PB95-963921
EPA/ROD/R03-95/211
February 1996
EPA Superfund
Record of Decision:
Brodhead Creek Site,
(O.U. 2) Stroudsburg, PA
6/30/1995
-------
RECORD OP DECISION
BRODHEAD CREEK SITE
OPERABLE UNIT TWO
DECLARATION
Site Name and Location
Brodhead Creek Site
Stroudsburg, Pennsylvania
Operable Unit Two
Statement of Baais and Purpose
This decision document: presents a selected remedy for residual
coal tar contamination and ground water contamination in the
subsurface soils at the Brodhead Creek Site (the "Site") in
Stroudsburg, 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 CFR Part 300.
The information supporting this decision is contained in the '
administrative record for this Site.
The Commonwealth of Pennsylvania concurs with the selected
remedy. ." • .
Description of the Remedy
The'Brodhead Creek Site is the location of a former coal
gasification plant which operated along the west bank of Brodhead
Creek in the Borough of Stroudsburg, Monroe County, Pennsylvania,
from approximately 1888 to .1944. A waste product from these
operation^ was coal tar, a black tar-like liquid which had a
density greater than water and was principally composed of
polynuclear aromatic hydrocarbons ("PAHs"). This coal tar was
placed in an open pit located on the property. This practice
continued until the mid-1940s when the plant was abandoned.
A previous Record of Decision ("ROD")., issued on March 29,
1991, selected an enhanced recovery process as an interim
remedial action for Operable Unit One ("OU-l")xat the Site which
addressed free coal tar in the subsurface soils at the..Site. As
part of the OU-1 interim remedial action, deed restrictions will
be imposed to limit future use of the Site. The shallow ground
water and Brodhead Creek will continue to be monitored to verify
that no unacceptable risks posed by conditions at the Site occur
in the future.
This ROD addresses ground water contamination and residual
coal tar contamination in the subsurface soils (Operable Unit Two
or "OU-2") . No further action is necessary for Operable Unit
Two.
AR302000
-------
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with (or waives) federal and state
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost effective.
Because the interim remedy for Operable Unit One selected in
the previous ROD will result in hazardous substances remaining
on-site above health based levels, a review will be conducted
within five years after commencement of the interim remedy The
review will be conducted to ensure that the interim'remedy
continues to provide adequate protection of human health and the
environment. Review of this Site, the interim remedy for
Operable Unit One and EPA's decision for Operable Unit Two will
be continuing as part of the development of a final remedy'for
Operable Unit One.
'Thomas C. VbltaSgio/^ J Date
Division Director-
Hazardous Waste Management Division
Region III
AR30200I
-------
RECORD OP DECISION
BRODHEAD CREEK SITE
TABLE OP CONTENTS
SECTION . PAGE
I. SITE NAME, LOCATION, AND DESCRIPTION .1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
IV. SCOPE AND ROLE OF RESPONSE ACTION 6
V. SUMMARY OF SITE CHARACTERISTICS 6
VI. SUMMARY OF SITE RISKS .• 14
VII. DESCRIPTION OF ALTERNATIVES 18
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . .20
IX. SELECTED REMEDY. .24
... X. STATUTORY DETERMINATIONS. 25
XI. EXPLANATION OF SIGNIFICANT CHANGES. . 27
APPENDIX A: FIGURES
Figure 1: Brodhead Creek Site Location Map
Figure 2: Site Plan
Figure 3: Maximum Probable Extent of Free Coal Tar
Surface
Figure 4: General Site Stratigraphic Column
Figure 5: Lateral Extent of Stream Gravel Unit
Figure 6: Top of Silty Sand Unit
Figure 7: Schematic of Extent of Free and Residual
Coal Tar
Figure 8: Water Supply Well Locations
Figure 9: Ground Water Flow Schematic
Figure 10: Log of Sum of Total Detected Organics
AR302002
-------
Figure 11
Figure 12
Figure 13
APPENDIX B:
Table .1:
Table 2:
Table 3:
Table 4:
Table 5:
Table 6:
Table 7:
Table 8:
Table 9:
Site.Plan with Monitoring Well Locations
Flow in Bedrock System
Regional Fracture Pattern
TABLES
Relevant and Appropriate Requirements
for Ground Water
Summary of Ground Water Analyses
Shallow Aquifer Screening Analysis
Justification Table for the Selection of
Constituents of Potential Concern in the
Shallow Aquifer
Deep Aquifer Screening Analysis
Justification Table for the Selection of
Constituents of Potential Concern in the
Deep Aquifer
Summary of Toxicity Data for
Constituents of Potential Concern
Intake/Risk Calculations for
Hypothetical Residential Use of Shallow
Ground Water by an Adult
Intake/Risk Calculations for
Hypothetical Residential Use of Shallow
Ground Water by a Child (0-6)
APPENDIX C: RESPONSIVENESS SUMMARY
AR302003
-------
RECORD OP DECISION
BRODHEAD CREEK SITE
DECISION SUMMARY
I. SITE NAME. LOCATION. AND DESCRIPTION
The Brodhead Creek Site ("the Site") encompasses
approximately 12 acres in the Borough of Stroudsburg in Monroe
County, Pennsylvania (Figure 1). The Site lies on the west bank
of Brodhead Creek between the bridges of Route 209 and Interstate
80. The detailed site plan is shown on Figure 2.
The Site occupies the flood plain area at the confluence of
Brodhead Creek and McMichael Creek. As a result, the natural
topography over most of the Site is one of low relief. Surface
elevations in the flood plain area range from about 377_feet
above mean sea level at the Creek banks to 381 feet in the flood
plain interior. In the northern one-third of the Site by
contrast, the land surface rises abruptly from the flood plain to
an elevation of about 400 feet. .
Superimposed over the natural topography is a large man-made
earthen levee constructed to protect the Stroudsburg Municipal
Sewage Treatment Plant, which is located on the western boundary
of the Site, from flood waters such as those experienced in the
aftermath of Hurricane Hazel in 1955 (See Figure 2) . On the Site
proper, this levee is arcuate in plan, curving from out of the
north and to the west, effectively blocking any potential
flooding from either Brodhead Creek or McMichael Creek. The levee
crown (elevation of 408 feet) is about 25 to 30 feet above the
surrounding flood plain. The Creek side of. the levee is sloped
at a ratio of 2.5:1 while the opposite side is sloped at a ratio
of 2:1. •
To the west, the levee extends out of the Site area. To the
north, the levee abuts the natural land surface and a concrete
flood wall which protects a Pennsylvania Power and Light Company
("PP&L") substation. The concrete flood wall extends from the
levee embankment northward and is keyed into the west abutment
for the Route 209 bridge. The flood wall is a 22-foot tall
reinforced, cast-in-place concrete wall constructed on top of an
interlocking sheet pile foundation which extends down to
elevation 361 feet. The elevation at the top of the "concrete
wall is about 407 feet above mean sea level.
A smaller, and presumably older earthen levee, which extends
northward from the main flood control levee, separates the flood
plain area of the Site from the grounds of the Stroudsburg
Municipal Sewage Treatment Plant. This smaller levee rises about
13 feet above the flood plain with its crown reaching about
elevation 394 feet above mean sea level.
-------
Two small drainage channels enter the Site, join in the Site
interior, and continue through the flood plain area. Flow in the
smaller of the two is intermittent in nature, as that channel
carries storm run-off, entering the Site at the northeast corner
via a storm sewer outfall. The smaller channel is not considered
to be a major Site feature for this reason. The larger channel
is perennial in nature and enters the Site from the west-
northwest, continuing across the central portion of the Site
through a flood gate in the levee to its outlet on Brodhead
Creek. It is referred to herein as the urban run-off channel.
The northern Site boundary is -a combination of private
commercial properties and a cemetery located along Main Street in
Stroudsburg.
The Borough of Stroudsburg has zoned the Creek, its eastern
and western banks, and the small promontory at the confluence of
Brodhead and McMichael Creeks as open space. The land from the
top of the flood control levee westward through Main street is
zoned as general commercial land. Land use at the Brodhead Creek
Site is categorized primarily as undeveloped. Those areas
containing the sewage treatment plant and the Stroudsburg Gas
Company are classified as utilities.
II. SITE HISTORY AND ENFO^CiMKMT ACTIVITIES
Union Gas Company is a successor company to companies which
operated a coal gasification plant along the west bank of
Brodhead Creek in Stroudsburg, Pennsylvania, from approximately
1838 to 1244. A waste product from these operations was coal
tar, a black tar- like liquid which had a density greater than
water and was principally composed of polynuclear aromatic
hydrocarbons ("PAHs") . This coal tar was placed in an open pit
located on the property. This practice continued until the mid-
19403 when the plant was abandoned.
In 1917, Pennsylvania Power & Light Company ("PP&L")
purchased the electrical section of the Union Gas Company
facilities. From 1917 until the 1960's, PP&L acquired adjoining
properties, including some of the property owned by Union Gas
Company.
On October 7, 1980, during construction repairs to the toe
of a flood control levee at the Site, materials identified as
coal tar were observed seeping into Brodhead Creek. As a result,
several investigations and emergency response measures were
initiated from 1981 through 1984, including:
o Installation of temporary filter fences and underflow
dams by PADER and EPA to intercept coal tar seepage;
RR30Z005
-------
o Installation of a temporary coal tar recovery pit by
PADER on the bank of Brodhead Creek;
o Construction of a slurry wall by EPA to mitigate coal
tar migration from the Site toward Brodhead Creek;
o Excavation of a backwater channel area where coal tar
seepage appeared to be particularly significant; and
o Installation of recovery wells in the main coal tar
pool by PP&L, with the subsequent recovery of
approximately 8,000 gallons of coal tar.
The Site was placed on the National Priorities List ("NPL")
in December, 1982 with a hazard ranking score ("HRS") of 31.09.
The regulations enacted pursuant to CERCLA require that a
Remedial Investigation and Feasibility Study ("RI/FS") and
baseline risk assessment be conducted at each NPL site. The
purpose of an RI is to characterize conditions at the site. The
subsequent PS then develops, screens, and analyzes a series of
remedial alternatives for addressing contamination at the site.
On August 20, 1987, PP&L and Union Gas Company entered into a
Consent Order and Agreement with PADER to conduct the original
RI/FS for the Brodhead .Creek Site.
Results of th« Original RI
The original RI, completed in 1989, indicated the following:
o The Site is underlain by the following distinct strata
(in descending order): fill, floodplain deposits,
. stream gravels, silty sands, and bedrock.
o The principal shallow water-bearing strata at the Site
are the stream gravel unit and the underlying silty
sand unit.
o Soil contamination due to coal tar-related compounds is
limited both horizontally and vertically, to the stream
gravel unit.
o The total area of contamination is approximately 4.28
acres containing an estimated maximum volume of 418,000
gallons of coal tar.
o The likely extent of free coal tar accumulations is
limited to a small area of a stratigraphic depression
east of the slurry wall (the area around MW-2) and to
the lowest portion of the stratigraphic depression
located west of the slurry wall (the RCC area). (See
Figure 3.) These two areas contain an estimated volume
of 338 gallons and 8715 gallons of free coal tar,
AR302006
-------
respectively. Free coal tar is defined as 100% of pore
volume saturation in the soil. Coal tar at residual
saturation levels is more extensive but limited to the
extent of the stream gravel unit. Residual coal tar is
defined as less than 100% of pore volume saturation in
the soil.
o Ground water flow from the upgradient side of the
slurry wall is both downward beneath the slurry wall
and southward to Brodhead Creek.
o Migration of coal tar constituents as dissolved
constituents in ground water may be constrained by
upward flow gradients and by the hydraulic boundaries
represented by Brodhead Creek and McMichael Creek.
o RI data suggest that surface waters of Brodhead Creek
are not affected by the discharge of coal tar
constituents. However, some sediment areas within the
Creek channel are slightly contaminated with coal tar.
o There are currently no significant risks associated
with the recreational use of Brodhead Creek or the
ingestion of fish from the Creek.
