United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-92/156
September 1992
dEPA Superfund
Record of Decision:
Tonolli, PA
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NOTICE
The appendices Hsted in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-92/156
3. Recipient's Accession No.
4. TWO and Subtitle
SUPERFUND RECORD OF DECISION
Tonolli, PA
First Remedial Action - Final
5. Report Date
09/30/92
7. Authoi
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EPA/ROD/R03-92/156
Tonolli, PA
First Remedial Action - Final
Abstract (Continued)
the landfill; and excess process water, battery acid, and stormwater runoff, which went
to the wastewater lagoon to be neutralized and recirculated back into the lime slurry air
scrubbers. From 1974 to 1989, the state, EPA, and Tonolli Corporation conducted various
sampling investigations that showed elevated levels of lead and other heavy metals in the
soil, air, surface water, and ground water. In 1985, Tonolli filed for bankruptcy and
abandoned the site. In 1989, EPA's Emergency Response Program completed stabilization
activities, which included pumping and onsite treatment of lagoon wastewater, pumping and
offsite disposal of wastewater in the above-ground storage tank, excavating and
stabilizing lagoon sludge, removing the lagoon liner, excavating the soil beneath the
lagoon, backfilling and grading an illegal diversion ditch and the lagoon, repairing the
perimeter fencing, and installing a mobile onsite treatment system for contaminated
surface water. In 1991, EPA issued a UAO to 46 PRPs to operate and maintain the
automated onsite water treatment plant to address the contaminated surface water that
continues to flow across the site during precipitation events. This ROD addresses a
final remedy for all the contaminated media present onsite, including battery piles,
onsite structures, soil, sediment, ground water, and surface water. The primary
contaminants of concern affecting the soil, sediment, debris, ground water, and surface
water are metals, including arsenic, cadmium, and lead.
The selected remedial action for this site includes transporting and treating offsite
approximately 13,000 cubic yards of battery wastes, including battery casings, iron
oxide, sump sediment, and dust by resource recovery at a secondary lead smelter;
conducting additional sampling and characterization of other waste pile materials
effectively via excavating and characterization of all sediment and battery fragments in
•stormwater collection piping and onsite dumps, or consolidation within the onsite
landfill; excavating and consolidating approximately 39,000 cubic yards of soil with lead
levels above 1,000 mg/kg within the onsite landfill; stabilizing onsite approximately
7,300 cubic yards of soil with lead levels over 10,000 mg/kg, with consolidation of the
treated soil into the onsite landfill; excavating soil situated in the residential area
to the immediate west of the property boundary containing greater than lead 500 mg/kg;
collecting confirmatory samples, consolidating soil into the onsite landfill, and
backfilling both onsite and offsite excavated areas with clean soil; sampling to define
the area and volume of soil potentially impacted by the site activities and requiring
remediation; consolidating and, if necessary, treating approximately 2,020 cubic yards of
treated sludge, 250 drums of melted plastic, and 210 cubic yards of excavated lagoon soil
in the onsite landfill prior to closure; conducting additional sampling and completion of
bioassays for contaminated sediment in Bear and Nesquehoning Creeks during the RD to
develop appropriate clean-up levels, and excavating all sediment above the set levels
from the creek (s) with consolidation within the onsite landfill; closing the onsite
landfill in accordance with the federally authorized state requirements for hazardous
waste, including removal of standing water from the landfill; upgrading the leachate
collection system, consolidating materials generated during the remedial action within
the landfill to meet the minimum grading requirements; application of the properly
designed layer of agricultural limestone, and covering over the landfill with a low
permeability cap; conducting a treatability study to evaluate the optimal application
rate of agricultural limestone to provide maximum pH buffering capacity to the
consolidated soil for this in-situ passive treatment method; maintaining the cap and
dewatering system, and monitoring ground water; collecting and treating approximately
(See Attached Page)
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EPA/ROD/R03-92/156
Tonolli, PA
First Remedial Action - Final
Abstract (Continued)
2 million gallons of landfill leachate decontamination fluids generated during
remediation, and approximately 16 gallons per year of contaminated stormwater using the
existing onsite treatment system, prior to onsite discharge to Nesquehoning Creek; using
monitoring data collected from the treatment system to determine appropriate discharge
levels; decontaminating onsite buildings, dismantling of nonstructural components, with
removal of equipment and debris offsite; disposing of drained nickel/iron batteries
offsite; monitoring air; implementing measures to prevent runoff of surface waters,
sediment, and/or contaminated soil or battery wastes into Nesquehoning or Bear Creeks;
evaluating underground storage tanks during remedial design, any tanks that will impede
the completion of the selected remedy (especially contaminated soil) will be addressed
during remediation; treating the contaminated overburdened ground water by constructing a
vertical chemical barrier, with possible injection of pH-adjusted water to enhance ground
water flow rates; using gradient controls to prevent infiltration of contaminants into
the bedrock aquifer; monitoring the effectiveness of the vertical chemical barrier and/or
injection of the pH adjusted fluids; and implementing institutional controls, including
deed restrictions to prevent excavation of the landfill and limit site use, and site
access restrictions. The estimated present worth cost for this remedial action is
$16,616,000, which includes an estimated annual O&M cost ranging from $35,300 to $35,600
for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil excavation levels are based on health-risk calculations and
include onsite lead 1,000 mg/kg and offsite lead 500 mg/kg. Soil will be stabilized
onsite to meet RCRA TCLP levels, such as lead 5 mg/1, prior to disposal.
Chemical-specific sediment clean-up levels will be determined during the remedial design
stage. Chemical-specific surface water and ground water clean-up levels will also be
determined during the remedial design stage and will be based on allowable NPDES
discharge parameters and state-specified background levels, respectively.
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RECORD OF DECISION
TONOLI.I CORPORATION SUPERFUND SITE
DECLARATION
SITE NAME AND LOCATION
Tonolli Corporation Superfund Site
Nesquehoning Borough/ Carbon County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Tonolli Corporation Superfund Site ("the Site"), located in
Nesquehoning Borough, Carbon County, Pennsylvania. The remedial
action was developed in accordance with the Comprehensive En-
vironmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthori-
zation Act of 1986 (SARA), and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based on the Administrative Record for
this Site.
The Commonwealth of Pennsylvania has not concurred on this
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, if
not addressed by implementing the response action selected in
this Record of Decision (ROD), may present an imminent and
substantial endangerment to the public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action selected for the Site is a final remedy, and
will address all sources of contamination present in soils,
battery wastes, the onsite landfill and surface water so that the
Site can be used in an industrial manner. This action will
restore the ground water to its beneficial use by cleaning the
overburden aquifer to background levels and preventing migration
of contaminants to the bedrock aquifer by using gradient
controls.
The selected remedy includes the following major components:
1) Offsite transport and treatment of approximately 13,000
cubic yards of battery wastes, including battery casings,
iron oxide, sump sediments, and dust by resource recovery at
a secondary lead smelter. Additional sampling and
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characterization of other waste pile materials (i.e.,
crusher building dusts) will, be conducted to confirm whether
these materials can also be treated effectively via this
process. Similarly, excavation of all sediments and battery
fragments in stonnwater collection piping and onsite sumps
will be completed, and these materials will be characterized
to determine whether they can be processed via resource
recovery or consolidated within the onsite landfill.
2) Excavation of all soils with lead contamination above
1,000 mg/kg (approximately 39,000 cubic yards), and backfill
and grading for excavated onsite areas. Consolidation of
all soils with lead contamination ranging from 1,000 mg/kg
to 10,000 mg/kg within the onsite landfill. Onsite
stabilization of all soils posing a principal threat with
lead contamination above 10,000 mg/kg (approximately 7,300
cubic yards), and consolidation of treated soils into the
onsite landfill. Excavation of soils situated in the
residential area to the immediate west of the property
boundary containing greater than 500 mg/kg lead, collection
of confirmatory samples, and consolidation of soils into the
onsite landfill, and backfilling of the area with clean
soil. Additional sampling will be completed prior to
excavation to define the area and volume of soils
potentially impacted by the Site activities and requiring
remediation.
3) Consolidation and, if necessary, treatment of
approximately 2,020 cubic yards of treated sludges,
approximately 250 drums of melted plastic, and approximately
210 cubic yards of excavated lagoon soils into the onsite
landfill prior to closure. Additional sampling will
determine whether the lagoon soils and drums can be
consolidated in the onsite landfill.
4) Additional sampling and completion of bioassays for
contaminated sediments in Bear and Nesquehoning Creeks will
be completed during the remedial design phase to develop
appropriate cleanup levels for this medium. Once an
appropriate cleanup level for sediments has been approved by
EPA in consultation with PADER, all sediments above the
approved cleanup level will be excavated from the creek(s)
and consolidated within the onsite landfill.
5) Closure of the onsite landfill in accordance with the
federally authorized Pennsylvania requirements for hazardous
waste, including: removal of standing water from the
landfill, upgrade of the leachate collection system,
consolidation of materials generated during the remedial
action within the landfill to meet the minimum grading
requirements, application of a properly designed layer of
agricultural limestone, and cover of the landfill with a cap
having a permeability of less than IxlO"7 cm/sec. The
addition of a layer of crushed or pulverized limestone shall
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be designed to prevent potential future leaching of lead
from the consolidated soils to the onsite landfill. A
treatability study will be completed to evaluate the optimal
application rate of agricultural limestone to provide the
maximum pH buffering capacity to the consolidated soils for
this in-situ passive treatment method. Post-closure care of
the landfill will include maintenance of the cap and
dewatering system, and construction and routine sampling of
a ground water monitoring network for a 30-year period.
6) Approximately 2 million gallons of landfill leachate
(standing water), decontamination fluids generated during
remediation, and approximately 16 million gallons per year
of contaminated stormwater will be collected and treated
using the existing onsite treatment system prior to
discharge to Nesguehoning Creek. Monitoring data collected
from the treatment system will be used by EPA in
consultation with the State to determine appropriate
discharge levels in compliance with the substantive
requirements of the NPDES program.
7) Treatment of contaminated overburden ground water by
construction of a vertical chemical barrier (i.e., limestone
trench) with possible injection of pH adjusted water to
enhance ground water flow rates. Gradient controls will be
used to prevent infiltration of contaminants into the
bedrock aquifer. Monitoring of the effectiveness of the
vertical chemical barrier and/or injection of pH adjusted
fluids, and monitoring of the bedrock aquifer beneath the
Site will be completed.
8) Decontamination of Site buildings by either vacuuming or
washing, including dismantling of non-structural components
and removal of equipment and debris that may inhibit
thorough decontamination.
9) Offsite disposal of drained nickel/iron batteries.
10) Maintenance of Site fence and Site security, as needed,
to limit trespassing and access to the Site during
construction.
11) Air monitoring during onsite activity.
12) During the course of the remedial action, and the
excavation and construction phase, measures will be taken to
prevent runoff of surface waters, sediments, and/or
contaminated soils or battery wastes from entering
Nesquehoning or Bear Creeks.
13) Evaluation of the onsite underground storage tanks will
be completed during remedial design. Any tanks that may
impede the completion of the selected remedy, specifically
the excavation of contaminated soils, will be addressed
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during remediation.
14} Institutional controls, in the form of deed restrictions
will be placed on the deeds to the parcel (s) that comprise
the onsite landfill to limit the use of this land and
prevent excavation or construction on the capped and closed
landfill. Additional deed restrictions will be implemented
to limit the use of the Site to industrial use only.
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) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review by EPA will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
ErŁckson Date
Administrator
* Region III
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RECORD OF DECISION
TONOLLI CORPORATION BUPERFUND SITE
TABLE OF CONTENTS
Page
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
III. SCOPE AND ROLE OF RESPONSE ACTION 6
IV. SUMMARY OF SITE CHARACTERISTICS 8
V. CONTAMINANT FATE AND TRANSPORT 16
VI. SUMMARY OF SITE RISKS 19
VII. SUMMARY OF REMEDIAL ALTERNATIVES 41
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES 56
IX. SELECTED REMEDY 63
X. STATUTORY DETERMINATIONS . . 72
ZI. EXPLANATION OF SIGNIFICANT CHANGES 77
XII. RESPONSIVENESS SUMMARY 80
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THE DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
The Tonolli Corporation Site (Site) is located in the Green
Acres-West Industrial Park on the north side of State Route 54 in
Nesquehoning Borough, Carbon County, Pennsylvania. The Site
covers approximately 30 acres, and is situated three miles west
of the Borough's business district and approximately 25 miles
northwest of Allentown, Pennsylvania (Figure 1).
The Site is situated within the Nesquehoning stream valley
bounded by Broad Mountain to the north and Nesquehoning Mountain
to the south. The Site is bordered by Nesquehoning Creek which
flows west to east approximately 50 feet south of the Site, and
Bear Creek which flows south from a reservoir along the western
boundary of the Site. The topography surrounding the Site is
mixed mountain/valley terrain with much of the area consisting of
mine spoil and coal refuse.
Major communities within a three-mile radius of the Site, in
addition to Nesquehoning, include three communities south of
Nesquehoning Mountain: Summit Hill Borough, Lansford Borough, and
Coaldale. Smaller communities within one mile of the Site
include Hauto, the Lake Hauto development, and Hauto Valley
Estates. Approximately 17,000 people live within the three-mile
radius of the Site, including 20 residences which are located
within one-quarter mile of the facility.
The Site consisted of a battery receiving and storage area,
battery crushing operation, smelter, refinery, wastewater
treatment plant, an above-ground 500,000 gallon wastewater
storage tank, a 500,000 gallon butyl rubber-lined waste lagoon,
and a 10-acre butyl rubber-lined solid waste landfill. Existing
Site structures include a battery crushing building, a refinery
building, air treatment units, a wastewater treatment plant, an
above-ground 500,000 gallon storage tank, and a 10-acre landfill.
The Site is protected with an eight foot high security fence with
three locked gates.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. BACKGROUND
The Tonolli Corporation ("Tonolli") operated a battery recycling
and secondary lead smelting plant at the Site from August 1974
until operations terminated in January 1986. The operation at
the Site included the storage, breaking, processing and smelting
of used batteries, battery components, and other lead-bearing
materials.
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FIGURE 1
SITE LOCATION MAP
A TAMAOUA QUADS
TONOLLI CORPORATION SITE
NESQUEHONING, CARBON COUNTY, PA
*0 ltd MMMTK MOBTM
on »T OJTTM or
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Spent batteries were brought in to the Site by truck, weighed,
and driven to an outdoor paved receiving area. In this area, the
batteries were broken, then piled on both sides of the receiving
area to allow the acid to drain into a sump. The acid flowed
from the sump through underground piping to a treatment plant for
neutralization. Broken batteries were transferred to the hopper
of a hammer-mill crusher, and the resulting crushed pieces were
moved by conveyer belt to a rotary breaking/drying drum which
separated the battery pieces using water. The metal and plastics
were separated from the rubber-based Bakelite casing materials by
flotation. Lead materials were conveyed to a storage/mixing
room, plastic was transported by truck to an onsite plastics
storage pile, and the bakelite (hard rubber) was transferred to
the onsite landfill.
The solid and aqueous byproducts generated during operations at
the Site consisted of four primary streams: 1) slag from the
secondary lead smelting process; 2) calcium sulfate sludge from
air pollution control scrubbers; 3) plastic battery casings and
bakelite chips; and, 4) excess process water, battery acid, and
stormwater runoff. Spent lead acid batteries and other lead
containing materials that were recycled through the furnaces to
recover the lead resulted in the production of slag. The slag
was cooled and disposed of in the onsite landfill. Calcium
sulfate sludge generated from the scrubber system was pumped to
the landfill through an above-ground pipe system. Excess process
water, battery acid and rainwater that passed through the plant
area were directed by underground piping to the settling tank and
wastewater lagoon. The water was neutralized and then
recirculated back into the lime slurry air scrubbers.
During periods of high precipitation, the lagoon was incapable of
holding the runoff, and thus the excess water was pumped to the
landfill for temporary storage. When the level in the lagoon was
sufficiently reduced, the water was pumped back through the
treatment system. In 1985, a 500,000-gallon tank was constructed
to handle the lagoon overflow. In addition, the Tonolli
Corporation excavated a trench adjacent to the wastewater lagoon
to assist in alleviating the overflow of the lagoon. The trench
was connected to a drainage ditch that allowed the lagoon
overflow to discharge directly to Nesguehoning Creek.
In late 1979 and early. 1980, Tonolli became subject to the
requirements of the Resource Conservation and Recovery Act
("RCRA"), 42 U.S.C. Section 6901, et sea. On August 7, 1980,
pursuant to Section 3010 of RCRA, the Tonolli Corporation
notified EPA of hazardous waste activity at the Site. On
November 18, 1980 Tonolli submitted a RCRA Part A ("Part A")
application to EPA indicating the types and characteristics of
the hazardous wastes generated and otherwise handled on the Site,
and qualified for interim status under Sections 3004 and 3005 of
RCRA. In 1985 Tonolli Corporation amended its Part A to include
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sludges, crushed battery casings, and storage of corrosive and
heavy metal-bearing wastes in an above-ground storage tank. The
hazardous wastes handled on the Site included emission control
dusts (KO69), solids and liquid wastes containing arsenic (DOO4),
cadmium (DOO6), chromium (DO07), and lead (DOO8).
A number of sampling programs were conducted at the Site under
the supervision of Tonolli Corporation, EPA Region III, and/or
PADER between 1974 and 1989. Soil samples collected by PADER in
1982 and EPA in 1984 showed elevated levels of lead and cadmium
in several onsite areas. Additional samples collected by EPA
between 1987 and 1989 showed elevated levels of arsenic, cadmium,
chromium, copper and lead in onsite soils near waste disposal
areas. Surface water sampling completed between 1983 and 1989
for both onsite areas and the Nesquehoning Creek showed elevated
levels of arsenic, cadmium, and lead. Groundwater sampling
activities completed between 1976 and 1989 showed elevated levels
of arsenic, cadmium, copper and lead in onsite monitoring wells.
Air sampling completed by Tonolli from 1974 until 1985 showed
that the National Ambient Air Quality Standard for lead was
exceeded on several occasions during this time frame.
After Tonolli filed for bankruptcy in late 1985 and thereafter
abandoned the Site, PADER inspected the Site, and found that an
illegal diversion ditch had been created to allow direct
discharge of contaminated surface water runoff to Nesquehoning
Creek in order to prevent an overflow of the onsite waste lagoon.
PADER issued a Noto.ce of Violation to Tonolli and assessed a
civil penalty. PADER continued to monitor the Site conditions,
and in late 1986 requested EPA to consider taking interim
response actions to address the contaminants and waste disposal
areas remaining at the facility.
B. REMOVAL ACTION
Between February and August of 1987, EPA completed three Site
assessment and samp-ling activities. High concentrations of lead,
cadmium, chromium, arsenic and copper were detected in both on
and offsite soils, groundwater and surface water. Samples from
the Nesquehoning Creek showed increased levels of heavy metals
and sulphates, and decreased pH in downstream areas. The
500,000-gallon storage tank was found to contain extremely acidic
wastewater with arsenic, cadmium, and lead. In addition, a break
in the Site's perimeter fence was found, thus allowing access to
contaminated onsite areas.
EPA's Emergency Response Program completed stabilization
activities at the Site between May and December 1989. The scope
of work included the pumping and onsite treatment of lagoon
wastewater, pumping and offsite disposal of wastewaters in the
above-ground storage tank, excavation and stabilization of lagoon
sludges, removal of the lagoon liner, excavation of soils beneath
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the lagoon, backfill and grading of the lagoon and illegal
diversion ditch, and repair of the Site's perimeter fence. A
mobile onsite treatment system was installed to provide treatment
and filtration of heavy metal-contaminated surface water that
continues to flow across the Site after rain events. In
addition, Site security was provided through contracting with a
local guard service.
