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Summary of Site History, Contamination, and Selected Remedy
The Paoli Rail Yard was used for storage and maintenance of passenger rail cars. The
Harrisburg Rail Line, which passes through the Rail Yard, is used for passenger and freight
transportation. The southernmost section of the track is referred to as the turnaround track,
and was used to transfer rail cars between the Car Shop and the Harrisburg Rail Line.
The Car Shop dates to 1915, when the Rail Yard was built. The shop was designed to
accomodate the repair of passenger rail cars, which were steam-powered at the time. The rail
lines were later converted to electrical power, at which time mineral oil was used to cool the
transformers in the trains. In the 1950's, polychlorinated biphenyls ("PCBs") replaced the
mineral oil in the transformers. PCBs in railroad transformers are released during servicing
and also by volatilizing when overheated during operation. SEPTA replaced the PCB fluids in
the rail car transformers with other coolants during a retro-fill program which was completed
in 1986.
Ownership of the Rail Yard has changed several times since 1915. The yard is now
owned by the National Railroad Passenger Corporation ("Amtrak") and is operated by
SEPTA. The yard was originally owned and operated by the Pennsylvania Railroad. When
the Pennsylvania Railroad and the New York Central Railroad merged in 1968, the yard was.
operated by the new Penn Central Transportation Company ("PCTC"). Amtrak took
ownership of the Rail Yard during the bankruptcy reorganization of PCTC in 1976. The
Consolidated Rail Corporation ("Corn-ail") operated the yard, during Amtrak ownership, from
1976 until 1982 when SEPTA took over operations.
The Commonwealth of Pennsylvania issued an Administrative Order in 1979 pursuant
to the Clean Streams Law against the Rail Companies which required investigation and
cleanup of the Rail Yard. EPA's involvement with the PCB contamination at the Site began as
a result of investigations conducted pursuant to the Agency's authority under the Toxic
Substances Control Act (TSCA"), 15 U.S.C. §§ 2601 to 2671. Information received from
the Rail Companies in response to TSCA subpoenas issued in 1985 revealed that extremely
elevated levels of PCBs were present onsite. As a result, the United States, the
Commonwealth of Pennsylvania, and the Rail Companies, SEPTA, Amtrak, and Conrail had
entered into five (5) separate partial Consent Decrees ("CDs") which addressed various clean-
up activities and worker protection measures at the Rail Yard and in the surrounding
community.
Under the third CD, the Rail Companies performed a Remedial
Investigation/Feasibility Study ("RI/FS") for the Site to determine the nature and extent of
contamination and alternatives for remediation. Additionally, as a part of this CD, the United
States and the defendants entered into a Worker Protection Stipulation which addressed
contamination inside the Car Shop. The stipulation called for, among other things,
decontamination of specific areas in the Car Shop and implementation of a routine maintenance
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program for particular areas including the lunchroom, locker room ("clean-side/worker-side"
lockers; laundry service), offices and other work storage areas.
On July 21, 1992, after a public comment period, EPA issued the ROD for the Site.
The selected remedy includes the following major components:
• Excavation and on-site treatment of 28,000 cubic yards of contaminated Rail
Yard soils using a solidification/stabilization process for soils with PCB
concentrations exceeding 25 parts per million ("ppm"). The treated soil would
be placed back on the Rail Yard in a containment cell. Long-term ground water
monitoring would be required in the immediate vicinity of the containment cell;
• Erosion and sedimentation controls to manage and control storm water runoff
and sediment from the Rail Yard;
• Development of deed restrictions on the Rail Yard to protect the integrity of the
remedy, prohibit use of the property for residential or agricultural purposes,
and prohibit the use of on-site ground water for domestic purposes;
• Decontamination of buildings and structures on the Rail Yard property to
minimize exposure to persons working the Site. This would involve
decontaminating approximately 35,000 square feet of high contact surfaces in
the Car Shop buildings having PCB concentrations in excess of 10 /ug/100 cm2.
