r

RECORD OF DECISION * .

REMEDIAL ALTERNATIVE SELECTION *%,

fy Site: Moyer Landfill Site, Collegcville, Pennsylvania

Data Reviewed;

The following documents describe the analysis of cost-effectiveness

and feasibility of remedial alternatives for the Moyer Landfill Site. I

have been briefed by my staff on their contents, and they form the principal

basis for my decision. Unless otherwise specified, the underlying technical

information is included in these reports:

- "Remedial Investigation Report", (Draft), Moyer Landfill Site,

Collegeville, Pennsylvania, (IMS Engineers, July ,1985)

- "Feasibility Study Report", (Draft) Moyer Landfill Site, Collegeville,

Pennsylvania, (IMS Engineers, July 1985)

- "Work Plan", Remedial Investigation/Feasibility Study of Alternatives,

Moyer Landfill Site, (NUS Corp. . September 1983)

- "Remedial Action Master Plan", Moyer Landfill Site, (NUS Corp.

September 1983)

- Summary of Remedial Alternative Selection.

- Recommendations by the Pennsylvania Department of Environmental

Resources*

- Notes and outlines provided by the site receiver.

- Staff summaries and recommendations, including these attached.

Description of the Selected Remedy;

After careful review and consideration of site areas identified In

the Remedial Investigation which warrant remedial action, and of all

alternatives developed by EPA in the Feasibility Study and the alternative

developed by the site receiver in the Addendum to the Feasibility Study,

the site receiver's methane gas generation/recovery alternative can be

implemented at the Moyer Landfill Site. This phased alternative will meet

the Superfund goals of minimizing present and future migration of hazardous

substances and protect human health and the environment, while also attaining

all applicable and relevant Federal public health and environmental standards,

guidances and advisories at the point of closure (10 to 20 years)*

000001
Specifically this option proposes:

Soil cover with a permeability of 10~*/10~5 cm/sec

Erosion and sedimentation control measures

Surface water diversion

Leachate collection, treatment and discharge /

Methane gas recovery and sale * ' ffp

Security/fencing measures 5%

Ground water monitoring j

All closure activities in compliance with RCRA at the conclusion

of gas generation phase (10 to 20 years).

This alternative contemplates broad remedial work and Its Implementation

will depend upon the success of the gas generation/recovery program and

the contributions from generators and other potentially responsible

parties (PRPs). If negotiations with the FRPs fail and/or the methane

gas alternative falls, EFA and PADER recommend Remedial Action Alternative

4.2. This alternative is the cost-effective remedy and will satisfy as

well all of the contamination and migration objectives identified in the

Remedial Investigation*

Specifically this option proposes:

* Miscellaneous work preparatory to installations of RCRA cap:

grading, flattening of steep slopes, retaining walls and installations of rip-rap at areas that are most likely to be eroded.

0 Gas venting and gas monitoring.

0 Surface water collection and discharge to Sklppack Creek.

0 Leachate collection and treatment that will meet the 10~° risk

level in the ground water and discharge requirements in the stream.

0 Operation and Maintenance: ground and surface water monitoring,

maintenance of the cap and treatment of leachate.

Declarations

Consistent with the Comprehensive Environmental Response and Compensation

and Liability Act of 1980 (CERCLA) (42 U.S.C 59601-9657) and the National

Contingency Plan (40 C.F.R* Fart 300), and ilOl (24) of CERCLA, I have

determined that either of the remedial actions described above, together

with proper operation and maintenance constitute remedies which mitigate

and minimize damage to public health, welfare and the environment. The

Pennsylvania Department of Environmental Resources has been consulted

and agrees with the approved remedy. These activities will be considered

part of the approved action and eligible for Trust Fund monies.

I have determined that the action being taken is appropriate when

balanced against the availability of Trust Fund monies for use at other

sites.

James

onal Administrator

EPA - Region III

000002
JEleilegeville

MOYER LANDFILL.

QUADRANGLE (Z5 M.NUT6

LOCATION MAP

MOYER LANDFILL SITE

COLLECEVILLE, PA

Scalei 1" « 2000'

000003

FIGURE 1

IMS

Engineers * Architecta. P.C.
Summary of Remedial Alternative Selection

Moyer Landfill Site

Site Location and Description

The Moyer Landfill is an inactive privately owned landfill located at

Moyer Road, R.D. #2, Collegeville, in Lower Providence Township in Montgomery

County, Pennsylvania (figure 1). The landfill was permitted for 65*5 acres

in 1976 of which 45 acres had been used by 1977; however, some dumping did

occur on unpermitted land* The site area consists of open land surrounded

by wooded areas on steep slopes* Located on the site are leachate sumps,

an office building, and a metal repair shed. Runoff from the slopes of

the landfill flows westerly Into Skippack Creek, which is located 350

feet vest of the site*

The landfill is bounded on the north by Evans burg State Park, on the

south by land owned by Providence Builders, on the east by land owned by

Howard P. Moyer and Catherine M* Moyer, and on the west by other residential land. The area immediately surrounding the landfill is sparse

residential, while large residential developments are located within one

mile of the site* The nearby Skippack Creek, which flows through Evans burg

State park, has in the past been stocked with trout*

According to local Federal Bureau of Investigation (FBI) Officials,

the landfill, during its operation, accepted a variety of solid and liquid

hazardous wastes, Including poly chlorinated biphenyls (PCBs), solvents,

paints, low- level radioactive wastes, and incinerated materials In bulk

form and/or containerized in drums* In 1972 when the Pennsylvania

Department of Environmental Resources (PADER) rules and regulations became

more restrictive, this landfill was cited, and finally in 1981, it was

closed and brought into receivership of the court* Since then, some

remedial work has been done at the site under the direction of the

receivership attorney Ms. Joanne Denworth, appointed by the U.S. District

Court under a 1982 Consent Order entered in a civil action initiated by

neighboring residents. This work was carried out by SMC Martin the

receiver's consultant. They have performed certain activities, I.e.,

design of collection systems and leachate treatabllity studies, and some

site work Including covering certain exposed areas of the landfill,

regradlng, and revegetation* Owing to increased involvement by local

residents and PADER, the site was eventually listed on the National

Priorities List (NPL) by the U.S* Environmental Protection Agency

(USEPA).

Although access into and around the site is limited somewhat by a

heavy growth of trees, steep slopes, streams, puddles and ponds, the site

is still accessible by foot* The entrance to the site did have a fence

and a gate at one time, limiting access to vehicular traffic. Elevations

000004
range from 275 feet above mean sea level (MSL) along the west side of the

site to 497 feet above MSL at the top of the landfill. Drainage from

site area flows westward Into Skippack Creek through direct runoff and

also via small streams located north, south, and southwest of the site^

Skippack Creek drains southwest Into Perkiomen Creek approximately 3,000

feet downstream from the site Skippack Creek is a recretional stream used

for fishing. Skippack Creek is not used for municipal water supplies.

Ground water in the site area occurs in an aquifer which has poor

water yields* The average depth of the wells in the area is 151 feet.

Wells drilled into the deeper system are often artesian due to the dense,

relatively impermeable layer of bedrock overlying the deep system.

Site History

The site had been operated as a municipal landfill from the 1940*8

until April 1981, during which time it received municipal refuse and

sewage sludges.

In the early 1970fs PADER developed and implemented more comprehensive landfill regulations. As a result, a leachate collection system

was constructed and began operating in 1972 at the Mover Landfill Site

The collection system consisted of underground drain pipes placed on top

of the bedrock at the toe of the landfill slopes. The leachate collected

in these pipes drained by gravity to earthen basins, called "Lagoon No*

1" and Lagoon No* 2", from which the leachate was to be pumped. The

concrete basins were later converted to function as pumping stations.

After the pumps were installed, the usable storage volume in the lagoons

was reduced to one or two feet because a certain amount of leachate had

to remain in the lagoons to prevent the pumps from running dry. Subsequent

testing by the PADER revealed that leachate - contaminated ground water

was appearing as springs downgradlent from the leachate collection pipe

on the northwest side of the landfill* An additional pump station was

then installed to intercept the springs and return this contaminated water

to Lagoon No. 2. Several force mains connected the collection system pumping

stations to a concrete basin (which has since been abandoned) at the top

of the landfill* From this basin, leachate was applied to the top of the

landfill and disposed of by spray irrigation.

Because of Increasingly stringent environmental regulations promulgated

by the State of Pennsylvania during the mld-1970's, the owners of the

landfill were prohibited from filling beyond the original boundaries.

The landfill owners then submitted an application to the PADER requesting

permission to expand the landfill boundaries. The original landfill was

for an estimated 5 acres. In the late 1970's, the landfill owners also

submitted an application to the PADER for a major expansion to an area

adjacent to the existing landfill, but this application was never approved

by the PADER.

000003
-3-

In the original fill area (39 acres), the waste was simply dumped, //>

compacted, and covered with earth. In the new fill area, the plans '

called for installing an impermeable liner prior to filling. Site

preparation work began on the new area In 1977. Landfllllng was reportedly

limited to this new lined area until the landfill was closed by a PADER

order in early 1981.

The early analysis on leachate from the landfill dates back to

February 1972 by Kappe Associates, done for the conventional parameters

such as BOD, COD, and nitrogen. This analysis was conducted in order to

design an aerated lagoon to treat the leachate.

Later, leachate from the landfill was sampled extensively by PADER

and to a lesser extent by EFA and by Mover's Landfill Inc., through

Lancaster Labs and SMC Martin (PADER, April 3, 1980 to March 10, 1982;

Austin, March 10, 1980; Bonder, October 3, 1980; SMC Martin, November 26,

1980). A wide range of heavy metals and organica were detected. In one

situation sulfate concentration was found to be four times higher than

USEPA Maximum Contaminant Level (MCL). The heavy metals are indicative

of sludges, both sewage and industrial, known to have been disposed of

on the site. The organics may have been components of certain industrial

sludges (i.e. from the solvent recycling or plastics industries), but

their probable origins cannot be determined at this time*

The USEPA detected several hazardous compounds In leachate emanating

from the Mover Landfill Site. These included benzene (2 to 4 ug/L),

toluene (7 to 50 ug/L), trichloroethylene (9 to 20 ug/L), tetrachloroethylene

(0*1 to 0.5 ug/L) and chlorobenzene (1 to 3 ug/L). Other compounds

detected by the USEPA include ethylbenzene (2 to 20 ug/L), vinyl chloride

(0.3 to 7 ug/L), methylene chloride (7 to 300 ug/L), chloroethane (0.7 to

2 ug/L), 1,1-dichloroethane (0.4 to 100 ug/L, and 1,1-dichloroethylene

(1 to 2 ug/L). These volatile organics in the concentrated or pure forms

are associated with industrial solvents.

From the point of view of conventional parameters such as BOD/COD,

the leachate appears to be considerably lower than the leachate emanating

from a typical landfill.

