ar500099 o - semspub.epa.gov
TRANSCRIPT
IN RE: PROPOSED REMEDIAL ACTION PLAN
PUBLIC MEETING
BRODHEAD CREEK SUPERFUND SITE
PROCEEDINGS HELD AT THE MONROE COUNTY
COURTHOUSE, STROUDSBURG, PENNSYLVANIA, TAKEN ON
WEDNESDAY, FEBRUARY 27, 1991, COMMENCING AT OR
ABOUT 7:00 P.M.
PANKO & JOHNSON REPORTING AGENCY
46 NORTH SIXTH STREET
STROUDSBURG, PENNSYLVANIA 18360
(717) 421-3620
AR500099 O
MS. DICOSMO: Good evening, everyone.
It's a little past seven, I thought we could
start.
My name is Francesca .DiCosmo and I'm
the community relations coordinator for the
Brodhead Creek Superfund Site.
As you know, we are here this evening
to have a public meeting to solicit comments and
input from the public on our proposed remedial
action plan.
The comment period opened on February
15th and will close on March the 18th. So there
is still time to get in comments and ask
questions.
I'd like to introduce some of the
people that we have with us this evening. Again,
I'm Francesca DiCosmo. With us we have Jeffrey
Pike who is the chief of the Western Pennsylvania
remedial branch. John Banks, of course, is our
remedial project manager and will be giving the
major portion of our presentation this evening.
Dawn lovan is the EPA toxicologist
assigned to Brodhead Creek. Mindy Snoparsky isAR500100
the EPA hydrogeologist. And we also have Robert
Davis who is the biologist.
In addition, from the Pennsylvania
Department of Environmental Resources we have
Robert Lewis who is the regional project officer
and John Mellow who is the hydrogeologist.
I'd like to begin this evening with a
brief overview of the superfund process just so
that we can see where we are and where we're
going.
Just as a quick review, the
superfund program was established by Congress to flB
remediate or clean up past waste disposal
practices of problems that have come to the
attention of EPA.
The solution for those problems was
development of a comprehensive environmental
response compensation and liability act in 1980 as
amended which is really a long way to say
superfund, but that is the legal title of the law
that we're operating under. And superfund has
come to be the most well known word for the
program. AR500I01
The mission of the program is to find
the nation's worst chemical contamination problems
and have them cleaned up. The superfund law set
up the mechanism by which EPA in coordination with
our partners in the State level, can have the
sites cleaned up and they developed the trust fund
to be used and enforcement authorities as well to
get the sites cleaned up and get the job done.
In order to be eligible for
remediation under the superfund program, a site
has to be included on the national priorities
list. That list is EPA's list of the country's
serious contaminated areas and is based on a score
that a site receives from the hazard ranking
system.
The hazard ranking system basically
takes data that was collected through various
means and various sources such as soil, air and
water and plugs it into a big formula.
And at the end of that formula, you
have a score from zero to a hundred. If your site
score is above 28.5, then you are put on the
national priorities lists and eligible OR- , ~
assistance under the superfund program.
What this does is the hazard ranking
system and the data that is collected at that
point alerts EPA to the fact that there is a
serious enough problem to warrant further study
and possible further action.
The common question we get is, well
what is this trust fund? Commonly the answer is
folks think that it is coming out of their state
taxes or from the income, federal witholding tax.
But it isn't. The trust fund was set up under
superfund to help pay for clean ups. Vp
And the fund consists of moneys and
received through taxes to the petro and chemical
industries.
Superfund sort of has two sides to
it, two authorities. One side of the superfund
law is the removal or removal actions. Those
actions are taken when the situation warrants
because releases or threats of release have
eminent or immediate threat to public health or
the environment. Those are sort of short-termAR500103 ,
situations where immediate action is warranted. ^B|
On the other hand, we have the
remedial side of the superfund program where a
problem has been identified which needs to be
corrected, but it is not an immediate threat to
the public health or the environment. That is not
to say it is not a problem there, but it is a
problem which would have longer term effects.
One has to be exposed over a longer
period of time. Therefore, we can take the time
to properly study the situation in order to make
the best selection or solution.
Very quickly I'd like to go over the
various steps of the superfund process. Once a
site is discovered and preliminary data is
collected, we, as I said previously, plug that
data into the hazard ranking system and come up
with a score. Once the score is validated and is
about 28.5, the site is put on the national
priorities list.
At that point, the remedial
investigation and feasibility study phase begins.
And basically that's where we are this evening.
Remedial investigation and
feasibility studies have now been complete and the
alternatives as presented in the feasibility study
have been put into the remedial action plan which
you all have a copy of.
And that would be the main focus of
our discussion this evening.
We have now opened up the comment
period, as I said and at the close of the comment
period, we will then make the record of decision
to set forth the final selection of the remedy.
Attached to the record of decision
will be a little document called, or a big
document, depending, called the response of the
summary where you can see all the comments,
questions that were asked about the site and EPA's
responses to those.
Finally we go in actually designing
and constructing whatever the selected remedy is
and there should be actually another one stuck in
here which is the operations and maintenance phase
of the program.
Once a remedy is constructed, EPA
doesn't walk away from the situation, it has a
A R S O O i O b
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long-term oversite monitoring program to ensure
that the selected remedy is in fact protecting
public health and the environment.
And then finally, the main goal is to
delete the site from the list because the selected
alternative has been successful.
With that, I'd like to turn the
program over to John who will explain and discuss
the action plan for the site. At the conclusion
of John's presentation, I'll then open it up to an
orderly show of hands for questions or comments.
You see that we do have a court
reporter here taking down the entire proceeding
this evening.
MR. BANKS: My name is John Banks,
I'm the EPA remedial project manager for the
Brodhead Creek superfund site here in Stroudsburg.
Tonight we're here to seek some
community input on the alternative which we are
proposing to implement at the Brodhead Creek site,
which to address surface soil contamination at the
site.
And during my presentation, I'm going
A R S O Q i O B
to be going through the site history, results of
the remedial investigation, feasibility study, and
EPA's proposed alternative for the site.
Starting with the site history,
Brodhead Creek site was a site of a coal
gasification plant which was operated by the
predecessors of Union Gas Company from 1888 to
1944 .
A by-product of this gasification
product was a black tar-like liquid, what we call
coal tar, it is principally composed of
polynuclear aromatic hydrocarbons or what whe callflp
for short PAH's.
This coal tar was disposed of in the
subsurface at the Brodhead Creek site. From 1917
to 1960, actually 1917, Pennsylvania Power and
Light purchased the electrical section of what was
then the predecessor of Union Gas Company
facilities .
Then from 1917 to 1960, Pennsylvania
Power and Light, or what I'll call PP&L purchased
adjoining properties throughout that time period.
1955 Brodhead Creek flooded due to a
10
hurricane. In response to that in 1960, flood
control levee was constructed on the site.
This flood control levee rises about
between eight feet above the natural land surface
at the site and was constructed with a corps of
engineer oversight at the time.
1980 during repairs to the tow of
this flood control levee, the maintenance workers
noticed coal tar seepage into Brodhead Creek. At
this time EPA was notified and initial measures
were taken under the clean water act to medicate
the threat to Brodhead Creek.
Around the 1980 time period, the
superfund law was also enacted and funds became
available under the superfund law to address this
contamination.
In 1982 EPA included the site on the
national priorities list and in the superfund
program for site cleanup.
In 1981 to approximately 1983, 1984,
EPA, Pennsylvania Department of Environmental
Resources and PP&L conducted numerous site
sampling and monitoring activities at thja sJJ;e,-. Ql\n oil u I u o
11
anywhere from installing test fits in subsurface
oil to porings to test wells to look at the ground
water.
In 1987, Pennsylvania Power & Light
and Union Gas Company signed a consent order and
agreement with the State of Pennsylvania to
conduct a remedial investigation capabilities
study.
The State of Pennsylvania had the
responsibilty during this time period for the
RIFS. And EPA and the State had been working in
conjunction during that time period trying to
finalize it.
So the actual field work for the
remedial investigation was conducted from 1987
through 1989.
In September of 1990, a final
remedial investigation report was submitted to the
DER and EPA followed by a final capability study
in January of 1991.
Just to highlight some of the
previous response activities that were taken at
the site during the early 1980's, there wasAR500109
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installation of filter fences and underflow dams
in the creek to intercept the coal tar seepage
going into the creek.
There was also installation of the
coal tar recovery pit on the Brodhead Creek bank.
The idea behind the pit was that the pit was dug,
free draining coal tar would drain into this pit
and we could recover it.
It was found though once this was
done, the pit was not catching that much free coal
tar and it was eventually backfilled.
In late 1981 through 1982, EPA under
an emergency response action under superfund
constructed a slurry wall to mitigate the coal tar
migration from the site toward Brodhead Creek.
The slurry wall lies between Brodhead
Creek and the flood control levee that is
presently on the site. Slurry wall is
approximately 648 feet long and it has a depth of
approximately 17 feet over the subsurface.
