RECORD OF DECISION

REMEDIAL ALTERNATIVE SELECTION

Sitei Craig Farm Site, Perry Township, Pennsylvania

Statement of Basis and Purpose

This decision document represents the selected remedial

action for the Craig Farm Site, in Perry Township,

Pennsylvania, developed in accordance with the Comprehensive

Environmental Response, Compensation and Liability Act of

1980, as amended by the Superfund Amendments and

Reauthorization Act of 1986 (CERCLA), 42 U.S.C. Section 9601

et seq. and to the extent practicable the National

Contingency Plan (NCP), 40 C.F.R. Part 300. This decision is

documented in the contents of the Administrative Record for

this site. The Commonwealth of Pennsylvania concurs with the

selected remedy.

-qssment of the Site

.rsuant to duly delegated authority, I hereby determine

rsuant to Section 106 of CERCLA, 42 U.S.C. Section

.tual or threatened releases of hazardous substances

_s site, if not addressed by implementing the response

selected in this Record of Decision (ROD), may present

riinent and substantial endangerment to the public health,

.ire, or the environment based on the information set

^ch in "Summary of Site Risks", pages 11-16.

Description of the Remedy

The selected remedy seeks to prevent site contaminants

from migrating offsite and/or impacting a small creek that

crosses the southern portion of the site (Unnamed Creek). A

landfill will be constructed for disposition of the source

material from the two disposal pits and the surrounding

contaminated soil. The source material will be stabilized/

solidified prior to its placement in the landfill. Contaminated ground water will also be collected passively using

two interceptor trenches at seepage points downgradient of

the two pits. The collected ground water will be transported

weekly to an offsite wastewater treatment plant until the

remediation is judged to be completed.

Additional components of the selected remedy are as

follows:

- After the two pits are excavated, they will be

refilled with uncontaminated soil, and the area will

be covered with enough soil to support vegetation.

- A ground water verification study will also be done

to determine whether or not the ground water (both

301443
on- and off site), not being addressed by the selected

remedy, needs any further remediation. This study

is expected to confirm that the ground water collection

system is working properly, and is adequate to address

all of the contaminated ground water.

Institutional controls, such as utilizing deed notices to

inform property owners about contaminants at the site,

will also be implemented.

A wetlands delineation will also be done in order to

determine that the proposed location for the landfill

is the appropriate distance from the onsite wetlands.

If the proposed location is found to be too close to

the wetlands, the landfill will be moved to a more

remote area of the site. Potential impacts to the

wetlands will be considered and minimized to the

extent practicable during the design phase of this

project.

A treatability study on the solidification procedure

will be done, and its effectiveness will be evaluated

by the EPA prior to the full-scale remedial action.

Declaration

The selected remedy is protective of human health and

the environment, attains Federal and State requirements that

are applicable or relevant and appropriate to this remedial

action, and is cost-effective as set forth in Section 121 of

CERCLA, 42 U.S.C. Section 9621 and Section 300.68 of the

NCP. This remedy satisfies the statutory preference as set

forth in Section 121(b) of CERCLA, 42 U.S.C. Section 9621(b)

for remedies that employ treatment that reduce toxicity,

mobility, or volume of the hazardous substances, pollutants

or contaminants. This remedy utilizes permanent solutions

and alternative treatment technologies to the maximum extent

practicable. Because this remedy will result in hazardous

substances remaining onsite above health-based levels, a

review will be conducted every five years after commencement

of remedial action in accordance with Section 121 (c) of

CERCLA, 42 U.S.C. Section 9621 (c) to ensure that the remedy

continues to provide adequate protection of human health and

the environment.

Edwin B. Erickson Date

Regional Administrator •'*** •

301444
RECORD OF DECISION

V_^ TABLE OF CONTENTS

PAGE

I SITE NAME, DESCRIPTION AND LOCATION 1

A Site Name and Location ' 1

B Site History 1

C Community Relations 4

D Identification of Operable Units 4

E Site Characteristics 5

II SUMMARY OF SITE RISKS ' 11

III DESCRIPTION OF ALTERNATIVES 17

IV COMPARATIVE ANALYSIS OF ALTERNATIVES 23

DESCRIPTION OF THE SELECTED REMEDY 27

: APPLICABLE OR RELEVANT AND APPROPRIATE

REQUIREMENTS 28

J

/II STATUTORY DETERMINATIONS 35

i VIII RESPONSIVENESS SUMMARY . 37

301445
SUMMARY OF REMEDIAL ALTERNATIVE

SELECTION FOR THE CRAIG FARM SITE

Site Name and Location

The Craig Farm site covers approximately 117 acres, and

is located near the village of Fredericksburg, just inside

the western border of Armstrong County, Pennsylvania. The

borough of Petrolia lies approximately two miles to the west,

and the town of Parker, on the Allegheny River > is about four

miles to the north. The area around the site is dominated by

farmland, and has a population density of approximately 120

persons per square mile.

The site was originally two abandoned strip mine pits

which had worked the Upper Freeport coal seam. As with most

strip mines in the area, the pits were cut into a hillside

beginning where the coal outcropped or subcropped. The pit

walls were formed by the working face (highwall) of the mine

and the spoil piles were deposited away from the working

face.

Site History and Enforcement Activities

The two pits were used for the deposition of distillation

residue from 1958 to 1963 (See Figure 1). The residue was

still bottoms from the production of resorcinol at the Koppers

Chemical plant in Petrolia, PA. Resorcinol, an organic compound,

is used as an adhesive enhancer in commercial products, such

as automobile tires and pharmaceuticals.

At the time when the source material was placed onsite,

the land was owned by Mr. Paul Craig. His brother, Mr. Herman

Craig, hauled the distillation residue from the plant andplaced it in the two pits. Approximately 2,500 tons of

residue contained in 55-gallon drums were deposited at the

site. Near the end of 1971, Koppers purchased 100 of the 117

acre Craig property, which included the pits. In 1985,

Koppers acquired the remaining portion of the Craig property.

Pursuant to Section 105 of CERCLA, 42 U.S.C. Section

9605, the Craig Farm Site was considered for placement on the

National Priorities List (NPL). mien the NPL was revised in

December, 1982, the Craig Farm site was ranked 415 out of 418

sites proposed for the NPL at that time. On February 25,

1983, Koppers presented to the Pennsylvania Department of

Environmental Resources (PADER) a proposal for a hydr ©geological study of the site. Koppers decided to also undertake

a surface water sampling study, a stream biological study, an

air quality survey, and to incorporate them into the hydrogeologic investigation resulting in an Environmental Assessment

(EA) of the site. The EA was submitted to PADER on October

31, 1983.

301446
I Figure l

I

I

I

301447
On January 19, 1984, the County of Armstrong, Department

of Public Protection prepared an Emergency Preparedness Plan

for the site. On April 23-24, 1984, Koppers undertook an

investigation to determine the approximate extent and

condition of the still bottom residue drums at the site.

Representatives of the PADER were onsite to observe the

investigation. A series of fifteen test pits were, excavated.

The results of the test pits indicated that the drums were

butted against the highwall of both strip mine cuts, and then

covered. The majority of the drums were broken or crushed

and were without lids.

EPA contracted GCA Corporation to review the Koppers

EA of the Craig Farm site. EPA, with GCA representatives,

visited the site on June 29, 1984, and issued draft comments

on the EA report in August, 1984. On April 1, 1985, the

~ 3ER and EPA offered joint comments on the EA report.

tring the fall of 1984, Koppers investigated several

;. measures, including excavation and recycling of the

and onsite and offsite incineration. On August 2,

3 PADER requested Koppers to perform a complete

Investigation and Feasibility Study (RI/FS) of

iig Farm site. On November 12, 1985, representatives

jers, PADER, and EPA met to discuss the RI/FS Work Plan

i6 EPA and PADER comments on the EA report. It was

.ed at this meeting that as much of the information from

j EA report as possible would be used in the RI/FS development. Additional work was required to satisfy RI/FS protocols

which evolved following the preparation of the EA report.

In February, 1986, Keystone Environmental Resources, Inc.

and Remediation Technologies, Inc. began work on the Craig

Farm site RI/FS for Koppers. From September, 1986 through

August, 1987, a biological survey was performed by Keystone

utilizing data obtained from four rounds of sampling at the

Craig Farm site. From October, 1986 through June, 1987, a

biota survey was performed by Keystone utilizing data obtained

from two rounds of sampling (Fall, 1986, and Spring, 1987) at

the Craig Farm site. From November, 1986 through August, 1987,

Keystone performed six rounds of sampling to characterize

the surface water and sediments at the site.

From December, 1986 through November, 1987, Keystone

performed four rounds of sampling to characterize the

ground water at the site. On February 10, 1987, Koppers

Company, Inc. signed a Consent Order and Agreement with

PADER to perform a RI/FS of the site.

301448
In May, 1988, the EPA and PADER requested that five

additional wells be installed to further delineate the

ground water contamination. These wells were installed in

November, 1988.