A detailed chronological profile of the development of activities

and operations at the site is presented In Appendix A. The site is listed

in Group 6 on the National Priorities List (NPL) of 418 sites, issued by

the EPA in December 1982. A work plan was developed which identified the

following data needs:

* To more fully delineate the extent and nature of ground water

contamination at the site.

* To determine the extent and nature of surface soil contamination

at particular locations.

OOOOOG
-4-

0 To evaluate ground water aquifer characteristics through pumping

tests and to record water-level readings.

to

A remedial Investigation/Feasibility Study was funded at a total

cost of $681,000 and field work began Hay, 1984.

Current Site Status

IMS Engineers conducted a soil and rock sampling, and monitoring

well Installation program at this site to define the geologic and

hydrogeologic regime of the site and areas adjacent to the site. A total

of thirteen monitoring wells have been installed. They consist of four

clusters of two wells each, one (1) deep and one shallow, located within

5 to 10 feet from each other, and five additional wells which are

interspersed around the boundary of the landfill site to give a broader

perspective of the geology and hydrogeology of the site. The shallow

wells are about 30 to 80 feet deep, and the deep wells are approximately

250 feet deep.

As Indicated by the boring samples the Mover Landfill Is situated

on a high, resistive ridge of shale, argillite and siltstone of the Lockatong

Formation, of Trlassic age (figure 2). At some of the boreholes, the rock is

disintegrated up to a depth of 40 to 80 feet, beyond which the formation

is very dense.

Permeability testing of wells has indicated the permeability of the

upper bedrock above 100 feet is about 5 x 10~5 cm/sec while below 100

feet, the permeability decreases from 1 x 10"^ cm/sec to 5 x 10"' cm/sec*

Ground water movement from the vicinity of the landfill site is generally

to the West with discharge around the toe of the fill and through seeps

along the steep valley of Skippack Creek. Hydraulic monitoring has

demonstrated that Skippack Creek is a hydraulic boundary and no flow of

leachate crosses the creek.

It is calculated that 95 to 98 percent of the flow is lateral and in

a downgradlent direction from the landfill site while 2 to 5 percent is

vertical Into the less permeable deeper aquifer zone* The rate of flow of

ground water through the fractures is in the range of 1 to 70 feet per

day. Permeability measurements at the site confirms the other investigations. The rate of leachate generation has been estimated to be at an

average rate of about 18,600 gallons per day. A leachate collection

system Installed by the owners is In a poor state of repair and is now

inoperable. Depending upon the year, excess leachate Is generated and

discharges to the Skippack Creek system during a period of 5 to 8 months

each year.

•

Data was obtained from analysis of samples taken on two separate

occasions, May 21 thru June 1, 1984 and October 2 thru 12, 1984. Samples

were collected from onslte monitor wells along with offsite monitor and

000007
GENERALIZED COMPOSITE STRATIGSAPHY

(Based on Subsurface Drilling Work)

50ft

25ft

40ft

40ft

10ft

2 FDDT KEY BED —

20ft

55ft

30ft

15ft

35ft

5ft

25ft

40ft

30ft

1 1" - 50'+/- ;20ft

Cored Thickness* «rt/*,

rox. 455' 10ft

Red AgrlLU-te

Gray

ArgiLlfte

Red AoriUrte

Red to Gray

AgrtlUte

Gray

Arglllfte

Gray

Argillm

ked to bray

AgrUUte

Gray

ArQlllftc

Gray

ArgilUre

Red to Gray

AgrHUrte

Red Aarnirte

ArgltLfte

Gap In Cored

Section

Gray .

ArgfUfte

Red AfirttUte

bray

Argltlfte

Very Fe

i

^

MOVER LANDFILL SITE

CollegeHille, PA

M//V

'°G(/J

w Limey Beds

\

<

rui

sg

§5

\ aW \ OM>

/

j-i \ __ «X

U-i. ; — • OH-

~a / ^ S / w»-

PS*r / / Z sS

S / J=

% / ^^, a

< / ^ ^

*u^wix ^r,r,u^ , t^ / *

*

Very 1

.

p

ew Limey Beds

FIGURE 2

000003

IMS

' BASE DF

Engineers • Architects, P.C.
^y'lMiS^^

. uti - . ^r^='V4j

BASE MAP IS A PORTION OF THE U&G.& COLLE5EVTLLE, PA QUADRANGLE CONTOUR INTERVAL C*

LEACEATE SAMPLE LOCATIONS

MOTEE. LANDFILL SIZE

COLLEGEVILLB, PA

(Z5 MINUTE SERIES, 1966,PHCTOREVEEDI973}.

JIG. 3*

000009

IMS

Engineers • Architects, P.c.

P.OCHESTBB *•*»• ———
BASE MAP IS A PORTION OF TOE U&&& COLLESEV1U.C, PA QUADRANGLE (T.3 MINUTE SERES, 1966, PHOTOREVSED1973).

CONTOUR WTERVALtf. '

SEEPS LOCATIONS

KOTER LANDFILL SITE

COLLEG27IUJE, PA 000010

Engineers • Architects, P.C,
-5-

domestic wells. Six leachate and six seep locations from the landfill £/#4/

site were sampled for water and/or sediment. Water sediments and fish (fieri]

samples were collected from upstream and downstream locations in Skippack *

Creek passing along its western boundary. Ground water samples from

twenty-two residential wells and thirteen newly installed monitoring

wells around the periphery of the site were sampled. These samples

were analyzed for priority pollutants, PCBs, dioxins and radioactivity*

The laboratory test results indicate that some contaminants observed In

the leachate and seep samples from the landfill site are also present in

water and sediment from the Skippack Creek, In the tissue of the fish

sampled downstream of the landfill, and in monitoring wells surrounding

the periphery of the landfill alte.

The occurence, distribution and probably transport of the various

chemicals Is summarized below. This will be presented under three subheadings: Onslte Contamination, Offsite Contamination, and Contamination

Transport.

ONSITE CONTAMINATION

Six (6) leachate (figure 3) and six (6) seep samples (figure 4) were

collected. Leachate samples were analyzed for 129 priority pollutants.

One additional leachate sample was analyzed for radioactivity* The seep

samples were analyzed for pH conductivity, oxidation-reduction potential

and temperature. The landfill surface shows a number of leachate and

seep locations. These are supposedly discharging several of priority

pollutants and Beta radlonuclldes into the surface water. Therefore, the

landfill site is very unsafe for public trespass. It Is a continous

source of polluting ground and surface water with several priority

pollutants and radiation of probably hospital origin. The following is

a summary of contamination observed at the site:

* The samples are observed to be contaminated with 86 priority

pollutants and 16 metals* Although the concentration of most

of these contaminants is low, nearly all of them are contaminants

(e.g., cyanide) of concern.

* At least four (4) of the priority metals: arsenic, barium, lead

and zinc, and eight of the organic priority pollutants: trlchloroethylene, toluene, xylene, di-N-octylphthalate, 2-hexanone, and

2-butanone, bis (2-ethylhexyl) phthalate are observed to be

above ambient levels.

* Lead and barium exceed United States Public Health Service Drinking

Water Standards.

* Beta Radiation (Technetium 99) Is observed in the leachate sample

and is above World Health Organization (WHO) Standards* This contamination is suspected to be of hospital origin.

* There is no evidence of any detectable level of air pollution.

ooooii
. .-._•- . w ,,*— -.—• .-r- *r- W..ATi>' ,CT • . . -. . «.' •

BASE MAP 1$ A PORTION OF THE US.&S. CCLLEGEV1LU, W QUADRANGLE (7.3 MINUTE SERES, I9eS,PHOTOREVSEDt973).

CONTOUR INTERVAL tf. ... . . «——«, -

FIGtJHE 5' •'

LEGENDS IMS 000013

Engineers - Architects, P.C.

ROCHESTER. NEW YORK

MONITORING WELLS LOCATIONS

MOTER LANDFILL SITE

COLLEGEVILLE, PA

• Shallow Wells

Q Deep Wells
BASE MAP IS A PORTION OP THE US.&& COLLEGEVILLfi, M OUACRAN5LE (73 MINUTE SERES, S6S,PHCTOREVISED B7I).

CONTOUR INTERwaLtf. • " F1GOPE 6

MONITORED RESIDENTIAL VELLS

KOTER LANDFILL SITE

COLLEGEVILLE, PA

000013

Engineers • Architects, p.a • -/

' f t-
BASE MAP tS A PORTION OF THE ULS.&S. OOLLESEVIUJE, PA QUADRANGLE (t5 MINUTE SERES, I96S,PHOTOR£V!S£DS73).

CONTOUR WTERVAtCr. . FIGURE 7

CREEKS SAMPLE WATE1

MOYER LANDFILL SITE

COLLECEVILLE. PA 000014

Engineers - Architects, P.a
—6—

OFFSITE CONTAMINATION

—————————————— Thirteen monitoring wells (figure 5), twenty-two residential wells

(figure 6) bordering the landfill site, Skippack Creek flowing by the

western boundary of the landfill site, Perkiomen Creek accepting flow

from Skippack Creek, and fish from Skippack Creek (figure 7) were

sampled for priority pollutants, metals, organics, PCBs, dioxins, and

Beta radiation. The following is a summary of the contamination observed

off the Noyer Landfill Site.

* The residential wells bordering the landfill site do not show

any detectable levels of organic or inorganic pollution. This

water meets all Federal USEPA Drinking Hater Standards and is,

therefore, safe for human consumption.

* The Skippack Creek shows detectable levels of contamination.

Those contaminants are: toluene, chloroform, 2-hexanone, bis (2-

ethylhexyl) phthalate, dl-N-octylphthalate» manganese, Iron and

possibly nickel. The concentrations of these contaminants are

very low. However, these contaminants are present and their

source can be traced back to the landfill. The creek water meets

all Federal, USEPA, and State of Pennsylvania Drinking Water

Standards and is therefore safe as a raw water supply source*

* The fish in the creek also show detectable levels of contamination.

The contaminants observed were lead, 0-xylene, 2-hexanone, TCE, 2-

butanone, toluene, di-N-octylphthalate, Again, the concentrations

of these contaminants are very low. None of these contaminants

exceeds FDA standards of fish consumption of this fish by humans.

The contaminants detected can be traced back to the landfill.

* The shallow monitoring wells installed around the periphery of

the landfill site show substantial concentrations of some contaminants* These wells are located on the western boundary of the

landfill site. The direction of ground water flow is also to the

west, northwest, and southwest* These contaminants are arsenic,

lead, barium, and nickel. The concentration of barium is 3,500

ug/1, whereas the USPHS standard is 1,000 ug/1. The concentration

of lead observed is 230 ug/1, whereas USPHS is 50 ug/1. The

DSPRS is considering revising the standard for lead. This is

expected to be more stringent than 50 ug/1. Both barium and

lead are toxic to humans. The arsenic concentration

observed is 25 ug/1, whereas the USPHS standard is 50 ug/1.

