UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY …Suite 601 Knoxville, TN 37923 SUBJECT: Novak...

UNFTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 01

841 Chestnut BuildingPhiladelphia. Pennsylvania 19107

Office of Superfund Direct Dial (215) 597-8257SE Pennsylvania Remedial Section Mail Code 3HW21

Re: 3d, 3b

October 20, 1992

FEDERAL EXPRESSMr. Mark A. TraversSenior Project Managerde maximus, inc.9041 Executive Park DriveSuite 601Knoxville, TN 37923

SUBJECT: Novak Sanitary LandfillRevised comments on the "REMEDIAL INVESTIGATION REPORT11and the "FEASIBILITY STUDY".

Dear Mr. Travers,

Enclosed are three (3) copies of reports summarizing theresults of our revised comments to the "REMEDIAL INVESTIGATIONREPORT" dated June 1992 and the "FEASIBILITY STUDY" dated July 8,1992, both prepared by Geraghty & Miller, Inc.

These comments are the result of negotiations last weekconcerning your objections to our comments as stated in yourletter dated October 9, 1992. Though you did not specificallystate the sections affected by your objections, we later learnedthat you only objected to the ecological portion ("7.0" of theRI) as noted by the subscripts (2) in the RI and (4) in the FS.

In summary, the resolution was that all additional ecologicalfield investigation will be deferred to Pre-design, at which timea remedy would have'been selected and the study can focus onassessing the habitat impact of the remedy (ie., a maintenanceroad through habitat supporting wildlife resources). The resultsof the habitat impact assessment will be used to guidedevelopment and implementation of restoration of site ecologicalfeatures impacted by construction of the site remedy.

OR5GINM;Red:

Mr. Mark A. Travers 2 October 20, 1992

These revisions will supersede our comments dated September25 & 28, 1992. For ease of interpretation, enclosed are alsomarked up versions of the superseded comments. The ^ |irepresent modified text, the otrikoouta are deleted lexi:7"'and the[brackets] are rationale for deleting the text. We recommendthat you use similar procedures to highlight deviations to draftreports in the future in order to avoid the unfortunatemisunderstanding that occurred in Section 7 of the RI.

To expand on your letter, our May 26, 1992 comments was anmutually accepted modification to the Consent Order but it wasattempted in good faith to expedite our responses to help infinalizing a RI/FS. Unfortunately, Attachments C (Section 7) waspart of other Attachments to the responses which measuredapproximately 1/2 inch thick and its ramification was not fullyrecognized.

Lastly, enclosed are also marked-up versions of Tables 2-6 &1-4 from the FS which you resubmitted on September 22, 1992 as aresult of our teleconference on September 3, 1992 concerningthese Tables and Section 7 of the RI. These Tables were notpreviously submitted for review in any draft form and containsignificant inaccuracies which also must be corrected.

We hope these revised comments will satisfy your needs sincethey were generated at your request. You also indicated thatthey will resolve all objections raised in your October 9, 1992letter and enable you to follow up with a written response withinthe fourteen (14) days that adequately address our otherconcerns. We are equally confident that your response will bringthe RI/FS to an expeditious conclusion. Please call if you haveany questions.

Sincerely,

Cesar Lee (3HW21)Remedial Project Manager

Mr. Hark A. Travers 3 October 20, 1992

Attachments.' '"• '. t ' ' i!'

cc: R. Smith (3HW13)R. Davis (3HW13)J. Newbaker (3HW13)W. Walters (3RC21)C.K. Lee (3HW51)P. Flores (3AT11)M. Heffron, DynamacM. Mustard, PAOERJ. Kunkle, PADERL. Diamond, Hannoch Weisman

CL:cl/102092.NOV

OfllGINAL(Red)

Comments on the "REMEDIAL INVESTIGATION REPORTNOVAK SANITARY LANDFILLSOUTH WHITEHALL TOWNSHIP

PENNSYLVANIA'1 dated June 1992

September 25, 1992

SK305535

Comments on the "Remedial Investigation Report,Novak Sanitary Landfill" dated June 1992

TART P. OF CONTENTSSECTION PAGE NO.

AUTHORIZATION ................................................. 2

OBJECTIVES ...................................................... 2

1.0 COMMENTS ON "4.0 EXPOSURE CHARACTERIZATION" .............. 3

2.0 COMMENTS ON "7.0 PHASE ONE ECOLOGICAL EVALUATION" ....... 4

3.0 COMMENTS ON "8.0 PRELIMINARY IDENTIFICATION OFAPPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARs)" ...................................... 6

4.0 COMMENTS ON "APPENDIX A: PHASE ONE BASELINERISK ASSESSMENT1 ............................................ 8

5.0 COMMENTS ON "CHEMICAL DATA TABLES" ....................... 9

Mr. Marie A. Travers September 25,1992

ORIGINAL

Comments on the "Remedial Investigation Report, ~Novak Sanitary Landfill" dated June 1992 ,

AUTHORIZATION

Not Applicable

OBJECTIVES

Not Applicable

Mr. Mark A. Travert September 25,1992

flK305537

Comments on the "Remedial Investigation Report,Novak Sanitary LandfilP dated June 1992

1.0 COMMENTS ON "4.0 EXPOSURE CHARACTERIZATION"

COMMENTS ON "4.4 EXPOSURE DOSE CALCULATIONS"

Comments on "4.4.4 Leachate Seep Water and Associated Soil"

Comment No. 1

Page A-75

The assumption of incidental ingestion of 5 mg/d of surficial soil from the vicinity of leachateseeps is underprotective. The scenario should assume that, on days when these soils arecontacted, 100 mg of incidental ingestion occurs. '

Comment No. 2

Table A-50: Equations and Example Calculation for Inhalation Exposure to VOCs in ShowerWater

The result of the sample calculation for non-cancer effects should be 1.8e-04 mg/kg/d, not1.8e-05. This appears to be only a typo in the example, which does not affect the exposurecalculations. '

Comment No. 3

Table A-79: Risk Estimation Summary

...cancer risk to children is additive with that to adults. These risks should be combined. '

Comment No. 4

The table should contain a risk summary for a potential current off-site resident - child(analogous to that for an adult, shown third from the top on page 1 of the table). Althoughthe appropriate route-specific risks were presented in earlier tables, they were omitted fromthe summary table.l

Mr. Mark A. Traven September 25,1992

"K3G5538

(Red)

Commenu on the "Remedial Investigation Report,Novak Sanitary Landfill" dated June 1992

2.0 COMMENTS ON "7.0 PHASE ONE BASELINE ECOLOGICAL EVALUATION"

Comment No. 1

It is suggested that the investigator |p|§ discard all of Section 7 of the RI except for theportion related to endangered species, or Special Resources/Critical Habitats as referred toin the RI. They appear to have contacted the appropriate people in both state and federalgovernment regarding this aspect.2

It is recommended that the chapter be reorganized to include lists of flora and fauna foundon site and in the surrounding areas and describe the habitats existing in support of theseresources. Since it is a site demonstrating such diversity of habitat, an attempt should bemade to census and map populations against habitats and to carry out a i|i mpi|Hskassessment based upon specific losses that would be expected under" each remedial

Details regarding sfceaki¥;:i:f:W;W£W:W ° °also be made regarding habitat restoration

COMMENTS ON "7.7 SEDIMENT AND SURFACE WATER SAMPLING"[Deleted to clarify comment is in reference to "7.7"] Comments on "Jordan Creek samplingAnalysis2

Comment No. 2

It is inappropriate to utilize soil contaminant levels to evaluate the potential impact of these

COMMENTS ON "7.8 SUMMARY AND CONCLUSIONS"Comments on "7.83 Conclusions"

Comment No. 3

EPA does not agree with the conclusions reached in this section, specifically: "Based uponthe ecological investigations conducted during the RI, there has been little to no effect onoff site ecological Characteristics" and "(a)lthough ... practices (on site) have disturbed the... ecological setting ... no available evidence demonstrates any significant effects to thecurrent ecological characteristics ..." 2

