HANNOCH WEISMAN / ((? 3 · 2021. 4. 10. · 07/25/91 Mark A. Travers Lisa Nichols 7 copies of the...

HANNOCH WEISMAN / ((? 3A PROFESSIONAL CORPORATIONCOUNSELLORS AT LAW

80 WEST STATE STREET 4 BECKED FARM ROAD IISO SEVENTEENTH STREET. N.W.

SUITE MOO ROSELAND. NEW JERSEY 07066-3766 SUITE 6OOP.O.BOX.296 «I01. 530. 8300 WASH.NGTON.D.C. 20036TKENTON. NJOaeO7-l2»B (2O2) 296-3432(609)392-2.00 WCBIMILK

- (609)392-7996 J'TTCL/PHONE OF COUNSELR.CHARDJ. HUGHESJOSEPH A WEISMAN

PLEASE REPLY TO: ROBERT A. MATTHEWSWRITER'S DIRECT LINE: P.O. BOX IO4O FILE I(201) 535-5493 NEWARK. NJ O7,o,-Se,9 42668_2

Hay 6, 1993

VIA HAND DELIVERY

Mr. Cesar Lee, P.E.Remedial Project Manager (3HW21)United States Environmental Protection AgencyRegion III641 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Ret Novak Sanitary Landfill, South Whitehall Township,Pennsylvania ("Novak Site" or "Site"), Documentsfor Inclusion in the Administrative Record_______

Dear Mr. Lee:

Enclosed is an index of documents exchanged between theNovak RI/FS PRP Group ("Group") and USEPA which we believe shouldbe included in the administrative record for the Novak Site. Wehave also enclosed a copy of the documents referenced in theindex for your ease of reference. Many of these documents relateto actions taken by the Group to fulfill its obligations underthe Administrative Order on Consent ("AGO") for this Site andinformation relevant to USEPA*s evaluation of response actionsappropriate for the Site, and are therefore the types ofdocuments appropriate for inclusion in the administrative recordfor the Site.

In addition to the documents listed in the enclosedindex, we note that there are other, more recent documents thatthe Group believes should be a part of the administrative recordbut which we assume may not have been available at the time ofthe last administrative record update. In that regard, weunderstand that the administrative record for this Site wassupplemented in early February 1993, shortly before our review ofthe record. At that time, the record did not include any of the

BR20798S

HANNOCH WEISMANA PROFESSIONAL CORPORATION

Mr. Cesar Lee, P.E.May 6, 1993

Group's responses to USEPA comments on the RI/FS submitted fromJanuary 1993 to the present. The record did, however, includeUSEPA's comments on the RI/FS. Given that the Group's responsesto those comments included information that is certainly relevantto USEPA's evaluation of any future response actions at the Site,the response documents should be included in the administrativerecord.

Please note that we cannot be certain that the documentswe have identified represent all of the documents that should beincluded in the administrative record. However, certainly therecord should include all deliverables required under the ACO andcorrespondence containing information relevant to selection ofthe response action for the Site. We therefore request thatUSEPA address this matter promptly so that the public will beprovided with all appropriate information during the public com-ment period that will follow issuance of the Proposed RemedialAction Plan for this Site.

Your anticipated cooperation in this regard is appreci-ated. Please feel free to call should you have any questions. ,

Very truly yours,

HANNOCH WEISMAN

JAP/mmlEnclosures

ccs Betsy Lukens, Esq. (w/o encs.)Via Hand Delivery

AR207986

INDEX OF NOVAK SITE DOCUMENTS FORINCLUSION IN THE 'AbMlNtSTRATIVE RECORD

•n':'•':;. t " ''

Date Author Recipient Description

,'08/89 Lawrence W. Diamond Michael Towle Request meeting toHannoch Weisman U.S. E.P.A. review workplan for

.: ,; /:i' RI/FS

04/09/89 Hark A. Travers Lisa Nichols Novak Sanitary LandfillU.S. E.P.A. Site March 1990 Honthly

Progress Report.

06/07/89 Edward F. HcTiernan Larry Lunsk Closure plan for NovakHannoch Weisman Pennsylvania Dept. Landfill

of EnvironmentalResources

Lawrence W. Diamond Joseph J.C. PRP Group's positionHannoch Weisman Donovan concerning the conflict

U.S. E.P.A. between the closure planof the Novak Landfilland the RI/FS.

07/24/89 Hark A. Travers Menneth A. Gelburd Novak Group's positionde maximis, inc. Pennsylvania Dept. concerning the closure

of Environmental activities proposed forResources the Novak Sanitary

Landfill.

08/21/89 Mark A. Travers Michael Towle Confirming that Geraghtyde maximis, inc. U.S. E.P.A. & Miller, Inc., will

continue as primecontractor forconducting the RI/FS.

AR207987

INDEX OF NOVAK SITE DOCUMENTS FORINCLUSION IN THE ADMINISTRATIVE RECORD


10/13/89 Mark A. Travers Michael Towle Confirming contactde maximis, inc. U.S. E.P.A. all property owners

where access isnecessary for eithersupply well sampling ormonitoring wellinstallation.

12/29/89 Edward F. McTiernan Kenneth Markowitz PADER'S requiring thatHannoch Weisman U.S. E.P.A. NSL undergo closure.

Requesting E.P.A inputon how to proceed.

03/30/90 Mark A. Travers Michael Towle Written notification ofde maximis, inc. U.S. E.P.A. delay in VOC analysis.

05/17/90 Mark A. Travers Lisa Nichols Three copies of thede maximis, inc. U.S. E.P.A. laboratory evaluation

checksheets and fieldaudit checklist.

05/17/90 Mark A. Travers Lisa Nichols Three copies ofde maximis, inc. U.S. E.P.A. corrective action record

prepared in response tothe lab missing VOCanalysis due to a delay.

05/21/90 Jonathon N. Lisa Nichols Counsel for NSL, Inc.,Petrakis U.S. E.P.A. is assuring E.P.A. thatFrey, Petrakis & no new waste is beingFerry brought to the landfill.

AR207988



,'07/90 Mark A. Travers Lisa Nichols Confirmingde maximis, inc. U.S. E.P.A. transportation of liquid

from monitoring wellsto E.I. DuPont DeNemours& Company Chambers Worksin Deepwater, N.J., fordisposal.

11/06/90 Mark A. Travers Lisa Nichols Transmits 7 copies ofde maximis, inc. U.S. E.P.A. the addendum to the

RI/FS Work Plan/FieldOperations Plan forreview.

03/05/91 Edward F. McTiernan Kenneth Markowitz Respondents request thatHannoch Weisman U.S. E.P.A. E.P.A. agree to apply

the 45 day review periodset forth in SectionVIII B of theAdministrative Order.

W/08/91 Edward F. McTiernan Kenneth Harkowitz Outline of howHannoch Weisman U.S. E.P.A. respondents intend to

proceed regardingrevisions to work plan.

07/01/91 Edward F. McTiernan Kenneth Markowitz Concerns regarding RIHannoch Weisman U.S. E.P.A. schedule.

07/15/91 Mark A. Travers Lisa Nichols 7 copies of "Qualityde maximis, inc. U.S. E.P.A. Assurance Summary Report

and Data Validation forthe Jordan CreekSediments . "

AR207989


Date Author Recipient Description= = = = = = = = = = = = = = = === = === = = = = = = = = = = = = = = = = = = = = = = = = :=:= = = = = = = = = = = = = = = = = = = = = = == = = =: = := = =

07/25/91 Mark A. Travers Lisa Nichols 7 copies of thede maximis, inc. U.S. E.P.A. "Quality Assurance

Summary Report and DataValidation forGround-Water Samplesfrom Residential Wells."

07/29/91 Edward F. McTiernan Kenneth Markowitz References July 12, 1991Hannoch Weisman U.S. E.P.A. conference call with

Lisa Nichols and MarkTravers regarding RIschedule.

03/01/92 Geraghty & Miller, U.S.E.P.A. "Responses to the U.S.Inc. E.P.A.'s Comments on the

Novak Sanitary LandfillRemedial Investigation."

03/31/92 Mark A. Travers Cesar Lee Responses to comments tode maximis, inc. U.S. E.P.A. the RI report.

04/16/92 Mark A. Travers Cesar Lee Schedule for thede maximis, inc. U.S. E.P.A. revision of the

Feasibility StudyReport.

06/09/92 Mark A. Travers Cesar Lee 4 copies of the revisedde maximis, inc. U.S. E.P.A. Remedial Investigation

Report.

AR207990


Date Author Recipient Description= rr = = = = := = = =::= = = = i= = = = =: = =:s = = =: = = = = =: === = = c = ==s=== = = = = = = = = = === = = = = = = = = = = = = = = = = === = = = = = !

16/92 Julie A. Parker Kenneth Markowitz Request for for anHannoch Weisman U.S. E.P.A. extension of time to

respond to the DynamacReport and to submit theRevised WasteCharacterization Sectionof the RI Report.

10/09/92 Mark A. Travers Cesar Lee Force majeurede maximis, inc. U.S. E.P.A. Report/Request for

Schedule Extension.

11/04/92 Mark A. Travers Cesar Lee Final Remedialde maximis, inc. U.S. E.P.A. Investigation and

Feasibility StudyReports.

/1R20799I

HANNOCHA PROFESSIONAL CORPORATIONCOUNSELLORS AT LAW

(MERGED WITH STERNS. HERBERT. WCINROTH & PETRINO)

•4 BCCKEIt FARM ROAO SU.TC «OORO3ELANO. NEW JERSEY O7O6d-37aa »9O SCVCNTCCNTM srircrr.

C200333-S300 W»«N,NOTON. DC «OO3«(tO2)29*-3432

TCLCCOPICK<"» ••*»•• CF COUNSEL

JOSEPH A. WEISMAN

PLEASE REPLY TO: WRITER'S DIRECT LINE:P.O. BOX IO-4O

NEWARK. NJ 07101-9819 (201) 535-5416rue*

December 29, 1989

Kanneth Markowitz, Esq.United States Environmental Protection AgencyRegion IIIOffice of Regional Counsel841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Re: Novak Sanitary Landfill ("NSL")Ptnsylvania Department of EnvironmentalResource* ("PADBH'M Closure Plan Review

Dear Mr. Markovitz:We are writing on behalf of the Novak RI/FS PRP Group

(the "Group1*). The Group is concerned that PADER's apparentrequirement that the NSL undergo closure pursuant to thePennsylvania Solid Haste Management Act will interfere with theGroup's ongoing Remedial Investigation/Feasibility Study("RI/FS"). Given the present schedule, we anticipate there willbe significant RI/FS field work during the first half of 1990.The Group requests your assistance in arranging a meeting withPADER in order to avoid conflicts between landfill closureactivities and the RI/FS process.

In May 1989 the owner/operator of the NSL responded toPADER's repeated requests and submitted a proposed landfillclosure plan. The closure plan was not prepared by, or for, theGroup. In July, 1989 the Group submitted technical **«*•«•«•»«••-ff" " »..%•»«-— ^v , - f —• — -«fc.«jx. Ali<* l>ruup cu.:>Oalerted ootn EPA and PADER to the potential conflict betweenstate and federal requirements. Copies of the Group's technicalcomments and letter outlining our concerns are attached. To datePADER has not responded to the Group's request for a meeting todiscuss these issues.

AR207992


•• ••. .:•'. . .-- ' • *''•:<'*•Kenneth Harkowitz, Esq.December 29, 1989Page 2

No mechanism presently exists which will ensure propercoordination of PADER's review and approval of the NSL closureplan and the RI/FS. The Group's technical consultants believethat implementation of the landfill closure plan will adverselyimpact efforts to characterize present site conditions andcompromise the validity of data collected during the RI/FS.Continued failure to coordinate the closure plan with the RI/FSis likely to result in inconsistent requirements, unnecessaryexpenditure of resources and duplication of efforts by state andfederal agencies, the Group, and the owner/operator of the NSL.

We understand that the RI/FS Project Coordinators, MikeTowle of EPA and Mark Travers of de maximis, inc., are attemptingto schedule a meeting with technical representatives of PADER toreview the engineering and environmental issues raised by theGroup's comments to the closure plan. We believe that a similarmeeting among appropriate legal representatives of the Group, EPAand PADER is also necessary.

Once you have had an opportunity to review this letter,please call me to discuss how to proceed.

:Very truly yours,

HANNOCH WEISMAN

By.Edward F. McTiernan

EFMthez

cc: Novak PRP CounselMark TraversMichael T. Towle (w/encl.)Adam Kushner, Esq. (w/encl.)Steven Hiano, Esq. (w/encl.)

HR207993

HANNOCH WEISMA,A PROFESSIONAL CORPORATIONCOUNSELLORS AT LAW

(MERGED WITH STERNS. HERBERT. WEINROTH & PETRINO)A raorcssiONM. COKFOIUTION

186 WCST STATC STRCCT 4 BECKCR FARM ROAD Su'TC 6OOP.0.80XI298 ROSELANO. NEW JERSEY 07068-3788 -190 SCVCNTCCNTM STRCCT. NWTRCNTON. NJ O88O7 1ZII <2OI> 933 S3OO WASHINGTON. OC 2OO36(609)392-2100 (202)296-3.02TCLCCOPICI* - (809) 302-7936 TCLCCOPICR

.20.) 99--7.M OF COUNSEL

9O NASSAU STRCCT RICHARD J HUGHESP.O. BOX 1248 ___ JOSEPH A. WEISMANPRINCCTOM. NJ 08342-.248 _, ,..-- OFOI V TO.(609) 924-2.08 PLEASE REPLY TO: WR|TER.S D|RECT UNE.TCUCCOP.CR (609)683-7739 P.O. BOXIO4O

NEWARK. NJ O7IOI-98I9 (201) 535-5357FILE!

34017-9March 8, 1989 A- , ,

VIA FEDERAL EXPRESS

Mr. Michael Towle, Remedial Project ManagerU.S. Environmental Protection Agency, Region IIIPa CERCLA Remedial/Enforcement Section341 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Re: Novak sanitary Landfill siteLehigh county, PennsylvaniaDocket No. III-89-10-DC

Dear Mr. Towle:

On behalf of the Respondents in the above matter, thisletter transmits six (6) copies, one of which is unbound, of theWork Plan for the Remedial Investigation/Feasibility Study of theNovak Sanitary Landfill. The Respondents believe a meeting toreview the Work Plan would be beneficial and the Respondents'technical team is available at your convenience. Please contactme if you have any questions or to schedule a meeting.

Very truly yours,

HANNOCH WEISMAN

Lawrence W. DiamondRespondents' Project Cooridnator

LWD/EFM:hezcc: Joseph J.C. Donovan, Esq.

Respondents

AR207991*

de maximis, inc.P.O. Box 90348

Knoxville, TN 37990615-691-5052

9April1989

Ms. Lisa NicholsUnited States Environmental Protection AgencyRegion 3641 Chestnut BuildingPhiladelphia, PA 19107Re: Novak Sanitary Landfill Sfte

March 1990 Monthly Progress ReportDear Ms. Nichols:Pursuant to the Administrative Order by Consent enclosed are three copies of themonthly progress report for the period of March 1990 for the Novak Sanitary Landfffl Site.If you or your staff have further questions concerning this report, please contact me at(815) 691-5052. Thank you for your assistance.

Best

: A. TraversSenior Project Manager

Enclosurescc: Lawrence W. Diamond, Esquire, Hannoch Weisman

Edward Me Teman, Esquire, Hannoch WeismanJadyn Baron, Geraghty & Mffler ,

AR207995

HANNOCH WEISMA. JA PROFESSIONAL CORPORATION

COUNSELLORS AT LAW(MERGED WITH STERNS. HERBERT. WEINROTH & PETRINOI

A »»OrCS3IONAI. COMPOHATlOM

.as west STATC sTMctT A acCKER FARM ROAO su.rcaooPO «O«i298 HOSELANO. NEW JERSEY O7O88-3799 i.9O SCVCNTCCNTM STBCCT. N wT»£i«TOM. NJ O88O7-I2M <2OI> 939-93OO • WASHINGTON. O C 2OO38(809)392-2100 (202)298-3432TCLtCOP.C« - (80») 392-7998 ,,7™%?!.

(2011 994.7198 OF COUNSEL

90 NASSAU STItCCT MI2 «T732-3a8j|C BICHARO J. HUGHESP O iOX 1248 ' __ . JOSEPH A, WEISMANP»iwCCTOM. NJ 08942-.248 _. -.-p OPOI V T«-».(809) 924-2.08 PLEASE REPLY TO: WRITER'S DIRECT LINE:

P.O. BOX 1040 (2Q1) .,J5-5416EWARK. NJ 07101-9319

426«8-2June 7, 1939

Mr. Larry LunskPennsylvania Department of Environmental Resources1375 New Hope StreetNorristown, Pennsylvania 19401

Re: Closure Plan for Novak LandfillSouth Whitehall Township

Dear Mr. Lunsk:

This letter references our telephone conversation ofJune 6, 1939. Our firm represents one of the Potentially Raspon-sible Parties ("PRP's") indentified by the USEPA in connectionwith the Novak Landfill. In addition, we serve as the Chair of acommittee of PRPs working with USEPA Region III on a remedialinvestigation and feasability study of the Novak Landfill.

During our conversation you indicated that your officehad received a copy of the proposed closure plan for the NovakLandfill and that you would be accepting public comments on theplan for the next two months. Zn order to allow the PRP Commit-tee to determine whether to submit comments, please confirm theprecise date on which the closure plan was received and the lastday of the public comment period. Zn addition, we are interestedin receiving notice of action on the closure plan. Please add myname to any public mailing list which your Department might de-velop or maintain concerning the Novak Landfill.

Thank you for your attention to this matter.Very truly yours,HANNOCH WEISMAN

BVEdward F. McTiernan

EFM:hezcc: H. Towle, USEPA

H. Travers, de maximis, inc. „««*.AR207996

HANNOCH WEISMANA PROFESSIONAL CORPORATIONCOUNSELLORS AT LAW

(MCROCD WITH 8TCRN9. MCMSCftT. WCINROTH & PCTRINO)• MorcuiOMAt. CO««O«*T>O»

>•• *C»T ITATC STNCCT * BCCKC* FARM ROAO su"C8oo«0 •OX'198 ROSELANO. NEW JERSEY O7O06-37ea "«0 tCVCNTCCHTN »T«ctT.« wTMWTON. >»j O«8O7.if>i . <«OII MS-faCC . W««M«IOTON. oC 4OO3fl8O9)38«-t.OO (SO»M8-343XCCICOP'C* -<«08) 3*t '••« LaltfiSrilfr.ItO.I •84-7.98 Or COUNSEL

•O NAfSAUSTKCCT • "ttTilTil MM* "'CHABO J HUCMCSP O 801 X48 ™ * 111 JOSEPH A WCI3MAM••iNCCTQN HJ 08|4< U48 • _• _(«o«) 9<4.s.0« PLEASE REPLY TO: WRITER'S DIRECT CINE:rttCCOP'C* <«O9|883-»73» P.O. BOX IO4O

NEWARK. NJ O7lOI-»ei» (201) 535-5357

July 5, 1989

FILE*

42668-2

VIA FEDERAL BTPRBflg

Joseph J.C. Donovan, Esq.Assistant Regional Couna-1United States Environmental ProtectionAgency, Region ZZI

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Re: KQT«3t Landfill

Dear Mr. Donovani

The Pennsylvania Department of Environmental Resources("DER") has requested that the owner/operator of the NovakLandfill subait a closure plan in accordance with thePennsylvania Solid Haste Kanagtaent Act. The owner/operator hascomplied with DER's request and recently submitted a closureplan. The closure plan references, but is totally independentfrom, the Remedial Investigation Feasibility Study ("RI/FS")which the PRP Group is about to undertake. DER is presentlyreviewing the closure plan. The PRP Group is concerned that theclosure plan is likely to conflict with the RI/FS. This letterpresents the PRP Group's position concerning the impendingclosure of the Novak Landfill.

The PRP Group believes that any action taken by DER atthe Novak Landfill, prior to completion of the RI/FS, ispremature and is likely to interfere with the RI/FS process. Forexample, the proposed closure plan calls for significantquantities of additional vasts to ba deposited at the site forgrading purposes. This additional disposal may introduce newsources and/or typss of contaainatlon. Zn addition, grading andpreparation of the landfill for capping may interfere with

HR207997


Joseph J.C. Donovan, Esq.July 5, 1989Page 2

*

monitoring well installation and data collection activities.Finally, the hydrologic changes (i.a.. groundwater mounding orradial flow) which occur due to landfill closure may adverselyimpact the quality of groundwater data collected during the RI.Besides the physical interference with RI activities, the PRPGroup may find itself in the unenviable position of facingconflicting demands from DER and EPA.

DER's closure plan regulations are designed to addresstypical conditions at solid waste disposal facilities, notSuperfund sites. As a result, DER's closure plan review willfocus on compliance with engineering standards. This is notconsistent with BPA's site characterization process.

Under C2RCLA Sections 105 and 110, 42 U.S.C. §9605 and9616, and the National Contingency Plan ("NCP"), EPA's entirescheme for rsviav and selection of ramsdial alternatives iscontingent upon completion of a comprehensive RI. It would beinconsistent with CERCLA process, including the NCP, to allow DBRto cause implementation of the closure plan prior to completionOf the RZ. Further, CERCLA fl22(S)6, 42 U.S.C. 9622(e)6,provides that once any potentially responsible party hasinitiated the RI/FS process pursuant to a consent decree, no"potentially responsible party may undertake any remedial actionat the facility unless such action has been authorized by thePresident." The closure plan is inconsistent with these centralCERCLA provisions.

The Commonwealth of Pennsylvania has also recentlyrecognized that DER action "may not interfere with, orcontradict, actions ordered by BPA pursuant to its powers underCERCLA. Even though the Federal Government has not preempted thefield, its action* taks precedence ovsr conflicting statsaction" • WMtiiflgfroyge, gjfctrio corp. v. PA DBR. PennsylvaniaEnviron. Hearing Bd. Docket No. 88-296-M. (October 1988).

Closure of the landfill should await completion of theRZ/FS. While DER's landfill closure regulations may be evaluatedas applicable or relevant and appropriate standards during theRZ/FS process, they should not be allowed to interfere with thePRP's investigation of the Novak Landfill sits.

The PRP Group requests that EPA contact DER concerningreview of the closure plan. Zn the interests of all concerned,implementation of closure activities should bs postponed untilcompletion of the RZ/FS. Zn the alternative, the PRP Grouprequests that EPA suspend the requirement that an RZ/FS be

HR207998

HANNOCH WEISMAN, ; . . • • * . ' - • - f

A PROVISIONAL CORPORATION

Josaph J.c. Donovan, Esq.July 5, 1989Pags 3

performed at this tiae. Than ones the DER approved closure planis inpleasntad, ths nasd for further raaadial action can beassessed.

Ths PRP Group aay construe any action to implementclosure prior to completion of ths RZ/FS to be a Force Kajeureevent under ths Adalnistrativa Order*

Dua to DER's present schedule for review of the closureplan, we request that you advise us of EPA's position by no latarthan July 21, 1989. Wa are available.to aaat with you to discussthis situation at your convenience. If you bsliava such a aaatngwould ba bansflcial plaass contact aa as soon as possible.

Vary truly your,

fCE W. DIAMOND

LWD:EFH/hsi

V / cci K. Tovls^ M. Travsrs

All PRP counsalJ. Baron

Sue rr •:

BR207999

ANNOCH WEISMAIA PROFESSIONAL CORPORATIONCOUNSELLORS AT LAW

(MERGED WITH STERNS. HERBERT. WCINROTH 4 PCTRINO)A ••OrilCONAL COHPO'ATtOH

>88 *C»T STATC »T»CCT * 8CCKER TARM ROAO Su'TC 8OOP080«'<98 ROSELANO. NEW JERSEY O7O60-370A "»O SCvCNTfewT- <T.CNTOS 08807 « UO..S39-9300 *A$H,NOTO- OC *OO38r«oa, 3»i >.QO (*o*)*98 3+3*TCI.CCOPICHTtLCCO»C» !809)3»e '998

KOI) 994-7I98 OrCOUNSCL» NY TCLCPHONC Bi/--.nn . -. .(-_<•«9O HASSAi, 4T»CCT HICMAR3 J HUQHtS

a** PLEASE REPLY TO: WRITER'S DIRECT LINE:TC.CCOPI. ,809,883 .739 P.O. BOXIO4O

NEWARK. NJ O7IOI-93I9 (201) 535-5357FILE*

42668-2 ,July 24, 1989

VIA TELECOPIER

Kenneth A. Gelburd, Esq.Office of Chief Counsel, Eastern RegionPennsylvania Department of Environmental Resources1314 Chestnut Street, Suite 1200Philadelphia, Pennsylvania 19107

Re: Hovak Sanitary LandfillSouth Whitehall Township. Pa. \J

Dear Mr. Gelburd:

I aa writing on behalf of the Novak RI/FS PRP Group (the"Novak Group"), which is comprised of sixteen entities that havebeen working closely with the United States Environmental Protec-tion Agency ("EPA") to investigate the Novak Sanitary Landfillpursuant to the requirements of the Comprehensive EnvironmentalResponse, Compensation and Liability Act, 42 U.S.C. 55 9601 to9675 ("CERCLA"). This letter presents the Novak Group's positionconcerning the closure activities proposed for the Novak SanitaryLandfill.

On or about Hay 25, 1989, a proposed closure plan wassubmitted by the owner/operator of the Novak Sanitary Landfill inaccordance with the Pennsylvania Solid Waste Management Act., Pa.Stat. Ann. tit. 35 55 6018.101 at seq. Detailed comments con-cerning deficiencies in the proposed closure plan have been pro-vided to the technical staff of the Pennsylvania Department ofEnvironmental Resources ("DER1*) under separate cover. A copy ofthese technical comments is enclosed for your ready reference.Although our comments have been provided during DER's publiccomment period to ensure that we are not foreclosed from present-ing them, we emphasize that these comments do not in any way

AR208000


. .,, •i fc.Kenneth A. Gelburd; Esq.July 24, 1989Page 2

•

represent either express or implied agreement by the Novak Groupthat any closure activities should occur at this time.

Under CERCLA Sections 105 and 116, 42 U.S.C. §§ 9605 and9616, and the National Contingency Plan ("NCP"), EPA's entirescheme for review and selection of remedial alternatives is con-tingent upon completion of a comprehensive Remedial Investigation("RI"). It would be inconsistent with the CERCLA process, in-cluding the NCP, to allow DER to cause implementation of theclosure plan prior to completion of the RI. Further, CERCLA §122(e)(6), 42 U.S.C. 9622(e)(6), provides that once any poten-tially responsible party has initiated the Remedial Investiga-tion/Feasability Study ("RI/FS") process pursuant to an adminis-trative order or consent decree, no "potentially responsibleparty may undertake any remedial action at the facility unlesssuch action has been authorized by the President." Implementa-tion of the proposed closure plan prior to completion of theRI/FS is inconsistent with these central CERCLA provisions.

A recent Pennsylvania Environmental Hearing Board (the"EHB") decision underscores this point. In Wcstinahouse ElectricCorp. v. PADER the EKB issued a partial supersedeas when an orderof DER conflicted with the performance of an RI/FS mandated byEPA. Environmental Hearing Board Docket No 88-296-M, (October1988). The EHB held that DER "may not interfere with, or contra-dict, actions ordered by EPA pursuant to its powers underCERCLA. Even though the Federal Government has not preempted thefield, its actions take precedence over conflicting stateaction." Westinohouse Electric Corp. v. PADER. PennsylvaniaEnviron. Hearing Bd. Docket,No. 88-296-M. (October 1988).

It is the Novak Group's position that any order, direc-tive or other action by DER requiring that closure be implementedat this time is likely to interfere with, and contradict, theongoing RI/FS being conducted by the Novak Group pursuant toAdministrative Consent Order Docket No. III-89-10-DC datedDecember 31, 1988 (the "Order") entered into with EPA. For ap-proximately one year, the Novak Group has been working closelywith EPA'0 technical and legal staff to facilitate an RI/FS atthe site. However, no mechanism presently exists which willensure coordination of DER'8 review and approval of the closureplan proposed by the landfill's owner/operators with the ongoingRI/FS process. To date, the Novak Group has experienced diffi-culty in obtaining information from DER concerning issues related

AR208001


Kenneth A. Gelburd, Esq.July 24, 1989Page 3

to closure of the landfill. Continued failure to coordinate theclosure plan with the RI/FS is likely to result in inconsistentrequirements, unnecessary expenditure of resources and duplica-tive efforts by state and federal agencies, the Novak Group andthe owner/operator.

By way of illustration, the proposed closure plan callsfor significant quantities of demolition waste to be deposited atthe site for grading purposes. This waste may introduce newsources and/or types of materials regulated as hazardous. More-over, regardless of whether waste or "clean" material is used toachieve the necessary grade, or whether any material at all isused for this purpose, any grading or other preparation of thelandfill for capping may interfere with monitoring well instal-lation or data collection activities required by the RI/FS.Further, the hydrologic changes (i.e.. groundwater mounding orradial flow) which will occur due to landfill closure mayadversely impact the quality of groundwater data collected duringthe RI.

Besides physical interference with RI activities, fail-ure to postpone implementation of the closure plan until comple-tion of the RI/FS may actually delay implementation of a finalremedy at the Novak Sanitary Landfill. Finally, if the closureplan and the RI/FS are not properly coordinated there may beconflicting technical demands or schedules imposed by DER andEPA. If closure activities result in the Novak Group's inabilityto complete the RI/FS in compliance with the schedule establishedunder the Order, EPA may seek to impose significant stipulatedpenalties.

DER's closure plan regulations address typical condi-tions at solid waste disposal facilities and do not appear torequire coordination with the RI/FS process. The scope of DER'sclosure plan review is relatively narrow and generally focuses oncompliance with engineering standards. The RI/FS process is muchbroader and mandates that the Novak Group undertake a detailedsite characterization study. The Novak Group is concerned thatdesign standards established by the regulations, and imposed byDER, will not be flexible enough to ensure that the broader RI/FSprocess can proceed in a technically efficient and cost-effectivemanner. DER's landfill closure regulations may be evaluated asapplicable or relevant and appropriate standards during the RI/FS

AR208002


Kenneth A. Gelburd, Esq. ....lJuly 24, 1989 "'* VPage 4

process; however, to impose them now would interfere with theNovak Group's investigation of the site.

To date, the Novak Group has maintained a good workingrelationship with EPA on the RI/FS project. The Novak Group isabout to embark on the RI phase of the project and believes thata meeting with DER and EPA is essential at this time. As soon asyou have had an opportunity to review this letter and the append-ed comments please contact the undersigned to schedule such ameeting.