Primary purpose of the slurry wall
was to halt the flow of the liquid coal tar
itself. It is not a barrier to ground wIBarQSllowO
13
Concern at that time was that the coal tar was
going to seep directly into Brodhead Creek and
that is what the slurry wall was put there to do,
to stop the coal tar.
Some of the coal tar constituents are
soluble in water. They dissolve in the ground
water and the ground water silt flows underneath
the slurry wall and around the slurry wall into
Brodhead Creek.
There was also excavation of the back
water channel where coal tar seepage was
particularly significant. The coal tar in that
back water chanel was found to be toxic to fish at
that time.
The back water channel was then
excavated and backfilled with clean soils and no
longer existes at the site.
And then, I believe it was 1983 and
part of 1984, there was the installation of
recovery wells in the main coal tar pool at the
Brodhead Creek site by PP&L.
They managed to remove approximately
8,000 gallons of free coal tar from this main Qoal
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tar pool which was the extent of the recoverable
coal tar at that time so they could get it out
that pit area.
So then beginning, the remedial
investigation was then conducted. The purpose of
the remedial investigation was to determine the
nature and extent of contamination at the site and
there were a number of significant findings which
came out of the remedial investigation.
The first one is that the coal tar
contamination is limited to a gravel unit and
migrations contained by underlying silty sand
unit.
In broad terms, there are three major
geological formations at the site. That being the
gravel unit, underlying the gravel unit is silty
sand unit and under that it is bedrock.
The total area of contamination is
approximately 4.3 acres containing an estimated
maximum volume of 418,000 gallons of coal tar.
The coal tar exists at the site as a
free liquid phase and as residual coal tar. And
the way we define free liquid phase coal tar is,
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it is that coal tar which is at 100 percent pore
volume saturation in the soil.
The residual coal tar is coal tar at
less than 100 percent pore volume saturation in
the soil.
So to kind of draw an analogy if you
think of a snow cone and the shaved ice in the
snow cone is the gravel and cobbles in this gravel
unit. And then you were to pour cherry flavoring
on it and the cherry flavoring is coal tar. When
you pour this on top, you saturate the shaved ice
and that is analogous to what is happening at
Brodhead Creek with the coal tar, you have all
this coal tar within the pore spaces.
Now, if you were to take that snow
cone and suck out the cherry flavoring, you are
going to have a tinge of red left over in the ice
that you can't really get it out.
That is what residual coal tar is, it
is that area of the gravel unit where the coal tar
doesn't occupy all the space in the pore volume
and it is sticking to the cobbles in the gravel.
Now, the free liquid phase coal tar 4fe
RR500H3
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exists in two main areas at the site, proximal to
MW-2 which is on the east side of the slurry wall
at the site, and in the RCC area. The RCC area is
a recovery well area were PP&L had recovered a
free base coal tar back in 1983.
And the area next to monitoring well
number two contains approximately 338 gallons of
coal tar. The area around RCC contains about 8700
gallons of coal tar.
The residual coal tar is througout an
additional 2.96 acres of the site, with an
estimated maximum of 409,000 gallons.
To illustrate this, what you see here
is the maximum probable extent of the free coal
tar. Here you can see the area around MW-2 and
this is the area around RCC. The darker
hatchmarked areas are where the free coal tar
presently exists.
They both exist in a stratagraphic
unit that's in the subsurface of the site. The
stratagraphic unit is a depression of silty sand
unit at the site. And what it is, it is almost a
geologic sink.
17
If you can picture the gravel unit
dipping down in the depression of silty sand unit.
And what it does is form a sink which the coal tar
migrates down into because of gravity and because
it is denser than water. So it flows down through
the water table into the stratagraphic depression.
The lighter hatchmarked area is the
maximum probable extent of the residual coal tar.
This is the coal tar that is adhering to the
cobbles and it is not really occupying all the
floor space in the soil.
I think it is important to note that flp
the way the boundaries of the residual coal tar
were drawn is from all the historic observations
from 1980 until the present, it encompasses all
those areas where coal tar was at one time or
another found in a test pit or a boring or a
monitoring well.
Just to illustrate this depression
again, this is a cross-section of the site. And
what you can see here is the flood control levee
right here. And then you have the stream gravel
unit or the gravel unit right here. Jfe
AR500I15
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I should make a point to clarify
this. When I say stream gravel unit, I do not
mean the gravel unit directly underlying the
stream bed.
The stream gravel unit is more
extensive than that. It underlies the majority of
the Brodhead Creek site, it is not just the
gravel. There is stream gravel underneath the
stream bed, but it is more extensive than
throughout the site, even underneath the stream
bed.
So here we have the stream gravel,
underneath the flood control levee. And this is
the underlying silty sand unit here. Here is the
natural sink that is formed just because of the
J? geology of the site. And the coal tar actually
migrates down the slopes of the silty sand into
these pools.
Now, this is the RCC area, the
smaller pool by monitoring well two is contained
effectively by the silty sand on its eastern side
because the silty sand rises above the coal tar
pool. And it is contained by the slurey:: Wfjljl { en
3
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its western side.
Now, it is postulated that when the
slurry wall was put in, this coal tar was trapped
on the opposite side of the slurry wall. That is
how it got there.
Like I said, the surry wall is
effective in not letting the free phase coal tar
move through it, although it does let the ground
water through.
The principal shallow water bearing
strata at the site are the stream gravel unit and
the underlying silty sand unit. The ground water
flow is basically west to east across the site and
the ground water moves downward beneath the slurry
wall and also down along the path of the slurry
wall and down around the sides of the slurry wall
towards Brodhead Creek.
Now, the migration of the coal tar
constituents may be constrained by upper flow
drainage and hydraulic boundaries by Brodhead
Creek and McMichael Creek.
And what I mean here is, I, jam pjw?t i -j
talking about the free phase coal tar migration.
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Some of the constituents, some of the PAH's and
some of the more volatile chemicals in the coal
tar are soluable in ground water.
These dissolve into the ground water
and then migrate towards the creek. At the
conclusion of the remedial investigation, there is
an upward flow grading of the ground water at the
creek, which is because of the higher head we
found in the wells.
And that there is no possibility for
the vertical migration contaminated ground water
down through the gravel into silty sand and then
into the bedrock ground water at the site.
EPA isn't disagreeing with this. I
think though, in order to be a hundred percent
sure, we still feel that some additional bedrock
wells should be put in at the site to assess the
bedrock water table, actually the bedrock aquifer
and to verify and get more information that indeed
there is no vertical flow breaking at the site for
contaminated ground water to move down to the
bedrock.
Other data shows the Brodhea
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surface waters are not affected by the discharge
of coal tar constituents. The ground water at the
site is contaminated and is discharging into the
creek.
However, once it hits the creek,
immediately upon entering the creek, we can't pick
detectable levels of any coal tar constituents.
They are immediately diluted below detection and
therefore there is no impact to the creek.
Some of the sediment areas in the
creek are contaminated with coal tar, they are
very low levels of coal tar in the surface {•
sediments.
A little bit more of the contamnation
is located in the lower sediments in the creek.
But again, it's very low contamination. It
appears that sufficient macroinvertibrate
population does not appear to have been adversely
impacted.
So it is good news for people who
fish on the site. It doesn't appear that the fish
are being impacted at the site, they don't seem to
be biocumulating the PAH's. AHjUUl
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During the remedial investigation,
there were fish studies done and also studies on
sea lamprey larva that live in the subsurface
sediment at the site.
We tested the fish and we found that
they are not biocumulating PAH's, which seems
reasonable because the fish are more mobile,
moving in and out the site boundaries at the creek
all the time. And also they metabolize any PAH's
that they would take in rather quickly.
Sea lamprey larva are another story.
Because of their lifestyle, they have a tendency
to biocumulate the PAH's at the site. They burrow
into the sediments at the site and they live there
for about four to seven years before migrating
down to the ocean. During that time they feed off
the organic matter in the substraight and the
organic matter does have a tendency to pick up
these PAH's and the sea lamprey biocumulate
itself.
So we do see some violation of the
sea lamprey larva, even though they are
biocumulating, they are adversely impffct'ea 4Deea-use
23
there is a great abundancy out there in the creek.
And also once they do migrate out of the site area
and move towards the ocean, it is also expected
that they are going to metabolize these things
quickly and discretely.
Based on the results of the remedial
investiation a risk assessment was conducted to
assess site impacts to human health and the
environment, if no remedies were to be implemented
at the site and the site were to stay as it is.
During the risk assessment, the main
site-related contaminants were the PAH's, benzene
and arsenic. These chemicals exceed the maximum
contaminant levels in the stream gravel ground
water on site.
And what maximum contaminant levels
are, those are standards for contaminants that
were promulagated under safe drinking water act,
which are acceptable levels for human consumption
of the water as drinking water.
Currently there is no exposure at any
on site wells simply because there are no drinking
water wells on site. And there is no exposure toAR500I2S
24
any off site municipal water supply wells since
wells that we sampled were cleaned.