We object to use of the term 'ecological investigations' as none was done to the best of our

Mr. Mark A. Travers September 25.1992

3R305539


knowledge. In place of this, the consultant used a reconnaissance site visit by a member ofEPA staff and a subsequent one-day visit by a site contractor. They have misrepresentedthe conversations and notes made by EPA staff as sufficient to fulfill the need for full floraand fauna Characterization as well as habitat evaluation. Since ecological investigations werenot carried out, it is obvious that evidence is not available to 'demonstrate any significanteffects'. [Deleted due to ecological risk assessment not required presently] You have alsofailed to carry out an ecological risk assessment which would have given them the neededinformation on which to base conclusions. 2

It is instructive to note at this point that the reconnaissance site visit demonstrated that avery desirable set of habitat conditions are present and improving at the site. A rich mixtureof uplands (open fields and immature forest), scattered wetlands (small pockets scatteredover the site with at least three larger and well developed areas) were noted. With such arich mixture, it would be difficult to complete a vegetation list during a one-day site visit.The one-day visit also showed a diversity of wildlife demonstrating that numerous wildlifereceptors are prevalent on site. 2

[Deleted due to ecological risk assessment not required presently] The •ecological assessmentis part of the site receptor characterization tasks needed for ecological risk assessment. Theoriginal RI Work Plan noted that human health, welfare and environmental assessmentswere to be carried out and, while that has been done for human exposure, it has yet to becarried out for ecological resources. 2

In conclusion, it is recommended that flora and fauna characterizations be completed alongwith the various habitats located in the area and viewed through the perception oflandscape. In this way, the ecological characterization can be viewed as a working wholerather than as individual parts. The vegetative cover should be described in terms ofacreage. [Deleted & Modified due no activities "off-site"] Ground truthing the wetlands andriparian areas off-site should-also be completed. The investigator relied solely on wetlandsmaps that should be used only as a point of departure. RemedialDl|s||i alternatives shouldbe developed in terms of protecting and enhancing the current habitat and landscapeconditions. 2

Mr. Mark A. Travers September 25,1992

Commenu on the "Remedial Investigation Report,Novak Sanitaiy Landfill" dated June 1992 v J

3.0 COMMENTS ON "8.0 PRELIMINARY IDENTIFICATION OF APPLICABLE ORRELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)"

Comment No. 1

The following Pennsylvania Chemical Specific ARARs must be included and addressed inthe Final Remedial Investigation Report for the Novak Sanitaiy Landfill Site:,

• The Clean Streams Law of Pennsylvania, Act of June 22, 1937, P.L. 1987, 35 P.S.§§619.1 etseq.,

• The Air Pollution Control Act, Act of January 8, 1960, P.L. 2119, 35 P.S. §§4110,et.seq.i

• Pennsylvania Air Quality Management Regulations:

- 25 PA Code §§123.1 et.seq. (Chapter 123-Standards for Contaminants)- 25 PA Code §§131.1 etseq. (Chapter 131-Ambient Air Quality Standards)

• The Pennsylvania ARAR for groundwater for hazardous substances is that allgroundwater must be remediated to "background" quality as specified by 25 PA Code§264.90-264.100, specifically 25 PA Code §§264.97 (i) and (j) and 264.100 (a)(9).The Commonwealth of Pennsylvania also maintains the requirement to remediateto background is found in other legal authorities including Article 1, Section 27 ofthe Pennsylvania Constitution, Section 301, 307, 401 and 402 of the PennsylvaniaClean Streams Law, and the Solid Waste Management Act The Department hasrecently finalized a Ground Water Quality Protection Strategy dated February 1992which also addresses remediation of groundwater within the Commonwealth ofPennsylvania. This Chemical Specific ARAR must be addressed due to the presenceof hazardous substances found in the groundwater (i.e. TCE) above backgroundlevels. 3


Comments on the "Remedial Investigation Report,Novak Sanitaiy Landfill" dated June 1992

The PRP's letter to EPA dated June 9, 1992 states:

"Both the U.S. EPA and the PADER take the position that the Pennsylvania ARARfor groundwater for hazardous substances is that all groundwater be remediated to"background" quality as specified by 25 PA Code 264.90-264.100, specifically 25 PACode 264.97 (i) and (j) and 264.100 (a)(9). The Group does not agree that thisrequirements is an ARAR or that this regulation requires all ground water to beremediated to background levels. Assuming however that this requirement continuesto be considered an ARAR for purposes of any ground water remediation (activeor passive) at this site, the Group believes that the ARAR should be waived underSection 121 of CERCLA."

If a waiver is to be considered, the Waiver of this Pennsylvania ARAR must comply withSection 121 (d)(4) of CERCLA and Section 300.430 (f)(l)(ii)(c) of the National ContingencyPlan.1


(Red)Comments on the "Remedial Investigation Report, ~

Novak Sanitary LandfilT dated June 1992 ,

4.0 COMMENTS ON "APPENDIX A: PHASE ONE BASELINE RISK ASSESSMENT"

GENERAL COMMENTS

Comment No. 1

[Deleted due to Page 4, Comment No. 1 which will be performed in Pre-design] The habitatcharacterization failed to include the values of wetland areas found on the site but awayfrom the wasto depositional areas.—It is our concern that the acreage figure for totalwetlands on the site will be misconstrued as much smaller than is actually there.—Fefexample, a very productive pond/cattail wetland was noted in the southeast corner of the sitebut was not fully distributed in the main part of the document-!

Comment No. 2

[Deleted due to ecological risk assessment not required presently] The—baselineenvironmental risk assessment must include an ecological-assessment The statements-to'thecurrent baseline risk assessment are inadequate in their characterization of the ecologicalreceptors. Nothing is provided to substantiate the "no impacts" conclusion. The absence oflisted endangered species or critical habitats does not mean there are no adverseenvironmental effects to ecological resources associated with the site.2 , j


8

Comments on the "Remedial Investigation Report,Novak Sanitary LandfUT dated June 1992

5.0 COMMENTS ON "CHEMICAL DATA TABLES"

Comment No. 1

As per Region III guidance, all data tables in the main bodies of the RI and risk assessmentshould include detection limits and the code 'U' for all non-detect observations. (If acompound was not detected in any sample of a particular medium, however, it is reasonableto omit it from the summary tables, as was done.) '

Mr. Mark A. Travera September 25.1992

Comments on the "FEASIBILITY STUDYNOVAX SANITARY LANDFILLSOUTH WHITEHALL TOWNSHIP

PENNSYLVANIA" dated July 3, 1992

September 23, 1992

TARTJ? OF CONTENTS

SECTION PAGE

GENERAL COMMENTS .............................................. 1

EXECUTIVE SUMMARY ............................................ 1

1.0 INTRODUCTION ......................................... .21.3 CHARACTERISTICS OF ENVIRONMENTAL MEDIA .......... 21.3.2 LEACHATE ......................................... 21.3.3 LANDFILL GAS ..................................... 21.3.4 GROUND WATER ................................... 31.3.8 SOILS .............................................. 3

2.0 IDENTIFICATION AND SCREENING TECHNOLOGIES ........... 42.2 REMEDIAL ACTION OBJECTIVES ......................... 42.2.2 SITE SPECIFIC REMEDIAL ACTION OBJECTIVES .......... 42.3.2.1.2 Evaluation of Risk-Based Preliminary Remediation Goals for GroundWater Based Upon On-site Monitoring Wells ...................... 42.5 IDENTIFICATION OF AREAS AND VOLUMES TO BEREMEDIATED ............................................ 42.5.3 LANDFILL GAS ...................................... 4

3.0 ASSEMBLY AND SCREENING OF REMEDIAL MEASURES ....... 53.3.4.3 Remedial Measure GW-3 ................................ 5