Very truly yours,

LAWRENCE W. DIAMOND

LWD:EFM/hez

cc: Louise Thompson, Esq., Chief Counsel, Eastern District, DERJoseph Donovan, Esq., Assist. Regional Counsel, EPA IIIWilliam Early, Esq., Acting Chief, Hazardous Waste Branch,ORC, EPA III

Marcia Mulkey, Esq., Regional Counsel, EPA IIIMichael J. Towle, EPA IIIStephen Wassersug, Dir. Hazardous Waste Mgt. Division,EPA III

Wayne Lynn, DER Regional Solid Waste DirectorRonald Klinikowski, DER Super fund CoordinatorLawrence Lunsk, DERAll PRP CounselJaclyn BaronMark Travers

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Knoxville, TN 37990615-691.5052

July 24, 1989

Mr. Lawrence LunsXRegional Waste Management Facilities SupervisorPennsylvania Department of Environmental Resources1375 New Hope StreetNorristown, PA 19401Re: Comment 3 en_ tha Prpposed. May 1989 Closure Plan for the

flovak Sanitary Landfill. South Whitehall Township,.Pennsylvania

Dear Mr. Lunsk:On behalf of the Novak Sit* PRP Group (Group), we areproviding comments on the Closure Plan for tha Novak SanitaryLandfill (Novak Landfill) dated May 1989 prepared by Walter B.Satterthwait* Associates, Inc. (HBSAI) on behalf of tha NovakLandfill Corporation.Pursuant to Administrative Consent Order Docket Ho.IH-39-10DC, tht United States Environmental Protection Agency(EPA) has authorized tha Group to conduct a RemedialInvestigation/Feasibility Study (RI/FS) at tha NovakLandfill. The Group btlievts that any action taken by thaDepartment of Environmental Resources (DER) at the NovakLandfill prior to cowplttion of tht RI/FS that could changesite conditions, is premature and likely to conflict and/orinterfere with the RI/FS process. Such interference iscontrary to CERCLA Sections 105 and 122, 42 U.S.C. Section 96and 9622, and EPA'3 National Contingency Plan and isinconsistent with a rtcant decision of tha Commonwealth ofPennsylvania Environmental Hearing Board.Notwithstanding tha Group's baliaf that closure of thelandfill should await completion of and ba completed incoordination with tha RI/FS, ve have reviewed tha propostsdMay 1989 Closure Plan prepared by Walter B. SatterthwaitoAssociates, Inc.. Zn accordance with tha 23 PA. Adain. codaSection 271.141, Publig. cetmentaf this latter presents theGroup's technical comments to the proposed Closure Plan. ThaGroup expressly reserves any and all rights or claimsconcerning the Closure Plan, including without limitation, itsright to challenge DER's authority and jurisdiction ovar thaNovak Landfill in so far as it interferes or conflicts withthe Group's obligations under federal law and the RI/FS priorto its completion.

AR20800<*; 4* T ».i o 1.1

7de maximis

, v • ; j -Kr. Lawrence Lunsk ' 'July 19, 1989Page 2 of 6

Our technical comments of the proposed Hay 1989 Closure Planfollow:PLACEMENT OF DEMOJLITIOK FILL

1. The closure Plan (Section 3.3) proposes to achieve finalcontours by bringing approximately 60,000 cubic yards ofdemolition debris to the site for use as fill. If thisproposal is approved, the Closure Plan will serve as anoperating permit for the acceptance of this new material.Although typical demolition debris nay not in and ofitself be hazardous, there is a distinct possibility thatmaterial which may be regulated as hazardous could beinadvertently accepted. Further, the components ofacceptable demolition debris (e.g./ asphalt) may introducehazardous materials to the site changing tha nature,concantration, or character of constituents at the site.

2. The Closure Flan (Station 3.3) states that w(i]t isanticipated that this volume of demolition wasta would beattainable at tha landfill within 18 months of approval."However, the Closure Plan makes no provision foralternatives in the event that tha required volume ofdemolition debris is not received in the 18 month period.

3. Alternatives to the use of demolition fill have not beenmentioned or discussed. Alternatives for closure shouldbe considered in tha Closure Plan (e.g., grading existingmaterials).

LANDFILL CLOSURE DESIGN

Tha proposed cap, described in Section 3.4.3 of the ClosurePlan does not satisfy Pennsylvania Municipal Waste ManagementRegulations, 25 PA Admin* Code Chapter 273, which requiresthat closure generally and construction of the capspecifically be accomplished in accordance with thtperformance standards set forth in the regulations. Itappears that based upon proposed final slopes, soil covarthickness, drainage and clay characteristics (as discussedbelow tha proposed cap does not satisfy performancestandards).Our overall concerns and technical recommendations regardingthe landfill closure design are discussed below. Tha commentsfall roughly into two categories: 1) comments concerning plan

AR208005r> MI * ra <s. T1 s *• T M r* I.I

de maximis

deficiencies with respect to the regulations, and 2) commentsconcerning areas that are not specifically covered by th«regulations but which in our opinion require improvement. Themost serious of our concerns relate to the quality of theproposed cap material. As discussed below, we do not believethat the Closure Plan adequately demonstrates that theproposed cap will satfisfy the performance standardsestablished in the regulations. Further, the suitability ofthe cap material is quest ionablt.Technical .Deficiencies Relating to the Overall Cap Design

1. The minimum slope proposed (approximately 2.5 percent) inthe Closure Plan design does not comply with PennsylvaniaMunicipal Waste Regulations (25 PA Admin. Code Section273.234) which require a minimum slope of 3 percent or ademonstration of equivilent performance.

2. The Pennsylvania Municipal Waste Regulations (25 PA Admin.Code Section 273.234) require that a drainage layercapable of transmitting flow and preventing erosion of thesoil layer must be placed over tha cap. No such drainagelayer is proposed in the Closure Plan design.

3. The Pennsylvania Municipal wasta Regulations (25 PA Admin.Coda Section 273.234) require that a uniform and compactedlayer of soil at least 2 feet thick be placed over thedrainage layer or tha equivalent to satisfy performancestandards. The Closure Plan proposes a soil layer only lfoot thick (6 inches of base material and 6 inches oftopsoil) and is not adequate since there is no evidenceprovided that tha design meets the regulatory performancestandards. For example, the design currently proposed bytha Closure Plan fails to make adequate provision toassura a successful vegetative layer and prevent frostpenetration.

Relating to Cap Material

Tha quality of tha proposed cap material and its performanceparameters hava not baan adequately addressed in tha closurePlan. Zn ganaral, tha Closure Plan does not demonstrate thattha proposed cap material satisfies Pennsylvania MunicipalWaste Regulations.The Closure Plan states that tha Pennsylvania Municipal WastaRegulations appear to require that the clay portion of the capba a minimum of 25 percent olay by weight with particlediameter less than 0.002 millimeters. However, the ClosurePlan indicates that of the five samples of potential capmaterial analyzed for clay content, two of these samples had aclay content of 17 to 13 percent. Tha remaining three samples

RR208006

,__7-...

de maximis

had a clay content of 30 to 33 percent. A composite samplewas also tasted"and found to have a clay, content significantlygreater than tha five aforementioned grab samples that weretested. Nonetheless, tha Closure Plan uses the compositesample test results as its basis for the conclusion that thecap material is suitable, ignoring the fact that the compositemay not be representative. Tht ttst results presented in theClosure Plan raise many questions which require furtherclarification. Becaust tht Closure Plan (Section 3) statesthat soils with "clay content greater than 25 percent will beused as cap material." Significant composite and mixingeffort of soils from various sources would be necessary toachieve the required average clay content. The Closure Plandoes not provide details on how this compositing of soils willbe accomplished.The permeability of the proposed cap material afttr compactionis an important factor in determining tht overall performance •of the cap. The proposed Closure plan fails to fully addressthis critical issuei First, the running of only ontpermeability test on tht proposed cap material Is inadequate.Only the falling head permeability test was performed on thtcomposite sample. As Indicated abovt, the composite sampleexhibited a significantly higher clay conttnt than all of theother samples tested. Thus, based on the sample.set, thtcoefficient of permeability obtained (1.36 x 10"6centimeters per stcond (cm/sec)) would represent a best castrather than a typical value. Second, the one test that was

v performed appears to havt been non-representative in severalrespects. The Closure Plan indicates that the permeabilityspecimen was ttsttd at 98 percent of the maximum dry dtnsity.The Pennsylvania Municipal Haste Regulations require, and theclosure Plan itstlf proposes compaction only to 90 percent ofmaximum dry dtnsity (standard Proctor Method). Therefore,this permeability valut was obtained for a sample with adtgrtt of compaction much grtattr than would be equalled intht field.The Closure Plan statts "permeability and compaction ttstsshall bt performed routinely during placement to assurematerial specifications art met" (Section 3). Kowtvtr, thtclosure Plan fails to articulate exactly how material qualitycontrol will be attained in the field. Tht acceptancecriteria for compaction and permeability should be clearlyestablished, as well as the testing methodology and frequency.In summary, the erittria and performance parameters (clayconttnt and permeability) for tht proposed clay cap material

AR208007T £ : f T NOW 6 Q - t- Z - T

-7—a—

de maximis

have not been adequately addressed, and the test results whichhave been obtained do not demonstrate that the proposedmaterial is acceptable. This has important ramificationsregarding whether or not the on-sita borrow materials may beused.STORM WATER CONTROL SYSTEM

1. The overall design of the storm water system is inadequate(Section 3.4.2 of tht Closure Plan).

2. The diversion culvert for transporting run-off to Pond No.2 is not adequately designed. For example, corrugatedmetal pipe diversion piping rests on tht top of only 6inches of compacted clay* This configuration increasestha chance of infiltration through tht cap and leachateformation from slug flow in the event of a leak in thapipe. Other designs and materials should bt considered.

3. The Closure Plan does not address storm water from thtPheasant Hill Subdivision on to tht Novak SanitaryLandfill Sitt.

ABATEMENT PROGRAM

In order to vent gases from greater depths along the westernedgt of the trench fill the abatement program, as outlined inSection 4.4 of tht Closure Plan, proposes convertingMonitoring Well MW-IB to a gas venting well. Tht Closure Planstates that tht gasts vented from this well contains elevatedconcentrations of volatile organic compounds, and that ventingof MW-IB will be an abatement mechanism for the volatileorganic compounds in tht ground water. The proposed ClosurePlan fails to addrtss tht rtltast of these compounds into theatmosphere*Gas Trench and Collection System

1. The gas trench and collection system has not beenadequately designed (Section 5 of the Closure Plan).

2. The gas trtnch and collection system should bt designed toprevent the landfill gas from migrating through tht gravellayer into tht crushed stont layer and bypassing thecollection system.

3. For Trenches 1 through 5, the Closure Plan does notensure that lateral gas migration will reach tht main gas

i IM i a: t> w * p T 2 : IP 1 MOWAR208008"44F- fZ- in r

maximis

collection pipts. Tht Closure Plan design incorrectlyassumes that gas will accumulate at the main collectionpipts, and does not take into account future subsidence.

4. Gas quality and possible odor problems art not addressedwithin tht framework of the Closure Plan.

SUMMARY

In summary, while wt do not believe tht Closure Plan for theNovak Sanitary Landfill Cite should go forward during theRI/FS, the Closure Plan as proposed does not meet currentPennsylvania Municipal Wastt Management Regulations and is notadequate with respect to overall closure design; cap design;screenwriter control/management; and gas collection. Znaddition, approval of the Closure Plan as submitted wouldserve as a permit to operate as a landfill for an indefinite •period of time and as presently proposed is likely to conflictwith tht RI/FS tfforts.We believe that these comments present serious questions whichshould be addressed either in a public meeting or an informaltechnical meeting.

If you would likt to discuss any of our comments in dttail,please contact mt and wt can arrangt a time.Sincerely,dt maximis, inc.

ark A. TraversProject Manager

MAT/mdm

cc: Novak Sanitary Landfill RI/FS PRP GroupMichael Towle, EPA Region ZZZ

AR208009


Knoxville, TN 37990

[rTir?f?ar?nn nr?AUG 25 198°1

615-691-5052 HANNOCH WciSMAN

21 August 1939

VIA TELEFAX

Mr. Michael TowleUnited States Environmental Protection AgencyRegion 3841 Chestnut BuildingPhiladelphia, PA 19107

Reference: Novak Sanitary Landfill SiteSouth Whitehall Township, Pennsylvania

Dear Mr. Towle:

This letter confirms prior conversation and correspondencethat Geraghty & Miller, Inc. of Hackensack, New Jersey willcontinue as prime contractor for conducting the RemedialInvestigation/Feasibility at the referenced site. Jacyln A.Baron will continue as Project Manager and Vincent Uhl as theProject Officer for Geraghty & Miller, Inc., and thisinvestigation .

If you have any questions, please do not hesitate to contactme.

Sincerely,de maximis, inc.

rk A. Traversoject Coordinator

cc: Lawrence W. Diamond, Esquire

MAT/mdm

AR2080IO

deP.O. Box 90348

Knoxviile, TN 37990615-691-5052

13 October 1989

Mr. Michael TowleUnited States Environmental Protection AgencyRegion 3841 Chestnut BuildingPhiladelphia, PA 19107

Reference: Novak Sanitary LandfillLehigh County, Pennsylvania

Dear Mr. Towle:

This letter confirms our conversation of 5 October 1989 inwhich you were informed, as required in the AdministrativeOrder of Consent, that contact has been made with all propertyowners where access is necessary for either supply wellsampling or monitoring well installation. Written agreementshave been received from three of the property owners (i.e., N.Pidtawski, D. Pidtawski, and R. Cole) and verbal agreementfrom all other property owners, including the Township ofSouth Whitehall. I anticipate receiving the remaining writtenagreements in the near future.

As we discussed, I had tried to reach you prior to 5 Octoberregarding the statue of gaining access, but apparently mymessages never made it to your desk. If you have anyquestions concerning access or any other aspect of thereferenced project, please do not hesitate to contact me.

Sincerely,de maximlc

irk A. Traversreject Manager

cc: Lawrence W. Diamond, Esquire

v , MAT/rndm

AR2080II


Knoxville.TN 37990

r?M?rar?nnnt7

ulAPR 5 19901

i Ufiiyju615-691-5052 HANNOCH WEISMAN

30 March 1990

Mr. Michael TowleUnited States Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Reference: Novak Sanitary Landfill SiteLehigh County, Pennsylvania

Dear Mr. Towle:

According to Administrative Order by Consent, Section XVI,FORCE MAJEURE, "Respondents shall notify EPA of any delay oranticipated delay in achieving compliance with this ConsentOrder. Such notification shall be made orally as soon aspossible but no later than two business days after becomingaware of any delay or anticipated delay and in writing nolater than seven business days after becoming aware of suchdelay or anticipated delay.11

On 23 March 1990, I was notified by Geraghty & Miller that theanalytical laboratory (Cambridge Laboratories, Inc.) hadmissed the holding times for volatile organic compound (VOC)analyses of ground water collected from the first sevenresidential wells (RW-1 through RW-2) sampled on 7 and 8 March1990. In accordance with the Administrative Order by Consent,verbal notification was provided within two business daysafter becoming aware of the potential delay. This letterprovides the necessary written notification. These sevenwells will be resampled for VOC analyses during the period of26 to 30 March 1990. We do not anticipate that it will benecessary to coordinate split-sampling as part of theresampling effort.

The Cambridge Laboratories has agreed to complete thelaboratory analyses and report the results by the originalturnaround time provided that all newly collected samples arereceived by the laboratory on or before 31 March 1990.

AR2080I2

de maximis

Mr. Michael Towle30 March 1990Page 2 of 2

However, if the laboratory does not comply with the turnaroundtime or arrangements cannot be made with the various residentsfor resampling, some delay in the project schedule would beanticipated and be considered a force ma j cure event.

As provided for in the Field Operations Plan, a correctiveaction record has been prepared to document the nature of theproblem and the correction action required. A copy of thiscorrective action will be provided once the necessaryresampling and analyses are completed.


Sincerely,de maximis inc.

Traversiior Project Manager

MAT/mdm

cc: L. Diamond, Esquire, Hannoch WeismanE. Me Tiernan, Esquire, Hannoch WeismanJ. Baron, Geraghty & MillerTechnical Committee

AR2080I3


Knoxville, TN 37990615-691-5052

17 May 1990via Federal Express

Ms, Lisa NicholsUnited States Environmental Protection AgencyRegion 3841 Chestnut BuikfingPhiladelphia, Pennsylvania 19107Re: Novak Sanitaiy LandfiU Site

Lehigh County, PennsylvaniaDear Ms. Nichois:On behalf of me Respondents in the above matter, this letter transmits three copies of thelaboratory evaluation checksheets and field audit checklist developed in conducting thelaboratory auol and field audit, respectively. Die laboratory audit and field audit wereconducted as defined in the Administrative Order of Consent and Field Operations Plan.if you or your staff have any questions concerning the results of either the laboratoryaudit of field audit, or any other aspect of the referenced project please do not hesitateto contact me.

Sincerely.

rravertProject Manager

CK Lawrence Diamond, Esquire, Hannoch WeismanEdward Me Tteman, Esquire, Hannoch WeismanJadyn Baron, Geraghty & Mfltor

AR2080II*


Knoxviile, TN 37990615-691-5052

17 May 1990

Via Federal Express

MS. usa NichoisUnited States Environmental Protection AgencyRegion 3641 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Re: Novak Sanitary Landfffl SiteLehfgh County, Pennsylvania

Dear Mr. Towle:This letter transmits three copies of the corrective action record that was prepared inresponse to the lab missing holding times for volatile organic analyses of the first sevenresidential well samples cofiected for the Remedial InvestigatiorVFeasbfity StudyP/FS) of the Novak Sanitary Landffl Sfte.If you or your staff have any questions concerning the enclosed or any other aspect ofthe referenced project, please do not hesitate to contact me.Sincerely,de

Project Managercc: Lawrence Diamond, Esquire, Hannoch Weisman

Edward Me Tfeman, Esquire, Hannoch WeismanJacfyn Baron, Geraghfy& Mffier

AR2080I5

CORRECTIVE ACTION RuJORD OAPP Appendix————————————————— • ————————— - Revision N'

(NOVAK SANITARY LANDFILL) December 30. 1'r.l5ie 1C of

RECORD ORIGINATOR: Jaclvn Baron ______ Prolact Manager ______ 23NAME POSITION DATE

NATURE OF DEVIATION OR PROBLEM: Informed bv Edward Lavler. Analytical LaboratoryProlecc Manager that the lab missed the holding time for VOC analyses of the firstseven residential well samples collected (RW-1 through RW-7) on March 7 and 8. 1990. .The problem was due to the relocation of the laboratory during the period when thesamples were in-house. The equipment for the special low detection limit analyses _____was not meeting CLP performance standards when setup after the move, and time for theanalyses ran out. ________________________________

PERSONS INFORMED: FIELD TEAM LEADER 22 Mar 1990 PROJECT MANAGER 22 Mar- 1990

PROJECT QA/QC OFFICER 22 Mar 1990 PROJECT COORDINATOR 23JJar_1990_

CORRECTIVE ACTION REQUIRED: Resamole these seven veils next week for VOCfEPA Oversight Contractor. Dvnamac. did not take any split sanples for these parameters.)The sample set vill consist of a total of 12 to 13 samples; RW-1 through RW-7. 1 fieldreplicate (at RW-7, Bartholomew, formerly Kramer Well), 2 field blanks, and 2 to 3 tripblanks, (depending on no. of days of sampling.) The extra sample volume for a matrixspike/matrix spike duplicate will also have to be re-collected. Samples will bedesignated 02, siznlfvinz second sanrole collected frost each well.

INITIATION DATE: 23 Mar 1990_______ COMPLETION DATE 28 Mar 1990

COMMENTS: Residential Wells RW-1 through RW-7 were rescheduled on March 26, andre sampled for VOCs on March 27 and 28, 1990. ____________________________

ffOAPPROVALS: 6* finO 0/ /990'pRdJECT MANAGER DATE PROJECT OA/QC OFFIC

Jaclyn A. Baron Peter N. Milionis

RECEIVEDFREY. PETRAKIS «fc FERRY

223O LAND TITLE BUILDING

100 SOUTH BROAD STREET HA\,vC'JH l.Vt!3.'.-ANPHILADELPHIA. PA. 1 01 10 NCW JERSEY OFFICE

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VOORHEES. N J. OBO4346OS) 424-4448

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Hay 21, 1990

Lisa NicholsRemedial Projects Manager .Superfund GroupEnvironmental Protection Agency841 Chestnut BuildingPhiladelphia, PA 19107

RE: Novak Sanitary Landfill

Dear Ms. Nichols:

Thank you for your letter of May 8, 1990. As counselfor Novak Sanitary Landfill, Inc. ("NSL, Inc."), I an veryconcerned with the continuing perception that the landfill isstill accepting waste or burning trash. I have discussed thisnatter with Hilda Novak, who, as a result of her husband's death,is now acting as President of the corporation.

Mrs. Novak has assured me that the landfill has ceasedall operation. I was very surprised to hear that Mike Towleobserved what he believed to be evidence of very recent dumpingat the time that he toured the site on April 30, 1990. Uponlearning of that information, I immediately contacted Mrs. Novak,and her son, Louis Novak. Mr. Novak has been assisting hismother in this matter. I advised them that Mr. Towle hadobserved a drum and what appeared to be trash bags or remnantsthereof in an area to the left of the road into the landfill. Atmy request, Mr. Novak toured the site, and reported to me that hebelieved that Mr. Towle had observed a long existing drum thatwas among the few that had yet to be gathered and stored fortesting and removal purposes. He advised me that he did not seeany evidence of recent dumping. In any event, you advised me inour phone conversation on May 10, 1990 that the trash observed byMr. Towle had been left there by the PRP group's contractors.

Be that as it may, I have emphatically stated to myclient that there must not be any dumping or burning activity atthe site, in an equally as emphatic manner, the Novaks havestated that no such activities are continuing. Mrs. Novak has

AR2080I7

FREY. PETRAKIS & FERRY

Lisa NicholsMay 21, 1990Page 2

advised me of a couple of instances of unauthorized use of thelandfill, for disposal of demolition debris, that have occurredin past months, but nothing, to her knowledge, of more recentvintage. She has posted a sign which clearly states that thelandfill is closed.

As to the trash burning issue, Mrs. Novak has advisedme as follows. Approximately two or three weeks ago, Louis Novakor one of his employees was doing some welding work on a truck onproperty adjacent to the landfill site, and accidentally ignitedsome hoses and other material in and about the vehicle.According to Mrs. Novak, tha fire marshal and the South Whitehallpolice were alerted, and inspected the scene. There has been noburning of trash.

On behalf of NSL, Inc. , I must also make a fewobservations about the circumstances that may be contributing tothe continued perception of landfill use. First, please recallthat Louis C. Novak operates a trucking business from a garage onthe property owned by NSL, Inc. adjacent to the actual landfillsite. Therefore, trucks go in and out of the area on a regularbasis. Consequently, the main gate from Limekiln Road to theproperty is occasionally opened and closed. However, Mr. Novakis presently installing a second gate in front of the actuallandfill area. Moreover, unfortunately, there is somewhat of a"family feud" ongoing between the Novaks and Debra Pidstawski.Mrs. Pidstawski is the daughter-in-law of the sister of Mrs.Novak1 s late husband. Apparently, some time ago, Mr. Novak andhis sister had a disagreement with respect to the purchase of herreal estate. Tha family members have never made amends.According to Mrs. Novak, Mrs. Pidstawski is unable to maintainobjectivity with respect to issues concerning the landfillbecause of this personal matter. It is regrettable that thesecircumstances exist as they unnecessarily complicate the job thatmust be done, but, I suggest that wa must keep them in mind.

Please allow me to assure you that the Novaks sincerelydesire to cooperate with EPA and the PRP Committee in seeing toit that tha RI/FS is completed in an efficient and timely manner.I will suggest that some of the recent actions of tha Novaks areproof of this desire. For example, as mentioned above, the drumsat the site have been gathered, and we are in the process ofretaining someone to sample their contents. With EPA approval,tha drums will ba disposed of off -site. Moreover, as I advisedyou in our telephone conversation on April 26, 1990, NLS, Inc.,in a "housekeeping" effort, has removed, or shortly will removescrap metal from an area adjacent to the landfill. Finally, NSL,Inc. has contributed almost $100,000 to the RI/FS effort, and, inall likelihood, will contribute further sums shortly.

AR2080I8

FREY. PETRAKIS & FERRY

Lisa Nichols W ., MfaMay 21, 1990Page 3

If you would like to tour the site or meet in order tofurther discuss this matter, please so advise me.

Very truly- yours ,

JONATHAN M. PETRAKIS

JMP/vh

cc: Hilda NovakLouis C. NovakKenneth Markowitz (3RC23)L. Lunsk (PADER)L. Diamond (Hannoch Weisman)

HR2080I9


Knoxville.TN 37990615-691-5052

7 September 1990

Ms. Lisa NicholsUnited States Environmental Protection AgencyRegion III341 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Reference: Novak Sanitary Landfill SiteLehigh County, Pennsylvania

Dear Ms. Nichols:

As we discussed, the liquid which was collected in thedecontamination of equipment, and purging of monitoring wellswas transported from the Novak Sanitary Landfill Site on 7August 1990. Tha liquid was vacuumed from the on-site storagetank by S&J Transportation and transported to E.I. DuPont DeNemours & Company Chambers Works in Deepwater, New Jersey fortreatment/disposal. Tha storage tank which had been leasedfrom S&J Transportation was demobilized on 14 August 1990.


Sincerely,de maximis, inc.

:k A. TraversS4nior Project Manager

MAT/mdm

cc: Ed Me Tiarnan, Esquire, Hannoch Weisman

AR208020

T_— T-» -r\ "*" * * *^ r*1<fe maximis, inc. R F \- . - -P.O. Box 90348 , 0 ,.3

Knoxviile, TN 37990 NOV 1 ?. v+615-691-5052

6 November 1990

VIA FEDERAL EXPRESS

Ms. Lisa NicholsUnited States Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Reference: Novak Sanitary LandfillLehigh County, Pennsylvania

Dear Ms. Nichols:

On behalf of the Respondents in the above matter, this lettertransmits seven (7) copies, one which is unbound, of theaddendum to the Remedial Investigation/Feasibility Study WorkPlan/Field Operations Plan for your review. The addendumincludes a schedule for completion of the activities outlinedin the addendum, and for submittal of the RemedialInvestigation Report.

If you or your staff have any questions concerning theenclosed addendum or any other aspect of the referencedproject, please do not hesitate to contact me.

Sincerely

Mark A. TraversSenior Project Manager

MAT/mdm

Enclosure

cc: Edward Me Tiernan, EsquireLawrence W. Diamond, Esquire

, File: nichols4/dsk 6

AR20802I


90 WCST STATI ar-fCT 4 BCCKCA FARM ROAD

SUiTti-00 ROSCLAND. NEW JERSEY O7Oaa-3788»O »OH >*••

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.00 OVC«1.00« CCNTi. —« —— ——— JOSEPH A. WEISMAN

CNS3CM PLEASE REPLY TO: "OBC(rr * MAT™E"S»«,NC«TOH. NJ 085-3 930* P.O. BOX IO-4O WRITER'S DIRECT LINE:(•o»l»»7»*oo NEWARK. NJ O7IOI-96I9 535-5416

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March 5, 1991

VIA

Kenneth Markowitz, Esq. (3RC23)Assistant Regional CounselRemedial Enforcement SectionOffice of Regional CounselU.S. Environmental ProtectionAgency Region III

841 Chestnut BuildingPhiladelphia, Pennsylvania

Re i Novak Sanitary LandfillAddend"* *9 RI/FS: _______

Dear Mr. Markowitz »

This letter references our telephone conversation ofMarch 4, 1991. As we discussed on February 27, 1991, therespondents received BPA's comments to the January 16, 1991 ad-dendum to the previously approved Work Plan/Field OperationsPlan.

Despite the numerous discussions between the ProjectManagers for BPA and the Respondents, and apparent agreement dur-ing a meeting held on January 3, 1991, BPA's latest comments dif-fer dramatically from the last set of BPA comments received onDecember 1, 1991 and December 28, 1990. The Respondents believethat BPA's February 27, 1991 letter constitutes an entirely newset of comments which are largely unrelated to the original roundof comments. Accordingly, the respondents hereby request thatBPA agree to apply the 45 day review period set forth in SectionVIII B of the Administrative Order to this latest round of com-ments .

AR208022


Kenneth Markowitz, Esq.March 5, 1991Page 2

Please contact me &o eoon as possible to discuss howbest to address this request while avoiding unnecessary delay.

Very truly yours,

HANNOCH WE I SHAN

ByEdward F. McTiernan

cct All PRP CounselMr. Mark Travers (via telecopier)

AR208023

\ HANNOCH WEISMANA PROFESSIONAL CORPORATION

COUNSELLORS AT LAWSO ««T JT.TC .T.CCT „ BECKER FARM »OAO ..so __„«„-„„... s,,,t£T „Su'Tt-00 ROSELANO. NEW JERSEY O7O65-37aa Su.rt «OO

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609I39**.00'»CS'-itC i«09)3»«»»9« 1*011 »»-• O* COUNSEL

T • «,,CHA«OJ HUGHCS00 OVC«LOO- CC-re. "'»' »«•»«« JOSEPH * «CISMA*

PLEASE REPLY TO: ROee"T * -*"-«••.NCCTON MJ 0890 930* P.O. BOX IO4O WRITER'S DIRECT LINE:.609] »*•> »ioo NEWARK. NJ O7IOI-98I9 /init CIS..e (201) 535-

ntci

March 8, 1991

Via Telecoier and Reular

Kenneth Markowitz, Esq. (3RC23)Assistant Regional CounselRemedial Enforcement SectionOffice of Regional CounselU.S. Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Re* Novak Sanitary Landfill,

Dear Mr. Markowitz s

This letter references the recent round of telephonediscussions between various representatives of EPA and theRespondents concerning BPA's second round of comments to theAddendum to the RI/FS Work Plan. In order to avoid unnecessaryconfusion, I am writing to outline our present understanding ofhow Respondents intend to proceed.

Based upon a series of conversations between MarkTravers and Lisa Nichols, BPA has agreed to limit the revisionsto the fork Plan contained in Lisa Nichols' February 22, 1991letter tot (1) installation of a single additional deep well inthe vicinity of existing MW-22; (11) collection of an additionalround of groundwater samples from the four monitoring wells whichhave exhibited the highest concentration of site-relatedcontaminants and (ill) collection of surface water samples inJordan Creek at the locations where sediment samples arecollected. We anticipate that there will be a separate letterfrom Mark Travers to Lisa Nichols on these technical issues andthat EPA will eventually memorialize its approval of the WorkPlan Addendum in a letter to us.

HANNOCH WEISMAN• A

In light of time which may be necessary to finalizethese understandings, we assume that the two-week extension(i.e.. until April 1, 1991) which you discussed with LarryDiamond on March 5, 1991 has been granted. In reliance on theapparent agreement, we do not plan to postpone any RI/FSactivities. Nevertheless, we request EPA's formal approval ofthe Work Plan Addendum by no later than April 1, 1991.