On January 20, 1989, BNS Acquisitions merged into

Koppers, and on January 26, 1989, the name of Koppers was

changed to Beazer Materials and Services, Inc. (Beazer).

In April, 1989, the Draft Remedial Investigation (RI)

was submitted to the State and the EPA. The Revised RI was

submitted in August, 1989. The Draft Feasibility Study (FS)

was submitted in July, 1989, and the Revised FS was

submitted in August, 1989.

A Special Notice Letter, granting Beazer the opportunity

to make a good faith offer pursuant to Section 122(e) of

CERCLA, 42 U.S.C. Section 9622(e), was sent by the EPA to

Beazer on August .24, 1989.

Community Relations

On April 7, 1987, PADER conducted a public meeting to

announce the start of the RI/FS at Craig Farm. The RI/FS and

the Proposed Plan for the Craig Farm Site were released to

the public in August, 1989. These two documents were made

available to the public in the administrative record file and

an information repository maintained at the EPA in Region III

and in the administrative offices of the Karns City Area

High School in Karns City, Pennsylvania.

The notice of availability for these two documents was

published in the Butler Eagle on August 25, 1989. A public

comment period was held from August 25, 1989 through

September 25, 1989. In addition, a public meeting was held

on September 13, 1989. At this meeting, representatives from

EPA and PADER answered questions about problems at the site

and the remedial alternatives under consideration. The only

written comments received during the public comment period

were In a letter from Beazer, a copy of which is attached.

The Responsiveness Summary is based on oral comments received

during the public meeting and on the written comments. The

above actions satisfy the requirements of Section 113(k) and

117 of CERCLA, 42 U.S.C. Section 9613(k) and 9617.

Identification of Operable Units

The Craig Farm Site has been divided into three operable

units:

301449
1. Operable Unit II

Operable Unit II is the distillation residue

material in each pit area and the adjacent contaminated

soils. Contaminated soils are defined as those soils

determined analytically to contain detectable amounts of

resorcinol. The detection limit for resorcinol in soils

*s approximately 50 parts per million.

2. Operable Unit 12

Operable Unit 12 is the remaining portion of each

pit area not defined as Operable Unit fl material, mainly

overburden and adjoining soils that are determined

analytically to be clean.

3. Operable Unit 13

Operable Unit 13 includes Seeps A and B (see Figure

) which are downgradient locations where seeps containing

itaminated ground water are discharging.

Operable Unit 12 is uncontaminated soil that is

•.sidered an operable unit merely because it must be moved

> get to the underlying contaminated soils and source

aterials. Howeverr Operable Unit 12, by definition, contains

nly clean soils and therefore, will not be discussed in the

inalysis of treatment alternatives. The operable unit does

contain any contaminated soils that would require any

remediation.

A ground water verification study will be done to

determine whether or not the ground water (both on and offsite), not being addressed in this ROD, needs any further

remediation. If additional ground water remediation is

required, it will be considered a separate operable unit,

and will be addressed in a subsequent ROD for this site.

Site Characteristics

A. Topography

The area around the site is farmland and forest, with

surface mining operations throughout the area. The site is a

small steep hillside with an average gradient of 1.43 ft/ft.

Strip raining activities have created two separate highwalls

with the bottom of the pits at an elevation of 1400 feet

(mean sea level). The topography of the site area is

characterized by a dendritic drainage pattern with good

surface water drainage throughout the watersheds.

301450
8. Land Use

Current figures show that approximately 28 percent of

Armstrong County is farmland, 52 percent is forest/ and 20

percent other. The area around the site, including the

village of Fredericksburg, is dominated by farmland. Strip

mining is also conducted in the surrounding area.

The site is not used for any commercial or residential

purposes, although it could be used for recreational purposes

after remediation. Due to the steepness of the topography

and remoteness of the site, future commercial or residential

development may be limited.

C. Hydrology

Surface water on the site consists of several seepage

ditches emanating from the former pits, and the Unnamed

Creek. Drainage, via hillside runoff and the seepage

ditches, flows from the site into Unnamed Creek, which in

turn flows southeast and discharges into Valley Run,

approximately one mile from the site. Valley Run flows

northeast for approximately one and a half miles and

discharges into the Allegheny River. The seepage ditches

are actually small erosion channels which have formed via

hillside runoff. The seeps drain into one of these two

channels.

D. Wildlife

Faunal species have been noted at the site during

various field investigations and include: several species of

small mammals (rabbits, squirrels, chipmunks, etc); various

species of birds, deer, and bear. These animal species are

commonly found in woodland habitats. Vegetation identified

as part of the biota investigation include: numerous

herbaceous species and several woody species in various

stages of growth (seedlings, saplings and mature trees).

E. Hydrogeology

Ground water at the site occurs under water table

conditions in the unconsolidated zone and under confined

conditions in the upper bedrock and lower sandstone aquifers.

Portions of the unconsolidated materials are water bearing.

The interval from below the Upper Freeport Coal to the top of

the lower sandstone unit has been collectively designated as

the upper bedrock aquifer, although this unit is not a good

water producing zone. Most water produced in this unit is

301451
present around the Lower Freeport Coal seam. Water level

measurements indicate that the flow in the upper bedrock

aquifer is to the west toward Unnamed Creek. The other

water producing zone beneath the site has been designated as

the lower sandstone bedrock which occurs beneath the Lower

Freeport Coal, at an approximate elevation of 1300 feet. The

ground water flow within the lower sandstone is to the south

and southwest toward the valley bottom.

Water level contours for the unconsolidated materials

indicate the water table surface resembles/ and usually

mimics, the topography. Flow lines indicate that ground water

migrates toward the stream valley, as expected. The contours

near the southern portion of the site, tend to swing toward

the east, which indicates that the seepage stream gully and

the topographic slope toward the former Craig property,

influence the ground water flow in this area.

Downslope from the two pits, the unconsolidated material

thins out near the 1350 elevation. This is also the

approximate elevation where many of the hillside seeps occur.

This indicates that the ground water flows through the

unconsolidated materials and along the shale contact, until

discharging on to the hillside.

F. Nature and Extent of Contamination

The distillation residue deposited in the two pits

contains resorcinol and other higher polymers. The

distillation residue is a waste created in the production of

resorcinol, and its composition has been analyzed. The waste

is a CERCLA hazardous substance, but it is not a Resource

Conservation and Recovery Act (RCRA) hazardous waste. The

composition of the waste is as follows:

Resorcinol 5-10%

Dihydroxydiphenyls (DHO) 20-25%

Trihydroxydiphenyls (THD) 30-35%

higher polymers 30-35%

The chemical structure of the compounds is illustrated in

Figure 2.

301452
FIGURE 2

CHEMICAL STRUCTURES OF PHENOL, RESORCINOL, DHD, THD,

and RELATED HIGHER MOLECULAR WEIGHT POLYMERS

OH

MOLECULAR W&6H7 POLYMERS 3Q1453
—^ Test pits dug into the two pits showed that the residue

ranged from black or pink semi-solid material to hardened

chunks. The northern pit encompasses 1.2-1.5 acres and the

southern pit encompasses approximately 0.8-1.0 acre. Analytical data also indicate that the source material in the pits

is most concentrated from 2.5-6.0 feet below the surface.

Contaminated soil exists near the two pits, especially downslope of these two areas.

The water quality data obtained from the RI has been

used to refine interpretations regarding the horizontal and

vertical extent of degraded ground water at the Craig Farm

site. Generalized boundary maps for the unconsolidated

materials zone/ upper bedrock aquifer, and lower sandstone

aquifer are based on the detection of one or more of the

process-related organic indicator parameters in penetrating

those respective monitoring intervals. The chemical constituents associated with the former site activities are present

in ground water in each of the three geologic intervals

described above.

Within the unconsolidated materials zone, the degraded

ground water appears to extend beneath most of the site. Due

to the thinning of this zone below the pits, ground water

••'' ~ moves along the top of the shale and discharges to the surface

\^j at an approximate elevation of 1340 ft. Because the Unnamed

Creek represents the local discharge point for the unconsoldated materials zone, the limit of the impacted ground water

is thought to be to the west by Unnamed Creek.

Within the upper bedrock aquifer unit, the degraded

ground water appears to extend beneath most of the study

area. Ground water moves through the shale and discharges

along the position of the Lower Freeport Coal seam. Because

the Unnamed Creek and the topographic position represent the

local discharge point for the upper bedrock aquifer, the

limit of the impacted ground water is thought to be to the

west by Unnamed Creek.

Within the lower sandstone aquifer unit, the degraded

ground water extends from the area of the two pits to an area

immediately east of the Unnamed Creek valley bottom.

Ground water movement in this unit is influenced by migration

of ground water from above the Lower Freeport Coal seam, as

well as through regional ground water discharge toward the

valley bottom.

