United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/062
September 1988
SEPA
Superfund
Record of Decision
Aladdin Plating, PA
-------
!0272. 1ft1
. REPORT DOCUMENTATION j'l.""REPORT NO.
PAGE EPA/ROD/R03-88/062
12.
3. ReciDient's Accession. No.
.. Title .nd Subtitle
SUPERFUND RECORD OF DECISION
Aladdin plating, PA
First Remedial Action
7. Author( s)
5. ReDOrt O.te
09/27/88
-
I.
-- -
8. Performina Or,.nization ReDt. No.
9. Perfo""in, O,..nization Neme end Address
10. Project/Task/Work Unit No.
- --
---
---
11. Contrect(C) or Grant(G) No.
(C)
(G)
12. SDOnsorin, Or,enization Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
- -- ----.--------- ---
Agency
13. TYDe 0# ReDort & Period Covered
800/000
1..
15. Supplementery Notes
11. AI~.trect (Limit: 200 wordS) dd . 1. . . f 1 1.
The two-acre Ala 1n P at1ng slte 1S a ormer e ectrop at1ng facility located in Scott
and Abington Townships, Lackawanna County, pennsylvania, approximately 1.5 miles north
of the Tow.n of Chinchilla. The area surrounding the site is wooded, with 4 residences
within 100 yards and about 120 people living within a 0.25 mile radius. Approximately
11,000 people within 3 miles of the site use domestic and public ground water wells for
drinking water. Site runoff flows northwest toward Legget~s Creek, a principal
~.ributarY of Griffin pond Reservoir. Leggetts Creek and Griffin pond are sources of
upplemental drinking water for more than 100,000 people. The nearest residential well
is less than 1,500 feet from the site. Aladdin Plating conducted electroplating
operations from 1947 to 1982. Hazardous materials used in operations include sulphuric
acidr chromic acid, cyanide, chromiumr and other heavy metals. For 35 years,
electroplating waste effluents containing heavy metals and other contaminants were
discharged via a ditch and underground pipes to a shallow surface lagoon near the
electroplating building. A fire destroyed the facility and ended operations in 1982.
Three source areas of contamination have been identified: the site of the former
plating facility building, a buried trench (presumably the building's floor drain), and
the lagoon. In 1983, chromium was detected in onsite soils. Subsequent testing by EPA
(See Attached Sheet)
-
lke~¥~e"b tn~~ i ~i BPFriptors
Aladdin plating, PA
First Remedial Action
Contaminated Media: gWr soil
Key Contaminants: arsenic, chromium, lead
b. Identifiers/Open-Ended Terms
c. COSATI Field/GrauD
AveilebUlty Stetement
19. Security Class (This ReDort)
None
21. No. 0' Paaes
24
_._-- --
I
20. Security Cln. (This Pa.e)
None
22. Price
(See ANSI-Z39.18)
See Instruction. on Reverse
OPTIONAL FOR" 272 (4-77\
(Formerly NTIS-35)
OeD.rtment of Commerce
-------
EPA/ROD/R03-88/062
Aladdin Plating, PA
First Remedial Action
16.
ABSTRACT (continued)
in 1984 also identified lead and cyanide in onsite soils. In addition, ground water
samples from onsite monitoring wells showed significant levels of arsenic, cadmium,
chromium, and lead; all exceeded their respective MCLs. In March 1987, EPA performed
emergency response activities to remove significant immediate health threats. These
responses included fencing contaminated zones and removing drums and vats containing
hazardous wastes. This response action addresses only the remediation of the
contaminated soil onsite. The ground water contamination will be addressed in a
subsequent remedial action. The primary contaminants of concern affecting the soil and
ground water are arsenic, chromium, and lead.
The selected remedial action for this site includes: excavation and offsite
stabilization of approximately 12,000 yd3 of contaminated soil, with disposal of the
treated soil in an offsite landfill and replacement of the excavated soil with clean
fill. The estimated present worth cost for this remedial action is $4,461,000 with no
associated O&M costs.
-------
RECORD OF DECISION
Site Name and Location
Aladdin Plating" Superfund Site
Chinchilla, PA
Statement of Basis and purpose
This decision document presents the selected remedial action
for the Aladdin Plating Site, in Chinchilla, PA, developed in accord-
ance with the Comprehensive Environmental Response, Compensation
and Liability Act of 198~, as amended by the Superfund Amendments
and Reauthorization Act of 1986 and is consistent, to the extent
practicable, with the National Oil and Hazardous Substances
Contingency Plan.
This decision is based upon the contents of the administrative
record for the Aladdin Plating site. (Index attached)
The Commonwealth of pennsylvania concurs with the selected"
remedy.
Description of the Remedy
This initial operable unit addresses the source of the con-
tamination by remediation of the on-site contaminated soils. The
remedy addresses the principal threats at th~ site by removing the
Aladdin property as a source of future groundwater contamination
and reducing the risks associated with exposure to the contaminated
materials.
The major components of the selected source control remedy
include:
- Excavation and off-site treatment, via stabilization,
of approximately 12,~~~ cubic yards of contaminated soil.
Disposal of the treated soils in an appropriate off-site
landfill.
