IN RE: PROPOSED REMEDIAL ACTION PLAN

PUBLIC MEETING

BRODHEAD CREEK SUPERFUND SITE

PROCEEDINGS HELD AT THE MONROE COUNTY

COURTHOUSE, STROUDSBURG, PENNSYLVANIA, TAKEN ON

WEDNESDAY, FEBRUARY 27, 1991, COMMENCING AT OR

ABOUT 7:00 P.M.

PANKO & JOHNSON REPORTING AGENCY

46 NORTH SIXTH STREET

STROUDSBURG, PENNSYLVANIA 18360

(717) 421-3620

AR500099 O

MS. DICOSMO: Good evening, everyone.

It's a little past seven, I thought we could

start.

My name is Francesca .DiCosmo and I'm

the community relations coordinator for the

Brodhead Creek Superfund Site.

As you know, we are here this evening

to have a public meeting to solicit comments and

input from the public on our proposed remedial

action plan.

The comment period opened on February

15th and will close on March the 18th. So there

is still time to get in comments and ask

questions.

I'd like to introduce some of the

people that we have with us this evening. Again,

I'm Francesca DiCosmo. With us we have Jeffrey

Pike who is the chief of the Western Pennsylvania

remedial branch. John Banks, of course, is our

remedial project manager and will be giving the

major portion of our presentation this evening.

Dawn lovan is the EPA toxicologist

assigned to Brodhead Creek. Mindy Snoparsky isAR500100

the EPA hydrogeologist. And we also have Robert

Davis who is the biologist.

In addition, from the Pennsylvania

Department of Environmental Resources we have

Robert Lewis who is the regional project officer

and John Mellow who is the hydrogeologist.

I'd like to begin this evening with a

brief overview of the superfund process just so

that we can see where we are and where we're

going.

Just as a quick review, the

superfund program was established by Congress to flB

remediate or clean up past waste disposal

practices of problems that have come to the

attention of EPA.

The solution for those problems was

development of a comprehensive environmental

response compensation and liability act in 1980 as

amended which is really a long way to say

superfund, but that is the legal title of the law

that we're operating under. And superfund has

come to be the most well known word for the

program. AR500I01

The mission of the program is to find

the nation's worst chemical contamination problems

and have them cleaned up. The superfund law set

up the mechanism by which EPA in coordination with

our partners in the State level, can have the

sites cleaned up and they developed the trust fund

to be used and enforcement authorities as well to

get the sites cleaned up and get the job done.

In order to be eligible for

remediation under the superfund program, a site

has to be included on the national priorities

list. That list is EPA's list of the country's

serious contaminated areas and is based on a score

that a site receives from the hazard ranking

system.

The hazard ranking system basically

takes data that was collected through various

means and various sources such as soil, air and

water and plugs it into a big formula.

And at the end of that formula, you

have a score from zero to a hundred. If your site

score is above 28.5, then you are put on the

national priorities lists and eligible OR- , ~

assistance under the superfund program.

What this does is the hazard ranking

system and the data that is collected at that

point alerts EPA to the fact that there is a

serious enough problem to warrant further study

and possible further action.

The common question we get is, well

what is this trust fund? Commonly the answer is

folks think that it is coming out of their state

taxes or from the income, federal witholding tax.

But it isn't. The trust fund was set up under

superfund to help pay for clean ups. Vp

And the fund consists of moneys and

received through taxes to the petro and chemical

industries.

Superfund sort of has two sides to

it, two authorities. One side of the superfund

law is the removal or removal actions. Those

actions are taken when the situation warrants

because releases or threats of release have

eminent or immediate threat to public health or

the environment. Those are sort of short-termAR500103 ,

situations where immediate action is warranted. ^B|

On the other hand, we have the

remedial side of the superfund program where a

problem has been identified which needs to be

corrected, but it is not an immediate threat to

the public health or the environment. That is not

to say it is not a problem there, but it is a

problem which would have longer term effects.

One has to be exposed over a longer

period of time. Therefore, we can take the time

to properly study the situation in order to make

the best selection or solution.

Very quickly I'd like to go over the

various steps of the superfund process. Once a

site is discovered and preliminary data is

collected, we, as I said previously, plug that

data into the hazard ranking system and come up

with a score. Once the score is validated and is

about 28.5, the site is put on the national

priorities list.

At that point, the remedial

investigation and feasibility study phase begins.

And basically that's where we are this evening.

Remedial investigation and

feasibility studies have now been complete and the

alternatives as presented in the feasibility study

have been put into the remedial action plan which

you all have a copy of.

And that would be the main focus of

our discussion this evening.

We have now opened up the comment

period, as I said and at the close of the comment

period, we will then make the record of decision

to set forth the final selection of the remedy.

Attached to the record of decision

will be a little document called, or a big

document, depending, called the response of the

summary where you can see all the comments,

questions that were asked about the site and EPA's

responses to those.

Finally we go in actually designing

and constructing whatever the selected remedy is

and there should be actually another one stuck in

here which is the operations and maintenance phase

of the program.

Once a remedy is constructed, EPA

doesn't walk away from the situation, it has a

A R S O O i O b

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long-term oversite monitoring program to ensure

that the selected remedy is in fact protecting

public health and the environment.

And then finally, the main goal is to

delete the site from the list because the selected

alternative has been successful.

With that, I'd like to turn the

program over to John who will explain and discuss

the action plan for the site. At the conclusion

of John's presentation, I'll then open it up to an

orderly show of hands for questions or comments.

You see that we do have a court

reporter here taking down the entire proceeding

this evening.

MR. BANKS: My name is John Banks,

I'm the EPA remedial project manager for the

Brodhead Creek superfund site here in Stroudsburg.

Tonight we're here to seek some

community input on the alternative which we are

proposing to implement at the Brodhead Creek site,

which to address surface soil contamination at the

site.

And during my presentation, I'm going

A R S O Q i O B

to be going through the site history, results of

the remedial investigation, feasibility study, and

EPA's proposed alternative for the site.

Starting with the site history,

Brodhead Creek site was a site of a coal

gasification plant which was operated by the

predecessors of Union Gas Company from 1888 to

1944 .

A by-product of this gasification

product was a black tar-like liquid, what we call

coal tar, it is principally composed of

polynuclear aromatic hydrocarbons or what whe callflp

for short PAH's.

This coal tar was disposed of in the

subsurface at the Brodhead Creek site. From 1917

to 1960, actually 1917, Pennsylvania Power and

Light purchased the electrical section of what was

then the predecessor of Union Gas Company

facilities .

Then from 1917 to 1960, Pennsylvania

Power and Light, or what I'll call PP&L purchased

adjoining properties throughout that time period.

1955 Brodhead Creek flooded due to a

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hurricane. In response to that in 1960, flood

control levee was constructed on the site.

This flood control levee rises about

between eight feet above the natural land surface

at the site and was constructed with a corps of

engineer oversight at the time.

1980 during repairs to the tow of

this flood control levee, the maintenance workers

noticed coal tar seepage into Brodhead Creek. At

this time EPA was notified and initial measures

were taken under the clean water act to medicate

the threat to Brodhead Creek.

Around the 1980 time period, the

superfund law was also enacted and funds became

available under the superfund law to address this

contamination.

In 1982 EPA included the site on the

national priorities list and in the superfund

program for site cleanup.

In 1981 to approximately 1983, 1984,

EPA, Pennsylvania Department of Environmental

Resources and PP&L conducted numerous site

sampling and monitoring activities at thja sJJ;e,-. Ql\n oil u I u o

11

anywhere from installing test fits in subsurface

oil to porings to test wells to look at the ground

water.

In 1987, Pennsylvania Power & Light

and Union Gas Company signed a consent order and

agreement with the State of Pennsylvania to

conduct a remedial investigation capabilities

study.

The State of Pennsylvania had the

responsibilty during this time period for the

RIFS. And EPA and the State had been working in

conjunction during that time period trying to

finalize it.

So the actual field work for the

remedial investigation was conducted from 1987

through 1989.

In September of 1990, a final

remedial investigation report was submitted to the

DER and EPA followed by a final capability study

in January of 1991.

Just to highlight some of the

previous response activities that were taken at

the site during the early 1980's, there wasAR500109

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installation of filter fences and underflow dams

in the creek to intercept the coal tar seepage

going into the creek.

There was also installation of the

coal tar recovery pit on the Brodhead Creek bank.

The idea behind the pit was that the pit was dug,

free draining coal tar would drain into this pit

and we could recover it.

It was found though once this was

done, the pit was not catching that much free coal

tar and it was eventually backfilled.

In late 1981 through 1982, EPA under

an emergency response action under superfund

constructed a slurry wall to mitigate the coal tar

migration from the site toward Brodhead Creek.

The slurry wall lies between Brodhead

Creek and the flood control levee that is

presently on the site. Slurry wall is

approximately 648 feet long and it has a depth of

approximately 17 feet over the subsurface.

