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Second

FIVE-YEAR REVIEW REPORT

Palmerton Zinc Pile

Superfund Site

Palmerton, Carbon County, Pennsylvania

February 2002

Prepared By:

U.S. Environmental Protection Agency

Region III

Philadelphia, Pennsylvania

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Table of Contents

Description Page(s)

Table of Contents ii - iiiList of Acronyms iv - vExecutive Summary vi - viiFive-Year Review Summary Form viii - xiI. Introduction 12 - 13II. Background 13 - 14 Land and Resource Use 13 History of Contamination 13 - 14 Physical Characteristics 14 Remedial Overview 14III. Remedial Actions 15 - 23 A. Operable Unit 1 (OU 1) - Blue Mountain 15 - 18 B. Operable Unit 2 (OU 2) - Cinder Bank 18 - 20 C. Operable Unit 3 (OU 3) - Community Soils 20 - 22 D. Operable Unit 4 (OU 4) - Area-wide Groundwater/Surface WaterInvestigation

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IV. Progress Since the Last Five-Year Review 23 - 24 A. Blue Mountain - Operable Unit 1 23 B. Cinder Bank - Operable Unit 2 23 C. Community Soils - Operable Unit 3 23 D. Area-wide Groundwater/Surface Water Investigation 23-24V. Five-Year Review Process 24VI. Technical Assessment 24

Question A: Is the remedy functioning as intended by the decisiondocuments?

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Question B: Are the exposure assumptions, toxicity data, cleanup levels,and remedial action objectives (RAOs) used at the time of theremedy still valid?

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Question C: Has any other information come to light that could call intoquestion the protectiveness of the remedy?

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Technical Assessment Summary 24VII. Protectiveness Statements 25VIII. Issues 25 - 26IX. Recommendations and Follow-up Actions 26X. Next Five Year Review 26

Tables

Table 1 - Chronology of Site Events 28 - 30Table 2 - Issues 31Table 3 - Recommendations and Follow-Up Actions 32

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Attachments

Attachment 1 - Site Location MapAttachment 2 - First Five-Year Review Report dated September 26, 1996Attachment 3 - WES/CRREL Audit Report dated January 25, 1995Attachment 4 - Charles R. Lee, Ph.D., CPSS, (USACE) Evaluation dated March

13, 2001 (“The Dr. Lee Report”)Attachment 5 - Viacom Map - Test Plot Locations dated September 27, 2000Attachment 6 - USACE letter dated March 14, 2001Attachment 7 - Adrian Brown Draft Report dated January 10, 2002

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List of AcronymsARAR Applicable or Relevant and Appropriate RequirementATSDR Agency for Toxic Substances and Disease RegistryCAA Clean Air ActCD Consent DecreeCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCMP Corrugated Metal PipeCRREL Cold Regions Research and Engineering Laboratory (USACE)CWA Clean Water ActDOJ United States Department of JusticeEAF Electric Arc Furnace DustECOLOAM Mixture of fly ash, sewage sludge and lime.EDD Eastern Diversion DitchEPA United States Environmental Protection Agency - Region IIIESD Explanation of Significant DifferencesHSCD Hazardous Site Cleanup DivisionHWMD Hazardous Waste Management DivisionG&W Gulf and Western Industries, Inc.GCL Geosynthetic Clay LinerHII Horsehead Industries, IncorporatedHRD Horsehead Resource Development Company, Inc.IRM Iron-rich MaterialMCL Maximum Contaminant LevelMCLG Maximum Contaminant Level GoalMRZ Metal Reduction ZoneNCP National Oil and Hazardous Substances Pollution Contingency PlanNEIC National Enforcement Investigations CenterNPDES National Pollutant Discharge Elimination SystemNPL National Priorities ListNRCS National Resources Conservation ServiceO&M Operations and MaintenanceOSWER Office of Solid Waste and Emergency ResponseOU Operable UnitPADEP Pennsylvania Department of Environmental ProtectionpH Potential of Hydrogenppm Parts Per MillionPRP Potentially Responsible PartyPRT Pollution Reduction TechnologyPVC Poly-Vinyl ChlorideQA/QC Quality Assurance/Quality Control

List of Acronyms

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RA Remedial ActionRD Remedial DesignRI/FS Remedial Investigation/Feasibility StudyRPM Remedial Project ManagerROD Record of DecisionSDWA Safe Drinking Water ActTCI TCI Pacific Communications, IncorporatedUAO Unilateral Administrative OrderUSACE United States Army Corps of EngineersUSDA United States Department of AgricultureVIACOM Viacom International Inc.WES Waterways Experiment Station (USACE)ZCA Zinc Corporation of America

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Executive Summary

The Palmerton Zinc Pile Superfund Site (Site) in Palmerton, Pennsylvania, is composedof four Operable Units (OUs): OU 1 - Blue Mountain; OU 2 - Cinder Bank; OU 3 - Community Soils; and OU 4 - Area-Wide Groundwater and Surface Water Study & Site-Wide EcologicalRisk Assessment. The remedies for the Site include stabilization and capping of contaminatedsoils (OU 1 & OU 2), runoff diversion, leachate collection and treatment (OU 2), remediation ofcontaminated residential soils and house dust (OU 3), and institutional controls (OU 2, & OU 3). Construction completion has not yet been attained. The trigger for this Five-Year Review wasthe completion date of the first Five-Year Review report, September 30, 1996.

The assessment for this Five-Year Review found that the remedies selected in theRecords of Decision (RODs) for OU 1 and OU 2 are being constructed in accordance with theROD requirements. The implementation of the ROD remedy for OU 3 is currently beingnegotiated between the U.S. Environmental Protection Agency - Region III (EPA) and thePotentially Responsible Parties (PRPs). The OU 3 ROD was issued on October 9, 2001. TheRemedial Investigation (RI) for OU 4 is nearing completion. The protectiveness statement foreach OU is as follows:

Protectiveness Statements:

Operable Unit 1 - BlueMountain:

The remedy is expected to be protective of human healthand the environment upon completion.

Operable Unit 2 - CinderBank:


Operable Unit 3 -Community Soils:

The remedy is expected to be protective of human healthand the environment upon completion. However, until theremedy selected in the October 9, 2001 ROD isimplemented, the following issues remain:

1. Homes with exterior soil lead levels above 650 ppm which were not remediated during the interim removal action need to be evaluated in accordancewith the ROD.

2. Playground areas in the residential communitiesneed to be remediated if lead levels are found to beabove 400 ppm.

3. A notification mechanism to protect futureresidential buyers of homes found to have soil leadlevels above 650 ppm but which will not beremediated needs to be implemented. [Protection offuture residential buyers by instituting a notificationmechanism needs to be implemented for homesfound to have soil lead levels above 650 ppm butwhich will not be remediated.]

The following remedies for the above issues, as cited inthe ROD issued on October 9, 2001, need to be taken toensure protectiveness:

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1. Exterior soil and interior dust remediation untilclean-up standards are obtained in accordance withthe ROD.

2. Sampling and clean up of residential play areas inaccordance with the ROD.

3. In accordance with the ROD, implementation ofInstitutional Controls to notify potential buyers of aproperty of the existence of sampling information.

Consent Decree negotiations are currently underwaybetween EPA and the PRPs for implementation of the aboveremedies.

Operable Unit 4 - Area-WideGroundwater and SurfaceWater Investigation:

A protectiveness determination cannot be made at this timeuntil further information is obtained. Further informationwill continue to be obtained during the RemedialInvestigation/Feasibility Study (RI/FS), currently underway. It is expected that the RI/FS will be completed by 2003, atwhich time a protectiveness determination will be made. Itshould be noted that exposure to groundwater is minimalsince most of the potentially affected area is connected to apublic water supply. The few nearby residential wells havebeen sampled and do not exhibit contaminants that can becurrently attributed to on-site groundwater.

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Five-Year Review Summary Form

SITE IDENTIFICATIONSite name: Palmerton Zinc Pile Superfund SiteEPA ID: PAD002395887

Region: 3 State: PA City/County: Palmerton/Carbon County

SITE STATUSNPL status: 6 Final o Deleted o Other (specify) _

Remediation Status (choose all that apply): 6 Under Construction o Operating o Complete

Multiple OUs?* 6 YES o NO Construction completion date: / / _

Has site been put into reuse? o YES 6 NO

REVIEW STATUSLead agency: 6 EPA o State o Tribe o Other Federal Agency _Author(s) name: ** Charlie Root/Alexis AlexanderAuthor(s) title: Remedial ProjectManagers

Author(s) Affiliation: U.S. EPA - Region 3

Review period:*** 07 / 30 / 2001 _ to 12 / 31 / 2001 _Date(s) of site inspection: 09 / 11 / 2001 _

Type of review: 6 Post-SARA o Pre-SARA o NPL-Removal onlyo Non-NPL Remedial Action Site o NPL State/Tribe-leado Regional Discretion

Review number: o 1 (first) 6 2 (second) o 3 (third) o Other(specify) _

Triggering action: o Actual RA Onsite Construction at OU # _ o Actual RA Start at OU# o Construction Completion 6 Previous Five-Year Review Reporto Other (specify)

Triggering action date: 09 / 26 / 1996 _

Due date (five years after triggering action date: 09 / 26 / 2001 _

* (“OU” refers to operable unit.)

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Five-Year Review Summary Form, cont’d

Issues:

Blue Mountain (OU 1):

1. Although revegetation via grass seed was highly successful, initial tree seedingof the 775 remediated acres on Blue Mountain (OU 1) and a subsequent plantingof tree seedlings has not been successful. In addition, limited sampling data mayindicate that translocation of contaminants is occurring through plant uptake. The extent of translocation of contaminants through plant uptake and it’s effectson the remedy, if any, need to be determined.

2. Remaining denuded acreage of Blue Mountain (OU 1) needs to be revegetated. Application rates, uniform coverage, areal extent to be remediated, types ofgrasses, long term survivability and performance standard issues in test plotsneed to be resolved.

Cinder Bank (OU 2):

3. Complete construction of Metal Reduction Zones (MRZs) and remainingrevegetation on the Cinder Bank (OU 2).

4. Address access restrictions and long term O&M of burning areas of Cinder Bank(OU 2).

Community Soils (OU 3):

5. Need to design and construct the remedy called for in the October 9, 2001 ROD(OU 3).

Recommendations and Follow-Up Actions:

1. Monitor and evaluate the completed portion of Blue Mountain for long termvegetation survivability and translocation of contaminants (OU 1).

2. Sample and analyze appropriate plant species for metals to determine iftranslocation is occurring (OU 1) and if it is causing adverse effects.

3. Periodically, on an as-needed basis, if appropriate, remove volunteer treespecies with high metal uptake (i.e., Birch, Poplar, etc.) (OU 1), repair areas ofvegetative die off, or apply soil amendments to minimize contaminant uptake.

4. Utilize a revegetation approach that has minimum metal uptake on the remainingacreage of Blue Mountain (OU 1) to ensure long term survivability and minimizetranslocation of contaminants, if it is shown to be a problem.

5. Ensure completion of construction of MRZs and remaining revegetation of theCinder Bank (OU 2).

6. Complete negotiations with the PRPs for implementation of the October 9, 2001ROD (OU 3).

7. Design and implement the October 9, 2001 ROD (OU 3).

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Protectiveness Statements:

Operable Unit 1 - BlueMountain:


Operable Unit 2 - CinderBank:


Operable Unit 3 - CommunitySoils:

The remedy is expected to be protective of human healthand the environment upon completion. However, until theremedy selected in the October 9, 2001 ROD isimplemented, the following issues remain:

1. Homes with exterior soil lead levels above 650ppm and which were not remediated during theinterim removal action need to be evaluated inaccordance with the ROD.

2. Playground areas in the residential communitiesneed to be remediated in accordance with theROD if lead levels are found above 400 ppm.

3. A notification mechanism to protect futureresidential buyers of homes found to have soillead levels above 650 ppm but which will not beremediated needs to be implemented. [Protectionof future residential buyers by instituting anotification mechanism needs to be implementedfor homes found to have soil lead levels above650 ppm but which will not be remediated.]

The following remedies for the above issues, as cited inthe ROD issued on October 9, 2001, need to be takento ensure protectiveness:

1. Exterior soil and interior dust remediation untilclean-up standards are obtained in accordance withthe ROD.

2. Sampling and clean up of residential play areas inaccordance with the ROD.

3. In accordance with the ROD, implementation ofInstitutional Controls to notify potential buyers of aproperty of the existence of sampling information.

Consent Decree negotiations are currently underwaybetween EPA and the PRPs for implementation of theabove remedies.

Operable Unit 4 - Area-WideGroundwater and SurfaceWater Investigation:

A protectiveness determination cannot be made at this timeuntil further information is obtained. Further information willcontinue to be obtained during the RemedialInvestigation/Feasibility Study (RI/FS) currently underway. It is expected that the RI/FS will be completed by 2003, at

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which time a protectiveness determination will be made. Itshould be noted that exposure to groundwater is minimalsince most of the potentially affected area is connected to apublic water supply. The few nearby residential wells havebeen sampled and do not exhibit contaminants that can becurrently attributed to on-site groundwater.

Other Comments: No further comments at this time.

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Second Five-Year Review ReportFebruary 2002

Palmerton Zinc Pile Site – Palmerton, PennsylvaniaEPA ID No. PAD002395887

I. Introduction

The purpose of a Five-Year Review is to ensure that a remedial action remains protective ofpublic health and the environment and is functioning as designed. The methods, findings, andconclusions of reviews are documented in Five-Year Review reports. In addition, Five-YearReview reports identify issues found during the review, if any, and provides recommendations toaddress them. This report documents the results of the review and will become a part of the sitefile.

The U. S. Environmental Protection Agency - Region III (EPA) prepared this Five-Year Reviewreport pursuant to Section 121 (c) of the Comprehensive Environmental Response,Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. § 9621 (c); Section300.430(f)(4)(ii) of the National Oil and Hazardous Substances Pollution Contingency Plan(NCP), 40 C.F.R. Part 300, as amended, and the Office of Solid Waste and Emergency Response(OSWER) Directives 9355.7-02 (May 23, 1991), 9355.7-02A (July 26, 1994), and 9355.7-03A(December 21, 1995).

CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances,pollutants, or contaminants remaining at the site, the President shall review suchremedial action no less often than each five years after the initiation of suchremedial action to assure that human health and the environment are beingprotected by the remedial action being implemented. In addition, if upon suchreview it is the judgment of the President that action is appropriate at such site inaccordance with section [104] or [106], the President shall take or require suchaction. The President shall report to the Congress a list of facilities for whichsuch review is required, the results of all such reviews, and any actions taken as aresult of such reviews.

The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use andunrestricted exposure, the lead agency shall review such action no less often thanevery five years after the initiation of the selected remedy.

EPA conducted this Five-Year Review of the remedies selected at the Palmerton Zinc PileSuperfund Site in Palmerton, Pennsylvania. This review was conducted by the Remedial ProjectManager (RPM), Charlie Root, and Alexis K. Alexander, RPM, for the entire site from July 30,2001, through December 31, 2001.

This is the second Five-Year Review for the Palmerton Zinc Pile Superfund Site. The triggeringaction for this policy review was the completion date of the first Five-Year Review report,

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September 26, 1996 (Attachment 2). The Five-Year Review is required due to the fact thathazardous substances, pollutants, or contaminants remain at the site above levels that allow forunlimited use and unrestricted exposure.

II. Background

Land and Resource Use

The Palmerton Zinc Pile Superfund Site (Site) is located in Carbon County, Pennsylvania, in thevicinity of the Lehigh Gap and is approximately 15 miles north of Allentown, Pennsylvania. Attachment 1 is the site location map. From 1898 to about 1981, zinc smelters were operatedwithin the Borough of Palmerton (Borough). The two former zinc smelters are locatedseparately on east and west sides of the Lehigh Gap where the Aquashicola Creek joins with theLehigh River. The East Plant is at the eastern end of the Borough, located on the southern sideof Aquashicola Creek at the foot of Blue Mountain. A smoldering slag pile known as the CinderBank lies adjacent to the East Plant and along the base of Blue Mountain. The Cinder Bankwaste pile is approximately 2.5 miles long and covers approximately 200 acres. The West Plantis located in the western end of the Borough on the northern bank of the Lehigh River.

The site was included on the National Priorities List (NPL) in September 1983 because of thethreat to human health and the environment posed by the Cinder Bank. Further investigation hasindicated that elevated levels of heavy metals are prevalent throughout the Palmerton Area.

The East and West Plants were operated by the New Jersey Zinc Company from 1898 until1967. During smelter operations, large amounts of lead, cadmium, zinc, and arsenic wereemitted as dust and particulate fallout from stack emissions. The smelting operation waspurchased from New Jersey Zinc in 1967 by Gulf & Western Industries, Inc. (G&W). In 1981,Horsehead Industries, Incorporated, (HII) purchased the smelters and began operating the facilityas a hazardous waste recycling plant. HII is the parent company of two on-site subsidiaries,Horsehead Resource Development Company, Inc. (HRD) and Zinc Corporation of America(ZCA). HRD is responsible for research and development and ZCA is the facility operator. HII,HRD, and ZCA will be referred to collectively as “Horsehead” throughout this document. G&Wis the predecessor of Viacom International Incorporated (Viacom) and TCI PacificCommunications, Incorporated, (TCI). Viacom and TCI will be collectively referred to as“Viacom” throughout this report. Viacom and Horsehead are the Potentially Responsible Parties(PRPs) at the site.

History of Contamination

The smelters emitted vast quantities of zinc, lead, cadmium, and sulfur dioxide over the years. This pollution led to the defoliation of approximately 2000 acres on Blue Mountain, depositionof heavy metal contamination within the Borough and the valley, and the stockpiling ofapproximately 32,000,000 tons of slag. The slag pile, which is called the Cinder Bank, causedpollution of the shallow aquifer and the Aquashicola Creek, which flows through the Boroughinto the Lehigh River. It was apparently common practice to deposit this slag material in thiswaste pile before it was fully quenched. Therefore, significant parts of the interior of the CinderBank continue to burn.