4.0 DEVELOPMENT OF SITE WIDE REMEDIAL ALTERNATIVES .... 5GENERAL COMMENTS .................................... 54.5 REMEDIAL ALTERNATIVE 4 ............................. 6

7.0 REMEDIAL ALTERNATIVES SELECTION AND RECOMMENDATION?

TABLES .......................................................... 8TABLE 2-6 SUMMARY OF PRELIMINARY GOALS FORGROUNDWATER ......................................... 8

APPENDIX A: SOIL'GAS SURVEY ................................... 103.0 TEST METHODS ...................................... 103.1 METHANE ........................................... 10

Comments on the "Feasibility Study,Novak Sanitary Landfill" dated July 8,1992 ^ J

GENERAL COMMENTS

Page ES-8, Paragraph 3, Sentence 1. Remedial Alternatives 4 through 8 do not meet thePennsylvania ARAR for groundwater. Alternatives 7 and 8 may meet the PA groundwaterARAR if groundwater remediation continues until background quality is reached. >

EXECUTIVE SUMMARY

The Pennsylvania ARAR for groundwater for hazardous substances is that all groundwatermust be remediated to "background" quality as specificized by 25 PA Code §264.90-264.100,specifically 25 Code §§264.97(i) and (j) and 264.100 (a)(9). The Commonwealth ofPennsylvania also maintains that the requirement to remediate to background is found inother Legal authorities including Article 1, Section 27 of the Pennsylvania Constitution,Section 301,307,401 and 402 of the Pennsylvania Clean Streams Law, and the Solid WasteManagement Act. The Department has recently finalized a Ground Water QualityProtection strategy dated February 1992 which also addresses remediation of groundwaterwithin the Commonwealth of Pennsylvania. This Chemical Specific ARAR must beaddressed due to the presence of hazardous substances found in the groundwater (i.e. TCE)above background levels.

Throughout this report it is noted that:

"The Novak RI/FS PRP Group does not consider that 25 PA Code §264.90(i)and (j) and 264.100(a)(9) are ARARs or that these regulations require allground water to be remediated to background levels. Assuming however thatthis requirement continues to be considered an ARAR by the USEPA forpurposes of any ground water remediation (active or passive) at the site, theGroup believes that the ARAR should be waived under Section 121 ofCERCLA".

A waiver of this Pennsylvania ARAR must comply with Section 121(d)(4) of CERCLA andSection 300.430(f)(l)(ii)(c)'Of the National Contingency Plan, t

Please note that the Pennsylvania Residual Waste Regulations 25 PA Code §287-299 havebeen finalized and were published in the Pennsylvania Bulletin, Volume 22, Number 27,Saturday, July 4, 1992. t


Comments on the "Feasibility Study,Novak Sanitary Landfill" dated July 8,1992

1.0 INTRODUCTION

13 CHARACTERISTICS OF ENVIRONMENTAL MEDIA13.2 Leachate

Page 1-25. 3rd Paragraph;

This section states, "The investigation determined that the standing liquid is primarily locatedalong the southwestern corner of the surface fill area, between the surface fill area and thenorthwestern corner of the Trench Area in all five trenches." This determination did not takeinto account that the greatest factor associated with the presence of leachate in the gas ventsis not the location of the vents, but the depth in which the vents are located below ground.Gas vents between 1.5 and 4.5 feet below the ground did not contain any standing liquid.Thirty-six percent of the vents between 4.5 and 5.5 feet below the ground contained standingliquid. Seventy-two percent of the gas vents 5.6 feet and deeper contained standing liquid.The deeper gas vents contained the majority of the standing liquid encountered in the upperzone of the landfill, i

Ninety-three percent of the gas vents in the Trench Area were 5.6 feet below grade ordeeper. The leachate appeared more prevalent in this area because the deeper vents madethe leachate more accessible than the other areas of the landfill. Eighty-two percent of thegas vents in the northwestern portion of the Surface Fill Area were 4.4 feet below grade orless, which could account for the lack of standing water in the vents located in this area.Eighty percent of the gas vents 5.6 feet or deeper in the Old Mine Area contained standingliquid, i

The leachate, or perched water in the landfill has not been fully characterized. Acomprehensive investigation of the leachate at the landfill should be performed before theconclusions about the volume of the leachate to be removed, as discussed in this report, canbe substantiated, i

133 Landfill Gas

Page 1-29:• • * ' . ' . •

This section clearly states that 10 of the landfill gas probes on the boundary of the landfillexceeded 90 % the Lower Explosive Limit (LEL). According to § 258.23 of the FederalRegister, Volume 26, No. 196, dated October 9, 1991, there are several mandates that are

Mr. Mark A. Ttavers September 28,1992

AR3055<<8

Comments on the "Feasibility Study,Novak Sanitary Landfill" dated July 8,1992 v J

required when the LEL is exceeded at the property boundary. These mandates include, butare not limited to a minimum of quarterly monitoring, and notification of the State. EPAmay wish to pursue a course of action regarding this issue, u

13.4 Ground Water

This section, and other sections relating to ground water, should discuss the fact that theunoccupied residential well on-site was plugged and abandoned. It is important to note thatthis well is located hydraulically downgradient of the landfill and had extensivecontamination. It must be stated in this report that this abandoned well will be replaced bythe appropriate monitoring well or wells to monitor ground water quality in this area. Thiswell was being used as part of the monitoring network surrounding the site before it wasabandoned, i

Page 1-31

The new Maximum Contamination Limits (MCLs) should be incorporated in the discussionof contaminants exceeding drinking water standards. The following contaminants, and thefact that they exceeded the drinking water standards should be discussed: u

Contaminant Observed MCL —'

Vinyl Chloride 10 ug/1 2 ug/11,2-trichloroethane 5 ug/1 5 ug/1Benzene 7 ug/1 5 ug/1Tetrachloroethylene 5 ug/1 5 ug/1Cadmium 7.5 ug/1 5 ug/1Nickel 197 ug/1 100 ug/1

13.8 Soils

Page 1-35 . 2nd Paragraph

The sentence, "In summary all evidence suggests that the former activities at the NSL havenot altered the quality of -the soils at the site," should be removed as suggested in theoriginal comments submitted March 12, 1992. The sediments of the leachate seep on thesouthern portion of the landfill revealed acetone at 230 ug/kg, 2-butanone at 15 ug/kg(Table 5-4 of the RI Report), and elevated levels of numerous semi-volatile compounds(Table 5-6 of RI Report). The sediments of the northeastern leachate seep revealed

Mr. Mark A. Travcn September 28,1992

Comments on the "Feasibility Study,Novak Sanitary Landfill* dated July 8,1992

ethylbenzene at 31 ug/kg, xylenes at 130 ug/kg (Table 5-4 of RI Report), and elevated levelsof semi-volatile compounds (Table 5-6 of RI Report), i

2.0 IDENTIFICATION AND SCREENING TECHNOLOGIESi

2.2 REMEDIAL ACTION OBJECTIVES2.2.2 Site Specific Remedial Action Objectives

Page 2-4. Landfill Gas

As presented in the numerous comments previously submitted, the Ambient Air MonitoringProgram conducted was very limited and not comprehensive. Based on this fact, thestatement referring to this program should read, "Based upon a very limited Ambient AirMonitoring Program...". A statement should be added to address the fact that additional airmonitoring will be conducted during the RD/RA phase of the project. During the March 31,1992 meeting between the PRPs and the EPA, it was agreed that the Ambient AirMonitoring Program was very limited and that additional monitoring would be conductedduring the RD/RA. i