C. INCLUSION ON THE NATIONAL PRIORITIES LIST
The Tonolli Site was scored using the Hazard Ranking System (HRS)
in 1987 by EPA. The Site was..given an HRS score of 46.58, based
on pathway scores for groundwater, surface water and air. The
Site was proposed for inclusion on the National Priorities List
(NPL) in June of 1988, and was promulgated on the NPL on October
4, 1989.
D. HISTORY OF CERCLA ENFORCEMENT ACTIVITIES
Between 1987 and 1988, EPA identified and notified several
hundred potentially responsible parties ("PRPs") for the Site
conditions. Based upon review of Tonolli's documentation of the
pounds of scrap batteries generated and transported to the Site
for processing and/or disposal, and responses to requests for
information from several companies who sent scrap batteries to
the Site, EPA developed a list of 391 PRPs. Following the
proposal of the Site on the NPL, EPA issued General Notice
letters to the PRPs in August 1988, requesting them to conduct or
fund a Removal Action and/or Remedial activities. On September
19, 1989, 46 PRPs entered into an Administrative Consent Order
with EPA for the conduct of a Remedial Investigation and
Feasibility Study ("RI/FS").
On December 17, 1991, EPA issued a Unilateral Administrative
Order for Removal Action pursuant to Section 106(a) of CERCLA, 42
U.S.C. Section 9606(a), to the 46 PRPs who performed the RI/FS
for the Site. This Order required the PRPs to operate and
maintain an automated onsite water treatment plant to address the
contaminated surface water that continues to flow across the Site
during precipitation events.
EPA continued to develop information on the PRPs associated with
the Site, and the documents collected from Tonolli's offices
during the course of the RI/FS. Upon identifying additional
parties who generated, transported and/or arranged for the
treatment or disposal of scrap batteries, EPA continued to issue
General Notice letters and encourage PRP participation in the
response actions. As a result of this work, a total of 528 PRPs
were identified for the Tonolli Site.
Using the documents collected from the Tonolli Site offices, EPA
developed a Waste-In List or Volumetric Ranking Summary which
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specified the volume of waste contributed to the Tonolli Site by
individual PRPs. EPA developed this list as a settlement tool to
identify those PRPs who would qualify as de mininis parties under
CERCLA Section 122(g). Between January and August of 1992, EPA
completed activities associated with an early de minimis waste
contributor settlement, as authorized under Section 122(g) of
CERCLA. In July 1992, a de minimis settlement was reached
between EPA Region III and 170 Tonolli Site PRPs. This
settlement is embodied in an Administrative Consent Order,
pursuant to which the settling PRPs agreed to pay approximately
$3,491,233 toward EPA's past response costs incurred at the Site,
and the future costs associated with the required remedial
action.
E. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The public participation requirements of Sections 113(k)(2)(B)
(i-v) and 117 of CERCLA have been met in this remedy selection
process. A newspaper advertisement was published in the Times
News. Lehighton, Pennsylvania, on Saturday, July 18, 1992. It
specified the availability of the Proposed Remedial Action Plan
(PRAP), the duration of the public comment period, and the
location of the Administrative Record file.
The public comment period began on July 18, 1992, and was
scheduled to end on August 18, 1992. EPA received a timely
request for an extension of the comment period, and thus granted
the minimum 30-day extension, in accordance with the provisions
of the NCP. A newspaper advertisement was published in the Times
News. Lehighton, Pennsylvania, on August 17, 1992, notifying the
public of the extension of the comment period to September 18,
1992.
A public meeting was conducted on July 28, 1992, at the
Nesquehoning Borough Recreation Center. Approximately 40 people
attended, including former Tonolli employees, residents from the
Site area, members of the Borough Council, representatives of the
local water authority, and staff from EPA Region III and PADER.
III. SCOPE AMD ROLE OF RESPONSE ACTION
This Record of Decision (ROD) selects a Remedial Action for all
contaminated media present at and around the Site, including the
battery waste piles, contaminated surface and subsurface soils
and sediments, ohsite buildings and structures, the onsite
landfill, and contaminated surface water and groundwater. This
action will address all sources of contamination present at the
Site, as well as all areas that are or may be impacted by the
contamination. Principal threats and lower level threats posed
by the Site conditions will be addressed by the remedial action
selected in this ROD.
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The primary objectives of the remedy are to prevent exposure to
the battery waste piles, contaminated soils and groundwater, to
minimize the migration of contamination from the Site via wind
and surface water transport, to reduce contamination in the
shallow alluvial aguifer, and to protect the bedrock aguifer from
migration of contaminants through the subsurface. The remedy
selected by EPA is consistent with the removal action implemented
at the Site in 1989.
Lead poses the greatest threat at the Site. EPA is adopting a
cleanup level for lead in onsite soils of 1000 mg/kg. Under this
cleanup level, the future use of the Site will be restricted to
industrial use, for which it is currently zoned. Present EPA
policy is to use a range of 500 - 1000 mg/kg in residential areas
to protect the health of young children, as supported by the
Integrated Uptake/Biokinetic Model. There are currently no
recognized methods for evaluating lead exposure in adults.
Without such a method, the criterion for a soil lead level that
will be protective of adults who work, but do not live, on an
industrial site has not been established. EPA has, therefore
used best available information to choose 1000 mg/kg, the upper
bound of the "residential" range, as a reasonable cleanup level
to protect the health of adult onsite workers.
EPA believes and expects that a cleanup level of 1000 mg/kg would
ensure that the average soil lead level remaining onsite would be
lower than 1000 mg/kg, and thus would not impact the environment,
e.g., leach to the groundwater. The RI/FS data shows that
elevated levels of lead in groundwater were only detected in
monitoring wells situated downgradient from the major process
areas (battery breaking, storage, smelting) at the Site. EPA
believes that this lead was introduced into the groundwater
through its dissolution in the low pH conditions associated with
battery acid and stormwater containing battery acid. Elevated
levels of lead were not detected in groundwater in Site soils
contaminated with lead, and that were upgradient of the major
process areas. This data indicates that lead levels in soil, far
greater than the 1000 ppm cleanup level, have not impacted
groundwater in most of the Site area. Based on this data, EPA
believes that the soil cleanup level of 1000 ppm for lead will be
protective of groundwater.
Specific objectives for the cleanup of the Site are to:
l. Prevent exposure (inhalation, ingestion) to onsite waste
piles (byproduct materials, dust, contaminated buildings)
and soils having a lead concentration greater than 1,000
mg/kg.
2. Prevent direct contact with battery casing piles and
sump sediments having lead concentrations greater than
1,000 mg/kg.
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3. Prevent direct contact with landfill contents and reduce
the potential for leachate leakage.
4. Prevent exposure of residents to soils situated to
the immediate west of the Tonolli property boundary having
a lead concentration greater than 500 mg/kg.
5. Reduce concentrations of contaminants present in the
overburden aquifer to background levels and prevent the
migration of contaminants to the bedrock aquifer.
6. Prevent migration of contaminated stormwater to offsite
areas, specifically Nesquehoning Creek, in excess of dis-
charge limits established under the NPDES program.
7. Prevent migration of contaminants that would result in
sediment contamination in excess of cleanup levels for lead,
arsenic, and cadmium, copper and zinc. Appropriate cleanup
levels must be determined by the conduct of sediment bio-
assays.
8. Prevent exposure to surface water, groundwater, runoff
and leachate containing Site contaminants above health-
based levels.
IV. SUMMARY OF SITE CHARACTERISTICS
A. BACKGROUND
The Tonolli Site is situated in a sparsely populated area, with
approximately 20 residences located within one-quarter mile of
the Site. Prior to Tonolli's activities, the Site area was used
for disposal of coal mine spoil and ash from a coal-fired power
plant that was situated approximately l.l miles west of the Site.
The Site area is zoned for industrial use, and is part of the
Green Acres Industrial Park West. Other industries in the Site
area include a company that manufactures residential house
siding, a coal company and its stockpiles, and a company that
blends plastics.
Within three miles of the Site the land use is mostly rural
undeveloped, with pockets of low-density residential and
industrial development. Much of the area is forested, with one
reservoir (Lake Hauto) located about one mile upstream on
Nesquehoning Creek, and a second reservoir located a similar
distance upstream on Bear Creek. There are no significant
agricultural lands in the Site vicinity, and according to the
Pennsylvania Game Commission there are no state gamelands,
wildlife refuges, wilderness areas, state parks, or state
recreational areas in the Site vicinity. Lake Hauto is used for
recreational fishing and boating.
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Dominant surface features in the Tonolli Site area include the
large quantities of mine spoil that are piled en the land
surface. The mine spoil includes coal refuse, mine spoil
overburden and ash, and is located on the south, north and east
sides of the Site property line. These piles are also locally
referred to as culm banks. The area in which the Site was
constructed was covered by mine spoil prior to the construction
of the Tonolli facility. This mine spoil is reportedly from the
Bethlehem Mines Site, Greenwood Colliery, and was brought into
the Nesquehoning Valley between 1920 and 1940 for cleaning
through a valley floor railway tunnel near Hauto.
The majority of the Site property is flat, sloping from the
northwest corner to the southeast corner in the area of the old
lagoon. Most of the ground surrounding the Site buildings is
covered with asphalt. One large pile of battery casings remains
in the northern area of the Site, and smaller piles remain in the
battery dumping and storage area. The eastern portion of the
Site is dominated by the existing landfill, which contains a
large portion of the byproducts generated during Tonolli's
operation. In addition, a large depression exists to the north
of the landfill where mine spoil appears to have been excavated
to begin construction of a new landfill cell at the Site. This
area and the truck garage area are the only parcels of the
Tonolli Site that are not enclosed by the fence.
The field work for the Remedial Investigation/Feasibility Study
(RI/FS) was completed in two major phases between July 1990 and
August 1991. Figiire 2 illustrates the general layout of the
Site, and the approximate onsite sampling locations for the
RI/FS. The initial; phase of activity included the sampling of
surface and subsurface soils, battery waste piles, surface water
and sediments, landfill materials (solids and aqueous),
installation and sampling of twenty monitoring wells, aquifer
testing and borehole geophysics, air sampling and meteorological
monitoring, a survey of the Site buildings, drainage structures,
and underground storage tanks, and an ecological characterization
of surface water, wetland, and terrestrial habitats. The second
phase of sampling work was primarily a confirmatory resampling of
groundwater, surface water and sediments, and also included
additional soil sampling (of fsite). In addition to this work,
limited sampling was completed between March and May 1992 to
address concerns regarding offsite soil lead levels and the
potential for groundwater contamination migration to the bedrock
aquifer beneath the Site.
The results of the RI/FS show that lead is the most abundant,
widespread, and concentrated contaminant present on the Site.
Arsenic, cadmium, copper and zinc were also identified as
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contaminants of concern in the various media present onsite. Low
concentrations of other metals and organic contaminants were also
sporadically detected in soils and other media, but these
contaminants are relatively minor and do not pose significant
risk to public health or the environment. Based on the RI/FS
sampling, the principal threats posed by the Site are: l)the
battery casings and piles of dusts and sludges remaining from
Tonolli's operation; 2) the lead contaminated sediments in the
onsite drainage network and in Nesquehoning Creek; and, 3) the
lead contaminated solids and standing water in the onsite
landfill. Lower level threats posed by the Site include the
overburden groundwater contaminated with arsenic, lead, and
cadmium, and the contaminated soils that are present in limited
portions of the Site.
B. MATURE AND EXTENT OF CONTAMINATION
Waste Piles. Byproducts, and Sump Sediments
Several types of battery wastes from Tonolli's operation and
byproducts resulting from EPA's Removal activities are present in
various areas of the Site. The sediments present in the onsite
drainage network are also included in this category due to their
high lead concentration. The waste pile and byproduct materials
include approximately 13,000 cubic yards of battery casings,
2,020 cubic yards of treated sludges, 243 cubic yards of dust
piled in the crusher and smelter buildings, 210 cubic yards of
excavated lagoon soils, and 250 drums of melted plastic remaining
from Tonolli's recycling activities. All waste pile materials
except the melted plastic were found to contain lead ranging from
6,930 parts per million (ppm) to 317,000 ppm.
Soils
The entire area of the Tonolli Site has been contaminated with
lead at concentrations ranging from background levels to 95,200
ppm. Background levels for soils on and around the Site ranged
from 152 ppm to 433 ppm lead. Impacted soils appear to be
limited to the unpaved areas of the Site, and the elevated
concentrations appear to be generally limited to the top three
feet of soil. Along portions of the onsite drainage ditches, and
in two locations to the north/northeast of the refinery building,
the lead impacts extend to a depth of five to ten feet.
Approximately 39,000 cubic yards of soils contaminated with lead
above a concentration of 1,000 ppm will require remediation.
An area of soils to the immediate west of the Tonolli property
boundary appears to contain lead at elevated levels. This area
is situated adjacent to the main entrance and receiving area for
the truck traffic associated with Tonolli's operation. The RI
data showed that this area of the Site contains high levels of
11
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lead in soils. It is probable that, due to the heavy traffic
associated with the delivery of scrap batteries to the Site,
contaminants may have been transported via wind dispersion to the
residential area near the Tonolli property entrance.
Meteorological data collected during the RI support this
potential pathway by showing that wind patterns in the Site area
include a westerly component. Two residential dwellings are
situated on this property to the west of the Tonolli property
entrance. The sampling data collected from this area shows that
the lead concentrations in surface soils range from 25 ppm to
4,410 ppm. This area will require additional sampling prior to
remediation.
Surface Water and Sediment
Portions of Nesguehoning Creek and Bear Creek have elevated
levels of lead present in creek water and sediments. Lead
concentrations in surface water exceeded the Ambient Water
Quality Criteria (AWQC) at the southwest corner of the Site in
Bear Creek, and along the southern border of the Site in
Nesguehoning Creek. Impacted sediments appear to be limited to a
small portion of Bear Creek where an outfall (underground pipe)
leads from the Site to the creek, and an area of Nesquehoning
Creek that is situated downgradient from the Site along the
southern property boundary. The primary mechanism of impact is
apparently stormwater runoff from contaminated soils. Levels of
lead (average 600 ppm) and arsenic (average 34 ppm) increased in
sediments adjacent to the Site as compared to upstream samples.
Copper levels increased from upstream to downstream areas (12.3
ppm to 33.3 ppm on average). An appropriate cleanup level for
contaminated sediments must be determined through the completion
of additional sampling and bioassays prior to remediation.
Approximately 16.3 million gallons of contaminated stormwater is
generated each year as rainfall flows across the Site. This
water is collected in the onsite drainage network, and then
stored and treated using the onsite treatment system which
includes a combination of bag filters, sand filters and an ion
exchange resin.
Approximately 2 million gallons of standing water are present
within the onsite rubber-lined landfill. This water contains
elevated concentrations of lead, and will require remediation
prior to closure of the landfill.
Landfill
The onsite landfill covers approximately 10 acres along the
eastern boundary of the Site. The landfill was an interim status
landfill under the RCRA regulations during Tonolli's operation at
the Site. The landfill is lined with a l/16th inch butyl rubber
flexible membrane liner, and is presently holding approximately
12
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105,000 cubic yards of solid and hazardous waste, and 2 million
gallons of standing water. The landfill liner appears to be
functioning as an effective barrier against any leaching of the
landfill contents into the subsurface. The landfill is
topographically isolated (i.e., situated at a higher elevation)
from the remainder of the Site, does not receive runoff from the
Site, and contains a non-homogeneous mixture of rubber and
plastic battery casing chips, calcium sulfate sludge, and slag
from the onsite smelting operations. The range of lead
concentrations present in the solid materials within the landfill
is from 11,200 ppm to 68,300 ppm. The landfill materials also
contain levels of arsenic, cadmium, copper, and zinc that are
elevated with respect to background. The pH of the water sampled
within the landfill ranges from 9.78 to 11.09.
Groundwater
OVERBURDEN AQUIFER
The aquifer of concern regarding the Tonolli Site is found in the
alluvium and mine spoil material. Groundwater in this aquifer is
derived solely from the infiltration of precipitation and
recharge from the underlying bedrock aquifer. The Tonolli
facility was constructed on a layer of mine spoils ranging in
thickness from 0 to 19 feet. A Quaternary alluvium, ranging in
thickness from 74 to 113 feet directly underlies the mine spoil
layer. The surficial water table aquifer is present in the
alluvial deposit and mine spoil materials beneath the Site.
Water level measurements from onsite monitoring wells indicate
that the horizontal flow direction of the shallow groundwater is
southeast across the Site toward Nesquehoning Creek. The
vertical groundwater flow in the overburden aquifer is downward
in the northern portion of the Site and upwards (discharging to
the Creek) in the southern portion of the Site.
Several dissolved metals were detected in the Site monitoring
wells in concentrations above background levels. These metals
include lead, arsenic, cadmium, copper, and zinc, which are
typical components of batteries and battery wastes. Prior to
Tonolli's lead smelting operation, the Site and surrounding area
were used for disposal and stockpiling of mine spoils and fly
ash. At present, the Site is surrounded by approximately 2.8
million cubic yards of mine spoils and fly ash from the previous
uses of the Site property. The presence of mine spoils under
and around the Site is a potential contributing anthropogenic
source of groundwater quality degradation in the area. The
presence of elevated concentrations of dissolved metals from both
waste sources and anthropogenic sources can be attributed to the
dumping of battery acid from the Site operations combined with
the "acid-mine drainage" effects of mine spoils. These impacts
have reduced the groundwater pH in most of the onsite areas, and
thus allowed for the increased dissolution of these metals.
13
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Lead, cadmium and arsenic were the contaminants detected in
elevated concentrations in filtered groundwater samples collected
from Site monitoring wells constructed within the overburden
aquifer. Dissolved lead was detected in six monitoring wells
sampled during the RI in concentrations ranging between 6.7 ppb
and 328 ppb. Cadmium was detected in the same six monitoring
wells in concentrations ranging between 2.8 ppb and 77 ppb.
Arsenic was also detected in concentrations ranging between 17
ppb and 313 ppb. The groundwater impacts observed within the
overburden aquifer (Wells 11, 12, 13, 14, and 16) appear to be
limited to the central portion of the Site, adjacent to or
downgradient from the previous battery processing and waste
disposal areas.
BEDROCK AQUIFER
The bedrock aquifer system underlying the Tonolli Site is found
in the Mauch Chunk formation. This aquifer is a current and
potential source of drinking water. The Lansford Coaldale Water
Authority supplies drinking water from the bedrock aquifer to
approximately 20,000 users in the area. The direction of
groundwater flow in the bedrock aquifer is generally to the east.
Groundwater in the bedrock aquifer is stored and transmitted via
intergranular voids and fractures. The number and degree of
interconnection of these voids and fractures dictates the volume
and maximum flow rate of available groundwater. Fracturing in
the Mauch Chunk occurs both as bedding plane fractures and as a
series of fracture orientations perpendicular to bedding.
Based on a survey completed during the RI, several wells drilled
into the Mauch Chunk formation, or bedrock aquifer, were found to
be under confined or semiconfined conditions. The evaluation of
groundwater flow patterns in the onsite monitoring wells
confirmed the presence of confined to semiconfined conditions in
the bedrock aquifer underlying the Tonolli Site.
Sampling and well construction activities completed during the
RI/FS at Tonolli primarily focused on the overburden aquifer as
the water-bearing zone of concern for the Site. In general, the
results of the sampling and testing show that Site contaminants
(lead, arsenic, cadmium) followed the most likely migration
pathway of infiltration to groundwater, and are present within
the alluvial material which underlies the Site. At one location
where groundwater was sampled at the overburden bedrock interface
(Well 12D), lead, cadmium, and copper were detected at elevated
levels. A deep bedrock well (12B) was constructed and sampled at
this same location. A very distinct difference was seen in the
overall water chemistry (pH, specific conductance, TDS, sulfates)
of the two wells, showing that the Site-related impacts appear to
be confined to the overburden aquifer.