- Replacement of the excavated soil with clean fill
A supplemental remedial investigation and feasibility study
be prepared to identify the extent of, and future potential for,
groundwater contamination and to develop and evaluate appropriate
remedial alternatives.
will
-------
-2-
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to the remedial action,
and is cost-effective. This remedy satisfies the statutory prefer-
ence for remedies that employ treatment that reduces toxicity,
mobility or volume as a principal element and utilizes permanent
solutions and alternative treatment (or resource recovery) technol-
ogies to the maximum extent practicable. Because this remedy will
not result in hazardous substances remaining on-site above health-
based levels, the five year f~cility review will not apply to this
action.
O~fk~
Acting Regional Administrator.
i -:27-g
Date
-------
D JONES
HO"AEWEL~
STRESSED
VEGETATION
STRESSED VEGETATION
SURFACE STAINING
SURFACE /~--t-~i\:3001
STAINING /
I \ SURFACE
I FILLED \ WATER
~\\ IN' FLOW
~ I SURFACE --
IMPOUNDMENT
\ I
, I
" /
..... ./
----.---'*'"
MILROY D
HOME WELL
SITE SKETCH
ALADDIN PLATING,LACKAWANNA CO., PA.
(NO SCALE)
Site of
Former Plating
STAINED SOIL
ACCESS ROADI
DRIVEWAY
- WALKER -0
HOMEWELL
-------
I
~
I
'1
SCALE 1:24000
o
1 MilE
ALADDIN PLATING SITE LOCATION
SCOrf & ABINGTON TOWNSHIPS
LACKAWANNA COUNTY, PA
o
SOURCE DALTON &: SCRANTON USGS QUADRANGLE MAPS
.
IITI ~
-------
Summary of Remedial Alternative Selection
Aladdin Plating Site
Contaminated Soil Operable Unit
SITE LOCATION AND DESCRIPTION
The Aladdin Plating Site is located off of Layton Road approx-
imately 1.5 miles north of the town of Chinchilla in Scott and South
Abington Townships, Lackawanna County, Pennsylvania. Refer to Figure 1.
The former electroplating facility encompasses an approximately
two acre grass field which is surrounded by woods. The small building
which originally housed. the electroplating operation was located in the
northeastern corner of the site. (The remains of this building were
removed from the site in Spring 1987 as part of EPA activities.) A
marshy lagoon area that once received liquid wastes from plant oper-
ations is located to the west of the former electroplating building.
Currently, four residences are located within 100 yards of the former
facility and approximately 120 people live within a one-quarter mile
radius of the site. (See Figure 2)
The land to the north of the site is sparsely populated and hilly
and is used primarily for agricultural purposes. To the west of the
site (2-3 miles) are the towns of Clarks Green and Clarks Summit in
which a major concentration of the population in relation to the site
is located. South of the site is a range of forested mountains that
run in a northeastern direction.
SITE HISTORY
The Aladdin Plating facility is presently owned by Mr. Russell
Richards. Mr.' Richards operated an electroplating plant on the site
from 1947 to 1982. Electroplating is a method of coating metal with
rust-proof surfaces such as chrome or nickel. At the Aladdin plant
objects were plated with nickel, copper, and chromium through a process
that used sulfuric acid, chromic acid, cyanide, and water. During the
electroplating process, the water used to rinse the plated objects
became contaminated with metals and other electroplating solutions.
During the 35 years of operation, electroplating waste effluents were
discharged via a ditch to a shallow surface lagoon approximately 300
feet west of the electroplating building.
-------
- 2 -
An estimated 11,000 people within 3 miles of the site rely on
domestic and public ground-water supplies for drinking water. The
nearest residential well is within 1,500 feet of the site property.
Runoff from the site flows .northwest toward Leggetts Creek which is a
principal tributary of Griffin Pond. Griffin Pond, located about one
mile from the site in the Town of Chinchilla, is a drinking water
supply reservoir which is used to supplement the water supply for the
City of Scranton (population 88,000). Water from the Griffin Pond
intake also is SOld to the Keystone Water Company and National Util-
ities Company to supplement their supplies which serves approximately
13,000 people. The PennsYlvania Gas & Water Company also has two
water intakes along Leggetts Creek downstream of the site.
In 1974, fOllowing a routine inspection of the site, PennsYlvania
Department of Environmental Resources (PADER) officials cited the
company for violating the Pennsylvania Clean Streams Law and for
operating without a permit to treat industrial waste. Although PADER
ordered the owner to fill the lagoon, the company continued on-site
disposal via pipelines which ran from the electroplating building under-
ground to the lagoon area.
In the early part of 1982, a fire occurred at the facility which
virtually destroyed the electroplating building. Chemical analysis
performed by PADER in 1983 detected chromium in soil at several locations
near the building and lagoon. EPA chemical analysis performed in 1984.
also identified lead and cyanide in on-site soils in addition to
chromium.
The site was subject to periodic testing by PADER and EPA contrac-
tors from 1984 to 1987. The Aladdin Plating Site waK nominated for
inclusion on the National Priorities List (NFL) in January, 1987.
