United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/079
September JL9_89
&EPA
Superfund
Record of Decision
Craig Farm Drum, PA
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R03-89/079
2.
3. ReclpIent'a ACC888lon No.
4. Title and SubtiUe
SUPERFUND RECORD OF DECISION
Craig Farm Drum, PA
First Remedial Action - Final
5. Report Date
09/29/89
6.
7. Author(a)
8. Performing Organization RepL No.
9. Performing Orgainization Name and Addre..
10. ProjectlTa8klWork Unit No.
11. C0ntr8ct(C) or Grant(G) No.
(C)
(G)
. 12. Sponeorlng Organiz8tion Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Covered
Agency
800/000
14.
15. SUpplementary Notea
16. Abatract (Umit: 200 worda)
. ~he Craig Farm Drum site covers approximately 117 acres near the village of
Fredericksburg in Armstrong County, Pennsylvania. The area around the site is dominated
by farmland and forest, and a creek crosses the southern portion of the site. The site
consists of two. abandoned strip mine pits which were later used for disposal of
distillation residue containing resorcinol and other high polymers. From 1958 to 1963
the Koppers Chemical Co. disposed of 2,500 tons of resorcinol production residue in
55-gallon drums in the pits. Resorcinol is an organic compound used as an adhesive
enhancer in commercial products such as tires and pharmaceuticals. Investigations in
1984 revealed that the majority of drums were broken or crushed and were without lids.
The primary contaminants of concern affecting the soil and ground water are organics
including benzene and phenol, inorganics, and metals including lead and chromium.
The selected remedial action for this site includes the excavation of 32,000 cubic
yards of soil from the two disposal pits and surrounding area with onsite treatment
using sOlidification; placement of treated soil in a newly excavated and lined onsite
landfill followed by capping; passive collection of ground water using a seep
interceptor system with offsite treatment; and performing a ground water verification
study. The estimated present worth cost for this remedial action is $5,188,000, which
includes estimated annual O&M costs of $124,000 for 30 years.
17. Document Analyala L DescriptO,.
Record of Decision - Craig Farm Drum, PA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: organics (benzene, phenol), inorganics, metals (chromium, lead)
b. Identifiers/Open-Ended Terma
c. COSA TI Reid/Group
18. Availability Statement
19. Security Clus (This Report)
None
21. No. 01 Pages
46
-
20. Security Clua (This Psge)
N()np
22. Price
I
(See ANSI-Z39.18)
See Inatructiona on Reverse
272 (4-77)
(Formerfy NTlS-35)
Department 01 Commerce
-..
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Craig Farm Site, Perry Township, Pennsylvania
Statement of Basis and Purpose
This decision document represents the selected remedial
action for the Craig Farm Site, in Perry Township,
Pennsylvania, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of
1980, as amended by the Superfund Amendments and
~eauthorization Act of 1986 (CERCLA), 42 D.S.C. Section 9601
~~. and to the extent practicable the National
Contingency Plan (NCP), 40 C.F.R. Part 300. This decision is
documented in the contents of the Administrative Record for
this site. The Commonwealth of Pennsylvania concurs with the
. selected remedy.
Assessment6f the Site
Pursuarit to duly delegated authority, I hereby determine
that pursuant to Section 106 of CERCLA, 42 D.S.C. Section
9606, actual or threatened releases of hazardous substances
from this site, if not addressed by implementing the response
. action selected in this Record of Decision (ROD), may present
an imminent and substantial endangerment to the public health,
welfare, or the environment based on the information set
. forth in "Summary of Site. Risks", pages 11-16.
. Description of the Remedy
The selected remedy seeks to prevent site contaminants
from migrating offsite and/or impacting a small creek that
crosses the southern portion of the site (Unnamed Creek). A
landfill will be constructed for disposition of the source
material from the two disposal pits and the surrounding
contaminated soil. The source material will be stabilized/
solidified prior to its placement in the landfill. Contam-
inated ground water will also be collected passively using
two interceptor trenches at seepage points downgradient of
the two pits. The collected ground water will be transported
weekly to an offsite wastewater treatment plant until the
remediation is judged to be complete~.
Additional components of the selected remedy are as
. follows:
After the two pits are excavated, they will be
refilled with uncontaminated soil, and the area will
be covered with enough soil to support vegetation.
A ground water verification study will also be done
to determine whether or not the ground water (both
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2
on- and offsite), not being addressed by the selected
remedy, needs any further remediation. This study
is expected to confirm that the ground water collection
system is working properly, and is adequate to address
all of the contaminated ground water.
Institutional controls, such as utilizing deed notices to
inform property owners about contaminants at the'site,
will also be implemented.
A wetlands delineation will also be done in order to
determine that the proposed location for the landfill
is the appropriate distance from the onsite wetlands.
If the proposed location is found to be too close to
the wetlands, the landfill will be moved to a more
remote area of the site. Potential impacts to the
wetlands will be considered and minimized to the
extent practicable during the design phase of this
project.
A treatability study on the solidification procedure
will be done, and its effectiveness will be evaluated
by the EPA prior to the full-scale remedial action.
Declaration
The selected remedy is prot~ctive of human health and
the environment,attains Federal and State requirements that
are applicable or relevant and appropriate to this remedial
attion, and is cost-effective as set forth in Section 121 of
CERCLA, 42 U.S~C. Section 9621 and Section 300.68 of the
NCP. This remedy satisfies the statutory preference as set
forth in Section l21(b) of CERCLA, 42 U.S.C. Section 962l(b)
for remedies that employ treatment that reduce toxicity,
mobility, or volume of the hazardous substances, pollutants
or contaminants. This remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable. Because this remedy will result in hazardous
substances remaining onsite above health-based levels, a
review will be conducted every five years after commencement
of remedial action in accordance with Section 121(c) of
CERCLA, 42 U.S.C. Section 9621(c) to ensure that the remedy
continues to provide adequate protection of human health and
the environment.
£l£3~
c; ~o/ /rl
Edwin B. Erickson
Regional Administrator
Date
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I
II
III
IV
V
VI
VII
VIII
RECORD OF DECISION
TABLE OF CONTENTS
PAGE
SITE NAME, DESCRIPTION AND LOCATION
1
1
1
4
4
5
A
B
C
D
E
Site Name and Location
Site History
Community Relations
Identification of Operable
Site Characteristics
Units
SUMMARY OF SITE RISKS
11
17
DESCRIPTION OF ALTERNATIVES
COMPARATIVE ANALYSIS OF ALTERNATIVES
23
DESCRIPTION OF THE SELECTED REMEDY
27
APPLICABLE OR RELEV~NT AND APPROPRIATE
REQUIREMENTS
28
35
STATUTORY DETERMINATIONS
RESPONSIVENESS SUMMARY
37
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SUMMARY OF REMEDIAL ALTERNATIVE
SELECTION FOR THE CRAIG FARM SITE
Site Name and Location
The Craig Farm site covers approximately 117 acres, and
is located near the village of Fredericksburg, just inside
the western border of Armstrong County, Pennsylvania. The
borough of Petrolia lies approximately two miles to the west,
and the town of Parker, on the Allegheny River, is about four
miles to the north. The area around the site is dominated by
farmland, and has a population density of approximately 120
persons per square mile.
The site was originally two abandoned strip mine pits
which had worked the Upper Freeport coal seam. As with most
strip mines in the area, the pits were cut into a hillside
beginning where the coal outcropped or subcropped. The pit
walls were formed by the working face (highwall) of the mine
and the spoil piles were deposited away from the working
face.
Site History and Enforcement Activities
The two pits were used for the deposition of distillation
residue from 1958 to 1963 (See Figure 1). The residue was
still bottoms from the production of resorcinol at the Koppers
Chemical plant in Petrolia, PA. Resorcinol, an organic compound
is used as an adhesive enhancer in commercial products, such
as automobile tires and pharmaceuticals. .
At the time when the source material was placed onsite,
the land was owned by Mr. Paul Craig. His brother, Mr. Herman
Craig, hauled the distillation residue from the plant and
placed it in the two pits. Approximately 2,500 tons of
residue contained in 55-gallon drums were deposited at the
site. Near the end of 1971, Koppers purchased 100 of the 117
acre Craig property, which included the pits. In 1985,
Koppers acquired the remaining portion of the Craig property.
Pursuant to Section 105 of CERCLA, 42 U.S.C. Section
9605, the Craig Farm Site was considered for placement on the
National Priorities List (NPL). When the NPL was revised in
December, 1982, the Craig Farm site was ranked 415 out of 418
sites proposed for 'the NPL at that time. On February 25,
1983, Koppers presented to the Pennsylvania Department of
Environmental Resources (PADER) a proposal for a hydrogeo-
logical study of the site. Koppers decided to also undertake
a surface water sampling study, a stream biological study, an
air quality survey, and to incorporate them into the hydro-
geologic investigation resulting in an Environmental Assessment
(EA) of the .ite. The EA was submitted to PADER on October
31, 1983.
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SITE PtOPMTT ftOUMDAftY
KEY
AfVMU/MtK fJIffMr Of OHUtS
SCAtf fffttt
2M
CHA16
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3
On January 19, 1984, the County of Armstrong, Department
of Public Protection prepared an Emergency Preparedness Plan
for the site. On April 23-24, 1984, Koppers undertook an
investigation to determine the approximate extent and
condition of the still bottom residue drums at the site.
Representatives of the PADER were onsite to observe the
investigation. A serIes of fifteen test pits wer~ excavated.
The results of the test pits indicated that the drums were
butted against the highwall of both strip mine cuts, and then
covered. The majority of the drums were broken or crushed
and were without lids.
EPA contracted GCA Corporation to review the Koppers
EA of the Craig Farm site. EPA, with GCA representatives,
visited the site on June 29, 1984, and issued draft comments
on the EA report in August, 1984. On April 1, 1985, the
PACER and EPA offered joint comments on the EA report.
During the fall of 1984, Koppers investigated several
remedial measures, including excavation and recycling of the
residue and onsite and offsite incineration. On August 2~
1985, the PACER requested Koppers to perform a complete
Remedial Investigation and Feasibility Study (RI/FS) of
the Craig Farm site. On November 12, 1985, representatives
of Koppers, PADER, and EPA met to discuss the RI/FS Work Plan
and the EPA and PACER comments on the EA report. It was
agreed at this meeting that as much of the information from
the EA report as possible would be used in the RI/FS develop-
ment. Additional work was required to satisfy RI/FS protocols
which evolved following the preparation of the EA report.
