United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/124
September! 991
4>EPA Superfund
Record of Decision:
Heleva Landfill (Amendment),
PA
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80272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R03-91/124
*a^t> and Subtitle
PERFUND RECORD OF DECISION
Heleva Landfill, PA
First Remedial Action (Amendment) - Final
7. Autwr(a)
8. Performing Orgalntzrfon Nune and AddniM
12. Sponsoring Organization Nun* and Addreae
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1 • Acceealon No.
5. Report Date
09/30/91
6.
8. Performing Organization Rept No.
10. ProiBCtTajk/Work Unit No.
1 1. CorrtracHQ or Grant(G) No.
(C)
(G)
13. Type ot Report ft Period Covered
800/000
14.
IS. Supplementary Notea
16. Abatract(Umrt: 200 word*)
The 25-acre Heleva Landfill site is a former sanitary landfill in North Whitehall
Township, Lehigh County, Pennsylvania. Land use in the area is predominantly rural
with scattered residences. The estimated 150 people who reside within one-quarter
mile of the site used the ground water underlying the site as their drinking water
supply prior to 1986. From 1967 to 1981, the Heleva Landfill accepted municipal and
dustrial wastes, which included large volumes of liquid TCE. As a result of
.leva's denied requests for solid waste permits and refusal to implement a State
ordered biostimulation project, the State closed the landfill in 1981. A number of
subsequent State investigations revealed ground water contamination by VOCs, other
organics, and DNAPLs at levels that exceeded State and Federal ground water limits.
A 1985 Record of Decision (ROD) addressed onsite ground water contamination and
provided for extending an existing water main; capping the entire landfill;
constructing surface water diversions and gas venting systems; constructing an onsite
ground water treatment facility; establishing a pumping and treating system for the
contaminated neargradient ground water; and ground water sampling and monitoring.
Construction of all of these major remedial activities has been completed except for
(See Attached Page)
17. Oocunent Anelyaia a. DMCripton
Record of Decision - Heleva Landfill, PA
First Remedial Action (Amendment) - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, TCE,
toluene, xylenes)
c. COSAT1 Hold/Group
4afaOty Statement
19. Security Claw (This Report)
None
20. Security CUM (Thia Page)
None
21. NaofPagea
26
22. Price
See Instructions on Reverse
Or* IIONAL. rvHM 2/2 (4>77)
(Formerly NTIS-35)
Department ot Commerce
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EPA/ROD/R03-91/124
Heleva Landfill, PA
~'rst Remedial Action (Amendment) - Final
stract (Continued)
the ground water extraction and treatment component. .This ROD amends the ground water
component based on data from the 1989 predesign study which determined that collection of
downgradient ground water is technically feasible. The primary contaminants of concern
affecting the ground water are VOCs including benzene, PCE, TCE, toluene, and xylenes.
The amended remedial action for this site includes continuing with the selected remedy
from the previous ROD and replacing the ground water portion with extracting near
gradient ground water to contain the highly contaminated dissolved plume immediately in
the vicinity of DNAPL contamination in the ground water; pumping and onsite treatment of
the downgradient portion of the aquifer, and discharging the treated ground water onsite
to surface water. The estimated present worth cost for this amended remedial action is
$40,950,000, which includes an annual O&M cost of $1,848,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Downgradient ground water will be remediated to State
background levels including benzene 0.2 ug/1, PCE 0.03 ug/1, TCE 0.03 ug/1, and
toluene 0.2 ug/1. The State and Federal ARARs for remediation of neargradient ground
water to background levels and MCLs will be waived due to technical impracticability.
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RECORD OF DECISION AMENDMENT
HELEVA LANDFILL SITE
DECLARATION
SITE NAME AND LOCATION
Heleva Landfill Site
Lehigh County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents an amendment to the United States
Environmental Protection Agency's (EPA) selected remedial action
chosen in a Record of Decision signed on March 22, 1985 (the
"1985 ROD1*) for the Heleva Landfill Site, in Lehigh County,
Pennsylvania. This amended remedy was chosen in accordance with
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. S 9601, et
seq.. and is consistent, to the extent practicable, with the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. This amendment is made in accordance
with Section 117 of CERCLA, 42 U.S.C. S 9617, and
40 CFR S 300.435(c)(2)(ii). This decision is based on information
contained in the Administrative Record file for the site.
The Commonwealth of Pennsylvania has not concurred with the
selected remedy. The Commonwealth does not agree with EPA that
the State ARAR for cleanup of neargradient ground water to
background levels and the Federal ARAR for cleanup to MCLs and
non-zero MCLGs should be waived at this time on the grounds of
technical impracticability.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. S 9606, that actual
or threatened releases of hazardous substances from the site, as
discussed in the section entitled "Summary Of Site Risks" below,
may present an imminent and substantial endangerment to the
public health, welfare, or the environment.
DESCRIPTION OF THE ORIGINAL SELECTED REMEDY
The remedial action selected in the 1985 ROD consists of:
1) Extending an existing water main from Ironton to Ormrod
2) Capping the entire 25-acre landfill according to Resource
Conservation and Recovery Act (RCRA) standards
3) Constructing surface water diversion and gas venting
systems
4) Conducting a predesign study to delineate fully the
source of contamination and determine sinkhole activity
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5) Pumping and treating of the neargradient ground water to
reduce the source of ground water contamination
6) constructing appropriate ground water treatment
facilities so that the treated ground water may be
discharged to nearby Coplay Creek.
Construction of all of the major components of the 1985 ROD has
been completed with the exception of components relating to
ground water extraction and treatment.
DESCRIPTION OF THE AMENDED SELECTED REMEDY
The original selected remedy remains the same except for the
ground water pump and treatment component, which is amended as
follows:
Pump and treat both the neargradient ground water to contain
the dissolved plume associated with contaminants in the form
of Dense Non-Aqueous Phase Liquids (DNAPLS), and the
downgradient ground water to restore that portion of the
aquifer to useability.
STATUTORY DETERMINATIONS
The remedial action specified in this amendment was determined to
be necessary in order to return the aquifer, to the extent
possible, to a useable state and to contain contamination where
the ground water cannot be restored. During the predesign
studies for the original pump and treat system, it was
demonstrated that an assumption made in the 1985 ROD—that it was
not feasible to effectively collect ground water downgradient of
the Site—was, in fact, erroneous. In addition, the recently
recognized effects of the DNAPLS, which provide a continuing
source of contamination, will preclude the restoration of the
ground water by the particular pump and treatment component of
the remedy selected in the 1985 ROD. As explained in more detail
below, the pump and treatment component of the amended selected
remedy will contain contamination in the area of the DNAPLs
(neargradient) and restore the downgradient ground water to
useability.
