
at a closed landfill facility. The PADER does have a
requirement for active landfills, PA Section 273.212, that
they be enclosed by a fence. While this is not an ARAR for
this site for the same reasons presented with respect (to the
Pennsylvania Municipal Waste Management Regulation discussed
in Section 8. above this action will satisfy that
requirement of Section 273.212 for a fence.
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Cost-Effectiveness.
The selected remedy affords overall protectiveness
proportionate to its costs. Fences have shown, if only
through their universal application, that they are an
economical and effective means to restrict access onto a
specific area.
Utilization of Permanent Solutions and Alternative Treatment
(or resource recovery) Technologies to the' Maximum Extent
Practicable (MEP).
The selected remedy utilizes a permanent solution1 to
the maximum extent practicable. EPA has used treatment for
past remedies at this site and intends to implement further
treatment technologies (again, as practicable) for future
actions at this site.
As an interim action, a security fence is most
effective as a quick, short time implementation remedy. It
is both relatively inexpensive and technologically simple to
construct and provides the best balance of trade-offs among
the alternatives with respect to the pertinent evaluation
criteria, given the limited scope of this action. It is
expected that in the long term it will be effective in
keeping a high percentage of trespassers out of the landfill
portion of the property, even if the fence line is breached.
In as much as the security fence is effective in keeping
these people from the landfill area, it will be effective in
reducing the toxilogical impacts of direct contact with the
effects of hazardous wastes present in the leachate seeps.
It will also be protective of both the landfill cap (from
grooving and campfires) and the leachate collection and
treatment system (from vandalism). Furthermore, the fence
and signs satisfy the restrictions raised and requested by
the community during the public meeting regarding landfill
control.
Of the criteria discussed above, the most decisive
factor was the ready implementablity of this remedy along
with its relatively low cost.
Preference for Treatment as a Principal Element. ^ .
The selected remedy does not utilize any treatment. As
an interim action, access to the area of soil contamination
and landfill leachate will be eliminated to all but trained,
authorized, remedial personnel. The principal treat of
direct contact exposure, especially to children trespassing
on the site, will be eliminated.
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The preference for treatment as a principal element
will be addressed by EPA in the final decision document (OU
3) for the site.
There were several factors for selecting Alternative 3.
It is cost effective, it is protective of human health, the
landfill cap, and the leachate collection system.
Alternative 3 is also easily and quickly implementable. No
unacceptable short term risks or cross media impacts will be
caused by implementation of this remedy.
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11. Documentation of Significant Changes
While it is not felt to be highly significant, the
selected remedy, as well as the other alternatives
considered, differ in one respect from the description of
the remedy in the proposed plan and the FFS. The proposed
plan and the FFS included costs and 0 & M for the leachate
collection and treatment system. Upon further review, it was
decided that the costs associated with these elements were
better addressed (and had been addressed ) under the remedy
for OU 1.
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RESPONSIVENESS SUMMARY FOR 8TRASBURG LANDFILL SITE
A. OVERVIEW
At the time of the public comment period which ran from
April 18, 1991 to May 18, 1991, EPA had already selected a
preferred interim access control for the Strasburg Landfill.
EPA's recommended alternative was the erection of an eight foot
high security fence around the circumference of the landfill
portion of this property, a linear distance of approximately
7,500 feet. Judging from the comments from the public and the
Commonwealth of Pennsylvania, there is strong support for
limiting access to the landfill area.
In response to the proposed plan and the documents contained
in the administrative record developed for this interim remedy,
the EPA received only two written comments(received from two
potentially responsible parties (PRPs). The issues raised in
these letters are addressed below:
B. summary of Written Comments Received During the Public Comment
Period
Comment: The risk estimate is low enough that no action needs to
be taken.
Response: The risk estimate developed as a result of the sampling
conducted on the site showed that the exposure risk for
on site exposure was 7.1 X 10"9. EPA believes that this
risk is sufficient to warrant this remedial action.
Furthermore, the action is consistent with the guidance
regarding remedy selection as contained in Section
300.430 of the NCP. In addition to the risk, EPA
believes that this interim action is warranted based on
the observed incidences of vandalism at the leachate
collection system and degradation to the existing cap
caused by unauthorized recreational activities on the
landfill.
Comment: The exposure calculation is too high.
