public information meeting salford quarry site boron

Public Information Meeting

Salford Quarry Site

Boron Action CommitteeU.S. Environmental Protection Agency, Region in

Tuesday, July 14, 19927:30 p.m.

AR300005

Public Information Meeting Summary

Salford Quarry Site

Table of Contents

L Introduction by Dr. Richard Pierotti, Boron Action Committee......................Page 1

IL EPA Agenda ...........................................................

A. David Sternbcrg.............................................»..».................,....................» Page 1

B. Cfesarl...............................................................

C. Lori Baker....................................................................................................Page 1

D. Jack Kelly ......................................................................................... Page 3

E. Jack Owens.................................................................................................. Page 4

m. Question and Answer Summary By Topic

A. Site De-listing.............................................................................................. Page5

B. RI/FS and Testing-related .......................................................................... Page 6

C Removal Action/Installation of Water Line................................................ Page 7

D. Technical Issues.......................................................................................... Page 8

E. MisceUaneous...............................................................»...........«.............

IV. Conclusions .................,...........,......,.................................................................

Appendix A: Presentation Materials, Cesar Lee

Appendix B: Presentation Materials, Jack Kelly

HR300006

Salford Quarry Site Public Information Meeting Summary

Public Information Meeting Summary

Boron Action CommitteeU.S. Environmental Protection Agency, Region HI

Salford Quarry SiteJuly 14,1992

Introduction by Dr. Richard Pierotti, Boron Action Committee

Dr. Pierotti opened the July 14,1992 public meeting by reviewing some recent Siteevents since the last meeting on November 20,1991. After last year's meeting. Dr.Pierotti and several other concerned citizens formed the Boron Action Committee andinitiated a petition drive to expedite activities at the Site. The Committee obtained 180names on a petition and submitted it to Senator Specter. In May 1992 Jack Owens, theOn-Scene Coordinator for the Removal action at the Salford Site, received approval touse Superfund trust fund monies under the Emergency Removal Program for Salford. Atthis point Dr. Pierotti turned the meeting over to David Stemberg, the CommunityRelations Coordinator for the U.S. EPA.

EPA Agenda and Presentations

A. David Sternberg, Community Relations Coordinator, U.S. EPAIntroductions and Agenda

After introducing himself, David gave an overview of the agenda for the meeting.He also asked that questions be held until after the presentations were complete.

B. Cesar Lee, Remedial Project Manager, U.S. EPAChronology of Site Events

Cesar began by discussing the history of the Salford Quarry Site, starting with itsusage as a stone quarry in the 1800*5, through recent discovery that it had beenalso used for disposal prior to American Olean's usage. He focused on the mostrecent Site activities, including the purchase and selling of American Olean byNational Gypsum in August 1988, the Remedial Investigation/Feasibility Study(RI/FS) started in May 1990, the Site listing on the National Priorities List (NPL)in August 1990, and the bankruptcy filing by National Gypsum in October 1990.Following the November 1991 public meeting, Jack Owens signed an actionmemo to provide affected citizens with bottled water in case National Gypsumdiscontinued its provision of bottled water. The Site has most recently been de-listed from the NPL. Sec Appendix A for a copy of Cesar's presentationmaterials.

C. Lori Baker, Site Assessment Expert, Preliminary Assessment/Site InspectionSection, U.S. EPA.Recent Court Decision on Site De-listing

Lori provided an explanation and history of the recent court decision which de-listed the Salford Site from the NPL. National Gypsum first disputed the scoringof the Site during the comment period when Salford was initially proposed for theNPL. EPA responded with no score change, and the Site was listed in August1990. In March 1992, the Court heard the Salford case, and on June 19,1992

My 14,1992 flR300007 """


vacated the listing. This court action effectively means that the Salford Site was"never on the NPL." The Site was sent back to EPA. with the option to either domore sampling or provide better documentation on the original decision to list theSite.