The amended selected remedy is protective of human health and the
environment and is cost-effective. EPA believes that the amended
selected remedy will meet all Federal and State requirements that
are applicable or relevant and appropriate to the remedial action
with the sole exception of the Commonwealth's requirement to
remediate ground water to background concentrations in the area
neargradient to the Site. Accordingly, I hereby waive the
provisions of 25 PA Code 264 with respect to ground water
background concentrations in the area neargradient to the Site
due to technical impracticability. This remedy uses permanent
solutions and alternative treatment technologies to the maximum
extent practicable. The extension of the water main, landfill
cover and ground water extraction and treatment remedy selected
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by this amended decision document satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility or volume as a principal element.
Because this remedy will result in hazardous substances remaining
onsite above levels allowing unrestricted use and unlimited
access, a review under Section 121(c) of CERCLA, 42 U.S.C.
S9621(c) will be conducted within five years of this action, and
every five years thereafter, 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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RECORD OF DECISION AMENDMENT
EELEVA LANDFILL SITE
DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
The Heleva Landfill Site (the "Site") consists of a 25-acre
landfill and adjacent land, located on a 93-acre tract of land
owned by the Heleva family in North Whitehall Township, Lehigh
County, Pennsylvania. The Site is located between Ironton and
Ormrod and is bounded by Legislative Route 39049 on the south and
east, Township Route 687 (Hill Street) on the north and
Legislative Route 39038 (Main Street) on the west (See Figure 1).
The area surrounding the site is primarily rural and has small,
single-family residential developments. Approximately
35 families reside in Ormrod, located about one-quarter mile
southeast of the Site. Ironton, located approximately one-
quarter mile west of the Site, has a population of about
150 residents (see Figure 2). Beginning in 1989, approximately
30 new homes were constructed along the north side of Hill
Street, adjacent to the Site. The Ironton Elementary School is
located within 1,500 feet, south of the Site.
Ground water beneath the Site has the characteristics of a Class
IIB aquifer (i.e. potentially available for drinking water,
agricultural, or other beneficial use) and flows in a
southeasterly direction towards Coplay Creek. The communities of
Ironton and Ormrod were connected to a municipal water supply
system in 1987 after the discovery of contamination in the West
Ormrod Water Association public water supply well located
southeast of the landfill area.
This ROD Amendment is necessary because, as explained in more
detail below, the ground water pump and treat remedy chosen in
the 1985 ROD (the "Original Remedy") stated that ground water
downgradient of the Site could not be remediated. However, a
better understanding of Site conditions, based on the study
"Field Data Acquisition For Design of Ground Water Extraction and
Treatment System", September 1989, has led to a reconsideration
of this portion of the Original Remedy. This ROD Amendment
specifies cleanup of the downgradient ground water via extraction
and treatment.
This ROD Amendment acknowledges that cleanup of Dense Non Aqueous
Phase Liquids (DNAPLs), the major source of ground water
contamination at this Site, is not feasible at this time. The
ROD Amendment, instead, aims to hydraulically contain the
dissolved portion of the plume in the immediate vicinity of the
DNAPLs (the "neargradient" ground water), while the dissolved
plume which has migrated downgradient from the subsurface DNAPL
source will be remediated and that portion of the aquifer (the
"downgradient" ground water) restored to useability. Both the
containment and the remediation will be accomplished by ground
water extraction and treatment (the "Amended Remedy").
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IX. SITE HISTORY AMD ENFORCEMENT ACTIVITIES
The Site began operations as a sanitary landfill in 1967 and
accepted 250 to 350 tons/day of general mixed refuse, paper,
wood, and orchard wastes from the Allentown area. In addition to
the municipal wastes, industrial wastes were sent to the Site as
early as 1967. State inspection reports from the early 1970s
indicate that the landfill accepted large volumes of liquid
trichloroethene (TCE), an industrial degreaser, from at least one
industry in the area.
The Site operated through the 1970s without a permit. On May
3, 1977, Heleva Landfill, Inc. ("Heleva Landfill"), submitted an
application to the Pennsylvania Department of Environmental
Resources (FADER) for a solid waste permit. On July 8, 1977,
this permit application was denied, and the landfill was ordered
to cease operation by PADER. On July 11, 1977, Heleva Landfill
filed an appeal with the Pennsylvania Environmental Hearing Board
to have the permit denial overturned. On May 19, 1980, a
consent order was signed by PADER and Heleva Landfill which
settled the permit appeal. In this consent order, Heleva
Landfill agreed to: control erosion to Todd Lake, control
leachate generation, cease dumping in currently filled areas,
limit dumping in unfilled areas, and initiate a biostimulation
pilot project for TCE reduction in the contaminated soil and
ground water. On November 25, 1980, PADER's Bureau of Solid
Waste Management denied Heleva Landfill's application to expand
the landfill operation because of Heleva Landfill's failure to
implement the biostimulation project to the Bureau's
satisfaction. Operations at the Site continued until its closure
by PADER on May 1, 1981. As part of the closure procedures,
Heleva Landfill was required to cover the landfill with two feet
of topsoil and then revegetate it. Attempts to seed the covered
area were not effective due to the low fertility of the cover
material; much of the land had little vegetation and many erosion
gullies were present.
The Site was listed as potentially hazardous on November 15, 1979
by PADER and the U.S. Environmental Protection Agency (EPA) under
the Resource Conservation and Recovery Act (RCRA) Section
7003 Dumpsite Program. A Site Inspection Report under this
program ranked the Site's apparent seriousness as high. A Hazard
Ranking System (HRS) model was first generated on August 4, 1982,
and was updated on September 2, 1982. The aggregate HRS score of
50.22 resulted in the listing of the Heleva Landfill Site on the
CERCLA National Priorities List (NPL) in September 1983.
EPA conducted a Remedial Investigation/Feasibility Study (RI/FS)
in 1984 to evaluate the nature and extent of Site contamination
and develop a remedial strategy. This investigation determined
that site related TCE had contaminated two residential wells at
concentrations above the 10~6 risk level. In addition, the 1985
ROD concluded that, if concentrations of Site related
contaminants in the residential wells rose to the levels found in
the monitoring wells, users of those wells would be exposed to
chronic toxicity effects. The remedial actions selected in the
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O
2 /o
Qo
^EA OF GROUND
WATER CONTAMINATION
HELEVA LANDFILL
SCALE IN FEET .*_„ *t _ . *, .•» , .v ^ *. . .\s ./ «• • i » ^S--,«««_«A. i / »j^. _ _»-i*1-.**^.
