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The Final (100%) Remedial
Design document was submitted to USEPA and PADEP on April 11, 2008
and was approved by USEPA/PADEP on May 8, 2008. The Final Design
presents Gould’s
proposal on how the Final Remedy will take place, what
will be done, and what the Site will look like after the remedy is
implemented. It incorporates the comments received from USEPA/PADEP
(received on August 10, 2007) on
the 30% Design and Gould's responses to USEPA/PADEP's Comments (submitted on September
7, 2007).
(USEPA/PADEP Comments on
the sampling and analysis portion of the 30% Design were received on
October 4, 2007. Gould responded to USEPA/PADEP's comments on
the sampling and analysis portion of the 30% Design on November 28,
2007. USEPA/PADEP's Comments and Gould's responses were added
into the 90% Design Document.)
This web page provides an overview
of the remedial activities as proposed in the Pre-Final Design
(Click
Here for the Overview),
information on proposed construction phasing
(Click
here for Construction Phasing),
and a summary of proposed permitting for implementation of the Final
Remedy
(Click here for Permitting).
NOTE: Similar to the 30% Design
document, the 90%
Remedial Design document fills two 3” binders and as such is too
large a document to put on this web site. The 90% Design
document, however, is available for review at the Marjol Community
Relations Office at 502 George Street in Throop (please call
570-383-9313 or e-mail Lisa Ayers at layers@advancedgeoservices.com
for an appointment) or at the Marjol Battery Site Repository located
at the Throop Municipal Building, 436 Sanderson Street in Throop,
PA.
OVERVIEW OF REMEDIAL ACTIVITIES AS PROPOSED IN
THE PRE-FINAL DESIGN
Implementation of the
Final Remedy for the Marjol Battery Site generally includes the
following activities:
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Site Preparation
- Establishment of the Support Zone (a “clean” area for office
and equipment trailers, etc.), Decontamination Area, and Access
Roads - The existing infrastructure will be used as much as
possible, but alternate or additional items will be added as needed.
It is anticipated that additional office and equipment trailers will
be mobilized by the Contractor. These trailers will be staged at the
existing support zone at the start of work. There will however, be a
point during construction when all trailers will be moved to a
second support zone (at the northeast corner of the facility) to
allow for excavations at the existing trailer location. The main
entrance at Delaware Street will be used, except when excavation and
restoration is occurring at the entrance. During the time period
when the Delaware Street entrance is being excavated and restored,
the existing Woodlawn Street entrance south of the existing trailer
area will be used for personal vehicles. Delivery vehicles and
trucks will not enter the Site during the time period when the
Delaware Street entrance is closed. Deliveries will be sequenced to
occur prior to the entrance being closed so that adequate materials
are present for work activities to continue. Traffic on
Borough roads will be minimized to the extent possible but there
will be traffic going into and leaving the Site especially during
mobilization, cap construction, and demobilization. The details of
road protection will be determined based on Throop Borough
requirements.
- Security - Gould will provide 24-hour per day site security
during active construction and demobilization. In addition,
the Contractor will establish procedures to prevent unauthorized
entry into the Site and to document all visitors.
- Installation of Dust Control
Measures and Erosion Control Measures - Dust control will be
provided by water spray and covering stockpiles at the end of each
work day. Air monitoring for dust and lead will be conducted during
all phases of soil disturbance to ensure that the surrounding
community is protected.
(Click
here for more information on air monitoring during construction.)
Erosion and sediment control measures,
consisting primarily of silt fencing, hay bales, construction
entrances, check dams and temporary diversion channels and berms, will be
installed to control sediment in runoff from impacting
non-contaminated areas and to control surface water from impacting
construction operations.
Clearing and Grubbing - In areas of excavation less than or
equal to 12 inches in depth, clearing of vegetation, brush and trees
less than 12 inches in diameter will occur to prepare areas for
excavations and consolidation. In areas of deeper excavation (in the
North Woods and within the Containment Area and perimeter berm
footprint), all vegetation, brush and trees will be cleared. Grubbing
will be performed in all cleared areas just prior to
construction or excavation. The chipped materials are considered clean and will not be placed in the Containment Area. Grubbed
materials from within the areas of contamination are assumed to be
contaminated and will be disposed of in the Containment Area.
Fence and Road Removal - Existing fencing and access roads
will be removed as needed to construct the Containment Area and to
excavate/consolidate contaminated materials. Road demolition
debris from outside the Containment Area footprint will be placed in
the Containment Area. Alternate fencing will be installed as
needed during construction to maintain site security. Permanent
replacement fencing will be installed at the completion of
construction and as needed for long-term site security.