The well that was sampled was one of
the East Stroudsburg Municipal wells on the East
Stroudsburg campus. This well penetrates bedrock
in the Stroudsburg area and the water quality was
good. It contained no contaminants whatsover
related to the site.
Potential future use of the upper
aquifer at the Brodhead Creek site itself is
highly unlikely. This is for a number of reasons.
Three of them being that the site lies within a
wetlands area. Flood control levee bisects the
site. Site is also in an industrial area. So it
is unlikely that somebody would screen a well in
the gravel unit on site.
However, even though it is unlikely,
the probability still is there that somebody could
do it.
As for the environmental impacts,
that are no site-related exceedances of ambient
water quality criteria in Brodhead Creek.
The ambient water quality criteria
AR5QQ122
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are criteria set for protection of aquatic life.
And you know, based on the ground water
discharging to the creek and us not being able to
detect contaminant levels in the creek, none of
them are exceeded.
Residual coal tar is present in some
locations in the stream bed sediments at very low
levels. But they are not affecting the aquatic
life and they are not imparting PAH's of any
significant levels whatsoever to the stream waterI
Again, PAH's were found to
biocumulate in the sea lamprey larva, but not in VP
the fish that were sampled in the creek. And
again there seems to be a healthy abundance of
aquatic life in Brodhead Creek.
For human health there are a number
of routes of exposure to contamination analyzed
for risk assessment. In doing a risk assessment,
the risks of exposure were analyzed for dermal
contanct with surfact soils, sediments and surface
water and likewise ingestion of surface soils,
sediments and surface water at Brodhead Creek.
Risk assessment also lookeff 'ar*-' ' <- Jfe
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ingestion of fish. And looking at a worst case
scenario, the levels of contaminants in sea
lamprey larva were looked at for fish ingestion.
So basically for ingestion of fish, we are looking
at, if you were to eat sea lamprey larva at the
site, which is pretty unlikely.
We also looked at vapor inhalation
from surface water and surface soil and dust
inhalation for the surface soils.
Taking those risks of exposure into
account, the total lifetime carcinogenic risk for
adults may be an additional two cases of a hundred
at the Brodhead Creek site or maybe two cases out
of an additional 100,000 people exposed to
contamination at the Brodhead Creek site.
And under the superfund program a
cancer risk higher than one in 10,000 is
considered unacceptable, so we are well below the
range.
We also looked at the total lifetime
chronic hazard index. The hazard index greater
than one for noncarcinogens is considered
unacceptable.AR500I21*
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The total lifetime hazard index or
exposure to noncarcinogens at the site is .0048,
so once again, we're well below the required
limit.
Given the complexity of the site, we
decided to divide the site into two separate
operable units.
The first one being contaminated
subsurface oils containing free coal tar in the
stream gravel unit. The basis behind this
operable unit is so that we have free coal tar on
the site, which is imparting high levels of
contaminants to the shallow ground water.
And what we want to do is mitigate
the principal threat caused by these coal tar
pools by dealing with them effectively.
The second operable unit would entail
ground water and stream gravel to and including
bedrock.
Under this operable unit, we want to
go back and put some additional bedrock wells in
to assess the quality of the bedrock aquifer.
We looked at a variety ofLsR5Qni25 IV
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alternatives under the feasibility study, but
before I get into them, the following alternatives
I'm going to show you do contain some common
elements which I wanted to make you aware of.
These all apply to all the
alternatives, except for the no action
alternative. Except for number five, but even
under a no action, EPA will review the site every
five years because we are leaving contaminants on
the site. But as for the other four, they will
apply to all the rest of the alternatives.
We will be looking at imposing deed
restrictions on the site to limit future use on
the site.
We are looking at a ground water
monitoring program to measure concentrations of
the coal tar relating to constituents and to
ensure that the integrity of the slurry wall is
maintained in the future.
We also implemented Brodhead Creek
biota monitoring program to ensure that the site
continues to have no significant impact on the
aquatic ecological system in Brodhead Creek.
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And we also looked at constructing a
fence around the site to prevent access.
For the interim remedy we are
proposing for subsurface oils, we looked at six
different alternatives.
The first being no action, which we
are required to look at under the superfund
program because it serves as a baseline for
evaluating the other alternatives.
Second alternative is limited action.
The limited action entails intermittent pumping of
the free coal tar in the RCC area, which is the WJf
larger coal tar pool. This would be done using
conventional pumping techniques.
And it is estimated that
approximately 50 percent of the coal tar could be
recovered. This would be done once per year until
we could not get any more free coal tar out of the
pit.
Then we have on site stabilization
solidification. Under this alternative, we would
excavate approximately 1,000 cubic yards of
contaminated soil. AR500127
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5533
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We then mixed the soil with some sort
of stabilizing substance to prevent the
contamination from reaching from out of this mass
that we would form.
We would take this inner mass and
place it back in the excavation and cover it with
the overlying soil. And this would help to reduce
the mobility of the contaminants after this
process is completed.
Another alternative is excavation of
the contaminated subsurface soil and then soil
washing. This is similar to alternative three in
that 1,000 cubic yards of contaminated soil would
be treated. Except under this alternative what we
would do is employ soil washing techniques, which
is literally washing the soil in a water solution,
strictly coal tar from the soil.
The clean soils would then be placed
in the excavation and the recovered coal tar would
be shipped off site for incineration.
We also looked at enhanced recovery
for the free coal tar. This is an innovated
technology being evaluated by the EPA superfundflR500!28
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innovated technology program.
Some in place application of
contaminated extractions from the soils involves
steam injection to the subsurface soils to
mobilize the coal tar and make it easier to pump.
The coal tar would then be removed
from the subsurface soils and then would be
transported off site for incineration.
I think it is estimated under the
enhanced recovery process to recover approximately
60 to 70 percent of the free coal tar and some of
the overlying residual coal tar with that. flp
And the sixth and last alternative we
looked at was the excavation of contaminated
subsurface soils and off-site incineration.
Under this alternative, what we would
do is excavate the thousand cubic yards of
contaminated soil and ship it directly off site
for incineration.
We would then in pour clean fill to
the site and backfill the excavation with the
clean fill.
These are the costs of the various; f
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alternatives. The least expensive of which,
barring the no action where we wouldn't do
anything is the limited action at approximately
1.2 million dollars.
The most expensive being alternative
six which is the off site incineration at 6.2
million dollars.
You have to keep in mind that these
figures are just estimates.
The six alternatives are then put
through EPA's superfund nine evaluation criteria.
These criteria are specified by the national
contingency plan which is the regulations
governing the superfund programs.
All the alternatives go through the
screening process where they are evaluated against
one another and the alternative which seems to
have the best balance of these nine criteria is
then proposed as the preferred alternative.
So for the first operable unit for
the contaminated subsurface soils as an interim
remedy, EPA has proposed the enhanced recovery via
the thermal mobilization which is alternative
AR500130
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number five at a cost of, estimated cost of 4.2
million dollars.
For operable unit number two, we are
looking at focused RIFS on the ground water,
installing additional bedrock wells to analyze
ground water in the bedrock and then writing a
final remedial action and a subsuent record of
decision for the entire site.
Just to quickly go over the main
components of alternative five, it is an
innovative technology. It is an insitu
application of contaminant extractions from the
soil and can be done in place.
It involves the physical displacement
of coal tar from the pore spaces in the soil
through steam ejection which heats the coal tar
and makes it more mobile and forces the coal tar
up through the subsurface and makes it easier to
pump.
Because it is an innovative
technology, we are going to do treatability
studies to determine the optimum performance of
the enhanced recovery process.
RR500I31
34
¥Based on the treatability studies, we
will run it at the most effective performance.
And if we find during the treatability studies
that this technique is not that particulary suited
to the Brodhead Creek site, then we will go back
and re-evaluate the alternatives.
It will employ treatment of
approximately 200 cubic yards at subsurface soil
containing free coal tar. Now this estimate is
based on the main coal tar pool at the site at the
RCC area.
We would like, based on the VP
treatability studies to try to apply this enhanced
recovery process to both the free coal tar areas
at RTCN and NW2, if possible.
Again, estimates from at least the
RCC areas at the process could recover
approximately 7200 gallons of free coal tar and up
3 to 10,800 gallons of residual coal tar.5
Recovered coal tar would be disposed
of off site and in an incineration facility.
The process water, the heated water
and steam that is used for soil f lushin$,R i£KM Bt£¥
35
is extracted with the coal tar, would be treated
and partially discharged to the creek and part of
it reinjected into the subsurface soils for
further flushing of the soils on the enhanced
recovery process.
Also during this process, we would
ensure to put adequate air monitoring provisions
in place to be sure we are not discharging any
unacceptable levels to the air.
That's basically it, I'll be happy
to answer any questions.
MR. SWIFT: My name is Bob Swift and
I'm an attorney from Philadelphia and I'm counsel
for Union Gas Company. I have a number of
questions.