000015
-7-

* Thirteen monitoring wells and one residential well were tested

for radium 226, Gross Alpha and Gross Beta radiation. Monitori

wells MW 5, 8, and 10 contained Beta radiation varying from a

to 124+20.3 pCl/1. These three wells are shallow wells and are

the most contaminated of the thirteen wells drilled at this site*

The residential well water Indicated very low levels of radiation

including Beta radiation. The WHO guideline for Beta activity

is 27 pCt/1.

Evidently the radiation activity in monitoring well water far

exceeds the maximum recommended for drinking water* In order to make a

proper health and environmental impact of this contaminantv it is

essential to determine the exact nature of this contaminant at its

Isotope level and also possibly identify Its source. For this purpose,

samples from these wells were collected again. The Analytical test

results are indicated in Tables 1 and 2.

* Potassium-40 is a naturally occuring isotope that may have been

contributed by the large amount of suspended material present in the

collected samples* The Technitium-99 may be attributed to hospital

wastes buried at the site.

" The shallow ground water is also contaminated with several of

the other organic contaminants found in the creek water, sediments,

and fish. Therefore, the shallow ground water flowing west and

northwest of the landfill site is substantially contaminated.

0 The vegetation and trees on the western boundary of the landfill

site show stress.

CONTAMINANT TRANSPORT

There are numerous seeps at the site that are either seeping

lightly or leaching heavily contaminated water from the landfill*

Eighty six organic priority pollutants and sixteen priority

pollutant metals have been observed in the samples from the site.

There are three mechanisms of transport of the contaminants from

the site: air, surface water and ground water.

No detectable levels of contaminants are observed in the air at

the site. Certain volatile contaminants such as toluene, xylene, and

cyanide have been detected at the site, but have not been detected

during air monitoring*

000016
Table

O

O

O

O

RADIONUCLIDE - ANALYTICAL TEST D/TA SUMMARY

MOVER LANDFILL SITE, COLLEGEV1LL3, PA

^ ii s t i t u c n t— — )

•

i-i

s

O.

55

OS

O

H

1-1

O

-

O'LEARY

RES-WELL

* 1

1 10

* 11

* 12

# 13

J 2

* 4

f 5

* 6

i 7

i S

i? 9

# 4

226 KA

Concuntrat ion:

pCi/L

0.5 1 0.1

0.4 1 0.1

2.7 1 0.1

0.2 ± 0.1

0.5 ± 0.1

0.5 i 0.1

0.4 ± 0.1

0.6 t O.I

'0.1 i 0.1

O.I J: 0.1

2.0 ± 0.1

0 > 0.1

0.2 J 0.1

CKOSS /LMIA

Concontt.- Lio n

pCi/l

2.5 1 2.5

0.1 J: 3.5

9.5 1 4.2

3.r> i (.3

1.4 I 2.3

2.3 :l. 1.9

0.8 1 2.0

8.2 J. >.2

1.6 J 1.2

2.5 * I..9

6.5 i ».0

-0.2 JL 1.7

1.8 i ->.j;

Detection

Limit

1.545

3.439

1.686

1,144

1.572

0.753

1.799

16.15

0.721

1.341

4. 056

1.519

0.629

GROSS BETA

Cuncohtrat ion

pCi/L

19.2 1 3.4

34.9 :L 6.0

IK 4 J: ^.0

2.9 J 2.3

' -0.2 J 2.5

7.7 ! 2.3

4.4 ± 3.3

92.0 I !7.6

5.3 ± 3.0

4.0 H: 2.7

124.0 -t 20.3

3.0 1 2.5

3.9 ± 2.5

Detect lot

Liiiilt

1.526

2.566

1.405

1 . 308

1.653

1.435

1.899

6.J39S

1.703

1.573

i>.-'.62

1.513

1.523

^

r*>5?
TABLE 2

ADDITIONAL RACIA.'ION A'

MOYER LANDFILL SITE, COLLEGER! LLE, PA.

Sample Identification Gross Beta Garrma Spectrun pCl/1Iter

Contaminant

Monitoring Well, MW 5 26 ± 6 Potass tun-40 27

RadIun-228 <1

Strontlun-90 1,9 *

Monitoring Well, MW 8 37 ± 7 Potass I tm-^fO

Radlun-228

Strontlui>-90

31

<1

<0.5

Monitoring Well, MW 10 32 * 7 Potass I un-40

RadIun-228

Strontlun-90

29

<1

<0.5

Leachate Water LS 2 199 ± 12 Pot ass I cm-** 0

RadIun-228

Stronttun-90

TechnetIur>-99

167

<1

<0.5

35 ± 15

Leachate Sediments, 7.8 t 0.6

LSS 2

Manganese-54

Ceslun-137

Potass Ion-40

CadnIurv-109

«0.07 ± 0.02

^0.09 * 0.02

«5.66 ± 0.07

«1.31 * 0.35

«pCI/gm Cdry)

000018
The ground water level 1* lower than the bottom of the landfill.

Therefore, ground water la not the direct vehicle of contaminant

transport from the alte. The transport of contamination is mostly due

to surface water percolation through the landfill. The exposed contaminants at the site are transported directly to the surface water bodies

(Skippack Creek and Perkiomen Creek) via surface runoff and indirectly

through contaminated ground water (upper aquifer) discharging to the

creeks* The lower aquifer Is not contaminated* Beta Radiation and

other contaminants observed in the monitoring wells (MW8 and MW4) are

the result of the transport route* Beta radiation and other contaminants

could also be transported directly via the surface water runoff from

the site to the surface water bodies* However, observed concentrations

In these receptors are low due to the enormous dilution effect in the

creeks* The shallow monitoring wells on the western boundary of the

landfill show this contamination. The majority of the pollutants

(trichlorethethylene, toluene, xylene, 2-hexanone, 2-butanone, acetic

acid methylester) observed in the monitoring wells and the surface

water bodies have high Mobility Index and are consequently easily

transported from the landfill site to these receptors.

Tables 3-5 summarize all critical contaminants associated with the

Mover Landfill*

ENDANGERMENT ASSESSMENT

The risk assessment for the Mover Landfill Site is based on hydrogeological and chemical analytical data obtained during previous

investigations and the RI conducted under this study. The objective of

this assessment Is to define the health risks associated with the

presence of hazardous contaminants on and around the site and to define

the potential environmental effects associated with the contaminants in

site-specific circumstances. In order for a health risk to occur,

contaminants having known chemical and biological toxic characteristics

must be present, actual or potential exposure pathways must be present,

and human environmental receptors must be located in the exposure paths.

Typically, the risk assessment procedures address the development of

the details of the location and demographics of the receptor population

and most sensitive environmental receivers* The risk assessment involves

assessing the significant contaminant migration routes and exposure

pathways, identifying the hazardous compounds of greatest concern, and

evaluating the possible effects In the context of probable exposure

scenarios*

The major potential contaminant transport path providing exposure

of human receptors to the landfill contaminants is the ground water

flow beneath the site* There are also several minor routes of transport

of contaminants* Volatilisation of organic and/or inorganic contaminants

000019
020000

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Contaminant

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2. Barium

X Laad

«• MengenaM

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4. Zinc

7. Bate Rattfetton

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Only one raaldentM wall WM testad for radiation

Concentration In fbh/»adlmenta. It I* In mg/kg for met«b and ug/kg for organl- i.

K wapactad concentration

t teMthan
o

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Critical O ^ . Hninu - Mobility Indexes

Contaminant

L Amnle

2. Barium

3. Load

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7. Data Radiation

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14. Bla (2-athythwyl)

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0-82

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10-24 5-25 10-11

49-261 50-3500 28-416

0-32 1.4-230 5-41

670-2420 23-7160 5-818

6.6-18 98-202 40

35-124 5-931 13-2070

33-144 •*.*

6.J

10-41 /

14K

140-590

41-1145 39-160

fl a ), CollagBviaa, Penmytvania

(•CD VAtlOH

i5ta*fc Sampw rvai

W-'tar m/kg ar ug/tojar

2-10 tl

47-1 13-57 2

4.4-28 0- ,76

18- 1 64-420 6

5-1- 0-9.7 0-2

11-62 4-14

4.7

3 25-27

23 8-10

8 188-1760

4 23 98

80

274- 52 120-895 2700-5280

SohfclUty Soil

Vapor In AfMorp.

fVaavjra Water Spadfk; Portlt.

at 2 (PC at 2CPC Gravity Co*f f.

60 1.100 1.46 120

22 520 0.867 390

5 180 0.88 760

1J* 0.285 0.99 49,695

2 35,000 0.83 13.8

24 125,000 0.808 6,85

tO. 01 0.4 0.99 41,000

Phtnalat*

15. Acetic AcM aa4

M«tnyl*«C*r

22-546 72-172 20 252,63

ro

* Only ana raldantlal wall WM tMtarf for ratflatlon

*• Concantratlon In flaVvmllmanto. ft to bi mgfttg tor metali and ug/kq for org nlc i.

t ThlavaporpraaHraltat 200°b

K ampectad concentration

L leai than

1.049 16.5

W««ar

PartlU

Cnefr. Honiuy

KOW

190

49U

1,400

2.7

1.5

0.08

0.36ft 3.7

0.102 5.64

0.512 4.49
-9-

to ambient air, with the contaminated air moving off site, has not been

observed at the Mover Landfill Site. Surface water runoff mixed with (ft

contaminated leachates emanating from the deposited wastes at Skippack

Creek, may affect the environment and surface waters of Skippack Creek,

and, consequently, may have a possible impact on the human health and

aquatic environment.

Potential receptors include nearby users of ground water for

drinking and all other purposes, persons using local surface waters for

recreational purposes, food grown in nearby fields, and persons eating

grazing animals fed from nearby fields. They include consuming milk

of animals fed from nearby fields, consuming aquatic biota In affected

surface water, terrestrial fauna using affected aquatic animals as a

food source, vegetation that may be stressed, and onslte remediation

workers. Although the residential wells adjoining the Moyer Landfill

Site were not contaminated at the time of sampling, the monitoring

wells on the western boundary of the landfill site did show contamination

from high levels of lead, barium, and arsenic. Beta radiation is also

suspected at the landfill* There are no nearby residential wells in

the direct path of leachate flow, which use water for drinking or any

other purposes.

Individuals at risk for exposure due to Beta radiation and other

organic and inorganic contaminants would include remedial construction

workers or persons trespassing the site, who may encounter the compounds

emanating from the seeps or leachate streams. However, this exposure to

contaminants would present concentrations in the environment of brief

duration. Ingestion of low doses of Beta radiation (Technitlum - 99)

could be avoided by proper health and safety provisions for the workers

operating at the site.

ALTERNATIVES EVALUATION

Table 6 presents a brief comparison of all alternatives included in

this document. The major objectives for remedial action to be taken at

the Moyer Landfill site are to mitigate or eliminate environmental contamination through collecting and treating leachate from the landfill

and capping the site to control leachate generation and soil erosion.