Lori continued with an explanation of the Hazard Ranking System (HRS), thescoring method used by EPA to determine a site's potential risk. The systemconsiders and assigns a score to such factors as observed releases, the toxicity andpersistence of the substance, and the number of people potentially affected If asite receives a score over 28.5, it is placed on the NPL. The Salford Site rankedover 50 using the HRS.

At the Salford Site, EPA initially tested for the presence of total boron. Boron hasa high toxicity and persistence. National Gypsum argued that only boron oxide ispresent at the Site, which is not toxic or persistent

At this point several audience members had questions for Lori.

Q: How did the court get the data to decide the case?

A: (Lori) National Gypsum presented information showing that boron oxide wasneither toxic or persistent. This was the major factor in the court's decision.

Q: Why did the court take National Gypsum's word?

A: (Jack Owens) The case was decided on two very thin issues. It is veryunusual for a site to be de-listed. However, the community is still receivingbottled water, and EPA Regional Counsel is discussing how to get the site back onthe NPL.

(Lori) This is one of the first NPL lawsuits that EPA has lost The courtrecommended that EPA perform more sampling and testing for different types ofboron compounds. EPA does not have a method to sample for these specificcompounds, but is currently doing a literature search on this topic. If EPA doesnot sample, the agency must at the very least provide better documentation on thetoxicity and persistence of boron oxide. EPA is also deciding whether to use theold HRS or the new HRS. Salford was originally ranked using the old model.The new model went into effect in December 1990 and now all sites are scoredusing that model.

(Jack O.) The Department of Justice presents the case, not EPA. EPA stronglydisagrees with the court decision.

Q: National Gypsum only owned the quarry for a short period of time. Whyare they responsible?

A: (Jack O.) Because that was a term of the purchase agreement.

(Cesar) What is also of interest is that National Gypsum bought the quarry butonly sold American Olean to Armstrong Tiles within a month. National Gyps ninformed EPA that it would assume full liability concerning the Site. Incidentally,National Gypsum is using the same lawyers that American Olean used previously.

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Q: Is the technology not available to accurately test for boron?

A: (Lori) Boron is not commonly tested for, and when we test for it, we onlytest for total boron. EPA is currently looking for a method which woulddistinguish between different boron compounds.

Q: So EPA is not the advocate in this case, it is really the Department ofJustice.

A: (JackO.) It is a coordinated case, with EPA presenting to the Department ofJustice. The issue is that boron is not a hazardous waste, it is actually acontaminant

Q: Were you ever able to get through the soil cover? Is National Gypsumcooperating?

A; (Cesar) No, we have not been able to get through the soil cover yet becauseof National Gypsum's court action. National Gypsum has continuously contestedEPA's recommendations. To this day we have no idea what was actually buried inthe quarry. National Gypsum would like to settle, but they are not offeringenough money to properly clean up the Site.

Q: Is there also TCE present?

A: (Cesar) Yes. TCE was found in the monitoring wells around the Site.

D. Jack Kelly, Agency for Toxic Substances and Disease Registry (ATSDR)Boron Overview

Jack opened by providing an explanation of the role of the ATSDR. This agencyis part of the U.S. Public Health Service, and provides EPA with informationupon request on issues concerning the public health.

Jack continued the presentation by explaining the toxjcjty of boron. This can beexplained using the toxicity response curve. The tpxicity effect is measured basedon animal studies. Generally, EPA selects the critical effect in the most sensitivespecies. EPA determines the no adverse effect level, which is 8.8 mg/kg/d forboron. Then EPA applies uncertainty factors to determine a reference dose,which is .09 mg/kg/d for boron. See Appendix B for a copy of Jack's presentationmaterials.

At this point, several audience members had questions for Jack.

Q: What are other sources of exposure to boron?

A: (Jack K.) Glass manufacturing, wood preservatives, pesticides, flameretardants, and fruits and vegetables.

Q: What is the worst well at Salford?

A: (JackK.) 23 mg/Hter or 23 parts per million. That is 25 times therecommended level for children. However, there is no data proving any effect atthis level.

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Q: Would you drink the water?

A: (JackK,) Not if I could get a cleaner source.