If this letter does not accurately reflect EPA's presentposition, please contact me at once.

Very truly yours,HANNOCH WEISHANA Professional Corporation

By.Edward F. KcTiernan

EFMtdldcct All PRP Counsel

*~-£i£jfcV,-*&:•££

SLTflpiiSt*-**- "'-

V.i Si'••*•%«.

flR208025


SO »CST STATC »T*tIT -4 DECKER TARM ROADSUITIKOO ROSELANO. NEW JERSEY O7O«8-378a• O CO* '<••

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(.0,, 3», 799.»ICHAJ»OJ HUGHES(SIX) 7J

.00 OVC-LOOK CC-Tt- «'*' ™ JOSEPH A «E,SMAN

PLEASE REPLY TO: ROSEI.TA MATTHEWS

. Mjo«9*3-s30* P.O. BOX IO4O WRITER'S DIRECT LINE:teo»>9»T-9«oo NEWARK. NJ O7IOI-98I9 (201) 535-5416r.CS'MiLC (8O9) 9a7-On« ^ '

FILE*

42668-2

July 1, 1991

Via Federal Express

Kenneth Markowitz, Esq. (3RC23)Assistant Regional CounselRemedial Enforcement SectionOffice of Regional CounselU.S. Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Res Novak Sanitary LandfillSite Access _________________

Dear Mr. Markowitz i

Despite several attempts I have been unable to reach youby telephone. Therefore, I am writing to express theRespondents' growing concern about certain BPA actions whichappear to be Increasingly arbitrary. In particular, there areproblema-.pith the schedule for completion of the RI and therequirements for the landfill gas vent survey. Unfortunately,despite numerous discussions, the technical Project Managers havebeen unable, to resolve these issues.

The confusion concerning the RI schedule is a majorconcern to the Respondents. BPA's final approval letter wasissued on May 13, 1991 and received on May 16, 1991. Therefore,under paragraph VIII. 6 of the December 31, 1988 AdministrativeOrder, the Hay 13, 1991 date triggers the schedule under the RIWork Plan. In addition, the recent access problems constituted aForce Majeure event entitling Respondents to a further schedule

flR208026


Kenneth Markowitz, Esq.July 1, 1991Page 2

adjustment. However, EPA's Project Manager reportedly insistsupon using a date in April as the approval date.

As our actions to date indicate, the Respondents are nottrying to unnecessarily delay the RI. However, we believe we areentitled to a reasonable and well defined project schedule.

Similarly, concerning the gas vent study, theRespondents have been diligently attempting to satisfy EPA'sconcerns and collect this data. Nevertheless, EPA has myriadcomments, several of which are inconsistent or impracticable. Ofcourse further changes or delays to the gas vent work planproposed by Respondents may eventually necessitate a furtherschedule adjustment.

Please call me once you have had an opportunity toreview these issues. I am certain we can reach a satisfactoryaccommodation.

Very truly yours,HANNOCH WEISMANA Professional Corporation

Edward F. McTiernan

EFWidldcci All PRP Counsel

AR208027

de maximis, inc.9041 ExecuUvc Park Drive

Knoxvtlle.eTN 37923 RECEIVED(615) 691-5052

July 10, 1991 JUL 1 5 1991

VIA OVERSIGHT COTOIBR HANNOCH WEISMAN

Ms. Lisa NicholsUnited States Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Reference: Novak Sanitary Laadfill siteLehigh County, Pennsylvania

Dear Ms. Nichols:

Enclosed are seven (7) copies, one of which is unbound, of the"Quality Assurance Summary Report and Data Validation for theJordan Creek Sediments" for the Novak Sanitary Landfill Site. Ifyou need additional copies or have any questions regarding theenclosed, please do not hesitate to contact me.

Sincerely,

MarSen

: A. Travers.or Project Manager

MAT/mdm

Enclosures

cc: Lawi eiiee "TJiantond, EsquireEdward Me Tiernan, Esquire

MttiSuorpt.Xovik/dsk 24

AR208028

de maximis, inc. JUL 2 9 19919041 Executive Park Drive

KnoxvmT-m 37923 HANNOCH WEISMAN{615) 691-5052

July 25, 1991

VIA OVERNIGHT COPRIER

Ms. Lisa Nichols (3HW21 LN)United States Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, PA 19107

Ret Novak Sanitary Landfill SiteLehigh County, Pennsylvania

Dear Ms. Nichols:

Enclosed are seven copies each, one of which is unbound, of the"Quality Assurance Summary Report and Data Validation forGround-Water Samples from Residential Wells (Second Round - FirstSet)" and the "Quality Assurance Summary Report and DataValidation for Ground-water Samples from Monitoring Wells (ThirdRound - First Set)" at the Novak Sanitary Landfill Site.

If you need additional copies or have any questions regarding theenclosed, please do not hesitate to contact me.Sincerely,de maximis, inc.

:k K. TraversSenior Project Manager

MAT/hg

Enclosures

cc: Lawrence Diamond, EsquireEdward McTiernan, Esquire

FUe:nfchol11.ltr/dsk:2/3009

AR208029


SO WIST STATC STUtCT 4 aCCXCR FARM ROAD 1190 SCVCNTCC*<T« STOttr NWSuiTCi-00 HOSELAND. NEW JERSEY O7O88-3788 Suite 6OO• oao*'i9o c*ons33.93oo WASM.NGTON.OCTKCNTOM. NJ O86O* 1298 (2021298 3<O2

rACS.M.LC (809I39Z 7986 r M O N r OF COUNSEL««*»»« R.CHAPO a HUGHES

IOO OVCHLOOK CCNTt» ___ JOSEPH A WEISMAN

PLEASE REPLY TO- POBERT A. MATTHEWS

N. NJ o85«3 930* P.O. BOX IO4O WRITER'S DIRECT LINE:(80»)»87.a200 NEWARK. NJ O7IOI-98I9 535-5416fACSIMILC (809)9870118

rut 42668-2July 29, 1991

Kenneth Markowitz, Esq. (3RC23)Assistant Regional CounselRemedial Enforcement SectionOffice of Regional CounselU.S. Environmental Protection Agency - Region III841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

ROJ Novak Sanitary Landf il\

Dear Mr. Markowitz s

This letter references our July 12, 1991 conference callwith Lisa Nichols and Mark Travers. During that call youindicated that you would discuss the confusion concerning tha RIschedule with your client and advise us of EPA decisionconcerning tha schedule by no latar than July 24, 1991. Wa havanot heard anything further from EPA since that call.Accordingly, tha Respondents' has been forced to conclude thatEPA has considered tha sequence of work plan approvals, tharecant access problems and tha timing of the revisions to tha gasvant survey and haa agreed that May 16, 1991 can serve as thaapproval data of tha RI Work Plan for Phase Two.

If this lattar does not accurately reflect EPA ' sposition pleasa contact me at onca.

Thank you for your assistance.

Very truly yours,

HANNOCH WBISMANA Professional Corporation

CLEdward F. McTiernan

ccs All PRP CounselMr. Mark Travers

flR208030

RESPONSES TO THEUS. ENVIRONMENTAL

PROTECTION AGENCY'S COMMENTSON THE

NOVAK SANITARY LANDFILLREMEDIAL INVESTIGATION

March 1992

Prepared for

Novak RI/FS PRP Group

Prepared by

Geraghty & Miller, Inc.180 Admiral Cochrane Drive

Suite 300Annapolis, Maryland 21401

(410)224-8777

GERAGHTY 6? MILLER. INC. AR20803I

CONTENTS

PAGE

GENERAL COMMENTS ON RI REPORT ............................ GC-1

EXECUTIVE SUMMARY ......................................... ES-1

2.0 BACKGROUND .............................................. 2-12.1 SITE DESCRIPTION ...................................... 2-1£2 SITE HISTORY .......................................... 2-423 PREVIOUS INVESTIGATIONS ............................. 2-5

3.0 FIELD INVESTIGATIONS ...................................... 3-133 AMBIENT AIR SAMPLING ................................ 3 t3.4 RESIDENTIAL WELL INVENTORY & SAMPLING ............. 3-5

3.4.2 Residential Wells Sampled ............................ 3-53.53 BEDROCK MONITORING WELLS .................... 3-6

3.53.1 Placement .................................. 3-63.533 Drilling and Installation Method ................. 3-6

3.6 GROUNDWATER SAMPLING .............................. 3-83.7 LEACHATE/DRAINAGEWAYS SAMPLING .................. 3-93.8 JORDAN CREEK INVESTIGATION & SAMPLING ............. ' "

3.8.1 Creek Reconnaissance ............................... * _s3.8.4 Stream Sediment Sampling ............................ 3-14

4.0 PHYSICAL CHARACTERISTICS ................................. 4-14.1 SITE SETTING .......................................... 4-1

4.12 Features of Interest ................................. 4-143 SITE CHARACTERISTICS ................................. 4-1

43.1 Waste Characteristics ................................ 4-1432 Landfill Disposal Areas .............................. 4-8

432.1 Old Mine Area .............................. 4-84323 Surface Fffl Area ............................. 4-9

4.4 GEOLOGY ............................................. 4-94.43 Local Stratigraphy and Lithology ....................... 4-10

4.432 Bedrock Lithology ............................ 4-104.5 HYDROGEOLOGY ...................................... 4-13

4.5.1 Regional Hydrogeologic Conditions ..................... 4-134.5.12 Regional Flow Evaluation ...................... 4-13

4.52 Site Hydrogeologic Conditions ......................... 4-144.52.1 Unconsolidated Materials ...................... 4-144.523 Bedrock Aquifer System ....................... 4-154.52.4 Aquifer Hydraulic Characteristics ................ 4-15

GERAGHTY & MILLER. INC. AR208032

CONTENTS (cont)

4.52.5 Ground-Water Flow Estimates ................... 4-21453 Summary ......................................... 4-22

5.0 NATURE AND EXTENT OF CONTAMINATION .................... 5-15.1 AMBIENT AIR .......................................... 5-152 UNCONSOLIDATED MATERIALS .......................... 5-453 LEACHATE AND DRAINAGEWAYS ........................ 5-5

53.1 Leacbate Seeps .................................... 5-5

6.0 BASELINE RISK ASSESSMENT .................................. 6-162 SUMMARY OF FINDINGS ................................. 6-2.

622 Surface Soil........................................ 6-2

7.0 PREUMlNARYroENTlFICATIONOFAREAS...................... 7-173.1 Federal Location Specific ARAR ............................ 7-1

8.0 SUMMARY AND CONCLUSIONS ................................ 8-1

Table 3.10 Ground Water & Surface Water Elevations .................... TBL-1

Appendix A: Baseline Risk Assessment ................................. A-l

3.0 CONSTITUENT CHARACTERIZATION ........................... A-l32 OCCURRENCE IN GROUND WATER ....................... A-l

32.4 On-Site Monitoring Wells ............................. A-l3.12 CONSTITUENT FATE AND TRANSPORT ................... A-5

3.12.1.1 Atmospheric Transport ....................... A-5

4.0 EXPOSURE CHARACTERISTICS ................................ A-64.1 RELEASE/SOURCE ANALYSIS ............................ A-642 EXPOSURE POINTS AND RECEPTORS ...................... A-6

43.6 Uncertainty in Exposure Point Concentrations ............. A-84.4 EXPOSURE POINTS AND RECEPTORS ...................... A-9

4.4.4 Leacbate Seep & Assoc. Surface Soil .................... A-94.45 Wading .......................................... A-9

5.0 RISK CHARACTERIZATION ................................... A-1052 ENVIRONMENTALRISKS................................ A-IO

522.1 On Site Surface Water ....................... A-105222 On Site Sediments ........................... A-ll

GERAGHTY & MILLER. INC. AR2Q8033

CONTENTS (com.)

Tables ......................................................... A-12Table A-6 ................................................. A-12Table A-12 ................................................ A-12Table A-13 ................................................ A-12Table A-16 ................................................ A-13Table A-30 ................................................. A-14Table A-50 ................................................ A-15Table A-51 ................................................ A-16

Appendix B: Historical Ground-Water Quality Summaries ................... B-lTable B-l .................................................. B-l

Appendix F: Storm Water Retention Ponds Capacity Calc ................... F-l

Appendix G: Ambient Air Monitoring Program Report ..................... G-l

Appendix L: Geotechnical Testing Report ............................... L-l

Appendix M: Bedrock Core Log ...................................... M-l

ATTACHMENTS

Attachment A: List of Abbreviations And Acronyms Used Throughout the RI Report

Attachment B: Well Construction Data For Wells Installed At The NSL Prior To TheRI/FS Program

Attachment C: 7.0 Phase One Baseline Ecological Evaluation

Attachment D: Depths And Geological Descriptions Of On-Site Sediment Samples

Attachment E: Geologic Logs For The Jordan Creek Sediment Samples AndSketches Of The Sample Locations

Attachment F: Rock Quality Designation (RQD) Synopsis

Attachment G: Revised Tables For Baseline Risk Assessment

Attachment H: Table 2-2a Runoff Curve Numbers For Urban Areas And RetentionBasin Field Notes

Attachment I: Definitions And Symbols Used In The Geotechnical Testing Report

GERAGHTY & MILLER. INC.

CONTENTS (cont.)

Attachment J: "Definitions of Surveying and Associated Terms" and HorizontalControl Sheet

Attachment K; Correspondence to USEPA from Mark Travers datedFebruary 28,1992

Attachment L: Correspondence to Lawrence W. Diamond from USEPA datedMarch 9,1992


GENERAL COMMENTSComment

a. The regional and local geology and ground-water system are well defined, andthe analyses and conclusions relating to new data collected in the RI convergewith those of prior studies in the area.,

ResponseIt is agreed that the findings of the RI are generally consistent with numerousprior studies of the area, and that the regional and local geology and ground-water system are well defined.

Commentb. The limited pump test program of the RI, under other circumstances, might

be considered inadequate, but the distribution and magnitude ofcontamination in the ground water system (see Figures 5-1 and 5-2 of the RIReport) does not seem to warrant the consideration of a pump and treatsystem, the typical precursor condition to a long-term pump test In addition,there are data from several short term pump tests that were carried outduring development of the monitoring wells, substantial water level data(including stream stage and stream flow measurements), and a considerableamount of ground water system information and parameters from otherstudies which leads to a well defined ground water flow system, in spite of thelack of a more extensive pump test program. The only pump test that mightprovide useful information would involve all of the existing public supply wellsplus the Cornerstone well to determine whether and to what extent themonitoring wells at the site would be affected by such a combined pumpingstress.,

ResponseIt is agreed that the distribution and magnitude of constituents in theground-water system do not warrant the consideration of a pump and treatsystem. It is also agreed that the hydrogeologic investigations, conducted atthe site in accordance with the approved Work Plans, have provided

GERAGHTY 6? MILLER. INC. AR208036

GC-2

considerable information from which to define the ground-water flow systemat the site.

The usefulness of data collected from a long term pump test, utilizing all ofthe existing public supply wells and the Cornerstone Well, is questionable,especially in consideration of the time period before the Cornerstone Well willbe folly utilized. More useful data could be collected during actual operationof the Cornerstone Well by recording ground-water level patterns prior to andduring pumping of this well at existing monitoring wells near the site. Sincethe existing monitoring wells are far from the Cornerstone Well and dose tothe NSL, a ground-water level monitoring program including the existingmonitoring wells could detect potential influences by the Cornerstone Well atan early stage of production.

Commentc. The interpretation of the local carbonate rock ground-water flow system as a

diffuse-flow system, instead of a conduit-flow system (dominated by solutionfeatures), is well evidenced. (See Section 45.1.1 and Section 4523) Thediffuse-flow system is overprinted, as it were, by fracture traces which serveas preferential flow zones for wells and the natural flow system. Thecontention that the milestone bedrock of the region and the site area is notdominated by Karst structures is also well founded and documented in the RIReport,

ResponseIt is agreed that the carbonate rock ground-water flow system at the NSL canbe characterized by a diffuse-flow system not dominated by Karst features.This is supported by the findings of the RI.

GERAGHTY & MILLER. INC AR208037

GC-3

Commentd. One general concern is the reported thickness of the vadose zone (see Section

4.523.) and the possibility that contaminants have been (are being) adsorbed,rather than reaching the saturated zone of the ground-water system wherethey would be detectable after they migrated from the waste disposal areas.Just how effective adsorption might be over time in retarding contaminantmigration from reaching the saturated system is uncertain and hypotheticalIt is recommended that the short-term and long-term potential for adsorptionof contaminants and the thick vadose zone be addressed in the RI in Section5.0 (Nature and Extent of Contamination).,

Response

It is agreed that the vadose zone beneath the NSL has a finite capacity foradsorbing constituents. This is due to the limited number of "sites* availablefor adsorptive bonding in the vadose zone and is evidenced by the detectionof leachate constituents in the ground water beneath the NSL. The detectionof leachate constituents in the ground water indicates that the capacity ornumber of available adsorptive "sites" in areas of the vadose zone have beenexceeded and leachate constituents are passing through the vadose zonerather than being adsorbed.

The quantity of leachate constituents passing through the vadose zone can bereduced by reducing the infiltration through the waste disposal areas. Thiscan be accomplished through a number of site improvements includingimprovement of storm-water management controls, site grading andconstruction of soil covers over areas of exposed waste.

Predicting or quantitatively analyzing the effects of the vadose zone onleaching constituents is very difficult, at best (Bagchi, Amalendu; Design,Construction, and Monitoring of Sanitary Landfill; John Wiley & Sons;


GC-4

1990). Therefore, it Is recommended thai continued monitoring of the groundv_/ water be incorporated into remediation plans for the NSL to monitor the

adsorptive capacity of the vadose zone and the effects of site improvementson ground-water quality.

Commente. With regard to the graphics (Figures) of the RI report, the topographic

contours are virtually impossible to read. As such, it is impossible to comparethe topography with the ground water contours. It is recommended that thegraphic quality of the topographic contours be improved.,

ResponseA topographic map with dearer graphic quality will be provided in therevised RI Report.

Commentf. A list of abbreviations used throughout the report, and their meaning, should

be provided after the Table of ContentsResponse

A list of abbreviations used throughout the report is provided in AttachmentA of this document and will be provided in the revised RI Report

Commentg. All chemical data tables. As per Region ffl guidance, all data tables in the

main bodies of the RI and risk assessment should include detection limits andthe code 'U* for all non-detect observations. (If a compound was not detectedin any sample of a particular medium, however, it is reasonable to omit itfrom the summary tables, as was done.)5

ResponseThe RI Report contains two complete sets of chemical data tables. The firstset In the Tables section of the report are summaries showing only thoseconstituents that were detected, and the second set in Appendix C arecompiled of the foil validated data spreadsheets with all of the testedparameters including the code "U* for non-detect observations. This dual

GERAGHTY & MILLER, INC. A R2 080 39

GC-5format was purposefully selected to maximize the clarity of the presentation.The tables in Appendix C make the entire data set readily accessible whilethe summary tables in the Tables section are easy to read for reference inconjunction with the text discussion. We are not aware of the EPA Guidancethat is referred to, nor were we provided with such. We request the EPAprovide the referenced guidance.

GERAGHTY & MILLER, INC. A R2 080^0

EXECUTIVE SUMMARY

Commenta. The Executive Summary section of the RI report fails to mention the

ecological characteristics of the Novak Sanitary Landfill (NSL). Section 32:Site Reconnaissance covers, in detail, the environmental setting and featuresof interest (wetlands, floodplains, and biological screening) of the site,however, there is no mention of these features of interest in the ExecutiveSummary.,

ResponseSince the intent of an Executive Summary is to discuss only those issues orfindings which may significantly affect the outcome of an investigation orstudy, a discussion of the environmental setting and features of the NSL didnot seem appropriate in the Executive Summary. This decision wassupported by the findings that no listed threatened or endangered spedes,and/or unique or critical habitats are known to exist at the site.

However, in an effort to respond to the USEPA's comment, the following willbe added as the third paragraph of the Executive Summary:

A field reconnaissance, as well as literature reviews and inquiries tofederal, state and county agencies, was conducted to characterize theNSL and its environmental setting. The investigation determined thatthe NSL, which is located in a developing area where ruralagricultural land is being converted to residential communities, isabove the 100-year flood plain of Jordan Creek and that there are nofederally mapped wetlands on the site. It was also determined that nolisted threatened or endangered spedes, and/or unique or criticalhabitats are known to exist in the site vicinity. The only wildlife ofspecial concern potentially located in the project area are three typesof plants which have been reported from two to three miles outside theproject area.

GERAGHTY & MILLER. INC. A R 2 0 8 0

ES-2

Commentb. On page ES-4, the second paragraph discusses hazard indices under

hypothetical future exposure pathways, and subsequently exposures tobackground levels of the potential constituents of concern in soils and airresulting in hazard indices greater than or approximately equal to thosecalculated for exposure to site-related constituents. It does not seem that thisconclusion is well supported. As will be seen in comments to follow, itappears as though G&M may not have sufficiently defined the backgroundlevels (upwind conditions) of the potential constituents of concern in air.,

ResponseThe objective of the Ambient Air Monitoring Program was two-fold. Theprimary objective was to evaluate the ambient air quality of the site toidentify air quality conditions, if any, which would have requiredincorporating special precautions into the site health and safety plan (HASP)in order to provide the necessary levels of protection to field personnel duringthe ensuing field activities. The second objective was to screen the site fortarget VOCs which, if identified, would have warranted further investigations.It was not an objective of the Ambient Air Monitoring Program to define thebackground levels of the potential constituents of concern hi air, but ratherto determine If the landfill had any effect on ambient air quality.

During the Ambient Air Monitoring Program, target VOCs were not detectedat the site in excess of Multimedia Environmental Goals (MEGs), ambientconcentration levels, American Conference of Governmental IndustrialHygienists (ACGIH) workplace standards, and Pennsylvania Department ofEnvironmental Resources (PADER) ambient Air Toxic Guidelines (ATGs).These findings led to the conclusion that no special precautions werenecessary in the HASP to provide the necessary health and safety protectionto field personnel

GERAGHTY & MILLER. INC.AR2080lf2

~ / - - 'i '"-•',..•: ; - ES-3

In obtaining data to fulfill the requirements of the second otyective of theAmbient Air Monitoring Program, Geraghty & Miller collected ambient airsamples from "upwind" site locations as well as "downwind* site locations.The purpose of the upwind and downwind air samples was to determine thenet effect of the landfill on ambient air quality and subsequently screen thesite for target VOCs. High concentrations of VOCs were not detected.

The purpose of collecting ambient air samples upwind of the waste disposalareas was not to determine "background" air quality with respect to theregion, but rather to Identify target VOCs, if any, in the ambient air at thesite which were the result of off-site sources. This procedure is typical andprovides a mechanism for differentiating between either on-site or off-sitesources of target VOCs should they be detected in downwind samples(USEPA; Air/Superfund National Technical Guidance Study Series; VolumesI through IV; 1989-90).

Since target VOC concentrations detected at both the upwind and downwindsampling locations ranged from non-detectable to detectable but well belowthe MEGs, ACGIH workplace standards and PADER ATGs, It was concludedthat the landfill had essentially no effect on the ambient air quality.Therefore, no further investigations of the ambient air were warranted.

GERAGHTY c? MILLER, INC. AR208Qt*3

2.0 BACKGROUND

2.1 SITE DESCRIPTIONComment

a. More detailed information should be included in this section. Thisinformation should include, but will not be limited to, descriptions ofperennial or intermittent streams, on-site ponds, fields, woods and wetlandslocated on or near the site. Access restrictions (fences, gates, etc.) should alsobe discussed in this section. This will have an impact on ease of access forterrestrial wildlife and for human trespassers. The presence of absence offencing should also be discussed in the Site Reconnaissance section.,

ResponseThe first paragraph of Section 2.1 will be revised to read as follows:

The NSL is located on a parcel of property approximately 65 acres insize in the northern portion of South Whitehall Township (SWTP) inLehigh County, Pennsylvania (Figure 2-1). The approximately 65 acrepared is situated on a hillside north of Jordan Creek and southOrefleld Road. Jordan Creek is approximately 400 feet from the NSLat its closest point; however, there are no defined drainage pathwaysfrom the NSL to Jordan Creek. The parcel of property south ofOrefidd Road is referred to as the 'NSL' and the "site" throughout theRI/FS and is part of an approximately 94 acre piece of propertyowned by the NSL and/or members of the Novak family. Theremaining pared of property, approximately 29 acres in size, is locatednorth of Orefleld Road and is also owned by the NSL or members ofthe Novak family. The site is separated from neighboring propertiesby a steep drop in elevation to the south and southwest; partially dueto natural topography and to the buildup of the landfill disposal areasand storm-water management berms. Stands of trees and heavy brushseparate the NSL from neighboring properties to the east, south andwest. The site is accessed from the north at the intersection c

GERAGHTY & MILLER. INC. AR2080H

2-2

OreCeld Road and Ume Kiln Road (Figure 2-1). Access is restrictedat this location, however, by buildings and a gate.

The following paragraph will be added to the end of Section 2.1:There are no natural perennial or intermittent streams located on theNSL. Primary surface water drainage pathways over the wastedisposal areas discharge to the southwest and southeast retentionbasins via the drainage swales constructed along the western andeastern property boundaries as discussed above. In addition to thesoutheast and southwest retention basins, poor surface watermanagement practices have resulted in smaller areas of standingwater on the site. These areas of standing water are located behindthe maintenance building in the northwest corner of the site, over thecentral portion of the Old Mine Area and over eastern portions of theSurface Fill Area. These areas, as well as the drainage pathways, areshown on Figure 3-6 of the RI report.

Page 2-1; 1st paragraph:Comment

b. The third sentence states, "Jordan Creek is approximately 400 feet from theNSL at its dosest point" This implies distance to a site boundary. Dynamacrecommends that the dosest distance to the surface water body, Jordan Creek,be presented as distance to a source area with an identified drainage pathway(ie: fill area, stonmvater retention pond, etc.):

ResponseThe third sentence of paragraph one will be replaced with the following:

Jordan Creek is approximately 700 feet from the nearest disposal areaon the NSL (Trench 5) and approximately 450 feet from the neareststormwater retention basin on the NSL However, there are DO defined

GERAGHTY & MILLER. INC fl R £ 08 0 If 5

2-3

drainage pathways from the waste disposal areas or the stormwateretention basins to Jordan Creek.

Commentc. The storm water retention ponds do not receive all the site drainage

according to Figure 3-6. The last paragraph in the section should include astatement that some of the drainage is discharging off-site through breachesin the drainage pathway.,

ResponseThe following will be added to the last paragraph of Section 2.1:

The southwest and southeast retention basins receive surface waterrun-off from portions of the Old Mine Area as well as the flow fromthe Surface Fill and the Trench Fill Areas. During excessive rainfallevents, the capacity of these retention basins may be exceeded, inwhich case they apparently discharge off-site; however, off-sikdischarge of the retention basins was not observed by Held personnelduring RI activities.

The potential for rainfall events to exceed the capacity of the retentionbasins is based on the Urban Hydrology for Small Watersheds modd(TR-55) developed by the United States Department of Agriculture SoilConservation Service. The model was conservatively applied to theNSL, in that the cover soils used in the modd are most likely lesspermeable than the exposed waste at the site; in which case, thecapacity of the retention basins would be exceeded less frequently dueto greater infiltration of surface water at the site than was modelled.

Based upon the topography of the site, not all of the site drainagedischarges to the on-site retention basins. Surface water flow ontsir*

GERAGHTY & MILLER. INC. A R2 080*16

2-4

of the bermed areas of the site along the .western, southern, and• • .,:, ''V •

eastern property lines discharges off-site along natural drainagepathways.

SITE HISTORYPage 2-5; 2nd paragraph:

'"fontnenta. The report states that the facility continued to accept waste after Trench 5

was filled. Where was this waste disposed if the trenches were filled?,Response

The second sentence of the second paragraph will be replaced with thefollowing :

After that time, field personnel observed that the facility accepted verylimited quantities of wastes, In the area of Trenches 4 and 5, and inlow lying areas of the Surface Fill Area.

b. The Site History should indude the same description of aerial photographsthat currently appear in Section 323 Interpretation of the photographs mayprovide valuable data (past chemical haiKflipg and storage practices, land usevariations over time, possible contaminants and current ecological conditions)for the site characterization.,

ResponseAlthough the intent of this comment Is more appropriate for characterizingindustrial facilities, descriptive information from the aerial photographs willbe incorporated into Section 2.2. Hie descriptive information will be basedupon the USEPA Site Analysis prepared try the Environmental MonitoringSystems Laboratory, Las Vegas, Nevada and upon subsequent reviews of thedocument.

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23 PREVIOUS INVESTIGATIONSComment

a. It should be mentioned in this section whether components of an ecologicalassessment have been performed at the site in the past If, through interviewswith NSL operators, nearby residents, and the review of available records itis discovered that no such assessment took place, then it should be mentionedhere.,

Response

The following paragraph will be added to the end of Section 23:Based upon a review of WBSAI's files, there is no indication that anecological assessment was conducted at the NSL. Discussions with thecurrent landfill owner/operator and nearby residents also did notindicate that ecological assessments were conducted at the NSL.

Page 2.6; 2nd and 3rd paragraph:

b. The drilling logs of the original monitoring well network discussed in thissection should be provided in Appendix N.2

ResponseInformation on the pre-Rl monitoring wells was obtained from Walter B.Satterthwaite (WBSAI) files; the firm that established the original monitoringnetwork at the NSL. The drilling logs for Monitoring Wells MW-1A, MW-1B,MW-1C, MW-2A, MW-5 and MW-6 are provided in Attachment B. Thedrilling logs for abandoned Monitoring Wells MW-1 and MW-2, and forMW-3 (Hilda Novak's residential wdl) and MW-4 (Louis Novak's residentialwell), were not available. However, a summary table by WBSAI (alsoprovided in Attachment B) includes MW-1, MW-2, MW-3 and MW-4construction details.

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2-6

Commentc. More specific information should be provided on the construction and/or

operation problems with the abandoned monitoring wells. Drilling logs forthese wells should also be provided in the Appendix. If no drilling logs areavailable for these wells, this should be stated in the report

ResponseAttachment B provides all the available drilling logs for the pre-RI on-siteresidential and monitoring wells. Further specific information on theconstruction and/or operation problems, beyond that noted in the RI textSection 23, was not available.