301454
10

G. Biological Findings

From September, 1986 through August, 1987 a biological

survey was performed to determine the effects, if any, of

potential constituents of concern on aquatic biota. The

study found that macroinvertebrate communities located downgradient of the site did exhibit signs of stress. The stress

vas characterized by a lack of macroinvertebrates species

that are indicators of good water quality. Statistical

correlations indicate that, of the process-related

constituents, trihydroxydiphenyl (THD) concentration has

the greatest impact on macroinvertebrates. Chemical analyses

of crayfish tissue determined that no bioaccumulation of any

PCOC could be detected. There also were no indications of

any biomagnif ication of any site-related compound.

There was no stress detected in the fish community in

alley Run, and the impacted macroinvertebrate community

»sted appear to recover within 1 mile of the confluence of

e Unnamed Creek with Valley Run.

H. Air Monitoring Findings

t -

In August and September, 1987, an air monitoring survey

as performed at the site to determine the air quality in

egards to the source material and several other compounds on

he Hazardous Substance List. The air survey determined that

:he constituents of concern were not impacting the air quality

at the site. Field sampling was conducted in accordance with

a RI/FS Air Monitoring Work Plan. The results of this study

were that the site in its present condition poses no health

threat via air transport of site-related compounds.

301455
11

SUMMARY OF SITE RISKS

Potential Contaminants of Concern

Soils, ground water, surface water and sediments, and

ambient air were analyzed for various priority pollutant

organics and metals as well as process-related constituents.

Based on the analytical results and the above criteria, the

following organic and inorganic constituents have been

selected as potential contaminants of concern (PCOCs):

Orqanicst Inorganics;

o resorcinol o cadmium

o trihydroxydiphenyl (THD) o chromium

o meta-phenolsulfonic acid (m-PSA) o copper

o para-phenolsulfonic acid (p-PSA) o lead

o benzene sulfonic acid (BSA) o zinc

o benzene meta disulfonic acid (BMDSA)

o benzene

o phenol

This list of organic PCOCs, excluding benzene, are processrelated constituents. Although other priority pollutant

; organics were detected in one round of surface water sampling,

^-^ they were not selected as PCOCs since the final round of

sampling determined the concentrations to be below the limits

of detection. The priority pollutant metals selected as

PCOCs are not process-related constituents. However, they were

detected at levels greater than typical background levels for

the media in which they were measured. Cadmium was the only

metal detected above background levels in the soil. The

other metals were detected in the ground water. It should be

noted that the above set of PCOCs were not necessarily detected

in each of the media of interest. Table 1 lists PCOCs in

each of the areas of interest.

Toxicological Profiles

Toxicological data on the majority of the PCOCs

identified at the site, i.e. the process-related constituents

- resorcinol, THD, DHD, m-PSA, p-PSA, BMDSA, and BSA,

is either scarce or absent. Resorcinol, for which some

toxicological data is available, was used as the representative for all of these related compounds based on the similarity

of their chemical structures. Resorcinol is moderately toxic,

but it is not presently considered a carcinogen.

301456
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13

The Registry of Toxic Effects and Chemical Substances lists

the oral lethal dose of resorcinol in rats as 301 rag/kg.

Benzene is the only known carcinogen that is a PCOC at this

site, and it is present only at low levels in the soils and

ground water.

Potential Migration Routes • •

An exposure pathway usually involves the transport of

chemicals through an environmental medium or from one

environmental medium to another. At the site, migration of

PCOCs could potentially occur via movement through surface

water, sediments, ground water, soil, or ambient air.

The analysis of surface water (i.e. Seeps A & B, Unnamed

Creek, and Valley Run) resulted in detectable concentrations

~* several of the PCOCs in both Unnamed Creek and the seeps.

-.'or, these same constituents were below detection limits

ley Run which is the body of surface water most likely

=ed by potential receptors. Therefore, surface water

considered as a significant migration route for

ecause of the lack of a receptor. Analysis of the

sediments resulted in 1) levels below limits of

on (resorcinol, m-PSA, BSA, BMDSA), 2) detectable

.rations in only one sampling round (THD), or 3) levels

.r to controls (benzene). These results indicate that

-ants do not provide a significant migration route for

: PCOCS.

Surficial soil samples taken from test pits 0 to 2 feet

in depth and from the strip mine pits resulted in detectable

concentrations of resorcinol, THD, m-PSA, p-PSA and cadmium.

Therefore, surficial soils and deeper soils may be potential

migration routes. Based on analytical results, ground water

is also a migration route for all of the PCOCs.

With respect to ambient air samples, the PCOCs were

either below detection limits, or in the case of benzene,

were equivalent to typical U.S. rural background levels.

Therefore, the transport of PCOCs through ambient air will

not be considered further as a potential migration route at

the site*

Potential Human Exposure Pathways

In the identification and evaluation of potential

exposure pathways, potential current and potential future

uses of the site were considered. The area currently is

restricted from recreational use. Hypothetical future uses

were determined based on the typography and current demographic use of the surrounding area. The steepness of the

hillside on which the site is located and its remoteness

may preclude future commercial or residential development.

301458
14

Therefore, future occupants or construction workers will

not be considered. Potential future use of the site for

mining, an activity that has occurred on the site and is

currently being practiced in the surrounding area, is

utilized as the human exposure pathway for the risk

calculations.

Potential Environmental Exposure Pathways

Surface water and sediments from Unnamed Creek, soil on

the site, and sediments in Valley Run could provide potential

environmental exposure pathways. Wildlife could be exposed

to site-related contamination by coming in contact with the

seeps on the hillside downgradient from the two pits.

Terrestrial species inhabiting the site, which is

primarily wooded, include deer, rabbits, squirrels and other

mammalian species. Amphibious species (i.e. turtles, frogs,

salamanders) also inhabit areas of the site. Aquatic

organisms that could inhabit Valley Run and Unnamed Creek

include invertebrates and fish.

The lack of benthic raacroinvertebrates and fish in Unnamed

Creek indicates that PCOCs in the stream are impacting aquatic

lifeRisk Characterization

An exposure assessment and risk characterization was

carried out for the following exposure pathways: 1)

incidental ingestion and dermal absorption of PCOCs in

surficial soils by trespassers; 2) dermal absorption of PCOCs

in ground water by hypothetical future miners; and 3)

incidental ingestion and dermal absorption of PCOCs in

ground water by future off site domestic well users.

The maximum concentration of resorcinol, THD, and DHD

found in soils were 1400 mg/kg, 11,500 mg/kg, and 250 mg/kg,

respectively. BSA had a maximum concentration of 700 mg/kg,

m-PSA had a maximum of 320 mg/kg, and the highest level of

p-PSA was 2250 mg/kg. The highest level of benzene found

in the soils was 7.8 mg/kg. The levels of PCOCs in the

ground water are listed in Table 2.

The PCOCs for each receptor group varied according to

predicted usage patterns, i.e. potential trespasser exposure

to surficial soils, potential exposure of hypothetical future

miners to ground water in the uppermost bedrock unit and the

lower sandstone unit, and potential future domestic well

usage of ground water from the lower sandstone unit.

301459
15

TABLE 2

GEOMETRIC MEAN CONCENTRATION RANGES OF

PCOCs IN GROUNDWATER

Frequency of

Compound (mg/1) Level Detection Range (mg/1)

BSA A 4/9 <25 - 70.5

«25) B 9/19 <25 - 74.4

C 3/12 <25 - 29.7

BMDSA A 2/9 <25 - 19.2

B 5/9

C 0/12

«25) B 5/9 0.37 - 122

r n/i? untlJ

i-PSA A 6/9 <25 - 96.7

<25) B 7/19 <25 - 183

C 1/12 <25 - 345

-PSA A 8/9 <25 - 721

<25) B 7/19 <25 - 1063

C 4/12 <25 - 811

Benzene (ug/L) A 6/9 <1.0 - 2.55

«1) B 6/19 <1.0 - 3.71

C 5/12 <1.0 - 1.6

Phenol A 9/9 0.05 - 0.86

«5) B 13/19 <0.005 - 0.71

C 9/12 <0.005 - 0.27

Resorcinol A 8/9 <5.0 - 878

«5) B 9/19 <5.0 - 872

C 5/12 <5.0 - 465

THD A 9/9 7.67 - 2453

«0.5) B 11/19 <5.0 - 2455

C 6/12 <5.0 - 1435

NOTES:

(l)Not detected in any sampling round.

Vindicates detection limit.

All concentrations in rag/L unless otherwise noted.

Level A is the shallow wells t Level B is medium-depth wells ,

and Level C is the deep wells.

301460
16

; , Hazard indices and/or risk calculations were calculated

'v->--/' for each of these receptor groups and are as follows:

o The total hazard index for trespassers, the sum of

the hazard indices for incidental ingestion

(3.28 x 10"3) and dermal absorption from soil

(0.07), is 0.07.

o The total hazard index for hypothetical future

miners for dermal absorption from ground water is

0.43 and the excess individual lifetime cancer risk

is 1.39 x 10' '.

o The total hazard index for future offsite domestic

well-users, the sum of the hazard indices for

incidental ingestion (0.63) and dermal absorption

from ground water (1.39 x 10~4) is 0.63.