The overall strategy is to mitigate and minimize harm to the public

health and the environment. This should include minimizing further upper

aquifer contamination and the possibility of direct contact with the waste.

Leachate control is an integral part of the overall scheme in order to

eliminate the continuing migration of contaminants across the site and

off the site to the Skippack Creek. Implementation of these measures

will benefit both the health of the local residents, as well as the

environment* Contamination of the food chain will be eliminated by

both the prevention of contact with the waste areas as well as the

prevention of leachate migration into the local water courses.

000023
1ABJE 6

mKNJll U KBUL MCASOU JJfD

DETCUOftKKT V BET BUL ACTION ALTEUUTIVES

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(Sec Attached)

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II SJUir--*

IAA2-1

UA1-2

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Soil Cover vith turfac*

it«r collection *nd dlt*

harge, leachate collection

d tTcatHeat. and lonfi* (round and cutf*co

•atei vonitorlne;

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collection up to 0-30 ft.

depth and treatwent at

Hoyer Landfill Sit*

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rovlslunii lc*ch«t« T«« H«

collection up to 0-60 ft.

depth and tr* at vent «C

Hoycr Landtltt Sit*

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collection up to 0-30 (t.

depth and treatment at

Oak* Treatment Plant

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collection «» to 0-40 ft.

depth and tre»teient at

Oaka Treatment Ftant

MA2-S RAAI piovltlonti teachat*

collection np to 0*10 ft,

depth and treat**nt at V«Hey

For|* riant

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collection up to 0-40 ft.

depth and tteatrefit at

Valley Forge riant

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ga* venting

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000025
-10-

The NCF specifies that remedial alternatives should be classified (f&rfi

either as source control (40 C.F.R. 300.68(e)(2)) or offsite (management '

of migration) remedial actions (40 C.F.R. 300.68(e)(3)). Source control

remedial actions address situations in vhich hazardous substances remain

at or near the areas in vhich they were originally located and are not

adequately contained to prevent migration into the environment. Offsite

remedial actions address situations in which the hazardous substances have

migrated from their original locations. Alternatives developed may fall

solely in either classification or may involve a combination of source

control and management of migration measures, as determined by the

specific site problems addressed*

In an effort to determine remedial alternatives for the subject

site, feasible technologies were identified for consideration in each

response action. Available technologies were then screened to eliminate

all but the most definitive and implementable alternatives. This

screening included: technical (site conditions or wastes characteristics),

environmental and public health, institutional, performance and cost

criteria.

Certain response actions and technologies were not associated with

any specific remedial objective or feasible technology for this site*

These technologies and response actions and the rationale for not

including them are listed on Table 7* Further detail of this initial

screening is included in Section 12 of the Remedial Investigation/Feasibility

Study.

Those technlogies which passed the technology screening process

were used to form remedial alternatives. Remedial alternatives were

developed using best engineering judgement to select a technology or

groups of technologies that best address the problems existing at the

site to protect public health and the environment.

In order to study a wide range of responses at this site, at least

one alternative has been proposed and developed in each of the five categories suggested In US EPA Guidance Document for Feasibility Studies

Under CERCLA. Also, the Receiver Remedial Action Alternative (RRAA)

suggested and prepared by the receiver attorney for the Mover Landfill

Site, is included. A brief description of the RRAA and those of the

five categories is given as follows.

* Receiver Remedial Action Alternative

The receiver proposes to meet all applicable standards by the

implementation of a closure plan that includes among other

things collection and treatment of leachate, soil cap, security

measures and a methane gas system. It is indicated that the

revenues available to the receiver shall be used to remediate

the site. The Receiver's RRAA is presented In Section 13.1 of the

RI/FS as such without any comments.

000026
•11-

TABLE 7

Rationale for Eliminating

Various Technologies

Response Action Rationale for Elimination

1* Alternative Water Supply

2* Ground Water Barriers

3. Ground Water Collection

4. Source Reduction

5. Incineration

No Residential Wells

Contaminated

Not Feasible

Not Feasible

Impossible to Identify

"Hot Spots"

Incineration Period

Estimated to be about

30 Tears, Very Expensive

Inadequate Cleanup

000027
0 */S/v*

 No action: No-action alternatives could include monitoring f&*J^*l

activities. '*ty

- Alternatives that meet the CERCLA goals of preventing or

minimizing present or future migration of hazardous substances

and protecting human health and the environment, but do not

attain all of the applicable or relevant standards (This

category may include an alternative that closely aproaches but

does not meet the level of protection provided by the applicable

or relevant standards).

- Alternatives that meet the CERCLA goals and attain all applicable

or relevant federal public health or environmental standards,

guidance, or advisories*

- Alternatives that exceed all applicable or relevant federal public

health and environmental standards, guidance, and advisories.

- Alternatives specifying offsite storage, destruction, treatment,

or secure disposal of hazardous substances at a facility approved

under the Resource Conservation and Recovery Act (RCRA). Such a

facility must also be in compliance with all other applicable EPA

standards.

The evaluation criteria selected were: technical feasibility, public

health, environment, institutional evaluation, land cost effectiveness.

Particular emphasis was placed on:

- Technical Feasibility

- Performance

- Implementabillty

- Reliability

- Public Health Evaluation

0 Reduction of Health Impacts

- Environmental Evaluation

* Reduction of Environmental Impacts

* Protection of Natural Resources

- Institutional Evaluation

* Legal Requirements, Institutional Requirements

* Community Impacts

- Cost Effectiveness

* Capital Costs

* Operation and Maintenance Costs

* Present Worth Values

* Sensitivity Analyses

000028
,-13-

Technologies remaining after the initial screening were combined in "

logical groups called components in order to fit into the five different

categories mentioned above* These components were then combined to form

various remedial alternatives.

Description of Remedial Alternatives

Receiver's Remedial Action Alternative (RRAA)

The Receiver's Remedial Action Alternative (RRAA) is intended to

accomplish the closure of the facility using best engineering judgement

to select technologies to address problems at the site consistent with

requirements and objectives outline In the National Contingency Flan

(NCP). In particular, the program is designed to avoid significant

adverse environmental impacts, while at the same time providing adequate

control to keep chemicals onsite or to prevent their offslte migration

at levels having a detrimental and adverse effect under minimal circumstances of threat or harm to public health, welfare or the environment.

In this connection, the RRAA takes into consideration:

1. the extent to which chemicals are a danger to public health,

welfare or the environment.

2* the extent of chemical migration.

3. previous experience in similar situations, and

4* environmental effects and welfare concerns.

The RRAA can be classified as a phased source control remedial action.

The RRAA provides for an interim soil clay cap as indicated under

the section entitled "Soil Cap" composed of a material having a permeability

of 10"4/10~5 to a depth of 36" which will substantially reduce rain

water infiltration into the landfill site. Also provided will be surface

water collection and discharge to the Sklppack Creek, long term ground

water and surface water monitoring, collection and treatment of residual

leachate, extraction, scrubbing and upgrading of methane gas for delivery

to the Philadelphia Electric Company (FECO) instead of gas venting to

the atmosphere*

The provision of the interim soil clay cap will partially reduce the

problem of erosion of existing cover material and minimize transmission

of contaminated material from the landfill site. It will also partially

reduce the generation of rain Induced leachate by decreasing rain water

infiltration Into the landfill.

000029
-14-

The leachate collection and treatment system proposed in the RRAA

are designed to intercept leachate for the entire periphery of the

landfill. The leachate collected will be treated at a plant constructed

as the site with the effluent subject to a NFDES permit discharged to the

Skippack Creek. After completion of methane gas collection, the site will

be closed in compliance with RCRA standards.

Ground water monitoring, storm water management and erosion and

sediment control together with site security as proposed by the Receiver

are intended to meet all requirements applicable to the site.

Methane Gas Recovery

Information supplied by the EPA and independent measurements at the

site indicate that solid waste tonnage present may range from 4 million

tons of uscable wastes up to 5.8 millions tons. Of these tonnages,

significant amounts are belived to be composed of sewage sludges and

other similar wastes rich in gas production potential.

Assuming that 4 million tons of solid waste are present at the site,

Mandeville & Associates (M&A) estimates that approximately 1.5 million

cubic feet per day of raw landfill gas can be generated for a period of

close to a decade. Additional tonnages, not accounted for, could permit

the production of greater amounts of landfill gas.

The 1*5 million cubic feet of gas per day is estimated to have a

methane content of 58Z, and, after processing, approximately 625,000 cubic

feet to 700,000 cubic feet of pipeline standard gas per day could be

available for introduction into the PECO pipeline. Such production

numbers would be dependent upon various contingencies including:

1. Confirmation of gas availability from the landfill.

2. The usage of available methane gas to run the facility, and

3. Efficiency of the gas separation system.

At present, M&A is considering producing a high Btu gas (950 Btu*s

per standard cubic foot) comparable to processed natural gas for sale to

PECO through the use of Monsanto PRISM gas separators* These separators

incorporate proven technology to upgrade and "clean" the methane gas

extracted from the site in order to produce pipeline quality gas. Additional processing steps may be required in the event that trace elements

of certain hazardous materials are found in the gas.

The system will include, among other things, construction of a system

of gas collection wells together tied into a common manifold, gas compressor,

membrane separators (the Monsanto PRISM separators), gas monitoring system,

gas pre-treater, control building, pipeline to PECO, gas measuring equipment,

and fencing security system.

000030
-15-

Current capital for the proposed gas facility is $2,873,000, including

special contingencies relating to gas production at a superfund hazardous

waste site.

Projected annual operating and maintenance costs attributable to the

gas processing facility are anticipated to be $332,000, a certain portion

of which are attributable to operations at a site containing hazardous waste.

Test wells drilled by SMC Martin at the site in 1983 provided certain

data concerning contaminants in the gas other than <X>2. Although the

gas appears "clean", the gas generated at the Mover Landfill may contain

trace amounts of toxic volatlles. To the extent that additional contaminants

are found, it will be feasible to install gas pre-treatment (carbon bed)

equipment to assure the delivery of gas to the pipeline meeting PECO

specifications* These contaminants will be treated.

A complete description is enclosed in the draft Addendum to the

Remedial Investigation/Feasibility Study.

Summary of RRAA

The RRAA defines the full scope of remedial work to be performed in

the immediate future. It contemplates broad remedial work and its

implementation will depend upon the success of the gas generation/recovery

program and the contributions from generators and other potentially

responsible parties (PRPe). The gases generated at the Mover Landfill

site are most likely to contain trace amounts of toxic volatiles and

gases; volatiles if any, will be properly treated. The economic

viability and public acceptability of the gas recovery program is a

proven concept in present practice in other parts of the U.S. As proposed,

this program will meet the NCF criteria of a corrective action planned

for a hazardous waste site. The contamination at Moyer Landfill site

requires remediation to mitigate the public health and environmental

concerns; the gas recovery program and leachate collection system will

address and remediate the concerns. After completion of methane gas

collection, the site will be closed in compliance with RCRA standards.