In February, 1986, Keystone Environmental Resources, Inc.
and Remediation Technologies, Inc. began work on the Craig
Farm site RI/FS for Koppers. From September, 1986 through
August, 1987, a biological survey was performed by Keystone
utilizing data obtained from four rounds of sampling at the
Craig Farm site. From October, 1986 through June, 1987, a
biota survey was performed by Keystone utilizing data obtained
from two rounds of sampling (Fall, 1986, and Spring, 1987) at
the Craig Farm site. From November, 1986 through August, 1987,
Keystone performed six rounds of sampling to characterize
the surface water and sediments at the site.
From December, 1986 through November, 1987, Keystone
performed four rounds of sampling to characterize the
ground water at the site. On February 10 1987, Koppers
Company, Inc. signed a Consent Order and Agreement with
PACER to perform a RI/FS of the site.
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4
In May, 1988, the EPA and PADER requested that five
additional wells be installed to further delineate the
ground water contamination. These wells were installed in
November, 1988.
On January 20, 1989, BNS Acquisitions merged into
Koppers, and on January 26, 1989, the name of Koppers was
changed to Beazer Materials and Services, Inc. (Beazer).
In April, 1989, the Draft Remedial Investigation (RI)
was submitted to the State and the EPA. The Revised RI was
submitted in August, 1989. The Draft Feasibility Study (FS)
was submitted in July, 1989, and the Revised FS was
submitted in August, 1989.
A Special Notice Letter, granting
to make a good faith offer pursuant to
CERCLA, 42 U.S.C. Section 9622(e), was
Beazer on August 24, 1989.
Beazer the opportunity
Section l22(e) of.
sent by the EPA to
Community Relations
On April 7, 1987, PADER conducted a public meeting to
announce the start of the RI/FS at Craig Farm. The RI/FS and
the Proposed Plan for the Craig Farm Site were released to
the public in August, 1989. These two documents were made
available to the public in the administrative record file and
an information repository maintained at the EPA in Region III
and in the administrative offices of the Karns City Area
High School in Karns City, Pennsylvania.
The notice of availability for these two documents was
published in the Butler Eagle on August 25, 1989. A public
comment period was held from August 25, 1989 through
September 25, 1989. In addition, a public meeting was held
on September 13, 1989. At this meeting, representatives from
EPA and PADER answered questions about problems at the site
and the remedial alternatives under consideration. The only
written comments received during the public comment period
were in a letter from Beazer, a copy of which is attached.
The Responsiveness Summary is based on oral comments received
during the public meeting and on the written comments. The
above actions satisfy the requirements of Section l13(k) and
117 of CERCLA, 42 U.S.C. Section 96l3(k) and 9617.
Identification of Operable Units
The Craig Farm Site has been divided into three operable
units:
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5
1.
Operable Unit #1
Operable Unit #1 is the distillation residue
material in each pit area and the adjacent contaminated
soils. Contaminated soils are defined as those soils
determined analytically to contain detectable amounts of
resorcinol. The detection limit for resorcinol in soils
is approximately 50 parts per million.
2.
Operable Unit #2
Operable Unit #2 is the remaining portion
pit area not defined as Operable Unit #1 material,
overburden and adjoining soils that are determined
analytically to be clean.
of each
mainly
3.
Operable Unit #3
Operable Unit #3 includes Seeps A and B (see Figure
il)which are downgradient locations where seeps containing
contaminated ground water are discharging.
Operable Unit #2 is uncontaminated soil that is
considered an operable unit merely because it must be moved
to get to the underlying contaminated soils and source
materials. However, Operable Unit #2, by definition, contains
only clean soils and therefore, will not be discussed in the
analysis of treatment alternatives. The operable unit does
contain any contaminated soils that would require any
remediation. .
A ground water verification study will be done to
determine whether or not the ground water (both pn and off-
site), not being addressed in this RO~, needs any further
remediation. If additional ground water remediation is
required, it will be considered a separate operable unit,
and will be addressed in a subsequent ROD for this site.
Site Characteristics
A.
Topography
The area around the site is farmland and forest, with
surface mining operations throughout the area. The site is a
small steep hillside with an average gradient of 1.43 ft/ft.
Strip mining activities have created two separate highwalls
with the bottom of the pits at an elevation of 1400 feet
(mean sea level). The topography of the site area is
characterized by a dendritic drainage pattern with good
surface water drainage throughout the watersheds.
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6
B.
Land Use
Current figures show that approximately 28 percent of
Armstrong County is farmland, 52 percent is forest, and 20
percent other. The area around the site, including the
village of Fredericksburg, is dominated by farmland. Strip
mining is also conducted in the surrounding area.
The site is not used for any commercial or residential
purposes, although it could be used for recreational purposes
after remediation. Due to the steepness of the topography
and remoteness of the site, future commercial or residential
development may be limited.
C.
Hydrology
Surface water on the site consists of several seepage
ditches emanating from the former pits, and the Unnamed
Creek. Drainage, via hillside runoff and the seepage
ditches, flows from the site into Unnamed Creek, which in
turn flows southeast and discharges into Valley Run,
approximately one mile from the site. Valley Run flows
northeast for approximately one and a half miles and
discharges into the Allegheny River. The seepage ditches
are actually small erosion channels which have formed via
hillside runoff. The seeps drain into one of these two
channels.
D.
Wildlife
Faunal species have been noted at the site during
various field investigations and include: several species of
small mammals (rabbits, squirrels, chipmunks, etc); various
species of birds, deer, and bear. These animal species are
commonly found in woodland habitats. Vegetation identified
as part of the biota investigation include: numerous
herbaceous species and several woody species in various
stages of growth (seedlings, saplings and mature trees).
E.
Hydrogeology
Ground water at the site occurs under water table
conditions in the unconsolidated zone and under confined
conditions in the upper bedrock and lower sandstone aquifers.
Portions of the unconsolidated materials are water bearing.
The interval from below the Upper Freeport Coal to the top of
the lower sandstone unit has been collectively designated as
the upper bedrock aquifer, although this unit is not a good
water producing zone. Most water produced in this unit is
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7
present around the Lower Freeport Coal seam. Water level
measurements indicate that the flow in the upper bedrock
aquifer is to the west toward Unnamed Creek. The other
water producing zone beneath the site has been designated as
the lower sandstone bedrock which occurs beneath the Lower
Freeport Coal, at an approximate elevation of 1300 feet. The
ground water flow within the lower sandstone is to the south
and southwest toward the valley bottom.
Water level contours for the unconsolidated materials
indicate the water table surface resembles, and usually
mimics, the topography. Flow lines indicate that ground water
migrates toward the stream valley, as expected. The contours
near the southern portion of the site, tend to swing toward
the east, which indicates that the seepage stream gully and
the topographic slope toward the former Craig property,
influence the ground water flow in this area.
Downslope from the two pits, the unconsolidated material
thins out near the 1350 elevation. This is also the
approximate elevation where many of the hillside seeps occur.
This indicates that the ground water flows through the
unconsolidated materials and along the shale contact, until
discharging on to the hillside.
F.
Nature and Extent of Contamination
The distillation residue deposited in the two pits
contains resorcinol and other higher polymers. The
distillation residue is a waste created in the production of
resorcinol, and its composition has been analyzed. The waste
is a CERCLA hazardous substance, but it is not a Resource
Conservation and Recovery Act (RCRA) hazardous waste. The
composition of the waste is as follows: .
Resorcinol
Dihydroxydiphenyls
Trihydroxydiphenyls
higher polymers
(DHD)
(THD)
5-10%
20-25%
30-35%
30-35%
The chemical structure of the compounds is illustrated in
Figure 2.
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8
FIGURE
2
CHEMICAL STRUCTURES OF PHENOL, RESORCINOL, DHD, THD,
and RELATED HIGHER MOLECULAR WEIGHT POL~MERS
OH
@
PJ.lc NOL
I
3~4 - Of}-l 'fDRO XYO( Pk £ NY L
0@J
OH
OH
RESORCINOL
OH
OH
,
2~3~4- rRIHYDROXYDI PJ.I£NYL
OH
I
".1..
"
QH
HI GHER MOL£CULA~ W!/6HT POL YMERS
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9
Test pits dug into the two pits showed that the residue
ranged from black or pink semi-solid material to hardened
chunks. The northern pit encompasses 1.2-1.5 acres and the
southern pit encompasses approximately 0.8-1.0 acre. Analyti-
cal data also indicate that the source material in the pits
is most concentrated from 2.5-6.0 feet below the surface.
Contaminated soil exists near the two pits, especially down-
slope of these two areas.
The water quality data obtained from the RI has been
used to refine interpretations regarding the horizontal and
vertical extent of degraded ground water at the Craig Farm
site. Generalized boundary maps for the unconsolidated
materials zone, upper bedrock aquifer, and lower sandstone
aquifer are based on the detection of one or more of the
process-related organic indicator parameters in penetrating
those respective monitoring intervals. The chemical constit-
uents associated with the former site activities are present
in ground water in each of the three geologic intervals
described above.
Within the unconsolidated materials zone, the degraded
ground water appears to extend beneath most of the site. Due
to the thinning of this zone below the pits, ground water
moves along the top of the shale and discharges to the surface
at an approximate elevation of 1340 ft. Because the Unnamed
Creek represents the local discharge point for the unconsol-
dated materials zone, the limit of the impacted ground water
is thought to be to the west by Unnamed Creek.
Within the upper bedrock aquifer unit, the degraded
ground water appears to extend beneath most of the study
area. Ground water moves through the shale and discharges
along the position of the Lower Freeport Coal seam. Because
the Unnamed Creek and the topographic position represent the
local discharge point for the upper bedrock aquifer, the
limit of the impacted ground water is thought to be to the
west by Unnamed Creek. .
Within the lower sandstone aquifer unit, the degraded
ground water extends from the area of the two pits to an area
immediately east of the Unnamed Creek valley bottom.
Ground water movement in this unit is influenced by migration
of ground water from above the Lower Freeport Coal seam, as
well as through regional ground water discharge toward the
valley bottom. .
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10
G.
Biological Findings
From September, 1986 through August, 1987 a biological
survey was performed to determine the effects, if any, of
potential constituents of concern on aquatic biota. The
study found that macroinvertebrate communities located down-
gradient of the site did exhibit signs of stress. The stress
was characterized by a lack of macro invertebrates species
that are indicators of good water quality. Statistical
correlations indicate that, of the process-related
constituents, trihydroxydiphenyl (THD) concentration has
the greatest impact on macroinvertebrates. Chemical analyses
of crayfish tissue determined that no bioaccumulation of any
PCOC could be detected. There also were no indications of
any biomagnification of any site-related compound.