According to EPA site inspection reports, vats, along with over 20
drums and other miscellaneous containers containing approximately 1,500
gallons of acids and bases, were left unsecured and exposed to the
elements. EPA believed that the presence of these contaminants on site
posed a significant health threat to nearby residents and potentially
threatened local drinking water supplies. On February 24, 1987,
officials from EPA, the Center for Disease Control (CDC) , Agency of
Toxic Substances and Disease Registry (ATSDR), and PADER visited the
site to determine what actions would be taken to eliminate the risk of .
direct human contact with the hazardous wastes found on site. As a
result of this visit, EPA began emergency response activities on March
4, 1987, to reduce the chance of human contact with the site contamin- .
ation. EPA secured the site's most contaminated zones with fencing and
sampled vats and drums remaining on site. EPA also began packing
decaying drums into transportation containers and demolishing and
removing the building rubble. On March 22, 1987, two drums containing
solid cyanide were shipped off site, under pOlice escort, to Tonelson
Industries in Detroit, Michigan, for treatment and disposal.
-------
- 3 -
Residential well sampling also was conducted in early 1987. EPA
began testing the wells of residents living closest to the site and in
this and two subsequent sampling actions over the following months
gathered a total of 100 water samples from residential wells in the
surrounding area. Based on the results of these tests, EPA informed
the residents that no contamination was found. In addition, EPA
conducted surface-water sampling of Griffin Pond in March 1987, but
found no contamination in the samples.
The USEPA Environmental Response Team/Response Engineering
Analytical Contractor (ERT/REAC) performed a hydrogeological investi-
gation of the site which was conducted in phases: (1) a systematic
shallow soil sampling program coupled with geophysical surveying,
and (2) geologic and hydrogeologic investigations including well
installation, sediment core logging and sampling, and chemical and
hydraulic testing of the saturated zone. EPA's Technical Assistance
Team assisted in the ground water survey by collecting residential
well samples.
Site stabilization and the extent of contamination survey were
conducted from March through December of 1987. Additional soil sampling
was conducted in March 1988.
COMMUNITY RELATIONS HISTORY
Community awareness of the Aladdin Plating operation has been
historically low. During initial interviews, most citizens acknow-
ledged that they were aware of the plating facility but h~d not
associated it with hazardous waste problems. At the, time of the
1982 fire which destroyed the plant, most residents were primarily
concerned about the threat posed by the fire, and were not aware
that toxic chemicals were stored in the building. Recently, concern
has been aroused as a result of the January.1987 news media coverage
of the nomination of the site to the NP~. Specifically, residents
became concerned about the safety of their drinking water after they
learned from press reports that the site COUld pose a health risk
as a source of ground-water contamination.
Two public meetings have been held. On March 23, 1987, EPA held
a meeting to discuss events at the site and to answer questions from
residents. In addition to notifying residents that initial well
samples showed no chemical contamination, EPA outlined additional
steps that were to be taken at that time to reduce the chance of
human contact with the wastes at the site. On August 16, 1988, EPA
held a meeting to present the Proposed Plan for the remedial
activities at the site.
-------
- 4 -
SCOPE OF OPERABLE UNIT
This response action is a source of contamination operable unit
and is consistent with Section 300.68 (c) of the National Contingency
Plan (NCP). This initial source of contamination operable unit is
being implemented to protect public health and the environment by
preventing direct contact with contaminated soils and controlling
migration of contamination into the groundwater. The operable unit
addresses known areas of surface and subsurface contamination in the
site soils. The USEPA and PADER feel that direct contact with contami-
nated soils and migration of contamination into the ground water are
the major concerns posed by this site. This operable unit was initiated
to deal with these concerns. It is fully consistent with all future
site work.
A ground water modeling study conducted by ERT determined that
the ground water under the site is not moving quickly, if at all,
from under the site and, therefore, does not pose a risk which needs
to be addressed as part of the present operable unit. A future
RI/FS is planned to determine the need for and type of ground water
remediation. The result of this study, and its recommendations,
will be described in a future operable unit Record of Decision.
SITE CHARACTERISTICS
In February, 1988, EPA's (ERT/REAC) completed a report entitled
"Hydrologic Investigation - Aladdin Plating Site" which summarized
all ground water and soil analytical data that had been collected by
the EPA Emergency Response Contractor, EPA's Technical Assistance
Team and ERT/REAC during the previous year. Non-carcinogenic risks
from the contaminated ground water and exposed soil locations on the
site were calculated based on present site conditions. These risks
are determined by comparing potential exposure of site visitors to
contaminant specific reference doses. The reference dose is an
estimate of the lowest exposure level that would not be expected to
cause adverse effects when exposure occurs.
The analytical results from the investigation can be found in
the report "Hydrogeological Investigations - Aladdin Plating Site,
Scott and South Abington Townships, Lackawanna County, Pennsylvania -
Final Draft Report", February 1, 1988. The risk assessment is detailed
in the memo " Aladdin Plating Site - Hydrogeological Investigations",
Dawn A. loven, Toxicologist to Richard Watman, RPM, dated September 8,
1988.
-------
- 5 -
Soil Contamination
The initial phase of site work identified several source areas
of contamination: the site of the former plating facility structure,
a buried trench (presumably the building floor drain) and an abandoned
lagoon. These contaminated areas stretch from east to west in a
relatively narrow band across the center of the site, with natural
surface drainage extending shallow contamination to the west and
northwest of the abandoned lagoon area. The highest concentration of
chromium in the shallow subsurface (6" - 12") was found to occur in
the area of the floor drain discharge located between the building
and lagoon areas.
In a worst case scenario, assuring that all chromium on-site is
present in the hexavalent form and that a 16 kg child ingests 200 mg
of the most contaminated on-site soils each day, the calculated dose
to that child exceeds the reference dose. for hexavalent chromium by
slightly more than an order of magnitude.