Response: The exposure calculation used by EPA is very
conservative. It was based on an individual utilizing
the site an average of 1.5 times per week. While £PA
feels that the actual frequency of exposure will be
somewhat seasonal-dependent, the seasons in which the
frequencies are likely to be the highest are those
where the trespassers will have the maximum amount of
dermal exposure, i.e., the late spring, summer, early
fall seasons. Furthermore, discussions with bikers who
have frequented the site indicate that they do not wear
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Comment:
any sort of protective gear. Usual dress for these
events is short pants, optional T shirt, and sneakers.
The total number of trespassers is unquantified;
however, observations and comments from the public
would place the number of the various recreational
users of the site well up in the hundreds (joggers,
hunters, "camp-fire makers", dirt bike riders, horse
back riders).
The exposure limit of 30 years is realistic
because people will continue to frequent the site if
left unrestricted and, furthermore, EPA has not a.s yet
determined a course of action for further remedial
action at the site.
The commenter also pointed out that the leachate
area is only a single 20 X 20 foot area. In fact, as
satellite photos (interpreted) have shown, there are
numerous (over a dozen) locations around the landfill
where leachate is coming out of the landfill.
Fencing the site is ineffective in keeping people from
the landfill property and also a three foot cyclone
fence and signs would be just as effective as an eight
foot security fence.
Response: The fence will be constructed in a location which will
not be visible from nearby Strasburg Road and a
determined individual will be able to compromise the
security of the fence without a considerable amount of
planning and effort. This, however, is the nature of
fences. It is hoped that this fence will remain as
intact as the fence has around the command post which
was built for the first remedial action. Even in the
event that the fence is cut or otherwise breached, the
majority of the fence will remain intact and will serve
as an access deterrent to the majority of trespassers
and also will stand as a statement by EPA that access
to this area is meant to be restricted.
*
A three foot fence was not considered effective
because even a child could lift a dirt bike over such a
low barrier. Furthermore, EPA's experience has st\own
that trespassers sometimes use these low barriers to
create ramps for further recreational enjoyment. Also,
the commenter suggested that coils of razor wire be
installed around hot spots. EPA feels that the risk of
children riding dirt bikes on the landfill and falling
into razor wire is unacceptable.
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Comment:
It is not clear that this commenter is aware that
signs are currently posted around the property. These
signs are posted at all of the normal egress routes
onto the property and clearly indicate that hazardous
wastes are present on the site. While these signs have
been clearly posted, it is apparent that they have
ignored by the trespassers. EPA will, however, look to
post additional signs on the fence of the landfill.
The most appropriate course of action would be to
address only the "hot spot" areas on the landfill.
Response: In the time that EPA has overseen the remediation of
this landfill, a number of additional leachate seeps
have emerged. Since new seeps appear on occasion, and
there is also some visual evidence that there are some
intermittent seeps, it would be inappropriate to
address only existing "hot spot" areas. There is no
good evidence to even identify areas of the landfill
where one could project seeps likely to occur.
Comment: The costs of the proposed remedies should be shared by
all of the responsible parties, including generators,
transporters, and disposers.
Response: This comment goes to the issue of enforcement and not
to the specific remedy proposed, which is the subject
of this Responsiveness Summary.
As part of this written comment, commentary was also provided
regarding the draft Remedial Investigation (RI) report, parts of
which were used for this decision to support the risk assessment.
These comments, with EPA's responses, are:
1. EPA should identify OSHA, NIOSH and ACGIH limits for vinyl
chloride.
Response: The cumulative risks associated with the chemicals
determined present at this site are discussed in detail in
Section 5, Human Health Risk Assessment, of the draft report.
2. Zarzicki's septic tank should be considered as a source of
contamination for his drinking water well.
Response: EPA considered this possibility; however, the
contaminants at monitoring wells nearer to the landfill show
higher levels of the same contaminants, and these contaminants
are not those typically associated with septic tank operation.
3. EPA should have used independent validation for their data
analysis.
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Response: Within EPA Region 3, separate offices are used to
collect the data and perform data validation.
4. The RI should clarify the use of an asphalt primary liner.
Response: The purpose of this RI was to determine the nature and
extent of contamination. Facts concerning the subject liner will
be evaluated during the design phase of the remedy dealing with
those aspects and is not of concern with regard to this selected
remedy.
5. A water balance needs to be performed to determine if
infiltration is excessive.
Response: This comment is acknowledged; however, it is felt to
not be of concern with regard to this selected interim remedy.
This comment will be reviewed in regard to finalizing the RI
document in connection with the next operable unit.
6. Other data more recent than 7-8 year old data should be used
to support remedy decisions.
Response: The underlying implication of this assertion is wrong.
Data from sampling as recent as December 1990 was considered in
developing this remedy.