Surface soil samples taken on Blue Mountain revealed contamination levels of cadmium from364 parts per million (ppm) to 1,300 ppm; lead from 1,200 ppm to 6,475 ppm; and zinc from

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13,000 ppm to 35,000 ppm. Most of this contamination is contained within the top 6 to 10inches of soil. This is because the metals are bound in organic materials which prevent moresignificant downward movement of metals.

Physical Characteristics

The Cinder Bank is approximately 2.5 miles long, 200 feet high, 200 feet wide at its crest, and1,000 feet wide at the base. This equates to approximately 200 acres of surface area. The CinderBank consists of mostly residual metals and carbonaceous material. As a result of eitherincomplete quenching or spontaneous combustion, portions smolder continuously. Thecontamination within the Cinder Bank consists of approximately 3,600 ppm lead, 250 ppmcadmium, and 27,000 ppm zinc, as well as other metals.

Smelting operations ceased in both plants in about 1981. Since 1981, when HHI bought thefacility, it has been operated as a hazardous waste recycling facility. It presently processes theRCRA hazardous waste K061, electric arc furnace (EAF) dust. This dust is a residue from thesteel mill industry and contains significant levels of several hazardous metals, including lead,cadmium, and zinc.

Remedial Overview

EPA divided this Superfund Site into four Operable Units (OUs) because of its size andcomplexity. Operable Unit 1 (OU 1) addresses revegetation of approximately 2,000 acres ofdenuded, non-residential land on the north face of Blue Mountain. A ROD for OU 1 was issuedon September 4, 1987. The selected alternative called for the application of a sludge/lime/fly ashmixture to the mountainside and revegetation using grass seed and tree seed. Grass cover hasbeen established on approximately 775 acres of Blue Mountain, with approximately 1,000 acresremaining to be revegetated.

Operable Unit 2 (OU 2) consists of remediation of the Cinder Bank. The Cinder Bank, which isprimarily a smoldering residue pile from historic zinc smelting operations, lies adjacent to theEast Plant and along the base of Blue Mountain. The Cinder Bank waste pile is approximately2.5 miles long and covers approximately 200 acres. A ROD for OU 2 was issued on June 29,1988. Until recently, no significant work had been completed on the Cinder Bank. However,over the past two years, construction activities have progressed towards diverting surface waterfrom Blue Mountain around the Cinder Bank; collecting and treating leachate coming from theCinder Bank; and revegetating the Cinder Bank. This construction work on the Cinder Bank isexpected to be completed in 2002.

Operable Unit 3 (OU 3) consists of remediation of residential soils and interior house dustexhibiting elevated levels of lead, which are a result of historic zinc processing operations. AROD was issued on October 9, 2001. Currently, negotiations to implement the ROD remediesare underway between EPA and the PRPs.

Operable Unit 4 (OU 4) concerns an area-wide investigation of contamination in the ground andsurface waters and includes an Ecological Risk Assessment. A Remedial Investigation (RI) ofthis OU is nearing completion and the Ecological Risk Assessment has been completed.

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III. Remedial Actions

A. Operable Unit 1 (OU 1) – Blue Mountain

1. Remedy Selection

OU 1 consists of the revegetation of approximately 2,000 acres on Blue Mountain under aninterim remedy. The Remedial Investigation and Feasibility Study (RI/FS) was conducted byEPA. The ROD was issued on September 4, 1987. The selected interim remedy utilized theapplication of a sludge/lime/fly ash mixture with grass seeds and tree seeds. While notaddressing all applicable or relevant and appropriate requirements (ARARs), the selectedalternative was deemed consistent with those action-specific ARARs addressing sludgeapplication, a special concern of the Commonwealth of Pennsylvania Department ofEnvironmental Protection (PADEP), which accepted the remedy selected in the ROD.

The Remedial Action Objectives of the ROD are as follows:

1. minimize direct contact with contaminated soil

2. reduce volume of runoff

3. reduce contamination in runoff

4. mitigate environmental damage

2. Remedy Implementation

A Consent Decree (CD) between EPA and ZCA, a Division of HII, for implementation of theROD for OU 1 was entered by the United States District Court for the Middle District ofPennsylvania on October 18, 1988. The final plans to implement the remedy were received byEPA on April 15, 1991, for remediation of up to 1000 acres. Approval to start construction wasgiven to ZCA by EPA on May 7, 1991.

The U.S. Army Corps of Engineers (USACE), located in Tobyhanna, Pennsylvania, has beenEPA’s Remedial Action (RA) oversight contractor since 1990.

The ROD refers to the remediation of approximately 2,000 acres; however, the exact limits ofrestoration were not precisely established. Ultimately, 775 acres underwent thesludge/lime/flyash plus grass/tree seeds application process by 1996 under the terms of the 1988CD until ZCA stopped work. A disagreement between EPA and ZCA regarding ZCA’s responsibility to continue work under the 1988 CD was never resolved and in December 1999,EPA issued a Unilateral Administrative Order (UAO) to Horsehead and Viacom requiringcompletion of the remedial activities selected in the ROD.

The revegetation remedial action over the 775 acres was highly successful in establishing grasscover. However, due primarily to unsuccessful competition with the newly established grass,and to a lesser extent, predation from small rodents and deer repopulating the grassy areas, etc.,tree seeding was not successful.

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A timber survey conducted in 1994-1995 by Horsehead identified areas where sufficient treedensity per the requirements of the remedial design (435 live trees per acre) already existed dueto volunteer species.

An audit report of the remedial action completed on 775 acres was prepared and submitted toEPA on January 25, 1995, by the USACE Waterways Experiment Station (WES), and theUSACE Cold Regions Research and Engineering Laboratory (CRREL) assessing the restorationsuccess of the interim remedial action. The findings of the report confirmed the success inestablishing grass cover, the establishment of indigenous volunteer birch and poplar speciesknown to take up metals, and the lack of success in establishing woody species from the initialseeding. This audit report is included as Attachment 3 of this report.

Due to the lack of success of tree seeding, and at the suggestion of EPA, ZCA planted test plotsof tree seedlings in late 1995. This involved breaking through surface soil with a dibble bar andthen planting seedlings into the subsoil. Some seedlings were augmented by ECOLOAM toallow the taproot access to soil below the contaminated layers. This effort utilized low metalsuptake species (oak and maple).

Beginning with the initial plantings by Horsehead in 1995, USACE, on behalf of EPA, hasmonitored the progress of the tree seedlings and taken various actions in an attempt to ensure theseedlings’ successful maturation. These actions have included; 1) cutting all grass in a 3.3 ft.area with a weed-whacker prior to dibble barring the seedling into the ground, in an attempt tominimize competition from grass, 2) inoculating the seedlings with a microrhizium developedfor contaminated soils prior to planting; 3) applying an animal repellant and an iron chelate(FeEDDHA) to seedlings; and 4) using insect control as needed. Later, a ground weed controlmat (3x3 ft.) or other control was applied around the seedlings in the Spring of 1998. A plasticprotective tube was placed around the seedlings at planting in November 1997 to protect fromanimal grazing. The plastic tube used was ineffective because during windy conditions on themountain it caused massive wind damage to the seedlings. A netting type of seedling protectorwas applied in March 1998. Seedling survivability and growth were observed every one to twomonths throughout the growing season each year.

Despite these extensive efforts, the 1995 tree seedling planting performed poorly and at therequest of EPA, USACE planted an additional round of tree seedlings in November 1999. Thiswas done to see if the accumulated knowledge from the previous efforts with the 1995 treeseedlings could be used successfully on newly planted tree seedlings. The November 1999demonstration was conducted in the plots that had the fewest surviving seedlings from the 1995planting. Inoculated oak seedlings (45 2-3 year old red oak seedlings, 90 2-3 year old shuwateroak seedlings and 45 2-3 year old red maple seedlings) were planted between the rowspreviously planted in the 0-100 ft., 100-200 ft., 200-300 ft., and/or 300-400 ft. sections atspacings of 10 ft.

An evaluation of the tree seedling demonstrations, as well as the overall revegetation remedialaction, was performed at the request of EPA by a USACE soil scientist, Charles R. Lee, Ph.D.,CPSS, and submitted to EPA on March 13, 2001. Dr. Lee’s findings included indications of anapparent increase in plant litter in areas where grass had previously been well established,coupled with the decrease in live vegetative cover and the lack of success in establishing woodyspecies via seeding and tree seedlings. In response to the obvious difficulty in creatingsuccessful forestland through either seeding or seedling planting, a cost analysis of establishingmeadowland versus forestland was also included in the evaluation. This cost comparison

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estimated meadowland establishment as $1,125/acre versus $6,125/acre for forestland via treeseedling planting and intensive seedling maintenance. The meadowland establishmentevaluation also included recommendations for maintenance of unwanted volunteer woodyspecies. This maintenance effort was included in the cost analysis. A copy of Dr. Lee’s evaluation is included as Attachment 4 of this report. Based on the experiences and evaluationsof the initial ROD implementation, EPA has adopted the following approach to implement theROD on the remaining acreage: utilize a self-sustaining meadowland revegetation approach thathas minimum metal uptake; sample and analyze appropriate indicator plant species for metals todetermine if any uptake is occurring; and periodically remove volunteer tree species with highmetal uptake (i.e., Birch, Poplar, etc.), if necessary.

As stated previously, EPA issued a UAO to Horsehead and Viacom on December 10, 1999, forremediation of the remaining portion of the ROD acreage on Blue Mountain. Viacom iscurrently complying with the UAO.

Viacom has hired the consulting firm of Adrian Brown to prepare the remedial design andoversee the implementation of the remedy on the remaining portions of the mountain. EPA isconducting oversight of the remedial design and remedy with the assistance of USACE. AdrianBrown, on behalf of Viacom, submitted a preliminary design which would include application ofseed, manure, fertilizer, fly ash, and lime from the air to complete the revegetation of BlueMountain called for in the ROD. The preliminary design also called for conducting a Field PilotTest Plan (Plan) utilizing varying mixtures of sludge, seed mix, fly ash, and lime to determinethe most effective ratio. The Plan included twelve randomly selected one-acre test plots andconsisted of three separate aerial application steps. Attachment 5 is Viacom’s September 27,2000 map showing the test plot locations. The first step in implementing the Plan was theapplication of a seed mix using a spreader bucket (inverted cone hopper) suspended byhelicopter. The second step was an application of lime using the same method. The third andfinal step involved the application of a manure/compost mixture. Due to problems encounteredwith application of the compost using the hopper, a change was made to apply the compost usinga tarp and sling method. The test plot applications were completed in October 2000 with theexpectation that the success of the applications would be evaluated and performance standardsfor full-scale application would be agreed upon in the Spring and Summer of 2001. EPA hassolicited input and received comments on the evaluation of the test plots from PADEP and theUnited States Department of Interior (DOI).

Several problems and concerns with the Plan regarding the application rates and coverage werenoted in a USACE March 14, 2001 letter (Attachment 6). DOI has also raised various concernsto EPA regarding the remedial approach. Subsequent field inspections confirmed several of thedeficiencies noted regarding application rates, uniform coverage, areal extent to be remediated,types of grasses to be utilized, and performance standards. Two site visits were conducted byEPA and included representatives of the PRP, USACE, DOI, and PADEP. The visits wereconducted in May 2001, and on September 11, 2001, to view the success rates of the test plots. During these visits it was determined that preliminarily two of the twelve test plots had beeninitially successful in establishing vegetative cover. However, EPA decided that furtherevaluation of the plots through Spring 2002 was warranted due to concerns regarding long-termsurvivability of the grass seeding. A report detailing the test plot application, observations, andevaluations from the site visit was submitted by Adrian Brown on behalf of Viacom on January10, 2002. The report also suggested possible resolutions for concerns raised regarding thepreliminary design approach, including modifications to the application methods and suggestions

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regarding performance standards. EPA and other interested parties including DOI and PADEPevaluated this report and provided comments and recommendations to Viacom. The commentsand recommendations are to be taken into account in a second test plot work plan to be preparedby Viacom. Depending upon the resolution of the concerns raised regarding the remedialapproach, it is expected that full scale remedy applications via this approach would begin nosooner than Fall 2002.

B. Operable Unit 2 (OU 2) - Cinder Bank

1. Remedy Selection

OU 2 consists of remediation of the Cinder Bank. The Cinder Bank, which is primarily asmoldering residue pile from historic zinc smelting operations, lies adjacent to the East Plant andalong the base of Blue Mountain. The Cinder Bank waste pile is approximately 2.5 miles longand covers approximately 200 acres. In September 1985, ZCA entered into an AdministrativeOrder on Consent (AOC) to conduct a RI/FS for the Cinder Bank. The RI/FS was submitted toEPA in May 1988 and accepted by EPA. A ROD for OU 2 was issued on June 29, 1988.

The Remedial Action Objectives of the ROD are as follows:

1. minimize direct contact with the Cinder Bank

2. reduce volume of run-off

3. reduce contamination in run-off

4. reduce the volume of run-on

5. collect and treat leachate

6. reduce wind-borne contaminated emissions

7. reduce particulate erosion

This OU has been the subject of controversy between the PRPs, PADEP, and EPA, due to theimposition of the State’s Municipal Landfill Regulations on the Cinder Bank remedy. When theROD was issued, PADEP asserted that the slope modifications must meet their MunicipalLandfill Regulations and that the fires within the Cinder Bank must be extinguished. As a result,EPA’s contractor, Black & Veatch Waste Sciences, Inc. prepared an Engineering Evaluation andCost Analysis (EE/CA) for the selected remedy. The EE/CA estimated that the cost toimplement the selected remedy, including installation of a cap which met PADEP’s regulationsand extinguishing the interior fires, would be approximately $250 million.

Subsequent to the signing of the ROD, ZCA agreed to perform additional studies in support of apossible alternative remedy. These studies included an air monitoring program to determine ifthe fires presented an environmental threat and the investigation of some of the latest recyclingtechnology relating to the slag itself. Work began in 1992 and was completed in 1994. Theresult of the studies indicated that there were no environmental risks as a result of air emissionsfrom the Cinder Bank and that recycling of the slag itself was not economically feasible.

19


On November 13, 1995, EPA entered into a CD with Horsehead which resolved a Complaintfiled against Horsehead alleging multiple violations of the Resource Conservation and RecoveryAct (RCRA), the Clean Air Act (CAA), and the Clean Water Act (CWA). The CD required thepreparation of a plan called the Pollution Reduction Technology plan (PRT Plan) to address themulti- media concerns raised in the Complaint. The PRT Plan includes a revegetation project forthe Cinder Bank in conjunction with leachate collection and treatment and surface waterdiversion. This approach was specifically advanced as a means of achieving effluent dischargelimits under the CWA as described in that CD.

The PRT Plan and Cinder Bank Vegetation Plan (“Vegetative Plan”) were prepared andsubmitted by HII in February 1999. EPA and PADEP approved the PRT Plan in March 2000. Shortly thereafter, work began on the PRT Plan in April, 2000. Work to be completed under thePRT Plan includes the following:

1. The Vegetation Plan provides for the continuation of vegetation of the Cinder Bank(in a manner similar to Blue Mountain). Approximately 68 of the 200 acres of the CinderBank were vegetated between the early 1980’s and the early 1990’s for erosion control. Completion of the Vegetation Plan will accomplish at least four technical objectives: (1)reduce wind and water erosion, (2) increase evapotranspiration, (3) decrease the amountof runoff and groundwater recharge, and (4) reduce Cinder Bank leachate. Approximately 132 acres of the Cinder Bank have not been vegetated. Of these,approximately 27 acres are associated with areas at which there may continue to beresidual burning. For safety reasons, these limited areas will not be vegetated.

During the 2000 work season, 45 acres of the Cinder Bank were revegetated. During the2001 construction work season 45 additional acres were revegetated.

2. The construction of surface water diversion channels to collect runoff from BlueMountain and the Cinder Bank. A riprap lined and grouted ditch identified as the EasternDiversion Ditch (EDD) intercepts water from the north side of Blue Mountain and islocated between Blue Mountain and the Cinder Bank. It intercepts and conveys waterstarting from the Pretreatment Zone (see description below) and around the entire easternside of the Cinder Bank. A second diversion system known as DT005 consists of twosections of half round corrugate metal pipe (CMP). DT005 has two separate reaches, onethat extends to the western side and one to the eastern side of the Cinder Bank in thevicinity of the EDD. The pitch includes 48” and 60” half round CMP and incorporates aseries of culverts, manholes, and water correction zones.

3. The construction of a pretreatment zone on the east side of the Cinder Bank whichincludes the placement of 25,000 tons of iron rich material (IRM) over a 10 acre area andthe construction of three metals reduction zones. The three metal reduction zones(MRZs) consist of large excavations at the toe of the Cinder Bank which have ageosynthetic clay liner (GCL), a series of PVC piping for influent and effluent, IRMbackfill treatment media, and then a vegetative cap. The intent of the MRZs is to captureCinder Bank leachate and treat it prior to discharge to the Aquashicola Creek. Also, theMRZs include the construction of two pH adjustment structures. The pretreatment zoneand MRZs will have ECOLOAM applied along with a vegetative cover.

20

Work on the construction required by the PRT Plan has been ongoing since April 2000. To date the eastern diversion ditch and the DT005 surface water diversion piping havebeen completed, MRZ #3 has been constructed, and the Pretreatment zone has beencompleted. Work will continue through the 2002 construction season toward completingthe construction of MRZ #1 and MRZ #2 and completing the revegetation of the CinderBank.