My first question is, I guess I'll
address this to Mr. Banks. Isn't it correct that
both EPA and DER have accepted the conclusions of
the remedial investigation and the risk
assessment?
MR. BANKS: I don't think that is
necessarily true. I think during the past year
when we have been trying to finalize these
36
documents and meeting with the PP&L, there were
some situations where we basically agreed to
disagree because we just came at them from two
different viewpoints.
MR. SWIFT: The feasibility study
has now been finalized, it is my understanding
that the contract that forms this entire work,
both the remedial investigation, risk assessment
and feasibility study, also reached a conclusion
as to which alternative was most desirable. The
contractor was very critical of alternative five.
Contractor felt that altnerative two was
acceptable and recommended that, but it is my
understanding that EPA and DER asked that those
conclusions be removed from the study. And it is
also my understanding that they are not part of
the public record. Is there any reason for that?
MR. BANKS: The purpose of the
feasibility study is to have alternatives
presented to EPA and DER for us to select the
preferred alternatives.
We are well aware of what the
ERM proposed, I disagree with you in that they
¥
37
were severely critical of the enhanced recovery
process.
MR. SWIFT: One of the proposals
apparently endorsed by EPA is to build a fence. I
think it's a 2,000 foot fence, which would keep
the public out.
Why would you endorse building a
fence when there is very limited public use of
this area and based on the information you gave us
tonight, there is no danger to the public from
using it?
MR. BANKS: There is not as much a
possibility for human exposure, I think we are
going to be taking remedial activities at the
site. There is going to be process equipment on
the site. There are ways to get on the site,
albeit, limited from the one flood plane area by
McMichal Creek and from the other side of Brodhead
Creek.
The extent of the fence is something
that can be determined during the remedial design.
I don't foresee fencing the entire site,
necessarily.
flR500i35
38
¥MR. SWIFT: Is it true that, is it
still true, as set forth in the remedial action
plan that the Department of Environmental
Resources in Pennsylvania has taken no position
with regard to the remedial action plan?
MR. BANKS: I think we have had
numerous discussions with DER and I think they are
on board with what we are trying to do.
MR. SWIFT: Have they taken any
official position?
MR. BANKS: Typically official
position isn't given until the record of decision
is designed.
MR. SWIFT: Now, approximately
$600,000 was spent to complete this on that table,
and what is known as the RIFS. It is my
understanding that the proposal tonight that you
have outlined is an interim proposal, not a final
proposal. And after spending $600,000 on the
study, why can't the agency recommend the
permanent solution?
MR. BANKS: They can't r cjDDimnjejidoa-
permanent solution simply because we are still a flh
39
little bit unclear as to the quality of the
bedrock aquifer. But we would like to be
confident in a final position for the site.
I think taking an interim remedy to
address the principal threats is in line with an
eventual overall remedy with the site.
And I think there is nothing wrong
with going back and looking at the bedrock aquifer
to make absolutely certain that here is no
vertical migration of contaminated ground water
for that unit.
MR. SWIFT: The alternative five
endorses technology I think that is generally
referred to as the crow process. Isn't it correct
that this technology is unproven?
MR. BANKS: It is an innovative
technology, it is still being evaluated under the
superfund innovative technology program.
As I understand, though, some of the
subsurface soils from the Brodhead Creek site have
been sent to, I believe the Western Gas Research
Institute, who have done bench scales on
subsurface soils at the site. And from m§ R b UU I O /
40
discussions with them, the results seem promising
and that it very well could work.
And in addition to that, we are going
to be conducting treatability studies at the site
to see how actually it does work in the field.
MR. SWIFT: Why would the
treatability studies be completed after rather
than before the ROD, rule of decision is entered?
MR. BANKS: Jeff Pike?10
MR. PIKE: Essentially we feel we
have enough information to have a record decision
that there is enough available data to profit the
work for this site. The feasibility study will
fine tune the design for that.
MR. SWIFT: Isn't it true that you
have no data on field testing the feasibility of
this process at any similar site?
MR. PIKE: As John said, there was
some actual samples taken from this site and we'll
have a very intense feasibility study done on this
particular site, if this is the remedy that is
chosen and we will be monitoring it. AR500I38
The short answer, if this has been
¥
¥
41
done in the field before, I don't have an answer
for that.
MR. SWIFT: Well, isn't it
appropriate to first determine the feasibility of
the process before deciding to spend a good deal
of money, in this case 4.2 million dollars?
MR. BANKS: I think we are doing
that. We are not just going in there and putting
this process in place and running it. We have
indications that it will work based on actual
soils taken from the site itself.
And we are going to be running the
treatability studies before the full scale
implementation of this process.
MR. SWIFT: Will the results from
those treatability studies be publicly available
and if they show that this process will not be
successful, what will happen to the ROD?
A The results from the treatability study
will be publicly available. If we find after the
treatability study that the process will not work
at the site, what we will do is go back and
re-assess the alternatives and re-ROD the site.
————————————————————ARGQOiOQ
42
¥MR. SWIFT: Since the feasibility in
the field of this technology hasn't been shown,
why hasn't the agency collected a commercially
available and proven technology at this site?
MR. BANKS: Part of the superfund law
is to look at innovative technologies to apply
them to superfund sites, and we have a technology
here that looks like it will work. And it looks
like it will work quite well by removing the free
coal tar.
Some of the other alternatives
presented had, in going through the nine criteria, WJf
had some disadvantages, moreso than the enhanced
recovery process did.
MR. SWIFT: My client has spent over
a million dollars at this site in terms of cleanup
and investigation, why does the agency think that
more money, presumably from parties like my client
should be spent on technology that hasn't been
proven in the field?
MR. BANKS: We keep going back to the
same, I understand your point, but I think we keep
going back to the same thing. We are not, I don't
AR500UO
43
^^ think we are going to be wasting anybody's money.
We are not going to apply this technology if it is
not going to work.
And again, we have run studies on the
subsurface soils and it appears that we do get 60
to 70 percent recovery, maybe even more based on
the treatability studies. I mean I can't tell for
sure at this point, but, of course if the process
is not going to work, we are not going to
implement it.
MR. SWIFT: But do I correctly
understand that in pursuing this process, it is
not your intension to spend EPA's own money as
opposed to other people's money?
MR. BANKS: Well, I don't understand
that question. I mean the first thing we are
going to do is of course try to have the potential
responsible parties try to pick up the costs.
EPA will then, if failing to do that,
pick up the cost under the superfund to implement
the process.
MR. SWIFT: You spoke earlier about
the treatment of water. As I understand the .., j.
44
¥process, there would be thermal injection. How
hot is the water that is going to be injected?
MR. BANKS: I don't remember that the
feasibility study had a specific temperature, it
was what is called a low grade scheme which is 50
percent, contains about 50 percent water.
MR. SWIFT: But you don't know the
temperature?
MR. BANKS: I know currently that
subsurface soil is approximately 46 degrees
fahrenheit, 50 degrees fahrenheit. The coal tar
would have to be heated to approximately 86 mj
degrees fahrenheit to mobilize it.
I am assuming a water temperature,
since we are talking about low grade steam, over
150 degrees.
MR. SWIFT: Won't that in effect
sterilize all micro-organisms in the soil?
MR. BANKS: I actually cannot answer
that at this time. Again, that is, even under a
treatability study, I think that is something we
would want to look at. j\ R 5 0 0 1 4 <l
We don't want to cause more of an
45
environmental impact trying to remediate the site
MR. SWIFT: Are you saying then that
if it did kill off all the micro-organisms that
you would not proceed?
MR. BANKS: I don't think I can
answer that at this time. I am not a biologist
and I don't have the expertise in that area.
MR. SWIFT: Based on what you called11
the bench tests, how contaminated will the water
be that you will seek to re-inject into the ground
and or discharge into the stream?
MR. BANKS: Well, ground water, once
it's pumped, will be treated. It has to be worked
out and designed. To move the organics, maybe
some sort of filter, maybe some sort of biological
treatment to remove organics from the processed
water. Maybe some sort of chemical precipitation
to remove some of the metals from the processed
water.
But any processed water that we
discharge to the creek or that we re-inject back
into the subsurface will meet the nationalA R 5 0 0 \kpollution elimination discharge system
46
requirements for discharge.
So we are looking at coming up with
pretty stringent levels for discharging processed
water.
MR. SWIFT: Are you familiar with any
technology that can treat the coal tar mixed with
water to eliminate the contamination so that you
then can re-inject the water at the level that you
say the contaminants will be?
MR. BANKS: I still think that is
something for the design to work out. It is not
coal tar and water. The coal tar can be separated
from the water. What we are talking about is
contaminated water.
MR. SWIFT: So you don't know that at
this stage?
MR. BANKS: I would say that
treatment of water is proven technlogy, there are
proven technologies. And I think organics, one of
them is biological treatment of the water.
Now, I do believe, but I cannot say
for certainty but I do believe that the
requirements could be met. A H b U u l 4 4 ¥
47
MR. SWIFT: Do you know how large a
treatment facility would have to be erected on
site?
