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Remedial Response
EPA/ROD/R03-93/173
September 1993
PB94-963911
c/EPA Superfund
Record of Decision
Novak Sanitary Landfill, PA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-93/173
3. Recipient's Accession No.
Title and Subtitle
SUPERFUND RECORD OF DECISION
Novak Sanitary Landfill, PA
First Remedial Action - Final
5. Report Date
09/30/93
7. Authors)
8. Performing Organization Rapt. No.
9. Performing Organization Name and Address
10 Project Task/Work Unit No.
11. Contract(C) or Grant(G) No.
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-963911
16. Abstract (Limit: 200 words)
The 65-acre Novak Sanitary Landfill site is an inactive, unlined, municipal landfill
located in South Whitehall Township, Lehigh County, Pennsylvania. Land use in the area
is predominantly residential and agricultural, with minor industrial and commercial
uses. The site borders residential homes to the north, south, and east, and Jordan
Creek, classified as a protected use stream for trout stocking and migratory fishes,
approximately 700 feet to the south. There are several private-residential wells and
public supply wells within a 3-mile radius of the site and several, small areas along
the perimeter that were classified as wetlands during the RI, even though there, are no
Federally-designated wetlands on the landfill site. There are four main waste disposal
areas: the 9-acre Old Surface Iron Mine Excavation in the north-central area; a 2-acre
Demolition Debris Fill Area in the northeast area; a 14-acre Surface Fill Area across
the northwestern and central area; and a 9-acre Trench Fill Area in the southern
portion of the property. Beginning in the mid-1950s, wastes were disposed of in the Old
Surface Mine Excavation, which was closed and covered prior to 1972. From 1972 to
1982, municipal, commercial, and industrial waste was deposited in the Surface Fill
Area, until the State directed that disposal be shifted to the Trench Fill Area. In
1982, disposal in the Trench Fill Area began, which included a series of five parallel
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Novak Sanitary Landfill, PA
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw, sw, air
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), metals (chromium, lead)
b. Iderrtifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None .
21. No. of Pages
80
22. Price
(SeeANSI-Z39.18)
See Instructions on Rtverse
OPTIONAL FORM 272 (4-77)
(Formerly NTlS-35)
Department of Commerce
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EPA/ROD/ROX-93/l"73
Novak Sanitary Landfill, PA
First Remedial Action - Final
Abstract (Continued)
east-to-west oriented trenches. By 1988, all trenches were filled; however, the landfill
continued to accept small quantities of refuse and construction debris until it was closed
in 1990. The total volume of the landfill is estimated at 1,040,000 yd3 of combined waste
and fill, and certain wastes, that were disposed of at the landfill in the 1950s and '
1960s, later may have been defined as hazardous wastes under RCRA. In 1985, site
inspections revealed potential ground water contamination. This ROD addresses a final
remedy to reduce the risk to human health and the environment caused by the unlined
landfill. The primary contaminants of concern affecting the soil, sediment, debris,
ground water, surface water, and air are VOCs, including benzene, PCE, TCE, toluene, and
xylenes; and metals, including chromium and lead.
The selected remedial action for this site includes installing a perimeter fence around
the site boundaries; sampling and assessing the sediment and water in all onsite surface
stormwater and leachate drainages and other standing water areas to define the areas of
contamination; removing and testing contaminated sediment to determine whether it is
hazardous waste or not; temporarily storing the contaminated sediment onsite in containers
until it can be transferred offsite to a licensed hazardous waste disposal facility or, if
it is not hazardous, moving it to other parts of the landfill to be used as fill material;
collecting and removing approximately 11,000,000 gallons of leachate; storing the leachate
onsite in storage tanks and transporting the leachate offsite to a wastewater
pre-treatment facility, prior to discharge to a POTW; providing for a contingent remedy
for leachate, including onsite treatment and discharge to Jordan Creek via a planned storm
sewer location north of the site, if the Lehigh County Wastewater Pretreatment Plant
cannot receive the leachate; constructing a geosynthetic clay cap to completely cover over
the Surface Fill, Trench Fill, Old Mine, and Demolition Fill Areas; allowing the ground
water to naturally attenuate by dispersion, adsorption, and biodegradation for 15 years,
or until concentrations in the ground water reach the lower of background levels or MCLs;
monitoring ground water for. 30 years; implementing additional ground water remedial
actions within the scope of this ROD, if necessary to attain performance standards;
providing an alternate water supply for affected residential wells; removing contaminated
surface water to be treated with the leachate; installing a surface water control system,
including regrading the site to provide drainage and to minimize soil erosion, and
implementing a storm water run-on, runoff, and erosion control system for the site;
collecting, venting, and monitoring landfill gas, including installing passive trenches
and pipe vents along the fractures at the landfill boundary; monitoring air during the RD
phase to determine if active venting is necessary; and implementing institutional
controls, including deed, ground water, and land use restrictions. The estimated present
worth cost for this remedial action is $16,105,149, which includes an estimated annual O&M
cost of $92,459 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water cleanup goals are based on the lower of background levels,
the SDWA non-zero MCLG, or the Federal or State MCLs, and include benzene 5 ug/1; PCE 5
ug/1; TCE 5 ug/1; toluene 1,000 ug/1; and total xylenes 10,000 ug/1.
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RECORD OF DECISION
NOVAK SANITARY LANDFILL SITE
DECLARATION
SITE NAME AND LOCATION
Novak Sanitary Landfill Site
South Whitehall Township, Lehigh County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Novak Sanitary Landfill Site (the "Site"), South Whitehall
Township, Lehigh County, Pennsylvania, which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
("CERCLA"), as amended by the Superfund Amendments and
Reauthorization Act of 1986 ("SARA"), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), 40 C.F.R. Part 300. This decision
document explains the factual and legal basis for selecting the
remedial action for this Site. The information supporting this
decision is contained in the Administrative Record for this Site.
The Commonwealth of Pennsylvania has neither concurred nor non-
concurred with the selected remedy as of the date of this Record
of Decision. The concurrence/non-concurrence letter from the
Commonwealth will be added to the Site Administrative Record upon
receipt.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. § 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 public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
The Novak Sanitary Landfill Site is a municipal landfill
approximately 65 acres in size. The remedial action selected
for the Site is a final remedy which will address the principle
threat and reduce risk to human health and the environment caused
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by the unlined landfill. To achieve this objective, the selected
remedy will: 1) ensure containment of the landfill contents; 2) */G/t,
provide long term monitoring of ground water for residences toeffi *
adjacent to the Site that are utilizing the ground water for '
drinking water; 3) mitigate the continued release of contaminants
leaching from the landfill to the aquifer; 4) control the
migration of combustible gases such as methane; 5) ensure
landfill contaminants in the Site's surface storm-water and
leachate drainages outside the proposed landfill cap are either
not of environmental risk or contained by the proposed cap.
The selected remedial action includes the following components:
Installation of perimeter fence around the Site
boundaries;
Deed restrictions within the Site boundaries;
Removal of contaminated on-site surface water and
sediments based upon results of additional sampling and
environmental risk assessment to be conducted;
Installation of surface water control systems to
provide drainage and to minimize soil erosion
throughout the Site;
Containment of the landfill contents by construction of
a cap over the entire waste area, including the Surface
Fill, Trench Fill, Old Mine and Demolition Fill Areas;
Site restoration to promote wildlife habitat diversity
without jeopardizing the integrity of the cap;
Installation and monitoring of a gas collection system
that is compatible with an active gas collection and
treatment system;
Ongoing leachate collection and monitoring throughout
the Site and transport of leachate to an approved
wastewater treatment facility by tanker for disposal;
Contingency for on-site leachate treatment and disposal
to surface water if approval for disposal at an
approved wastewater treatment facility is not obtained;
Long-term ground water monitoring in the vicinity of
the Site. Achievement of background levels (or MCLs,
whichever is lower) in ground water. Contingency for
provision of drinking water (via residential treatment
units or waterline hook-ups) to affected residences.
Delineation of the source of ground water contamination
in the vicinity of RW-13;
AR30888U
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(ft
9 Operation and maintenance (O&M) of the vegetative soil
cover, the cap, and the treatment systems on-site.
STATUTORY DETERMINATIONS
The selected remedial action 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 remedial action
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 remedial action will result in hazardous substances
remaining at the Site, a review by EPA will be conducted within
five years after the initiation of the remedial action, and every
five years thereafter, as required by Section 121(c) of CERCLA,
42 U.S.C. § 9621(c), to ensure that the remedial action continues
to provide adequate protection of human health and the
environment.
Stanley L. Laskowski Date
Acting Regional Administrator
Region III
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TABLE OF CONTENTS
I SITE NAME, LOCATION, and DESCRIPTION ......... 1
II SITE HISTORY and ENFORCEMENT ACTIVITIES ........ 1
III HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
IV SCOPE and ROLE of RESPONSE ACTION WITHIN SITE STRATEGY 4
V SUMMARY of SITE CHARACTERISTICS 4
A. SOILS ...... ...... 6
B. SURFACE WATER ................... 6
C. GEOLOGY . . ............ 6
D. HYDROGEOLOGY ...... 7
E. NATURE and EXTENT of CONTAMINATION . 8
1. Leachate 8
2. Landfill Gas ......... ... 9
3. Ground Water ....... 10
4. Surface Water 11
5. Sediments . -....' . 12
6. Soils . -.'.. 13
VI SUMMARY OF SITE RISKS . . 13
A. HUMAN HEALTH RISKS 13
B. ECOLOGICAL RISKS .......... 18
VII DESCRIPTION OF ALTERNATIVES 20
VIII SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .... 26
A. OVERALL PROTECTION of HUMAN'HEALTH
and the ENVIRONMENT 27
B. COMPLIANCE WITH ARARs 29
1. Landfill Contents 30
2. Air Emissions 32
3. Surface Water Discharge 34
4. Sediments/Leachate Sludge 35
5. Ground Water 36
6. Wetlands 36
7. Wildlife Habitat 36
8. Historic Sites/Artifacts 37
C. LONG-TERM EFFECTIVENESS and PERMANENCE ...... 37
D. REDUCTION of TOXICITY, MOBILITY, or VOLUME
THROUGH TREATMENT ..*..... 38
.RR3U8886
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E. SHORT-TERM EFFECTIVENESS 40
F. IMPLEMENTABILITY 41
G. COST . 42
H. State Acceptance 43
I. Community Acceptance 44
IX SELECTED REMEDY AND PERFORMANCE STANDARDS 44
A. Installation of Perimeter Fence 45
B. Deed Restrictions 45
C. Removal of Contaminated Landfill Surface Water
and Sediments 46
D. Installation of Landfill Surface Water Control
System . . 46
E. Installation of Landfill Cap 47
F. Site Restoration 47
G. Installation of Landfill Gas Venting &
Monitoring Systems 48
H. Installation of Landfill Leachate Collection
Systems 48
I. Installation of the "Collected Leachate" Treatment
System (Contingency) 49
J. Ground Water Monitoring; and Achievement ofc
Background Levels (or MCLs, whichever is lower) in
Ground Water; 50
K. Operation and Maintenance 53
L. Remedy Review 54
X. STATUTORY DETERMINATIONS 54
A. Protection of Human Health and the Environment . . 55
B. Compliance with Applicable or Relevant and
Appropriate Requirements 56
C. Cost-Effectiveness . 57
D. Utilization of Permanent Solutions and
Alternative Treatment (or resource recovery)
Technologies to the Maximum Extent Practicable (MEP).57
E. Preference for Treatment as a Principal Element. . 57
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 57
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C.'.
FIGURES AND TABLES (in Attachments):
Figure 1: Site Plan
Figure 2: Soil-Gas Survey Sampling Probe Location
Figure 3: Volatile Organic Compounds in Ground
Water
Figure 4: Regional Water-Level Contour Map
Figure 5: Decision Tree for Providing Alternate
Water Supply
Table 1: Comparison of Leachate Characteristics
Between USEPA Subtitle D Study and Data
Collected from the NSL
Table 2: Soil Gas Survey Results (2 pages)
Table 3: Concentration Ranges of Metals and
Inorganics in Soil and Sediments
Table 4: Risk Estimation Summary (3 pages)
Table 5: Summary of Remedial Alternatives
Table 6: Glossary of Evaluation Criteria
Table 7: Alternative Compliance with Established
Criteria
TABLES (in Text):
Table 8: Remedial Action Objectives
Table 9: Contaminants of Concern in Ground Water.
Page
.. 28
.. 52
iii
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Decision summary for the Record of Decision for Novak Sanitary
Landfill Site
I. SITE NAME, LOCATION, and DESCRIPTION
The Novak Sanitary Landfill (the "NSL" or the "Site") is located in
the northern portion of South Whitehall Township (SWTP) and
northwest of Allentown in Lehigh County, Pennsylvania (Figure 1).
The approximately 65 acre parcel is situated on a hillside north of
Jordan Creek and south of Orefield Road. The Site is separated
from neighboring properties by a steep drop in elevation to the
south and southwest; partially due to natural topography and to the
buildup of the landfill disposal areas and storm-water management
berms. Stands of trees and brush separate the NSL from neighboring
properties to the east and west. There is no fence that surrounds
the property. The Site is accessed from the north at the
intersection of Orefield Road and Lime Kiln Road. Access is
restricted at this location, however, by buildings and a gate.
The NSL is owned and operated by Novak Sanitary Landfill, Inc. A
member of the Novak family permanently resides at the north end of
the Site adjacent to Orefield Road and there is a second unoccupied
Novak residence at the northwest corner of the property. The small
former landfill office, two other small structures in disuse, and
a maintenance building are also located on the northwestern part of
the property. The maintenance building is presently used in
connection with a trucking business operated by Valley Hauling,
Inc. Most of the remainder of the property has been utilized for
solid waste disposal. The Waste Disposal Areas include the
following: (1) an old surface iron mine excavation (Old Mine Area)
in the north-central area (approximately 9 acres); (2) a
demolition debris fill area (Demolition Fill Area) in the northeast
area (approximately 2 acres); (3) .a Surface Fill Area (including
the East, West and Southwest Trenches) containing municipal and
commercial solid waste which extends across the northwestern and
central part of the property (approximately 14 acres); and, (4) a
Trench Fill Area occupying the southern portion of the property
(approximately 9 acres) also containing municipal and commercial
solid waste. The approximate boundaries of each fill area are
depicted on Figure 1.
II. SITE HISTORY and ENFORCEMENT ACTIVITIES
Operations at the NSL reportedly began in the mid-1950's with the
disposal of wastes in the old surface iron mine excavation. The
November 1958 aerial photograph confirms this understanding of
landfill operations as it depicts evidence of disposal activity
around the large abandoned quarry. Aerial photography from 1967
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indicates refuse disposal southwest of the Old Surface Mine and'
aerial photography from July 1971 shows waste disposal areas
expanding southeast of the Old Surface Mine Area. Filling of the
Old Mine Area with solid waste was substantially completed. The
area was closed and a cover was applied prior to 1972. In 1969,
Novak Sanitary Landfill, Inc. submitted an application to the
Pennsylvania Department of Environmental Resources (PADER) for a
permit to expand the landfill operations. A solid waste management
permit was issued to Novak Sanitary Landfill, Inc. by the PADER on
March 24, 1972. The permit, which incorporated design plans
submitted with the permit application, authorized the operation of
a natural renovation landfill (a natural renovation landfill is
typically unlined and considers the ability of underlying soils to
attenuate the constituents leached from the landfill disposal
area) , with material disposal in the Surface Fill Area on the
northern portion of the Site, and in the Trench Fill Area on the
southern portion of the property.
The NSL received solid waste from municipal, commercial, and
industrial operations. Waste was deposited in the Surface Fill
Area from 1972 through the summer of 1982. In 1982, the PADER
conducted an assessment of the Surface Fill Area and determined it
was overfilled. At that time, the PADER directed the Novak
Sanitary Landfill, Inc. to shift disposal to the Trench Fill Area
of the landfill.
The Trench Fill Area plans included a series of five parallel east-
to-west-oriented trenches, numbered 1 through 5 sequentially in a
north-to-south direction. The disposal of waste in the trenches
was initiated on August 30, 1982 with the filling of Trench 2, and
proceeded with the filling of Trenches 1, 3 and 4. Aerial
photography dated June 1983 shows the presence of Trenches 1
through 3. PADER representatives were on-site during the
excavation of Trenches 1 through 4, approved the trench locations
and separation distances of all five trenches, and were present at
the closing of Trenches 1 through 3. On December 13, 1984, the
PADER issued an order and civil penalty assessment alleging various
permit violations and directing Novak Sanitary Landfill, Inc. to
cease all solid waste disposal operations. Novak Sanitary
Landfill, Inc. filed an appeal contesting the order.
On August 13, 1987, the Pennsylvania Environmental Hearing Board
(PEHB) issued an opinion in which it concluded that the PADER had
failed to prove its most serious allegations. An order was entered
allowing Novak Sanitary Landfill, Inc. to reopen. Trench 5 was
substantially filled as of September/October 1988 but the landfill
continued to accept small quantities of refuse and construction
debris through May 1990.
In June 1985, NUS Corporation (NUS), acting as a USEPA Region III
contractor, conducted a site inspection of the NSL. NUS identified
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the ground-water route as the primary concern due to the substances
found in on-site monitoring wells, the close- proximity of private
residential wells to the landfill, and the existence of public
supply wells within a 3-mile radius of the Site. A Hazard Ranking
System (HRS) score of 42.34 was calculated for the Site. The NSL
was proposed by the USEPA for inclusion on the National Priorities
List (NPL) on January 22, 1987. The Site was listed on the NPL on
October 4, 1989.
Since the NPL listing, EPA has been conducting a PRP search. From
the evidence gathered to date, it is clear that NSL received both
municipal and industrial wastes. Because of the lack of records
regarding the operation of the landfill, the specific ratio, or
volume from any one source is difficult to determine, but it is
estimated that the total volume of the landfill is approximately
1,040,000 cubic yards of combined wastes and fill. Responses from
industrial contributors to inquiries from EPA as to the substances
deposited in the landfill show that a potential exists that certain
wastes that were later defined as hazardous wastes under the
Resource Conversation and Recovery Act (RCRA) may have been
disposed of in the landfill during the 1950's and 1960's.
Beginning in May 1988, EPA sent General and Special Notice Letters
to PRPs for performance of work at the Site. On January 11, 1989,
16 PRPs (the Novak PRP Group) entered into an Administrative Order
by Consent with the United States Environmental Protection Agency
(EPA) Region III for preparation of a Remedial Investigation/
Feasibility Study (RI/FS) of the Novak Sanitary Landfill. The
Novak PRP Group submitted the RI/FS Report to the EPA on January
28, 1993.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The current Proposed Plan for the Novak Sanitary Landfill Site was
released for public comment on May 26, 1993. A Remedial
Investigation (RI) and Feasibility Study (FS) ,, summarized in the
Proposed Plan, were also made available for public comment. These
two documents and the Proposed Plan, along with other Site related
documents, were made available to the public in the administrative
record.maintained at the EPA Docket Room in Region III and at the
Parkland Library located at 4422 Walbert Avenue, Allentown, PA.
The notice of availability for these two documents was published in
the Morning Call on May 26, 1993.
In accordance with CERCLA Sections 113 (k)(2)(B)(i-v) and 117, a
public comment period was held from May 26, 1993 to June 25, 1993.
In addition, a public meeting was held on June 8, 1993 at the South
Whitehall Township Building. At this meeting, representatives from
EPA and PADER answered questions about problems at the Site and the
remedial alternatives under consideration. A response to the
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comments received during the public comment period is included in
the Responsiveness Summary, which is part of this ROD.