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SEEPS
Ten seeps of various flow rates were observed along the northern
bank of Nesquehoning Creek during the RI. The seeps occurred in
areas directly downgradient from the major operations areas at
the Site, and also emanate from the large mine spoil pile
situated along the eastern boundary of the Site. The seeps
correspond in elevation to the contact between the alluvium and
mine spoil which underlie the Site. This interface appears to
serve as a migration pathway for horizontal movement of shallow
groundwater, and provides additional base flow to the
Nesquehoning.-Creek. Concentrations of lead, arsenic, and cadmium
detected in the seep samples were elevated with respect to
background.
Mr
Air sampling and analysis was completed during the RI to assess
the potential risk posed by airborne dust and lead particles.
Four high-volume air samplers were placed around the Site, and a
wind speed and direction monitor were mounted on the flag pole at
the Site's entrance. The highest 90-day average concentration of
lead detected during the monitoring was 0.0549 micrograms per
cubic meter (ug/m3) . This level was well below the national
ambient air quality standard (NAAQS) of 1.5 ug/m3 for lead.
Total suspended particulates (TSP) at the Site averaged 44.1
ug/m3 at the upwind location. This average did not change
significantly, but tended to decrease slightly at the downwind
locations. The majority of the ambient TSP may be due to the
presence of the large, unvegetated coal refuse piles situated -
offsite.
Onsite Buildings and Scrap Piles
The buildings on the Tonolli Site are in various stages of
deterioration. The refinery building has numerous holes in or
near the roof which allows rain to enter the building. This
water is collected in low lying areas within the building and in
some areas is beginning to erode the material stockpiled by EPA
during the removal work. A dust sample from near the furnace
area was analyzed for lead and found to contain 221,000 ppm. The
Toxicity Characteristic Leaching Procedure (TCLP) leachate had
detectable levels of cadmium and lead at concentrations of 33.7
mg/1 and 15.5 mg.l respectively.
Several scrap piles are present at the Site and generally consist
of scrap metal that is rusted and wooden pallets. These piles
were not sampled during the RI. One pile consists of a black
material that is believed to be slag. The soil immediately
adjacent to this pile was sampled via field screening (XRF) and
had a lead concentration of approximately 39,000 ppm.
15
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Approximately 120 nickel-iron batteries are grouped in eight to
ten racks, and are situated to the east of the battery receiving
and storage area at the Site. Most cf these batteries appear to
be open and are drained.
Stormwater Piping and Underground Tanks
Site records, including design drawings and plant layout
drawings, were reviewed during the RI to assess Site stormwater
drainage and underground storage tanks. The records indicate
several underground storage tanks present at the Site, and
several underground stormwater drainage pipes. Due to incomplete
information, the connections of certain sumps and stormwater
catch basins are not known. Three of the underground storage
tanks identified during the RI contain fuel oil or gasoline, and
one is empty. This tank is also believed to have contained
petroleum products in the past. In addition to the above, there
is a possibility that another storage tank exists directly in
front of the onsite office building.
V. CONTAMINANT FATE AND TRANSPORT
Lead is the most widespread and concentrated contaminant present
on the Site and was identified as the contaminant of greatest
health concern on the Site based on the baseline risk assessment.
Additional contaminants of major concern for the Site include
arsenic, copper, cadmium, and zinc.
Current information about the Tonolli Site indicates that three
migration pathways are of concern: surface water, groundwater and
air. Potential migration pathways for soil-borne metals may
include leaching into groundwater, surface water runoff into
drainage ditches and the creeks, where contaminants may wash out
as sediments, and wind dispersion. While wind dispersion did not
appear to play an appreciable role in offsite migration of
contaminated soils and dust based on sampling completed during
the RI, it may have played a more important role during the
historical operation at the Site, and thus it is retained as a
potential migration pathway.
Water-borne contaminants may follow two migration pathways:
surface water discharge and migration through subsurface soils to
the groundwater and then discharge into Nesguehoning Creek. The
lateral groundwater migration in the immediate vicinity of the
Site is toward the southeast. The vertical gradient is downward
north of the Site and upward near Nesguehoning Creek.
Data collected during the RI indicate that offsite migration
occurs to the air and surface water pathways. Current data on
the potential migration of contaminants through groundwater shows
that the Site has impacted a limited area of the overburden
16
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aquifer. Although the bedrock aquifer beneath the Site exists
under confined to semiconfined conditions, and may thus prevent
the migration of contaminants from the overburden to the deeper
bedrock aquifer, this remains a possible pathway of concern.
Additional monitoring within the bedrock will be required during
remediation to further evaluate this pathway.
Contaminant Persistence
In general, cationic metals bind readily to clay and organic
particles and are relatively persistent in the environment. None
of the five contaminants of concern undergoes photochemical
reactions to an appreciable degree.
Lead tends to form compounds of low solubility with the major
anions of water. Tetraalkyl lead may form by a combination of
chemical and biological alkylation of inorganic lead compounds.
Lead may accumulate in plants and animals but does not appear to
be biomagnified in food chains. Because lead binds very tightly
to soil particles, atmospheric lead is generally retained in the
upper two to five centimeters of soil.
Arsenic may undergo various transformations including oxidation-
reduction reactions, ligand exchange, biotransformation, and/or
precipitation and adsorption, resulting in a high degree of
mobility in aqueous systems. Arsenate compounds may be
methylated by microorganisms and subsequently may volatilize.
Significant biomagnification of arsenic in aquatic food chains
does not apparently occur.
Cadmium in the atmosphere tends to bind to very small particles,
particularly those of fly ash. It is not reduced or methylated
by microorganisms. Cadmium is strongly accumulated by all
organisms, both through food and water.
Sorption is the predominant reaction of zinc. Zinc is an
essential nutrient and is bioaccumulated in biota. Biological
activity may affect the mobility of zinc in surface water or
groundwater.
Contaminant Deposition and Migration
The battery breaking and smelting activities performed on the
Site contributed various forms of lead, sulfuric acid, and other
heavy metals to the Site. The handling, storage, onsite
treatment and disposal of battery wastes also contributed
contaminants to the Site. These activities covered extensive
areas of the Site property, but were generally focused on the
smelter and crusher buildings, and the wastewater lagoon and
onsite landfill. The storage area for broken battery casings
also covered a large area to the north of the smelter/refinery.
17
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The RI sample results establish the presence of lead, arsenic,
copper, cadmium, and zinc on the Site in soils, sediments,
surface water and groundwater. All five of these metals bind
readily to clay and organic particles that have negatively
charged surfaces. Generally, lead is the most tightly bound of
the metals, followed in order bycopper, zinc, and cadmium, with
arsenic having the greatest mobility.
The vertical distribution of lead in soils was generally limited
to the upper five feet. Three onsite areas showed elevated lead
levels at a depth between five and ten feet: the area underlying
the drainage ditch to the east of the lagoon; the area west of
the northern perimeter of the landfill; and an area just north of
the smelter/refinery building. These areas also showed elevated
levels of cadmium, copper and zinc at the greater sampling
depths.
Migration pathways established as a result of the current
understanding of the nature and extent of contamination found on
the Site are as follows:
Surface Water: Soil-borne metals transported via runoff caused
by precipitation into Nesquehoning and Bear
Creeks;
Surface water infiltration/leaching of metals to
subsurface soils and groundwater.
Groundwater: Vertical and horizontal migration of lead,
cadmium and arsenic in dissolved and particulate
form;
Discharge of contaminated groundwater into
Nesquehoning Creek.
Air: Wind or vehicular traffic transport of soils
and/or dusts to offsite areas.
Groundwater results indicate that the overburden aquifer in a
central portion of the Site has been impacted by lead, cadmium,
and arsenic. Due to the unconsolidated nature of the overburden
and the presence of mine spoils and fly ash in the overburden,
filtered groundwater samples were primarily considered in
identifying the dissolved metals that are most likely to be
transported through groundwater. Six of the onsite monitoring
wells showed elevated levels of metals in dissolved form. These
six wells also represent the lowest pH readings, indicating that
pH is a factor with regard to contaminant migration. Evaluation
of Site hydrogeology indicates that shallow groundwater flows
horizontally to the southeast where it discharges to Nesquehoning
Creek. Vertical groundwater flow in the alluvium is downward in
the northern portion of the Site and upwards (discharge to Creek)
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in the southern portion of the Site. The bedrock aquifer beneath
the Site exists under confined to semiconfined conditions, and
tends to prevent leakage downward from the shallow to the bedrock
aquifer.
Sediment samples collected in Nesquehoning Creek immediately
south of the Site were identified as impacted with regard to
arsenic, lead, and possibly cadmium. Sediments in Bear Creek at
the southwest corner of the Site also show an impact with regard
to lead. Based on the RI data, the elevated lead found in
sediments is tightly bound and is not being released to the water
column in either dissolved or suspended form.
Population and Environmental Areas Potentially Affected
The Site primarily consists of an abandoned industrial facility,
and is part of the 290-acre Green Acres Industrial Park West
which extends along the northern side of Route 54 in
Nesquehoning. Approximately 20 residences are located within
one-quarter mile of the Site, with two homes situated immediately
adjacent to the southwest corner of the Tonolli property.
Access to the Site is restricted by the perimeter fence, although
several trespassing incidents have been reported at the Site. A
local contractor provides Site security services. Additional
access to the Site is provided for a contractor to perform
routine sampling and maintenance as required for the onsite
surface water treatment plant.
In addition to the direct exposure to high levels of
contamination present in onsite battery waste piles, soils, and
to a lesser extent in groundwater, the RI documented the release
of contamination into the surface water and sediments of
Nesquehoning Creek and a small portion of Bear Creek.
Nesquehoning Creek is designated by PADER as a Cold Water
Fishery, and its tributary streams, including Bear Creek, are
designated as High Quality-Cold Water Fisheries. According to
the Pennsylvania Fish Commission, no recreational fishing occurs
in Nesquehoning Creek due to the near absence of fish.
VI. SUMMARY OF SITE RISKS
The data collected at the Site during the RI was used to complete
a human health and ecological assessment. The baseline risk
assessment provides the basis for taking action and indicates the
exposure pathways that need to be addressed by the remedial
action. It serves as the baseline, indicating what potential
risks would exist if no action were taken at the Site. This
section of the ROD reports the results of the baseline risk
assessment conducted for this Site.
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A. Human Health Risks and Exposure Assessment
The evaluation of human health risks is based on the current and
potential future land use of the Site. The Tonolli Site covers
approximately 30 acres of property that is zoned for industrial
use by the current zoning ordinance of the Borough of
Nesquehoning. The Site property forms the western boundary of a
290-acre area that comprises the Green Acres Industrial Park
West. This industrial park is described in a plan that was
sponsored by the Carbon-Schuylkill Industrial Development
Corporation in 1973. According to the Carbon County Office of
Planning and Development, fulfillment of this plan is still the
anticipated future land use for the Site property, as well as
properties to the east and south of the Site.
Based upon the information described above, the assessment of
human exposure to the Site was completed for a current and most
probable future use of the Tonolli property as a part of an
industrial park. To determine if human and environmental
exposure to the Site contaminants might occur in the absence of
remedial action, an exposure pathway analysis was performed. An
exposure pathway is comprised bf four necessary elements: 1) a
source and mechanism of chemical release; 2) an environmental
transport medium; 3) a human or environmental exposure point,
and, 4) a feasible human or environmental exposure route at the
point of exposure.
The assessment of health risks that could result from exposure to
contaminated Site 'materials specifically evaluated the following
exposure pathways: v
• t
1. Ingestion of contaminated waste piles, byproducts, or
sump sediments by an older child trespasser or long
term onsite adult worker.
2. Ingestion of contaminated soils by an older child
trespasser-r^a long term onsite adult worker, and an
offsite resident child or adult.
3. Inhalation of fugitive dust by an older child tres-
passer, an offsite resident child or adult, a long
term onsite adult worker, and a short term onsite
construction worker.
4. Ingestion of contaminated groundwater by a long term
onsite adult worker.
5. Ingestion of homegrown vegetables grown in contaminated
offsite soils by an offsite resident child or adult.
A summary of potential Site-related exposure pathways that were
considered and fully evaluated in the risk assessment is shown in
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Tables 1 and 2.
The baseline risk assessment focused on lead, arsenic, cadmium,
copper, and zinc as the contaminants of major concern. In
general, the RI data were used to develop exposure point
concentrations for calculating potential health risks posed by
exposure to Site contaminants via the pathways listed in Tables 1
and 2. In each medium at the Site, for each contaminant of
concern, except lead, the 95th percent Upper Confidence Limit of
the arithmetic average concentration was used to describe the
exposure point concentration. The exposure point concentrations
developed for the Site and used to calculate potential health
risks are shown in Tables 3 through 6. The major assumptions
about exposure frequency and duration that were included in the
exposure assessment are shown in Table 7.
For lead, a different approach for calculating risk was employed.
Presently, the only credible model available for evaluating
exposure to lead is the Integrated Uptake/Biokinetic (IU/BK)
Model. There are limitations, however, with regard to
application of the IU/BK model. The IU/BK model is capable of
assessing the impacts of lead exposure in only the most
susceptible subpopulation to lead toxicity, young children. In
its current form, the IU/BK model can not be used as a predictive
tool for adults, however it can be used as a baseline for
comparison. Although it is recognized that land use at the
Tonolli Corporation Site is considered industrial, the IU/BK
model was incorporated in the baseline risk assessment to provide
comparative exposure information on the contaminant of probably
single greatest concern at the Site, lead. The exposure
parameters used in the IU/BK model, as well as the predicted
impacts, are presented in Tables 8A and 8B.
B. Toxicitv Assessment
The toxicological properties of the contaminants of concern and
the toxicological basis of the health effects criteria summarized
in Table 9 are discussed in this section. The purpose of these
summaries is to provide general information on the health effects
of the selected chemicals and to present pertinent toxicological
results used to calculate and quantify toxicity criteria for the
Site. The criteria derived from the toxicological studies will
be used in conjunction with the estimated exposure levels to
evaluate potential human health risks.
Slope factors (SFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic contaminants
of concern. SFs, 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
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REPLACEMENT PAGE FOR THE TONOLLI HUMAN HEALTH AND ECOLOGICAL ASSESSMENT REVISED 1/24/92
CURRENT LAND-USE EXPOSURE PATHWAYS AT THE TONOLII SITE
Exposure
Hedlum
Mechanisms of Release
Exposure Point Potential Receptor Route of Exposure
Pathway
Complete?
Quantitatively Evaluated? Basis.
Surface Soil .Direct contact Hlth existing soil Off site Residents (a)
Surface Soil Direct contact With existing soil On site Trespassers (b)
Surface Soil Direct contact with existing soil Off and on site All receptors
Subsurface Soil Direct contact with existing soil On site . Trespassers (b)
Air Fugitive dust from surface soils Off site Residents (a)
Air Fugitive dust from surface soils On site Trespassers
Surface Water Surface run-off, seeps, and ground Off site Residents
water recharge to Nesquehoning Creek
Surface Water Surface run-off, seeps, and ground Off site Residents
water recharge to Nesquehoning Creek
Creek Sediment Site surface run-off or seeps Off site " Residents
Fish Ingestion of surface water Off site Residents
Vegetables Uptake from soil, translocatlon into Off site Residents
vegetables, deposition from air
Venison Ingestion of surface water Off site Residents
Ground Water Leaching to ground water and Off site Residents
water transport within aquifer
Sum/Pile Material Direct contact with materials In On site Trespassers
piles, sumps, buildings, and landfill
Incidental Ingestion Yes
Incidental ingestlon Yes
Dermal exposure No
Incidental ingestlon No
Inhalation Yes
Inhalation Yes
Incidental ingestion No
Dermal exposure No
Ingestion •
Ingestion
Ingestion of home
grown produce
Ingestlon
Ingestion
Ingestion
No
No
Yes
No
No
Yes
Yes. Evaluated under future land
use scenario.
Yes, for all metals. On-slte
surface soil data.
No. Hetals are not significantly
absorbed from a dry soil matrix.
No. Ground Instruslve activities
are not likely to be performed by
trespassing older children.
Yes. Air monitoring results for
soil data ratios for other metal;
Yes. Air monitoring results for
soil data ratios for other metal)
No. Ho recreational use of
Nesquehoning or Bear Creeks.
No. No recreational use of
Nesquehoning or Bear Creeks.
No. No recreational use of
Hesquehonlng or Bear Creeks.
No. No fish population In
Nesquehoning or Pear Creeks.
Yes. Evaluated under future Ian-
use scenario.
No. The chemicals of potential
concern have a low potential
for bloaccunulatlon In deer.
No. Only nearby production well
are upgradient In the bedrock aq
Yes. On-slte waste materials da
(a) For chemicals other than lead, evaluated for two age groups: 0-6 years,
(b) Evaluated for older children ages 8-14.
and 19 and older, for lead, evaluated for 0-6 years and 7 and older.
-------
Table 2
FUTURE EXPOSURE PATHWAYS
Exposure
Medium
Surface Soil
Surface Soil
Surface Soil
Sump/pile
material
Air
Air
Vegetables
Vegetables
Ground Water
Ground Water
Mechanisms of Release
Direct contact with surface soils
Direct contact with surface soils
Direct contact with surface soils
Direct contact with materials In
piles, sumps, buildings, and
landfill.
Fugitive dust from surface soils
Fugitive dust from surface soils
Uptake from soil, translocatlon
Into vegetables, deposition from
air.
Uptake from soil, translocation
Into vegetables, deposition from
air.
Leaching to ground Hater
Leaching to ground Mater
Exposure Point
on site
On site
Off site
On site
On site
On and off site
On site
Off site
On site
On site
Potential Receptor
Worker (a)
Residents (b)
Residents (b)(c)
Residents (b)
Worker (a)(d)
Residents (b)
Residents (b)
Residents (b)(c)
Worker (a)
Residents (b)
Route of Exposure
Ingest ion
tngestlon
Ingest ion
tngestlon
Inhalation
Inhalation
Ingest Ion
Ingest I on
Ingest Ion
Ingest ion
Pathway
Complete?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Quantitatively Evaluated? Basis.
Yes. On-slte soil data.
Yes. On-slte soil data.
Yes. Off-site soil data.
Yes. Sump/pile materials data.
Yes. Air monitoring data and
metal ratios In soil.
Yes. Air monitoring data and
metal ratios In soil.
Yes. Methodology of Baes et al.
(1984)
Yes. Methodology of Baes et al.
(1984)
Yes. On-slte grounduater
data.
Yes. On- site groundwater
data.
(a) Evaluated for adults only.
(b) Evaluated for two age groups: 0-6 years, and 19 and older.
(c) Off-site exposure to soils and vegetables Hill be evaluated for two separate off-site areas. See text.
(d) Exposure to fugitive dust by workers will be evaluated for two worker scenarios: Long term Industrial and short term construction.
-------
Table 3
ON-SITE SURFACE SOIL EXPOSURE POINT CONCENTRATIONS
Chemical
SITE-UIDE (a)
Arsenic
Cadmium
Copper
Lead
Zinc
Average
Exposure Point
Concentration
(rag/kg)
61
10.6
419
8,300
167
RUE
Exposure Point
Concentration
(tag/kg)
134
41.7
377
74,900
311
Max i nun
Measured
Concentration
(rag/kg)
411
130
8,440
95,200
1,480
(a) Calculated using all soil samples in footnotes and contained.