There was no stress detected in the fish community in
Valley Run, and the impacted macroinvertebrate community
tested appear to recover within 1 mile of the confluence of
the Unnamed Creek with Valley Run.
H.
Air Monitoring Findings
In August and September, 1987, an air monitoring survey
was performed at the site to determine the air quality in
,regards to the source material and several other compounds on
the Hazardous Substance List. The air survey determined that
the constituents of concern were not impacting the air quality
at the site. Field sampling was conducted in accordance with
a RI/FS Air Monitoring Work Plan. The results of this study
were that the site in its present condition poses no health
threat via air transport of site-related compounds.
- .
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11
SUMMARY OF SITE RISKS
Potential Contaminants of Concern
Soils, ground water, surface water and sediments, and
ambient air were analyzed for various priority pollutant
organics and metals as well as process-related constituents.
Based on the analytical results and the above criteria, the
following organic and inorganic constituents have been
selected as potential contaminants of concern (PCOCs):
Orqanics:
Inorganics:
o resorcinol 0
o trihydroxydiphenyl (THD) 0
o meta-phenolsulfonic acid (m-PSA) 0
o para-phenolsulfonic acid (p-PSA) 0
o benzene sulfonic acid (BSA) 0
o benzene meta disulfonic acid (BlmSA)
o benzene
o phenol
cadmium
chromium
copper
lead
zinc
This list of organic PCOCs, excluding benzene, are process-
related constituents. Although other priority pollutant
organics were detected in one round of surface water sampling,
they were not selected as PCOCs since the final round of
sampling determined the concentrations to be below the limits
of detection. The priority pollutant metals selected as
PCOCs are not process-related constituents. However, they were
detected at levels greater than typical background levels for
the media in which they were measured. Cadmium was the only
metal detected above background levels in the soil. The
other metals were detected in the ground water. It should be
noted that the above set of PCOCs.were not necessarily detected
in each of the media of interest. Table 1 lists PCOCs in
each of the areas of interest.
Toxicoloqical Profiles
Toxicological data on the majority of the PCOCs
identified at the site, i.e. the process-related constituents
- resorcinol, THD, DHD, m-PSA, p-PSA, BMDSA, and BSA,
is either scarce or absent. Resorcinol, for which some
toxicological data is available, was used as the representa-
tive for all of these related compounds based on the similarity
of their chemical structures. Resorcinol is moderately toxic,
but it is not presently considered a carcinogen.
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RETAINm PO'I'EN11AL HUMAN EXPOSURE PA11IWAYS
.... C.... - 8da11114'Ne1 8d818c4....
-- W..... 1'84_A.~. 8.. 1- o..lII8dwe A""'" reoc.
3Ce W.ler Current- =- Reaalion8l Uten- Not Retained - No rcoc. None in Valley Run
_iRlf'" VaIeJ Run 0nIr W8den .. Valley R..
_ilk RT" ....Iion bait see'en
Future s..e. AIIowe Sa.. .. Abowe Same .. Above None in Valley Run
'-"'ter CurreRI No8e
--
4 S:ria
_I ) raon:inol.11tD. .-PSA"
Fut..e Da8aI Hypotlle8ic81 Flllure Retained P:~ BMDSA,
IrL-"trIN ..... = ft::CI = ,.:cnzeRe.
I............
cadmium. chromium.
copper
mea Future De...1 Oft-Site Do8et8ic Re88ined
1 Oldy) .......ion We"u.en Not Re88i8al- Not Voialile based
.. .~RI air rauIU relOr~ m-PSA,
Incide.....l...ion Re88ined ~A, iD. pheaol,
A, c:actmium.
chrORllUll\ curper
lead. zinc
Ci8I~ Current DeI88l Trapetwn Retained resorcinol. 1110. rn-PSA.
'-o8kr .......... Not RetaiRed- b8Ied p-PSA, c:edmium
6; on aft111ie88 air moaiIorint ra"'"
Dill) Incide"'" "",ion RcC8illed
Future SallIe .. Above Sa.. .. Abowe Same .. Abcwc: Same .. Above
-p Soils Currenl None
tier Soils
)
Fulure Dermal HJP.08helic81 Fulure Not Relained-Slrip Mined
Inhalalion menen Not Relained-Slrip Mined
lneidenlallnseslion Nul Rel.ined-Slrip Mined
Table 1
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13
The Registry of Toxic Effects and ~hemical Substances lists
the oral lethal dose of resorcinol in rats as 301 mg/kg.
Benzene is the only known carcinogen that is a PCOC at this
site, and it is present only at low levels in the soils and
ground water.
Potential Miqration Routes
An exposure pathway usually involves the transport of
chemicals through an environmental medium or from one
environmental medium to another. At the site, migration of
PCOCs could potentially occur via movement through surface
water, sediments, ground water, soil, or ambient air.
The analysis of surface water (i.e. Seeps A & B, Unnamed
Creek, and Valley Run) resulted in detectable concentrations
of several" of the PCOCs in both Unnamed Creek and the seeps.
However, these same constituents were below detection limits
in Valley Run which is the body of surface water most likely
to be used by potential receptors. .Therefore, surface water
was not considered as a significant migration route for"
PCOCs, because of the lack of a receptor. Analysis of the
PCOCs in sediments resulted in 1) levels below limits of
detection (resorcinol, m-PSA, BSA, BMDSA), 2) detectable
concentrations in only one sampling round (THO), or 3) levels
similar to controls (benzene). These results indicate that
sediments do not provide a significant migration route for
the PCOCs. " "
Surficial soil samples taken from test pits 0 to 2 feet
in depth and from the strip mine pits resulted in detectable
concentrations of resorcinol, THO, m-PSA, p-PSA and cadmium.
Therefore, surficial soils and deeper soils may be potential
migration routes. Based on analytical results, ground water
is also a migration route for all of the PCOCs.
With respect to ambient air samples, the PCOCs were
either below detection limits, or in the case of benzene,
were equivalent to typical U.S. rural background levels.
Therefore, the transport of PCOCs through ambient air will
not be considered further as a potential migration route at
the site.
Potential Human Exposure Pathways
In the identification and evaluation of potential
ex?osure pathways, potential current and potential future
uses of the site were considered. The area currently is
restricted from recreational use. Hypothetical future uses
were determined based on the typography and current demo-
graphic use of the surrounding area. The steepness of the
hillside on which the site is located and its remoteness
may preclude future commercial or residential development.
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14
Therefore, future occupants or construction workers will
not be considered. Potential future use of the site for
mining, an activity that has occurred on the site and is
currently being practiced in the surrounding area, is
utilized as the human exposure pathway for the risk
calculations.
Potential Environmental Exposure Pathways
Surface water and sediments from Unnamed Creek, soil on
the site, and sediments in Valley Run could provide potential
environmental exposure pathways. Wildlife could be exposed
to site-related contamination by coming in contact with the
seeps on the hillside downgradient from the two pits.
Terrestrial species inhabiting the site, which is
primarily wooded, include deer, rabbits, squirrels and other
mammalian species. Amphibious species (i.e. turtles, frogs,
salamanders) also inhabit areas of the site. Aquatic
organisms that could inhabit Valley Run and Unnamed Creek
include invertebrates and fish.
The lack of benthic macroinvertebrates and fish in Unnamed
Creek indicates that PCOCs in the stream are impacting aquatic
life.
Risk Characterization
An exposure assessment and risk characterization was
carried out for the following exposure pathways: 1)
incidental ingestion and dermal absorption of PCOCs in
surficial soils by trespassers~ 2) dermal absorption of PCOCs
in gro~nd water by hypothetical future miners~ and 3)
incidental ingestion and dermal absorption of PCOCs in
ground water by future offsite domestic well users.
The maximum concentration of resorcinol, THD, and DHD
found in soils were 1400 mg/kg, 11,500 mg/kg, and 250 mg/kg,
respectively. BSA had a maximum concentration of 700 mg/kg,
m-PSA had a maximum of 320 mg/kg, and the highest level of
p-PSA was 2250 mg/kg. The highest level of benzene found
in the soils was 7.8 mg/kg. The levels of PCOCs in the
ground water are listed in Table 2.
The PCOCs for each receptor group varied according to
predicted usage patterns, i.e. potential trespasser exposure
to surficial soils, potential exposure of hypothetical future
miners to ground water in the uppermost bedrock unit and the
lower sandstone unit, and potential future domestic well
usage of ground water from the lower sandstone unit.
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15
TABLE 2
GEOMETRIC MEAN CONCENTRATION RANGES OF
PCOCs IN GROUNDWATER
Frequency of
Compound (mg/1) Level Detection Range (mg/l)
BSA A 4/9 <25 - 70.5
( < 25) B 9/19 <25 - 74.4
C 3/12 <25 - 29.7
B~1DSA A 2/9 <25 - 19.2
«25) B 5/9 0N~11) 122
C 0/12
m-PSA A 6/9 <25 - 96.7
«25) B 7/19 <25 - 183
C 1/12 <25 - 345
p-PSA A 8/9 <25 - 721
«25) B 7/19 <25 - 1063
C 4/12 <25 - 811
Benzene (ug/L) A 6/9 <1.0 - 2.55
«1) B 6/19 <1. 0 - 3.71
C 5/12 <1.0 - 1.6
Phenol A 9/9 0.05 - 0.86
«5) B 13/19 <0.005 - 0.71
C 9/12 <0.005 0.27
Resorcinol A 8/9 <5.0 - 878
«5) B 9/19 <5.0 - 872
C 5/12 <5.0 - 465
THD A 9/9 7.67 - 2453
«0.5) B 11/19 <5.0 - 2455
C 6/12 <5.0 - 1435
NOTES:
(l)Not detected in any samplin~ round.
<-indicates detection limit. .
All concentrations in mg/L unless otherwise noted.
Level Ais the shallow wells, Level B is medium-depth
and Level C is the deep wells.
wells,
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16
Hazard indices and/or risk calculations were calculated
for each of these receptor groups and are as follows:
o
The total hazard index for trespassers, the sum of
the hazard ~ndices for incidental ingestion
(3.28 x 10- ) and dermal absorption from soil
(0.07), is 0.07.
o
The total hazard index for hypothetical future
miners'for dermal absorption from ground water is
0.43 and the e~cess individual lifetime cancer risk
is 1.39 x 10- .
o
The total hazard index for future offsite domestic
well-users, the sum of the hazard indices for
incidental ingestion (0.63) a~d dermal absorption
from ground water (1.39 x 10-) is 0.63.