This decision document presents the selected remedial action for
the Novak Sanitary Landfill Site, in South Whitehall Township,
Lehigh County, Pennsylvania, chosen in accordance with CERCLA, as
amended by SARA, and to the extent practicable, the National
Contingency Plan. The decision for this Site is based on the
administrative record.
IV. SCOPE and ROLE Of RESPONSE ACTION WITHIN SITE STRATEGY
This final remedy will address the long-term threat and reduce risk
to human health and the environment caused by the unlined landfill.
In order to achieve remediation objectives consistent with the
National contingency Plan (NCP) , the final remedy must: 1) ensure
containment of the landfill contents; 2) provide long term
monitoring of ground water for residences adjacent to the Site that
are utilizing the ground water for drinking water; 3) prevent the
continued release of contaminants leaching from the landfill to the
aquifer; 4) control the migration of combustible gases such as
methane; 5) ensure landfill contaminants in the Site's surface
storm-water and leachate drainages outside the proposed landfill
cap are either not of environmental risk or are contained by the
proposed cap; and 6) mitigate unavoidable impacts to wetlands (or
"waters of the U.S.").
V. SUMMARY Of SITE CHARACTERISTICS
A Mobil petroleum pipeline right-of-way runs 350 feet to the west
of the Site boundary. Two other pipelines traverse the general
region south of Jordan Creek and approximately 1 mile to the west
of the Site. A Pennsylvania Power and Light (PP&L) utility
easement crosses the Site from the northern portion of the eastern
boundary to the southern boundary. Utility poles and cables are
aligned through the easement. Waste has been deposited in the
landfill up to the western easement limits.
The Site is located in a primarily residential and agricultural
area with minor industrial and commercial uses. Residential homes
surround the Site to the north, southland east. Pheasant Hills
Estates, a residential community, is located north of Orefield
Road, across the road from the landfill. Bridgeview Terrace is
located to the west. Other residential communities within a 0.5
mile radius of the Site include Russell Estates, Bramble Ridge,
Clearview Farms and Country Crest. Currently, South Whitehall
Township has extended water mains along River Road short of the
Lapp Road intersection, and into the Pheasant Hill and Bridgeview
Terrace community complexes. - There are corn and wheat fields
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cultivated by the local residents to the west and southwest of the
Site. There are also turkey hatcheries located as near as 0.5 mile
north of the Site.
There is a public recreational park located approximately 350 feet
south of the southern boundary of the landfill. The park, located
along Jordan Creek, is set up as a baseball field complex. There
are numerous other recreational areas within a three mile radius of
the Site. These recreational areas include rod and gun clubs,
county preserve lands, campgrounds, parks, stables, and golf
courses.
Jordan Creek, located approximately 700 feet south of the Site, is
classified as a protected use stream for trout stocking and
migratory fishes. The creek also recharges the ground water
underlying the Site. The ground water flows in a north to
northeast direction and eventually discharges into the Lehigh
River. Because of its elevated topography, the Site is not
inundated by Jordan Creek 100-year frequency floodwater.
The two nearest Jordan Creek crossings are the Wehr's and Manasses
Guth Covered Bridges. They are located 0.5 mile southwest and
southeast of the Site and are listed on the National Register of
Historic Places. The Pennsylvania Historical and Museum
Commission, Bureau for Historic Preservation has also indicated
that there is a high probability that prehistoric and historic
archaeological resources are located in the Site.
Based upon the National Wetland Inventory, there are no federally-
designated wetlands on or adjacent to the landfill. However,
several small areas of the Site were classified as wetlands as a
result of a preliminary wetlands delineation conducted during the
RI. The areas that were identified as having a potential for
supporting a valuable habitat are located along the perimeter of
'the Site.
There are numerous limonite (iron oxide deposits) and limestone
bedrock quarries within a 3-mile radius of the Site. An old
limonite quarry was used for waste disposal on the north central
portion of the Site. Quarries are located to the north, west, and
south of the Site.
The nearest airport (Allentown-Bethlehem-Easton Airport) is located
approximately 7 miles east of the Site and is separated from the
Site by the Lehigh River.
A. SOILS
The Site is directly underlain by unconsolidated deposits comprised
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AR3Q8893
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of residual clay or saprolite. In addition to the saprolite,
deposits of glacial till materials were observed at a borrow pit in
the northeast section of the Site.
B. SURFACE WATER
NSL is located within the Jordan Creek drainage basin and is
underlain by both clastic and carbonate sedimentary rock aquifer
systems. A surface-water divide between the Jordan Creek and
Coplay Creek drainage basins lies less than 100 feet due north of
the Site. Surface drainage from the Site would naturally be south
toward Jordan Creek; however, off-site drainage is inhibited by the
southwest and southeast storm-water retention ponds and the berms
constructed at the southern perimeter of the property. The
southwest and southeast retention basins receive surface water run-
off from portions of the Old Mine Area as well as the flow from the
Surface Fill and the Trench Fill Areas. During excessive rainfall
events, the capacity of these retention basins may be exceeded.
Based upon the topography of the Site, not all of the Site drainage
discharges to the on-site retention basins. Surface water flow
outside of the bermed areas of the Site along the western,
southern, and eastern property lines .discharges off -site along
natural drainage pathways.
C. GEOLOGY
The Site is located within the Great Valley Section of the Valley
and Ridge Physiographic Province of eastern Pennsylvania. The
dominant structural feature in the area is a regional northeast
recumbent anticline. The Lower Ordovician age Epler Formation of
the Beekmantown Group underlies the Site. The .Epler Formation
consists of medium grey, medium dark grey, to blue-grey limestone
and interbedded dolomite.
The depth to bedrock in and around the Site ranges from a depth of
2 feet, southwest of the landfill, to 85 feet on the northern end
of the landfill.
The exposed bedrock planes near River Road strike approximately
N60E to N85E and dip on an average of 35 degrees to the south-
southeast. The major joint trend in the bedrock is to the northwest
between N10W and N30W, and a minor joint trend near perpendicular
to the major joint trend.
The unconsolidated materials in and around the Site consist of
orange-brown silt loam derived from the in-situ chemical weathering
of the bedrock. Deposits of glacial till are located on the
northern portion of the Site.
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Several features, which were observed and/or documented in
literature, indicate a degree of karst development around the Site.
Several small depressions, which may represent possible sinkholes,
are located immediately to the east and southeast of the landfill.
A sinkhole was also identified by PADER approximately 1,500 feet
southwest of the landfill along River Road. A cave is mapped 0.75
miles to the east of the landfill, along Jordan Creek.
D. HYDROGEOLOGY
The Beekmantown Group and Allentown Formation, although
lithologically different, are similar enough to be considered a
single hydrologic unit and comprise the aquifer that underlies the
Site. Well yields, with few exceptions, are reported to be low.
The median reported yield for 50 drilled wells was only 16 gallons
per minute (gpm); of this group, 20 wells were reported to yield
less than 6 gpm, and only three wells were reported to yield 1,000
gpm or greater.
Areas underlain by the Beekmantown Group exhibit many of the typi-
cal features of karst topography including sinkholes, caves, and
poorly developed drainage. Ground-water movement tends to be
focused along fractures or joints, and solutioning of the rock may
enlarge these zones, further enhancing flow.
Studies of the Jordan Creek indicate that the stream continually
loses water to the underlying carbonate rocks (primarily the Epler
Formation). Losses in these reaches are such that the lower part
of Jordan Creek dries up on an average of once every 2 years.
Water lost from Jordan Creek flows east to northeast underground
and discharges into the Lehigh River through numerous seeps and
springs along the river banks between Coplay and Fullerton.
Ground water beneath the Site is characterized by a localized,
elongated mounding effect in the bedrock beneath the Trench Fill
Area. The localized mound is believed to be caused by the uncapped
landfill and slow ground water movement in the underlying bedrock.
The mound radiates off approximately 40,000 to 50,000 gallons of
water daily to the ground water. The mound did reach approximately
less than 10 feet below the grade in the Trench Fill Area. During
the gas vent sampling in 1991, standing liquids were detected in
less than 5 feet below grade in the West and Southwest Trench Areas
and approximately 6 feet below grade in the Old Mine Area.
E. MATURE and EXTENT of CONTAMINATION
Based on available information, the landfill received refuse from
various municipal, residential, commercial, and industrial sources.
Listed below are the categories of waste materials that were
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%0.
commonly accepted. Similar to typical municipal landfills, 80
percent of the materials accepted were paper and wood products, and
residential trash. The categories of waste materials identified as
sent to the landfill include, but are not limited to, the
following:
Residential Trash, Incinerator Ash (Industrial and Municipal
Sources), Lawn Clippings, Waste Paper and Cardboard, Empty
Paint and Ink Containers Residuals, Paint Resins, Paint
Sludges, Used Rags, Metallic Materials and Scrap Steel, Metal
Turnings and Plate Electronic Components, Construction and
Demolition Debris (i.e., concrete, wood, asphaltic materials,
metal, etc.), Waste Auto Parts/Products, Plastic Scrap, Waste
Rubber (scraps and coatings), Welding Materials, Waste Pickle
Liquor, Caulk, Plant and Office Rubbish/Trash, Empty Ink
Containers, Wastewater Treatment System Waste Sludges,
Hospital/Medical Waste, Agricultural Wastes (e.g., waste
fertilizer containers).
1. Leachate
Intermittent leachate seeps and associated stained soils were found
in the southwestern portion of the Surface Fill Area, the northern
portion of the Old Mine Area and in the Trench Fill Areas.
Analysis of three leachate seeps indicate the presence of VOCs
(acetone, benzene, chlorobenzene, chloroethane, ethylbenzene,
toluene, and xylene), semi-VOCs (benzoic acid, 1,4-dichlorobenzene,
and 4-methyl phenol), and most of the Target Analyte List (TAL)1
inorganics analyzed. Most of these contaminants were at
concentrations below those known to adversely affect aquatic life.
Beryllium and nickel occurred at concentrations equal to or
slightly greater than EPA criteria for the protection of aquatic
life. Antimony, cadmium, chromium, iron, lead, silver and zinc
concentrations significantly exceeded the EPA water quality
criteria. Sediments collected from leachate seeps contained up to
19 ppm of polycyclic aromatic hydrocarbons (PAHs), and elevated
levels of barium, beryllium, cadmium, calcium, and iron.
In addition, standing liquids from three gas vents (one in each of
the Old Mine, Surface Fill, and Trench Fill Areas) were measured
and sampled. The highest concentration of certain contaminants
detected in the gas vent samples exceeded the levels for those
contaminants detected in the leachate seeps. These contaminants
included VOCs (acetone, benzene, chlorobenzene, chloroethane,
ethylbenzene, and xylene), semi-VOCs (1, 4-dichlorobenzene, bis (2-
ethylhexyl) phthalate, diethyl phthalate, and naphthalene), and
metals/inorganics (sodium, magnesium, and potassium). Table 1
TAL is a list of site sample analytes developed by EPA for Superfund. It includes 23, metals plus total cyanide which are
routinely analyzed using EPA approved protocols.
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provides a comparison of highest compound concentrations detected
in the leachate seeps and the standing liquids in the gas vents to
typical ranges of leachate detected in an EPA Subtitle D study2. In
summary, contaminant levels in leachate are within the range of
those found in the Subtitle D study, and are therefore typical of
municipal landfills, and they exist in all waste disposal areas at
the Site including the Old Mine Area.
2. Landfill Gas
Passive landfill gas vents exist throughout the Site. Ten vents
are located in the Old Mine Area, 26 in the Surface Fill Area and
17 in the Trench Fill Area. During field investigations, landfill
gases were also observed bubbling up through the areas of standing
water in the Surface Fill Area.
During the RI, a two-day Ambient Air Monitoring Program was
undertaken as part of the Site Health and Safety Plan to screen for
VOCs that may have warranted additional investigations. This
program detected compounds (methylene chloride, acetone, and
2-butanone) that were also found in the field blanks. Other
compounds detected include possibly fuel-related constituents
(benzene, toluene, ethylbenzene, and xylene [BTEX]), which may be
attributed to the diesel and gasoline-powered vehicles operating
during the sampling. It has been assumed that the Site did not
have an effect on air quality. Air quality will be further tested
in the Remedial Design. It should be noted that the Ambient Air
Monitoring Program surveyed the air quality conditions on the Site
surface and is not a direct analysis of the constituents inside the
landfill gas vents. .
During the FS, an additional landfill-gas survey was performed in
the soils along the perimeter of the Site because it was believed
that landfill gas was a possible source of contamination in ground
water monitoring wells. Of the 94 locations sampled, 84 detected
concentrations at less than 90 percent of the methane lower
explosive limit (LEL). 10 locations exceeded 90 percent of the
methane LEL. Total VOC concentrations detected in the majority of
the wells sampled ranged from 1.2 parts per million (ppm) to 10.8
ppm. One location exceeded 20 ppm. It was determined from the
survey that landfill gas was following a path of least resistance
along the fracture traces. Based upon the source of the migrating
Subtitle D Study (1986) Phase I Report, EPA/530-SW-86-054, USEPA.
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gas (the landfill), it is believed that the gas is primarily
methane. The location and results of the soil-gas survey are
provided in Figure 2 and Table 2.
Since it was determined that landfill gas might follow preferential
off-site migration pathways along fracture traces, the basements of
8 residences adjacent to the landfill were subsequently screened
for methane. None of the residences exhibited concentrations of
methane in excess of 25 percent of the LEL.
3. Ground Water
Ground water beneath the landfill was found to contain 17 aromatic
and chlorinated aliphatic Target Compound List (TCL)3 VOC
constituents. Compounds such as 1,1-dichloroethane,
1,2-dichloroethylene, 1,2-dichloropropane, trichloroethylene,
chlorobenzene, benzene, and toluene were frequently detected.
Figure 3 illustrates the results of the historical sampling in the
vicinity of the Site. On-site monitoring wells were designated as
"MW" and residential wells were designated as "RW". VOCs were
detected in several on-site wells at levels above safe drinking
water standards. VOCs detected in six (6) of the off-site home
wells were at trace levels and did not exceed safe drinking water
standards. Residential wells on the west side of the landfill in
which traces of VOCs were detected are connected to the South
Whitehall Township (SWTP) community supply system. VOCs were not
detected in the SWTP Bridgeview East supply well, which is located
farther to the north. .
VOCs were also not detected in the Pheasant Hill community supply
well north of the landfill. This well lies north of a trough in
the water table which separates ground water flow from that of the
landfill (Figure 4) . Elevated levels of nitrate/nitrite were found
in the Pheasant Hill community supply well. However, due to the
ground-water flow direction, type of upgradient activity (e.g.,
agricultural activities), and lower nitrate/nitrite levels in the
on-site wells, it was concluded that the nitrate/nitrite levels
found in the Pheasant Hill well may not be related to the Site.
The formerly used well at the Novak unoccupied house (RW-13) in the
northwest corner of the Site exhibited VOC concentrations exceeding
state Water Supply Criteria and federal MCLs. The compounds
detected in this well included many of those which are associated
with the ground-water mound in the vicinity of the Trench Fill
Area. It is unclear if the constituents in this northwest on-site
TCL is a list of site sample analytes developed by EPA for Superfund. It includes 34 volatile organic chemicals, 65 scmivolnlile
organic chemicals, 19 pesticides, 7 polychlorinated biphenyls (PCBs), 23 metals and total cyanide which are routinely analyzed
using EPA approved protocols.
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area are linked to the fill areas or to the Maintenance Area.
Similar types of materials as those disposed in the landfill may
have been handled at one time in the Maintenance Area, and the
Maintenance Area may be an additional source of constituents in the .
ground water. This well was abandoned and plugged on March 13,
1992.
Several TCL semi-VOC constituents (bis(2-ethylhexyl)phthalate,
4-methyl phenol, diethyl phthalate, 1,2-dichlorobenzene,
1,4-dichlorobenzene, di-N-butylphthalate, naphthalene, and unknown
compounds) were present in on-site wells at trace to low levels.
Their occurrence appears to be confined to the proximity of the
Trench Fill Area. Pesticides and PCBs were not detected.
Several trace metals (arsenic, barium, cadmium, chromium, copper,
iron, lead, manganese, nickel, silver, sodium, and zinc) were
detected and appeared to be more prevalent near the Trench Fill
Area than in the downgradient on-site and off-site wells. Though
their concentrations were low and do not exceed state Water Supply
Criteria or federal MCLs, concentrations for cadmium, chromium,
copper, cyanide, and lead were equivalent to or slightly exceeded
the EPA chronic water quality criteria. Iron was found in
monitoring wells at a mean concentration of 7.5 mg/1 (maximum 16.7
mg/1), exceeding the EPA chronic criterion of 1.0 mg/1.
The on-site monitoring wells closest to the landfill exhibited the
highest concentrations of landfill leachate indicators such as
ammonia, chemical oxygen and total dissolved solids.
4. Surface Water
Eight surface-water samples were collected. Six samples were taken
from ponds and drainage ditches and two samples were taken from two
flowing leachate seeps. Analytical results from the six pond and
drainage ditch samples reported no TCL VOCs. Total TCL VOCs
concentrations for the two leachate samples were reported as 59 and
62 ug/1. Analytical results from the six pond and drainage ditch
samples reported no TCL semi-VOCs, except for di-N-butylphthalate
in one sample, which is a common laboratory/ field contaminant. In
one of the leachate water samples, 1,4-dichlorobenzene was detected
(3 ug/1) and 1,274 ug/1 of unknown compounds were reported. In the
other leachate sample, total TCL VOCs concentrations of 553 ug/1
was detected and 2,340 ug/1 of unknown compounds were reported.
Analytical results for Target Analyte List (TAL) metals and
inorganics in the pond and drainage ditch samples indicate that
they have been impacted only slightly. Both leachate samples
contained elevated concentrations of TAL metals. Concentrations of
antimony, cadmium, copper, cyanide, lead, nickel and zinc equalled
or slightly exceeded EPA water quality criteria. Iron
concentrations generally greatly exceeded the chronic criterion of
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1.0 mg/1, reaching as high as 92 mg/1 in a pond on the Old Mine
Area. Sediments from the on-site surface water areas contained low
concentrations of VOCs, as well as PAHs.
5. Sediments
Sediment samples were collected at six areas on-site corresponding
with the surface-water samples and one sample off-site below the
southwest breached retention basin. Jordan Creek sediment samples
were also collected for one upstream background sample and five
downstream samples.
For the six on-site samples, 34 positive results for TCL VOCs were
reported but 31 of the positive results have been determined to be
due to laboratory blank contamination. Therefore the results are
not considered representative of actual conditions and TCL VOCs
appear to be present at only one location. At this location, the
total TCL VOCs concentration is 23 ug/kg. TCL VOCs were not
detected at the off-site sampling location.
Only three on-site sampling locations had detectable semi-VOCs
which consisted of polycyclic aromatic hydrocarbons (PAHs). Total
PAH concentrations at the three areas were 431,872, and 6,509
ug/kg. One of the three areas was the southwest storm water
retention pond. At the off-site sampling location below the
southwest storm-water retention pond, only two phthalate ester
semi-VOCs were reported as detected.