BASE MAP IS A REDUCTION OF A PORTION OF THE U S.&S CEMENTON.PA QUADRANGLE (75 MINUTE SEMES, 1964. PHOTOREVISED 1972. CONTOUR INTERVAL K)l AND
THE CATASAUQUA. RA QUADRANGLE (75 MINUTE SERIES, 1964,PHOTOREVISEO 1972.CONTOUR INTERVAL lO') FIQJRF
LOCATION MAP
HELEVA LANDFILL SITE, NORTH WHITEHALL TWR. PA
IMUS
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<;iTF NORTH WHlTFHAI I TWP PA
MFI FV/A I
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1985 ROD consisted of 1) extending an existing water main from
Ironton to Ormrod, 2) capping the entire landfill according to
RCRA standards, 3) constructing surface water diversion and gas
venting systems, 4) conducting a predesign study to delineate
fully the source of contamination and determine sinkhole
activity, 5) constructing a ground water treatment facility
onsite, 6) pumping and treating highly contaminated ground water,
7) monitoring and sampling existing wells and surface water, and
8) conducting operation and maintenance for at least two years.
In accordance with the 1985 ROD, a number of remedial activities
have been completed. Ormrod was connected to the municipal water
system in 1986. Construction of a synthetic membrane cap,
surface water diversion, and gas venting system over the 25 acre
landfill was completed in May, 1990. Predesign studies were
conducted in 1986, 1987 and 1989 to delineate more fully the
source of ground water contamination and to determine if
collection of ground water at the source would be effective in
reducing the Site contamination.
The following additional actions were taken in conjunction with
the 1985 ROD:
Under an agreement with EPA dated October 1, 1986, AT&T
Technologies, Inc. reimbursed EPA for costs of construction
of the new water mains between Ironton and Ormrod, PA.
Under an Administrative Order By Consent, issued August 5,
1988, AT&T Technologies, Inc. agreed to provide an alternate
water supply to three locations not connected to public
water supply mains.
Under an Administrative Order By Consent, issued October 28,
1988 to Stephen D. and Lois M. Heleva, EPA obtained access
to property necessary to perform the designated remedial
response.
Under an Administrative Order By Consent, issued October 28,
1988 to Arthur J. Heleva and Mary Ann Klugh, EPA obtained
access to property necessary to perform the designated
remedial response.
Under a December 21, 1990, amendment to the Administrative
Order By Consent issued August 5, 1988, AT&T Technologies
agreed to connect the three locations being provided bottled
water to the public water supply main.
A Remedial Investigation ("RI") was conducted during 1989 and
1990 to evaluate areas of contaminated soil. Ground water
samples were also taken from soil boreholes where water was
present. High concentrations of TCE and acetone were found in
the ground water as well as 2-butanone, chloroform,
dichloroethene (DCE), and methylene chloride, all widely used
industrial solvents (see Table 1). Exposure to contaminants
would occur if the contaminated ground water were ingested or
used for showering or bathing. One or more samples of the ground
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water found the following contaminants of concern in excess of
their respective,Maximum Contaminant Levels (MCLs): TCE, vinyl
chloride, 1,1-dichloroethene, 1,1,1-trichloroethane, chloroform,
benzene, tetrachloroethene, toluene, ethylbenzene, total xylenes.
In addition, the total carcinogenic risk from consuming or
showering and bathing with this contaminated ground water is
greater than the 10~* to 10"6 risk range.
III. COMMUNITY RELATIONS HISTORY
In accordance with Sections 113(k) and 117(a) of CERCLA, 42
U.S.C. §S9613(k) and 9617, EPA issued a Proposed Remedial Action
Plan on July 19, 1991 (the "Proposed Plan"), and held a public
comment period from July 19, 1991 through September 18, 1991 for
the proposed remedial actions described in that Proposed Plan.
The Proposed Plan identified a proposed amendment to the selected
alternative in the 1985 ROD and announced the comment period.
The notice of availability of the Proposed Plan and supporting
Administrative Record was published in the Allentown Call-
Chronicle on July 19, 1991. Several potentially responsible
parties (PRPs) were notified directly of the Proposed Plan. The
opportunity for a community public meeting was offered in the
Proposed Plan and the newspaper notification, but no request for
a meeting was received from the community. Written comments
regarding the Preferred Remedy in the Proposed Plan were received
from one member of the public as well as one PRP. Responses to
significant comments can be found in the Responsiveness Summary
section located at the end of this document.
This decision document presents the amended selected remedial
action for the Heleva Landfill Site chosen in accordance with
CERCLA and, to the extent practicable, with the NCP. All
documents supporting the remedy selection decisions contained in
this ROD are included in the Administrative Record for this Site
and can be reviewed or referred to for additional information.
IV. SUMMARY OF SITE CHARACTERISTICS
The relative distribution of contaminants observed in the ground
water during the most recent sampling approximated past sampling
events, however, the concentrations found most recently tended to
be much higher. In addition, acetone, which had not been
observed in any of the ground water samples previously taken at
the Site, was found in high concentrations. In the vicinity of a
portion of the Site known as "the TCE Spill Area" very high
levels of acetone (up to 1,900,000 M<3/L) and TCE (up to
930,000 Mg/L) were found. Vinyl chloride was also detected at
high concentrations (up to 19,000 M9/L)• At the "Abandoned
Building Spill Area", acetone (up to 590,000 /ig/L), and TCE (up
to 280,000 M9/L) were detected. Vinyl chloride was detected at a
moderate level (2,200 Mg/L) northeast of the abandoned building
inside the landfill boundary.
The distribution of contamination in ground water at the Site
indicates that there are two contiguous areas exhibiting
different levels of contamination. The area of higher levels of
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HELEVA
TABLE 1
CONTAMINANTS OF CONCERN - NEARGRADIENT GROUND WATER
Compound
Vinyl Chloride
Methylene Chloride
Acetone
1, 1-Dichloroethene
1 , 1-Dichloroethane
Total
1 , 2-Dichloroethene
Chloroform
2-Butanone
1,1,1-
Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Ethylbenzene
Concentration
Range
(Mg/L)
2-19000
13-660
25-1900000
18-4400
1-1500
5-160000
19-31000
110-120000
44-19800
4-930000
4-8
17-1400
8-2800
10-4000
Average
Concentration
(ug/L)
1715
23
82724
214
67
23443
3449
8040
1006
125091
3
64
163
263
Number of
Hits/Total
Number
Samples
16/33
3/33
14/33
6/33
8/33
30/33
9/33
8/33
7/33
28/33
7/33
7/33
10/33
14/33
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contamination, which is closer to the landfill, contains DNAPLs.