Ground Water Contamination
The site appears to be situated atop of a buried paleo-valley
unit in a sandstone and shale bedrock that has been filled with
pleistocene glacial deposits. Locally, these deposits are divided
into two types: those deposited by melting ice sheets (tills) and
those deposited by meltwater action (outwash). Under the site, the
tills and outwash deposits appear as alternating layers. The outwash
sands and gravels can be subdivided into 3 units based on their
relative position and permeability: shallow, upper and lower.
Chemical analysis of sediment cores obtained at depth during the
drilling of shallow-on-site wells indicated that, while the vast
majority of chromium was bound in soils near the surface, vertical
migration had occurred through the vadose (unsaturated) zone in the
vicinity of the presumed floor drain discharge. Consequently, later
well sampling indicated that the shallow water table aquifer was
contaminated within and hydraulically down gradient of this area.
In addition, several semi-permeable sediment lenses within the
overburden material have been contaminated. This vertical migration
has occurred in spite of the very low permeability observed in most
of the site sediments, and appears to be the result of the strong
downward head gradient evidenced at the site,. coupled with the long
time frame of operation at the plating facility (35 years).
-------
- 6 -
Elevated chromium concentrations were noted in several samples
from a bedrock contact well located near the center of the northern
property boundary. Contamination in this well is potentially signifi-
cant because it provides a possible route for contamination of bedrock
fracture systems from which local residents obtain their water supply.
The fact that contamination is not observed in two on-site wells that
intercept the shallow bedrock fracture system, and sampling of neigh-
boring residential wells does not indicate a pattern of off-site
contaminant migration, suggests that deep bedrock contamination has
not occurred to date.
Ground water samples collected from on-site monitoring wells
revealed significant levels of arsenic, cadmium, chromium and lead.
All of these contaminants were found at levels above their respective
Maximum Contaminant Levels (MCLs).
ALTERNATIVES EVALUATION
The major objective of the Engineering Evaluation/Cost Analysis
(EE/CA) was to evaluate the need for an initial source control measure
and possible actions which could be undertaken. As discussed above,
this operable unit will not address ground water remediation. This
will be addressed in the subsequent RI/FS. Due to the limited scope
of the EE/CA which examined the threat to public health and the
environment posed by the contaminated soils, alternatives were
formulated to achieve the following goals:
- Minimize the potential for direct contact with the contami-
nation.
Minimize the potential for migration of surface contamination
into the ground water.
- Provide measures that will be consistent with the final site
remedy.
A comprehensive list of appropriate remedial technologies was
identified for source control. These technologies were screened based
on the characteristics of the site and the characteristics of the
contaminants. The technologies which survived the initial screening
were further screened based on effectiveness, implementability and
cost. Cost was only used between alternative technologies providing
similar degrees of protection and treatment.
Technologies which satisfied the screening requirements were
refined to form remedial action alternatives. The five alternatives
developed are detailed below. With the exception of the no action
alternative, all are based on removal and/or treatment of 12000 cubic
yards of contaminated soil.
-------
- 7 -
Alternative I - No Action
The National Contingency Plan (NCP) requires that the "no action"
alternative be considered through the detailed analysis. Under this
alternative, EPA would take no further action at the site to control
the sources of contamination.
The no action alternative does not meet EPA's goal of providing
a permanent cleanup solution, nor does it comply with current
statutory requirements, because site contamination would remain in
place. It also does not address the public health and environmental
concerns raised previously. There are no costs associated with
implementing this alternative.
Alternative 2 - On-site extraction
This alternative would involve excavation of the soil and
treating it with one or more chemicals and wash solutions to remove
metals. The wash solution (containing the extracted contaminants) .
is further treated to remove the contaminants and the clean solution
may be recycled to treat the soil or discharged. The number of
washes, soil/solution ratios, and other process requirements are
determined by site-specific conditions such as soil type, metals
present, metals species, etc.
The treated soil may require disposal at a landfill, depending
on the residual metal concentrations in the soil. The spent extrac-
tion solution containing metals must be treated prior to discharge.
The metals may be recovered or concentrated for offsite disposal.
Concentration by chemical precipitation may result ill hazardous
sludges being produced, which in turn must be disposed of properly.
. The total estimated cost for implementing this alternative is
$5,052,000.. This assumes that the sludge from treating the metal
extraction solution is the only materia~ that must be disposed of
offsite. There are no post-remedial activities or costs.
This alternative would permanently reduce the volume, mobility
and toxicity of contaminated materials at the site to levels which
meet public health standards. It will not be necessary to excavate
and transport large volumes of soils, but the sludge left over from
the treatment process will have to be disposeq of in an approved
hazardous waste facility.
Alternative 3 - Off-Site Stabilization
This process involves excavation of the contaminated soil and
replacement with clean fill. The contaminated soil will be
shipment off-site where it would be chemically reacted with an
admixture. The material becomes a solidified mass and there is a
-------
- 8 -
reduction in the amount of metals that can be leached. The material
becomes a concrete-like solid which is stable over the long-term.
Leachate tests have been conducted on these materials and they
have shown that the leachate contained metal concentrations below
EPA's EP toxicity limits. The concrete-like product with the immobi-
lized metals will be disposed of, off-site, in an appropriate manner
At least one commercially available stabilization process produces
a stabilized product that can be disposed of as a non-hazardous
waste.