EPA and PADEP have been reevaluating the remedy for this OU based upon the resultsof the EE/CA performed by Black & Veatch, the additional studies performed byHorsehead, and the work performed by Horsehead under the PRT plan. EPA is nowevaluating whether the work required under the PRT Plan will meet the objectives of the1988 ROD.

C. Operable Unit 3 (OU 3) – Community Soils

OU 3 consists of remediation of residential soils and interior house dust exhibiting elevatedlevels of lead from zinc processing activities in the Borough of Palmerton, the Village ofAquashicola, and other residential areas of Lower Towamensing Township.

In September 1985, EPA entered into an AOC with G&W, a former owner/operator of the Site. Under the terms of that agreement Gulf and Western agreed to conduct a RI/FS for OU 3. Thedraft RI for OU 3 was completed in 1988 and forwarded to EPA. In response to comments fromEPA, Paramount Communications, Incorporated, (formerly Gulf and Western Industries,Incorporated, now known as Viacom International Incorporated), submitted a revised RI in 1994. EPA deemed the RI deficient and took over the RI/FS for this OU.

In February 1991, the Pennsylvania Department of Environmental Resources (PADER), nowknown as the Pennsylvania Department of Environmental Protection (PADEP), sampled dusts intwo houses in Palmerton. The results of these samples indicated high levels of lead, cadmium,and zinc. At the request of PADEP, EPA conducted additional sampling at 24 homes inPalmerton. The sampling results from the additional 24 homes correlated with PADEP results. At that time, EPA amended the 1985 AOC with Horsehead and Horsehead agreed to conduct aninterior cleanup of the homes. Horsehead completed the cleanup activities in Spring 1992. EPAalso issued a UAO to Paramount Communications, Incorporated, to undertake an extent-of-contamination study to determine the possibility of additional contaminated households. Theactivities required by EPA in the UAO issued to Paramount Communications, Incorporated,were performed but because so few residents would allow sampling on their properties, the studydid not, in EPA’s opinion, fully define the environmental contamination of the residentialcommunities.

In October 1991, EPA conducted a comprehensive environmental sampling program inPalmerton in conjunction with the Agency for Toxic Substances and Disease Registry (ATSDR)health testing program. Analytical results were received by EPA in October 1992. Those resultsshowed elevated levels of lead, cadmium, and zinc in surface soils and in household dust. InJanuary and February of 1993, EPA received additional results and reviewed the populationmake-up in the areas sampled. Based on the sample results, and the make-up of the receptorpopulation, the EPA Remedial Project Manager (RPM) requested EPA removal assistance tomitigate immediate threats to human health, welfare, and the environment posed by the presenceof high levels of contamination in residential areas. The EPA On Scene Coordinator (OSC)

21

deemed that Removal Activities were necessary to mitigate threats to public health posed by theSite.

EPA conducted an Interim Removal Action from 1994 through 1997. This action addressed theimmediate threats to children and pregnant woman, which are the most sensitive populations,from high levels of lead, cadmium, and arsenic in exterior soil surrounding the nearby residentialcommunity as well as interior dust in their homes. A total of 438 houses were sampled duringthe four-year period covering the Interim Removal Action. A total of 202 houses were cleanedduring the four-year period, of which 116 were cleaned on the interior (including, HighEfficiency Particulate Arresting (HEPA) vacuuming and carpet removal/replacement) and 195were cleaned on the exterior (excavation of upper 2 inches of most contaminated soil and tillingin of agricultural amendments or clean top soil).

1. Remedy Selection

EPA also conducted a Baseline Risk Assessment (BRA) for this OU to determine the long-termrisk, if any, associated with the elevated levels of lead, cadmium, and arsenic in the community. This BRA, which was completed in early 1999, was used to prepare the final Feasibility Study. The final Feasibility Study, which evaluated remedial alternatives to address the risks identifiedin the BRA, was completed in June 2000. EPA issued the ROD for OU 3 on October 9, 2001, toaddress the risks identified in the BRA.

The ROD includes a Selected Remedy and Contingent Remedy as described below. Both willaddress the lead and arsenic contaminated exterior residential soil source and will address thetracked in exterior soil in interior dust. The Selected Remedy will also include evaluation and, ifnecessary, abatement of lead-based paint. However, the Selected Remedy is contingent uponEPA and the PRPs reaching a Consent Decree whereby the PRPs agree to implement theremedy. If such an agreement cannot be reached, the Contingent Remedy will address theindustrial sources of lead contamination and leave the properties within the OU 3 area on a levelplaying field with all other homes in the United States constructed prior to 1978 with regard tolead-based paint.

The Selected Remedy includes the following major components:

Soliciting participation in the remedial action through letters, fact sheets, local media outlets, andpersonal contacts;

Eligibility sampling based on 650 ppm lead in a representative composite soil sample;

Lead-based paint evaluation and abatement, if necessary, and HEPA vacuuming of homeinteriors until clearance standards consistent with Subpart D of 40 CFR Part 745 are attained.

Exterior soil remediation, including tilling in either pre-amended soil or agricultural-typeamendments, and/or excavation, removal, and proper disposal of targeted soils until appropriatecleanup standards are attained. (A cleanup standard of 950 ppm lead in soil, as determinedthrough composite sampling, shall be applied in exterior soils only if any potential source ofinterior lead dust contamination from lead-based paint is identified and, if present, addressedappropriately, or lead-based paint is determined not to pose a risk, as determined by a state-licensed risk assessor. Otherwise, an exterior soil cleanup standard of 650 ppm shall apply).

22

Sampling and cleanup of residential play areas, if present.

Institutional controls to notify potential buyers of a property of the existence of samplinginformation in the situation where sampling indicates the eligibility of a property and theproperty owner declines to have the appropriate cleanup performed.

The Contingent Remedy incorporates residential exterior soil, and specialized interior cleaningremedial actions for all homes that qualify for such remediation and in which property ownersconsent to participate. Exposure to exterior soils and interior dust above cleanup standardsrepresents a primary threat to human health; therefore, the action described below will berequired.

The Contingent Remedy includes the following major components:

Soliciting participation in the remedial action through letters, fact sheets, local media outlets, andpersonal contacts;

Eligibility sampling based on 650 ppm lead in a representative composite soil sample forexterior soils and 650 ppm interior dust sample;

Exterior soil remediation, including tilling in either pre-amended soil or agricultural-typeamendments, and/or excavation, removal, and proper disposal of targeted soils until the 650 ppmcleanup standard is attained.

Sampling and cleanup of residential play areas, if necessary.

Specialized interior cleaning, including HEPA vacuuming, wet wiping of hard surfaces, andclearance sampling consistent with Subpart D of 40 CFR Part 745 for floors.

Institutional controls to notify potential buyers of a property of the existence of samplinginformation in the situation where sampling indicates the eligibility of a property and theproperty owner declines to have the appropriate cleanup performed.


Viacom has indicated its willingness to implement the ROD and has begun preparation of aRemedial Design Work Plan. A Consent Decree is currently being drafted so that negotiationsfor implementation of the ROD can continue.

D. Operable Unit 4 (OU 4) – Area-wide Groundwater/Surface Water Investigation

OU 4 concerns an area-wide investigation of contamination in the ground and surface waters andincludes a Site-wide Ecological Risk Assessment. EPA sent Special Notice letters to thePotentially Responsible Parties for the Site on December 22, 1995, offering them the opportunityto perform the RI/FS for OU 4. The PRPs declined and EPA decided to perform the RI/FS usingmoney from Superfund rather than issuing Unilateral Administrative Orders for performance ofthe work. In consideration of community concerns regarding the groundwater investigation,EPA determined that the RI would be performed in three phases. The first phase included theevaluation of all existing groundwater data including existing routine monitoring well datacollected by Horsehead. EPA also sampled existing on-site monitoring wells and fourresidential wells. The results of this evaluation were used to determine that no new well

23

installations were necessary prior to moving forward to complete the RI/FS. The results of thefirst phase of the investigation were made part of an EPA presentation given to the concernedcitizens on April 21, 1999. Since then, EPA has begun work on the RI and has also conductedadditional sampling of existing monitoring and residential wells to supplement the existing data. The field work for the Ecological Risk Assessment part of the Remedial Investigation took placeduring 1997 and 1998.

Currently, the RI for this OU is nearing completion and the Ecological Risk Assessment hasbeen completed and will be incorporated into the RI. The FS and ROD are expected to becompleted by early 2003.

IV. Progress Since the Last Review

A. Blue Mountain - Operable Unit 1:

Additional tree seedlings were planted in November 1995.An EPA Unilateral Administrative Order (UAO) was issued on December 10, 1999, toHorsehead and Viacom to remediate the remaining portion of the ROD acreage on BlueMountain.Under the UAO, Viacom hired the consulting firm of Adrian Brown to prepare theremedial design and oversee the implementation of the remedy on the remaining portionsof the mountain.Adrian Brown developed a Field Pilot Test Plan and implemented this plan on 12 testplots.

B. Cinder Bank - Operable Unit 2:

A Consent Decree, settling Clean Air Act, Clean Water Act, and RCRA violations, wasentered into between HII/HRD, PADEP, and EPA. This CD resulted in the PRT Planwhich addressed Cinder Bank concerns.Construction required by the PRT Plan began in April 2000. Construction of the easterndiversion ditch, the DT005 surface water diversion piping, and the Metal Reduction Zone(MRZ) #3 has been completed. MRZ #1 and #2 remain to be constructed andrevegetation of the Cinder Bank to be completed.

C. Community Soils - Operable Unit 3:

An EPA Interim Removal Action was conducted from 1994 to 1997 to address theimmediate threats to children and pregnant women from high levels of lead, cadmium,and arsenic in the exterior soil surrounding the residential community, as well as theinterior dust in the homes.A risk assessment to determine the long term risks was completed in March 1999.A Record of Decision (ROD) was issued on October 9, 2001.

D. Area-wide Groundwater and Surface Water - Operable Unit 4:

EPA conducted the groundwater investigation in three phases in response to communityconcerns. The first phase included the evaluation of all existing groundwater data. Thisevaluation showed that the second phase, the installation of shallow monitoring wells,was not necessary.

24

The field work for the ecological portion of the Remedial Investigation was begun in1997 and completed by 1998. This completed Ecological Risk Assessment will beincorporated into the Remedial Investigation, currently nearing completion.

V. Five-Year Review Process

Interested parties were notified of the start of the review. The review team consisted of the SiteRPM, Charlie Root, and Alexis K. Alexander, another EPA RPM. The review was conductedfrom approximately July 30, 2001, through December 31, 2001. The previous Five-YearReview, all of the associated RODs for each OU, and supporting correspondence were reviewedduring this period. A site inspection was conducted on September 11, 2001.Field conditions on the first 1000 acres confirmed the successful establishment of vegetation. Some areas showed vegetative die off while other areas showed a proliferation of certainvolunteer species. As discussed earlier in the Remedial Actions section for OU 1, two of the testplots initially appeared successful in establishing vegetation. However, field inspectionsconfirmed deficiencies regarding application rates, uniform coverage, areal extent to beremediated, types of grasses to be utilized, and performance standards. VI. Technical Assessment

A. Is the remedy functioning as intended by the decision documents?

Construction completion has not been achieved to date. The portions of the remediesimplemented thus far appear to be functioning as intended by the decision documents.

B. Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives (RAOs) used at the time of remedy selection still valid?

Yes, however, limited sampling results may indicate that translocation of contaminantsmay be occurring through plant uptake in the revegetated acreage of Blue Mountain. Further sampling and evaluating needs to be conducted to determine if translocation ofcontaminants is occurring and if corrective actions need to be implemented.

C. Has any other information come to light that could call into question the protectivenessof the remedy?

No. However, see B. above.

Technical Assessment Summary:

The revegetation efforts implemented and currently being piloted on Blue Mountain (OU 1) andthe Cinder Bank (OU 2) will need to continue to be monitored to ensure the vegetation’s long-term survivability. Accordingly, appropriate O&M procedures will need to be implemented. The remedy selected for Operable Unit 3 needs to be implemented and the remedy for OperableUnit 4 needs to be selected and implemented.

25

VII. Protectiveness Statements:

Operable Unit 1: The remedy is expected to be protective of human health and theenvironment upon completion.Operable Unit 2: The remedy is expected to be protective of human health and theenvironment upon completion.Operable Unit 3: The remedy is expected to be protective of human health and theenvironment upon completion. However, until the remedy selected in the October 9, 2001 RODis implemented, the following issues remain:

Homes with exterior soil lead levels above 650 ppm and which were notremediated during the interim removal action need to be evaluated in accordancewith the ROD.Playground areas in the residential communities need to be remediated if leadlevels are found to be above 400 ppm.A notification mechanism to protect future residential buyers of homes found tohave soil lead levels above 650 ppm but which will not be remediated needs to beimplemented.

The following remedies for the above issues, as cited in the ROD issued on October 9, 2001,need to be taken to ensure protectiveness:

Exterior soil and interior dust remediation until clean-up standards are obtained inaccordance with the ROD.Sampling and clean-up of residential play areas in accordance with the ROD.Implementation of Institutional Controls to notify potential buyers of a propertyof the existence of sampling information in accordance with the ROD.

Consent Decree negotiations are currently underway between EPA and the PRPs forimplementation of the above remedies.

Operable Unit 4: A protectiveness determination cannot be made at this time until furtherinformation is obtained. Further information will continue to be obtained during the RI/FScurrently underway. It is expected that the RI/FS will be completed by early 2003, at whichtime a protectiveness determination will be made. It should be noted that exposure togroundwater is minimal since most of the potentially affected area is connected to a public watersupply. The few nearby residential wells have been sampled and do not exhibit contaminantsthat can be currently attributed to on-site groundwater.

VIII. Issues

Operable Unit #1 - Blue Mountain

Although revegetation via grass seed was highly successful, initial tree seeding of the 775remediated acres on Blue Mountain (OU 1) and a subsequent planting of tree seedlings has notbeen successful. In addition, limited sampling data may indicate that translocation ofcontaminants is occurring through plant uptake. The extent of translocation of contaminantsthrough plant uptake and it’s effects on the revegetated acreage, if any, need to be determined.

26

The remaining denuded acres of Blue Mountain (OU 1) need to be revegetated. Applicationrates, uniform coverage, areal extent to be remediated, types of grasses and performancestandard issues in test plots need to be resolved for proposed Viacom design.

Operable Unit #2 - Cinder Bank

Construction of Metal Reduction Zones (MRZs) and remaining revegetation on the Cinder Bankneeds to be completed(OU 2). Access restrictions and long term O&M issues of Cinder Bankneed to be addressed (OU 2).

Operable Unit #3 - Community Soils

EPA and the PRPs need to complete Consent Decree negotiations and then design and constructthe remedy called for in the October 9, 2001 ROD (OU 3).

IX. Recommendations and Follow-Up Actions

Operable Unit #1 - Blue Mountain

The completed portion of Blue Mountain should be monitored and evaluated for long termvegetation survivability and translocation of contaminants. Appropriate plant species should besampled and analyzed for metals to determine if translocation is occurring. If it is occurring,what adverse effects it is causing, if any, should be determined. If it is determined thattranslocation of contaminants through plant uptake of metals is causing adverse effects thenperiodically, on an as-needed basis, removal of volunteer tree species with high metal uptake(i.e., Birch, Poplar, etc.), repair of areas of vegetative die off, or application of soil amendmentsto minimize contaminant uptake may be implemented.

On the remaining acreage of Blue Mountain a revegetation approach that has minimal metaluptake to ensure long term survivability and minimize translocation of contaminants, if it isshown to be a problem, should be implemented.

Operable Unit #2 - Cinder Bank

Completion the construction of the MRZs and the remaining revegetation should be ensured. Operation and Maintenance of the Cinder Bank remedies needs to be implemented.

Operable Unit #3 - Community Soils

Complete Consent Decree negotiations with PRPs for implementation of the October 9, 2001ROD and begin the design and implementation of the ROD.

X. Next Five-Year Review

This Site involves long-term remediation and therefore another policy review will be required. The next Five-Year Review will be due five years from the signature date of this Five-YearReview report.

Tables

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TABLE 1. SITE CHRONOLOGY

DATE DESCRIPTION OPERABLEUNIT #

1898 – 1967 Zinc smelters operated by New Jersey Zinc Company. N/A

1967 – 1981 Zinc smelters operated by Gulf & Western Corporation. N/A

1981 Horsehead Industries, Incorporated, purchased the smelters and began operatingthe facility as a hazardous waste recycling plant.

N/A

September1983

Site listed on the NPL. N/A

September1985

EPA entered into an Administrative Order on Consent (AO) with HorseheadIndustries, Incorporated, and the current owner/operator of the Site, The NewJersey Zinc Company, a division of HII. Under the terms of this AO, HII agreed toconduct a Remedial Investigation/Feasibility Study (RI/FS) for OU 2 and Gulf &Western Industries, Incorporated, agreed to conduct a RI/FS for OU3.

2 & 3

September 4,1987

Record of Decision (ROD) issued which called for the revegetation of 2000 acreson Blue Mountain.

1

1988 The Draft RI was completed by Paramount Communications, Incorporated,(formerly Gulf and Western Industries, Incorporated). EPA deemed the RI/FSdeficient and subsequently took over the RI/FS for this OU.

3

June 29, 1988 Record of Decision issued for OU 2, remediation of the Cinder Bank. 2

October 18,1988

Consent Decree entered into between EPA and ZCA, a division of HII, toimplement the ROD.

1

1990 U.S. Army Corps of Engineers (USACE) contracted to be the Remedial Actionoversight contractor for EPA.

1

1991 – 1996 775 acres out of the 2000-acre total underwent the remediation application process. 1

February1991

PADEP, then known as PADER, conducted sampling of two homes in Palmertonwhich showed high levels of lead, cadmium, and zinc. PADEP then requestedEPA sample an additional 24 homes. The results from sampling these additionalhomes also showed high levels of lead, cadmium, and zinc.