The total hazard indices calculated for trespassers,
hypothetiqal future miners and future offsite domestic
well users were all less than 1. A hazard index of 1 or
less indicates that the estimated intakes are less than the
threshold intake levels and that there is no appreciable
risk of adverse health effects.
The cancer risk to future miners is based on potential
exposure of future miners to benzene in the ground water.
The potential excess individual lifetime cancer ris~ calcu-
lated for hypothetical future miners was 1.39 x 10- which
is lower than the_~pper b~~nd of the range recommended by
the U.S.EPA of 10 to 10 .
The human health threat presented by this site is
negligible in as much as there are no human receptors
onsite, or immediately adjacent to the site at this time.
The site is presently having an impact on Unnamed Creek
and the onsite wetlands as well as the organisms living
in these communities. Thus, the selection of the remedy is
based on the site's impact on the environment rather than on
a risk to human health. As described above, the site does
present an imminent and substantial endangerment to the
environment as set forth in Section 106 of CERCLA, 42 U.S.C.
Section 9606.
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17
DESCRIPTION OF ALTERNATIVES
A number of alternatives were developed to meet the
following remedial action goals:
- minimize risk to -the public health and environment
from direct contact with contaminated material
- control the migration of contaminants into nearby
surface waters
- control the migration of contaminants into ground
water
OPERABLE UNIT '1 (OU1) - The source material in the two
pit areas and the adjacent contaminated soils.
Alternative 1: No Action
This alternative provides the baseline or reference
point against which each of the operable unit alternatives
are compared. If the other selecte~ alternatives do not
offer substantial benefits in reduction of toxicity, mobility,
or volume, then the No Action alternative may be considered a
feasible approach. - .
The No Action alternative would consist of continued
monitoring of Unnamed Creek and the ground water, as well as
potential deed notices. Monitoring of Unnamed Creek and the
ground water would consist of monitoring for PCOCs on a semi-
annual basis. The semi-annual monitoring would be implemented
to determine the potential effects, if any, on the creek and
ground water, and would be assumed to continue for a 30-year
period. The monitoring would consist of the collection and
analysis of 16 groundwater samples and 5 surface water samples.
Institutional controls utilizing deed notices would be
implemented to inform property owners about the PCOCs at the
site. Fences would also be erected around the two pit areas.
Monitoring would require a two-man field crew spending
approximately 8 days each year. The Operation and Maintenance
(O&M) costs for this alternative are estimated as $49,000 per
year which includes sampling and analysis, administration
costs, and labor. Assuming a 5% interest rate and a projected
30-year monitoring period, the associated present worth of
this alternative has been estimated to be $817,000.
Alternative 2A:
Slurry Walls with Impermeable Cap
This alternative provides for installing upgradient
slurry walls and surface capping the OU1 areas with low
permeability material. Low permeability caps would be con-
tructed over the OUI areas to substantially reduce migration
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18
of PCOCs to Unnamed Creek. The surface cap would consist of
a relatively impermeable soil layer, a synthetic membrane
liner, a conducting zone, cover soil, and top soil with a
vegetative cover.
The capped area would be graded to achieve the required
surface drainage patterns, and compacted to provide a stable
subgrade for cap construction. After the ini~ial'surface
preparation work, the relatively impermeable barrier soil
layer would be constructed. This layer would consist of
two feet of either remolded natural clay or soil with clay
(bentonite) additives. A High Density Polyethylene (HOPE)
synthetic membrane liner would be installed over the barrier
soil layer. Above the 50 mil synthetic membrane, a one-foot
thick conducting zone would be constructed of granular
material and would intercept infiltrating water, and direct
it to the perimeter of the cap for discharge into surface
drainage facilities. Above the conducting zone, two feet of
soil cover would be placed for frost protection. The cap
construction would be completed with a six-inch topsoil layer
and the entire capped area, as well as'adjacent disturbed
areas, would be seeded and mulched for long-term erosion'
control.
To divert the ground water around the OUI areas, a slurry
trench of approximately 600 linear feet would be installed on
the upgradient side of both the northern and southern pits.
The slurry trench would be founded into the shale layer,
which is approximately 15 feet below surface, and the width
of the trench would be at least 24 inches. The slurry wall
would be constructed using a soil/bentonite clay mixture.
The trench would be excavated using special backhoes and the
slurry material would be mixed and backfilled using a bulldozer.
This alternative would take four months to complete.
The capital cost for this alternative is estimated to be
approximately $1,280,000, and the associated O&M costs are
approiimately $49,000. The total present worth of this
alternative is, therefore, about $2,033,000, assuming a 30-
year period at 5% interest.
Alternative 28: Slurry Walls, In-Situ Solidification/Fixation
Treatment, Capping
This ,alternative provides for sOlidificatton/~ixati~n
treatment of OUI material, installing upgradient slurry walls
and surface capping the OUI areas with low permeability
material. OUI material would be chemically treated and low
permeability caps with slurry walls would be constructed over
the OU1 areas to substantially reduce migration of PCOCs to
Unnamed Creek. The surface cap and slurry walls would be
identical to those discussed in alternative 2A.
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In-situ chemical treatment of OUI material would be
performed by injecting reagent into the sub-surface area and
mixing the reagent in place with the OUI material. The
equipment used for subsurface stabilization is similar to
typical augering equipment with specialized bits. The
treatment area would be divided into blocks for treatment
with approximately 10% overlap of the treatment blocks to
ensure complete treatment of the entire OUI area. The
volume of material to be solidified/fixed is expected to
be 5,000 cubic yards. It would be necessary to perform
treatability testing to determine the reagents that would
be best suited for stabilizing OUI material before this
alternative could be implemented.
This option would take approximately 6 months to
complete. The capital cost for this alternative is estimated
to be about $2,717,500. The O&M costs associated with the
alternative are estimated to be $49,OOO/year. The total
present worth of the excavation and landfill alternative
is, therefore, about $3,471,000, assuming a 30-year period and
a 5% interest rate.
Alternative 3A:
Excavation with Onsite Landfill
This alternative provides for the complete excavation of
OUI material and onsite landfilling. The excavated material
would be placed onsite in a secure landfill (1.5-2.0 acres)
located in the immediate area between the two existing pit
areas. Typical construction equipment would be used for
landfill construction and loading. The landfill would be
lined with a two-foot clay barrier, and two layers of HDPE
liner with filter fabric on each side. A one-foot leak
detection zone would be placed above the secondary liner,
and a one-foot thick seepage collection zone would be placed
above the primary liner. Impacted soil would be compacted
and placed on the liner to a depth of about 12 feet. After
all impacted soil has been placed in the landfill, a cap
would be constructed over the landfill. The cap would be
composed of a two-foot clay barrier, one layer of HDPE liner,
a one-foot drainage layer, and two feet of cover soil. After
the cap is constructed, the area would be vegetated for erosion
control.
This alternative would take approximately 5 months to
complete" The capi tal cost for this option is estimated to
be about $2,309,000. The maintenance costs associated with
it are about $49,OOO/year. The total present worth of the
excavation and landfill alternative is, therefore, about
$3,062,000 assuming a 30-year period and a 5% interest rate.
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Alternative 3B:
Qnsite Landfill
Excavation with Solidification/Fixation Treatment
This alternative provides for the complete excavation of QUI
material, solidification/fixation of the source material using .
fixing agents ~nd landfilling of all QUI material onsite. The
method of excavation and landfilling would be identical to
that discussed for Alternative 3A; however the source material
will be solidified before landfilling. Solidification/fixation
treatment of QUI material (5,000 cubic yards) would be performed
by one of two methods. The simplest method would be to mix.
an appropriate reagent with the material using typical excavating
equipment such as a bulldozer or backhoe. The second possible
method would include excavating the source material and mixing
it with an apppropriate reagent in a pug mill. After solidifi-
cation, the material would be transported to the onsite
landfill. It would be necessary to perform treatability
testing to determine the reagent that would be best suited for
stabilizing the material before this alternative could be
implemented. Some fixing agents react chemically with the
waste material and thus change the chemical make-up of the
resultant solid. Other solidifying agents have only a physical
reaction, and merely encase the waste in a solid mixture.
A solidification that involves a chemical reaction would be
preferable because the toxicity of the waste material is
reduced in the process. The effectiveness of the solidifi-
cation procedure would also be evaluated during the treatability
study by using the TCLP method (EPA Method 1311, 53FR18792,
May 24, 1988). -
This alternative would take six months to complete. The
capital cost for this alternative is estimated to be about
$3,053,750. The O&M costs associated with the alternative
are estimated to be $49,000/year. The total present worth of
this alternative is about $3,807,000 assuming a 30-year period
and a 5% interest rate.
Alternative 3C: Excavation and Solidification/Fixation
Treatment with Offsite Landfill
This alternative provides for complete excavation and
solidification of all QUI material and disposal at an offsite
landfill. The method of excavation would be identical to
that discussed for Alternative 3A and solidification/fixation
treatment would be identical to that described for Alter-
native 3B. The materials would be removed and placed in a
secure offsite landfill. Dump trucks with a capacity of 16
cubic yards would be employed. The transportation would
be performed by licensed haulers, and appropriate regulations
would be met for the transportation of these types of wastes.
About 2,490 truck loads (@ 13 cubic yards/truck) would be
required to transport this material to the landfill.
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21
. ..
. .
The excavated material would be taken to a. licansed
facility permitted to handle these materi~ls in a secure
landfill. The facility would have appropriate. state and
federal permits to receive these materials. This' alternative
would take 6 months to complate. The total ~resent worth
for this alternative is about $23,168,750 assuming a 30-~ear
period and a 5% interest rate.. . ..
Alternative 4A:
Excavation with Onsite Incineration.
This alternative deals with complete excavation of OUI
material and then incineration in a onsite incineration.. .
unit. For the purposes of this evaluation, the incineration
equipment is assumed to be a rental unit, and the estimated.
volume of material to be treated is about 32,300 cubic yards~
The onsite incineration equipment would consist ofa.
primary oxidation chamber which would heat the OUI material
to be treated to an operating temperature of 1,5000F to
2,0000F, which is sufficient to drive the PCOCs from the. :
m~terial, and initiate their thermal destruction. Secondary'
chamber exhaust is processed through a heat exchanger to
reduce the heat content of the gas stream. Heat may be re-
covered in the form of steam or preheated combustion air.. .
The cooled gas is treated for particulate matter removal and; .
where required, acid gases are reduced through a wet scrubbihg
technology. . . ..