Q: Do you have any more data on the boron leaching into the soil?

A: (JackK.) No.E. Jack Owens, On-Scene Coordinator, US. EPA

Removal Actions. Recent Water Testing and Water Ling Installation

Jack stated that until the source of contamination at the Salford Site is properlyremediated, the contamination will continue to spread. Emergency Response hasgotten involved because of the unusual circumstances at this Site. This is the onlyboron-contaminated drinking water site in the United States, and there is noknown filtration system to eliminate the contamination, which is why EPAdecided to install the water lines. There is also an on-going debate in thescientific community as to how dangerous boron is.

EPA developed a site map illustrating the plume. Over the past two weeks 52water samples have been collected, and 11 more still need to be collected. Thepreliminary tests have just come back, and indicate that some boron levels havegone down. This is the "ping-pong1* effect EPA has had a difficult time gettingthe water line implemented.

To speed this process, the Superfund Accelerated Clean-up Model came outwithin the last three months. This fund has only been tapped three times, twice byJack's section. He has obtained the funding for the water line, even though thesampling has not been completed.

Jack is maintaining close contact with the North Penn Water Authority to speedup the water line installation process. Thirty homes will definitely get a waterline, and hopefully more homes will be included Jack displayed a mapillustrating where the water lines would be and which homes would receive accessto the line. Jack emphasized that this map changes daily.

Environmental Technologies in Richmond, Virginia, will issue an invitation to bidfor construction of the water lines. They must receive at least 3 bids and thelowest bid will be selected. When the water lines are complete, the North PennWater Authority will take over the lines. Those homes sandwiched between highand low levels will most likely not be involved in the water lines.

HI Question and Answer Summary by Topic

Following the presentations, David turned the floor over to those assembled to askquestions of any of the presenters.

The questions and answers have been grouped according to topic area for ease ofunderstanding.

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A. Site De-Msting

Q: What is the timeline for putting Salford back on the NPL?

A: (Lori) We're not really sure how long it will take. If we can resubmit the Siteusing the old MRS model, it may be a matter of months. If we repropose the Siteusing the new HRS model* it could take a year or longer.

(David) Under CERCLA we can continue the RVFS even though the Site is nolonger listed [Title 40, Code of Federal Regulations. 300.425]. So the data is stillcoming in.

Q: We're hearing rumors that EPA is abandoning the Site.

A: (Lori) The Department of Justice is not interested in petitioning the court foranother review. That has nothing to do with EPA's interest in the Site, whichcontinues. We will do everything we can to put the Site back on the NPL.

Q: So who do we pressure to make things happen? The Department ofJustice?

A: (Lori) The EPA attorney is actively pursuing the Department of Justice tomake a decision on the best way to re-list the Site.

Q: Can the community be included in this process?

A: (Lori) At this point, there is really nothing that the community can do. It is amatter that must be decided by the DOJ and EPA.

Q: How much money will it cost to clean up the Site?

A: (David) The average Superfund site costs $25 million to clean up.

Q: I'm quoting from the data • "boron compounds rapidly transform toberates in water." The data is there. No matter what the tests indicated,how did EPA lose?

A: (Lori) We don't know. The DOJ and EPA Headquarters'attorneys tried thecase. The Region had very little involvement They thought they had a strongcase, and were surprised by the decision.

Q: What is the time table for the legal activities? What are the next steps?

A: (Lori) We are waiting for the decision from EPA attorneys at headquartersregarding whether we should use the old or new Hazard Ranking System.

Q: What is it about the new system that makes it so different?

A: (Lori) The new system is much more complex, and it weighs more towardsenvironmental effects than the old model.

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B. RI/FS and Testing-related

Q: Has any contamination been found in the surface water?

A: (Ccsar) Yes, low levels of boron have been detected in Skippack Creek.Boron levels of 400 ppb were detected downstream of Skippack Creek whilelevels of 130,000 ppb have been detected in a seep/spring adjacent to the quarry.

Q: Is there a well depth range which indicates higher levels of boron?A: (Ccsar) No, we don't have that information presently, but it is beinginvestigated as part of the Rl/FS.