Following completion of the original RI/FS in 1991, EPA
divided the remedial work to be undertaken, at the Site into two
manageable components called "operable units (OUs)". These were
as follows: -
OU-1: Contaminated subsurface soils containing free coal
tar in the stream gravel unit
OU-2.: Ground water in the stream gravel unit to and
including bedrock
^
. EPA determined that an interim remedial action should be
taken for OU-1 to initiate reduction of the toxicity, mobility,
and volume of contaminants in the stream gravel unit at the Site.
In a Record of Decision issued on March 29, 1991, EPA selected an
interim remedial action which included the following components:
(1) Installation of extraction wells and injection wells in the
free coal tar areas of the subsurface soils;
(2) Recovery of coal tar and process water from the extraction
wells by using the innovative technology of enhanced
recovery;
(3) Separation of the coal tar from the process water followed
by treatment of the process water;
AR302007
-------
(4) Discharge of a portion of the treated process water to
Brodhead Creek and the reinjection of the remaining process
water into the subsurface soils to enhance coal tar
recovery;
(5) Disposal of the recovered coal tar at an off-site permitted
incineration facility;
(6) Installation of a fence to prevent public access during
remedial activities;
(7) Imposition of deed restrictions to limit future use of the
Site; and
(8) Monitoring of ground water and biota in Brodhead Creek to
ensure protection to human health and the environment.
EPA entered' into a Consent Decree with PP&L and Union Gas
Company on September 2, 1992, under which PP&L and Union Gas
Company agreed to implement the remedial design/remedial action
("RD/RA") for OU-1 at the Site. On July 14, 1994, an Explanation
of Significant Differences ("BSD") was issued by EPA to revise
the performance standards for the interim selected remedy for OU-
1. The enhanced recovery process (referred to as the Contained
Recovery of Oily Waste Process, or "CROW" process) has been
constructed and is expected to become operational in the summer
of 1995.
On June 3, 1992, PP&L and Union Gas Company entered into a
Consent Order with EPA to conduct a Focused RI/FS for OU-2 to
further investigate ground water contamination at the Site. This
Record of Decision discusses the results of the Focused RL/FS.
III. HIGHLIGHTS OP COMMUNITY PARTICIPATION
The Focused RI/FS and the Proposed Remedial Action Plan
("Proposed Plan") for OU-^2 were released for public comment on
May 25, 1995, in. accordance with Sections 113(k)(2) (B), 117(a),
and 121 (f) (1) (G) of CERCLA. These and other related documents
were made available to the public in the administrative record
file located in the EPA Region III office in Philadelphia and at
the Stroudsburg Borough Building in Stroudsburg, Pennsylvania. A
notice of their availability was published in the Pocono Record
on May 25, 1995. A public meeting to discuss the Proposed Plan
for OU-2 was held on June 6, 1995 in Stroudsburg, Pennsylvania.
EPA's response to all comments on the Proposed Plan received
during the comment period is included in the Responsiveness
Summary section of this ROD. In addition, a copy of the
transcript of the public meeting has been placed in the
administrative record file and information repository located at
the Stroudsburg Borough Building.
AR302008
-------
IV. SCOPE AND ROLE O7 RESPONSE ACTION
As discussed above, Che interim remedial action previously
selected for Operable Unit Qne (enhanced recovery) addresses the
areas of free coal tar contamination in the subsurface soils on-
site. A final ROD for the Site addressing free coal tar
contamination will be issued following completion of the OU-1
..enhanced recovery program.
Once the enhanced recovery program is completed, there
should be no principal threats from the former areas of coal tar
accumulation at the Site since they should contain only residual
levels of coal tar contamination. However, contaminants are
leaching and will continue to leach from the -subsurface soils
containing residual coal tar at the Site. These contaminants
will continue to contribute to ground water contamination on-
site. . '
This second operable unit addresses ground water
contamination and residual coal tar contamination in the
subsurface soils on-site.
V. SUMMARY OF 3ITS CHARACTERISTICS
A. Waste Characterisation
The coal tar disposed of in the subsurface soils at the
Brodhead Creek Site was the waste product of a coal gasification
plant which operated at the Site between 1888 and 1944. No
factual accounts of actual operations at the plant exist nor is
there any certainty of the actual process or processes used to
manufacture the gas. However, the tars generated by gas
manufacturing plants have several general characteristics
including: (1) a density slightly greater than water; and (2) a
composition lacking tar acids (primarily phenolics) but
containing large amounts of high molecular weight residual
material with 40-75% of the tars boiling above 300°C.
The chemical constituents of coal tars are primarily
polynuclear aromatic hydrocarbons (PAHs), including heterocyclic
compounds. Coal tars typically consist of the following:
Distillation
Compos it ion Range Typical-Composition
Light Oil Up to 200°C Monocyclic Aromatics
Middle Oil 200-250°C Substituted
monocyclic and
dicyclic aromatics
Heavy Oil 250-300°C Substituted dicyclic
aromatics
AR302009
-------
Anthracene Oil . 300-350°C Substituted dicyclic
aromatics; tri- and
polycyclic aromatics
Pitch Carbon, wax, bottoms
During the RI at the Site, a sample of coal tar from well
RCC-C was collected and submitted for percent water and
fractional distillation testing. The distillation data and
specific gravity (which approached that of water) indicate that
the coal tar at the Brodhead Creek Site consists of approximately
50% light and middle oil components.
Metals analysis of the coal tar revealed slightly elevated
arsenic concentrations in the tar. The remaining metals values
were below average concentrations observed in the natural soil
environment occupied by the coal tar.
Coal tar is not 'a Resource Conservation and Recovery Act, as
amended, ("RCRA") listed waste. However, subsequent testing of
the coal tar utilizing the toxicity characteristic leaching
procedure ("TCLP") during the remedial desi'gn phase of the OU-1
interim remedy revealed that the coal tar is a RCRA
characteristic waste for toxicity.
B. Regional Geology
The Brodhead Creek Site is located within the Valley and
Ridge physiographic province of the Appalachian Mountains.
Bedrock at the Site is the Devonian Age Marcellus Shale which is
described as a dark,, fissile, carbonaceous shale, with some
notably calcerous zones. Directly underlying the Marcellus Shale
in the vicinity of the Brodhead Creek Site is. the Devonian Age
Buttermilk Falls Formation, which is a viable water supply. This
formation supplies water for the. City of East Stroudsburg
municipal wells #1 and #2.
The wide valley through -which Brodhead Creek flows has been
filled by up to 100 feet of unconsolidated glacial deposits. The
Brodhead Creek Site is underlain by at least 60 feet of
unconsolidated sediments of both glacial, recent fluvial, and
human origin. The geology at the Site can be divided into the
following distinct strata (in descending order): surficial fill,
floodplain deposits, stream gravels, silty sands, glacial till,
and bedrock (See Figure 4).
The surficial fill is comprised of earthen fill material
which was deposited for land reclamation and levee construction
as well as stream bed modifications. Fine sands and silts
deposited during flood events of Brodhead and McMichael Creeks
comprise the flood plain deposits. Fluvial origin stream gravels
underlie the flood plain/fill deposits beneath much of the Site,
AR3020IO
-------
and are Che surficial materials in some areas of the Site. The
lithology of the stream gravels can be characterized as loosely
consolidated, stratified, well rounded, coarse gravels. These
gravels are most likely reworked glacial drift transported and
deposited by the streams as they migrated across the valley floor
during the past; therefore, this gravel deposit correlates with
the streambed gravels in the Brodhead Creek channel .
Historic site borings and test pit observations indicate
that the stream gravel deposits are limited in horizontal extent,
pinching out in the west -central and southern portion of the
study area (See Figure 5) . The stream gravel thickness averages
about 10 to 15 feet, but ranges from absent in some parts of the
study area to a maximum, of over 25 feet in a stratigraphic
depression near the center of the Site. Figure 6 shows a contour
map of the base of the stream gravels (or the top of the
underlying silty sands) which shows this stratigraphic
depression. The shape and location of the stratigraphic
depression suggest that it may have been coincident with a
confluence of the ancestral Brodhead Creek and another ancestral
drainage. -However, it is postulated that the depression is a
kettle feature created by the melting of a large block of glacial
ice embedded in the silty sand.
The thickness of the stream gravel unit beneath and
immediately east of Brodhead Creek is well defined. However, the
extent of the stream gravel east of the eastern levee is not
known. Because the stream gravel is a channel deposit, it is not
expected to be extensive. The unit is thin in this area, ranging
between approximately 10 feet thick on the north near the
Interborough Bridge to approximately 16 feet thick across from
the island located in Brodhead Creek. Borings and backhoe pits
on the island indicated a significant thinning of the gravel unit
beneath Brodhead Creek due to downcutting by erosion and/or
dredging. Under the island, the unit thins to 4 to 6 feet thick.
Since the stream bed itself is at a lower elevation than the
island surface, the unit is even thinner under the stream, and
may possibly be absent in some areas.
A deposit of stratified fine sands and silts, with some
clayey and gravelly lenses underlies the stream gravels at the
Site. These sediments have been described as fairly uniform
silty sands with virtually no clay fraction present. Underlying
the deposits is a glacial till deposit.
C. MachanJi^f *pft Extent of Coal Tar Migration
The coal tar at the Brodhead Creek Site has a density
slightly greater than water. Once coal tar was introduced into
the subsurface at the Site, the density differential caused the
coal' tar to sink downward through both the unsaturated and
AR3020II
-------
saturated sections of the stream gravel unit to the interface
with the silty sand unit.
The coal tar movement downward into the finer grained silty
sand is prevented by the higher capillary pressures within the
much smaller diameter pores of that unit. From the source area,
continued migration has been lateral downgradient along the
•sloping surfaces of the silty sand unit to lower points where it
accumulated if sufficient coal tar volume was present. This
process accounts for the historic .accumulation -of recoverable
volumes of coal tar within the stratigraphic depression in the
silty sand unit located directly downgradient of the former
gasification plant facilities. Recovering the free coal tar is
the focus of the interim remedy for OU-1.
Figure 3 depicts the spatial area defined as. the extent of
the subsurface coal tar presence, based on all available
information. The area defined as the extent of the coal tar
presence encompasses all historical subsurface coal tar
observations, but it cannot be inferred that the entire area is
contaminated by a continuous _ layer of mobile coal tar. It is the
area where coal tar may have migrated through coarser grained
material in the stream gravel unit in the past and where coal tar
may remain at residual saturation levels. The region of the Site
outside of the area defining the extent of coal tar presence
appears to be unaffected by coal tar; the coal tar does not
appear to have migrated into these areas in the past .No coal
tar was found to be present east of Brodhead Creek. This is
consistent with the configuration of the surface of the silty
sand unit . . • •
The extent of subsurface stream gravels affected by coal tar
at residual saturation levels (coal tar at less than 100% pore
volume saturation) , is estimated to be 128,702 square feet (2.96
acres), and the volume is estimated at 27,558 cubic yards. The
total volume of residual coal tar at the Site is estimated to
range from 303,000 gallons to 409,348 gallons. Figure 7 presents
a 3 -dimensional representation of the extent of the coal tar
contamination. .