Primary purpose of the slurry wall

was to halt the flow of the liquid coal tar

itself. It is not a barrier to ground wIBarQSllowO

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Concern at that time was that the coal tar was

going to seep directly into Brodhead Creek and

that is what the slurry wall was put there to do,

to stop the coal tar.

Some of the coal tar constituents are

soluble in water. They dissolve in the ground

water and the ground water silt flows underneath

the slurry wall and around the slurry wall into

Brodhead Creek.

There was also excavation of the back

water channel where coal tar seepage was

particularly significant. The coal tar in that

back water chanel was found to be toxic to fish at

that time.

The back water channel was then

excavated and backfilled with clean soils and no

longer existes at the site.

And then, I believe it was 1983 and

part of 1984, there was the installation of

recovery wells in the main coal tar pool at the

Brodhead Creek site by PP&L.

They managed to remove approximately

8,000 gallons of free coal tar from this main Qoal

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tar pool which was the extent of the recoverable

coal tar at that time so they could get it out

that pit area.

So then beginning, the remedial

investigation was then conducted. The purpose of

the remedial investigation was to determine the

nature and extent of contamination at the site and

there were a number of significant findings which

came out of the remedial investigation.

The first one is that the coal tar

contamination is limited to a gravel unit and

migrations contained by underlying silty sand

unit.

In broad terms, there are three major

geological formations at the site. That being the

gravel unit, underlying the gravel unit is silty

sand unit and under that it is bedrock.

The total area of contamination is

approximately 4.3 acres containing an estimated

maximum volume of 418,000 gallons of coal tar.

The coal tar exists at the site as a

free liquid phase and as residual coal tar. And

the way we define free liquid phase coal tar is,

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it is that coal tar which is at 100 percent pore

volume saturation in the soil.

The residual coal tar is coal tar at

less than 100 percent pore volume saturation in

the soil.

So to kind of draw an analogy if you

think of a snow cone and the shaved ice in the

snow cone is the gravel and cobbles in this gravel

unit. And then you were to pour cherry flavoring

on it and the cherry flavoring is coal tar. When

you pour this on top, you saturate the shaved ice

and that is analogous to what is happening at

Brodhead Creek with the coal tar, you have all

this coal tar within the pore spaces.

Now, if you were to take that snow

cone and suck out the cherry flavoring, you are

going to have a tinge of red left over in the ice

that you can't really get it out.

That is what residual coal tar is, it

is that area of the gravel unit where the coal tar

doesn't occupy all the space in the pore volume

and it is sticking to the cobbles in the gravel.

Now, the free liquid phase coal tar 4fe

RR500H3

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exists in two main areas at the site, proximal to

MW-2 which is on the east side of the slurry wall

at the site, and in the RCC area. The RCC area is

a recovery well area were PP&L had recovered a

free base coal tar back in 1983.

And the area next to monitoring well

number two contains approximately 338 gallons of

coal tar. The area around RCC contains about 8700

gallons of coal tar.

The residual coal tar is througout an

additional 2.96 acres of the site, with an

estimated maximum of 409,000 gallons.

To illustrate this, what you see here

is the maximum probable extent of the free coal

tar. Here you can see the area around MW-2 and

this is the area around RCC. The darker

hatchmarked areas are where the free coal tar

presently exists.

They both exist in a stratagraphic

unit that's in the subsurface of the site. The

stratagraphic unit is a depression of silty sand

unit at the site. And what it is, it is almost a

geologic sink.

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If you can picture the gravel unit

dipping down in the depression of silty sand unit.

And what it does is form a sink which the coal tar

migrates down into because of gravity and because

it is denser than water. So it flows down through

the water table into the stratagraphic depression.

The lighter hatchmarked area is the

maximum probable extent of the residual coal tar.

This is the coal tar that is adhering to the

cobbles and it is not really occupying all the

floor space in the soil.

I think it is important to note that flp

the way the boundaries of the residual coal tar

were drawn is from all the historic observations

from 1980 until the present, it encompasses all

those areas where coal tar was at one time or

another found in a test pit or a boring or a

monitoring well.

Just to illustrate this depression

again, this is a cross-section of the site. And

what you can see here is the flood control levee

right here. And then you have the stream gravel

unit or the gravel unit right here. Jfe

AR500I15

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I should make a point to clarify

this. When I say stream gravel unit, I do not

mean the gravel unit directly underlying the

stream bed.

The stream gravel unit is more

extensive than that. It underlies the majority of

the Brodhead Creek site, it is not just the

gravel. There is stream gravel underneath the

stream bed, but it is more extensive than

throughout the site, even underneath the stream

bed.

So here we have the stream gravel,

underneath the flood control levee. And this is

the underlying silty sand unit here. Here is the

natural sink that is formed just because of the

J? geology of the site. And the coal tar actually

migrates down the slopes of the silty sand into

these pools.

Now, this is the RCC area, the

smaller pool by monitoring well two is contained

effectively by the silty sand on its eastern side

because the silty sand rises above the coal tar

pool. And it is contained by the slurey:: Wfjljl { en

3

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its western side.

Now, it is postulated that when the

slurry wall was put in, this coal tar was trapped

on the opposite side of the slurry wall. That is

how it got there.

Like I said, the surry wall is

effective in not letting the free phase coal tar

move through it, although it does let the ground

water through.

The principal shallow water bearing

strata at the site are the stream gravel unit and

the underlying silty sand unit. The ground water

flow is basically west to east across the site and

the ground water moves downward beneath the slurry

wall and also down along the path of the slurry

wall and down around the sides of the slurry wall

towards Brodhead Creek.

Now, the migration of the coal tar

constituents may be constrained by upper flow

drainage and hydraulic boundaries by Brodhead

Creek and McMichael Creek.

And what I mean here is, I, jam pjw?t i -j

talking about the free phase coal tar migration.

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Some of the constituents, some of the PAH's and

some of the more volatile chemicals in the coal

tar are soluable in ground water.

These dissolve into the ground water

and then migrate towards the creek. At the

conclusion of the remedial investigation, there is

an upward flow grading of the ground water at the

creek, which is because of the higher head we

found in the wells.

And that there is no possibility for

the vertical migration contaminated ground water

down through the gravel into silty sand and then

into the bedrock ground water at the site.

EPA isn't disagreeing with this. I

think though, in order to be a hundred percent

sure, we still feel that some additional bedrock

wells should be put in at the site to assess the

bedrock water table, actually the bedrock aquifer

and to verify and get more information that indeed

there is no vertical flow breaking at the site for

contaminated ground water to move down to the

bedrock.

Other data shows the Brodhea

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surface waters are not affected by the discharge

of coal tar constituents. The ground water at the

site is contaminated and is discharging into the

creek.

However, once it hits the creek,

immediately upon entering the creek, we can't pick

detectable levels of any coal tar constituents.

They are immediately diluted below detection and

therefore there is no impact to the creek.

Some of the sediment areas in the

creek are contaminated with coal tar, they are

very low levels of coal tar in the surface {•

sediments.

A little bit more of the contamnation

is located in the lower sediments in the creek.

But again, it's very low contamination. It

appears that sufficient macroinvertibrate

population does not appear to have been adversely

impacted.

So it is good news for people who

fish on the site. It doesn't appear that the fish

are being impacted at the site, they don't seem to

be biocumulating the PAH's. AHjUUl

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During the remedial investigation,

there were fish studies done and also studies on

sea lamprey larva that live in the subsurface

sediment at the site.

We tested the fish and we found that

they are not biocumulating PAH's, which seems

reasonable because the fish are more mobile,

moving in and out the site boundaries at the creek

all the time. And also they metabolize any PAH's

that they would take in rather quickly.

Sea lamprey larva are another story.

Because of their lifestyle, they have a tendency

to biocumulate the PAH's at the site. They burrow

into the sediments at the site and they live there

for about four to seven years before migrating

down to the ocean. During that time they feed off

the organic matter in the substraight and the

organic matter does have a tendency to pick up

these PAH's and the sea lamprey biocumulate

itself.

So we do see some violation of the

sea lamprey larva, even though they are

biocumulating, they are adversely impffct'ea 4Deea-use

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there is a great abundancy out there in the creek.

And also once they do migrate out of the site area

and move towards the ocean, it is also expected

that they are going to metabolize these things

quickly and discretely.

Based on the results of the remedial

investiation a risk assessment was conducted to

assess site impacts to human health and the

environment, if no remedies were to be implemented

at the site and the site were to stay as it is.

During the risk assessment, the main

site-related contaminants were the PAH's, benzene

and arsenic. These chemicals exceed the maximum

contaminant levels in the stream gravel ground

water on site.

And what maximum contaminant levels

are, those are standards for contaminants that

were promulagated under safe drinking water act,

which are acceptable levels for human consumption

of the water as drinking water.

Currently there is no exposure at any

on site wells simply because there are no drinking

water wells on site. And there is no exposure toAR500I2S

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any off site municipal water supply wells since

wells that we sampled were cleaned.