DNAPLs are defined as hydrocarbon liquids which, in their pure
state, have densities greater than that of water, causing them to
sink through the water column. After sinking, water that comes
into contact with the pure chemical causes the chemical to
dissolve into the water slowly over time. Thus, the pure
chemical is a continual source of contamination. Current
scientific research suggests that if contaminants with certain
physical and chemical properties are present as free phase
liquids in the subsurface, concentrations in the ground water
will be at least a percent or more of the pure aqueous solubility
limit. -TCE, which has a solubility of 1100 ppm
(1,100,000 M9/L)» has been detected in the ground water at this
Site at levels up to ninety percent of that limit. Thus,
although actual DNAPL pools have not be located, EPA believes
that DNAPLs exist at this Site where the concentration of any
individual chlorinated hydrocarbon solvent listed in Table 1 is
equal to or greater than 1% of its pure aqueous solubility limit.
At this time, further sampling is necessary to more precisely
identify the DNAPL areas. For the purposes of this ROD
Amendment, the "neargradient" area is the area in which DNAPLs
are present. The area of lower levels of contamination, in which
DNAPLs are not present, is the "downgradient" area. The DNAPLs
present in the aquifer provide an overwhelmingly large percentage
of contaminant loading to the ground water compared to other
known source areas. These DNAPLs will continue to recontaminate
the ground water to levels which will cause excedences of MCLs or
other health based levels.
V. DESCRIPTION OF ALTERNATIVES
Construction of all of the major components of the 1985 ROD has
been completed with the exception of the components relating to
ground water extraction and treatment. For that reason, EPA
seeks to amend only the ground water portion of the selected
remedy, as described below:
1. Proposed Amendment - Containment of Neargradient Ground water,
Cleanup of Dovngradient Ground water
Estimated Capital Cost: $ 12,541,500
Estimated OUt Cost: $ 1,848,000
Estimated Present Worth: $ 40,950,000
This alternative utilizes the pumping of ground water wells to
extract contaminated water from the aquifer. Ground water wells
would be installed in the contaminated ground water plume with
two separate purposes. Because the DNAPLs in the aquifer will
continue to recontaminate the ground water to levels above MCLs
or non-zero Maximum Contaminant Level Goals (MCLGs) and those
specified in Federal and State Applicable or Relevant and
Appropriate Requirements (ARARs) as long as the DNAPL resides in
the aquifer, wells will be installed and the ground water
extracted in order to contain the highly contaminated dissolved
plume immediately in the vicinity of the DNAPLs. With this
highly contaminated plume prevented from moving away from the
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8
Site, other extraction wells will be located dovngradient of the
Site to clean the dovngradient portion of the aquifer to
background levels as required by State ARARs. As discussed in
EPA document EPA/540/4-91-002 regarding DNAPLs, there are no
technologies presently in existence capable of locating or
remediating DNAPL pools or accumulations in fractured bedrock
such as at this site. Drilling, in fact, may remobilize
stabilized masses and exacerbate the situation. Therefore, for
the area of ground water containment (neargradient), the State
ARAR for cleanup to background levels and the Federal ARAR for
cleanup to MCLs and non-zero MCLGs will be waived on the grounds
of technical infeasibility.
Appropriate treatment facilities will be constructed so that,
after treatment, ground water extracted from both the
neargradient and downgradient areas can be discharged into nearby
Coplay Creek in compliance with Federal and State ARARs.
The following ARARS apply to this proposed amendment:
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air
Act, 40 C.F.R. S50.6 and 40 C.F.R. $52.21(j).
The downgradient ground water will be cleaned to
"background" levels as required by 25 PA Code $$264.90 -
264.100, specifically 25 PA Code $$264.97(i) and (j) and
264.100(a)(9) or to Federal MCLs or non-zero MCLGs, if such
Federal standards are more stringent.
Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. $$122.41-122.50),
the Pennsylvania NPDES regulations (25 PA Code $92.31), and
the Pennsylvania Wastewater Treatment Regulations (25 PA
Code $$95.1 -95.3).
Onsite treatment will comply with RCRA regulations and
standards for owners and operators of hazardous waste
treatment, storage, and disposal facilities 40 C.F.R. $$
264.170 - 264.178(containers), $$ 264.190 - 264.200
(tanks), $$ 264.220 -264.249 (surface impoundments)
and $$264.601 - 264.603 (miscellaneous units) and will
comply with $$ 264.1032 - 264.1033 which regulate air
emissions from process vents and $$ 264.1052 - 264.1062
which regulate air emissions from equipment leaks.
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved State Implementation Plan for the
Commonwealth of Pennsylvania (Clean Air Act, 40 C.F.R. Part
52, Subpart NN, $$ 52.2020 - 52.2023, State Implementation
Plans for National Ambient Air Quality Standards).
Handling, treatment and disposal of any residual considered
a hazardous waste under 40 C.F.R. $261.3 will comply with 40
C.F.R. $$ 264.1 - 264.50 and 25 PA Code $75.264(v) which
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requirements regulate the land disposal of hazardous wastes.
Offsite transportation of contaminated materials or
treatment residuals will be done in compliance with Federal
regulations applicable to generators and transporters of
hazardous wastes (40 C.F.R. Part 262 and 40 C.F.R. Part
263) as well as with Pennsylvania regulations (25 PA Code
$75.263).
Off-gas from any air strippers used to clean the ground
water before discharge will comply with OSWER Directive
9355.0-28 which requires air pollution controls for air
strippers with certain emission rates.
2. Selected Alternative in 1985 ROD - Cleanup of Highly
Contaminated Ground water Under the Landfill/ Mo Action On
Downgradient Ground water
Estimated Capital Cost; $17127,224
Estimated Annual O&M Cost: $ 324,000
Estimated Present Worth: $3,944,000
This alternative called for drilling wells into the bottom of the
landfill to capture the highly contaminated ground water in the
unconsolidated deposits beneath the Site. These wells were to be
pumped until monitoring of wells in the surrounding area showed
that ground water contamination levels had been reduced to
between 5/ig/L and SO/ig/L for TCE and lOjig/L for vinyl chloride.
A treatment plant was to be constructed onsite to remove the
contaminants from the water before it was discharged into nearby
Coplay Creek.