D .
Ground Water Clarification and Local Water U««
It is EPA' s Superfund policy to use EPA' s Ground Water
Protection Strategy and Ground Water Classification Guidelines to
assist in determining the appropriate type of remediation for a
Superfund Site. Three classes of ground water have been
established on the basis of the value of ground water and its
vulnerability to contamination. Ground water at the Brodhead
Creek Site may be classified as Class II. Class II ground water
AR3020I2
-------
is ground water which is a current or potential source of
drinking water or a water that has other beneficial uses.
The urban areas of Stroudsburg and East Stroudsburg are
supplied by surface and ground water. Stroudsburg Borough is
served by a public water supply owned by the Stroudsburg
Municipal Authority. The Municipal Authority obtains its water
supply from Brodhead Creek (upstream of the Site). The water is
pumped directly to the Municipal Authority Plant.
The Borough of East Stroudsburg receives its water via a
gravity. feed from two impoundment reservoirs in Smithfield
Township, and from three wells located in the City of East
Stroudsburg. Two of the wells are on the campus of East
Stroudsburg University (indicated as "State Teacher's College" on
Figure 8) while the third is a well screened at the top of
bedrock and located over 2,000 feet upstream of the Site, on the
opposite side of Brodhead Creek in Dansbury Park. These three
wells are used on an intermittent basis only. One of the wells
on the campus is only for emergency use (i.e., fire protection),
and the second well was not used in 1994 except to exercise the
pump. The well in Dansbury Park is used on-an as-needed basis to
supplement the surface water supplies. The location of the water
supply wells is presented in Figure 8.
The Dansbury Park Well was examined closely during the
original RI. The original RI concluded that migration,of coal-
tar constituents from the Site to the well was not possible for
several reasons: (1) the well pumps water from a lower gravel
unit and the upper portions of a limestone bedrock over 11,0 feet
below the surface; (2) the lower gravel unit is not the same unit
as the stream gravel unit of concern at the Site (the lower
gravel unit is confined by less permeable overlying silts and
clays) and it is not subject to contamination by the Site; and
(3) significant hydraulic boundaries (Brodhead and Little Sambo
Creeks) lie between the Site and the well. Furthermore, a review
of the sampling data from the Dansbury Park well and the other
two East Stroudsburg municipal supply wells did not reveal the
presence of any coal tar-related compounds.
Shallow Ground Water
The principal shallow water bearing strata at the Site are
the stream gravel unit and the underlying silty sand unit.
Together, they comprise a water table aquifer. While the two
stratigraphic units of the water table aquifer differ with
respect to hydraulic characteristics, they may be considered to
be a single aquifer with regard to ground water flow direction
and gradient as they are not separated by any intervening
confining layers.
10
RR3020I3
-------
The median depth to ground water at the Site was 10 feet
prior to the construction of the slurry wall. Construction of
the slurry wall at the Site as a response measure to prevent coal
tar migration has resulted in a significant alteration of the
water table flow regimes. At present, the water table is nearly
coincident with the ground surface in the flood plain areas
upgradient of the slurry wall, and 3 to 7 feet below surface
downgradient of the slurry wall. A ground water head loss of 2
to 3 feet across the slurry wall is present. To a -lesser extent,
the sheet pile base of the concrete flood wall extends the head
loss effect of the slurry wall northward from the slurry wall to
at least the Route 209 bridge abutment.
Hydraulic head levels appear to indicate: (1) that an
upward flow component exists between the water table and the
underlying strata; (2) that the urban run-off channel likely
recharges the ground water system; (3) that Brodhead Creek and
McMichael Creek are hydraulic boundaries; and (4) along Brodhead
Creek the majority of this boundary is characterized by ground
water discharge conditions.
Ground water flow from the upgradient side of the slurry
wall is both downward beneath the slurry wall/flood wall and
southward to Brodhead Creek south of the urban run-off channel
outlet. .This ground water flow does carry some dissolved coal
tar constituents from the upgradient side of the slurry wall to
the downgradient side, with subsequent discharge to Brodhead
Creek. North of the urban run-off channel outlet, the ground
water system on the downgradient side of the slurry wall
discharges to Brodhead Creek in the northern most portion of the
Site, is recharged by Brodhead Creek in the middle portion, and
discharges to Brodhead Creek in the southern portion. South of
the urban run-off channel outlet to the confluence with McMichael
Creek, the ground water system discharges to Brodhead Creek.
The recharge/discharge conditions along Brodhead Creek are
altered when the Creek rises at times of high precipitation. RI
data indicates that at these times, the ground water system is
recharged along the entire length of Brodhead Creek.
Figure 9 is a 3-dimensional cross-section across the
southern third of the Site that depicts the conceptual ground
water, flow paths resulting from all of the influences discussed
above.
The shallow aquifer was extensively studied during the
original RI/FS and is being monitored as part of the interim
remedial action for OU-1.. No additional data for the shallow
aquifer was obtained during the OU-2 RI. The data from the
original RI, the OU-1 monitoring program, and the OU-1 interim
remedial action were evaluated in order to establish the most
11
&R3020U
-------
appropriate data set for the OU-2 risk assessment for the shallow
aquifer.
The principal contaminants of concern in the ground water in
the shallow aquifer are polynuclear aromatic hydrocarbons
("PAHs"), benzene, and arsenic. The concentrations of
contaminants detected in the shallow aquifer during the original
RI may be found in Table 1. Federal Maximum Contaminant Levels
("MCLs") for drinking water are exceeded for benzene, a range of
PAHs, pentachlorophenol, cyanide and arsenic. These MCLs are
codified at 40 C.F.R. Part 141 pursuant to the Safe Drinking
Water Act, 42 U.S.C. § 300f et seqi. and are indicated on Table
1.
The highest concentrations of organic coal tar-related
constituents dissolved in ground water are centered around the
areas of known coal tar presence near MW-2 and RCC (See Figure
10}. Vertical distribution of dissolved-phase contamination is
limited to the shallow aquifer and possibly to the uppermost
portions of the silty sand unit.
D««p Ground Water
The purpose of the Focused RI for OU-2 was to further
characterize the ground water contamination at the Site--in
particular, the quality of the bedrock aquifer at the Site.
The investigation of the bedrock aquifer included the
installation of three bedrock wells at the Site, measurement of
ground water elevations of the shallow, intermediate, and bedrock
wells, and ground water sampling and analysis of the bedrock
wells.
The installation of the three bedrock wells (designated as
BR-1, BR-2, and BR-3) at the Brodhead Creek Site was completed in
May of 1993. The purpose of the bedrock wells was to determine
if the ground water in the bedrock aquifer was being impacted by
the contamination at the Site. To the extent possible, the
bedrock wells were to be located outside the shallow coal tar
accumulation, so as to minimize the risk of cross-contaminating
the deeper aquifer. In addition, bedrock wells were to be -
located'adjacent to existing shallow wells, when possible. The
location of the bedrock wells is presented in Figure 11.
Based on water level measurements, the bedrock system flow
is southward (See Figure 12). On initial evaluation, this is not
an expected condition, as flow would be expected northeastward
either to discharge locally at Brodhead Creek, or deeper along
the bedrock structural trend of the valley towards the Delaware
River. However, a closer look at Regional structure explains
this flow, as described below.
12
-------
The topographic quadrangle of the area shows a regional
fracture set oriented north-northwest/south-southeast
perpendicular to regional bedrock orientation. The regional
fracture pattern is shown in Figure 13. Along the course of
Brodhead Creek north of Stroudsburg, one large fracture cuts
across the regional structural trend,'forming water gaps north of
Stroudsburg. South of the Site, Brodhead Creek follows an
apparent fracture orientation, and then turns 90 degrees toward
the east at the contact with the resistant bedrock ridge to the
south. However, the fracture appears to continue even across the
bedrock ridge to the south.
Given the above structural conditions, it appears likely
that bedrock flow from the Site follows the fracture south-
southeastward, flowing beneath and parallel to Brodhead Creek.
Discharge is likely to Brodhead Creek at or near contact with the
ridge. The apparent southerly flow direction beneath the Site is
probably a function of triangulation of the potentiometrie
surface of the three wells. Flow is-actually either south-
southeastward along the fracture, or southeastward into the
fracture, if the Site does not lie directly on the fracture.
Two rounds of ground water sampling were conducted of the
bedrock wells BR-1, BR-2, BR-3, and a residential well (herein-
after referred to as the "CS" well) during the weeks of June 1,
1993 and December 9,.. 1993, respectively. A third round of. ground
water sampling of the bedrock wells only was conducted on May 8
and 9, 1995. The CS well is a domestic well located in
Smithfield Township, approximately 1-1/2 miles east of'the
Brodhead .Creek Site. Based on a well survey conducted during the
original RI, the CS well is the closest residential well to the
Site that remains in use. For this reason, the CS well was
selected as a monitoring point for the Brodhead Creek Site.
Ground water was sampled for volatile organic compounds
("VOCs"), semivolatile organic compounds ("SVOCs"), dissolved
metals (on the first round of sampling only), and cyanide. With
the exception of trichloroethene ("TCE") at well BR-3 and 1,1-
dichloroethane at the CS well, no VOCs were detected at greater
than 1 ug/1. TCE and 1,1-dichloroethane are not constituents of
coal tar, and were not detected in any ground water samples taken
during the original RI.
Trace levels of xylene and 1,2,4-trimethylbenzene were
detected in BR-1 and BR-3, but not in BR-2 or the CS well.
Naphthalene was detected at trace levels in BR-1, BR-2, and BR-3.
Trace levels of toluene were detected in BR-1 and BR-2. In
addition, arsenic and cyanide, two Brodhead Creek Site
contaminants, were absent from all samples collected during the
first round of sampling. Detected concentrations of contaminants
for the bedrock wells are summarized -in Table 2.
13
AR3020I6
-------
VI. SUMMARY OF SITE RISKS
As part of the Focused Remedial Investigation performed for
OU-2 at the Brodhead Creek Site, a Risk Assessment ("RA") was
conducted to evaluate the potential impacts of the Site on human
health and the environment. In the RA, chemicals of potential
concern were identified for detailed evaluation based on the OU-2
and OU-1 sampling results. The Risk Assessment then evaluated
the potential health and environmental risks associated with
exposure to these chemicals.
The risk assessment for OU-2 at the Brodhead Creek Site
focused on the potential human health risks associated with
ground water in both the shallow and deep aquifers underlying the
Site. The potential for ground water discharges to Brodhead
Creek and other surface water bodies was addressed during the
original risk assessment and therefore was not re-evaluated.
(See the Brodhead Creek Risk Assessment dated September 1990.)
Likewise, potential impacts to ecological receptors were
extensively evaluated during the original risk assessment and
were not re-evaluated. The risks associated with ingesting
ground water bn-site are summarized below. ,
A. Indicator Chemical Selection
The contaminants identified .in the Brodhead Creek Site RI
are comprised of a diverse group of compounds with different
physical, chemical, environmental, and toxicological properties.