The well that was sampled was one of

the East Stroudsburg Municipal wells on the East

Stroudsburg campus. This well penetrates bedrock

in the Stroudsburg area and the water quality was

good. It contained no contaminants whatsover

related to the site.

Potential future use of the upper

aquifer at the Brodhead Creek site itself is

highly unlikely. This is for a number of reasons.

Three of them being that the site lies within a

wetlands area. Flood control levee bisects the

site. Site is also in an industrial area. So it

is unlikely that somebody would screen a well in

the gravel unit on site.

However, even though it is unlikely,

the probability still is there that somebody could

do it.

As for the environmental impacts,

that are no site-related exceedances of ambient

water quality criteria in Brodhead Creek.

The ambient water quality criteria

AR5QQ122

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are criteria set for protection of aquatic life.

And you know, based on the ground water

discharging to the creek and us not being able to

detect contaminant levels in the creek, none of

them are exceeded.

Residual coal tar is present in some

locations in the stream bed sediments at very low

levels. But they are not affecting the aquatic

life and they are not imparting PAH's of any

significant levels whatsoever to the stream waterI

Again, PAH's were found to

biocumulate in the sea lamprey larva, but not in VP

the fish that were sampled in the creek. And

again there seems to be a healthy abundance of

aquatic life in Brodhead Creek.

For human health there are a number

of routes of exposure to contamination analyzed

for risk assessment. In doing a risk assessment,

the risks of exposure were analyzed for dermal

contanct with surfact soils, sediments and surface

water and likewise ingestion of surface soils,

sediments and surface water at Brodhead Creek.

Risk assessment also lookeff 'ar*-' ' <- Jfe

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ingestion of fish. And looking at a worst case

scenario, the levels of contaminants in sea

lamprey larva were looked at for fish ingestion.

So basically for ingestion of fish, we are looking

at, if you were to eat sea lamprey larva at the

site, which is pretty unlikely.

We also looked at vapor inhalation

from surface water and surface soil and dust

inhalation for the surface soils.

Taking those risks of exposure into

account, the total lifetime carcinogenic risk for

adults may be an additional two cases of a hundred

at the Brodhead Creek site or maybe two cases out

of an additional 100,000 people exposed to

contamination at the Brodhead Creek site.

And under the superfund program a

cancer risk higher than one in 10,000 is

considered unacceptable, so we are well below the

range.

We also looked at the total lifetime

chronic hazard index. The hazard index greater

than one for noncarcinogens is considered

unacceptable.AR500I21*

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The total lifetime hazard index or

exposure to noncarcinogens at the site is .0048,

so once again, we're well below the required

limit.

Given the complexity of the site, we

decided to divide the site into two separate

operable units.

The first one being contaminated

subsurface oils containing free coal tar in the

stream gravel unit. The basis behind this

operable unit is so that we have free coal tar on

the site, which is imparting high levels of

contaminants to the shallow ground water.

And what we want to do is mitigate

the principal threat caused by these coal tar

pools by dealing with them effectively.

The second operable unit would entail

ground water and stream gravel to and including

bedrock.

Under this operable unit, we want to

go back and put some additional bedrock wells in

to assess the quality of the bedrock aquifer.

We looked at a variety ofLsR5Qni25 IV

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alternatives under the feasibility study, but

before I get into them, the following alternatives

I'm going to show you do contain some common

elements which I wanted to make you aware of.

These all apply to all the

alternatives, except for the no action

alternative. Except for number five, but even

under a no action, EPA will review the site every

five years because we are leaving contaminants on

the site. But as for the other four, they will

apply to all the rest of the alternatives.

We will be looking at imposing deed

restrictions on the site to limit future use on

the site.

We are looking at a ground water

monitoring program to measure concentrations of

the coal tar relating to constituents and to

ensure that the integrity of the slurry wall is

maintained in the future.

We also implemented Brodhead Creek

biota monitoring program to ensure that the site

continues to have no significant impact on the

aquatic ecological system in Brodhead Creek.

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And we also looked at constructing a

fence around the site to prevent access.

For the interim remedy we are

proposing for subsurface oils, we looked at six

different alternatives.

The first being no action, which we

are required to look at under the superfund

program because it serves as a baseline for

evaluating the other alternatives.

Second alternative is limited action.

The limited action entails intermittent pumping of

the free coal tar in the RCC area, which is the WJf

larger coal tar pool. This would be done using

conventional pumping techniques.

And it is estimated that

approximately 50 percent of the coal tar could be

recovered. This would be done once per year until

we could not get any more free coal tar out of the

pit.

Then we have on site stabilization

solidification. Under this alternative, we would

excavate approximately 1,000 cubic yards of

contaminated soil. AR500127

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5533

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We then mixed the soil with some sort

of stabilizing substance to prevent the

contamination from reaching from out of this mass

that we would form.

We would take this inner mass and

place it back in the excavation and cover it with

the overlying soil. And this would help to reduce

the mobility of the contaminants after this

process is completed.

Another alternative is excavation of

the contaminated subsurface soil and then soil

washing. This is similar to alternative three in

that 1,000 cubic yards of contaminated soil would

be treated. Except under this alternative what we

would do is employ soil washing techniques, which

is literally washing the soil in a water solution,

strictly coal tar from the soil.

The clean soils would then be placed

in the excavation and the recovered coal tar would

be shipped off site for incineration.

We also looked at enhanced recovery

for the free coal tar. This is an innovated

technology being evaluated by the EPA superfundflR500!28

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innovated technology program.

Some in place application of

contaminated extractions from the soils involves

steam injection to the subsurface soils to

mobilize the coal tar and make it easier to pump.

The coal tar would then be removed

from the subsurface soils and then would be

transported off site for incineration.

I think it is estimated under the

enhanced recovery process to recover approximately

60 to 70 percent of the free coal tar and some of

the overlying residual coal tar with that. flp

And the sixth and last alternative we

looked at was the excavation of contaminated

subsurface soils and off-site incineration.

Under this alternative, what we would

do is excavate the thousand cubic yards of

contaminated soil and ship it directly off site

for incineration.

We would then in pour clean fill to

the site and backfill the excavation with the

clean fill.

These are the costs of the various; f

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alternatives. The least expensive of which,

barring the no action where we wouldn't do

anything is the limited action at approximately

1.2 million dollars.

The most expensive being alternative

six which is the off site incineration at 6.2

million dollars.

You have to keep in mind that these

figures are just estimates.

The six alternatives are then put

through EPA's superfund nine evaluation criteria.

These criteria are specified by the national

contingency plan which is the regulations

governing the superfund programs.

All the alternatives go through the

screening process where they are evaluated against

one another and the alternative which seems to

have the best balance of these nine criteria is

then proposed as the preferred alternative.

So for the first operable unit for

the contaminated subsurface soils as an interim

remedy, EPA has proposed the enhanced recovery via

the thermal mobilization which is alternative

AR500130

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number five at a cost of, estimated cost of 4.2

million dollars.

For operable unit number two, we are

looking at focused RIFS on the ground water,

installing additional bedrock wells to analyze

ground water in the bedrock and then writing a

final remedial action and a subsuent record of

decision for the entire site.

Just to quickly go over the main

components of alternative five, it is an

innovative technology. It is an insitu

application of contaminant extractions from the

soil and can be done in place.

It involves the physical displacement

of coal tar from the pore spaces in the soil

through steam ejection which heats the coal tar

and makes it more mobile and forces the coal tar

up through the subsurface and makes it easier to

pump.

Because it is an innovative

technology, we are going to do treatability

studies to determine the optimum performance of

the enhanced recovery process.

RR500I31

34

¥Based on the treatability studies, we

will run it at the most effective performance.

And if we find during the treatability studies

that this technique is not that particulary suited

to the Brodhead Creek site, then we will go back

and re-evaluate the alternatives.

It will employ treatment of

approximately 200 cubic yards at subsurface soil

containing free coal tar. Now this estimate is

based on the main coal tar pool at the site at the

RCC area.

We would like, based on the VP

treatability studies to try to apply this enhanced

recovery process to both the free coal tar areas

at RTCN and NW2, if possible.

Again, estimates from at least the

RCC areas at the process could recover

approximately 7200 gallons of free coal tar and up

3 to 10,800 gallons of residual coal tar.5

Recovered coal tar would be disposed

of off site and in an incineration facility.

The process water, the heated water

and steam that is used for soil f lushin$,R i£KM Bt£¥

35

is extracted with the coal tar, would be treated

and partially discharged to the creek and part of

it reinjected into the subsurface soils for

further flushing of the soils on the enhanced

recovery process.

Also during this process, we would

ensure to put adequate air monitoring provisions

in place to be sure we are not discharging any

unacceptable levels to the air.

That's basically it, I'll be happy

to answer any questions.

MR. SWIFT: My name is Bob Swift and

I'm an attorney from Philadelphia and I'm counsel

for Union Gas Company. I have a number of

questions.

My first question is, I guess I'll

address this to Mr. Banks. Isn't it correct that

both EPA and DER have accepted the conclusions of

the remedial investigation and the risk

assessment?