The total hazard indices calculated for trespassers,

hypothetical future miners and future offsite domestic

well users were all less than 1. A hazard index of 1 or

less indicates that the estimated intakes are less than the

threshold intake levels and that there is no appreciable

risk of adverse health effects.

The cancer risk to future miners is based on potential

V_y exposure of future miners to benzene in the ground water.

The potential excess individual lifetime cancer risk calculated for hypothetical future miners was 1.39 x 10"' which

is lower than the upper bound of the range recommended by

the U.S.EPA of 10~4 to 10~7.

The human health threat presented by this site is

negligible in as much as there are no human receptors

onsite, or immediately adjacent to the site at this time.

The site is presently having an impact on Unnamed Creek

and the onsite wetlands as well as the organisms living

in these communities. Thus, the selection of the remedy is

based on the site's impact on the environment rather than on

a risk to human health. As described above, the site does

present an imminent and substantial endangerment to the

environment as set forth in Section 106 of CERCLA, 42 U.S.C.

Section 9606.

301461
17

DESCRIPTION OF ALTERNATIVES

' A number of alternatives were developed to meet the

following remedial action goals:

- minimize risk to the public health and environment

from direct contact with contaminated material

- control the migration of contaminants into nearby

surface waters

- control the migration of contaminants into ground

water

OPERABLE UNIT fl (OUl) -. The source material in the two

pit areas and the adjacent contaminated soils.

Alternative 1: No Action

This alternative provides the baseline or reference

point against which each of the operable unit alternatives

are compared. If the other selected alternatives do not

offer substantial benefits in reduction of toxicity, mobility,

or volume, then the No Action alternative may be considered a

feasible approach.

The No Action alternative would consist of continued

monitoring of Unnamed Creek and the ground water, as well as

potential deed notices. Monitoring of Unnamed Creek and the

ground water would consist of monitoring for PCOCs on a semiannual basis. The semi-annual monitoring would be implemented

to determine the potential effects, if any, on the creek and

ground water, and would be assumed to continue for a 30-year

period. The monitoring would consist of the collection and

analysis of 16 groundwater samples and 5 surface water samples.

Institutional controls utilizing deed notices would be

implemented to inform property owners about the PCOCs at the

site. Fences would also be erected around the two pit areas.

Monitoring would require a two-man field crew spending

approximately 8 days each year. The Operation and Maintenance

(O&M) costs for this alternative are estimated as $49,000 per

year which includes sampling and analysis, administration

costs, and labor. Assuming a 5% interest rate and a projected

30-year monitoring period, the associated present worth of

this alternative has been estimated to be $817,000.

Alternative 2A: Slurry Walls with Impermeable Cap

This alternative provides for installing upgradient

slurry walls and surface capping the OUl areas with low

permeability material. Low permeability caps would be contructed over the OUl areas to substantially reduce migration

301462
18

of PCOCs to Unnamed Creek. The surface cap would consist of

a relatively impermeable soil layer, a synthetic membrane

liner, a conducting zone, cover soil, and top soil with a

vegetative cover.

The capped area would be graded to achieve the required

surface drainage patterns, and compacted to provide.a stable

subgrade for cap construction. After the initial surface

preparation work, the relatively impermeable barrier soil

layer would be constructed. This layer would consist of

two feet of either remolded natural clay or soil with clay

(bentonite) additives. A High Density Polyethylene (HOPE)

synthetic membrane liner would be installed over the barrier

soil layer. Above the 50 mil synthetic membrane, a one-foot

thick conducting zone would be constructed of granular

material and would intercept infiltrating water, and direct

it to the perimeter of the cap for discharge into surface

-linage facilities. Above the conducting zone, two feet of

over would be placed for frost protection. The cap

--ction would be completed with a six-inch topsoil layer

.; entire capped area, as well as adjacent disturbed

ould be seeded and mulched for long-term erosion

•

; divert the ground water around the OU1 areas, a slurry

of approximately 600 linear feet would be installed on

.^gradient side of both the northern and southern pits.

slurry trench would be founded into the shale layer,

Men is approximately 15 feet below surface, and the width

of the trench would be at least 24 inches. The slurry wall

would be constructed using a soil/bentonite clay mixture.

The trench would be excavated using special backhoes and the

slurry material would be mixed and backfilled using a bulldozer,

This alternative would take four months to complete.

The capital cost for this alternative is estimated to be

approximately $1,280,000, and the associated O&K costs are

approximately $49,000. The total present worth of this

alternative is, therefore, about $2,033,000, assuming a 30-

year period at 5% interest.

Alternative 2Bt Slurry Walls, In-Situ Solidification/Fixation

Treatment, Capping [

This alternative provides for solidification/fixation

treatment of OU1 material, installing upgradient slurry walls

and surface capping the OU1 areas with low permeability

material. OU1 material would be chemically treated and low

permeability caps with slurry walls would be constructed over

the OU1 areas to substantially reduce migration of PCOCs to

Unnamed Creek. The surface cap and slurry walls would be

identical to those discussed in alternative 2A.

301463
19

In-situ chemical treatment of OUl material would be

performed by injecting reagent into the sub-surface area and

mixing the reagent in place with the OUl material. The

equipment used for subsurface stabilization is similar to

typical auger ing equipment with specialized bits. The

treatment area would be divided into blocks for treatment

with approximately 10% overlap of the treatment blocks to

ensure complete treatment of the entire OUl area. The

volume of material to be solidified/fixed is expected to

be 5,000 cubic yards. It would be necessary to perform

treatability testing to determine the reagents that would

be best suited for stabilizing OUl material before this

alternative could be implemented. . '

This option would take approximately 6 months to

complete. The capital cost for this alternative is estimated

to be about $2,717,500. The O&M costs associated with the

alternative are estimated to be $49, 000/year. The total

present worth of the excavation and landfill alternative

is, therefore, about $3,471,000, assuming a 30-year period and

a 5% interest rate.

Alternative 3A: Excavation with Ons ite Landfill

This alternative provides for the complete excavation of

OUl material and onsite landfilling. The excavated material

would be placed onsite in a secure landfill (1.5-2.0 acres)

located in the immediate area between the two existing pit

areas. Typical construction equipment would be used for

landfill construction and loading. The landfill would be

lined with a two-foot clay barrier, and two layers of HDPE

liner with filter fabric on each side. A one-foot leak

detection zone would be placed above the secondary liner,

and a one-foot thick seepage collection zone would be placed

above the primary liner. Impacted soil would be compacted

and placed on the liner to a depth of about 12 feet. After

all impacted soil has been placed in the landfill, a cap

would be constructed over the landfill. The cap would be

composed of a two- foot clay barrier, one layer of HDPE liner,

a one-foot drainage layer, and two feet of cover soil. After

the cap is constructed, the area would be vegetated for erosion

control.

This alternative would take approximately 5 months to

complete. The capital cost for this option is estimated to

be about $2,309,000. The maintenance costs associated with

it are about $49,000/year. The total present worth of the

excavation and landfill alternative is, therefore, about

$3,062,000 assuming a 30-year period and a 5% interest rate.

301464
20

Alternative 3Bt Excavation with Solidification/Fixation Treatment

Onsite Landfill

This alternative provides for the complete excavation of OU1

material/ solidification/fixation of the source material using

fixing agents and landfilling of all OU1 material onsite. The

method of excavation and landfilling would be identical to

that discussed for Alternative 3A; however the source material

will be solidified before landfilling. Solidification/fixation

treatment of OU1 material (5,000 cubic yards) would be performed

by one of two methods. The simplest method would be to mix

an appropriate reagent with the material using typical excavating

equipment such as a bulldozer or backhoe. The second possible

method would include excavating the source material and mixing

it with an apppropriate reagent in a pug mill. After solidification, the material would be transported to the onsite

landfill. It would be necessary to perform treatability

testing to determine the reagent that would be best suited for

stabilizing the material before this alternative could be

implemented. Some fixing agents react chemically with the

iste material and thus change the chemical make-up of the

sultant solid. Other solidifying agents have only a physical

action, and merely encase the waste in a solid mixture.

solidification that involves a chemical reaction would be

dferable because the toxicity of the waste material is

/educed in the process. The effectiveness of the solidifiration procedure would also be evaluated during the treatability

Jtudy by using the TCLP method (EPA Method 1311, 53£R18792,

lay 24, 1988).

This alternative would take six months to complete. The

capital cost for this alternative is estimated to be about

$3,053,750. The O&M costs associated with the alternative

are estimated to be $49, 000/year. The total present worth of

this alternative is about $3,807,000 assuming a 30-year period

and a 5% interest rate.

Alternative 3d Excavation and Solidification/Fixation

Treatment with Qffsite Landfill

This alternative provides for complete excavation and

solidification of all OU1 material and disposal at an offsite

landfill. The method of excavation would be identical to

that discussed for Alternative 3A and solidification/fixation

treatment would be identical to that described for Alternative 38. The materials would be removed and placed in a

secure offsite landfill. Dump trucks with a capacity of 16

cubic yards would be employed. The transportation would

be performed by licensed haulers, and appropriate regulations

would be met for the transportation of these types of wastes.

