United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/063
September 1988
3EPA
Superfund
Record of Decision
Palmerton Zinc Pile, PA
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........... . ~ I I
.R.EPORT DOCUMENTATION 11. REPORT HO.
R, - PAGE EPA/ROD/R03-88/063
< 4. Titl. and Subtltl.
ItSUPERFUND RECORD OF DECISION
I. Palmerton Zinc, PA '. .
con4 Remedial Action
,. Author(s)
I~
3. Recipient's Accession No.
5. Repart O.te
06/29/88
&.
- .
. 9. Pe"orm'n. O,.anization Hame and Addr..,
a. Performin. Or.aniution Rept. No. - _. ~
I
I
10. Project/Ta'k/Work Unit Ho.
- - -~ --
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11. Contract(C) or Grant(G) No.
(C)
(G)
1~ Spansorin. Or.aniution H.me and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
--. -
13. Type 0' Repart & Period Coverees
_.-
800/000
14.
15. Supplementary Hot..
I&. Ab,trect (Umit: 200 -rdl)
The Palmerton Zinc site is composed of two locations in the Borough of palmerton,
Carbon county, Pennsylvania. Smelting operations have been conducted at two locations,
a west smelter and an east smelter, flanking the Town of palmerton, which is located at
the confluence of the Lehign River and Aquashicola Creek. Approximately 7,000 residents
live in palmerton, many of whom work at the smelting facility. Land use in the area is
industrial, residential, and agricultural. The drainage pattern in the site area is
)ward Aquashicola creek, designated a warm water fishery by th~ State of pennsylvania,
.nich flows into Lehigh River. . Smelting operations were conducted in the west plant
from 1898 to 1987, and in the east plant from 1911 to present. The site has had three
owners, including the current operator, Zinc Corporation of America, and historically
has produced zinc and other metals for a variety of products. Primary smelting of
concentrated zinc sulfide ores, conducted until December 1980, resulted in the emission
of large quantities of zinc, lead, cadmium, and suI fer dioxide. This air pollution
caused defoliation of over 2,000 acres of vegetation in the vicinity of the east
smelter. Between 1898 and 1987 process residue and other plant wastes (as well as
municipal. waste until 1970) were disposed of on Cinder Bank, a 2.5-mile, 2,000-acre
waste pile located behind the east plant at the base of the Blue Mountains. Cinder Bank
(See Attached Sheet)
17R~~~~nto'l.'It~.C i.S. p~rtptors,
palmerton Zinc, PA
Second Remedial Action
contaminated Media: gw, sw, sediments
Key Contaminants: cadmium, lead, zinc
b. Identlfi.rs/Open.Ended Terms
.
.
<:. COSATI Fleld/GnlUp
,v.lI.bllity St.tement
19. Security Class (This Report)
None
21. No. 0' Pac..
60
--- --
20. Security Class (This Pa.e)
None
22. Price
(s.. AHSI-139.18)
5.. Instructions on Reve,.e
O",IOHAL FORW 272 (.-77)
(Formerly NTI5-3S)
Department 0' Commerce
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EPA/ROD/R03-88/063
Palmerton Zinc, PA
Second Remedial Action
16.
ABSTRACT (continued)
contains approximately 27.5 million tons of leachable metals including lead, zinc, and
cadmium, as well as carbonaceous material. Large blocks of residue crack and break off,
allowing rapid infiltration of runoff during periods of rain and snow melt, resulting in
contaminated leachate perc.olating down to the ground water and seeping out of Cinder
Bank. This remedial action addresses Cinder Bank. Additional areas of contamination as
well as ground water and surface water contamination will be addressed in subsequent
~emedial actions. The prlmary contaminants of concern affecting the sediments, ground
water, and surface water are metals including cadmium, lead and zinc.
The selected remedial action for this site includes: slope modification, capping, and
application of a vegetative cover on Cinder Bank; construction of surface water
diversion channels; surface water and leachate collection and treatment using
lime-activated filtration lagoons and/or constructed wetlands; implementation of an
inspection, monitoring, and maintenance plan; and wetlands restoration measures, if
necessary. The estimated present worth cost for this remedial action will be in excess
of $2,861,800; however, the exact figure will not be known until agreement is reached on
the extent of remediation during remedial design.
\
~':..:..l.i~
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'~
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Palmerton Zinc Superfund Site - Cinder Bank Operable Unit
Borouqh of Palmerton, Carbon County, Pennsylvania
STATEMENT OF PURPOSE
This decision document represents the selected interim
remedial action for this site developed in accordance with
the Comprehensive Environnmental Response, Compensation and
Liability Act of 1983, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (CERCLA), 42 U.S.C. Secti~n
9631 et seq., and to the extent practicable, the National
Contingency Plan, 43 C.F.R. Part 333.
STATEMENT OF BASIS
This decision is based upon ,and documented in the contents
of the administrative record. The attached index identifies
the items which comprise the administrative record. The
Commonwealth of Pennsylvania has r~viewed, commented and
concurred with this Record of Decision.
DESCRIP~ION OF THE SELECTED REMEDY
This innovative interim remedy focuses on the second of
four separate operable units at the Palmerton Zinc Smelter
site. The first operable unit, Blue Mountain, is in the
remedial design phase while the remaining two operable units,
the Valley soil contamination and the Area-Wide Groundwater
and Surface Water Contamination, are both in the RI/FS phase.
The selected site interim remedy does ensure compliance
with all ARARs and will be consistent, to the extent practicable,
with those specified herein. The implementation of the selected
capping and vegetation project will provide leachate reduction
by way of influencing precipitation infiltration (in combination
with contouring of slopes) and eliminate particle erosion
thereby providing protection to the environment.
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The selected interim remedy for the Cinder Bank consists
of contouring the Cinder Bank to acceptable slopes, controlling
surface water run-on and runoff, placement of a soil clay
barrier and using a mixture of wastewater treatment plant
sludge and fly ash as a substrate for vegetation. Pre-design
studies will be performed to determine the best method of
controlling or extinguishing the internal fires within portions
of the Cinder Bank.
In addition, treatability studies will be undertaken with
. regard to the collection and treatment of surface water runoff
from the Cinder Bank using constructed wetlands and lime trea~-
ment in conjunction with the already operational facility water
treatment plant. . The Cinder Bank run-off collection and treat-
ment systems are needed initially since covering the Cinder
Bank may take at least three years. Surface water run-on to
the Cinder Bank from Blue Mountain will be controlled by the
construction of surface water diversion channels.
Operation and Maintenance will be implemented for this
Operable unit once it has been demonstrated that treatment
discharge, if necessary, to the Aquashicola Creek meets the
clean-up goals in the attached Record of Decision. This is
in conformance with Section UJ4 (c) (i) (6) of CERCLA, 42 U.S.C.
Section 9604 (c)"(i) (6).
The general procedures for the above described remediation
will be as follows:
Step 1:
Contour Slopes of Cinder Bank
Slope modification is required to enhance precipi-
tation runoff from the Cinder Bank apd reduce the
amount of precipitation infiltration and particulate
erosion. Heavy equipment will be used to modify
slopes targeted for vegetation. Excessively steep
or otherwise unstable slopes may be built-up from
the toe of the slope. Gas vents will be installed,
if necessary. The Remedial Design generated prior
to the implementation of this interim remedial action
will provide grading specifications necessary to
ensure success in the fi~al cap placement.
Step 2:
Construction of Surface Water Diversion Channels
Surface water diversion channels will be constructed,
which will assure the water run-off from Blue Mountain
will be diverted away from the Cinder Bank area. During
construction of the remediation action surface water
run-off from Blue Mountain will be diverted through
channels away from the Cinder Bank and to a treatment
-------
system if warranted. Leachate from the Cinder Bank will
be collected by channels and diverted to the treatment
system, initially, lagoons in compliance with RCRA
standards, will be utilized for the temporary storage
of collected surface water.
Step 3: Construction and Cap
A cap consisting of a minimum of 18" of soils and 6" of
clay or soil/bentonite mixture will be placed over
the Cinder Bank to prevent: 1) infiltration and
leaching of heavy metals into the groundwater; and
2) seeps contaminated with heavy metals from exiting
the toe of the Cinder Bank. ( See Alternative selection
for further discussion).
Step 4: Vegetative Cover
A stabilizing vegetative cover will be applied over
the cap. The cover may be comprised of a wastewater
treatment sludge/ flyash mixture, or conventional
mulching, fertilization and seeding. The purpose of
the vegetative cover will be to stabilize the slopes,
prevent erosion, and control surface water movement.
Step 5: Long-Term Activities
An inspection, monitoring, and maintenance plan
will be implemented to assure effectiveness of the
remedy.
Declaration
The selected remedy is protective of human health and environ-
ment, attains Federal and State requirements that are applic-
able or relevant and appropriate, and is cost-effective as
set forth in Section 121(d) of CERCLA, 42 U.S.C. Section 9621
(d), and Section 300.68 of the NCP. This remedy satisfies
the statutory preference as set forth in Section 121(b) of
CERCLA, 42 U.S.C. Section 9621(bj, for remedies that employ
treatment that reduces toxicity, mobility or volume as a
principal element. Finally, it is determined that this interim
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Because this interim remedy will result in hazardous
substances remaining on-site, a review will be conducted
within five years after commencement of remedial action to
ensure that this interim remedy continues to provide adequate
protection of human health and the environment.
Date __———' // Jarae^ M. Seif
Jgional Administrator
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SECTION
II.
IIL
IV.
VI.
VII.
VI I I.
IX.
XI.
XII.
Table of Contents
for
Decision Summary
PAGE
I .
INTRODUCTION.................................... .1
SITE NAME, LOCATION AND DESCRIPTION~.............l
SITE HI STORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
ENFORCEMENT HISTORY..............................3
V.
SITE CHARACTERISTICS.............................4
A. GEOLOGY/HYDROLOGY.............................4
B. EXTENT OF CONTAMINATION.......................S
1.
2.
3 .
4.
Cinder Bank Wastes
Surface Water
Stream Sediments
Groundwater
~
1....
SUMMARY OF SITE RISKS........................lS
COMMUNITY RELATIONSHISTORY.....................16
REMEDIAL ALTERNATIVE OBJECTIVES.................16
EVALUATION OF REMEDIAL ALTERNATIVES.............17
DESCRIPTION
OF ARARs............................ 23
X.
COMPARATIVE ANALYSIS OF ALTERNATIVES............24
DOCUMENTATION OF SIGNIFICANT CHANGES............24
SELECTED REMEDIAL ALTERNATIVE...................25
A. DESCRIPTION AND PERFORMANCE GOALS............25
B. STATEMENT OF FINDINGS REGARDING WETLANDS
AND FLOODPLAINS............................. 27
DETERMINATIONS.........................27
XIII. STATUTORY
APPENDIX A. - SUMMARY OF ANALYTICAL DATA
APPENDIX B. - RESPONSIVENESS SUMMARY
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Palmerton Zinc Site
Operable Unit II
Cinder Bank
.
. .