MR. BANKS: I don't think that is

necessarily true. I think during the past year

when we have been trying to finalize these

36

documents and meeting with the PP&L, there were

some situations where we basically agreed to

disagree because we just came at them from two

different viewpoints.

MR. SWIFT: The feasibility study

has now been finalized, it is my understanding

that the contract that forms this entire work,

both the remedial investigation, risk assessment

and feasibility study, also reached a conclusion

as to which alternative was most desirable. The

contractor was very critical of alternative five.

Contractor felt that altnerative two was

acceptable and recommended that, but it is my

understanding that EPA and DER asked that those

conclusions be removed from the study. And it is

also my understanding that they are not part of

the public record. Is there any reason for that?

MR. BANKS: The purpose of the

feasibility study is to have alternatives

presented to EPA and DER for us to select the

preferred alternatives.

We are well aware of what the

ERM proposed, I disagree with you in that they

¥

37

were severely critical of the enhanced recovery

process.

MR. SWIFT: One of the proposals

apparently endorsed by EPA is to build a fence. I

think it's a 2,000 foot fence, which would keep

the public out.

Why would you endorse building a

fence when there is very limited public use of

this area and based on the information you gave us

tonight, there is no danger to the public from

using it?

MR. BANKS: There is not as much a

possibility for human exposure, I think we are

going to be taking remedial activities at the

site. There is going to be process equipment on

the site. There are ways to get on the site,

albeit, limited from the one flood plane area by

McMichal Creek and from the other side of Brodhead

Creek.

The extent of the fence is something

that can be determined during the remedial design.

I don't foresee fencing the entire site,

necessarily.

flR500i35

38

¥MR. SWIFT: Is it true that, is it

still true, as set forth in the remedial action

plan that the Department of Environmental

Resources in Pennsylvania has taken no position

with regard to the remedial action plan?

MR. BANKS: I think we have had

numerous discussions with DER and I think they are

on board with what we are trying to do.

MR. SWIFT: Have they taken any

official position?

MR. BANKS: Typically official

position isn't given until the record of decision

is designed.

MR. SWIFT: Now, approximately

$600,000 was spent to complete this on that table,

and what is known as the RIFS. It is my

understanding that the proposal tonight that you

have outlined is an interim proposal, not a final

proposal. And after spending $600,000 on the

study, why can't the agency recommend the

permanent solution?

MR. BANKS: They can't r cjDDimnjejidoa-

permanent solution simply because we are still a flh

39

little bit unclear as to the quality of the

bedrock aquifer. But we would like to be

confident in a final position for the site.

I think taking an interim remedy to

address the principal threats is in line with an

eventual overall remedy with the site.

And I think there is nothing wrong

with going back and looking at the bedrock aquifer

to make absolutely certain that here is no

vertical migration of contaminated ground water

for that unit.

MR. SWIFT: The alternative five

endorses technology I think that is generally

referred to as the crow process. Isn't it correct

that this technology is unproven?

MR. BANKS: It is an innovative

technology, it is still being evaluated under the

superfund innovative technology program.

As I understand, though, some of the

subsurface soils from the Brodhead Creek site have

been sent to, I believe the Western Gas Research

Institute, who have done bench scales on

subsurface soils at the site. And from m§ R b UU I O /

40

discussions with them, the results seem promising

and that it very well could work.

And in addition to that, we are going

to be conducting treatability studies at the site

to see how actually it does work in the field.

MR. SWIFT: Why would the

treatability studies be completed after rather

than before the ROD, rule of decision is entered?

MR. BANKS: Jeff Pike?10

MR. PIKE: Essentially we feel we

have enough information to have a record decision

that there is enough available data to profit the

work for this site. The feasibility study will

fine tune the design for that.

MR. SWIFT: Isn't it true that you

have no data on field testing the feasibility of

this process at any similar site?

MR. PIKE: As John said, there was

some actual samples taken from this site and we'll

have a very intense feasibility study done on this

particular site, if this is the remedy that is

chosen and we will be monitoring it. AR500I38

The short answer, if this has been

¥

¥

41

done in the field before, I don't have an answer

for that.

MR. SWIFT: Well, isn't it

appropriate to first determine the feasibility of

the process before deciding to spend a good deal

of money, in this case 4.2 million dollars?

MR. BANKS: I think we are doing

that. We are not just going in there and putting

this process in place and running it. We have

indications that it will work based on actual

soils taken from the site itself.

And we are going to be running the

treatability studies before the full scale

implementation of this process.

MR. SWIFT: Will the results from

those treatability studies be publicly available

and if they show that this process will not be

successful, what will happen to the ROD?

A The results from the treatability study

will be publicly available. If we find after the

treatability study that the process will not work

at the site, what we will do is go back and

re-assess the alternatives and re-ROD the site.

————————————————————ARGQOiOQ

42

¥MR. SWIFT: Since the feasibility in

the field of this technology hasn't been shown,

why hasn't the agency collected a commercially

available and proven technology at this site?

MR. BANKS: Part of the superfund law

is to look at innovative technologies to apply

them to superfund sites, and we have a technology

here that looks like it will work. And it looks

like it will work quite well by removing the free

coal tar.

Some of the other alternatives

presented had, in going through the nine criteria, WJf

had some disadvantages, moreso than the enhanced

recovery process did.

MR. SWIFT: My client has spent over

a million dollars at this site in terms of cleanup

and investigation, why does the agency think that

more money, presumably from parties like my client

should be spent on technology that hasn't been

proven in the field?

MR. BANKS: We keep going back to the

same, I understand your point, but I think we keep

going back to the same thing. We are not, I don't

AR500UO

43

^^ think we are going to be wasting anybody's money.

We are not going to apply this technology if it is

not going to work.

And again, we have run studies on the

subsurface soils and it appears that we do get 60

to 70 percent recovery, maybe even more based on

the treatability studies. I mean I can't tell for

sure at this point, but, of course if the process

is not going to work, we are not going to

implement it.

MR. SWIFT: But do I correctly

understand that in pursuing this process, it is

not your intension to spend EPA's own money as

opposed to other people's money?

MR. BANKS: Well, I don't understand

that question. I mean the first thing we are

going to do is of course try to have the potential

responsible parties try to pick up the costs.

EPA will then, if failing to do that,

pick up the cost under the superfund to implement

the process.

MR. SWIFT: You spoke earlier about

the treatment of water. As I understand the .., j.

44

¥process, there would be thermal injection. How

hot is the water that is going to be injected?

MR. BANKS: I don't remember that the

feasibility study had a specific temperature, it

was what is called a low grade scheme which is 50

percent, contains about 50 percent water.

MR. SWIFT: But you don't know the

temperature?

MR. BANKS: I know currently that

subsurface soil is approximately 46 degrees

fahrenheit, 50 degrees fahrenheit. The coal tar

would have to be heated to approximately 86 mj

degrees fahrenheit to mobilize it.

I am assuming a water temperature,

since we are talking about low grade steam, over

150 degrees.

MR. SWIFT: Won't that in effect

sterilize all micro-organisms in the soil?

MR. BANKS: I actually cannot answer

that at this time. Again, that is, even under a

treatability study, I think that is something we

would want to look at. j\ R 5 0 0 1 4 <l

We don't want to cause more of an

45

environmental impact trying to remediate the site

MR. SWIFT: Are you saying then that

if it did kill off all the micro-organisms that

you would not proceed?

MR. BANKS: I don't think I can

answer that at this time. I am not a biologist

and I don't have the expertise in that area.

MR. SWIFT: Based on what you called11

the bench tests, how contaminated will the water

be that you will seek to re-inject into the ground

and or discharge into the stream?

MR. BANKS: Well, ground water, once

it's pumped, will be treated. It has to be worked

out and designed. To move the organics, maybe

some sort of filter, maybe some sort of biological

treatment to remove organics from the processed

water. Maybe some sort of chemical precipitation

to remove some of the metals from the processed

water.

But any processed water that we

discharge to the creek or that we re-inject back

into the subsurface will meet the nationalA R 5 0 0 \kpollution elimination discharge system

46

requirements for discharge.

So we are looking at coming up with

pretty stringent levels for discharging processed

water.

MR. SWIFT: Are you familiar with any

technology that can treat the coal tar mixed with

water to eliminate the contamination so that you

then can re-inject the water at the level that you

say the contaminants will be?

MR. BANKS: I still think that is

something for the design to work out. It is not

coal tar and water. The coal tar can be separated

from the water. What we are talking about is

contaminated water.

MR. SWIFT: So you don't know that at

this stage?

MR. BANKS: I would say that

treatment of water is proven technlogy, there are

proven technologies. And I think organics, one of

them is biological treatment of the water.

Now, I do believe, but I cannot say

for certainty but I do believe that the

requirements could be met. A H b U u l 4 4 ¥

47

MR. SWIFT: Do you know how large a

treatment facility would have to be erected on

site?

MR. BANKS: That is all part of the

process design and all part of sizing.