The extent of contamination varied widely in concentration and
occurrence throughout the Brodhead Creek Site. The first step
involved in selecting indicator chemicals involved a comparison
of reported constituent concentrations from upgradient sampling
locations. Constituents which did not exceed background
concentrations were not evaluated further. .
For those constituents detected at concentrations greater
than background concentrations, a comparison was made between the
maximum downgradient concentrations and risk based screening
levels developed by U.S. EPA Region III. This comparison was
made to evaluate the potential for adverse human health effects
resulting from the hypothetical use of ground water.
Based on a review of the data from'the original and the
focused RIs, a set of chemicals of potential concern were
selected for detailed evaluation in the risk assessment. The
results of the screening analysis for the shallow aquifer is
presented in Table 3. Table 4 provides a justification for the
selection or rejection of individual constituents from the risk
assessment for the shallow ground water. The results of the deep
aquifer screening is presented in Table 5. Table 6 provides a
justification for the elimination of individual constituents from
the risk assessment for the deep aquifer. No constituents of
14
AR3020I7
-------
potential concern were identified in the deep aquifer.
Therefore, a quantitative risk assessment was not performed to
evaluate potential exposures to ground water in the deep aquifer.
B. Exposure Pathways
This step in the risk assessment process involves.
determining the potential routes of exposure to the human
population, the estimated concentrations to which the population
is exposed, and the.population at risk. Currently, there are no
users of the ground water on-site. The risk assessment for OU-2
evaluated the potential risks associated with the hypothetical
future use of on-site ground water as a residential water supply.
The RA considered on-site ground water use by both adults and •
young children and evaluated all three potential routes of
exposure associated with the residential use of ground water
(i.e., ingestion, dermal contact during bathing, and inhalation .
of VOCs during showering).
C. Toxicity Assessment
Cancer potency factors ("CPFs") have been developed by'EPA
for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CPFs, which are
expressed in units of (mg/kg-day) "1, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime cancer
risk associated with exposure at that intake level. The term
"upper bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassay to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses ("RfDs") have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs are
exposure levels for humans, including sensitive individuals, that
are likely .to be without.an appreciable risk of adverse health
effects. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived
from human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
15
AR3020I8
-------
quotient (HQ) (or the ratio of the estimated intake to the
reference dose) . By adding the HQs for all contaminants within a
medium or across all media to.which a given population may
reasonably be exposed, the Hazard Index ("HI") can be generated.
The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a
single medium or across media.
Excess lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of IxlO'6
indicates that, as a plausible upper bound, an individual has a
one in one million chaihce of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
A summary of the toxicological indices for the indicator
chemicals selected for the Brodhead Creek Site are presented in
Table 7.
D. Riak Characterization .
The potential carcinogenic risks associated with the
Brodhead Creek Site were calculated by multiplying the calculated
intakes by the appropriate carcinogenic potency factors.
Concurrent exposures to more than one carcinogen or to one
chemical .through multiple exposure routes were evaluated by
adding the individual risk estimates. Potential carcinogenic
risks are identified by the risk level (i.e., a 1.0 x 10"6 risk
level indicates one additional chance in 1,000,000 that an
.individual will develop cancer). EPA's acceptable risk range for
Superfund cleanups is between 1.0 x 10"4 to 1.0 x 10"6. If the
risk exceeds 1.0 x 10"4, EPA will generally take action to reduce
the risk to within the acceptable risk range.
The potential risks associated with exposure to
noncarcinogens were estimated by the calculation of the Hazard
Index. An HI is equal to the estimated intake for a specific
chemical divided by the appropriate RfD. Hi's may be summed for
each constituent and exposure route to which a receptor may be
simultaneously exposed in order to evaluate exposure to multiple
chemicals or exposure via multiple routes. The HI identifies the
potential for the most sensitive individuals to be adversely
affected by non-carcinogenic chemicals that damage human organs.
If the HI exceeds one (1.0), there may be concern for potential
systematic effects. As a rule, the greater the value of the HI
above 1.0, the greater the level of concern.
The Risk Assessment used a statistical analysis concept
called Reasonable Maximum Exposure ("RME") to predict the highest
expected concentrations that a receptor might be exposed to, for
16
AR3020I9
-------
use in Che Risk Assessment. The risk assessment estimates the
reasonable maximum exposure for possible receptors. This concept
produces a very conservative and protective estimate of risk.
The risk calculations for both carcinogens and noncarcinogens are
presented in Tables 8 and 9, and are summarized as follows:
(1) The estimated carcinogenic risks associated with the
hypothetical residential use of shallow ground water by
an adult and a child are 2.49 x 10*2 and 9.57 x 10~3,
respectively.
(2) The hazard indices calculated for the. hypothetical
residential use of shallow ground water by an adult
and a child are 114 and 311, respectively.
E. Uncertainty in Exposure Assessment
It should be re-emphasized that, under current use
conditions, there are no users of ground water from either the
shallow or deep aquifers in the immediate vicinity of the
Brodhead Creek Site. The Borough of East Stroudsburg does
receive water from two wells located on the campus of East
Stroudsburg University, and a.third shallow gravel well located
2,000 feet from the Brodhead Creek Site, in Dansbury Park.
However, the original RI concluded that the migration of coal
tar-related constituents in ground water beyond Brodhead Creek to
any nearby wells east of the Site is not possible under the
hydraulic conditions at the Site. The water supply well located
in Dansbury Park is separated from the Site by Brodhead Creek and
draws its yield from a separate deeper gravel unit. A review of
the sampling data from the Dansbury Park well and the other two
East Stroudsburg municipal supply wells did not reveal the
presence of any coal tar-related compounds.
Although hypothetical future use of on-site ground water
would result in an unacceptable risk, such a scenario is
extremely unlikely for several reasons. Several site-specific
constraints limit the practicality .of using the ground water at
the Site as a drinking water source. These include the flood
control levee and wetlands located on-site. In addition, the
gravel unit is too limited in extent to serve as a viable long-
term-ground water supply at the Site. Brodhead Creek serves as a
hydraulic boundary for shallow ground water contamination; it is
not possible for ground water in the shallow aquifer to migrate
east of Brodhead Creek. Furthermore, the Focused RI reaffirmed
that upward flow gradients exist at the Site. Therefore, there
is little probability that the bedrock aquifer underneath the
Site will be impacted.
Finally, any use of ground water from the shallow aquifer is
very unlikely in light of a municipal ordinance in the Borough of
17
AR302020
-------
Ease Stroudsburg which requires mandatory connection to the
municipal water distribution system (East Stroudsburg Code §154-
4). EPA understands that the Borough of Stroudsburg is presently
in the process of developing a similar ordinance. in addition,
deed restrictions will be imposed to limit future use of the Site
as part of the OU-1 interim remedial action.
VII. DESCRIPTION OP ALTERNATIVES
The Superfund statute and regulations (NCP) require that the
alternative chosen to clean up a hazardous waste site meet
several criteria. The alternative must protect human health and
the environment, be cost effective, .and meet the requirements of
environmental regulations. Permanent solutions to contamination
problems should be developed wherever possible. The solutions
should reduce the volume, toxlcity, or mobility of the
contaminants. Emphasis is also placed on treating the wastes at
the site, whenever this is possible, and on applying innovative
technologies to clean up the contaminants.
The Focused FS studied a variety of technologies to see if
they met these criteria and were applicable for addressing the
contamination at the Site. The technologies determined to be
most applicable to these materials were developed into remedial
alternatives. These alternatives are presented and discussed
below. Many other technologies were screened out. This process
is fully detailed in the original FS dated January 1991 and the
Focused FS for Operable Unit Two.
All costs and implementation timeframes specified below are
estimates based on best available information. Present worth is
the total cost of the remedy including capital costs and 30 years
of operation and maintenance of the remedial action, in current
dollars.
Regardless of the alternative chosen, EPA will review the
Site every five years to ensure the continued protection of human
health and the environment, as required by the ROD for OU-1.
Alternative 1: No Further Action
Time to Implement: 0 month*
Capital Cost: $0
Annual Ground Water O&M: $0
Annual Site Maintenance: $0
Present Worth: $0
Under this alternative, no further action, beyond the OU-1
activities, would be taken to reduce the amount of residual coal
tar in the subsurface soils or to remediate ground water. The
ROD for OU-1 addressed free coal tar contamination at the Site.
The enhanced recovery system to remove the free coal tar has been
18
AR30202I
-------
constructed and should become operational in the summer of 1995.
Deed restrictions to limit future use of the Site will be imposed
as part of the OU-l interim remedial action. The OU-1 ground
water and Creek monitoring will continue.
Alternative 2: In-Situ Stabilization/Solidification
Time to Implement: 21 months
Capital Coat: $11,830,000
Annual Ground Water O&M: $35,000
Annual Site Maintenance: $25,575
Present Worth: $13,066,100
This alternative would include the in-place mixing of
stabilizing agents into the contaminated soils, thereby fixating
the contaminants in an inert matrix and reducing their ability to
leach into the ground water. A mathematical model was used to
determine the extent of the coal tar-contaminated soil that would
need to be treated in order to achieve cleanup criteria that
would be protective of ground water. The results of this model
revealed that all areas contaminated with residual coal tar would
need to be remediated. The maximum extent of this area is
depicted in Figure 3 and Figure 7. These areas include the soils
beneath Brodhead Creek, the fill/highlands, the wetlands and the
flood control levee pn-sitei A treatability study and pilot
study t.o select the most appropriate stabilizing reagents for the
soils and to determine the leachability of coal tar-related
constituents from the stabilized/solidified soils would be
required.
Alternative 3: In-Situ Bioremediation
Time to Implement: 26 months
Capital Cost: $3,515,000
Annual Bioremediation O&Ms $241,000
Annual Ground Water O&M: $35,000
Annual Site Maintenance: $25,575
Present Worth: $6,617,100
. In-situ bioremediation involves enhancing the natural
microbial degradation of contaminants in the subsurface soils and
ground water without excavation of the overlying soil. This
technology usually involves adding nutrients, oxygen, and in some
cases microorganisms to stimulate biodegradation of the
contaminants. A treatability study would be necessary to
determine the rate and extent of biodegradation achievable and
the oxygen and nutrient addition requirements of the
biodegradation process. In addition, a pilot study would be
necessary to confirm the results of the treatability study and to
determine if the hydrogeplogic conditions at the Site (e.g. well
spacings, iron fouling problems) are amenable to in-situ
bioremediation. As in Alternative 2, the maximum extent of coal
19
AR302022
-------
tar-contaminated soils would need to be treated. The remediation
process would include a network of air sparging wells to
stimulate bioremediation of the residual levels of coal tar in
the subsurface soils. The Focused FS assumed that multiple
treatment "cells" would be required, that two cells would be
operated simultaneously and that the well spacings would be
approximately fifty feet. Approximately 100 wells would be
required to remediate the entire Site. The wells would range in
depth from 20 feet to 40 feet. The 40-foot wells would penetrate
the levee.
VIII. SUMMARY OP COMPARATIVE ANALYSIS OP ALTERNATIVES
The Superfund process requires that the alternative chosen
to cleanup a hazardous waste site meet, two threshold criteria:
protect human health and the environment, and meet the
requirements of environmental regulations (Applicable or Relevant
and Appropriate Requirements--"ARARs"). EPA's primary balancing
criteria are: long-term effectiveness and permanence, short-term
effectiveness, reduction of volume, toxicity, or mobility of the
contaminants, cost effectiveness, and implementability. EPA's
modifying criteria are state and community acceptance.