About 2,490 truck loads (@ 13 cubic yards/truck) would be

required to transport this material to the landfill.

301465
21

The excavated material would be taken to a licensed

l , facility permitted to handle these materials in a secure

^^^ landfill. The facility would have appropriate state and

federal permits to receive these materials. This alternative

would take 6 months to complete. The total present worth

for this alternative is about $23,168,750 assuming a 30-year

period and a 5% interest rate.

Alternative 4A: Excavation with Onsite Incineration

This alternative deals with complete excavation of OU1

material and then incineration in a onsite incineration

unit. 'For the purposes of this evaluation, the incineration

equipment is assumed to be a rental unit, and the estimated

volume of material to be treated is about 32,300 cubic yards.

The onsite incineration equipment would consist of a

primary oxidation chamber which would heat the OU1 material

to be treated to an operating temperature of 1,500°F to

2,000°F, which is sufficient to drive the PCOCs from the

material, and initiate their thermal destruction. Secondary

chamber exhaust is processed through a heat exchanger to

reduce the heat content of the gas stream. Heat may be recovered in the form of steam or preheated combustion air.

The cooled gas is treated for particulate matter removal and,

where required, acid gases are reduced through a wet scrubbing

V_y technology.

The treating capacity of the incineration process would

be approximately 50 to 100 tons per day. It is estimated to

take 24 to 48 months based on the 50 to 100 tons per day rate

to incinerate the 32,300 cubic yards. After incineration and

destruction of the constituents in the excavated materials,

inert ash may be replaced in the excavated zones of the site.

Analysis of the ash during laboratory testing for comparison

to EPA Toxicity Criteria indicated that ash from incineration

of the Craig Farm waste material is inert and non-toxic.

Soils for backfilling and placing a soil cover over the

excavated areas will be obtained onsite. Spreading and

compacting backfill material will be achieved using a mediumsized dozer and self-propelled compactor. This alternative

would be completed within 4 years. Total capital cost for

the excavation and onsite incineration alternative is approximately $13,471,00. O&M costs associated with this option

are $49,000, therefore, the total present worth for Alternative

4A is $14,224,000 assuming a 30-year period and a 5% interest

rate.

301466
22

Operable Unit 13 (OU3) - Seeps A & B downgradient of the two

disposal pits.

In the preliminary screening of alternatives for OU3, it

was determined that the aquifer supplying these seeps was not

very productive. Therefore, an active collection and treatment

option/ such as a recovery well connected to an air stripper,

was not feasible for this operable unit, and was eliminated in the preliminary screening. The alternatives that

were determined to be feasible for Operable Unit 13 are as

follows:

Alternative 1A: No Action

This alternative would entail no action regarding the

two seeps which are downgradient of the two disposal pits.

There would be no cost associated with this alternative as

it would not involve monitoring of the seeps.

Alternative 2A: Seep Interceptor System and Offsite

Treatment

This alternative provides for collection of OU3 water

using an interceptor system and transporting it offsite to a

treatment system that is capable of handling wastewater

of this type. This wastewater collection will continue

indefinitely until the remediation is judged complete. The

judgement about the completeness of the remediation will be

done by periodically analyzing the water quality and toxicity

of the wastewater using a bioassay test for resorcinol

approved by the EPA.

Collection trenches would be installed perpendicular to

the slope several feet above the location where Seeps A and B

appear on the hill side. The trench would be constructed

using conventional construction equipment. Each trench would

be approximately 20 feet long, 5 feet deep, and 2 feet wide.

The exact size of the trenches will be determined during

remedial design. The trenches would be sloped to one side

and a conducting zone composed of gravel and perforated pipe

would be placed in the trenches, to collect the OU3 water and

channel it to the sump located on the low side of the trench*

A sump pump with level control would pump the water to a

40,000gallon tank providing a minimum of 10 days storage

capacity. A pump truck would collect the water once each

week and deliver it to the system at an offsite treatment

plant. Total capital cost for this alternative is approximately $228,000. O&M costs associated with this option are

$75,000, therefore, the total present worth for the alternative

is $1,381,000 assuming a 30-year period and a 5% interest

rate .

301467
23

. COMPARATIVE ANALYSIS OF ALTERNATIVES

In evaluating remedial alternatives, EPA evaluates nine

specific criteria. The criteria are explained and briefly

summarized in Table 3. The following section describes the

nine evaluation criteria and how each of the alternatives

compare according to each of these criteria. The criteria'

are analyzed first for OUl, and then for OU3.

1). Overall Protection of Human Health and the Environment

OUl

The site's main impact is on the environment; its impact

on human health is negligible. Excavation with onsite

incineration would reduce or eliminate the potential adverse

'•npact on Unnamed Creek and the surrounding wetlands. Based

- -reatability testing/ the ash would be of quality suitable

--incorporation on the site. Alternative 3C would also

: the adverse impact on the environment. The material

3 placed off site, so that future remediation is

y. Solidification treatment and onsite landfill

.so reduce or eliminate the adverse impact to the

environment. However, this remedy would not eliminate

^sibility of future remediation if the liner or cap

: and the solidification process failed. The remaining

.natives (2A,2B,3A) would be even more likely to require

-:Lner remediation.

OU3

Collection of the OU3 water, and transporting it off site

reduces PCOC migration by decreasing PCOC concentrations at

the site.

2). Compliance With ARARs

OUl

All of the alternatives would meet ARARs, and no waivers

would be required. The waste material is a CERCLA hazardous

substance, but it is not a RCRA hazardous waste. Certain RCRA

regulations, specified in Table 7, although not applicable,

are relevant and appropriate. The onsite landfilling alternatives would have to meet RCRA design standards for landfills.

The incinerator option would have to meet RCRA requirements

regarding incinerators. The offsite landfilling option would

have to meet Hazardous Materials Transportation regulations.

RCRA Closure and Post-Closure would require deed notices and

long-term monitoring. The Executive Order on Protection of

Wetlands is applicable, because there are wetlands onsite.

Any remedial actions must be done without adversely impacting

the wetlands. The proposed landfill must be a minimum of 300

feet from the wetlands because of the RCRA siting criteria

regarding wetlands. The Occupational Safety and Health Act

would be applicable in terms of protecting the safety of

workers during any remedial action.

301468
24

Table 3. DESCRIPTION OF EVALUATION CRITERIA

Overall Protection of Human Health and the Environment -

addresses whether or not a remedy will: cleanup a site to

within the risk range; result in any unacceptable impacts;

control the inherent hazards (e.g., toxicity and mobility)

associated with a site; and minimize the short-term impacts

associated' with cleaning up the site.

Compliance with ARAR's - addresses whether or not a remedy

will meet all of the applicable or relevant and appropriate

requirements of other environmental statues and/or provide

grounds for invoking a waiver.

Long-term Effectiveness and Permanence - refers to the

ability of a remedy to maintain reliable protection of human

health and the environment over time once cleanup goals have

been met.

Reduction of Toxicity, Mobility, or Volume through Treatment -

refers to the anticipated performance of the treatment

technologies that may be employed in a remedy.

Short-term Effectiveness - refers to the period of time

needed to achieve protection, and any adverse impacts on

human health and the environment that may be posed during the

construction and implementation period until cleanup goals are

achieved.

Implementability - describes the technical and administrative

feasibility of a remedy, including the availability of materials

and services needed to implement the chosen solution.

Cost - includes the capital for materials, equipment, etc.

and the operation and maintenance costs*

Support Agency Acceptance - indicates whether, based on its

review of the RI, FS and the Proposed Plan, the State concurs

with, opposes, or has no comment on the preferred alternative.

Community Acceptance - will be assessed in the Record of

Decision following a review of the public comments received

on the RI, FS, and the Proposed Plan.

301469
25

^ ou3

The wastewater collection and treatment system would be

operated to ensure compliance with chemical-specific ARARs

(See Table 5).

3). Long-Term Effectiveness

OU1

The most effective option long-terra is the incineration

option. Alternative 38 has good long-term effectiveness

because if the containment system failed, the source material

would be bound up/ and the impact on human health and the

environment would be minimal. The other treatment options

would also be effective long term, especially if the site

is properly maintained.

OU3

Collection and treatment of OU3 water will provide

•^mediation of that water until it is no longer necessary.

. Reduction in Toxicity, Mobility, Volume

• J.

Excavation with onsite incineration would result in

permanent reduction in toxicity, mobility and volume of the

. organic PCOC's. Excavation with solidification and onsite

^—/ '.andfilling would also reduce mobility of the PCOC's. It

lay or may not also reduce volume and toxicity depending on

the solidification process. Some solidifications increase

the volume of the waste material, and some decrease it. Some

solidications decrease the toxicity of the waste material, and

some do not effect the toxicity of the waste material. The

most likely scenario is that the volume of the waste material

would increase, and the toxicity would be reduced. Excavation

and landfilling would reduce the mobility of site-related

contaminants. Capping and slurry walls would reduce mobility.

No action would not reduce toxicity, mobility or volume.

OU3

The collection and treatment of the contaminated water

from the two seeps would reduce the mobility of the PCOCs.