Three TCL semi-VOCs were detected in one or more of the six Jordan
Creek sediment samples. However one of the constituents, di-N-
butylphthalate, which was detected in one of two upstream
background samples was not detected in any other sample. Bis-(2-
ethylhexyl)phthalate was detected in all six samples, but was
suspect in three of the downstream samples. The maximum
unqualified concentration, 2,200 ug/kg, was not a background
sample. Detection of bis-(2-ethylhexyl)phthalate in the Jordan
Creek sediments samples is not unusual, and since bis-(2-
ethylhexyl)phthalate is a common laboratory contaminant and only
one sample had high concentrations of it, the detection of bis-(2-
ethylhexyl)phthalate is not necessarily indicative that the Site
has affected Jordan Creek. The concentrations of metals and
inorganics in the stream sediments were consistent with
concentrations detected in the upgradient, or. background, sediment
sample and regional background concentrations. .Since sediment
samples did not indicate that the creek was altered by surface
water run-off from the Site, no further investigations were
conducted.
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6. Soils
Soil samples were collected from one background off-site boring,
two on-site borings, and from three areas which exhibited leachate
staining at the surface. The samples were collected from two-foot
intervals at varying depths from 0 to 42.3 feet. These samples
were analyzed for TAL metals and inorganics. The stained surface
soils were analyzed for TCL VOCs, TCL seroi-VOCs, TAL metals and
inorganics.
Metal and inorganic concentrations detected on-site ranged from
less than background to approximately five times background. The
concentration ranges of metals and inorganics in soil and sediments
is provided in Table 3.
VI. SUMMARY OF SITE RISKS
The contaminants in the landfill leachate and seeps and in the
monitoring and residential wells consist of a variety of hazardous
compounds. This section provides a summary of the potential risks
to human health from these contaminants in the absence of any
remedial action.
It should be noted, that, although EPA has evaluated the current
risks posed by the Site contaminants, further delays in remedying
the exposed landfill may lead to increased leachate production,
greater number of seeps and more potential exposure risks.
A. HUMAN HEALTH RISKS
The landfill currently is closed and has been for approximately 3
years. There is a fence and two gates at the entrance drive
(accessed from Orefield Road). The remainder of the landfill is
not fenced. There is no evidence of trespassing (e.g., paths,
bicycle tracks, etc.); however, because the Site is not completely
fenced, the potential for trespassing exists. Children aged 6 to
15 years were assumed to represent the age group most likely to
trespass on the Site. Potential exposure via incidental ingestion,
dermal.contact, and/or inhalation of vapors and particulates to
constituents detected in surficial soils, on-site surface water and
sediments, leachate seep water and surface soils in the vicinity of
the seeps was evaluated for a potential current trespasser (aged 6
to 15 years).
The volume of seep water is probably related to the amount of
precipitation infiltration; thus, discharge from the seeps may be
very low or nonexistent during certain times of the year (e.g.,
extended dry periods). Climatic conditions also affect the
surface-water bodies that occur on-site. It is possible .that
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during extended dry periods little or no water is present in the
southeast retention pond. Although the water depth observed in the
retention pond is not conducive to swimming, the potential exists
that someone could wade in this ponded water.
The majority of the Site (with the exception of portions of the
trench fill area) is grass covered, thereby limiting direct soil
contact and fugitive dust generation. The areal extent of exposed
soil at the landfill is relatively small; therefore, the potential
for off-site migration and subsequent exposure to constituents
originating in soils at the Site is not as important a pathway as
for on-site receptors (e.g., potential current trespasser,
hypothetical future on-site residents).
The inhalation of VOC vapors potentially released from surficial
soils, leachate, and subsurface wastes (via the engineered vents)
by people accessing the Site or living off-site is also a potential
exposure pathway. However, based on the low concentrations of VOCs
detected in air (none of the VOCs exceeded the PADER Air Toxics
Guidelines), the potential for these levels to represent a
significant off-site hazard, even if exposure occurred on a regular
basis, is probably low. An estimate of potential risks to off-site
receptors involving vapors and/or particulates (i.e., dust)
released from the Site was not conducted because this exposure
route is being evaluated for future on-site residents and
inhalation risks for off-site receptors would be less than those
calculated for on-site residents.
Although it is assumed for the purposes of this risk assessment
that there is the potential for NSL to be developed into a
residential area in the future, this development is currently
prohibited by zoning restrictions. It was assumed that a house
would be built adjacent to the former disposal areas (i.e., Old
Mine Area, Surface Fill Area, Trench Fill Area) and that residents,
both children (aged 0 to 6 years) and adults, would be exposed to
the potentially affected media at the Site (i.e., ground water,
surficial soil, air, leachate seep water and seep area surface
soil, and surface water and sediment). Young children (aged 0 to
6 years) were chosen to represent potential exposure risks for a
sensitive subpopulation.
The potential exists for a current occupant of the on-site
residence .to be exposed to constituents detected in all media at
the Site: ground water, surficial soils, air, leachate water and
soil at seep areas, and surface water and sediments. There is no
evidence to indicate that a current on-site resident regularly
accesses the former waste disposal areas and has contact with the
leachate seep areas or the surface water and sediments. Exposure
to these media by a current on-site resident is not quantified in
this risk assessment because it is evaluated for the future
hypothetical resident scenario and the two exposures are assumed to
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be comparable.
In summary, the potential exposure pathways identified are the
following:
(1) ingestion of ground water from a current on-site private well
by residents (both children and adults) and inhalation of VOCs
potentially released during showering (for an adult);
(2) ingestion of ground water from a current off-site private well
by residents (both children and adults) and inhalation of VOCs
potentially released during showering (for an adult);
(3) ingestion of ground water from the current downgradient
community supply well (i.e., Pheasant Hill Well) by residents
(both children and adults);
(4) ingestion of ground water (by children and adults) from a
future hypothetical well installed on the Site and inhalation
of VOCs potentially released during showering (for an adult);
(5) incidental ingestion, dermal contact, and inhalation of
particulates from surficial soils by a potential current Site
trespasser (child aged 6 to 15), and by hypothetical future
on-site residents (both children and adults); ;
(6) inhalation of VOCs by a potential current Site trespasser
(child aged 6 to 15), and by hypothetical future on-site
residents (both children and adults);
(7) dermal contact and incidental ingestion of leachate seep water
and surface soil in the vicinity of the seep area by a
potential current Site trespasser (child aged 6 to 15) and by
hypothetical future on-site residents (both children and
adults); and
(8) dermal contact and incidental ingestion of surface water and
sediment by a potential current Site trespasser (child aged 6
to 15) and by hypothetical future on-site residents (both
children and adults).
Although exposures to ground water, air, soil, leachate, surface
water and sediment may actually be occurring, it should be
remembered that the risk estimates for these exposures are
"reasonable maximum" values. It is likely that potential receptors
would be exposed to lower levels of contaminants. The assumptions
used.. for the toxicity of the contaminants were similarly
protective. Therefore, the true risks could be lower.
It is important to note that these risk estimates are based on a
theoretical human in a theoretical circumstance. Residents now
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living in the vicinity of the. Site are not being exposed to ground /
water in which contaminants are present above safe drinking water
standards.
As is common with landfills, several contaminants are contributing
to the risk at the Site. The principle VOCs contributing to the
risk include vinyl chloride; chloromethane; 1,2-dichloroethylene;
1,1,1-trichloroethane; carbon tetrachloride; trichloroethylene;
benzene; and tetrachloroethylene. Metals contributing to the risk
include barium, cadmium, chromium, copper, lead, manganese,
mercury, and nickel.
Potential human health problems are identified by calculating the
risk level and hazard index. Potential carcinogenic risks are
identified by the risk level. A risk level of 1 x 10"6 indicates
one additional chance in 1,000,000 that an individual will develop
cancer above the expected rate of 250,000 in 1,000,000. The risk
calculated is the maximum risk that is reasonably expected to
occur. The hazard index identifies the potential for the most
sensitive individuals to be adversely affected by non-carcinogenic
chemicals. If the hazard index exceeds one (1), there may be
concern for potential non-carcinogenic effects. The greater the .
value of the hazard index above 1.0, the greater the level of
concern.
The results of the risk calculations are presented in Table 4. The
principal results may be summarized as follows:
GROUND WATER: CURRENT RESIDENTS OFF-SITE. The excess
lifetime cancer risk for an adult currently exposed to
contaminants in the ground water in the most contaminated well
immediately down-gradient from the Novak Sanitary Landfill is
5 x 10"6. This means that approximately five additional people
out of 1,000,000 exposed are at risk of developing cancer
caused by 30 years of exposure to Site related contaminants
averaged over a lifetime (70 years), if the level of ground
water contamination is not reduced. The hazard index for a
currently exposed child is 2, indicating a potential for
adverse non-cancer effects.
GROUND WATER: POTENTIAL CURRENT RESIDENTS ON-SITE. The
excess lifetime cancer risk for a potential current adult
exposed to contaminants in the ground water in the most
contaminated existing on-site well is 3.x 10"4. This means
that, if this well were used as a residential water source,
approximately three additional people out of 10,000 exposed
would-be at risk of developing cancer caused by 30 years of
exposure to Site related contaminants averaged over a lifetime
(70 years), if the level of ground water contamination is not
reduced. The hazard index for a potentially exposed child is
2, indicating a potential- for adverse non-cancer effects.
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This well is not currently used as a drinking water source.
GROUND WATER: FUTURE RESIDENTS ON-SITE. The excess lifetime
cancer risk for a hypothetical adult who builds a residence on
the Site and obtains water from the most contaminated part of
the aquifer would be 3 x 10"4. This means that, if this well
were used as a residential water source, approximately three
additional people out of 10,000 exposed would be at risk of
developing cancer caused by 30 years of exposure to Site
related contaminants averaged over a lifetime (70 years), if
the level of ground water contamination is not reduced. The
hazard index for a child in this hypothetical residence is 3,
indicating a potential for adverse non-cancer effects. This
exposure will not occur if new homes are not built on the
Site. .
SOIL: CURRENT TRESPASSERS^ FUTURE RESIDENTS ON-SITE. Excess
lifetime cancer risks from incidental soil exposure ranged
from 7 x 10"5 for potential on-site residents to 2 x 10"6 for
current adolescent trespassers. This means that, if surface
soil was not remediated, as many as 7 additional people out of
100,000 exposed would be at risk of developing cancer. The
hazard indexes for this exposure route ranged from 6 for on-
site residents to 0.2 for off-site residents and trespassers,;
This suggests that surface soil, if unremediated, presents a
moderate hazard for non-carcinogenic effects. j
AIR: CURRENT TRESPASSERS & FUTURE RESIDENTS ON-SITE. Excess
lifetime cancer risks from inhalation of potentially
contaminated air ranged from 7 x 10"5 for potential on-site
residents to 7 x 10"7 for current adolescent trespassers. This
means that, if volatilization of contaminants is not
prevented, as many as 7 additional people out of 100,000
exposed could be at risk of developing cancer. The hazard
indexes for this exposure route ranged from 0.6 for an on-site
residents to 0.006 for trespassers. This suggests that air
emissions from the Site have little potential for non-
carcinogenic effects.
LEACHATE, SURFACE WATER & SEDIMENTS: COMBINED CURRENT &
FUTURE RESIDENTS ON-SITE. Combined excess lifetime cancer
risks from exposure to contaminated leachate, surface water,
and sediments ranged from 2 x 10"5 for on-site resident
children to 6 x 10"6 for on-site resident adults. Combining
these risks across age groups, this result means that up to 2
additional people out of 100,000 exposed could be at risk of
developing cancer. The hazard indexes for this exposure route
ranged from 4 for on-site resident children to 0.5 for on-site
resident adults. This suggests that surface water and
sediments, particularly those associated with leachate and
seeps, have a moderate potential for causing adverse health
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:j
V
<
effects in children.
Remedial action is generally warranted when the calculated
carcinogenic risk level exceeds 1 x 10"4, or when the hazard index
exceeds 1. At the 1 x 10"* level, one additional person out of
10,000 is at risk of developing cancer caused by a lifetime of
exposure to the contaminants in question. At a hazard index of 1,
an exposed receptor is receiving the highest dose of Site related
contaminants that EPA believes will be without adverse effect.
Accordingly, actual or threatened releases of hazardous substances
from this Site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
B. ECOLOGICAL RISKS
Historical records from the Commonwealth of Pennsylvania indicate
that none of the fishes, amphibians, reptiles, birds, or mammals
listed as endangered or threatened are known to occur at or in the
immediate vicinity of the Site. No critical or unique habitats
have been identified at the Site or in the immediate vicinity.
Historical records indicate no sightings of endangered or
threatened plants at the Site or in the immediate area. However,
three plant species of special concern have been sighted from 2 to
3 miles from the landfill: Lance-leaved Salvia reflexa (sedge) ,
Mead's Carex meadii (sedge) , and hard-leaved Solidago rigida
(goldenrod) .
The United States Department of Interior (DOI) expects the only
fish and wildlife species to be affected by this Site are migratory
birds. Based on observations made during a February 1992 site
visit, a diverse mixture of terrestrial habitat types occurred
across the Site. These habitats support robins, chickadees, crows,
mourning doves, red-tailed hawks, slate-colored juncos, and
sparrows. In addition, other bird species expected to be present
include titmouse, cardinal, woodpeckers, brown creeper, wren,
killdeer, goldfinch, and sharp-shinned hawk. The majority of the
Site is covered with grasses, with the exception of portions of the
trench fill area. These portions of the Site are likely to support
local populations of invertebrates and small mammals such as field
mice, rabbits, voles, and woodchucks. Deer and rabbit tracks have
been observed. A detailed ecological characterization will be
conducted to support Remedial Design activities.
Anadromous fish such as alewife may someday return to Jordan Creek
once restoration efforts on the Lehigh River are complete. Fish
passage facilities have already been built at two of three Lehigh
River dams, and construction is. currently underway at. the third.
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Based on the evaluation of the Nature and Extent of Contamination
at this Site as described in Section V.E.I "Leachate", Section
V.E.3 "Ground Water", Section V.E.4 "Surface Water", and Section
V.E.5 "Sediments" of this document, a variety of migratory birds
probably consume contaminated water and sediments at various
leachate seeps, or contaminated surface water and sediments in the
various ponds and depressional areas on the landfill surface. Such
exposure to the various metals exceeding water quality criteria and
the organic compounds poses an unacceptable threat to these
resources.
Sampling results indicate that leachate seeps, stormwater retention
ponds, and isolated ponded water areas on the Site contain metals
including cadmium, beryllium, copper, iron, and zinc at
concentrations exceeding the EPA acute and/or chronic water quality
criteria. Sediment metals concentrations did not appear to be
high, but most of the samples were collected at either inlet or
outlet locations, thus possibly biasing the sediment results on the
low side. Outlet locations would not be expected to yield worst-
case results, since most contaminants should settle out long before
reaching the outlet location; inlet locations may also be poor
sample collection areas. Without further information on whether or
not a depositional ("delta") area was sampled, it cannot be
determined if these locations were suitable. -L
Adverse effects on migratory birds of consuming contaminated water
and sediments at the Site are likely. The "Terrestrial Risk"
assessment in the RI/FS states that the degree of wildlife exposure
to the various pathways of contamination was difficult to quantify.
However, the surface water and sediment sampling and ecological
characterization to be done during Remedial Design will provide
additional opportunity to refine Remedial Actions to fully protect
fish and wildlife species utilizing the Site.
The RI/FS stated that the Site is not having an effect on Jordan
Creek. This conclusion was based primarily on sediment sampling
results which showed heavy metals in creek sediments adjacent to
the Site occurring in concentrations similar to those found
upstream of the Site. Although the stream sediment sampling was
insufficient to support this conclusion, based on the low
concentrations of contaminants in the ground water at the Site and
the lack of significant surface water pathways from the Site to
Jordan Creek, it is unlikely that the Site would have a measurable
adverse effect on aquatic life in the creek.
In summary, the Site poses a number of risks to human health and
the environment. Leachate seeps pose risks to Site visitors and
trespassers. Leachate also enters the local natural environment
through run-off into surrounding soils. We also know that leachate
continues to discharge to the groundwater from the uncapped
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/5R308907
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landfill'. Alternatives to address reduction of these risks were
developed and evaluated.
VII. DESCRIPTION OF ALTERNATIVES
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 alternative examined satisfy each of the
above statutory requirements is provided below.
The intent of this action is to reduce the health risk to people
through elimination of present and potential future routes of
exposure. In accordance with 40 CFR §300.430 a list of remedial
response actions and representative technologies were identified
and screened to meet the remedial action objectives at this Site
(see Table 8) . The FS studied a variety of technologies to
determine if they were applicable for addressing the contamination
at the Site. Those technologies determined to be most applicable
were then developed into remedial alternatives. In addition, EPA
has evaluated the No Action Alternative (Alternative 1) as required
by the National Contingency Plan (NCP). These alternatives are
presented and discussed below. All costs and implementation time
frames provided for the alternatives below are estimates.
The following alternatives, which were identified and evaluated in
the FS, will be discussed with respect to: the remedial action
objectives, effectiveness, implementability, and cost. For ease of
comparison, all the remedial alternatives have also been summarized
in Table 5. Note that the cost and time factors listed in this ROD
and Table 5 are estimated values based on best engineering judgment
by EPA. -''
.Alternative 1 - No Action
Capital Cost: $ O
Operation and Maintenance (O&M) Costs: $ 59,189/yr
Present Worth: $ 557,967
Implementation Time: Immediately
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tit
Pursuant to the NCP, this alternative was developed to provide a
baseline to which the other remedial alternatives can be compared.
For the purposes of this alternative, no action is considered to be
"no further action" and includes, as part of the costs, annual
monitoring of 12 existing monitoring wells, and 11 residential
wells in the surrounding community. This on-going cost is also
included in all of the other alternatives described below. This
alternative, which involves no remediation, is considered in the
detailed analysis to provide a baseline to which the other remedial
alternatives can be compared,
Alternative 2 - Vents
Capital Cost: $ 539,859
O & M Costs: $ 65,629/yr
Present Worth: $ 1,157,540
Implementation Time: 18 months
Alternative 2 would include all of the actions listed above in the
"no action" alternative, with the addition of deed restrictions,
perimeter fences and gas vents installed on the immediate landfill
property. Deed restrictions would prohibit use of the Site for
human habitation or other uses that would cause unacceptable risks
until such time.as the risk levels in the various exposure media
were reduced to acceptable levels. Eight foot perimeter fences
would inhibit trespassing and minimize that route of potential
exposure. Under this alternative, landfill gas would b£
intercepted by passive trench vents and pipe vents constructed
along the landfill boundary and across fracture traces. Monitoring
wells and residential wells would be sampled annually and bottled
water would be provided to residences where acceptable contaminant
levels are exceeded.
Alternative 3 - Soil cover with Vents and Leachate Collection
Capital Cost: $ 5,930,107
O & M Costs: $ 118,285/yr "
Present Worth: $ 7,045,170 . "
Implementation Time: 2 to 3 years
In addition to the deed restrictions and passive gas vents
described in Alternative 2, Alternative 3 includes regrading the
existing Site topography, upgrading the existing soil covers in the
"Old Mine and Demolition Fill Areas, and constructing a 2-feet thick
vegetated soil cover over the Surface Fill and Trench Fill Areas.
The Site would be regraded to provide drainage and to minimize soil
erosion. Surface-water controls, such as swales, terraces, and
retention ponds would be constructed to provide proper surface-
water management. Subsurface drains, in and around the landfill,
would be constructed for leachate collection and the collected
-21-
flft308909
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leachate would be transported to an industrial pretreatment
facility. Residential treatment units instead of bottled water
would be provided to residences that are determined to exceed
acceptable contaminant levels. Alternative 3 would install
vehicular access obstructions at strategic locations in lieu of a
perimeter fence.