A detailed analysis was performed on the three alternatives
using these nine evaluation criteria. The following is a
comparison of the alternatives with respect to these criteria.
Protection of Human Health and th« Environment
All of the alternatives, including Alternative 1 (No Further
Action), would provide protection to human health and the
environment by eliminating, reducing, or controlling risk through
treatment, engineering controls, or institutional controls.
Implementing Alternatives 2 or 3 would not increase human health
protection over Alternative 1, as there is currently no
significant potential for human health impact and no significant
risk related to ground water exposure. Ground water is not
currently used at the Site. Although hypothetical future use of
on-site ground water could result in an unacceptable risk, such
use is highly unlikely, as discussed in the section on "Summary
of Site Risks," above. Brodhead Creek serves as a regional
boundary to ground water flow; thus, no ground water across the
Creek from the Site would be impacted by the Site. Upward flow
gradients at the Site decrease the likelihood that the bedrock
aquifer beneath the Site will be impacted. A municipal ordinance
in the Borough of East Stroudsburg requires mandatory connection
to the municipal water distribution system. EPA understands that
the Borough of Stroudsburg is presently in the process of
developing a similar ordinance. Finally, deed restrictions to
limit future use of the Site will be imposed as part of the OU-1
interim remedial action.
20
AR302023
-------
Compliance with ARARs
CERCLA requires EPA to conduct its remedial actions in
compliance with all environmental laws identified before the
Record of Decision, if they are applicable or relevant and
appropriate for the situation. These requirements are commonly
referred to as ARARs.
Drinking Water and Ground Water ARARs
Alternative 1 would be in compliance with all identified
ARARs except federal MCLs for drinking water and Pennsylvania's
"background" ARAR which requires that contaminated ground water
be restored to "background" levels. For the Brodhead Creek Site,
"background" would be defined as the method detection limit for
the method of analysis utilized with respect to a particular
contaminant. The appropriate methods for the Brodhead Creek Site
would be EPA Methods 524.2 and 525.1.
The results of the ground water modeling in the Focused RI/FS
for OU-2 revealed that all areas contaminated with residual coal
tar would need to be remediated to even attempt to meet MCLs or
background levels. These areas include soils beneath Brodhead
Creek arid beneath the fill/highlands, the wetlands and the levee
on-site.
Remediation of areas contaminated with residual coal tar is
not technically practicable for a number of reasons. The
existing earthen levee could be damaged during the stabilization
process of Alternative 2 and might need to be removed and
replaced. Implementation of either Alternative 2 or Alternative
3 would severely impact and/or destroy the wetland areas at the
Site and on the south fork of Brodhead Creek, which would in turn
impact the existing wildlife at the .Site. The wetlands would
need to be restored. In addition, it would be necessary to
reroute Brodhead Creek temporarily to divert water from the south
fork in order to access coal tar-impacted soils beneath the Creek
bed. This would increase the flow velocity and height of the
Creek. Therefore, it might be necessary to reinforce the
existing 1-80 bridge abutments in order to reduce scour. Work on
Brodhead Creek would temporarily impact the aquatic habitat.
If, despite these problems, Alternatives 2 or 3_were
implemented, they would provide some, reduction in the
concentrations of coal tar constituents in ground water over the
long term. However, it is not likely that either Alternative 2
or 3 would allow reduction of the concentrations of coal
tar-related constituents to background or MCL levels within a
reasonable timeframe. Low levels of coal tar-related
constituents would continue to leach from the stabilized soils
and some constituents would remain recalcitrant to
bioremediation.
21
AR30202U
-------
Therefore, EPA is waiving Che federal MCLs for drinking
water and Pennsylvania's "background" ARAR on the basis of
technical impracticability. Use of the "Technical
Impracticability" (TI) waiver is appropriate when attainment of
an ARAR would be illogical or infeasible from an engineering
perspective and therefore would be "impracticable." (See
"Technical Impracticability of Ground Water Restoration, Brodhead
Creek Site" dated June 29, 1995)
Other ARARi
Alternatives 2 and 3 would comply with PADER requirements
for air emissions set forth in 25 Pa. Code §§ 123.1 et. sea. .
Off-site transportation of wastes would be conducted in
accordance with the Department of Transportation Rules for
Hazardous Materials Transport and Pennsylvania Hazardous
Substance Transport regulations. Disposal of hazardous waste
from the Site would be conducted in accordance with the
requirements of the Resource Conservation and Recovery Act,
Pennsylvania Solid Waste Management Act, and/or Pennsylvania
Residual Waste Management Act. All discharges of treated process
water under Alternative 3 would be conducted in accordance with
the National Pollution Discharge Elimination System (NPDES)
requirements developed pursuant to the Clean Water Act and PADER
Bureau of Water Quality Standards. .'....
As discussed above, implementation of Alternatives 2 or 3
would severely impact and/or destroy the wetland areas at the
Site and the south fork of Brodhead Creek, which would in turn
impact the existing wildlife at the Site. All regulatory
requirements for the construction activities in the wetlands and
the Creek would have to be met. Alternative 1 would not impact
Site wetlands.
Long-Term Effectiveness and Permanence
Alternative 1 would be effective in the long term for
several reasons. The slurry wall installed at the Site will
continue to prevent free coal tar from discharging to Brodhead
Creek. 'Implementation of the OU-1 enhanced recovery program for
the free coal tar areas on-site will reduce the areas of highest
subsurface soil contamination to residual saturation JLevels,
which is expected to improve conditions for natural microbial
degradation. The OU-1 monitoring program will provide the data
required to evaluate the fate of the coal tar-related
constituents, the integrity of the slurry wall and the "health"
of the biological community in Brodhead Creek.
Alternatives 2 and 3 would both be effective in the long
term in that both will reduce the amount of coal tar constituents
in ground water. However, coal tar at residual saturation levels
22
AR302025
-------
would continue to be a source for the release of low levels of
coal tar-related constituents to the ground water in the shallow
aquifer, thus precluding compliance with MCLs and Pennsylvania's
"background" ARAR.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternative 1 would not reduce the toxicity, mobility, or
volume of the contaminants. However, the OU-1 enhanced recovery
program will provide for reduction in the toxicity, mobility, and
volume of the contaminants by removing the free coal tar and the
source of the highest ground water contamination.
Alternative 2 would not reduce the toxicity or the volume of
the residual coal tar. However, the mobility of the contaminants
in the subsurface soils would, be significantly reduced, thereby
reducing their impact on ground water in the shallow aquifer.
Alternative 3 would reduce the toxicity and mobility of the
coal tar contaminants in ground water in the long term. However,
in the short term, the mobility of the contaminants could
increase as a result of microorganisms producing surfactants as a
"food source." Alternative 3 would not be expected to
significantly reduce the volume of residual coal tar since some
constituents would remain recalcitrant to bibremediation. -
Short-Term Effectiveness
There are no short-term risks associated with implementing
Alternative 1.
Potential risks to on^site workers and/or the community
might occur dufing implementation of'Alternatives 2 and 3.
Exposure to releases of coal tar-related constituents could be
minimized by the use of proper operating procedures and personal
protective gear for on-site workers. Some emission of VOCs .
during the treatment activities is likely to occur. Precautions
would have to be taken to ensure that these emissions would not
impact off-site populations. Off-site transportation of any
recovered coal tar and wastewater during the implementation of
Alternatives 2 and 3 could create the potential for accidental
releases, with attendant human health and environmental risks.
The wetland areas at the Site and the south fork'of Brodhead
Creek would be destroyed during implementation of Alternatives 2
and 3, which could subsequently impact the existing wildlife
habitat.
Xmplementability
Each of the alternatives under consideration would be
implementable at the Site. Alternative 1, No Further Action,
23
AR302026
-------
would be Che easiest to implement. The equipment and labor
required for the implementation of Alternatives 2 and 3 is
readily available. RCRA-permitted hazardous waste facilities are
available to receive the recovered coal tar and wastewater.
Several Site-specific constraints would make the
implementation of Alternatives 2 and 3 difficult. These include
the need to: (1) reroute Brodhead Creek temporarily to divert
water from the south fork in order to access coal tar-impacted
soils .beneath the Creek bed; (2) reinforce the existing 1-80
bridge abutments in order to reduce scour due to the increased
flow velocity and height of the Creek; and (3) restore wetlands
which would be impacted by the implementation of Alternatives 2
and 3. In addition, the existing earthen levee could be damaged
during the stabilization process of Alternative 2 and might need
to be removed and replaced.
Cost
The present worth cost for Alternative 1 is $0, which is the
lowest cost alternative. The highest cost alternative is in-situ
stabilization (Alternative 2) at $13,066,10.0.
State Acceptance
The Commonwealth of Pennsylvania has concurred with the
remedy.
Community Acceptance
Community acceptance of the various alternatives is
reflected in the attached Responsiveness Summary. The
Responsiveness Summary presents all of the public comments
received on the RI/FS and the Proposed Plan, and EPA's responses
to the comments.
IX. SELECTED REMEDY
After careful consideration of the requirements of CERCLA,
the detailed analysis of the alternatives, and public comments,
EPA has selected Alternative 1, No Further Action, for Operable
Unit Two at this Site.
Although the hypothetical ingestion of on-site ground water
reveals a risk above IxlO"4, this scenario is highly unlikely.
As mentioned previously, several Site specific constraints limit
the practicality of using the ground water at the Site as a
drinking water source. These include the levee and wetlands
located on-site. Furthermore, it should be noted that any use of
ground water from the shallow aquifer is very unlikely in light
of a municipal ordinance in the Borough of East Stroudsburg which
requires mandatory connection to the municipal water distribution
24
UR302027
-------
system (East Stroudsburg Code §154-4). EPA understands that the
Borough of Stroudsburg is presently in the process of developing
a similar ordinance.
In addition, 'the gravel unit is too limited in extent to
serve as a viable ground water supply at the Site. Brodhead
Creek serves as a hydraulic boundary for shallow ground water
contamination; it is not possible for ground water in the shallow
aquifer to migrate east of Brodhead Creek. Furthermore, the
Focused RI reaffirmed that upward flow gradients exist at the .
Site. Therefore, there, is little probability that the bedrock
aquifer underneath the Site will be impacted.
X. STATUTORY DETERMINATIONS
The No Further Action Alternative, in conjunction with the
OU-1 remedy, will be protective of human health and the
environment. Implementation of the OU-1 enhanced recovery
program for the free coal tar areas on-site will reduce the areas
of highest subsurface soil contamination to residual saturation
levels, which is expected to improve conditions for natural
microbial degradation. The OU-1 monitoring program will provide
the data required to evaluate the fate of the coal tar related
constituents, the integrity of the slurry wall and the "health"
of the biological community iii Brodhead Creek. This will provide
long term protection against the unlikely event that Site
conditions might change and potential exposures increase. In
addition, the slurry wall installed at the Site will continue to
prevent free coal tar from discharging to Brodhead Creek.
There is currently no significant potential for human health
impact and no significant risk related to ground water exposure.
Ground water is not currently used at the Site. Although
hypothetical future use of on-site ground water could result in
an unacceptable risk, such use is highly unlikely, as discussed
in.the section on "Summary of Site Risks," above. Brodhead Creek
serves as a regional boundary to ground water flow; thus, no
ground water across the Creek from the Site would be impacted by
the Site. Upward flow gradients at the Site decrease the
likelihood that the bedrock aquifer beneath the Site will be
impacted. A municipal ordinance in the Borough of East
Stroudsburg requires mandatory connection to the municipal water
distribution system. EPA understands that the Borough of
Stroudsburg is presently in the process of developing a similar
ordinance. Finally, deed restrictions to limit future use of the
Site will be imposed as part of the OU-1 interim remedial action.