MR. SWIFT: You don't know that?

MR. BANKS: Not from the feasibility

study. That is to show us, present alternatives

and show us conceptually what is going to happen.

MR. SWIFT: It's my understanding

that the State of Pennsylvania has taken the

position that nothing can be injected into the

ground or discharged into a stream which doesn't

meet background levels. I personally don't agree

with that, but will this water that is taken out

of the ground with the coal tar constituents and

treated, meet background levels when it is

re-injected?

MR. BANKS: Well, as far as

discharging to the stream, I don't believe the

background applies. The background applies to

ground water. As for re-injection of the

processed water back into the subsurface, at this

48

¥time because it is an interim remedy and we are

not looking at ground water treatment or

evaluation as part of this interim remedy, just

looking at mitigating the principal threat from

the free coal tar and subsurface soils, the

background right now is not really considered --

MR. SWIFT: Are you able to say

whether or not the water that will be discharged

into the stream after being treated on site will

be better or worse than the ground water that

currently flows from the site into the stream?

MR. BANKS: You are asking me if the JV

process water after treatment is going to be a

better or worse quality than the ground water

currently in the stream, in the subsurface?

MR. SWIFT: Let me restate it. Ground

water currently is entering the stream and has

been measured and tested in remedial

investigation. Isn't it true that it is very

likely that the ground water, not the ground

water, but the water that is taken from these

wells through your enhanced recovery process, will

¥

49

currently going into the stream?

MR. BANKS: I don't follow your

logic. The ground water that we are going to be

extracting as part of the process will be highly

contaminated, but if we run it through a treatment

unit, we are going to meet all applicable

regulations before discharging into the stream, so

it should be much, much cleaner than the ground

water that is currently discharging into the

stream.

MR. SWIFT: Now, you will be

injecting water at very high temperatures under

pressure into the ground, there is currently a

slurry wall in place which is apparently according

to DRI has been very effective. Do you have any

study to show that this enhanced recovery process

will not worsen the situation by causing more coal

tar constituents to reach the stream?

MR. BANKS: I think with the enhanced

recovery process, the way it was stated in a

feasibility study, is that a remediation cell is

going to be blocked off. Within that remediation

cell we are going to keep hydraulic control of theAR50U 1 4 /

50

ground water.

When injecting the stream, it is

conceivable that we are going to be driving more

of the coal tar constituents into solution in the

ground water. By maintaining the hydraulic

control within the remediation cell, we will not

let that contaminated ground water escape that

remediation cell and thereby minimizing any impact

from the enhanced recovery process from driving

coal tar constituents into the ground water.

MR. SWIFT: Again, isn't it a fair

statement to say you have no field data to show

that you could be successful in doing that?

MR. BANKS: No, but again, that's

part of the treatability study.

MR. SWIFT: Now, has EPA performed a

cost benefit analysis of the various alternatives?

MR. BANKS: Yes, I believe we have,

using the nine evaluation criteria.

MR. SWIFT: What is the cost per

gallon of removing a gallon of coal tar and using

AR500U8MR. BANKS: We haven't gone through

¥

¥

¥

51

those lengths.

MR. SWIFT: Isn't it a fair statement

that the cost would be about $370 per gallon?

MR. BANKS: I wouldn't know, I

haven't done the calculations.

MR. SWIFT: Isn't it also a fair

statement that the cost of simply excavating and

removing soil would be about $15 per gallon?

MR. BANKS: Again, I haven't done the

calculations, but the excavation does have other

disadvantages. You are talking about excavating

large volumes of soil, exposing coal tar

contaminated soil, which you are going to get more

volatilization of some of the constituents in the

coal tar to the air. You are talking about stock

piling soils on site for an extended period of

time increasing possible human exposure.

I mean, there are other, there are

some disadvantages to the excavation which don't

make it a very good candidate for the site.

MR. SWIFT: Now, isn't it also true

that in the 4.1 million dollar estimate for this

enhanced recovery process, that the

s

21J

1

j

55

i$3j

i

wasn't even included?

52

¥MR. BANKS: That's corret. The

feasibility study did look at soley the RCC area

where the free coal tar was. Because the free

coal tar is an area which is the source of the

highest contamination

that all the free coa

Based on the treatabi

to the ground water, we feel

1 tar should be cleaned up.

lity studies, we would also

like to apply it to the area around MW2 .

Now the

reflect the cost for

Since the MW2 area is

cost I believe would

million, a million to

cost estimate does only

applying it at the RCC area.

much smaller, the additional^

seem to be about another

two million dollars to apply

it to that area.

MR. SWIFT: That would take it

approximately up to the same cost as total

excavation?

MR. BANKS: We're not talking about

total excavation. We're talking about excavation

of a hot spot. And we're not talking about the

excavation of area MW2 , where excavation not be

applied .

AR500150

>

p

53

MR. SWIFT: Now, this --

MS. DICOSMO: Excuse me, do you have

very many more questions? Because we really need

to move on and let some of the others have a

chance.

MR. SWIFT: Not many more, sure.

Isn't it true that for this five or

six million dollars that would be spent on this

proposal, assuming as you have, that you're going

to do the MW2 as well, that you'll only be

removing three to six percent of the total coal

tar at the site?

MR. BANKS: I guess that's true based

on current estimates. But the coal tar that we

are removing is the coal tar that is causing major

contamination at the site. It is the free coal

tar. The residual coal tar was spread throughout

the rest of the site.

It's relatively immobile, has

probably lost most of it's volatile chemical

content, and it's not probably imparting that much

contamination to the ground water as opposed to

the high levels being imparted by the free coalAR500I5I

54

tar, which are the main source areas.

MR. SWIFT: Now, a little earlier in

your presentation, you mentioned that the United

States had helped the State of Pennsylvania design

the rechannelization in 1960. And in fact the

United States was party to a lawsuit with my

client, where the United States was sued and

Pennsylvania is currently being sued for

contribution. Pennsylvania is also an owner of

some of the land at this site and has a permanent

easement.

Do you know whether EPA or DER have

any plans to contribute to the cost of the work

that would be done?

MR. BANKS: At this time you are

getting into litigation enforcement questions and

at this time I'm really not going to -- final,

determinations haven't been made yet as far as who

may be potentially responsible parties at the

site.

I think it is just premature to start

answering those questions.AR500I52 ,

MR. SWIFT: Thank you. mJL

¥

55

(Whereupon a brief recess was taken.)

MS. DICOSOMO: We are ready to

resume, may I have the next comment or next

question?

MR. BAYLOR: My name is Don Baylor

and I am an aquatic biologist and I am associated13

with a lot of local conservation organizations.

I have a couple questions.

In the process you are proposing, do

you have any idea of what volume of water you

might be discharging into the stream?

MR. BANKS: Again, those are design

considerations. I think what we would try to do

is try to recycle as much as possible and try to

minimize the amount.

MR. BAYLOR: I suppose you don't have

an idea at this time what temperature the water

might be when it is discharged to the stream?

MR. BANKS: I guess those would be

design considerations. I would imagine it would

probably be the ambient temperature.

MR. BAYLOR: It also might be one of

the MPDS limits that would be construed. One of

AR500i53

56

tthe concerns I have, and this is the major reason

for these questions, the lower Brodhead, that is

actually Brodhead Creek, is classified by DER as a

trout stock fishery which does not assume any wild

trout population. It assumes that the stream can

support stock trout for a certain time of the

year. It doesn't maintain stream bred or wild

trout.

My concern is that in fact the

Brodhead below Stroudsburg and East Stroudsburg

for some distance is a very viable fishery for

trout through the entire season, although it does WJ

reach critical temperatures at some times for

trout.

And I would be concerned about any

discharge to the stream as far as its thermal

quality as well as its chemical quality for that

reason.

The MPDS requirements would probably

be for a trout stock fishery, which may assume

that you don't have to maintain trout at that

time, later in the season in the lower Brodhead,

when in fact lower Brodhead does maintain wild Jfe

57

trout.

It's not recorded scientifically very

adequately by either DER or the Pennsylvania Fish

Commission because physically it's the type of

stream that is very difficult to survey. It's of

the size you can't survey, very adequately wading,

but it is not big enough that you can get into

with a boat unit and survey it.

Many of us locally know that it is an

excellent trout fishery and we're concerned about

any discharge into it on that basis. That is my

main concern.

MS. DICOSMO: Okay. Next? Sir?

MR. MASSE: My name is Thomas Masse,

presently with Timco Environmental Consultants.

I've spent 15, 16 years with the corps of

engineers and that many years with EPA and the

past year and a half I have been in my own

consulting firm.

I was the original EPA federal person

to come up on the site, 1980, '81 and put in the

present slurry wall and stop the coal tar from

entering the environment. A R D 0 0 i t) 5

58

¥I am pleased to hear after ten years

the wall that I put in is still working and in

fact I note from one of the reports the word

excellent, so I take that as a compliment. All

the efforts that we did back then and not knowing

what we were dealing with, but still able to

control and stabilize the situation that was not

controlled and not stabilized.