The following remedial alternatives and sub-alternatives below have

been prepared by IMS Engineers for the EFA. A detailed description and

evaluation of each alternative are presented as follows:

A. No Action Alternative

Alternative No. 1 - No Action with Monitoring

Under the no action alternative, additional remedial activities

would not be performed. However, a long-term monitoring program would be

established to provide information on contaminant concentration remaining

and extent of potential migration. The monitoring program would include

ground water, surface water, sediment sampling, and respective analysis.

000031
The Remedial Investigative work confirmed the presence of heavy £

metals and the organic contaminants of concern in the monitoring wells, (fieri]

creek waters, leachate samples, sediments and fish* Some of these '

contaminants are arsenic, barium, lead, nickel, zinc, trichloroethylene

(TCE), toluene, xylene, dl-n-octylphthlate, 2-hexanone and 2-butanone

methylethyl ketone (MEK). Besides, the shallow aquifer on the west and

southwest of the Moyer Landfill exhibits contamination with Beta radionuclldes, lead, and barium* Therefore, the no-action-monitoring program

should include analysis for all contaminants. Since fractures in the

geologic formations can provide a pathway for migration of contaminants

Into the lower aquifer, it Is necessary to monitor the ground water. The

lower aquifer was not found to be contaminated. Monitor wells constructed

during the RI phase of this study could be used for monitoring migrating

contaminants downgradient from the site.

Surface waters are potential receptors for leachate that seeps from

the deposited wastes. Also the shallow (upper aquifer) ground water has

a potential for contaminating nearby surface waters. These surface waters

may be used for bathing, Irrigation, lawn watering and recreational uses

as well as providing a habitat for aquatic organisms* Under these circumstances, the sampling stations should include the creek, some selected

residential wells and monitoring wells constructed during the RI phase of

the study.

Notwithstanding that the RI study showed none of the residential wells

were contaminated, monitoring of selected residential wells is vital since

the water is being used for human consumption. The residential wells recommended for monitoring are 1, 6, 7, 11, 16 and 19 as shown in figure

6* Due to seasonal variations, sampling and analyses should be conducted

at least once every three months* For costing purposes, It is assumed

that this program would be continued for 30 years.

This alternative will not reduce or eliminate any of the impacts resulting from the landfill* It will be effective In providing information

about the movement of the contaminants, so that, if necessary, future remedial actions could be taken. The site would continue to be a source

of contamination. This landfill will continue to produce leachate that

will cause ground water to continue to exceed 10~6 risk levels offsite.

The possibility of the public coming into direct contact with the hazardous

substances or leachate would remain. Contamination of nearby surface

waters would continue as leachate flows unchecked offsite. There would

be no capital costs for this alternative.

B. Alternatives that meet the objectives of CERCLA (RAA2)

Alternative No. 2 - Soil Cover with Surface Water Collection and Discharge,

Long-Term Leachate Collection and Treatment and Long-Term Ground Water

Surface Water Monitoring.

000032
-17-

This alternative proposes to collect surface vater from the landfill

site and proposes to discharge to the Skippack Creek. It proposes to

collect leachate up to 0-30 feet depth for the entire periphery of the

landfill* These vary from a minimum of 5 feet depth on the Northeast

boundary to a maximum of 30 feet depth on the western boundary of the

landfill site. It Is presumed that up to 50X of leachate generated

might be intercepted by this alternative. In order to assure a much better

interception of leachate (80%), it Is proposed to intercept leachate up

to 60 feet depth from the western boundary of the landfill site. The

depths of interception of leachate on the other parts of the boundary of

the landfill stay the same. The leachate collected could be treated at a

plant constructed at the Moyer Landfill Site and the effluent discharge

to Skippack Creek* As an alternative, the leachate could be transported

to Oaks Sewage Plant or the Valley Forge Sewage Plant for treatment and

discharged along with the plant effluent for the purposes of evaluation

of this alternative and more specifically development of costs.

Remedial Action Alternative 2 will be sub-divided as follows:

RAA2.1 Leachate collection up to a maximum of 0-30 feet and leachate

treatment at Moyer Landfill Site.

* Soil cover, 4 feet thick (Including top soil for vegetation)

* Surface water collection and discharge to Skippack Creek

* Leachate collection at depths up to a maximum of 30 feet

0 Leachate treatment at onsite treatment plant

RAA2.2 Leachate collection up to a maximum depth of 0-60 feet and

leachate treatment at Moyer Landfill Site*

* Soil cover, 4 feet thick (Including top soil for vegetation)

* Surface water collection and discharge to Skippack Creek

* Leachate collection up to a maximum of 60 feet

* Leachate treatment at onsite treatment plant

RAA2.3

* All Items similar to RAA2.1, except that leachate is collected,

transported and treated at Oaks Sewage Treatment Plant.

RAA2.4

* All Items similar to RAA2.2 except that leachate is collected,

transported and treated at Oaks Sewage Treatment Plant.

RAA2.5

* All items similar to RAA2«1 except that leachate is collected,

transported and treated at Valley Forge Sewage Treatment Plant.
-18-

RAA2.6

0 All Items similar to RAA2.2 except that leachate Is collected,

transported end treated at Valley Forge Sewage Treatment Plant.

Soil cover has been demonstrated to be a fairly effective method of

excluding a substantial portion of rainwater from the wastes that are

being covered with soil. The expected useful life of the cover system

proposed herein is unlimited if the soil cover is properly maintained.

This can be accomplished by filling in natural soil for any settlements

caused in the line and grade of the cover. Also proposed unit processes

for treatment of leachates are conventional technologies and are known

to perform adequately.

Percolation of precipitation Into the fill and into the waste would

be reduced by the proposed soil cover; however, leachate will continue to

be generated. The leachate collection and treatment will considerably

reduce the ground water contamination. Therefore the ecological receptors

will have reduced exposure to the contaminants. It is assumed that a

larger percentage of the leachate will be collected by using this alternative; however, if meticulous maintenance Is not carried out periodically, there Is always the possibility that cracks may occur during the

summer months and the leachate may eventually bleed out. Also this alternative does not take care of the leachate that might percolate below the

depths the leachate is intercepted* Even though it can be argued that the

contribution will be only mlminal, this alternative does not resolve the

ground water contamination completely. Emissions and discharges from the

leachate treatment process units should not adversely affect the environment

or ecological receptors if their operation meets regulatory permit levels.

This alternative provides a distinct improvement in the protection of

ground water and surface water receptors compared to RAA1 (Remedial Action

Alternative 1). The RCRA requirements stipulate provision of a soil cover

that should be less permeable than the bottom of the landfill. From this

standpoint, this alternative does not comply with the current RCRA requirements. However, this alternative does reduce the contamination of ground

water which is a major CERCLA requirement. The discharge requirement

levels will be met by way of leachate treatment*

The capital costs of construction, annual operation and maintenance

costs, present-worth of operations and maintenance costs for 30 years and

the total present-worth cost are presented in detail in the RI/FS. These

costs estimates incoprorated the sensitivity analysis for those Items of

work, the costs of which are likely to vary during implementation of this

alternative. Depending upon the sub-alternative, the capital costs of

construction vary from $10,557,500 to $23,881,500, the annual operation

and maintenance costs from $254,300 to $327,000, and the total presentworth costs including present-worth costs for operation and maintenance

for 30 years, varies from $13,085,000 to $26,812,100.

000033
-19-

C. Alternatives that Satisfy All Applicable Standards (RAA3)

RCRA Cap with Surface Water Collection and Discharge to Skippack Creek,

Gas Venting and Short-term Ground Water and Surface Water Monitoring.

This alternative provides for a RCRA cap to essentially eliminate

the rainwater infiltrating into the landfill site. It also provides

surface water collection and discharge to Skippack Creek, short-term

ground water and surface water monitoring, and gas venting to the atmosphere.

This alternative does not provide for collection and treatment of residual

leachate that will be trapped once this RCRA cap is installed. Provision

of this cap will stop the problem of erosion of existing cover material

and minimize transmission of contaminated material from the landfill

site. Compared to RAA2, this alternative will substantially reduce the

generation of the rain-induced leachate by preventing rainwater

Infiltration into the landfill.

The U.S. Army Corps of Engineers (Hydrologic Simulation on Solid

Waste Disposal Sites) has developed a computer model to estimate the

amount of leachate generated by the movement of water through a multilayered system similar to the one that Is being discussed here. It has

been demonstrated that such an impermeable cap is extremely efficient in

diverting water away from the soil beneath it. On an average, 95 percent

of the precipitation that falls on the area of infiltration-control would

be diverted before it reaches the soil beneath the cover system.

The soil layers that are being contemplated for this alternative are

much more stringent and thicker than the soil cap described in RAA2. Therefore,

the quantity of leachate that is expected to be generated is negligibly

less due to the soil-clay cap option proposed here.

Theoretically, the quantity of leachate to be treated would be the

residual leachate that is captured within the site due to the construction

of the cap. For all practical purposes, that water that is percolating

through the landfill is assumed to be just enough to saturate the landfill

wastes, but practically no excess leachate bleeds out; it is the excees

leachate that normally bleeds out, and in this theoretical case, there

would be no excess.

This frequently applied capping technology has demonstrated the

ability to effectively eliminate infiltration and minimize subsequent

leachate generation. Capping is perhaps the most consistently recommended

remedial technology for waste disposal sites. Gas collection and venting

are also reliable, remedial technologies.

000034
-20-

Maintenance of this alternative is relatively minor and stralghtforw

O&M for RAA3 is considerably less than O&M for RAA2. Periodic inspection

of the soil and vegetative cover and of the gas collection system will be

required to ensure proper operation. Any problems resulting with the gas

collection systems or the cover layer must be corrected. Post-closure,

ground water monitoring, and analysis will also be required for this

alternative.

Under this alternative it is not proposed to collect the leachate

that may be given off by the waste material trapped under the RCRA cap.

These wastes have a high moisture content, and would be expected to

produce leachate for five to ten years* This leachate will be continuously

discharging into the ground and or surface water. The discharge of

leachate into surface water is not, however, through the surface run-off

but leachate discharges into the Skippack Creek through ground water.

All hydrogeological evidence indicates that the creek acts as a sink for

the ground water from the landfill site* The impact of this leachate on

ground water and surface water and other environmental and ecological

receptors cannot be estimated at this time. Realistically, a major

concern that remains is that the upper aquifer might be infiltrated

laterally as well as vertically. If this is the case, the site will

continue to generate leachate that could migrate into the lower aquifer

through fractured bedrock. However, the implementation of this alternative

does have the provision for ground water and surface water monitoring.

This provision will assist in making an assessment if the environment

is effected in the future.