7. EPA should point out that landfill design was compatible with
Diamond Shamrock's PVC waste.
Response: The high levels of PVC measured in the soil gases
makes it clear that PVC is escaping through the PRP designed and
constructed cap.
8. All known users and generators should be listed in Table 1-4.
Response: The users and generators listed are presented to
typify those who used this landfill. EPA is continuing to develop
information with regard to the complete list of potentially
responsible parties for this site.
9. Problems associated with analytic interpretations regarding
vinyl chloride determinations should be explained in the report.
Response: EPA has considered and adapted this recommendation; the
data used in the risk assessment was appropriately qualified.
This information along with the appropriate qualifiers is
contained in Volume II of the Remedial Investigation. None of the
data qualified as "R" was used in the risk assessment.
10. PVC Wastes were adequately described in the approved module.
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Response: This comment is acknowledged; however, the PVC wastes
are not affected by this selected interim remedy. This comment
will be reviewed in regard to finalizing the RI document in
connection with the next operable unit.
11. Requests that a statement be included that FADER should not
have allowed broken shale to be placed on top of the liner.
Response: EPA disagrees with this comment
at this time.
12. Requests that the following information be obtained before an
interim remedy is installed:
a) methane and total gas generation rate;
b) landfill gas pressure;
c) waste elevations;
d) liner elevations (multiple);
e) leachate collection elevations (multiple);
f) groundwater elevations in and directly adjacent to the
landfill.
Response: This comment is acknowledged; however, none of these
issues are affected by the interim remedy. This comment will be
reviewed prior to finalizing the RI in connection with the next
operable unit.
13. Tables in the report should be revised to reflect elevation
levels.
Response: This comment is acknowledged, however, it is not
related to this selected interim remedy. This comment will be
reviewed prior to finalizing this document in connection with the
next operable unit.
14. Requests the report to state that vinyl chloride is present
due only to the degradation of other solvents.
Response: EPA disagrees with this conclusion and will not
include such a statement in this report. There are several
different routes through which vinyl chloride was deposited at
the site, including, for example, direct deposit of "off-spec"
vinyl chloride product by manufacturers.
15. Requested a clarification of the bioassay results. v
Response: This comment is acknowledged; however, it is not
relevant to this selected interim remedy. This comment will be
reviewed prior to finalizing the RI document in connection with
the next operable unit.
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16. There is no basis to suspect any "separate phase dense
chlorinated organics were associated with the waste [Diamond
Shamrock] PVC".
Response: EPA agrees with this comment.
17. Requested that the RI be amended to include a statement that
the landfill was inappropriately located over an intermittent
stream and should never have been allowed to operate by PADER.
Response: EPA has no evidence to substantiate this allegation;
consequently no such statement will be included. Furthermore,
this comment has no bearing on the selected remedy or data
supporting it.
18. Requested that the site be reconsidered as two separate sites
and then each site should be separately evaluated for inclusion
on the NPL.
Response: EPA has already concluded its evaluation on this
matter and is satisfied that the site has been appropriately
identified and scored. EPA disagrees that this proposed approach
is more protective.
Comment: Parties representing the Newlin Corporation and the
Somerset Strippers of Virginia assert that they were not involved
in the operation of the landfill.
Response: EPA does not agree with this assertion and will not
include such a statement in the report.
C. Comments Raised During The Public Meeting:
During the public meeting, which was held on April 30, 1991
a number of comments were raised. All of these comments were
raised by the residents who live in the vicinity of the landfill.
These comments are summarized below:
Comment: There are concerns that a fence, being located in a
remote area will only be cut and recreation will continue on
the landfill.
Response: There is the possibility of the fence being cut,
however, EPA feels that the mere presence of the fence*, will
keep out a large majority of the trespassers; and, through
scheduled maintenance, the fence will be repaired on a
routine basis thereby limiting, even further access to the
landfill.
Comment: The fence should contain some remote sensing
capabilities
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Response: After a few comments, the public agreed that, even if
an alarm is set off, given the terrain of the landfill, it
is difficult for enforcement officials to adeguately respond
to the landfill and, ultimately, there are no advantages to
a remote sensing fence over a standard fence at this
location.
Comment: Additional signs with stronger warnings should be posted
on the fence.
Response: EPA had proposed additional signs as an "add on"
alternative. Based on the community concerns EPA has added
additional signs as part of the selected remedy.
Comment: EPA needs to do a better job communicating the risks
associated with the landfill to both some of the trespassers
and to the State Police.