The treating capacity of the incineration process would
be approximately 50 to 100 tons per day. It is estimated to'
take 24 to 48 months based on the 50 to 100 tons per day ra.te
to incinerate the 32,300 cubic yards. After incineration and
destruction of the constituents in the excavated materials,
inert ash may be replaced in the excavated zones of the site.
Analysis of the ash during laboratory testing for comparison
to EPA Toxicity Criteria indicated that ash from incineration
of the Craig Farm waste material is inert and non-toxic.
Soils for backfilling and placing a soil cover over the
excavated areas will be obtained onsite. Spreading and
compacting backfill material will be achieved using a medlum-
sized dozer and self-propelled compactor. This alternative
would be completed within 4 years. Total capital cost for. .
the excavation and onsite incineration alternative is approx-
imately $13,471,00. O&M costs associated with this option
are $49,000, therefore, the total present worth for Alternative
4A is $14,224,000 assuming l 30-year period and a 5% interest
rate.
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Operable Unit 13 (OU3) -
disposal pits.
Seeps A & B downgradient of the two
In the preliminary screening of alternatives for OU3, it
was determined that the "aquifer supplying these seeps was not
very productive. Therefore, an active collection and treatment
option, such as a recovery well connected to an air stripper,
was not feasible for this operable unit, and was elimi-
nated in the preliminary screening. The alternatives that
were determined to be feasible for Operable Unit '3 are as
follows: "
Alternative lA:
No Action
This alternative would entail no action regarding the
two seeps which are downgradient of the two disposal pits.
There would be no cost associated with this alternative as
it would not involve monitoring of the seeps.
Alternative 2A:
Treatment
Seep Interceptor System and Offsite
This alternative provides for collection of OU3 water
using an interceptor system and transporting it offsite to a
treatment system that is capable of handling wastewater
of this type. This wastewater collection will continue
indefinitely until the remediation is judged complete. The
judgement about the completeness of the remediation will be
done by periodically analyzing the water quality and toxicity
of the wastewater using a bioassay test for resorcinol
approved by the EPA.
Collection trenches would be installed perpendicular to
the slope several feet above the location where Seeps A and B
appear on the hill side. The trench would be constructed
using conventional construction equipment. Each trench would
be approximately 20 feet long, 5 feet deep, and 2 feet wide.
The exact size of the trenches will be determined during
remedial design. The trenches would be sloped to one side
and a conducting zone composed of gravel and perforated pipe
would be placed in the trenches, to collect the OU3 water and
channel it to the sump located on the low side of the trench.
A sump pump with level control would pump the water to a
40,000gallon tank providing a minimum of 10 days storage
capacity. A pump truck would collect the water once each
week and deliver it to the system at an offsite treatment
plant. Total capital cost for this alternative is approxi-
mately $228,000. O&M costs associated with this option ar~
$75,000, therefore, the total present worth for the alternative
is $1,381,000 assuming a 30-year period and a 5% interest
rate. .
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COMPARATIVE ANALYSIS OF ALTERNATIVES
In evaluating remedial alternatives, EPA evaluates nine
specific criteria. The criteria are explained and briefly.
summarized in Table 3. The following section describes the
nine evaluation criteria and how each of the alternatives
compare according to each of these criteria. The. criteria
are analyzed first for OU1, and then for OU3.
1 ) .
Overall Protection of Human Health and the Environment
OU1
The site's main impact is on the environment1 its impact
on human health is negligible. Excavation with onsite
incineration would reduce or eliminate the potential adverse
impact on Unnamed Creek and the surrounding wetlands. Based
on treatability testing, the ash would be of quality suitable
for re-incorporation on the site. Alternative 3C would also
reduce the adverse impact on the environment. The material
would be placed offsite, so that future remediation is
unlikely. Solidification treatment and onsite landfill
would also reduce or eliminate the adverse impact to the
nearby environment. However, this remedy would not eliminate
the possibility of future remediation if the liner or cap
failed and the solidification process failed. The remaining
alternatives (2A,2B,3A) would be even more likely to require
further remediation.
OU3
Collection of the OU3 water, and transporting it offsite
reduces PCOC migration by decreasing PCOC concentrations at
the site.
2 ) .
Compliance With ARARs
OU1
All of the alternatives would meet ARARs, and no waivers
would be required. The waste material is a CERCLA hazardous
substance, but it is not a RCRA hazardous waste. Certain RCRA
regulations, specified in Table 7, although not applicable,
are relevant and appropriate. The onsite landfi1ling alter-
natives would have to meet RCRA design standards for landfills.
The incinerator option would have to meet RCRA requirements
regarding incinerators. The offsite 1andfi1ling option would
have to meet Hazardous Materials Transportation regulations.
RCRA Closure and Post-Closure would require deed notic-s and
long-term monitoring. The Executive Order on Protection of
Wetlands is applicable, because there are wetlands onsite.
Any remedial actions must be done without adversely impacting
the wetlands. The proposed landfill must be a minimum of 300
feet from the wetlands because of the RCRA siting criteria
regarding wetlands. The Occupational Safety and Health Act
would be applicable in terms of protecting the safety of
workers during any remedial action.
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Table 3.
DESCRIPTION OF EVALUATION CRITERIA
Overall Protection of H~man Health and the Environment .~..
addresses whether or not a remedy will:. cleanup a site to
within the risk range; result in any unacceptable impacts;
control the inherent hazards (e.g~, toxicity and mobility)
associated with a site; and~inimize th.. short-term impacts
associated with cleaning up the site. . .
Compliance with ARAR's - addresses 'whether or not a remedy
will meet all of the applicable or relevant and appropriate
requirements of other environmental statues and/or provide
grounds for invoking a waiver. . . , .,'
, '
Long-term Effectiveness and Permanence';" refers to the,
ability of a remedy to maintain reliable protection of human
health and the environment over time once cleanup goals have
been met. ., . .
Reduction of Toxicity, Mobility, or Voluinethrough Treatment -
refers to the anticipated performance:,of the treatment
technologies that may be employed in'a remedy. .
Short-term Effectiveness - refers ~o' ihe ~eriod of time
needed to achieve protection, and~nyadver5e impacts on
human health and the environment that, may be' posed during the
construction and implementation p.riod,untilcleanup goals are
achieved. . ,.
Implementability - describes the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
Cost - includes the capital for materials, equipment, etc.
and the operation and maintenance, costs. ..
Support Agency Acceptance - indicates whether, based on its
review of the RI, FS and the Proposed Plan, the State concurs
with, opposes, or has no comment on the preferred alternative.
Community Acceptance - will be assessed in the Record of
Decision fOllowing a review of the~ublic comments received
on the RI, FS, and the Proposed Plan.
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25
OU3
-
, '
The was~ewater,collection and,
operated to ensur& compliance
, (.See Table 5)." ,
treatment system would be
with chemical-specific ARARs
3).
Long-Ter~Ef£ectiveness
OUI
. .. .
The most effectiye' option long;"term is the incineration:
option. Alternative 3B has go,od long-term' effectiveness, " , '
'because if the containment system' failed, the source material.
would be bound up, and the impact on human health and the' .
environment would be minimal., The other treatment options
would also be effective longter~, especially if the site
is properly maintained. '. " ',' . '
OU3
Collection and treatm~nt of :OU3 water will provide,
remediation of that water uri.tilit' is no longer necessary.
4) .
Reduction in Toxicity" Mobility, Volume
OUI
Excavation with onsiie'incineration would result in .
permanent reduction in toxic.ity, mobility and volume of th~'
organic PCOC's. Excavatibn:with solidification and onsit. "
landfilling would also reduce mobility of the PCOC' s. It.,
mayor may not also reduc~volome and toxicity depending on
the solidification process.~' -Some 'solidifications increase' ,
the volume of the waste material, and some decrease it. Some
solidications decrease the 'toxicity of the waste material, and
some do not effect the toxicity of the waste material., The
most likely scenario is that the volume of the waste material
would increase, and the toxicity would be reduced. Excavation
and landfilling would reduce the mobility of site-related "
contaminants. Capping and slurry walls would reduce mobility.
No action would not reduce toxicity, mobility or volume. '.
OU3
The collection and treatment of the contaminated water
from the two seeps would reduce the mobility of' the PCOCs.
No action would not reduce toxicity, mobility or volume.
5) .
Short-term Effectiveness
OUI
, ,
, ,
The slurry wall and cap could be completed in four
months, and the material would be contained. Excavation,
solidification and onsite landfill would be completed in six
months and would be a permanent treatment of the waste., '
Excavation and incineration would tak& 4 years ~6 complete,
so its short-term effectiveness would'be low. No short-term
reduction in PCOC's can be associated with the no action
alternative. ' '.
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OU3 ..
Construction of the collection and offsite treatment
alternative would be completed in approximately one. month,
however, collection and treatment would continue
indefinitely.
6).
Implementabilitv
OU1
All of the alternatives proposed for this site can
easily implemented. For the solidification options, it
be necessary to perform treatability' tests to determine
most effective method of solidification. The onsite
incineration is the most difficult of the treatment options
to implement. .
be
would
the
OU3
The collection and offsite treatment option could be
easily implemented. Access would be no problem, and the
required equipment is readily available.
7).. Cost
OUl
The most inexpensive treatment option is in-situ treatment,
with slurry walls. Alternative 3B is only marginally more
expensive; it costs aprroximately $400,000 more than in-situ
treatment. Incineration and offsite landfilling are substan- .
tially more expensive, at $14.2 and $23.9 million respective1y~
An important consideration at this site regarding cost is . . . .
that, with the risk to human health being low, the more
expensive remedies are difficult to justify.
8). State Acceptance - The PADER concurs with the remedy
selection at this site. A copy of the state's concurrence
letter is attached.
9). Community Acceptance - Community interest is low at this
site. A single letter contained the only written comments. .
received during the public comment period. A public meeting
was held, and it lasted approximately 90 minutes. In general,
the citizens seemed interested in having the site remediated
as soon as possible. The citizens did not appear interested,
however, in the details of the selected remedy. All signifi-
cant comments are addressed in the attached Responsiveness'
Summary. .
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, . . .
'. . .
. .
DESCRIPTION OF THE SELEC~ED RE~EDY
. .
. .
. .
Based upon consideration of the requii,ments of C~RCLAr
the detailed evaluation of th.e alterna.tives, 'and public '.
comments, EPA has determined tha tAl terriati 'Ie 3B .'
(Excavation, Solidification/Fixation Treatm~nt Onsite.