Because of the highly fractured nature of the downgradient
bedrock, the complete interception or total collection of the
downgradient ground water was, at that time, judged not
practical, effective, or technically feasible.
The 1985 ROD declared the following environmental laws to be
potentially applicable or relevant to the implementation of the
original selected remedy:
- National Environmental Policy Act (NEPA)
- Clean Air Act (CAA)
- Clean Water Act (CWA)
- Safe Drinking Hater Act (SDWA)
- Resource Conservation And Recovery Act (RCRA)
- Pennsylvania Clean Streams Act
All substantive requirements of these laws were to be met by the
original selected remedy with the exception of RCRA. The 1985
ROD stated that because the capture of downgradient ground water
was judged to be not technically feasible, this portion of the
RCRA closure requirements could not be met.
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VZ. COMPARATIVE ANALYSIS OF ALTERNATIVES
The proposed amendment to the selected remedy and the original
selected remedy were evaluated under the nine evaluation criteria
described in 40 CFR Part 300.430(e)(9). These nine criteria are:
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through
treatment
Short-term effectiveness
Implementability
Cost
State acceptance
Community acceptance
Overall Protection*
If feasible, the Original Remedy would achieve a greater degree
of protectiveness for the ground water under and neargradient to
the Site as it seeks to achieve a contamination level between
5j*g/L and 50/ig/L for TCE and 10/ig/L for vinyl chloride in all
parts of the aquifer, while the Amended Remedy does not envision
the cleanup of the neargradient aquifer. The DNAPLs present in
the aquifer will, however, prevent the pumping and treatment
selected under the Original Remedy from achieving the cleanup
levels called for in the 1985 ROD within a reasonable time frame.
The Amended Remedy will achieve a greater level of protectiveness
in the downgradient ground water as it calls for cleanup of this
ground water to "background" levels and will contain the
neargradient ground water to limit potential exposure. Thus, the
Amended Remedy will provide greater overall protection of human
health and the environment.
Compliance with ARARs. Both the Original Remedy and the Amended
Remedy would meet the contaminant-specific ARARs for the
discharge of treated wastewater into Coplay Creek. The Amended
Remedy will meet contaminant specific ARARs, including the State
ARAR for cleanup to background, in the downgradient ground water,
and will waive all contaminant specific ARARs for the
neargradient ground water on the grounds of technical
infeasibility. The Original Remedy would not meet contaminant
specific ARARs in the neargradient or downgradient ground water
and does not waive these ARARs for either area. (The State ARAR
for cleanup of ground water to background was not asserted by the
Commonwealth of Pennsylvania until after the 1985 ROD had been
signed. EPA did not consider State regulations as ARARs until
1986. Therefore, this "background" standard did not become an
ARAR until the decision was made to amend the 1985 ROD.)
No location specific ARARs were identified for the site. It is
expected that action-specific ARARs (e.g., Clean Air Act
regulations and federal and state regulations for hazardous
material transport) would be met for both of the alternatives.-
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11
Long-Tara Effectiveness and Permanence.
Because of the DNAPLs, the Original Remedy would not achieve any
long-term effectiveness in the neargradient aquifer, as the
DNAPLS will continue to provide a source of contamination to the
aquifer. This is also true in the downgradient aquifer as the
Original Remedy would rely on natural attenuation to clean this
area. The continuing recontamination of the neargradient ground
water by dissolution of the DNAPLs will not allow natural
attenuation to occur.
The Amended Remedy will provide greater long-term effectiveness
as it will contain the dissolved plume in the vicinity of the
DNAPLs to the neargradient ground water, thereby allowing pumping
of the downgradient ground water to restore that portion of the
aquifer. The expected timeframe for this downgradient
restoration is 30 to 40 years.
Both the Original Remedy and the Amended Remedy would permanently
remove contaminants from the ground water, though the Amended
Remedy will remove them from the entire aquifer while the
Original Remedy would remove them only from the neargradient
portion. Thus, the Amended Remedy achieves more long term
effectiveness and permanence than the Original Remedy.
Reduction of Contaminant Toxieitv. Mobility, or Volume Through
Treatment.
The Amended Remedy will reduce the contaminant mobility by
containing the dissolved plume associated with the DNAPLs, as
well as other contamination, to the neargradient aquifer in which
the DNAPLs presently exist. In the downgradient aquifer, the
Amended Remedy will reduce the volume of contaminants by
extracting the water from the aquifer and treating it to remove
those contaminants. The Original Remedy would reduce the volume
of contaminants to a lesser extent by extracting ground water
from the neargradient aquifer and treating it to remove those
contaminants, but would not affect the contamination in the
downgradient aquifer.
Short-Term Effectiveness. Both the Original Remedy and the
Amended Remedy include some degree of treatment and, therefore,
present a potential risk of contaminant exposure to site workers,
the community, and the environment in the event of treatment
system failures. In general, the degree of risk increases with
the amount of time required to implement the remedial action.
The Amended Remedy envisions pumping the neargradient ground
water for an indefinite period of time due to the necessity of
containing the dissolved DNAPL contamination. The overall risk
is considered small as perimeter and work area air monitoring,
personal protective equipment for site workers, spill control
procedures/ process equipment checks, and other health and safety
procedures would all help to minimize risks associated with
onsite activities.
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12
Iaplemen.Mfr.il ifcY- The Original Remedy is considered no longer
implementable as, it requires cleanup of the neargradient aquifer
to a level between 5/jg/L and 50/jg/L for TCE and 10/ig/L for vinyl
chloride. Attainment of these levels in the neargradient ground
water within any reasonable time frame is not technically
feasible as the DNAPLs present will continue to recontaminate the
aquifer. The Amended Remedy can be readily implemented. Once
the dissolved plume associated with the DNAPLs is contained by
the neargradient pumping wells, the downgradient aquifer can be
restored to usability.
Coat. The estimated present worth cost of the ground water
portion of the Amended Remedy is $ 40,950,000 (see Table 2 for a
detailed cost estimate). The estimated present worth of the
ground water portion of the Original Remedy is $3,944,000.
State t"* r-nmmunitv Acceptance
No comments were received from the local community regarding the
proposed amendment. An opportunity for a public meeting was
offered, but EPA received no request for such a meeting.
Comments were received from one individual and one PRP which are
answered in the Responsiveness Summary section of this document.
At this time, the Commonwealth of Pennsylvania has not concurred
with this amendment. The Commonwealth has expressed the concern
that EPA has not presented sufficient information to support the
assertion that DNAPLs are present in the ground water at the
Site. The Commonwealth suggests that this amendment should
require cleanup of all ground water at the Site to background
levels, with contingency language that allows for future waiver
of State and Federal ARARs. EPA believes that data in the
Administrative Record provides ample evidence of the existence of
DNAPLs in the ground water at this Site and does not agree with
the Commonwealth's position.