-------
Table 5
EXPOSURE POINT CONCEMTRATIONS FOR STOCKPILED MATERIALS AM) SUHP SEOIKEMTSCa)
Chemical
Arsenic
Cadmium
Copper
Lead
Zinc
Average
Exposure Point
Concentration
(ug/L)
505
414
1,090
111,000
3,090
Reasonable Maximum
Exposure Point
Concentration
-------
Table 7
SUMMARY OF. EXPOSURE PARAMETERS USED FOR THE TONOLL! HUMAN HEALTH AND ECOLOGICAL ASSESSMENT
Exposure Pathway
Exposure Parameters Used
Average Case RME Case
SOIL INGEST ION
Older Child Trespasser *
Adult Worker *
Adult Resident «
Chi Id Resident
EF = 8 dys/yr
ED = 7 yrs
[R = 13 rag/day
FI = 0.25
BU = 41 kg
EF = 172 dys/yr
ED = 8.4 yrs
IR = 7 mg/day
0.5
70 kg
FI =
BU
EF = 350 dys/yr
ED = 30 yrs
IR = 7 nig/day
FI = 1.0
BU = 70 kg
EF = 350 dys/yr
ED = 7 yrs
IR = 114 mg/day
FI = 1.0
BU = 14.5 kg
EF
ED
IR
FI
BU
EF
ED
IR
FI
BU
EF
ED
IR
FI
BU
EF
ED
IR
FI
BU
= 34 dys/yr
= 7 yrs
= tOO mg/day
= 0.25
= 41 kg
= 172 dys/yr
= 25 yrs
= 100 rag/ 'day
= 0.5
= 70 kg
= 350 dys/yr
= 30 yrs
=100 mg/day
= 1.0
= 70 kg
= 350 dys/yr
= 7 yrs
= 200 mg/day
= 1.0
= 14.5 kg
GROUNDUATER INGESTION
Adult Worker
Adult Resident
Chi Id Resident
EF = 241 dys/yr
ED = 8.4 yrs
IR = 1.4 L/day
FI = 0.5
BU = 70 kg
EF = 350 dys/yr
ED • 30 yrs
IR = 1.4 L/day
FI = 1.0
BU = 70 kg
EF = 350 dys/yr
ED = 7 yrs
IR = 0.4 L/day
FI = 1.0
BU = 14.5 kg
EF
ED
IR
FI
BU
EF
ED
IR
fl
BU
EF
ED
IR
Fl
BU
= 241 dys/yr
= 25 yrs
= 2 L/day
= 0.5
= 70 kg
= 350 dys/yr
= 30 yrs
= 2 L/day
= 1.0
= 70 kg
= 350 dys/yr
= 7 yrs
= 0.8 L/day
= 1.0
= 14.5 kg
Please see footnotes on the following page.
-------
Table 7
SUMMARY OF.EXPOSURE PARAMETERS USED FOR THE TONOLLI HUMAH HEALTH AND ECOLOGICAL ASSESSMENT
Exposure Pathway
Exposure Parameters Used
Average Case RME Case
OUST INHALATION
Older Child Trespasser
Adult Long Term Industrial Worker
Adult Short Term Construction Worker
Adult Resident
Child Resident
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
EF =34 dys/yr
ED = 7 yrs
ET = 4 hrs/day
EF = 241 dys/yr
ED = 25 yrs
ET = 8 hrs/day
EF = 30 dys/yr
ED = 1 yr
ET = 8 hrs/day
EF = 350 dys/yr
ED = 30 yrs
ET = 24 hrs/day
EF = 350 dys/yr
ED = 7. yrs
ET = 24 hrs/day
VEGETABLE INGEST ION
Adult Resident *
Child Resident *
NA
MA
NA
NA
MA
NA
MA
MA
MA
NA
NA
NA
EF = 350 dys/yr
ED = 30 yrs
1RV = 26 g/day
IRR = 34 g/day
IRL = 20 g/day
BU = 70 kg
EF * 350 dys/yr
ED = 7 yrs
IRV * 16 g/day
IRR » 48 g/day
IRL = 11 g/day
BU = 70 kg
Please see footnotes on the following page.
-------
Table 7
SUMMARY CF. EXPOSURE PARAMETERS USED FOR THE TONOLLI HUMAN HEALTH AND ECOLOGICAL ASSESSMENT
Exposure Parameters Used
Exposure Pathway Average Case RME Case
KOTES:
EF = Exposure Frequency
ED = Exposure Duration
ET = Exposure Time
IR = Ingestion Rate
IRV = Ingestion Rate for Vine Crops
IRR = Ingestion Rate for Root Crops
IRL = Ingestion Rate for Leafy Crops •
FI = Fraction Ingested (i.e., the fraction of yak ing hours that receptor is in contact with the site.
BU = Body Weight
NA = Not Applicable; pathway was evaluated for RME case only.
* = For these pathways, relative oral bioavailability factors from Fraser and Lun (1983) were used.
Use of these values is not typical for USEPA Region III risk assessments. However, their
use in this case does not impact the final decision for this site and they have been included
in the risk calculations. The values used were 0.294 for arsenic, 0.11 for cadmium,
0.105 for copper, and 0.099 for zinc.
-------
level. The tern "upper bound" reflects the conservative estimate
of the risks calculated from the SF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Slopefactors 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
contaminants of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of
lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of contaminants of concern from
environmental media can be compared to the RfD. RfDs are derived
from human epidemiological. studies or animal studies to which
uncertainty factors have been applied (i.e., to account for the
use of animal data to predict effects on humans).
1. Lead
Exposure to lead via inhalation and ingestion can cause potential
carcinogenic and noncarcinogenic adverse health effects. The
following discussion presents toxicological information and
toxicity values for the carcinogenic and noncarcinogenic effects
of lead.
Carcinogenic Effects - The Carcinogen Assessment Group (CAG) of
the U.S. EPA has recently assigned a weight-of-evidence
classification of B2 to lead, indicating that lead is a probable
human carcinogen. The B2 classification was assigned on the
basis of sufficient animal evidence, with inadequate human
evidence.
Noncarcinoqenic Effects - The noncarcinogenic toxicological
effects of lead are well documented. Lead affects the following
human systems or organs:
- Hematopoietic system
- Central nervous system
- Kidneys
- Gastrointestinal system
- Bone marrow cells
- Reproductive system
- Endrocrine system
- Heart
- Immune system.
The consensus on the blood lead (Pb-B) level of children which is
considered toxic has changed in recent years. In 1975, the U.S.
Centers for Disease Control (CDC) defined the toxic level in
29
-------
Table 8A
UBK MODEL PARAMETERS USED TO ESTIMATE
BLOOD LEAD LEVELS FOR RESIDENTS AGES 0-7
Medi un/Parameter
UBK
Default Parameter
Site-specific
Parameter
Air Data:
Air Concentration
Indoor Air Percentage
of Outdoor Air
Lung Absorption
Vary Air Cone, by Year
Age Specific Data:
Age
0-1
1-2
2-3
3-4
4-5
5-6
6-7
0.20 ug Pb/aii
302
32. OX
No
Ventilation
Rate
2.0 m3/day
3.0 ml/day
5.0 mS/day
5.0 m3/day
5.0 enS/day
7.0 o3/day
7.0 m3/day
Time Spent
Outdoors
1 hr/day
2 hr/day
3 hr/day
4 hr/day
4 hr/day
4 hr/day
4 hr/day
0.12 ug Pb/ni3
Water Data:
Water Concentration
Absorption
Water Consumption
Age: 0-1
1-2
2-3
3-4
4-5
5-6
6-7
4.00 ug/l
SOX
0.20 1 /day
0.50 I/day
O.S2 I /day
0.53 I/day
0.55 I/day
0.58 I/day
0.59 I/day
27.7 ug/l (a)
Diet Data:
Absorption
Diet Intake
Age: 0-1
1-2
2-3
3-4
4-5
5-6
6-7
SOX
5.88 ug Pb/day
5.92 ug Pb/day
6.79 ug Pb/day
6.57 ug Pb/day
6.36 ug Pb/day
6.75 ug Pb/day
7.48 ug Pb/day
-------
Table SB
UBK RESULTS FOR CHILD RESIDENT
AGES 0-84 MOUTHS
Scenario
Soil
Concentration
(mg/kg)
Geometric Mean
Blood Lead Level
(ug/dl)
Percent of Population Above
Blood Level Cut-Off (10 ug/dL)
GSO = 1.42
GSD = 1.7
ON-SITE SURFACE SOIL:
Without ingestion of 8,300
home grown vegetables
With ingestion of 8,300
home grown vegetables
ON-SITE SIMP SEDIMENT/
PILE MATERIAL:
Without ingestion of
home grown vegetables
OFF-SITE TO THE WEST:
Without ingest ion of
hone grown vegetables
With ingest ion of
hone grown vegetables
111.000
433
433
46 (a) >99.9 (a)
71 (a) >99.9 (a)
NC
5.2
9.0
NC
2.9
34.6
99.7 (a)
>99.9 (a)
NC
10
38.9
OFF-SITE TO THE NORTH,
SOUTH AND EAST:
Without ingestion of
hone grown vegetables
With ingestion of
home grown vegetables
145
145
2.8
4.5
0.01
0.98
0.71
6.2
NC = Not calculated; model could not be run with a concentration of 111,000 mg/kg lead, as
unrealistic results would occur.
(a) These results are biologically implausible and have occurred because the UBK model
cannot adequately predict the plateau effect observed in population blood lead
concentration curves as soil lead concentrations increase to very high levels.
-------
Table 9
CRITICAL TOXtCITY VALUES FOR CHEMICALS OF POTENTIAL CONCERM
AT THE TONOLLI SITE
Chemical
Chronic Inhalation Subchronic
RfC (mg/kg-day) Inhalation
[Uncertainty RfC (mg/kg-day) Target
Factor] (a) [Uncertainty Factor] Organ (b)
RfC
Source
Unit Risk
(ug/m3)-1
EPA Weight
of Evidence
Classifi-
cation (c)
UF
Source
Inhalation:
Arsenic
Cadmium
Copper
Lead
Zinc
Chemical
—
—
—
—
...
Chronic RfD
(mg/kg-day)
[Uncertainty
Factor] (a)
— —
— —
— —
- - - • - *
Subchronic RfD
(mg/kg-day) Target
[Uncertainty Factor] Organ (b)
4.30E-03
1.80E-03
... —
... —
* - - • - -
Slope Factor
RfD (SF)
Source {mg/kg-day) -1
A
81
--
82
0
EPA Weight
of Evidence
Classifi-
cation (c)
IRIS
IRIS
—
IRIS
IRIS
SF
Source
Oral:
Arsenic
Cadmium (water)
Cadmium (food)
Copper
Lead
Zinc
1.00E-03 [1J
5.00E-04 [10] (e)
1.00E-03 [10] (e)
3.70E-02 C1] (f)
...
2.00E-01 t10] (e)
1.00E-03 [1]
—
—
3.70E-02 [1] (f)
—
2.00E-01 [10] (e)
Skin HEAST
Kidney IRIS
Kidney IRIS
GI Irritation HEAST
CNS IRIS
Anemia HEAST
1.75E*00 (d)
...
—
...
...
- — —
A
...
—
—
82
....
IRIS
IRIS
IRIS
...
IRIS
...
(a) Uncertainty factors are a measure of the uncertainty in the data available. A higher uncertainty factor represents
a greater amount of uncertainty in the data.
(b) A target organ is the organ most sensitive to a chemical's toxic effect. RfDs are based on toxic effects in the
target organ. If an RfD was based on a study in which a target organ was not identified, an organ or system known
to be affected by the chemical is listed.
(c) EPA Weight of Evidence for Carcinogenic Effects:
[A] = Human carcinogen based on adequate evidence from human studies; and
[81] = Probable human carcinogen based on limited human data;
[82] = Probable human carcinogen based on inadequate evidence from human studies and adequate evidence from animal
studies.
[01 = Mot classified as to human careinogenicity.
(d) A unit risk of 5E-05 (ug/L)-1 has been proposed by the risk assessment forum and this recommendation has been
scheduled for review (SAB). This is equivalent to 1.75 (mg/kg-day)-1 assuming a 70 kg individual ingests 2 L/day.
(e) Variation in human sensitivity.
(f) The current drinking water standard of 1.3 mg/L has been converted to an RfD assuming a 70 kg individual ingests
2 L of water per day.
NOTE: IRIS
= Integrated Risk Information System.
= No information available.
-------
children's blood as 40 micrcgrams per deciliter (ug/dl). This
value was reduced in 1985 by the CDC to 25 ug/dl. In 1986, the
World Health Organization (WHO) recommended 20 ug/dl as the upper
acceptable limit for children. In the same year, EPA's Clean Air
Scientific Advisory Committee indicated that levels of 10 to 15
ug/dl can be associated with adverse health effects in children.
In October, 1991, the CDC recommended an intervention level of 10
ug/dl. Consequently, a Pb-B level of 10 ug/dl was used as the
Pb-B limit for children, below which children should not be
considered at risk from exposure to lead, according to currently
available data.
For adults, particularly white males of 40 to 59 years old,
studies have indicated that increases in blood pressure are
associated with Pb-B levels ranging from possibly as low as 7
ug/dl to 30 or 40 ug/dl. As a result, a Pb-B level limit of 10
ug/dl was used for adults, a level below which adults should not
be considered at risk from exposure to lead.
Although lead has been classified as a probable human carcinogen
by EPA's CAG, EPA has considered it inappropriate to develop a
reference dose (RfD) for inorganic lead and lead compounds, since
many of the health effects associated with lead intake occur
essentially without a threshold. Therefore, it is not possible
to calculate a cancer risk number as it is done for other
contaminants. In order to evaluate the human health risks posed
by exposure to lead, EPA uses an uptake model, the Integrated
Uptake/Biokinetic Model (IU/BK). This model takes into account
the uptake of lead from multiple exposure pathways, and estimates
the resulting blood lead levels of the exposed person(s).
2. Arsenic
Arsenic has been classified as a Group A human carcinogen by
EPA's CAG. Ingestion of arsenic results in an increased
incidence of skin cancers, although only a fraction of the
arsenic-induced skin cancers are fatal. The assumption of a
linear relationship between arsenic dose and cancer risk may
overestimate the risk. EPA believes that the uncertainties
associated with ingested inorganic arsenic are such that risk
estimates could be modified downwards as much as tenfold relative
to risk estimates associated with other carcinogens.
Epidemiological studies of workers in smelters and in plants
manufacturing arsenical pesticides have shown that inhalation of
arsenic is strongly associated with lung cancer and perhaps with
hepatic angiosarcoma. Ingestion of arsenic has been linked to a
form of skin cancer and more recently to bladder, liver, and lung
cancer. Dermal absorption of arsenic is not significant. Acute
exposure of humans to metallic arsenic has been associated with
gastrointestinal effects, hemolysis, and neuropathy. Chronic
33
-------
10
SUMMARY OF POTENTIAL HUMAN HEALTH RISKS
Current Site Use Scenario
EXCESS
LIFETIME
CANCER RISK* HAZARD QUOTIENT
RECEPTOR
Older Child Trespasser;
Incidental Ingestion of Soil 3xlO~7
Incidental Ingestion of
Sump/Pile Material 8xlO~6
Inhalation of Fugitive Dust 7xlO"9
TOTAL 8xlO~6
Adult Off -Site Resident;
Inhalation of Fugitive Dust 2xlO~6
TOTAL 2xlO~6
Young Child Off-Site Resident;
Inhalation of Fugitive Dust 4xlO~7
TOTAL 4xlO'7
Arsenic Cadmium Copper Zinc
2xlO"3 2xlO"4 3xlO~4 IxlO"5
•
5xlO~2 IxlO'2 5xlO"4 5xlO"4
NA NA NA NA
5xlO~2 1X10~2 8xlO~4 5xlO"4
NA NA NA NA
NA NA NA NA
NA NA NA ' NA
NA NA NA NA
Calculated cancer risks are related to exposure to arsenic and/or cadmium.
NA = Not applicable; no inhalation toxicity criteria are available for the noncarcinogenic
effects of the chemicals of potential concern.
-------
Table 11
•UBBABT Or FOTBRXAL WOm
Tatar* sit* use i
RECEPTOR
Lona-Terc On-Site Adult Worker:
Incidental Ingestion of Soil
Incidental Ingestion of
Sump/Pile Material
Inhalation of Fugitive Dust
Zngestion of Ground Hater
EXCESS
LIFETIME
CAKCER RISK"
7xi
-------
exposure of humans to high levels of arsenic can produce toxic
effects on both the peripheral and central nervous systems,
keratosis, hyperpigmentation, precancerous dermal lesions, and
cardiovascular damage.
3. Cadmium
Cadmium has been classified as a Group Bl probable human
carcinogen by the inhalation pathway. Epidemiological studies
have demonstrated a strong association between inhalation
exposure to cadmium and cancers of the lung, kidney, and
prostate. Cadmium bioaccumulates in humans, particularly in the
kidney and liver. Chronic oral or inhalation exposure of humans
to high doses of cadmium has been associated with renal
dysfunction, bone damage, hypertension, anemia, endocrine
alterations, and immunosuppression.
4. Copper
Copper is an essential element, and a daily copper intake of 2 mg
is considered to be adequate for normal health and nutrition.
Adverse effects in humans resulting from acute exposure to copper
concentrations that exceed these recommended levels by ingestion
include salivation, gastrointestinal irritation, nausea,
vomiting, hemorrhagic gastritis, and diarrhea. Acute inhalation
of dusts of copper salts by humans may produce irritation of the
mucous membranes and pharynx, ulceration of the nasal septum, and
metal fume fever (chills, fever, headache, and muscle pain).
5. Zinc ;''
\
Zinc is an essential trace element that is necessary for normal
health and metabolism. Exposure to zinc at concentrations that
exceed recommended levels has been associated with a variety of
adverse effects. Chronic and subchronic inhalation exposure to
zinc has been assoeiated with gastrointestinal disturbances,
dermatitis, and metal fume fever. Chronic oral exposure to zinc
may cause anemia and altered hematological parameters.
C. Risk Assessment
The principal threats posed by the Site are: 1) the waste piles
and byproduct materials including the battery casings and piles
of dusts and sludges; 2) the lead contaminated sediments in the
subsurface drainage network; and, 3) the lead contaminated solids
and standing water in the onsite landfill. Lower level threats
include the lead and arsenic contaminated sediments in
Nesquehoning and Bear Creeks, the lead contaminated soils that
cover portions of the Tonolli property and a small area to the
immediate west of the property boundary, and the groundwater
(overburden) contaminated with arsenic, lead, and cadmium.
36
-------
The sampling of Site soils found that the average concentration
of lead in onsite surface soil samples was 8,300 milligrams per
kilogram (mg/kg). The average lead concentration found in the
waste and dust piles, byproduct materials and sump sediments was
111,000 mg/kg. The average lead concentration found in the
landfill materials (solids) was 36,588 mg/kg. The average lead
and arsenic concentrations found in creek sediments were 395
mg/kg and 24.8 mg/kg, respectively. The average lead (dissolved)
concentration found in the overburden aquifer was 0.0277
milligrams per liter (mg/1). The average lead concentration
found in soils in an area containing two residential dwellings to
the immediate west of the Tonolli property boundary was 433
mg/kg.
In addition, EPA has recently identified a blood lead
concentration of 10 micrograms per deciliter (ug/dl) as a level
of concern for both children and adults. Using the average soil
lead concentration and current biological impact models (i.e.,
the IU/BK model), the risk assessment estimated that >99.9% of
the children residing onsite would have blood-lead above 10
ug/dl, with an average level of 82 ug/dl. The IU/BK model also
estimated that 38.9% of the children residing to the immediate
west of the Tonolli property boundary would have blood-lead above
10 ug/dl, with an average level of 9.0 ug/dl.
The overburden aquifer appears to be contaminated by lead,
cadmium, and arsenic. Elevated lead concentrations were found
only in two wells adjacent to the battery dumping and storage
area and crusher building. Elevated concentrations of cadmium
were found in five monitoring wells situated in the central
portion of the Site, and generally downgradient from the battery
processing and waste disposal areas. Arsenic at elevated
concentrations was found to occur in only one well situated
immediately downgradient from the onsite landfill. The elevated
concentrations of dissolved metals appear to be associated with
lower pH conditions.
Elevated levels of contaminants were only found to occur within
the overburden aquifer at the Site. Although the overburden
aquifer is not currently used for drinking water supply, EPA
considered the potential for a well to be constructed within the
onsite overburden in evaluating potential health risks posed by
the Site conditions. Based on limited sampling of one onsite
bedrock well during the later stages of the RI, no Site-related
contaminants have been detected in the deep bedrock aquifer. The
deep aquifer consists of the Mauch Chunk formation, and is
currently used to supply drinking water to over 20,000 residents.