Response: EPA has responded to this request by going out and
meeting with some of the people who were identified as using
the site for recreation and has also scheduled a meeting
with the State Police to discuss site security.
D. Concerns Raised by the Pennsylvania Department of
Environmental Resources (FADER)
In addition to a number of general Applicable or Relevant
and Appropriate Regulations (ARARs) for site remediation, the
PADER cited several action-specific ARARs for the Strasburg
Landfill. These comments (with response by EPA) are as follows:
1) EPA should consider PA Municipal Waste Regulation Section
277.212 regarding site access control.
Response: EPA and PADER are in agreement that access needs
to be restricted to the landfill area. EPA disagrees that
this regulation is relevant and appropriate for this site.
The Regulation cited is for an active landfill whereas this
site is a closed landfill. PADER does not routinely require
fencing of closed landfills nor do they routinely require an
attendant to be on duty. The fence which was selected as the
remedy in this Decision will satisfy the PADER regulatory
requirements for closed landfills with regard to the access
control. \
2) EPA should include a sketch with the proposed location of the
map.
Response: EPA has included a sketch of the fence line in the
ROD.
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3) A copy of the Risk Assessment needs to be provided to PADER
for this interim remedy.
Response: The Risk Assessment was included with the
finalized Focused Feasibility Study (FFS) which was sent to
PADER.
4) EPA needs to be more specific with regard to the
specifications for the fence.
Response: The specifics of the fence will be included at the
design stage of this project and PADER will have an
opportunity at that time to provide additional input. .
E. Remaining concerns
The main issue the public focused upon was that since the
landfill was located on a remote portion of the property that
the proposed fence would be vandalized so that access could be
gained to the landfill area. This (vandalism) has occurred at
other sites administered by EPA. In light of this experience,
part of the O & M costs projected for this remedial action is for
repair of fence cutting and gate vandalism. In the event that the
vandalism continues and the 0 & M shows to be ineffective, EPA
will then, in that light and in the light of the remedial status
of the landfill at that time, evaluate some of the other
alternatives reviewed in this action, such as remote sensing
devices, and on-site security guards.
8
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Lee Park, Suite 6010
555 North Lane
Conahohocken, PA 19428
215-832-6012
June 28, 1991
Mr. Edwin B. Erickson
Regional Administrator
U.S. Environmental Protection Agency
841 Chestnut Building
Philadelphia/ PA 19107
Re: Letter of Concurrence
Strasburg Landfill
Superfund Site
Newlin Township/ Chester County
Interim Record of Decision
Operable Unit #2, Site Access Control
Dear Mr. Ericksons
The Interim Record of Decision/ concerning a specific action to be
taken at the Strasburg Landfill Superfund Site/ has been reviewed by
the Department.
The major components of the selected remedy for the Site Access Control
Operable Unit #2 include)
* Construction of a fence around the landfill perimeter. The fence
will enclose leachate seeps, contaminated soils, an air stripper
for leachate treatment/ and a soil borrow, area.
* Construction of four gates to permit access by trained
authorized personnel.
I hereby concur with the EPA's proposed action, with the following
conditions t
* The Pennsylvania ARARs for a fence or barrier to control access/
as specified by 25 Pa Code Sections 273.212 (a)(b)(c) and
277.212 (a)(b)(c), will be adhered to.
* it is understood that EPA is not waiving Pennsylvania ARARs for
this final remedy at this time.
Recycled Plptr.
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Mr Edwin B. Erickson
June 28, 1991
-2-
* The Department will be given the opportunity to evaluate
appropriate remedial alternatives to insure compliance with
Pennsylvania ARARs-and to concur with future decisions related
to the design of the remedial action.
* EPA will assure that the Department is provided an opportunity
to fully participate in any negotiations with responsible
parties.
* The Department's position is that its design standards are ARARs
pursuant to CERCLA Section 121 as amended by SARA, and will
reserve our right to enforce those design standards.
* The Department will reserve the right and responsibility to take
independent enforcement actions pursuant to State law.
* This concurrence with the selected remedial action is not
intended to provide any assurance pursuant to CERCLA Section 104
(c)(3) as amended by SARA.
Thank you for the opportunity to concur with this EPA Record of
Decision.
If you have any additional questions in this matter, feel free to
contact me.
Very truly yours,
Leon T. Gonshor
Regional Director
cc: Office of Environmental Protection
Mr. Snyder
Ms. Hoffman
Mr. Lynn
Mr. Danyliw
Mr. Cole
" Mr. Gelburd
Mr. Olowiler
Re (G) LB819
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