3

May 7, 1991 EPA approval to start construction was given to ZCA. 1

October 1991 EPA and ATSDR conducted a comprehensive sampling program in Palmerton. 3

October 1992 EPA received the sampling results received from the joint EPA/ATSDR samplingconducted in Palmerton. The results showed high levels of lead, cadmium, andzinc in the household dust and surface soils surrounding the residential homes.

3

29

Jan/Feb 1993 EPA received additional results supporting the high metal content of the previoussampling results. An On-Scene Coordinator (OSC) from the EPA Removal Branchwas called in to mitigate the health threats posed by the Site.

3

1994 -1997 EPA’s Removal Branch conducted an Interim Removal Action to address theimmediate health threats to children and pregnant women due to the high levels oflead, cadmium, and zinc.

3

January 25,1995

USACE Audit Report of the 775 remediated acres submitted to EPA. 1

November 13,1995

EPA entered into a Consent Decree with Horsehead to resolve multiple violationsof RCRA, CAA and CWA. Under the CD, Horsehead must remediate the CinderBank to meet effluent discharge limits.

2

1995 ZCA stopped remediation work on OU 1 due to disagreement regarding theirresponsibility to continue work under the 1998 Consent Decree. This dispute isstill unresolved.

1

December 22,1995

EPA sent Special Notice Letters to the PRPs, which contained an offer for them toperform the RI/FS for OU 4. After the PRPs declined this offer, EPA decided toperform the RI/FS using Superfund monies.

4

1997 & 1998 EPA conducted field work associated with the ecological aspects of OU 4. 4

March 1999 EPA completed a Baseline Risk Assessment as part of the Remedial Investigation(RI) to determine the long-term risk associated with the high metal levels in theresidential areas.

3

February1999

HII submitted the PRT Work Plan to EPA. 2

November1999

ZCA planted an additional round of tree seedlings. 1

December 10,1999

EPA issued a Unilateral Administrative Order (UAO) to Horsehead and Viacom toremediate the remaining OU 1 acreage.

1

March 2000 EPA approved the PRT Work Plan. 2

April 2000 PRT Work Plan construction initiated. 2

June 2000 EPA completed the Feasibility Study, which was based on the 1999 Baseline RiskAssessment.

3

October 2000 The Adrian Brown consulting firm, hired by Viacom to remediate the remainingacreage under the UAO, completed test plot applications on 12 one-acre sites.

1

March 13,2001

USACE soil scientist, Dr. Charles R. Lee, Ph.D., CPSS, submitted an evaluation ofthe tree seedling plantings to EPA. This evaluation is known as “The Dr. LeeReport”.

1

March 14,2001

USACE letter submitted to EPA regarding application rates and coverage concernsof the Adrian Brown test plots.

1

30

May 2001 Site visit conducted by EPA, and representatives of the PRPs, DOI, PADEP andUSACE to view the success rate of the test plots.

1

September11, 2001

Second site visit conducted by EPA, and representatives of the PRPs, DOI, PADEPand USACE to view the success rate of the test plots.

1

January 2001 Adrian Brown draft report detailing the observations, evaluations, and potentialresolutions regarding the test plots submitted to EPA.

1

October 9,2001

EPA issued ROD for OU 3. 3

31

TABLE 2. ISSUES

ISSUE#

ISSUE AFFECTSCURRENT

PROTECTIVNESS(Y/N)

AFFECTSFUTURE

PROTECTIVNESS(Y/N)

1 Although revegetation via grass seed was highlysuccessful, initial tree seeding of the 775 remediated acreson Blue Mountain (OU 1) and a subsequent planting oftree seedlings has not been successful. In addition,limited sampling data may indicate that translocation ofcontaminants is occurring through plant uptake. Theextent of translocation of contaminants through plantuptake and it’s effects on the remedy, if any, need to bedetermined.

N Y

2 Remaining denuded acreage of Blue Mountain (OU 1)needs to be revegetated. Application rates, uniformcoverage, areal extent to be remediated, types of grasses,long term survivability and performance standard issuesin test plots need to be resolved.

Y Y

3 Complete construction of Metal Reduction Zones (MRZs)and remaining revegetation on the Cinder Bank (OU 2).

Y Y

4 Address access restrictions and long term O&M ofburning areas of Cinder Bank (OU 2).

Y Y

5 Need to design and construct the remedy called for in theOctober 9, 2001 ROD (OU 3).

Y Y

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Table 3. Recommendations and Follow-up Actions

ISSUE#

Recommendations and Follow-Up Actions

PartyResponsible

OversightAgency

MilestoneDate

Affects Protectiveness(Y/N)

CURRENT FUTURE

1 Monitor and evaluate the completedportion of Blue Mountain for longterm vegetation survivability andtranslocation of contaminants (OU1).

PRPs EPA Summer/Fall 2002

N Y

2 Sample and analyze appropriateplant species for metals to determineif any uptake is occurring.

PRPs EPA Summer/Fall 2002

N Y

3 Periodically, on an as-needed basis,if appropriate, remove volunteer treespecies with high metal uptake (i.e.,Birch, Poplar, etc.) (OU 1), repairareas of vegetative die off, or applysoil amendments to minimizecontaminant uptake.

PRPs EPA Asnecessary

N Y

4 Utilize a revegetation approach thathas minimum metal uptake on theremaining acreage of Blue Mountain(OU 1) to ensure long termsurvivability and minimizetranslocation of contaminants, if it isshown to be a problem.

PRPs EPA Fall/Spring2002- ‘03

Y Y

5 Ensure completion of theconstruction of the MRZs and theremaining revegetation (OU2).

Horsehead EPA Spring/Summer2002

Y Y

6 Complete negotiations with PRPsfor implementation of the October 9,2001, ROD (OU 3).

EPA/PRPs EPA Spring/Summer2002

Y Y

7 Design and implement the October9, 2001 ROD (OU 3).

PRPS EPA Summer/Fall 2002

Y Y

Attachments

Attachment 1

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Attachment 2

FIVE-YEAR REVIEW REPORT

Palmerton Zinc Pile

Superfund Site

Palmerton, Carbon County, Pennsylvania

Prepared by:

U.S. Environmental Protection Agency

Region III

Philadelphia, Pennsylvania

U. S. Environmental Protection Agency Region III

Hazardous Waste Management Division Five-Year Review ( Type Ia)

Palmerton Zinc Pile Site - Palmerton, Pennsylvania

I. Introduction

Authority Statement. Purpose. EPA Region III conducted this review pursuant to CERCLA section 121(c),NCP section 300.400(f)(4)(ii), and OSWER Directives 9355.7-02 (May 23, 1991), and 9355.7-02A (July 26, 1994).It is a statutory review. The purpose of a five-year review is to ensure that a remedial action remainsprotective of public health and the environment and is functioning as designed. This document will become apart of the Site File. This review (Type Ia) is applicable to a site at which response is ongoing.

Site Characteristics.

The Palmerton Zinc Superfund Site is located in the Borough of Palmerton, Carbon County, PA about 20 milesnorth of Allentown. Approximately 6500 residents live in Palmerton. From 1898 to about 1981, a zinc smelterwas operated within the Borough. The smelter was purchased in 1967 from private ownership by Gulf and WesternCorporation (G&W). In 1981, Horsehead Industries, Inc. purchased the smelters. The site was placed on theNational Priorities List (NPL) in Dec. 1982.

The smelting operations were located at two separate plant locations. The west plant smelter began operationsin 1898, and the east plant in 1911. Both plants ceased operations about 1981. The facility recovered zincand other metals for the manufacture of machinery, pharmaceuticals, pigments, and other products.

The primary zinc smelting operation utilized concentrated sulfide ores. The smelters over the years haveemitted vast quantities of zinc, lead, cadmium, and sulfur dioxide. This pollution led to the defoliation ofapproximately 2000 acres on Blue Mountain, deposition of heavy metal contamination within the Borough and thevalley, and the stockpiling of approximately 32,000,000 tons of slag. The slag pile, which is called theCinder Bank, is causing pollution of the shallow aquifer and the Aquashicola Creek which flows through theBorough into the Lehigh River. It was apparently common practice to deposit this slag material in this wastepile before it was fully quenched. Therefore significant parts of the interior of the Cinder Bank continue toburn.

Surface soil samples taken on Blue Mountain revealed contamination levels of cadmium from 364 ppm to 1,300ppm, lead from 1,200 ppm to 6,475 ppm, and zinc from 13,000 ppm to 35,000 ppm. Most of this contamination iscontained within the top 6 to 10 inches of soil. This is because the metals are bound in organic materialswhich prevents more significant downward movement of metals.

The Cinder Bank is approximately 2.5 miles long, 200 feet high, 200 feet wide at its crest, and 1,000 feetwide at the base. The Cinder Bank consists of mostly residual metals and carbonaceous material. As a resultof either incomplete quenching or spontaneous combustion, portions smoulder continuously. The contaminationwithin the Cinder Bank consists of 3,600 ppm lead, 250 ppm cadmium, and 27,000 ppm zinc, as well as othermetals.

Since 1981, when Horsehead Industries, Inc. bought the facility, it has been operated as a hazardous wasterecycling facility. It presently processes RCRA waste number K061, electric arc furnace (EAF) dust. This dustis a residue from the steel mill industry which contains significant levels of several hazardous metals,including lead, cadmium and zinc. Horsehead Industries Inc. (HII) is the parent company with twosubsidiaries. The first is Zinc Corporation of America (ZCA) the facility operator. The second is HorseheadResource Development Company (HRD) which is responsible for research and development, including considerablemanagement of the remedial action in progress on Blue Mountain, the only remedial action underway at thistime.

II. Discussion of Remedial Objectives; Areas of Noncompliance.

The Site has been divided into four operable units. The following is a brief history of the first operableunit (OU), the Blue Mountain Restoration Project:

Operable Unit # 1 - Blue Mountain

OU # 1 consists of the revegetation of approximately 2,000 acres on Blue Mountain under an interim remedy[see enclosed excerpts from the Declaration for the Record of Decision (ROD)]. The Remedial Investigation andFeasibility Study (RI/FS) was conducted by EPA. The ROD was issued on September 4, 1987. The selected interimalternative is to apply a sludge/lime/fly ash mixture with grass seeds and tree seeds. While not addressing

all applicable or relevant and appropriate requirements (ARARs), the selected alternative was deemedconsistent with those action-specific ARARs addressing sludge application, a special concern of theCommonwealth of Pennsylvania, who accepted the ROD.

A Consent Decree (CD) to perform the remedial design and remedial action (RD/RA) was entered into betweenEPA, ZCA, and HRD on Oct. 18, 1988. The final plans were received in EPA on April 15, 1991. Approval to startconstruction was given on May 7, 1991. Approximately 200 acres per year were scheduled for remediation.

The ROD refers to the remediation of 2,000 acres, however the exact limits of restoration were not preciselyestablished. Approximately 775 acres has undergone the sludge/lime/flyash plus grass/tree seeds applicationprocess. A timber survey conducted in 1994-1995 by the Potentially Responsible Party(ies)(PRPs) identifiedareas where sufficient tree density per the requirements of the remedial design (435 live trees per acre)already existed and thus did not require remediation. The U. S. Army Corps of Engineers (USACE) , Tobyhanna,PA has been EPA' s RA oversight contractor since 1990 and has extensive experience with this effort. As ofthis date, the remedy ( i.e. sludge/lime/fly ash mixture with grass seeds and tree seeds) has been applied tothose areas specified in the RD.

In conjunction with that oversight, an audit report was prepared by the U.S. Army Corps of Engineers (USACE)Waterways Experiment Station (WES), and the USACE Cold Regions Research and Engineering Laboratory (CRREL) atthe request of U.S. EPA Region III (USEPA) concerning the restoration success of the interim remedial action.That report, date January 25, 1995, concluded the following:

• The application of the sludge/ lime/flyash mixture (ECOLOAMtm) appeared to stabilize the treatedareas, reduce soil erosion and improve soluble (contaminant metals) water quality associated withrunoff to a large extent.

• Soluble concentrations of metals were still above water quality criteria.

• Plant-available metals from the contaminated soil were not affected or may have increased, resultingin plants continuing to take up excessive metals, and potentially contaminate foodchains.

• While establishment of grass cover appeared successful, reestablishment of tree cover did not. Of 14test plots evaluated, eleven had tree counts of less than the 435 live woody stems per acre called forin the remedial design.

• The establishment of the indigenous volunteer birch and poplar species, known to take up hazardousmetals from the soil into leaves, could make these metals available to the foodchain, especiallyinvertebrates, via leaf litter. This could be counterproductive to the remedial objective of in- situstabilization of hazardous metals in the soil, and, in conjunction with a newly vegetated Mountain,attract wildlife to a potentially contaminated foodchain.

• USACE WES/CRREL observations have not shown tap root penetration below the ECOLOAM layer.

The PRPs, at the suggestion of USACE WES/CRREL and EPA, planted test plots of tree seedlings in late 1995.This involved breaking through surface soil with a dibble bar, then planting seedlings into the subsoil, withsome augmented by ECOLOAM, to allow the tap root access to soil below the contaminated layers. This effortutilized low metals uptake species (oak and maple) and is being evaluated at this time. Tree seedlings werethe specified alternative in the ROD if the tree seed would not adequately germinate.

The Site has three other operable units. The following is a brief history and current status of each:

Operable Unit #2

This OU deals with remediation of the Cinder Bank. In September 1985, HRD and ZCA entered into a ConsentDecree to conduct a RI/FS for the Cinder Bank. A ROD was issued on June 29, 1988. The selected alternativeincluded the following:

1. Slope modification to enhance precipitation runoff from the Cinder Bank, thus reducing the amount of infiltration through the Cinder Bank. Grading specification are to be developed in the Pre- Design.

2. Construction of surface water diversion channels to collect the runoff from Blue Mountain and the Cinder Bank, and the leachate from the Cinder Bank. This water is to be treated prior to entering the stream.

3. Construction of a cap consisting of a minimum of 18 inches of soil and 6 inches of clay or a soil/ bentonite mixture.

4. Vegetative cover consisting of a sludge/ lime/ fly ash mixture, grass seeds, and tree seedings.

This alternative has been the subject of controversy between the PRPs and the Pennsylvania Department ofEnvironmental Protection (PADEP) and is currently being reevaluated by EPA. Specifically, PADEP has claimedthat the slope modifications must meet their Municipal Landfill Regulations and that the fires within theCinder Bank must be extinguished. In EPA's Engineering Evaluation and Cost Analysis (EE/CA) for this remedy,EPA's contractor, Black & Veatch Waste Sciences, Inc. estimated that the cost to implement the PADEP’s capand extinguish the interior fires would be approximately $250 million.

The PRPs agreed to perform additional studies in support of a possible alternative remedy. These included anair monitoring program to determine if the fires present an environmental threat, and the investigation ofsome latest recycling technology. Work began in 1992 and was completed in 1994. The collective results ofthese studies were inconclusive.

On July 20, 1994, EPA Region III's Hazardous Waste Management Division (HWMD) invited HRD (a subsidiary ofHII) to submit a work plan for a demonstration project to attempt to vegetate areas of the Cinder Bank underthe Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, i.e. Superfund). OnNovember 13, 1995, the United States entered into a Consent Decree (CD) with HII regarding multiplecomplaints under the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA) and the CleanWater Act (CWA) which, among other things, resulted in a very similar vegetation project being presented toEPA Region III' s Water Division (WATER) as a pollution reduction technology (PRT) in the CD. Specificallythis approach was advanced as a means of achieving the effluent limitations described in that CD.

In January 1996, EPA HWMD found that the vegetation project proposed as part of this CD essentiallyduplicated the demonstration work originally proposed by HRD to HWMD under Superfund. For this reason, EPARegion III HWMD decided that they would evaluate HII/ HRD's effort to vegetate those portions of the CinderBank described in the CD under the oversight of WATER. To date, HII/HRD has taken NO action on this project,having claimed a force majure issue against PADEP. In August 1996 the United States Department of Justice (DOJ) addressed this issue and gave notice to the PRPs to begin work.

Operable Unit # 3 - Offsite Soil Study

In Oct. 1991, EPA began a comprehensive environmental sampling program in conjunction with the ATSDR healthtesting in Palmerton and Jim Thorpe. The EPA environmental sampling final report was issued in January 1995.

In Spring of 1992, EPA' s National Enforcement Investigations Center (NEIC) in Denver, CO began a sourceidentification study to determine the various sources of the contamination in the Borough of Palmerton. Thisstudy was completed in June 1994 and concluded that over 90% of the lead, cadmium and zinc contamination inPalmerton was due to past primary zinc smelting, approximately 10% was due to contemporary (since 1981) EAFdust recycling activities and contamination due to lead-based paint, long claimed a major source by somefactions in Palmerton was " insignificant."

A health study by the Agency for Toxic Substances and Disease Registry (ATSDR) was completed in April, 1994.Among its findings were that 27% of children tested by ATSDR in Palmerton had elevated blood lead levels,that is, blood lead levels of 10 ug/dL or higher.

Following two unsatisfactory efforts by the PRPs, EPA Region III began a (Super) Fund-lead risk assessmentfor the Borough of Palmerton in March 1995. EPA has invited both the community and the PRPs to participate inthis endeavor. This risk assessment is expected to be completed by the end of this year and EPA plans toissue a ROD for OU #3 by late 1997 or early 1998.

Operable Unit # 4 - Areawide Groundwater/ Surface Water Investigation

This investigation is to involve the groundwater, surface water, and the any effects from existing solidwaste management units within the operating facility on same. An areawide ecological risk assessment willalso be included in this operable unit.