2.3.2.1.2 Evaluation of Risk-Based Preliminary Remediation Goals for Ground Water BasedUpon On-site Monitoring Wells

Page 2-13. Last Paragraph

1.1.1-Dichlorothane should be changed to 1.1-Dichloroethane. s

15 IDENTIFICATION OF AREAS AND VOLUMES TO BE2JS3 landfill Gas

Page 2-24. 3rd Sentence

The third sentence, and the other sentences throughout the report, should be rephrased toremove "if any", which jmplies that the landfill gas evaluation may or may not be performed.As discussed during the March 31, 1992 meeting between the EPA and the PRPs andcomments on the RI and FS Reports, the volume and composition of the landfill gasmigrating form the site needs to be evaluated, i


Comments on the Teasibility Study,Novak Sanitary Uuulfiir dated July 8,1992

3.0 ASSEMBLY AND SCREENING OF REMEDIAL MEASURES

Section 3.3.4.3 Remedial Measure GW-3

Page 3-44

If community water supply wells are determined to be affected by the landfill, it isrecommended that these wells also receive treatment. 5

4.0 DEVELOPMENT OF SITE WIDE REMEDIAL ALTERNATIVES

GENERAL COMMENTS

Comment No. 1

[Deleted due to a habitat impact assessment will be conducted in Pre-design] The-RI failsto provide a- complete -flora/fauna and habitat characterization and ecological riskassessment, os provided for in the RI/FS Work Plan, and we therefore question how tho FSplanning can develop any remedial actions that will sufficiently consider protection ofecological resources. <

Comment No. 2

[Deleted due to a habitat impact assessment will be conducted in Pre-design] The FeasibilityStudy mentions a cap, but fails to mention how it will impact ecological resources. In fact»no remedial action can be contemplated at this time because insufficient information isavailable to assess ecological impacts. It is possible that Q remedial plan-can-be formulatedthat will satisfy both the policies of the state and-protect the ecological resources on site, butthat cannot be determined until the component parts of the ecological characterization andrisk assessment are completed; <

Comment No. 3

Remedial alternatives should be developed in terms of protecting and enhancing the currenthabitat and landscape conditions. The following recommendations are offered to point thedirection of remediation with habitats in mind. It is not to be considered a complete andtotal set of suggestions, but merely a point of departure in remediating with ecological valuesas a primary consideration. 4

Mr. Mart A. Travels September 28,1992

HR305S5

Comments on the "Feasibility Study,Novak Sanitary Landfill" dated July 8.1992

Area 1 should be cleared of waste rubble and debris and enhanced forecological values, i.e., diverse flora and fauna.4

The swale (area 8) should also be cleared of waste rubble, debris, etc.and designed to carry water slowly through it towards the proposedponded area in the southwest comer of the property. Area 8 shouldalso be revegetated with desirable wetlands species. 4

The cap, if put in place, should be designed to duplicate the undulatingcover so that swales and pocket wetlands emulate current conditionsas closely as possible. Maintenance in swales, if required, should becarried out after the killing frost in autumn and the vegetation clippedat a height of 15 to 24 inches and no lower. <

The southeast retention pond should be expanded only with care as itis currently a high quality cattail wetlands in conjunction with amaturing forest on one side, this area represents good diversity andshould be protected as much as possible. 4

4 .5 REMEDIAL ALTERNATIVE 4

The original comment on the temporary wells for dewatering was not addressed. TheRemedial Measure LCH-3 proposes using temporary well points for the one time dewateringof leachate in the Surface Fill and Trench Area. The well construction and design needs tobe discussed, i


1B30_5552

CommenU on the "Feasibility Study, "Novak Sanitary LandfUl" dated July 8,1992 1

7.0 REMEDIAL ALTERNATIVES SELECTION AND RECOMMENDATION

If the landfill is to undergo closure by October 9, 1993, the landfill must meet therequirements of the Final Rule on Solid Waste Disposal Facilities, as outlined in FederalRegister No. 56, dated October 9, 1991. At a minimum, the following sections should betaken into account in the remedy selection: z

§ 258.6 (a)(l) The infiltration layer should have an infiltration rate of < l(r*cm/sec, common borrow material may not meet these criteria,or PADER § 264.31|(1) and 273.234(1)(2)(3) should befollowed.2

§ 253.23 (a)(2) The state director should be notified. 2

§ 258.61 (a)(4) A gas monitoring system must be implemented. 2

§ 258.61 (a)(2) A leachate collection system in accordance with § 258.40 tomaintain less than a 30-cm depth of leachate over the liner.Also, PADER § 264.310(6)(iii) and § 273.192(5) should befollowed, i

A pre-agreement with the Lehigh County Wastewater Pretreatment Plant should also bedocumented, i

It should be mentioned that the final landfill gas venting system design will be modifiedaccording to the results of a Remedial Assessment Investigation, i


fl»305553

Comments on the "Feasibility Study,Novak Sanitary Landfill" dated July 8,1992

TABLES

TABLE 2-6 SUMMARY OF PRELIMINARY GOALS FOR GROUND WATER

Comment No. 1

Tables of preliminary remedial goals (PRGs) have been added, but these are inadequate inseveral ways.

First, PRGs are supposed to be developed in the scoping stage, in order to facilitate an earlystart on developing remedial alternatives. PRGs are intended to be revised on the basis ofthe RI and baseline risk assessment to consider the effects of (1) multiple contaminants, (2)multiple routes of exposure, and (3) site-specific exposure patterns. Presentation of single-contaminant, single-route PRGs in a feasibility study in effect wastes the information gainedby the baseline risk assessments

Second, PRGs have been presented only for groundwater and leachate. Surface soil, air,surface area, and sediments have been omitted despite the fact that all these media presentrisks greater than 10* to some receptors, j

Third, the groundwater PRGs consider only ingestion, even though inhalation exposure alsopresented significant risks. 3

To address this deficiency, it is suggested the following tables of risk-based cleanup goals beadded:

1. For non-carcinogenic effects, based on the most sensitive receptor(usually children for residential scenarios, adults for occupationalscenarios, and teenagers for trespassing scenarios), one table for eachreceptor which exceeded a total hazard index of 1 for all exposureroutes combined. For this site, this should include current on-siteresidents, current off-site residents, current trespassers, andhypothetical future on-site residents. Each table should list allsubstances contributing 1% or more of the total hazard index, theexposure concentration used in the baseline risk assessment for eachexposure route, and the concentration at which the total hazard indexwould be 1. There exists considerable latitude for exercising judgmentin the last item, except that the total hazard index should be 1. Theseconcentrations become the risk-based cleanup goals. 3


Comment! on the "Feasibility Study,Novak Sanitary Landfiir dated July 8, 1992

2. For carcinogenic effects, based on the sum of risk to adults andchildren, one table for each receptor which exceeded a totalcarcinogenic risk of 10* for all exposure routes combined. As for non-carcinogenic effects, each table should list all substances contributing1% or more of the total risk, and the exposure concentration used inthe baseline risk assessment for each exposure route. Instead of asingle set of concentrations adding to a hazard index of 1, the tableshould contain three sets of concentrations adding to 10*4,10"5, and 10*total cancer risk. As for non-carcinogens, judgment should be used toapportion risk among exposure routes and chemicals to arrive at thesefixed risk levels. 3

Comment No. 2

The Preliminary Remediation Goals (PRGs) should be changed to reflect the new MaximumContamination Limits (MCLs) as outlined in the April, 1992 U.S.EPA Office of WaterDrinking Water Regulations and Health Advisors; Federal Register No. 56, dated January30, 1991; and Federal Register No. 57, dated July 17, 1992. The following PRGs need tobe changed to. reflect the updated MCLs: i

Contaminant MCLEthylbenzene 700 ug/1Styrene 100 ug/1Tetrachloroethylene 5 ug/1Toluene 1,000 ugAVinyl chloride 2 ug/1Xylenes 10,000 ug/1Di (N-Ethylhexyl)phthalate 6 ug/11,2,4-Trichlorobenzene 70 ug/1Antimony 6 ug/1Beryllium 4 ug/1Nickel ... 100 ug/1Thallium 2 ug/1Cyanide 200 ug/1

.