MR. BANKS: That is all part of the
process design and all part of sizing.
MR. SWIFT: You don't know that?
MR. BANKS: Not from the feasibility
study. That is to show us, present alternatives
and show us conceptually what is going to happen.
MR. SWIFT: It's my understanding
that the State of Pennsylvania has taken the
position that nothing can be injected into the
ground or discharged into a stream which doesn't
meet background levels. I personally don't agree
with that, but will this water that is taken out
of the ground with the coal tar constituents and
treated, meet background levels when it is
re-injected?
MR. BANKS: Well, as far as
discharging to the stream, I don't believe the
background applies. The background applies to
ground water. As for re-injection of the
processed water back into the subsurface, at this
48
¥time because it is an interim remedy and we are
not looking at ground water treatment or
evaluation as part of this interim remedy, just
looking at mitigating the principal threat from
the free coal tar and subsurface soils, the
background right now is not really considered --
MR. SWIFT: Are you able to say
whether or not the water that will be discharged
into the stream after being treated on site will
be better or worse than the ground water that
currently flows from the site into the stream?
MR. BANKS: You are asking me if the JV
process water after treatment is going to be a
better or worse quality than the ground water
currently in the stream, in the subsurface?
MR. SWIFT: Let me restate it. Ground
water currently is entering the stream and has
been measured and tested in remedial
investigation. Isn't it true that it is very
likely that the ground water, not the ground
water, but the water that is taken from these
wells through your enhanced recovery process, will
¥
49
currently going into the stream?
MR. BANKS: I don't follow your
logic. The ground water that we are going to be
extracting as part of the process will be highly
contaminated, but if we run it through a treatment
unit, we are going to meet all applicable
regulations before discharging into the stream, so
it should be much, much cleaner than the ground
water that is currently discharging into the
stream.
MR. SWIFT: Now, you will be
injecting water at very high temperatures under
pressure into the ground, there is currently a
slurry wall in place which is apparently according
to DRI has been very effective. Do you have any
study to show that this enhanced recovery process
will not worsen the situation by causing more coal
tar constituents to reach the stream?
MR. BANKS: I think with the enhanced
recovery process, the way it was stated in a
feasibility study, is that a remediation cell is
going to be blocked off. Within that remediation
cell we are going to keep hydraulic control of theAR50U 1 4 /
50
ground water.
When injecting the stream, it is
conceivable that we are going to be driving more
of the coal tar constituents into solution in the
ground water. By maintaining the hydraulic
control within the remediation cell, we will not
let that contaminated ground water escape that
remediation cell and thereby minimizing any impact
from the enhanced recovery process from driving
coal tar constituents into the ground water.
MR. SWIFT: Again, isn't it a fair
statement to say you have no field data to show
that you could be successful in doing that?
MR. BANKS: No, but again, that's
part of the treatability study.
MR. SWIFT: Now, has EPA performed a
cost benefit analysis of the various alternatives?
MR. BANKS: Yes, I believe we have,
using the nine evaluation criteria.
MR. SWIFT: What is the cost per
gallon of removing a gallon of coal tar and using
AR500U8MR. BANKS: We haven't gone through
¥
¥
¥
51
those lengths.
MR. SWIFT: Isn't it a fair statement
that the cost would be about $370 per gallon?
MR. BANKS: I wouldn't know, I
haven't done the calculations.
MR. SWIFT: Isn't it also a fair
statement that the cost of simply excavating and
removing soil would be about $15 per gallon?
MR. BANKS: Again, I haven't done the
calculations, but the excavation does have other
disadvantages. You are talking about excavating
large volumes of soil, exposing coal tar
contaminated soil, which you are going to get more
volatilization of some of the constituents in the
coal tar to the air. You are talking about stock
piling soils on site for an extended period of
time increasing possible human exposure.
I mean, there are other, there are
some disadvantages to the excavation which don't
make it a very good candidate for the site.
MR. SWIFT: Now, isn't it also true
that in the 4.1 million dollar estimate for this
enhanced recovery process, that the
s
21J
1
j
55
i$3j
i
wasn't even included?
52
¥MR. BANKS: That's corret. The
feasibility study did look at soley the RCC area
where the free coal tar was. Because the free
coal tar is an area which is the source of the
highest contamination
that all the free coa
Based on the treatabi
to the ground water, we feel
1 tar should be cleaned up.
lity studies, we would also
like to apply it to the area around MW2 .
Now the
reflect the cost for
Since the MW2 area is
cost I believe would
million, a million to
cost estimate does only
applying it at the RCC area.
much smaller, the additional^
seem to be about another
two million dollars to apply
it to that area.
MR. SWIFT: That would take it
approximately up to the same cost as total
excavation?
MR. BANKS: We're not talking about
total excavation. We're talking about excavation
of a hot spot. And we're not talking about the
excavation of area MW2 , where excavation not be
applied .
AR500150
>
p
53
MR. SWIFT: Now, this --
MS. DICOSMO: Excuse me, do you have
very many more questions? Because we really need
to move on and let some of the others have a
chance.
MR. SWIFT: Not many more, sure.
Isn't it true that for this five or
six million dollars that would be spent on this
proposal, assuming as you have, that you're going
to do the MW2 as well, that you'll only be
removing three to six percent of the total coal
tar at the site?
MR. BANKS: I guess that's true based
on current estimates. But the coal tar that we
are removing is the coal tar that is causing major
contamination at the site. It is the free coal
tar. The residual coal tar was spread throughout
the rest of the site.
It's relatively immobile, has
probably lost most of it's volatile chemical
content, and it's not probably imparting that much
contamination to the ground water as opposed to
the high levels being imparted by the free coalAR500I5I
54
tar, which are the main source areas.
MR. SWIFT: Now, a little earlier in
your presentation, you mentioned that the United
States had helped the State of Pennsylvania design
the rechannelization in 1960. And in fact the
United States was party to a lawsuit with my
client, where the United States was sued and
Pennsylvania is currently being sued for
contribution. Pennsylvania is also an owner of
some of the land at this site and has a permanent
easement.
Do you know whether EPA or DER have
any plans to contribute to the cost of the work
that would be done?
MR. BANKS: At this time you are
getting into litigation enforcement questions and
at this time I'm really not going to -- final,
determinations haven't been made yet as far as who
may be potentially responsible parties at the
site.
I think it is just premature to start
answering those questions.AR500I52 ,
MR. SWIFT: Thank you. mJL
¥
55
(Whereupon a brief recess was taken.)
MS. DICOSOMO: We are ready to
resume, may I have the next comment or next
question?
MR. BAYLOR: My name is Don Baylor
and I am an aquatic biologist and I am associated13
with a lot of local conservation organizations.
I have a couple questions.
In the process you are proposing, do
you have any idea of what volume of water you
might be discharging into the stream?
MR. BANKS: Again, those are design
considerations. I think what we would try to do
is try to recycle as much as possible and try to
minimize the amount.
MR. BAYLOR: I suppose you don't have
an idea at this time what temperature the water
might be when it is discharged to the stream?
MR. BANKS: I guess those would be
design considerations. I would imagine it would
probably be the ambient temperature.
MR. BAYLOR: It also might be one of
the MPDS limits that would be construed. One of
AR500i53
56
tthe concerns I have, and this is the major reason
for these questions, the lower Brodhead, that is
actually Brodhead Creek, is classified by DER as a
trout stock fishery which does not assume any wild
trout population. It assumes that the stream can
support stock trout for a certain time of the
year. It doesn't maintain stream bred or wild
trout.
My concern is that in fact the
Brodhead below Stroudsburg and East Stroudsburg
for some distance is a very viable fishery for
trout through the entire season, although it does WJ
reach critical temperatures at some times for
trout.
And I would be concerned about any
discharge to the stream as far as its thermal
quality as well as its chemical quality for that
reason.
The MPDS requirements would probably
be for a trout stock fishery, which may assume
that you don't have to maintain trout at that
time, later in the season in the lower Brodhead,
when in fact lower Brodhead does maintain wild Jfe
57
trout.
It's not recorded scientifically very
adequately by either DER or the Pennsylvania Fish
Commission because physically it's the type of
stream that is very difficult to survey. It's of
the size you can't survey, very adequately wading,
but it is not big enough that you can get into
with a boat unit and survey it.
Many of us locally know that it is an
excellent trout fishery and we're concerned about
any discharge into it on that basis. That is my
main concern.
MS. DICOSMO: Okay. Next? Sir?
MR. MASSE: My name is Thomas Masse,
presently with Timco Environmental Consultants.
I've spent 15, 16 years with the corps of
engineers and that many years with EPA and the
past year and a half I have been in my own
consulting firm.
I was the original EPA federal person
to come up on the site, 1980, '81 and put in the
present slurry wall and stop the coal tar from
entering the environment. A R D 0 0 i t) 5
58
¥I am pleased to hear after ten years
the wall that I put in is still working and in
fact I note from one of the reports the word
excellent, so I take that as a compliment. All
the efforts that we did back then and not knowing
what we were dealing with, but still able to
control and stabilize the situation that was not
controlled and not stabilized.