I have been retained by the attorneys

for Union Gas to review the studies that have been

performed. I've spent ample time in looking them

over and quite frankly I'm confused on some of the^P

elements, so I hope you bear with me with the

questions that I ask concerning the study.

I note that this alternative five is

a proposal which of the 418,000 gallons estimated

to be there in four point some acres, that only

three to six percent would be removed as a threat

from the environment by basically this proposal

that you have.

Do I understand that correctly?

MR. BANKS: That is essentially

right.AR500156

59

MR. MASSE: If that is the proposal

in alternative five, the system that will be used,

if I understand the engineering, is still yet to

be determined by some treatment system,

treatability system that you'll put into effect

after you approve the system? You are going to

evaluate what you propose to do after you start

doing it?

MR. BANKS: I keep going back to the

same thing all the time.

MR. MASSE: I know, that's what is

confusing to me, so I am from Missouri here a

little bit and I have been in this business and

around the block a few times. And I'm very

confused on the procedure.

MR. BANKS: We have done, scale

studies have been done under the sites programs

which I am sure you are familiar with?

MR. MASSE: Yes.

MR. BANKS: And showed very promising

results. I spoke to somebody in the sites program

about Brodhead Creek. They were well aware of

Brodhead Creek in the EPA Cincinnati lab.

60

Enhanced recovery showed promising mj

results with the soil samples that were sent to

Western Gas Research Institute to try bench scale

studies on the soils of Brodhead Creek.

So we are confident that it is going

to work. The matter of doing the treatability

study is to see what the optimum performance is.

I think another matter is, you are

right, we do have to test it in the field, who is

to say we don't get better results in the field.

MR. MASSE: The Alaskan oil spill is

a prime example I'm thinking of where the steam

jetties were brought out into the field to clean

off rocks. The studies from that Alaskan oil

spill determined that more damage was done by

reason of the heat and thermal water of the

washing of the oil off of the rocks and gravel,

caused more damage by making the soil sterile.

And if I understand your proposal,

that you are going to inject hot water, basically

hot water jets and steam down 25, 50 feet to

loosen up all the oil between the gravel and make

it flow and then suck it up, all of this mass of

AR500I58

¥

¥

61

oil and now contaminated water. Is that what I

understand what the proposal is? I don't want to

oversimplfy.

MR. BANKS: I think you understand

the enhanced recovery process and maybe, Bob you

can, I don't know about steam sterilizing the

soil.

But I think one thing I do want to

say is, we are talking about a 12 acre site. The

RCC area is a 9,000 gallon pool. But we are

talking about applying the process of a

remediation cell, which when looking at the

overall acreage of the site is a very small

portion of the site.

MR. MASSE: You do realize when

injecting water, when you inject a lot of water

heated, steamed, into an enviroment that is

unsterile, insitu, you are going to cause

something to happen. Either bubbling up, moving,

this unknown further contaminated water into other

areas .

Something has to happen when you

inject a lot of hot water into the ground. That

AR500159

62

4problem alone will exist. ^Br

The secondary problem that you'll

have is when you bring this material up to

separate it, and then possibly re-inject that

again causing further problems of hydraulics in

the ground water and the movement of contaminated

water, and all this is based upon some test in the

field that will be developed after you approve the

system.

That's what I understand the proposal

is .

MR. BANKS: As far as driving, I 4fc

already understand the concerns about causing more

harm than good. But we are trying to minimize as

much as possible any detrimental effects that may

be caused by this process. We are blocking off

the remediation cell.

Hydraulic control within that

remediation cell, you know, we are going to drive

probably more of the coal tar constituents into

the solution. But with the hydraulic control if

we can maintain it within that remediation cell, I

don't think we are going to prevent more lateral

AR500I60

>•

•

•

•

63

spreading of contaminated ground water or more

contaminated ground water.

As far as the steri

soil, Bob?

MR. DAVIS: Yes, I

have to worry about that at that

way, I'm Bob Davis with EPA.

lization of the

don't think you

facility. By the

The living creatures down there

are sparse to be sure, wouldn't

what happened up in Alaska. It

comparable environment.

MR. MASSE: In the

the material that are you going

be comparable to

is not a

treatability of

to bring up and

the free injecting back into, what contingencies

do you have that this natural insitu -- and I'm

talking the slurry wall, the twelve point acres

where there is almost no significant health threat

is emitting from it.

It is just sitting there and that

there is from your own test, indicate that there

is no dectectable contamination

Creek from ground water sources

level of certainty.

entering Brodhead

that you feel a

AR500I6I

64

And this proposal that what you are 4A

doing there will not further generate potential

problems of contaminating the surface of Brodhead

Creek and letting discharges of water that is

re-injected back in to the stream.

I mean is there a level of certainty?

MR. BANKS: I think again, the

treatability studies will show that.

MR. MASSE: And I do recall a

question asked earlier, that the treatability

study will be made public information, correct?

MR. BANKS: Yes.

MR. MASSE: And the treatability

studies will be based upon field implemented

tests?

MR. BANKS: Yes, in the field.

MR. MASSE: I think I hit you pretty

hard on this alternative five, my opinion on this

alternative five is that it's not the only act.

And for you people to be possibly looking at this

where the net result is only three to six

percent --

MR. BANKS: It's three to six. percent

¥

fix percenti#500162

65

of the highest contamination areas.

MR. MASSE: Three to six percent of

418,000 estimated gallons.

MR. BANKS: It's the source of the

highest levels of contamination.

MR. MASSE: The fact remains, if I

read it right, it's three to six percent, you are

giving your best shot here, you are saying three

to six percent of whatever the contamination

problem is in this area will remove 4.12 million.

I understand that.

I am saying that I don't feel that it

is the alternative that would find the solution to

your problem. I don't think you get the biggest

bang for your bucks and I think you are leading

too much up to a wish that the treatability

studies will do this for the feasibility of that.

So I recommend that you revisit some

of your alternatives, maybe the five or so that

you have there. Even still, I think that there is

too much out there that is tried and proven to go

with unproven technology.

Thank you.

AR500I63

66

¥15 MS. DICOSMO: Next question or

comment?

MR. SWIFT: I have one more. In

terms of the, we've been talking three to six

percent, I think we need also to point out that of

that three to six percent, perhaps half of that is

the easy to get coal tar, the so-called free coal

tar that can be pumped out at a cost of mabye 20

to $30,000.

And the other half is what you will

be spending virtually all the money for; is that

correct?

MR. BANKS: No, I don't think that is

quite true.

MR. SWIFT: Can you give me then a

breakdown of how much free coal tar you'll get at

a much lower cost, how much other coal tar you'll

get at the significantly higher?

MR. BANKS: Under, what you're

talking about is alternative number two which is

the intermittent pumping, feasibility study

estimated approximate recovery of 50 percent of

the free coal tar. So we are talking about 4500 ^^

AR500161*

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.0

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67

gallons possibly.

Under that alternative, you are going

to get virtually none of the residual coal tar

because it is too tightly bound to the cobbles.

I think with the enhanced recovery,

you are going to get, I believe the estimate was

7200 hundred gallons. You are looking at 60 to 70

percent removal of the free coal tar in the coal

tar pool. And you are also getting up to maybe

another ten thousand gallons of the residual coal

tar lying about that stratagraphic sink.

I think also by getting that residual

coal tar, you are helping to prevent the amount of

coal tar that you had available from running back

down and into that sink and re-accumulating.

MS. DICOSMO: Next?

MR. MATERGIA: Ralph Matergia,

solicitor for the Borough of Stroudsburg. To what

extent is the Borough of Stroudsburg a potentially

responsible party to recovering cost?

MR. BANKS: At this time I really

don't want to comment on that because typically

when we will know the potentially responsible

IIt)

•

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68

parties is after the record of decision is signed. •

At this time I don't think any final

determinations have been made.

MR. MATERGIA: Has there been any

communication between your department and the

Department of Environmental Resources indicating

that the Borough of Stroudsburg is being

considered as a potentially responsible party?

MR. BANKS: Again those are ongoing

enforcement activities and whatever other

litigation activities which we just don't feel we

can comment on at this time. m

MR. MATERGIA: Do you have any reason

to believe, Mr. Banks, that any of the parties who

were designated as potentially responsible parties

back in 1980 are not being considered as

potentially responsible parties today?

MR. BANKS: Again, I'm going to

defer, those are legal questions and we will, you

know, finalize our determination of who the PRP ' s

are and submit specialized letters to them.

MR. MATERGIA: Am I lead to believe

from the discussions we had today and this evening J

AR500166

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69

that the risk of migration of the coal tar into

the Brodhead Creek is itself really not a

particular concern at this point as, the slurry

wall had basically contained the coal tar from

entering the stream?

MR. BANKS: If you are speaking about

the free coal tar entering the stream, I'd say

yes. And as for the ground water that is

contaminated, discharging into the creek that's

not concerned either because it's just being

diluted since hitting the creek.