Soil having permeability of less than 10~7 cm/sec, is not available

in the vicinity of the site* The closest source for the clay is at a

distance of more than 20 miles. This factor will significantly increase

the cost of this alternative. However, the other major components and

ancillary needs for contruction of a cap are obtainable close to the

site. There are no internal site restrictions that would prevent a timely

completion of this technology* Implementation of this alternative is

more efficiently performed during dry weather and could be completed in a

6-month period from May to October* Scheduling of materials, labor, and

equipment should be done so that they are available onsite when needed.

The capital costs of construction, annual operation and maintenance

costs, present-worth of operation and maintenance costs for 30 years, and

the total present-worth costs are presented in detail in the RI/FS*

These cost-estiamtes incorporate the sensivity analysis for those items

of work, the costs of which, are likely to vary during the implementation

of this alternative. The capital costs of construction for the alternative

vary from $16,777,700 to $20,506,000; the annual operation and maintenance

costs vary from $222,300 to 271,700, and the total present worth costs,

including present-worth costs for operation and maintenance for 30/5

years, vary from $18,290,100 to $22,354,400.

000035
-21-

D' Alternatives that Exceed All Applicable Standards (RAA4)

This alternative contains all the provisions made in RAA3. It also

proposes the following additional provisions under this alternative:

* Residual leachate will be collected, treated, discharged.

The residual leachate will be collected and treated In the same

manner as the leachate generated, collected, and treated under Remedial

Action Alternative 3. Additionally, included in this alternative is the

collection of leachate from 0 to 30 feet and 0 to 60 feet. For the

purposes of evaluation of this alternative and, more specifically, for

the development of costs, the RAA4 will be divided as follows:

RAA4.1

* Miscellaneous work preparatory to installations of RCRA cap:

grading, flattening of steep slopes, retaining walls and installations of rip-rap at the areas that are most likely to be eroded.

* Surface water collection and discharge to Sklppack Creek

* Leachate collection between 0 to 30 feet depth and treatment

at Moyer Landfill Site*

RAA4.2

* Same as RAA4.1 except the leachate shall be collected between 0 to

60 feet*

RAA4.3

* Same as RAA4.1 except the leachate will be treated at the Oaks Sewage

Treatment Plant.

RAA4.4

0 Same as RAA4.2 except that the leachate will be treated at the

Oaks Sewage Treatment Plant.

RAA4.5

* Same as RAA4.1 except that the leachate will be treated at the

Valley Forge Sewage Treatment Plant.

RAA4.6

* Same as RAA4.2 except that the leachate will be treated at the

Valley Forge Sewage Treatment Plant.

000036
-22-

* ORIGINAL

(Red)

In spite of the fact that interception of the maximum amount of leachate

is proposed, (an estimated 802), it may not be possible to collect all the

leachate. However, some leachate will still percolate to ground water.

Based on the findings of the RI, 21 of the uncaptured leachate would migrate

vertically and the other 18Z would discharge into the creek. Short-term

ground and surface water monitoring might help assess the impact and also

indicate any potential future monitoring.

Under this alternative, the leachate would be collected and treated

to meet the 10-6 risk levels in the ground water and discharge requirements

in the stream. This is estimated to take 5 years* Secondly, the quantity

of leachate that is expected to be generated under alternative RAA4 is less

than 50Z of what would be generated under RAA2 (15,000 gpd vs. 30,000 gpd),

unless the upper aquifer is being recharged laterally.

As pointed out under RAA3, soils having permeability of less than 10~?

cm/sec are not available in the vicinity of the site. The closest source of

supply of the required cover material is at a distance of more than 20 miles.

This will consequently greatly increase the cost of this alternative. However,

the other major components and ancillary needs for construction of a cap are

obtainable close to the site. There are no local site restrictions that

would prevent a timely completion of this technology. Implementation of this

alternative is most efficiently performed during dry weather and could be

completed In a 6-month period from Hay to October. Scheduling of materials,

labor, and equipment should be done so that they are available onslte when

needed.

The public and environmental health benefit of this alternative has been

discussed in RAA2.

The cap will comply with current RCRA requirements, which require that

the cap should not be less permeable than the bottom of the landfill. The

regulations also require elimination of ground water contamination, which

this alternative addresses through residual leachate collection and treatment.

As part of RCRA requirements for closure of existing land disposal facilities

(part 265), RCRA provides that no synthetic liner is required If the unit

does not have synthetic underllners to effectively control the quantities of

leachate produced presently. Monitoring of ground water and surface water,

leachate treatment, and maintenance of the cap would be part of the operations.

This alternative exceeds all the institutional requirements, with no additional

public or environmental benefits.

000037
-23-

ORIGINAL

(Red)

13.4.4.6 Cost

The capital costs of construction, annual operation and maintenance

costs, present-worth of operation and maintenance costs for 30/5 years and the

total present-worth cost are presented in detail in the RI/FS. These cost

estimates incorporate the sensitivity analysis for those items of work, the

costs of which are likely to vary during the Implementation of this alternative*

Depending upon the subalternatlve, the capital costs of construction will

vary from $21,200,000 to $36,585,300, the annual operation and maintenance

costs vary from $287,700 to $377,410, and the total present-worth costs

including present-worth cost for operation and maintenance for thirty/five

years, will vary from $23,912,500 to $40,153,100*

E. Alternatives that Specify Offsite Disposal (RAA5)

This alternative consists of constructing a new RCRA landfill site

on an area of land adjacent and upstream of Moyer Landfill Site. The

waste materials shall be excavated from the Moyer Landfill Site and

disposed of at the new landfill site. The existing site shall be minimally

graded and revegetated. Ground water and surface water monitoring programs

as in other alternatives, shall also be implemented for a period of five

(5) years.

The Moyer Landfill Site currently covers approximately 61 acres of

which about 43.5 acres has been used for depositing waste materials* For

all practical purposes, the wastes are assumed to be dumped randomly all

over this 43.5 acres of land. The maximum elevation at the landfill is

493.5 feet. Different sectional views of the Moyer Landfill Site were

drawn in order to compute the total volume of the material contained in

the site. The volume of wastes buried on the site is computed to be

approximately equal to 7*8 million cubic yards.

Placing these wastes Into a new secure landfill involves excavation and

hauling waste material from the Moyer Landfill to a nearby onsite RCRA-approved

landfill* Contaminants would be released from the disturbed landfill through

volatilization, which would lead to possible air pollution. The level of

pollution will depend upon the location and the type of wastes buried at the

site and climatic conditions during excavation and transport of wastes*

Specialized construction/excavation techniques would have to be developed to

mlmlnize the amount of air pollution* The techniques under consideration are

the use of a temporary liner over excavated portions of the landfill and

covered trucks during any type of transportation. Excavation and hauling

would take place 16 hours each day to minimize the length of time the material

is to be exposed* The excavation of the fill can be accomplished with power

shovels. If, during excavation, any saturated material is removed, it will

be deposited on the road by draglines* This wet trash will be picked up and

moved to a dewatering pad for subsequent disposal. Water from the dewatering

pad will be conveyed and mixed with residual leachate that is otherwise being

treated and discharged into Skippack Creek.

000038
-24-

ORIGINAL

Long-term operation of an onsite disposal facility, such as the one (Red)

described here, Increases the risk of cancer, chronic health effects, and

acute health effects to offsite receptors. This occurs becuase of the

potential for emissions during storage of the waste, following excavation and

prior to processing* A similar increase in risk to users of offsite surface

water can be expected if discharges from the wastewater treatment plant exceed

the applicable health and safety water quality criteria.

Excavation of the landfill poses the highest potential for deleterious

environmental effects during the implementation of the alternatives

previously discussed* The level of Increased risk cannot be quantified.

However, two major factors that tend to increase health risk and

environmental damage under this alternative are:

- Construction activity will be more intense and of greater duration

during any of the previous options,

- The concentrated waste will be exposed to the environment and

handled routinely for a considerable length of time.

The capital costs of construction, annual operation and maintenance

costs, present-worth of operation and maintenance costs for 30/5 years and

the total present-worth cost are presented in detail in the RI/FS. These

cost estimates Incorporate the senslvity analysis for those items of work,

the costs of which, are likely to vary during the implementation of this

alternative.

Recommended Alternatlve(s)

Section 300.68(J) of the National Contingency Flan (NCP) [47 FR

31180; July 16, 1982] states that the appropriate extent of remedy shall

be determined by the lead agency's selection of the remedial alternative

which the agency determines Is cost-effective (I.e., the lowest cost alternative that is technically feasible and reliable) and which effectively

mitigates and minimizes damage to and provides adequate protection of public

health, welfare, and the environment. In selecting a remedial alternative

EPA considers all environmental laws that are applicable and relevant.

Receiver's Remedial Action Alternative

Based on the evaluation of the proposed alternatives, the comments

received from the public, information from the Feasibility Study and Information from PADER, the Receiver's Remedial Action Alternative (RRAA) can be

implemented at the Moyer Landfill Site. This phased remedy will satisfy all

of the contamination objectives identified in the Remedial Investigation at

the point of closure (10 to 20 years)*

The proposed gas recovery system will collect, clean and upgrade the

methane gas generated in the Landfill instead of venting it to the

atmosphere and provide energy for the operation of the leachate treatment

plant. The receiver will receive royalties from the sale of the gas to

PECO which will be applied toward the overall closure cost*

000039
-25-

ORIGINAL

The leachate collection system and treatment plant will eliminate

the offsite migration of untreated leachate into adjacent surface waters.

The placement of a soil cover with a permeability of 10~VlO~5 cm/sec,

will allow the most efficient recovery of methane gas, and still reduce

the generation of leachate to be collected and treated. At the conclusion

of the gas recovery program the RRAA provides for the construction of an

additional cap which will meet RCRA standards* The ground water monitoring

program will assure that necessary environmental standards are met*

It is contemplated by the RRAA that capital financing costs for the

leachate collection system and treatment plant, soil cap, soil erosion

program, security and fencing, the methane gas recovery facilities and

all other related capital expenditures will be financed through limited

partnership investment, bank financing and other capital contributions*

Operating and maintenance costs relating to the methane gas recovery

system (exclusive of those costs relating to the hazardous waste aspect

of such O&M) will be paid out of gross revenues generated from the

production and sale of methane gas at the facility* Operating and

maintenance costs for the leachate collection and treatment system and

other related costs including maintenance of the soil cap, a portion of

security and fencing, debt and/or lease rental payments relating thereto

will be paid for by the PRPS and out of royalty payments due the receiver

from the methane gas recovery program*

Capital investment for the methane gas recovery program, expected to

range from approximately $2 million and $2.5 million, will be at risk

with payment subject to the ability of the project to generate pipeline

quality gas for delivery to PECO pursuant to the contract betwen ERF and

PECO.

Revenues generated pursuant to the PECO contract are based upon the

amount of gas sold to PECO, paid for at the rate of 90% of the then

current Transco gas pipeline tariff. At the present, said tariff is

$3.55 per 1000 cubic feet of gas* ERF estimates that tariffs in effect

at the time of initial gas production in early 1986 will remain at such

level until 1987. Thereafter, annual price increases of 52 are estimated.