Alternative 4 - Partial Cap with Vents and Leachate Collection
Capital Cost: $ 12,778,070
O & M Costs: $ 92,459/yr
Present Worth: $ 13,649,670
Implementation Time: 2 to 4 years
In addition to: (a) the deed restrictions and passive gas vents
described in Alternative 2; (b) the vehicular access obstructions,
surface water controls, and provision of residential treatment
units described in Alternative 3; Alternative 4 provides for a
single barrier cap to be constructed over the Surface Fill and
Trench Fill Areas. A single barrier cap consists of an
intermediate soil cover, a synthetic membrane barrier, a synthetic
drainage layer, filter fabrics, a final soil cover, and vegetation
to prevent erosion. Additionally, the landfill gas migrating under
the Surface Fill and Trench Fill Areas would be intercepted by a
gas collection layer and discharged to the atmosphere through pipe
vents. Prior to construction of the cap, well points would be
installed for a one-time extraction/collection of existing leachate
in the Surface Fill and Trench Fill Areas. The collected leachate
would be transported to an industrial pretreatment facility for
disposal.
Alternative 4A Cap with Vents and Leachate Collection
Capital Cost: $ 15,233,549 '
0 & M Costs: $ 92,459/yr
Present Worth: $ 16,105,149
Implementation Time: 2 to 4 years
Alternative 4A is a combination of several components of
Alternatives 2, 4 and 5. Under this alternative, deed restrictions
would be implemented and a perimeter fence would be installed.
During Remedial Design, additional sampling and assessment of
environmental risk would be performed on the sediments and water in
all on-site surface storm-water and leachate drainages and other
standing water areas outside of the proposed landfill cap area.
Any contaminated sediments would be tested to determine whether
they are hazardous wastes under RCRA, and then removed to other
parts of the landfill as fill material if not hazardous waste, or
transported off-site for disposal at a hazardous waste facility, if
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&R3Q89IO
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,
necessary. Contaminated water would be transported to a '"
pretreatment facility with the leachate. The existing topography
would then be regraded to provide drainage and to minimize soil
erosion throughout the Site. Then a single barrier cap, consistent
with current PADER Residual Waste Management Requirements, would be
constructed over the Surface Fill, Trench Fill, Old Mine and
Demolition Fill Areas. The landfill's structural stability would
be routinely monitored.
A landfill gas venting system utilizing a combination of a gas
collection layer and a pipe collection system would be installed
over the entire waste area. Passive trenches and pipe vents would
be installed over fractures. During the pre-design stages of the
Remedial Design and during the Remedial Design, additional air
monitoring including direct gas vent and well monitoring would be
conducted to determine whether flaring of the gas and/or an active
collection system are necessary to protect human health and the
environment.' If at any time thereafter, EPA determines that
constituents of the gas or flow of the gas are such that a threat
to human health and the environment may be present, flaring and/or
an active system will be added.
Permanent wells would be installed prior to construction of the cap
in the Surface Fill and Trench Fill Areas to pump leachate into
temporary on-site storage tanks. Any leachate observed in the Old
Mine and Demolition Fill Areas during Remedial Design would also be
collected. The collected liquid would be transported via tanker
truck to an approved wastewater treatment facility. The permanent
wells would be used to monitor leachate after the Remedial Action
is completed to assess the need for further pumping.
A ground water sampling and analysis program, including new
monitoring wells around RW-13, would be formulated during Remedial
Design. The RW-13 area would also be investigated during the RD/RA
to determine whether the source of this contamination is Site
related. If it is determined that the landfill remedy will not
reduce the contamination in the vicinity of this well to acceptable
levels, or the source of the contamination is determined to be
unrelated to the Site, EPA will issue an Explanation of Significant
Differences (BSD) or a ROD amendment. The ground water sampling
and analysis program also includes monitoring of 12 existing
monitoring wells and 11 residential wells in close proximity to the
landfill on at least an annual schedule. Any residences that are
determined to exceed acceptable contaminant levels as described in
Figure 5, with confirmation sampling for Site related chemicals,
would be provided with residential treatment units or waterline
hook-ups, according to which option was most implementable. It is
anticipated that the ground water in the on-site wells will achieve
restoration to background levels in fifteen (15) years. If
background is not achieved in 15 years, other appropriate measures
will be implemented to achieve background (or MCLs).
-23-
AR3089II
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Alternative 5 - Partial Cap with Active Vents and Leachate
Collection
Capital Cost: $ 13,526,458
O & M Costs: $ 138,173/yr
Present Worth: $ 14,829,002
Implementation Time: 2 to 4 years
In addition to: (a) the deed restrictions and passive gas vents
described in Alternative 2; (b) the vehicular access obstructions,
surface water controls, and provision of residential treatment
units described in Alternative 3; Alternative 5 provides for a
single barrier cap to be constructed over the Surface Fill and
Trench Fill Areas. Additionally, the landfill gas migrating under
the Surface Fill and Trench Fill Areas would be intercepted by a
gas collection layer and vapor extraction wells would be used to
collect landfill gas along perimeter fractures. The gas collected
from the vapor extraction wells would be destroyed in a flare
system.
Prior to construction of the cap, well points would be installed
for a one-time extraction/collection of existing leachate in the
Surface Fill and Trench Fill Areas. The collected leachate would
be transported to an industrial pretreatment facility for disposal.
Alternative 6 - Partial Cap with Active Vents and On-Site Leachate
Treatment .
Capital Cost: $ 14,475,805
O & M Costs: $ 392,241/yr
Present Worth: $ 16,273,955
Implementation Time: 2 to 4 years
In addition to: (a) the deed restrictions and passive gas vents
described in Alternative 2; (b) the vehicular access obstructions,
surface water controls, and provision of residential treatment
units described in Alternative 3; Alternative 6 provides for a
single barrier cap to be constructed over the Surface Fill and
Trench Fill Areas. Additionally, the landfill gas migrating under
the Surface Fill and Trench Fill Areas would be intercepted by a
gas collection layer and vapor extraction wells would be used to
collect landfill gas along perimeter fractures. The gas collected
from the vapor extraction wells would be destroyed in a flare
system.
Prior to construction of the cap, well points would be installed
for a one-time extraction/collection of existing leachate in the
Surface Fill and Trench Fill Areas. The collected leachate would
be treated for metals by precipitation, coagulation/flocculation,
-24-
fiR3U89!2
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and gravity clarification. Treated leachate would then be piped to
a local POTW for discharge.
Alternative 7 - Partial Cap with Active Vents. On-Site Leachate and
Ground Water Treatment
Capital Cost: $ 13,545,906
O & M Costs: $ 478,677/yr
Present Worth: $ 15,990,741
Implementation Time: 2 to 4 years
In addition to: (a) the deed restrictions and passive gas vents
described in Alternative 2; (b) the vehicular access obstructions,
surface water controls, and provision of residential treatment
units described in Alternative 3; Alternative 7 provides for a
single barrier cap to be constructed over the Surface Fill and
Trench Fill Areas. Additionally, the landfill gas migrating under
the Surface Fill and Trench Fill Areas would be intercepted by a
gas collection layer and vapor extraction wells would be used to
collect landfill gas along perimeter fractures. The gas collected
from the vapor extraction wells would be destroyed in a flare
system.
Prior to construction of the cap, well points would be installed
for a one-time extraction/collection of existing leachate in the
Surface Fill and Trench Fill Areas. The collected leachate would
be treated for metals by precipitation, coagulation/flocculation,
and gravity clarification. Treated leachate would then be piped to
a local POTW for discharge.
In addition, ground water would be extracted from beneath the mound
in the southern portion of the Site using vertical extraction
wells. The extracted ground water would be piped, along with the
treated leachate to a local POTW for treatment and discharge.
Alternative 8 - Cap with Active Vents. On-Site Leachate and Ground
Water Treatment
Capital Cost: $ 15,804,903
0 & M Costs: $ 700,424/yr
Present Worth: $ 19,908,778 . .
Implementation Time: 2 to 4 years
In addition to: (a) the deed restrictions and passive gas vents
described in Alternative 2; (b) the vehicular access obstructions
and surf ace water controls described in Alternative 3; Alternative
8 provides for a double barrier cap over the entire waste area. A
double barrier cap differs from a single barrier cap in that the
double barrier cap is constructed with an additional 2 feet of clay
-25-
AR3U89I3
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«*'«*..
'
layer. Additionally, the landfill gas migrating under the waste
areas would be intercepted by gas collection layers and vapor
extraction wells would be used to collect landfill gas along
perimeter fractures. The gas collected from the vapor extraction
wells would be treated and disposed of through thermal destruction.
Prior to construction of the cap, well points would be installed
for extraction/collection of existing leachate in the Surface Fill
and Trench Fill Areas. The collected leachate would be treated for
metals by precipitation, coagulation/flocculation, and gravity
clarification.
In addition, ground water would be extracted and treated from
beneath the mound in the southern portion of the Site using
vertical extraction wells. The extracted ground water would be
piped, along with the treated leachate to Jordan Creek for
discharge. As part on the ongoing ground water monitoring program,
any residences determined to exceed acceptable contaminant levels
would be connected to the South Whitehall Township water supply
system.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
An analysis was performed on all of the alternatives using the nine
criteria specified in the NCP in order to select a remedy for the
NSL. An explanation of the nine criteria is attached as Table 5.
These nine criteria are as follows:
THRESHOLD CRITERIA .
1. Overall protection of human health and the environment
2. Compliance with applicable or relevant and appropriate
requirements (ARARs)
PRIMARY BALANCING CRITERIA
3. Long-term effectiveness
4. Reduction of toxicity, mobility, or volume through treatment
5. Short-term effectiveness
6. Implementability
7. Cost
MODIFYING CRITERIA
8. Community acceptance
9 . State acceptance
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AR3U89U
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These evaluation criteria relate directly to the requirements in ""-(//
Section 121 of CERCLA, 42 U.S.C. Section 9621, which determine the
overall feasibility and acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy to be
eligible for selection. Primary balancing criteria are used to
weigh major trade-offs between remedies. State and community
acceptance are modifying criteria formally taken into account after
public comment is received on the Proposed Plan.
The following is a summary of the comparison of each of the
alternatives' strengths and weaknesses with respect to the nine
criteria. Unless otherwise specified, all alternatives identified
as encompassing Alternative 4 shall include Alternative 4A. For
example, Alternative 3 through 8 includes Alternative 4 and 4A.
For ease of comparison, each alternatives' strengths and weaknesses
with respect to the nine criteria have also been summarized in
Table 7.
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. Each alternative's overall protection of human health
and the environment is evaluated on whether this alternative
attains all the remedial action objectives as listed on Table 8.
The remedial action objectives were developed based on the
intentions of the NCP, the results of the RI and the Baseline Risk
Assessment for the specific media present at this Site.
Alternatives 3 through 8, except Alternative 4A, would partially
attain the remedial action objectives established for the landfill
contents, on-site surface water and sediments, leachate, landfill
gas and ground water. Alternative 4A would fully attain these
objectives. Alternatives 3 through 8 would reduce the human health
risks associated with potential human health exposure pathways
exhibiting hazard indices exceeding one (1).
The greatest level of overall protection is provided by Alternative
4A. Due to the complex geology of fractures and joints that
underlie the topography throughout the Site, ground water movement
cannot be anticipated definitively. Therefore, by removing any
potential leachate from the Old Mine, Demolition Fill, Surface Fill
and Trench Fill Areas prior to capping and by constructing a single
barrier cap over the entire waste disposal area, Alternative 4A
would assure reduction of leaching and any potential leaching of
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TABLES: REMEDIAL ACTION OBJECTIVES
For Landfill Contents:
o Prevent direct contact to exposed landfill contents;
For Leachate:
o Prevent direct contact to the leachate seeps on the landfill surface;
o Reduce the leaching of constituents from the landfill contents to the ground water;
For Landfill Gas:
o Control subsurface off-site migration of landfill gas; and
o Control combustible gas concentrations;
For Ground Water
o Prevent human ingestion and inhalation of ground water containing site-related constituents in excess of
federal MCLs or Pennsylvania Water Quality Criteria (WQC); and,
o Prevent human ingestion and inhalation of ground water which would present excess lifetime cancer risks
greater than 1x10"4 or hazard indices greater than one (1);
o Remediate ground water to background levels;
For On-Site Surface-Water . .
o Remediate altered surface-water quality exhibiting excess lifetime cancer risks greater than IxlO"4 and
hazard indices greater than one (1);
o Prevent contact of surface water with landfill contents; and
o Control surface-water runoff and erosion;
For On-Site Sediments: - .'.
o Remediate altered sediment quality presenting/posing excess lifetime cancer risks greater than IxlO"4 and
hazard indices greater than one (J);
For Ecological Receptors: ,.
o Conduct chronic toxicity studies (through environmental risk assessments) to determine if low levels of
contamination may cause ecological impairment;
For Jordan Creek:
Based upon the analytical results of sediment samples taken from Jordan Creek, and an evaluation of
ground-water and surface flow characteristics, it was determined that the conditions of Jordan Creek
. downstream of the NSL are consistent with conditions upstream of the NSL, or background conditions.
Since inorganic sediment samples did not indicate that the creek was altered by surface water run-off from
the site, a determination was made to forego further investigations and actions regarding the creek;
-28-
4*3089
/6
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constituents from the landfill contents to the aquifer. This
action would allow for natural attenuation processes to more
rapidly restore the quality of the aquifer, thereby reducing risks
associated with exposure to ground water. The perimeter fence and
signs to be installed under Alternative 4A would deter potential
contact with landfill contents and seep areas by potential
trespassers from nearby recreational facilities and residential
communities. This measure would also serve to protect the control
systems and equipment to be installed on the landfill.
Through the installation of a soil cover or cap, Alternatives 3
through 8 including Alternative 4A would protect ecological
resources in that the cap or soil cover would be designed both in
terms of physical structure and ecological habitat to recapture
some if not all the ecological values that may be lost. For
example, landscape ecology would be employed along with undulations
in the surface material to restore the current conditions.
With the exception of Alternative 4A, Alternatives 1 through 8
provide no contingencies for removal of leachate in the Old Mine
and Demolition Fill Areas or evaluation and adjustment for the
unknown characteristics of the landfill gas. Alternative 8
provides protection through capping the entire waste disposal area
but does not provide contingencies for removal of leachate in the
Old Mine and Demolition Fill Areas. None of the Alternatives
except 4A provide contingencies for removal of contaminated surface
water and sediments on-site.
Alternative 2 attains certain remedial action objectives for the
landfill contents, gas, leachate, and ground water, but would not
attain any of the required, remediation levels. Under this
alternative, direct contact exposures to the landfill contents and
leachate would be restricted through installation of a perimeter
fence. This remedial action may limit potential trespasser
exposures to the waste and seep areas but would not protect Site
workers or the environment. Determined trespassers could breach
the security fence.
Alternative 1 would not provide protection of human health or the
environment because hazard indices greater than one (1) would not
be reduced and the landfill contents would remain exposed.
Since all of the remedial action objectives would be assured and
attained in Alternative 4A, Alternative 4A would be most protective
of human health and the environment.
B. COMPLIANCE WITH ARARs
Section 121(d) of CERCLA requires that remedial actions at CERCLA
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AR3089I7
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sites at least attain legally applicable or relevant and
appropriate federal and State standards, requirements, criteria,
and limitations which are collectively referred to as "ARARs",
unless such ARARS are waived under CERCLA Section 121(d)(4).
Applicable requirements are those cleanup standards, standards of
control, or other substantive requirements, criteria, or
limitations promulgated under federal environmental or state
environmental law or facility siting laws that specifically address
hazardous substances, pollutants, contaminants, remedial actions,
locations, or other circumstances at a CERCLA site. Only those
state standards that are identified by a state in a timely manner
and that are more stringent than federal requirements may be
applicable.
Relevant and appropriate requirements are those cleanup standards,
standards of control, and other substantive requirements, criteria,
or limitations promulgated under federal environmental or state
environmental law or facility siting laws that, while not
applicable to a hazardous substance, pollutant, contaminant,
remedial action, location or circumstance at a CERCLA site, address
problems or situations sufficiently similar to those encountered at
the CERCLA site that their use is well suited to the particular
site. Only those state standards that are identified in a timely
manner and are more stringent than federal requirements may be
relevant and appropriate.
On-site actions must comply with applicable and relevant and
appropriate requirements, but need comply only with the substantive
parts of those requirements. By contrast, ARARs do not apply to
off-site actions which must comply with legally applicable
requirements, including both substantive and administrative parts of
those requirements.
The applicable and relevant or appropriate requirements for the
alternatives developed in this ROD are listed below.
1. Landfill Contents
The landfill was permitted in 1972 by PADER as a municipal waste
landfill and operated until May 1990. Therefore the Pennsylvania
Municipal Waste Landfill Regulations, effective April 9, 1988, are
applicable for the landfill closure contemplated in Alternatives 3
through 8. Although EPA has evidence that wastes which were later
listed as RCRA hazardous may have been disposed of in the landfill
during the 1950's and 1960's, there is no conclusive evidence that
RCRA listed wastes were disposed of in the landfill after the
effective date of RCRA, November 19, 1980. Testing performed
during the RI/FS of the surface water, sediments, leachate, soils
and ground water does not show levels of hazardous substances at
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concentrations high enough to render any of those media j
"characteristic" hazardous wastes under, the RCRA toxicity I
characteristic (40 C.F.R. § 261.24). Therefore, the Pennsylvania *
Hazardous Waste Regulations do not apply. I
-31-
Pennsylvania's Residual Waste Management Regulations, effective *
January 21, 1992, provide requirements for residual waste
landfills. "Residual waste" is defined as,, among other things,
industrial waste which is not RCRA hazardous waste. An industrial ''
establishment is defined as an establishment engaged in \
manufacturing or processing. The landfill accepted waste from \
industries as well as municipalities and commercial operations. '
However, because the landfill closed in May 1990, prior to the \
effective date of these regulations, the Pennsylvania Residual
Waste Management Regulations would not be applicable to simply
capping the landfill contents, as in Alternatives 3 through 8 ;
(exclusive of Alternative 4A) . However, the removal of
contaminated sediments and the placement of these sediments in the ;
landfill prior to capping, as planned in Alternative 4A, would
constitute current disposal of residual wastes. In this case, the
Residual Waste Management Regulations would be applicable. Since
both the Municipal Waste Regulations, and the Residual Waste
Management Regulations address landfill closure, and the latter are
more stringent, the Residual Waste Management Regulations are the
primary source of the ARARs for this ROD. However, since the "
requirements for Municipal Waste Landfills at 25 PA Code Chapter .
273 are also applicable, they would take precedence where the
Residual Waste Regulations dp not address a particular issue. The
substantive requirements of the Residual Waste Management '.
Regulations governing landfills at 25 PA Code Chapter 288, <
including, but not limited to, the following specific regulations :
are applicable (many of these address media other than the landfill ;
contents): !
25 PA Code § 288.211 - Signs and markers - ;
§ 288.212 - Access control ,4
§ 288.213 - Access roads
§ 288.217 - Air resources protection
§ 288.218 - Nuisance control-
§ 288.220 - Litter
§ 288.231 - Topsoil storage
§ 288.232 - Daily.cover .