W305555

Comments onNovak Sanitary Undfill" dated July 8,1992

APPENDIX A: SOIL GAS SURVEY

3.0 TEST RESULTS3.1 Methane

Page A-5. 2nd Paragraph. Last Sentence:

There is a typographical error in this sentence. The sentence should read: Methane readingstaken..., as opposed to: Methane reading stake.... i

Table A-l

Several readings are noted to have initially read 100% and then dropped to a lower level.This is a very important fact and should be discussed in the text. If the needle on theexplosimeter pegs and then returns to zero it is an indication that the readings exceeded theupper explosive limit The quick peak and deflection to zero occurs because the gas mixturein the combustion cell is too rich to burn and causes the filament to conduct a current justas if the atmosphere contained no combustion at all. Geraghty and Miller should reassesstheir field notes to be sure that all soil gas locations that originally peaked on theexplosimeter be included in the table. According to the EPA contractor's notes, LFG # 81and LFG #1 locations also exhibited a quick peak and then zero on the LEL meter, t

Mr. Mark A. Travera September 28,199210

AR305556

comments on the "REMEDIAL INVESTIGATION REPORTNOVAX SANITARY LANDFILLSOUTH WHITEHALL TOWNSHIP

PENNSYLVANIA" dated June 1992

October 20, 1992

AR305557

(Red)Comments on the "Remedial Investigation Report,

Novak Sanitary Landfill" dated June 1992

TABLE OF CONTENTS

SECTION PAGE NO.

AUTHORIZATION .................................................. 2

OBJECTIVES ...................................................... 2

1.0 COMMENTS ON "4.0 EXPOSURE CHARACTERIZATION" .............. 3

2.0 COMMENTS ON "7.0 PHASE ONE ECOLOGICAL EVALUATION" ....... 4

3.0 COMMENTS ON "8.0 PRELIMINARY IDENTIFICATION OFAPPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARs)" ...................................... 6

4.0 COMMENTS ON "APPENDIX A: PHASE ONE BASELINERISK ASSESSMENT' ............................................ 8

5.0 COMMENTS ON "CHEMICAL DATA TABLES" ....................... 9

Mr. Marie A. Traven October 20,1992

AR305558

Comment* on the "Remedial Investigation Report,Novak Sanitaiy LandfiU" dated June 1992 , j

AUTHORIZATION

Not Applicable

OBJECTIVES

Not Applicable

Mr. Mark A. Traven October 20,1992

4R305559

(Red)

Comments on the "Remedial Investigation Report,Novak Sanitary Landfill' dated June 1992

1.0 COMMENTS ON "4.0 EXPOSURE CHARACTERIZATION"

COMMENTS ON "4.4 EXPOSURE DOSE CALCULATIONS"

Comments on "4.4.4 Leachate Seep Water and Associated Soil"

Comment No. 1

Page A-75

The assumption of incidental ingestion of 5 mg/d of surficial soil from the vicinity of leachateseeps is underprotective. The scenario should assume that, on days when these soils arecontacted, 100 mg of incidental ingestion occurs.'

Comment No. 2

Table A-50: Equations and Example Calculation for Inhalation Exposure to VOCs in ShowerWater

The result of the sample calculation for non-cancer effects should be 1.8e-04 mg/kg/d, not1.8e-05. This appears to be only a typo in the example, which does not affect the exposurecalculations.'

Comment No. 3 •

Table A-79: Risk Estimation Summary

...cancer risk to children is additive with that to adults. These risks should be combined.'

Comment No. 4

The table should contain a risk summary for a potential current off-site resident - child(analogous to that for an adult, shown third from the top on page 1 of the table). Althoughthe appropriate route-specific risks were presented in earlier tables, they were omitted fromthe summary table.' • . . .

Mr. Mark A. Travers October 20,1992

flR305560

'- (ij Comment* on the "Remedial Investigation Report,Novak Sanitary Landfill" dated June 1992

2.0 COMMENTS ON "7.0 PHASE ONE BASELINE ECOLOGICAL EVALUATION"

Comment No. 1

It is suggested that the investigator modify all of Section 7 of the RI except for the portionrelated to endangered species, or Special Resources/Critical Habitats as referred to in theRI. They appear to have contacted the appropriate people in both state and federalgovernment regarding this aspect

It is recommended that the chapter be reorganized to include lists of flora and fauna foundon site and in the surrounding areas and describe the habitats existing in support of theseresources. Since it is a site demonstrating such diversity of habitat, an attempt should bemade to census and map populations against habitats and to cany out a habitat impactassessment for the design alternatives during the pre-design phase. Details regardingappropriate habitat restoration will also be developed during the pre-design phase. 2

COMMENTS ON "7.7 SEDIMENT AND SURFACE WATER SAMPLING"

Comment No. 2

It is inappropriate to utilize soil contaminant levels to evaluate the potential impact of thesecontaminants in sediments for Jordan Creek and on-site sediments. *

COMMENTS ON "7.8 SUMMARY AND CONCLUSIONS"Comments on "7.83 Conclusions"

Comment No. 3

EPA does not agree with the conclusions reached in this section, specifically: "Based uponthe ecological investigations conducted during the RI, there has been little to no effect onoff site ecological Characteristics" and "(a)lthough ... practices (on site) have disturbed the... ecological setting ... no available evidence demonstrates any significant effects to thecurrent ecological characteristics ..." 2

We object to use of the term 'ecological investigations' as none was done to the best of our


(Red)Comments on the "Remedial Investigation Report,


knowledge. In place of this, the consultant used a reconnaissance site visit by a member ofEPA staff and a subsequent one-day visit by a site contractor. They have misrepresentedthe conversations and notes made by EPA staff as sufficient to fulfill the need for full floraand fauna Characterization as well as habitat evaluation. Since ecological investigations werenot carried out, it is obvious that evidence is not available to 'demonstrate any significanteffects', j

It is instructive to note at this point that the reconnaissance site visit demonstrated that avery desirable set of habitat conditions are present and improving at the site. A rich mixtureof uplands (open fields and immature forest), scattered wetlands (small pockets scatteredover the site with at least three larger and well developed areas) were noted. With such arich mixture, it would be difficult to complete a vegetation list during a one-day site visit.The one-day visit also showed a diversity of wildlife demonstrating that numerous wildlifereceptors are prevalent on site. t

In conclusion, it is recommended that flora and fauna characterizations be completed alongwith the various habitats located in the area and viewed through the perception oflandscape. In this way, the ecological characterization can be viewed as a working wholerather than as individual parts. The vegetative cover should be described in terms ofacreage. Design alternatives should be developed in terms of protecting and enhancing thecurrent habitat and landscape conditions. t

Mr. Mark A. Travera October 20,1992

(Red)Comment! on the "Remedial Investigation Report,


3.0 COMMENTS ON "8.0 PRELIMINARY IDENTIFICATION OF APPLICABLE ORRELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)"

Comment No. 1

The following Pennsylvania Chemical Specific ARARs must be included and addressed inthe Final Remedial Investigation Report for the Novak Sanitary Landfill Site: ,

• The Clean Streams Law of Pennsylvania, Act of June 22, 1937, P.L. 1987, 35 P.S.§§619.1 etseq.,

• The Air Pollution Control Act, Act of January 8, 1960, P.L. 2119, 35 P.S. §§4110,

Pennsylvania Air Quality Management Regulations:

- 25 PA Code §§123.1 et.seq. (Chapter 123-Standards for Contaminants)- 25 PA Code §§131.1 et.seq. (Chapter 131-Ambient Air Quality Standards)