VIZ. SELECTED REMEDY
1, Propos^fl A^epdiHent ** Conta^ **"»*** t of Nearqradient Ground Water*
Cleanup of Downqradient Ground Water
ZMTRODUCTZOM
After careful consideration of the proposed remedial alternatives
and evaluation by the nine criteria listed above, EPA has decided
to amend the Original Remedy selected in the 1985 ROD. In the
judgment of EPA, the Amended Remedy represents the best balance
among the evaluation criteria when compared to the Original
Remedy.
The 1985 ROD declared that collection of downgradient ground
water was technically infeasible due to the highly fractured
bedrock underlying the Site. This amendment to the ground water
portion of that ROD determines that, based on data collected
during the 1989 predesign study for the ground water extraction
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HELEVA
TABLE 2
COST SUMMARY FOR AMENDED GROUND WATER REMEDY
Capital Cost
Direct Costs $ 8,375,500
Indirect Costs1 $ 1,330,000
$ 9,705,500 Total Field Costs
Cash Reserve2 $ 1,455,600
Construction Mgmt $ 1,380,000
Total Construction Costs $ 12,541,500
Operation & Maintenance $ 1,848,000
Present Worth3 $ 40,950,000
1 Calculated using an industry average 70% x direct labor costs
2 15% of total labor cost
3 30 Years § discount rate = 5%
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system, collection of the dovngradient ground water is
technically feasible and will be implemented.
The 1985 ROD called for collection of the highly contaminated
ground water under the landfill until contaminant concentrations
were reduced to between 5 and 50/jg/L for TCE and lOjjg/L for vinyl
chloride. This amendment determines that reduction of
contaminant concentrations in the neargradient ground water to
those levels is not presently feasible, as the DNAPLs will
continue to recontaminate the aquifer to well above those levels
for many years. Although the area of DNAPLs can be identified
generally, there are no technologies presently in existence
capable of locating or remediating specific DNAPL pools or
accumulations in the ground water under this Site because of the
extremely heterogeneous distribution, both horizontally and
vertically, of fractures within the bedrock. Drilling, in fact,
may remobilize stabilized masses and exacerbate the situation.
At other sites, it may be possible to locate and remove DNAPLs
which have pooled on the surface of unfractured bedrock. Under
this Amendment, the purpose of the extraction of this
neargradient ground water is to contain the high concentrations
of TCE and other chemicals to an area near the landfill. The
neargradient area will encompass that portion of the
contamination plume containing levels of chlorinated hydrocarbon
solvents indicative of DNAPLs.
Because the above containment will prevent the highly
contaminated dissolved plume associated with the DNAPLs, as well
as other contamination, from migrating, EPA believes it is
possible to restore the ground water downgradient of the DNAPLs
to a usable condition. Under this Amended Remedy the ground
water downgradient of the DNAPL source will be cleaned to levels
complying with present ARARs. Under the Original Remedy this
would not be accomplished.
In summary, this Amended Remedy replaces the ground water portion
of the 1985 ROD with the following:
a) pumping of neargradient ground water to contain the
dissolved plume associated with DNAPLs to that limited
area.
b) pumping of downgradient ground water to clean that
portion of the aquifer to "background" levels.
c) treatment of all extracted ground water to levels which
will allow for discharge into nearby Coplay Creek in
compliance with the requirements of State and Federal
discharge regulations.
All other portions of the 1985 ROD remain the same.
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PERFORMANCE STANDARDS
The Amended Remedy will achieve containment of the DNAPL source
in the neargradient area to prevent further recontamination of
the downgradient ground water. The neargradient area is the area
in which ONAPLs are present. DNAPLs will be assumed to be
present in any area where the concentration in the ground water
of any individual chlorinated hydrocarbon solvent listed in
Table l is greater than 1% of its aqueous product solubility.
Extraction wells will be located so that the dissolved portion of
the DNAPL plume will be prevented from moving downgradient.
The Amended Remedy will achieve the background levels (Table 3)
for the contaminants in the downgradient ground water, which is a
relevant and appropriate requirement under the PA Hazardous Waste
Management Regulations. The Pennsylvania ARAR for hazardous
substances in ground water is that all ground water must be
remediated to "background" quality as specified by 25 PA Code SS
264.90 - 264.100, specifically 25 PA Code §5 264.97(i) and (j)
and S 264.100(a)(9). The Commonwealth of Pennsylvania also
maintains that the requirement to remediate to background is also
found in other legal authorities.
In order to remediate the downgradient ground water, the
extraction system implemented under this Amended Remedy shall
operate until ground water monitoring shows that the
concentrations of contaminants of concern have been reduced to
the "background" levels specified in Table 3. To this end,
monitoring wells shall be installed in the downgradient area and
sampled on a quarterly basis for at least 30 years. . The number
and location of these wells will be specified in the design of
the extraction system. If sampling confirms that background
levels have been attained throughout the downgradient area and
remain at the required levels for twelve consecutive quarters,
operation of the extraction system can be suspended. If,
subsequent to the extraction system shutdown, quarterly
monitoring shows the ground water concentrations of any
contaminant of concern to be above the levels specified in Table
3, the extraction system shall be restarted and continued until
the levels in Table 3 have once more been attained for twelve
consecutive quarters.
All extracted ground water will be treated to levels which will
allow for discharge into nearby Coplay Creek in compliance with
the requirements of State and Federal discharge regulations.
If implementation of the Amended Remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will not be possible to meet the remediation goals and it is thus
technically impracticable to achieve and maintain background
concentrations throughout the downgradient aquifer, then EPA, in
consultation with the Commonwealth of Pennsylvania, may amend the
ROD or issue an Explanation of Significant Differences to inform
the public of alternative ground water goals which may include,
but not be limited to, any of the following:
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HELEVA
TABLE 3
"BACKGROUND" LEVELS FOR DOWNGRADIENT GROUND WATER (/ig/L)
COMPOUND
Vinyl Chloride
Methylene Chloride
Acetone
1 , 1-Dichloroethene
1 , 1-Dichloroethane
Trans 1, 2-Dichloroethene
Cis l, 2-Dichloroethene
Chloroform
2 -But anone
1,1,1-Trichloroethane
Tr ichloroethene
Benzene
Tetrachloroethene
Toluene
Ethy Ibenzene
BACKGROUND SCENARIO1
0.18
0.25
0.50
0.13
0 . 07
0.10
0.122
0.05
0.50
0.03
0.03
0.20
0.03
0.20
0.20
1. Method 601/602 Detection Limits (40 C.F.R. Part 136)
except where noted.