§ 288.233 - Intermediate cover and slopes
§ 288.234 - Final'cover and grading
§ 288.236 - Revegetation
§ 288.237 - Standards for successful revegetation
§ 288.241 - Water quality protection; general i
requirements
§ 288.242 - Soil erosion and sedimentation control
§ 288.243 - Sedimentation ponds
§ 288.244 - Discharge structures . .
AR3089.I9
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§ 288.245 - Water supply replacement
§ 288.251 - Water quality monitoring; general
requirements
§ 288.252 - Number, location and depth of monitoring
points
§ 288.253 - Standards for casing of wells
§ 288.254 - Sampling and analysis
§ 288.262 - Gas control and monitoring
§ 288.271 - Hazard prevention
§ 288.272 - Emergency equipment
§ 288.452 - Leachate treatment; basic treatment
§ 288.453 - Leachate transportation
§ 288.455 - Leachate collection and storage
§ 288.456 - Leachate analysis and sludge handling
2. Air Emissions
There are several potential sources of air emissions among the
remedies evaluated for this Site. First, the landfill is currently
emitting gases in an uncontrolled manner. Such emissions must be
controlled in accordance with the requirements for gas control and
monitoring included in the Pennsylvania Residual Waste Management
Regulations listed above (25 PA Code § 288.262).
The construction of the passive trenches and vents along the
perimeter fractures, as provided in Alternatives 2 through 4A, the
construction of a gas collection layer and pipe vents in the
Demolition Fill and Old Mine Areas and/or Surface Fill and Trench
Fill Areas, as provided in Alternatives 4 through 8 (including 4A) ,
the construction of vapor extraction wells along the perimeter
fractures and destruction by flare or thermal destruction, as
provided in Alternatives 5 through 8, and the construction of gas
extraction wells, as provided in Alternatives 7 and 8, would
necessitate compliance with the following additional ARARs:
The State Implementation Plan (SIP) for Pennsylvania as
incorporated at 40 CFR Subpart NN, § 52.2020 et sea. . which
includes, but is not limited to, the following substantive State
regulations: . - -
25 PA Code § 123.1 - Prohibition of certain fugitive emissions
(regulates emissions during construction)
§ 123.2 - Fugitive particulate matter (construction)
§ 123.31 - Limitations on odor emissions (crossing
property line)
§ 123.41 - Limitations on visible emissions/opacity
(including construction activities)
§ 123.43 - Measuring techniques for opacity
(including construction activities)
§ 127.12(a)(3)-(8) --Substantive elements of permit
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application for a new or modified source,
including use of Best Available Technology
(BAT) to limit emissions.
In addition to the construction of components to address gas
emissions from the landfill, the construction activity associated
with regrading and covering the landfill with a soil cover or cap
as provided for in Alternatives 3 through 8 would result in air
emissions. ARARs for this activity are included among those listed
above, relevant to construction activity.
Leachate collection and treatment prior to offsite shipment via
pipeline to a POTW or discharge to surface water would involve
metals precipitation, coagulation/flocculation, and gravity
clarification for Alternatives 6 and 7, and, in addition,
ultrafiltration and carbon adsorption for Alternatives 4A and 8.
If the use of these technologies in Alternatives 4 A (as a
contingency) and 6 through 8 result in any air emissions,
compliance with 25 PA Code § 127.12 (a) (3)-(8) , .including the
substantive elements of permit application for a new or modified
source, would be required.
In addition, the EPA guidance entitled "Control of Air Emission
from Superfund Air Strippers at Superfund Groundwater Sites," dated
June 15, 1989, OSWER Directive 9355.0-28, addresses air strippers
at Superfund Sites in ozone non-attainment areas. In addition tp
air strippers, the guidance may be applied to VOC air emissions
from other vented extraction techniques, i.e., the gas collection
and venting system discussed above. This EPA guidance is a "To Be
Considered" (TBC) for Alternatives 2 through 8, which use leachate
treatment and/or gas venting systems.
Storage of leachate in tanks on-site prior to shipment to a
pretreatment facility as provided in Alternatives 3 through 5
(including 4A), and any storage of leachate in tanks prior to on-
site treatment in Alternatives 4A (contingency) and 6 through 8
would require compliance with State regulations governing storage
tanks containing volatile organic compounds at 25 PA Code §§
129.56-57.4
The majority of the gaseous emissions from the landfill are
methane; however, certain other toxic volatile organics have also
been detected. On May 30, 1991, EPA proposed a rule requiring
certain new and existing municipal solid waste landfills to install
a landfill gas collection and control system. The requirement to
install a collection and control system is based on estimated
annual nonmethane organic compound (NMOC) emissions. If the
The emissions from the gas and leachate collection and treatment systems provided for in Alternatives 4A through 8 are
not specifically addressed by the State regulations which deal with the release of volatile organic emissions by specific
sources.
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<*.'.
*'<'&
estimated NMOC. emissions exceed a certain level (e.g., 150 Mg/yr as
proposed) a collection and control system would be required. This
proposed rule, which is a Maximum Achievable Control Technology
(MACT) standard to be promulgated under Section 112 of the Clean
Air Act, is a TBC for all Alternatives under this ROD.
3. Surface Water Discharge
Construction activities in Alternatives 2 through 8 must comply
with the requirements in 25 PA Code §§ 102.11 - 102.24 for erosion
and sedimentation control and restoration, which are applicable to
any earth-moving activities.
Alternatives 3 through 8 include some form of collection and
treatment of leachate prior to discharge to surface water off-site.
All of these Alternatives would be required to meet the ARARs
regarding leachate under the Pennsylvania Residual Waste Management
Regulations listed above.
Alternatives 3 through 5 (including 4A) provide for transport via
tanker to a pretreatment facility prior to discharge to a POTW.
The applicable regulations listed above include 25 PA Code §§
288.453 (leachate transportation) and § 288.455 (leachate
collection and storage).
Alternatives 6 and 7 provide for on-site treatment of leachate
through metals precipitation, coagulation/flocculation, and gravity
clarification prior to discharge via pipeline to a POTW. In
addition to the PA Residual Waste Regulations listed above, the
more stringent of the Clean Water Act Pretreatment Regulations for
Existing and New Sources ofPollution at 40 CFR Part 403 or the
Clean Streams Law Pretreatment Requirements for Industrial Users atx
25 PA Code § 97.91, and the EPA-approved Pretreatment Program for
the local POTW would be applicable to this activity.
Alternatives 4A (as a contingency) and 8 provide for on-site
treatment of leachate prior to discharge to surface waters. In
addition, Alternative 4A includes the removal of and treatment of
contaminated on-site surface waters from ponds and drainage ditches
with the collected leachate; these treated waters would be
discharged to surface waters with the treated leachate, if this
contingency was chosen. Due to the fact that the receiving stream,
Jordan Creek, is located only 700 feet from the landfill, for
purposes of determining ARARs, this is considered an on-site
discharge under CERCLA and the National Contingency Plan (NCP).
Such surface water discharges would have to comply with the more
stringent of the substantive requirements of the Clean Water Act
and the PA Clean Streams Law regarding discharges to surface
waters. The following ARARs would apply:
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40 CFR Part 122 - National Pollutant Discharge Elimination System
40 CFR Part 131 - Water Quality Standards
25 PA Code Chapter 92 - National Pollutant Discharge Elimination
System: regarding permit applications,
permit conditions, and monitoring
25 PA Code Chapter 93 - Water Quality Standards: regarding water
quality criteria which must be used in
the development of the discharge permit.
Delaware River Basin Commission (DRBC) Authorizations
4. Sediments/Leachate Sludge
Under Alternative 4A, contaminated on-site sediments from ponds and
drainage ditches will be removed. A determination of whether the
materials are hazardous wastes shall be made in accordance with 25
PA Code § 262.11 and 40 CFR § 262.11. If these sediments are not
determined to be hazardous wastes under federal and State law, they
will be placed in the landfill and covered by the cap. If the
sediments are determined to be hazardous wastes, they will be
transported off-site to a licensed hazardous waste disposal
facility in accordance with the requirements of federal and State
regulations as follows: V
.1) storage on-site in containers for less than ninety (90)
days must be in accordance with the substantive requirements
of 25 PA Code Chapter 262.34. In the event that storage is
not as specified above, the provisions of 25 PA Code Chapter
264 Subchapter I (for containers) Subchapter K (for surface
impoundments) or Subchapter L (for waste piles), as well as
Subchapters B (general facility standards), C (preparedness
and prevention), D (preparedness, prevention and contingency
(PPC) plan and emergency procedures), F (groundwater
monitoring) and G (closure and postclosure care applicable to
containers, waste piles and surface impoundments), would also
be applicable to the design, construction and maintenance of
the area into which the treated sediments are deposited; and
40 CFR § 268.50 (prohibitions on storage of restricted wastes)
would also apply;
2) manifesting must be in accordance with 25 PA Code Chapter
262, Subchapter B, and land disposal restrictions (LDR)
certification must be performed in accordance with 40 CFR §
268.7 (waste analysis and recordkeeping);
and
;*
3) the requirements applicable to generators of hazardous
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waste under 25 PA Code Chapter 262 would also be applicable.
In addition, under Alternatives 4A (as a contingency) and 6 through
8, on-site treatment of leachate will result in the production of
a sludge and other treatment residues. This sludge and other
treatment residues will be disposed of on-site, unless it is
determined to be hazardous in accordance with the State and federal
regulations cited above, in which case it will be handled in the
same manner set forth in the preceding paragraph regarding
sediments.
5. Ground Water
Ground water monitoring will be conducted under all of the
Alternatives. The relevant and appropriate standards for ground
water are the more stringent of the State Water Quality Standards
for drinking water use at 25 PA Code Chapter 93, the non-zero
Maximum Contaminant Level Goals (MCLGs), or the federal or state
Maximum Contaminant Levels (MCLs) promulgated under the Safe!
Drinking Water Act at 40 CFR Part 141 Subparts B, F, and G. In
addition, the State has identified attainment of "background" water
quality as an ARAR.
Under Alternative 4A, a timeframe is established for groundwater
quality to achieve background levels. The applicable requirement
for establishing background is 25 PA Code § 288.252, which
addresses the number, location and depth of monitoring points.
6. Wetlands
Alternatives 2 through 8 all involve some construction activity on-
site. These alternatives must comply with the applicable
requirements regarding wetlands protection and replacement as
contained in 25 PA Code Chapter 105, including Sections 105.17,
105.18a, 105.20a and 105.451. Executive Order 11990, "Protection
of Wetlands", which requires the avoidance, to the extent possible,
and the minimization of adverse impacts associated with the
destruction or loss of. wetlands, is a "To Be Considered" (TBC) for
Alternatives 2 through 8.
7. Wildlife Habitat
Alternatives 2 through 8 all involve disturbance to the surficial
features of the Site. For any activities conducted under these
Alternatives which would result in the control or structural
modification of any natural stream or body of water, which may
affect fish and wildlife, the substantive requirements of the Fish
and Wildlife Coordination Act,- 16 U.S.C. 661 et seq.. and the
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regulations promulgated thereunder would be ARARS. These
regulations require consultation with the Fish and Wildlife Service
and the appropriate State agency to determine how to mitigate,
prevent and compensate for project-related losses of wildlife
resources.
8. Historic Sites/Artifacts
Alternatives 2 through 8 would be subject to the requirements of
Section 106 of the National Historic Preservation Act and 40 CFR §
6.301(b) for the preservation of historic, architectural,.
archeological, and cultural sites. Measures must be taken to
preserve historic artifacts located within 1/4 mile of facilities
listed on the Pennsylvania Inventory of Historic Places and within
one mile of facilities listed on the National Register of Historic
Places.
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. . |
-ii
The hazard index for all potential receptors is greater than 1 for
direct contact with the seep areas at the Site. Alternatives 3
through 8 would effectively reduce this risk over the long term
through collection and off-site or on-site treatment of leachate,
and construction of physical barriers over the seep areas.
As no remedial action is planned under Alternatives.1 and 2, the
magnitude of risks identified in the Risk Assessment portion of the
RI report will remain; however, some of the risks may gradually
reduce due to natural attenuation. The landfill would continue to
be a major source for leachate migration to groundwater. Landfill
gas would also continue to migrate through the existing cover.';
Therefore, these alternatives are. not effective in the long term.
Under Alternatives 2 through 8, long-term periodic monitoring of
groundwater would help to track contaminants and future remedial
action would depend upon these monitoring results. Deed
restrictions on the property would mitigate exposure possibilities-,
which would protect human health but not the environment..
Under Alternative 4A however, long-term periodic monitoring of
groundwater, air, leachate and the cap's structural stability would
help to track not only contaminant activities in these media, but
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determine specific effectiveness of each component of the remedial
action. Deed restrictions and perimeter fence would further
mitigate exposure possibilities, which would not only protect human
health but also safeguard the control systems and equipment
installed to protect the environment.
Alternatives 7 and 8 incorporate ground water extraction and
treatment which would reduce the toxicity of contaminants in ground
water over the long term.
The greatest level of long term effectiveness is provided by
Alternative 4A. Due to the complex geology of fractures and joints
that underlies the topography throughout the Site, ground water
movement cannot be anticipated definitively. Therefore, by
removing any leachate from the Old Mine, Demolition Fill, Surface
Fill and Trench Fill Areas prior to capping and by constructing a
single barrier cap over the entire waste disposal area, Alternative
4A would assure reduction of leaching and any potential leaching of
constituents from the landfill contents to the aquifer. This
action would allow for natural attenuation processes to more
rapidly restore the quality of the aquifer. The perimeter fence
and signs to be installed under Alternative 4A would prevent
potential contact with landfill contents and seep . areas by
potential trespassers from nearby recreational facilities and
residential communities. This measure would also serve to protect
the control systems and equipment to be installed on the landfill.
D. REDUCTION Of TOXICITY, MOBILITY, or VOLUME THROUGH
TREATMENT
Reduction of toxicity, mobility, or volume through treatment refers
to the anticipated performance of a remedy with regard to its
ability to permanently destroy or detoxify the contaminants on the
Site. ...
The ground water monitoring, deed restrictions, perimeter fence and
vehicle access obstacles planned under Alternatives 1 through 8 do
not treat the contaminated surface waters, sediments, soils, ground
water, leachate, or landfill gases, and consequently, these
components would not provide any reduction in the toxicity,
mobility, or volume of the contaminated media. Therefore
Alternative 1, which includes only ground water monitoring, would
provide for no reduction in toxicity, mobility, or volume.
Through installation of a soil cover or a cap on the landfill,
infiltration of precipitation into the landfill would be reduced.
Consequently, the quantity of leachate generated within the
landfill would also decrease. The degree of leachate reduction
depends on the level of containment. The soil cover over the
entire waste area proposed in Alternative 3 would not provide the
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adequate degree of containment and therefore would not adequately
restrict mobility of the contaminants. The single barrier cap
proposed in Alternatives 4 through 7, not including Alternative 4A,
would be designed according to the performance specifications of
the PA Municipal Landfill Regulations in the Surface Fill and
Trench Fill Areas only. This would not restrict mobility of the
contaminants in the Old Mine and Demolition Fill Areas.
Alternatives 4A and 8 cap the entire waste area using at least a
two foot layer of clay as specified in the PA Residual Waste
Management Regulations, and therefore adequately restrict mobility
of the contaminants. Since the contaminated contents of the
landfill would be confined through sealing from the top, leachate
generation would be reduced (and thus groundwater contamination
would also be reduced) and mobility of the contaminants would be
restricted. However, soil covering and capping by itself would hot
reduce the toxicity or volume of the contaminants in the landfill
contents.
A passive gas collection system would vent the landfill gas to the
atmosphere in a controlled manner. (The gas is currently escaping
at random). Even though it will not reduce toxicity, mobility, or
volume through treatment, venting would help to alleviate a
possible pressure buildup of gases within the landfill.
Alternatives 2 through 4 would provide for such a system.
Alternatives 5 through 7 provide for active vapor extraction and
flaring, which would reduce the volume of the gases. However;
flaring would not necessarily mitigate any potential toxicity of
gases collected.
If it is determined that landfill gas emissions would need to be
treated before being released into the atmosphere, treatment
proposed in 4A and 8 would reduce VOCs and methane, which would
mitigate the toxicity of landfill emissions.
Since leachate would be collected and treated by a pretreatment
facility or on-site treatment to remove or destroy toxic
constituents before discharge, this would result in a reduction in
toxicity of the leachate. In addition, due to leachate pumping,
less contamination will reach the ground water, thus reducing the
mobility of these contaminants. Groundwater contamination would be
allowed to attenuate naturally. Alternatives 3 through 8 would
reduce mobility, toxicity, and volume of leachate, to a substantial
extent, through treatment. However only Alternative 4A would
provide permanent monitoring wells to assure that leachate would
not be allowed to migrate into the soil and groundwater. Any
leachate detected during the ongoing monitoring will be collected
and treated to reduce toxicity prior to discharge. Also
Alternative 4A is the only alternative that provides for the
contingency of treatment of any leachate encountered in the Old
Mine and Demolition Fill Areas.
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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.
Under Alternative 1, monitoring rather than remedial actions are
planned. These activities would not pose any short-term risk to
the community. Monitoring would be carried out by workers using
the proper levels of personal protection as specified in OSHA.
There would not be any environmental impacts from these non-
construction activities.
The institutional controls, monitoring and access measures
discussed in Alternatives 2 through 8 would not pose any risk to
the community. Monitoring and access restrictions would be carried
out by workers using the proper levels of personal protection as
specified in OSHA. There would not be any environmental impacts
from these non-construction activities. Installation of barricades
may take approximately three to four weeks. Deed restrictions can
be in place within a couple of months.
Under Alternatives 3 through 8, the soil covering and, in the case
of Alternatives 4 through 8, capping contemplated would involve
constructing a multilayered soil cover or cap over the landfill.
During construction, potential short-term environmental impacts
would include noise, dust, and increased traffic through
neighborhoods. These activities are not likely to pose any
significant risk to the community. Workers involved in the
construction task would follow OSHA specified health and safety
practices in accordance with 20 CFR 1910.120. Exposed surfaces of
landfill contents would be kept to a minimum to reduce potential
on- and off-site exposures using operational controls such as
following soil and erosion plan guidelines. Monitoring of ambient
air will be carried out along the perimeter and at the work sites
to identify potential exposure to workers and residents.
Operational procedures during field activities will be designed to
reduce emissions. Smoking will not be allowed in the area of
potential emissions. Construction of the landfill, cap may take
several months.
Under Alternatives 3 through 8, short-term environmental impacts
due to passive or active leachate collection and on-site or off-
site treatment would be similar to those discussed for landfill
soil covering and capping. Workers engaged in sampling,
construction, operation, and maintenance of the leachate collection
and treatment systems would have to follow approved health and
safety procedures. Construction may take several months, and
operation and maintenance would- be long term.
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For Alternatives 2 through 8, during sampling and construction of
the landfill gas collection and, in Alternatives 4A through 8,
treatment system, short-term environmental impacts, similar to
those discussed for landfill soil covering and capping would occur.
Standard health and safety practices would be adhered to by
construction workers. No smoking would be allowed around gas
collection and treatment activities, to minimize the potential for
fire due to the methane content of landfill gas. Special drilling
techniques and increased air monitoring for methane would be
carried out to avoid an explosion. Construction activities would
take a few months and operation and maintenance would be long term.
Alternative 1 is a no-action alternative and could be implemented
immediately. Alternative 2 could be implemented within 18 months.
Alternatives 3 through 8 could be implemented within 2 to 4 years.
None of the alternatives pose any significant adverse impacts to
human health or the environment during implementation.