I have been retained by the attorneys
for Union Gas to review the studies that have been
performed. I've spent ample time in looking them
over and quite frankly I'm confused on some of the^P
elements, so I hope you bear with me with the
questions that I ask concerning the study.
I note that this alternative five is
a proposal which of the 418,000 gallons estimated
to be there in four point some acres, that only
three to six percent would be removed as a threat
from the environment by basically this proposal
that you have.
Do I understand that correctly?
MR. BANKS: That is essentially
right.AR500156
59
MR. MASSE: If that is the proposal
in alternative five, the system that will be used,
if I understand the engineering, is still yet to
be determined by some treatment system,
treatability system that you'll put into effect
after you approve the system? You are going to
evaluate what you propose to do after you start
doing it?
MR. BANKS: I keep going back to the
same thing all the time.
MR. MASSE: I know, that's what is
confusing to me, so I am from Missouri here a
little bit and I have been in this business and
around the block a few times. And I'm very
confused on the procedure.
MR. BANKS: We have done, scale
studies have been done under the sites programs
which I am sure you are familiar with?
MR. MASSE: Yes.
MR. BANKS: And showed very promising
results. I spoke to somebody in the sites program
about Brodhead Creek. They were well aware of
Brodhead Creek in the EPA Cincinnati lab.
60
Enhanced recovery showed promising mj
results with the soil samples that were sent to
Western Gas Research Institute to try bench scale
studies on the soils of Brodhead Creek.
So we are confident that it is going
to work. The matter of doing the treatability
study is to see what the optimum performance is.
I think another matter is, you are
right, we do have to test it in the field, who is
to say we don't get better results in the field.
MR. MASSE: The Alaskan oil spill is
a prime example I'm thinking of where the steam
jetties were brought out into the field to clean
off rocks. The studies from that Alaskan oil
spill determined that more damage was done by
reason of the heat and thermal water of the
washing of the oil off of the rocks and gravel,
caused more damage by making the soil sterile.
And if I understand your proposal,
that you are going to inject hot water, basically
hot water jets and steam down 25, 50 feet to
loosen up all the oil between the gravel and make
it flow and then suck it up, all of this mass of
AR500I58
¥
¥
61
oil and now contaminated water. Is that what I
understand what the proposal is? I don't want to
oversimplfy.
MR. BANKS: I think you understand
the enhanced recovery process and maybe, Bob you
can, I don't know about steam sterilizing the
soil.
But I think one thing I do want to
say is, we are talking about a 12 acre site. The
RCC area is a 9,000 gallon pool. But we are
talking about applying the process of a
remediation cell, which when looking at the
overall acreage of the site is a very small
portion of the site.
MR. MASSE: You do realize when
injecting water, when you inject a lot of water
heated, steamed, into an enviroment that is
unsterile, insitu, you are going to cause
something to happen. Either bubbling up, moving,
this unknown further contaminated water into other
areas .
Something has to happen when you
inject a lot of hot water into the ground. That
AR500159
62
4problem alone will exist. ^Br
The secondary problem that you'll
have is when you bring this material up to
separate it, and then possibly re-inject that
again causing further problems of hydraulics in
the ground water and the movement of contaminated
water, and all this is based upon some test in the
field that will be developed after you approve the
system.
That's what I understand the proposal
is .
MR. BANKS: As far as driving, I 4fc
already understand the concerns about causing more
harm than good. But we are trying to minimize as
much as possible any detrimental effects that may
be caused by this process. We are blocking off
the remediation cell.
Hydraulic control within that
remediation cell, you know, we are going to drive
probably more of the coal tar constituents into
the solution. But with the hydraulic control if
we can maintain it within that remediation cell, I
don't think we are going to prevent more lateral
AR500I60
>•
•
•
•
63
spreading of contaminated ground water or more
contaminated ground water.
As far as the steri
soil, Bob?
MR. DAVIS: Yes, I
have to worry about that at that
way, I'm Bob Davis with EPA.
lization of the
don't think you
facility. By the
The living creatures down there
are sparse to be sure, wouldn't
what happened up in Alaska. It
comparable environment.
MR. MASSE: In the
the material that are you going
be comparable to
is not a
treatability of
to bring up and
the free injecting back into, what contingencies
do you have that this natural insitu -- and I'm
talking the slurry wall, the twelve point acres
where there is almost no significant health threat
is emitting from it.
It is just sitting there and that
there is from your own test, indicate that there
is no dectectable contamination
Creek from ground water sources
level of certainty.
entering Brodhead
that you feel a
AR500I6I
64
And this proposal that what you are 4A
doing there will not further generate potential
problems of contaminating the surface of Brodhead
Creek and letting discharges of water that is
re-injected back in to the stream.
I mean is there a level of certainty?
MR. BANKS: I think again, the
treatability studies will show that.
MR. MASSE: And I do recall a
question asked earlier, that the treatability
study will be made public information, correct?
MR. BANKS: Yes.
MR. MASSE: And the treatability
studies will be based upon field implemented
tests?
MR. BANKS: Yes, in the field.
MR. MASSE: I think I hit you pretty
hard on this alternative five, my opinion on this
alternative five is that it's not the only act.
And for you people to be possibly looking at this
where the net result is only three to six
percent --
MR. BANKS: It's three to six. percent
¥
fix percenti#500162
65
of the highest contamination areas.
MR. MASSE: Three to six percent of
418,000 estimated gallons.
MR. BANKS: It's the source of the
highest levels of contamination.
MR. MASSE: The fact remains, if I
read it right, it's three to six percent, you are
giving your best shot here, you are saying three
to six percent of whatever the contamination
problem is in this area will remove 4.12 million.
I understand that.
I am saying that I don't feel that it
is the alternative that would find the solution to
your problem. I don't think you get the biggest
bang for your bucks and I think you are leading
too much up to a wish that the treatability
studies will do this for the feasibility of that.
So I recommend that you revisit some
of your alternatives, maybe the five or so that
you have there. Even still, I think that there is
too much out there that is tried and proven to go
with unproven technology.
Thank you.
AR500I63
66
¥15 MS. DICOSMO: Next question or
comment?
MR. SWIFT: I have one more. In
terms of the, we've been talking three to six
percent, I think we need also to point out that of
that three to six percent, perhaps half of that is
the easy to get coal tar, the so-called free coal
tar that can be pumped out at a cost of mabye 20
to $30,000.
And the other half is what you will
be spending virtually all the money for; is that
correct?
MR. BANKS: No, I don't think that is
quite true.
MR. SWIFT: Can you give me then a
breakdown of how much free coal tar you'll get at
a much lower cost, how much other coal tar you'll
get at the significantly higher?
MR. BANKS: Under, what you're
talking about is alternative number two which is
the intermittent pumping, feasibility study
estimated approximate recovery of 50 percent of
the free coal tar. So we are talking about 4500 ^^
AR500161*
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.0
•
67
gallons possibly.
Under that alternative, you are going
to get virtually none of the residual coal tar
because it is too tightly bound to the cobbles.
I think with the enhanced recovery,
you are going to get, I believe the estimate was
7200 hundred gallons. You are looking at 60 to 70
percent removal of the free coal tar in the coal
tar pool. And you are also getting up to maybe
another ten thousand gallons of the residual coal
tar lying about that stratagraphic sink.
I think also by getting that residual
coal tar, you are helping to prevent the amount of
coal tar that you had available from running back
down and into that sink and re-accumulating.
MS. DICOSMO: Next?
MR. MATERGIA: Ralph Matergia,
solicitor for the Borough of Stroudsburg. To what
extent is the Borough of Stroudsburg a potentially
responsible party to recovering cost?
MR. BANKS: At this time I really
don't want to comment on that because typically
when we will know the potentially responsible
IIt)
•
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31j1I3|1
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68
parties is after the record of decision is signed. •
At this time I don't think any final
determinations have been made.
MR. MATERGIA: Has there been any
communication between your department and the
Department of Environmental Resources indicating
that the Borough of Stroudsburg is being
considered as a potentially responsible party?
MR. BANKS: Again those are ongoing
enforcement activities and whatever other
litigation activities which we just don't feel we
can comment on at this time. m
MR. MATERGIA: Do you have any reason
to believe, Mr. Banks, that any of the parties who
were designated as potentially responsible parties
back in 1980 are not being considered as
potentially responsible parties today?
MR. BANKS: Again, I'm going to
defer, those are legal questions and we will, you
know, finalize our determination of who the PRP ' s
are and submit specialized letters to them.
MR. MATERGIA: Am I lead to believe
from the discussions we had today and this evening J
AR500166
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69
that the risk of migration of the coal tar into
the Brodhead Creek is itself really not a
particular concern at this point as, the slurry
wall had basically contained the coal tar from
entering the stream?
MR. BANKS: If you are speaking about
the free coal tar entering the stream, I'd say
yes. And as for the ground water that is
contaminated, discharging into the creek that's
not concerned either because it's just being
diluted since hitting the creek.