The Pennsylvania ARAR for groundwater for hazardous substances is that allgroundwater must be remediated to "background" quality as specified by 25 PA Code§264.90-264.100, specifically 25 PA Code §§264.97 (i) and (j) and 264.100 (a)(9).The Commonwealth of Pennsylvania also maintains the requirement to remediateto background is found in other legal authorities including Article 1, Section 27 ofthe Pennsylvania Constitution, Section 301, 307, 401 and 402 of the PennsylvaniaClean Streams Law, and the Solid Waste Management Act. The Department hasrecently finalized a Ground Water Quality Protection Strategy dated February 1992which also addresses remediation of groundwater within the Commonwealth ofPennsylvania. This Chemical Specific ARAR must be addressed due to the presenceof hazardous substances found in the groundwater (i.e. TCE) above backgroundlevels. 3

Mr. Mark A. Travert - October 20,1992

Comments on the •Remedial Investigation Report,Novak Sanitary Landfill" dated June 1992

The PRP's letter to EPA dated June 9, 1992 states:

"Both the U.S. EPA and the PADER take the position that the Pennsylvania ARARfor groundwater for hazardous substances is that all groundwater be remediated to"background" quality as specified by 25 PA Code 264.90-264.100, specifically 25 PACode 264.97 (i) and (j) and 264.100 (a)(9). The Group does not agree that thisrequirements is an ARAR or that this regulation requires all ground water to beremediated to background levels. Assuming however that this requirement continuesto be considered an ARAR for purposes of any ground water remediation (activeor passive) at this site, the Group believes that the ARAR should be waived underSection 121 of CERCLA."

If a waiver is to be considered, the Waiver of this Pennsylvania ARAR must comply withSection 121 (d)(4) of CERCLA and Section 300.430 (f)(l)(ii)(c) of the National ContingencyPlan.'

Mr. Mark A. Travels October 20,1992

flR30556l*


4.0 COMMENTS ON "APPENDIX A: PHASE ONE BASELINE RISK ASSESSMENT"

GENERAL COMMENTS

Comment No. 1

[Deleted] t

Comment No. 2

Nothing is provided to substantiate the "no impacts" conclusion. The absence of listedendangered species or critical habitats does not mean there are no adverse environmentaleffects to ecological resources associated with the site.2

Mr. Mark A. Travera October 20,1992

8

AR305565

Comments on the "Remedial Investigation Report,Novak Sanitary LandGII" dated June 1992

5.0 COMMENTS ON "CHEMICAL DATA TABLES"

Comment No. 1

As per Region III guidance, all data tables in the main bodies of the RI and risk assessmentshould include detection limits and the code 'U' for all non-detect observations. (If acompound was not detected in any sample of a particular medium, however, it is reasonableto omit it from the summary tables, as was done.)'

Mr. Mark A. Travcrs October 20.1992

305566

ORIGINAL(Red)

Comments on the "FEASIBILITY STUDYNOVAK SANITARY LANDFILLSOUTH WHITEHALL TOWNSHIP

PENNSYLVANIA" dated July 8, 1992

October 20, 1992

"K305567

ORIGINAL(Red)

TABLE OF CONTENTS' ——————————————

SECTION PAGE

GENERAL COMMENTS ............................................. 1

EXECUTIVE SUMMARY ............................................ 1

1.0 INTRODUCTION ......................................... .21.3 CHARACTERISTICS OF ENVIRONMENTAL MEDIA .......... 2

1.3.2 LEACHATE ......................................... 21.3.3 LANDFILL GAS ..................................... 21.3.4 GROUND WATER ................................... 31.3.8 SOILS .............................................. 3

2.0 IDENTIFICATION AND SCREENING TECHNOLOGIES ........... 42.2 REMEDIAL ACTION OBJECTIVES ......................... 42.2.2 SITE SPECIFIC REMEDIAL ACTION OBJECTIVES .......... 42.3.2.1.2 Evaluation of Risk-Based Preliminary Remediation Goals for GroundWater Based Upon On-site Monitoring Wells ...................... 42.5 IDENTIFICATION OF AREAS AND VOLUMES TO BEREMEDIATED ............................................ 42.5.3 LANDFILL GAS ...................................... 4

3.0 ASSEMBLY AND SCREENING OF REMEDIAL MEASURES ....... 53.3.4.3 Remedial Measure GW-3 ................................ 5

4.0 DEVELOPMENT OF SITE WIDE REMEDIAL ALTERNATIVES .... 5GENERAL COMMENTS .................................... 54.5 REMEDIAL ALTERNATIVE 4 ............................. 6

7.0 REMEDIAL ALTERNATIVES SELECTION AND RECOMMENDATION?

TABLES .......................................................... 8TABLE 2-6 SUMMARY OF PRELIMINARY GOALS FORGROUNDWATER ......................................... 8

APPENDIX A: SOIL'GAS SURVEY ................................... 103.0 TEST METHODS ...................................... 103.1 METHANE ........................................... 10

305568

' Comments on the "Feasibility Study,Movak Sanitary Landfill" dated July 8, 1992(Red)

GENERAL COMMENTS

Page ES-8, Paragraph 3, Sentence 1. Remedial Alternatives 4 through 8 do not meet thePennsylvania ARAR for groundwater. Alternatives 7 and 8 may meet the PA groundwaterARAR if groundwater remediation continues until background quality is reached. 5

EXECUTIVE SUMMARY

The Pennsylvania ARAR for groundwater for hazardous substances is that all groundwatermust be remediated to "background" quality as specificized by 25 PA Code §264.90-264.100,specifically 25 Code §§264.97(i) and (j) and 264.100 (a)(9). The Commonwealth ofPennsylvania also maintains that the requirement to remediate to background is found inother Legal authorities including Article 1, Section 27 of the Pennsylvania Constitution,Section 301,307,401 and 402 of the Pennsylvania Clean Streams Law, and the Solid WasteManagement Act. The Department has recently finalized a Ground Water QualityProtection strategy dated February 1992 which also addresses remediation of groundwaterwithin the Commonwealth of Pennsylvania. This Chemical Specific ARAR must beaddressed due to the presence of hazardous substances found in the groundwater (i.e. TCE)above background levels.

Throughout this report it is noted that:

"The Novak RI/FS PRP Group does not consider that 25 PA Code §264.90(i)and (j) and 264.100(a)(9) are ARARs or that these regulations require allground water to be remediated to background levels. Assuming however thatthis requirement continues to be considered an ARAR by the USEPA forpurposes of any ground water remediation (active or passive) at the site, theGroup believes that the ARAR should be waived under Section 121 ofCERCLA".

A waiver of this Pennsylvania ARAR must comply with Section 121(d)(4) of CERCLA andSection 300.430(f)(l)(ii)(c).of the National Contingency Plan, t

Please note that the Pennsylvania Residual Waste Regulations 25 PA Code §287-299 havebeen finalized and were published in the Pennsylvania Bulletin, Volume 22, Number 27,Saturday, July 4, 1992. s


^305569

ORIGINALComments on the "Feasib

Novak Sanitary Landfill" dated July 8,1992

1.0 INTRODUCTION

13 CHARACTERISTICS OF ENVIRONMENTAL MEDIA13.2 Leachate

Page 1-25. 3rd Paragraph:

This section states, "The investigation determined that the standing liquid is primarily locatedalong the southwestern corner of the surface fill area, between the surface fill area and thenorthwestern corner of the Trench Area in all five trenches." This determination did not takeinto account that the greatest factor associated with the presence of leachate in the gas ventsis not the location of the vents, but the depth in which the vents are located below ground.Gas vents between 1.5 and 4.5 feet below the ground did not contain any standing liquid.Thirty-six percent of the vents between 4.5 and 5.5 feet below the ground contained standingliquid. Seventy-two percent of the gas vents 5.6 feet and deeper contained standing liquid.The deeper gas vents contained the majority of the standing liquid encountered in the upperzone of the landfill, i

Ninety-three percent of the gas vents in the Trench Area were 5.6 feet below grade ordeeper. The leachate appeared more prevalent in this area because the deeper vents madethe leachate more accessible than the other areas of the landfill. Eighty-two percent of thegas vents in the northwestern portion of the Surface Fill Area were 4.4 feet below grade orless, which could account for the lack of standing water in the vents located in this area.Eighty percent of the gas vents 5.6 feet or deeper in the Old Mine Area contained standingliquid, i

The leachate, or perched water in the landfill has not been fully characterized. Acomprehensive investigation of the leachate at the landfill should be performed before theconclusions about the volume of the leachate to be removed, as discussed in this report, canbe substantiated, t

13.3 I -andfiil Gas

Page 1-29: ...