MR. MATERGIA: And therefore, is it16

accurate then that the impact or concerns that

your agency is addressing with respect to this

remedial plan is the impact on ground water

solely?

MR. BANKS: Yes.

MR. MATERGIA: If you can, maybe in

some lay terms, give some appreciation for the

risk of the residual coal tar to the ground water

versus the hole that you are speaking.

MR. BANKS: Well, when talking about

the coal tar at the site, I think what we can say

————————————————————————AR5QQ1G7—

70

is the free coal tar pools compart the highest

levels of contamination. I think some of the

ground water results were got for benzene, which

is one carcinogen was 1100 parts per billion,

which is above its drinking water standard of five

parts per billion in the ground water.

We are also looking at arsenic which

is another carcinogen which is at 108 micrograms

per liter, which is also 108 parts per billion.

Its drinking water standard is 50 parts per

billion.

If you are looking at the number of

PAH's and benzoid pyrine, chrysine and denopyrine,

which are well above they're drinking water

standard of point two parts per billion.

There is a high level of

contamination being imparted to the ground water

at the free coal tar areas.

Now, as we move away radially from

the free coal tar areas, not only the RCC area,

but the smaller part pool at MW2, we see a

decrease in the contamination in the ground water.

What that suggests is that the highest levels ofAR50QSS8

¥

¥

71

the ground water contamination is the free coal

tar. It contains the most volatiles and still the

most soluable constituents.

The residual coal tar spread

throughout the rest of the site is probably

stripped of most of its volatile content. It's

become very sticky.

PAH's don't have a tendency to

dissolve into ground water. They have a high

affinity for staying bound to soil particles and

to organic particals.

So, I think by removing the free coal

tar, you are going to drastically reduce the

amount of ground water contamination on site.

MR. MATERGIA: Now, with respect to

these alternatives, explain to me, if you will,

the alternative, I think it was six, that had to

do with the excavation, is that limited to just

the areas where free coal tar is located?

MR. BANKS: Well, more specifically

it is just limited to the RCC area which is the

bigger pool.

MR. MATERGIA: That doesn't treat the

____________________flR.snn {sg

72

¥second area?

MR. BANKS: No, the problem with the

second area is it abuts the slurry wall.

MR. MATERGIA: Excavation with

potential damage to the slurry wall?

MR. BANKS: That's right, we could

reach the slurry wall.

MR. MATERGIA: Does pumping at the

location of the MW2 prefer an alternative to the

alternative five? In other words, I guess what I

am asking you is could you excavate at the one

location on the RCC and have to pump the RW2? f|P

Is that an alternative?

MR. BANKS: Well, you could do that.

What you can do under the feasibility study is

take portions of alternatives and combine them in

a record of decision.

Again, I do want to re-emphasize, as

far as the excavation which when going through the

nine evaluation criteria as far as the

implementability, because of the high water table

and silty sand, you have a running sand problem

and we feel we are going to run into significant mj^

AR500I70

73

problems as far as slope stability going with

excavation in that area, which is going to have to

go down approximately 30 feet.

MR. MATERGIA: In evaluating that

particular alternative, did you speak to any of

the parties that are involved in the project,

reconstruction of the sewage treatment plant here

in East Stroudsburg, speak to the contractors and

engineers involved in that project?

MR. BANKS: No, we haven't.

MR. MATERGIA: I might suggest that

you do so. They had to undertake excavation in an

area that is fairly close in proximity to this

area, to get a better idea what to expect when you

dig down.

Tell me if you will, where this

process has been undertaken with respect to coal

tar removal other than where you had other

experiences with this I guess is what I am asking?

MR. BANKS: I would have to get more

information on that. I am aware that it was

applied at one other site that had similar coal

tar contamination problems. But I'd be happy to

74

¥get you more information on that.

What can the residents of the Borough

expect to observe while the recovery process is

being undertaken? What are we going to see when

we drive by and stand on the bank and fish and so

forth?

MR. BANKS: I think what you are

going to see, this process calls for ten injection

wells and two extraction wells. So you are

looking at 12 wells being put in, one remediation

cell on site.

for heating the water for injection into the

subsurface. There is going to be some sort of

phase separator on site because when you pull up

the recovered coal tar, you are going to pull up

coal tar and process water and you are going to

have to separate the two.

And You are probably going to see

some sort of on site treatment system for the17

process water of which I don't know yet,

biological filter, chemical precipitation,

r true

AR500I72possibly also a tank, to hold, tanker truck or a Jfc

75

tank to hold the recovered coal tar as is being

recovered for eventual shipment off the property.

MR. MATERGIA: I think your report

talks about a period of time, six months?

MR. BANKS: It talks about six months

to implement the process. I think the report

assumed an operation time of approximately three

years.

MR. MATERGIA: How would you propose

to secure the site other than to fence it,

assuming that the concept of fencing is determined

by the community as unacceptable or undesirable?

MR. BANKS: Fencing is undesirable?

MR. MATERGIA: Well, I'm asking you

to assume that it will be.

MR. BANKS: I guess what we could

look at is posting a guard there.

MR. MATERGIA: What will the site

look like after you're gone?

MR. BANKS: I wouldn't imagine it

would look any different than it is now.

MR. MATERGIA: Will it be fenced?

MR. BANKS: I think we call Rroafi<P tha>t

76

¥determination at a later point.

MR. MATERGIA: Who will bear the long

term maintenance responsibilities with respect to

the site?

MR. BANKS: State of Pennsylvania

typically has to give an assurance. Well,

actually I should say if it is undertaken by

potentially responsible parties, typically we try

to get them to pick up the long-term operation and

maintenance on the site.

Barring that, typically we could get

an assurance from the state to pick up operation mjp

and maintenance.

MR. MATERGIA: Anybody from the State

want to speak to the question of whether or not

the State will try to pass that responsibility off

to the Borough of Stroudsburg?

Nobody wants to give me that

assurance?

MS. DICOSMO: Any further questions?

MR. ROGERS: Carl Rogers for the

Borough of Stroudsburg. What was the MPL score?

MR. BANKS: I believe the MPL score Jfe

AR500I71*

77

was 31.09.

MR. ROGERS: Presently the total

excess carcinogenic risk is less than the

acceptable amount; is that correct?

MR. BANKS: Yes.

MR. ROGERS: Do you have any idea how

the remedial action that you are proposing would

further lower that risk?

MR. BANKS: Well, with the risk

assessment, the risk assessment did not take into

account ingestion of contaminated ground water on

the site. It took everything else into account

other than that.

At the time the risk assessment was

being done by the PRP's, EPA felt that because we

? already exceeded drinking water standards in the

shallow ground water, there was no need to do a

risk assessment on the ground water because it was

clear, there was a potential health threat already

there.

As I said, the benzene concentration,

arsenic and benzoid pyrine exceed the promulgated

drinking water standards for human cons&mp5tQLon!.7 5

3

78

And it is our belief that when we remove these

coal tar pools, we are going to substantially

reduce the human health threat from ingestion of

that ground water because we are going to be

lowering the concentrations of the constituents in

the ground water significantly.

But again, I also have to

re-emphasize again at the same time, it is very

unlikely that somebody will screen a well in the

gravel unit at the site simply because of a number

of site constraints. It's in a flood plain, it's

in an industrial area.

A well screened in that unit may not

even produce enough water. It may to supply a

small household or a small business. But because

we cannot impose, there are no restrictions from

somebody putting a well in that area, we have to

take into consideration possible human health

threats if somebody were to screen a well in the

ground.

MR. MATERGIA: Mr. Banks, we have

ordinances in the Borough of Stroudsburg that

prohibit instituting wells in our town. We have a

¥

¥

•A R 5 Q Q I 7 6

79

municipal water system. We don't permit, but we

make mandatory that the water service connection

be municipal. Does that fact have any impact on

evaluation?18

MR. BANKS: I think that is something

we have to take into consideration. I am glad you

brought that up.

MR. MATERGIA: Let me ask just

another question, assuming you draw a line around

an area where you would like to prevent wells from

being dug for health reasons. What is then the

risk of contaminants in the ground water outside

that area? What happened at that point?

MR. BANKS: Well, I would say

upgrading it, meaning towards the west of the

site, I don't think you are going to see

significant contamination because of the ground

water flow, it is basically moving the

contamination towards the creek.

I would definitely still like to see

bedrock analyzed because I want to be confident

that the bedrock is not being impacted.

If the bedrock is not being impacted,AR500I77

80

it would seem that indeed the shallow ground water

is discharging into the creek and therefore it is

not going to impact anybody on the opposite side

of the creek.

So I think if we drew a circle

around the site where you are not going to allow

wells, I think we can be reasonably confident that

there is going to be no human health threat.

MR. MATERGIA: Is it possible to do

the testing, test wells in bedrock prior to

institution of this recovery method?

MR. BANKS: We certainly want to

¥

¥expedite trying to put these test wells in. I

still think though that we need to go back and

re-analyze it. The problem I am having I guess is

that you still, barring even the exposure, you are

still having degradation of a natural resource.