MR. MATERGIA: And therefore, is it16
accurate then that the impact or concerns that
your agency is addressing with respect to this
remedial plan is the impact on ground water
solely?
MR. BANKS: Yes.
MR. MATERGIA: If you can, maybe in
some lay terms, give some appreciation for the
risk of the residual coal tar to the ground water
versus the hole that you are speaking.
MR. BANKS: Well, when talking about
the coal tar at the site, I think what we can say
————————————————————————AR5QQ1G7—
70
is the free coal tar pools compart the highest
levels of contamination. I think some of the
ground water results were got for benzene, which
is one carcinogen was 1100 parts per billion,
which is above its drinking water standard of five
parts per billion in the ground water.
We are also looking at arsenic which
is another carcinogen which is at 108 micrograms
per liter, which is also 108 parts per billion.
Its drinking water standard is 50 parts per
billion.
If you are looking at the number of
PAH's and benzoid pyrine, chrysine and denopyrine,
which are well above they're drinking water
standard of point two parts per billion.
There is a high level of
contamination being imparted to the ground water
at the free coal tar areas.
Now, as we move away radially from
the free coal tar areas, not only the RCC area,
but the smaller part pool at MW2, we see a
decrease in the contamination in the ground water.
What that suggests is that the highest levels ofAR50QSS8
¥
¥
71
the ground water contamination is the free coal
tar. It contains the most volatiles and still the
most soluable constituents.
The residual coal tar spread
throughout the rest of the site is probably
stripped of most of its volatile content. It's
become very sticky.
PAH's don't have a tendency to
dissolve into ground water. They have a high
affinity for staying bound to soil particles and
to organic particals.
So, I think by removing the free coal
tar, you are going to drastically reduce the
amount of ground water contamination on site.
MR. MATERGIA: Now, with respect to
these alternatives, explain to me, if you will,
the alternative, I think it was six, that had to
do with the excavation, is that limited to just
the areas where free coal tar is located?
MR. BANKS: Well, more specifically
it is just limited to the RCC area which is the
bigger pool.
MR. MATERGIA: That doesn't treat the
____________________flR.snn {sg
72
¥second area?
MR. BANKS: No, the problem with the
second area is it abuts the slurry wall.
MR. MATERGIA: Excavation with
potential damage to the slurry wall?
MR. BANKS: That's right, we could
reach the slurry wall.
MR. MATERGIA: Does pumping at the
location of the MW2 prefer an alternative to the
alternative five? In other words, I guess what I
am asking you is could you excavate at the one
location on the RCC and have to pump the RW2? f|P
Is that an alternative?
MR. BANKS: Well, you could do that.
What you can do under the feasibility study is
take portions of alternatives and combine them in
a record of decision.
Again, I do want to re-emphasize, as
far as the excavation which when going through the
nine evaluation criteria as far as the
implementability, because of the high water table
and silty sand, you have a running sand problem
and we feel we are going to run into significant mj^
AR500I70
73
problems as far as slope stability going with
excavation in that area, which is going to have to
go down approximately 30 feet.
MR. MATERGIA: In evaluating that
particular alternative, did you speak to any of
the parties that are involved in the project,
reconstruction of the sewage treatment plant here
in East Stroudsburg, speak to the contractors and
engineers involved in that project?
MR. BANKS: No, we haven't.
MR. MATERGIA: I might suggest that
you do so. They had to undertake excavation in an
area that is fairly close in proximity to this
area, to get a better idea what to expect when you
dig down.
Tell me if you will, where this
process has been undertaken with respect to coal
tar removal other than where you had other
experiences with this I guess is what I am asking?
MR. BANKS: I would have to get more
information on that. I am aware that it was
applied at one other site that had similar coal
tar contamination problems. But I'd be happy to
74
¥get you more information on that.
What can the residents of the Borough
expect to observe while the recovery process is
being undertaken? What are we going to see when
we drive by and stand on the bank and fish and so
forth?
MR. BANKS: I think what you are
going to see, this process calls for ten injection
wells and two extraction wells. So you are
looking at 12 wells being put in, one remediation
cell on site.
for heating the water for injection into the
subsurface. There is going to be some sort of
phase separator on site because when you pull up
the recovered coal tar, you are going to pull up
coal tar and process water and you are going to
have to separate the two.
And You are probably going to see
some sort of on site treatment system for the17
process water of which I don't know yet,
biological filter, chemical precipitation,
r true
AR500I72possibly also a tank, to hold, tanker truck or a Jfc
75
tank to hold the recovered coal tar as is being
recovered for eventual shipment off the property.
MR. MATERGIA: I think your report
talks about a period of time, six months?
MR. BANKS: It talks about six months
to implement the process. I think the report
assumed an operation time of approximately three
years.
MR. MATERGIA: How would you propose
to secure the site other than to fence it,
assuming that the concept of fencing is determined
by the community as unacceptable or undesirable?
MR. BANKS: Fencing is undesirable?
MR. MATERGIA: Well, I'm asking you
to assume that it will be.
MR. BANKS: I guess what we could
look at is posting a guard there.
MR. MATERGIA: What will the site
look like after you're gone?
MR. BANKS: I wouldn't imagine it
would look any different than it is now.
MR. MATERGIA: Will it be fenced?
MR. BANKS: I think we call Rroafi<P tha>t
76
¥determination at a later point.
MR. MATERGIA: Who will bear the long
term maintenance responsibilities with respect to
the site?
MR. BANKS: State of Pennsylvania
typically has to give an assurance. Well,
actually I should say if it is undertaken by
potentially responsible parties, typically we try
to get them to pick up the long-term operation and
maintenance on the site.
Barring that, typically we could get
an assurance from the state to pick up operation mjp
and maintenance.
MR. MATERGIA: Anybody from the State
want to speak to the question of whether or not
the State will try to pass that responsibility off
to the Borough of Stroudsburg?
Nobody wants to give me that
assurance?
MS. DICOSMO: Any further questions?
MR. ROGERS: Carl Rogers for the
Borough of Stroudsburg. What was the MPL score?
MR. BANKS: I believe the MPL score Jfe
AR500I71*
77
was 31.09.
MR. ROGERS: Presently the total
excess carcinogenic risk is less than the
acceptable amount; is that correct?
MR. BANKS: Yes.
MR. ROGERS: Do you have any idea how
the remedial action that you are proposing would
further lower that risk?
MR. BANKS: Well, with the risk
assessment, the risk assessment did not take into
account ingestion of contaminated ground water on
the site. It took everything else into account
other than that.
At the time the risk assessment was
being done by the PRP's, EPA felt that because we
? already exceeded drinking water standards in the
shallow ground water, there was no need to do a
risk assessment on the ground water because it was
clear, there was a potential health threat already
there.
As I said, the benzene concentration,
arsenic and benzoid pyrine exceed the promulgated
drinking water standards for human cons&mp5tQLon!.7 5
3
78
And it is our belief that when we remove these
coal tar pools, we are going to substantially
reduce the human health threat from ingestion of
that ground water because we are going to be
lowering the concentrations of the constituents in
the ground water significantly.
But again, I also have to
re-emphasize again at the same time, it is very
unlikely that somebody will screen a well in the
gravel unit at the site simply because of a number
of site constraints. It's in a flood plain, it's
in an industrial area.
A well screened in that unit may not
even produce enough water. It may to supply a
small household or a small business. But because
we cannot impose, there are no restrictions from
somebody putting a well in that area, we have to
take into consideration possible human health
threats if somebody were to screen a well in the
ground.
MR. MATERGIA: Mr. Banks, we have
ordinances in the Borough of Stroudsburg that
prohibit instituting wells in our town. We have a
¥
¥
•A R 5 Q Q I 7 6
79
municipal water system. We don't permit, but we
make mandatory that the water service connection
be municipal. Does that fact have any impact on
evaluation?18
MR. BANKS: I think that is something
we have to take into consideration. I am glad you
brought that up.
MR. MATERGIA: Let me ask just
another question, assuming you draw a line around
an area where you would like to prevent wells from
being dug for health reasons. What is then the
risk of contaminants in the ground water outside
that area? What happened at that point?
MR. BANKS: Well, I would say
upgrading it, meaning towards the west of the
site, I don't think you are going to see
significant contamination because of the ground
water flow, it is basically moving the
contamination towards the creek.
I would definitely still like to see
bedrock analyzed because I want to be confident
that the bedrock is not being impacted.
If the bedrock is not being impacted,AR500I77
80
it would seem that indeed the shallow ground water
is discharging into the creek and therefore it is
not going to impact anybody on the opposite side
of the creek.
So I think if we drew a circle
around the site where you are not going to allow
wells, I think we can be reasonably confident that
there is going to be no human health threat.
MR. MATERGIA: Is it possible to do
the testing, test wells in bedrock prior to
institution of this recovery method?
MR. BANKS: We certainly want to
¥
¥expedite trying to put these test wells in. I
still think though that we need to go back and
re-analyze it. The problem I am having I guess is
that you still, barring even the exposure, you are
still having degradation of a natural resource.