Landfill) for Operable Unit #1 in combination with
Alternative 2A (Seep Interceptor System and Offsite .
Treatment) for Operable Unit #3 is the most appropriate remedy
for the Craig Farm Site in Perry Township, P~nns~lvania. .'.
, . .
Approximately 32,000 cubic yards of contaminated ~oil
and source material will be excavated from the two source'
pits. A treatability study of the solidification procedu~e
will be done, and its effectiveness will be evaluated using.
the TCLP prior to the full-scale remedial action. The, ."
results of this study will be submitted to EPA and PADER'for
review and comment. I f the solidif ication procedure' 1s' not.
found to be effective, then other remedial alternati~es will
be considered. If the solidification procedure is effective
in the treatability study, the source material will then be' .
solidified, and the solidified waste and the contaminated. .
soil will be placed in a double-lined landfill. All sOil,
around the two disposal pits containing detectable lev~ls~f
resorcinol will be placed in the landfill. The pits will be
excavated until there are no longer any detectable levels 'of
resorcinol in the soil. . :. .
Fill material will be placed in the excavated afe~s1, '.
and a minimum of six inches of soil cover will be placed,on.
top of the fill material to support vegetation. The landfill
will be lined with a two-foot clay barrier, and two ~ayers
of liner with filter fabric on each side. A one-foot leak
detection zone would be placed above the secondary liner
and a one-foot thick seepage collection zone will be 'placed
above the primary liner. After all impacted soil has been
placed in the landfill, a cap would be constructed over
the landfill. The cap will be composed of a two-f09t clay.
barrier, one layer of liner, one-foot drainage area,' and two
feet of cover soil. After the cap is constructed, the area
would be vegetated for erosion control. .
The selected remedy also includes collection and.
treatment of the groundwater via a seep interceptor system.
Collection trenches will be installed perpendicular to the
slope several feet above the location where Seeps A~nd B
appear on the hill side. Each trench will be approximately.
twenty feet long, t~ve feet deep and two feet wide. The flow
rate from the two seeps is approximately 4000 gallons per
day. A sump pump with level control would pump the water to
a 40,000 gallon tank providing a minimum of 10 days storage
time. A pump truck would collect the water once a week and
transport it to an offsite water treatment plant. This
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28
collection andtreatm~nt of
continue indefinitely until
complete. The completeness
by using a bioassay testing
EPA. . .
the contaminated water will
the remediation is judged to be
of the remedy will be determined
procedure that is approved by the
. A ground water verification study will also be done
, to determine whether or not the ground water (both on- and
offs i te), not be ing addressed in the selected remedy needs
any, further remediation. If additional ground water
remediation is required, it will be considered a separate
6perable unit, and will be addressed in a subsequent ROD
for this site. .
... Some changes may be made to the remedy as a result of
the remedial design and construction process. Such changes
in'general will reflect modifications resulting from the
~ngine~ring design process~ '
'APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
.. ,Section 121 of CERCLA, 42U.S.~~ Section 9621, requires
,that remedial actions comply with applicable or relevant and
appropriate requirements (ARARs), "of, 'promulgated federal and
'state' laws. ... '" '.. .
, '
. . Atequirement may be either "applicable" or "relevant
,and appropriate" toaremedial ,action. Applicable
,requirements are cleanup standards, criteria, or requirements
established under federal or state law that specifically.
'address a hazardous substance, pollutant, contaminant, "
remedial action, location, or other circumstances at a CERCLA
sit~. Relevant and appropriate requirements may not be .
"applicable" toa hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstance at a CERCLA
site, but may address problems or situations sufficiently
similar to those ~ncountered at the CERCLA site. '
ARARs are divided into three separate groups of
requirements: chemical-specific, location-specific, and action-
specific. Chemical-specific ARARs are requirements which set
health or risk-based concentration limits or'ranges for.
specific hazardous substances, pollutants, or contaminants.
Maximum Contaminant Levels (MCLs) are exam~les6fchemical- '.
specificARARs.Location-specific ARARs set restrictions on
activities based upon the characteristics of the site and/or.
the immediate environs. Examples of this type of ARAR .
include federal and state siting laws for' hazardous waste
facilities and sites on the National Register of Historic'
Places. The third classification of ARARs, . action-specific,;
refers to the requirements' that coritrol r,emedial' activities.
selected to accomplish a, remedy. " RC.RA 'regulations, ,for,'
-------
29
closure of hazardous waste storage units, RCRA incineration
standards, and pretreatm~nt standards under the Clean Water
Act for discharges to wastewater treatment plants are examples
. of action-specific ARARs.. 0
Chemical~Specific ARARs
. . As previously stated, chemical-specific ARARs set health
or risk-based concentration. limits or ranges for specific
hazardous substances, pollutants, and/or contaminants. Based
on° the results of the Reomedial Investigation, chemical
specific ARARs for air-related impacts were not considered.
. Table 4 is a list of the state chemical-spec if ic ARARs, and
o Table 5 is a list of the ofederal chemical-specific ARARs
00 identified for the Craig Farm site. Table 6 shows the limits
for the PCOCs under the chemical-specific ARARS.
o Loca t ion-S pec i f ic ARARs
Location-specific ARARsare requirements that set
restrictions on activities~ba~ed upon the characteristics of
the site and immediate eovirons. Table 4 includes a review
. of statelocation~specificoARARs. Federal locaotion-specific
ARARs are listed in Table,.S. 0..... .
. , '.
. .
Action-Specific ARARs
. .
'. .. "
o ARARs for the d~velopment of the remedial action
alternatives under consideration for the Craig F~rm Site can
also beodivided instate and federal ARARs. Table 7 sets
o forth federal action-specific ARARs, and state action-
specific ARARs can be found in Table 4.
. It should be noted that the RCRA Land Disposal Restrictions
. found at 40 CFR Section 0268 apply only to RCRA hazardous wastes
that are land dispos~d oor placed after the ef.fective date of
the restrictions. The waste present at the Craig Farm Site.
is a CERCLA hazardous substance, not a RCRA hazardous waste, .
so the Land Disposal Restrictions are not applicable. Further~
EPA has determined that the waste is not similar enough to a
RCRA waste to make Land Disposal Restrictions relevant and
appropriate. Thus, Land Disposal Restrictionsareonot ARARs.
."" .
. ,'.
..' .
--------- -----'--
-------
Standard, Requirement,
,Criteria, or Limitation
, Chemical~Specific
PA Uater c;:.\Jali ty ,
Cri~eria including Tbxic
r1anagement Strategy
'Location-Specific
Solid Waste r.'anagerrent Act
, -EnvirOl1lOOntal Siting'
, Cd teria 0
M
Clean Streams Law
Management Act
- Hetlands '
Citation
25 PA Code Chapter 93
Chapter 97
Chapter 101
,25 pA Cod~ Chapter 75 '
25 PACode SeC~ 88.1
25PA Code Sec. 105.1
TABLE 4
, STAtE MARS
Description,
Establishes acceptable
levels in surface waters for
pollutants of concern.
" ,
Establishes criteria for
, si ting and operating solid
waste'disposal facilities.
Establishes, criteria for
protection of streams.
Criteria for wetlands
Applicable/
Relevant
and
Appropriate
Yes/No
Yes/No
, ,
Yes/No
Yes/No
CCII100nt
phenol limit
0.005 ng/l
Landfills may not be
permitted in environ- :
mentally sensitive'
areas.
Proposed lirni ts expected
to be promulgated in
Fall 89.
Applicable if sited in
or within 300 feet of ,
an important Wetland.
-------
"tndard, Requirerrent,
iteria, or Limitation
. .
fe Drinking Water. Act
tional. Primary
inking Water
1ndardS
.:ional SecOr1dciry
inking Water ..
=tndards .
~.
C""I
2an Water. Act
ter_QJality Criteria
ecutive Order on
otect ion of -Wetlands -
Citation
- 40 li.s.c. 300
40 C.F.R. Part 141
40 C.F.R. Part 143
- 33 U.S.C.
1251-1376
40 C.-F.R. PartH1
Quality Criteria- -
for Water -
Exec. Order No.
11,990
40 C.F.R. Part 6
Appendix A.
TABLE 5
FEDERAL rnf1otlCAL-SPECIFIC A.RA.Rs
- - Description.-
. .
Establlshes heaith-based ~tandards
- for public water systems (maximum -
contaminant levels).. . .
. .' .
Estabiishes welfare-based - standards.-.
for public water systems (secbndary
maximum contaminant levels). --
- -
. .' .
- setscrlteria for water quality
. - based on toxicity_t9aquatic
-. organi~-and tluman health -
- FEDERAL IOCATION-5PECIFIC ARA.Rs
Requires Federal agencies to avoid
to the extent possible, the adverse
impacts associated with the
destruction or loss of wetlands and
to avoid support of new construction
in wetlands if a practical alter-
native exists.
Applicable/
Relevant and
.. Appropriate
No,/Yes
No,/Yes
- -. No,/Yes
- -
YesjNo
. '
C<:mrent
The ~Ls for RX>Cs are
re levant and approp-
riate for groundwater
used for drinking - - -
. -
purposes.
Secondary ~Ls for R:PCs.
are re levant and' approp-
riate for groundwater
used for drinking
purposes.
AWQ::.s for IQJCs are
relevant and appropriate
Applicable because there
are wetlands on site.
A. wetlands delineation
will be done during the
reJOOdial design.
-------
CIIEMICAL-SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
PCOQ
. Safe DriDtin, Waler Act
MCL(a) 'SMCL(b) ~~
lm~\ Iml/" ImrJU
:admium
hromium VI
opper
~ad
!nc
0.01
0.05
1.0
0.05
5.0
0.005 0
::nzene
esorcinol
~enol
SA
MDSA N
!PSA M
PSA
HD
H.maa Heall" A ~
Waler alld Aqualic
Oro.isms (Jilin
PADEI\
Aqulic Life A woe '1IDdards(e)
Fresh Waler (ulll)(d
Acule Chronic (mfll)
10 ug/l
.50
1000
50
RCRA
Groundwaler
Prolectio8«()
Standard
MCL
(meJI)
3.9 1.1 0.01
16 11 0.05
18.0 12.0
82.0 3.2 0.05
120 110
5300 " ~-
10,200 . 2,560
0.66
3.5 mg/l
:~aminant Levels Standards, promulgated under the Safe Drinking Water Act (40 CFR 141). .
J) Secondary Maximum Contaminant Levels, proposed under the Safe Drinking Water Act (40 CFR 141). .