Introduction
The Superfund investigation of the Palmerton Zinc smelter
focuses on four ~roblem areas which are each being studied as
individual units: first, the deposition of heavy metals,
mainly cadmium, lead, and zinc, throughout the valley as a
result of air emissions from the smelter; second, the Cinder
Bank, approximately 2.5 miles long, which consists of an
estimated 33 million tons of slag; third, the defoliated
portions of Blue Mountain next to the smelter; and fourth,
the overall site groundwater and surface water contamination.
The investigation of the Cinder Bank, which is located'on the
smelter, property and at the base of Blue Mountain, is the
subject discussed herein. The Blue Mountain unit has recently
entered the design phase, while the Valley and groundwater/surface
water units are in the Remedial Investigation and Feasibility'
Study phase.
II.
Site Name, Location and Description
The Palmerton Zinc Superfund Site is located in the
Borough of Palmerton, Carbon County, Pennsylvania as shown
on Figure 1. The town is situated at the confluence of the
Lehigh River and Aquashicola Creek, just north of the Lehigh
Water Gap. Land uses in the area include industrial sites,
forest lands, residential communities and agricultural farm-
lands. Approximately 7,333 residents live within the town
which has historically provided a majority of the workforce
at the smelter. From 1898 to 1967 the smelter was privately
owned by the now defunct New Jersey Zinc Company. It was then
sold to Gulf & Western Inc. which operated the facility
until 1981, when it was purchased by its current owner Zinc
Corporation of America.'
The topography surrounding the site is mountainous, lying
in a deep valley within the Appalachian Mountains between
Blue Mountain (elevation 1,533 feet) and Stony Ridge (elevation
933 feet). The Appalachian Trail runs along the top of Blue
Mountain. ,
The smelting operations are located at two separate
locations, a west smelter and an east smelter. Both smelters
are located at the base of Blue Mountain (see Figure 2).
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SOURCE: RAND McNAllEY ROAD ATLAS
Figure 1
SITE LOCATION
PALMERTON ZINC SITE, PALMERTON, PA
SCALE: 1" - 95040'
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...,
H
G')
e
NJZ
WEST
PLANT
N
~
CREEK
rv
AQUAStllCOlA CREEK
IIAltn 15
1m tn/;r
@.
I=::
AGGR£GAHS
BRIDGE
IHD
°TATION
BRIDGE
PALM£lUON
CINDER
BANK
216TH STRHT "\ .. \ \\
BRIDGE 0 0" () \\ \\
YI\.\\t
TATRA INN
BRIDGE
Zinc Corpora~ion of America fast and West Plants
Aquashicola Creek and Lehigh River
Palmerton. Pennsylvania
Key: 0 tlEiC Sampling Statton
28 USGS GAGE STATION
(UAlNUIPO!tr)
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-2-
The major watercourse in the project area is the Lehigh
River. The drainage pattern of the study area is toward
Aquashicola Creek, a tributary of the Lehigh River. Aquash-
icola Creek flows through a buried valley, between Blue
Mountain on the south and Stony Ridge on the north. The'
creek flows southwesterly and is joined by Buckwha Creek
about one-half mile upstream of Harris Bridge and by ~ill
Creek near the east plant's main gate (See Figure 2). Aquash-
icola Creek f~ows into the Lehigh River approximately 1.5
miles southwest of the east plant.
The reach of Aquashicola Creek in Palmerton is classified
as a warm water fishery and is stocked for trout by the Pennsyl-
vania Department of Environmental Resources. According to
the criteria of water uses in this classification, the creek
should maintain stocked trout from February 15 to July 31.
It should also maintain and ptopagate fish species and addi-
'tional flora and fauna that are indigenous to a warm-water
habitat.
.A water intake is located on the Aquashicola Creek near
the Field Station Bridge. This intake pumps water from the
stream for industrial use at the east plant. Water from Aquash-
icola Creek is also pumped from an intake located between the
Main Gate Bridge and the Sixth Street Bridge during times of
emergency need for industrial process water.
Groundwater in the site vicinity occurs in both the
unconsolidated deposits and the underlying bedrock. The
shallow aquifer is classified as a Class 3 aquifer and the
aquifer is classified 2a as determined by EPA Groundwater
Classification Guidelines.
deep
At the foot of Blue Mountain, the Palmer Water Company,
which supplies water to the towns of Palmerton and Aquashicola,
has as its water source four production wells, ranging in
depth from about 200 feet to more than 400 feet, drawing
ground water from bedrock. The yield of these wells reportedly
ranges from 115 to 130 gallons per. minute.
I II.
Site History
The Zinc Corporation of America currently operates one
zinc smelter in Palmerton, referred to as the east plant,
which opened for operation in 1911. Another smelter located
in the west plant had operated between 1898 and 1987 at which
time it was shut down. The Palmerton Zinc facility historically
has produced zinc and other metals' for machinery, pharmaceu-
ticals, pigments, and many other products.
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-3-
Primary smelting of concentrated zinc sulfide ores, which
was the main source of air pollution, was stopped in December
of 198~. However, until then the smelters had emmitted large
quantities of zinc, lead, cadmium and sulfur dioxide which
caused to the defoliation of many acres of land including
approximately 2,~~~ acres on Blue Mountain, located adjacent
to the east smelter. Aerial photography of the site taken
from 1938 to 1985 shows the various stages of damage to
vegetation. Vegetation damage is defined as areas of exposed
rock and soil where the original vegetation, as seen on a
1938 aerial,photgraph, has been destroyed as a result of the
smelter's emissions.
Vegetation damage first appeared on a 1951 aerial photo-
graph as isolated patches on the steep, north-facing slope of
Blue Mountain, located immediately south of the Palmerton Zinc
east plant. During the 1938-1985 period of analysis, the
vegetation damage progressed and additional areas of damage
appeared. By 1985, vegetation damage appeared as a continuous,
widespread area with barren, eroded land visible in aerial
photographs.
The disposal of plant waste since the smelter operations
began at Palmerton in 1898 has enabled the Cinder Bank tg be
built to its present dimensions of 2.5 miles and 33 x l~
tons. It contains large amounts of leachable lead, zinc,
cadmium, and other metals.
IV.
Enforcement History
Past zinc smelting operations have created widespread
heavy metal contamination both on and off the Palmerton Zinc
plant property. The contaminated areas have been divided
into four distinct areas by EPA and are referred to as the
Blue Mountain Project, the Cinder Bank, the Valley Contami-
nation and overall groundwater and surface water contam-
nation. An RIiFS for the Cinder Bank has recently been com-
pleted by the Zinc Corporation of America who, as the current
owner of the facility is a potentially responsible party
(PRP) at this site. The Valley Contamination Study is
currently being performed under a Consent Order by Gulf
Western, the other PRP associated with this site. Both
declined participation in the Blue Mountain RI/FS which
completed by EPA in April, 1987.
and
PRPs
was
In a letter dated June 10, 1987, EPA gave the PRPs notice
of their potential liability with regard to the implementation
of the Blue Mountain Project ~emedial action. Enclosed with
this letter was a copy of the completed RI/FS and a copy of
EPA's proposed remedial alternative. The PRPs were extended
the opportunity to present a good faith proposal to conduct
-------
- 4 -
t~e Remedial Action to the Agency within sixty (60) days of
receipt of the June 10, 1987 notice letter. EPA received a
proposal from ZCA and completed successful negotiations in
which ZCA, by means of a Consent Decree agreed to implement
the Blue Mountain ROD. Gulf and Western Inc. again declined
participation in this project.
v.
Site Characteristics -
A.
Geology/Hydrogeology
1. SURFACE WATER
The drainage pattern of the study area is toward Aquash-
icola Creek, a tributary of the Lehigh River. Aquashicola
Creek flows t~~ough a buried valley, between Blue Mountain on
the south and Stony Ridge on the north. The creek flows.
southwesterly and is joined by Buckwha Creek about one-half
~ile upstream of Harris Bridge and by Mill Creek near the
east plant's main gate. Aquashicola Creek flows into the
Lehigh River approximately 1.5 miles southwest of the zinc
plant. .
The reach of Aquashicola Creek in Palmerton is classified
as a trout-stocking stream by the Pennsylvania Department of
Environmental Resources.
A water intake is. located on the Aquashicola Creek near
the Field Station Bridge. This intake pumps water from the
stream for industrial use at the east plant. Aquashicola
Creek water is also pumped from an intake located between the
Main Gate Bridge and the Sixth Street Bridge during times of
emergency need for industrial process water.
2. GROUND WATER
Groundwater in the site vicinity occurs in both the un-
consolidated deposits and the underlying bedrock. The glacial
outwash deposits in the stream valley contain significant
variability typical of this type of deposit.
Bedrock in the site area also contains significant quan-
tities of groundwater. The intense deformation of the bedrock
is expected to occur through interconnected fractures and in
related solution openings in the limestone formations. The
degree of interconnection between the unconsolidated and bed-
rock aquifers and theitrelationship to nearby surface waters
has not been defined to date, but is being investigated.
-------
- 5 -
At the foot of Blue Mountain, the Palmer Water Company,
which supplies water to the towns of Palmerton andOAquashi-
cola, has as its water source four production wells, ranging
in depth from about 2~~ feet to more than 4~~ feet, which
draw groundwater from the bedrock aquifer. The yield of these
wells reportedly ranges from 115 to l3~ gallons per minute.
The depth to groundwater in the valley is reported to
be about 5 feet. The flow directions of shallow groundwater
are expected to be controlled by local topography and by °
Aquashicol? Creek. Shallow groundwater may flow north from
Blue Mountain to the creek. Wells installed in the unconsol-
idated deposits near Aquashicola Creek may receive substantial
recharge from the creek. Deeper groundwater flow may be in-
fluenced primarily by both structural and stratigraphic
relationships. Furthermore, deep groundwater will likely flow
from the site toward the Lehigh River, tQ the west-southwest.
The groundwater flow patterns are also being investigated.
3.
Soils
.The bedrock of Blue Mountain is Silurian-aged Shawangunk
Conglomerate, ranging from a quartzitic sandstone to a coarse
conglomerate. To the south is the Ordovician Martinsburg
Shale, and, to the north, are red siltstones and shales inter-
bedded with limestone and sandstone in the Bloomsburg (Cayuga) .
formation.
All of Carbon County was glaciated by the Kansan Glacier.
The second, or Illinoian, glacier ~xtended into the valleys
to the north and south of Blue Mountain, but apparently did
not cover the ridge itself.
The periglacial frost action during the Illinoian and Wisconsin
glacial periods resulted in shallow channery soils on most
ridges with deep deposits of colluvial material at the bases.
B.
Extent of Contamination
1. Cinder Bank
A.
Nature of Cinder Bank Wastes
Much of the Cinder Bank residue is in the form of bri-
quettes from the vertical ~etorts and contains residual metals
and carbonaceous material. As a result of either incomplete
quenching or spontaneous combustion large portions smolder con-
tinously and several of these areas are posted as "Fire Areas."
In areas that have not been physically disturbed, large cracks
form in the surface roughly parallel to the outer edge.