25
AR302028
-------
B. Complianca with Applicable or Relevant; and Appropriate
Requirementa
The Record of Decision for Operable Unit One (March 29,
1991) addressed all the ARARs concerning the Site except for
ARARs relating to ground water or drinking water. Reference can
be made to the ROD for OU-1 for a full discussion of the ARARs
discussed therein.
Since the selected remedy requires no further action for
residual coal tar contamination and ground water contamination,
action specific ARARs do not apply. The only ARARs that apply to
ground water are the Safe Drinking Water Act MCLs promulgated at
40 C.F.R. 141 and the * Pennsylvania ARAR-for ground water which
requires that all ground water be remediated to "background"
quality, as specified by 25 PA Code §§ 264.90-264.100 and in
particular 25 PA Code §§ 264.97(i), (j), and 264.100 (a) (9) . EPA
is waiving Federal MCLs and Pennsylvania's "background" ARAR on
the basis of "Technical Impracticability." Several site specific
constraints as discussed earlier make the implementation of
engineering solutions to the contamination impracticable.
The horizontal and vertical extent for which the TI waiver
will be invoked is the shallow aquifer at the Site, including
the area containing free and residual coal tar depicted in Figure
3, and the zones beneath Brodhead Creek, the island, the levee,
the wetlands, and the fill/highlands on-site. The vertical
extent includes the stream gravel unit between the fill and the
silty sand units as depicted in Figure 7.
Several intermediate wells screened in the silty sand unit
of the Site are currently being used to monitor the shallow
aquifer (TI zone) . In the Proposed Remedial Action Plan for the
final ROD on OU-1, EPA will recommend adding more intermediate
wells to the long-term monitoring network. These wells will
monitor the TI zone and will also serve as early indicators in
the unlikely event that contamination moves vertically downward
toward the deeper ground water in bedrock.
C. Coat-Effactivenesa
No additional cost would be incurred by the selected remedy.
This remedy is No Further Action and is not intended to
utilize permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable
for this operable unit.
26
RR302029
-------
XI. DOCUMENTATION OP SIGNIFICANT CHANGES PROM THE PROPOSED PLAN
The Proposed Plan for the Brodhead Creek Site was released
for comment in May of 1995. It described the alternatives
evaluated in the Focused FS for OU-2 and identified Alternative 1
as EPA's Preferred Alternative. After reviewing all of the
written and verbal comments submitted during the comment period
and at the public meeting, EPA has determined that no
significant changes to the Proposed Plan remedy are necessary.
27
AR302030
-------
APPENDIX A
-------
FIGURE 1
Brodhead Creek Site Location Map
Stroudsburg, Pennsylvania
®
N
W0«
2S3J3.CC.C1
0*«-»r/0itt: P.MicAll.n 7/18/90 j
C.licttl It
«,,„•« >T,0.,.:.M.Smlth a. 17 90
B.I790
SR302032
-------
CO
o
ro
C5
CO
CO
Figure 2
Site Plan
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
»,...»,/«.u CMi'fl/ii/aa I C...L. >, / »M. » Kan
jf •» IM* **•' • V«* *•••*
-------
CO
CD
ro
CD
co
FIGURE 3
Maximum Probable Extent of
Free Coal-Tar Surface
Brodhead Creek Remedial Investigation
Stroudsburg, PA
fc^t,'*"* CMt» a/I 1/09
»M n Kan a/I 1/89
-------
General Site Stratographlc Column
Brodh««d Cr««k Sit*
Stroudtburg, Pennsylvania
20'
80'
ISO1
.. . v • i. . •- . -. , •.. .
'*.•''*.•"»..'*»."'••' •'•*.'"•
•.•- .;> ..•. !•• •.."'•,'•,' *
•*•'/ • '•,• •*. - • ;.. «
'•-/ . '.'.•./.••••'.."'-I'*'»
.-• 'V. • »'• ••. t' :
fn
flood Piam Otoo«rt
Strnm
1 73 i IQ -* ft/
Ovrt in
from ' J • '0 -i '!/«« ia
< .• i»ml«4 :*t int.
T>
-------
CO
C3
ro
o
CO
cr»
FIGURE 5
Lateral Extent of
Stream Gravel Unit
Brodhead Creek Remedial Investigation
Stroudsburg, PA
I «J 4J CS I k L I
\\\l !•!••• *l il>««n> t-,
v>* tMMl *M«IMI«I «.«.!
Nltlllt k| ( •<)•
253 2!> 05
-------
30
CO
CD
ro
CD
CO
FIGURE 6
Top of Silly Sand Unit
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
lo
-------
Figure 7
Schematic off Extent off Free and Residual Coal Tar
Brodh«ad Cr««k SIU
Stroudsburg, Pennsylvania
E«l«nl ol Rcwduol
Subwirloc* Cool Tor
flooo Control Wull
CO
CD
DO
CD
CO
CO
-------
FIGURE 8
Water Supply Well Locations
Brodhead Creek Site OU-2
Stroudsburg, Pennsylvania
-•(
|L'"__ '• • It ' "-
'
Borou^i ot East
SlrouCJburg Wattr
SuopV Wdl 3
Oinlxry Ptrk
Source: U.S.G.S.Tooograohic Quadrangles. East Stroudsburg. PA and Stroudaburg. PA-N
EXM J
RR302039
-------
Figure 9
Ground Water Flow Schematic
Brodhead Creek Site
Stroudsburg, Pennsylvania
- £«l«nl ol Ruidual
Flood Control Wull
CO
o
ro
B1
I ^>
-------
FIGURE 10
Log off Sum of Total
Detected Organics
Brodhead Creek Remedial Investigation
Stroudsburg, PA
locjerxJ
U I •"•
CO
CD
ro
CD
-------
FIGURE 11
Site Plan with Monitoring Well Locations
Brodhaad Craak SIU
Stroudtburg, Pennsylvania
-------
CO
O 8
ro s
o g
jr* o
CO |
FIGURE 12
Flow In Bedrock System
7 September 1003
Brodh«*d Cr««k SIU OU-2
Stroudtburg, P«nn§ylvenla
Scwoge Treatment Plant
JS) PaUnlMMixKK Surtac* IW.
w«clM>n ol Iki.
!•••!•
nIJtn ol (low
Slu Mai.
-------
FIGURE 13
~r-^: -— ;'N Regional Fracture Pattern-~^ ".. ,._\. **?•
-.-^-^-S^.-1 Brodhead Creek Site *#* *:'. '.">^<"
1-* %t" '
• • --^
*. W^iS^^'W I!
LgCEND
— Apprexinwti Fracturt Ori«ntation ^.
?jplu ViUty Or- .
-------
APPENDIX B
AR3020U5
-------
Rtlrruttutd Appmpmw Rtqairroiena forGiaand W(wr
Sradhtad Cmk Sit* Fnubility Study
iill conetntntiom *" >* **ffl- mum* ethtmruM i
CHEMICAL
A:cicr.e
Cirton Duulfid*
Chioroiorai
Methyl (thvl keton*
1 . 1 . 1 •ThcrUorocuxut*
Bnutnt
Tolutnt
3\jofobcnunc
Ethytbatzew
Styrcnt
Xyltn*
PhwoJ
Ac0upnuiy')Uki
AccniphthM
Fniofvw
Phfluwthfw
AnthnccM
Fluanmhai*
Pywnt
BcmUtatthnctn*
OUfMfM
Binio(b>a«QMHlh«M
BMBoOdflaoaMlMM
BOTMWpjmm
lndtneprnM
B0izo(ghi)pvfyftBi0
NiphttulM
2-MfthyiNaphttukM
Dibuty) phdulitt
Butyl bvizyl phdulitt
Amnk
auiun
Beryllium
Zadatiuni
OwonuumVI
Copptr
Iran
L««d
MangiiMM aid coafeund*
Mtroiry , morjmjc
Nidul
SeUfUua
Siivtr and eea^eundt
Sodium
Thallium
Vvudixm
Zinc
Cytntd*
Ground Waitr
Conc«nmhon»
Muimam Avtngt
8.50E-02 9.43E-01
4.20E-02 6.29E-03
2.ME-02 S.44E-03
J OOE-03 9 70E-03
JOOE-OJ SJUE-U3
i.ioE*oo rioe-ot
1.40E-01 1-24E-02
2.JOEXS 5^6E-03
4.00E-01 9.1SE-02
2.70E-02 6.UE-09
6.10E-01 1.14E-01
2JOE42 6. 12-03
8.70E-01 1.17E-01
1.40E*00 1.04E-01
l.«OE*00 U 6.13EXn
NA NA
NA NA
Utt-m 3.UI4B
5.9SE41 I.9JE-01
3JOC-M SJOEMM
115I-OS LISl-O
UR-OS L3OMB
1J9B4B 1J9B-03
177E« i.aoe*oo
4JOB-03
SJOe-03 1.008-01
1J»-01 5JJOM2
U* IJOI-rtO
NA J.OOE-01
ojns* sjot-oa
NA SJOMI
2JMB-03
l.OOE-01
5JBC-
-------
Summary of Ground Water Analyses
Brodhead Creek Site Oil-2
TABLE 2
CO
CD
l\3
CD
JT
ORCANICS
VOC»(ngll)
Carbon Disulfide
Trichloroethene
m&pxylene
1,2,4 trimethylbeiuene
Chloromethane
Trichlorofluorometnane
1.1-Dichloroethane
1,1,1 Trichkmxrthane
Benzene
Toluene
SVOC«
2-Methylnaphlhafene
Naphthalene
Diethylphthalale
Butylbenzylphthalate
Bistf-ethylhexyDphlhalate
Dimethylphinalate
Pentachlorophenpl
Phenanlhrene
Di-n-butylphthalate
Bis (2-ethylhexyUadipate
BR-1
6/3/93 12/10/93 5/8/95
0.2 NA ND
0.6 ND ND
ND 0.1 ND
0.1 ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND 0.1 ND
ND 03 ND
0.09 0.1 ND
0.1 0.1 ND
03 0.2 0.06
ND 04)8 ND
21 8.0 0.8
ND 0.06 ND
ND ND ND
ND 04)5 ND
ND 0.4 ND
ND 0.3 ND
BR-2
6/3/93 12/9/93 5/9/95
0.4 NA ND
03 ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND 0.2 ND
ND ND ND
ND 0.08 0.04
0.2 tt3 0.09
ND 0.1 ND
ND 10 04
ND OS* ND
ND 01 ND
ND ND Om
ND 0.1 ND
ND as ND
BK3
6/4/93 12/9/91' 5/8/95
0.2 NA ND
5.1 ND ND
0.2 ND ND
0.1 ND NO
ND 0.2 NO
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
0.09 ND ND
0.2 ND ND
0.3 ND ND
0.1 ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
-------
Shallow
SrodMiaM Cftik Sit* I f*D "•"
itroudsbvrf. Prmsylvamt
Constituent
VoUnle Compound*
C-Butanone
8«(uene
Toluene
Ethylbenzer.t
To.tal Xvlenes
Seyrtnt
Semi* Volatile Campetiade
Naphthiknt
2-Methylniphthaltnt tt
Acenaphthylent tt
Acenaphthtnt
Dibtnxofunn tt
Fluorent
Phtnanthrtnt t
Anthracene
FIuonnthtM
Pyrtnt
8tfuo(a)anmnctM
Chryitnt
n't/5 MliifUuwltaHthmlBM
Btnzo(b or k)fiuonnmtjM*
BenzoUtpyrtnt
tndtno( 1 -13-cdlp)rtg»
OibtnXaJtianthnetnt
B«nzo
129141
'
.