RISK CHARACTERIZATION SUMMARY
A summary of the total potential carcinogenic and noncarcinogenic
human health risks calculated for the Site is provided in Tables
37
-------
10 and 11. These tables summarize the potential risks posed by
the Site if no action would be taken. When reviewing the
quantitative information presented in these tables, the following
threshold levels should be used. For noncarcinogenic risks, a
hazard index or hazard quotient value above a value of 1.0
indicates the potential for an adverse health impact. For the
carcinogenic risks, a value greater than IxlO"4 to lxlO~6 is
generally recognized as indicating a risk beyond the acceptable
level.
1. Noncarcinogenic Risk
The Hazard Index (HI) Method is used for assessing the overall
potential for noncarcinogenic effects posed by the contaminants
of concern. 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). HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed can be added to generate an HI value.
Tables 10 and 11 present the calculated hazard quotients for each
potential receptor evaluated under both the current and future
use scenarios for the Site. This table calculates HQs for
reasonable maximum exposure scenarios (RME) using the exposure
point concentrations calculated previously. EPA makes use of the
RME calculations in assessing potential health risks posed by the
Site.
Calculations demonstrate that noncarcinogenic risks may be
incurred by an adult, long-term onsite worker who ingests
groundwater drawn from the overburden aquifer. Elevated levels
of arsenic and cadmium are the driving factors in establishing a
potential noncarcinogenic risk for this pathway.
2. Carcinogenic Risks
For potential carcinogens, risks are estimated as probabilities.
Excess lifetime cancer risks are determined by multiplying the
exposure point concentration with the cancer potency slope and
expressing the result in scientific notation. As excess lifetime
cancer risk of IxlO"6 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.
Tables 10 and 11 present the calculated potential carcinogenic
risks for each potential receptor evaluated under both the
current and future use scenarios for the Site. These tables
include the RME scenarios that are used by EPA in assessing
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potential health risks posed by the Site.
The exposure scenario which results in potential excess cancer
risk greater than IxlO"4 involves ingestion of contaminated
groundvater and/or contaminated waste pile and sump material by
an adult long term onsite worker. Elevated levels of arsenic and
cadmium are the primary factors in generating a potential
carcinogenic risk for this pathway.
Several exposure scenarios result in potential excess cancer risk
between lxlO~4 and lxlO~6, or the acceptable risk range.
However, the majority of these scenarios assume future
residential development of the Site, which is not valid. Since
the most probable future use of the Tonolli Site is as an
industrial facility, as supported by current zoning and planning
documents, these scenarios are not considered further.
Based on the conclusions of the Risk Assessment completed for
Tonolli, actual or threatened releases of hazardous substances
from this Site, if not addressed by implementing the response
action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to the public health,
welfare, or the environment.
3. Environmental Assessment
An ecological characterization of the Tonolli Site and an area
within a 0.5 mile radius of the Site was performed during the
RI/FS. Terrestrial and wetlands resources within the study area
consist of deciduous forest, scrub/shrub, mixed scrub/shrub-
herbaceous, and floating aquatic macrophytic plant communities.
Most of the study area was found to consist of mature deciduous
forest associated with the slopes of Broad Mountain to the north
and Nesquehoning Mountain to the south. The other communities,
including wetlands and the Nesquehoning Creek aquatic community
are spread along the valley floor. There is no obvious evidence
of vegetation stress due to the Site.
The Site itself is industrial land with limited vegetation
present, generally situated near the edges of the property. The
land surrounding the Site is largely undeveloped forest, coal
spoil stockpile areas, and industrial properties. The
terrestrial and wetland vegetation community types within the
study area are commonly found throughout the Pocono Mountain
region, and most of Pennsylvania. No plant species of special
concern (state and federal listed rare, threatened, or endangered
species) are recorded for the study area and none were observed
during the field study.
Potential environmental receptors, or indicator species selected
for the ecological evaluation included aquatic life, plants,
earthworms, white-tailed deer, and shrews. An additional
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potential receptor identified by the Fish and Wildlife Service
includes migratory passerine birds that may use the Site to feed,
bathe, and use Site soils or gravel as grit. Based on the low
habitat value of onsite areas, the potential for exposure of most
of the species of concern was considered to be low. Exposure
pathways evaluated in this assessment included: 1) direct contact
of aquatic life with surface water and sediment; 2) direct
contact of plants and earthworms with surface soils; 3) ingestion
of surface water by white-tailed deer; and 4) ingestion of
earthworms, that had accumulated heavy metals from the Site, by
shrews.
Lead contamination present in the sediments and surface water may
be of potential concern to aquatic life in Nesquehoning Creek.
Nesquehoning Creek is designated by FADER as a Cold Water
Fishery. However, habitat suitability of the creek in general
has been greatly impacted by the presence of extensive amount of
coal spoils in areas both upstream and downstream from the Site,
and the Pennsylvania Fish Commission has reported that they are
aware of the depauperate community existing there. Terrestrial
species such as deer are not expected to experience any adverse
impacts as a result of this exposure.
Elevated concentrations of copper and lead in surface soils
onsite may have an impact on earthworms and some species of
plants. Small carnivorous mammals such as shrews may also
experience some adverse impacts when feeding onsite. However,
the onsite area is greatly disturbed (i.e., covered by asphalt,
buildings, or battery waste piles) and has a limited habitat or
forage value.
4. Significant Sources of Uncertainty
The general limitations inherent in the risk assessment process
as well as the uncertainty related to some of the major
assumptions made in this assessment are described below.
a.) Environmental sampling and analysis error can stem from
several sources including the characteristics of the matrix being
sampled and systematic or random errors in the sampling and
analytical methods. The following factors contribute to the
uncertainty: analytical precision or accuracy, the QA/QC review
of data, laboratory analysis procedures, respresentativeness of
data, and proper sampling strategy.
b.) Estimation of exposure parameters includes several potential
sources of uncertainty, including: estimation of exposure point
concentrations, choice of exposure models, selection of input
parameters used to estimate exposures, and selection of pathways
for evaluation.
c.) Toxicological data error is also a large source of
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uncertainty in this risk assessment. The factors contributing to
this are as follows;
-Extrapolation of toxicity data from both animals to humans
and from high to low doses,
-Method used for calculating the RfD for cadmium,
-Toxicity values used in the ecological assessment,
-Uncertainties associated with lead toxicity (i.e., lead
speciation, solubility, and bioavailability factors),
-Uncertainties associated with use of IU/BK model at high
soil lead levels.
d.) Due to the limitations-of the risk assessment process itself
and to conservative assumptions made specific to the Tonolli
Site, the risk levels calculated are considered to be estimates
of worst-case risk.
VTI. SUMMARY OF REMEDIAL ALTERNATIVES
In accordance with 40 C.F.R. Section 300.430, a list of remedial
response actions and representative technologies were identified
and screened to meet the remedial action objectives at the Site.
The technologies that passed the screening were assembled to form
remedial alternatives. The FS identifed seven remedial
alternatives that were determined to be the most applicable for
this Site. Two cleanup levels were cited under each of the
alternatives presented in the FS, however, only those citing a
cleanup level of ^000 mg/kg for lead in soils are considered to
be protective of human health and the environment.
It should be noted that all costs, time frames and volumes
discussed below are estimates. This information will be further
refined during the remedial design.
1. Alternative 1 - No Action/No Further Action. The National
Contingency Plan (NCP) requires that EPA consider a "No Action"
or "No Further Action" alternative for each site to establish a
baseline for comparison to alternatives that do require action.
For Tonolli, this alternative provides only for maintaining the
current conditions at the Site. The existing fence would be
remain, and sampling of groundwater and creek sediments would be
performed quarterly for a two year period, and semi-annually
thereafter for a period of 30 years.
The contaminants in the soils, battery waste piles, buildings,
and sediments at the Site would be left in place, and the
existing stormwater treatment plant would no longer be operated.
This would allow Site contaminants to be released to the
Nesquehoning Creek during major precipitation events. The Site
would continue to pose a risk to trespassers, potential onsite
workers, and nearby residents. In addition, continued migration
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of contaminants through soils, surface water, and groundwater nay
further impact the environment. Because this alternative will
result in contaminants remaining onsite, CERCLA Section 121(c)
requires that a Site review be conducted every 5 years.
- Capital Cost: $0
- Annual O * M Cost (Monitoring-30 years): $54,600
- Present Worth Cost: $550,000
- Time to Implement: N/A
There are no ARARs associated with a no action alternative.
2. Alternative 2 - Limited Ac'uion/jtustitutional Controls. This
alternative consists of maintaining and operating the existing
stormwater treatment system, maintaining the fence and Site
security, monitoring groundwater and creek sediments, and
implementing institutional controls such as deed restrictions.
Such restrictions would be applied to limit the use of the Site
and to prevent excavation on the Site property. Under this
alternative, contamination would remain onsite and health risks
to trespassers, onsite workers and nearby residents would remain
at an unacceptable level.
No additional action would be taken to remove, contain, or
remediate the contaminated waste/byproduct piles, battery
casings, contaminated soils, sediments, onsite landfill or
groundwater. Although the restriction of Site access with a
security fence provides a minimal degree of protection, there is
no long-term effectiveness because wastes remain onsite and
exposed. The onsite treatment plant collects and treats
contaminated surface water, however this action provides an
insufficient reduction in toxicity, mobility, and volume of Site
contaminants. State and community acceptance of this alternative
is very unlikely. Because this alternative will result in
contaminants remaining onsite, CERCLA Section 121(c) requires
that a Site review be conducted every 5 years.
- Capital Cost: $0
- Annual O fc M cost: $277,600
- Present worth cost: $4,000,000
- Tina to Implement: N/A
Compliance vith ARARs
The operation of the onsite treatment plant will meet the
substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
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Fugitive dust emissions generated during remedial activities will
comply with the National Ambient Air Quality Standards (NAAQS)
set forth at 40 CFR Part 50 and 25 PA Code Sections 131.2 and
131.3. Such emissions will comply with regulations in the
federally-approved State Implementation Plan for the Commonwealth
of Pennsylvania, 40 CFR Part 52, Subpart NN, Sections 52.2020 -
52.2023 and in 25 PA Code Sections 123.1 and 123.2.
This Limited Action alternative would provide no remediation of
the contaminated media at the Site and, therefore, would not meet
the chemical-specific and action-specific ARARs discussed under
Alternative 3 below.
3. Alternative 3 - Soil Capping/Landfill Closure/Decontaminate
Buildings. Alternative 3 consists of a cap over contaminated
soils, waste piles, byproduct materials and battery casings,
closure of the onsite landfill in accordance with RCRA
requirements, and treatment of contaminated stormwater, landfill
leachate, and decontamination fluids in the onsite treatment
plant prior to discharge to Nesquehoning Creek under the
substantive requirements of a NPDES permit.
Under this alternative, approximately 13,000 cubic yards of
battery casings, 15 cubic yards of sump sediments, 215 cubic
yards of crusher building dusts, 23 cubic yards of iron oxide
dust, and 39,000 cubic yards of soils contaminated above a level
of 1000 mg/kg for lead would be graded and capped with a four-
inch thick asphalt layer. The areas to be capped would be graded
to reduce slopes and fill material would be added if needed to
obtain a minimum 2 percent slope for drainage. The capped areas
would be vegetated, where appropriate, to reduce erosion and
infiltration and promote runoff. Ancillary surface water runoff
control measures such as ditches would be applied as needed for
capped areas.
Closure of the landfill consistent with the federally authorized
Pennsylvania hazardous waste requirements would include
dewatering the landfill through two pumping wells, placing
approximately 20-30,000 cubic yards of fill material on the
landfill to provide for minimum 2 percent slopes, and placing a
very low permeability multilayer synthetic cap on the landfill.
The existing manholes would be cleaned out and used as future
leachate collection points along with dewatering well points.
Prior to installing the cap, approximately 6 cubic yards of
excavated stream sediments, 210 cubic yards of lagoon soils,
2,020 cubic yards of treated sludges, and 250 drums of plastic
would be consolidated within the landfill. This action would be
contingent upon additional sampling and characterization of the
materials. Post-closure care for the landfill would include
maintenance of the cap and devatering system, and long-term
groundwater monitoring of at least one upgradient and three
downgradient monitoring wells. Sampling would occur quarterly
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for the first two years and then semi-annually thereafter.
The fence would be maintained under this alternative and
nickel/iron batteries currently stored at the Site would be
disposed offsite. Sediments containing greater than 450 mg/kg
lead in Nesquehoning Creek and Bear Creek would be removed and
placed in the existing landfill prior to capping. Onsite
buildings would be decontaminated using vacuuming or washing
techniques. The buildings may either be dismantled, sold or left
onsite for future use. Because this alternative will result in
contaminants remaining onsite, CERCLA Section 121(c) requires
that a Site review be conducted every 5 years.
-Capital Cost: $ 5,130,000
-Annual Costs: $ 40,600
-Present Worth Cost: $ 6,213,000
-Time to Implement: 12 months
Compliance with ARARs
Major ARARs that will be met under this alternative include:
1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements ,
25 PA Code, Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulations in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2.
3) The removal of sediments from Nesquehoning and Bear
Creeks will comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.).
This activity will also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania waste pile requirements set
forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
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the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or this
alternative, specifically, the movement of contaminants within an
area of contamination (AOC) for consolidation purposes during
remedial activities. Given the widespread surface and shallow
surface contamination at the Site, the entire Site may be
considered an AOC with respect to LDRs. Movement within or
consolidation of contaminants within the AOC would not constitute
placement, therefore LDRs are not applicable or appropriate.
Under Alternative 3, chemical specific ARARs pertaining to
groundwater, such as the Safe Drinking Water Act (Maximum
Contaminant Levels (MCLs), Maximum Contaminant Level Goals
(MCLGs), Secondary Maximum Contaminant Levels (SMCLs)), standards
would not be met in the near term. This alternative would not
comply with PADER's Ground Water Quality Protection Strategy
which prohibits continued groundwater quality degradation, since
the contaminated soils and wastes will remain onsite.
4. Alternative 4 - Soil Capping/Resource Recovery/Landfill
Closure/Decontaminate Buildings. Alternative 4 consists of a cap
over contaminated soils, transport of battery casings and certain
waste pile/byproduct materials (iron oxide, sump sediments, and
dust) to an offsite lead smelter for resource recovery, closure
of the onsite landfill in accordance with the federally
authorized Pennsylvania hazardous waste requirements, and
treatment of contaminated stormwater, landfill leachate, and
decontamination fluids in the onsite treatment plant prior to
discharge to Nesquehoning Creek under the substantive
requirements of an NPDES permit. Except for the resource
recovery process, all activities associated with this alternative
are described under Alternative 3.
Under this alternative, approximately 13,000 cubic yards of
plastic and rubber battery casings, 15 cubic yards of sump
sediments, 23 cubic yards of iron oxide, and 0.5 cubic yards of
dust from onsite buildings would be transported to an offsite
secondary lead smelter. These materials would be processed
through the smelter's reverberatory and/or blast furnaces to
recover lead and/or to serve as a supplementary fuel source. The
battery casings may have up to 18,000 BTUs per pound and were
found to contain lead at percentage levels from 1 to 10 percent.
This process will operate by substituting a fraction of the
normal feed material to the smelter's furnaces with the battery
wastes from the Tonolli Site. The net result will be the
detoxification of these materials, while providing a viable
product, reclaimed lead. The smelting facility is subject to a
RCRA permit for the storage and disposal of hazardous wastes and
a Clean Air Act permit regulating air emissions. Because this
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alternative will result in contaminants remaining onsite, CERCLA
Section 121(c) requires that a Site review be conducted every 5
years.
- Capital Cost: $ 8,290,000
- Annual Costs: $ 41,600
- Present Worth Cost: $ 9,200,000
- Time to Implement: 18 months
Compliance with ARARs
Major ARARs that will be met under this alternative include:
1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements ,
25 PA Code Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulatons in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2. In addition, the secondary lead smelting operation will
comply with- all applicable air emission requirements in
accordance with 25 PA Code Sections 123.11 - 13 (particulate
matter emissions), 25 PA Code Sections 123.21-22 (sulfur compound
emissions), 25 PA Code Section 123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
sulfur dioxide emissions);
3) The removal of sediments from Nesquehoning and Bear
Creeks would comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.).
This activity would also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant would comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania requirements for waste piles
set forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
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7) The transport and resource recovery of battery casings
and wastes to an offsite secondary lead smelter will comply with
25 PA Code 261.6(a), Department of Transportation (DOT) Rules for
Hazardous Materials Transport, and the federally authorized
Pennsylvania requirements for hazardous waste handling and
transportation, 25 PA Code Chapters 262 and 263.
8) The processing of battery casings at a secondary lead
smelter will be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
9) This alternative will comply with CERCLA Section
121(d)(3) and with EPA OSWER Directive #9834.11, both of which
prohibit the disposal of Superfund Site waste at a facility not
in compliance with Sections 3004 and 3005 of RCRA and all
applicable State requirements.
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or this
alternative, specifically, the movement of contaminants within an
area of contamination (AOC) for consolidation purposes during
remedial activities. Given the widespread surface and shallow
surface contamination at the Site, the entire Site may be
considered an AOC with respect to LDRs. Movement within or
consolidation of contaminants within the AOC would not constitute
placement, therefore LDRs are not applicable or appropriate.
Under Alternative 4, chemical specific ARARs pertaining to
groundwater, such as the Safe Drinking Water Act (MCLs, MCLGs,
SMCLs) standards would not be met in the near term. This
alternative would not comply with PADER's Ground Water Quality
Protection Strategy which prohibits continued groundwater quality
degradation, since the contaminated soils and wastes will remain
onsite.
5. Alternative 5 - Onsite Soil Disposal/Resource Recovery/
Landfill Closure/Decontaminate Buildings/Groundwater Treatment.
Alternative 5 differs from Alternative 4 in that all soils
containing lead greater than 1,000 mg/kg lead will be excavated
and consolidated in the onsite landfill. Battery casings, iron
oxide, sump sediments and dust will be sent offsite for resource
recovery at a secondary lead smelter. Other waste piles and
scrap materials will be consolidated into the landfill. Once
Site soils and other materials are consolidated into the
landfill, the landfill will be closed consistent with the
federally authorized Pennsylvania hazardous waste requirements.
Based on sampling and investigation completed during the RI/FS,
EPA believes that the onsite landfill is sufficiently stable to
accept additional materials (i.e., hazardous solids) generated
during the remedial action. According to historical records,
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design drawings and sampling work completed during the RI to
characterize the landfill contents and structural integrity, the
landfill has sufficient additional capacity to take approximately
49,000 cubic yards of material prior to its closure. The butyl-
rubber liner appears to be functioning as an effective barrier,
for the landfill is currently holding approximately 2 million
gallons of standing water resulting from the accumulation of
precipitation over several years. Based on these factors, EPA
believes that there will be no adverse effects from adding
additional material to the onsite landfill.
Excavated areas where contaminated soils were removed will be
sloped or backfilled with clean fill, and vegetated to provide
drainage and stability. Contaminated stormwater, landfill
leachate, and decontamination fluids would be treated during
remediation in the existing treatment system and discharged to
Nesquehoning Creek. Additional activities include the
decontamination of onsite buildings using either vacuuming or
washing, excavation of contaminated sediments from Nesquehoning
and Bear Creeks and disposal in the onsite landfill, maintenance
of the Site fence, and offsite disposal of nickel/iron batteries.
In addition to the above activities, this alternative includes
limited remedial action to address the contaminated groundwater
that is present in certain portions of the Site's overburden
aquifer. This action would include the construction of a
vertical chemical barrier (i.e., limestone filled trench) through
which the groundwater would flow prior to discharge to the
Nesquehoning Creek, and the discharge or injection of pH adjusted
water to increase the flow rate through the limestone barrier.