No action would not reduce toxicity, mobility or volume.

5). Short-term Effectiveness

OUl

The slurry wall and cap could be completed in four

months, and the material would be contained. Excavation,

solidification and onsite landfill would be completed in six

months and would be a permanent treatment of the waste.

Excavation and incineration would take 4 years to complete,

\^ so its short-term effectiveness would be low. No short-term

reduction in PCOC's can be associated with the no action

alternative.

301470
26

OU3

Construction of the collection and offsite treatment

alternative would be completed in approximately one month,

however, collection and treatment would continue

indefinitely.

6). Implementability

OU1 '

All of the alternatives proposed for this site can be

easily implemented. For the solidification options, it would

be necessary to perform treatability tests to determine the

most effective method of solidification. The onsite

incineration is the most difficult of the treatment options

to implement.

OU3

The collection and offsite treatment option could be

easily implemented. Access would be no problem, and the

required equipment is readily available.

7). Cost

our

The most inexpensive treatment option is in-situ treatment

with slurry walls. Alternative 3B is only marginally more

expensive; it costs aprroximately $400,000 more than in-situ

treatment. Incineration and offsite landfilling are substantially more expensive, at $14.2 and $23.9 million respectively.

An important consideration at this site regarding cost is

that, with the risk to human health being low, the more

expensive remedies are difficult to justify.

8). State Acceptance - The PADER concurs with the remedy

selection at this site. A copy of the state's concurrence

letter is attached.

9). Community Acceptance - Community interest is low at this

site.A single letter contained the only written comments

received during the public comment period. A public meeting

was held, and it lasted approximately 90 minutes. In general,

the citizens seemed interested in having the site remediated

as soon as possible. The citizens did not appear interested,

however, in the details of the selected remedy. All significant comments are addressed in the attached Responsiveness

Summary.

301471
27

: DESCRIPTION OF THE SELECTED REMEDY

Based upon consideration of the requirements of CERCLA,

the detailed evaluation of the alternatives, and public

comments, EPA has determined that Alternative 3B

(Excavation, Solidification/Fixation Treatment Onsite

Landfill) for Operable Unit tl in combination with

Alternative 2A (Seep Interceptor System and Offsite

Treatment) for Operable Unit 13 is the most appropriate remedy

for the Craig Farm Site in Perry Township, Pennsylvania.

Approximately 32,000 cubic yards of contaminated soil

and source material will be excavated from the two source *

pits. A treatability study of the solidification procedure

will be done, and its effectiveness will be evaluated using

the TCLP prior to the .full-scale remedial action. The

results of this study will be submitted to EPA and PADER for

review and comment. If the solidification procedure is not

found to be effective, then other remedial alternatives will

be considered. If the solidification procedure is effective

in the treatability study, the source material will then be

solidified, and the solidified waste and the contaminated

soil will be placed in a double-lined landfill. All soil

around the two disposal pits containing detectable levels of

resorcinol will be placed in the landfill. The pits will be

excavated until there are no longer any detectable levels of

\^_^/ resorcinol in the soil.

Fill material will be placed in the excavated areas,

and a minimum of six inches of soil cover will be placed on

top of the fill material to support vegetation. The landfill

will be -lined with a two-foot clay barrier, and two layers

of liner with filter fabric on each side. A one-foot leak

detection zone would be placed above the secondary liner

and a one-foot thick seepage collection zone will be placed

above the primary liner. After all impacted soil has been

placed in the landfill, a cap would be constructed over

the landfill. The cap will be composed of a two-foot clay

barrier, one layer of liner, one-foot drainage area, and two

feet of cover soil. After the cap is constructed, the area

would be vegetated for erosion control.

The selected remedy also includes collection and

treatment of the groundwater via a seep interceptor system.

Collection trenches will be installed perpendicular to the

slope several feet above the location where Seeps A and B

appear on the hill side. Each trench will be approximately

twenty feet long, five feet deep and two feet wide. The flow

rate from the two seeps is approximately 4000 gallons per

day. A sump pump with level control would pump the water to

a 40,000 gallon tank providing a minimum of 10 days storage

i time. A pump truck would collect the water once a week and

^-^ transport it to an offsite water treatment plant. This

3014t8
28

collection and treatment of the contaminated water will

^_> continue indefinitely until the remediation is judged to be

complete. The completeness of the remedy will be determined.

by using a bioassay testing procedure that is approved by the

EPA.

A ground water verification study will also be done

to determine whether or not the ground water (both on- and.

offsite), not being addressed in the selected remedy needs

any further remediation. If additional ground water

remediation is required, it will be considered a separate

operable unit, and will be addressed in a subsequent ROD

for this site.

Some changes may be made to the remedy as a result of

the remedial design and construction process. Such changes

in general will reflect modifications resulting from the

engineering design process.

PPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

rtion 121 of CERCLA, 42 U.S.C. Section 9621, requires

.tedial actions comply with applicable or relevant and

late requirements (ARARs) of promulgated federal and

i , laws.

A requirement may be either "applicable" or "relevant

and appropriate" to a remedial action. Applicable

requirements are cleanup standards/ criteria/ or requirements

established under federal or state law that specifically

address a hazardous substance, pollutant, contaminant,

remedial action, location, or other circumstances at a CERCLA

site. Relevant and appropriate requirements may not be

"applicable" to a hazardous substance, pollutant, contaminant,

remedial action, location, or other circumstance at a CERCLA

site, but may address problems or situations sufficiently

similar to those encountered at the CERCLA site.

ARARs are divided into three separate groups of

requirements* chemical-specific, location-specific, and actionspecific. Chemical-specific ARARs are requirements which set

health or risk-based concentration limits or ranges for

specific hazardous substances, pollutants, or contaminants.

Maximum Contaminant Levels (MCLs) are examples of chemicalspecific ARARs. Location-specific ARARs set restrictions on

activities based upon the characteristics of the site and/or

the immediate environs. Examples of this type of ARAR

include federal and state siting laws for hazardous waste

facilities and sites on the National Register of Historic

Places. The third classification of ARARs, action-specific,

^^ refers to the requirements that control remedial activities

selected to accomplish a remedy. RCRA regulations for

301473
29

closure of hazardous waste storage units, RCRA incineration

standards, and pretreatment standards under the Clean Water

Act for discharges to wastewater treatment plants are examples

of action-specific ARARs.

Chemical-Specific ARARs

As previously stated, chemical-specific ARARs set health

or risk-based concentration .limits or ranges for specific

hazardous substances, pollutants, and/or contaminants. Based

on the results of the Remedial Investigation, chemical

specific ARARs for air-related impacts were not considered.

Table 4 is a list of the state chemical-specific ARARs, and

Table 5 is a list of the federal chemical-specific ARARs

identified for the Craig Farm site. Table 6 shows the limits

for the PCOCs under the chemical-specific ARARS.

Location-Specific ARARs

Location-specific ARARs are requirements that set

restrictions on activities based upon the characteristics of

the site and immediate environs. Table 4 includes a review

of state location-specific ARARs. Federal location-specific

ARARs are listed in Table 5.

Action-Specific ARARs

ARARs for the development of the remedial action

alternatives under consideration for the Craig Farm Site can

also be divided in state and federal ARARs. Table 7 sets

forth federal action-specific ARARs, and state actionspecific ARARs can be found in Table 4.

It should be noted that the RCRA Land Disposal Restrictions

found at 40 CFR Section 268 apply only to RCRA hazardous wastes

that are land disposed or placed after the effective date of

the restrictions. The waste present at the Craig Farm Site

is a CERCLA hazardous substance, not a RCRA hazardous waste,

so the Land Disposal Restrictions are not applicable. Further,

EPA has determined that the waste is not similar enough to a

RCRA waste to make Land Disposal Restrictions relevant and

appropriate. Thus, Land Disposal Restrictions are not ARARs.

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35

STATUTORY DETERMINATIONS

Protection of Human Health and the Environment

The selected remedy would greatly reduce or eliminate potential

migration of PCOC's, thereby reducing the potential for impacts

on Unnamed Creek or the surrounding wetlands. The site presently

has little or no impact on human health. This human health risk

would be even lower after the selected remedy is implemented.

The excavation process would be controlled to ensure that fugitive

dust emissions and subsequent inhalation by nearby residents would

be minimized. The implementation of the remedy will not pose

unacceptable short-term risks or adverse cross-media impacts.

Cost-Effectiveness

The selected remedy is cost-effective because it has been

etermined to provide overall effectiveness proportional to its

ost, the net present value being $4,479,000. The estimated

jsts of the selected remedy are within an order of magnitude

: the costs associated with onsite landf illing of the source

.aterial, and yet the selected remedy assures a much higher

degree of certainty that the remedy will be effective in the

long terra due to the reduction of the toxicity and mobility

of the wastes achieved through solidification of the wastes

prior to landf illing. While the selected remedy effectively

reduces the hazards posed by all of the contaminants at the

site/ it costs approximately $10 million less than the onsite

incineration alternative. Additionally/ the cost-efficiency

will be furthered by value engineering conducted during the

remedial design. Treatability testing to determine the optimal

reagent and its concentration for the solidification will

also improve cost-efficiency of the remedy.