-------
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-------
- 6 -
Occasionally large blocks of partially consolidated residue
come off of the main mass of the Cinder Bank and tumble down
the steep north slope towards Aquashicola Creek. As the
cracks develop, steam and smoke issue from them leaving
sublimated yellowish deposits on the adjacent surfaces. These
cracks and resulting broken rough surfaces provide avenues
for rapid infiltration and percolation of rain and snow melt,
and facilitate leaching of soluble constituents from the
Cinder 3ank.
*
In 1981 approximately 1,800 linear feet of reside in the
Palmer ton cinder bank was sampled and analyzed. The purpose
of the project was to define as accurately as possible the
recoverable values in this waste pile.
Twenty-seven holes were drilled by the New Jersey Zinc
Company in a more or less random pattern into the seven zones
which comprise the residue bank. If there was any bias in
selecting the locations to be investigated, it was that the
drilling areas were chosen where the expectation of high
metallic values was greatest. Approximately 200 samples were
taken and analyzed.
The results of the drilling program, which analyzed for
specific metals, are summarized below and as a whole, the
bank can be said to contain the following:
27,500,000 Tons of Residue
16% Carbon
2.7% Zinc
0.025% Cadmium
0.36% Lead
0.33% Copper
0.6 Oz./T Indium
The Cinder Bank has been the repository of process re-
sidues and other wastes from the Palmerton operations for the
past 65 years. It is located behind the East Plant and stretches
approximately two and one-half miles along the base of Blue
Mountain, covering about 200 acres of the lower slope. Until
1970, all of Palmerton1s municipal waste was disposed by
burying it in the residue. As of December 1987 the Cinder
Bank ceased to be used as a depository for plant waste material.
An estimated 25-30 million tons of various materials are
deposited over this area in irregular piles and ridges. Some
segregation by type has been practiced in recent years with
the objective of potential reclamation. During the past 30
years, considerable quantities of material suitable for aggreg-
ate and anti-skid uses have been removed by private contractors.
-------
-7-
The method of transporting, unloading and distributing
the waste materials has changed over the life of the Cinder
Bank, and, to some extent, it has determined the character of
the bank. Prior to the late 194~'s, the materials were trans-
ported in gondola cars by steam locomotives and unloaded by
locomotive cranes, followed by gangs of laborers who shoveled out
the remaining material. The material was piled in ridges on
either side of the unloading track, causing long shallow ridges.
With the conversion in the 194~'s to diesel locomotives, dump-
type rail cars, bulldozers, and front-end loaders, steeper
track grades became possible and large, broad, deep piles
resulted which buried many of the early ridges.
. The Cinder Bank area has been geographically zoned with
regard to material types and environmental factors (see Figure
3). . In general, Zones A, Band C at the east end are the
significant sources of environmental concern because leachate
contaminated with heavy metals can enter the nearby Aquashicola
Creek. These zones are influenced the most by the residues
generated since 195~ when a substantial increase in the use
of sulfur-bearing ores occurred. The other zones, thus far,
have indicated minimal problems with contaminated leachate.
Zone A - 3,~~~,~~~ Tons (Estimate)
This zone comprises a single large pile of Vertical Retort
residue, American Process Oxide residues, and municipal waste,
capped by a layer of blast furnace slag deposited during the
195~'s. Some burning has occurred within this pile and the
leachate is contaminated with heavy metals. It has been
graded over a bed of high lime residue from the Waelz Kiln
process to precipitate the heavy metals, and was vegetated
with zinc tolerant grass in an attempt by the site owners to
further her reduce the reduce the contaminated leachate problem.
Zone B - 5,~~~,~~~ Tons (Estimate)
This zone is at the extreme end of the bank and contains
most of the Verticai Retort and American Process Oxide residues
generated during the 196~'s and 197~'s. Municipal waste was
buried in an isolated section of the zone, and the balance of
the material placed during this period is relatively undiluted.
There is a small section where Vertical Retort residue from pro-
cessing high silver and indium-bearing Huari concentrates are
segregated. A portion of one of the ridges contains around 2%
copper believed to be part of the residue from processing
African c?ncentrates during the mid-l94~'s.
-------
-8-
Zone C
This zone was designated primarily as a part of the
environmental program because it is a swampy area draining
the leachate from Zone B. A small quantity of the highly alkaline
Waelz Kiln residue has been placed along the edge of this zone as a
start in efforts to precipitate heavy metals from the leach-
ate.
Zone D - 15,000,000 Tons (Estimate)
This zone is a large, irregular ridge about two-thirds
mile long/ containing a mixture of all types of waste-furnaces
residues, coal ashes, sludges, slags, and municipal waste.
It was last used in the 1940's. Most of the aggregate reclama-
tion activity has taken place here, leaving pits, exposed
faces of fused material and piles of screening rejects.
Considerable internal burning has taken place and hot spots
are still in evidence today.
Zone E - 500,000 Tons (Estimate)
This zone was designated for Vertical Retort residue
exceeding 5% zinc. Since the shutdown of the metal circuit
in November 1980, American Process Oxide residue has been
deposited at this location. No evidence of burning appears
at this zone.
Zone F - 500,000 Tons (Estimate)
Approximately half of this zone contains American Pro-
cess Oxide residue with zinc content around 10%, making this
material a suitable feed to the Waelz Kilns when mixed with
other higher zinc material. A small ridge of residue trailing
off to the east contains 4-7% copper in an estimated 3,000
tons of residue. Like the area in Zone B, this residue is
also believed to have resulted from processing African concen-
trates.
Zone G - 500,000 Tons (Estimate)
This zone has a variety of materials not readily identified.
However, one identified material is Vertical Retort residues
from processing Willemite ore.
Zone H - 3,000,000 Tons (Estimate)
This zone contains mostly Waelz Kiln residues in the west
portion with a lesser quantity of high iron and manganese re-
sidues from the former flat grate oxide furnaces. Several
thousand tons of waste acid treatment sludge and about a
thousand tons of Cadmium Plant residues are located atop the
Waelz Kiln residues bordering the mountainside.
-------
- 9 -
B.
Cinder Bank Runoff and Seepage
Much of the Cinder Bank residue is in the form of briquettes
f.rom the vertical retorts and contains residual metals and
carbonaceous material. As a result of either incomplete
quenching or spontaneous combustion large portions smolder
continuously and several of these areas are posted as "Fire
Areas". In areas that have not been physically disturbed,
large cracks form in the surface roughly parallel to the
outer edge. Occasionally large blocks of partially consol-
idated residue come off of the main ~ass of the Cinder Bank
and tumble down the steep north slope toward Aquashicola
Creek. As the cracks develop, steam and smoke issue from
them leaving sublimated sulfurous deposits on the adjacent
surfaces. These cracks and resulting broken rough surfaces
provide avenues for rapid infiltration and percolation of
rain and snow melt and facilitate leaching of soluble con-
stituents from the Cinder Bank. In addition, the Cinder Bank
has been contoured to a slope approaching 2 to 1 which is
unstable.
Evidence of minera~ leachate from the Cinder Bank is abun-
dant. Zinc concentrations in waters passing over or through
the Cinder Bank increased significantly, especially in the
~re~ east of NEIC Station 69 (NJZ Station l~A) (see Figure
4). In this area, zinc concentrations increased from back-
ground levels ranging from ~.27 to ~.67 mg/l to values generally
greater than 17 mg/l and as high as 23~ mg/l in Cinder Bank
run-off and seepage. Increase cadmium concentrations in the
Cinder Bank run-off were also highest in this area.
The high concentrations of zinc in run-off and seepage
from the east end of the Cinder Bank contributes to significant
increases of zinc in Aquashicola Creek. About one-half of the
total zinc load to the creek entered upstream of the Field
Station Bridge (see Figure 2).
Cadmium and zinc were detected in all samples from ~eeps
and springs near the base of the Cinder Bank. The average
concentration of dissolved cadmium in samples from the seeps
and springs at the base of the Cinder Bank was ~.ll8 mg/l or
about l~ times higher than the run-off not influenced by the
Cinder Bank.. The average of all dissolved zinc concentrations
in samples of seeps and springs at the base of the Cinder
Bank was 35 Mg/l or about 24 times greater than background.
The highest concentrations of cadmium and zinc observed
were in samples from seeps and springs along the eastern ~.6
mile at the base of the Cinder Bank. These samples
also exhibited low pH values from 4.3 to about 6 standard
units.
-------
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-------
-l~-
Data from samples .of seeps and springs at the base of
the Cinder Bank show clearly that cadmium and zinc are being
leached from the Cinder Bank and contribute to the contamin-
ation of Aquashicola Creek and the area groundwater.
Average annual precipitation in the vicinity of Palmerton
is about 46 in. (117 em) of which about 49% falls during the
growing season (May to September); average annual runoff is
about 24 in. (61 em). The drainage area directly above Aquash-
icola Creek to the crest of Blue Mountain in the reach spanned
by the NJZ East Plant and the Cinder Bank is about 1,100 acres
(4.5 x l~ sq m). Therefore, the average annual run-off to
Aquashicola Creek from the Cinder Bank and Blue Mountain is
about 2,200 acre-ft. Assuming that run-off and seepage flows
and metals concentrations during the surveys were represent-
ative of average conditions, the average annual loads of
cadmium and zinc contributed to Aquashicola Creek in the
reach between the east end of the Cinder Bank and the 6th
Street Bridge would be estimated at about 0.48 tonslyr and
110 tonslyr, respectively.
During periods of run-off, contaminated storm water per-
colates through the Cinder Bank to the groundwater. The
groundwater recharges the creek and also seeps out through'
the Cinder Bank. The Compani has attempted to isolate Blue
Mountain runoff from the Cinder Bank with little success.
Pipes were placed at the surface discharqes of two rills to
convey this water over the Cinder Bank. The pipes on top of
the Cinder Bank froze, split and were not repaired. As a
result, the water flows into the Cinder Bank.
2.
Surface Water
There are significant contributions of zinc, cadmium and
manganese to Aquashicola Creek in the reach from Harris Bridge
to the 6th Street Bridge, located just downstream from the
East Plant. Zinc and cadmium loads each'increased about thirty
times in this reach, while manganese increased sevenfold. No
increases in metals above that which was found in the reach of
the Aquashicola Creek from the Harris Bridge to the 6th Street
Bridge were noted between the 6th Street Bridge and the Tatra
Inn Bridge at the confluence of Aquashicola Creek and the Lehigh
River.
-------
-11-
Based on five-day average data, most of the zinc and cadmium
load was contributed to Aquashicola Creek by groundwater and
run-off sources:
Source Zinc Cadmium
Non-point contribution
between Harris and Field
Station Bridges (%) 5" 13
Non-point contribution between
Field Station and 6th Street
Bridges (%) 32 79
Total of non-point contribution
between Harris and 6th St.
Bridges (%) 82 92
East Plant Discharges (%) 18 8
Total (%) 1"" 1""
Most of the zinc enters the creek upstream of :he Field Station
Bridge. However, most of the cadmium enters the creek between
the Field Station and 6th Street Bridges in tht~ reach directly
adjacent to the plant.