The total estimated cost for implementing this alternative is
$4,461,0.00. There are no post-remedial activities or costs.
This alternative would permanently reduce the volume, mobility
and toxicity of contaminated materials on site to levels which meet
public health standards. In addition, depending on the treatment
process, no hazardous sludges or other hazardous by-products will
be produced which would require subsequent disposal.
Alternative 4 - Microencapsulation
In this process, contaminant particles in solid or liquid waste
are immobilized by encapsulation materials which create small scale
encapsulation cells. Metals contaminated soils would be excavated
and mixed with a polymeric substance in an extruder to form a produc
in which the contaminants are encased in a polymeric matrix which is
dispersed throughout the soil. Immobilizing materials (which form the
matrix) may include polymers like polyethylene and other thermoplastics
Very stable products are produced which affo-rd strong resistance
to long term chemical and mechanical stresses. Metals are held in the
additive matrix resulting in their long-term immobilization.
Two commercially available treatment methods produce microencap-
sulated waste products which can be disposed of in a non-hazardous
facility.
The total estimated cost for implementing this alternative is
$6.0 million. There are no post-remedial costs or actions.
This alternative would provide desired levels of protection of
public health by permanently removing the source of contamination from
the site and the mobility of the hazardous materials removed would be
reduced to the point that they could be disposed of in a non-hazardous
facility.
-------
- 9 -
Alternative 5 - Excavation and Off-site Disposal
This alternative would involve excavating the contaminated soils
and hauling them to a RCRA permitted hazardous waste landfill. The
excavated area would be regraded and backfilled with clean soil.
The total estimated cost for implementing this alternative is
$2,730,000 capital costs. There are no post-remedial activities or
costs.
This alternative would provide desired levels of protection of
public health by removing the source of contamination from the site.
It does not, however, satisfy EPA's pOlicy giving preference to
remedies using permanent solutions or alternative treatment methods.
In addition, disposal of waste of this type without prior treatment
has been prohibited as of August 8, 1988 by 42 U.S.C. 6924 (g) (6)
unless EPA can certify that no treatment capacity is available.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The five alternatives assembled were evaluated based on the following
nine criteria:
- Overall protection of human health and the environment;
- Compliance with all federal and state applicable or relevant
and appropriate requirements (ARARs);
- Reduction of toxicity, mobility or volume;
- Short term effectiveness;
Long term effectivenessi
- ImplementabilitYi
- Cost;
Communi ty acceptance; and
- State acceptance.
A summary of the reiative performance of the alternatives with respect
to each of the nine criteria is provided in this section.
Overall Protection
All of the alternatives, with the exception of the no action
alternative, would provide adequate protection of human health and the
environment by eliminating, controlling or reducing risk through treat-
ment and/or permitted disposal. The preferred alternative would
eliminate the direct contact threat and prevent future ground water
contamination while creating no hazardous by-products or residues.
-------
- 10 -
Lonq-Term Effectiveness and Permanence
With the exception of the no-action alternative, all of the
alternatives would provide adequate protection of human health and
the environment by eliminating, controlling or reducing risk through
treatment and/or permitted disposal. The preferred alternative would
also treat the contaminated soils to the point where they could be
disposed of as non-hazardous waste.
ComDliance with ARAR's
All alternatives except the no action alternative would comply
with applicable or relevant and appropriate requirements Of Federal and
State environmental laws.
. Reduction of Toxicitv. Mobilitv. or Volume of Contaminants
Three of the 5 alternatives would treat the waste. Alternative
2 would produce a contaminated sludge, while alternatives 3 and 4
would not produce any hazardous by-product or sludge.
Short term effectiveness
Alternatives 3, 4 and 5 would remove the contaminated soils fro~
the site within several months. There would be some small risk of
exposure to the public from the excavation and removal operations.
Routine dust and erosion control measures implemented during remediation
would minimize any public exposure. Air monitoring will be conducted
to assure that the health of the local residents is protected. Alter-
native 2 would leave contaminated soils stockpiled on-site until the
treatment is complete.
ImDlementability
Alternatives 2, 3, 4, and 5 have all been proven either in full
scale uses or in pilot studies.
~
Alternative I has no costs. The construction costs for each of
the remaining alternatives are estimated to be as follows: Alternative
2: $5,052,000; Alternative 3: $4,461,000; Alternative 4: $6,000,000;
Alternative 5: $2,730,000. In each case, the present worth costs are
identical to the above capital costs.
-------
- 11 -
Communi tv Acceptance
Two public meetings have been held for the site.. The first
was held in March, 1987, to announce the mobilization of EPA's
Emergency Response Team on the site and to discuss the removal plans
and address citizen questions. The second meeting was held in August,
1988, to discuss remedial alternatives, including EPA's preferred
alternative.
Overall, the general attitude of the residents and local
officials is positive. The only comments from the local residents
have concerned potential truck traffic and air pollution during
excavation operations.
State Acce?tance
The Commonwealth of Pennsylvania, through the PA Department of
Environmental Resources (DER), concurs with the selected remedy.
SELECTED ALTERNATIVE
After careful consideration of the proposed cleanup sOlutions,
EPA's selected alternative for addressing the contaminated soils is
alternative 3: Stabilization. Alternative 3 would permanently
reduce the mobility and toxicity of the contaminated materials at .
the site to levels which meet public health and environmental standards,
while not creating any hazardous by-products or residues which would
have to properly disposed of. Soil contamination levels will be
monitored during cleanup to assure that all contamination, including
off-site drainage, is addressed.