Utilization of Permament Solutions to the Maximum Extent

Practicable :

EPA has determined that the selected remedy represents

the maximum extent to which permanent solution and treatment

technologies can be utilized in a cost-effective manner for the

Craig Farm Site. Of those alternatives that are protective of

human health and the environment and comply with ARARs/ EPA

has determined that the selected remedy provides the best

balance of tradeoffs in terms of long-term effectiveness and

permanence/ reduction in toxicity/ mobility/ or volume achieved

through treatment/ short-terra effectiveness/ impleraentability,

cost, and also considering the statutory preference for

treatment as a principal element.

301480
36

While the selected remedy does not offer as high a degree of

(^ long-terra effectiveness and permanence as the incineration alternative, it will significantly reduce the inherent hazards posed

by the source material through stabilization such that the

residual material that remains to be managed can be contained

with a high degree of certainty over the long term. Since

the remaining material will be bound up/ even if the containment

system were to fail, the impact on human health and the environment would be minimal.

The selected remedy treats the principal threats posed by the

source materials and soils only slightly less effectively than the

incineration. The selected remedy is as least as effective as all

the all other treatment options in the short-term, requiring

only six months to implement as opposed to possibly four years for

incineration. The implementability of the selected remedy

is comparable to the non-treatment options, and significantly

better than the incineration option. The selected remedy is

also one of the two least expensive treatment options, and costs

significantly less than both incineration and offsite disposal.

The selection of treatment of the source material is

consistent with program expectations that indicate that toxic

and mobile wastes are a priority for treatment and often necessary

to ensure the long-term effectiveness of a remedy. The major

tradeoffs that provide the basis for this selection decision

. are short-term effectiveness, implementability, and cost. The

N^ selected remedy has better long-term effectiveness than in-situ

treatment which is the only other treatment remedy that is

less expensive. Excavation, solidification and onsite landfilling (3B) is therefore determined to be the most appropriate

solution for the Craig Farm Site.

Preference for Treatment

By treating the source material with a solidification/

stabilizing reagent, the selected remedy addresses one of the

principal threats posed by the site through the use of treatment technologies. Therefore, the statutory preference for

remedies that employ treatment as a principal element is

satisfied.

301481
37

FINAL RESPONSIVENESS SUMMARY

FOR THE CRAIG FARM SITE

PERRY TOWNSHIP, PENNSYLVANIA

The U.S. EPA established a public comment period from

August 25, 1969 through September 25, 1989 on the Remedial

Investigation and Feasibility Study (RI/FS) and the Proposed

Plan for the Craig Farm Site in Perry Township, Pennsylvania.

The RI/FS and other site-related documents utilized by the

EPA to select a preferred remedial alternative are included

in the site repository and have been available to the public

since the beginning of the public comment period. The purpose

of this Responsiveness Summary is to summarize comments on

these documents as expressed by local residents, and other

interested parties during the public meeting, and to provide

EPA's responses to the comments. The only written comments

that were received during the public comment period was a

single letter from Beazer. The EPA responses to the comments

in the letter are listed after the responses from the public

meeting.

Summary of Major Comments and EPA Responses

A public meeting was held on the Proposed Plan at the

Petrolia Fire Hall on September 13, 1989 at 7:00 P.M.

Those attending the meeting included representatives from

EPA, PADER, and approximately 20 members of the general

public. During the meeting, EPA staff presented an overview

of the background of the site, the nature and extent of

contamination, the alternatives that have been considered for

site contamination, and EPA's preferred alternative for

remediating the sources of contamination. Following the

presentation, EPA staff answered questions from the citizens

about the site.

Questions received during the meeting are summarized

below and are categorized into the following topics: 1)

Responsible Party Involvement; 2) Extent of Contamination;

3) Potential Health Hazards; 4) Site Remediation; 5)

Miscellaneous. Each comment is followed by EPA's response.

All significant questions and comments made during the

public meeting are included in this responsiveness summary.

A complete transcript of the meeting is available for

public review as part of the Administrative Record established

for this site at the Karns City Area High School, Karns City,

Pennsylvania.

1). Responsible Party Involvement -

Several questions were asked about the responsible

party, and their role in both the RI/FS, and the future

remediation of the site. Citizens were concerned about oni 4on

the responsible party's ability to properly remediate the O01482

site. EPA staff explained that the responsible party

performed the RI/FS under the direction and supervision
38

of both the EPA and PADER. Any future remediation, if

performed by the responsible party, would also be performed

under the same supervision.

Extent of Contamination

2) A citizen asked how far the contamination extended from the

two disposal pits on the Craig Farm Site* EPA staff . explained

the extent of contamination, and also said that the contaminants

i.rom the site did not in any way impact the Allegheny River.

Human Health Threat

3) A question was asked about the human health risk that is

associated with the site. EPA staff explained that the site's

impact on human health is negligible. EPA staff also advised

the citizens not to drink water from the Unnamed Creek.

-.£ Remediation

question was asked about how long it would be before the

remediated. EPA staff explained that the remedial

d remedial action would be completed in approximately

xneous

A citizen asked about the possible interaction of several

. rcund sites which are all located near Petrolia, Penn-

. ivania. EPA staff responded by saying that it is very

unlikely that the sites would interact in such a manner to

present a human health risk. It was also mentioned that

this type of interaction has not been studied in that area.

Written Comments and EPA Responses

Beazer wrote that the separation of the site into three

operable units needed further clarification. They also added

an explanation of what they felt was in each of the operable

units. The EPA is in agreement with Beazer as to the

separation of the site into three operable units, and the

definition of each unit.

Beazer also wanted to clarify the length of time that

the OU3 water will be collected and treated. The EPA

response is that this remediation will continue until judged

complete using a bioassay test approved by the EPA and

PADER.

Beazer wanted also express an opinion about the ground

water verification study. The ground water verification

study will be done to determine if any additional ground

water remediation is necessary at this site.

301483
Beazer Materajs ana services. Inc.

A Member of THE BEAZER GROUP

Environmental Services

436 Seventh Avenue, Pittsburgh, PR. 15219

Phone:412-227-2500 Fkx: 412-227-2042

September 25, 1989

Mr. Stephen R. Wassersug

Hazardous Haste Management Division

USEPA Region III

841 Chestnut Street

Philadelphia, Pennsylvania 19107

Re: Comments of Beazer Materials and Services, Inc.

Regarding the Craig Farm Site Proposed Remedial

Action Plan ________ _____ _. ________

Dear Mr. Wassersug:

Beazer Materials and Services, Inc. (BM&S) hereby

submits comments with regard to the Proposed Remedial Action

Plan (the Plan) dated August 22, 1989 for the Craig Farm Site in

Perry Township, Armstrong County, Pennsylvania. BM&S generally

is in agreement with the Proposed Plan as set forth by EPA

Region III with the exceptions noted below. In addition, a

number of points raised generally in the Plan require

clarification based on the technical considerations addressed in

the Remedial Investigation (RI) and Feasibility Study (FS)

prepared for this Site.

Operable Unit il

The Plan provides that Operable Unit fl (OU1) consists

of the distillation residue material in each pit area and the

adjacent contaminated soils. BM&S agrees with this

identification of the extent of OU1. and the preferred

alternative for addressing these materials. However, BM&S

believes that stabilization should be limited to the

distillation residue material which was estimated in the FS to

be approximately 5000 cubic yards. Non-residue materials should

301484

Writer* Direct Dial __________
Mr. Stephen R. Wassersug

September 25, 1989

Page 2

not be required to be stabilized by the Record of Decision

(ROD).

Operable Unit *2 ' .

Operable Unit #2 (O02) is defined as the remaining

portion of each pit area not defined as OU1 material, mainly

overburden and adjoining soils that are determined analytically

to be "clean". BM&S agrees with EPA's description -of the

operable unit. With regard to the requirement that overburden

and soils be determined analytically to be "clean", BM&S

believes that because the material in OU2 has not been

demonstrated to have health or environmental impact, a

practically based cleanup level for OU2 materials should be

50 ppm resorcinol although based upon the human health and

environmental risks examined in the RI/FS an appropriate cleanup

evel would be much greater than 50 ppm. This recommendation is

ised upon the following factors:

• 50 ppm is the lowest quantifiable detection limit

roven for resorcinol at this time;

• The lack of health or environmental risk has been

documented for levels of resorcinol in soils that greatly exceed

the 50 ppm limit. See, e.g.. Chapter 9.0 of the RI for the

Craig Farm Site (the Public Health and Environmental Assessment

document ) .

BM&S wishes to clarify that the language of the

preferred alternative on page 7 of the Plan should include the

approach adopted by the description included in Alternative 2A

described immediately above the preferred alternative on page 7.

As contemplated in the Plan, BM&S will place OU2 material back

into the pits for appropriate grading, covering and vegetation.

Operable Unit f 3 . .