2. Method 524.2 Detection Limits (40 C.F.R. Part 141).
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15
a) engineering controls such as physical barriers, or
long-term gradient control provided by low level
pumping, as containment measures;
b) chemical-specific ARARs will be waived for the cleanup
of those portions of the aquifer based on the technical
impracticability of achieving further contaminant
reduction;
c) institutional controls will be provided/maintained to
restrict access to those portions of the aquifer which
remain above remediation goals;
d) continued monitoring of specified wells; and
e) periodic reevaluation of remedial technologies for
ground water restoration.
The decision to invoke any or all of these measures may be
made by EPA in consultation with PADER, during a periodic review
of the remedial action, which occurs at least every five years,
in accordance with Section 121(c) of CERCLA, 42 U.S.C. S 9621(c).
VIII. STATUTORY DETERMINATIONS
The Amended Remedy satisfies the remedy selection requirements of
CERCLA and the NCP. This amendment will be protective of human
health and the environment, will comply with or waive ARARs,
would be cost effective, and would utilize permanent solutions
and alternative treatment technologies to the maximum extent
practicable. Because it would treat the ground water to remove
contaminants, the Amended Remedy also would meet the statutory
preference for the use of a remedy that involves treatment as a
principal element.
Protection of H"Bfln Health and the Bnviron|"6nt
The amended ground water portion of the selected remedial action
protects human health and the environment by containing the
heavily contaminated dissolved contaminant plume associated with
the DNAPLs to an area near the Site and then cleaning the
downgradient aquifer to background levels. All ground water
extracted from the aquifer will be treated and discharged to a
local stream in compliance with the substantive requirements of
State and Federal discharge regulations.
Compliance with Applicable or Relevant and Appropriate
Requirements
These standards are considered applicable to this action:
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air
Act, 40 C.F.R. S50.6 and 40 C.F.R. $52.21(j).
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Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. SS122.41-122.50),
. the Pennsylvania NPDES regulations (25 PA Code $92.31), and
the Pennsylvania Wastewater Treatment Regulations (25 PA
Code SS95.1 -95.3).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved State Implementation Plan for the
Commonwealth of Pennsylvania (Clean Air Act, 40 C.F.R. Part
52, Subpart NN, SS 52.2020 - 52.2023, State Implementation
Plans for National Ambient Air Quality Standards).
Handling, treatment or disposal of any residual considered a
hazardous waste under 40 C.F.R. S261.3 will comply with 40
C.F.R. SS 264.1 - 264.50 and 25 PA Code S75.264(v) which
requirements regulate the land disposal of hazardous wastes.
Offsite transportation of contaminated materials or
treatment residuals will be done in compliance with Federal
regulations applicable to generators and transporters of
hazardous wastes (40 C.F.R. Part 262 and 40 C.F.R. Part
263) as well as with Pennsylvania regulations (25 PA Code
S75.263).
These standards are considered relevant and appropriate to this
action:
Onsite treatment will comply with RCRA regulations and
standards for owners and operators of hazardous waste
treatment, storage, and disposal facilities 40 C.F.R. SS
264.170 - 264.178(containers), SS 264.190 - 264.200
(tanks), SS 264.220 -264.249 (surface impoundments)
and SS264.601 - 264.603 (miscellaneous units) and will
comply with SS 264.1032 - 264.1033 which regulate air
emissions from process vents and SS 264.1052 - 264.1062
which regulate air emissions from equipment leaks.
The downgradient ground water will be cleaned to
"background" levels as required by 25 PA Code SS264.90 -
264.100, specifically 25 PA Code SS264.97(i) and (j) and
264.100(a)(9).
This directive is to be considered:
Off-gas from any air strippers used to clean the ground
water before discharge will comply with OSWER Directive
9355.0-28 which requires air pollution controls for air
strippers with certain emission rates.
Cost Effectiveness.
Cost effectiveness is determined by comparing the costs of the
alternatives being considered with their overall effectiveness to
determine whether costs are proportional to the effectiveness
achieved. The estimated present worth cost of the ground water
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17
portion of the Amended Remedy is $40,950,000. This Amended
Remedy is judged to afford overall effectiveness proportional to
its cost such that the remedy represents good value for the
money. When the relationship between cost and overall
effectiveness of the Amended Remedy is compared to the cost and
overall effectiveness of the Original Remedy, the Amended Remedy
is judged the more cost effective.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maxipu"" B tent Practicable.
EPA has determined that the Amended Remedy represents the maximum
extent to which permanent solutions and alternative treatment
technologies can be utilized while providing the best balance
among the other evaluation criteria. The Amended Remedy provides
the best balance in terms of the nine evaluation criteria
Preference for Treatment as a Principal Element.
The Amended Remedy satisfies the statutory preference for
remedies that employ treatment as a principal element to
permanently reduce the volume, toxicity, or mobility of hazardous
substances. By extracting ground water from the aquifer and
removing contamination from it before it is discharged to a local
stream, the remedy addresses the primary risk posed by the Site
through the treatment.
IX. EXPLANATION OF CHANGES TO THE PREFERRED ALTERNATIVE
The estimated cost for the Amended Remedy has been revised since
publication of the Proposed Plan. This revision is based on
updated cost information developed by EPA which lowered the
capital cost estimate, and the recalculation of the 30-year
present worth using a discount rate of 5%, which better reflects
the present discount rate than the 11% used in the initial
calculation.
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Z. RESPONSIVENESS SUMMARY
This Responsiveness Summary documents significant public concerns
and comments regarding the proposed amendment to the 1985 ROD
expressed during the public comment period. The summary also
documents EPA's responses to the comments and concerns that were
received. The public comment period for the Heleva Landfill site
began on July 19, 1991, and extended to September 18, 1991. The
opportunity for a community public meeting was offered in the
Proposed Plan and the newspaper notification, but no request for
a meeting was received from the community. Written comments were
received from one individual ("Commentor 1") and one Potentially
Responsible Party ("Commentor 2"). EPA's responses to
significant comments appear below.
COMMENTOR 1
Comment; The length of the comment period did not allow enough
time to review the administrative record.