The barrier would be placed just north of Nesquehoning Creek and
within the Site property, extending across the area of
contaminant discharge to the Creek. A trench will be filled with
crushed limestone, and designed to form a barrier through which
all contaminated groundwater must pass before discharge to
Nesquehoning Creek. Contaminated water passing through this
barrier would rise in pH to a level that would effectively
immobilize the dissolved metals. This groundwater action would
be designed to reduce the levels of contaminants present in the
overburden aquifer to background concentrations. Gradient
controls would be designed to decrease cleanup time and prevent
infiltration of contaminants into the bedrock aquifer, which is
used for a public drinking water supply. pH adjustment of this
water will be utilized to enhance the cleanup.
This alternative also includes remedial action to address the
limited area of contaminated soils found to exist in a
residential area to the immediate west of the Tonolli property
boundary. This action includes excavation of soils containing
greater than 500 mg/kg lead, collection of confirmatory samples,
and backfill with clean fill and topsoil. Excavated soils would
be consolidated in the onsite landfill prior to its closure. The
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residential area requiring this action is contiguous with the
extent of soil contamination found on the Tonolli Site property.
Because this alternative will result in contaminants remaining
onsite, CERCLA Section 121(c) requires that a Site review be
conducted every 5 years.
- Capital Cost: $ 11,290,000
- Annual Cost: $ 35,600
- Present Worth Cost: $ 12,310,000
- Time to Implement: 20 months
Compliance with ARARs
Major ARARs that will be met under this alternative include:
1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements ,
25 PA Code Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulatons in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2. In addition, the secondary lead smelting operation will
comply with all applicable air emission requirements in
accordance with 25 PA Code Sections 123.11 - 13 (particulate
matter emissions), 25 PA Code Sections 123.21-22 (sulfur compound
emissions), 25 PA Code Section 123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
sulfur dioxide emissions);
3) The removal of sediments from Nesquehoning and Bear
Creeks would comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.).
This activity would also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania waste pile requirements set
forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
49
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the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
7) The transport and resource recovery of battery casings
and wastes to an offsite secondary lead smelter will comply with
25 PA Code 261.6(a), Department of Transportation (DOT) Rules for
Hazardous Materials Transport, and the federally authorized
Pennsylvania requirements for hazardous waste handling and
transportation, 25 PA Code Chapters 262 and 263.
8) The processing of battery casings at a secondary lead
smelter will be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
9) This alternative will comply with CERCLA Section
121(d)(3) and with EPA OSWER Directive #9834.11, both of which
prohibit the disposal of Superfund Site waste at a facility not
in compliance with Sections 3004 and 3005 of RCRA and all
applicable State requirements.
10) Groundwater flushing activities will comply with
applicable portions of regulations concerning underground
injection wells established under the Safe Drinking Water Act, 40
CFR Parts 144 through 146, and administered under 40 CFR 147,
Subpart NN.
11) Groundwater remediation activities will comply with
applicable portions of the PADER Ground Water Quality Protection
Strategy which prohibits continued groundwater degradation, and
requires remediation of groundwater to background levels (25 PA
Code Sections 264.90 to 264.100, specifically 25 PA Code Sections
264.97(i) and 264.100(a)(9).
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or this
alternative, specifically, the movement of contaminants within an
area of contamination (AOC) for consolidation purposes during
remedial activities (i.e., soils, battery waste piles, stream
sediments). Given the widespread surface and shallow surface
contamination at the Site, the entire Site may be considered an
AOC with respect to LDRs. Movement within or consolidation of
contaminants within the AOC would not constitute placement,
therefore LDRs are not applicable or appropriate.
6. Alternative 6 - Onsite Soil Treatment/Resource Recovery
/Landfill Closure/Decontaminate Buildings/Groundvater Treatment.
This alternative provides for onsite treatment of contaminated
soils and battery wastes/byproducts containing more than 1,000
mg/kg lead prior to disposal in the onsite landfill. The
landfill would be closed consistent with the federally authorized
Pennsylvania hazardous waste requirements, and the aqueous media
would be treated during construction in the existing treatment
system. All remaining activities associated with this
50
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alternative are described under Alternative 5.
Two types of treatment were considered in .this alternative; soil
washing and solidification/stabilization. Based on treatability
screenings completed during the FS for Tonolli, EPA's preferred
option for soils treatment is solidification/stabilization. The
soil washing technique is expected to be a slower process than
onsite stabilization and one which generates a hazardous residual
requiring offsite treatment and disposal. In addition, this
technique was estimated to be significantly more costly than
stabilization for onsite soils. Based on this analysis, EPA
retained the solidification/stabilization treatment method for
further consideration in remedial decision-making.
Solidification/stabilization involves excavation of soils
containing greater than 1000 mg/kg lead, and stabilization of
this material to remove the hazardous characteristics. The RI
sampling included limited TCLP tests, which confirmed that Site
soils ranging in total lead concentration from 282 mg/kg to 9,800
mg/kg exhibit hazardous characteristics for lead, as defined
under RCRA. Additional sampling and testing of Site soils (TCLP
or EP Toxicity) will be required to further define the volume of
soils to be treated via stabilization. The treatment process
involves the encapsulation of contaminated soils in cement-like
materials that have a high structural integrity. Stabilization
would convert the contaminated soils into a less soluble and less
mobile form that meets the treatment requirements of RCRA Land
Disposal Restrictions. The stabilized soils would be placed in
the onsite landfill prior to its closure.
The remaining activities under this alternative include the
offsite resource recovery of approximately 13,000 cubic yards of
battery casings and wastes, the groundwater treatment activities
including injection of pH adjusted fluids and/or a limestone
barrier, remediation of contaminated soils found on the
residential property to the immediate west of the Tonolli
property boundary, operation of the existing treatment plant,
maintenance of the Site fence, decontamination of the onsite
buildings, and offsite disposal of the nickel/iron batteries.
Because this alternative will result in contaminants remaining
onsite, CERCLA Section 121 (c) requires that a Site review be
conducted every 5 years.
- Capital Cost: $ 22,945,000
- Annual Cost: $ 35,300
- Present Worth Cost: $ 24,179,000
- Time to implement: 24 months
Compliance with ARARs
Major ARARs that will be met under this alternative include:
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1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements,
25 PA Code Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulatons in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2. In addition, the secondary lead smelting operation will
comply with all applicable air emission requirements in
accordance with 25 PA Code Sections 123.11 - 13 (particulate
matter emissions), 25 PA Code Sections 123.21-22 (sulfur compound
emissions), 25 PA Code Section 123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
sulfur dioxide emissions);
3) The removal of sediments from Nesquehoning and Bear
Creeks will comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.).
This activity will also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water, Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania waste pile requirements set
forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
7) The transport and resource recovery of battery casings
and wastes to an offsite secondary lead smelter will comply with
25 PA Code 261.6(a), Department of Transportation (DOT) Rules for
Hazardous Materials Transport, and the federally authorized
Pennsylvania requirements for hazardous waste handling and
transportation, 25 PA Code Chapters 262 and 263.
8) The processing of battery casings at a secondary lead
smelter will be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
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9) This alternative will comply with CERCLA Section
121(d)(3) and with EPA OSWER Directive #9834.11, both of which
prohibit the disposal of Superfund Site waste at a facility not
in compliance with Sections 3004 and 3005 of RCRA and all
applicable State requirements.
10) Groundwater flushing activities will comply with
applicable portions of regulations concerning underground
injection wells established under the Safe Drinking Water Act, 40
CFR Parts 144 through 146, and administered under 40 CFR 147,
Subpart NN.
11) Groundwater remediation activities will comply with
applicable portions of the PADER Ground Water Quality Protection
Strategy which prohibits continued groundwater degradation, and
requires remediation of groundwater to background levels (25 PA
Code Sections 264.90 to 264.100, specifically 25 PA Code Sections
264.97(i) and 264.100(a)(9).
12) The handling and onsite treatment of soils and certain
battery wastes will comply with the federally authorized
Pennsylvania requirements for generators of hazardous waste, 25
PA Code Chapter 262.
13) Treatment of soils via stabilization will comply with
the handling, transportation and other standards of the federally
authorized Pennsylvania requirements, 25 PA Code Chapters 262,
263, and 264.
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or this
alternative, specifically, the movement of contaminants within an
area of contamination (AOC) for consolidation purposes during
remedial activities (i.e., soils, battery waste piles, stream
sediments). Given the widespread surface and shallow surface •
contamination at the Site, the entire Site may be considered an
AOC with respect to LDRs. Movement within or consolidation of
contaminants within the AOC would not constitute placement,
therefore LDRs are not applicable or appropriate.
The State's Residual Waste Management Regulations, 25 PA Code
Sections 287.1-299.232, are not considered to be applicable to
the Tonolli Site or to the actions required by this ROD.
Specifically, 25 PA Code Section 287.1 describes residual waste
as certain waste, ... if it is not hazardous. Accordingly, EPA
has determined that these regulations are not applicable to sites
that are subject to regulations for the management or handling of
hazardous waste. The waste at the Tonolli Site is hazardous and
therefore, outside of the scope of the regulations. The residual
waste regulations were drafted to prevent harm to the public or
environment that may result from the failure to treat waste that
is potentially harmful, but not "hazardous", by definition, and
therefore not regulated under hazardous waste regulations. The
lead-contaminated soils at levels exceeding 1000 ppm will be
consolidated (before or after treatment) into the onsite
landfill. This landfill will then be closed in accordance with
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the federally authorized Pennsylvania hazardous waste
requirements. Since the PA residual waste regulations pertain
to, "Garbage, refuse, other discarded material or other waste...
if it is not hazardous", these regulations are neither
appropriate or applicable to the hazardous materials at the
Tonolli Site. See PA Code Section 287.1.
7. Alternative 7 - Offsite Soil Treatment Ł Disposal/Resource
Recovery/Landfill Closure/Decontaminate Buildings/Groundwater
treatment. This alternative differs from Alternative 6 in that
soils containing greater than 100Q rag/kg lead and certain battery
wastes would be shipped offsite to a permitted hazardous waste
disposal facility for solidification/stabilization prior to land
disposal. Limited regrading and surface water runoff control
measures would be implemented around all excavated areas. The
landfill would be closed consistent with the federally authorized
Pennsylvania hazardous waste requirements, and the aqueous media
would be treated during construction in the existing treatment
system.
The remaining activities under this alternative include the
offsite resource recovery of approximately 13,000 cubic yards of
battery casings and wastes, the groundwater treatment activities
including injection of pH adjusted fluids and/or a limestone
barrier, remediation of contaminated soils found on the
residential property to the immediate west of the Tonolli
property boundary, operation of the existing treatment plant,
maintenance of the Site fence, decontamination of the onsite
buildings, and offsite disposal of the nickel/iron batteries.
Because this alternative will result in contaminants remaining
onsite, CERCLA Section 121(c) requires that a Site review be
conducted every 5 years.
- Capital Cost: $ 42,750,000
- Annual Cost: $ 35,300
- Present Worth Cost: $43,760,000
- Time to Implement: 20 months
Compliance with ARARs
Major ARARs that will be met under this alternative include:
1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements ,
25 PA Code Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulatons in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
54
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Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2. In addition, the secondary lead smelting operation will
comply with all applicable air emission requirements in
accordance with 25 PA Code Sections 123.11 - 13 (particulate
matter emissions), 25 PA Code Sections 123.21-22 (sulfur compound
emissions), 25 PA Code Section 123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
sulfur dioxide emissions);
3) The removal of sediments from Nesquehoning and Bear
Creeks will comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.) .
This activity will also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania requirements for waste piles
set forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
7) The transport and resource recovery of battery casings
and wastes to an offsite secondary lead smelter will comply with
25 PA Code 261.6(a), Department of Transportation (DOT) Rules for
Hazardous Materials Transport, and the federally authorized
Pennsylvania requirements for hazardous waste handling and
transportation, 25 PA Code Chapters 262 and 263.
8) The processing of battery casings at a secondary lead
smelter will be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
9) This alternative will comply with CERCLA Section
121(d)(3) and with EPA OSWER Directive #9834.11, both of which
prohibit the disposal of Superfund Site waste at a facility not
in compliance with Sections 3004 and 3005 of RCRA and all
applicable State requirements.
10) Groundwater flushing activities will comply with
applicable portions of regulations concerning underground
injection wells established under the Safe Drinking Water Act, 40
CFR Parts 144 through 146, and administered under 40 CFR 147,
55
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Subpart NN.
11) Groundwater remediation activities will comply with
applicable portions of the PADER Ground Water Quality Protection
Strategy which prohibits continued groundwater degradation, and
requires remediation of groundwater to background levels (25 PA
Code Sections 264.90 to 264.100, specifically 25 PA Code Sections
264.97(i) and 264.100(a)(9).
12) The handling and offsite treatment of soils and certain
battery wastes would comply with the requirements set forth in
the federally authorized Pennsylvania requirements for generators
of hazardous waste, 25 PA Code Chapter 262.
13) Treatment of soils via stabilization will comply with
the handling, transportation and other standards of the federally
authorized Pennsylvania requirements, 25 PA Code Chapters 262,
263, and 264.
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or this
alternative, specifically, the movement of contaminants within an
area of contamination (AOC) for consolidation purposes during
remedial activities (i.e., soils, battery waste piles, stream
sediments). Given the widespread surface and shallow surface
contamination at the Site, the entire Site may be considered an
AOC with respect to LDRs. Movement within or consolidation of
contaminants within the AOC would not constitute placement,
therefore LDRs are not applicable or appropriate.
VZZZ. COMPARATIVE ANALYSIS OF ALTERNATIVES
The seven remedial action alternatives described above were
evaluated under the nine evaluation criteria as set forth in the
NCP 40 CFR Section 300.430(e)(9). These nine criteria are
organized according to the groups listed 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.
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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.
A. overall Protection of Human Health and the Environment.
Overall protection of human health and the environment addresses
whether each alternative provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or controlled,
through treatment, engineering controls, and/or institutional
controls.
Alternatives 5, 6 and 7 provide the highest degree of protection
of human health and the environment since contaminated soils and
battery wastes are consolidated and/or treated either onsite or
offsite, prior to disposal. These alternatives also include
groundwater remedial action, excavation of contaminated
sediments, and continued operation of the onsite stormwater
treatment plant. Alternatives 5, 6 and 7 would thereby
eliminate, reduce, and/or control risks posed via all exposure
pathways for the Site.
Alternatives 3 and 4 are also considered to be protective of
human health by requiring the capping of contaminated soils and
battery wastes, however future excavation at the Site may result
in unnecessary exposure to contaminants remaining onsite.
Alternative 2 also provides some protection of human health via
the use of institutional controls; however, this would be assured
only if such controls are implemented and enforced properly over
the long term. No,groundwater protection is offered in
Alternatives 2, 3„ and 4, and thus they are not considered to be
protective of the environment.
Alternative 1, the No Action/No Further Action alternative, does
not eliminate, reduce or control any of the exposure pathways,
and it is therefor^ not protective of human health or the
environment and will not be considered further in this analysis.
B. Compliance with ARARs.
Compliance with ARARs addresses whether a remedy will meet all of
the applicable or relevant and appropriate requirements of other
Federal and state environmental statutes or provides a basis for
invoking a waiver.
Alternatives 6 and 7 would attain all their respective Federal
and state ARARs. Alternative 5 would also comply with all ARARs.
Alternatives 2, 3, and 4 do not comply with federal groundwater
cleanup ARARs (i.e., Safe Drinking Water Act MCLs, MCLGs, SMCLs),
or applicable portions of the PADER Ground Water Quality
Protection Strategy which prohibits continued groundwater quality
57
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degradation, and requires remediation of groundwater to
background quality. Since Alternatives 2, 3, and 4 will not
comply with groundwater cleanup ARARs, these alternatives will
not be considered further in this analysis.
Major ARARS identified for this Site include:
1) The closure of the onsite landfill will comply with the
federally authorized Pennsylvania hazardous waste requirements,
25 PA Code Chapter 264;
2) Fugitive dust emissions generated during remedial
activities will comply with the National Ambient Air Quality
Standards (NAAQS) set forth at 40 CFR Part 50 and 25 PA Code
Sections 131.2 and 131.3. Such emissions will comply with
regulations in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
Sections 52.2020 - 52.2023 and in 25 PA Code Sections 123.1 and
123.2. In addition, the secondary lead smelting operation will
comply with all applicable air emission requirements in
accordance with 25 PA Code Sections 123.11 - 13 (particulate
matter emissions), 25 PA Code Sections 123.21-22 (sulfur compound
emissions), 25 PA Code Section 123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
sulfur dioxide emissions);
3) The removal of sediments from Nesquehoning and Bear
Creeks will comply with the requirements of the Dam Safety and
Encroachment Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et
seq., and specifically Chapter 105 (25 PA Code 105.1 et seq.).
This activity will also comply with the requirements of the PA
Clean Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
4) Operation of the onsite treatment plant will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
9.3.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
5) The handling and onsite consolidation/disposal of scrap
materials and drums containing plastic will comply with the
federally authorized Pennsylvania requirements for waste piles
set forth in 25 PA Code Chapter 264.
6) The regrading and capping of materials will comply with
the requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
7) The transport and resource recovery of battery casings
and wastes to an offsite secondary lead smelter will comply with
25 PA Code 261.6(a), Department of Transportation (DOT) Rules for
Hazardous Materials Transport, and the federally authorized
Pennsylvania requirements for hazardous waste handling and
transportation, 25 PA Code Chapters 262 and 263.
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8) The processing of battery casings at a secondary lead
smelter will be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
9) The resource recovery and offsite disposal activities
will comply with CERCLA Section 121(d) (3) and with EPA OSWER
Directive #9834.11, both of which prohibit the disposal of
Superfund Site waste at a facility not in compliance with
Sections 3004 and 3005 of RCRA and all applicable State
requirements.
10) Groundwater flushing activities will comply with
applicable portions of regulations concerning underground
injection wells established under the Safe Drinking Water Act, 40
CFR Parts 144 through 146, and administered under 40 CFR 147,
Subpart NN.
11) Groundwater remediation activities will comply with
applicable portions of the PADER Ground Water Quality Protection
Strategy which prohibits continued groundwater degradation, and
requires remediation of groundwater to background levels (25 PA
Code Sections 264.90 to 264.100, specifically 25 PA Code Sections
264.97(i) and 264.100(a)(9).
12) The handling and onsite treatment of soils and certain
battery wastes will comply with the federally authorized
Pennsylvania requirements for generators of hazardous waste, 25
PA Code Chapter 262.
13) Treatment of soils via stabilization will comply with
the handling, transportation and other standards of the federally
authorized Pennsylvania requirements, 25 PA Code Chapters 262,
263, and 264.
C. Long-term Effectiveness and Permanence.
Long-term effectiveness and permanence refers to expected
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup levels have been met. This criterion includes the
consideration of residual risk and the adequacy and reliability
of controls.
Alternatives 5, 6 and 7 are the most effective and permanent
remedies over the long term. Of these, Alternatives 6 and 7
provide the greatest reduction of the overall risk posed by
residual contamination (i.e., any contaminants remaining onsite
after remediation). The on- or offsite treatment of soils prior
to disposal will significantly reduce the threat posed by
contaminated materials by reducing the mobility of the
contaminants. However, since soils will be consolidated in the
onsite landfill in either a treated (i.e., stabilized) or
untreated form, the key consideration is the long-term
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effectiveness and permanence of the onsite landfill as a
containment unit.
Based on the evaluation of the onsite landfill during the RI, EPA
believes that the existing butyl-rubber liner remains intact, and
once the approximately 2 million gallons of standing water are
removed, should continue to remain intact, and serve as an
effective barrier from any leaching of the landfill contents into
the subsurface. Added protection is provided through the upgrade
of the landfill's leachate collection system, the postclosure
landfill monitoring, and the implementation of the groundwater
remedy. The groundwater action requires the construction of a
limestone barrier that will be designed to intersect any
contaminated overburden groundwater emanating from the Site.