Commentd. What is the exact composition of the landfill gas? Monitoring well Ic, which

is venting landfill gas, bad high levels of VOCs in the groundwater. VOCscan be volatilizing from this well in the form of landfill gas, therefore theexact composition of this gas needs to be determined

ResponseHigh levels of VOCs were not detected at Monitoring Well MW-1C In fact,during the three rounds of ground-water monitoring (April 27, 1990, May 10,1990 and May 6, 1991), none of the detected VOCs exceeded Federal MCLsor Pennsylvania WSC

Since the Ambient Air Quality Monitoring Program did not detect targetVOCs at concentrations above Multimedia Environmental Goals, ambientconcentration levels, American Conference of Governmental IndustrialHygienists workplace standards, and PADER ambient Air Toxic Guidelines,further characterization of ambient air quality, indnding determining theexact composition of landfill gas venting from the site, is not necessary forcharacterizing the site. This is supported by the understanding that theconfiguration of landfill gas vents at the site, as well as the cover systems

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2-7

over the waste, will change with the forthcoming remedial actions. For thisreason, the characteristics of ambient air quality following implementationof remedial actions will most likely change from current conditions.Therefore, since the current air quality conditions were not a health andsafety concern and were not characterized by high concentrations of VOCs,further characterization of a condition which will most likely change withimplementation of remedial actions was not justified. As discussed duringthe February 13,1992 meeting with the USEPA and confirmed In a February14,1992 correspondence from Mark Travers (de maximis, Inc.) to Cesar Lee(USEPA), any additional air quality evaluations will be considered during theRemedial Design stage of the project.

fioynment

e. This section mentions that monitoring well MW-1C has been observed ventinglandfill gas. There is no mention of gas monitoring for combustible gas viasoil migration in this report A soil gas survey was conducted at the site andthis information should be included in the RI Report,

ResponseThe soil gas survey and subsequent report were conducted and prepared,respectively, under the FS so as not to delay RI field activities or submittalof the RI report. This approach was necessary largely due to the significantamount of time required for preparation and approval of Work Plan

*Addendum No. 2. Approximately three months tune elapsed between USEPAnotification to the Novak PRP RI/FS Group that a work plan for theadditional field work was necessary and subsequent approval of the preparedwork plan. By the time Work Plan Addendum No. 2 was approved by theUSEPA, RI field activities were completed.

Furthermore, since the data to be collected under Work Plan AddendumNo. 2 was considered pre-design data rather than Investigative data, it was


2-Sagreed to with the USEPA, that the data did not need to satisfy the dataquality objectives (DQOs) established for the RI. Therefore, since datacollected under Work Plan Addendum No. 2 is not consistent with the DQOsfor the RI, it is not appropriate to include it in the RI report.

Last, during approval of the Work Plan Addendum No. 2 for conducting theSoil Gas Survey, it was agreed to, by the USEPA, that the correspondingreports on the results of the additional investigation would be included as anappendix to the FS and would not be induded in the RL

GERAGHTY & MILLER. INC **

3.0 FIELD INVESTIGATIONS

Commenta. The Soil Gas Survey and the sampling of the gas vents should be discussed in

this section and not in the Feasibility Study as suggested. The location of thegas vents, used for the soil gas survey, as well as the methane vents, used forthe liquid sampling, should be provided in a figure.,

ResponseAs previously stated, during approval of Work Plan Addendum No. 2 forconducting the Soil Gas Survey as well as the Gas Vent Investigation/LiquidSampling and Analysis, it was agreed to by the USEPA, for the reasonspreviously stated, that the corresponding reports on the results of theadditional investigations would be included as appendices to the FS andwould not be included in the RI. The reports subsequently included in theFS are submitted with maps which Indicate the approximate locations of thesoil gas probe locations and the gas vents.

Commentb. An Ecological Assessment should be conducted at the site (See the attached

document for guidance on conducting Ecological Assessments).,Response

The ecological assessment efforts of the RI were conducted In accordance withthe approved Work Plan and Field Operations Plan (FOP), as requiredpursuant to the AOC These efforts included some but not all of the taskslisted as part of a Phase I Study in the Recommendations For ConductingEcological Assessment guidance that was attached to the USEPA's commentsto the RI report. Nevertheless, limited additional investigations have beenconducted at the site in the effort to respond to the USEPA comments on theRI Report and as agreed to during the February 13, 1992 meeting with theUSEPA.

GERAGHTY 6? MILLER. INC. flR208052

3-2*-'', -.

On Wednesday, February 19,1992, Mark Travers of de maximis, inc. andDoreen Sousa of Geraghty & Miller, Inc. met at the NSL with Robert S.Davis of the USEPA to conduct a walkover of the site. The purpose of thewalkover was for the USEPA to generally evaluate the NSL with respect towetlands and wildlife habitats of significant value and to determine whetherany additional wetland investigations may be appropriate. The findings ofthe walkover are summarized in a memorandum to Cesar Lee (USEPA) fromRobert S. Davis dated February 20,1992. An agreement was reached betweenMr. Travers and Mr. Davis with the concurrence of Mr. Lee, that apreliminary wetland delineation would be conducted as part of the RLAdditional investigations, if any, would be conducted during the RemedialDesign stage of the project

On March 11, 1992, Geraghty & Miller conducted a preliminary wetlandsassessment at the NSL. The preliminary wetland assessment was conductedin accordance with Mr. Davis' memorandum and included the identificationof wetland areas based on current depth to ground water and vegetativegrowth guidelines outlined in the 1989 United States Department ofAgriculture Federal Manual for Delineating Wetlands.

The findings of the preliminary wetlands evaluation, as well as the findingsof the other ecological assessment components of the RI, have been compiledinto a comprehensive section of the RI Report; Section 7.0 Phase OneBaseline Ecological Evaluation (previous Sections 7.0 through 9.0 winsubsequently be renumbered as Sections 8.0 through 10.0, respectively).Section 7.0 is structured In accordance with the Recommendations forConducting Ecological Assessment Guidance and is provided as AttachmentC

GERAGHTY & MILLER. INC. AR2080S3

3-3Our understanding based upon the February 13, 1992 meeting andsubsequent discussions with the USEPA regarding the Ecological Evaluationsis that this additional work Is fully responsive to USEPA's comments andcompletes the Ecological Evaluation for the RI at the NSL site.

Commentc. An "Ecology" subsection should be inserted in the "Environmental Setting"

section of Chapter 3. The Ecology section should include a discussion of theecosystems (eg. woods, fields, wetlands, streams, ponds) on or near the site.This section should also include information on visibly stressed biota,, 4

ResponseAs stated in the previous response, the ecological assessment components ofthe RI have been compiled into a comprehensive section of the RI Report(Section 7.0 Phase One Baseline Ecological Evaluation). The section isprovided as Attachment C

Commentd. The ecological characterization in some cases has not been ground-truthed.

For example, the investigator only used the National Wetland Inventory Mapsfor drawing conclusions about the existence of wetlands. The investigatorshould ascertain through visits to the area that no wetlands are present andshould resort to the Federal Manual for Identifying and DelineatingJurisdictional Wetlands (if any are found).4

ResponseThe wetlands delineation presented in the RI Report was prepared in fullaccordance with the approved Work Plan and Field Operations Plan.However, as discussed in response to comment 3.0 b, in an effort to addressthe USEPA's comments, Geraghty & Miller conducted a preliminary wetlandsevaluation on March 11,1992 based on the recommendation of Mr. RobertS. Davis (USEPA). The scope and basis for the preliminary wetlands


evaluation was discussed with the USEPA during a meeting with them onFebruary 13,1992 and subsequently reviewed on February 19,1992 during tsite walkover with Mr. Davis. The preliminary wetlands evaluation indndedthe identification of wetland areas based on current depth to ground waterand vegetative growth guidelines as described In the 1989 United StatesDepartment of Agriculture Federal Manual for Delineating Wetlands.

33 AMBIENT AIR SAMPLINGComment

It does not seem that a two-day ambient air sampling program conducted inFebruary would adequately assess the potential for off-site migration ofairborne constituents year round, especially considering the variable seasonsat this geographic location,,

ResponseThe RI field activities schedule necessitated conducting the Ambient AirMonitoring Program in February, prior to commencement of other scheduledinvestigative activities. This was necessitated since the primary purpose ofthe Ambient Air Monitoring Program was to screen the NSL for air qualityconditions requiring special consideration in the Health and Safety Plan. Nosudi conditions were encountered.

Furthermore, the discharge of landfill gas from the landfill gas vents at thesite are subject to greater fluctuations due to diurnal atmospheric changesrather than seasonal atmospheric changes. The dairy fluctuations inatmospheric pressure, which occur throughout the year, provide suffidentvariations in pressure gradients between the buried waste, where the landfillgas is produced, and ambient conditions to detect changes in landfill gasdischarges on a daily basis. On the other hand, the elevated temperatures ofthe buried waste remain rdativdy constant over the course of the year. Therelatively constant temperatures within the waste result in the consistent

AR2080S5GERAGHTY 6? MILLER. INC

3-5production of landfill gas, leaving landfill gas discharge rates subject to thediurnal changes in pressure gradients and not seasonal variations in ambientair temperature (Sanitary Landfill Design, Department of EngineeringProfessional Development, University of Wisconsin-Madison).

CommentG&M should provide a more specific description for the sample locationsrather than simply stating "upwind" and "downwind". G&M should alsoreference these locations on a site map.,

ResponseThe sample locations were located near the waste boundary, not the propertyboundary, in order to provide a more conservative understanding of ambientair quality. Figures 1 and 2 are provided with the Ambient Air QualityMonitoring report and illustrate the general location of samplers with respectto the site boundary. For clarity, these locations will be provided on a siteplan of the NSL in the revised RI report.

3.4 RESIDENTIAL WELL INVENTORY AND SAMPLING3.42 Residential Wells Sampled

Page 3-18:Comment

RW-13 had the highest levels of VOCs of all the residential wells sampled butno information on depth screened interval, etc. is provided. A more extensiveinvestigation should be conducted to determine the details of this we!L2

ResponseAs provided in correspondence to the USEPA on January 11, 1992,Residential Well RW-13 has been abandoned. The well was abandoned onMarch 13, 1992. As a result of the abandonment, well constructioninformation was obtained. The depth of the well was approximately 350 feet

GERAGHTY ft MILLER. INC.

<• - -W- 3-6with casing extending to approximately 160 feet. This well was abandonedfollowing the recommendations of the Pennsylvania Geologic Survey.

3.5.3 Bedrock Monitoring Wells3.5.3.1 Placement

Page 3-25; 2nd Paragraph:Comment

This section denotes the rationale for well placements. In the secondparagraph, deep bedrock well MW-7 is referenced in the beading (as a wellfor which a rationale is being given) and in the body of the text (as a rationalefor the placement of a well in the heading). "MW-7" should be removed fromthe text and replaced by MW-6, which is the shallow bedrock well dosest todeep bedrock well MW-8. For the text to be consistent with the heading, thewells in parentheses should be "(MW-1C, MW-6, and MW-2A)".,

ResponseThis change will be made in the revised RI Report.

3.53.3 Drilling & Installation MethodologyPage 3-28; Third paragraph:

CommentNeed to explain the National Geodetic Vertical Datum (NS VD) and how youwent about determining your measurements.}

ResponseThe National Geodetic Vertical Datum (NGVD) refers to a standard systemof measuring elevations relative to control points (he. bench marks ormonuments) established by the United States Geological Survey (USGS).Refer to "Definitions of Surveying and Associated Terms*. American Societyof Civil Engineers (1978) page 51, provided in Attachment J.

AR208057TMT

3-7The horizontal and vertical control was established at the perimeter of theNSL by Quinn Associates of Horsham, PA while in preparation of the sitetopographic map. The horizontal control was established relative to thePennsylvania Site Plane Coordinate System, United States Coast andGeodetic Survey (USC and GS) Monument 'AUentown Radio WAEB CenMast" (see enclosed horizontal control data sheet also provided hi AttachmentJ.). The vertical control was established relative to the USGS Dlse labdedC-7 (Elevation 33325) located on a Conrail Railroad Bridge over JordanCreek in South Whitehall Township approximately 0.66 miles southeast of theNSL site.

All of the horizontal and vertical measurements for the monitoring wells andstream staff gauges were surveyed by Gilmore & Associates, Inc. of Trappe,PA from the established control at the NSL perimeter.

Page 3-29; 3rd paragraph:Comment

The fourth sentence states, "At the end of this time, the development waterappeared dear and relatively free of sediment" it is recommended that thisstatement be made authoritative. What was the state of the discharge? Wenote that the pumping rate and period would have removed 4500 gallons ofwater, somewhat less than the estimated 6000 gallons of bentonite slurry lostin the drilling process.,

ResponseFour successive samples of the discharge water were collected to visuallyinspect the progress of the Monitoring Well MW-23 development By the endof the development time, it was evident to the field geologist that clear waterwas being removed from the well and further development would be non-productive.

AR208058GERAGHTY 6? MILLER. INC.

3-8.. .. -'.K-'-tThe collection of clear water after pumping only 4500 gallons of water from

the well during development is evidence that much of the 6000 gallons ofdrilling mud was lost to the "highly fractured bedrock* intervals encounteredat Monitoring Well MW-23. These conditions confirm the appropriatenessof the decision to discontinue drilling at this location due to the proximity tothe SWTP Bridgeview East Community Supply WdL The decision todiscontinue drilling at Monitoring Well MW-23 was readied throughtelephone conversations with Jay Nuebaker and Lisa Nichols, both of theUSEPA, on May 31,1991.

3.6 GROUND WATER SAMPLINGPage 3-32:

CommentFor future sampling episodes, EPA suggests obtaining a groundwater sampleprior to purging the monitoring well, as well as after purging for comparisonpurposes.]

ResponseThe Novak PRP RI/FS Group disagrees with this suggestion. The purposeof sampling and analyzing ground water from monitoring wells at CERCLAsites is to determine the chemical characteristics of the ground water in theunderlying aquifers. It is not the purpose of a CERCLA ground-watermonitoring program to determine the chemical characteristics of stagnantwell water, nor is it the purpose of a CERCLA ground-water monitoringprogram to devdop a comparison between aquifer ground-water quality andstagnant well water quality. The latter is an academic exercise which is welldocumented.

Since stagnant water in wells may not be representative of in-sitn ground-water quality, the standing water should be purged or evacuated from the wellprior to ground-water sampling. Wdl evacuation is a standard procedure

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3-9

recommended by several USEPA publications including USEPA GroundWater Handbook (Ground Water Handbook, Volume II: Methodology,USEPA, July 1991) and RCRA Guidance (RCRA Ground-Water MonitoringTechnical Enforcement Guidance Document, USEPA, September, 1986).

3.7 LEACHATE/DRAINAGEWAYS SAMPLINGPage 3-33:

CommentA description of the sediment samples needs to provided. The descriptionshould include sample depth, composition (ie: sandy, silty, amount of organicmaterial, etc.) Where HNU readings taken at the time of sample collection,if so provide these readings

Response,The depths and geologic descriptions of the sediment samples collected weredocumented by the field geologist The table provided in Attachment Dsummarizes this information for each sample.

3.3 JORDAN CREEK INVESTIGATION AND SAMPLING3.8.1 Creek Reconnaissance

Page 3-35; 1st paragraph:Comment

a. Wear's Covered Bridge is not shown on Figure 3-2.,Response.

At the scale selected for Figure 3-2, Wehr's Covered Bridge is beyond thelimits of the sheet size.

Commentb. Statements are made in Section 3.8.4, "Stream Sediment Sampling" that

pertain to two "decision trees" which address the sampling of surface waterand sediments. It has been concluded that surface water in Jordan Creekneed not be sampled because there was no apparent or obvious discharge of

AR203060GERAGHTY & MILLER. INC.

v 3-10surface water or groundwater to Jordan Creek during the February 1990stream reconnaissance. However, it was decided that the sediments shouldbe sampled because a "number of interrelated RI observations and datasuggested the probability of past incidences of surface water runoff in asoutherly direction from the landfill.* This statement, coupled with theconclusion that the storm water retention ponds are insufficient to control siterunoff during storm conditions (Section 4.6.2: Site Drainage Features)suggests that the release of site contaminants may occur during heavy rain.In addition, it is also possible that contaminants found in the sediments ofJordan Creek are available to migrate from the sediments to surface water.It is therefore suggested that surface water samples should be collected at up-,mid-, and downstream locations on Jordan Creek during flooding conditionsas discussed in Section 4.6.2.,

ResponseThe basis for sampling Jordan Creek sediments and surface water was deariypresented in the approved Work Plan (Geraghty & Miller, Inc~, June 1989),and the approved Field Operations Plan (Geraghty & Miller, Inc, February1990) for the NSL. The dedsion-maJdng process for sampling Jordan Creeksediments and surface water was illustrated in both documents with decisiontrees. The dedsion trees outlined a series of evaluations which would bebased on the RI data prior to making a determination of whether surfacewater and/or sediment sampling was or was not necessary. This decisionreceived further concurrence from the USEPA in finalization of AddendumNo. 1 to the Work Plan and Field Operation Plan.

Evaluation and implementation of the dedsion trees were based upon the1990 reconnaissance of the creek. This investigation observed no evidence ofexisting surface-water or ground-water releases to Jordan Creek, but did yidddata which suggested the possibility of past inddences of surface-water run-off in a southerly direction from the landfill which may have contained some

GERAGHTY 8 MILLER. INC " "

3-11site-related constituents. Implementing the decision tree process with thesefindings resulted in the sampling of Jordan Creek sediments but not JordanCreek .surface water. This interpretation of the dedsion trees and creekreconnaissance data was presented in the Addendum to the Work Plan/FieldOperations Plan (Geraghty & Miller, Inc-, November, 1990) which wasapproved by the USEPA in January 1991.

Despite accepting the evaluations of the design trees, the USEPA collectedsamples of Jordan Creek surface-water on March 21,1991. The samples werecollected by representatives of Dynamac. The analytical results of thesampling activities have not been provided to the Group. However, basedupon conversations held during the February 13, 1992 meeting with theUSEPA, U is the Group's understanding that the holding times for VOCanalysis of the samples was exceeded and the subsequent analytical resultswere determined to be invalid. The reason for exceedance of the holdingtimes is not clearly known to the Group on the basis for determining the datato be unuseable.

Based upon a memorandum to Cesar Lee from Dynamac (Justification forAdditional Sampling of Jordan Creek, dated February 26,1992), it appearsthat concerns regarding the potential effects of the NSL on Jordan Creek arethe results of detected concentrations of lead and bis (2-ethyIhexyl) phthalatein Jordan Creek sediment samples, and the locations at which the sedimentsamples were collected.

All of the lead concentrations detected in the Jordan Creek sediment samples,with the exception of the highest detected concentration, fall within onestandard deviation, or the 68 percent confidence interval, for lead content ofsurficial materials in the Eastern United States (Hansford T. Shacklette andJosephine G. Boerngen, Element Concentrations in Soil and Other Surficial

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3-12•f i

Materials of the Conterminous United States, U.S. Geological SurveyProfessional Paper 1270, 1984). This confidence interval ranges from 12ppm to 273 ppm. The highest detected concentrations of lead (31.1 ppm)falls just outside of this confidence interval, but falls well within the 95percent confidence interval which ranges from 3.7 ppm to 53J ppm. Basedupon a more location specific evaluation of the regional lead content ofsurficial soils, the same reference indicates that lead data specific to easternPennsylvania typically exhibited lead concentrations greater than 30 ppm.Therefore, the concentrations of lead detected in Jordan Creek sedimentsamples are clearly within concentrations expected in naturally occurringmaterials and it is unlikely that they are the results of influences from theNSL. In addition, all of the concentrations of lead detected in on-sitesediment samples were below the 31.1 ppm detected in the Jordan Creeksediment sample; therefore disputing any correlations between the detectionof lead in Jordan Creek sediment and the NSL.

The detection of bis (2-ethjihexyi) phthalate in the Jordan Creek sedimentsamples is not unnsnaL Bis (2-ethylhexyl) phthalate is a common laboratorycontaminant which is typically detected in samples during laboratoryanalysis. The detection of bis (2-ethyihexyI) phthalate at 2,200 ppm in onesample when the remainder of the samples are qualified as either having theanaivte concentration detected at less than ten times the concentration foundin laboratory blanks or being estimated is not indicative that the NSL hasaffected Jordan Creek.

Sediment sample locations were coordinated in the field with representativesof Dynamac. The sediment samples were subsequently collected at locationsin the creek where sediments were being deposited. These locations did notnecessarily coindde with the inside of curves in the stream but moreimportantly at changes in the gradient of the stream bed where sediment was

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3-13accumulating. Field notes documenting the locations where sedimentssamples were collected are provided in Attachment E. As discussed with theUSEPA during the February 13,1992 meeting, the bottom of Jordan Creekis not laden with sediment but rather covered with cobbles and rocks. Thecondition of Jordan Creek presented to the USEPA on February 13,1992 issupported by the February 20,1992 memorandum to Cesar Lee from RobertS. Davis. During the February 19, 1992 walkover of the NSL, which waspreviously discussed, Mr. Davis and Mr. Travers also had an opportunity toevaluate the condition of Jordan Creek and concluded that the samplelocations were appropriately selected.

Commentc. There is no mention of any field delineation of wetlands on the site, only of

wetlands delineation from federal National Wetlands Inventory maps (Section3.2.2.1 Field delineations should be performed in accordance with thePennsylvania Code, Title 25, (Environmental Resources) to locate anypossible wetland systems on the landfill. A project ecologist would be helpfulin this delineation process.,

ResponseAs previously stated, the wetlands delineation presented hi the RI Report wasprepared in full accordance with the approved RI Work Plans. However, inan effort to address the requirements of this response, Geraghty & Millerconducted a preliminary wetlands evaluation based on the recommendationof Mr. Robert Davis (USEPA). The preliminary wetlands evaluation includedthe identification of wetland areas based on current depth to ground waterand vegetative growth guidelines as described in the 1989 United StatesDepartment of Agriculture Federal Manual for Delineating Wetlands. Thisapproach is consistent with discussions held during the February 13,1992meeting with USEPA, the previously discussed memorandum to Cesar Leefrom Robert S. Davis (dated February 20,1992) and correspondence to Cesar

GERAGHTY & MILLER. INC

•yfts£- t IA-.'•*'• M •'- ,- 3-14

Lee from Mark Travers (dated March 6, 1992) regarding the preliminarywetlands evaluation.

3.8.4 Stream Sediment SamplingComment

The sediment samples taken should be described (ie: water saturation,sediment size, etc.)j

ResponseThe geologic logs for the six Jordan Creek sediment samples are provided inAttachment E. Adjacent materials were collected at each sampling stationuntil a sufficient sample volume for analysis was collected. These weresaturated sediments in the depth interval from 0 to 2.0 feet at the streamchannd bottom. Also provided in Attachment E are sketches identifying thelocation in the creek from where the sediment samples were collected. Thesediment samples were collected in accordance with the approved Work Planand Field Operations Plan.

GERAGHTY & MILLER. INC 208065

4.0 PHYSICAL CHARACTERISTICS

4.1: SITE SETTING4.1.2: Features of InterestComment

Although several State and Federal agencies have assured NSL that there areno federally listed or proposed threatened or endangered species known toexist within the site boundaries (Section 4.12), it may be that other non-endangered terrestrial wildlife and plant life found on or near the site areadversely affected by the site. The environmental health of these differentflora and fauna need to be compared to others in an established reference sitein order to properly characterize the potential impacts of contaminants on thesite ecosystem.,

ResponseThis comment implies that an ecological assessment is required for the NSL.This matter was addressed in Section 3.0 Field Investigations.

43 SITE CHARACTERISTICS43.1 Waste CharacteristicsComment

a, A list of the 225 landfill users, as well as the typical waste they disposed in thelandfill, should be attached as an Appendix

ResponseAs explained during the February 13, 1992 meeting with the USEPA, insubsequent conversations with the USEPA, and hi the February 28, 1992correspondence to the USEPA from Mark Travers (a copy of which isattached as Attachment K), the additional work requested by the USEPA hithis comment was not required by the approved Work Plan, is inconsistentwith the USEPA's guidance and is not supported by available informationregarding the NSL. In addition, the information requested in this commentis currently on file with the USEPA and at the South Whitehall Townshiprepository.

GERAGHTY c? MILLER. INC. "n 2 0 8 0 6 6

4-2After the USEPA received the February 28, 1992 correspondence, Julie A.Parker, Esq., Hannoch Weisman, was informed by Kenneth Markowitz, Esq.,USEPA, during a March 4,1992 telephone conversation, that the approachoutlined in the correspondence was acceptable to the USEPA and that theGroup would receive a letter from the USEPA confirming that acceptability.However, on March 9,1992, Lawrence Diamond, Esq., Hannoch Weisman,received a letter from the USEPA requesting extensive information regardingeach entity that may have utilized the NSL site, wastes generated by eachsuch entity and wastes that may have been disposed of at the NSL. A copyof that letter, and an example of the format requested by the USEPA, isattached as Appendix L. As a result of this inconsistency, Steve Miano, Esq.sought clarification from the USEPA. Finally, on March 26, 1992, Mr.Markowitz informed Mr. Miano that the approach outlined in the February28,1992 letter is acceptable to the USEPA. The Group's understanding isthat this matter is therefore resolved.Thus, although the Group believes the additional work is neither necessarynor required by the approved Work Plan, it has nevertfadess prepared anexpanded waste characteristics section in an effort to address the intent ofthis comment

Information concerning the general characteristics of the wastes disposed atthe NSL were obtained from the following sources: responses to §104(e)requests issued by the USEPA; interviews with Louis C Novak, Jr. and otherpersons with knowledge of landfill operations; landfill inspection recordsgenerated by the PADER; and, PADER correspondence. The informationreviewed indicates that the landfill contents are typical of materials acceptedby permitted municipal landfills during the period of tune that the NSLoperated. Many of these same materials are accepted at currently permittedmunicipal landfills.


4-3

In general, the available information indicates that the NSL received dryrefuse, construction debris and demolition materials from municipal,residential, commercial, and industrial sources. Landfill Guidance describesthe waste types typically disposed of hi municipal landfills. It states that'municipal wastes disposed of in these landfills typically includes aheterogeneous mixture of materials primarily composed of household refusesuch as yard and food wastes and paper, and commercial waste such asplastics, inert mineral waste, glass, and metals." It then notes that thelandfills contain principally municipal waste, and to a lesser extent,hazardous waste, such as that resulting from small-quantity generators,household hazardous wastes, biodegradation of wastes and pre-RCRAoperations. Information reviewed indicates that the NSL accepted thefollowing general categories of waste materials:

Residential Trash Incinerator Ash (SteelLawn Clippings Manufacturer andWaste Paper and Cardboard Municipal Sources)Empty Paint Containers and Paint ResinsPaint Residuals Paint Sludges

Metallic Materials and Metal Turnings and PlateScrap Steel Electronic Components

Construction and Demolition Waste Auto Parts/ProductsDebris (Le~, concrete, wood, Plastic Scrapasphaltic materials, metal, Waste Rubberetc.) Welding Materials

Waste Pickle Liquor CaulkPlant and Office Rubbish/Trash Empty Ink ContainersB&D Wastewater Treatment System Hospital/Medical WasteWaste

Agricultural Wastes (e.g wastefertilizer containers)

The information reviewed does not routinely provide the quantity of materialtransported to the NSL. Where information relating to quantity of material

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Is provided, the data is not considered consistently accurate. However, aPADER memorandum from 1978 states that 80 percent of the materials beingaccepted by the NSL were paper and wood products, and residential trash.

Records indicate that the landfill was authorized to accept waste sludges fromselect commercial and industrial sources. These materials were only acceptedupon approval by PADER. The approval by PADER was required as asafeguard against the NSL accepting what PADER considered hazardouswaste. The only sludge specifically identified in the record review is a paintsludge. A material not dearly identified as a sludge but likely of similarconsistency to sludge and approved for disposal at the NSL is a neutralizedlabel pulp. (Note: If additional Information relating to sludges is identified,it will be added at the time of the final revision.)

The information reviewed contains no specific reference to the disposal ofdrums. However, PADER inspection reports contain references, on threeoccasions, to storage, not disposal, of drums/barrels. It is not dear whetherthe drums/barrels contained liquid. The first reference to the storage ofdrums/barrels at the NSL is in a September 28, 1978 inspection reportprepared by PADER, The report orders the operator to remove alldrams/barrels immediatdy. Inspection reports for October 20, 1978, andNovember 20, 1978 again refer to the drums/barrels and orders theowner/operator to remove the drums/barrels immediately. Thedrums/barrels were apparently removed after the third request by PADERsince there is no reference to the drums/barrels in subsequent inspectionreports. Since waste disposed of at the NSL was compacted throughout thesite's operation, any drums which may have been disposed of in the landfillwould have been crushed and compacted along with the other wastes.However, based on interviews with Louis C Novak, Jr. and others familiar

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with the landfill operations, NSL did not accept drums and if a drum wasidentified in a load of material, it was removed.

In conclusion, the records review and results of leachate sampling andanalysis demonstrate that the NSL should be dassified as a Type I landfillsite as defined in the Landfill Guidance, excepting specific reference tosignificant co-disposal of hazardous waste. There are no known hot spotareas, and historical records and physical evidence, gathered during the RI,do not document any discrete subsurface disposal areas. As such, theinformation from the listed sources adequately characterizes wastes disposedof in the landfill for the purposes of selecting a remedy through the RI/FSprocess.

Since the information provided comports with that described hi the February28, 1992 letter, our understanding is that this expanded description andadditional information adequatdy responds to the USEPA's comment on thisissue.

Commentb. This section states that "the landfill was authorized to accept waste sludges

from commercial and industrial sources on a case-by-case basis," the exactnature and quality of these waste sludges needs to be provided. u

ResponsePursuant to discussions held during the February 13,1992 meeting with theUSEPA, available information regarding the type(s) of sludge disposed of atthe NSL will be summarized and included in the expanded description ofwaste characterizations discussed in the previous response. The informationreviewed for preparation of the expanded waste characterization indnded:responses to $104(e) requests issued by the USEPA; interviews with Louis C.Novak, Jr. and other persons with knowledge of the landfill operations;


4-6.'-. *;-•' Cu'-'

landfill inspection records generated by the PADER; and PADERcorrespondence.

Commentc. Due to the fact that the trench area appears to be the primary source of

contamination and because, TADER inspection reports contain occasionalreferences to disposal of 55 gallon barrels although it is not dear if theycontain liquids", a geophysical survey, and if possible test pitting of thetrenches, should be conducted

ResponseGeophysical surveys depend on the seismic and/or electrical resistivity ofsubsurface conditions to create measurable responses to artifidal impulsesor currents. The measurement of these responses in turn indicate thepresence of variations in subsurface conditions, such as the top of bedrock,buried drums or other large metal objects. However, the heterogeneousnature of waste at sanitary landfills generally renders this investigativetechnique useless. If discernible responses can even be detected from thegeophysical equipment, which is unlikely, the likelihood of responsesindicating the presence of metallic objects other than drums (Le. stoves,refrigerators, sinks, bath tubs, box springs, car bodies, etc.) is very high.

Test pitting is an intrusive technique for investing the presence of largeobjects such as SS gallon barrels. However, there is little to no indication inNSL records or inspection reports that barrels may be buried at the NSLand, if so, at what locations. With over one million cubic yards of availablefill volume at the NSL and over 262,000 cubic yards of available Gil volumein the Trench Fill Area alone; such an investigation could be considered 'aneedle in the haystack* investigation without detailed evidence as to wherebarrels may be located. The only report of drums/barrels relates to thePADER inspection reports which noted that the NSL should not be 'storing"drums and they should therefore by removed. Furthermore, had barrels been

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disposed of at the NSL, they would have been compacted with the other wastematerials disposed of at the site and most likely destroyed, rendering thechances of their recovery remote.