F. IMPLEMENTABILITY
Under the limited action components of Alternatives 2 through 8,
the use of deed restrictions is a reliable technique to achieve the
desired goal of preventing residential development on the landfill
and all the attendant risks. Decisions regarding monitoring
frequency and Site boundaries for perimeter fencing, vehicle
barriers or deed restrictions will be finalized by consulting with
EPA and the local authorities. Future remedial actions will be
based upon the monitoring results for leachate, ground water, and
landfill gas.
All of the other alternatives evaluated for this ROD involve
technology that has been proven feasible and is readily available.
Containment technologies such as soil covering and capping are
readily available and routinely constructed at landfill sites. The
main disadvantages of soil covering and capping are uncertain
design life and the need for long-term maintenance. There is some
"implementability" concern over the placement of a cap which would
comply with the requirements of PA Municipal Landfill Regulations
or the.PA Residual Waste Management Regulations, especially on the
steep slope areas of the landfill. This will be further evaluated
during the design phase of this project.
Adequate equipment and personnel are available to construct any of
the remedies from a number of sources located within a few miles of
the Site. Several qualified contractors are available to install
the soil cover and/or to construct the landfill cap. Other
additional remedial actions could be undertaken after installation
of the cap, if determined appropriate and essential. Long-term
monitoring and maintenance plans would also be designed and
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implemented.
Under Alternatives 2 through 8, venting of the landfill gas will be
accomplished through passive or active gas collection systems.
These systems involve installation of highly permeable (relative to
surrounding soil) wells that would provide pathways for gas to flow
to points of controlled release. The installation of these wells
would require specialized drilling techniques to prevent methane
explosions. These types of techniques are routinely used. The
design of the gas collection system would require a test well to
determine the final system parameters (well size and numbers of
wells). Other limited data would also be collected during Remedial
Design, such as gas generation rate, moisture content, and
composition to assist in system design. This information would
also be collected during a long-term monitoring program and the
system would be modified accordingly.
Leachate collection and/or treatment systems as discussed under
Alternatives 3 through 8 are reliable and established technologies.
Design and installation of collection trenches are standard
techniques and could be readily accomplished. Potential problems
with installation include slopes around landfill, installation in
rock-outcropping and standard trench requirements (shoring).
Contractors are available to install the collection and treatment
system. Approval from regulatory agencies would be obtained before
construction of any system. Approvals for discharge to approved
wastewater treatment facilities or Jordan Creek through private
property would have to be obtained with the concerned parties.
The design information for the various media as discussed under
Alternatives 2 through 8 will need to be collected for final
determination of overall implementability and construction.
G. COST
Estimated Costs for the various alternatives are presented in Table
5.
Alternative 4A offers the greatest amount of protection in the long
term due to monitoring which may trigger contingent actions
including the installation of an active gas collection system,
ongoing leachate pumping, and treatment of contaminated surface
waters as described above in Section VII and more fully in Section
IX below. This measure, which was developed based on the fact that
the information collected during the Remedial Investigation was
inconclusive with regard to the threats posed by certain media, was
not considered by the other alternatives. The cost of evaluating
such uncertainties or performing limited response actions such as
relocating potential contaminated sediments into the landfill
contents, should not affect the overall cost comparison. However,
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if subsequent investigation during Remedial Design warrants action
as described by this alternative such as treatment of the landfill
gas, collection of abundant leachate in the Old Mine and Demolition
Areas, or substantial treatment of on-site surface water, the
overall cost may increase considerably over the estimate provided
here.
Based on the cost comparison of Alternatives 1 through 8 and the
considerations discussed under the other criteria, EPA concludes
that the landfill cap, gas collection system, and leachate
collection system identified in Alternative 4A presents the most
cost effective proposal among those that provide the necessary
protection.
H. State Acceptance
Representatives of the..PADER have inspected the Site on a number of
occasions and have observed the condition of the exposed landfill.
The Commonwealth also feels that the issue of leachate, as it
impacts the area ground water needs to be addressed. Since
Alternatives I and 2 do not address these continuing sources of
contamination, the Commonwealth would not accept these
alternatives.
The Commonwealth has stated that the entire waste disposal area, as
it impacts the area ground water, needs to be capped. Alternatives
4, 5, 6, and 7 do not provide capping over the Old Mine and
Demolition Fill Areas. Consequently, the Commonwealth will not
concur with the selection of these alternatives.
Alternatives 4A and 8 both provide for capping the entire waste
disposal area, collection of leachate flows, potential treatment of
landfill gases and the consequent restoration of on-site ground
water quality through natural attenuation. Alternative 4A also
includes a timeframe to achieve restoration of ground water on-site
to background levels. In terms of reduction of risk to the
environment, both Alternatives 4A and 8 would be acceptable to the
Commonwealth. . .
I. Community Acceptance
Community Acceptance is assessed in the attached Responsiveness
Summary. In general,'commentors from the developing residential
community continue to be concerned over the future use of this
property and would be opposed to the no action and limited action
alternatives. The commentors from the community also agree that
the present condition is not protective of human health, and are
concerned about the emergence of new leachate streams on the
landfill. During the public meeting, the attendees agreed that
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something needed to be done to address the exposed landfill. This
is not adequately addressed by Alternatives 1 through 3.
Therefore, EPA believes that the community would not accept these
alternatives.
Furthermore, there appears to be general community agreement that
Alternative 4 is practical and will address identified community
concerns over the risks posed by the landfill as long as a diligent
monitoring and contingency program is continued.
With regard to Alternatives 5 through 8, opinions at the public
meeting were impartial towards any on-site treatment systems but
the main concern was regarding the complex geology and its effects
on ground water. As stand-alone alternatives, these alternatives
would not be acceptable to the community members who voiced an
opinion. The concern was that not enough controls and
contingencies were in place at potential source areas such as the
Old Mine and Demolition Fill Areas or the Maintenance Area near
residential well RW-13.
Alternative 4A was the alternative preferred by the community, as
it provides the most safeguards of any of the alternatives.
IX. SELECTED REMEDY AND PERFORMANCE STANDARDS
Based on the comparison of the nine evaluation factors for each of
the nine alternatives, Alternative 4A is the selected alternative.
The components of this selected alternative are as follows:
A. installation of perimeter fence;
B. deed restrictions;
C. removal of contaminated landfill surface water & sediments;
D. installation of landfill surface water control systems;
E. source containment by capping;
F. Site restoration;
G. gas collection system;
H. leachate collection and transport to a pretreatment facility
by tanker;
I. on-site leachate treatment and surface water disposal
contingency;
J. routine monitoring of ground water; and achievement of
background levels (or MCLs, whichever is lower) in ground
water;
K. operation and maintenance of the above systems;
L. 5-year review of the remedy.
If, after implementation of the selected remedy, monitoring of
physical and chemical evidence demonstrates that the remedy does
not meet the remediation requirements for this action, and it may
be technically impracticable -(either technically infeasible or
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unreliable) to achieve and maintain the capping, venting, leachate
collection system, and ground water restoration timeframe goals at
this Site, the EPA, in consultation with the Commonwealth of
Pennsylvania, would amend this ROD or issue an Explanation of
Significant Differences to inform the public of alternative
remedial measures.
Due to the fact that hazardous substances will remain on Site, the
five-year review required by Section 121(c) of CERCLA is applicable
to the selected remedy. This review will be conducted in
conjunction with the other remedial actions developed and specified
for this Site.
Approximate physical dimensions of various components are included
solely to facilitate understanding of the remedy. Actual
dimensions, if not explicitly specified, as well as other specifics
of design and construction and maintenance will be identified and
selected during the Remedial Design.
A. Installation of Perimeter Fence
Site access restrictions in the form of an 8-foot, security fence
and warning signs shall be installed and maintained around the Site
boundaries, prior to construction and thereafter, that shall
prevent potential contact with landfill contents and seep areas by
trespassers as well as protect the control systems and equipment
on-site.
B. Deed Restrictions
Deed restrictions shall be placed on the property within the Site
boundaries to prohibit: (1) the use of the land for residential or
agricultural purposes; and (2) the use of on-site ground water for
domestic purposes, including drinking water. The purpose of these
restrictions is to prevent excavation or construction on the capped
and closed landfill, and to prevent the risks associated with human
exposure to landfill contents, leachate and ground water.
G. Removal of Contaminated Landfill Surface water and
Sediments
Before construction of the cap or any surface regrading,
contaminated sediments shall be removed to other parts of the
landfill that will be covered by the cap as fill material unless
they are determined to be hazardous wastes under RCRA, in which
case they will be temporarily stored in containers on-site and then
transported to a licensed hazardous waste disposal facility.
Contaminated water shall be treated with the leachate.
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Sampling and assessment of environmental risk shall be performed on
the sediments and water in all on-site surface storm-water and
leachate drainages and other standing water areas including such
areas outside of the proposed landfill cap area in order to define
areas of contamination. Sediments and water sampled will be
considered to be contaminated if contaminants are present in excess
of levels determined by EPA to be safe for human health and the
environment. Also, a baseline environmental characterization shall
be conducted for all Site areas to be unavoidably impacted by
remedial activities to aid in design and implementation of Site
restoration.
D. Installation of Landfill Surface Water Control System
The existing topography shall be regraded to provide drainage and
to minimize soil erosion throughout the Site. Storm water run-on,
runoff and erosion controls shall: (1) effectively collect and
control at least the water volume resulting from a 24-hour,
100-year storm and prevent or effectively minimize erosion from the
Site property for a run-on design; (2) effectively collect and
control at least the water volume resulting from a 24-hour, 25-year
storm and prevent or effectively minimize erosion from the Site
property for a run-off design; and (3) be inspected and maintained
on a regular basis to insure compliance with the requirements of
(1) and (2) above (at least semi-annually). Surface-water controls
shall include swales, terraces, and retention ponds as necessary.
Dust, erosion and sedimentation controls shall be utilized during
construction to prevent to the extent feasible any release of
hazardous substances from the Site through these routes.
Implementation of dust controls and erosion and sedimentation
controls during construction shall comply with Pennsylvania
Department of Environmental Resources' Chapter 102 regulations as
explained in the EROSION & SEDIMENT POLLUTION CONTROL PROGRAM
MANUAL dated APRIL 1990 (as authorized under the Clean Streams Law,
35 P.S. § 691.202 et. sea.l
E. installation of Landfill Cap
In order to contain the landfill contents, a cap shall be
constructed to completely cover over the Surface Fill, Trench Fill,
Old Mine and Demolition Fill Areas so that all areas of disposal of
hazardous substances are covered. This cap shall be constructed to
meet the performance specifications applicable under Residual Waste
Management Regulations, 25 PA Code Chapter 288.
In accordance with 25 PA Code § 288.234, Final Cover and Grading,
the cap shall be constructed as follows (subject to EPA approval
during Remedial Design):
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^308931*
-------
(a) A uniform and compacted 2-foot layer of clay shall be
placed and graded over the entire surface of final soil
layer5, or a synthetic material in lieu of the clay
layer may be used. The cap shall-be no more permeable
than 1.0 x 10'7 cm/sec.
(b) A soil drainage layer, 12 inches thick with a hydraulic
conductivity of 10"7 cm/sec or greater, or a geosynthetic
drainage layer, capable of transmitting flow and
preventing erosion of the soil cover, shall be placed
over the cap.
(c) A uniform layer of clean cover soil, at least 2 feet in
thickness, shall be placed over the soil drainage layer.
This layer of material shall support vegetation and
protect the cap from erosion by wind and rain.
(d) Vegetation, to minimize erosion of the soil cover by wind
and rain, to the maximum extent practicable, shall be
planted in the soil cover.
F. Site Restoration
Site restoration shall include specific measures to promote
wildlife habitat diversity on the Site without jeopardizing the
integrity of the cap. Careful attention shall be paid to the
selection of plant species (with emphasis on use of native grasses
or vegetation indigenous to the area as well as those with food and
cover values) and planting patterns. Use of such vegetation shall
not prelude the use of annual grasses usually used to quickly
stabilize the cap soil. These aspects shall be detailed in the
remedial design. All planning activities associated with habitat
restoration shall be performed in consultation with the U.S. Fish
and Wildlife Service (FWS).
G. Installation of Landfill Gas Venting & Monitoring Systems
Landfill gas shall be collected and vented in a controlled manner
or treated to prevent any threats to human health and the
environment due to potentially toxic or explosive gases. A
landfill gas venting system utilizing a combination of a
(estimated) 12-inch thick granular gas collection layer and a pipe
collection system shall be installed over the Surface & Trench Fill
and Demo & Old Mine Areas in order to provide a controlled pathway
over the entire waste capped areas for the gas to migrate and be
The final soil layer constitutes earth used in the regrading of existing topography as described in Section IX.D ('Installation
of Landfill Surface Water Control System*) of this document
-47-
^308935
-------
vented. In addition, a series of passive trenches and pipe vents'
shall be installed and monitored along the fractures at the
landfill boundary in order to intercept the potential migration of
subsurface landfill gas off-site. The number, location and
placement of these vents and the venting system shall be developed
during Remedial Design. These vents shall be monitored quarterly
to detect emission of gas volume and constituents of the gas for a
period of 30 years or until EPA determines that no gas monitoring
is necessary.
Since the ambient air sampling effort in the RI/FS was not
sufficient to determine the constituents of the gas in the
landfill, additional air monitoring including direct gas vent and
well monitoring shall be conducted during the pre-design stages of
the Remedial Design and during the Remedial Design. The results of
this program shall be used to determine whether the venting system
shall be passive or active. Any passive system shall be designed
to include vertical gas extraction wells that can be converted to
an active system if determined to be necessary to protect human
health and the environment in the future, based on the constituents
of the gas or the flow of the gas. At this 'time, the health
effects estimated from current data do not warrant gas treatment.
The landfill gas venting system shall meet the requirements for new
air emission sources as specified in 25 PA Code Chapters 123 and
127. in addition, all gas management systems shall meet current
Best Available Technology (BAT) criteria, as established by 25 PA
Code §127.12 (a) (5), specifically the new permitting criteria
issued by the Pennsylvania Bureau of Air Quality dated May 4, 1990.
H. Installation of Landfill Leachate Collection Systems
All leachate shall be collected and removed from the Waste Disposal
Areas as expeditiously as practicable prior to construction of the
cap. The collected leachate shall be-treated properly in order to
allow discharge to a POTW or a receiving stream. Permanent wells
shall be installed and the accumulated leachate shall be pumped
into temporary storage tanks that comply with the requirements of
25 PA Code §§ 129.56-57 and 288.455 prior to construction of the
cap in the Surface Fill and Trench Fill Areas. Any leachate
observed in the Old Mine and Demolition Fill Areas during Remedial
Design shall also be collected. Since it is conservatively
estimated that approximately 11,000,000 gallons of leachate is
contained in the Waste Disposal Areas, removal of this material is
expected to eliminate the leachate seeps and reduce constituent
migration pathways to the underlying aquifer and surface water.
Leachate removal shall be continuous and shall ensure that leachate
depth in the waste disposal areas does not exceed one (1) foot.
The collected liquid shall be transported via tanker truck to a
wastewater pretreatment facility prior to discharge to a POTW.
-48-
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Since a firm commitment has not been received from the Lehigh
County Wastewater Pretreatment plant, the following contingency has
been selected to prevent future complications and delays in the
remediation of this Site. If, at the onset of Remedial Design, a
firm commitment from an approved wastewater pretreatment facility
to accept the discharge for the duration of the remedial action has
been received and documented, then the Remedial Design shall
proceed with discharge to the approved wastewater treatment
facility. If a firm commitment has not been obtained within six
(6) months after EPA's approval of an Engineer to start the
Remedial Design, however, the remedy shall change to the
contingency and Remedial Design shall proceed with on-site
treatment and discharge to local surface water. However, if a
commitment is obtained at anytime prior to the start of Remedial
Action and the beginning of construction of a leachate treatment
facility, then the leachate can, upon approval by EPA, be
transported to the pretreatment facility and the contingent remedy
will not be usedi
I. Installation of the "Collected Leachate" Treatment System
(Contingency)
In place of off-site treatment and discharge of collected leachate.
to the POTW, the contingent remedy shall include on-site treatment
of the collected leachate and discharge to local surface water. In;
order to avoid potential delays due to construction of a pipeline
on private property, the treated water shall be discharged directly
from the Site to Jordan Creek via a planned storm sewer located
north of the Site. All other components of the selected remedy
discussed above shall be identical. The capacity of the collection
and treatment system shall be determined by EPA during Remedial
Design. The treatment system shall be constructed and operated to
insure compliance with both air emissions standards in 25 PA Code
Chapters 123 and 127, and complianpe with the CWA as specified in
40 CFR Part 122 subpart c and PA Clean Streams Law, as specified in
25 PA Code Chapters 92, 93, 94, and 96..
J. Ground Water Monitoring? and Achievement of Background
Levels (or MCLs. whichever is lower) in Ground Water;
Background levels of contaminants in ground water or MCLs,
whichever is lower, shall be achieved in 15 years. Based on the
assumption that constituent concentrations will attenuate by
dispersion, adsorption and biodegradation, analytical modeling6
showed that as the plume migrates toward the northern property
boundary, the concentrations of 1,1-DCA, 1,2-DCE and TCE will
Analytical Modeling of Plume Migration in Saturated Bedrock'. Novak Sanitary Landfill, Vincent Uhl Associates, Inc., June
1993.
-49-
.R 3 0-8 9 3.7'
-------
decline to 1.0 ug/1 within 5 to 9 years after capping the landfill.
If ground water monitoring during each of the 5 year reviews does
not indicate a statistically significant decrease in contaminants
(using 40 CFR § 258, Subpart E) such that background levels could
be attained in 15 years, additional remedial actions shall be
implemented within the scope of this ROD to attain the performance
standards, unless at that time it is determined to be technically
impracticable to achieve background levels. EPA may issue an
Explanation of Significant Differences or a ROD amendment if any
additional remedial action with respect to ground water is
determined to be necessary which fundamentally alters the remedy
selected in the ROD with respect to scope, performance, or cost.
It is anticipated that the level of groundwater contamination and
the potential for off-site migration will decrease following
initial leachate removal and the completion of the landfill cap.
If contaminant levels in off-site wells increase to levels above
performance standards for a statistically significant period of
time (as referenced in 40 CFR § 258, Subpart E), EPA will issue an
Explanation of Significant Differences or a ROD amendment as
necessary depending on whether or not EPA decides to select
additional remedial action which fundamentally alters the remedy
selected in the ROD with respect to scope, performance, or cost.
The Performance Standard for the remedy for each contaminant of
concern in the ground water (see Table 9) shall be the lower of
either the background concentration, the SOWA non-Zero MCLG or the
federal or State MCL for that contaminant. The background
concentration for each contaminant of concern shall be established
in accordance with the procedures for ground water monitoring
outlined in 25 PA Code § 288.252. In the event that a contaminant
of concern is not detected in samples taken for the establishment
of background concentrations, the detection limit for the method of
analysis utilized with respect to that contaminant shall constitute
the "background" concentration of the contaminant.
The appropriate standards the detection limits'and the appropriate
analytical methods for testing for the contaminants of concern are
listed in Table 9. It should be noted that the remedy will address
not only contaminants of concern but also other hazardous
substances at the Site.