This barrier would also intersect any leachate that might migrate
from the landfill into the overburden groundwater. EPA believes
that the combination of remedial activities described above will
serve to insure the long-term effectiveness of the landfill's use
and closure.
Alternative 5 also provides for long-term effectiveness and
permanence, but used containment instead of treatment to do so.
The consolidation of soils prior to closure of the onsite
landfill would reduce the contaminated area at the Site to one-
third of its original extent. Closure of the onsite landfill
using a multilayer cap is a highly reliable containment method
for preventing direct contact with the contents and significantly
reducing or eliminating any leaching of landfill contaminants
into deeper soils or groundwater beneath the landfill. Under
this alternative, the soils would remain untreated prior to
consolidation, and thus the proper construction and maintenance
of the landfill cap and monitoring network is critical to
preventing future exposure. The engineering controls (i.e.,
landfill closure) required for this alternative are highly
reliable, and will provide for long-term effectiveness and
permanence, as long as they are properly maintained.
D. Reduction of Toxicity, Mobility & Volume Through Treatment.
Reduction of toxicity, mobility, or volume through treatment
refers to the anticipated performance of the treatment
technologies a remedy may employ.
Alternatives 6 and 7 provide the greatest reduction in toxicity
and mobility because they include the treatment of approximately
39,000 cubic yards of contaminated soils. The stabilization
process would increase material volume by approximately 20%, but
reduce toxicity and mobility. The soil washing process was not
retained for further consideration based on the significantly
higher cost, reduced implementation time, and comparable
performance to the stabilization treatment method in meeting the
reduction of toxicity, mobility and volume through treatment
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criteria.
Alternative 5 reduces the toxicity and volume of contaminated
solids since approximately 13,000 cubic yards of battery wastes
containing the highest lead concentrations would be sent offsite
for resource recovery at a secondary lead smelter. Alternative 5
does not require treatment of contaminated soils, but instead
uses closure of the landfill in accordance with RCRA to contain
the soil contamination, therefore reducing the mobility.
E. Short-Term Effectiveness.
Short-term effectiveness refers to the period of time needed to
complete the remedy and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation of the remedy until cleanup levels are achieved.
Alternatives 5 and 7 are estimated to be implemented with the
shortest duration and least complexity. Alternative 6 utilizes
more complex technologies and treatment equipment for a longer
period of time, thereby increasing short-term risks to onsite
workers. Alternative 7 requires additional materials handling
and truck transport of approximately 39,000 cubic yards of
contaminated soils to an offsite treatment and disposal facility.
This activity would require over 3,900 trucks to leave the Site
with contaminated soils and travel to a treatment/disposal
facility, thereby increasing the chance of accident and
subsequent contact with contaminated soils.
Each alternative involves earth moving activity which would
result in the generation of dust. Thus, dust control measures
must be implemented and air monitoring must be performed to
reduce the chance of offsite migration of contaminants.
F. Implementability.
Implementability considers the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the action.
Each alternative is implementable and utilizes readily available
and reliable, technologies. Alternatives 5 and 7 are the least
complex in terms of the technical and administrative feasibility.
Alternative 5 would be the most implementable of those
alternatives incorporating media treatment.
Alternatives 5 through 7 include offsite actions which would
require administrative coordination. Alternative 6 utilizes
relatively new technologies, and field conditions might delay
completion or reduce the effectiveness of this alternative.
G. Cost.
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CERCLA requires selection of a cost-effective remedy that
protects human health and the environment and meets the other
requirements of the Statute. Project costs include all
construction and operation and maintenance costs incurred over
the life of the project. Capital costs include those
expenditures necessary to implement a remedial action.
The costs of the seven alternatives range from $ 0 to
$ 43,760,000. The degree of protection provided by the
alternatives also varies. Comparison of different levels of cost
for different levels of protectiveness and permanence of
treatment technologies is a primary decision criterion in this
evaluation.
Alternatives 6 and 7 are the highest in cost due to the use of
additional treatment technologies for soils prior to either
onsite or offsite disposal. These alternatives may also be
considered to offer a somewhat higher degree of long-term
effectiveness and permanence since they include the stabilization
of soils.
The cost of implementing Alternative 5 is lower, but reflects the
consolidation of contaminated soils in the onsite landfill
without treatment. This alternative offers approximately the
same degree of protection as Alternatives 6 and 7, due to the use
of the onsite landfill to contain either treated or untreated
soils.
H. Community Acceptance.
The July 18, 1992 Proposed Plan and July 28, 1992 public meeting
produced a small number of comments from the general public and
an extensive amount of technical comments from a local water
authority, and from a group of potentially responsible parties
(PRPs) for the Site. Responses to these comments appear in the
Responsiveness Summary section of this ROD.
I. State Acceptance.
The Commonwealth of Pennsylvania has not concurred with this
selected Remedial Action.
IX. SELECTED REMEDY
Modified Alternative 6 - Onsite Soil Treatment and
Disposal/Resource Recovery/ Landfill Closure/Deconti
Buildinas/Groundvater Treatment.
A. EPA has selected a modified version of Alternative 6 as the
remedy for the Site. This modified remedy differs from the
Preferred Alternative described in the July 18, 1992 Proposed
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Plan in the trigger level that will be used to define those soils
which pose a principal threat and that require treatment prior to
consolidation in the onsite landfill. The modified remedy also
differs from the Proposed Plan Preferred Alternative in the
estimated cost for remediation. The modified remedy combines
certain features (i.e., handling of contaminated Site soils) of
Alternative 5 with Alternative 6. This modified remedy was
selected based on EPA's consideration of new information and
extensive comments submitted during the public comment period.
This topic is discussed in Section XI of the ROD (Explanation of
Significant Changes).
EPA's selected remedy, Modified Alternative 6, requires active
treatment, or onsite stabilization for soils defined as a
principal threat (i.e., soils containing greater than 10,000
mg/kg lead - one order of magnitude greater than the cleanup
level), prior to the consolidation of treated soils in the onsite
landfill. Passive treatment, including the addition of
agricultural limestone to the landfill after consolidation of
soils posing a lower level threat (i.e., soils containing lead at
levels between 1,000 mg/kg and 10,000 mg/kg), will provide in-
situ pH adjustment to protect from potential future leaching of
metals from the soils.
This modified approach to soils treatment provides an equivalent
level of protection and long-term effectiveness as the originally
proposed remedy, while being somewhat more cost-effective.
Modified Alternative 6 represents the best balance among the
evaluation criteria and satisfies the statutory requirements of
protectiveness, compliance with ARARs, cost effectiveness, and
the utilization of permanent solutions and treatment to the
maximum extent practicable. EPA believes that this combination
of treatment to address the principal threats and engineering
controls (i.e., containment) to address lower level threats will
effectively reduce and eliminate the potential risks posed by the
Site. The major components of the selected remedy include the
following:
1) Offsite transport and treatment of approximately 13,000 cubic
yards of battery wastes, including battery casings, iron oxide,
sump sediments, and dust via resource recovery at a secondary
lead smelter. Additional sampling and characterization of other
waste pile materials (i.e., crusher building dusts) will be
conducted to confirm whether these materials can also be treated
effectively via this process. Similarly, excavation of all
sediments and battery fragments in stormwater collection piping
and onsite sumps will be completed, and these materials will be
characterized to determine whether they can be processed via
resource recovery, or consolidated within the onsite landfill.
2) Excavation of all soils with lead contamination above 1000
n»g/kg (approximately 39,000 cubic yards), and backfill and
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grading for excavated onsite areas. Consolidation of all soils
with lead contamination ranging from 1000 mg/kg to 10,000 mg/kg
within the onsite landfill. Onsite stabilization of all soils
posing a principal threat with lead contamination above 10,000
mg/kg (approximately 7,300 cubic yards), and consolidation of
treated soils in the onsite landfill. Excavation of soils
situated to the immediate west of the property boundary
containing greater than 500 mg/kg lead, collection of
confirmatory samples, and consolidation of soils in the onsite
landfill, and backfill the area with clean soil. Additional
sampling will be completed prior to excavation to define the area
and volume of soil's potentially impacted by the Site activities
and requiring remediation.
3) Consolidation and, if necessary, treatment of approximately
2,020 cubic yards of treated sludges, approximately 250 drums of
melted plastic, and approximately 210 cubic yards of excavated
lagoon soils in the onsite landfill prior to closure. Additional
sampling will determine whether the lagoon soils and drums can be
consolidated in the onsite landfill.
4) Additional sampling and completion of bioassays for
contaminated sediments in Bear and Nesguehoning Creeks will be
completed during remedial design to develop appropriate cleanup
levels for this medium. Once an appropriate cleanup level for
sediments has been approved by EPA, in consultation with PADER,
all sediments above the approved cleanup level will be excavated
from the creek(s) and consolidated within the onsite landfill.
5) Closure of the onsite landfill in accordance with the
federally authorized Pennsylvania (RCRA) hazardous waste
requirements, including; removal of standing water from the
landfill, upgrade of the leachate collection system,
consolidation of materials generated during the remedial action
within the landfill to meet the minimum grading requirements,
application of a properly designed layer of agricultural
limestone, and cover of the landfill with a cap having a
permeability of less than IxlO"7 cm/sec. The addition of a layer
of crushed or pulverized limestone shall be designed to prevent
potential future leaching of lead from the consolidated soils to
the onsite landfill. A treatability study will be completed to
evaluate the optimal application rate of agricultural limestone
to provide the maximum pH buffering capacity to the consolidated
soils for this in-situ passive treatment method. Post-closure
care of the landfill will include maintenance of the cap and
dewatering system, and construction and routine sampling of a
groundwater monitoring network for a 30 year period.
6) Approximately 2 million gallons of landfill leachate (standing
water), decontamination fluids generated during remediation, and
approximately 16 million gallons per year of contaminated
stormwater will be collected and treated using the existing
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treatment system prior to discharge to Nesquehoning Creek.
Monitoring data collected from the treatment system will be used
by EPA in consultation with the State to determine appropriate
discharge levels in compliance with the substantive requirements
of the NPDES program.
7) Treatment of contaminated overburden groundwater via
construction of a vertical chemical barrier (i.e., limestone
trench), with possible injection of pH adjusted water to enhance
groundwater flow rates. Gradient controls will be used to
prevent infiltration of contaminants into the bedrock aquifer.
Monitoring of the effectiveness of the vertical chemical barrier
and/or injection of pH adjusted fluids, and monitoring of the
bedrock aquifer beneath the Site will be completed.
8) Decontamination of Site buildings via either vacuuming or
washing, including dismantling of non-structural components and
removal of equipment and debris which may inhibit thorough
decontamination.
9) Offsite disposal of drained nickel/iron batteries.
10) Maintenance of Site fence and Site security, as needed, to
limit trespassing and access to the Site during construction.
11) Air monitoring during onsite activity.
12) During the course of the remedial action, and the excavation
and construction phase, measures will be taken to prevent runoff
of surface waters, sediments, and/or contaminated soils or
battery wastes from entering Nesquehoning or Bear Creeks.
13) Evaluation of the onsite underground storage tanks will be
completed during remedial design. Any tanks that may impede the
completion of the selected remedy, specifically the excavation of
contaminated soils, will be addressed during remediation.
14) Institutional controls, in the form of deed restrictions will
be placed on the deeds to the parcel(s) that comprise the onsite
landfill to limit the use of this land and prevent excavation or
construction on the capped and closed landfill. Additional deed
restrictions will be implemented to limit the use of the Site to
industrial use only.
Some changes may be made to the remedy as a result of the
remedial design and construction process. Such changes, in
general, reflect modifications resulting from the engineering
design process. If required, EPA may issue an Explanation of
Significant Differences (BSD) or an amendment to the ROD to
document any major changes in the remedy.
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B. PERFORMANCE STANDARDS
(1) Resource Recovery of Battery Wastes
The entire volume of battery casings presently stored on the
surface of the Site (approximately 13,000 cubic yards) shall be
transported to a secondary lead smelter for treatment via
resource recovery. Approximately 23 cubic yards of iron oxide,
15 cubic yards of sediments excavated from the onsite drainage
network (sumps), and approximately 0.5 cubic yards of dust
collected during decontamination of onsite buildings will also be
transported to the offsite smelter for processing via resource
recovery. Additional sampling and characterization of other
waste pile materials (i.e., crusher building dusts) will be
conducted to confirm whether these materials can also be treated
effectively via this process. All sediments and battery
fragments in stormwater collection piping and onsite sumps shall
be excavated, and these materials will be characterized to
determine whether they can be processed via resource recovery, or
consolidated within the onsite landfill. The performance
standard for the characterization and processing shall be that
the material will be tested for its lead content and, if
feasible, taken to the resource recovery facility for processing.
The potential for use of rail transport for the resource recovery
action shall be evaluated during remedial design. The final
transport method to be used for this portion of the remedial
action is subject to EPA approval, in consultation with PADER
prior to implementation.
If it is determined that rail transport is not viable, the
materials transported offsite shall be placed in trucks lined
with plastic and covered with tarps prior to leaving the Site to
prevent wind dispersion of the materials. All vehicles used to
transport the contaminated battery casings will be washed down
before leaving the Site to minimize the spread of contamination
to presently non-contaminated areas away from the Site.
(2) Excavation, Treatment and Consolidation of Soils
All soils containing greater than 1000 mg/kg lead (approximately
39,000 cubic yards) shall be excavated from onsite areas.
Additional sampling shall be completed to define the areal extent
and volume of soils exceeding the cleanup level and the target
level for treatment. Soil excavation will continue until all
soils over the cleanup level of 1000 mg/kg have been removed.
Those soils identified as a principal threat, that is exceeding
10,000 mg/kg of lead, shall be treated onsite using
stabilization. Stabilization requires treatment with a
cementitious or pozzolanic reagent mixture developed specifically
to bind the metal constituents within the stabilizer matrix.
Treatability testing of the stabilized matrix will be performed
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to determine the stabilizing mixture needed to pass the toxicity
test of less than 5 mg/liter of lead. After being treated to
pass the toxicity test, the stabilized soils will be consolidated
in the onsite landfill.
Remaining soils (i.e., those soils containing lead at
concentrations between 1000 mg/kg and 10,000 nig/kg) will be
consolidated in the onsite landfill prior to its closure. Post
excavation sampling will be completed to confirm that soil
cleanup levels have been met.
Additional sampling shall be conducted on residential property to
the immediate west of the property boundary to confirm the extent
of Site-related contamination. All soils containing greater than
500 mg/kg lead in the residential area shall be excavated and
consolidated in the onsite landfill with the remaining untreated
soils. The soils will be handled in a manner consistent with
Standard #2 above. Post excavation sampling will be completed to
confirm that soil cleanup levels have been met. All excavated
areas will be backfilled with clean fill material and regraded to
confirm with the original topography of the property. Filled
areas will also be vegetated.
(3) Miscellaneous Solids and Debris
Approximately 2,020 cubic yards of treated sludges presently
stored in the onsite smelter building shall be consolidated in
the onsite landfill prior to its closure. Approximately 250
drums of melted plastic remaining from Tonolli's recycling
operation and approximately 210 cubic yards of lagoon soils
excavated during EPA's previous removal action will also be
consolidated within the onsite landfill prior to closure.
Additional sampling shall be completed to determine whether the
lagoon soils pose a principal threat, that is a lead
concentration greater than 10,000 mg/kg. If the lagoon soils
contain greater than 10,000 mg/kg lead, they will be treated
onsite via stabilization prior to consolidation within the
landfill. If the debris materials (i.e., drums) pass the TCLP or
EP Toxicity test for lead, they may be disposed of in an offsite
landfill. If the debris materials fail the TCLP or toxicity
test, the drums will be either transported offsite for treatment
and disposal in accordance with LOR standards, or they will be
consolidated in the onsite landfill.
(4) Sampling and Excavation of Sediments
Additional sampling and characterization of impacted sediments
and surface water in Bear and Nesquehoning Creeks shall be
completed during remedial design. Bioassays, preferably using
Hyallela azteca. shall be completed to determine an appropriate
cleanup level for creek sediments. Once a sediment cleanup level
is established, subject to the approval of EPA in consultation
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with FADER, all sediments exceeding this level will be excavated
froic Bear and Nesgushoning Creeks and consolidated in the onsite
landfill. Sediments will be removed by either hand excavation or
by using hydraulic vacuums.
(5) Closure of Onsite Landfill
The onsite landfill shall be closed in accordance with the
federally authorized Pennsylvania RCRA hazardous waste
requirements. The capping and closure of the landfill shall
include pumping the standing water out of the landfill (treating
in onsite treatment system - see Standard #6), removing all
materials present within the existing manholes and upgrading the
landfill manholes to be used as future leachate collection
points, placing fill material to meet minimum grading
requirements, and placing a very low permeability multilayer
synthetic cap on the landfill. The landfill cap shall be
designed to have a permeability of less than IxlO"7 cm/second.
In lieu of fill material, the treated (stabilized) and untreated
soils, and debris discussed under items 2 and 3 above may be
consolidated in the landfill prior to capping. In addition, a
layer of crushed or pulverized limestone shall be spread and
tilled over the clean fill layer placed on the landfill during
closure. A treatability study will be completed in remedial
design to evaluate the optimal application rate of agricultural
limestone to provide maximum pH buffering capacity to the
consolidated materials.
j&
Post-closure care shall include routine inspection and
maintenance of the cap, the dewatering system and the leachate
collection system for a 30 year period. Maintenance shall
include repairs to'the landfill cap as necessary to maintain the
permeability standard, correct any breaches, or any effects of
settling, subsidence or erosion, and the cultivation of natural
vegetation on the cap to prevent erosion. An operation and
maintenance plan for the landfill cap will be required, and is
subject to the approval of EPA in consultation with PADER.
Long-term groundwater monitoring, as required by the federally
authorized Pennsylvania RCRA requirements for landfill closure
(25 PA Code Chapter 264), and as set forth in a landfill
monitoring plan is subject to the approval of EPA in consultation
with PADER. A monitoring network for the landfill shall be
constructed and maintained for a period of 30 years. Sampling of
the landfill monitoring wells will occur quarterly for the first
two years until a database is built and then semi-annually
thereafter.
(6) Operation of Stormwater Treatment System
The existing Stormwater treatment system shall be operated and
maintained to effectively reduce contaminant levels prior to the
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discharge of treated water to Nesquehoning Creek. Approximately
2 million gallons of landfill leachate (standing water),
decontamination fluids generated during remediation, and
approximately 16 million gallons per year of contaminated
stormwater will be collected and treated using the existing
system. Monitoring data collected from the treatment system over
the past year will be used by EPA, in consultation with the State
to determine acceptable discharge levels in accordance with the
substantive requirements of the NPDES program.
The treatment plant will continue to be operated and maintained
for the duration of the remediation. From the monitoring data,
EPA, in consultation with PADER will determine a clean up level
for the storm water influent (i.e., surface water flowing across
Site into treatment system). Semi-annual monitoring of the storm
water influent shall be performed. EPA, in consultation with
PADER, will review the semi-annual monitoring to determine if
further treatment of storm water influent will be required. If,
at any time, the monitoring confirms that the clean up levels of
the influent have been attained, and remain at the required
levels for eight consecutive quarters, treatment may be
suspended.
(7) Shallow Groundwater Remediation
The overburden groundwater shall be remediated to reduce the
levels of contaminants and to prevent the migration of
contaminants to the deep bedrock aquifer, which is used as a
drinking water supply. An evaluation of the most effective and
timely method for achieving the groundwater cleanup levels will
be conducted during remedial design. An appropriate method to
achieve the cleanup levels is subject to the approval of EPA, in
consultation with PADER. The groundwater remediation shall
achieve the background levels for the contaminants in the
overburden groundwater, which is the performance standard. This
requirement is set forth in the PA Hazardous Waste Management
Regulations, where it is required that all groundwater must be
remediated to "background" quality as specified by 25 PA Code
Sections 264.90-264.100, specifically PA Code Sections 264.97(i)
and (j) and Section 264.lOO(a)(9).