Well Abandonment and Modification - Some of the monitoring
wells that are in the proposed cap area or that will no longer be
needed will be filled (abandoned) and some of the existing wells
will be made higher so they can be used for long-term monitoring.
One new well is being installed to replace an existing well that
requires too much extension to be practical.
Utility Location and Abandonment - Any existing utilities
including electric, water, sanitary, storm, telephone and gas which
are present in excavation areas or the Containment Area will be
located, disconnected and abandoned, or relocated prior to excavation or
Containment Area construction.
Electric, communications, water and sewer service to the existing
trailer location will be maintained as long as possible, and
terminated immediately prior to excavation in those areas. Electric
and communications service will be provided at an alternate trailer
location when this happens. Water service will be maintained to the
Site as needed for dust control at all times.
Construction of a new Stormwater Basin -
Construction of a new stormwater basin will occur because
the old stormwater basin is located in the area of the cap footprint. Once the
new basin is constructed, stormwater flow will be diverted to the
new basin and the old basin will be removed from service. The
following drawing shows the proposed location of the new
stormwater basin. The new basin will discharge into Sulphur
Creek just as the current basin does.
During construction, only water running over clean areas will be
directed into the new stormwater basin. Water running over
contaminated areas will be directed onto the cap area. During
construction, a skimmer will be used to take water out of the basin
and leave sediment behind in the basin. This protects Sulphur Creek
and the Lackawanna River while construction is going on. The basin
also will have a baffle in it that also helps keep sediment in the
basin. Once construction is complete and grass is growing on all
disturbed areas, the skimmer and the baffle will be removed.
Demolition of On-Site Structures - The Drum Storage Area,
trailer, and existing stormwater diversion structures will be
demolished, and demolition debris will be placed in the Containment
Area. The curbing/barriers at the Low-Haz and High-Haz Stockpile
perimeters will be demolished concurrently with stockpile removal
and placed in the Containment Area or alternatively, they may be
decontaminated and reused as necessary.
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Containment Area
Construction
Following clearing and grubbing, the existing
surface within the Containment Area will be graded and rolled to
create a smooth surface for waste consolidation. A perimeter 10-foot-wide berm will be constructed to provide additional airspace volume
for waste placement and to create a stable surface for anchoring
the layers of the cap. It is anticipated that Containment Area
preparation and construction will occur in two phases to minimize
the size and duration of the disturbed area.
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Waste Excavation and Handling
Contaminated soils and battery casing material
will be excavated from areas outside of the cap area to minimize the
size of the cap, to remove the material from areas of possible
pothole subsidence and to provide isolation from the Five-Foot coal
seam. Based on the results of the PDI, adequate isolation from the
Five-Foot seam is provided by excavating any battery casing material
that is located within 12.5 feet (2.5 times the seam thickness) of
the subcrop of the Five-Foot seam in weathered rock.
Waste excavation and placement includes the
following steps:
- Excavation of contaminated soil and waste material from outside of
the Containment Area footprint;
- Consolidation of contaminated soil and waste material within the
Containment Area; and
- Solidification of the uppermost layer of waste within the
Containment Area with cement-based reagents before placement in the
cap area.
While many of the construction details will be determined by the
Contractor and then approved by Gould and EPA/PADEP, it is anticipated
that the excavation, transport, and placement of contaminated
material into the cap area will be sequenced in a manner to minimize
the potential for cross-contamination of remediated (clean) areas,
to minimize double-handling of wastes, to produce an even
distribution of waste types allowing for wastes suitable for
solidification to be placed in the uppermost waste layer and
materials with the highest lead concentrations to be placed at the
bottom of the Containment Area, and to minimize the area requiring
temporary cover during winter demobilization. As required by the
2006 RCRA Consent Order, confirmatory sampling will be conducted at
the bottom of excavation areas.
It is anticipated that waste materials will be transported in
covered off-road dump trucks. Access roads will be constructed
on-site as needed to allow the dump trucks to travel from an
excavation area to the Containment Area without entering public
roadways.
The uppermost layer of waste will be solidified prior to
placement. This layer is considered to be the first layer of the
cap. The 90% Design calls for placement of 3 lifts of solidified
material to be placed and compacted for a final thickness of 18 to
24 inches.