,) Proposed Maximum Contaminant Level Goals. . . .
J) Am~ient Water QU8Ii~ <:riteria for the protection of human health, promulgated under the Oean Water Act~
~) Maximum Allowable Limits of the P ADER. '.
) Maximum Contaminant Levels under RCRA (40 CFR 264.94). .'
Table.6
. .
-------
tandard, Requirement,
riteria or LUnitation
Citation
TABLE 7
FEDERAL ACTION SPECIFIC ARMs
Descri tion
Applicable/
Relevant and
A riate
C
-------
;tandard, Requirement,
:riteria, or LUffiitation
}ccupationa1 Safety and
ealth Act
3zardous Materials
!"ansportation Act
3zardous Materials
r-ansportation
Jgulations
-<:t
C"')
Citation
29 U.S.C.
1910 & 1926
29 CFR 1910-120 or
54 FR 9294
49 U.S.C.
1801-1813
.49 C.F.R. Parts.
107,171-177
Table 7 (oontinued)
Description
Regulates worker health and
safety in industry and
construction~
Health and Safety standards
for employes engaged in hazardous
waste operations. .
Regulates transportation of
hazardous. materials.
. Applicable/
Relevant and
. Appropriate. CaT1'OOnt
Yes,INo .
Under 40 C.F.R. 360.38,
requ irerrents, of the
Act appi y to all
response activities
under the NCP.. ...
Yes,INo. .
Final rulereplaoes
existing interim:. .
. final rule on March
6, 1990.
", .' .
. '
'Yes,INo
Only if an alternative
developed WQUld . .'
invel ve transportation :
of hazardous materials.
. .
. .
-------
'35
.STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The selected remedy would greatly reduce or eliminate potential
migration of PCOC'Sttheraby reducing the potential for impacts
on Unnamed Creek or. the surrounding wetlands. The site presently
has little or no impact on human health. This human health risk
would be even lower. after the selected remedy is implemented.
The excavation process would be controlled to ensure that fugitive
dust emissions and ,subsequent inhalation by nearby residents would
be minimized. The.implementation of the remedy will not pose
unacceptable short-term risks or adverse cross~media impacts.
. ,
Cost-Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
cost, the net present value being $4,479,000. The estimated
costs of the selected remedy are within an order of magnitude
of the costs assoc'ia'ted with onsite landfilling of the source
material, and yet~he ~elected remedy assures a much higher
degree of. certain:t„ that the remedy will be effective in the
long term due tohthe.reduction.of the. toxicity and mobility
of the wastes achieved. through solidification of the wastes
prior to .landfillin'g. . While the selected remedy effectively
redu~es the hazard~ po,ed by all of the contaminants at the
site, it costs approximately $10 million less than the onsite
incineration alternative. Additionally, ~h~ cost-efficiency
will be further~dby value engineering conducted during the
remedial deslgri.Treatability testing to determine the optimal
reagent and its concentration for the solidification will
also improve cost>-eff ic iency of the remedy.
Utilization of Permament solutibns to the Maximum Extent
'Practicable
EPA has determined that the selected remedy represents..
the maximum extent to which permanent solution and treatment
technologies can be utilized in a cost-effective manner for the
Craig Farm Site. Of those alternatfvesthat are protective of
human health and the environment.a'nd comply with ARARs, EPA
has determined that the selected' remedy provides the best
b~lance of,tradeoffs in terms of long-t~rm effectiveness and
permanence, reduction iri toxicity, mobility, or volume achieved
through treatment, short-term effectiveness,.implementability,
cost, and also cons~dering the statutory' preference for
treatment as a principal element. '.
-------
36
While the sel'ected remedy does not offer as high a degree pf
long-term effectiveness and permanence as the incineration alter-
native, it will significantly reduce the inherent hazards posed
by the source material through stabilization such that the
residual material that remains to be managed can be contained
with a high degree of certainty over the long term. Since
the remaining material will' be bound up, even if the containment
system were to fail, the impact on human health and the envi-
ronment would be minimal.
The selected remedy treats the principal threats posed by the
source materials and soils only slightly less effectively than the
incineration. The selected remedy is as least as effective as all
the all other treatment options in the short-term, requiring
only six- months to implement as opposed to possibly four years for
incineration. The implementability of the selected remedy
is comparable to the non-treatment options, and significantly
better than the incineration option. The selected remedy is
also one of the two least expensive treatment options" and costs
significantly less than both incineration and offsite disposal.
The selection of treatment of the source material is
consistent with program expectations that indicate that toxic
and mobile wastes are a priority for treatment and often necessary
to ensure the long-term effectiveness of a remedy. The major
tradeoffs that provide the basis for this selection decision
are short-term effectiveness, implementability, and cost. The
selected remedy has better long-term effectiveness than in-situ
treatment which is the only other treatment remedy that is
less expensive. Excavation, solidification and onsite land-
filling (3B) is therefore determined to be the most appropriate
solution for the Craig Farm Site.
Preference for Treatment
By treating the source material with a solidification/
stabilizing reagent, the selected remedy addresses one of the
principal threats posed by the site through the use of treat-
ment technologies. Therefore, the statutory preference for
remedies that employ treatment as a principal element is
satisfied.
-------
37
FINAL RESPONSIVENESS SUMMARY
FOR THE CRAIG FARM SITE
PERRY TOWNSHIP, PENNSYLVANIA
The U.S. EPA estab).ished a public comment period from
August 25, 1989 through September 25, 1989 on the Remedial
Investigation and Feasibility Study (RI/FS) and the Proposed
Plan for the Craig Farm Site in Perry Township, Pennsylvania.
The RI/FS and other site-related documents utilized by the
EPA to select a preferred remedial alternative are included
in the site repository and have been available to the public
since the beginning of the public comment period. The purpose
of this Responsiveness Summary is to summarize comments OR
.these documents as expressed by local residents, and other
interested parties during the public meeting, and to provide
EPA's responses to the comments. The only written comments
that were received during the public comment period was a
single letter from Beazer. The EPA responses to the comments
in the letter are listed after the responses'from the public
meeting.
Summary of Major Comments and EPA Responses
A public meeting was held on the Proposed Plan at the
Petrolia Fire Hall on September 13, 1989 at 7:00 P.M.
Those attending the meeting included representatives from
EPA, PADER, and approximately 20 members of the general
public. During the meeting, EPA staff presented an overview
of the background of the site, the nature and extent of
contamination, the alternatives that have been considered for
site contamination, and EPA's preferred alternative for
remediating the sources of contamination. Following the
presentation, EPA staff answered questions from the citi~ens
about ,the site.
Questions received during the meeting are summarized
below and are categorized into the following topics: 1)
Responsible Party Involvement; 2) Extent of Contamination;
3) Potential Health Hazards; 4) Site Remediation; 5)
Miscellaneous. Each comment is followed by EPA's response.
All significant questions and comments made during the
public meeting are included .in this responsiveness summary.
A complete transcript of the meeting is available for
public review as part of the Administrative Record established
for this site at the Karns City Area High School, Karns City,
Pennsylvania.
I ) .
Responsible Party Involvement
Several questions were asked about the responsible
party, and their role in both the RI/FS, and the future
remediation of the site. Citizens were concerned about
the responsible party's ability to properly remediate the
site. EPA staff explained that the responsible party
performed the RI/FS under the direction and superv~sion
-------
38
of both the EPA and PADER. Any future remediation, if
performed by the responsible party, would also be performed
under the same supervision.
Extent of Contamination
2) A citizen asked how far the contamination extended from the
two disposal pits on the Craig Farm Site. EPA staff explained
the extent of contamination, and also said that the contaminants
from the site did not in any way impact the Allegheny River.
Human Health Threat
3) A question was asked about the ~uman health risk that is
associated with the site. EPA staff explained that the site's
.impact on human health is negligible. EPA staff also advised
the citizens not to drink water from the Unnamed Creek.
Site Remediation.
. 4) A question was asked about how long it would be before the
site was remediated. EPA staff explained that the remedia~
design and remedial action would be completed in approximately
.two years. ..
. Miscellaneous
5) A citizen asked about the possible interaction of several
Superfund sites which are all located near Petrolia, Penn-
. sylvania.EPA staff responded by saying that it is very
. unlikely that the sites would interact in such a manner to
present a human health risk. It was also mentioned that
this type of interaction has not been studied in that area.
Written Comments and EPA Responses
Beazer wrote that the separation of the site into three
operable units needed further 6larification. They also added
an explanation of what they felt was in each of the operable
units. The EPA is in agreement. with Beazer as to the
separation of the site into three operable units, and the
definition of each unit. . ..
~eazeralsa wartted to clarify the length of time that
the.OU3water will be collected and treated. The EPA
response'is thatthi~ remediation will continue until judged
complete u~ing a bioassay test approved by the EPA and
PADERw.'. .
. Beazer wanted also express an opinion about the ground
water verification study. The ground water verification
study will be dorte to determine if any additional ground
water rem~diation is necessary at this site.
-------
BeaZer~erws arid 5eMces. Inc.
A Member of THE BEAZER GROUP
Environmental Services
436 Seventh Avenue. Pittsburgh, M 15219
Phone: 412-227-2500 Fax: 412-227-2042
::4. ..
- : <. -'..-- ~- -.- .,--,..- .
; "..' - l.-y ...., 4
; U-. I~~ I." f --: 1 --:
~' '-' \... ~ J..j~ (- ~ ...
-'~"'--" " --......-
September 25, 1989
Mr. Stephen R. Wassersug
Hazardous Waste Management
USEPA Region III
841 Chestnut Street
Philadelphia, Pennsylvania
Division
19107
Re: Comments of Beazer Materials and Services, Inc.
Regarding the Craig Farm Site Proposed Remedial
Action Plan
Dear Mr. Wassersug:
. Beazer Mater ials and Services, Inc. (BM&S) hereby
submits comments with regard to the Proposed Remedial Action
Plan (the Plan) dated August 22, 1989 for the Craig Farm Site in
Perry Township, Armstrong County, Pennsylvania. BM&S generally
is in agr.eement wi th the Proposed Plan as set forth by EPA
Region. III with the exceptions noted below. In addition, a
number of points raised generally in the Plan require
clarification based on the technical considerations addressed in
the Remedial Investigation (RI) and Feasibility Study (FS)
prepared for this Site. .