And generally under the ground water protection

strategy that we do want to try and return ground

water to its beneficial use.

And I think given the information

that you just told us that there are ordinances in

the City of Stroudsburg for putting in private 4fe

AR500I78

81

wells, I think we would need to take that

information and go back and re-analyze the

situation.

MR. MATERGIA: And also, just for

informational purposes, you know the Borough's

limits basically stop at the stream. You are

talking about wells on the other side of the

stream, you will have to talk to the officials of

East Stroudsburg, where I believe they have a

similar ordinance.

MR. BANKS: This is a question for my

own. There are some private wells, though, in the

area. There are 40 wells in a two mile radius.

Was this ordinance enacted recently or are these

older wells?

MR. ROGERS: Two mile radius will

take you well outside the Borough of Stroudsburg.

MR. BANKS: I believe there are some

inside the Borough. I can't remember, there is

one hotel. Indian Queen Hotel or something like

that?

MS. SNOPARSKY: I have a question.

If the people were to be hooked up to pufa^ftfe Q Q j 7 9

82

water, does that prevent them from putting a well

in themselves?

MR. MATERGIA: I think so.

MR. ROGERS: Not only the Borough,

but DER regulations also.

MS. SNOPARSKY: DER I don't think

does .

MR. MELLOW: John Mellow from DER.

DER does not have any regulations regarding

installation of wells in private residences. We

have regulations on anything but commercial

supply.

MR. MATERGIA: Perhaps if you would

exchange your information concerning well

locations, we will respond.

MS. DICOSMO: Next question?

MR. MASSE: I just have a followup.

In the alternative five, your option five, you are

proposed to go ahead with it, in the event that

you don't go ahead with five, as it has been

presented here tonight and you modify it or go to

another proposal, would there be another public

meeting? AR500180

¥

83

MR. BANKS: I believe there would be.

MR. PIKE: If due to the comments

from the public, folks here, written comments we

receive, the agency and the consultation with DER,

we determine there is another alternative that may

be better for the site, re-evaluation of the

information that came in.

If it is one of the alternatives that

we presented tonight, we would not have to go out

for more public comment. If it is something other

than one of the alternatives we presented here,

then we would have to go out to the public for

comment.

It may be a combination of one or two

of those, but the point that I made earlier, maybe

excavation and pumping of the wells. But as long

as it is a combination of something presented

tonight here, essentially we would not have to go19

out for public comment

MR. MASSE: Well, the only comment I

made about that is I am under the impression that

the option five is the preferred option and that

was presented and not the other five options were

———______________QRsnnm

84

presented. VP

MR. PIKE: Well, the proposed

remedial action plan talks about each one of the

altneratives. The public administrative record of

those studies identifies the different

alternatives.

MR. MASSE: But it doesn't afford an

opinion for any request or information in the form

that you presented here in that I might have

opinions on the other options which I didn't

express as being feasible or not. I know that

option five is not a viable action opinion, you

don't get your bang for your bucks in my opinion.

In the presentation I understood

clearly what was said by EPA and what they propose

to do. I understood that very clearly about the

treatability and the unknowns, the costs

associated with option five.

I do not have an explanation other

than reading a document and not having a public

forum on the other five options and I just am

wondering the wisdom of you people not explaining

to the public or having an opportunity to respondAR500182

1*

0

=?

1

15z_J

5a

3

3

*

85

to the other five options if they are viable or

not.

MR. BANKS: I think you do have a

public forum. I think the purpose of this public

meeting is for us to present our preferred

alternatives, but it is to get comments from the

community on the preferred alternative on the

feasibility study, on the remedial investigation

report and on all the alternatives that we

presented.

I mean if you don't have an

understanding of an alternative I put up here on

the screen, I would entertain questions on it and

I think you would be afforded that opportunity.

MR. SWIFT: Since you have raised

that, let me ask you about the excavation

alternatives. This was an alternative that a year

ago, I believe, in papers filed with the Federal

Court in Philadelphia, the State of Pennsylvania

should be done. What is EPA's position as to

whether or not the entire site should be excavated

and removed and new soil should be brought in?

MR. BANKS: I am not aware of DER'sAR500183

86

t'

we would not like to see full scale excavation on

the site. I think then, you are talking about

getting a bang for a buck, then you are talking

about enormous costs, you are talking about

tearing down a flood control levee, damage to

wetlands, rerouting public utilities underneath

the site.

And I don't think the, I just don't

see it being feasible to even do something like

that.

MS. DICOSMO: Anyone else? flfc

MR. ROGERS: 4.2 million is the

estimated cost of OUl or your performed

alternative five, that is not the end of the

operation as I understand it, there is an OU2?

MR. BANKS: Yes.

MR. ROGERS: What would be involved

in OU2?

MR. BANKS: OU2 is going to involve

further investigation at the site simply with the

bedrock aquifer. We want to assess the quality of

the bedrock aquifer. Take that information,

AR500i8Ii

87

analyze it against the other ground water results

that we do have and in conjunction with how, if we

do implement the preferred alternative, which is

the enhanced recovery, how that is working, we

come up with an overall site plan.

And the determination of what the

otherall site remedial action would be will be

made at a later date.

MR. ROGERS: So OU2 would take place

simultaneously --

MR. BANKS: Yes.

MS. DICOSMO: If I might add, the

same process would then be implemented in terms of

the steps that we were talking about earlier. We

would then again, when those decisions are ready,

those alternatives were prepared and we would

again come out with a remedial plan for that and

implement it.

MR. ROGERS: EPA will assume these

responsibilities with OU2 and all other future

site activities, what does that sentence mean?

MR. BANKS: It means at this point as

far as OU1, we will go ahead with the designing

88

construction of the enhanced recovery process, if

that ultimately is the selected alternative.

As far as OU2 , EPA will undertake,

will be lead agency for OU2 in implementing,

either implementing or overseeing the PRP's,

putting in the bedrock wells and doing a focused

remedial investigation and feasibility study.

MR. ROGERS: So as in OUl, we would

be looking for the PRP's to pay for the study and

any actions taken on OU2?

MR. BANKS: Let me be a little more

clear. OUl, first we'll try to reach an agreement

with the PRP's to undertake it themselves.

Failing to do that, EPA will undertake them. And

then seek cost recovery afterwards from the PRP's.

MR. ROGERS: So you want to involve

some studies as of yet uncollected data, you are

going to have an estimated OU2 , cost estimate for

OU2?

MR. BANKS: Not at this time.

MR. WISE: Brad Wise. Why do you do

OU2 at all? I am still unclear on that. Why

would you want to go in the bedrock anH 'i O;K f/Oa: ¥flR500J86

89

something else?

MR. BANKS: I think we have concern

that there is -- we are not disagreeing with the

conclusions drawn. I think we do want to feel

confident before writing a final ROD on this site.

And I think one of the concerns we

had was, it was either boring, B14 or MWB14, in

that boring, there was an odor down in the silty

sand unit. Now, whether it is part of the coal

tar, possibly. I just think we need to me sure

that indeed there is no vertical migration down to

the bedrock. Just some hard data.

MS. SOMASICK: Mary Jean Somasick,

borough council. We may not have another

opportunity to disuss the other alternatives, just

tell me why alternative five is better than

alternative four? I don't have any knowledge

other than what I have here in front of me, but it

looks like alternative four costs a little bit

less and moves more free coal tar and the result

is three to six percent.

MR. BANKS: Going through those nine

criteria again with the implentability,AR500187

90

alternative four employs the soil washing. And flp

again we are talking about excavating contaminated

soil and leaving open a large excavation from

which contaminants can volatilize.

Now, we are talking about stock

piling soils, clean over burden materials, stock

piling those, which may have some coal tar

contamination, probably stock piling some of the

coal tar contaminated soil while it is waiting to

be run through this soil washing treatment.

I think more of a concern with human

exposure from the soils being less stock piled,

plus from the open excavation area being there.

I think also with the soil washing,

giving the type of soils we have, we are talking

about a stream gravel where we have cobbles,

rather large cobbles, we may be talking about

materials handling problem with the soil washing

unit.

So it does have some drawbacks. And

I might mention to say also that the soil washing

is also an emerging technology.

MS. DICOSMO: Anyone else^?R 5 0 0 I 8 8

91

Shall I slam the gavel down?

Okay. I would like to thank everyone

for coming this evening. I would also like to

reiterate the comment period is open until March

18th.

(Concluded.)

* * *

92

¥I, BONNIE HAYES, a shorthand reporter

and Notary Public in the State of Pennsylvania,

certify that the foregoing is a true and

accurate transcript of the hearing taken

stenographically by me at the time and place

and on the date hereinbefore set forth.

I further certify that I am neither

attorney nor counsel for, nor related to or

employed by any of the parties to the action in

which this proceeding is taken, nor am I J^

financially interested in the action. I

BONNIE HAYES, COURT REPORTER

A R S O O i B O ¥