EPA invited the PRPs to undertake the RI/FS for this operable unit via Special Notice issued in December1995. The PRPs declined in early 1996. EPA took over the RI/FS for Operable Unit # 4 effective June 1996 asanother Fund-lead effort and expects to begin work before the end of the year.

III. Recommendations.

EPA/USACE will continue to evaluate the success of the interim remedy applied to the first 1,000 acre area ofBlue Mountain, Operable Unit # 1. EPA/USACE will also continue to explore current and future methods ofreforestation with the PRPs to meet the tree establishment and other requirements in the remedial design. Theissue of maintaining adequate in-situ stabilization of hazardous metals in the soil to prevent potentialrecontamination of the food chain will also be a part of this effort.

EPA will likewise continue to address immediate and long term threats to human health and the environment ascharacterized by the other operable units.

IV. Statement on Protectiveness.

The remedy is not at this time protective of human health and the environment. EPA is taking steps to makethe remedy protective. (See III. Recommendations above).

V. Next Five-Year Review.

The next five-year review will be completed no later than September 30, 2001.

Enclosure:

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Palmerton Zinc Superfund Site - Blue Mountain Operable Unit Town of Palmerton, Carbon County, Pennsylvania

STATEMENT OF PURPOSE

This decision document represents the selected remedial action for this site developed in accordance withCERCLA, an amended by SARA, and to the extent practicable, the National Contingency Plan.

STATEMENT OF BASIS

This decision is based upon the administrative record ( index attached) . The attached index identifies theitems which comprise the administrative record upon which the selection of a remedial action is based.

DESCRIPTION OF THE SELECTED REMEDY

This is an interim remedy...(indeciferable)...of three separate operable units at ......(indeciferable).The other two operable units are being investigated by the responsible parties and will be addressed at alater date.

The selected site remedy does not attempt to ensure compliance with all ARARS, but will be consistent, to theextent practicable, with those action specific ARARS addressing sludge application, the Clean Water Act andBest Management Practice requirements.

The selected remedy consists of using a mixture of sewage sludge and fly ash to revegetate the defoliatedareas of Blue Mountain. The general procedures for the revegetation program would be as follows:

- Step 1: Heavy equipment (i.e., bulldozers) would be used to install access roads in the areas targeted for revegetation.

A concrete pad with reasonable berms would be installed to mix the sludge and fly ash on-site.

- Step 2: Lime potash application -- Lime and potash would be sprayed on the areas targeted for revegetation. Lime would be applied at approximately 10 tons per acre and potash at 80 pounds actual K per acre.

- Step 3: Sludge-fly ash application -- The sludge-fly ash mixture would be applied by spraying the mixture onto the target area. The sludge- fly ash ratio will be based on further analysis of the field test plots. The sludge will be obtained from the Town of Palmerton, Allentown, and, if necessary, Philadelphia.

- Step 4: Plant target area -- Grasses would be planted by blowing a mixture of grass seed onto the target area. Studies are continuing on the feasibility of also blowing tree seed onto the area. If tree seed will not germinate, seedlings will be planted.

- Step 5: Apply mulch -- To protect the seed and permit germination, adequate mulch will have to be applied. Mulching may be reduced or eliminated if spring oats are planted in the fall. This will provide winter cover that will die by spring. The target areas can then be seeded with the permanent plant species in the spring, and the spring oat stubble will serve as a protective “mulch” cover for the permanent species needed.

DECLARATION

The selected remedy is an interim remedy and is protective of human health and the environment, attainsFederal and State requirements that are applicable or relevant and appropriate, and is cost-effective. Thisremedy satisfies the preference for treatment that reduces mobility or volume as a principal element.Finally, it is determined that this remedy utilizes permanent solutions and alternative treatmenttechnologies, to the maximum extent practicable.

Recommended Alternative

Section 121 of SARA and the current version of the National Contingency Plan (NCP)(50 Fed. Reg. 47912,November 20,1985) establish a variety of requirements relating to the selection of remedial actions underCERCLA. Applying the current evaluation criteria in Table 2 to the three remaining remedial alternatives, werecommend that Alternative 3 be implemented at the Palmerton Zinc Superfund Site.

This is an interim remedy for the site. When the RI/FS’s for the other operable units are completed by theresponsible parties, ROD’s will be issued to address all aspects of the site. This interim remedy will not,however, be inconsistent with a final comprehensive remedy for the site. This interim remedy does not attemptto ensure compliance with all ARARS for the entire site, but as discussed above under Alternative 3, will beconsistent, to the extent practicable, with those, action specific ARARS addressing sludge application, theClean Water Act and, Best Management Practice requirements.

This alternative consists of using a mixture of sewage sludge and fly ash to revegetate the defoliated areasof Blue Mountain. Based on greenhouse studies and results of field tent plots it appears that this technologyis feasible.

Although changes may be made to application rates and/or sludge-fly ash ratios, it appears that a generaloutline of the procedures for the revegetation program would be as follows:

Step 1: Site preparation -- Heavy equipment (i.e., bulldozers) would be used to install access roads in the areas targeted for revegetation.

A concrete pad with reasonable berms would be installed to mix the sludge and fly ash on-site.

Step 2: Lime potash application -- Lime and potash would be sprayed on the areas targeted for revegetation. Lime would be applied at approximately 10 tons per acre and potash at 80 pounds actual K per acre.

Step 3: Sludge-fly ash application -- The sludge-fly ash mixture would be applied by spraying the mixture onto the target area. The sludge- fly ash ratio will be based on further analysis of the field test plots. The sludge will be obtained from the Town of Palmerton, Allentown, and, if necessary, Philadelphia.

Step 4: Plant target area -- Grasses would be planted by blowing a mixture of grass seed onto the target area. Studies are continuing on the feasibility of also blowing tree seed onto the area. It in not yet clear if tree seed will germinate on the site. If tree seed will not germinate, seedlings will be planted.

Step 5: Apply mulch -- To protect the seed and permit it germination, adequate mulch will have to be applied. Mulching may be reduced or eliminated if spring oats are planted in the fall. This will provide winter cover that will die by spring. The target areas can then be seeded with the permanent plant species in the spring, and the spring oat stubble will serve as a protective “mulch” layer for the permanent species seed.

Schedule

The anticipated schedule is to continue with some limited design studies in the Fall of 1987. Beginning assoon as possible, but probably not before the end of 1987, large scale, multi-acre revegetation will begin.It will take a number of years to complete the remedial action, the exact time depending on the amount ofsludge available. EPA s goal is to complete the project in five years.

Attachment 3

CEWES-ES-F 25 Jan 1995

MEMORANDUM FOR Mr. Fred MacMillan USEPA Region III 841 Chestnut Building Philadelphia, PA 19107-4431

SUBJECT: Evaluation of the Restoration Success at the Blue Mountain Palmerton, PA Zinc SuperfundSite

1. Three trips to the Palmerton Zinc Superfund site and the results of all testing and evaluations will bediscussed.

2. Mr. Tony Palazzo from Cold Regions Research and Engineering Laboratory (CRREL) and Mr.Richard Price, Charles Hahn, and myself from U.S. Army Corps of Engineers Waterways Experiment Station(WES), traveled to Palmerton, PA on 11-14 July 1994 to sample plants and soils in Phases I, II and III. PhaseV soil samples were planned to be collected also, if possible.

3. On Tuesday, 12 July 1994, soil samples were collected at approximately 100 feet above thebaseline road in Phase V. These samples were designated LI, L2, and L3. Final decisions for the access andterrace roads had not been made upon arrival at the site. Therefore, sampling was limited to within 100 ft from the existing baseline road. Other samples could be collected at a later date after the access roads areconstructed.

4. On Wednesday, 13 July 94, Mr. Bob Thompson, Borsehead Resource Development Company,Inc. (HRDC), explained and demonstrated his methodology previously used for counting tree seedlings at oneof his control plots in Phase I. Based on his demonstration, his procedure appeared to be appropriate. Onlylive tree seedlings and woody stems were counted. Mr. Thompson was not able to find the exact location ofhis previous data collection within the plot, because he tried to eyeball a perpendicular transect into the plotfrom the road. Information on the existing data sheets gives only distance from the road into the plot but notthe direction from the rebar marker at the road. A stake should be placed to mark each location that treecounts are made.

5. In order to evaluate the success of plant rooting depth, observations and samples were collectedfrom the oldest restored plots. Since HRDC collected some data for control plots in Phase I WES/CRRELcollected soil, plant leaf and root samples to further evaluate restoration success in Phase I, control plot 91A(sample site labels Ml and M2 as well as plot 91B, M3). Additional samples were collected in Plot BM 05(sample site labels U1 and U2). A third site was planned for sampling but rain, thunder and lightning,prevented the collection of samples from plot BM 06. One plant leaf sample was collected in plot BM 06 (U3A) before the weather prevented any further sample collection at this site. Field sampling time was limiteddue to the time required for the mixing and splitting procedures implemented on collected soil samples. Inorder to be able to collect more samples, only one half of the soil samples were mixed and split on site inHRDC's laboratory. The other half of the samples were taken back to the WES to perform the mixing andsplitting. These samples were shipped overnight to Mr. Thompson as soon as they were split. Samples ofIntermediate Wheatgrass were collected at the sites described at the beginning of this paragraph. These plantsamples were transported back to the WES to be rinsed, weighed, dried, ground and split for chemicalanalysis. Split plant samples were forwarded by Federal Express overnight delivery to Mr. Oyler as soon asthey were processed along with the acid digestion procedure to be used to analyze the plant tissue. Allsamples were processed in secured facilities at all times. Processed samples were stored under locked workareas. Chain of custody was maintained for all samples.

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6. Rooting of intermediate wheatgrass appeared to be massive in the ECOLOAM layer (labeled DO,approximately 4 inches thick) and penetrating the surface layers (Dl, 0-1" and D2, 1-2") of the original soil,continuing into the 2-6" soil depth (D3) and even into the 6-12" soil depth (D4). This was observed in each ofthe 5 sampling sites where plant tissue samples were collected (Figures 1 and 2, Table 1). However, almost allobservations of rooting of tree seedlings appeared to be concentrated in the ECOLOAM and not penetrating the 0-1" or 1-2" layers of the original soil. Five tree seedlings were dug up and only one was found to berooting below the ECOLOAM layer. Figure 3 shows an example of a tree seedling root growing horizontallyin the ECOLOAM and not penetrating vertically into the lower soil depths. Soil DTPA extraction indicates theECOLOAM layer contained an average of 256.6 parts per million (ppm) zinc, 5.6 ppm cadmium and 28.99ppm lead, while just below the ECOLOAM at Dl (0-1") and D2 (1-2") DTPA extractable metals were foundto average 1297.7 and 1413.1 ppm of zinc, 60.22 and 56.78 ppm cadmium, and 49.86 and 42.67 ppm lead,respectively (Table 2). While the 2-6" layer (D3) was still elevated with 1012.2 ppm zinc, 47.67 ppmcadmium, and 41.36 ppm lead, respectively, the 6-12" layer (D4) showed a decreased concentration of zinc,cadmium, and lead to 356.4, 9.21 and 16.74 ppm, respectively. Previous research with metal contaminateddredged material showed plant toxicity and reduced plant growth of an indicator plant, Cyperus esculentus, atDTPA extractable concentrations of approximately 800 ppm or more zinc (Folsom et al. 1981). The responseof Cyperus esculentus to excessive metals in dredged material and soils has been well correlated to otherplant species such as lettuce, radish, wheat, ryegrass, poplar, etc.(Van Driel et al. 1985; Davies andHoughton, 1983; Kay, Scholten and Bowmer, 1988; and Chaney, 1990). In general, rooting belowECOLOAM into the original substrate was found in about 50% (16 out of 32) of the observations forintermediate wheatgrass and about 10% (3 out of 30) for Canada bluegrass. Intermediate wheatgrass appearsto be penetrating the 0-6" layers that have elevated plant available zinc concentrations. In contrast, treeseedling roots do not appear to be penetrating below the ECOLOAM layer in the oldest restored plots inPhase 01.

7. Soil extraction data (Table 2) indicated that the ECOLOAM has lower concentrations of metals in all formstested; water soluble, DTPA, nitric acid digestible than the original surface soil layers 0-1" and 1-2", with the exception of DTPA lead. The 2-6" soil depth showed continued elevated concentrations of some metals, andthe 6-12" soil depth generally showed a decrease in metal concentrations to those found in the ECOLOAM.Zinc shows the typical distribution of a metal among different forms. Water soluble zinc showed the lowestconcentrations of the forms measured (Tables 2). Water soluble zinc was 1.58 ppm in the ECOLOAM andincreased over thirty times to 52.82 ppm in the original 0-1" surface soil and remained elevated at 49.87 ppmin the 1-2" soil depth. The concentration of water soluble zinc decreased to 21.29 and 13.76 ppm in the 2-6"and 6-12" soil depth, respectively, which were not different from that measured in the ECOLOAM. Watersoluble cadmium and lead showed similar results (Table 2). Water soluble metals are most prone to leachfrom soils and migrate on or from the site. DTPA extractable metals indicate what is available to plant rootsto absorb and take up. This fraction, of soil metals is predominately associated with soil organic complexes.Both DTPA extractable zinc and cadmium showed measurable increases in the 0-1", 1-2", and 2-6" soildepths compared to the ECOLOAM or 6-12" soil depth. Two acid soil extraction procedures (nitric acid andaqua regia) were conducted and indicated the total amount of metals present in the soil. Soil digestion withaqua regia acid (concentrated Nitric plus Hydrochloric acids) was thought to be more aggressive than theEPA nitric acid extraction. However, there was no statistical difference in soil metals measured in the aquaregia digestion compared to nitric acid extraction. The aqua regia soil extraction data are included in AppendixB.

Elevation Effects. Soil samples were collected at three different elevations up the mountain adjacent to theplant operations at Palmerton, PA. Lower elevations were in the 500-600 ft range, middle elevations werearound 800 ft and upper elevations were between 925 to 1275 ft. The lower elevations tended to containhigher concentrations of zinc in the water soluble and DTPA forma than the upper elevation (Table 3). whilethe other metals and forms tended to show similar results, statistical differences were not found at P = 0.05.

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These data indicated that zinc and to a lesser extent, cadmium and lead have migrated down the mountainfrom the upper elevations to the lower elevations. Therefore, plant and animal species will be exposed to moremetals at the lower elevations than the higher elevations. In addition, metals at the lower elevations have morepotential to exist the site in surface and ground waters.

ECOLOAM Effects. Zinc and cadmium showed similar results in regard to the apparent effect ofECOLOAM applications (Tables 4 and 5). Lead did not show as much effects as zinc and cadmium (Table6). Hater soluble zinc and cadmium were lowest in the 0-1" soil depth under the ECOLOAM in Phase 01compared to Phases 04 or 05 without ECOLOAM application (Tables 4 and 5). These data indicate thatsoluble zinc and cadmium in the original surface soil would be reduced, and migration down slope and off-siteshould be reduced. It should be noted that all water soluble zinc, cadmium and lead concentrations presentedin Tables 4, 5, and 6, exceed the US EPA Water Quality Criteria for these metals in freshwater and couldpose an adverse impact to receiving streams, especially if rainfall were to mix with the soil at a soil/water ratio of 1 to 5, the ratio used in the water soluble extraction procedure. In contrast, DTPA extractable zincand cadmium concentrations in the 0-1" and 1-2" depths were not reduced by ECOLOAM applications, infact, cadmium increased to 113.32 ppm in the 0-1" depth (Table 5). While the ECOLOAM mixture with itslime/flyash component appears to influence water soluble fractions of soil metals, no such influence is seenfor the organic complexed fraction represented by DTPA extraction. These data indicate that plants on sitewill continue to be exposed to plant available zinc and cadmium and will continue to take up these metals afterECOLOAM applications. Consequently, while the remedy of ECOLOAM applications appear to reducewater soluble migration of zinc and cadmium to some degree on or from the site, it may not meet surfacewater quality criteria or standards nor will it control plant contamination with zinc and cadmium and themigration of zinc and cadmium through plants into the foodwebs associated with the mountain. Storm et al.1994 reported that metals are migrating into foodwebs on Blue Mountain and elevated levels have beenobserved in wildlife sampled on site. ECOLOAM applications will not eliminate or reduce the migration ofmetals into plants, even though they will allow plants to grow on the site. In summary, the remedy is of limited success.

8. Mr. Tony Palazzo and I traveled to Palmerton, Pa on 1-5 August 1994 to recount all QA/QC plotsthat had previously collected data on tree seedling survival. Using a copy of the data collected by HRDC theprevious year, 16 control plots were revisited and woody counts were made within a 11.7 foot diameter circleat the same distances within the 100, 200, 300, and 400 foot transects as described in the Remedial Design forthe Blue Mountain Operable Unit (April 1991). A copy of the data sheets can be found in Appendix D. Alltransects were measured and staked in a north/south direction from the rebar marker at roadside. In contrast,Mr. Thompson, HRDC, stated that he tried to get the transects visually perpendicular to the road and did notstake the location of the plot. Therefore, it was not possible to find the exact locations of the HRDC woodycount circles now or at any time in the future. Consequently, at some sites when our counts were differentfrom HRDC recorded count, the trees counted by HRDC could be seen outside the 11.7 foot circle where weperformed our counts. Therefore, the difference in WES/CRREL counts observed at some sites was probablydue to not being in the exact location of HRDC 11.7 foot circle. However, differences in WES/CRRELcounts versus HRDC counts at other sites were due to the counting of suckers developed from one mainwoody stem. Mr. Thompson, HRDC, stated that he counted each suckering stem as a woody stem. He wasinstructed to count all live stems within the 11.7 foot circle. However, in reality, each suckering stem was abranch from one tree. Many older sassafras and white poplar trees had terminal death and multiple suckersgrowing from the base of the tree (Figure 4). Since Mr. Thompson, HROC, stated he would have countedeach sucker as a woody stem, this would have inflated the woody count for that plot. Mr. Thompson was veryaccurate in counting stems within the circle, he did not miss any stems while in our presence. The inflatednumbers of woody stems from counting suckers would elevate the number of woody stems per plot and givean erroneous high number of woody stems per acre. Mr. Thompson was consistent in counting suckers whenthey fell within the 11.7 foot circle. A situation was encountered of multiple stems from dead

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terminal stems or older trees. Two choices existed; count each stem as a live woody or count the cluster of suckers as one live original stem or tree. Mr. Thompson chose the former. However, this decision falselyinflated the restoration success from ECOLOAM applications. Suckers from one stem should be counted as asingle live woody stem.