And generally under the ground water protection
strategy that we do want to try and return ground
water to its beneficial use.
And I think given the information
that you just told us that there are ordinances in
the City of Stroudsburg for putting in private 4fe
AR500I78
81
wells, I think we would need to take that
information and go back and re-analyze the
situation.
MR. MATERGIA: And also, just for
informational purposes, you know the Borough's
limits basically stop at the stream. You are
talking about wells on the other side of the
stream, you will have to talk to the officials of
East Stroudsburg, where I believe they have a
similar ordinance.
MR. BANKS: This is a question for my
own. There are some private wells, though, in the
area. There are 40 wells in a two mile radius.
Was this ordinance enacted recently or are these
older wells?
MR. ROGERS: Two mile radius will
take you well outside the Borough of Stroudsburg.
MR. BANKS: I believe there are some
inside the Borough. I can't remember, there is
one hotel. Indian Queen Hotel or something like
that?
MS. SNOPARSKY: I have a question.
If the people were to be hooked up to pufa^ftfe Q Q j 7 9
82
water, does that prevent them from putting a well
in themselves?
MR. MATERGIA: I think so.
MR. ROGERS: Not only the Borough,
but DER regulations also.
MS. SNOPARSKY: DER I don't think
does .
MR. MELLOW: John Mellow from DER.
DER does not have any regulations regarding
installation of wells in private residences. We
have regulations on anything but commercial
supply.
MR. MATERGIA: Perhaps if you would
exchange your information concerning well
locations, we will respond.
MS. DICOSMO: Next question?
MR. MASSE: I just have a followup.
In the alternative five, your option five, you are
proposed to go ahead with it, in the event that
you don't go ahead with five, as it has been
presented here tonight and you modify it or go to
another proposal, would there be another public
meeting? AR500180
¥
83
MR. BANKS: I believe there would be.
MR. PIKE: If due to the comments
from the public, folks here, written comments we
receive, the agency and the consultation with DER,
we determine there is another alternative that may
be better for the site, re-evaluation of the
information that came in.
If it is one of the alternatives that
we presented tonight, we would not have to go out
for more public comment. If it is something other
than one of the alternatives we presented here,
then we would have to go out to the public for
comment.
It may be a combination of one or two
of those, but the point that I made earlier, maybe
excavation and pumping of the wells. But as long
as it is a combination of something presented
tonight here, essentially we would not have to go19
out for public comment
MR. MASSE: Well, the only comment I
made about that is I am under the impression that
the option five is the preferred option and that
was presented and not the other five options were
———______________QRsnnm
84
presented. VP
MR. PIKE: Well, the proposed
remedial action plan talks about each one of the
altneratives. The public administrative record of
those studies identifies the different
alternatives.
MR. MASSE: But it doesn't afford an
opinion for any request or information in the form
that you presented here in that I might have
opinions on the other options which I didn't
express as being feasible or not. I know that
option five is not a viable action opinion, you
don't get your bang for your bucks in my opinion.
In the presentation I understood
clearly what was said by EPA and what they propose
to do. I understood that very clearly about the
treatability and the unknowns, the costs
associated with option five.
I do not have an explanation other
than reading a document and not having a public
forum on the other five options and I just am
wondering the wisdom of you people not explaining
to the public or having an opportunity to respondAR500182
1*
0
=?
1
15z_J
5a
3
3
*
85
to the other five options if they are viable or
not.
MR. BANKS: I think you do have a
public forum. I think the purpose of this public
meeting is for us to present our preferred
alternatives, but it is to get comments from the
community on the preferred alternative on the
feasibility study, on the remedial investigation
report and on all the alternatives that we
presented.
I mean if you don't have an
understanding of an alternative I put up here on
the screen, I would entertain questions on it and
I think you would be afforded that opportunity.
MR. SWIFT: Since you have raised
that, let me ask you about the excavation
alternatives. This was an alternative that a year
ago, I believe, in papers filed with the Federal
Court in Philadelphia, the State of Pennsylvania
should be done. What is EPA's position as to
whether or not the entire site should be excavated
and removed and new soil should be brought in?
MR. BANKS: I am not aware of DER'sAR500183
86
t'
we would not like to see full scale excavation on
the site. I think then, you are talking about
getting a bang for a buck, then you are talking
about enormous costs, you are talking about
tearing down a flood control levee, damage to
wetlands, rerouting public utilities underneath
the site.
And I don't think the, I just don't
see it being feasible to even do something like
that.
MS. DICOSMO: Anyone else? flfc
MR. ROGERS: 4.2 million is the
estimated cost of OUl or your performed
alternative five, that is not the end of the
operation as I understand it, there is an OU2?
MR. BANKS: Yes.
MR. ROGERS: What would be involved
in OU2?
MR. BANKS: OU2 is going to involve
further investigation at the site simply with the
bedrock aquifer. We want to assess the quality of
the bedrock aquifer. Take that information,
AR500i8Ii
87
analyze it against the other ground water results
that we do have and in conjunction with how, if we
do implement the preferred alternative, which is
the enhanced recovery, how that is working, we
come up with an overall site plan.
And the determination of what the
otherall site remedial action would be will be
made at a later date.
MR. ROGERS: So OU2 would take place
simultaneously --
MR. BANKS: Yes.
MS. DICOSMO: If I might add, the
same process would then be implemented in terms of
the steps that we were talking about earlier. We
would then again, when those decisions are ready,
those alternatives were prepared and we would
again come out with a remedial plan for that and
implement it.
MR. ROGERS: EPA will assume these
responsibilities with OU2 and all other future
site activities, what does that sentence mean?
MR. BANKS: It means at this point as
far as OU1, we will go ahead with the designing
88
construction of the enhanced recovery process, if
that ultimately is the selected alternative.
As far as OU2 , EPA will undertake,
will be lead agency for OU2 in implementing,
either implementing or overseeing the PRP's,
putting in the bedrock wells and doing a focused
remedial investigation and feasibility study.
MR. ROGERS: So as in OUl, we would
be looking for the PRP's to pay for the study and
any actions taken on OU2?
MR. BANKS: Let me be a little more
clear. OUl, first we'll try to reach an agreement
with the PRP's to undertake it themselves.
Failing to do that, EPA will undertake them. And
then seek cost recovery afterwards from the PRP's.
MR. ROGERS: So you want to involve
some studies as of yet uncollected data, you are
going to have an estimated OU2 , cost estimate for
OU2?
MR. BANKS: Not at this time.
MR. WISE: Brad Wise. Why do you do
OU2 at all? I am still unclear on that. Why
would you want to go in the bedrock anH 'i O;K f/Oa: ¥flR500J86
89
something else?
MR. BANKS: I think we have concern
that there is -- we are not disagreeing with the
conclusions drawn. I think we do want to feel
confident before writing a final ROD on this site.
And I think one of the concerns we
had was, it was either boring, B14 or MWB14, in
that boring, there was an odor down in the silty
sand unit. Now, whether it is part of the coal
tar, possibly. I just think we need to me sure
that indeed there is no vertical migration down to
the bedrock. Just some hard data.
MS. SOMASICK: Mary Jean Somasick,
borough council. We may not have another
opportunity to disuss the other alternatives, just
tell me why alternative five is better than
alternative four? I don't have any knowledge
other than what I have here in front of me, but it
looks like alternative four costs a little bit
less and moves more free coal tar and the result
is three to six percent.
MR. BANKS: Going through those nine
criteria again with the implentability,AR500187
90
alternative four employs the soil washing. And flp
again we are talking about excavating contaminated
soil and leaving open a large excavation from
which contaminants can volatilize.
Now, we are talking about stock
piling soils, clean over burden materials, stock
piling those, which may have some coal tar
contamination, probably stock piling some of the
coal tar contaminated soil while it is waiting to
be run through this soil washing treatment.
I think more of a concern with human
exposure from the soils being less stock piled,
plus from the open excavation area being there.
I think also with the soil washing,
giving the type of soils we have, we are talking
about a stream gravel where we have cobbles,
rather large cobbles, we may be talking about
materials handling problem with the soil washing
unit.
So it does have some drawbacks. And
I might mention to say also that the soil washing
is also an emerging technology.
MS. DICOSMO: Anyone else^?R 5 0 0 I 8 8
91
Shall I slam the gavel down?
Okay. I would like to thank everyone
for coming this evening. I would also like to
reiterate the comment period is open until March
18th.
(Concluded.)
* * *
92
¥I, BONNIE HAYES, a shorthand reporter
and Notary Public in the State of Pennsylvania,
certify that the foregoing is a true and
accurate transcript of the hearing taken
stenographically by me at the time and place
and on the date hereinbefore set forth.
I further certify that I am neither
attorney nor counsel for, nor related to or
employed by any of the parties to the action in
which this proceeding is taken, nor am I J^
financially interested in the action. I
BONNIE HAYES, COURT REPORTER
A R S O O i B O ¥