Operable Unit 13 (OU3) is described as the management of

groundwater Seeps A and B located downgradient of the pits.

BM&S agrees that the preferred alternative to managing this

portion of the remedy should include the collection of 003 water

by use of a passive interceptor system and off -site treatment.

The Plan, as proposed, does not address the criteria for

determining the duration of seep collection and treatment. This

301485
Mr. Stephen R. Wassersug

September 25, 1989

Page 3

issue is of critical importance to effective implementation of

the preferred remedy. BM&S believes that management of the OU3

water should be limited to the duration of needed treatment.

Once the source of contamination is removed , the quality of the

groundwater is expected to improve dramatically over a

reasonable period of time thereby eventually eliminating the

necessity for continued collection and treatment.

BM&S recommends that the applicable cut-off criteria be

determined by appropriate testing during the remedial design

phase, possibly including an aquatic bioassay. It bears

repeating that the RI has demonstrated that no effect is

expected from the impact of the OU2 material on human health or

the environment. Therefore, because the actual environmental

impact will be the possible entry of constituents to Unnamed

Creek, the appropriate standards should be applied to the water

quality downstream of the location where seeps A and B converge.

(See sampling point 5 as indicated on Figure 5-1 on page 5-2a of

the RI for the Craig Farm Site).

In addition, BM&S believes that the parameters to be

included in the testing protocol should be limited strictly to

v . the potential constituents of concern (PCOCs) identified in the

^-^ Plan on page 2-5 of the FS for the Craig Farm Site. Moreover,

the applicable standards for determining when OU3 water

collection and treatment may be terminated (which will be

derived after appropriate testing as described above) must not

be set at a level that is below the practical quantification

limit for resorcinol or any other PCOC.

Finally, we note that the successful implementation of

the preferred remedy for OU3, as envisaged by the Plan, may

entail the cooperation of the Pennsylvania DER in modifying the

NPDES permit for the Petrolia plant to accept these additional,

albeit minimal, flows.

Groundwater Verification Study

Although the currently available data show no risk to

the deeper aquifer at the Site, BM&S would agree to perform a

limited groundwater verification study. However, BM&S restates

its position expressed previously to Region III and the

Pennsylvania OER that such study should involve only resorcinol

and resorcinol-type compounds implemented via a limited well

system. The existing data do not support a broad investigation

30U86
Mr. Stephen R. Wassersug

September 25, 1989

Page 4

of groundwater quality. Should additional studies indicate that

concentrations of these constituents do not improve after source

removal as expected, then a further focused study may be

considered. However, this additional study should not be a

stated requirement of the ROD.

In closing, BM&S adds that we object to the sending of a

"special notice" letter to BM&S before the adoption of the ROD.

In fact, the comment period for the Plan is just ending, thereby

requiring BM&S to determine whether a good faith offer to

conduct or finance the ROD should be made to EPA before we are

certain of what will be contained in the ROD. BM&S requests

that the 60 day period for responding to the special notice

letters be stayed until the ROD issues.

Sincerely yours,

Shannon K. Craig

cc; Deborah McNaughton, PADER

Garth Connor

Billie S. Nolan, Esquire

Dean A. Calland, Esquire

801487
COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

Po8t Office Box 2063

Hanisburg, Pennsylvania 17120

Deputy Secretary for September 29, 1989

Environmental Protection

717-787-5028

Mr. Edwin B. Erickson

Regional Administrator

USEPA Region III

841 Chestnut Building

Philadelphia, PA 19107 £f^ 1 .

•fiff* fcs«..u ,— ...'..•>'*»

Re: Craig Farms Superfund Site

draft Record Of Decision (ROD)

.-:. Erickson t

The draft Record of Decision (as received September 25,

for the Craig Farm site has been reviewed by the

cment. It is understood that this draft document is in an

uoing revision process and that a final document is not yet

-dilable. Therefore, the Department is not able to comment, or

concur with, the actual final language of the ROD document at

this time. I can provide the Department's position, on a general

level, with the proposed remedy.

The proposed remedy for the Craig Farm site would

include the following!

* The primary source material will be excavated and

treated by solidification/fixation.

* A treatability study will be conducted to determine if

the proposed solidification process will effectively

stabilize the waste material. EPA and DER will jointly

determine the effectiveness of the solidification

process, based on the results of the treatability

study.

* The treated primary source material along with any

contaminated soils will be placed in a lined landfill,

which will be constructed at the site.

* Interceptor trenches will be constructed at seepage

points to collect some of the shallow groundwater for

treatment and disposal.

301488
Mr. Edwin B. Erickson - 2 - September 29, 1989

Regional Administrator

* An additional groundwater study will be conducted to

address all groundwater' (on-site and off-site) not

being collected by the interceptor trenches. All

groundwater, which is not being addressed in this ROD,

will be addressed by a later ROD.

. The state does not concur with the proposed remedy,

as currently stated in the draft ROD. The state hereby will

concur, if the following comments and conditions are included

as part of the final ROD.

* It is understood that the final ROD will contain

language which will explain that the treatability study

will evaluate the solidified test material using a

TCLP, or similar type,.leaching test. The data

generated by the tests will be used by EPA and DER to

determine the effectiveness of the treatment. A final

determination that the treatment is effective, will

require the joint approval of both EPA and DER.

' • * If it is determined that the treatment is not

effective, then the portions of this ROD related to

excavation, treatment, and on-site disposal will not be

implemented. EPA would then propose an alternative

remedy, which would be covered by a new ROD.

* Concurrent with the treatability study, an additional

feasibility study will be conducted to evaluate an

incineration remedy which would be equivalent to the

proposed excavation, treatment, and on-site disposal

remedy. This new incineration option would include

incineration of the same volume of source material as

is proposed for treatment under currently proposed

remedy (estimated to be 5000 cubic yards), with the ash

and the remaining contaminated soil being placed in an

on-site landfill. This new incineration option would

be considered as an alternative to the currently

proposed remedy, if it is determined that the

solidification process is not effective.

* It is understood that this ROD only addresses the

groundwater which will be collected by the collection

trenches. All other groundwater, on-site and off-site,

and including the shallow groundwater not collected by

the trenches, will be addressed as a separate unit in

an additional groundwater study, which will be covered

by a later ROD. 301489
Mr. Edwin B. Brickson - 3 - September 29, 1989

Regional Administrator

* The collection trenches, as proposed in the draft ROD,

only collect a small portion of the shallow aquifer.

The final design of these collection trenches must

attempt to maximize collection of contaminated

groundwater, and these details will be addressed during

the remedial design process.

* The groundwater collection and treatment will continue

until the collected groundwater reaches background

concentrations, or until the PCOCs are below detection

limits, or until otherwise determined jointly by EPA

and DER.

* EPA will assure that the Department is provided an

opportunity to fully participate in any negotiations

with responsible parties.

* The Department will be given the opportunity to concur

with decisions related to the design of the remedial

action, to assure compliance with DER design specific

ARARs. (ie. landfill siting criteria)

* The Department's position is that its design standards

are ARARs pursuant to SARA Section 121, and we will

reserve our right to enforce' those design standards.

* The Department will reserve our right and

responsibility to take independent enforcement actions

pursuant to state and federal law.

* This concurrence with the selected remedial action is

not intended to provide any assurances pursuant to SARA

Section 104(c)(3).

If you have any questions regarding this matter please

do not hesitate to contact me.

i > Deputy Secretary

r

".' McClellan

301490
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

641 ChMtnut Building

Philadelphia, P»nn«ylvanla 18107

v """'; ' ' ' C'.r • :-; >

Mr. James Snyder

Director/ Bureau of Hazardous Waste

Pennsylvania Department of

Environmental Resources

P.O. Box 2063

Harrisburg, PA 17120

Re: Concurrence Letter for the Craig Farm Site

Dear Mr. Snyder:

I am writing to you about DER's concurrence letter for

the Record of Decision (ROD) at the Craig Farm Site, which

was received by the EPA on October 6f 1989. The ROD went

through a number of changes during the last week of September,

and it was signed on September 29, 1989. A number of comments

were received from both Jim Shack and David Crownover of DER

during that week, and changes were made to the ROD to incorporate these comments.

There are two differences between the final ROD and the

conditions in the state's concurrence letter that require

further explanation because they weren't anticipated by the

EPA. The state requested a feasibility study to further

evaluate the incineration remedy. The ROD states that other

remedial alternatives will be examined j^f the solidification

is not found to be effective in the treatability study. Thus,

the incineration remedy will only be examined if the solidification process is not effective. Secondly, the concurrence

letter also mentions that the ground water collection system

will be in operation until the collected ground water reaches

background concentrations, or until the PCOCs are below

detection limits, or until otherwise determined jointly by

EPA and DER. The ROD states that the completeness of the

remediation will be done by periodically analyzing the

wastewater using a bioassay test for resorcinol approved by

the EPA.

If you have any questions, do not hesitate to contact me.

Sincerely,

Thomas C. Voltaggio

Director, Superfund Office

Hazardous Waste Management Division-.

301491