Q: Do the most recent test results show that the plume has spread?A: (Jack O.) Yes, it has spread slightly to the southwest We are doing moresampling to track the spread

Q: Are the wells being tested new wells, or are they the existing wells?

A: (Jack O.) Only the wells which have been tested in the past are being re-tested.

Q; What about the independent lab readings which show different results?

A: (Jack O.) EPA uses extremely qualified labs which follow stringent QualityAssurance/Quality Control procedures. We also send in blanks and duplicates todouble check. If there seems to be a problem* we will pursue it

Q: If they cleaned everything out, how long would it take for all thecontaminants to go away?

A: (Cesar) We don't have that information presently. Our approach has been totry to get to get at the source under the soil cover. The best way to eliminate thecontamination is to eliminate the source rust To attempt to define every fractureand plug every possible path of migration is next to impossible (as can be seen onpictures of fractures in the quarry walls).

Q: Why is National Gypsum refusing to let you?

A: (Cesar) They claim there is enough data on what they disposed.

Q: Will the contractor lab be able to distinguish between species of boron?

A; (JaclcO.) If there is a need, yes.

Q: On the testing, is there a margin of error associated with the testsamples?

A: (Jack O.) It depends on the detection limits established.

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Q: Does a water softener mask the test results?

A: (Jack 0.) We considered that when performing the tests, and got the water atthe source. A softener does lower the rating.

Q: On what basis did you determine which houses to test initially?

A: (Jack O.) By the plume. We tested everyone around it

Q: Is your map at 600 ppm or 900?

A; (JackO.) This map is actually 600.C. Removal Action/Installation of Water Line

Q: Shouldn't EPA do more periodic testing first to make sure of the homesthat should be hooked up to the water line?A: (Jack O.) We have gathered sufficient data to make the decision. We willtest quarterly to track the plume.

Q: Will the quarterly testing be performed by Remedial or Removal?

A: (Jack O.) We don't know right now. If there is a dispute Removal will do itThat type of testing is more remedial, it is not normal for Removal to do it

Q: What about the homes that don't qualify for the water line?

A: (Jack O.) For $2,500 the North Penn Water Authority can provide access tothe property line. This payment can be extended over five years. There is anadditional charge to extend the water line from the property line to individualhomes.Q: What about the undeveloped land adjacent to the water lines?

A: (Jack O.) The line will be 16 inches so that future ties will not be a problem.It is a simple procedure.

Q: What will happen in the long run? What if they discover moreproblems?

A: (Jack O.) The most effective solution is to remediate the Site. If there issufficient demand for additional water lines, the water authority will do the line.We are looking to start in the Fall and be done by Christmas.

Q: If homes don't get the water line under the Emergency Removal, will theyhave to go through the whole process again to get the water line?

A: (Jack O.) Yes, unless they want to pay for it

July 14,1992 ^ . n Page 7PR3000I3


Q: Shouldn't the selection of homes for the water line be done geographicallyrather than by individual test results?

A: (Jack O.) There are a lot of contract issues related to that decision. It willtake time to get the program together.

Q: Is there any cost for the homes which have been selected to get the waterline?

A: (JackO.) No.

Q: What about those homes that are dose to the contamination. What abouttheir water?

A: (JackO.) They can either hook up to the line or buy bottled water.

Q: What if they can't afford it?

A: (JackO.) We are looking at the marginal concentrations for safety. Nothingis set in stone.

Q: The most recent tests indicated that 10 homes had higher boron levels.Are they included on the map?A: (Jack O.) This map is 99% correct There were two additional homes that Ididn't have the chance to update on this map.

D. Technical Issues

Q: I've talked to a waste expert and a geologist, and both are uncertain thatthe boron concentrations will not go up in the future.

A: (Jack O.) My funding guidelines are limited. We are trying to work aroundboundaries.Q: You're testing wells at whatever level they are. What about someoneoutside the plume with deeper or more shallow wells?