Cross-sectional concentration data at three stations in the
Harris Bridge to 6th Street Bridge reach showed generally
higher zinc and cadmium levels on the Cinder Bank side of the
creek. No significant metal concentrations were found in
Mill Creek, indicating that the run-off and groundwater from
the drainage ~rea on the left side of Aquashicola Creek are
relatively metal-free.
Particulate erosion from the Cinder Bank adds to the contamin-
ation of Aquashico1a Creek. Sediment analyses for cadmium,
zinc, manganese, lead, and copper from Aquashicola Creek stations
adjacent to the Cinder Bank showed increases at~ve nearby back-
ground stations of 32, 26, 17, 11, and 1" times, respectively.
-------
-12-
Metals released to Aquashicola Creek in the reach adja-
cent to the Cinder Bank had a negative impact on water quality,
resulting in imbalanced aquatic communities. Benthic macro-
invertebrate and periphyton numbers and diversity were reduced,
as was the survival of test fish.
3.
Sediment Quality
Zinc concentrations in sediments from the background
Stations (27, 99 and 30) ranged from 420 mg/g to 840 mg/g and
averaged 620 mg/g. The stations (25, 24, 23, 22, 21, and 20)
adjacent to the Cinder Bank, East Plant and downstream on
Aquashicola Creek to its confluence with the Lehigh River
ranged from 6,200 mg/g to 42,000 mg/g and averaged 19,900 mg/g.
This is 32 times the average of the background stations.
Cadmium concentrations in sediments from the background
stations ranged from 2 to 13 mg/l and averaged 6 mg/1. The
Stations (25, 24, 23, 22, 21, and 20) adjacent to the Cinder
Bank, East Plant and downstream on Aquashicola Creek to its
confluence with the Lehigh River ranged fr~m 39 mg/l to 420
mg/l and averaged 157 mg/g. This is 26 times the average of
the background stations.
Similarly, manganese, lead, and copper, as compared to
the background stations, showed corresponding increases adjacent
to the Cinder Bank and East Plant areas of 17%, 11% and 10%,
respectively.
Background concentrations of zinc in stream sediments in
southeastern Pennsylvania are generally less than 200 parts
per.million (ppm). The high concentrations of metals in
Aquashicola Creek and in the Lehigh River sediment are attri-
buted to discharges including erosion from the Cinder Bank.
A.
Benthic Macroinvertebrates
Both Aquashicola Creek and the Lehigh River are character-
ized by a well-entrenched channel, moderate gradient and fre-
quent. large cobble-filled riffles over a hard-rock bottom.
Thoughout the study area, including reference (control) sites,
benthi~ macroinvertebrate population levels were low (44 to
l85l/m ) indicating that both Aquashicola Creek and the Lehigh
River are not highly productive.
-------
- 13 -
In Aquashicola Creek at Station 27, the reference station,
the benthos reflected good water quality. The 29 kinds of orga-
nisms collected were well distributed among the forms present.
Conditions began to deteriorate at the next two downstream sites,
stations 32 and 25, where a 40% reduction in the number
of kinds and 45% reduction in numbers/m2 occurred. This reach
of the stream is influenced by run-off from the NJZ Cinder Bank
and changes in the benthos population are attributed to the
high heavy metal concentrations in the run-off.
Conditions found in the Lehigh River, both upstream and
downstream of Aquashicola Creek, reflect typical conditions
for large, organically enriched, eastern U.S. rivers. No
apparent effect of Aquashicola Creek on the river was observed.
i
B. Periphyton
Periphyton communities reflected the influence of the Palm-
erton Zinc Site in several ways. Attached algal populations
responded to the toxicity of Cinder Bank run-off and seepage by
decreasing from about 40,000 organisms per cm2 at reference
Station 27 to about 20,000 and 5,000/cm2 in the reach adjacent
to the Cinder Bank. This toxicity-induced decrease was also
reflected in low chlorophyll concentrations of 69 and 27 ug/
cm2.
It appears that wastes carried by Aquashicola Creek did
not influence Lehigh River periphyton significantly; communities
were similar in numbers and composition upstream and downstream
from the creek confluence.
C. Fish Survival
Mortalities among in-situ test fish occurred at six of eleven
exposure sites. Significant mortality (greater than the 10%
allowable for the control group) only occurred at Stations
20, 21, 22, and 23; this is the reach of Aquashicola Creek
extending from the mouth to approximately 3 river kilometers
upstream. This stretch of the creek receives Cinder Bank
run-off and seepage.
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- 14 -
There appears to be a correlation between total zinc
concentration and mortality. At Station 24, the average
total zinc concentration during the exposure period was ~.49
mg/l and no mortality of test fish was recorded. Station 21
had an average total zinc concentration of ~.87mg/l, and
produced the highest mortality of any site (4~%). At Station
2~, near the confluence of Aquashicola Creek, total zinc concen-
tration was somewhat lower at ~.7l mg/l and 2~% mortality
occurred.
3 .
Groundwater Quality
Specific conductivity of groundwater samples from seven
wells on the East Plant site ranged from l3~ to 8~~ micromhos
per centimeter. Calculated total dissolved solids concentrations
ranged from 85 mg/l to 52~ mg/l. Generally, waters of this
quality are considered acceptable for public drinking water
supply. However, zinc concentrations in groundwater ranged
from ~.~~3 mg/l to 3.2 mg/l and cadmium concentrations ranged
from ~.~~2 mg/l to 0.024 mg/l. Zinc was detected in all
seven wells sampled and cadmium was detected in four of the
seven wells sampled. Higher levels of zinc and cadmium were
detected in the two wells designated as Stations 93 and 94.
These wells are located on the east side of the field Station
between the Cinder Bank and raw materials storage area on the
soutll and Aquashicola Creek on the north. . Because of its
location and the presumed direction of natural groundwater
flow from south (Blue Mountain) to north (Aquashicola Creek),
it is likely that the high metals concentrations in the wells
resu~ted from leachate originating in the Cinder Bank.
Pumping of the wells in this well field induces groundwater flow
toward the well field from the Creek. The dilution of the
groundwater provided by this infiltration results in metals con-
centrations somewhat lower than would be expected in the shallow
aquifer if no pumping and induced infiltration were occurring.
Station Nos. 96, 97 and 98 are wells at the west end of
the East Plant area on the lower flank of Blue Mountain near
the Palmer Water Company maintenance building and a railroad
switching yard. These wells are referred to by the Palmer
Water Company as "deep wells," ranging in depth from about
200 ft (60 m) to more than 400 ft (120 m). The aquifers
tapped by these wells are bedrock aquifers of small yield and
have little or no direct contact with surface waters or the
shallow alluvial aquifer. A small amount of cadmium was
detected in Station No. 98 and low concentrations of zinc
were detected in each of these three wells.
-------
- 15 -
C.
SUMMARY OF SITE RISKS
As required by the Superfund Amendments and Reauthori-
zation Act (SARA) of 1986, EPA asked the U.S. Public Health
Service, Agency for Toxic Substances and Disease Registry
(ATSDR) to evaluate the health threat posed by the defoliated
portions of Blue Mountain. In a February 6, 1987 memorandum,
ATSDR found that there is potential risk in human exposure
through consumption of fish.
Erosion and run-off from the Cinder Bank have contributed
to high metai levels in fish. The levels of lead and cadmium
in the fish present a potentially significant health threat
to persons who regularly consume fish from area streams~ It
is ATSDR's opinion that ". . . consumption of fish from the
area streams presents a potential health threat and. . . the
public should be advised to consume fjsh from the immediate
area streams on a limited basis only (no more than once per
week) ."
Rainwater infiltration and surface water infiltration
(Blue Mountain 'runoff) are leaching metals from the Cinder
Bank and contributing to contamination of Aquashicola Creek.
Low pH values assist in the leaching of metals from certain
sections of the Cinder Bank.
The easternmost portion of the .Cinder Bank appears to have
the greatest impact on water quality with the zinc concentra-
tions av~raging 40 to 80 times greater than background zinc
concentr3tions and cadmium concentratins averaging 10 times
greater than background cadmium concentrations.
If average metal concentrations obtained from ZCA'S two-
sampling events in 1986 are assumed for the entire Cinder Bank,
then these values, along with run-off and drainage area calcu-
lations from NEIC's 1979 investigation, indicate that the
Cinder Bank may contribute 283 lbs. of cadmium, 622
lbs. of copper, 99 lbs. of lead, 296 lbs. of manganese, and
117,051 lbs. of zinc to Aquashico~a Creek each year.
Non-point sources, such as groundwater discharge, are re-
sponsible for between 80 and ~5 percent of metals loading to
Aquashicola Creek.
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- 16 -
VI.
Community Relations History
The community has generally been concerned about the
environmental devastation and the negative image a barren
mountain projects. The action being considered at this time
deals only with the Cinder Bank, however, there are two other
major contamination problems which are of public concern: 1)
widespread soil contamination which exists because of the
deposition of heavy metals from past air emissions from the
smelter, and 2) significant groundwater and surface water
contamination on ~nd near the smelter property.
The public has been concerned about the potential health
effects of the soil and groundwater contamination and also
about the potential financial impact on the Zinc Corporation
of America of any remedial action. An RI/FS on the widespread
soil contamination is being completed by the previous owners
of the smelter, Gulf & Western, Inc. pursuant to a consent
order with EPA. The report will be available for public
review and comment in the coming months. A separate RI/FS
for the overall surface water and groundwater is also underway.
VII.
Remedial Alternative Objectives
The major obje~tives of remedial actions to be taken at the
Palmerton Zinc Superfund Site include (1) minimize direct con-
tact with the Cinder Bank (2) reduce volume of run-off, (3)
reduce contamination in run-off, (4) reduce the volume of run-
on, (5) collect and treat leachate, (6) reduce wind-borne
contaminated emissions and (7) reduce particulate erosion.
Based on the above objectives, numerous source control
and mitigation control technologies were screened to provide
a limited number of technologies applicable for remedial
actions at the Site. Some of these technologies were removed
from further consideration based on site specific information
and other comparative criteria listed in Table 1.
-------
- 17 -
VI I Ie
Description of the Alternatives
A.
Remedial Alternative Evaluation
Each technology was evaluated not only in terms of theo-
retical feasibility, but also in terms of whether the technology
is applicable to the site specific conditions. The candidate
technologies that were dismissed from retention are presented
below with a summary of the justification for elimination.
Technology
Reason(s) for Elimination
- Site Fencing
High cost and does not minimize risk
- In-situ chemical
precipitation
Poor performance and unreliable
- Removing substances
for offsite disposal/
treatment
High cost; negative environmental
and public health impacts during
construction; unavailability of
adequate treatment/disposal
services
- Construction of
Hazardous Waste
Landfill onsite
Site is located in a floodplain;
High cost to construct and operate.
- Recycling Material
in Cinder Bank
High cost; negative environmental
and publjc health .impact.