The waste characterization provided in the RI and subsequently expanded inthe correspondence to the USEPA (M. Travers; February 28, 1992) wasprepared in accordance with USEPA guidance for "Conducting RemedialInvestigation/Feasibility Studies at CERCLA Municipal Landfill Site*. ThisUSEPA guidance indicated that "landfill content investigations areundertaken to characterize known or suspected hazardous waste disposalareas (potential hot spots)," and that such investigations "are rarelyimplemented at municipal landfills'. Therefore, since hot spot areas were notidentified and are not suspected at the NSL, investigations into the landfillcontents for the purpose of waste characterization are not justified.Additionally, any intrusive investigations (test pits) into the trench areawould require substantial precautions to prevent exposure of workers andnearby residents to materials removed from the landfill and potentiallyreleased to the air. At least one residence is located within 200 feet of theTrench Fill Area. Additionally, the precautions necessary to protect workerswould need to consider the existence of hospital/medical waste in the TrenchFill Area. These types of materials can not be monitored through real timemonitoring equipment, therefore, requiring elevated levels of protection.

For the foregoing reasons, neither a geophysical investigation nor test pits areappropriate for the NSL. Furthermore, if such work was intended to be apart of the RI for this site, it certainly would have been described in theWork Plan. It was not a part of the approved Work Plan, and therefore theUSEPA's comment constitutes a request for additional work which the Groupis not required to undertake pursuant to either the Work Plan or the AOC

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for this site. As such, the Group does not intend to complete the additionalwork requested by the USEPA in this comment

4.3.2 Landfill Disposal AreasComment

The actual slopes, and the cover thickness of the various disposal areas needto be incorporated into the description of each disposal area. If the slopesare not known they should be field surveyed.}

ResponseWhile the slopes of the disposal areas can readily be taken off topographicmaps of the NSL, determination of the cover thicknesses would require Cddinvestigations. This information is more appropriately obtained during theRD/RA phase, if any, of the program.

432.1 Old Mine AreaComment

Information on the depth and size of the old mine should be obtained fromthe Pennsylvania Department of Mines.2

ResponseThe following Pennsylvania offices were contacted regarding informationpertaining to the former surface mine at the NSL:

Research Department, Bureau of Mines;State Geological Survey;Mine and Reclamation Office; and,Department of Metal and Non-Metal Mines.


4-9

None of these offices have records pertaining to the former Novak mine. Infact, according to discussions with representatives of these offices, no staterecords were maintained for surface mines which closed prior to 1972.

These sources recommended using aerial photographs and contacting theowner/operator of the facility for information on the depth of the mine.These approaches were followed in the RI and the results incorporatedthroughout the RI Report

4.3.2.3 Surface Fill AreaPage 4-18; 1st Paragraph:

CommentThe "sixteen million feet of trash...", should be in cubic feet2

ResponseThis change will be incorporated into the revised RI Report

CommentThe storm water ponds should be discussed in detail in this section (ie: depth,size, overflows, year of installation, etc.).2

ResponseThe storm-water retention basins are discussed in detail in this section (4.&2Site Drainage Features) and in Appendix F - Storm-Water Retention PondsCapacity Calculations.

4.4 GEOLOGYPage 4-23; First paragraph:

CommentThe Blue Mountain, not the Kittaniny Mountain, is to northwest of the site.3

ResponseThe discussion on Page 4-23 introduces the Geology section of the RI with aregional description. The paragraph in question refers to the boundaries of

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4-10

the Lehigh Valley which is situated between the Reading Prong to thesoutheast and Kittaniny Mountain to the northwest

4.43 Local Stratigraphy and Lithology4.432 Bedrock Lithology

Page 4-29; First paragraph:Comment

a. What does the abbreviation RDQ mean? ,Response

As stated on Page 4-29, RQD (not RDQ) means Rock Quality Designation.The use of the RQD was requested by USEPA Region III in the planningphase of the project

The RQD was developed to provide "a simple and direct means of indicatingrock-mass properties* and is based on modified core recoveries as defined onRI pages 4-28 and 4-29. Literature explaining the use of the modified corerecoveries as an index of rock quality and the corresponding RQDs isprovided in Attachment F.

Page 4-30, First paragraph:Comment

b. It is stated that landfill gas was detected emanating from the drilled hole ofMW-7 from the 95 to 100 ft interval. How was this detected~with andHNU...a methane probe, etc.? This was not noted on the bedrock log inAppendix. N. It needs to be established exactly what is contained in thelandfill gas.2

ResponseThe landfill gas in the Monitoring Well MW-7 borehole was detected first bya noticeable "sweet and pungent odor* emanating from the borehole duringdrilling through the 95 to 100-ft intervaL Hie borehole was monitored at the

GERAGHTY & MILLER. INC A R 2 0 8 0 7 S

4-11

surface during active and passive periods while drilling through this intervaland negative (zero) readings were obtained with both the GasTechExplosimeter (percent of the Lower Explosive Limit [LEL] readings) andHNU. A reading of over 54 percent of the LEL was obtained after the first20-foot length of 6-inch sted casing was lowered into the borehole. This isnot noted on the bedrock log in Appendix N as these logs currently presentthe geological descriptions of the boreholes; however, this information will beadded to the log for submittal of the revised RI Report

Additional air monitoring and landfill gas characterization was not pursuedat the NSL for two reasons. First, VOCs were not detected during theAmbient Air Monitoring Program at concentrations warranting specialconsiderations in the site Health and Safety Plan or warranting additionalinvestigations. This is supported by the fact that the concentrations of VOCswhich were detected during the Ambient Ah* Monitoring Program did notexceed Multimedia Environmental Goals, ambient concentration levels,American Conference of Governmental Industrial Hygienist workplacestandards, and PADER ambient Air Toxic Guidelines. Second, theconfiguration of landfill gas vents at the site, as well as the cover systemsover the waste, will change significantly with any forthcoming remedialactions. For this reason, the characteristics of ambient air quality followingimplementation of remedial actions will change from current conditions.Therefore, since the current air quality conditions were not a health andsafety concern and were not characterized by high concentrations of VOCs,further characterization of a condition which will most likely change withimplementations of remedial actions was not justified. As discussed duringthe February 13,1992 meeting with the USEPA and confirmed in a February14,1992 correspondence from Mark Travers (de maximis, inc.) to Cesar Lee(USEPA), any additional ah- quality evaluations would be addressed duringthe Remedial Design stage of the project


4-12

Page 4-30, Second paragraph:Comment

c. It is stated here that "Ground water was observed to enter both the MW-10and MW-11 boreholes at variable intervals below 145 bgs." This statementdoes not correspond to the information in Table 4.1. There is also noinformation concerning the depth of water infiltration in the logs inAppendix N^

ResponseThis statement is correct based on the observations of the Oddhydrogeologist The *NM" notes in the last columns of Table 4.1 simplyindicate that the rate of water entering the borehole was not measured anddo not indicate that the water was not present In some instances it was notpossible to measure the rate of groundwater infiltration into the borehole;this was the case when water was added to the borehole to facilitate cuttingsremoval and dust control or if the rate of water entering the borehole wasvery low.

Page 4-30, Third paragraph:Comment

d. There is no backup information contained in Table 4.1 or Appendix N tosupport the statement concerning the ground water infiltration into theborehole of MW-12

ResponseThe information shown in Table 4.1 is consistent with the text statement that"During drilling shallow off-site Monitoring Well MW-12, groundwaterentered the borehole within a fractured interval from 118 to 125 feet bgs ata rate of approximately 10 to 15 gpm.* (see last line of page 1 of the table).

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Page 4-31; fourth paragraph:Comment

e. A fracture interval from 90 to 110 feet was noted for MW-20, however,PADER notes indicate that the well is only 90 feet deep.,

ResponseMonitoring Well MW-20 was drilled to a depth of 115 feet below land surface.The PADER notes are incorrect

4.5 HYDROGEOLOGY4.5.1 Regional Hydrogeologic Conditions43.12 Regional Flow Evaluation

Page 4-43; Third paragraph:Comment

The potential for the Novak Sanitary Landfill to have a negative effect on theSouth Whitehall Township (SWTP) Cornerstone Well lacks a quantitativebasis for evaluation. The statements on page 4-42 and 4-43 purporting toaddress this issue are qualitative and speculative. The passage, "...in theabsence of an aquifer pumping test and resultant capture zone analysis, adefinitive and quantitative assessment of potential effects is not possible...." isthe only definitive statement given the lack of data.,

ResponseAs stated previously in response to General Comment b, the most effectiveapproach to evaluating the potential influences of the Cornerstone Well onthe NSL is a ground-water level monitoring program while the CornerstoneWell is in operation. Given the location of existing monitoring wells withrespect to the NSL and the Cornerstone Well, and the period of time beforethe Cornerstone Well will be in full production, a ground-water levelmonitoring program, incorporating existing wells, will detect any potentialwater-level drawdown influences by the Cornerstone Well in the early stages


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of production. This approach seems most effective given the distribution andlow magnitude of constituents in the ground water at the NSL.

»

4.S2 Site Hvdrogeologic Conditions4.5.2.1 Unconsolidated Materials

Page 4-45; Third paragraph:Comment

It is stated here that the intermittent presence of water in MW-15 is likely tobe from inflow from a ponded water area upgradient of the well. Thisstatement is not entirely substantiated since the elevations of the prominentleachate seeps are below the water level in this well. There is also nomention of the groundwater mounding influence on this well.2

ResponseMonitoring Well MW-15, as well as the ponded water upgradient of the well(referred to as impoundment *C* on Figure 3-6) are both located in areas ofunconsoIidated materials, not in waste disposal areas. Based on theirrespective positions in the unconsoIidated materials, it is likely that water inthe pond influence water levels in the wdl. There is no relationship suggestedin the RI Report regarding water levels in Monitoring Well MW-15 and theelevation of leacbate seeps. Since the leachate seeps occur in theheterogeneous waste disposal areas, it would be difficult to predictrelationships between water levels in the unconsoIidated materials and theheterogenous waste.

A discussion of the ground-water mounding influence on Monitoring WellMW-15 is not provided in the RI Report because Monitoring Well MW-15was completed to an elevation of 383 feet NGVD and the ground-waterinfluences in the area of this well only reach approximately 310 feet NGVD,which is 73 feet below the bottom of Monitoring Well MW-15.


4-15

4.5.23 Bedrock Aquifer SystemPage 4-52; Third paragraph:

CommentIf MW-7 is affected by mounding, then it is recommended that the contour forthe deep water table be changed to include the mounding, especially since thevertical component created by the mounding beneath the trench fill arearesulted in the limited downward movement of VOCs.3

ResponseFigure 4-7 is provided to illustrate the ground-water contours of the aquiferbeneath the NSL. Since the effects of mounding on the aquifer were onlydetected at Monitoring Well MW-7, plotting of the ground-water contourswith the effects of mounding on the aquifer would result in a limitedrepresentation of the actual mound and would not be truly indicative of theaquifer ground-water contours.

Text Section 4.5.23 presents a discussion of the deeper ground-water flowcharacteristics that included the ground-water flow direction, overallhydraulic gradient, and the effect of ground-water mounding on MonitoringWell MW-7. The contour map is intended to partially illustrate and bereferenced in conjunction with the text discussion. The downward transportof VOCs resulting from the vertical flow component created by the moundingis discussed in Text Section 5.5.2.1.

432.4 Aquifer Hydraulic CharacteristicsPage 4-53; 2nd paragraph:

Commenta. AQTESOLV is a software computer program which may or may not be

available to reviewers or other interested parties. In the latter case, thisprohibits replication of the analysis. In addition, the input values necessaryto obtain a solution on the basis of other methods are not provided in the RI


4-16

report nor the calculations. As such, the transmissivity values output by thissoftware and reported in the RI report are not subject to verification. Thispresents a problem with respect to the documentary aspects of the RI reportThere needs to be a mechanism, in the context of the RI report, that enablesEPA reviewers and others to replicate the quantitative hydrogeologic findingsof the report Without the software, the calculations, or the input dataincluded in the RI report, a technical reviewer can do nothing substantive inthis area. Dynamac recommends that the consultant make whateveralternations and additions to the RI report that are necessary to enableverification of the quantitative hydrogeologic findings.,

ResponseAQTESOLV has not been provided with the RI report because the softwareis copyrighted information. Should the USEPA or its oversight contractordesire to obtain a copy of AQTESOLV, it is available through Geraghty &Miller, Inc., 10700 Packridge BIvxL, Suite 600, Reston, Virginia 22091.

Furthermore, the Monitoring Well Pumping Test Plots provided in AppendixS are semi-log plots of water-Ievd drawdown versus the time of pumping. Assuch, the water-level drawdown versus time (s) values can be derived from theplots and the transmissivity values can be readily reproduced using standardanalytical methods. The AQTESOLV software (which utilizes the presentedand referenced Cooper Jacob (1946) Modified Non-Equilibrium Method tosolve for transmissivity) was used as a subsidiary tool; the calculations wereconfirmed by hand. The information in the RI Report enables verification ofthe quantitative hydrogeologic findings as it stands. However, in order tofacilitate reproduction of the calculations the raw data from which the water-level drawdown versus time plots were made will be provided in the revisedRI Report.

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Page 4-53; 2nd paragraph:Comment

b. In order to fully document and evaluate the calculations relating to theequation, tc = 0.6 (dc2 - dp2) / Q/s, the reference (Schafer, D.C., 1978)should be included verbatim in the RI report, or a detailed presentation ofthe methodology should be included in the RI report Perhaps, an examplecalculation could be included in the appendices. In addition, the input valuesassociated with each well should be provided in the RI report.,

ResponseThe following synopsis of the casing storage concept is provided inGroundwater And Wells, Fletcher G. Driscoll, Second Edition:

"Schafer (1978) suggests that in many instances early pumping test data maynot fit Jacob's modification of the nonequilibrinm theory, and thatcalculations based on the early AS values will be erroneous. These early datareflect the removal of water stored in the casing. When pumping, water inthe casing is removed first. As the water level in the casing fails, waterbegins to enter the well from the surrounding formation. Gradually, a greaterpercentage of the well's yield will be from the aquifer. The AS value will behigher during the time required to exhaust the casing storage, giving anerroneous transmissivity value in the early stages of the pumping tests.

Schafer suggests that the critical time can be calculated by the equation __[Equation shown on Page 4-53 of the RI Report].

Determination of the true transmissivity value depends on being able toidentify whether a casing storage effect has occurred or a recharge boundaryhas been encountered early in the pumping test"


4-18

The above equation contains two unknowns: 1. the time when the casingstorage effect becomes negligible (tc), and 2. the drawdown at time tc (s).Initially, any drawdown value can be chosen, a specific capacity (Q/s)calculated, and a trial tc value can then be calculated. Using the trial valueof tc and time-drawdown graph, a specific capadty value (Q/s) Is obtainedwhich is entered into the equation to calculate a second trial tc value. Thisprocedure is reiterated two or three times until the calculated value for tcconverges.

Example Calculation No. 1: Monitoring Well MW-12At 90 minutes, Q/s e 322 gpm/ft

Iterations

L tc «= 0.6 (dc* - oy = 21.45Q/s 322

tc e 6.66 minutes2. At 6.66 minutes, Q/s = 2.44 gpm/ft

tc s 8.79 minutes3. At 8.79 minutes, Q/s = 232 gpm/ft

tc e 924 minutes4. At 924 minutes, Q/s s 232 gpm/ft

tc B 924 minutes

Note that there is no change in the tc value between the last two iterations.Thus, the four iterations suggest that the casing storage effect becomesnegligible at approximatdy 9 minutes. Any calculation of transmissivityshould be based on the later part of the time-drawdown curve after 9minutes.

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Example Calculation No. 2: Monitoring Well MW-9

At 10 minutes, Q/s = 0.17tc = 0.6 (

Q/stc = 125 minutes

Since the total time of pumping at MW-9 was only 18 minutes, the firstiteration indicates that the time at which storage casing effect becomesnegligible far exceeds the total tune of pumping.

Page 4-54; 3rd paragraph:("fonTnent

c. The modified non-equilibrium equations should be referenced and is not Inaddition, the data used in solution of this equation should also be documentedin tabular form; thereby documenting the analysis and enabling a reviewer toreplicate the analysis.,

ResponseThe Modified Non-Equilibrium Equation is referenced on Page 4-53, secondparagraph. The input data that were used in solution of this equation are asfollows:

Well Discharge Rate (Q) Slope of Drawdown versus Tune(gpm) over one log-cycle of time (AS)

MW-10 3.0 2.0MW-11 3.0 026MW-12 4.0 0.42MW-23 15.7 3.8

GERAGHTY & MILLER. INC. AR208081*

*<••

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Page 4-55J 2nd paragraph:Copimcnt

d. In order to fully document and evaluate the calculations relating to theequation, Q/s = T / (264 log fTt/2,693 r2 S] - 653 ),the reference (Walton, 1962) should be induded verbatim in the RI report,or a detailed presentation of the methodology should be induded in the RIreport In addition, the recursive numerical methodology necessary to solvethe equation, plus the initial guess, should be included in the RI report fordocumentary purposes.,

Response ,The following synopsis of the Walton (1962) equation is provided in Walton(1985) Practical Aspects of Ground Water Modeling:

In many cases in reconnaissance ground water investigations, thehydrogeologic properties of an aquifer must be estimated on well-log, waterlevd, and specific capacity data. High specific capacities usually indicate ahigh coefficient of transmissivity, and low specific capacities generallyindicate low coefficients of transmissivity.

Because of the usefulness of rough estimates of T, an examination of therelation between the coefficient of transmissivity and specific capadty isusefuL ••.,'.';.:..

- • • r ,. iJ*-1 *' "' " • '•

The theoretical specific capadty of a well discharging at a constant rate ina homogenous, isotropic, nonleaky artesian aquifer, infinite in area! extent isgiven by the following equation (Walton, 1962)_[See page 4-55 of the RIReport]. ?

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4-21

Using the normalized specific capacity data (excluding MW-14), theremaining Input values listed on page 4-55 of the RI Report for S, r_ and t,and an initial estimate of 1000 gpd/ft for transmissivity:

0.50 a T / (264 log [1000 gpd/ft(30 mln)/2693 (OJ5)2 (0.010)] - 6530.50 = T / 1122 - 65.5T s 528 gpd/ft

"It may appear to be presumptuous to assume a transmissivity value beforeone b known. However, because it appears hi the log term of the equation,its effect on the value of the divisor is minimal" (Driscoll, 1986).

4323 Ground-water Flow EstimatesPage 4-57; last paragraph, last sentence:

CommentWhat is the source for the effective porosity vahie used in the calculation of \the linear ground water velocity in the vicinity of the mound? Could theconsultant provide a more precise estimation of the uncertainty of the linearground water velocity by using the upper and lower value estimates ofeffective porosity for the particular carbonate formation at the site or forsimilar carbonate formations in other areas? ,

ResponseThe principal literature source for the effective porosity value is "Flow'Through Porous Media, RJwVL De WIest, ed. Academic Press, New York, pp.53-58,65,70,80-81,86-89*. The range of porosity provided In this referencefor dolomite was from 0.4 percent to 63 percent If upper and lower valuesof ground water velocity are required, it is simply a matter of substituting thevalue for porosity hi the equation on page 4-57.


. • • . ' - . • ' : : - . ' • • .....,;, 4-22.?>*..*£ ' • - . • • , ' ' - - • • *».'-'f;v'?4.53 Summary

Page 4-58; Second paragraph:Comment

It states here that, "......ground-water movement is through an assemblage ofinterconnected fractures and joints...", while on page 447, the last paragraphstates groundwater movement is through diffuse flow rather than conduit flow.Please be consistent in your description of ground-water flow. 2

ResponseThe diffuse groundwater flow is through an assemblage of interconnectedfractures and joints. This is consistent for a diffuse flow system in contrastto a conduit flow system.

E t-

GERAGHTY c? MILLER. INC. AR208087

5.0 NATURE AND EXTENT OF CONTAMINATION

CommentThe Soil Survey and the Liquid Sampling of the Gas Vents should be "discussed in detail in this section and not in the Feasibility Study (FS) assuggested.,

ResponseThis matter was discussed in response to prior comments.

5.1 AMBIENT AIRComment

a. It is agreeable that the analytical results detected extremely lowconcentrations of potential contaminants; however, it is questionable as towhether or not the selected locations truly represent upwind or downwindconditions. As well, it is questionable as the whether two days in Februaryare representative of the likelihood of air contaminant migration the full yearround.,

Response v jCareful review of wind direction data and sampler location (Figures 1 and 2)shows that samplers were oriented properly during the Air QualityMonitoring Program and even relocated during Test 1 to assure downwindorientation.

As stated in response to the first comment in Section 33, the RI fieldactivities schedule necessitated conducting the Ambient Air MonitoringProgram in February, prior to commencement of other scheduled investigativeactivities. This was necessitated since the primary purpose of the AmbientAir Monitoring Program was to screen the NSL for air quality conditionsrequiring special consideration in the site Health and Safety Plan. No suchconditions were encountered.

GERAGHTY c? MILLER. INC. AHd08088

5-2Furthermore, as also stated in response to "the Section 33 comment, thedischarges of VOCs from the landfill gas vents at the site are subject togreater fluctuations due to diurnal atmospheric changes rather than seasonalatmospheric changes. The daily fluctuations in atmospheric pressure, whichoccur throughout the year, provide sufficient variations in pressure gradientsbetween the buried waste, where the landfill gas is produced, and ambientconditions to detect significant changes in landfill gas discharges on a dailybasis. On the other hand, the elevated temperatures of the waste remainrelatively constant over the course of the year. The relatively constanttemperatures within the waste result in the consistent production of landfillgas, leaving landfill gas discharge rates subject to the diurnal changespressure gradients.

Commentb. In the second paragraph, G&M states "Other compounds detected include fuel-

related constituents (...[BTEX]), which may be attributed to the diesel andgasoline powered vehicles which were operating or stored on-site and/or nearbyvehicular traffic...samples collected upwind of the landfilled areas also exhibitedthe presence of BTEX..." If the BTEX contamination is being attributed to on-site vehicular traffic, this may suggest that the upwind sample was likewisebeing influenced by on-site activities and therefore may not be trulyrepresentative of background conditions.,

ResponseVehicular traffic is present on-site as well as on roads leading to and aroundthe site. Since upwind sources of BTEX are just as likely to exist as on-sitesources, it is not unlikely for upwind monitoring stations to detect BTEX.

As discussed previously, one purpose for collecting the upwind and downwindambient air samples was to establish the net effect of the iandfilled areas onambient air quality and subsequently screen the site for concentrations of

GERAGHTY c? MILLER. INC UOU09

5-3VOCs. It was not the purpose of the Ambient Air Monitoring Program to .establish regional background air quality characteristics.

The detection of BTEX in the upwind and downwind samples supports theconclusion that the downwind concentrations of BTEX are not necessarily theresult of BTEX migrating from the landfilled areas, but are more likely theresult of vehicular traffic, particularly trucks, adjacent to the landfilled areas.Because any potential effects of the landfill on ambient air quality would haveto be exhibited in the downwind (not upwind) direction, the net effect of thelandfill on ambient air quality would be the downwind BTEX concentrationminus the upwind BTEX concentration. The ability to determine the on-siteand off-site contributions of VOCs to the ambient air quality at the landfillis therefore achieved.

Commentc. It is agreeable that the detected concentrations do not appear to pose a \

significant health hazard when compared to the Multimedia EnvironmentalGoals (MEGs). PADER ambient Air Toxic Guidelines, and ACGFH TLVs.Once again, what is questionable is whether the data collected are trulyrepresentative of the year round background and site conditions.,

Response,Refer to the response for Comment a, Section 5.1

Commentd. It is necessary to evaluate the landfill gas being emitted from the gas vents as

well as several of the monitoring wells.,Response

Since the Ambient Air Monitoring Program did not detect VOCconcentrations in excess of the air quality guidelines stated above, there is noneed to conduct further investigations of the ambient air quality at the NSL

GERAGHTY c? MILLER. INC flR208090

at this time. Being able to reach such a conclusion, either for or againstadditional investigations, was one of the purposes for the Ambient AirMonitoring Program. This approach was approved by the USEPA in thepreviously referenced Work Plan and Work Plan Addendum. Furthermore,an evaluation of the landfill gas being emitted from the gas vents as well asat least one monitoring wdl, was not part of the approved Work Plan orWork Plan Addendum.

Should potential remedial action at the NSL require additional airmonitoring, including gas vent and well monitoring, it will be conductedduring the RD/RA phase of the project as discussed during the February 13,1992 meeting with the USEPA and confirmed In a February 14, 1992correspondence from Mark Travers (de maximis, inc.) to Cesar Lee (USEPA).

S2 UNCONSOLIDATED MATERIALSPage 5-2; First paragraph:

CommentProvide the HNU reading obtained from NSL-SB-2. Provide a speculation asto why HNU readings were detected but no VOCs were detected duringsample analysis.2

ResponseThe momentary HNU reading noted was 50 parts per million. The HNU isa field screening instrument that is not a definitive indicator ofcontamination and has been found to be sensitive to atmospheric influences(eg, moisture). In this instance, the proper follow-up action was taken; thatis to submit a sample for quantitative laboratory analysis. The sampleanalysis, a more definitive indicator of contamination, did not detect VOCs,and the momentary HNU reading should therefore be disregarded.

GERAGHTY & MILLER. INC. AR20809I

5-553 LEACHATE AND DRA1NAGEWAYS53.1 Leachate SeepsComment

Description of the soil samples and leachate samples should be provided inthis section (ie: moisture, grain size, etc.).,

ResponseSee Response to Section 3.7. (The geologic descriptions of the soil andsediment samples are provided in Attachment B).

GERAGHTY 6? MILLER. INC da208092

6.0 BASELINE RISK ASSESSMENTSUMMARY STATEMENTS

i , a. The report leading up to and supporting this section is of good quality.ub. The risks calculated by Geraghty & Miller, Inc. for the Novak Sanitary

Landfill human health risk assessment are conservative estimates that areunlikely to be lower than the actual risks.,

c. The authors of the risk assessment have followed closely the EPA riskassessment guidance (USEPA, 1991; USEPA, 1989a; USEPA, 1989b) withrespect to calculation of exposure point concentrations and have considereda wide variety of potential exposure scenarios.,

d. The carcinogenic risks from exposure to CPAH have been evaluated byconsideration of all CPAH as equipotent to benzo(a)pyrene. Thisconservative assumption will overestimate actual carcinogenic risk due to theextremely high potency of benzo(a) pyrene relative to other CPAH,,

e. The total carcinogenic and non-carcinogenic site risks are conservativebecause they incorporate EPA's standard default exposure factors (USEPA,1991), utilize EPA's numerical toxicity criteria for all chemicals of concern,and consider all conceivable exposure pathways for adult and child receptors.This use of multiple conservative assumptions to develop the ffrpi riskestimates should be borne in mind when the risk assessment results are usedfor risk management decisions at the site.,

ResponseThe Baseline Risk Assessment was prepared using conservative assumptionsdesigned to provide an upper estimate of potential exposures and subsequentrisk to human health and the environment A conservative approach wasfollowed to ensure protection from exposure to constituents at the NSL site. •Actual risks for the site are unlikely to be higher than those presented in theBaseline Risk Assessment and may be much lower.

AR208093GERAGHTY & MILLER. INC

6-2

Commentf. The Risk Assessment and Table 6-1 give no indication of total on-site and off-

site carcinogenic risk or total hazard index for all contaminants of concernsResponse

The total on- and off-site carcinogenic risk and hazard Index were calculated.Revised Table 6-1 (page 6-3) provides the results of summing the risks andhazard indices for a particular receptor, as well as for the site as a whole.The calculation of a total* site risk is an exercise designed to estimate risksfor several different populations. Since these populations are not likely tooverlap, the total site risk does not provide meaningful information. Thesummed risk to various receptor populations is a more valid determinationof the potential threat from exposure to constituents at the NSL.

62 SUMMARY OF FINDINGS622 Surface SoilComment v j

The integrity of the background soil samples needs to be evaluated since theselevels apparently pose a greater risk than on-site soils. The exact locations ofthe background soil samples needs to be provided to determine if these werereally background levels

ResponseThe background soil sample (NSL-SB-1) was collected off-site from theresidential property of Louis C. Novak, Jr. Mr. Novak's residential propertyis located on the east side of Lapp Road at the intersection of Lapp Roadand Orefleld Road. This location was selected, and agreed to by the USEPA,since it is not affected by landfill operations and does not receive surfacewater run-off from the site. The location of this sample is shown on Figure3-2 of the RI Report.

GERAGHTY & MILLER, INC AR20809I*

7.0 PRELIMINARY IDENTIFICATION OF APPLICABLE OR RELEVANT ANDAPPROPRIATE REQUIREMENTS

i ; (Note: Section 7.0 will be renumbered Section 8.0 in the revised RI report)

73.1 Federal Location and Specific ARARPage 7-8;

Commenta. The Protection of Floodplains is listed as a Federal Location-Specific ARAR.

However, Figure 4-3 does not show a part of the site as being in the 100-yearfioodplain, although Section 4.1.2, page 4-6, paragraph 3 states that, "the 100-year fioodplain boundary of Jordan Creek, —approaches immediately southof River Road in line with the western site boundary.",

ResponseThe NSL site is not in the 100-year floodplain. The quoted statement will beclarified by the following modification: "the 100-year fioodplain boundary ofJordan Creek~~approaches immediately south of River Road In line with andapproximately 300 feet south of the western site boundary.'* The Protection

V_y of Floodplains is listed as a Federal Location-Specific ARAR in the event thatoff-site activities in the floodplain, namdy discharge pipelines to JordanCreek, are evaluated in the FS. This potential ARAR will be discussed ingreater detail in the appropriate section of the FS.

CommentIf the site's western boundary does approach River Road, this should bereflected in Figure 4-3.,

ResponseFigure 4-3 is correct Refer to the previous comment.

GERAGHTY c? MILLER. INC. AR208095

7-2

Page 7-8;Comment

b. 40 CFR 264 is listed as a Federal Location-Specific ARAR under the SolidWaste Disposal Act Part 264 discusses the "Standards for Owners andOperators of Hazardous Waste Treatment, Storage, and Disposal Faculties."Section 43.1, page 4-14, states that "available information indicated that thewastes disposed at the NSL were typical of wastes streams handled bymunicipal solid waste landfills..." The identification of the waste streams ashazardous or non-hazardous is an important issue. Paragraph 43.1 indicatesthat the landfill accepted "waste sludge from select commercial and industrialsources" in addition to "55-gallon barrels although it is not dear if theycontained liquids." A proper identification of the wastes accepted by NSL isnecessary because this will have a significant impact on selection of theremedial alternatives in the future, namely capping.,

ResponseAn expanded discussion of waste characterization was provided to the USEP ^prior to this submittaL The characterization was based upon availablelandfill records, PADER reports and reports submitted by waste generations($104-E reports).