9. A third trip was completed on 6 October 1994 to collect leaves from trees exhibiting zinc toxicitysymptoms for the purpose of chemically analyzing the tissues for zinc, cadmium and lead contents. These datawould support the visual observations made on site and depicted in the Figures in this memorandum. Zinctoxicity symptoms have been studied and described by Lee et al. 1968, 1969 in flax, soybeans and cotton. Thisis not a new phenomenon, but rather has been described as early as 1939 by Chapman, Liebig and Vanselow,as being a zinc-induced iron deficiency. Since that time, other scientists have reported zinc-induced irondeficiency in a variety of plant species (Brown and Tiffin, 1962; Gall and Barnette, 1940; Guest andChapman, 1944; Hewitt, 1948 and 1953; Hunter and Vergnano, 1953; Millikan, 1947 and 1949; and Smith andSpecht, 1953). In sand and water cultures, zinc has been shown to induce symptoms apparently identical withthose of iron deficiency (Brown and Tiffin, 1962; Guest and Chapman, 1944; Hewitt, 1948, 1949 and 1953;Hunter and Vergnano, 1953; Millikan, 1947 and 1949; and Smith and Specht, 1953). Observations of zinc-induced iron deficiency in the field have been reported (Millikan, 1947; Staker and Cummings, 1941; Wallaceand Hewitt, 1946 and Lee et al. 1965, 1968). Lee et al. 1965, 1967, 1968 and 1969 reported zinc toxicity-induced iron deficiency symptoms in sensitive flax plants containing as little as 48 ppm zinc (normal leavescontained 15 ppm zinc), in cotton plants containing 2022 ppm zinc (normal leaves contained 78 ppm zinc) andsoybean plants containing 380 ppm zinc (normal leaves contained 77 ppm zinc). These data indicate that plantspecies have different responses to zinc toxicity. Tree leaves of different species were collected at Blue Mountain, Palmerton, PA that appeared to exhibit zinc-induced iron deficiency symptoms Figures 5-12. Thesefigures indicate that zinc toxicity symptoms were observed in a wide range of trees including suckers growingat the base of old dead trees, lower leaves on older trees, on younger trees and even on small seedlings. Ofthe species sampled, birch leaves contained the highest concentrations of zinc (853 to 2696 ppm), sassafrasleaves contained less zinc (125 to 621 ppm) but exhibited extreme zinc-induced iron deficiency symptoms andoak leaves contained the least concentrations of zinc (90 to 272 ppm) while exhibiting lesser symptomsresembling zinc-induced iron deficiency (Table 7). This differential uptake of zinc appears to follow results observed with different trees grown on contaminated dredged material reported by Kay, Scholten andBowmer, 1988. Poplar tree leaves contained 1495 ppm zinc, while oak leaves contained only 80 ppm zinc andmaple leaves contained only 52 ppm zinc.

Grass leaf samples of Intermediate wheatgrass were collected during the soil sampling of Phase I and showedinitial tissue concentrations ranging from 72 to 267 ppm zinc, 1.57 to 6.96 ppm cadmium, and 2.45 to 7.30 ppmlead, respectively (Table 8). Normal plant tissue concentrations range from 15 to 150 ppm zinc, 0.1 to 1.0 ppmcadmium, and 2 to 5 ppm lead (Table 9). Tissue concentrations of zinc at 290 ppm have been associated witha 10% yield reduction in agronomic crops, while tissue zinc concentrations of 500 ppm have been associatedwith a 25% yield reduction in crops (Lee et al. 1991). Oyler 1988 reported a suggested permissible tolerancelevel for zinc at 300 ppm. Based of these results it initially appears that Intermediate wheatgrass is not takingup excessive amounts of zinc and probably is not showing a yield reduction on site. Tissue cadmiumconcentrations appear to be above the normal range and exceed the permissible tolerance levels of 3 ppmreported by Oyler (1988), but have not reached the critical content of 8 ppm associated with detrimentaleffects observed in plants (Lee et al. 1991). The majority of the tissue lead concentrations initially appear tobe in the normal range with five samples slightly above 5 ppm and all samples below the 10 ppm reported byOyler (1988). Eighteen vegetation samples collected and analyzed by HRDC showed tissue concentrationsranging from 107 to 593 ppm zinc, 3.9 to 17.6 ppm cadmium and <2.3 to 35 ppm lead (CAL, 1993). Thesesamples had considerably higher upper ranges than the samples collected from Phase I by WES/CRREL andreported in the present report. However, the recoveries obtained in the present report were below the

4

US ROOT 0055

certified values by some 67% for Cd, 32% for Pb and 54% for Zn (Table 10). Therefore, if all values forgrass reported were increased by these percentages, the grass tissue values would approach and exceed thelevels reported by Oyler, 1988 and would be comparable to that reported by CAL, 1993 for HRDC. WhileIntermediate wheatgrass appears to be successfully vegetating the slopes, there appears to be some degree of contamination with zinc or lead in the WES/CRREL data that if corrected for low recoveries would becomparable to data collected by HRDC that should be of concern. Both WES/CRREL and HRDC tissue datashow some elevated levels of cadmium that should be of concern in foodwebs associated with the site. Storm et al. 1994 reported that metals were contaminating wildlife at Palmerton prior to ECOLOAM applicationsand showed elevated animal tissue concentrations of cadmium in the kidneys of white-footed mice andcadmium in the kidneys and livers of white-tailed deer. Data collected by WES/CRREL and HRDC in the present report indicate no potential change in the migration of metals into foodwebs at Palmerton afterECOLOAM applications.

The application of limestone or a liming material (Thorne and Wallace, 1944) to raise soil pH values to nearneutral or 7.0 has been shown to reduce plant available soil iron and reduce iron concentrations in plantsgrowing in such soil conditions. This has become common knowledge in the agricultural community over thepast fifty years. Excessive plant-available soil zinc in combination with soil pH values at 7.0 and low plantavailable soil iron can be devastating for most plants, especially sensitive trees, to grow and survive. Thecombination of ECOLOAM application of materials limed to pH 7.0 and the extremely high concentrations ofDTPA extractable zinc and cadmium will result in poor tree seedling growth and considerable uptake of zincand cadmium by susceptible trees. These results indicated that foodwebs at the site will have elevatedconcentrations of zinc and cadmium and potentially pose a serious risk to wildlife feeding on site. Theobservations of massive biological activity and the increased numbers of wildlife invading the newly vegetatedmountain indicate an attraction of wildlife to a contaminated ecosystem that will provide contaminated foodfor those birds and animals that graze or forage on the mountain.

10. QA/QC data (Tables 8 and 9) indicate that while laboratory precision was good, accuracy was poorerthan expected in that the microwave acid digestion procedure did not dissolve all the metals in the samples.Therefore, all values presented are below the actual metal contents in plant tissues and soil samples. Valuesfor grass samples are approximately 67% for Cd, 32% for Pb and 54% for Zn below the actual values.Values for tree leaf samples are approximately 67% for Cd, 56% for Pb, and 31% for Zn below the actualvalues. Values for soil samples are approximately 31% for Cd, 25% for Pb and 36% for Zn below the actualvalues. Actual concentrations could be estimated using these percentages. However, all relative comparisonsand relationships discussed are valid within the data sets used in the statistical analyses.

11. Two statistical analyses were performed to compare the number of woody stems counted byWES/CRREL versus the number counted by HRDC. The first analysis consisted of a paired t-test, in whicheach record of a woody stein count by HRDC was compared to the analogous woody stem count byWES/CRREL at the same sample point (i.e. same plot, transect, distance along transect). The results of thist-test were not statistically significant, which means that there were no differences in WES/CRREL andHRDC woody stem counts. The second analysis was a t-test comparing the overall mean of woody stemcounts of HRDC versus the overall mean of woody stem counts of WES/CRREL. Again, the results were notstatistically significant, indicating that the overall means of HRDC and WES/CRREL woody stem counts didnot differ and that a differences could not be measured. Perhaps the most direct and informative way oflooking at the woody stem counts is to look at the relative percentages of plots which meet the requiredcriterion of 435 woody stems per acre and also the relative percentages of sample counts which meet thiscriterion. In Table 10, the means of ten sampled circles (11.7 ft. diameter) of woody stems per plot are presented. Only 31.25% of the plots sampled by HRDC had mean woody stem counts equal to or greaterthan 4.35 (which translates to 435 stems/acre), while only 25% of the plots sampled by WES/CRREL met thiscriterion. Even when considering the total numbers of woody stems on a per sampled circle basis, 76.9% of

5US ROOT 0056

the sample counts recorded by HRDC were not greater than 4, which equates to 435 stems/acre (Table 11,Figure 13a), while 80.6% of WES/CRREL records were not greater than 4 (Table 12, Figure 13b). Figure 14 shows the percentage of frequency of observations of woody counts per sampled circle from HRDC andWES/CRREL data,. and emphasizes the large number of sampled circles that were below 4 woody stems per11.7 ft circle (below 435 woody stems/acre). Considering the relative percentages of woody stem countson a per plot and per sampled circle basis as noted above, it is evident that only clusters of trees are beingrestored in a relatively low percentage of the total area being treated.

12. In addition to tree seedling (woody) counts, the percentages of vegetative cover and stone wererecorded (Appendix D). It appeared as though the amount of stone present might reduce tree seedling countsas well as thick grass appeared to result in low tree seedling counts. On other restored sites, WES/CRRELscientists have observed poor tree survival when grass cover was thick and able to out compete with the treeseedlings. Therefore, data were recorded in an attempt to separate out the potential causes for low treeseedling counts in certain plots. Extensive analyses of these data were conducted to look for possiblerelationships among these percentages and woody stem counts. Simple linear and polynomial (quadratic andcubic) regressions of woody stem counts (dependent variable) versus percent cover, percent stone, and theinteraction of percent cover and stone (independent variables) were conducted to investigate the possibility ofa relationship between woody stem counts and the above-mentioned independent variables. The regressionswere initially conducted on raw data and subsequently repeated with log-transformed data. Most of theregressions were not statistically significant, and of the few that were, R-square values were extremely low,so that very little confidence could be placed on the reliability of these relationships. In summary, nomeaningful consistent relationships could be found between numbers of woody stems and percentagevegetative cover or stone. In some areas of large amounts of stones, some trees were surviving. Likewise, insome areas of thick vegetation, some trees were surviving. On the other hand, there were areas of no stoneand no trees as well as thin or very little vegetation and no trees. Therefore, consistent relationships could notbe found.

13. At this point in our evaluation, it can be concluded that restoration with trees only covers 25-31.2% ofthe area. Existing trees exhibiting zinc toxicity symptoms will not survive in the long term. Something else willbe required to achieve better tree establishment and survival on larger areas of the mountain.

14. It appears that tree seedling roots are not penetrating below the ECOLOAM layer and need to beincorporated below the original 0-6" soil depth, beneath the elevated toxic levels of zinc and cadmium to besuccessful. Additional sources of iron should be considered such as sludge high in iron to correct induced irondeficiency. Use of plant species that are tolerant to elevated soil concentrations of zinc, cadmium and leadshould be considered. These tolerant grasses and trees should be capable of immobilizing soil metals and onlytake up small amounts of metals into plant tops or leaves. Control measures for species such as black birchshould be considered. This will minimize migration of metals into foodwebs associated on site.

15. The restored vegetated areas had considerable wildlife activity. Deer, turkeys, birds, grasshoppers,hornworms and spiders were observed during sample collection. Girdling was observed on a few of seedlings,especially in plot 9IB. Many rodent holes were also observed in this plot. The amount of girdling should berelated to the shortage of food for small mammals during the winter. Less food will more than likely result inmore girdling. Grazing of the woody foliage was observed in a number of locations. This terminal (tops)damage resulted in suckering and a bushy tree appearance (Figure 15) . The above observations could verywell result in premature death of the trees. In addition, massive numbers of grasshoppers were observed feeding on foliage. Massive numbers of ants were observed feeding on aphids on the under leaves of poplarseedlings (Figure 16). Any uptake of metals by these plants that are being grazed will transfer metals into thegrazers and further up the foodchains associated with the site. This is an undesirable situation and should becontrolled.

6US ROOT 0057

16. In conclusion, the remedy of ECOLOAM application is showing limited success, and will not result inthe establishment and survival of 435 trees/acre over the mountain. ECOLOAM application and the plantspecies being used will not control the migration of excessive metals into plants and subsequently into grazinganimals. Something else is required.

17. If I can be of further assistance, please contact me at (601) 634-3585.

Charles R. Lee, PhD, CPSS Soil Scientist

CF: Jim Moore, Baltimore District Tony Palazzo, USACRREL

7US ROOT 6658

Figure 1. Ball of roots under Intermediate Wheatgrass extendingthroughout the 0-6" soil depth at plot 91A.

US ROOT 8059

- v ;••-.,;^:---*• v •• • -•'.<*

US ROOT 8868

US ROOT 0061

US ROOT 0062

«S £> W«T!

Figure 5. Zinc Toxicity Symptoms in Sassafras young seedling at BM-03-200

120063

Figure 6. Zinc Toxicity Symptoms inSassafras Sprout Supers atBM-03-200-

13US ROOT 0064

Figure 7. Severe Zinc Toxicity Symptoms in Sassafras Sprout Suckersat BM-03-200-10.

14US ROOT 0865

^r^v^v *^ \ ^S'*'«?&+.'. m&\

. r . -: f> - --*<e~i *- Z*3,r^V- vit fir >7?>i ••«

15 US ROOT 0066

••;•. ••••'I/T-J*

' - - •"'•••••'• ' ' : '

- ':^&L'-r.^\

(a) BM08-400-50

(b) 1050 Phase 2 West 12

Figure 9. Close up view of Zinc Toxicity Symptoms in Young SassafrasTree leaves collected from (a) BM08 400-50, containing 508 ppmzinc, 1.7 ppm cadmium and 35.4 ppm lead and (b) 1050 Phase 2West 12 containing 466 ppm zinc, 10.2 ppm cadmium, and 12.6 ppmlead.

16

US ROOT 8067

• - - „ - • - . , • •• - . - -t v--.--v- -— •-'Ki &**&.<>' ir? •- ••'.-v-. • f * \~-tT-• •^')f ^^ ."* . *r * v*5" *r i'ij^ * m i -^ «• * A >

Figure 10. Zinc Toxicity Symptoms in an Young Sassafras Treeat BM-14-200-100.

17

US ROOT 8068

Figure 11. Zinc Toxicity Symptoms in a Birch seedling at BM05-300-100.

18

US ROOT 0869

(a) BM05-200-100

-• • •*».'.:-

(b) BM05-200-75i. s ™ tn\ BM05-200-100, containingFigure 12. Birch leaf.symptoms observed on (a) BM055 20^ ^

y 2186 ppm zinc, 39.0 ppm cadra ,a"° zinc 43.8 ppm cadmium,(b) BM05-200-75, containing 2696 ppm zinc,and 30.0 ppm lead.

19US ROOT 9070

76.9 •/. BEUM415 TREES/tCRE

1 1 2 91 1 1 1 1 1 1 2 2 2 3 4 6 3 5 7 6

1 2 3 4 5 6 7 8 9 0 1 2 3 4 . 5 8 2 5 7 1 8 7 9 6 1 6WOOOY

(a) HRDC data

WES/CRREL

i i i i i i i i I i I I I I i I _ 1 I J1 1 3

1 1 1 1 2 2 2 2 3 5 5 0 1 31 2 3 4 5 6 7 8 9 4 6 8 9 1 2 6 9 9 6 8 1 2 4

WOODY

(b) WES/CRREL data

Figure 13. Cumulative Percent of Woody Stems in (a) HRDC Data and(b) WES/CRREL data.

20

US ROOT 8071

HROC

0 1 2 3 4 5 6 7 8 9 0

1 1 2 91 1 1 1 1 1 2 2 2 3 4 6 3 5 7 61 2 3 4 5 8 2 5 7 1 8 7 9 6 1 6

WOOOY

(a) HRDC data

ucc

50

40

30

20 -

10 -

WES/CRREl

1 1 31 1 1 1 2 2 2 2 3 5 5 0 1 3

0 1 2 3 4 5 6 7 8 9 4 6 8 9 1 2 6 9 9 6 8 1 2 4WOOOY

(b) WES/CRREL data

Figure 14. Frequency Percentages of Woody Stems in (a) HRDC Data and(b) WES/CRREL data.

21

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Figure 15. Terminal Grazing (arrows) of Sassafras Stomp Sproutsat plot 91B-100.

22

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Figure 16. Massive ants feeding on aphids on the under leaf of a poplarseedling at BM-02-200.

23ROOT 0874

Table 1. Plant Root Yield (gin, dry weight) at Various Soil Depths

Sampling LocationSoil Depth, inches Ml M2 M3 Ul U2 Total Average

ECOLOAM (DO) 12.76 12.89 5.89 1.42 6.52 39.48 7.90 a

0-1 (Dl) 2.25 0.81 0.77 1.25 0.81 5.89 1.18 b

1-2 (D2) 0.28 0.61 0.18 0.50 0.35 1.84 0.84b

2-6 (D3) 0.12 0.42 0.17 0.84 0.33 1.88 0.38 b

6-12 (D4) 0.23 0.26 0.08 0.11 0.21 0.89 0.18 b

M- middle elevation, plots 91A and 9IBU- upper elevation, BM-05.