The technologies that have been retained for !urther
arialysis can be grouped into the fol~owing four alternatives:
- No-action
- Capping using soil amendments and vegetation
- Collection and treatment of run-off and run-on
- Capping using soil-clay mixture and vegatation
To analyze these alternatives, an evaluation was conducted
that considered the new requirements vf the Superfund Amendments
and Reauthorization Act of 1986 (SARA~ (P.L. 99-499) and the
current version of the National Contlr'gency Plan (NCP) (50
Fed. Reg. 47912, November 20, 1985). Three broad categories
were used for the evaluation: effectiveness, implementability,
and cost. Within these categories there are seven factors
that consider the short-term and long-term effects of each
alternative (see Table 1). The evaluation is presented in
detail in the RI/FS report on the Cin6er Bank. The following
is a summary of the evaluation:
-------
TABLE
EVALUATION FACTORS FOA ALTERNATIVE EVALUATION
EFFECTIVENESS IMPLEMENT ABILITY COST
Reduction of
T oxicity, Technical Administrative
Mobility,
Protectiveness or Volume Feasi~ility Feasibility Availability Remtxly Replacement
SHORT. Reduclion 01
TERM exisling ,isks
Compliance with
ARARs
Compliance with
olhe. c,ite,ia.
adviso,ies. and
guidances
P,oteclion 01
community during
.emedial actions
Time unlil protedion
is achieved
Ability to consl,uci
lechnology
Short-Ierm reliabilily
01 technology
lfi1i~~q~.'':.:i'
LONG- Reduclion oI.'utu,e
TERM .Isks
Long-te,m ,eliability
Compliance with ARARs
P,evention o"ulu,e
exposu'e to ,esiduals
POlenlial nettd lor
'eplaccmt!nl
Pe,manenl and
signilicant .educllon
01 toxicily. mobility or
volume-
Use 01 pe'manenl
solulions and Ireat-
menl lechnologies o.
,esou,ce ,ecovery
lechnologies
bilily 10 oblain
Jpp,ovals Irom olhe.
. gancies
ikelihood ollavo,able
mmunily 'esponse
ordinal ion wilh
Ihe. agencies
eve"'tllnent ollulure
rdinalion nelwo,k
mpliaoce wilh some
alion-specdic ARAA<
Availabilily 01 Ireal-
menl, slofag8. and
disposal services
and capacily
Availabilily 01
necessaty equip-
ment and specialisls
Devolopmenl and
conslruclion cosl=-
Ope.aling CL)sls
'0' implementing
.emedial aClion
Olhiu capilal and
short-Ierm cosls
unlil ,emedial
aCIion is complele
fH.r~~""i:~~J!'tWi't~~~Hto\r:~~Ai)~:.
. '~i1!~~r~~~J'.dr~ft .~.. "'~~c' .
Eas8 01 undertaking
additional ,emedial
aClion. II necessaty
Ability to monilo,
ellecliveness 0'
,emedy
.a.bilily to pefform
o~falion and main-
le~anc8 lunclions
CoslS 01 operalion
and mainlenance
10. as long as
necessary
COSIS 01 5.yea.
roviows
POlenlial '0.
,emedial aClion
o. ,eplacemenl
cosls iI ,emody
were 10 lail
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- 13 -
Alternative 1. - No-Action
The NCP requires that the no-action alternative be
considered. This alternative will have no environmental
or public health benefits. It will not be protective in
the short-term or the long-terra. The metals on the Cinder
Bank will not degrade and will remain mobile and toxic for
decades and probably centuries. The environmental and
public health problems will continue into the foreseeable
future.
Taking no action would not comply with the requirements
of the Clean Water Act regarding Best Management Practices
(BMP). As discussed in a 1979 EPA report by the National
Enforcement Investigation Center (NEIC), steps should be
taken to minimize erosion and run-off from the Cinder Bank
in order to comply with the BMP requirements of the Clean
Water Act.
The factors in these categories do not require an
implementability and cost analysis since there are no imple-
implementation issues or costs associated with taking no
action.
Alternative 2 - Capping using Soil Amendments and Vegetation
This alternative would consist of using a mixture of
wastewater treatment sludge, lime potash, and fly ash to aid
in establishing a vegetative cap covering the Cinder Bank.
This method is considered an innovative technology and is
also solving the sludge and flyash disposal difficulties
encountered by local municipalities and industries. This
alternative only addresses that portion of the Cinder Bank which
EPA and PADER determine to be subject to municipal waste regulations
Pennsylvania State ARARs require a minimum 2 foot soil cover over
municipal waste.
Studies conducted by the City of Allentown and the Zinc
Co., between 1979-1983, demonstrated the feasibility of using
sludge to vegetate the bank, i.e., the vegetation in these
areas, some of which is entering its tenth year with no
maintenance, is still performing very well. As discussed
in chapters 5 and 6 of the Remedial Investigation for the
Blue Mountain project, greenhouse studies and field tests
have demonstrated that this technology is feasible. The
exact design and procedures will be based on further analysis
of the field plots. This alternative will be effective by
being protective in both the short-term and long-term and
will reduce the toxicity and mobility of the hazardous
substance onsite.
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- 19 -
The alternative will meet all seven of the remedial action
objectives. The direct contact risk will be reduced in the
short-term through the application of the soil amendments.
In the long term, after vegetation is established, the direct
contact threat will be further minimized as a layer of organic
debris is formed from falling leaves and a mat of stubble and
grass debris is formed. Vegetation can significantly reduce
the volume of run-off by plant uptake or transpiration of
water in their growth processes. Through transpiration large
amounts of water can be pumped back out of the soil. It is
anticipated that the vegetation program will help reduce the
metals levels in the run-off in a number of ways as detailed
in the Cinder Bank FS. In general, it has been established
that wind erosion can be abated by having a 4G% cover of
vegetation. Work already completed on the Cinder Bank shows
that stands of vegetation ranging from 9~GG% are possible if
the correct amendments and techniques are employed.
This alternative meets the Clean Water Act requirements
of BMP because vegetating the Cinder Bank will reduce surface
water discharges and prevent particulate erosion. The vegeta-
tion program will reduce the mobility of the metals. The
lime will help form low-solubility metal compounds and the or
ganic matter in the vegetative debris will form organic
complexes to further reduce the mobility of the metals. The
volume of hazardous substances will not be reduced .because no
cinders or organic matter will be removed from the Site.
The short-term technical and administrative feasibility is
very good. The materials and equipment required to implement the
project are available, or, in the case of a spreader truck,
could be built in 6G to IGG days. To date, support from the
local community and the state government has been very favor-
able and helpful. Continued support is anticipated and would be
necessary for the successful implementation of the project.
Relevant and appropriate action and location-specific require-
ments regarding the land application of sewage sludge have been
developed by the Commonwealth of Pennsylvania. Commonwealth
-------
- 20 -
guidelines require that soil pH be adjusted to 6.0 in the
first year, up to pH 6.5 by the second year and maintained at
6.5 for 2 years following application. With joint applications
of lime and fly ash, these levels should be attainable. A
protective erosion and sedimentation plan will be developed
and implemented.
It may be technically impossible to meet some of the guide-
lines (i.e. sludge application and 2 foot municipal landfill soil
cover) because of the terrain on the Cinder Bank. Specifically,
the steep terrain prevents incorporation of the sludge/fly
ash into some areas of the cinders as preferred by the guide-
lines; the slopes of the Cinder Bank are in excess of the 20%
maximum recommended by the guidelines. To overcome these
problems, the project can be implemented to minimize any
erosion caused by the steep slopes and the inability to incor-
porate the sludge. Consideration of Wetland and Floodplain
Regulations will be incorporated into the final plans when
making decisions on slope contours.
Overland movement of the sludge/fly ash mixture was
nonexistent during the field tests. The long term effective-
ness of the alternative can be monitored through soil and
water sampling. Vegetative growth and metals uptake by the
plants can also be easily monitored.
Operation and maintenance will be necessary to control erosion
of the soil amendments and insure the integrity of the vegetative
cover. Because the pH of the rainfall in Palmerton is acidic,
it is anticipated that over several years the Site could
begin to reacidify. This can be easily monitored through
routine soil testing and top-dressings of lime can be applied
as needed.
All remedial action on surface water and groundwater beyond
controlling Cinderbank Run-on and run-off will be handled under
Palmerton Zinc Operable Unit 4.
The costs to implement this alternative are calculated
to be approximately $4,500,000 which includes some slope contouring
and placement of 2 foot soil cover on 25% of the Cinderbank (this
percentage is for costing purposes only).
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- 21 -
Alternative 3 - Collection and Treatment of Runoff and Run-on
This alternative would consist of using a combination of
lime activated filtration lagoons and/or constructed wetlands
as a treatment for the collected run-off. These systems should
precipitate or bioaccumulate any metals that remain in the run-
off. Laboratory tests and field studies have demonstrated that
both of these technologies are technically feasible. The exact
design and procedures will be based on further laboratory and
field tests.
This alternative will be effective in both the short-term
and the long-term for the lime filtration lagoons, and in the
long-term for the constructed wetlands, following the estab-
lishment of the vegetation. This alternative will reduce the
toxicity and mobility of the the hazardous substances on site.
This alternative meets all seven of the remedial action ob-
jectives. In addition, it meets the Clean Water Act requirements
of BMP to reduce surface water discharges.
The vegetation in the wetlands will reduce the toxicity,
mobility and volume of metals in the run-off by bioaccumulation.
As the vegetation in the wetlands becomes saturated with metals,
it can be harvested and run through the kiln.
The lime in the filtration lagoons will reduce the toxicity,
mobility and volume of metals in the water being treated by chem-
ical precipitation of the metals. As the lime becomes saturated
with metals, it can be replaced with fresh lime, and the old
material can be run through the kiln and regenerated. The short-
term technical and administrative feasibility is very good. It
is technically feasible to install constructed wetlands and
lime-activated filtration lagoons. The materials and equipment
needed are available or could be purchased. The cost of this
alternative is approximately $2,86l,8~~.
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- 22 -
The long-term effectiveness of this alternative can be
monitored through water, plant, and soil sampling. Operation
and maintenance should be limited to harvest of the above-
ground portions of the wetland plants on an infrequent basis
and replenishment of the lime in the filtration lagoons as
needed. Some routine maintenance such as keeping water dis-
persion structures operational will be needed periodically.
The goal of this alternative is to treat Cinder Bank leach-
ate and potentially treat Blue Mountain run-off and reduce
metal levels to surface water background comparable to areas
not impacted by the Palmerton Zinc Site.
Alternative 4- Capping Using Soil and Vegetation
This alternative would consist of contouring the Cinder
Bank and applying a cap on the Cinder Bank. This cap would
prevent water from infiltrating the cinders and will consist
of an initial placement of 6 inches of soil and bentonite.
mixture covered by 18" of soil. Over the cap, there will be
a cover of soil into which there may be incorporated wastewater
treatment sludge, lime potash, and fly-ash, or some combination
of these materials, to aid in establishing a vegetative cover
of shortrooted grasses for erosion control.
The alternative will meet remedial action objectives.
The toxicity and mobility of the hazardous substances will be
reduced, although, because 00 cinders will actually be removed
from the Cinder Bank, the v~lume of ,hazardous substances at
the site will not be reducej.