Clean-up Levels
This initial source-control operable unit is being implemented
to eliminate the threat of direct contact with contaminated soils
to persons walking on-site as well as to reduce the potential for
migration of the contamination to the groundwater below the site.
To 'accomplish these aims, contaminated soils will be removed down to
a depth where the remaining chromium contamination is 50 ppm or
less, and will be replaced with clean soil. It is anticipated that
12000 cubic yards of soil will need to be removed in order to meet
this goal. Chromium is the major contributor to risk at the site
and the remedial activity described above will be protective of
human health and the environment. ERT calculations show that future
-------
- 12 -
impact on the ground water resulting from this remaining soil
contamination will be at levels below the MCLs cited above.
Operation and Maintenance
There is no annual operation and maintenance (O&M)
activity associated with the selected alternative.
STATUTORY DETERMINATIONS
The U.S. EPA and PADER believe that this remedy will
satisfy the statutory requirements of providing protection of
human health and the environment, attaining applicable or
relevant and appropriate requirements and other environmental
statues, will be cost~effective, will utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practiCable, and will
satisfy the preference for treatment as a principal element.
Protection of Human Health and the Environment
The selected remedy provides adequate protection
human health and the environment by preventing direct
with contaminated soils an~ reducing future migration
contamination into the groundwater.
of
contact
of
Attainment of Applicable or Relevant and Appropriate
Requirements (ARARs)
This remedy will comply with all ARARs.
ARARs are listed in Table I.
Significant
Cost-Effectiveness
This alternative affords a high degree of overall effec-
tiveness in not only protecting any future site visitor from
direct contact with contaminated soils, but also in reducing
future contamination migrating to the groundwater to levels
below present MCLs. The U.S. EPA believes that the costs of
the selected remedy are proportionate to the overall effec-
tiveness it affords such that it represents a reasonable
value for the money.
-------
TABLE I
Applicable or Relevant and Appropriate Requirements
Aladdin Plating Site
Applicable Federal Requirements
OVERVIBf
1. Hazardous Waste Requirements
(RCRA Subtitle, 40 CFR
Part 264)
Resource Conservation and Recovery
Act (RCRA) of 1976 (Amended 1984)
governs the generation,
transportation, storage, and dispose
of hazardous wastes. RCRA 40 CFR
Part 264 standards are used for
actions including offsice hauling
and disposal of hazardous wastes,
onsite capping and landfilling,
and groundwater monitoring.
2. Safe Drinking Water Act
-Maximum Contaminant Levels
The Safe Drinking Water Act
promulgated National Primary Prinking
Water Standard Maximum Contaminant
Levels (MCLs). MCLs are enforceable
standard* for contaminants in public
drinking water supply system*. They
not only consider health factors,
but also the economic and technical
feasibility of removing a contaminant
from a water supply system.
3. OSHA requirements (29 CFR,
Parts 1910, 1926, and 1904)
OSHA regulations provide occupational
safety and health requirements
applicable to workers engaged in
onsite field activities.
4. DOT Rules Hazardous Materials
Transport (49 CFR, Parts 107,
171. 1-171.500)
DOT regulates the transport of
hazardous waste materials including
packaging, shipper equipment, and
placarding. These requirements are
considered applicable to any vast*
shipped offsite for laboratory
analysis, treatment, or disposal. '
Applicable Stat4 Reouirements
OVERVIEW
1. Pennsylvania Solid Waste
Disposal Regulations, PA Code
Title 25, Chapter 75,
Subehapter 0
Governs the generation,
transportation, storage, and
disposal of hazardous wastes.
-------
- 13 -
Utilization of Permanent Solutions and Alternative Treatment
Technoloqies to the Maximum Extent Practicable.
Thetl.S. EPA beiieve~ this remedy is the most appropriate
solution for controlling the source of contamination at the
site. As the contaminated soil will be excavated and rendered
permanently non-hazardous at an off-site facility, this
remedy represents the maximum extent to which permanent
solutions and treatment can be utilized.
Preference for Treatment as a Principal Element
The statutory preference for treatment is satisfied as
the selected remedy calls for removal and off-site treatment
of the contaminated soils.
-------
-3-
III.
SUItIWlY OF KAJOR COIKENTS AND EPA RESPONSES
EPA invited public comment on the Proposed Plan for the Aladdin Plating
Superfund site and other site-related information from August 16, 1988 through
September 14, 1988. On the first day of the public comment period, EPA held a
public meeting at the Justus Fire Hall in Clark Summit, Pennsylvania to
discuss the remedial alternatives presented in the Proposed Plan with local
officials and residents. EPA representatives in attendance at the meeting
included:
Thomas C. Voltaggio - EPA Superfund Branch Chief
Nanci Sinclair - EPA Community Relations Coordinator
Richard Watman - EPA Remedial Project Manager (RPM)
Frances Burns - Previous EPA RPM
Edward Martin Powell - EPA On-Scene Coordinator (OSC)
(CRC)
The meeting was opened at 8:15 p.m. by the EPA Community Relations
Coordinator (CRC) for the Aladdin site, Nanci Sinclair, who explained that the
purpose of the meeting was to discuss remedial alternatives for the site and
to hear the public's responses to them. She pointed out that copies of the
EE/CA Report had been deposited in the information repositories for Scott and
South Abington Townships and that a fact sheet summarizing the alternatives
was available at the meeting. The EPA On-Scene Coordinator for the site,
Marty Powell, reviewed emergency removal activities that have 'been completed
by EPA, and the EPA Remedial Project Manager (RPM), Rich Watman, described the
remedial alternatives evaluated in the EE/CA Report and EPA's preferred
alternative. The meeting concluded with a question-and-answer period.