Operable Unit #1
. . The Plan provides that Operable Unit #1 (OU1) consists
of the distillation residue material in each pit area and the
adjacent . contaminated . soils. BM&S agrees with this
identification of the extent of OUl and the preferred
:~lte~native for addressing these materials.. However, BM&S
believes ~ that stabilization should be limited to the
distillation residue mater ial which was estimated in the FS to
b~ approximately 5000 cubic yards. Non-residue materials should
. . Writer's Direct Dial
~. . .
,"."
-------
Mr. Stephen R. Wassersug
September 25, 1989
~age 2
no t be
( ROD) .
required
to be
stabilized by
the Record of
Decision
Operable Unit #2
Operable Unit #2 (OU2) is defined as the remaining
portion of each pit area not defined as OUl material, mainly
overburden and adjoining soils that are determined analytically
to be "clean". BM&S agrees with EPA's description .of the
operable unit. With regard to the requirement that overburden
and soils be determined analytically to be "clean", BM&S
believes that because the material in OU2 has not been
demonstrated to have health or environmental impact, a
practically based- cleanup level for OU2 materials should be
50 ppm resorcinol although based upon the human health and
environmental risks examined in the RI/FS an appropriate cleanup
level would be much greater than 50 ppm. This recommendation is
based upon the following factors:
. 50 ppm is the lowest quantif iable detection limi t
proven for resorcinol at this time:
. The lack of health or environmental risk has been
documented for levels of resorcinol in soils that greatly exceed
the 50 ppm limi t. See,~, Chapter 9.0 of the RI for the
Craig Farm Site (the Public Health and Environmental Assessment
documen t) .
BM&S wishes to clarify that the language of the
preferred alternative on page 7 of the Plan should include the
approach adopted by the description included in Alternative 2A
described immediately above the preferred alternative on page 7.
As contemplated in the Plan, BM&S will place OU2 material back
into the pits for appropriate grading, covering and vegetation.
Operable Unit # 3
Operable Unit #3 (OU3) is described as the management of
groundwater Seeps A and B located downgradient of the pits.
BM&S agrees that the preferred alternative to managing this
portion of the remedy should include the collection of OU3 water
by use of a passive interceptor system and off-site treatment.
The Plan, as proposed, does not address the criteria for
determining the duration of seep collection and treatment. This
-------
Mr. Stephen R. Wassersug
September 25, 1989
Page 3
issue is of critical importance to effective implementation of
the preferred remedy. 8M&S believes that management of the OU3
water should be limited to the duration of. needed treatment.
Once the source of contamination is removed, the quality of the
groundwater is expected to improve dramatically over a
reasonable period of time thereby eventually eliminating the
necessity for continued collection and treatment.
BM&S recommends that the applicable cut-off criteria be
determined by appropriate testing during the remedial design
phase, possibly including an aquatic bioassay. It bears
repeating that the RI has demonstrated that no effect is
expected from the impact of the OU2 material on human health or
the environment. Therefore, because the actual environmental
impact will be the possible entry of constituents to Unnamed
Creek, the appropriate standards should be applied to the water
quality downstream of the location where seeps A and 8 converge.
(See sampling point 5 as indicated on Figure 5-1 on page 5-2a of
the RI for the Craig Farm Site).
In addition, 8M&S believes that the parameters to be
included in the testing protocol should be limited strictly to
the potential constituents of concern (PCOCs) identified in the
Plan on page 2-5 of the FS for the Craig Farm Site. Moreover,
the applicable standards for determining when OU3 water
collection and treatment may be terminated (which will be
der ived after appropr iate testing as descr ibed above) must not
be set at a level that is below the practical quantification
limit for resorcinol or any other PCOC.
Finally, we note that the successful implementation of
the preferred remedy for OU3, as envisaged by the Plan, may
entail the cooperation of the Pennsylvania DER in modifying the
NPDES permit for the petrolia plant to accept these additional,
albeit minimal, flows.
G~oundwater Verification Study
Although the currently available data show no risk to
the deeper aquifer at the Site, 8M&S would agree to perform a
limited groundwater verification study. However, 8M&S restates
its position expressed previously to Region III and the
Pennsylvania DER that such study should involve only resorcinol
and resorcinol-type compounds implemented via a limited well
system. The existing data do not support a broad investigation
-------
Mr. Stephen R. Wassersug
September 25, 1989
Page 4
of groundwater quality. Should additional studies indicate that
concentrations of these. constituents do not improve after source
removal as expected, then a further focused study may be
considered. However, this additional study should not be a
stated requirement of the ROD.
In closing, BM&S adds that we object to the sending of a
"special notice" letter to BM&S before the adoption of the ROD.
In fact, the comment period for the Plan is just ending, thereby
requiring BM&S to determine whether a good faith offer to
conduct or finance the ROD should be made to EPA before we are
certain of what will be contained in the ROD. BM&S requests
that the 60 day per iod for responding to the special notice
letters be stayed until the ROD issues.
Sincerely yours,
~~17?
cc:
Deborah McNaughton, PADER
Garth Connor
Billie S. Nolan, Esquire
Dean A. Calland, Esquire
-------
13\
PENNSYLVANIA.
DEC...'
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
Deputy Secretary for
Environmental Protection
~eptember 29, 1989
R ~""r': ,I; .. .. ~
. &;.;. 1\'e ;_.", .:
717-787-5028
~.)
Mr. Edwin B. Erickson
Regional Administrator
USEPA Region III
841 Chestnut Building
Philadelphia, PA 19107
OCT 06 1989
EE.:\.. r
iifili:!:Ii ~~~i'"-''' ......... 'XJ
Re:
Craig Farms Superfund Site
draft Record Of Decision (ROD)
Dear Mr. Erickson:
The draft Record of Decision (as received September 25,
1989) for the Craig Farm site has been reviewed by the .
Department. It is understood that this draft document is in an
on-going revision process and that a final document is not yet
available. Therefore, the Department is not able to comment, or
concur with, the actual final language of the ROD document at
this time. I can provide the Department's position, on a general
level, with the proposed remedy.
The proposed remedy for the Craig Farm site would
include the following:
*
The primary source material will be excavated and
treated by solidification/fixation.
A treatability study will be conducted to determine if
the proposed solidification process will effectively
stabilize the waste material. EPA and DER will jointly
determine the effectiveness of the solidification
process, based on the results of the treatability
study.
*
*
The treated primary source material along with any
contaminated soils will be placed in a lined landfill,
which will be constructed at the site.
*
Interceptor trenches will be constructed at seepage
points to collect some of the shallow groundwater for
treatment and disposal.
.._.~ .-.'
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Mr. Edwin B. Erickson
Regional Administrator
September 29, 1989
*
An additional groundwater study will be conducted to
address all groundwater (on-site and off-site) not
being collected by the interceptor trenches. All
groundwater, which is not being addressed in this ROD,
will be addressed by a later ROD.
The state does not concur with the proposed remedy,
as currently stated in the draft ROD. The State hereby will
concur, if the following comments and conditions are included
as part of the final ROD. .
*
It is understood that the final ROD will contain
language which will explain that the treatability study
will evaluate the solidified test material using a
TCLP, or similar type, leaching test. The data
generated by the tests will be used by EPA and DER to
determine the effectiveness of the treatment. A final
determination that the treatment is effective, will
require the joint approval of both EPA and DER.
If it is determined that the treatment is not
effective, then the portions of this ROD related to
excavation, treatment, and on-site disposal will not be
implemented. EPA would then propose an alternative
remedy, which would be covered by a new ROD.
*
*
Concurrent with th~ treatability study, an additional
feasibility study will be conducted to evaluate an
incineration remedy which would be equivalent to the
proposed excavation, treatment, and on-site disposal
remedy. This new incineration option would .include
incineration of the same volume of source material as
is proposed for treatment under currently proposed
remedy (estimated to be 5000 cubic yards), with the ash
and the remaining contaminated soil being placed in an
on-site landfill. This new incineration option would
be considered as an alternative to the currently
proposed remedy, if it is determined that the
solidification process is not effective.
It is understood that this ROD only addresses the
groundwater which will be collected by the collection
trenches. All other groundwater, on-site and off-site,
and including the shallow groundwater not collected by
the trenches, will be addressed as a separate unit in
an additional groundwater study, which will be covered
by a later ROD.
*
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September 29, 1989-
Mr. Edwin B. Erickson
Regional Administrator
*
The collection trenches, as proposed in' the draft ROD"
only collect a small portion of the shallow aquifer. ','
The final design of these collection trenches must. " '
attempt to maximize collection of contaminated '
groundwater, and these details will be addressed during
the remedial design process. ,-
The groundwater collection and treatment will continue
until the collected groundwater reaches background .
concentrations, or until the PCOCs are below detection,'
limits, or until otherwise determined jointly by EPA '
and DER.
*
*
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. (ie. landfill siting criteria)
*
The Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
*
The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state and federal law.
This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section l04(c)(3).
*
If you have any questions regarding this matter please
do not hesitate to contact me.
&.v~,t7~ {fYd/fl/
~f~~~llan
Deputy Secretary
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~ 1P4,.. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i A \ REGION III
\ - f 841 Cheltnut Building
~4t ~ Phllade'ph'a. Pennlytvanta 18107"
Mr. James Snyder
Director, Bureau of Hazardous
Pennsylvania Department of
Environmental Resources
P.O. Box 2063 .
Harrisburg, PA 17120
Waste
Re:
Concurrence Letter for the Craig Farm Site
Dear Mr. Snyder:
I am writing to you about DER's concurrence letter for
the Record of Decision (ROD) at the Craig Farm Site, which
was received by the EPA on October 6, 1989. The ROD went
through a number of changes during the last week of September,
and it was signed on September 29, 1989. A number of comments
were received from both Ji~ Shack and David Crownover of DER
during that week, and changes were made to the ROD to incorpo-
rate these comments.
There are two differences between the final ROD and the
conditions in the state's concurrence letter that require
further explanation because they weren't anticipated by the
EPA. The state requested a feasibility study to further
evaluate the incineration remedy. The ROD states that other
remedial alternatives will be examined if the solidification
is not found to be effective in the treatability study. Thus,
the incineration remedy will only be examined if the solidifi-
cation process is not effective. Secondly, the concurrence
letter also mentions that the ground water collection system
will be in operation until the collected ground water reaches
background concentrations, or until the PCOCs are below
detection limits, or until otherwise determined jointly by
EPA and DER. The ROD states that the completeness of the
remediation will be done by periodically analyzing the
wastewater using a bioassay test for resorcinol approved by
the EPA.
If you have any questions, do not hesitate to contact me.
Szy~
Thomas C. Voltaggio
Director, 'Superfund Office
Hazardous Waste Management
Division
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