The remedy is protective of human health and the environ-
ment, as it will eliminate 3ccess to the hazardous substances
by direct contact, prevent water and wind from moving the
hazardous substances, and, ultimately, will reduce metal-
contaminated water from ent~ring either groundwater or surface
water.
Finally, the remedy satisfies the statutory preferences
for maximum use of alternative technology and for permanence.
While the remedy is innovative and practical, it is not
experimental, but rather comes from a proven method for
dealing with large piles of waste materials. The method's
dependability also insures that it will permanently work to
eliminate access to' the hazdrdous substances by water, wind,
animals, and humans. The c"st of this alternative, assuming
contouring 25% of the Cinder Bank to a 33% grade, then placing
the cap on 53% of the Cinder Bank, is approximately $5,533,333
(listed percentage for slop~ contour and cap placement are for
costing purposes only). Operation and maintenance costs and
technical considerations
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- 23 -
will be reduced to periodic walkthrough, once erosion from the Cinder
Bank has ceased, to insure that no damage has been inflicted
as that cinders might become exposed. Capping may eliminate the
need for a leachate collection system and erosion-controlling
grasses eliminate the need, when the remedy is complete, for
catching and settling the clean water from the Cinder Bank.
The diverted water from Blue Mountain, also clean run-off,
will be able to enter the Aquashicola Creek directly. The need
for these water and leachate management systems will be reevaluated
once the Cinder Bank has been revegetated.
The remedy meets the requirements of the Clean Water Act
Best Management Practice and the Pennsylvania Solid Waste
Management Act ARARs, as it significantly reduces contamination
in surface water discharges and in groundwater. Although
residual contamination will be present as water remaining in
the Cinder Bank and in the ground makes its way to the Aquash-
icola, this remedy will stop the crescendo of contamination.
IX. DESCRIPTION OF MAJOR ARARS
FEDERAL
CWA
Wetlands impact
DifferentiBl Groundwater
policy
Best Management practices
Ambient Water Quality
Criteria
RC~A
Land Ban Disposal Restrictions
Executive Order 11988,
Protection of Floodplains
40 CFR 6, Appendix A
Action to avoid adverse effects,
minimize potential harm,
restore and preserve natural
and beneficial value
Executive Order 11990,
Protection of Wetlands,
40 CFR 6, Appendix A
Action to minimize destruction,
loss, or degradation of
wetlands
STATE
-.-
PADER
-Guidelines for
Sewage Sludge
Land Reclamation
(April 1988)
Maximum metals loading
rates
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- 24 -
Solid Waste Manage-
ment Rules and
Regulations -
Section 275:"Standards - Application and storage of
for Land Application of optional sludge
Sewage Sludge Waste
Disposal".
Section 273: Standards - Cover and vegetation .
for Municipal Waste
Landfills
X. Comparative Analysis
No environmental or public health benefits would result
from implementing Alternative 1. The reduction of existing
or future health risks by preventing continued exposure to
metals would not be addressed. Unlike Alternative 2, 3, and
4 the metals would remain mobile and would continue to contam-
inate area surface waters and groundwater by not minimizing
run-off, erosion and infiltration. This would not comply with
requirements of the Clean Water Act regarding Best Management
Practices (BMP).
Alternative 1 does not require an implementability analysis
since there is no implementation issues associated with taking
no action. Based on the results of field test plots, Altern-
ative 2 is implementable, provided there are reliable sources
of sewage sludge to complete the revegetation of the defoliated
area. Alternative 3 is implementable but depends on achievable
contours, Alternative 4 will be implementabie.
There are no costs for Alternative 1 since this involves
no action. Implementing Alternative 2 and 3 would be cost
effective, if the cost of supplying the wastewater treatment
sludge for municipalities is a cost effective means of disposal
in lieu of their current practices. Alternative 4 is the pre-
ferred alternative by the Commonwealth of Pennsylvania and
will be implemented where slope contours allow, and where not,
Alternative 3 will be utilized. Alternative 4 is cost effective
in the long term by reducing the amount of leachate to be treated,
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- 25 -
Documentation of Significant Changes
XI.
No significant changes to the preferred alternative pre-
sented in the proposed plan have occurred with the exception
of being more specific in addressing the required ARAR base covers
prior to the placement of the sludge-flyash mixture and vegetation.
XII.
Selected Remedial Alternative
A.
Descriotion and Performance Goals
Section 121 of SARA and the current version of the National
Contingency Plan (NCP) (5~ Fed. Reg. 47912, November 2~, 1985)
establish a variety of requirements pertaining to remedial
actions under CERCLA. Applying the current evaluation criteria
in Table 1 to the four remaining remedial Alternatives, we
recommend that Alternative 3 be implemented. In addition,
on areas of the Cinder Bank which contain RCRA listed waste
Alternative 4 is recommended, otherwise, in the areas not containing
RCRA listed waste, Alternative 2 will be implemented. Prior to
implementation of any remediation alternatives, both EPA and PADER
will be in complete agreement with the remedial design for the remedies
This is an interim remedy for the site. When the RI/FS
for the other Operable Units are com~leted by the responsible
parties, RODs will be issued to address all aspects of the
site. This interim remedy will not, however, be inconsistent
with a final comprehensive remedy for the Site. This interim
remedy attempts to ensure complian(:e with all ARARs for this
Operable Unit and will be consistent, to the extent practicable,
with those ARARS addressed herein.
The general procedures for thl~ above described remediation
will be as follows:
Step 1:
Contour Slopes of Cinder Bank
Slope modification is required to enhance pre-
cipitation run-off from the Cinder Bank and reduce
the amount of precipitation infiltration and
particulate erosion. Heavy equipment will be used
to modify slopes targeted for vegetation. Excessively
steep or otherwise unstable slopes may be built-up
from the toe of the slope. Gas vents will be installed,
if necessary. The Remedial Design generated prior
to the implementation of this interim remedial action
will provide grading specifications necessary to
ensure success in the final cap placement.
-------
Step 2:
Step 3:
Step 4:
Step 5:
- 26 -
construction ~f Surface Water Diversion Channels
Surface water diversion channels will be constructed,
which will assure the water run-off from Blue Mountain
will be diverted away from the Cinder Bank area.
During construction of the remediation action,
surface water run-off from Blue Mountain will be diverted
through channels away from the Cinder Bank and to a
treatment system if warranted. Leachate from the Cinder
Bank will be collected by channels and diverted to the
treatment system. Initially, lagoons in compliance
with RCRA standards, will be utilized.for the temporary
storage of collected surface water.
Construction and Cap
A cap consisting of a minimum of 18" of soils and 6".
of clay or soil/bentonite mixture will be placed over
the Cinder Bank
to prevent: 1) leaching of heavy metals
into the groundwater; and 2) seeps contaminated
with heavy metals from exiting the toe of the Cinder
Bank. (See Alternative selection for further discussion.)
vegetative Cover
A stabilizing vegetative cover will be applied over
the cap. The cover may be comprised of a wastewater
treatment sludge/flyash mtxture, or conventional
mulching, fertilization and seeding. The purpose of
the vegetative cover will be to stabilize the slopes, .
prevent erosion, and control surface water movement.
Long-Term Activities
An inspection, monitoring, and maintenance plan to
assure effectiveness of the remedy will be implemented.
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- 27 -
B.
Statement of Findings Regarding Wetlands and Floodplain
Management
The Palmerton Zinc Site is located within a floodplain
and contains several wetland areas. All excavation and fill
activities during the remedial action shall be conducted in a
manner consistent ,with provisions of Appendix A of 43 CFR
Part 6. The subject regulations have been entitled "Statement
of Procedures on Floodplain Management and Wetland Protection."
These procedures constitute policy and guidance for carrying
out provisions of Executive Orders 11993 ~nd 11988 respectively.
The Remedial Design of the Remedial Action shall be
developed in a manner consistent with Appendix A of 43 CFR
Part 6 to assure that potential harm and adverse effects to
the wetlands is minimized. The Remedial Design has not yet
been initiated at this time. Therefore, specific ,steps to
minimize impacts have not yet been identified. In addition,
the effect of the Remedial Action on the wetlands cannot
accurately be assessed at this time.
While all remedial measures shall be designed 'to minimize
harm to wetlands, it is possible that some adverse effects
may be unavoidable. Should remedial activity be expecte~ to
create such effects, restorative measures shall be developed
during the Remedial Design. Should anticipate adverse effects
occur, restorative measures shall be implemented as part of
the Remedial Action. .
Schedule
The anticipated schedule is to continue with some limited
design studies in the Fall of 1988. Beginning as soon as
possible, but probably not before the end of 1988, large
scale, multiacre revegetation will begin. It will take a
number of years to complete the remedial action, the exact
time depending on the amount of sludge available. EPA's goal
is to complete the project in three years.
XIII.
The Statutory Determinations
, A.
Protection of Human Health and The Environment
The selected remedy will reduce and control the amount of
Cinder Bank leachate which will ensure adequate protection of
human health and the environment. No unacceptable short-term
'risks or cross-media impact will be caused by implementation
of the remedy. .
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- 28 -
B.
Attainment of ARARs
The selected remedy will attain the applicable or relevant
and appropriate requirements and are as follows:
FEDERAL
CWA
RCRA
Executive Order 11988,
Protection of 'loodplains
40 CFR 6, Appendix A
Executive Order 11990,
Protection of Wetlands,
40 CFR 6, Appendix A
STATE
PADER
-Guidelines for
Sewage Sludge
Land Reclamation
(April 1988)
Solid Waste Manage-
ment Rules and
Regulations -
Section 275:"Standards
for Land Application of
Sewage Sludge Waste
Disposal".
Section 273: Standards
for Municipal Waste
Landfills
Wetlands impact
Differential Groundwater
Policy
Best Management Practices
~~bient Water Quality
Criteria
Land Ban disposal Restrictions
Action to avoid adverse. effects,
minimize potential harm,
restore and preserve natural
and beneficial value
Action to minimize destruction,
loss, or degradation of
wetlands
Maximum metals loading
rates
Application and storage of
optional sludge
Cover and vegetation
-------
- 29 -
C.
Cost-effectiveness
The selected remedy provides overall effectiveness commen-
surate to its costs .such that it represents a reasonable value
for the money.
D.
Utilization of permanent solutions employing alternative
technologies to the maximum extent practicable
The selected remedy is the most appropriate solution for
this operable unit and represents the maximum extent to which
permanent solutions and treatment can be practicably utilized.
E.
Preference for treatment as a principal element
The preference is satisfied since treatment of the oper-
able unit's principal threats (i.e., cadmium, zinc) were found
to be practicable.
-------
APPENDIX A
-------
,':'..; ''';..1 S :: .. : : :. a " .. . . ::. i.'Ie: - . ....: -... ~:!::
-::er".. -e~..:..;~ _,;c~a::. s: :-.,; . - ....
~.ay ..,..... ~ :a:a
. ~ I "1
7o:al !o':a~ :':J:al _.