The public comments summarized below are organized according to the
following general subject areas: (a) human health and safety; (b) nature and
extent of contamination; (c) groundwater issues; (d) alternative remedies; (e)
site sampling; (f) post-cleanup status of the site; and (g) other comments.
These comments include those voiced at the public meeting or submitted to EPA
in writing. Three written comments have been received by EPA, all of which
were generally supportive of EPA's work at the Aladdin site. EPA will take
both verbal and written comments into consideration in determining the best
remedial alternative for addressing contamination at the Aladdin site. The
selection of this alternative will be outlined by EPA in a formal Record of
Decision (ROD). The ROD is typically signed shortly after the close of the
public comment period.
A.
IIU88D Health and Safet;y
Co88ent: Several residents asked what precautions EPA would use to protect
residents and workers from dust, fumes, and other means of exposure to
contaminants during remedial activities.
-------
-4-
EPA Response: The spread of airborne contaminants will be prevented by
keeping the work area damp with water carried on a truck. Workers will be
protected by measures at least as. stri.::~ent as those required by federal
regulations. . Air sampling and monitoring stations on the site and around its
perimeter will provide protection for both workers and residents. Operations
will be shut down if contaminant levels are above background readings, well
before standards are exceeded.
Before the remedial work begins, EPA will develop a health and safety plan
to govern this phase of the cleanup. At that time, EPA will hold another
public meeting to explain the contents ~f the plan and discuss any remaining
health and safety concerns ,the community may have.
Co88ent: One resident sugges~ed that r. monitoring device be placed at the
mobile home located on the site, noting that one of the two occupants of the
trailer is a child. A written comment also requested that special measures be
taken to control airborne contamination in the vicinity of this mobile home,
pointing out that the trailer is situated 20-50 feet from removal activities
and that the child living in the trailer often plays in the yard.
IPA Response: EPA plans to locate monitoring devices at the residences
nearest the site, and acknowledges that the trailer also may be an appropriate
location.
Co88ent: One written comment requested that EPA take safety measures to
protect neighborhood children from truck traffic associated with the site.
IPA Response: EPA noted that the cleanup will involve a $ignificant amount ot
truck traffic -- perhaps twenty-to-thirty trucks per day, six days a week
traveling to and from the site, -- which may disrupt the neighborhood. EPA
and contractors working on site will cooperate with the neighborhood as much
as possible to minimize disturbances. EPA will coordinate with the town's
needs regarding timing of truck traffic (e.g., work around school bus
schedules). Workers are constrained, however, to work only during daylight
hours.
B.
..bae and btent of Cont--fWUlt1on
Co88ent: Residents asked about the depth of soil contamination and the volume
of contaminated soil needing removal.
IPA Response: The depth of soil contamination varies; in the area of the
lagoons, it is approximately six feet deep. Current estimates indicate that
approximately twelve thousand cubic yards of soil require removal.
Co88ent: A resident asked if EPA had determined where the perimeter of the
lagoon area lies, and whether or not cleanup activities would occur on her
land.
-------
,I'l'"
-5-
EPA Response: EPA informed the resident that the monitoring well on her land
does reveal contamination, but that further sampling is planned in the lagoon
drainage area to determine the extent of contamination.
c.
Groundwater Issues
Co88ent: One resident asked how EPA plans to clean up groundwater
contamination.
EPA Response: EPA will be conducting further investigations to determine
whether or not cleaning up the groundwater contamination associated with the
A1addin site will be necessary. When EPA has identified alternatives for
addressing groundwater contamination, another public meeting will be held to
discuss the proposed alternatives with the community.
Co.8ent: One resident asked when EPA sampled the off-site/perimeter
groundwater wells and whether the results of the samples had differed from
previous samples.
ErA Response: These wells were sampled in July 1987 and Kay 1988. The
results of the two sampling effdrts were comparable. Although there was a
slight fluctuation in the results, EPA attributes this to the fact that the
samples were taken in different seasons and analyzed by different labs.
Co.8ent: Two meeting participants expressed concern about the frequency and
duration of EPA's groundwater monitoring activities, indicating that they
would like to see frequent and continuing monitoring. One person urged EPA to
sample wells on a continual basis, particularly during site disturbance
associated with cleanup activities and after heavy rains. Two residents
submitted written requests for additional sampling of their well water during
site. excavation.
ErA Response: EPA has completed one round' of sampling, and does intend to
conduct an additional round during site excavation. The data obtained to date
indicates that the groundwater contamination is not moving toward residences
quickly, if at all. For this reason, EPA does not consider it urgent to
sample the groundwater again soon. No decisions have been made about how far
into the future monitoring will continue.
D.
Alternative v-dies
Co88ent: One resident asked for clarification about the difference between
Alternatives 3 and 5. He asked whether both involved removal of contaminated
materials and off-site treatment. He also asked if the treatment called for
under Alternative 3 would delay removal of contaminated soils, and suggested
that under Alternative 5, treatment could be done off site after all waste had
. been removed and replaced with clean topsoil, thereby expediting removal.