US

Table 2. Extractable Metal Concentrations at Each Incremental SoilDepth Across Phases*.

Soil Depth Water DTPA Nitric Acid

Zinc

Ecoloam

0 - 1 "1 - 2 "2 - 6 "6 - 12"

Ecoloam

1.58 b ** 256.6 b 700 b

52.82 a 1297.7 a 6749 a49.87 a 1413.1 a 5657 a21.29 b 1012.2 a 2369 b13.76 b 356.4 b 613 b

Cadmium (ppm)

0.044 b 5.60 b 8.9 b

0126

- 1"- 2"- 6"- 12"

Ecoloam

0126

- 1"- 2"- 6"- 12"

1100

0

0000

.112

.029

.399

.245

.000

.280

.218

.007

.000

aabb

b

aabb

6056479

Lead

28

49424116

.22

.78

.67

.21

aaab

161.8143.961.510.8

aabb

(ppnO

.99

.86

.67

.36

.74

a

aaaa

92.0

1832129229634

b

.8

.5

.0

.9

aabb

* Data averaged over Phases 01, 04, and 05.

»* values followed by different letters within each column andwithin each metal are statistically different at P=0.05.

EPA freshwater quality criteria:

Zinc 0.120Cadmium 0.0039Lead 0.082

Chronic

0.110 ppm0.0011 ppm0.0032 ppm

25

US ROOT 0076

Table 3. Extractable Metal Concentrations at the Lower, Middle,and Upper Elevations of the Mountain.

Soil Depth

Lower

Middle

Upper

Lower

Middle

Upper

Lower

Middle

Upper

Water

49

26

24

0

0

0

0

0

0

.86 a

.99 b

.13 b

.846 a

.647 a

.512 a

.190 a

.109 a

.070 a

DTPA

Zinc (pp»1

1325.0 a

987.3 ab

677.8 b

Cadmium (ppm)

35.03 b

61.27 a

27.89 b

Lead (ppnO

49.03 a

29.00 a

34.90 a

Nitric Acid

4711 a

3924 a

2629 a

104.6 a

108.2 a

61.6 a

840.8 a

955.7 a

693.4 a

Values followed by different letters within each column andwithin metal are statistically different at P= 0.05.


Zinc 0.120Cadmium 0.0039Lead 0.082

Chronic

0.110 ppm0.0011 ppm0.0032 ppm

26

US ROOT 0877

Table 4 . Effects of Ecoloam Applications on Zinc Forma atDifferent Soil Depths within Phases.

Phase WaterZINC

Nitric Acid

010405

1.583

Ecoloam (DO)

256.6 700

010405

4.98 b72.75 a59.50 a

0-1" (Dl)

1481.7 a1383.5 a676.6 a

6993 a7155 a4849 a

010405

7.96 a68.69 a50.72 a

1 - 2 - (D2)

1144.1 a1485.0 a1597.6 a

4859 a6299 a4634 a

010405

10.29 b23.41 ab31.86 a

2-6" (D3)

599.6 a1087.4 a1424.1 a

2516 a2145 a2943 a

6 - 12" (D4)

010405

7.25 b14.43 ab22.16 a

152.9 a411.3 a494.6 a

444 .5 a598.7 a942.1 a

* Values followed by different letters within each column andwithin metal are statistically different at P= 0.05.

-i- Statistically different at P- 0.06


Zinc

Acute

0.120

Chronic

0.110 ppra

27

US ROOT 0078

Table 5. Effects of Ecoloam Applications on Cadmium Forms atDifferent Soil Depths within Phases.

Phase

010405

Water

0.0443

CADMIUMDTPA Nitric Acid

Ecoloam (DO)

5.60 8.91

010405

0.128 b '1.546 a1.161 ab

0 - 1 " (Dl)

113.3 a41.5 b40 .5 b

193.0 a160.4 a114.7 a

010405

0.231 a1.392 a1.025 a

1 - 2 " (D2)

94 .8 a4 4 . 5 a38.4 a

145.6 a151.9 a111.9 a

010405

0.333 a0.375 a0.602 a

2 - 6 " (D3)

53.6 a41.5 a60.4 a

74,50,

aa

79.1 a

6 - 12" (D4)

0104 •05

0.195 a0.245 a0.327 a

8.42 a7.75 a15.90 a

9.64 b8.99 b

19.04 a

* Values followed by different letters within each column andwithin metal are statistically different at P» 0.05.

EPA freshwater quality criteria: Acute

Cadmium 0.0039

Chronic

0.0011 ppm

28

US ROOT 0079

Table 6. Effects of Ecoloam Applications on Lead Forma atDifferent Soil Depths within Phases.

LEADPhase Water DTPA Nitric Acid

Ecoloam (DO)

01 0.000 28.99 1000405

0 - 1 " (Dl)

01 0.000 a ' 43.76 a 1524 a04 0.394 a 40.40 a 2144 a05 0.325 a 94.68 a 1208 a

1 - 2 " (D2)

01 0.041 a 53.98 a 1063 a04 0.293 a 27.59 a 1485 a05 0.239 a 79.09 a 971 a

2 - 6 " (D3)

01 0.000 a 29.70 b 386 a04 0.012 a 31.08 b 208 a05 0.000 a 98.49 a 468 a

6 - 12" (D4)

010405

0.000 a0.000 a0.000 a

16.68 b14.58 b29.76 a

30.5 a30.5 a57 .2 a

* Values followed by different letters within each column andwithin metal are statistically different at P- 0.05.

EPA freshwater quality criteria: Acute Chronic

Lead 0.082 0.0032 ppra

29 US ROOT 0080

Table 7. Metal Concentrations in Tree Leaves

OBS SITE

123456789

101112

9 IBBM02BMOSBM05BMOSBM09BM09BM09NBM13

BM09BM09BM09

TRANSECT

50400200"200300100100105435

100110200

LOCATION

6615751001008585750

5030100

SPECIES CD PB ZN

BIRBIRBIRBIRBIRBIRBIRBIRBIR

OAKOAKOAK

9.900045.294143.333338.529432.451050.686332.60003.10004.9020

0.00000.00000.0000

32.000015.784327.549024.019628.039219.509810.200015.800029.9020

0.00007.50002.8000

1311.101547.652687.352177.551599.121351.571058.60851.601312.35

145.60181.6088.90

13141516171819202122232425

9 IBBM03BM03BM03BMOSBMOSBM09BM11BM14BM14BM14P02WESTP02WEST

1001020020040040020030020020030010501050

663010110SO54100431001057500

SASSASSASSASSASSASSASSASSASSASSASSASSAS

2.20002.90002.15691.56861.17651.47060.00003.13730.49020.00001.37250.00009.7059

12.90009.500018.23539.509832.941235.78437.600011.17655.88244.80393.627520.098010.1961

272.10343.10464.80395.20506.47619.22197.60437.35293.73292.75206.47147.16456.96

30

US ROOT 0881

Table 8. Metals Concentrations in Intermediate wheatgrass

OBS

1234567a910111213141516

PHASE

P01P01POl'P01POlPOlPOlPOlPOlPOlPOlPOlPOlPOlPOlPOl

SITE

91A91A91A91A91A91A9 IB9 IB9 IBBM05BM05BM05BM05BM05BM05BM06

TRANSECT

100100100245245245300300300240250260360370375100

LEVEL

MMMMMMMMMUUUUUUU

SUBLEVEL

1112223331112223

CD PB ZN

3.235294.019612.100004.500002.448981.078434 .300002.600003 .900002.500001.826922.058826.470595 .700002.254903.50000

0.000002.941180.000000.000003.571430.000000.000000.000004.800000.000000.000000.000003 .137250.000000.000004.30000

119.804110.980137.200111.200127.75564.510175.200102.200159.20082.60072.11581.569225.686260.200122.74556.700

Plants"Critical"Content**

rontaminant Normal* ppm leaves

jpT Ht Growth

Zinc

Cadmium

Lead

15-150

0.1-1

2-5

200

8

Reductionppm leaves

290

15

25% Yield

3Dm leaves Phytotoxic*

500 -1500

Varies 5-700

* From Chaney (1983). Normal —tissue content (ppra) normally observed in

plants.

31

US ROOT 8082

Table 10. QA/QC Data for Tree Leaf and Grass Tissue Analyses

Sample

Tree Leaves

NBM13-435 OAK

BM09-100-50 OAK

BM09-110-30 OAK

91B 100-34 OAK

BM09-200-100 SAS

BM14-300-75 SAS

BM14-200-100 SAS

91B 0-70 SAS

BM03-200-110 SAS

91B 100-66 SAS

91B 125-66 SAS

Cadmium

duplicate

duplicate

duplicate

duplicate

% Recovery

lab duplduplicate

duplicate

% Recoverylab duplduplicate

duplicate

% Recovery

lab duplicate

% Recovery

lab dupl

% Recoverylab duplduplicate

< 0.51< 0.51

< 0.5< 0.5

< 0.50< 0.50

< 0.48< 0.48

< 0.5092.0

< 0.50< 0.50

1.864.90

0.9888.00.981.08

< 0.5< 0.5

2.0696.0

2.75

2.794.0

2.6

1.8094.01.401.40

Lead

8.611.9

< 2.58.0

10.011.8

10.5810.10

10.169.4

8.0< 2.5

6.08< 2.50

8.3385.69.31

11.27

16.713.4

11.9686.2

13.14

15.493.6

14.5

11.598.211.910.5

Zinc

272.4271.4

147146

183211

149.04163.46

19982.0

216191

207.84251.96

295.1076.0298.04298.04

125126

403.9284.0

397.06

28194.0

280

261104.0251253

32

US ROOT 8883

Table 10. QA/QC Data for Tree Leaf and Grass Tissue Analyses (continued)

Sample

BM09 100-85

BM09 105-75

SIR 11% Recoverylab duplduplicate

BIR 12duplicate

CITRUS LEAVES 11121314

Cadmium

33.192.033.229.8

3.603.50

0 *0 *0 *0 *

Lead

12.784.814.411.8

18.3016.8

7.905.107.003.20

Zinc

1060.094.0

1070.0744.0

853.01010.0

13.4022.8022.60.90

Certified Reference (SRM 1571) 0.03

* Cadmium detection limit was 0.01.

13.3 29

Grass Tissue

P0191B300M3-A

P0191A100M1-B

CITRUS- LEAVES *112

Certified Reference(SRM 1571) 0.03

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33

US ROOT 8884

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34 ROOT 0885

TABLE 12. FREQUENCY TABLE FOR I OF WOODY STEMS, HRDC DATA SET.

WOODY

012345678910111213141518222527314867139156271966

Freouencv

55262012104425113211111112111111

CumulativePercent Freouencv

34.416.312.57.56.22.52.51.33.10.60.61.91.30.60.60.60.60.60.60.61.30.60.60.60.60.60.6

5581101113123127131133138139140143145146147148149150151152154155156157158159160

Percent

34.450.663.170.676.979.481.983.186.286.987.589.490.691.291.992.593.193.794.495.096.296.997.598.198.799.4100.0

35US ROOT 0886

TABLE 13. FREQUENCY TABLE FOR f OF WOODY STEMS,WES/CRREL DATA SET.

WOODY

01234567891416181921222629395658101112334

Freauencv

682720774333211131111111111

CumulativePercent Freauencv

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6895115122129133136139142144145146147150151152153154155156157158159160

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100.0

36

US ROOT 0887

Appendix A

Literature Cited

Literature Cited

(1) Lee, C. R. 1965. Soil Factors influencing the growth of cotton following peach orchards. MS Thesis,Clemson University, Clemson, SC.

(2) Lee, C. R., and N. R. Page. 1967. Soil Factors influencing the growth of cotton following peachorchards. Agron. J. 59: 237-240.

(3) Lee, C. R. 1968. Factors affecting plant growth in high zinc medium. PhD Dissertation, ClemsonUniversity, Clemson, SC.

(4) Lee, C. R., G. R. Craddock, and H. E. Haramar. 1969. Factors affecting plant growth in high zincmedium. I. Influence of iron on the growth of flax at various zinc levels. Agron. J. 61:562-565.

(5) Lee, C. R., and G. R. Craddock. 1969. Factors affecting plant growth in high zinc medium. II.Influence of soil treatments on growth of soybeans on strongly acid soils containing zinc from peachsprays. Agron. J. 61:565-567,

(6) Brown, J.C., and L.O. Tiffin. 1962. Zinc Deficiency and iron chlorosis dependent on the plant speciesand nutrient- element balance in Tulare clay. Agron. J. 54:356-358.

(7) Gall, O. E., and R. M. Barnette. 1940. Toxic limits of replaceable zinc to corn and cowpeas grown onthree Florida soils. J. Amer. Soc. Agron. 32:23-32.

(8) Chaney, R. L. 1983. Potential Effects of Waste Constituents on Food Chain in Land Treatment ofHazardous Wastes. Noyes Data Corp. N. J. pp. 152-240.

(9) Guest, P. L., and H. D. Chapman. 1944. Some effects of Ph on the growth of citrus in sand andsolution cultures. Soil Sci. 58:455-465.

(10) Hewitt, E. J. 1948. Relation of Manganese and some other metals to the iron status of plants. Nature161:489-490.

(11) Hewitt, E. J. 1953. Metal interrelationships in plant nutrition. 1. Effects of some metal toxicities onsugar beets, tomato, oats, potato and marrowstem kale in sand culture. J. Experimental Bot. 4:59-64.

(12) Hunter, J. G. and 0. Vergnano. 1953. Trace-element toxicities in oat plants. Ann. Appl. Biol.40:761-777.

(13) Millikan, C. R. 1947. Zinc toxicity in flax grown in a wire netting "Bird Cage". J. Aust. Inst. Agr. Sci.13:64-67.

(14) Millikan, C. R. 1949. Effects on flax of a toxic concentration of boron, iron, molybdenum, aluminum,copper, zinc, manganese, cobalt or nickel in the nutrient solution. Proc. Royal Soc. Vict. (Melbourne)61:25-42.

(15) Smith, P. F. and A. W. Specht. 1953 Heavy metal nutrition and iron chlorosis of citrus seedlings.Plant Physiol. 28:3,71-382.

(16) Staker, E. V. and R. W. Cummings. 1941. The influence of zinc on the productivity of certain NewYork peat soils. Soil Sci. Soc. Amer. Proc. 6:207-214.

38US ROOT 0097

(17) Wallace, T. and E. J. Hewitt. 1946. Studies in iron deficiency of crops. I. Problems of iron deficiencyand the interrelationships of mineral elements in iron nutrition. J. Pomol. Hort. Sci. 22:153-161.

(18) Oyler, J. A. 1988. Remediation of metals - Contaminated site near a zinc smelter using sludge/fly ashamendments: herbaceous species. In Proceedings of Trace Substances in the Environment, Columbia,MO.

(19) Folsom, B. L., Jr., and C. R. Lee. 1981. Zinc and Cadmium Uptake by the Freshwater Marsh Plant(Cyperus esculentus) Grown in Contaminated Sediments Under Reduced (Flooded) and Oxidized(Upland) Disposal Condition. In International Symposium on Trace Element Stress in Plants. J. ofPlant Nutrition 3:233-244.

(20) Lee, C. R. , Tatem, H. E., Brandon, D. L., Kay, S. H., Peddicord, R. K., Palermo, M. R., andFrancingues, N. R., Jr. 1991. "General Decisionmaking Framework for Management of DredgedMaterial," Miscellaneous Paper D-91-1, US Army Engineer Waterways Experiment Station,Vicksburg, MS.

(21) Centre Analytical Laboratories, Inc. 1993 Analysis Report for Vegetation from Blue MountainRestoration Project. 19p.

(22) Chancy, R. L. 1990. "Comparison of Plant Uptake of Metals by Cyperus esculentus and AgronomicPlants Grown on Sewage Sludge Amended Soils," Contract Report DACW39-89-0030.

(23) Kay, S. H., Scholten, M. C. Th., and Bowmer, C. T. 1988. "Mobility of Soil Contaminants in anEcosystem of Trees Growing on Dredged Material - The Broekpolder (Rotterdam, The Netherlands,"Technical Report R88/488, Technology for Society Division (MT) of Netherlands Organization forApplied Scientific Research (TNO), Delft, NL.

(24) Davies, B. E., and Houghton, N. J. 1983. "Heavy Metal Uptake by Agronomic Crops Grown onContaminated Soils and Cvperus esculentus grown on Oxidized and Reduced Contaminated Soils,"Contract Report DAJA37-82C-0195, US Army Research, Development and Acquisition Group, UK.

(25) Storm, G. L., G. J. Fosmire, and E. D. Bellis 1994. Persistence of Metals in Soil and SelectedVertebrates in the Vicinity of the Palmerton Zinc Smelters. J. Environmental Quality 23:508-514.

(26) Thorne, D. W. and A. Wallace. 1944. Some Factors Affecting Chlorosis on high-lime soils: 1. Ferrousand Ferric Iron. Soil Sci. 57:299-312.

39US ROOT 0098

Attachment 4

MEMORANDUM FOR RECORD 13 March 2001

SUBJECT: Evaluation of Vegetation Survey Data

1. Reference visit to ZCA Superfund Remediation Site at Palmerton, PA on 8 and 9 Sep 99 by Mr.Tony Palazzo, USACE-ERDC-CRREL and Dr. Dick Lee, USACE-ERDC-WES.

2. Reference Memorandum dated 7 August 2000, Subject "Blue Mountain Woody Tally Field Data1995-1999" from L. J. Piazza to Dick Lee and Tony Palazzo.