This potential ARAR will be discussed in greater detail in the appropriatesection of the FS.

Page 7-8;

c. Federal Register, volume 56, No.196, October 9, 1991, should be reviewed andlisted as an


ResponseThe comment refers to RCRA Subtitle D regarding municipal solidlandfills. This potential ARAR will be reviewed and discussed in gidetail in the FS.

Commentd The following Pennsylvania ARARs should be included in Section 7. 3

1. The Solid Waste Management Act, Title 25, Chapter 264 containDepartment's Hazardous Waste Management Regulations correaction level for background ground water quality, specifically sec264.97(i) and 0) and 264.100(a)(9). The Pennsylvania ARABground water for hazardous substances is that ground water mufremediated to "background" quality as specified by 25 PA Code 2fr264.100, specifically 25 PA Code 264.97(i) and (j) and 264.100(a;The Commonwealth of Pennsylvania also maintains thatrequirement to remediate to background is also found in other Iauthorities.3

2. The Clean Streams Law of Pennsylvania, Act of June 22, 1937, ]1987, 35 PJS. 619.1 £L3S& 3

3. The Air Pollution Control Act, Act of January 8, 1960, PX. 211$P.S. 400L et. seq. 3

4. Pennsylvania Air Quality Management Regulations:-25 PA Code 123.1 et. seq. (Chapter 123-Standards for Contaminant•25 PA Code 131.1 et. seq. (Chapter 131- Ambient Air Qua]Standards).3

GERAGHTY & MILLER. INC A R 2 0 80 9 7

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Response ,It is inappropriate to consider as an ARAR any Pennsylvania requirementthat ground water must be remediated to background quality. The only basisreferenced for this purported requirement Is a regulation that applies tohazardous waste facilities, which the NSL is not, and is generally prospectivein application. As such, the requirements cannot be considered 'applicable.*

»

Furthermore, this hazardous waste regulation is not particularly well suitedto address deanup issues at the NSL and does not meet the NCP criteria forinclusion as a "relevant and appropriate* standard. This issue will beaddressed in greater detail in responses to comments on the FS, but thepurported ARAR has not been Incorporated at this stage for the foregoingreasons. We also note that PADER has not identified any other authroitieswhich it daims support the purported ARAR requiring a corrective actionlevd of 'background' for water quality. If EPA or PADER believes suchauthorities exist, the Group requests that such authorities be provided to theGroup promptly so that they can be evaluated. \

The Clean Streams Law of Pennsylvania, the Air Pollution Control Act andthe Pennsylvania Air Quality Management Regulations will be incorporatedinto the revised RI Report as potential ARARs and evaluates in detail in theFS.


8.0 SUMMARY AND CONCLUSIONS(Note: Section 8.0 will be renumbered Section 9.0 In the revised RI report)

. •'•'>'%'' ' f*f?*:, - ^Comment

a. It is agreeable that the concentrations of compounds detected in the airmonitoring program were below available guidelines; however, it isquestionable as to whether or not the selected sampling locations accuratelyassess the upwind (background) and downwind ambient air conditions at thesite.,

JResponseRefer to response b of the Executive Summary.

Commentc. An Ecological Assessment of the site is recommended. Guidelines for

conducting an Ecological Assessment are attached. Until an EcologicalAssessment can be conducted and evaluated for the site, the affects on theenvironmental media cannot be fully determined for the NSL.,

ResponseThis issue was discussed in response to Section 3.0 comment b.

Commentd In general, the Remedial Investigation Report for Novak Sanitary Landfill

evaluated and incorporated many of the criteria necessary for an EcologicalAssessment It is apparent, however, that some components of an EcologicalAssessment are missing and need to be addressed before moving on to theFeasibility Study (FS) stage. As set forth above, a trained field ecologist willbe best qualified to assist in the preparation of an Ecological Assessment,

ResponseThis issue was discussed In response Section 3.0 comment b.

GERAGHTY c? MILLER. INC. 1R208099

TABLES

TABLE 3.10 GROUND WATER AND SURFACE WATER ELEVATIONSComment

The dates of measurement collection needs to be added to this table. 2Response

These data will be added to the revised RI Report

GERAGHTY & MILLER. INC. fl ft 2 Q S / fl fl

APPENDIX A: BASELINE RISK ASSESSMENT3.0 CONSTITUENT CHARACTERIZATION32 OCCURRENCE IN GROUND WATER

Page A-9:Comment

Filtration of water samples may reduce concentrations of organic compoundsdue to coagulation on the filter paper. Unfiltered samples should be used.In addition, not all organic compounds will be in the dissolved form.

ResponseFor the organic constituents, only unfiltered data were collected and thuswere used to calculate the arithmetic mean and 95 percent upper confidencelimit (UCL) on the arithmetic mean. The text will be revised to state:•Unfiltered data were used in estimating exposure point concentrations fororganic constituents.' It Is a well known standard technical practice as wellas USEPA's policy to collect only unfiltered water samples for organicanalysis (USEPA, 1989 (Risk Assessment Guidance for Superfund, Volume1, Human Health Evaluation Manual (Part A), Interim Final, EPA 540/-89/002J).

' ;: ! . •32A On-Site Monitoring Wells

Page A-12:(Homment

a. The practice of averaging data from different wells to estimate reasonablemaximum exposure is underprotective. Because future residential wells wouldbe located at single points, it is reasonable to assume that such a well couldbe placed in the region of greatest groundwater contamination. The users ofthis well would therefore be continually exposed to concentrations far abovethe average of all monitoring wells.

GERAGHTY 6? MILLER. INC fl ft 2081 01

A-2

ResponseThe average concentration was not used in the exposure assessment The 95 .jpercent upper confidence limit on the arithmetic average concentration wasused in the risk assessment Single point maximum concentrations are notused because they are a poor representation of exposure point concentrationsover the extended periods of time modelled for most drinking water scenarios.

CommentTherefore, hypothetical future exposure scenarios for on-site and off-sitemonitoring wells and for off-site residential wells, should focus on the mostcontaminated well or small group of proximate similarly contaminated wells.The only averaging that is appropriate is over time. Since the future on-siteresidential well scenario averaged only two wells and the 95% UCL exceededthe maxima, this scenario does not need to be changed

ResponseThe approach used in the Baseline Risk Assessment was designed to providea conservative estimate of potential exposures. It is unlikely theconcentrations currently measured in monitoring or residential wells willremain constant over time. Nor, is it reasonable to assume an individual willingest the maximum detected concentration over 30 years. As a result, theuse of the 95 percent UCL represents a method of evaluating exposure to allmeasured levels of constituents assuming a receptor has an equal probabilityof encountering all constituents at all concentrations.

The use of the average concentration may not adequately provide an estimateof exposure to constituents at a site, therefore, the Baseline Risk Assessmentused the 95 percent UCL as the exposure point concentration. Use of thisvalue was based on the following USEPA guidance: (1) In most situations,assuming long-term contact with the maximum concentration is notreasonable* and (2) "Because of the uncertainty associated with any estimate

GERAGHTY & MILLER. INC.AR208I02

v^ A-3

of exposure concentration, the upper confidence limit (i.e~, the 95 percent, upper confidence limit) on the arithmetic average is used for (the exposure

point concentration]* (USEPA, 1989 [Risk Assessment Guidance forSuperfund, Volume 1, Human Health Evaluation Manual (Part A), InterimFinal, EPA 540/49/002]). USEPA (1989) stated further that if there is agreat deal of variability in the data, the UCL may be too high. This situationwas seen for the on-site residential wells. In discussing the estimation ofground-water exposure point concentrations, USEPA (1989) states that "watercould be drawn from anywhere in the aquifer, regardless of the location ofexisting wdls relative to the contaminant plume.* The mmrimumconcentrations of the constituents of concern were used to re-evaluate thepotential current off-site and hypothetical future on-site exposure scenarios.The maximum concentrations of the constituents of concern for the off-siteresidential wells were scattered among several of the wells and it Is unlikdyany one residential well will contain 95 percent UCL concentrations of allconstituents of concern. Thus, to respond to the comment and be

( conservative, the risk estimates for potential current off-site resident (adultand child) exposure were calculated separately for each of the 10 residentialwdls. The results are included as Tables A-24a through A-24h (adult), A-25athrough A-25h (child), and A-32a through A-32f (shower) in this submittal.These tables will be incorporated into the final document

For the hypothetical future on-site resident ground-water exposure scenarios,the monitoring data were evaluated to determine the location of the maximumdetects for each of the constituents of concern. An evaluation of the on-sitemonitoring well data indicates that the maxima for the constituents ofconcern did not occur in one or two wells, but were grouped into 4 generaldusters based on the well locations (wells 10 and 11 [duster 1J; wdls 2A and9 [cluster 2]; wdls 7 and 1C [duster 3]; and wdls 6 and 8 [duster 4]). Theresults are Included as Tables A-28a through A-28d (adult), A-29a through

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A-4

A-29d (child), and A-33a through A-33d (shower), in this submittal. Theseresults will be integrated into the revised baseline risk assessment prior tosubmittal of the final RI to the USEPA.

CommentThe document seems to imply that contaminant levels less than twice themaximum background concentration are unimportant Statistically, suchconcentrations may be significantly greater than background; the onlyacceptable demonstrations of similarity to background are statistical, withadequate power (fl=OJ20 or less). Toxicologicalry, some backgroundconcentrations may be harmful (depending on the specific contaminant), soeven slight excursions above background may be significant; the onlyacceptable demonstration of safety is a risk-based estimate. All languagereferring to twice the background maximum should be removed from the riskassessment

ResponseA statistical analysis could not be performed to determine whether or notconstituents were present at background levels. Instead, a technique wasused to approximate the statistical analysis. Use of twice the maximumconcentration allows for the natural variation in element concentrations. Theintent of using twice the maximum concentration was to approximate anupper confidence limit (UCL) for individual data points. Use of twice themaximum background concentration is a conservative estimate for the 95%UCL. This approach is recommended in USEPA, Region IV, guidance forSnperfund risk assessments (Supplemental Region IV Risk AssessmentGuidance, March 26, 1991). Our experience tells us that using twice thebackground concentration is an effective tool: the results obtained aretypically as conservative as results obtained by performing more rigorous nonparametric statistical analyses.

GERAGHTY*M,l"R.,NC Aft208lOt

A-53.12 CONSTITUENT FATE AND TRANSPORT &&

f,. .'• . . " • '.-:

3.12.1.1 Atmospheric TransportPage A-18:

.CommentA Henry's Law constant of 10*3 is the level at which volatilization is limitedby surface exchange, not the lower limit of volatility. Compounds with H =1C*4 still partition strongly into air from aqueous solution. All compoundshaving H_>. 10"* should be included in the showering inhalation calculations.

ResponseAs the Henry's Law constant (H) decreases below 10"3 atm-m'/mol, factorsother than surface exchange compete to limit volatilization. A constituentwith H IO*4 atm-mVmol is most likely more soluble than a constituent witha higher H, and Is less likely to volatize. AH organic constituents were usedto evaluate inhalation exposures while showering for the on-site and off-siteresidential wdls. Exposure to constituents present in on-site monitoring wdlswas evaluated for the VOCs only. To address the USEPA comment and beconservative, all semi-volatile organic constituents detected in on-sitemonitoring wdls were added to the inhalation exposure scenario. A revisedTable A-33 is Included with this submittal.


A-6

4.0 EXPOSURE CHARACTERISTICS4.1 RELEASE/SOURCE ANALYSIS

Page A-58:

CommentThe reference to the source of elevated concentration of nitrate in the watercollected from the Pheasant Hill well should be USEPA 1991d and not 1991cas cited. This is based on a review of the references provided.

ResponseThis reference has been changed.

42 EXPOSURE POINTS AND RECEPTORSPage A-59:

Comment

Current on-site residents at Mrs. Hilda Novak's house are exposed to waterfrom Well RW-08. Selecting the maximum concentration from the analyticalresults from this well and other wells is appropriate, although it may lead tooverestimation of the risk under the current exposure scenario.

ResponseUse of the maximum concentration is a conservative assumption. It isunlikely the concentration at the well will remain at this levd over the 30-yearexposure period evaluated in the Baseline Risk Assessment The use of themaximum tends to over estimate potential risks.

CommentThe residential well RW-14 possibly does not represent the condition of thebedrock aquifer. However, specific information regarding the well screendepth in relation to the bedrock water table and other documentation arerequired to justify the exdusion. Exclusion of wells, particularly in a fracturedrock situation, should be justified based on hydrology. If this residential well

GERAGIfrY LLER.INC AR208I06

A-7i' •'•••:$ . f -/V"';

is not screened in the bedrock, it necessitates assessment of exposure ofresidents using wells screened in the shallow aquifer.

ResponseResidential well RW-14 was not induded in the Baseline Risk AssessmentThe well does not represent the condition of the bedrock aquifer. Please referto RI text Section 4.5.2.1 UnconsoIidated Materials (Page 4-45) in theHydrogeology section for specific information. As described in this section,the data indicate that this residential well is a hand-dug well completed ina local shallow perched ground-water system that is approximately 170 feetabove the regional bedrock aquifer system. The perched ground-water systemis not a shallow aquifer and is not hydraulically connected to ground wateroriginating at the NSL. Additionally, sampling of RW-14 during the RI studydid not indicate any degradation of the water quality at this location.Therefore, the ground-water monitoring data from residential well RW-14were not used to evaluate potential exposure point concentrations.

Page A-62:

Comment

It is not necessarily the case that the intake parameters and risk assessmentswould be the same for current and hypothetical future exposure. Theassumption that the activities and/or exposure parameters would be the samefor future site use needs to be justified.

ResponseHuman activity patterns with respect to the quantity of water ingested or airbreathed do not change over time for particular age groups. All adults arelikely to drink 2 liters of water each day and inhale 20 m* of air each day.There is no reason to expect individuals' habits will change in the future. Asa result, USEPA standard default values were used to evaluate exposure toall residential population. The assumption in the risk assessment was that


A-8

these values would remain constant over time. For the Baseline Risk ,Assessment, the currently detected levels of constituents were assumed toremain constant over time, although it is expected that constituentconcentrations will decrease with time. As a result, the potential risks oradverse health effects would be the same for the current and hypotheticalfuture resident

43.6 Uncertainty in Exposure Point ConcentrationsPage A-66:

The uncertainty in exposure point concentrations may also be due tounderestimation of exposure point concentrations. The nature of thecontaminant release and the location and the time of the intercepting plumewill dictate whether an increase or decrease relative to the presentconcentration might occur.

ResponseThe EPCs were the lesser of the 95 percent UCL and the maximum detectedconcentration. Concentrations were assumed to remain constant over time.These two assumptions will tend to overestimate chronic exposures. However,to respond to the USEPA comment, the following will be added to the end ofthe paragraph in question: The EPCs presented in this report couldunderestimate exposure if the ground-water samples did not represent thehighest constituent concentrations at the site. To protect against this type ofoccurrence, the EPCs used were the lesser of the 95 percent UCL on thearithmetic average and the maximum detected concentration.*

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4.4 EXPOSURE DOSE CALCULATIONS ^4.4.4 Leachate Seep and Associated Surface Soil

Page A-74:

CommentThe assumption of incidental ingestion of 5 mg/d of surficial soil from thevicinity of leachate seeps in underprotective. The scenario should assumethat, on days when these soils are contacted, 100 mg of incidental ingestionoccurs.

ResponseAn inddental ingestion rate of 100 ing/day likely over estimates exposure, buthas been used In the revised calculations at the request of the USEPA.Revised Tables A-43, A-44, and A-45 have been attached. The text will berevised to state 100 mg/d was used as an incidental ingestion rate.

4.45 WadingPageA-76:

CommentVerify how the exposed skin surface areas for the children were obtained.

ResponseThe following will be added to the text: "(bands, arms, legs, and feet).*

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5 . 0 RISK CHARACTERIZATION . v52 ENVIRONMENTAL RISKS53.2.1 On-Site Surface Water

Page A-92; Second paragraph:

The discussion on Aluminum criterion in this section is in error for tworeasons. First, Pennsylvania expresses its metal criteria as total recoverable.While EPA developed lists criteria as add soluble, The Agency translates itscriteria as stipulated by the State, therefore, in Pennsylvania's case, the metalcriteria are expressed as total recoverable, not add soluble. Second,Pennsylvania's criteria for aluminum is a "maximum 0.1 of the 96 hour LC50for the representative important spedes... to the ambient quality of thereceiving water." Therefore, the important spedes for the on-site surfacewaters should be determined and the criterion should be calculated based onthose spedes. In addition, if the water in the retention ponds has thepotential to overflow into Jordan Creek, then the criterion should becalculated using the important species of Jordan Creek.

ResponseThe USEPA's chronic FWQC (Ambient Water Quality Criteria for Aluminum,Office of Research and Devdopment, Environmental Research Laboratory,Dulnth, MN, 1988) was used as a comparison criterion because, based oninformation collected during two site visits, the on-site surface waters werenot capable of supporting fish due to their intermittent nature. Thequalitative assessment of potential ecological risks did not involve adetermination of the representative important spedes in Jordan Creek for thefollowing reasons: (1) as conduded in the RI, there is no indication that theNSL has affected Jordan Creek; and (2) the FWQC for aluminum wasdeveloped to be protective of sensitive species.


Page A-92, Third paragraph.' ..:.>; ; • :fr' .

CommentContrary to what is stated in this section, Pennsylvania does have criteria tcobalt The chronic criteria is 396 ng/l and the acute criteria is 1980 pg/

ResponseThe Pennsylvania criteria for cobalt (PADER, Chapter 16, Snbchapter -Guidelines for Devdopment of Criteria for Toxic Substances and WatQuality Criteria for Toxic Substances, 1991) have been incorporated in tlrisk assessment The text will be revised to include the Pennsylvania cobacriteria.

5222 On-Site SedimentsPageA-95

: , ' Comment"Comparator" needs to be changed to "Comparative."

ResponseThe word change has been made.

GERAGHTY C? MILLER. INC. noon/*..wncUOl|/

A-12

TABLESTable A-6:

Q?rpnient

The UCL concentrations for acetone, benzene, carbon tetrachloride, and1,1,1-trichloroethane are less than the means. Since this is impossible, thistable (and all calculations which depend on the EPC numbers in it) should becorrected.

ResponseThe UCL calculations were recalculated and the revised Table A-6 isattached. The excess lifetime cancer risks, hazard quotients, and hazardindices were recalculated and revised Tables A-39, A-40, and A-41 areincluded in this submittal.

Table A-12:

Comment

The Standard or Criterion values are not the most recent values available(October, 1991).

ResponseThe table has been updated and the revised Table A-12 is attached.Table A-13:

The criterion for induding inorganic contaminants in the risk calculationappears to have been in exceedance of the maximum background level (nottwice the maximum as implied earlier in the text). This standard, althoughstricter, has the same problems discussed earlier, it demonstrates neitherstatistical similarity to background, nor safety. Arsenic, cobalt, and cadmiumshould be added to the risk assessment for all exposure routes from whichthey were dropped.

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Response "'-Please refer to the response to the comment on page A-3 of this snbmittaLThe use of two times background was designed to approximate the mean pinstwo standard deviations. Guidance was not available from USEPA RegionIII for exduding these constituents from the risk assessment; therefore,USEPA Region IV guidance (Supplemental Region IV Risk AssessmentGuidance, March 26, 1991) was followed.Table A-16:

The following toxicological constants should be changed to reflect currentEPA guidance:

2-Butanone

Chlorobenzene

Chloroethane

Methylene chloride

Ammonia

Arsenic

Nickel

Nitrate

Nitrite (addition)

2.0e-2

3.0e-4

L6e+0

l.Oe-1

5.7e-3

2.9e-2

1.6e-3

USt+l

NA

GERAGHTY & MILLER. INC.AR208II3

A-14

ResponseIRIS (Integrated Risk Information System) and HEAST (Health EffectsAssessment Summary Tables) were accessed in May 1991. Values may changein IRIS as the USEPA release additional information. These values wouldnot have been available when the Baseline Risk Assessment was prepared.The values could have been available when the USEPA reviewed the BaselineRisk Assessment Not all of these toxidty values are available on IRIS(accessed on January 30,1992). A new HEAST also is not available to thepublic. Therefore, the Baseline Risk Assessment could not have beenprepared with these values. The new toxicity values have been included in therisk assessment following the guidance of Dr. Roy Smith (USEPA). At thedirection of Dr. Roy Smith (via telephone conversation with Christopher Day[Geraghty & Miller, Inc.] on February 28,1992) only toxicity values availableon IRIS and/or HEAST were used to revise the risk assessment The revisedtables are attached to this submittal.

Table A-3fc

Commenta. The doses received by inhalation of VOCs during showering are

underestimated by a factor of about 10, through a combination of causes.First, the model used is nonconservative in that it assumed all VOCs emittedin the shower are instantly volatilized throughout the entire bathroom. Thisapproach seriously underestimates the likely concentrations in the shower,where most of the exposure occurs. Second, underprotective assumptions aremade for a number of variables used in the model, especially drop time, andto a lesser extent water temperature (and therefore viscosity) and length ofshower.

GERAGHTY c? MILLER. INC

AR2Q8IIU

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b. The shower exposures should be recalculate as follows: use a 2-sec droptime, 318° [K] water temperature, viscosity of 0396 cp, shower time of 15 min,and time in bathroom after shower of 5 min. During the shower, the airdilution volume should be 25 m3, only after the shower can the full bathroomvolume of 10 m3 be used.

ResponseThe original dilution volume of 10 m3 was a valid assumption because vaporsformed in the shower may migrate to the ceiling and away from the showerstalL Most shower stalls are not enclosed to the ceiling on all sides. As aresult, the use of a dilution volume of 23 m3 is an overly conservativeassumption. To address USEPA's concern the shower modd was rerun usingthe assumptions identified by the USEPA with the exception of the airdilution volume. Tables A-31, A-32a through A-32f, and A-33a through A-33dwere revised and are induded with this submittal. The air dilution volumewas reduced from 10m3 to 6m3 to be consistent with the air dilution volumeused by Foster and Chrostowskj (1987) for time spent in the shower and timespent in the bathroom after the shower.

Table A-50:

Comment

Need to show actual calculated Pb blood levels in pg/dL also the inputs forthe model. ..

.Response ,The lead concentrations used in the model are provided in the table. It isundear what other inputs for the modd are required. The USEPA LEAD4model does not provide all the variables used in the calculations. All defaultvalues programmed into the model were used except for the site-specificconcentrations. •

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Table A-51:

Where the same individual could reasonably be exposed by more than oneexposure route, risks from different scenarios should be combined. Thisshould include, for example, future on-site well water ingestion, plusshowering, plus surface soil contact, plus VOC inhalation, plus contact withseeps. Also, cancer risk to children is additive with that to adults. These risksshould be combined.

ResponseA revised Table 6-1 is attached and the text will be revised to state thefollowing:

Exposure of a potential on-site adult resident via ingestion andinhalation of constituents in ground water resulted in an excesslifetime cancer risk of 2 xlO"4 and a hazard index of 0.9. Exposure ofa potential current on-site child resident via ingestion of ground waterresulted in an excess lifetime cancer risk of 8 x 10"5 and a hazardindex of 2. The excess lifetime cancer risk and hazard index rangedfrom not determinable to 4 x 10"* and not determinable to 0.9,respectively, for exposure to ground water via ingestion and inhalationof ground water by a potential current off-site adult resident Inseveral wells, constituents of concern were not detected and an excesslifetime cancer risk and/or hazard index could not be calculated. Theexcess lifetime cancer risk and hazard index ranged from notdeterminable to 1 x 10"6 and not determinable to 2, respectively, forexposure to ground water by a potential current off-site child residentExposure of a potential current trespasser via contact with surfacesoil, air, leachate seep water and sediment, and surface water andsediment resulted in an excess lifetime cancer risk of 1 x 10"5 and a

GERAGHTY & MILLER, INC. A R 2081 I 6

A-17••&•'•* . . .: • - • • • • ••' . ffrhazard index of 3. The overall exposure of a hypothetical future on-site adult resident resulted in an excess lifetime cancer risk rangingfrom 2 x 10"4 to 4 x W4 and a hazard index ranging from 7 to B. Theoverall exposure of a hypothetical future on-site child resident resultedin an excess lifetime cancer risk ranging from 1 x 10"4 to 2 x 10"* anda hazard index ranging from 11 to 12. These ranges were dependenton which monitoring well cluster was used in the evaluation. A totalsite risk and hazard index were calculated for current and futureexposures. For current exposures, the total site risk and hazard indexwere 3 x 10*4 and 8, respectively, using the maximum value for the off-site residential wdls. For future exposures, the total site excesslifetime cancer risk and hazard index ranged from 3 x 10"4 to 6 x 10"4and 18 to 20 depending on which monitoring well duster wasconsidered.

GERAGHTY & MILLER, INC.AR208II7

APPENDIX B: HISTORICAL GROUND-WATER QUALITY SUMMARIESTable B-l:

CommentIt is very difficult to interpret the analytical data from ground water wellsfrom which no construction information is provided for those wells. It isnecessary to provide construction information on all wells, residential ormonitoring

ResponseAs discussed hi response to previous comments, all available wellconstruction data for the residential and monitoring wells installed at the siteprior to the RI/FS program, is provided in Attachment B and will beinduded in the revised RI Report

GERAGHTYff MILLER.INC. A R2 0 8 I | 8

APPENDIX F: STORM WATER RETENTION PONDS CAPACITY CALCULATIONSPage F-l; Item 1:

Commenta. In order to fully document and evaluate the determination of the runoff curve

number, Table 2-2C of the reference (United States Department ofAgriculture Soil Conservation Service, 210-VI-TR-55, 1986) should beincluded as part of Appendix F. i

ResponseA copy of Table 2-2a - Runoff curve numbers for urban areas of the dtedreference has been induded in Attachment E.

Commentb. Dynamac recommends that the consultant indude the specific soil group

identified at the site in this section that generates the D Soil Group listing.1

( i JResponseThe D soil group listing was originally chosen as a conservative classificationof soils at the NSL. Upon further review of the USDA Soil ConstructionServices Soil Survey Map for Lehigh County, Pennsylvania, the following soilswere identified:

Soil Name Hydrologic Soil GroupHuntington Silt loam BUndside Silt loam CDufiield Silt loam BWashington Silt loam BMade land ~ .

Based upon these identified soil groups, the most conservative soil group,group C soil, will be assumed to cover the entire site. This conservativeassumption is made since a certain amount of site grading and filling has

GERAGHTY 6? MILLER. INC. A R 2 0 8 I | 9

F-2occurred over the years and it would be difficult to accurately delineate theactual existing site soil groups. The runoff curve number and all subsequentcalculations will be revised to reflect this change.

Commentc. Dynamac feels that the runoff curve number should be revised based on cover

types and hydrologic conditions described in Table 2-2C of the listedreference. Dynamac disagrees with the consultant's assumption of Cover Typemeadow with generally mowed grass for the entire site and recommends thatthe consultant select open space for the cover type category. Dynamac basesthis on field visits where site conditions were found to be approximately 80%grass with sparse vegetation cover and 20% bare soil. These conditions willresult in a higher runoff curve number, which will then result in higherretention volumes. Dynamac recommends that the consultants reevaluate theretention volumes based on the higher runoff curve number.i

ResponseAssuming an open space grass cover with 75% grass and 25% base soil andhydrologic soil group C, the runoff curve number is 74 based upon table 2-2aof the listed reference. The retention volumes will be revised based upon thischange in the runoff curve number.

Page F-2; Item 3:Comment

d. The site listed as being approximately 65 acres and the drainage areascalculated by the consultants add up to approximately 54 acres. EPArecommends that the consultant provide an explanation for the discrepancyin the numbers.i

ResponseThis discrepancy is the function of two factors. First, several maps fromseveral sources, and developed at different scales, were used throughout theRI to calculate the area of the site as well as the areas of the drainage basins.

GERAGHTY & MILLER, INC A R 2 0 8 I 2 0

F-3j '•* . £-N| 'Discrepancies in the 'assumed* property boundaries on these maps haveresulted in estimates of total site area ranging from approximatdy 58 acresto 65 acres. The only legal source of information documenting the size of theNSL property and utilized during the RI was tax map information. The taxmaps indicate the pared of property south of Orefidd Road, the site of theNSL, is 64.8 acres. Second, approximately five acres of the site, all outsidethe limits of the waste disposal areas, drain directly off-site and not to theexisting or proposed retention basins. The five acres are predominatelylocated along the eastern and western property boundaries.

Commente. Also, according to Section 4.62, page 4-64,2nd full paragraph, surface water

run-on to the NSL occurs along the northern site boundary east of Mrs.Novak's residence. EPA recommends that surface water run-on be taken intoconsideration when calculating the necessary volume for the proposed OldMine Area stormwater retention pond.i

ResponseThe Group plans to evaluate whether or not it is appropriate for storm-waterfrom the Pheasant Hills development to discharge to private property, namelythe NSL. Should it be found appropriate, storm-water flow from thePheasant Hills development which discharges onto the NSL will be taken intoconsideration when storm-water management controls are designed during theRemedial Design phase of the project

Page F-2; Item 5:Comment

f. The AutoCad DCA is a software computer program which may or may notbe available to reviewers or other interested parties. EPA recommends thatthe consultant include a brief summary of the relevant data generated fromthe February 1990 site reconnaissance field sketches that were utilized in

GERAGHTY 8 KflUER. INC. A K2 0 8 I 2 I

F-4

determining the surface impoundment storage capacities (i.e., lengths, widths,and depths). The consultants should also indude a brief summary of themethodology contained in the computer software.i

ResponseData that was collected from the February 1990 site reconnaissance indudingsketches, and approximate dimensions of length, width and depth of theexisting surface impoundment are provided in Attachment H.

AutoCAD DCA software has not been provided with the RI Report becausethe software is copyrighted information. Should, the USEPA or its oversightcontractor desire a copy of AutoCad DCA software, it is available throughAutodesk, Ine~ 2320 Marinshlp Way, Sausalito, California 94965.

The AutoCad DCA software uses a triangulated irregular network (TIN) togenerate a grid over digitized surfaces. The digitized surfaces are generallyexisting contours, which would formulate the datum surface, and proposedcontours, which could potentially be surface-water levels when determiningthe volume of retention basins. The software then compares the computedelevations at the grid nodes of the proposed! contours to the elevations at thegrid nodes of the datum surface. The results are the differences hi elevationsbetween the existing and proposed surface at each grid node. These valuesare then multiplied by the area assigned to each respective node and theproducts summed across the area under evaluation. The result, in short, Isthe volume between two surfaces. Depending on how the evaluation isstructured, these volumes can represent the existing volumes of retentionbasins, the volume of excavation needed to enlarge a retention basin to apredetermined capacity, or many other similar volumetric values.