This section clearly states that 10 of the landfill gas probes on the boundary of the landfillexceeded 90 % the Lower Explosive Limit (LEL). According to § 258.23 of the FederalRegister, Volume 26, No. 196, dated October 9, 1991, there are several mandates that are

Mr. Mark A. Travers October 20,1992

flfi305570

Comment! on the "Feasibility Study,ORIGINAL Novak Sanitaiy Undfiir dated July 8, 1992(Red)

required when the LEL is exceeded at the property boundary. These mandates include, butare not limited to a minimum of quarterly monitoring, and notification of the State. EPAmay wish to pursue a course of action regarding this issue, u

1.3.4 Ground Water

This section, and other sections relating to ground water, should discuss the fact that theunoccupied residential well on-site was plugged and abandoned. It is important to note thatthis well is located hydraulically downgradient of the landfill and had extensivecontamination. It must be stated in this report that this abandoned well will be replaced bythe appropriate monitoring well or wells to monitor ground water quality in this area. Thiswell was being used as part of the monitoring network surrounding the site before it wasabandoned, t

Page 1-31

The new Maximum Contamination Limits (MCLs) should be incorporated in the discussionof contaminants exceeding drinking water standards. The following contaminants, and thefact that they exceeded the drinking water standards should be discussed: u

Contaminant Observed MCL

Vinyl Chloride 10 ug/1 2 ug/11,2-trichloroethane 5 ug/1 5 ug/1Benzene 7 ug/1 5 ug/1Tetrachloroethylene 5 ug/1 5 ug/1Cadmium 7.5 ug/1 5 ug/1Nickel 197 ug/1 100 ug/1

13.3 Soils

Page 1-35 . 2nd Paragraph

The sentence, "In summary ail evidence suggests that the former activities at the NSL havenot altered the quality of-the soils at the site," should be removed as suggested in theoriginal comments submitted March 12, 1992. The sediments of the leachate seep on thesouthern portion of the landfill revealed acetone at 230 ug/kg, 2-butanone at 15 ug/kg(Table 5-4 of the RI Report), and elevated levels of numerous semi-volatile compounds(Table 5-6 of RI Report). The sediments of the northeastern leachate seep revealed

Mr. Mark A. Traver* October 20,1992

1R30557I

Comments on the "FeasibiliNovak Sanitary Landfill" dated July

ethylbenzene at 31 ug/kg, xylenes at 130 ug/kg (Table 5-4 of RI Report), and elevated levelsof semi-volatile compounds (Table 5-6 of RI Report), i

2.0 IDENTIFICATION AND SCREENING TECHNOLOGIES

2.2 REMEDIAL ACTION OBJECTIVES2.2.2 Site Specific Remedial Action Objectives

Page 2-4. Landfill Gas

As presented in the numerous comments previously submitted, the Ambient Air MonitoringProgram conducted was very limited and not comprehensive. Based on this fact, thestatement referring to this program should read, "Based upon a very limited Ambient AirMonitoring Program...". A statement should be added to address the fact that additional airmonitoring will be conducted during the RD/RA phase of the project. During the March 31,1992 meeting between the PRPs and the EPA, it was agreed that the Ambient AirMonitoring Program was very limited and that additional monitoring would be conductedduring the RD/RA. i

2.3J2.1.2 Evaluation of Risk-Based Preliminary Remediation Goals for Ground Water BasedUpon On-site Monitoring Wells

Page 2-13. Last Paragraph

1.1.1-Dichlorothane should be changed to 1.1-Dichloroethane. s

2.5 IDENTIFICATION OF AREAS AND VOLUMES TO BE REMEDIATED25 3 Landfffl Gas

Pace 2-24. 3rd Sentence

The third sentence, and the other sentences throughout the report, should be rephrased toremove "if any", which.implies that the landfill gas evaluation may or may not be performed.As discussed during the March 31, 1992 meeting between the EPA and the PRPs andcomments on the RI and FS Reports, the volume and composition of the landfill gasmigrating form the site needs to be evaluated, i


ORIGINAL Comments on the "Feasibility Study,(Re(j) Novak Sanitaiy Landfill" dated July 8, 1992 , J

3.0 ASSEMBLY AND SCREENING OF REMEDIAL MEASURES

Section 3.3.43 Remedial Measure GW-3

Page 3-44

If community water supply wells are determined to be affected by the landfill, it isrecommended that these wells also receive treatment, i

4.0 DEVELOPMENT OF SITE WIDE REMEDIAL ALTERNATIVES

GENERAL COMMENTS

Comment No. 1

[Deleted] A

Comment No. 2

[Deleted] 4

Comment No. 3

Remedial alternatives should be developed in terms of protecting and enhancing the currenthabitat and landscape conditions. The following recommendations are offered to point thedirection of remediation with habitats in mind. It is not to be considered a complete andtotal set of suggestions, but merely a point of departure in remediating with ecological valuesas a primary consideration. 4

• Area 1 should be cleared of waste rubble and debris and enhanced forecological values, i.e., diverse flora and fauna.4

• The swale (area 8) should also be cleared of waste rubble, debris, etc.and designed to carry water slowly through it towards the proposedponded area in the southwest comer of the property. Area 8 shouldalso be revegetated with desirable wetlands species. 4


W3Q5573

ORIGINAL(RedJ

Commeau on the "Feasibility Study,Novat Sanitary Landfiir dated July 8,1992

The cap, if put in place, should be designed to duplicate the undulatingcover so that swales and pocket wetlands emulate current conditionsas closely as possible. Maintenance in swales, if required, should becarried out after the killing frost in autumn and the vegetation clippedat a height of 15 to 24 inches and no lower. 4

The southeast retention pond should be expanded only with care as itis currently a high quality cattail wetlands in conjunction with amaturing forest on one side, this area represents good diversity andshould be protected as much as possible. «

4.5 REMEDIAL ALTERNATIVE 4

The original comment on the temporary wells for dewatering was not addressed. TheRemedial Measure LCH-3 proposes using temporary well points for the one time dewateringof leachate in the Surface Fill and Trench Area. The well construction and design needs tobe discussed, i


fiR30557l*

ORIGINALCommenu on the "Feasibility Study, N

Novak Sanitary Landfilf dated July 8,1992 ,

7.0 REMEDIAL ALTERNATIVES SELECTION AND RECOMMENDATION

If the landfill is to undergo closure by October 9, 1993, the landfill must meet therequirements of the Final Rule on Solid Waste Disposal Facilities, as outlined in FederalRegister No. 56, dated October 9, 1991. At a minimum, the following sections should betaken into account in the remedy selection: 2

§ 258.6 (a)(l) The infiltration layer should have an infiltration rate of < 10*cm/sec, common borrow material may not meet these criteria,or PADER § 264.310(1) and 273.234(1)(2)(3) should befollowed.2

§ 258.23 (a)(2) The state director should be notified. 2

§ 258.61 (a)(4) A gas monitoring system must be implemented. 2

§ 258.61 (a)(2) A leachate collection system in accordance with § 258.40 tomaintain less than a 30-cm depth of leachate over the liner.Also, PADER § 264.310(6)(iii) and § 273.192(5) should befollowed.