A: (Jack O.) All areas have been tested. There are seasonal changes and changesin well depths, which we have considered.

Q: People are concerned about the variability of the test results. Could youexplain that?

A: (Jay Newbakcr, EPA Hydrogeologist) The variability of the levels ofcontamination observed in some residential wells can be attributed to threefactors. First, how much the well is used. Second, the vertical extent anddistribution of contamination which has not yet been contaminated. Three, thenumber of water-bearing intervals intercepted by a given welL The plume isnarrow and runs about 3/4 of a mile southwest of the Site. The movement of theplume in this direction is consistent with the fact that both the primary jointsystem and the water-bearing beds - the two factors controlling groundwater flow-trend in a northeast-southwest direction.

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Q: What happens if we stop using the wells?

A: (Jay) Geology is driving the problems, not well usage. It would change thehydraulics of the system, but I don't know how much.

E. Miscellaneous

Q: There is disagreement between EPA and people I have talked to. Isn'tEPA supposed to protect the public? If you can't do it, who do we pressureto do it?

A: (Jack O.) I don't know. I can tell you that Specter did not have any input tothis decision. As an agency, we're trying to be fair. No matter what, someonewill be unhappy.

Q: What Is the time table for telling us about future plans, another meeting?

A: (Jack O.) We are still collecting data, and there are more things to be done.As soon as I know more! I will share it with you.

UL Conclusions

David ended the meeting by thanking everyone and promising a fact sheet in the nearfuture to update the community on the most recent Site developments. David alsoencouraged citizens to call him with any questions. Dr. Pierotti also thanked everyonefor coming and promised to continue pushing for more homes to receive the water line.

July 14,1992 Page 9RR3Q0015

Appendix A

Presentation Materials:Cesar Lee, Remedial Project Manager, U.S. EPA

Salford Quarry Site

Public Information MeetingJuly 14. 1992

AR3000I6

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1800's Quarried for Stone/Aggregate for Unknown Period of Time.

1940's to1950*S Quarry Used for Waste Disposal. Contents of Wastes were

Unknown.

1963 Quarry Purchased for Waste Tile Disposal.

1974 2 Monitoring Wells Installed.

1976 Quarry Capacity Reached.

1980 Continue Complaints Received Concerning Site.

1982 Quarry Capped. Elevated Boron & TCE in On-siteMonitoring Wells.

1983 PAISI. 3 Homes Sampled (below 3150 ppb).

1986 Site Proposed for A/PL.

1988 PRP (American Olean) Agree to Conduct RI/FSJMafChJNational Gypsum (NG) purchase AO.lAu9UStfNG sells AO to Armstrong Tiles.

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1989 20 Additional Homes Sampled (below 3150 ppb). **NG Submits RI/FS Workplan. **°*

1990 EPA Comments on RI/FS Workplan. MarchNG Disputes EPA Comments. *"Dispute Resolved. RI/FS Starts. Ma*Access (Monitoring Well) Problems. RI/FS Stops.Jun9Site Listed on NPL ***NG Files for Bankruptcy. <**NG Files Challenge to Listing on NPL °"

1991 Access Problem Resolved. MvchNG file Proof of Claim/Estimation Hearing in Dallas.Jw"RIIFS Field Work Complete. ***Results of Sampling Above 'Action Lever. **"*Additional Home Well Sampling. s"*-0tc*BA(? is formed. "~Action Memo Signed (Bottled Water). Meeting w/NG on Additional Studies. °"

1992 NG Submit Additional Workplan.JanEPA Comments on Workplan. MafchNPL Listing Court Hearing in DC. MarchNG Resubmit Workplan & (reserve) Dispute. ***NG Invoke Dispute Resolution. M3yEstimation Hearing in Dallas. MayEPA made Determination on Dispute Resolution.Jun*Action Memo Signed (Waterline).Jun*Site Delisted from NPL & Estimation Hearing Decided.Jun*

Appendix B

Presentation Materials:Jack Kelly, ATSDR

Salford Quarry Site

Public Information MeetingJuly 14, 1992

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