GERAGHTY c? MILLER. INC

Comment

. „ i, .'-•-. i^. ~ F'5PageF-3;

g. The second sentence states, "One solution to this requirement is to havesurface impoundments of sufficient storage capacity to hold the entire volumeof runoff1. Will other alternative solutions be considered or has theconsultant selected this solution to manage the surface runoff at the site?i

ResponseThe site-wide recommendation for storm-water management at the NSL is toregrade the waste disposal areas to achieve positive drainage throughout thesite and minimize infiltration into the waste, and to provide sufficient on-sitestorage capacity to accommodate a 100-year storm event Implementation ofsuch a recommendation would require increasing the capadties of thesouthwest and southeast retention basins by approximately 8200 cubic yardsand 6700 cubic yards, respectively and constructing a third retention basinof approximately 12,400 cubic yards capacity in the northeast corner of thesite. The ability to properly manage storm-water on site would alleviate theneed for constructing overflow structures from on-site retention basins toJordan Creek.

GERAGHTY & MILLER. INC fl ft 2 0 8 / 2 3

APPENDIX G: AMBIENT AIR MONITORING PROGRAM REPORTComment

a. G&M has not identified the distance from the site boundaries of thedownwind sampling locations which makes it difficult to determine if theconclusions drawn for this report are accurate.

ResponseFigures 1 and 2 show the relative location of samplers with respect to the siteperimeter. To add a conservative bias, downwind samplers were placed hicloser proximity to the previously landfilled areas, not at the perimeter of thesite. Results should, therefore, be higher and more conservative than ifplaced at the perimeter.

Commentb. G&M explains that when the battery operated pumps for sample DW1C and

DW1S stopped operating they replaced the pump and continued sampling.Standard protocols for sampling usually require that if a sample experiencespump failure the complete sample is void. It seems that the procedure ofreplacing the pump as employed by G&M may have resulted in erroneousdata. Therefore, it is recommend that the results from such samples beidentified as questionable data.1

ResponseIf the fidd technician was not present when the pump failure occurred, thelast recorded time the pump was inspected was used for determining the testduration and total air sample volume. The recorded duration of the failedpumped was combined with the recorded duration of the replacement pumpto determine the total ah* sample. However, no allowance was made for thelikely possibility that additional constituents were recorded by the failedpump apparatus after it was last inspected and before it actually failed. Thisconservative procedure could potentially result in biasing detected constituentconcentrations on the high side because a smaller air volume would be usedfor comparison to the volume of constituents detected. Implementing this


G-2V"** . . •$*%

i , procedure maintained the schedule for the field activities withoutjeopardizing the quality of the data.

As stated previously, the Ambient Air Monitoring Program was implementedto screen the NSL for potential ambient air quality conditions which mayrequire special attention hi the HASP and to screen the site for unusual airquality conditions which would warrant further investigations. As concurredby the USEPA, no such conditions were detected.

Page 2;Comment

c. G&M indicates that the meteorological station on Day 1 was "positioned onsite at the flattest and most unobstructed locations". G&M then states, "Thelocation of the meteorological station on Day 2 was chosen because of easyaccess as well as its relatively unobstructed location ".. The location of the stationshould be more dearly described and referenced on a site map. G&M makesan indirect reference to the terrain and physical features of the site in thesestatements. However, upon viewing Figure 1 & 2 (which G&M have notappropriately referenced for locating the meteorological stations) there arenot topographical reliefs or physical features depictedi

ResponseThe meteorological station is indicated on Figures 1 and 2 of the July 1991revised report Both locations accurately depicted site wind conditions andwere accessible for fldd crew members to observe and record wind datathroughout the test The location of the meteorological station will beinduded on Figure 3-2 of the RI Report

Commentd. Upon reviewing Figures 1 & 2, it does not appear that G&M chose sampling

i i locations that are truly "downwind" and "upwind" of the site. For instance, on

GERAGHTY c? MILLER. INC. A R 2 G 8 f 2 5

G-3Day 2 the upwind location is actually located within the site boundaries. Also, —the upwind location for Day 1 is positioned just outside of the site boundary.Typically, "upwind" locations are positioned far enough from the siteboundaries that there is very little likelihood that the results would beinfluenced by the on-site conditions. This does not appear to be the case forthe two locations selected.1

ResponseUpwind locations were chosen to represent upwind ambient air characteristicsimmediately before potential effects from the waste disposal areas. As statedpreviously, it was not the purpose of the upwind sampling to collect datarepresentative of regional ambient air quality. Therefore, the position of theupwind sampling points with respect to the site property boundaries isirrelevant What is important, however, is that the upwind sampling stationswere positioned outside of the limits of the waste disposal areas with respectto the prevailing wind direction of the given sampling day. This is the casefor the upwind sampling locations on both sampling days.

Downwind sampling locations were based upon the prevailing wind directionat the time of sampling and sampling stations were maintained downwind ofthe waste disposal areas during sampling events.

Commente. Likewise, it does not appear that the downwind locations are truly

representative of downwind conditions. On both days it appears as though thedownwind locations are positioned closer to the upwind boundary when theyshould be located nearer the downwind perimeter or even off-site so that theyare more representative of the air traveling over most of the site.i

ResponseAs previously stated, downwind sites were grouped around the knownpreviously landfilled areas, not on the property boundary. Also, one must \_>

GERAGHTY & MILLER, INC. AR208l?fi

i , review the raw wind direction data in conjunction with Figures 1 and 2 tothoroughly understand sdection and placement of samplers. The wind vectorplotted in Figures 1 and 2 is the resultant average for the period. Winddirection shifted during Test 1 from the southwest towards the northwestThe downwind Sampler 2 was moved to site "B* 5 1/2 hours into the test toaccommodate this change.

On Page 3;Comment

f. G&M states "....specific reasons for choosing the sampling locations illustratedfor Day 1 were based on the National Weather Services forecast of windsbecoming northwesterly over the course of the day as well as the distinctland/Wing areas contained within the properties boundaries and the local terrain. "It appears that if the winds were expected to become northwesterly over thecourse of the day, then the downwind locations should have been positioned

— doser to the southeast boundaries of the site. Likewise, the upwind locationshould have been located further northwest than its indicated position. Also,if terrain and landfill physical features were used as criteria for selectingsampling locations, G&M should depict such on the site maps.i

ResponseThrough review of the raw wind data for Test 1, it is evident that winds werefrom the southwest for the first half of the test Later in the day, they shiftedat which time the downwind Sampler 2 was relocated to position "B*. TheNational Weather Bureau had predicted this wind shift and the test teamacted accordingly. ,

Commentg. It is not typical to relocate samples once the sampling period has begun. In

the event of wind shifts, it may have been more appropriate for G&M to start'.i j a second sample in the "new" downwind direction.1

GERAGHTY & MILLER. INC AR208I27

G-5

ResponseSamplers were routinely relocated with changes in prevailing wind directionsto maintain their downwind orientation. This assures maximum effect fromthe site at the downwind location and provides conservative results (USEPA;Air/Superfund National Technical Guidance Study Series; Volumes I throughIV; 1989-90).

Tables 1 & 2;Comment

h. G&M shows a sampling time of 2 minutes for the two trip blanks, what doesthis time represent? The Ambient Air Quality Monitoring Program,presented as Appendix B of Appendix G, indicates only a "passive" exposureof the trip blank without pumping air through the tubes.i

ResponseThe tubes were not used to sample air. They accompanied the other sampletubes in the same shipping container and were removed at the site from theirsealed container for approximately 2 minutes with the end caps left on.

Commenti. The narrative of Appendix G suggests that sample DW1C collected on Day

1 should represent a duplicate of Sample DW1, also collected on Day 1.However, Table 4 shows a marked difference in the analytical results formethylene chloride. G&M should offer an explanation for the differences,!

ResponseThese represent two separate samples that were collected in close proximityto each other. While they generally show good agreement, especially in lightof the low ambient concentrations present, the discrepancy in methylenechloride may be due to inadvertent laboratory contamination of tube DWIC.Methylene chloride is a common laboratory contaminant that can sometimesinfluence test results.

GERAGHTY & MILLER. INC A R 2 0 8 I 2 8

,,„,, ;;,::£ . G-6Comment

j. The "Sorbent Tube Collection Sheet" for sample D2-UW1-007 includes adiagram showing the sample location as just south of the two garages on theNovak property. G&M has identified this as the "upwind" location. However,this sample appears to be in very dose proximity of the site boundaries andmay not be truly representative of upwind conditions.1

Response ;The upwind location for Test 2 was representative of ambient air effecting thelandfilled area. Any potential contribution from garages, residentialwoodburning, or automobiles would have automatically been included in theupwind sample as well as at the downwind sampling location. In any event,upwind and downwind locations were essentially the same, showing only tracelevds of constituents. .'

Commentk. On the "Sorbent Tube Collection Sheet" for sample D1-DW2-001, G&M

indicates that the pump was checked at 4:09; however, on this same page,G&M indicates that the finish .time for the sample was 1530 (3:30). Thereappears to be an error in this recorded data since the last check is listed asoccurring 39 minutes after the sample collection finishedi

ResponseBy careful review of the raw data sheet for Sampler D1-DW2-00, it is evidentthat 1530 was not the finish time, but the time the sampler was relocated toposition *B", a more downwind direction with respect to shifting winddirection. The actual finish time was 1757 or 5:57 pm.

Comment . rL The report has not indicated whether the pumps were equipped with a

rotameter so that G&M could actually check the flow rate of the pumpi , throughout the duration of the sampling event And since G&M has only

GERAGHTY & MILLER. INC £ U O I 2 9

G-7

indicated the times the pump was checked and not corresponding flow rates,it is assumed that G&M was not monitoring the flow rate of the pump duringthe sampling event In this event, it is typical to use the most conservativevolume of air sampled, therefore generating the highest concentration. Thisis especially true when the air sampling pump shows a wide variability in flowrates, as is often the case with battery-powered pumps. For this reason, itmay have been more appropriate to calculate the sample volume using thelowest flow rate rather than the average.!

ResponsePumps were equipped with an electronic flow controller and a LED toindicate when pumps were in operation. Pumps were calibrated with a Mini-Buck calibrator prior to and at the condusion of testing. Since onlyabsorbent tubes were used, pressure drop remained constant over the test andvariation in flow rate corrected to standard conditions was minimal.Averaging of pre- and post-test calibration is, therefore, justified.

Commentm. G&M has not provided a "Sorbent Tube Collection Sheet" to correspond to

the "Pump Calibration Sheet" for pump DUP518 on 02/28/90, nor for pumpDUP513 on 02/27/90. G&M should provide an explanation for this.i

ResponseThe sorbent data sheet for the downwind Sampler 1 and downwind Sampler2 series location contains this information. Two separate tubes were run inseries for this determination. As noted on the data sheet, pump DUP 518replaced pump DUP 542 after a malfunction to pump DUP 542.

The sorbent tube collection sheet for Pump DUP 513 was the downwindSampler 2 location on Day 2 of testing (DS-DW2-006). The pump number(DUP 513) is clearly shown on the sorbent tube collection sheet

GERAGHTY & MILLER, INC. A R 2 0 8 I 30

i j Comment

•**.»vG-8

n. The Ambient Air quality Monitoring Program indicates that downwindsampling stations would be aligned with the nearest residences; however,G&M has not shown the location of the nearest residences on the site mapin this section to document such.1

ResponseTo add a more conservative bias, the samplers were placed downwind of theknown previously landfilled area. This placement offered more intenseexposure than would have been registered for the residential location at agreater distance. Any residential exposure would, therefore, be considerablyless than recorded values.

Comment

o. G&M had indicated that meteorological data would be documented at 15-minute intervals during the tests; however, in reviewing the "Sorbent TubeCollection Sheets" in Appendix A of Appendix G, it appears the majority ofthe meteorological data was recorded at 45- to 60- minute intervals.1

ResponseMeteorological data was recorded from the field instruments at the site atvarying intervals; however, the majority of data was taken at fifteen minuteintervals. During those intervals when elapsed time between data recordingsexceeded fifteen minutes, the field technidans were tending to the samplingstations.

When reviewing the meteorological data, attention should be given to thedistinction between data collected at the field meteorological station and thestation at AIIentown/Bethlehem/Easton (ABE) Airport Meteorological datafrom ABE Airport is only available on an hourly basis.

GERAGHTY c? MILLER. INC fiR208!3l

APPENDIX L: GEOTECHNICAL TESTING REPORTComment

a. The definitions for the symbols used in the Laboratory Testing Assignmentand Data Summary Form are not induded in Appendix L. As the symbolsare not defined, the porosity (N-initial), porosity (N-consolidated ), degree ofsaturation (initial), and degree of saturation (consolidated) values presentedin Table 3-5 cannot be verified.i

ResponseThis information is provided in Attachment I and will also be provided in therevised RI report.

Commentb. The pore volumes of distilled water permeated through the samples are not

presented, and are normally calculated to demonstrate that the test wasconducted for an adequate amount of time.i

ResponseThe testing standard for the permeability test (ASTM D-5084) requires themercury u-tube reading fall by a minimum of 2 cm to demonstrate that thetest is conducted for an adequate amount of time. During the permeabilitytests provided for each sample, the smallest recorded change in u-tubereadings was not less than 5 cm.

Commentc. For sample NSL-SB-2, the degree of saturation is over 100% (105%). The

reason for this value being greater than 100% should be explained in afootnote to Table 3-5.1

ResponseIn theory, the degree of saturation should not exceed 100 percent Inpractice, it is common for the degree of saturation to be slightly greater than100% due to Inconsistencies with the number of significant figures used foreach value used to calculate this parameter. Values greater than 100 percentcan be considered equal to 100 percent

GERAGHTY & MILLER. INC A R 2 0 8 I 3 2

APPENDIX M: BEDROCK CORE LOG

a. The drill logs from Monitoring Wells 1 through 6 should also be provided inthis Appendix

ResponseAs discussed in response to a previous comment, available well constructiondata for monitoring wdls installed prior to the RI/FS program are indudedAttachment A and will be included in the revised RI Report.

Commentb. The drill log for Monitoring Well 15 is missing j

ResponseMonitoring Well MW-15 is an unconsoIidated welL therefore thecorresponding well log does not belong fan Appendix M.

GERAGHTY c? MILLER. INC. AR208I33

ATTACHMENT A

LIST OF ABBREVIATIONS AND ACRONYMSUSED THROUGHOUT THE RI REPORT

GERAGHTY6?MILLER.INC. AR208 I

ABBREVIATIONS AND ACRONYMS

A.CGIH - American Conference of Governmental Industrial Hygienists

ACL - Alternate Concentration Limit

AOC - Administrative Order by Consent

AQTESOLV - Aquifer test sober software

ARARs - Applicable or Relevant and Appropriate Requirements

BTEX - Benzene, toluene, ethylbenzene, and xylene

C&D - Construction and Demolition

CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act of1980

CFR - Code of Federal Regulations

CLP - Contract Laboratory Program

CWA • Clean Water Act

—/EQB • Environmental Quality Board

FOP - Field Operations Plan

FS • Feasibility Study

FSP - Field Sampling Plan

gpd - gallons per day

HASP - Health and Safety Plan

HC - Hydrochloric Add

HRS - Hazard Ranking System

T-F-T-. Lower Explosion Limit

MCLG - Maximum Contaminant Level Goals

MCLs - Maximum Contaminant Levels

GERAGHTY & MILLER. INCAR208I35

ABBREVIATIONS AND'ACRONYMS (Continued)

MEGs - Multimedia Environmental Goals

meq/L - milliequivalents per liter

MF - Migratory Fishes

mg/L - milligrams per liter

NCP - National Contingency Plan

NET - National Environmental Testing, Inc.

NGVD - National Geodetic Vertical Datum

NPDES - National Pollutant Discharge Elimination System

NPDWRs - National Primary Drinking Water Regulations

NPL - National Priorities List

NSL - Novak Sanitary Landfill

PADER - Pennsylvania Department of Environmental Resources

PAHs - Petroleum Aromatic Hydrocarbons

PCBs - Polychlorinated Biphenyls

PEHB - Pennsylvania Environmental Hearing Board

PNDI - Pennsylvania Natural Diversity Inventory

PRN - Property Reference Number

PRP - Potentially Responsible Party

PVC - Polyvinyl Chloride

QAPP - Quality Assurance Project Plan

RCRA - Resource Conservation and Recovery Act

RI - Remedial Investigation

GERAGHTY 6? MILLER. INC. ^ . „AR208I36

ABBREVIATIONS AND ACRONYMS (Continued)

RI/FS - Remedial Investigation/Feasibility Study

RQD - Rock Quality Designation

SARA - Superfund Amendments and Reauthorization Act of 1986

SCS RCN - Soil Conservation Service Runoff Curve Number

SDWA - Safe Drinking Water Act T

SMCLs - Secondary Maximum Contaminant Levels

SWTP DPW - South Whitehall Township Department of Public Works

SWTP • South Whitehall Township

TAL - Target Analyte List

TBC - To Be Considered

TCL - Target Compound List

TLVs - Threshold Limit Values

TOC - Total Organic Carbons

TSF - Trout Stocking Fishes

USDA - United States Department of Agriculture

USEPA - United States Environmental Protection Agency

USEPA ORD - United States Environmental Protection Agency Office of Research andDevelopment

USGS - United States Geological Survey

VOCs - Volatile Organic Compounds

WBSAI - Walter B. Satterthwaite Associates, Inc.

WQC - Water Quality Criteria

GERAGHTY & MILLER. INC. A R 2 0 8 I 3 7

ATTACHMENT B

WELL CONSTRUCTION DATA FORWELLS INSTALLED AT THE NSL PRIOR TO THE

RI/FS PROGRAM

GERAGHTY & MILLER.1NC. A R 2 0 8 I 3 8

Novak Sanitary LandfillMonitor Well Construction

Well Number Total Depth Construction Information Hell Yield

1* 227' solid PVC - O1 to 10' 1 gpraperforated PVC - 10' to 27 •open rock hole - 27' to 227*

1A* 175' original soldd steel - 0' to 127' 1-2 gpm135' after open rock hole - 127' to 175'

collapse1B 124' original solid steel - 0' to 37' .1 gpm

105' final -after open rock hole - 37' to 105'filling

2* 200' solid PVC - 0' to 10' 1 gpmperforated PVC - 10' to 15'open rock hole - 15' to 200'

2A 175' so J1d steel - 0' to 33' 1-2 gpniopen rock hole - 33' to 175'

3 250' solid steel - 0' to 5V **open rock hole - 51' to 250'

4 206' solid steel - 0' to 59' **open rock hole - 59' to 206'

. 5 275' solid steel - 0' to 50' 1.5 gpmopen rock hole - 50* to 275'

6 150' solid steel - 0' to 83' 0.2 gpmopen rock hole - 83* to 150'

Well at 350' solid steel - -0' to 102' 2-4 gpmRental Property open rock hole - 102' to 350'

* Abandoned.** Exact yield unknown. Sufficient for domestic use, estimated at greater than

3 to 5 gpm.

AR208I39

Novak Hater Levels & Recovery Data

Static Water level measurements taken after drilling wells 5 & 6 and before collectinglarterly samples on November 13, 1984.

Depth to Static Wa- Static Water Level*Too of Casing ter Level below Too Elevation

Date Hell No. Elevation ' of Casing___ (Mean Sea Level)

U/9/84 1 436.23 101.1' 335.02 416.5 108.5' 308.03 475.3 difficulty measuring level4 445.4 140.8' 305.55-6 NOT COMPLETED DRILLING

11/16/84 1 436.23 102.0 334.22 416.5 109.0 307.43 475.3 171.9* 303.34 446.4 141.7 304.65 380.93 62.7 318.16 395.66 77.2 318.4

11/19/84 1 436.23 102.3 333.92 416.5 109.2 307.23 475.3 169.8 305.44 446.4 141.7 304.65 380.93 62.7 318.16 395.66 77.2 318.3

11/20/84 1 436.23 102.7 333.52 416.5 110.5 305.93 475.3 159.8 305.44 446.4 141.9 304.55 380.93 63.0 317.86 395.66 80.3 315.2

(probably not fullyrecovered)

Survey data by C.A. Cos tell o Engineering Cocnoany.

AR208UO

DRILLING ADMINISTRATION

I i Project: Well 1ANovek (abandoned)

Well Contractor: Odenheimer

Address: Allentown, Pennsylvania

Name of Driller: Bobby Helper (s)

Rig: Number Hake , I-R

Phone: 791-4353

GregBar

Model Length: 25'

Reference Point: Approximately 200 feet northwest of old Well f\

Casing fi Grouting Summary '(Amounts, Lengths, diameters) see below

Diary of Drilling

Date

4/17/85

j4/18/65

4/19/85

^

Time

12:00 noon3:10 P.B.

5:00 p.B.6:00 e.a.10:00 e.B.11:00 e.a.

12:30 p.B.4:00 P.B.7:45 e.B.9:40 a.a.

12:28 P.B.2:30 p.B.

What Was Done fi (Problems if

Set up on well, began drilling ,Drilled to 130 feet, began setting casing. 7x20*threaded steel casing. Drive shoe.Drove 120' of casing, stopped for the day.

Any)

lengths of 6* diameter

Drillers arrive, welded 9' .section of leftover casing.Cement arrived ' ? :Drove casing to 125 feet. .Set packer et 124 feetstones in cement caused pump to seize. Took pump

, tried to grout butapart, cleaned.

reassembled. Tried to pump screened cement but pump seized again.Cement truck left. Took pump apart, couldn't reassemble.Left for the day.Drillers arrive.Completed presure grouting 25 'bags of cement. Nosurface. Pulling packer* cement on 2* pipe. 50'73' b.g.l. when lowering bit into holes. Cut offstick up of 2 feet. Casing to 125 feet.Completed drilling to 175 feet.Completed developing well for. two hours.

* .-;. | ;

Cuttings: . ; .

Geologist: John RobertsOther Persons on -Site:

',

sign of it at theb.g.l. Hit cement et2* of casing, final

A

Weather

clear, mild

hazy, hot

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J0"SATTERTHWAITE ASSOCIATES, INC.11 North Fn/9 Points Road sneer *o.———3—————————— or —

WEST CHESTER. PENNSYLVANIA 19380 JHR(215) 692-5770 CALCULATED »Y——*_________ DATE.

CHECKED BY ______________________ OATt

SchematicSCALE ___________________________

———————— 0 —————————————————————

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DRILLING ADMINISTRATION* . ' " • . ' ' . • X . :...

Project: ''-' WellNovak ,

Well Contractors odenhetoer

Address s Allentown, Pennsylvania

Name of Drillers Bob \ Helper (s)

Rigs Number Hake I-R

Phones 791-4333

Ronny. CaneBar

Model Lengths 25

Reference Points roughly midway between 1A and the original Well fi

Casing c Grouting Summary(Amounts, Lengths, diameters) see below

Diary of Drilling

Date

5/6/85

1

y

\

5/7/85

J*

Time

8:15 e.n.9:009:5010:30

1:45 p...

2:20 p.a.3:10 p...6:25 p.m.9:00 a...

12:00 noon1:00 p._.4:30

What Was Done fi (Problems if

No drillers on cite.Drillers arrive, begin setting upBegin drilling

Any)

Rock at 19 feet, drilled to 39 feett stopped to set casing- 2 x 20' lengths of 6* threaded steel casing• drive shot at bottom • '- packer set at 36'Pressure grouted 11 bags (96 IDS) of Type 1A ceaent to within 3* of thesurface. When packer was pulled, it had ceoent on 5" of the pipe aboveit. Pecker held good soil, well is grouted tight.Broke for lunchBegan drilling again.Drilled to 125 feet. Stopped for the day.Drillers arrive. Begin developing well.Additional 2* of casing threaded onto existing 40Locking cap. • ••Drillers leave site. 'Grouting crew arrives. Backfill hole with stoneGrouting crew leaves.

- i '

t

Cuttings si . . :

Geologists John RobertsOther Persons on Sites ^ Novak, Sr.

. Frank Yourga

.

Drove casing to 39 feet.

feet.

to approximately 110 feet.

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+—1.75 Top of 6" protective casing+~1.70 Top of PVC riser pipe

0 Ground Surface j

-2.0 Base of Footing

NOTE: Annulus above bentonite seal filledwith grout. Overburden t yellow-brownclay rich silt and fine sand with some iquartz fragments.

-4.0 Bedrock surface '

-44.0 Void filled with mud (.2 ft)-44.5 Base of 8 inch borehole-45.0 Base of casingNOTE: Bentonite seal bridged on collar-50.0 Centering collar ( 1 f t )

Bedrock: Dark gray-blue dolomite withsome white calcitic crystals

NOTE: Open annulus between bridged bentoniteand bentonite which is in place at topof gravel pack

-79.0 Centering collar (1 ft)

-86 to 87 Void filled with mud-96 to 101 Decomposed rock

-98.0 Static water level at end of 1/22/33

-112.0 Top of gravel pack-118.0 Top of .010 slot PVC screen

-138.0 Base of screen

-142.0 Base of 6 inch borehole

NOVAK LANDFILL: MONrTORlNG WELL NO.1C DETAIL

^ WALTER B. SATTtRTH WATTE ASSOC, INC ££ISn i°SU

DRILLING ADMINISTRATION,. ,, .;-••.; ••, i^ ' '

Project: WellI ; Novek

Well Contractor: Odenheiner

Address: Allentown, Pennsylvania Phone: 791-4353

Name of Driller: Bobby Helper(s) GregBar

Rig: Number Hake I-R Model Lengths 25*

Reference Point: 90-100 feet north of pole on edge of berm, 150 feat northwest of old Well 12

Casing & Grouting Summary(Amounts, Lengths, diameters) see below .

Diary of Drilling

Date

4/16/85

y

4/17/85

4/19/65

{)

Time

9:00 a.a.10:55 a.a.

12:00 noor

4:30 p.a.10:30 a.a.

4:00 p.a.

What Was Done fi (Problems if Any)

Setting up on site. "Drilled to 34 feet, began setting casing.- 2 x 20' lengths 6* diameter steel casing, threaded together• drive shoe «t bottom- drove casing to 32 feet, drove hard. Cut off 4' of casing.- probe read no water at bottom of hole.Began grouting.- 8-1/2 bags (94 Ibs) Type IA cement, pressure grouted from 34' toground level

- drove casing to 32.5 feet, wouldn't advance farther- cut off 1 foot of casing for final stick up of 2.5 feet.Stopped for the day.Completed drilling to 175 feet, developed well for 1/2 hour.Screw cup in place. •Locking cap installed. ,

- ' . : ' - . !

i

i

Cuttings:

Geologist: John Roberts, Rick WroblewsklOther Persons on Site: Joe Manduke (PA DER)

' ''" Louis Novak. Sr.

A

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WALTER B. SATT|Hfl}WAIU ASSOC1AFCS. INC.

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56

ATTACHMENT C

7.0 PHASE ONE BASELINE ECOLOGICAL EVALUATION

(Note: Sections 7 through 9 of the November 1991 RI Report submittalsubsequently be renumbered Section 8 through 10, respectively)

GERAGHTYff MILLER.INC. & ft 2 0 8 f g J

7.0 PHASE ONE BASELINE ECOLOGICAL EVALUATION

7.1 OVERVIEW

Ecological characteristics of the NSL were evaluated during the RI in accordancewith the approved Work Plan (Geraghty & Miller, Ine, June 1989) and the approvedAddendum to the Work Plan/Field Operations Plan (Geraghty & Miller, Inc. November1990.) The ecological evaluations conducted for the NSL were consistent with componentsof a Phase One Baseline Ecological Evaluation; which is the first "phase" of an ecologicalassessment

According to USEPA Region in (USEPA, 1992), developed subsequent to theapproved Work Plan and Field Operations Plan for this RI/FS, a Phase One BaselineEcological Evaluation consists of six components. These components are as follows:

1) Cover type map detailing habitats within a 0.5 mile radius of the facility. Thismap would detail major vegetative communities, wetlands, streams andsignificant habitats (e.g., spawning areas, rookeries, etc.). The map would beprepared using aerial photographs, topographic maps, and soil maps followedby ground training.

2) Identification of special resources/habitats within a 2 mile radius of the site.The U.S. Fish and Wildlife Service, in addition to any other pertinentgovernment agencies should be contacted regarding any known resourcesand/or critical habitats in the vicinity of the site.

3) Identification of typical vegetation in each major community and the wildlifespecies that would most likely utilize these communities.

4) Documentation of any existing stress (if any) placed on the habitat/wildlifethat is directly related to on-site waste disposal activities.

GERAGHTY ff MILLER. INC. " A R 2 0 8 I 5 8

7-2r- '/;*( • "' ;

S) Identification of any fish and other wildlife related Applicable or Relevantand Appropriate Requirements (ARARS), per EPA Risk AssessmentGuidance for Superfund Volume IT Environmental Evaluation Mar ia ,March 1989.

6) Sediment samples with co-located surface water samples should be collectedfrom marsh areas (wetland areas), drainage areas, tributaries and otherdepositional areas identified as potential surface runoff or discharge migrationpathways.

The following sections discuss the activities undertaken during the RI which satisfy thecomponents of the Phase One Baseline Ecological Evaluation.

COVER TYPE MAP

Several maps were prepared to present the ecological features identified in thevicinity of the NSL. These maps, which include streams, fioodplains, wetlands, surface waterfeatures of the site and major vegetative communities, are discussed in the followingsections.

7.2.1 Streams,. Floodplains and Nationally Mapped Wetlands

Figure 4-3 presents the streams located within a three mile radius of the NSL. Theseecological features include Jordan, Cbplay, and Cedar Creeks; however, only Jordan Greekpasses within one-half mile of the NSL. Coplay Creek and Cedar Creek are respectivelyapproximately 0.75 miles north and four miles south of the landfill, and are outside of thearea of interest for all practical purposes. There were no streams, perennial or intermittent,identified on NSL property.

GERAGHTY c? MILLER, INC. A R 2 0 8 I 5 9

7-3The extent of the 100-year floodplains of Jordan Creek, Coplay Creek, and Cedar

Creek, are also indicated on Figure 4-3. The 100-year flood plain boundary of Jordan Creek;.as indicated on the USGS map, is several hundred feet south of River Road near LappRoad, and approaches immediately south of River Road in line with the western siteboundary. On the Federal Insurance Administration map, the 500-year flood plain boundaryis indicated as being somewhat wider; however, both the 100 and 500-year flood plainboundaries are at or south of River Road along the reach of Jordan Creek which passes bythe site. Because of the topography of the area, the NSL is extremely unlikely to beimpacted by Jordan Creek floodwaters.

Also depicted on Figure 4-3 are nationally-mapped wetlands within a three-mileradius of the NSL. No such wetlands were identified on the NSL.

7JL2 Site Surface Water Features

Surface water and drainage features identified at the site are shown on Figure 3-6. ^This figure illustrates the locations of the constructed southwest and southeast storm-waterretention basins, as well as several areas of standing water resulting from poor surface-watermanagement practices. The larger areas of standing water on the site are located behindthe maintenance building, over the central portion of the Old Mine Area, and on theeastern portions of the Surface Fill Area.