A pre-agreement with the Lehigh County Wastewater Pretreatment Plant should also bedocumented. 2

It should be mentioned that the final landfill gas venting system design will be modifiedaccording to the results of a Remedial Assessment Investigation. 2


3R305575

ORIGINAL: Comments on the Teasibilft

Novak Sanitary Landfffl* dated July 8,1992

TABLES

TABLE 2-6 SUMMARY OF PRELIMINARY GOALS FOR GROUND WATER

Comment No. 1

Tables of preliminary remedial goals (PRGs) have been added, but these are inadequate inseveral ways.

First, PRGs are supposed to be developed in the scoping stage, in order to facilitate an earlystart on developing remedial alternatives. PRGs are intended to be revised on the basis ofthe RI and baseline risk assessment to consider the effects of (1) multiple contaminants, (2)multiple routes of exposure, and (3) site-specific exposure patterns. Presentation of single-contaminant, single-route PRGs in a feasibility study in effect wastes the information gainedby the baseline risk assessments

Second, PRGs have been presented only for groundwater and leachate. Surface soil, air,surface area, and sediments have been omitted despite the fact that all these media presentrisks greater than 10"* to some receptors, i

Third, the groundwater PRGs consider only ingestion, even though inhalation exposure alsopresented significant risks, j

To address this deficiency, it is suggested the following tables of risk-based cleanup goals beadded:

1. For non-carcinogenic effects, based on the most sensitive receptor(usually children for residential scenarios, adults for occupationalscenarios, and teenagers for trespassing scenarios), one table for eachreceptor which exceeded a total hazard index of 1 for all exposureroutes combined. For this site, this should include current on-siteresidents, current off-site residents, current trespassers, andhypothetical future on-site residents. Each table should list allsubstances contributing 1% or more of the total hazard index, theexposure concentration used in the baseline risk assessment for eachexposure route, and the concentration at which the total hazard indexwould be 1. There exists considerable latitude for exercising judgmentin the last item, except that the total hazard index should be 1. Theseconcentrations become the risk-based cleanup goals. »

Mr. Mark A. Travels October 20.19928

AR305576

ORIGINAL Comment* on the "Feasibility Study,/n , Novak Saoitaiy Landfill" dated July 8,1992 . v >

For carcinogenic effects, based on the sum of risk to adults andchildren, one table for each receptor which exceeded a totalcarcinogenic risk of 10* for all exposure routes combined. As for non-carcinogenic effects, each table should list all substances contributing1% or more of the total risk, and the exposure concentration used inthe baseline risk assessment for each exposure route. Instead of asingle set of concentrations adding to a hazard index of 1, the tableshould contain three sets of concentrations adding to 10*4,10'J, and 10*total cancer risk. As for non-carcinogens, judgment should be used toapportion risk among exposure routes and chemicals to arrive at thesefixed risk levels, j

Comment No. 2

The Preliminary Remediation Goals (PRGs) should be changed to reflect the new MaximumContamination Limits (MCLs) as outlined in the April, 1992 U.S.EPA Office of WaterDrinking Water Regulations and Health Advisors; Federal Register No. 56, dated January30, 1991; and Federal Register No. 57, dated July 17, 1992. The following PRGs need tobe changed to reflect the updated MCLs: 2

Contaminant MCLEthylbenzene 700 ug/1Styrene 100 ug/1Tetrachloroethylene 5 ug/1Toluene 1,000 ug/1Vinyl chloride 2 ug/1Xylenes 10,000 ug/1Di (N-Ethylhexyl)phthalate 6 ug/11,2,4-Trichlorobenzene 70 ug/1Antimony 6 ug/1Beryllium 4 ug/1Nickel • •' 100 ug/1Thallium 2 ug/1Cyanide 200 ug/1

Mr. Mark A. Traven • October 20,1992

305577

/Red;Comments on the "Feasibility Study,

Novak Sanitary Undfill" dated July 8. 1992

APPENDIX A: SOIL GAS SURVEY

3.0 TEST RESULTS3.1 Methane

Page A-5. 2nd Paragraph. Last Sentence;

There is a typographical error in this sentence. The sentence should read: Methane readingstaken..., as opposed to: Methane reading stake.... i

Table A-l

Several readings are noted to have initially read 100% and then dropped to a lower level.This is a very important fact and should be discussed in the text If the needle on theexplosimeter pegs and then returns to zero it is an indication that the readings exceeded theupper explosive limit The quick peak and deflection to zero occurs because the gas mixturein the combustion cell is too rich to burn and causes the filament to conduct a current justas if the atmosphere contained no combustion at all. Geraghty and Miller should reassesstheir field notes to be sure that all soil gas locations that originally peaked on theexplosimeter be included in the table. According to the EPA contractor's notes, LFG # 81and LFG #1 locations also exhibited a quick peak and then zero on the LEL meter, i

/ M r . Mark A. Traven October 20,199210

SQ\Q\[UU», g Summary of Preliminary Remediation Goals for Ground Water, Novak

Sanitary Landfill, South Whitehall Township, Pennsylvania

Constituent Preliminary SourceRemediation

______________________Goal (ug/1)________________Volatile Organic Compounds:

Acetone NEBenzene 5 SDWA MCL; PADER WSCChlorobenzene 100 PADER WSCChloroethane NE11-Dichioroethylene 7 SDWA MCL; PADER WSC1,2-Dichloroethane 5 SDWA MCL; PADER WSCU-Dichloropropane 5 Phase II NPDWRtrans-l,3-Dichloropropene 0.47 PRG for Target Risk (a)Ethylbenzene 700 Phase H NPDWRMethylene Chloride NE4-Methjrl-2-Pentanone NEStyrene 100 Phase II NPDWRTetrachloroethylene 5 Phase II NPDWR; PADER

WSCToluene 1.000 Phase fl NPDWRl,U-Trichloroethane 200 SDWA MCL; SDWA Non-

Zero MCLG; PADER WSCTrichloroethylene 5 SDWA MCL; PADER WSCVinyl Chloride 2 SDWA MCL; PADER WSCXylene(s) total 10,000 Phase II NPDWR

l>Dichlorobenzene 600 Phase II NPDWR; PADERWSC

U-Dichlorobenzene 600 PADER WSCl,4-Dichlorob««ene . 75 -PABER WSCDiethylnhthalate NE ilC- ^ "~VODi-N jM hthalate ' *NE f ^ ——Bis(2-ethylhexyl)phthalate 6.1 PRG for Target Risk (a)4-Methylphenol NENaphthalene NE1,2,4-Trichlorobenzene

GERAGHTY & VflLLER. INC A R 3 0 5 5 7 9

Table 2-6 (Com). Summaiy

constituent "reuminaryRemediation

AntimonyArsenic

CalcnunChromium

Spper

NickelaarSilver

ThalliumVanadiumZincCyanide

«

ORIGINALRed)

nsidered Criteria for Remediation, if Necessary, at

NPDWR PHASE V NPDWRrERIA(u

Chemical Name ___________(PENDING MCL)

Ortanict

500 *»Andipatei JW(Dietaylhexyl)adipatel 200Dalapoa 5 0 (a)Dichloromethane ^ 7Dinoseb __ 20Diquat M 100EndothaU IUI 2Endrin nf 700Glyphosate /UT 0 (a)Hexachlorobenzene * 50Hexachlorocydopentadiae »j- 200Oxamyl (Vydate) *» 0 (a)PAHs lBenzo(a)pvrenel «•*Fhthalates 0 (a)[Di(ethylhexvl)phtha!atel * 500Pidoram ^ 1Simaziae ->/% .- 9l TrichloiobenzenB V O 3LW-Trichloretbane 5 ..2A73-TCDD

Inorganics

Contaminant Level-Goals of zero are not be considered relevant and appropriate.

/JR30558IGERAGHTV MIT t PP ivr

UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY …Suite 601 Knoxville, TN 37923 SUBJECT: Novak...

Documents

Transcript of UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY …Suite 601 Knoxville, TN 37923 SUBJECT: Novak...