3. Reference MFRs, dated 8 Feb 1999, Subject "Cost Estimate for Restoration of Lands Impacted byZinc Company of America.", MFR dated 2 March 1999, Subject "Additional Information onRestoration Efforts on Metal Contaminated Soil at Zinc Company of America Superfund Site,Palmerton, PA", and MFR dated 5 May 1999, Subject "Tree Observations on 5-6 May 1999 atPalmerton, PA ZCA Superfund Site.

4. Vegetation cover measurements were conducted on 8-9 Sep 1999 on 91-A and BM-03 plots tocompare data collected in 1995 and 1996 to 1999 measurements at the same transect sites. Theprocedure was to locate the 1995 and 1996 stakes where previous measurements were taken and tore-measure the vegetation cover using the same technique used previously, that is, a tripod with anapproximately six foot pipe with ten holes spaced evenly along the pipe where a laser pen was placedin the hole pointing to the ground. The laser marked whether live plant material, plant litter, rock,gravel or bare ground was touched by the laser beam. The observation was recorded on a formprepared by Mr. Bob Thompson, ZCA.

5. Data collected for plot 91-A was tabulated in Tables 1-2 and plotted in Figures la and 1b. Thirteen outof 20 measurements in 1999 showed less live vegetation and more plant litter than tor both 1995 and1996. Data for plot 91-A and all plots together for 1995-1999 received in Reference 2 was averagedand plotted to show live vegetation and litter observations over the years sampled in Figures 2 and 3.All plots (Figure 3) show the same trend as plot 91-A (Figure 2) and the 91-A observation by ERDC(Figure 1). These figures show quite obviously that the original planted grasses are dying andbecoming plant litter. The live vegetation that is being observed is being converted to annual weedspecies (Figure 4). It is not clear where and what future vegetation will evolve into. Budleia appearsto becoming widespread on the mountain (Figure 5). The ability of this plant species to take up metalshas not been determined or evaluated. Annual weeds that are establishing in widespread areas will diedown in the winter time and could reduce the plant litter available for controlling soil erosion in thewinter and spring. There could be a potential for increased surface runoff of paniculate metals fromthe mountain slopes and a step back to prior conditions that required remediation in the first place. Inother words, the successful revegetation of the mountain appears to be only temporary long-termapproach if the sown perennial vegetation continues to die-out. Ultimately, an effort will be requiredto repeat the remedial actions performed previously.

6. The success of the total woody counts and establishment of woody species on the mountain has beendescribed in previous evaluations by Lee and Palazzo. Observations taken for plots 91-A, BM01 andBM03 on the September 1999 were tabulated in Table 3 and plotted in Figure 6. Most current woodycount data received in August 2000 was evaluated and presented in Table 4 and Figure 7. While theoverall average woody count for any year might indicate successful establishment of 435 woodyspecies/acre or more, this value does not provide information on the spatial distribution of the treesover the area Consequently, the number and percent of successful individual plots gives a differentpicture of success and failure to meet the target goal of 435 woody species/acre. The number andpercent of the measured plots that failed to attain 435 woody species/acre were most in 1995 at 77%and decreased through the years to 53% in 1999. However, even in 1999, more than 50% of the plotsmeasured did not have 435 woody species established and alive. This implies that more than 50% of

the mountain were lacking in woody species in 1999 or four years after treatment In addition, there isdisagreement on counting greenbriars as woody species and if not included in the counts, the targetgoal of 435woody species/acre would not be achieved on many more areas. This coupled with grassvegetation dying out will result in a reversion to a condition of metal migration from the mountain aspreviously documented and a renewed need for repeated remediation.

7. Tree establishment was evaluated over three years and documented in previous MFRs. Even with themost recent tree seedling planting techniques that included control of excess grass growth aroundplanted tree seedlings, dipping bare root seedlings with metal tolerant micro-rhizal inoculum, sprayinginsecticide for insect control, spraying deer repellant to control animal grazing of seedling growth andiron sprays at the base of the seedling and over seedling leaves to counteract zinc toxicity in theseedling, and use of tree protector covers to reduce animal grazing, 65%, 65% and 49% survival wasobserved for Shuwater Oak, Red Maple and Red Oak, respectively. These techniques addsubstantially to the cost of establishing desired trees on site as indicated in a previous MFR, dated 8Feb 1999.

8. Cost of establishing meadow land compared to forest land appears to be $1,125/acre versus$6,125/acre. Meadowland establishment cost includes ecoloam application and seeding and control ofundesirable volunteer trees. Forest land establishment cost includes ecoloam application, seeding,transplanting trees with additional controls for animal grazing, insects, iron deficiency, and weedcontrol.

9. Based on these results, it is recommended:

A) it would appear that vegetating the mountain with self-sustaining meadowland vegetation thathas minimum metal uptake would be the most appropriate recommendation at this time. Amixture of metal tolerant grasses and legumes would have a longer term stability than thepresent vegetation that appears to be starting to die-out. Tall fescue should not be plantedsince this species tends to take up metals readily. A recommended seed mixture is:

Canada bluegrass (20%) (Species previously used) Chewings fescue (15%) Hard fescue (15%) Intermediate wheatgrass (30%) (Species previously used ) Birdsfoot trefoil (10%) (Species used sometimes) Perennial ryegrass (10%)

B) Budleia leaves should be sampled and analyzed for metals, zinc, cadmium and lead todetermine if metals are being taken up into the leaves. Tissue contents above 250 ppm Zn, 10ppm Cd, and/or 50 ppm Pb should be of concern for transfer into food chains on site.

C) Continue to observe dying vegetation (plant litter) and invading weed species Additionalmeasurements of vegetative cover should be made at least once annually and continued for atleast three years. Clarification in observations should be made. Plant litter should be recordedas dead leaves or dead wood. Vegetative cover should be recorded as planted grasses andlegumes or annual weed species or Budleia.

D) Control of undesirable trees such as Poplar and Black Birch should be implemented annuallyto reduce uptake of soil metals into tree leaves and the accumulation of metals on the surfaceof the soil. Control could be physical cutting of undesirable seedlings and/or by selectedherbicide such as Round-Up or an equivalent herbicide.

E) Manage site to reduce migration of metals into plants and surface runoff. This can beaccomplished by implementing recommendations A-D. Maintaining a live vegetative cover ofthe species listed will reduce soil erosion of metals into surface runoff. Soil pH should bemaintained at 6.5-7.0 to reduce soluble forms of metals in the soil.

F) Annual Vegetation Data Collection should continue to record vegetative cover using the sameprocedure as previously as amended above in C. However, data should be collected twiceeach year, preferably late spring and then in early fall at the same sample point on thetransect. This should indicate changes in plant species over the growing season and invasionof annual weeds. Annual soil, ecoloam and plant tissues should be collected. Soil and ecoloamsamples should be analyzed for pH and N-P-K nutrients. Plant tissues should be sampledannually and analyzed for metals, zinc, cadmium and lead. Tissue contents should be belowthose values presented in B above. A predetermined sample size such as a 8" x 8" squarearea should be randomly collected adjacent to the point where vegetative observation weremade in each control plot. Success rate should be measured as 70% live vegetation after oneyear and 80% live vegetation each year thereafter.

G) One final observation and evaluation of tree seedling growth for the previous demonstrationplots should be made to complete the data collection. These data can be used to document thefinal results of tree seedling planting and management to control animal grazing, insectdamage and soil metal toxicity.


Table 1. Counts of Live Vegetation on Plot 91-A at ZCA Palmerton, PA.

Table 2. Counts of Plant Litter on Plot 91-A at ZCA Palmerton, PA.

Table 3. Tree Observations on Plot 91-A, September 1999.

Table 4. Percentage of Plots at ZCA Palmerton, PA That Failed to Have 340 Woodies/Acre Over theObservation Years of 1995-1999.

Figure la. `Live Vegetation Observations on Plot 91-A at ZCA Palmerton, PA. (ERDC Data fromTable 1).

Figure 1b. Plant Litter Observations on Plot 91-A at ZCA Palmerton, PA. (ERDC Data from Table 2)

Figure 2. Comparison of Live Vegetation versus Plant Litter (Dead Vegetation) on Plot 91-A at ZCAPalmerton, PA.

Figure 3. Comparison of Live Vegetation versus Plant Litter (Dead Vegetation) on all Plots 91-Athrough BM-36.

Figure 4. Annual Weeds Growing on Plots of Plant Litter and No Live Originally Seeded Vegetation.

Figure 5. Massive Growth and Distribution of Bndleia on ZCA Blue Mountain Slopes.

Figure 6. September 1999 Tree Observations at ZCA Palmerton, PA

Figure 7. Percent of Plots Showing Tree Failure, less than 340 woodies/acre.

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CEWES-ES 8 Feb 1999

MEMORANDUM FOR RECORD

SUBJECT: Cost Estimate for Restoration of Lands Impacted by Zinc Company of America.

1. Restoration of impacted land for establishment of a meadow ecosystem will essentially be the procedureused by Zinc Company of America to restore Blue Mountain, that is, terrace road construction and theblending and application of "Ecoloam" with a grass/legume seed mixture. The cost of this restoration processwill depend on the cost or tipping fee collected for sewage sludge, lime and fly ash. These costs can beobtained from the previous operations at ZCA.

2. The cost of restoring the impacted land to forest will be the same as the application of "Ecoloam", with asavings of one half the grass/ egume seed cost plus the added cost of establishing trees. The cost forestablishing trees according to the recommendations suggested in previous communications has beenestimated to be $4,636.00/acre by Dr. Ed Cordelle of PHC Reclamation, Inc. This estimate includes weedcontrol prior to transplanting seedlings, the planting of 545 seedlings/acre (assuming an 80% survival rate) on350 acres/year, using two year old seedlings (1.5-2.0 foot height and 0.50-0.75 inch root collar diameter),mycorrhiza innoculated, iron chelate sprayed in the dibble bar planting hole, insecticide and animal repellantspraying three times during the growing season and the installation of tree shelters.

3. An additional $35,000 will be required this FY for monitoring of seedling growth, applying insecticide andrepellent and auditing tree count data.

4. Additional information can be obtained by contacting me at (601) 634-3585.


MEMORANDUM FOR RECORD 2 March 1999

SUBJECT: Additional Information on Restoration Efforts on Metal Contaminated Soil at Zinc Company ofAmerica Superfund Site, Palmerton, PA.

1. Under the meadow land management strategy, there will be a need to control the colonization ofundesired tree species such as poplar and birch trees. Control of these volunteer trees will more than likelyinclude the cost for manually spraying a herbicide once a year on these tree seedling when observed on site.This cost will be labor @ $15.00/hr and equipment/chemical @ $10.00/acre for a total cost of $ 25.00/acre.This cost would be added to the $1,100/acre estimate to apply Ecoloam and seed with a grass/legume mixtureto total $1,1257/acre for the meadow strategy. Establishing desirable trees was estimated at $ 5,000/acrefollowing vegetative established on applied Ecoloam. This cost would be added to the $1,125/acre forEcoloam application and a reduced seed mixture and control of undesirable volunteer trees to total$6,125/acre.

2. All sewage sludges used to restore metal contaminated soils should have a high iron concentration ratherthan alum sludges. The extra iron will counteract metal toxicity in plants colonizing the restored areas.Adequate lime should be included in the Ecoloam to maintain soil pH at 6.0 or greater for the long term (atleast ten years or more).

3. Restoration of the cinder bank should use high iron sludge rather than alum sludge. Adequate lime shouldbe included in the Ecoloam to maintain soil pH at 6.0 or above for the long term (at least ten years or more).

4. Use of a manufactured soil from dredged material placed on the cinder bank, cellulose and biosolidsshould be demonstrated, if at all possible. The manufactured soil will enhance plant growth for the long-termand will establish a self-sustaining low maintenance vegetative cover. Locally available cellulose should beused. Sludge with a high content of iron should be used. Adequate lime should be included to maintain a soilpH of 6.0 or more for the long term.

5. Innovative technologies are available that more than likely could manufacture building blocks from thecinder waste material on site in combination with other waste materials. This would provide a useable productfor additional storage buildings on site for the responsible party. Cinder blocks would be unique to the site anduseful in providing additional facilities. Recommend preliminary evaluation of cinder block manufacturingtechnology. These blocks could have been used to construct the security wall that was built of wood recently.

6. Further discussion of these recommendations could be obtained through a conference call to either DickLee (601) 634-3585 or Tony Palazzo (603) 646-4374 or both at your convenience during your meeting on 3March 1999. Both will be in their respective office all day.

Charles R. Lee, PhD, CPSS

MEMORANDUM FOR RECORD 5 June 1999

SUBJECT: Tree Observations on 5- 6 May 1999 at Palmerton, PA ZCA Superfund Site

1. Reference visit of Mr. Tony Palazzo, ERDC/CRREL and Dr. Dick Lee, ERDC/WES on 5-6 May 1999 toZinc Company of America Superfund site at Palmerton, PA.

2. The observation data included the number of alive or dead seedlings, presence of suckers, lateral stemgrowth, leaf size and color and insect damage. These data were collected at 91-A, BM-03 and BM-16 plots,tabulated and evaluated for differences among the three planted species, Red Oak, Shuwater Oak and RedMaple.

3. Live seedlings counts were highest for Shuwater Oak and Red Maple, 65% for each. Red Oak liveseedling counts were lower at 49%. More Red Oak seedlings died, 51% of those planted. Whereas the othertwo species showed 35% dead seedlings. The amount of suckers observed on the three species was 34%,26% and 22% for Red Oak, Shuwater Oak and Red Maple, respectively. However, the amount of lateralgrowth was observed at 66%, 74% and 78% for Red Oak, Shuwater Oak and Red Maple, respectively. WhileRed Oak tended to show more suckering, the Shuwater Oak and Red Maple tended to show more lateralgrowth indicating the terminal growth point died, but the main stem for these species was still alive. Red Oak apparently tended to have the entire main stem die, resulting in more suckers to develop at the base of themain stem.

4. It is interesting that the existing trees on the Palmerton site appear to have the terminal growth points deadand either lateral growth or suckers trying to develop. So the same effects appear to be occurring in new treeseedling planting.


Attachment 5

Attachment 6

March 14, 2001

Northeastern Resident Office

SUBJECT: Palmerton Zinc Superfund Site, Blue Mountain Operable Unit No. 1

U.S. Environmental Protection Agency, Region III Attention: Charlie Root 1650 Arch Street Philadelphia, Pennsylvania 19103-2029

Dear Mr. Root:

On October 11, 2000, at your request Messrs. Piazza and Lombardo of my staff conducted a site visitfor the purpose of evaluating the revegetation effort of 12 test plots at Palmerton Zinc Pile Superfund Site(O.U. #1) being conducted by Adrian Brown on behalf of Viacom International Inc. and TCI PacificCommunications, Inc. using aerial application methods.

The test plot application consisted of three separate application steps. First Step, a seed mix wasapplied using a spreader bucket (inverted cone hopper) suspended by helicopter. Second Step, was theapplication of lime using the same method used for the seed. The third and final step involved the applicationof compost which was applied using a tarp and sling method. Quality control was conducted/measured byusing five pans spread out on each test plot location. The test plots were 100 meters square and the five panswere located within the plots with one at each corner and one centrally located within the plot.

The following observations were noted during this test plot demonstration.

Loading Operation: There was a loss of seed, lime, and compost amendments due to wind conditions and helicopter wash duringloading and transportation operations.

Application Phase: Application rates can not be verified for a variety of factors:

A. During the application of the amendments it was observed that the material was being blown outof the hopper by the helicopter wash and blown out of the test plot area by wind conditions as shown on thevideo tape.

B. Verification of the application rates for each individual amendment (seed, lime, compost) noted foreach of the proposed mixes was not conducted. As previously noted a total of 5 pans were placed at each testplot. Individual amendment application rates were not measured. Measurements were taken after applicationof all amendments. Due to problems noted with the seed, lime, and compost loss during the loading and

piazza/bae/7052

transport phase, the individual totals could not be measured using this method.

Evaluation: Determination of success must be identified. First, a measurement of success must be defined similar to BlueMountain O.U. # 1 i.e. 70 % cover at the end of the first growing season. Second, the method for verificationof success must be outlined. The method for evaluating the success must be provided i. e. tip of shoe method,pin and point method, or area verification (200 blades of grass/S.F. with no bare area greater then 5 S.F.).

Safety Issues: 1. No PPE (i.e. dust mask, gloves, tyveks, etc) were worn by workers. 2. Initial field verification personnel on mountain experienced communication problems. ZCA had to provideradios for communication. 3. Field technician did not follow the buddy system. 4. Field technician was sprayed with amendments during initial amendment application. 5. The empty tarp flapping in the wind behind and under the helicopter could present a serious safety problem. 6. No monitoring was conducted during this work as required and outlined in the Health and Safety Plan. 7. Eating in the EZ was observed. This is in violation of the Health and Safety Plan. 8. No Formal decon was set up for workers.

Conclusion: 1. Lack of confidence in the application rates due to failure to monitor each separate amendment. 2. Wind and Helicopter wash effects noted during the loading and application of amendments. 3. Additional monitoring and sampling is recommended. Since all amendments are applied separately, Irecommend that collection pans being placed and collect for each separate amendment applied. This is theonly way to guarantee that the required amount of each amendment was applied. 4. Recommend that the application methods be varied to evaluate the best application method (i.e. Step 1, 2, 3,then Step 3, 2, 1).

I have enclosed a copy of the video tape and digital photographs prepared during the test plotapplication. If you have any questions please contact Mr. Piazza, or myself at (570) 895-7052.

Sincerely,

James P. Moore Resident Engineer

Enclosure

Copies Furnished (w/Encl): CENAB-CO CENAB-COF-HA Piazza Lombardo Harbert

File (w/Encl): Viacom Test Plots L:/Palmerton/Viacom Test Plots

Attachment 7

second palmerton zinc pile superfund site palmerton ... · second five-year review report palmerton...

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