.
•
9331*01
4J9B42
.
IJ7M2
V^58-03
1161-01
* Serttning Itvtl btatd on pywnt teoOOtr *•»
NA«Notamlyud
NO'NotdtMatd
8 • compound ww dettcttd in blank umplt at • «0uUr eonocrandon
- • no nsk-eated «a*ewng tovil It avukblt tor itni compound
ittvo)
-------
TABLE 4
Conjtirufttt
Stckpoimd
concmndon atuimuB R«i»in«d tor
frtiitr dun CicMdi RMJIOII dracad to rxliuoon in
downgndicnt III ruk-e
2.M«fiylniptitfukf»
Actruph*yl«no
A^MUBfertW^M
AC VTtdl^lU mt W
Dibtntofunn
Ftuoiw
Phtmmhrtnv
Arthrmnt
FTuofwichtm
r. l>a.
rjri»Tw
BcnsofftlttttnncoW
6^2^lllO«rl)pMttlM
Btruoik or klfluotmdvno
BtnMi)p7>w
Indonol liKdlpr1""*
Oibtro( i Jittntfuioono
Bfnxofgjulporytam
Phnwl
PtntocMorophoMt
atrayl Alcohol
N'o
No
No
No
No
No
No
No
No
No
MA
•^•Q
NO
No
No
No
No
No
No
No
No
No
No
No
No
No
Sfo
i'W
NO
No
Yoi
No
No
No
No
. *•
Yo)
So
So
Sa
i*W
TO)
No
No
No
TO)
Yo)
TO)
TO)
TOI
Toi
No
No
No
No
Vo
Y«
No
YM
No
No
Yoi
Yoi
Toi
Toi
T«M
^
Toi
No
Toi
YM
Toi
YM
Toi
TOJ
Toi
Toi
Toi
No .
No
Toi
No
No
No
YM
No
No
No
Yoi
Toi
Toi
YM
YM
YM
Toi
No
Toi
Y«
Toi
Toi
"»
Toi
Toi
Toi
Toi
NO
NO
Toi
MM
• »*r
No
Did not ftu icnwuif ipinw ruk-btMd d not fad icrwnutg tpinn nik-6u*d tcnvrvrf !«v«
Rjno 01 juiioiuffi conctntnaon to CM KnMnui| w«i u
Did not fill xntrung ipimt nak-b*Md lomun; l«vt<
Did not fail tcnnunf ipuui njk-ouM icrttniri l«v«i
F«M Krominc tpirM nik-dMOd icnvrup j l«vti
Fiilod icronnt tpirot rak-o«od KiHninf |M«!
FuM tenojunf ifiuM nk-MMd KTMiunf Irnl
gnstv tfuw 0.1
gfMtvthinai
Old not fell ni'^uif jpirat rvk-biMd aoiwinf kfvti
ttidocrftiuxoffiuaaaKvwmanra^ftTivu^irr^ut
FtiW KMRiaf tfurot rMfOMod laoaung tenl
Not t omatuom of cotl w (MO apart tnt) .
FII)O *MI«^HB> Mtfk jM^oaaA laaa«4
W^ (W BHl IBWV^ o^MW nK*WB IQvWnB lonrV-
FtiM KMninf tfurm mk-ooMd tcnmrtf tani
Old not htl MMninf ipinoi nMoMd icnomni M*4
Aluaunum
Anonie
Suium
^"ilriufli
Iran
VfagnoRum
SUnfUMM
Nickol
Sodium
No
No
No
No
No
No
No
No
No
No
To)
NO
Toi
No
Toi
No
No
No
No
No
No
Toi
No
No
trtmitaMtfor
anMUMoLowmul
ofpeonul
FtiM MOI
Old not M
No
huarnnuMom.net
ZiiK
Cyuud*
No
No
No
No
No
No
No
No
Toi
No
No
Toi
Old not Ml *ao
DMnottMliawnnf
rtbMrti
rur» to«l
> no rak-6«od laomnf K*e1 • (vuitol*
-------
Deep Aquifer Screening Analysis
Bredhead Creek Site
Stroudsbvrg, Pennsylvania
TABLE 5
Maximum
Downgradient Background
Constituent Concentration Concentration
Volatile Compounds
Benzene
Carbon disuifide
Trichloroe there
Toluene
m+p Xylene *
1 .2,-t-Trimethy Ibenzene
Semi* Volatile Compounds
Naphthalene
2-Methylnaphthalene tt
Diethylphthalate
Di-n-butylphthalate
Dimethylphthalate
Butylbenzylphthalate
Bis (2-ethylhexyl)adipate
8is(2-ethylhexyl)phthalate
Pentachlorophenol
Phenanthrene t
Total Metals (unfiltend)
Calcium
Iron
Magnesium
Manganese
Notes:
J = quantitative estimate
ND » Not detected
0.1
0.4
0.6
0.5
O.I
0.1
0.1
0.1
03
0.4
0.06
0.1
0.5
21
0.1
0.05
58100
9600
5080
347
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
-
ND
0.2
5.1
0.3 B
0.2
0.1
0.2
0.09
03
03 B
ND
0.1
0.2 B
12 B
ND
ND
40800
33600
10900
354
Ratio of
USEPA Region Maximum
(II Risk-Based Detected/
Concentration Screening
Table Level
0.36
21
1.6
750
520
3
1500
1500
29000
3700
370000
7300
56
48
0.56
1100
_
.
-
180
2.78E-01
1.90E-02
N/ A
6.67E-04
1.92E-04
3.33E-02
6.67E-05
6.67E-05
1.03E-05
1.08E-04
1.62E-07
1.37E-05
8.93E-03
4.38E+00
1.79E-01
4.55E-05
,
.
.
N/ A
- = no risk-based screening level is available for this compound
tt Screening level based on withdrawn naphthalene toxicity data
. p • i i ^ j *
t screening level oases on pyrnte ton
* Screening level based on p-Xyiene
idrydata
N / A Not applicable; Did not exceed the background concentration
All values in iig/L
-------
Tttlt for tlu itlfCtiam of CamttinrmU of fotnliMl Camcom im Ifc* Otff A^mtftr
conctttmio* dMMttd M fUtiuwd for
r HIM ruiirti topM III Kiwuof k»«l tvahutiM IB
nik-tand pmiMrtkM ink
0.1? _ «M«M»«n*i
No No No No Did not tad KIWI* «|MM n*k-bM*J Iwt.
No No No No Did not <•! Kmmnf ifairai ntk-bwd tovri
No Yoi Y« No Not •cantiiaMmaicuiuriM* noon tot)
No No No No Old an f«< cnnnf >(>irai r*k-b«» !)•*««
No No Yoi No OhiiwWKnMn|ifMMlf«k-bM»Jli««i«^
pom w |m«d wmr • MOM (M* npait
No No No No DtfMfiilaaMMVifaMr.ik-bM>:ilmi
No No No No DMli«fMlnMiia|ip««mk-»MtJlw«l
Tom i
No • -No riin|niiMHiil»i nmut) intern in mnlilili
•MMttl huoun nuinmt not luMonui conunucm
afpOMMMlc
No NoauMMMlvtHudtjrindieHifttvuUM*.
oipaMMiitcaneMi
tlignniiim Y«> • . - No NoquMiwiliv*Munyindien«n>JvUliMt.
l huauo nuuvm. not hiMoncal canHaunu
N/A N/A No OMKMd in bickpoundM higher
no - jcmnm ^ far
N/A • Not ippbribir. did not tm«d bottyound conctntr juon.
flR30205l
-------
Summary of Toxicity Data for Constituents of Potential Concern
Brodhtad Crttk Site
Stroudabtirg, Pennsylvania
TABLE 7
Constituent
Volatile Compounds
Benzene
Ethy [benzene
Semi- Volatile Compounds
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofunn
Fluorene
Phenanthrene
Fluoranthene
Pyrene
Benzo(a)anthracene
Quysene
Benzo(b or k)fluoranthene
Benzo(a)pyrene
Indeno(lZ3-cd)pyTene
Dibenz(ajt)anthncene
Pentachlorephenol
Dissolved Metals
Arsenic
Barium
Lead
Manganese
Cyanide
Inhalation
RfD
mg/kg/day
1.7TE-03
2.36E-01
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.43E-04
NA
1.43E-09
NA
RfD
mg/Vs/dav
(6) NA
(I) l.OOE-01
4.00E-02
4.00E-02
4.00E-02
6.00E-02
4.00E-02
4.00E-02
3.00E-02
4.00E-02
3.00E-02
NA
NA
NA
NA
NA
NA
0.03
3.00E-04
(2) 7.00EXB
NA
(1) 5JXE-03
rOOE-02
(1)
(4)
(4)
(4)
(D
(4)
(D
(5)
(1)
(1)
(1)
(1)
(1)
(D
(1)
Inhalation Oral US EPA
CP? CPF Carcinogenic
1/mf/ki/dav iymcAft/day ClawinVation
2.90E-02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6.10E41
6.10E-03
6.10E-01
6.10E>00
6.10E-01
6.10E-M30
NA
U1E*01
NA
NA
NA
NA
(1) 2.90E-02 (1)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(3) 730E-01 (3)
(3) 7.30E-03 (3)
(3) 7JOE-01 (3)
(2) 730E*00 (1)
(3) 7JOE-01 (3)
(3) 7JOE*00 (3)
1.20E41 (1)
(1) 1.75E>00 (1)
NA
NA
NA
NA
A
0
D
•
D
•
D
D
D
D
D
B2
B2
82
B2
82
82
82
A
»
82
D
0
Note*
NA » Not available from UUS or HEAST
I . IRIS (USEP A. 1994)
2 - HEAST (U5EPA, 1994b)
3 =. BenwXaJPyrtne Emnvitane* (USEPA. 1993)
4 * Baaed on wimdnwn naphthalene value from OUS/HEAST.
5 » Baaed on tontitf dtft far pyrene.
6 » EPA-ECAO, 1994
A * Human carcinogen.
B 2 « Probablt human carcinogen; sufficient evidence in animals or no evidence in humans
D » Not dassinabl* as to human eareinogtnidty
••Notdassifitd
AR302052
-------
Stt»
TABLE 8
KUfc
&IOOMU*
CaactnoraM
Ont
OT
Conjom*m
(auk* Fioor Uitua f
InfMM Otimtt
I90E-OZ
4*4842
460C42
460E42
4.93E44
1.90C42
TVf.09
7XC41
t.17142
CUTOTW
ObmflUV
U2E42
190*42
9X149
i.at-n
I.17E42
1.17142
1.17142
1.17B42
190E42
410841
i 101.49
410*41
». 10143
i.Ut«00
44*142
I.DI42
USE-OS
I J7C42
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
TottlRhfa
S06E-04
149C43
iM£4)
14IS09
5IOE43
314604
IfTt-OS
2.S243
2.WC-02
UD
to
Hauri
940*41
490*41
taoc«OB
N/A
LOOM!