..: :30-
Si:e Cac:::.~ :-'.ar.ga~ese :'ud .~~
--..-
:"oca:i':1n Sam=:e:- ~ ~ ' I " , (:n~/:) (::1~/:') .',
\.=~/ -J " ......., - I
}J,l-27 ~AI 3/13/86 7.27 0; 0 13 0.14 ND c. J C
AW-";.7 R~A! 8/14/86 8.28 ND 0.03 0.009 O. Z6
}J,l-27 ~::C 5/79 7.00 0.001 0.04 0.004 0.C3
AW-25 R!'.oiA: 3/13/86 7.31 0.011 0.14 ND 0.39
}J,l- 4:5 R-CW A! 8/14/86 6.93 0.008 0.16 ND 0.63
AW- 25 m::C 5/79 7.15
}J,l-24 RnlAI 3/13/86 7.07 0.008 0.09 ND 0.41
AW-24 R~A! 8/13/86 7.98 ND 0.24 0.021 0.4a
}J,l-24 m:!C 5/79 6.94 0.007 0.21 0.003 0.52
AW-21 REWA! 3/12/86 7.02 O.OlS 0.11 ND o.;;.a
}J,l-21 REW Al 8/13/86 7.04 0.023 0.21 ND :. ~9
AW-Z1 m::c 5/79 7.12 0.040 0.25 0.004 0.86
}J,l-20 RnJAI 3/12/86 7.22 0.013 0.06 0.005 0.51
AW-20 RaJA! 8/13/86 7.12 0 . 03 1 0.28 0.012 1.14
}J,l-20 m::c 5/79 7.54 0.040 0.19 0.009 0.75
LR-1 R:1JAI 3/14/86 6.80 0.008 0.20 0.005 0.33
LR-1 R-~A! 8/15/86 6.78 ND 0.15 ND 0.21
LR-1 NE!C 5/79 6.88 0.001 0.15 0.001 0.08
LR-2 Rnl AI 3/14/86 6.83 0.018 0.15 ND 0.25
LR-2 RnlAI 8/15/86 7.09 ND 0.08 ND 0.21
LR-2 NE!C 5/79 6.66 0.002 0.13 0.004 0.08
No Data
ND - Not Detected
AWQC*
( ug/l)
Cadmium
Zinc
Lead
1 day - 3.9
1 day - 120
1 day - 83
4 day -,1.1
4 day - 110
4 day - 3.2
* hardness dependent criteria based upon average hard~ess of 100 ~/l C~C03
-------
[lass LQadin~ Cat:a En ,~quash i:01a C:eel(
liar~ l~CI~
s i ~'! Flc'" C~d:nium Coprer Lead I'anganese z~:"~
!..:-- 2 ~. ,'" ~ t...!; t':! .!v l~~/~a.' ~~~I ~av '~s/dav 1~si~3v
A:'/-27 226.14 24.52 169.14 G 264."4 565.~C
C:3RO ;!. ~" 3."3 9.21 0.32 9.26 4.39
A~/- 2S 156.16 14.33 65.12 " 192.33 517.~3
AU-14 133.02 8.99 44.38 " 99.84 454.95
~IJ:OF 2.62 3.99 2.47 1. 7" 4.47 39.98
AI~- 2l 196.95 29.43 114.45 3 179.86 784.83
STP 1.44 ' 9.36 I" 84 9 3.72 22.59
AW-29 218.96 23.74 73.35 9.13 109.57 931.32
Auau~t. 1986
Site Flow Cadmium Copper Lead lianganese Zinc
[.o~~t 1~!'I ~ l"'~/d~y Ih~/da.v lb!!/day l~!I/dav lbs/dav
AII-27 25.16 0 8.39 1.89 6.39 54.56
CDRO 0.45 0.08 ".13 ".81 ".18 4.7S
AW-25 26.1Jl 1.74 4. J4 9 J4.71 136.66
Mi - 14 25.28 " 6.33 " 5".96 111. 20
NJ:OF Jo6l 0.92 0.65 0.87 2.69 28.46
AW-2l 37.C3 7.le 15.44 9 64.85 336.62
STP 1.44 9.29 ".48 9.1 3.36 :~. B9
M/-2\! 59.47 13.95 ~51. 53 5.05 11 7 . 86 479.95
callo - C i nd a r Bank Runoff Sites
SJZCF - New Jersey Zinc Ou ttall Sites
ST'P - ~almerton Sewaqe Treatment Plant (lo:lds based on estimated flow)
-------
C~mparisons of A4U~shi~?la C:eek Sed iments
May 1!?79/l1arch and AuguSt 1986
5'~te Cad:nium Copre r ~1 an:; <1n es Q tead Zinc
, ....,. ~ t . . '" ~ .: -.,.. ~ A ~ Q.4u '~a/\.:~} (mc/\((!) ("'0/'<0) (mc/I!a! (~C!/'<~,
--' -
'\5-27 ?!:~;A I 3/13/96 U.9 34.5 315. \1 78.5 739.11
'\S-27 ?!:::AI 9/14/96 1.3 12.9 165. a 11.3 2.5
AS-27 ~:t:c 5/79 13. a 51.3 550.a 52.9 849.11
A5-2S F:r.:IA I 3/13/86 37.5 148.0 1.165.9 234.9 2.750.11
"S-25 ~t;';AI 8/14/96 44.9 137." 21. a9l1. 0 134.3 73.3
"S-2S /It:C 5/79 39.11 1.3911.0 5.4119.0 1. 030." 6.299.3
"5-24 ;ltWA I 3/U/96 95." 695.9 52.se9.\1 765.9 23.699.3
AS-24 Rt\~AI 8/13/86 15.1 365.11 12.6i11J.\I 121.3 3.75"."
AS-24 ~I E: : C 5/79 121'- 9 5011.9 15.5911.11 823." 17.ae9.3
AS-21 REWAI No Sample
A5-21 Po!:'"" I 8/13/86 42.1 174.9 7.35".9 183." 8.679..9
A5-21 NEIC 5/79 58.1 368.11 9.709.3 071.9 14.""".11
A5-29 !U:WAI 3/12/86 64.5 166.9 3.601'-\'1 413.9 9."00.3
A5-21 flEWA I 8/13/86 29.5 54.7 4.1189.0 88,7 4.671.11
A5-23 NEIC 5/79 95.11 390.9 9.991.\1 499.9 11. seO.1I
-- No Siu"r1e
-------
ftt^
\rt '•• I
•*•
V- '' VJ
300
-------
-------
APPENDIX B
-------
FINAL RESPCNSIVENESS SUMMARY
PA.t.l1EIm:N ZINC SUPERFUND SITE
OPERABLE UNIT 2: THE CINDER BANK
prepared for
u.S. ~ nClu.""J."~CII1GE1C't
Office of waste progrus Enforcement
~, D.C. 20460
WOrk Assignment No.
EPA Region
Site No.
Contract No.
CDM Federal Programs
Corporation Document No. : 'l'772-C03-cR-cEYJ-2
Prepared By : Booz, Allen' Hamil ton Inc.
WOrk Assignment Project Manager: Kristina Stein
Telephone Number ( 301) 951-4527
Primary Contact : Patricia Tan
Telephone Number (215) 597-3164
Date Prepared : July 21, 1988
: 772
: III
: 3P26
: 68-01-7331
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TAB L E
INTRODUCTION.
II.
. . . . .
. . . . . .
. . . . . .
I.
o F
CON TEN T S
COMMUNITY RELATIONS BACKGROUND
COMMUNITY INTERESTS
. . . . . . . .
A..
. . . ~ . .
. . . . . . . .
Comments on the Proposed Remedy.
B.
Remaininq Concerns
. . . . .
. . . . . . . . . . . .
PAGE
NUMBER
. . . . . 1
. . . 2
. . . 2
. . . 2
. . . 4
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INTRODUCTION
In accordance with the U.S. Environmental Protection Aqency's
. (EPA) Community Relations policy and quidance, the EPA Reqion III
Office held a public comment period to obtain comments on the
recommendations ot the Remedial Investiqation/Feasibility Study
(RI/FS) prepared tor the Palmerton Zinc Supertund site's cinder
bank, Operable Unit 2. The opportunity for a public meetinq was
provided, but no interest was expressed in havinq one. The public
comment period ran trom May 16, 1988 to June 14, 1988. .
The tollowinq responsiveness summary was prepared by Booz,
Allen & Hamilton Inc., a subcontractor to CDM Federal proqrams
Corporation, under contract to Reqion III to provide community
relations support. The community relations backqround section of
the paper summarizes the community relations activities that have
recently taken place at the site. The summary of public comments
was developed from written comments received by Patricia Tan and
Nanci Sinclair durinq the public comment period. The written
comments will be placed in the public record.
1
-------
I.
COMMUNITY RELATIONS BACKGROUND
In meetinq its public outreach responsibilities under the
Superfund proqram, community relations activities at the Palmerton
Zinc Superfund site have been onqoinq. In May 1988, a revised
Community Relations Plan (CRP) was prepared, a Proposed Remedial
Action Plan for the cinder bank was prepared and circulated, a
Public Notice ot the public comment period was printed, and the
opportunity tor a public meetinq was provided. The public comment
period ran from May 16, 1988 to June 14, 1988. In addition to
these activities concerning the cinder bank, a number of community
relations activities have been conducted tor the ot~er operable
units at the site.
II.
COMMUNITY INTERESTS
OVerall, there has been little interest in the cinder bank.
Much of the interest has been directed to Operable Unit 1 and
Operable Unit 3, the Blue Mountain and the Valley, respectively.
During the public comment period on the proposed remedial
action for the cinder bank, EPA received two written comments trom
local residents and a written comment trom the Board ot Supervisors
ot Lower Towamensinq Township. EPA also received one telephone
call trom a concerned local tarmer.
In the letter dated May 18, 1988, a local resident raised
several questions regarding the financial impacts of the remedial
project: the satety ot the drinking water and local ';ardens; and
the use of lime to eliminate the heavy metals, lead, cadmium, and
zinc from the cinder bank runoft.
In the letter dated June 4, 1988, a local resident suggested
that the contamination has spread throughout the tO~1 and that the
only true solution to the contaminated cinder bank is removing it.
This citizen accepts EPA's proposed remedy but does not believe the
remedy vill resolve the entire problem.
In the letter dated June 13, 1988, the Board ot Supervisors ot
Lower Towamensing Township commented on the recyclinq ot materials
on the cinder bank and expressed concern about the transportation
routes by which the revegetation materials tor Blue Mountain will
be transported.
A.
Comments on the Proposed Remedy
Following is a concise summary ot specitic questions and
comments raised by the public on matters relating to '~ne cinder
bank during the comment period.
CO~: The Board ot Supervisors ot Lower Tovamensinq suggested
that EPA has not considered the Board's interests and concerns
regarding the Palmerton Zinc site.
2
-------
EPA'S RESPONSE: On May 3, 1988, EPA met with the Chairman and a
member ot the Board ot Supervisors ot Lower Towamensing Township,
durinq which the proposed remedy tor the cinder bank was
discussed. In addition, the written comments trom the Board of
Supervisors that EPA received during the public comment period were
considered in EPA's decision on the proposed remedy.
COMMENT: The local resident suggested that the real purpose of the
remedial project is two-fold: to remove sewage sludge and fly ash
from Palmerton, Allentown, and Philadelphia, and to bring
additional income to the Palmerton Zinc Company accepting the
sludge and fly ash with pay.