733 Wetlands and Ma|or Vegetative Communities

A preliminary wetlands evaluation was conducted at the NSL on March 11, 1992.The evaluation was in response to discussions held during a meeting with the USEPA onFebruary 13, 1992 and was proceeded by a walkover of the site with Robert S. Davis(USEPA), Mark Travers (de maximis, inc.) and Doreen Sousa (Geraghty & Miller, Inc.) onFebruary 19,1992.

GERAGHTY & MILLER. INC. AR208I60

7-4The purpose of the walkover was for the USEPA to generally evaluate the NSL with

respect to wetland and wildlife habitats and to determine the need for additional wetlandinvestigation. The findings of the walkover are summarized in a memorandum to Cesar Lee(USEPA) from Robert S. Davis dated February 20, 1992. An agreement was readiedbetween Mr. Travers and Mr. Davis that the preliminary wetland delineation would beconducted. The preliminary wetland assessment was conducted in accordance with Mr.Davis' memorandum and induded the identification of wetland areas based on currentdepths to ground water and vegetative growth guidelines outlined in the 1989 United StatesDepartment of Agriculture Federal Manual for Delineating Wetlands.

723.1 Methodology of the Preliminary Wetlands Evaluationi t , '

For an area to be classified as a wetland, three essential characteristics must bepresent: (1) wetlands bydrogeology, (2) hydric soils, and (3) hydrophytic vegetation. Dueto the season the field program was conducted, it was agreed that a preliminary wetland

\, evaluation would be conducted based on current ground-water conditions and obviousvegetation encountered. The methodology used during the preliminary wetlands delineationindude the following:

1. Ine area was inspected for evidence of wetland hydrologic conditions such assurface-water ponding, inundated soils, and other hydrogeologic indicators;

2. Plant community composition was examined Due to the season in which thefield program was conducted, only obvious plant community spedes wereidentified (i.e. phragmites, cattails, shrubs, etc.); and,

3. General site topography, man-made features, disturbances, and generaldrainage patterns were noted.

GERAGHTY6? MILLER, INC. /)R208f6I

7-51232 Findings of the Preliminary Wetlands Evaluation

Several small areas were classified as wetlands during the preliminary delineation;these areas are shown on Figure 7-1 (Figure 7-1 will be provided with the revised RIreport). The dominant vegetation encountered was phragmites and cattails; other vegetationrecorded induded grasses and shrubs. Depth to ground water was noted and theapproximate area of the wetland was measured. The data collected at each of thedesignated wetland areas are summarized in Table 7-1.

Based on the size of the wetlands, the amount of disturbance encompassing thewetlands, and the vegetation present, most of the wetland areas identified during thispreliminary assessment appeared to have minimal habitat value. The areas with minimalvalue are located on the landfill and were the result of disturbed drainage patterns formingponded water.

Three areas were identified as having a potential for supporting a valuable habitatThese areas are designated Area 1, 8, and 20. The areas are located along the perimeterof the landfill and will be least effected during cap construction, if any, on the landfill.

73 SPECIAL RESOURCES/CRITICAL HABITATS

A biological screening of the project area was conducted to identify biological spedesof concern which exist on or in the vicinity of the site and which could potentially beaffected by site activities. The specific purpose of the screening was to ascertain thepresence or absence of such spedes, and determine those which would warrant considerationas part of the Baseline Risk Assessment, if any.

The biological screening was accomplished through informal contacts with federal andstate agendes with statutory authority for the various spedes, and subsequent formal letters

GERAGHTY & MILLER. INC ^ R 2 0 8 I 6 2

• •• V $$$ 7-6

of inquiry. The following agendes provided information on listed threatened or endangeredspedes, and/or unique or critical habitats in the site vicinity:

Agency Jurisdiction

1. United States Department Birds, mammals, fishes,of the Interior, Fish and amphibians, reptiles, otherWildlife Service

2. Pennsylvania Game Birds and mammalsCommission

3. Pennsylvania Fish Fishes, amphibians, reptiles,Commission aquatic organisms

4. PADER, Bureau of Forestry Plants

5. PADER, Pennsylvania Pennsylvania's rare, endangered orNatural Diversity Inventory otherwise significant plant and(PNDI) in conjunction with animal spedesThe Nature Conservatory

The finding? of the biological screening are summarized in the following sections.

73.1 United States Department of the Interior

The United States Department of the Interior, Fish and Wildlife Service hasindicated that "Except for occasional transient spedes, no federally listed or proposedthreatened or endangered spedes under [its] jurisdiction are known to exist in the projectimpact area. Therefore, no Biological Assessment or further Section 7 consultation underthe Endangered Spedes Act., is required with the Fish and Wildlife Service." (March 7,1990 letter provided in Appendix D).


7-7732 Pennsylvania Game Commission ,/

The Pennsylvania Game Commission has "determined that [the project] is not locatedwithin a quarter mile of the boundary line of any State Game Lands". The Commission hasalso "determined that except for occasional transient individuals, the proposed project is notlocated within an area which is the habitat of an endangered or threatened spedes of birdor mammal protected by the Federal Endangered Spedes Act of 1973 or recognized by thePennsylvania Game Commission. Furthermore, [the Commission] do[es] not anticipate anylong-term adverse impacts to any critical or unique habitats as direct result of this project"(March 16,1990 letter provided in Appendix D).

733 Pennsylvania Fish Commission

The Pennsylvania Fish Commission has indicated that "Presently, none of the fishes,amphibians, or reptiles [it] list[s] as endangered or threatened are known to occur at or inthe immediate vicinity of the study area, or in other areas that would be potentially -/impacted by this landfill." (March 15,1990 letter provided Appendix D).

73A PADER Bureau of Forestry and PNDI»^

The only spedes of special concern identified by the PADER Bureau of Forestry,through the PNDI, are three types of plants which have been reported from two to threemiles outside the project area. These plants are as follows: Sarvia reflex (Lance-leavedsedge; Carex meadii (Mead's sedge); and Solidago rigida (Hard-leaved goldenrod). (August30,1990 letter provided in Appendix D).

7-3.5 Other Ecological Habitats of Concern

Under the Pennsylvania Water Quality Standards rules and regulations adopted byPADER (PADER, 1988), Jordan Creek is dassified as a stream with protected uses. These ,-

GERAGHTY MILLER. INC. AR208I61*

7-811 •'„ if*- '•".'•j'3.:

protected uses are trout stocking (TSF) and migratory fishes {MF). The TSF category isdefined as the "maintenance of stocked trout from February 15 to Jury 31 and themaintenance and propagation of fish spedes and additional flora and fauna which areindigenous to a warm water habitat* During the RI field programs, trout fisherman havebeen observed in the reach of Jordan Creek which passes by the site. The MF category isdefined as the 'passage, maintenance and propagation of anadromous and catadromousfishes and other fishes which ascend to flowing waters to complete their life cycle." Theseprotected uses, and applicable water quality standards and criteria, should be considered indeveloping effluent limitations on any discharges to Jordan Creek which may be connectedwith the landfill remediation.

7.4 TYPICAL VEGETATION AND WILDLIFE

This exercise was not required by the approved Work Plan or by discussions heldwith the USEPA during the February 13, 1992 meeting. However, in an effort to addressthe intentions of this task of the Phase One Baseline Ecological Evaluation, observationsmade during the previously discussed site walkover and preliminary wetlands evaluation areincorporated herein.

Typical mammalian spedes seen or noted as present at the NSL indude deer,raccoons, possums, rabbits, voles, mice and woodcmicks. Typical bird spedes seen or notedas present at the NSL indude robins, chickadees, crows, mourning doves, red tailed hawk,slate colored juncoe, starlings, and sparrows. These mammalian and bird identifications arebased upon Mr. Robert S. Davis' (USEPA) observations made February 19, 1990 during thesite walkover.

Based upon the preliminary wetland evaluation conducted at the NSL on March 11,1992, typical vegetation encountered at the site indude phragmites, cattails, grasses andshrubs.

GERAGHTY & MILLER, INC.

7-9Our understanding, based upon the February 13, 1992 meeting and subsequent ,

discussions with the USEPA, is that this additional work fully responds to the USEPA'scomments on the draft RI Report, and that no further efforts are necessary regarding thisissue.

7.5 EXISTING STRESS ON HABITAT/WILDLIFE

This exercise was not required by the approved Work Plan, Field Operations Planor by discussions held during the February 13, 1992 meeting with USEPA. Ourunderstanding is that no further efforts are necessary to address this issue.

7.6 FISH AND WILDLIFE RELATED ARARS

The following potential Applicable and/or Relevant and Appropriate Requirementswere identified for the NSL:

Citation Requirement -S

Endangered Spedes Act of 1973 (16 Action to conserve endangered spedesUSC 1531 et set); 50 CFR Part 200, 50 or threatened spedes, includingCFR Pan 502 consultation with the Department of the

Interior.*»

Wild Resource Conservation Act, PJL Action to conserve endangered spedes547, No. 170,32 P.S. 5301 - 5314 or threatened spedes, induding

consultation with DER Bureau ofForestry.

Fish and Wildlife Coordination Act (16USC 661 et seq.); 40 CFR 6302 Action to protect fish or wildlife.

PA SWMA, Act 97 Ch. 268.50(b)(ll) Prohibition of adverse impacts onspedes or habitat

GERAGHTY & MILLER, INC. 1K208I66

7-10Citation Requirement

Fish and Wildlife Conservation Act of Requires States to identify significant1980 PX. 96-366,16 USC 2901, et seq. habitats and develop conservation plans

for these areas.

Federal Water Pollution Control Act Establishes numerical criteria for the(dean Water Act) P.L. 92-500,33 USC protection of fresh and salt water plants1251 et seq. and «nimak and their habitats, covering

both acute and chronic.

The status of these potential ARARs will be reviewed in detail in the appropriatesections of the FS.

7.7 SEDIMENT AND SURFACE WATER SAMPLING

In this section, data and discussions are presented regarding on-site and off-sitesediment and surface water sampling which was conducted during the RL This section isin response to the sixth component of the Phase One Baseline Ecological Evaluation.

7.7.1 On-Site Sediment and Surface Water

During the RI, six pairs or surface water/sediment samples and one additionalsediment sample were collected from the storm-water retention ponds, drainage swales,and standing water areas on the NSL. The following sections discuss the sediment andsurface water sampling, as well as the analytical results of the sample testing.

7.7.1.1 On-Site Sediment and Surface Water Sampling

The sediment and surface water sampling was conducted in accordance with theapproved Work Plan and FOP. The sample locations are shown on Figure 3-6 anddescribed as follows:

GERAGHTY c? MILLER. INC. AR208 I fi7

7-11Sample Location . jDesignation Sample Location Description

SW/SD-01 Standing water (pond) downslope of the maintenance building andstorage area: at the outlet point where the water drains toward thenorth to a south flowing drainage swale at the western siteboundary.

SW/SD-02 Southwest storm-water retention pond: in the northern basin, at theedge of the spillway dike into the southern basin.

SW/SD-03 Southeast storm-water retention pond: at the inlet point where thewater in the north to south flowing drainage swale on the easternpart of the site enters the pond.

SW/SD-04 Standing water (pond) in the Old Mine Area in the north-centralpart of the site: at the outlet point where water drains into thenortheast flowing drainage swale.

SW/SD-05 North to south flowing drainage swale at the western site boundary:at an area of intermittent ponding within the swale, which receivesdrainage from the Surface Fin Area. The sample location was just /upstream of an off-site drainage pathway.

SW/SD-06 Standing water (pond) on the northeast part of the site, whichreceives drainage from the Surface Fill Area: at the outlet pointwhere water drains toward the north to south flowing drainage swaleon the eastern part of the property. The pond is immediatelyupstream of an off-site drainage pathway.

LH/SS-07 Leachate seep from the Surface Fill Area: this seep joins the northto south flowing drainage swale at the western site boundary whichends at the southwest storm-water retention pond.

SD-09 Off-site drainage pathway on the wooded slope southwest of thesite: this drainageway appears to begin in an area where theearthen dike at the southern site boundary was breached andreplaced with piled boulders. The drainage channel is discernableto River Road, but not beyond.

The individual samples collected and the parameters analyzed are summarized inTable 3-1. The samples were collected in pairs and were designated as surface

GERAGHTYff MILLER.INC. AR208 I 68

7-12.

water/sediment (SW/SD). Samples SW/SD-01 through SW/SD-06 were collected onApril 11 and 12,1990.

Sampling at the SD-09 location was postponed to await a potential opportunity forsampling storm water in this off-site drainage channel Tnis opportunity was neverrealized and eventually, on June 27,1990, a sediment sample alone was collected TheSD-9 location was resampled on July 26,1990 due to VOC holding time exceedances bythe laboratory.

At each surface sampling location, the surface-water sample was collected first,followed by the sediment or soil sample. During fluid sampling, care was taken tominimize disturbance to the underlying materials. The fluid samples were collected withdedicated glass flasks supplied and pre-deaned by the laboratory. The sediment sampleswere collected with stainless-steel trowels. The samples were transferred directly intolaboratory-supplied containers. The containers for all parameters except VOCs werepre-preserved in the laboratory. The samples were immediately placed in iced coolersand shipped by overnight carrier to the laboratory. Chain-of-custody procedures werefollowed. -

The surface samples were analyzed for TCL VOCs, TCL semi-VOCs, TAL metalsand inorganics. The 12 ground-water chemistry parameters were analyzed for, and fieldanalyses of pH, temperature, and specific conductance were performed on, the fluidsamples. Table 3-4 provides the results of the field analyses; and Table 5-3 through 5-9provide the results of the laboratory sample analysis.

For quality control purposes, field blanks were collected by transferringlaboratory-supplied blank water into the flask (for water) and over the trowel (for soil).A trip blank sample was submitted along with the samples on each day when sampleswere collected for TCL VOC analyses.

GERAGHTY 6? MILLER. INC. 4 R 2 0 8 / 6 9

7-13

7.7.1.2 On-Site Surface Water Analysis

As described in Section 3.7, six surface-water points on the landfill property weresampled. The analytical results for VOCs in the surface-water samples are presented inTable 5-3. The results indicate that TCL VOCs were not present in the surface-watersamples. The data set is characterized by trace positive results for several compounds(at or below 5 ug/L), all of which are qualified as suspect due to blank contamination.The samples from the pond in the Old Mine Area (SW-04), and west of the Surface FillArea (SW-05) exhibited low levels of unknown VOC compounds (7 to 33 ug/1).

The analytical results for semi- VOCs in the surface-water samples are presentedin Table 5-5. The results indicate that TCL semi- VOCs are also not present in thesurface water. The single positive TCL semi-VOC result was for di-N-butylphthalate (15ug/L in Sample SW-05). This compound is also a common laboratory/field contaminant,which has frequently been qualified as such throughout the project data set TCLpesticides and PCBs were not detected in the surface water samples.

The analytical results for TAL metals and inorganics in the surface-water samplesare presented in Table 5-7. Several trace metals (antimony, arsenic, beryllium, selenium,silver, and thallium) were not detected. Others, including cobalt, mercury, and vanadiumwere detected only in the standing water in the Old Mine Area (SW-04). In comparisonto the other sampling locations, the standing water in the Old Mine Area also exhibitedhigher concentrations of other metals which were characteristic of the landfill leachate,inducing barium (790 ug/L), cadmium (26.4 ug/L), chromium (20.8 ug/L), copper (359ug/L), lead (60.1 ug/L), nickel (374 ug/L), and zinc (762 ug/L). Although these resultsindicate that this standing water has been affected, the effect has been slight in terms ofthe magnitude of the trace metal concentrations. The standing water hi the Old MineArea also contained the highest levels of iron (92,000 ug/L) and manganese (3,820ug/L). The relative contribution of iron and manganese from the landfill waste massand from natural components of the materials in this old iron mining area is undear.

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7-14•? •** . . gWf--

The ponded water in the drainage swale near the western part of the Surface Fill Areav /- (SW-05) and the pond near the eastern part of the Surface Fill Area (SW-06) also

exhibited relatively high levels of iron (3,110 and 8,900 ug/L) and manganese (2£00 and540ug/L).

7.7.13 On-Site Sediment Analysis

As described in Section 3.7, the surface sediments sample set was comprised ofseven samples. The analytical results for VOCs in the surface sediments are presentedin Table 5-4. This data indicates that 31 of the 34 positive results for TCL VOCs in thesix sample sediment set collected hi April 1990 (SD-1 through SD-06) are qualified dueto laboratory blank contamination. The qualified results are not consideredrepresentative of actual conditions, and VOC constituents appear to be present at onlyone of the sampled sediment locations (SD-06 collected from the pond on the northeastpart of the site). The low total TCL VOC concentration of 23 ug/kg detected in this

i . sample was comprised of three aromatic constituents: chlorobenzene (4 ug/kg),ethylbenzene (8 ug/kg), and xylene (11 ug/kg). TCL VOCs were not detected in thesediment sample (SD-09) collected from the southwestern off-site drainageway in July1990.

The analytical results for semi-VOCs in the surface sediments are presented inTable 5-6. The results indicate that PAHs were present in sediments in the southweststorm-water retention pond, the sediments in the standing water in the Old Mine Area,and in the sediments in the pond on the northeast pan of the site. The sediment samplefrom the southwest storm-water retention pond (SD-02) exhibited a total PAHconcentration of 6,509 ug/kg, comprised of thirteen individual PAH constituents, whichwere detected at concentrations from 49 to 820 ug/kg. The sediment sample from thestanding water in the Old Mine Area (SD-04) exhibited a total PAH concentration of872 ug/kg, comprised of seven individual PAH constituents, which were detected atconcentrations from 82 to 210 ug/kg. In the sediment sample from the pond on the

GERAGHTY tf MILLER, INC. /) ft 2 Q Q \ 7 I

7-15northeast portion of the site (SD-06), a total PAH concentration of 431 ug/kg wasdetected, comprised of six individual PAH constituents at concentrations from 58 to 110ug/kg. A trace of one PAH, fluoranthene (49 ug/kg), was also detected in the sedimentsample from the area of standing water behind the maintenance building (SD-01).

Other than PAHs, the analytical results for the sample set do not indicate thepresence of other TCL semi-VOCs in the on-site surface sediments,Bis(2-ethylhexyl)phthalate was detected in several samples; however, the positive resultsfor this compound were qualified as suspect due to blank contamination. Hexadecanoicadd was tentatively identified in the on-site samples (290 to 1,600 ug/kg). The samplesfrom the standing water in the Old Mine Area and from the pond on the northeast panof the site exhibited concentrations of unknown hydrocarbons (240 to 1,150 ug/kg). Allof the samples also contained unknown semi-VOC constituents; TCL pesticides andPCBs were not detected in the sediment samples.

Di-n-butylphthalate and batylbenzylphthalate were the only TCL semi-VOCs /detected in the sediment (soil) sample from the off-site drainage pathway southwest ofthe landfill (SD-09). Both phthalate results were qualified as suspect due to blankcontamination. The sample also exhibited unknown hydrocarbons (4,090 ug/kg) andconcentrations of unknown compounds (total 16,580 ug/kg).

The analytical results for TAL metals and inorganics hi the surface sediments areprovided in Table 5-8; the concentration ranges are summarized in Table 5-23. Ingeneral, no location appears to exhibit metals concentrations that are significantlyelevated and indicative of degradation.

7.72 Sampling of Jordan Creek Sediments

The Work Plan and FOP induded two "decision trees", which outlined a series ofsteps of evaluation based on the 1990 RI findings prior to developing a sampling


7-16/ , i}"-< "i\'

program for Jordan Creek. The first decision tree addressed the sampling of surfacewater, and the second decision tree addressed sampling of sediments. The reason for theseparation of the two decision trees was related to the timing of possible releases.

The decision tree addressing surface-water sampling called for surface-watersampling of Jordan Creek in the event that the 1990 RI reconnaissance observedevidence of existing surface-water or ground-water releases to Jordan Creek. The 1990RI reconnaissance results indicated no evidence of such present releases. Therefore,surface-water samples of Jordan Creek were not taken.

The decision tree addressing creek sediment sampling called for sampling ofJordan Creek sediments in the event that the 1990 RI reconnaissance discoveredevidence of past as well as apparent releases of sediments from the NSL to JordanCreek. A number of interrelated RI observations and data suggested the probability ofpast incidences of surface-water runoff in a southerly direction from the landfill whichmay have contained some site-related constituents. Given this possibility, it was notconsidered possible in the absence of hard data to demonstrate a lack of effect on thesediments in Jordan Creek. Therefore, six samples of Jordan Creek sediments werecollected on March 21 and 22,1991. The creek sediment sampling stations are asfollows:

Sample Location Sample LocationDesignation Description

SD-11 Upstream; near Bartholomew residenceSD-12 East of Staff Gauge SG-1SD-13 South of West Site BoundarySD-14 South of Power Line Right-of-WaySD-15 East of Staff Gauge SG-3SD-16 Downstream; west of Guth Covered Bridge

The sediment sampling stations were spaced along an approximate 4300-foot reach ofJordan Creek south of the landfill. The objective in determining Jordan Creek sediment

GERAGHTY & MILLER, INC. /J ft^ Q Q I j *

7-17sample locations was to obtain samples, where possible, from areas of deposition in thecreek. These areas were not easily located as the bottom of Jordan Creek is ladened-with rocks and cobbles. Areas of deposition were generally found, however, to be in themiddle of the creek where changes in creek bed gradients resulted in sedimentdeposition. The locations of all six samples were evaluated and agreed upon, in thefield, by representatives of Geraghty & Miller and Dynamac. The locations of thesediment sampling stations are shown on Figure 3-6. These locations were recorded bytheir relation (azimuth and distance) to a permanent reference point such as a bridge ora house. Sketches recording these locations are provided in Appendix T of the RIReport

A 2-inch diameter by 2-foot long split-barrel sampler threaded to a one- or two-foot drive bar was used to collect the samples. The sampler was driven with a sledgehammer one to two feet into the stream bottom to obtain samples representative of thesediment column. The creek sediment samples were transferred from the split-barrelsampler into laboratory-supplied containers. A field blank sample (equipment rinsate)was collected by transferring laboratory-supplied blank water through the sampler. Thesamples were immediately placed in iced coolers, and shipped by overnight carrier to thelaboratory. Chain-of-custody procedures were followed.

The sediment samples collected from Jordan Creek and the respective analyticalparameters are summarized in Table 3-1. The samples were analyzed for TCL semi-VOCs (add and base/neutral extractables) and TAL metals and inorganics. Theseparameters were selected since the concern was potential effect from past surface-waterreleases, as opposed to releases from the ground water.

7.73 Jordan Creek Sampling Analysis

The analytical results for semi-VOCs, and metals and inorganics in the JordanCreek sediment samples are presented in Tables 5-10 and 5-11, respectively. Three TCL

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7-18, semi-VOC constituents were detected in one or more of the sediment samples. The five

positive results for di-n-butyl phthalate, both upstream and downstream, were qualifiedas suspect due to blank contamination. A trace of naphthalene (61 ug/kg) was detectedat background location SD-12, The presence of this petroleum hydrocarbon componentcould be from a non-specific source such as highway runoff. Bis(2-ethyihexy|)phthalatewas detected in all six samples; however, only the results for the two backgroundlocations (SD-11 and SD-12) and for the point south of and aligned with the western siteboundary (SD-13) were not qualified as suspect The bis(2-ethylhexyl)phthalateconcentration detected at SD-13 (2£00 ug/kg) was higher than at the two backgroundsamples (37 and 86 ug/kg). The PAHs found in the on-site soils at points of leachateseepage and in the sediments of the southwest storm-water retention pond and otherponds at the landfill were not detected in the Jordan Creek sediment samples. As such,the single comparatively elevated result for bis(2-ethylhexyl)phthalate is not an indicationthat the creek at this location has been affected by releases from the landfill.Furthermore, bis(2-ethylhexyl)phthalate is a common laboratory contaminant

The concentration ranges of TAL metals and inorganics identified in the JordanCreek sediment samples are presented in Table 5-23. In general, the concentrations inthe adjacent and downstream samples were comparable to those found in the upstreambackground samples. Metals and inorganics that were not detected in the sediments atthe background locations (mercury, selenium, silver, sodium, thallium, and cyanide) werealso absent in the sediments adjacent and downstream of the landfilL

Based upon a memorandum to Cesar Lee from Dynamac (Justification forAdditional Sampling of Jordan Creek, dated February 26,1992), it appears that concernsregarding the potential effects of the NSL on Jordan Creek are the result; of detectedconcentrations of lead in Jordan Creek sediment samples.

All of the lead concentrations detected in the Jordan Creek sediment samples,with the exception of the highest detected concentration, fall within one standard

GERAGHTY tf ,MILLER, INC. A R 2 0 8 I 7 5

7-19deviation, or the 68 percent confidence interval, for lead content of surficial materials inthe Eastern United States (Hansford T. Shaeklette and Josephine G. Boemgen, FfgmfnfConcentrations in Soil and Other Surficial Materials of the Conterminous United States,U.S. Geological Survey Professional Paper 1270,1984). This confidence interval rangesfrom 72 ppm to 273 ppm. The highest detected concentrations of lead (31.1 ppm) fallsjust outside of this confidence interval, but falls well within the 95 percent confidenceinterval which ranges from 3.7 ppm to 532 ppm. Based upon a more location specificevaluation of the regional lead content of surficial soils, the same reference indicates thatlead data specific to eastern Pennsylvania typically exhibited lead concentrations greaterthan 30 ppm. Therefore, the concentrations of lead detected in Jordan Creek sedimentsamples are dearly within concentrations expected in naturally occurring materials and itis unlikely that they are the results of influences from the NSL. Also, all of theconcentrations of lead detected in on-site sediment samples were below the 31.1 ppmdetected in the Jordan Creek sediment sample; therefore disputing any correlationsbetween the detection of lead in Jordan Creek sediment and the NSL,

7.8 SUMMARY AND CONCLUSIONS

7.8.1 On-Site Surface Water and Sediments

Surface water sampled at the NSL does not contain TCL VOC or semi-VOCs,The surface water samples collected from six on-site locations contain metalconcentrations typically elevated above background ground-water quality. PAHs arepresent in sediments in the southwest storm-water retention pond, the standing water inthe Old Mine Area, the pond on the northeast part of the site, and the standing waterbehind the maintenance building. The sediment in the pond on the northeast portion ofthe site also contains traces of several TCL VOCs that are characteristic of the leachateseeps. The on-site sediments associated with surface-water drainage pathways whichwere sampled exhibited the presence of varying concentrations of tentatively identifiedand unknown semi-VOCs. The soil in the off-site drainageway southwest of the site does


« .- '' 7'20i not contain TCL VOCs or semi-VOGs, but does exhibit the presence of unknown semi-

VOCs. The standing water in the Old Mine Area appears to have been affected bymetals which were detected in the leachate seeps; however, the effect is slight in terms ofthe magnitude of the concentrations.

7&2 Jordan Creek

Since there are no defined drainage pathways from the NSL to Jordan Creek, andsince sediment samples obtained from Jordan Creek indicate that the creek has not beenimpacted by the NSL, it was determined in accordance with decision trees approved bythe USEPA that the NSL has not affected Jordan Creek. This determination, made withthe concurrence of USEPA, obviated the need for further sampling and analysis of creekmedia.

7£3 Conclusions

Based upon the ecological investigations conducted during the RI there has beenlittle to no affect on off-site ecological characteristics. Although waste disposal andexcavation practices have disturbed the original ecological setting of the NSL property,no available evidence demonstrates any significant effects to the current ecologicalcharacteristics of the site due to these practices.

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ATTACHMENT D

DEPTHS AND GEOLOGIC DESCRIPTIONSOF ON-SITE SEDIMENT SAMPLES

GERAGHTY 6? MILLER. INC. « H 2 0 8 f 7 9

DEPTHS AND GEOLOGIC DESCRIPTIONS OF ON-SITE SEDIMENT SAMPLES

Sample Location Depth IntervalDesignation _________ (feet) __________ Description ____________

NSL-SD-01 0.0 to 0.5 Clay and silt, orange-brown; some fine tomedium angular rock fragments, grey.

NSL-SD-02 0.0 to 05 Clay, orange-brown and silt, brown; someorganic material (i.e., reeds).

NSL-SD-03 0.0 to 05 Silt, brown with day, orange-brown; somesmall pebbles.

NSL-SD-04 0.0 to 05 Silt and clay, brown; some fine pebbles,with decayed vegetation.

NSL-SD-05 0.0 to 05 Silt and clay, orange; some decayedvegetation (i.e., reeds).

NSL-SD-06 0.0 to 05 Silt and day, olive green-brown, withdecayed vegetation.

NSL-SS-07 Surface Silt, decayed vegetation and soil, brownMaterial light grey to black.

NSL-SS-08 Surface day and silt, surface stained purple-Material black, beneath surface soil is brown.

NSL-SD-09 Surface day with some silt, well-sorted, veryMaterial loose, moist, reddish brown.

NSL-SS-10 Surface Clay and silt with little sand, medium toMaterial fine, moderately well-sorted, very loose,

moist, black and light brown.


ATTACHMENT E

GEOLOGIC LOGS FOR THEJORDAN CREEK SEDIMENT SAMPLES

ANDSKETCHES OF THE SAMPLE LOCATIONS

GERAGHTY & MILLER. INC A R 2 0 8 I 8 I

JORDAN CREEK SEDIMENT SAMPLE LOGS

Sample Location Depth IntervalDesignation _________ (feet) _________ Description

NSL-SD-11 0.0 to 1.0 day and fine gravel, brown.

NSL - SD-12 0.0 to 15 day and fine gravel, brown.

0.0 to 2.0 day and fine gravel, brown.

0.0 to 15 day and fine gravel, brown.

NSL-SD-13 0.0 to 03 Fine gravel

03 to 15 day and fine gravel

0.0 to 0.8 Fine gravel, brown.

0.0 to 15 Fine gravel, brown.

0.0 to 15 Fine gravel, grey/brown.day and fine gravel, brown.

0.0 to 15 Fine gravel and day.

NSL-SD-14 0.0 to 1.0 Fine gravel and clay, brown.

0.0 to 1.0 Fine gravelFine gravel and day, orange-brown.

NSL-SD-15 0.0 to 15 Fine gravel and clay, orange-brown.

NSL-SD-16 0.0 to 1.0 Fine gravel

0.0 to 12 day and fine gravel

0.0 to 15 day and fine gravel, coarse sand.

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LLER, INC.Environmental Services

LOCATION SKETCH

Wet!(s)_____ Project/No. MJnf.»t-fl? _______________ Page.

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£*& MILLER. INC.Ground- Water Consultants

LOCATION SKETCH

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AR206+6 5

HANNOCH WEISMAN / ((? 3 · 2021. 4. 10. · 07/25/91 Mark A. Travers Lisa Nichols 7 copies of the...

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