Due to the complex geology of fractures and joints that underlie
the topography throughout the Site, ground water movement cannot be
completely defined without further investigation. Therefore
specifics of a new monitoring well network will not be detailed
until the Remedial Design. Such a ground water monitoring program
shall be implemented to evaluate the effectiveness of the remedy in
meeting cleanup levels and to ensure protection of nearby
residents. This program may include the installation of new
monitoring wells. EPA shall determine the exact location of
-50-
flR3U89.38
-------
monitoring wells and residential wells to be included in the
monitoring program. The frequency and duration of sampling and the
analytical parameters and methods to be used shall also be
determined by EPA during Remedial Design; however, EPA anticipates
that the following wells shall be sampled at the following
frequencies for a period of 30 years upon issuance of this ROD.
Parameters to be monitored shall include constituents sampled
during the RI/FS (i.e., TCL VOCs, TAL metals/inorganics, and ground
water chemistry parameters).
l. 12 existing monitoring wells (MW-lC, MW-6, MW-7, MW-S, MW-io,.
MW-11, MW-16, MW-17, MW-18, MW-19, MW-20, and MW-21) at least
annually, as referenced on Figure 1 of this document.
2. 11 residential wells quarterly. These residential wells
include RW-1, RW-2, RW-3, RW-4, RW-6, RW-8, RW-9, RW-10, RW-
12, RW-15 and RW-16. However, other residential wells within
1 mile of the Site boundary may be substituted.
3. The recently deactivated Pheasant Hills Community Well and
Bridgeview East Wells, and the newly commissioned Cornerstone
Community Well annually.
Since it is not known if the landfill is the source of
contamination in the vicinity of decommissioned residential well
RW-13, additional monitoring wells shall be installed during the
Remedial Design sufficient to identify the source and define the
extent of the contamination plume in that region. The number and
location of these wells and resulting remedy is subject to approval
by EPA. If EPA determines that the source is not within the Site
boundaries or the contamination will not be affected by the
components of the landfill remedy, EPA may issue an Explanation of
Significant Differences or a ROD amendment if any additional
remedial action for the Site is determined to be necessary which
fundamentally alters the remedy selected in this ROD with respect
to scope, performance, or cost. ' . '
Any residential wells sampled during the RI/FS found to be affected
by contamination, as well as any other wells that are determined to
have Site-related contaminants, shall be evaluated based upon the
Decision Tree For Implementing Alternative Water Supplies as shown
in Figure 5. If the evaluation shows that an alternative water
supply is necessary, bottled water shall be provided initially and
a confirmatory sampling shall be taken immediately so that no
action is taken based on one result. When additional sampling has
confirmed that action is necessary, the affected residence shall be
hooked .up to a waterline if a waterline is available for that
property. Otherwise, the affected residence shall be provided with
-51-
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Contaminants of Concern in Ground Water
TABLE 9
Water Quality
Drinking Water
Contaminant
ORGANICS
benzene
bromodichloromethane
chlorobenzene
chloroform
dibromochloromethane
1 ,4-dichlorobenzene
1,1-dichloroethane
1 ,2-dichloroethane
1,1-dichloroethene
1 ,2-dichloroethene (cis)
1 ,2-dichloroethene (trans)
1 ,2-dichloropropane
1 ,3-dichloropropene (trans)
ethyl benzene
toluene
tetrachloroethene
1 ,1 ,1-trichloroethane
trichloroethylene
vinyl chloride
xylene (Total)
INORGANICS
cadmium
beryllium
MCL (ug/I)
5
100*
100
100*
100*
75
HQ@1=810
5
7
70
100
5
CR@10-*=9.6
700
1,000
5
200
5
2
10,000
5
4
POL
(ug/I)
2
5
5
5
5
5
5
5
5
5
5
5
5
2
5
5
5
5
2
5
1
3
SW-846
Method
8020
8240.8260
8240,8260
8240,8260
8240
8020,8260
8240,8260
8240,8260
8240,8260
8240.8260
8240
8240
8010,8240
8020
8240
8240
8240
8240
8010
8240,8020
7131
6010
MDL
(ug/0
0.10
0.08
0.14
0.03
0.05
2.00
0.07
0.22
0.19
0.12
0.19
0.17
0.20
0.04
0.12
0.29
0.24
0.36
0.31
0.05-0.2
1
0.30
EPA Method
502.2,503.1, 524.1, .2
502.2,524.2
503.1 ,502.1 ,.2,524.1, .2
502.2,524.2
502.2,524.2
503.1 ,502.1, .2,524.1, .2
601
502.1 ,.2.524.1. .2
502.1 ,.2.524.1 ,.2
502.1, .2,524.1 ..2
502.1 ,.2,524.1, .2
502.1, .2,524.1, .2
601
502.2,503.1, 524.1, .2
502.2,503.1, 524.1, .2
502.1, .2,503.1, 524.1. .2
502.1, .2,524.1 ,.2
502.1, .2.503.1, 524.1, .2
502.1 ..2,524.1 ..2
502.2,503.1 .524.1. .2
200.7A1,213.2
200.7,.8..9,210.2
HQ = Hazard Quotient ot one (1) for non-carcinogenic compounds lacking MCLs.
CR = Cancer Risk of 10"* for compounds lacking MCLs.
= Total trihalomethanes (Methods 502.2, 524.2)
200.7A1 = Method 200.7A, Appendix to Method 200.7, March 1987, USEPA, Environmental Monitoring and Support
-52-
-------
' W
Laboratory, Cincinnati, OH 45268 ('/;/:
"'4lfjf:
For water quality analysis, the practical quantification limit (PQL) has been selected over the method detection limit (MDL) because
detection limits (DL) are controversial and cause confusion. Different laboratories will produce different MOLs even though they use
the same analytical procedures, instruments, sample matrices, and methods. The PQL is about five times the MDL and represents
a practical and routinely achievable detection limit with a relatively good certainty that any reported value is reliable. Therefore all
laboratories can achieve the same PQLs. PQLs are applied in accordance with 40 CFR 264.97 (h).
For drinking water analysis, MDLs were selected over PQLs even though different laboratories will produce different MDLs using the
same analytical methods; EPA or State certified laboratories for drinking water analysis will be able to meet the MDLs. The decision
was based on the need for increased protection of human hearth through the use of the more stringent limit.
Water quality analysis constitutes samples taken from leachate, on-s'rte and off-site ground water monitoring wells, surface water, and
other sources not utilized for human consumption. Since the Site is a landfill, the test methods evaluate the presence of hazardous
wastes in all media as defined by the Resource Conservation and Recovery Act (RCRA).
Drinking water analysis constitutes samples taken from residential wells or other sources utilized for human consumption. The test
methods evaluate the presence of pollutants in Drinking Water and Raw Source Water.
SW-846 and TCLP Methods, used for TDS (Treatment Disposal Storage) Facility, are found in 40 CFR Part 264 Appendix IX 'Ground
Water Monitoring List* and 40 CFR Part 258 Appendix II 'List of Hazardous Inorganic and Organic Constituents'.
200 and 500 series Methods, used for drinking water only, are found in 40 CFR Part 141. Since drinking water regulations do not
exist for 1,1-dichloroethane and 1,3-dichloropropene (trans). Method 601 was used. Method 601 is found in 40 CFR 136.
a residential treatment unit sufficient to provide drinking water
that meets the more stringent of MCLs, State Safe Drinking Water
Standards or other appropriate levels as specified in Figure 5 and
Table 9. .
In the event that contaminants such as Vinyl Chloride are confirmed
to have affected a home well above acceptable levels, as it was in
the abandoned residential well RW-13, the affected residence shall"
be hooked-up to a waterline. This is necessary since standard
residential treatment units such as Granulated Activated Carbon
(GAC) are ineffective for Vinyl Chloride.
K. Operation and Maintenance
Operation and maintenance (O & M) of the remedy shall be conducted
at the.Site. This will include, but not-be limited to, O & M of
all components of the remedy such as the landfill cap, the landfill
gas venting system, and the leachate collection and, if
appropriate, the treatment systems. To minimize the succession of
trees and shrubs on the landfill cap, maintenance of native grasses
shall be provided through once-a-year rotational mowing. This
means that one-third to one-fourth of the landfill surface area
shall be mowed once a year. This mowing shall occur in the late
fall between late October and early November. In addition to
ground water monitoring, there shall be routine monitoring of the
landfill gas, leachate and structural stability of the cap
-53-
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(including but not limited to surface depressions, side slopes and
erosion). Specifics of such a monitoring program shall be detailed
in the Remedial Design.
L. Remedy Review
The selected Alternative results in hazardous substances remaining
on-site in the landfill; therefore, the five-year review required
by Section 121(c) of CERCLA is applicable to the selected remedy.
This review will be conducted in conjunction with the other
remedial actions developed and specified for this Site. As stated
in Section IX.J "Ground Water Monitoring" of this document, it is
anticipated that the ground water in the on-site wells will achieve
restoration to background levels (or MCLs, whichever is lower) in
fifteen (15) years. If restoration is not achieved by the
specified timeframe, actions must be taken within the scope of this
ROD, in order to achieve such background levels or MCLs. EPA will
issue an Explanation of Significant Differences or a ROD amendment
as necessary depending on whether or not the further remedial work
required will fundamentally alter the remedy selected in this ROD
with respect to scope, performance, or cost.
X. 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.
In summary, the selected remedy is protective of human health and
the environment as required by Section 121 of CERCLA. Potential
risks from exposure to contaminated surface soil and leachate
through ingestion, inhalation and immediate contact are prevented
by the installation of the landfill cap and the leachate collection
and treatment system. Potential human health risks and hazards
caused by the presence of explosive gases in the landfill will be
addressed by the gas vent system. The selected remedy is the most
cost-effective action available to fully protect human health and
the environment.
-54-
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A. Protection of Human Health and the Environment
The selected remedy (Alternative 4A) will be protective of human
health and the environment in that construction of the cap on the
waste areas would eliminate direct exposure pathways to waste,
reduce leaching of landfill constituents to ground water by
reducing the transport mechanism for the landfill constituents to
the aquifer, and eliminate the potential for erosion of the
landfill. Together with storm-water management controls,
installation of the cap would reduce surface-water infiltration by
approximately 98 percent. Subsurface migration of landfill gas
would be reduced through construction of trench vents and pipe
vents. Toxicity and flow of landfill gas will be monitored
routinely to determine whether flaring of the gas and/or an active
collection system are necessary. If at any time, constituents of
the gas or flow of the gas are such that flaring and/or and active
system is necessary, such system(s) shall be added.
Removal of the leachate prior to construction of the cap would
eliminate direct contact with the seep areas, especially to
children trespassing on the Site, and therefore directly reduce the
health risks of potential current and future hypothetical receptors
whose non-carcinogenic hazard indexes were estimated to exceed one
(1) . The removal of leachate would also provide protection with
respect to ground water by removing the transport mechanism for
constituents from the landfill contents to the aquifer. This
selected remedial action provides that concentrations of site-
related contaminants shall be reduced to background (or MCLs,
whichever is lower) in the ground water.
Routine ground water monitoring of residential and community wells
near the Site will continue to ensure the detection of any
contamination which might pose a threat to human health. If any
contaminants are detected in levels above the performance
standards, an alternative water supply will be provided. If the
cleanup levels are exceeded for a statistically significant period
of time, further remedial activities will be implemented. None of
the off-site residential wells evaluated presently exceeded safe
drinking water standards.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will comply with the Applicable or Relevant and
Appropriate Requirements (ARARs) as specified in Section VIII.B
"Compliance with ARARs" of this document.
The selected remedy achieves the ARARs for preservation of
historical artifacts which may be present in the undisturbed
portions of the Site.
-55-
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.-
The Old Mine Areas, which have been closed since 1972, and the ''.->
Surface Fill and Trench Pill Areas, which received waste through
1988, would be capped consistent with current PADER requirements
for residual waste landfill caps.
Currently, off-site ground water quality meets federal MCLs and
Pennsylvania Water Quality Criteria (WQC). The combination of
remedial actions recommended, including (1) removal and disposal of
leachate; (2) containment of landfill contents; and (3) ground
water monitoring, are considered to be the most protective,
effective and practical solutions for remediation of ground water
quality.
The selected remedy is expected to comply within 15 years with
background remedial action levels for ground water based on
Pennsylvania's Residual Waste Management Regulations 25 PA Code
§288.252. However, if following removal of the leachate, natural.
attenuation is not reducing contaminant concentrations as
predicted, other measures (possibly including pump and treat) would
need to be implemented under this ROD to achieve the required
levels.
/ -
Atmospheric venting of the landfill gas would require compliance
with 25 PA Code Chapter 127 concerning operation of potential air -:
contamination sources. If it is determined during RD/RA that air f
quality ARARs are not currently being achieved, additional gas T
management systems that include but may not be limited to flaring :
and/or an active gas collection and treatment system will be
installed to achieve air quality ARARs. At a minimum, the system
will be required to maintain combustible gas levels below the Lower
Explosive Level (LEL) at the property boundary and below twenty-
five percent of the LEL in adjacent areas. In addition, all gas
management systems must meet" current Best Available Technology
(BAT) criteria as established by 25 PA Code §127.12 (a) (5),
specifically the new permitting criteria issued by the Pennsylvania
Bureau of Air Quality dated May 4, 1990.
C. Cost-Effectiveness
The selected remedy includes all components necessary to protect
human health and the environment. This remedy is the most cost-
effective remedy considered which will provide such assurance.
Landfill caps have proven to be an economical and effective means
to close landfill operations. Leachate collection systems, as
specified in this document, are reasonably cost effective and
provide an additional, necessary treatment system which will aid in
the natural attenuation of contaminants in the ground water.
-56-
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D. Utilization of Permanent Solutions and Alternative
Treatment (or resource recovery) Technologies to the
Maximum Extent Practicable (MEP).
The selected remedy utilizes a permanent solution to the maximum
extent practicable. Although the landfill contents will not be
excavated, leachate pumping and installation of the cap will
significantly reduce the transport of contaminants from the
landfill to the ground water. Contaminants collected through
-leachate pumping will be removed from the Site and treated prior to
disposal. The residual risks to human health and the environment
remaining after implementation of remedial actions is expected to
be well below the 10"6 cancer risk and the hazard index of 1.
Both the State and the community played a significant role in the
development of this decision. Treatment technologies and continued
monitoring will be implemented based on their concerns.
E. Preference for Treatment as a Principal Element.
The selected remedy satisfies the preference for treatment in that
it would reduce the toxicity of leachate through pumping and
treatment of the transported leachate at a wastewater treatment
facility prior to disposal. Future generation and mobility of
additional leachate would be reduced through containment of the
waste disposal areas to reduce infiltration.
At this time, EPA's sample data does not indicate the presence of
toxic constituents at levels of concern in landfill gas. However,
if at any time sample results show levels of concern, a system will
be installed to prevent the release of the gas to the air and thus
reduce the toxicity and mobility of the gas.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan for the Site was released for public comment on
May 26, 1993. The proposed plan identified Alternative 4A (Cap
with Vents and Leachate Collection) as EPA's proposed Alternative.
EPA reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments it was
determined that no significant changes to the remedy were necessary
based on these comments. However, due to the fact that a
commitment has not yet been obtained from a wastewater pretreatment
facility to accept the collected leachate for treatment prior to
disposal to a POTW, EPA has developed a contingency for on-site
treatment of leachate and discharge to surface waters if such a
commitment is not received within six (6) months of EPA's approval
of an engineer to start the Remedial Design. See Section IX.I.
-57-
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FIGURES
fl R 3 0 8 9 U 6
-------
FIGURE 1-SITE PLAN
Novak Sanitary Landfill,
South Whitehall Township, Pennsylvania
Residential Wells
o Shallow Wells
a Deep Wells
? FEET y
-------
FIGURE 2
SOIL-GAS SURVEY
SAMPLING PROBE LOCAT10
AR3089U8
-------
hlUUHb 3-VULAI lib UHUAIMIU UUMPUUIMUb IN UHUUIMU WAI hH
Novak Sanitary Landfill, South Whitehall Township, Pennsylvania
MW-11
PARAMETER
1ST
2J
2ND
PARAMETER
NO DETECTS
RW-I:
PARAMETER
PI
B
l.t-DCA
1 .....
TCE
PCE
VC
wo
....u..
1
.4J
......j..-.
...__....
...
1
f
PARAMET
1.1-TCA
F
PARAMET
NODETEC
RW-I:
PARAMETER
X
MW-J3
PARAMETER
T
no
jj
3RD
IJ
1ST
RW-
PARAMETER
1.1.1-TCA
»
1ST
IB
SAFE DRINKING Vy
CB NONE IHO.W ppt|
B , -5
T -1.000
1.2-DCE -70
PCE -5
A1ER LEVELS' I
vc -i
E -mo
X - 10.000
1.1-OCA -NONEIMMlOppb
ICE -5
1.1.1-TCA.200
1- Imli lor Id |oi raiKiniillM iiuclilit mtlk i
ooo-cotcliiO|iilc omrl 0.001)011 |*Q) 01 1 lot miooM* httbio.
MCli|.*llcoKiMiitloiii in ihon Mo*.
RW-04
PARAMETER
NO DETECTS
1ST
2ND
M
PARAMETER
T
K-12
1ST
IJ
2ND
2ND
3RD
...U.
PARAMETER ABBREVIATIONS
CtkCtilofobenzeng
B-Benzene
T^Toluene
1,2-DCE-1.2.DlcMoraa1liytem
PCE-TeltachlorMthytene
Unte = (iW = ppb
VC-V^Ctitoltlt
1.1-OCA.OkManelm
1.1,1-TU.I.I.I-TMilonMtiini
SAMPLING RESULTS
m-nnt Rowd MW i m (Mifcw«ptn iggo)
flB- Socond Rourt MW (Ilky IMO) RW (Apil-Augujl INI)
MO- mn) Ann) MM (thr-Juno mi)
h tMtaM UXU. M M ««OkM Mil * ta M M HIM «*
fcift ta M TOM I-M (*j|M).
O.
o
OLDMME DEMOLITION
AREA I T|.
Residential Wefls
Shallow Wells
9 DeapWelb
? FEET f
Approilmate Sola
IRQ
1 J
PARAMETER
U-OCA
JAKE.
TQ.E
PCE
1, 1.1-TCA
W-03
1ST
.9J
1J
IHD
1
.gj
.9J
i
3
HW-0]
PARAMETER
.«._
B
1.1-DCA
ft!'
1ST
...J.5.J..
IJ
IJ
".«T"
RW-17
PARAMETER
J.1-.DSA
1,2-OCE
"PCE
2ND 1
...u..,
..At.
IJ
2ND
IB
-------
CO
cr
CD
UD
cn
CJ
Ground Wattr Flow Direction
GERAGHTY
fif MILLER INC.
tuanncOMT|pC*»*i
rtJS^*. "«"""
=&! "~
REGIONAL WATER-LEVEL CONTOUR MAP
JUNE 1991
HOVAK SAMTAHV LANDTU.
SOUTH WHTEHAU. TOWNSHP. PENNSYLVM1A
FIGURE
4
-------
Swfen IXJ -Ground W«Mr McMoring-
ollliailooumnL
GERAGHTY
MILLER, INC.