EPA'S RESPONSE: The purpose of the remedial project is to protect
public health and the environment from contamination at the cinder
bank. . Neither of the two factors mentioned above were considered.
EPA is proposing a remedy that involves the treatment of soil with
a mixture of wastewater treatment sludge and fly ash to allow for
vegetation of the cinder bank.
COMMENT: Two local residents raised questions about the safety of
the drinking water. The request was made that the drinking water
be tested, just as the Aquashicola Creek was tested.
EPA'S RESPONSE: Test results of the Borough's drinking water
supply have shown that the quality of the water meets current
drinking water standards. The testing of these wells will
continue.
COMMENT: The local r~sident raised doubts that li.e application
can get rid of the heavy metals, lead, cadmium, and zinc from the
cinder bank runoff.
EPA'S RESPONSE: The application of large amounts of lime
immobilizes the metals by torming low-solubility co.pounds. EPA is
not, however, considering the application ot lime, alone, as a
remedial technology. This technology will be used as a component
ot a .ore comprehensive action aimed at controllinq the runotf.
COMMENT: The local resident wants to know how deep the
contaaination from the runoft has seeped.
EPA'S RESPONSE: The above comment raises questions that will be
addressed in the 8tudies conducted tor Area-Wide Ground Water and
Surtace Water, Operable Unit 4. These studies vill investigate all
possible areas ot contamination.
co~: The local resident wants to knov it the proposed remedy
can neutralize the ettect ot metals.
EPA'S RESPONSE: ' In-Situ Treatment requires treatinq the metal
contaaination with chemicals that reduce their mobility and/or
3
-------
toxicity. With the application ot larqe amounts ot lime, the
metals will be immobilized.
COMMENT: The Board ot Supervisors requested that the proposed
remedy allow non-hazardous materials in the cinder bank to be
available tor recyclinq.
EPA'S RESPONSE: The remedial action is desiqned to prevent the
leachinq ot heavy metals into the river and qround water.
Racyclinq ot non-hazardous material at this time is not consistent
with the qoal ot containinq the heavy metals in the cinder bank.
However, non-hazardous materials at the site not associated with
the cinder bank can potentially be recycled.
COMMENT: Two residents expressed concern about the current
operations ot the East Plant. They tear that the current
operations will contribute additional pollution problems onto the
cinder 'bank.
EPA'S RESPONSE: The cinder bank has been closed as ot December
1987. No additional residues may be placed there.
COMMENT: The local resident suqqested that the comments raised by
area citizens will qo unheeded.
EPA'S RESPONSE: EPA has established the community relations
proqram tor the purpose ot listeninq to and addressinq the public
concerns and interests ot the site communities. Throuqh various
outreach ettorts, includinq this responsiveness summary which will
be entered into the public record, the community relations,proqram
strives to obtain intormation trom the local citizens, provide
intormation to the community, and involve the comaunity throuqhout
the remedial process. EPA interviewed local citizens,and community
leaders in May 1988 to' seek input on their concerns and interests
reqardinq the site.
B.
Remaininq Concerns
Additional concerns were raised durinq the public comment
period that do not relate to the proposed remedy for the cinder
bank. Many ot these concerns will be addressed in the studies and
proposed action for Operable Uni~ 3 and Operable Uni~ 4. Followinq
is a summary ot these remaininq concerns.
CO~: A local area tarmer expre88ed concern abou~ the impac~ ot
the pas~ air emis.ions on hi. tara.
EPA'S RESPONSE: This comm.n~ raise. ques~ions ~~ vill be
addressed in the studies conducted tor Operable CDit 3, the Valley.
CO~: The local resident wants to know EPA's plan. for qrowinq
qrass on the unseeded steep slopes ot Blue Mountain. Only the
4
-------
sliqht slopes are seeded, as reported by this citizen, and these
slopes are brown. This citizen further requests that EPA conduct
an inspection of the already seeded areas.
EPA'S RESPONSE: CUrrently, the reveqetation of Blue Mountain is in
the desiqn staqe. These concerns will be addressed in the near
future. Periodic inspections are performed on the already
veqetated portions.
COMMENT: The local resident raised the question of whether or not
it is. safe to qrow and eat leafy veqetables.
EPA'S RESPONSE: There have been a number of studies concerninq the
safety of eatinq veqetables qrown in the Borouqh's soil, which may
have elevated levels of zinc, cadmium and lead. EPA has previously
deterained that home qrown veqetables are safe to eat based on
qarden studies performed durinq the period of 1985 to 1987.
.
COMMENT: The Board of Supervisors of Lower Towamensinq Township
expressed concern about the transportation routes by which the
reveqetation materials for Blue Mountain will be transported.
EPA'S RESPONSE: The transportation routes and safety plans for
. reveqetatinq Blue Mountain will be developed during the remedial
desiqn staqe.
5
-------
ADDENDUM
Subsequent to the public comment period and in response to an
invitation from the Lower Towamensinq Township Board of
Supervisors, Nanci Sinclair and patricia Tan of EPA's Reqion III
staff attended the regular monthly Township Board meetinq, held on
July 5, 1988. At this meetinq, the remedy for the cinder bank was
discussed. Board members reiterated their concern that the
remedymay exclude materials from recyc1inq, that site information
be made available to area residents, and that transportation routes
be developed in coordination with Township officials. EPA
responded to these concerns and, additionally, informed the Board
that all site-related information is available in the information
respository in the Palmerton Public Library.
-------
C7A
PENNSYLVANIA
~
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg. Pennsylvania 17120
Deputy Secretary 10r
Environmental Protection
717-787-5027
June 30, 1988
Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
Palmerton Superfund Site, Record Of Decision (ROD)
Dear Mr. Wassersug:
The Record Of Decision Declaration for the Palmerton site'
(attached) has been reviewed by the Department. I hereby concur
with the EPA's proposed remedy, with the following conditions:
I
*
EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
The Department will be given the opportunity to concur
with decisions related to the design of the Remedial
Action, to assure compliance with DER design specific
ARARs . .
*
*
The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state law.
It is understood that: (1) the Department waiver of
. specific RCRA requirements, which would be applicable
ARARs in this case, in lieu of an alternative which
attains an equivalent standard of perfor.mance,. is
comparable to the SARA Section 121(d)(4)(D) exemption;
and (2) therefore will not be construed by EPA to be an
inconsistent application c'f a state ARAR pursuant to
SARA Section 121(d)(4)(E) for other remedial actions.
*
-------
*
This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section l04(c)(3).
Thank you for the opportunity to concur with this EPA Record
Of Decision. If you have any questions reqardinq this matter
please do not hesitate to contact me.
i!zr~
flfH: MCC1~llan U-
-------
PAL~RTON ZINC PILE - PHASE II *
ADMINISTRATIVE RECORD **
INDEX OF DOCUMENTS
SITE IDENTIFICATION
Preliminary Assessment and Site Investi~ation Reports
1)
Potential Hazardous Waste Site Investigation and Preliminary Assessment,
5/20/80. P. 1-6.
2) Potential Hazardous Waste Site Investigation, 5/28/80. P. 7-7.
3) Potential Hazardous Waste Site Investigation and Preliminary Assessment,
10/27/80. P. 8-11
4) Potential Hazardous Waste Site Inspection Repo~t, 2/19/81. P. 12-20.
5)
Memorandum to Mr. Joe Donovan, U.S. EPA, from Mr. Kenneth G. Symms,
Ecology and Environment, Inc., re: concerns voiced during a meeting
involving representatives from EPA Headquarters and National Enforcement
Investigations Center (NEIC), 2/12/82. P. 21-25. A letter regarding
cadmium toxicity and a list of the cadmium-related effects in humans
are attached to the memorandum.
6)
Report: Site Inspection/Sampling of New Jersey Zinc Company, Palmerton,
Penns lvania IDD No. FJ-8101-20, prepared by Mr. Stanley Bumble,
Ecology and Environment, Inc., undated). P. 26-72.
7)
Report: A Preliminary Assessment of New Jersey Zinc Company, Palmerton..
Pennsylvania, TDD No. FJ-8007-28, prepared by Ecology and Environment,
Inc., (undated). P. 73-110.
Disposition/NPL Ranking
1)
Potential Hazardou8 Waste Site Tentative Disposition, 5/29/81.
P. 1-3.
*
For further documentation on this site, please refer to the Palmerton
Zinc Pile (Blue Mountain) Administrative Record.
** Administrative Record available 4/25/88.
1
-------
REMED IAL ENFORCEMENT PLANNING
Signed Orders
1 )
Administrative Order by Consent between Horsehead Industries, Inc., and
its Division, The New Jersey Zinc Company, Gulf & Western Industries,
Inc., and the United States Environmental Protection Agency, 9/12/85.
P. 1- 23 .
2
-------
REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Palmerton Zinc Remedial Investigation/Feasibility Study
Oversight for EPA TES III, Work Plan, prepared by COM Federal Programs
Corporation, 5/19/87. P. 1-18.
Remedial Investigation/Feasibility Study Reports
1) Report: Remedial Investigation Report, Volumes 1-7, prepared by the
New Jersey Zinc Company, Palmerton, Pennsylvania, 11/20/87. P. 1-2130.
References are listed on P. 408-410, 1750, and 1855-1856.
-------
COMMUNITY INVOLVEMENT
Community Relations Plans
1)
Report: Palmerton Zinc Superfund Site, Community Relations Planning
for EPA TES III Work Plan, prepared by CDM Federal Programs Corporation,
1/11/88. P. 1-4.
4
-------
16)
17)
GENERAL GUIDANCE DOCUMENTS *
1 )
2)
"Pro.mu1gation of 51 tes from Updates 1-4," Federal Reg:1 ster, dated 6/10/86.
"Proposal of update 4," Federal Register, dated 9/18/85.
3)
Memorandum to U. s. EPA from Mr. Gene Lucero regard1~g community relations
at Superfund Enforcement sites, dated 8/28/85.
4)
Groundwater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
5)
Memorandum to Toxic Waste.Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6)
7)
Guidan~e of Remedial Investigations under CERCLA, dated 6/85.
Guidance on Feasibility Studies under CERCLA, dated 6/85.
8)
9)
"Proposal of Update 3,". Federal Register, dated 4/10/85.
Memorandum to Mr. Jack McGraw entitled "Co~nity Relations Activites
at Superfund Sites - Interim Guidance," .dated 3/22/85.
10)
11 )
"Proposal of Update 2," Federal Register, dated 10/15/84
EPA Groundwater Protection Strategy, dated 9/84.
12)
Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
:.Transm1 t tal at Superfund RelDOval Procedures - Revision 2,'. dated 8/20/84.
13)
"Proposal of Update 1," Federal Register, dated 9/8/83.
14)
Community Relations in Superfund: A Handbook (interim version), daced
9/83..
15)
"Proposal of first National Priority List," Federal Register, dated
12130/82.
"ExpaDded Eligibility List," Federal Register, dated 7/23/82.
"Interim Priorities L1st," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System: A User's Manua1
( undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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