It Is anticipated that these gross revenues will be sufficient to

cover operating and maintenance expenses for the methane gas recovery

program, enable ERF to make necessary debt service payments and to prove

a fair return to its investors.

Capital expenses for the non-methane gas recovery portions of the

RRAA base cost is to be $3,425,500 million. Debt service on these amounts,

and operating and maintenance cost relating thereto will be paid for by

the PRPS pursuant to a closure agreement that provides security sufficient

to assure that required payments will be made.

The security for such payments aay include, provision of operating and

debt service reserve funds, letters of credit, or corporate guarantees as

appropriate under the circumstances.

000040
-26-

*j.; '

To the extent that the receiver's .interim remedial measures are •''-

insufficient to accomplish the permanent closure of the site in accordance

with applicable environmental standards, the RRAA includes provision that

the FRPS will furnish such additional funds as may be necessary to close

the site consistent with the remedial action alternative described below

and will post a bond or other security sufficient in amount to make

necessary additions and alterations to the existing interim remedial

measures so as to permanently close the site.

The above financing program contemplates initiation of design and

construction of the facilities on a fast track basis which will allow

the methane gas generation system to be in operation in early 1986 and

the leachate treatment facilities to be operational by the summer of

1986.

The RRAA defines the full scope of remedial work to be performed in

the immediate future. It contemplates broad remedial work and its implementation will depend upon the success of the gas generation/recovery

program and the contributions from generators and other potentially

responsible parties (PRF). The gases generated at the Moyer Landfill

site are most likely to contain trace amounts of toxic volatiles and

gases; the gas will be cleaned to pipeline quality and toxics, if any,

will be properly disposed. The economic viability and public acceptability

of the gas recovery program is a proven concept in present practice in

other parts of the U.S. As proposed, this program will meet the NCP

criteria of a corrective action planned for a hazardous waste site. The

contamination at Moyer Landfill site requires remediation to mitigate

the public health and environmental concerns; the gas recovery program

will address and remediate the concerns.

If negotiations with the PRPs fail and/or the methane gas generation/

recovery program fails, we recommend Remedial Action Alternative 4 with

a modification to the cap, be Implemented at the Moyer Landfill Site.

This remedy will satisfy as well all of the contamination objectives

identified in the Remedial Investigation.

Alternative 4

The modified Alternative 4 meets all federal standards. It consists

of a 10~? RCRA cap without the synthetic liner, with surface water

collection and discharge, leachate collection(ranging between 0-60 feet)

and treatment, gas venting and ground water and surface water monitoring.

The cap originally proposed in RAA4 does not provide any additional

health or environmental benefits, exceeds all standards, requires a

longer construction period and is not as costeffective as the proposed

10"' RCRA cap* In addition, the leachate collection system will be

designed to meet the 10~6 risk level in the ground water and discharge

requirements in the streams. The depth could vary anywhere from 0 to 60

feet.

In spite of the fact that interception of the maximum amount of

leachate is proposed, it may not be possible to collect all the leachate.

Some leachate will still percolate to ground water and also probably, to

a certain extent, through the ground water to the surface water* However,

the quantities of leachate will be so minimal that their exact impact

could not be predicted at this time. Short-term ground and surface water

monitoring might help assess the Impact and also indicate any potential

future monitoring.

000041
-27-

The cap will comply with current RCRA requirements, which require

that the cap should not be less permeable than the bottom of the landfill.

The regulations also require elimination of ground water contamination,

which this alternative addresses through residual leachate collection and

treatment* As part of the RCRA requirements for closure of existing

land disposal facilities (Fart 265), RCRA provides that no synthetic

liner is required if the unit does not have synthetic underliners to

effectively control the quantities of leachate produced presently.

Monitoring of ground water and surface water, leachate treatment, and

maintenance of the cap would be part of the operations*

The capital costs of construction and annual operation and maintenance

costs are as follows:

1. Soil/Clay 1(T7 Cap * $9,308,400

2. Run Off Collection and Discharge 330,000

3* Gas Vent System 331,800

4. Access Road for Maintenance

Purpose 108,000

5. Leachate Collection ** 4,650,000

6. Leachate Treatment 656,600

Total Capital Costs $15,384,800

Annual Operation and

Maintenance 343,100

* This cap does not include a 20 mil. synthetic liner.

** Design parameters which directly affect the size of the system and

quantities of the materials required influence costs. Trench depth

is the most cost-Influencing factor* The exact depth of the

collection system will be based on coring results developed in

the Design Phase and a fate and transport model to determine the

amount of leachate that needs to be treated to maintain discharge

requirement levels into the Skippack Creek and 10~° risk levels in

ground water.

Operations and Maintenance

Monitoring and Post-Closure Maintenance activities are required to

verify the site cleanup, effectively maintain permanent onsite actions,

monitor potential contaminant migration. Detailed costs are Itemized in

Volume I Section 13 of the Remedial Investigation/Feasibility Study. All

samples taken will be analyzed for Hazardous Substance List (HSL)

parameters.

Schedule for Alternative 4

Approve Remedial Action (Sign ROD) 9/30/85

Negotiations with PRP Conclude 11/30/85

000042
-28-

Start Design 12/30/85

Complete Design 8/30/86

Start Construction 9/30/86

Evaluation of Alternatives Not Selected

The No-Action with Monitoring alternative was not selected since

soil, sediment, and surface water contamination will continue to pose a

direct contact threat to human health and the environment. There would

he a continued migration of contaminants to the ground water, surface

water and release to the air.

Alternative 2 and subcomponents meet CERCLA goals but fall short of

providing full protection from contamination of shallow ground water.

The soil cover will still allow leachate generation and subsequent

contamination of the ground water. O&M will be more expensive than O&M

In Alternative 4, Permits were unobtainable for offsite treatment.

Alternative 3 satisfies all applicable standards, reduces further

contamination by stopping the generation of fresh leachate. However, it

does not provide for the collection, treatment and disposal of residual

leachate that is trapped under the impermeable cover.

Alternative 5 was not chosen due to extremely high costs, difficulty

in Implementing, safety concerns and lengthy construction duration of

10 to 20 years.

Consistency with Other Environmental Laws

EPA Is currently proposing regulations requiring the agency to select

a remedial Superfund remedy which "...attains or exceeds applicable or

relevant Federal public health or environmental standards." See proposed

40 C.F.R. 1300.68(f).

Environmental laws which may be applicable or relevant to remedial

activity are:

- National Environmental Policy Act (NEPA)

- Clean Air Act (CAA)

- Clean Water Act (CWA)

- Safe Drinking Water Act (SDWA)

- Resource Conservation and Recovery Act (RCRA)

000043
- Pennsylvania Clean Streams Act

- Toxic Substances Control Act (TSCA)

These two chosen alternatives meet NEPA functional equivalency

exception because the necessary and appropriate investigation and analysis

of environmental factors as they specifically relate to the Moyer Landfill

Site. In addition, a meaningful opportunity for public comment on environmental issues was provided before the final selection of the remedial

alternatives were made.

Compliance with all substantive requirements of the CWA and CAA as

well as the Pennsylvania Clean Streams Act will be incorporated into the

design of the remedial alternatives. Any discharge into the atmosphere

of gas will be monitored to assure all applicable standards are not exceeded*

Discharge of treated surface water will comply with appropriate standards*

The cap chosen will meet all of the RCRA requirements under 40 C.F.R.

1264.310.

000044
MOYER LANDFILL RESPONSIVENESS SUMMARY

INTRODUCTION

The preferred alternatives as described in this ROD generally are

supported by the local community and its leaders. Both residents and

public officials are frustrated by the duration of the RI/FS process,

and the relative expediency of the receiver's proposal is seen as its

most desireable feature. The community also has voiced concern that

EPA's "fall back alternative" be ready for implementation if the

receiver's proposal fails In some way. The only substantive change in

the ROD process as a result of community input was an extention of the

comment period from September 18 to September 23.

COMMUNITY INVOLVEMENT HISTORY

According to available information, the first three decades of Moyer

Landfill history were marked by minimal community Interest. However, in

1977, when the operators of the landfill sought to expand the site from

44 acres to 185 acres, residents in the vicinity of the landfill joined

together and formed a group called the Lower Providence Concerned Citizens

(LPCC) to fight the expansion plans. In addition to stopping the growth

of Moyer Landfill, the LPCC demanded that the existing site be closed.

LPCC concern over what was perceived as the PADER indifference to

citizen's complaints, and to obvious violations of State and Federal

environmental laws at the Moyer Landfill Site, led to the filing of a

civil suit in Federal court in June 1980. The LPCC was Joined in this

effort by approximately 100 Individuals and several local civic and

sportsmen's groups, including the League of Women Voters of the Valley

Forge (Pennsylvania) area, the Valley forge Audubon Society, and the

Country Boy Bass Association. The original suit named the PADER, as

well as the owners and operators of Moyer Landfill, Inc., as defendants;

but the suit was dismissed. Later, a combined suit was filed by the

citizens and organizations mentioned above and the PADER against the

owners and operators of Moyer Landfill, Inc.

Although the early years of LPCC existence were marked by difficulties

with local government, the organization and other residents are pleased

with the present elected officials and report a good working relationship

with them. The community's relationship with the PADER can be characterized

as cautious. Local officials and residents were satisfied when the EPA

began investigating the Moyer Landfill Site, but both groups are unsatisfied

with the duration of the RI/FS process and have demanded effective clean up

action as soon as possible.

0000415
COMMENT SUMMARY y

This section is divided into two parts: ^6/r

\

 *

I. Remarks and Issues voiced during a September 10 public

meeting.

II. Other remarks and issues concerning the Moyer Landfill

site including those raised during a September 10 briefing

with Township representatives.

A public meeting was held at 7:00 p.m. on September 10, 1985, at the

Lower Providence Township Municipal Building in Lower Providence

Township, Pennsylvania. The purpose of the meeting was to discuss,

with Interested parties, the results of the Remedial Investigation

(RI)/Feasiblllty Study (FS) conducted by EFA at the Moyer Landfill

site, and to request comments from the public concerning the cleanup

alternatives presented in the FS.

There were approxlmatley 40 individuals In the audience including

representatives from the local newspaper and television station,

various state agencies, contractors who have been involved in site

work, the U.S. EPA, and Interested citizens.

Officials hosting the meeting included Tom Voltagglo, Chief of the

Superfund Branch of EPA; Greg Crystall, member of the enforcement

section of EPA; Stephanie Del Re, site project officer of EPA; Ray

Germann, Community Relations Specialist of EFA, Don Beeker, from the

Pennsylvania Department of Environmental Resources (PADER); Joanne

Denworth, court receiver for the Moyer Landfill; and Fred Ehmann,

representing Energy Recovery Partners.

Attached is a summary of issues and questions raised during the

meeting, and the responses given by EPA.

Public and Environmental Health

ISSUE: A number of questions pertained to the nature and extent of

contamination at the site. Several citizens wanted to know

what health risks contamination (I.e., radiation) from the

site posed to them.