The background concentrations for each contaminant of concern
shall be established in accordance with the procedures for
groundwater monitoring outlined in 25 PA Code Section 264.97
before groundwater treatment begins. The background
concentrations to be established during remedial design are
subject to the approval of EPA, in consultation with PADER.
A vertical chemical (limestone) barrier shall be constructed at a
point through which all potential Site affected groundwater must
pass before discharge to the Nesquehoning Creek. Additional
details will be required to be developed during remedial design
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to establish proper criteria for determining the optimal depth,
thickness, and length of this barrier. The selected method for
achieving the cleanup levels for groundwater is subject to the
approval of EPA, in consultation with FADER. On a preliminary
basis, it is anticipated that the groundwater remediation will
include the construction of a vertical limestone barrier
extending for approximately 1,100 feet from onsite monitoring
well 16 to monitoring well 15. The barrier will extend eastward
to a point that would intersect groundwater flowing under the
onsite landfill. The barrier will consist of permeable crushed
limestone placed in an approximately 20 foot trench that would
extend from approximately 10 feet below the water table to
approximately two feet above the water table.
In order to decrease the time for all impacted aquifer water to
be treated by the limestone barrier, injection, or flushing of pH
adjusted fluids into wells situated upgradient from the barrier
shall be considered. Additional evaluation of this process, and
collection of pertinent groundwater data shall be conducted
during remedial design to consider the overall effectiveness of
implementing both approaches for shallow groundwater remediation.
The selected method or combination of remedial methods for the
groundwater treatment is subject to the approval of EPA, in
consultation with PADER.
Monitoring of the effectiveness of the groundwater treatment
method(s) shall be conducted by constructing monitoring wells
onsite and in offsite areas, downgradient from the vertical
barrier and Nesguehoning Creek. This monitoring network will be
capable of determining whether the limestone barrier is
effectively removing Site-related contaminants from the shallow
groundwater. An operation and maintenance plan for the
groundwater treatment method and monitoring network shall be
required. The performance of the groundwater treatment system
shall be carefully monitored on a regular basis and the system
may be modified, as determined by EPA, based upon the performance
data collected during operation. If, at any time, sampling
confirms that background levels have been attained through the
overburden aquifer and remain at the required levels for twelve
consecutive quarters, monitoring may be suspended.
It may become apparent during implementation or operation of the
groundwater treatment system, that contaminant levels have ceased
to decline and are remaining constant at levels higher than the
Performance Standards over some portion of the Site. If EPA and
the Commonwealth of Pennsylvania determine that implementation of
the selected remedy demonstrates, in corroboration with
hydrogeological and chemical evidence, that it will be
technically impracticable to achieve and maintain the Performance
Standards throughout the entire area of groundwater
contamination, EPA and the PADER may require that any or all of
the following measures be taken, as further modifications of the
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existing system:
- Long-term gradient control nay be provided by low level
pumping, as a containment measure;
- Chemical-specific ARARs may be waived for those portions
of the aquifer for which EPA and PADER determine that it is
technically impracticable to achieve further contaminant
reduction;
- Institutional controls may be provided to restrict access
to those portions of the aquifer where contaminants remain above
Performance Standards; and
- Remedial technologies for groundwater restoration may be
re-evaluated.
The decision to invoke any or all of these measures may be made
during the 5-year reviews of the remedial action. If such a
decision is made, EPA will amend the ROD or issue an Explanation
of Significant Differences.
(8) Decontamination of Onsite Buildings
Decontamination of Site buildings via either vacuuming or
washing, including dismantling of non-structural components and
removal of equipment and debris which may inhibit thorough
decontamination. If the buildings are dismantled, the debris
material will be managed in accordance with RCRA.
(9) Offsite Disposal of Drained Nickel/Iron Batteries
The 10 1,000-pound nickel/iron batteries shall be transported
from the Site to an offsite landfill for disposal.
(10) Site Fence
The Site perimeter fence and security shall be maintained to
prevent trespassing and access to the Site during construction.
The fence shall be maintained for 30 years.
(11) Air Monitoring
Air monitoring shall be completed during onsite activity. The
air monitoring shall be designed to monitor the contaminants of
concern for the Site and total suspended particulates. The air
monitoring shall assure the health and safety of the workers and
nearby residents from exposure to site and remediation generated
contaminants.
(12) Surface Water Runoff Controls
During the course of the remedial action, and the excavation and
construction phase, measures shall be taken to prevent runoff of
surface waters, sediments, and/or contaminated soils or battery
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wastes from entering Nesquehoning or Bear Creeks. Runoff control
measures shall effectively collect any water, dust, or other
solids generated during decontamination or remedial activities in
such a way as to prevent offsite migration of these materials.
(13) Underground Storage Tanks
Additional evaluation of the onsite underground storage tanks
will be completed during remedial design. Any tanks that may
impede the completion of the selected remedy, specifically the
excavation of contaminated soils, will be addressed during
remediation.
(14) Deed Restrictions
Restrictions shall be placed in the deed to the Site to prohibit
excavation or construction of any kind on the approximate 10 acre
area comprised by the onsite landfill. Additional deed
restrictions will be implemented to limit the use of the Site to
industrial use only.
ZZ. STATUTORY DETERMINATIONS
Section 121 of CERCLA requires that the selected remedy:
-be protective of human health and the environment;
-comply with ARARs;
-be cost-effective;
-utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
-address whether the preference for treatment as a
principal element is satisfied.
A description of how the selected remedy satisfies each of the
above statutory requirements is provided below.
Protection of Human Health and the Environment.
The selected remedy for the Site will be protective of human
health and the environment by reducing the principal threats
posed by the Site. The selected remedy uses treatment
technologies to address the principal threats, engineering
controls to contain the lower level threats, and institutional
controls to enforce and support the containment portion of the
remedy. Potential health risks posed by the Site through viable
exposure pathways (i.e., direct contact, ingestion of waste
piles, contaminated soils, sediments, ingestion of contaminated
groundwater, and inhalation of contaminated dusts) will be
eliminated and controlled by the remediation selected in this
ROD.
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The selected remedy requires the use of offsite resource recovery
to address the battery casings and other high lead content
materials. Soils that pose a principal threat, that is exceeding
10,000 mg/kg of lead, will be excavated and treated onsite via
stabilization to immobilize the contaminants prior to
consolidation of the treated soils in the onsite landfill.
Remaining soils posing a lower level threat will be consolidated
in the onsite landfill using agricultural limestone as a passive,
in-situ treatment method to reduce mobility of the contaminants.
Closure of the onsite landfill in accordance with the federally
authorized Pennsylvania (RCRA) hazardous waste requirements will
prevent exposure to these materials, and significantly reduce or
eliminate any leaching of contaminants into soils or groundwater.
Shallow groundwater will be treated as it flows through a
limestone barrier placed onsite, and monitoring will be
instituted to verify the effectiveness of this system and to
monitor water quality in the bedrock aquifer.
Compliance with Applicable or Relevant and Appropriate
Requirements.
These standards are considered applicable to this action:
The closure of the onsite landfill will comply with the federally
authorized Pennsylvania (RCRA) hazardous waste requirements, 25
PA Code Chapter 264.
Fugitive dust emissions generated during remedial activities will
comply with the National Ambient Air Quality Standards (NAAQS)
set forth at 40 CFR Part 50 and 25 PA Code Sections 131.2 and
131.3. Such emissions will comply with regulatons in the
federally-approved State Implementation Plan for the Commonwealth
of Pennsylvania, 40 CFR Part 52, Subpart NN, Sections 52.2020 -
52.2023 and in 25 PA Code Sections 123.1 and 123.2. In addition,
the secondary lead smelting operation will comply with all
applicable air emission requirements in accordance with 25 PA
Code Sections 123,4.1 - 13 (particulate matter emissions}, 25 PA
Code Sections 123.21-22 (sulfur compound emissions), 25 PA Code
Section 123.25 (monitoring requirements) and 25 PA Code Chapter
127, Subchapter D (Prevention of Significant Deterioration of Air
Quality requirements related to sulfur dioxide emissions.
The removal of sediments from Nesquehoning and Bear Creeks will
comply with the requirements of the Dam Safety and Encroachment
Act of 1978, P.L. 1375, as amended, 32 P.S. 693.1 et seq., and
specifically Chapter 105 (25 PA Code 105.1 et seq.). This
activity would also comply with the requirements of the PA Clean
Streams Law, Chapter 102 (25 PA Code 102.1 et seq.).
Operation of the onsite treatment plant will comply with the
substantive requirements of the National Pollutant Discharge
Elimination System Requirements (NPDES) established under the
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Clean Water Act, 40 CFR Part 122, the Pennsylvania Wastewater
Treatment Regulations (25 PA Code Sections 95.1 - 95.3), the
Pennsylvania Water Quality Standards (25 PA Code Sections 93.1-
93.9), and the PA Discharge Elimination System Rules, 25 PA Code,
Chapter 92.
The handling and onsite consolidation/disposal of scrap materials
and drums containing plastic would comply with the federally
authorized Pennsylvania (RCRA) requirements for waste piles set
forth in 25 PA Code Chapter 264.
The regrading and capping of materials will comply with the
requirements of the PA Soil Erosion and Sediment Control
Regulations set forth in 25 PA Code, Chapter 102.
The resource recovery of battery casings and wastes at an offsite
secondary lead smelter will comply with 25 PA Code 261.6(a),
Department of Transportation (DOT) Rules for Hazardous Materials
Transport, and the federally authorized Pennsylvania (RCRA)
requirements for hazardous waste handling and transportation, 25
PA Code Chapters 262 and 263.
The processing of battery casings at a secondary lead smelter
will be performed at a facility permitted under 25 PA Code
Chapter 265, Subchapter R, and 25 PA Code Chapter 270, in
accordance with 25 PA Code Chapter 264, Subchapter O, regarding
incineration, and in accordance with the applicable provisions of
40 CFR Part 266, Subpart H, regarding the handling and processing
of hazardous wastes in boilers and industrial furnaces.
The resource recovery and offsite disposal activities will comply
with CERCLA Section 121(d)(3) and with EPA OSWER Directive
#9834.11, both of which prohibit the disposal of Superfund Site
waste at a facility not in compliance with Sections 3004 and 3005
of RCRA and all applicable State requirements.
Groundwater flushing activities will comply with applicable
portions of regulations concerning underground injection wells
established under the Safe Drinking Water Act, 40 CFR Parts 144
through 146, and administered under 40 CFR 147, Subpart NN.
Groundwater remediation activities will comply with applicable
portions of the PADER Ground Water Quality Protection Strategy
which prohibits continued groundwater degradation, and requires
remediation of groundwater to background levels (25 PA Code
Sections 264.90 to 264.100, specifically 25 PA Code Sections
264.97(i) and 264.100(a)(9).
The handling and onsite treatment of soils and certain battery
wastes will comply with the federally authorized Pennsylvania
requirements (RCRA) for generators of hazardous waste, 25 PA Code
Chapter 262.
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Treatment of soils via stabilization will comply with the
federally authorized Pennsylvania hazardous waste requirements
for handling, transportation and other standards at 25 PA Code
Chapters 262, 263, and 264.
The additional sampling and evaluation of an appropriate cleanup
level for contaminated sediments will be completed in accordance
with the requirements of the Fish and Wildlife Coordination Act,
16 U.S.C. Section 661, et. seq.
These standards are considered relevant and appropriate to this
action:
.. * t ~
Onsite treatment will comply with the federally authorized
Pennsylvania (RCRA) regulations and standards for owners and
operators of hazardous waste treatment, storage and disposal
facilities, in accordance with 25 PA Code Chapter 264,
Subchapters A-E, Subchapter I (containers) , and Subchapter J
(tanks).
This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding groundwater monitoring.
Contamination in the groundwater will be reduced to background
levels as required by 25 PA Code Sections 264.90-264.100,
specifically 25 PA Code Section 264.97(i) and 264.I00(a)(9). if
implementation of the Selected 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 shallow aquifer, then EPA, in
consultation with PADER, may amend the ROD or issue an
Explanation of Significant Differences to inform the public of
alternative groundwater goals.
The following are to be considered during this action:
This alternative will comply with EPA OSWER Directive #9834.11
which prohibits the disposal of Superfund Site waste at a
facility not in compliance with Section 3004 and 3005 of RCRA and
all applicable State requirements.
Determinations about the effectiveness of soil remediation at the
Site will be based on EPA 230/O2-89-042, Methods for Evaluating
Cleanup Standards. Vol. I; Soils and Solid Media.
The following are not considered to be applicable to this action:
RCRA Land Disposal Restrictions (LDRs) codified at 40 CFR Part
268 are not considered to be ARARs for this Site or the action
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required by this ROD, specifically the movement of contaminants
within an area of contamination (AOC) for consolidation purposes
during remedial activities (i.e., soils, battery waste piles,
stream sediments). Given the widespread surface and shallow
surface contamination at the Site, the entire Site may be
considered an AOC with respect to LDRs. Movement within or
consolidation of contaminants within the AOC would not constitute
placement, therefore LDRs are not applicable or appropriate.
The State's Residual Waste Management Regulations, 25 PA Code
Sections 287.1-299.232, are not considered to be applicable to
the Tonolli Site or to the actions required by this ROD.
Specifically, 25 PA Code Section 287.1 describes residual waste
as certain waste, if it is not hazardous. Accordingly, EPA has
determined that these regulations are not applicable to sites
that are subject to regulations for the management or handling of
hazardous waste. The waste at the Tonolli Site is hazardous and
therefore, within the universe of sites that are subject to the
regulations governing the handling of hazardous waste. The
residual waste regulations were drafted to prevent harm to the
public or environment that may result from the failure to treat
waste that is potentially harmful, but not "hazardous", by
definition, and therefore not regulated under hazardous waste
regulations. The lead-contaminated soils at levels exceeding
1000 ppm will be consolidated (before or after treatment) into
the onsite landfill. This landfill will then be closed in
accordance with the federally authorized Pennsylvania hazardous
waste requirements. Since the PA residual waste regulations
exempt from regulation, "Garbage, refuse, other discarded
material or other waste... if it is not hazardous", these
regulations are neither appropriate or applicable to the
hazardous materials present at Tonolli. See PA Code Section
287.1.
Cost Effectiveness
The estimated present worth cost for the selected remedy is
$ 16,616,000. The remedy is cost-effective in mitigating the
risks posed by the principal threats at the Site in a reasonable
time and meets all other requirements of CERCLA. Site materials
containing the highest concentrations of inorganic contaminants
will be treated on (stabilization) or offsite (resource recovery)
to reduce toxicity and mobility. Stabilized soils will be
consolidated in the onsite landfill prior to closure.
Contaminated soils posing a lower level threat will be
consolidated in the onsite landfill using a passive in-situ
treatment method to reduce the mobility and prevent migration of
contaminants. After consolidation of treated and untreated
materials, the onsite landfill will be properly closed in
accordance with RCRA standards. This combination of treatment
and engineering controls effectively reduces and eliminates the
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potential risks posed by the Site in a cost-effective manner.
The selected remedy provides a high degree of long-term
effectiveness and permanence. This remedy is judged to afford
overall effectiveness proportional to its cost such that the
remedy represents a reasonable value.
Utilisation of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable.
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable while providing
the best balance among'the"other evaluation criteria. Of all
alternatives evaluated, the selected remedy provides the best
balance in terms of long-term effectiveness and permanence,
reduction of toxicity, mobility or volume through treatment,
cost, implementability, and community acceptance.
The criteria that were most critical in the selection of the
remedy were overall protection of human health and the
environment, long-term effectiveness and permanence, and
reduction of toxicity, mobility, or volume through treatment.
Because EPA anticipates that the Site will be used for industrial
purposes after the cleanup is completed, the permanence and long-
term effectiveness of the remedy were of critical concern. The
selected remedy will effectively reduce the contaminated area at
the Site to one-third of its original extent, and minimize the
operation and maintenance requirements for the remedial
activities.
The selected remedy meets the statutory requirement to utilize
permanent solutions and treatment technologies to the maximum
extent practicable. Treatment has been selected to address the
Site materials and contaminated media posing the principal
threats to human health and the environment. Four of the six
categories of contaminated wastes or environmental media will be
subject to treatment under this remedy. Engineering controls
(i.e., containment- landfill closure) have been selected to
complement the treatment methods, as well as to contain treated
materials, and certain untreated materials that pose lower level
threats.
Preference for Treatment as a Principal Element
The selected 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 removing the battery casings and wastes
containing the highest lead concentrations for offsite resource
recovery, treating onsite soils which pose a principal threat via
stabilization prior to consolidation in the onsite landfill, and
treating surface water and groundwater to remove contaminants
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before it is discharged back into the environment, the selected
remedy employs treatment as a principal element.
ZZ. EXPLANATION OP SIGNIFICANT CHANGES
The Proposed Plan identifying EPA's preferred alternative for the
Tonolli Corporation Site was released for comment in July 1992.
The selected remedy described in this ROD differs from the remedy
in the Proposed Plan with regard to the following:
1) During the public comment period, new information indicated
that EPA's remedial action objectives and health-based cleanup
levels could be met by an alternaLe approach to treating
contaminated Site soils. This information also indicated that
such an alternate approach to soils treatment would provide for a
more cost-effective remedy to permanently and effectively address
the Site conditions. Based on an evaluation of this new
information, EPA selected a different trigger level that will be
used to define those soils which pose a principal threat and that
require treatment prior to consolidation in the onsite landfill.
This modification serves to combine certain features (i.e.,
handling of contaminated Site soils) of Alternative 5 with
Alternative 6, as they appeared in the July 18, 1992 Proposed
Plan.
The modified Alternative 6 requires the treatment of contaminated
soils defined as a principal threat (i.e., soils with lead levels
exceeding 10,000 mg/kg, or one order of magnitude greater in
concentration than the cleanup level) via onsite stabilization
prior to consolidation in the onsite landfill. This approach
requires treatment of approximately 7300 cubic yards of soils
containing the highest total lead concentrations. Remaining
soils (i.e., soils containing lead between 1000 and 10,000 mg/kg}
will be consolidated in the onsite landfill, in combination with
a more passive treatment method designed to significantly reduce
potential for leaching of any contaminants. A layer of crushed
or pulverized agricultural limestone will be added to the onsite
landfill as part of the cap construction and landfill closure.
This modified remedy provides an equivalent level of protection
and long-term effectiveness as the originally proposed remedy,
while being more cost-effective. EPA believes that this
combination of treatment and engineering controls will
effectively reduce and eliminate the potential risks posed by the
Site in as permanent a manner as the originally proposed remedy.
2) The estimated present worth cost for this modified version of
Alternative 6 is $16,616,000. This figure for modified
Alternative 6 includes an estimated cost for remediation of Site
groundwater via the construction of a vertical chemical barrier,
and the flushing of pH adjusted fluids to decrease the treatment
duration. This groundwater cost information was not entirely
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provided in the Feasibility Study Report, but EPA collected
supplemental information which is available in the Administrative
Record for Tonolli. The cost of the preferred alternative
described in EPA's Proposed Plan did not include these estimated
groundwater costs, nor did any of the other alternatives
presented therein.
3) The estimated time to implement Modified Alternative 6 is 25
months. This implementation time differs from that cited under
the preferred alternative in EPA's Proposed Plan by one month.
4) The soils excavated from a residential area situated to the
immediate west of the Tonolli property boundary will be
consolidated in the onsite landfill prior to its closure, rather
than treated onsite via stabilization.
5) Additional sampling and bioassays will be conducted to
determine an appropriate cleanup level for the contaminated
sediments that have been detected in Bear and Nesguehoning
Creeks. Based on comments received from the U.S. Department of
Interior, Fish and Wildlife Service, EPA has deleted the
reference of a 450 ing/kg sediment cleanup level for lead that was
included in the Preferred Remedy described in the Proposed Plan.
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