Depending on the type of surface, decontamination would be accomplished by
wiping with a solvent, applying a chemical foam, shot blasting, or similar
methods;
• Excavation and treatment of PCB-contaminated residential soils. The cleanup
standard is to achieve an average PCB concentration of 2 ppm for each
individual property. Excavated soil would be returned to the Rail Yard
property and treated using the solidification/stabilization process;
• Pumping of ground water contaminated with fuel oil at the Rail Yard using
extraction wells, fuel oil recovery, ground water treatment using filtration and
activated carbon, and discharge of the treated ground water on-site through a
subsurface infiltration gallery. The recovered fuel oil is disposed off-site at an
approved RCRA facility. This remedial alternative is currently being
implemented;
• Long-term ground water monitoring to evaluate the effectiveness of ground
water pumping and treatment system and fuel oil recovery system;
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• Excavation and treatment of stream sediments along North Valley Creek,
Hollow Creek, and Cedar Hollow Creek (all tributaries to Little Valley Creek)
and Little Valley Creek and Valley Creek with PCS concentrations exceeding 1
ppm. Contaminated sediments would be returned to the Rail Yard and treated
using solidification/stabilization. Adverse impacts to the stream(s) and
surrounding area shall be mitigated to the maximum extent practicable.
The Car Shop was SEPTA'S Western-most commuter car facility and served for several
years as SEPTA's sole maintenance facility. Long term heavy repair service to SEPTA'S 304
multiple unit electric commuter car fleet was provided here. Operations at the Car Shop
included brake inspection and service, preventative maintenance programs, heavy long-term
repairs, transformer repairs and conversions and rebuilding of car components.
In January 1995, SEPTA maintenance operations were relocated to another property.
Since the Car Shop is no longer in use, demolishing the building will permanently remove the
risk of exposure to and release of PCBs into the environment as would happen as the building
degrades.
Description of the Significant Differences and the Basis for those Differences
The selected remedy in the 1992 ROD called for decontamination of the Car Shop since
it was still an operating facility. This alternative would have involved decontamination of
approximately 35,000 square feet of high contact surfaces which had PCB concentrations in
excess of lO^g/ 100cm2. Decontamination would have been accomplished by several different
methods depending on the type of surface material, and would have generated waste material
for disposal. The capital cost of this alternative in 1992 was $260,000. Since some of the
PCB contamination would have been allowed to remain on-site under this alternative, ongoing
maintenance would have been necessary to ensure the remedy remained protective. The
Worker Protection Stipulation would also have continued under this alternative, and was
estimated to cost approximately $117,875 annually.
The modified remedy is decontamination, as necessary, of the Car Shop and associated
buildings in preparation for demolition. Materials from the demolition will then be recycled
and/or transported off-site for disposal. This alternative was presented during the public
comment period in 1992 and was in the proposed plan, but was not selected since the Car
Shop was operational at that time.
This modified remedy will decontaminate the Car Shop and associated buildings, as
necessary, and then the buildings will be demolished. The materials from the demolition will
be recycled and/or disposed of in a permitted off-site landfill. A pre-design study will be
conducted to determine the methods to accomplish these activities. All materials with PCBs in
excess of 50 ppm will be separated from the rest of the materials and either disposed off-site in
a TSCA landfill, or decontaminated and recycled or disposed of off-site in a permitted facility.
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The capital cost in 1992 was $1,000,000 if the material could be disposed as non-PCB waste.
This figure is not significant when viewed in context of the total remedy, which has a capital
cost of approximately $25 million. Therefore, the increase in cost represents approximately
4% difference in the total cost of the remedy. The Worker Protection Stipulation will be
discontinued since workers will no longer be exposed to PCBs in the Car Shop.
Support Agency Comments
The Commonwealth of Pennsylvania concurs with this BSD.
Affirmation of the Statutory Determinations
EPA believes that the revised remedy remains protective of human health and the
environment, complies with federal and state requirements that were identified in the ROD as
applicable or relevant and appropriate to this remedial action at the time this ROD was signed,
and is cost-effective. In addition, the revised remedy utilizes permanent solutions and
alternative treatment and resource recovery technologies to the maximum extent practicable for
this Site.
Public Participation Activities
This BSD and the information upon which it is based are included in the Administrative
Record file for this Site.
Thomas C. Voltaggio, I^epidr//' Date
Hazardous Waste Managementn5ivision
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