Srrvtecs
DECISION TRffi FOR PROVIDING
ALTERNATE WATER SUPPLY
NOVAK SANITARY LANDFILL
SOUTH WHITEHALL TOWNSHIP. PENNSYLVANIA
FIGURE
5
flR3U895
-------
TABLES
1R3U8952
-------
Table 1 Comparison of Leachate Characteristics between USEPA Subtitle D study and
data collected from the NSL. Novak Sanitary Landfill
USEPA Subtitle
D Study
Compounds
Volatile Organic Compounds
Acetone
Benzene
Chlorobenzene
Chloroe thane
1 , 1-Dichloroethene
1 ,2-Dichloropropane
Ethylbenzene
Total Ketones
Tetrachloroethene
Toluene
1,1, 1-TricbJoroe thane
Vinyl Chloride
Xylene
Semi-Volatile Organic Compounds
1 ,4-Dichlorobenzene
Dietbyl phthalate
bis(2-Ethylhexyl)phthalate
Naphthalene
Metals/Inorganics
Iron
Zinc
Manganese
Sodium
Copper
Lead
Magnesium
Potassium
Cadmium
Selenium
Chromium
Low
(ug/L)
140
2
2
5
2
2
5
10
2
2
0
0
12
2
2
6
4
200,000
600
600
20,000
1,000
1
3,000
35,000
0
0
20
High
(ug/L)
11,000
410
237
170
6,300
100
580
28,000
100
1,600
2.400
100
79
20
45
110
19
5,500,000
220,000
41000
7,600,000
9,000
1,440
15,600,000
2,300,000
375
2,700
18,000
Leachate
Seeps
(ug/L)
44
1
11
4
ND
ND
21
14
ND
18
ND
ND
19
ND
ND
ND
ND
331,000
3,310
16,200
145,000
286
644
130,000
104,000
83
2
212
NSL Data
Standing
Liquid
(ug/L)
96
<5(b,c)
25(c)
12
<5(b,c)
<5(b,c)
27
(a)
< 5(b,c)
< 5(b,c)
< 5(b,c)
< 5(b,c)
25
4
ND
10
8(c)
65,000
940
1,030
360,000(c)
29
26
260,000
230,000
24
<2(c)
11
Old Mine Area
Standing Liquid
(ug/L)
34
<5(b)
25
<5(b)
<5(b)
<5(b)
19
(a)
<5(b)
<5(b)
<5(b)
<5(b)
13
<2
<2
6
8
7,200
88
300
360,000
8
8
74,000
180,000
<3(b)
<2(b)
<5(b)
(a) Not Sampled
(b) Below Detection Limit
(c) Old Mine Area Sample
Ub09-27.wkl/oavak.n2S
Table 1-1
Source: Feasibility Study 7/8/92
Ceraghty & Miller. Inc.
Reviled by Dynamo: 09/27/& R 3 U 8 9 5 3
-------
Table 2 SoU Gas S«r«y Result*, Novdc Sanitary LwddL
PROBE
LOCATION
DATE NUMBER
September 9. 1991 1
4
5
t
7
8
in
lu
11
14
15
16
September 12. 1991 17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
September 13. 1991 47
48
TOTAL VOLATILE ORGANIC COMPOUND
CONCENTRATION (PPM) I
INSTANTANEOUS
READING
4JO
42
4O
4.7
14
SJO
44
4 x
^»w
4.4
3.5
34
3.4
3.0
3.4
3.0
3.4
34
42
3.8
3.6
4.4
4.0
4.4
4.0
5.4
4.0 .
32
3.4
32
4.7
4.0
3.6
104
33
24
3.4
2-6
2.4
22
22
3.9
3D
24
24
2.7
2.4
4D(1)
2.4
2 MIN.
READING
4.1
3.4
3.4
2.1
2.4
4.1
2.1
2.7
3.9
24
23
2.4
2.4
2.4
2.4
2.0
32
2.1
32
2.6
24
2.9
2.4
24
22
2J
23
22
1.9
2.9
2.1
23
2J
14
2D
2.1
1-8
1.4
1.4
14
1.9
1.7
14
1.9
U
14
14
1.9
4 MIN.
READING
34
3.4
' 3.5
2.1
2.6
^
2.1
24
3.9
2.4
2.4
2.4
2.4
2.4
^ "
20
A v
~~
^
^
^
~
""
*
^
~
~ "*
"
^ ^
^
~*
*
*
*
^^
~~
PERCENT OF LOWER
DCPLOSIVE LIMIT FOR METHANE
INSTANTANEOUS 1MIN.
READING READING
0
0
0
0
18
1
1
23
0
0
0
55
*
0
in
IU
.
_
0"
1
1'
0
0.
0
0
0"
0
0
0
45
1
so
29
0
0'
35
o
o
0
0
0
0
0
0
0
23
0
0
30
0
0
3
0
5
0
0
3
o
0
o
1
1
o
o
o
o
o
o
0
o
0
Meter initUDy read 100% (first few pnmpi), then dropped to icro or recorded level.
(1) Dyntmac iplil umpte
(2) Taken at approximately 30 tec. (initial reading amiable)
GERAGHTY
-------
Table 2 (continued). Soil Cms Survey Results, Novak Sanitary Landfill.
F«jelofl
DATE
September 13. 1991
(continued)
September 9. 1991
September 13. 1991
PROBE
LOCATION
NUMBER
49
49a
49b
49e
90
51
52
53
54
55
56
56*
57
57»
57b
58
59
59.5
60
60.5
61
61.5
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
18.5(3)
17.5(3)
TOTAL VOLATILE ORGANIC COMPOUND
CONCENTRATION (PPM)
INSTANTANEOUS
READING
34
3.9
34
44
44
4.4
3J
44(1)
44
44(1)
6.4
64
9.0
SJ
8.9(2)
7.2(2)
10.
74
64(2)
74
6A
62
SA
42
42
>20
5.4
54
32
62
6.2
54
5.7
3A
54
42
44
4.9
44
44
42
3.9
X2
54
3.4
2MIN.
READING
14
12
U
24
3J
2J
24
1J
0.9
04
24
04
24
74
12
1.4
14
32
42
54
5.4
54
34
34
44
44
5.6
32
4.9
S3
43
54
4J
44
4.4
34
44
3.9
3.5
34
t9
34
U
24
2.9
4MIN.
READING
.
..
_.
--
--
-
--
__
__
- .
__
--
--
--
--
--
--
--
--
--
PERCENT OF LOWER
EXPLOSIVE LIMIT FOR METHANE
INSTANTANEOUS 1 M1N.
READING READING
100
0
13
5
0
0
0
12
75
0
100
0
100
100
0
90
30
0
0
15
0
0
0
0
0
0
0
0
0
0
0
0
30
0
3
0
0
0
0
0
0
0
2
0
0
0
100
0
9
7
0
0
0
8
72
0
35
0
40
90
0
0
0
3
12
2
0
0
0
0
0 'I
0 ,',
0 ^
0
0
0
0
0
30
0
1
0
0
0
0
0
0
0
2
2J
0
3
Meter inituOy read 100% (first few pomp*), tkea dropped to zero or recorded level.
(1) Dynamic ipiit sample
(2) Taken at appresimateljr 30 see. (initial readUgoaitaUe)
(3) Sample requested by USEP A.
GERAGHTY & MILLER. INC.
-------
Table 3 Concentration Ranges of Mcult and Inorganics In Soil ind Sediments; Novtk Sanitary Undmi. South Whitehall Township. Pennsylvania.
'
t
Xsi
3?
co
c::
oo
UD
cn
cr»
Surface Soili
Soil Bortogi Underlying
Off-Site Leachale
Background(a) On-Site(b) Secpi(c)
Aluminum 1,470-19.300 456-22.700 7.030-9,980
Antimony NR ND - I6.7L ND-I09J
Arsenic I.I - 16.7 ND-18.1 6.SK-9.3J
Buium 10 S- 113 ND-130 1691 - 636
Beryllium 0.89-11.9 ND-2.S IIL-I5B
Cadmium 6.5-13.3 ND-40.5 5.6-308
Calcium 253B - 194.0001 I54B - 4.8701 5.790 - 46.6001
Chromium 9.4-27.3 4.3-46.9 11.0-20.3
Cob.ll 10 SB -29.3 ND-2S.9 7.8L - 19.3
Copper 5.2B - 11.2 2.8B - 26.9 9.SB - 22.3L
Iron 6.450 - 37.400 1 . 170 - 38.200 17.600 - 1 1 3.000
Lewi I2.0K- 60.61 21.3K - 92.4K 5.3J-26.4J
Magnesium 540-101.000 121 - 1.090 1.4001 -2.320J
Manganese 246K-2.3IOK 7.2L-2.4IOL 392L-429L
Mercury ND-0.21 ND-0.71 ND
Nickel I9.7B - 47.3 ND - 45.6 22.7B - 56.0
Potassium 328B- 1.590 ND - 1.990. I.070K -2.790B
Selenium ND - 0.72L ND-0.99L ND
Silver ND-2.5 ND-2.3L 2.8B
Sodium 36.6B-2ISB 44.9B-208B I70B-9.980J
Thallium ND . ND ND
Vanadium 108-40.6 II. 1-52.5 21. IB -35.1
Zinc 35.2J-I72J 6.5 - 1361 49.SJ - I57L
Cyanide ND ND ND
(a) Bated on Sample* NSL-SB-I-OI. -08. -13. and -15 (Table S-l).
(b) Bated OB Sample* NSL-SB-2-OI. -04. -06. and -08 and NSL-SB-3-OI. -05. -10.
(c) Bated on Samplei NSL-SS-07-OI. SS-08-01. and SS-IO-OI (Table 5-8).
(d) Bated on Samplei NSL-SD-OI-OI. SD-02-01. SD-03-01. SD-04-01. SD-05-01.
(e) Bated on Sample NSL-SD-O9-OI (Table 5-8).
(0 Bated on Sample* NSL-SD-1 1-01 and SD-12-01 (Table S-l 1).
On-Site Ponds
&Drainageways
Sedimenls(d)
791 - 16.600
ND- 31.91
ND - 8 OK
13.6-58.4
O.S3B-2.I
ND- 11.3
432 - 3.990
3.0-17.8
5.4 - 26.2
ND - 23.0
1.730-36.000
4.6-23.2
234I-I.240J
8I.IL-905L
ND
9.6B - 40.S
I.I60B-2.270B
ND
NR
4.6SOJ - 6.870J
ND
8.0B-3I.6
8.8J - 86.0J
ND
and -IS (Table S-l).
Off-Sile
Dralnigeway
Sediment(e)
17.500
ND
7.31
80.11
2.0L
8.8L
2.630B
23.6L
I7.2L
2I.8L
28.500
11.91
2.080
NR
ND
35. IB
I.580K
ND
2.0B
S9.4B
ND
33.5L
87.2L
ND
and SD-06-01 (Table 5-8).
Jordan Creek Sediments
Upstream(f)
9.7001 - I5.000J
NR
3.9L - 8.8L
42.9 - 68.4
0.60 - 0.67
3.7-5.5
707 - 1.070
19.2 - 25.2
9.2B - 17.0
29.8-31.7
27.2001 - 39,8001
6.7B- 20.61
4.350 - 7.680
958-1.870
ND
24.1-33.0
852-971
ND
ND
ND
ND
15.3 -21.5
SS.W - 77.SJ
ND
ND Not detected.
NR No results.
Adjacent and
Downstream(g)
I0.400J - IS.OOOJ
NR
5.9L - 9.4L
63.7 - 185
0.65-1.3
5.3 - 6.4
947 - 9.530
18.7-28.1
17.5 - 33.6
24.3 - 42.7
39.800J - 46.200J
14.41- 31. IJ
3.000 - 8.020
!.!"> 4.550
ND
26.4 - 42.0
753-1.090
ND
ND
ND
ND
19.4 - 27.0
64.IJ-88.2J
ND
All concentration! are shown In milligrams
per kilogram (mg/kg).
(«) Bated on Samplet NSL-SD-I3-OI. SD-I4-OI. SD-I5-OI. and SD-I6-OI (Table S-ll).
NNMOl-yCBMIM
GERAGHTY & MILLER. INC.
-------
Table 4
Page 1 of 3
Risk Estimation Summary, Novak Sanitary T-anHfin, South Whitehall
Township, Pennsylvania.
Excess Lifetime*
Cancer Risk
Hazard"
Index
Potential Current On-Site Resident - Adult
Ground Water - Ingestion
Ground Water - Showering
Surface Soilc <=-
Air6
Seep Areas (Water and Soil)
Surface Water and Sediments
Total:
Potential Current On-Site Resident - Child
Ground Water - Ingestion
Ground Water - Showering
Surface Soil
Air
Seep Areas (Water and Soil)
Surface Water and Sediments
Total:
Potential Current Off-Site Resident - Adult
Ground Water - Ingestion"
Ground Water - Showering"
Surface Soil6
Air*
Seep Areas (Water and Soil)'
Surface Water and Sediments6
Total:
Potential Current Off-Site Resident - Adult
2x10"
7x10*
7x10*
7x10*
4x10*
2x 10*
4x10"
8x10*
NE
5x10-*
4x10*
2x10*
2x10*
2x10"
3x10*
2x10*
2x10*
7xl(T7
1x10*
1x10*
2x10*
0.8
0.3
6
0.6
02
8
2
NE
5
0.5
4
A3.
12
0.8
0.1
02
0.007
3 .
Ground Water Ingestion (Community Supply Well) NC
Ground Water Showering (Community Supply Well)
03
NDND
Footnotes appear on page 3.
. 1992
GERAGHTY & MILLER. INC.
flR3G89-57
-------
Page 2 of 3
Table 4 Risk Estimation Summary, Novak Sanitary landfill, South Whitehall
Township, Pennsylvania.
Excess Lifetime* Hazard1*
Cancer Risk Index
Potential Current Off-Site Resident Child
Ground Water - Ingestion (Community Supply Well) NC 0.6
Ground Water - Showering (Community Supply Well) ^ NENE
Potential Current Trespasser
Surface Soil6 2 x 10* 02
Air6 7xlO"7 0.006
Seep Areas (Water and Soil)' 1x10* 3
Surface Water and Sediments6 1 x 10* 0.1
Total: 1x10* 3
Hypothetical Future On-Site Resident - Adult " . .
Ground Water - Ingestion' 2 x 10" 1
Ground Water - Showering' 8 x 10* 0.4
Surface Soil6 7x10* 6
Air* 7x10* 0.6
Seep Areas (Water and Soil) 4 x 10* 02
Surface Water and Sediments 2 x 10* 03
Total: 4x10* 8
Hypothetical Future On-Site Resident - Child
Ground Water - Ingestion' 1 x 10" 3
Ground Water - Showering NE NE
Surface Soil 5 x 10* 5
Air 4x10* 0.5
Seep Areas (Water and Soil) 2 x 10* 4
Surface Water and Sediments 2x 10*
Total: 2x10* 13
Footnotes appear on page 3.
DOC1037\JuM 9.1992
GERAGHTY & MILLER. INC. -"nJ 08958
-------
Page 3 of 3
Table 4 Rjsfc Estimation Summary, Novak Sanitary Tanrfffli South Whitehall
Township, Pennsylvania.
a An excess lifetime cancer risk range between 1 x 10** and 1 x 10"6 is typically deemed
"acceptable" by regulatory agencies (FR, 1990).
b A hazard index value less than or equal to 1 is typically deemed "acceptable" by
regulatory agencies (FR, 1990).
c Risk estimates shown are the sum of risks for an adult resident (24-year exposure)
and a young child resident (6-year exposure).
d Risk estimates shown are from the off-site private well having the highest excess
lifetime cancer risk and hazard index (NSL-RW-07).
e Risk estimates shown are for the potential current older child trespasser and assume
that this trespasser could live at the off-site residence and use the affected water (e'.g^
NSL-RW-07).
f Risk estimates shown are for the on-site monitoring wells designated as Ouster 4
because the risks were highest (of the four clusters) for this group of wells.
NC None of the constituents of concern detected in ground water are classified as
carcinogens via the oral route.
ND No VOCs were detected in ground water from this welL
NE Not evaluated.
DOCKBAJuae 9.1992
AR3G8959
GERAGHTY & MILLER. INC.
-------
TABLE 5
Summary of
Remedial Alternatives
BSUES
ALTERNATIVE II
ALTERHATIVEI2
ALTERNATIVE 13
ALTERNATIVE M
TITLE
LANDFU CONTENTS
Cn*
N» fatal
No toon
I*.
LANDFUGAS
N» fafcn
M»l«*e»
LANDFU GAS
Ow-Tm
LEACHATE
MtaMtaMMIMcai
GROUND WATER
CONSTRUCTION COSTS
nsjns*
S1UUM
PRESENT WORTH OF
OtMCOSTSpOVRS)
an ja
tt.IH.1M
B.4MJH
H.iajns
PRESENT WORTH OF
*l TW1MAT1VE COST
IUJ2MOS
t1SJ»W41
HIJWTTt
>-« Ooubtt Imr C*> «tn tan S«gh taMr Cv h M « OooMi kniv am*wl » «
^ 'flR308'960
-------
TABLES
GLOSSARY OF EVALUATION CRITERIA
Threshold Criteria
Overall Protection of Human Health and the Envi-
ronment addresses whether a remedy provides
adequate protection and describes how risks are elimi-
nated, reduced, or controlled.
Compliance with ARARs - addresses whether a
remedy will meet all of the applicable or relevant and
appropriate requirements of environmental statutes.
Primary Balancing Criteria
Long-term Effectiveness and Permanence - refers to
the ability of a remedy to maintain reliable protection of
human health and the environment over time once
cleanup goals are achieved.
Reduction of Toxicity, Mobility, or Volume Through
Treatment - is the anticipated performance of the
treatment technologies a remedy may employ.
Short-term effectiveness - addresses the period of
time needed to achieve protection and any adverse
impacts on human health and the environment that
may be posed during the construction and implementa-
tion period until cleanup goals are achieved.
Implementability - the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particu-
lar option.
Cost - includes estimated capital, operation and main-
tenance costs, and present worth costs.
Modifying Criteria
State Acceptance indicates whether, based on its
review of the backup documents and Proposed Plan,
the State concurs with, opposes, or has no comment
on the preferred alternative.
Community Acceptance - will be assessed in the
Record of Decision following a review of any public
comments received on the RI/FS report and the Pro-
posed Plan.
-------
Table 7
Alternative Compliance with Established Criteria
OVERALL
PROTECTION
OF HUMAN
HEALTH AMD
ENVKOH.
COMPLIANCE
WTTHABAR.
REDUCTION Of
MOBILITY.
TDXh-nit * --
VOLUME
LONG TERM
EFFECTIVE r:
SHORT TE&M
EFFECTIVE
MPLEMETABH.
mr
COST On
Mlllia*)
ALT4
PARTIAL'
NO"'
NO
NO
NO
0 YEARS
N/A
tOJM
ALT4
PARTIAL"
NO""
PARTIAL'
PARTIAL1
YES
II MONTHS
YES
S1.1SM
41**'
PARTIAL"
NO "'
PARTIAL"
PARTIAL"
YES
M Y»S.
YES
ITJBSM
4M-4
PARTIAL*
NO""
PARTIAL*
PARTIAL*
YES
J-« YRJ.
YES
II1A4
ALT^A
ns
res"
ns"
ns*
ns
Hns.
ns
tH.IU
A1T-*
PARTIAL'
NO""'
PARTIAL'
PARTIAL'
YES
J-4YM.
YES
II4JM
AtT-4 " '"/
PARTIAL'
NO""-"
PARTIAL'
PARTIAL'
YES
V4YR5.
YES"
J16JM
*LTJ»
PARTIAL'
YE3"«»
PARTIAL1
PARTIAL1
YES
1-4 YM.
YES'
SUM
«»i'!#
YES
YB"'-»J"
YES
YES
YES
2-< YRS.
YES"
SI«JM
i«(ubua.iu m. rtnm m.
25 PA Cote HA n. n* Ut 90.9. 25 PA Cote It
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