EPA Response:
EPA verified that plans for excavating and removing wastes from
-------
~.:';",,;..~.,.~,
-6-
the site are the same under Alternatives 3 and 5; however, plans for treatment
differ. Alternative 3 calls for treating the waste to render it non-
hazardous, while Alternative 5 does not. Under Alternative 3, treatment
capacity may be a constraint because at this time EPA knows of only one
appropriate treatment facility, and such facilities can only accept a certain
number of trucks per day.
Alternative 5 would require a variance of new statutory requirements
because it calls for disposal of untreated waste in a landfill. Congress
recently passed legislation prohibiting disposal of hazardous waste in
landfills unless it has been treated first. Although variances are possiole
if no' treatment facility is available, EPA would prefer not to, use that
option.
Co88ent: Two meeting participants and one written comment expressed concern
about the quality of the fill that would be brought in to replace excavated
soil under Alternative 3. One resident wanted EPA to certify in writing that
contaminated materials would not be returned to the site. Another resident
wanted to know if the fill might be soil that had been excavated from another
hazardous waste site and then treated and tested. The written comment
expressed reservations about the. fact that the EE/CA Report did not specify
that stabilization would take place off-site, that excavated materials would
not be returned to the site, and that fill would consist of uncontaminated
soiL
ErA Kespoase: EPA indicated tbat the ROD would state in writing that
excavated materials would not be brought back to the site, that the
stabilizing treatment would occur off-site, and that the fill material would
be clean fill. The EE/CA Report contains only suggested remedies, while the
ROD documents the official remedy and carries the weight of law.
I.
Site S-l hI,
Con nt: Two residents expressed concern about possible contamination of
drinking water supplies in Griffin Pond, whieh constitutes a portion of the
public water supply for the City of Scranton.
ErA Iespoaae: EPA sampled Griffin Pond during the emergency response
conducted in the spring of 1987. Although the pond was one of the most likely
areas to receive run-off from the site, sampling results revealed no
detectable contamination. EPA does intend to sample the pond again in the
future.
Co88ent: A written comment indicated a local resident's belief that soil
samples taken by EPA in 1987 had been lost, and requested repeat sampling.
ErA Response: Results of all soil samples are available for review in the
Administrative Record maintained by EPA. If additional soil samples need to
be taken, EPA will do so before site excavation begins.
-------
-7-
F.
Post-Cle8DUD Status of the Site
Co88ent:
A resident asked how the site would be categorized after cleanup.
EPA Response: EPA explained that after the cleanup, the site probably will be
"delisted," which is the reverse of the listing process. As part of the
delisting process, an account of site cleanup activities will be published in
the Federal Register, along with a statement from EPA that the site is clean.
Following a public comment period, the site is then removed from the National
Priorities List. This will not occur, however, until EPA has cleaned up the
groundwater contamination or determined that groundwater remediation is not
necessary. Further investigation of the groundwater is planned following the
removal of soil contaminants.
Co88ent: One meeting participant and two written comments requested that EPA
return the site to its original contours following the cleanup. The meeting
participant was particularly concerned about the northwest'corner of the site,
noting an unusually high degree of runoff from that area after a recent storm.
EPA Response:
EPA does intend t~ re-contour the site.
G.
Other
ec-ent: Several residents expressed concern about how long it will take to
remove contaminants from the site.
EPA Response: EPA expects to begin the removal in late September or October
1988. Actual cleanup may not start until October 1988 because the public
comment period is open until September 14 1988, and any comments submitted
will be considered in cleanup decisions. In addition, there is an
administrative complication with obtaining funds for the removal.
Once the ROD is signed and funds are in place, it will take several weeks
for EPA contractors to set up equipment, about twelve weeks to excavate the
contaminated soil, and a few more weeks to replace the excavated area with
clean fill. Work will continue until snow stops the trucks or frozen ground
stops the excavation, and will resume in the spring of 1989. Work will
continue, however, until the job has been completed. .
ec-ent: A resident suggested that EPA bring in clean fill as excavation
progresses, rather than wait until all contaminants have been removed.
EPA Response: EPA does plan to bring in clean fill as work progresses to the
extent possible. A road will be constructed through the area where the plant
was in order to get the trucks off the town's roads. Once this area has been
dug up and staged below, fill will be brought in. The work will be undertaken
in cells to avoid contamination of clean fill.
-------
~
.~~u
~"~~
.."'~.~~..
" ~.-=~ 1.',--- 0}
-........,~
.' 1"'''~I!R<::''"~''t'
-8-
C088eut: A resident requested that the next meeting be held in the fire hall
located in South Abington Township.
EPA Response: EPA agreed to hold the next meeting in South Abington as long
as a large enough meeting space was available. There will be a meeting after
the signing of the ROD is announced to discuss logistical information and the
safety plan. In addition, another meeting will be held in several months to
discuss the groundwater study.
IV.
COBCLUSIOR
EPA is in the process of selecting a remedial approach for the Aladdin
Plating Superfund site. . The public comments summarized above are being taken
into consideration in making this decision. The selection of an alternative
will be formalized in the ROD, which is signed by EPA's Regional
Administrator. EPA will make an official announcement when this decision has
been made.
------- |