40*01
1.65141
Ftuotm
FluonnMn*
140141
5.731.00
aaoc^o
1001^0
938*42
400(42
40*02
400*42
40*02
10*02
Ar
3*miai
101*41
3.95*41
700*41
Cyiiud*
174(42
174*42
174(42
174(41
174(42
174142
17U42
174(42
174(42
174*42
174(42
174*42
174*42
174*42
174*42
174(42
I.I5I43
408*41
523*41
901(41
l.«*42
1.97*42
178*4S
1.1A42
L4H42
1.7W42
JJU42
1«*41
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.43*41
NA
14*142
1J1I42
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1OT41
116C41
1.30E41
9»IE4l
IJ1H-D
I 41141
I JH-02
U3I4I
4.sf^n
199C41
t 141.42
AR302053
-------
(Itt of Sk«
3 40-01
54H41
161E-04
4ISE43
91RE4)
6.20E41
107E42
1.4SC42
4.97Y4)
7&SI4*
190E-CZ
«loe-oi
1 4AE-02
N/A
N/A
6.10E4I N/A
6.IOE41 N/A
4.10E^» N/A
4.10E41 N/A
NA N/A
N/A
SRE04
JME-04
«»^-03
«72EiM
113E-04
1 I3E-05
194E43
wo
UD
4.90*41
ia««oo
3.&3E4I
1.45141
8.49*41
5.73ZWS
N/A
1.00*41
40*41
6.00*49
4.00*41
400*49
4.00*43
4,00*42
4JH4J
6J9I49
4J9MI
6JN4I
4J9f4J
6J9*4Z
4J9V42
6JH42
1.CT4J
&5ZS49
1J3*42
1.47149
3-3*01
U1S42
11U4S
t9042
Cyvrad*
93M42
900*49
1J38*41
3.95*41
1.13IWH
1.4
3.00*42
300*42
340*44
700*41
340*41
U10K42
6JK4Z
4J»MJ
09*41
191141
3JO*42
1*2*41
I.HI4J
LMC41
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
«J**41
«J»*41
NA
IJ1E41
14H4Z
N/A
N/A
N/A
N/A
N/A
N/A
N/A
4.90E4I
4WC-01
104E.OO
37M4I
1.00C«01
N/A
N/A
N/A
N/A
N/A
N/A
1911-01
34*1-0:
34a-01
1.471 wa
4.63*41
flR30205U
-------
APPENDIX C
RESPONSIVENESS SUMMARY
BROOHEAD CREEK SUPERFUND SITE
OPERABLE UNIT TWO
This Responsiveness Summary for Operable Unit Two of the
Brodhead Creek Superfund Site ("the Site") in Stroudsburg,
Pennsylvania, is divided into the following sections:
Section I
Section II
Section III
Overview - A summary of the
public's reaction to EPA's
preferred alternative for Operable
Unit Two.
Background on Community Involvement
A discussion of community interest
in the Site and of information
provided to the community by EPA
and the media.
Summary of Public Comment* and
Agency Response* - A summary of
comments received during the public
comment period on the Proposed
Remedial Action Plan for Operable
Unit Two and EPA's responses
I.
OVERVIEW
On March 29, 1991, EPA issued a Record of Decision ("ROD")
on Operable Unit One ("OU-1") at the Brodhead Creek Superfund
Site. This ROD contained EPA's selected interim remedy for the
free coal tar accumulation in the subsurface soils at the Site.
The interim remedy consisted of an enhanced recovery program for
the free coal tar and attendant ground water monitoring.
On May 25, 1995, EPA issued a Proposed Remedial Action Plan
("Proposed Plan") for Operable Unit Two C'OU-211) at the Site.
The Proposed Plan addressed residual coal tar in the subsurface
soils and ground water contamination. In the Proposed Plan, EPA
identified its preferred alternative for OU-2 as no further
action. The Agency determined that the work already being done
under OU-1 should be sufficient to protecf-human health^ arrifthe
environment..
A public comment period on the Proposed Plan was held from
May 25 through June 23, 1995. On June 6, 1995, a public meeting
was held which provided an opportunity for the public to ask
questions and express opinions on the Proposed Plan. Attendance
at the meeting was moderate. Based on input received during the
AR302055
-------
public meeting, EPA believes the community members are generally
supportive of the no-further-action alternative for OU-2
II. BACKGROUND Of COMMUNITY INVOLVEMENT
The Brodhead Creek Superfund Site is located in the Borough of
Stroudsburg, Monroe County,' Pennsylvania. This area of
Pennsylvania is located between the Pocono Mountains and the
Delaware River and is a popular winter and summer resort area
with tourism as the mainstay of the area's economy. Brodhead
Creek, which originates in the Pocono Mountains and flows past
the Site, has been identified as one of the best cold water trout
fishing streams in Pennsylvania. Many of the area's conservation
groups and tourism groups, as well as the local and county
officials, are aware of the problems at the Site. However, there
have been few expressions of community interest or inquiries to
EPA about the Site.
Besides the meeting on June 6, 1995, EPA held public meetings to
update the community on the progress of site activities in
February of 1991 and February of 1994. In April of 1995, EPA
conducted interviews with community residents and officials to
determine the community's awareness of, and concerns about the
Site. EPA has also kept community members informed of ongoing
work through informational fact sheets and announcements in the
Pocono Record. In addition, the community has access to EPA's
local information repository at the Stroudsburg Borough Building.
Media coverage of the Site was extensive in the early 1980 's when
the contamination was first discovered, but has decreased to
sporadic newspaper articles. The media did cover the public
meeting held on February 27, 1991 on the Proposed Remedial Action
Plan for Operable Unit One and the meeting held on June 6, 1995,
on the Proposed Remedial Action Plan for Operable Unit Two.
The comments made during the public comment period and EPA's
responses to those comments are described in the following
summary .
III. SUMMARY OP PUBLIC COMMENTS AND AGENCY RESPONSES
1. A community member asked if the pocket of coal tar
accumulation located outside the slurry wall is a result of a
defect in the slurry wall.
EPA RESPONSE s No. The slurry wall is working as
However, when the slurry wall was originally constructed, a small
area of free coal tar was inadvertently trapped outside of the
wall. This free coal tar accumulation is effectively contained
by the elevation of the silty sand unit in this area because the
free coal tar cannot move through the silty sand, and therefore
it should not pose a threat to Brodhead Creek. The OU-1 remedy
AR302056
-------
addresses this area (MW-2 area) of free coal car. In addition,
the incegrity of che slurry wall will concinue Co be monicored as
pare of che OU-1 remedy.
2 . A communicy member commenced on che coses of che Alternatives
for OU-1 and OU-2 and questioned why EPA did noc selecc a no-
furcher-accion alcernacive for Operable Unic One as well.
EPA RESPONSE: 1C was determined Chat the free coal Car present
ac che Sice was a principal chreat to ground water. EPA defines
a principal threat as a high volume, high toxicity waste.
Therefore, EPA determined that the free coal tar in the
stratigraphic depression on-site (RCC area) and the MW-2 area of
the Site should be removed. This will be accomplished by the OU-
1 enhanced recovery program. Once the enhanced recovery program
is completed, there should be no principal threat from the former
areas of free coal tar accumulation at the Site since they should
contain only residual levels of coal tar contamination.
3 . A community member asked if the residual coal tar will remain
unchanged or if nature will take care of it.
EPA RESPONSE: Over the long-term, natural breakdown of the coal
tar contaminants in the soils would be expected to occur.
Unfortunately, there is no way to determine accurately how long
these natural processes will take. The removal of free coal tar
from the subsurface soils may improve conditions for the natural
degradation of the contaminants.
4 . A community member asked what would prompt EPA to take action
at the Site in the future.
EPA RESPONSE: The ground water and Brodhead Creek will continue
to be monitored under the OU-1 remedial program. Should these
monitoring results reveal that Site conditions have changed, EPA
will reevaluate its selected remedies and determine if they are
still protective of human health and the environment or if
further action is needed. In addition, EPA will conduct a formal
review of the Site every five years to ensure that the selected
remedies continue to protect human health and the environment.
Finally, if EPA determines that Site conditions represent an
imminent and substantial endangerment to the public health or
welfare, it has authority to take action under Section 106 of the
Comprehensive Environmental Response, Compensation and Liability
Act, 42 U.S.C. § 9601 et sea. . and Secticmu7;003 of the
Conservation and Recovery Act, 42 U.S.C. § 6901 at
5. A community member questioned what types of deed restrictions
would be placed on the Site property and whether the property
could be put to beneficial use.
EPA RESPONSE: The property owners will be required to place deed
AR302Q57
-------
restrictions on the property to prevent the disturbance of
material.below the surface and to prevent the use of ground water
on-site. Possible future uses of the Site will be considered
when structuring the deed restriction.
6. A community member asked what the classification of Brodhead
Creek was and if the levels of contaminants entering the stream
are below the levels necessary to maintain that classification.
EPA RESPONSE: Brodhead Creek is classified by Pennsylvania as a
high quality cold water stream. A high quality cold water stream
is a stream or watershed which has excellent quality waters and
environmental or other features that require special water
quality protection and maintains and/or propagates fish species
and additional flora and fauna which are indigenous to a cold
water habitat. Although dissolved coal tar contaminants are
discharging to the Creek via ground water, upon entering the
Creek these contaminants are being diluted to a level which
cannot be detected. EPA has determined that there are currently
no significant risks associated with the recreational use of
Brodhead Creek or the ingestion of fish from the Creek.
7. A community member asked if the coal tar contaminants
entering Brodhead Creek are being carried downstream and
affecting other areas.
EPA RESPONSE: Current information indicates that for the reason
discussed in EPA's response to comment 6 above, there is no risk
associated with the use of Brodhead Creek either at the Site or
downstream of the Site.
3. A community member asked, if severe disturbance to the creek
bed were to occur from natural excavations or a flood, would that
allow dangerous levels of coal tar contaminants to enter Brodhead
Creek?
EPA RESPONSE: The possibility of a flood was considered during
the original remedial investigation and feasibility study
conducted for the Site. A worst case scenario of a 1,000 year
flood event was assumed. Computer modeling revealed that
approximately two feet of the creek bed would be eroded. Under
that scenario, there would not be a significant release of coal
tar contaminants to the Creek.
9. A community member asked if the Stroudsburg sewage treatment
plant (on the western boundary of the SifeeU,is impactecWby^ihe
Site.
EPA RESPONSE: No. The sewage treatment plant is not impacted by
the Site.
10. A community member asked if potential development upstream
4
AR302058
-------
would be restricted because of the Site.
EPA RESPONSE: EPA does not foresee that.any restrictions at the
Site will limit other activities upstream; i.e., there is no need
for restrictions upstream of the Site.
11. A community member asked who is bearing the cost of the
remedy for Operable Unit 1.
EPA RESPONSE: Pennsylvania Power and Light Company and Union Gas
Company are paying for the cleanup work.
12. A community member asked when EPA will make a final decision
on Operable Unit Two and notify the public.
EPA RESPONSE: EPA is hoping to make a decision on Operable Unit
Two as soon as possible. However, EPA wants to ensure that it
has considered all available information and evaluate public
comments prior to making a final decision. EPA will also consult
with the Commonwealth of Pennsylvania prior to finalizing its
decision. EPA will publish a public notice in the Pocono Record
when it has finalized its decision for Operable Unit Two of the
Brodhead Creek Site.
flR302059
------- |