RESPONSE: The remedial investigation report defines the nature and

extent of contamination at the site. Radiation levels detected

offsite were below drinking water standards. The main problem

at the site is the heavy metals and volatile organlcs found

in the leachate that is flowing offslte into Skippack Creek.

The court receiver's remedial alternative would adequately

address the leachate problem.

000046 "" 2 **
ISSUE: Several citizens expressed concern that leachate is entering

the shallow groundwater and contaminating their wells.

RESPONSE: Most of the leachate is flowing into Skippack Creek via groundwater and seeps. The rock formation separating the upper and

lower aquifers is very tight and residential wells are drilled

below the rock formation. There is very little seepage of

leachate through the rock formation and therefore little

danger of residential well contamination near the site.

ISSUE: Several citizens were concerned about leachate flowing into

the Skippack Creek. They wanted to know what kind of damage

this leachate could be causing to the creek, fish in the

creek, and children playing near the creek.

RESPONSE: EPA has conducted extensive testing of Skippack Creek and has

found only low levels of contamination in the water and in

fish. EFA acknowledges that leachate flowing into Skippack

Creek Is a major problem at the site. The recommended remedial

alternative will provide for collection and treatment of

leachate entering the creek.

ISSUE: A citizen reported that periodically large trucks drive up

towards the site area at night and return a short time later.

Is dumping still occurring at the site?

RESPONSE: The landfill is closed. Dumping has been reported on areas

adjacent to the site. Any specific information on Illegal

dumping should be passed on to the EPA*

ISSUE: A few citizens were concerned that the proposed gas line from

the landfill would damage their property.

RESPONSE:* The gas company will negotiate to buy private right-of-ways

and if this is unsuccessful, then the public right-of-way will

be used. No residents will be forced to accept the gas line

through their property.

EPA Cleanup Process

ISSUE: Several citizens wanted to know why many studies have been

conducted at the site over the years but nothing has been

done to stop the flow of leachate from the site. Citizens

wanted to know a definitive date when site cleanup would begin.

RESPONSE: Studies are lengthy but are required to accurately define the

nature and extent of contamination at the site. Information

from the RI/FS and hydrogeological assessment conducted at the

site will be carefully evaluated by EPA so it can select a

cleanup alternative that is environmentally sound and costeffective. EPA is anxious to begin cleanup work at the site and

encourages public comment on the various cleanup alternatives.

EPA will decide on the cleanup alternative by the end of the month,

000047
ISSUE: A citizen wanted to know if the people who are responsible

for contaminating the site will clean up the site.

RESPONSE: The responsible parties should definitely play a role In cleanup

at the site. The court receiver's plan would provide for this

by making generators a financial party in any cleanup agreement.

At least 28 potentially responsible parties have been contacted

by EPA. If anyone has additional documentation of other

potentially responsblle parties, EPA would like to have this

information.

ISSUE; A citizen expressed concern whether funding was available to

clean up the site.

RESPONSE: EPA will likely sign the record of decision (ROD) at the end of

the month. At that time, potentially responsible parties (PRPs)

have 60 days to enter into an agreement with EPA to help clean

up the site. After this 60 day period, funding is either made

available from PRPs or from EPA If no agreement is made. This

means that funding for site cleanup should be available in late

November. This schedule assumes that Congress passes a new

Superfund bill presently under debate in Congress.

ISSUE: Several citizens stated that they wanted to be informed of

cleanup progress at the site.

RESPONSE: EPA will meet with concerned citizens again In October to

inform them of progress and plans and to address additional

concerns. The court receiver also emphasized that citizen

participation is very important in the cleanup process.

ISSUE: A representative of some of the PRP, wanted to have the comment

period extended to have adequate time to comment on the RI/FS.

RESPONSE: The comment period will be extended until September 23.

ISSUE: A citizen expressed the opinion that star wars and the Pentagon

is preventing the Government from adequately protecting the

public air and water. The individual suggested that cost

should not be a consideration in site cleanup.

RESPONSE: None

Technical

ISSUE: A citizen who lives north and west of the landfill near

Eagle Stream wanted to know why his well had not been tested.

RESPONSE: EPA will investigate this possibility but it is likely that

the well has been tested and EPA can find the results In the

RI/FS document.

000048
ISSUE: A citizen expressed concern that methane gas will cause the

clay cap to crack.

RESPONSE: There will be continuous maintenance of the clay cap.

ISSUE: A citizen was concerned that leakage will slowly occur from

the upper aquifer into the lower aquifer. Have recovery wells

been considered to withdraw contaminated groundwater and to

prevent seepage into the lower aquifer?

RESPONSE: The leachate collection system and RCRA cap will capture most of

the leachate and monitoring will continue to provide information

on conditions In the lower aquifer. Recovery wells were

not considered cost-effective or necessary.

(A

Remedial Action Alternatives

ISSUE: A citizen wanted to know what will happen If the court receiver's

alternative falls due to a lack of cooperation from potentially

responsible parties.

RESPONSE: EPA has a preferred "fall back" alternative which provides for

a site cap, leachate collection and treatment, gas venting and

monitoring. If the court receiver's alternative fails, for

whatever reason, EPA would implement the "fall back" alternative.

ISSUE: A citizen was concerned that EPA's 'fall back" alternative

was dangerous because capping would trap the methane gas.

RESPONSE; EPA's preferred "fall back** alternative Includes a provision

for venting methane gas to stop any dangerous build-up of

gas and to prevent damage to the cap.

ISSUE: A citizen wanted to know what will be done to collect the

leachate seeps in Evansburg State Park.

RESPONSE: The selected alternative will provide for collection of

leachate from all major sources of generation.

ISSUE: A citizen inquired whether EPA had accepted the court receiver's

alternative.

RESPONSE: EPA prefers the court receiver's alternative but has not accepted

it. Public comment is required prior to making a decision* Public

comments are strongly encouraged by EPA during the cleanup process.

ISSUE: A citizen wanted to know what would happen if something went wrong

after the court receiver's alternative had been Implemented and

suddenly money was not available for site cleanup.

RESPONSE: EPA requires that there be enough financial backing behind the

cleanup plan so that if something goes wrong there is still

enough money to close the site as required under EFA guidelines.

- 5 - 000049
ISSUE: Several citizens expressed a favorable opinion regarding the

alternative presented by the court receiver, but wanted to know

when the remedial action could begin.

RESPONSE:* If EPA approves the alternative, final closure and cleanup plans

could begin Immediately. The facilities could be built and put

Into operation by late spring. EPA officials emphasized that

the court receiver's alternative would allow cleanup to begin

sooner than allowed under EPA's alternative.

* The response to the comment was made by Joanne Denworth,

court receiver for the Moyer Landfill.

II. This section addresses past and present Issues not already Included

in the meeting summary*

ISSUE: A Township official was concerned that EPA's plans for cleanup

were not more specific, and that we did not already have specific

plans for the preferred alternative.

RESPONSE: EPA and/or the receiver will draw up specifications and begin

design after the comment period closes and a ROD Is written. The

FS process outlines concepts, but does not draw up specifications.

ISSUE: A local land owner suggested creating a lined landfill adjacent

to the current site and requiring that, for each ton of new waste

deposited in the lined landfill, the owner be required to accept

one ton from the Moyer landfill, eventually transferring the

entire Moyer landfill into a lined facility.

RESPONSE: A variation of this suggestion is Included as an option in the

FS. It would Include total excavation over a term of 5-15 years,

and encounter strong resistance from local residents.

ISSUE: Potentially responsible parties were not given adequate time to

comment on the RI/FS prior to development of the ROD.

RESPONSE: The RI/FS was received by PRPs July 24. The comment period ended

Sept. 23. The National Contingency Plan (NCP) calls for a 30-day

comment period on the RI/FS before a cleanup alternative is chosen.

ISSUE: The Information obtained to date shows that the actual environmental

Impact that has occurred and the potential for future Impacts do

not represent any Imminent danger to the environment or human health

and safety near the Moyer Landfill. Also, there are several areas

In which the data base and analysis are Insufficient.

RESPONSE: While the evidence suggests that there has been little or no Impact

upon public health or the environment from site contamination to

date, the continued flow of contaminated leachate from the landfill

may pose a future threat to public health or the environment. This

possibility Is sufficient to justify remedial action under the

Comprehensive Environmental Response Compensation and Liability Act

(CERCLA) and the National Contingency Flan (NCP). EPA considers

the sampling plan and protocol outlined in the RI sufficient to

accurately gauge potential risks posed by the site.

000050
ISSUE: The RI/FS evaluates a number of remedial action alternatives. In

general, the environmental benefits which may be obtained from

their implementation have not been identified or weighed against

the risk of potential harm suggested in the RI or against any

risks which may be presented by the alternatives themselves.

Should a comprehensive risk assessment be conducted, it is likely

that is would identify either RAA-1 or RAA-2 as the measures most

consistent with the NCP.

RESPONSE: As outlined in the FS, either of the preferred alternatives will

adequately address the flow of leachate off site, thereby

eliminating the future risk to public health or the environment.

EPA believes that the provisions in the preferred alternatives

provide cleanup benefits superior to those included in other

remedial action alternatives.

- 7 -

000051
PENNSYLVANI A

Bureau of Solid Waste Management

COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

Post Office Box 2063 .

Harrlsburg, Pennsylvania 17120

September 27, 1985

717-783-7816

United States Environmental

Protection Agency

Region III

841 Chestnut Building

Philadelphia, PA 19107

Attention: Thomas C. Voltagglo, Chief

Superfund Branch

Re: Moyers Landfill Superfund Site

Lower Providence Township

Montgomery County

Dear Mr. Voltaggio:

This letter constitutes our response to the Remedial Alternative Selection Summary for the Moyer

| Landfill, which we received on September 26, 1985. It is the Department's position that government

funds should not be utilized for remedial action projects when other monies are readily available

to be used for such purposes. This enables an agency to reserve funds for cleanup situations when

| no other sources of relief are provided. In the Moyer Landfill case, we concur with EPA on the

I recommended receivers Remedial Action Alternative (RRAA), as discussed on pages 24 through 28

of summary. As a precaution, EPA proposes to resort to Alternative 4 in event that the methane

|gas recovery program does not materialize, or falls to accomplish the required remedial work.

This office strongly recommends that individuals who propose to undertake the gas

[recovery program provide ample bond to assure that all the remedial work can occur. A proposed

(schedule with remedial design phases concomitant with the progress of the methane recovery

irogram should be prepared first. EPA should then consider entering into a binding legal

igreement with the PRPs to ensure their commitment to satisfy the entire scope of the remedial

iction, and to perform Operations and Maintenance at the site for 30 years.

We hope that all future activities at the Moyer Landfill will develop to everyone's

satisfaction, and especially to the improvement of the environment.

Very truly yours,

Dwight D. Worley, Chief

Division of Emergency and Remedial Response

000052