Response; EPA believes that the 30 day period specified in the
Proposed Plan provided, in this instance, an adequate opportunity
for the public to review the administrative record and comment on
the Proposed Plan. In addition, the NCP gives the public an
opportunity to request an extension of that period for another 30
days. This commentor did not request an extension. However, a
timely request for an extension was received from another party
and the comment period was extended for another 30 days. Notice
of that extension was published in the Bethlehem Globe Times on
August 20, 1991.
?QTPiTireiVt* The Proposal does not identify any specific new
information which supports the proposed changes to the ROD.
Responset The Proposed Plan specifically cites the data gathered
during the 1989-90 RI/FS as providing evidence that DNAPLs are
present in the aquifer under the Site and goes on to explain that
these DNAPLs will prevent the Original Remedy from achieving its
goals. The Proposed Plan also encourages the public to review
the Administrative Record to gain a more comprehensive
understanding of the Site and the activities conducted there.
EPA believes that, together, the Proposed Plan and the
Administrative Record provide a firm basis for the decision to
pursue a ROD amendment.
Comment! Why is there TCE in the downgradient area? Does EPA
believe it migrated from the landfill?
Response t The 1989-90 RI/FS and the numerous past ground water
investigations conducted at the Heleva Landfill Site all clearly
show that the chemical contamination in the aquifer originates at
or near the landfill and migrates downgradient from the Site.
These investigations are reproduced in the Administrative Record
which is available for public review. Furthermore, EPA has
evidence of disposal of large quantities of liquid waste
solvents, containing TCE and acetone, at the Site.
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Comment; Was the prior geological conclusion as to fractures in
subsurface water bearing strata confirmed by the subsequent RI?
Response; The 1985 ROD declared that the complete interception or
total collection of the downgradient ground water was, at that
time, not practical, effective, or technically feasible because
of the highly fractured nature of the downgradient bedrock. The
April 1990 Remedial Investigation was conducted specifically to
investigate an area of contaminated soils that was found during
the predesign studies which took place prior to construction of
the landfill cap. As part of this investigation, borings were
drilled through the unconsolidated material and each boring was
terminated when bedrock was encountered. As such, no new
information on the nature of the bedrock was developed and the
prior conclusion regarding fractures was neither confirmed nor
refuted.
C?BU?*fnt' In EPA's analysis of the short term effectiveness of the
Amended Remedy, EPA's discussion of risk minimization is not a
proper substitute for a risk analysis.
Response; EPA disagrees. The commentor is, in effect, asking EPA
to conduct a risk assessment based on assumptions regarding the
level of emissions from, frequency of spills at, and other
presently unknowable information about, a remedial action which
has not yet undergone a final design. The usefulness of the
results of such an analysis would be questionable at best. Risk
to the public from construction and operation of the Amended
Remedy will be evaluated during the design stage in order to
minimize any such risks. Based on ongoing remedial actions at
other Sites, the short term risk of implementing the Amended
Remedy is judged to be small and is so stated in the body of this
ROD.
79TW"?"? i Did EPA perform a risk analysis of exposures generated
by "pump and treat1* remedies versus static remedies? The
proposed remedy is not grounded on a proper risk analysis.
Response; In the absence of any explanation by the commentor of
the phrase "static remedies", EPA assumes that a "No Action"
alternative was meant. The "No Action" and "Pump and Treat"
alternatives were evaluated in the 1985 ROD, among others. Risk
analysis was performed as part of the RI/FS on which the 1985 ROD
was based, but addressed only the risk to public health from
consumption or other use of ground water. No analysis was
performed of risk from construction or operation of ny of the
alternatives as the usefulness of such an analysis we-Id be
questionable, at best (see above response).
C?Bfflfnti The commentor postulates the following five "intuitive"
sources for the contamination in the ground water, discusses each
in detail, and claims that a remedy can not be selected until all
of these sources have been evaluated:
1. Other TCE disposal into the soils above the
downgradient plume.
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2. Migration of dissolved TCE in ground water from unknown
areas outside the covered area.
3. Migration of TCE as nonagueous phase liquid from
unknown areas outside the covered area.
4. Migration of dissolved TCE in ground water from the
covered area.
5. Migration of TCE as nonagueous phase liquid from the
covered area.
Response; In regard to the postulated sources of contamination,
EPA has been studying this Site since its inclusion on the NPL,
and has data which was developed by the Site owner prior to that
time. EPA has no information that any disposal of TCE took place
at any location other than at the Heleva Landfill Superfund Site.
This does not mean, however, that EPA believes that all of the
TCE that has contaminated the ground water was disposed of in the
area which is now covered by the cap. As the Administrative
Record clearly shows, there is an area of disposal, marked by
grossly contaminated soils and underlying materials, that lies
mostly outside the covered area but still within the Site
boundary. Migration of DNAPLs and the associated dissolved plume
from this area was taken into account in developing the Amended
Remedy.
EPA perceives a general misunderstanding of the Amended Remedy on
the part of this commentor. As explained in this ROD Amendment,
EPA does not intend to install the containment wells at the edge
of the capped landfill area and expect to contain the DNAPLs. On
the contrary, the ground water data and other technical
information will be analyzed to determine the likely areal extent
of the DNAPLs and extraction wells will be located so as to
prevent the dissolved plume of contamination associated with
those DNAPLs from moving downgradient.
Comment; Does EPA find the cost of the preferred alternative
reasonable?
Response; EPA believes that the cost of the Amended Remedy is
reasonable. As stated in the body of this ROD Amendment, the
Amended Remedy is judged to afford overall effectiveness
proportional to its cost such that the remedy represents good
value for the money. When the relationship between cost and
overall effectiveness of the Amended Remedy is compared to the
cost and overall effectiveness of the Original Remedy, the
Amended Remedy is judged the more cost effective.
CQMMENTOR 2
CfrffllflfrTTI+'r * The Proposed Plan does not indicate whether the new goal
of containment for the neargradient ground water includes
treatment of the neargradient ground water.
Responsei Although EPA believes that the Proposed Plan's
Preferred Alternative, when read in its entirety, does indicate
that neargradient ground water will be treated, language has been
included in the body of this ROD Amendment to highlight the fact
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21
that the ground water extracted from both the neargradient and
downgradient will be treated before discharge to Coplay Creek.
C9inn?tT*'; If the goal is containment only, there is no need for
ground water withdrawal or* treatment of neargradient ground water
at all.
Response; EPA disagrees. As the commentor has provided no
rationale for this conclusion, EPA can only refer to the
Administrative Record and to the discussion in the body of this
ROD Amendment to demonstrate the need for extraction and
treatment of the neargradient ground water to contain the
dissolved contaminant plume in the vicinity of the DNAPLs.
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