Dust Control
During construction activities, and in particular,
during soil disturbance activities, the "No Visible Dust" rule will
be strongly implemented. Soils that are set for excavation
will be watered down before they are moved and every effort will be
made to keep from creating dust. In order to be sure that
construction activities are not impacting the air, air monitoring will be conducted during
construction for all phases of soil disturbance to ensure that
the surrounding community is protected. Three types of air
monitoring will be conducted: site perimeter, real-time and
personnel.
- Site perimeter monitoring - this will consist of ambient
air monitoring for lead using the high-volume sampler method, which
is what has been used for the past 20 years at the Site. This
sampling will determine if air lead is being emitted from the Site.
Results with this type of monitoring are not immediate as the air
collection filters have to be sent to a lab for analysis.
Perimeter air sampling will be conducted on a 6 day rotating
schedule with 5 samplers running simultaneously for a 24 hour
period.
During construction, two of the air monitors that are
currently at the Site will be relocated to provide additional
information for the community. One will be placed just inside
the perimeter fence on Delaware Street where it will be visible
to anyone driving near the Site; this will provide air lead data
for residential areas adjacent to the Site. The other was
relocated to the Mid-Valley Secondary Center on February 27,
2008, as requested by Throop Borough’s Planning Agency and
Engineer. This monitor will provide air lead data near the local
schools.
- Real-Time air monitoring (Near Field Zone monitoring) - this type of air
monitoring will determine if dust is migrating outside of the
immediate work area so that additional dust control measures can be
implemented before any dust can move off-site. This
monitoring will consist of hourly, real-time particulate (dust)
monitoring with a hand-held aerosol monitor equipped with a data
logger at locations upwind and downwind of the work zone during all
phases of work with potential for significant release of dust (i.e.,
during soil excavation, backfill, waste placement, and cap
installation.) Real-Time monitoring provides immediate
information on the amount of dust (not just lead) being generated.
- Personnel air monitoring (Work Zone monitoring) - this type of air monitoring
will be performed to determine if site workers are wearing
appropriate personal protective equipment. The monitoring will be
time-weighted average air monitoring for lead exposure.
Results are not immediate as air filter canisters have to be sent to
the lab for analysis.
More details will be provided on the air monitoring once the
contractor develops a more specific sequence for construction
activities.
River Monitoring
Sediment samples will be collected for total lead
analysis from the Lackawanna River quarterly during construction and
the first year of post-construction to make sure there are no
releases of lead due to soil disturbances during construction
activities. Monitoring of the existing stormwater management
basin will not be conducted during construction as the basin will be
removed from service.
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Containment Area Capping
The proposed cap area is 9.7 acres in size. The proposed
footprint of the cap has been designed such that the cap will be
within the existing fence line and at a distance of at least 300
feet from occupied dwellings. The proposed cap is expected to be
able to accommodate all of the contaminated material that is going
to be excavated and consolidated during the final remedy. At this
point, it is not expected that any contaminated material will have
to be removed from the Site.
The layers of the cap, from top to bottom, will consist of the
following materials:
- Vegetative (grass) cover (to help prevent erosion);
- 6 inches topsoil (to retain water in order to sustain
vegetation and to keep the roots of non-woody vegetation from
reaching the drainage layer or geosynthetics);
- Minimum 18 inches cover soil (functions similarly to the topsoil
and also, like the vegetative cover and the topsoil, contributes to
eliminating direct contact with contaminated soil);
- Double-sided geocomposite drainage layer (creates a
preferential path for water to flow into a perimeter collection
system; geonet with geotextile bonded to both sides);
- 60 mil textured LLDPE geomembrane (minimizes
infiltration of rain water into the underlying materials);
- 8-ounce geotextile (to protect the geomembrane from
damage or puncture by the underlying solidified waste material); and
- 18-to-24-inch solidified layer comprised of soil-cement
(provides an extra layer of protection to prevent erosion of
waste materials and releases to air and surface water in the
unlikely event of a breach in the overlying layers of the cap until
the breach could be repaired).
Passive Gas Vents
Even though gas generation from the material placed in the cap is
expected to be minimal because the quantity of biodegradable
material (the type of material that creates gas) is small compared
to the overall volume of material in the Containment Area, passive
gas vents will be installed at the highest point in the cap and on
the sides towards the residential properties as
required by USEPA and PADEP. The passive gas vents will allow gases
generated by decomposition of biodegradable waste to exit the cap
prior to building up at the underside of the cap.
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Restoration and Water Management
- Following completion of excavation activities and confirmatory
sampling, excavation areas will be backfilled and graded to the
extent necessary to achieve drainage. Disturbed areas will be hydroseeded to restore vegetative cover.
An access road will be constructed around the Containment Area to
facilitate long-term operations and maintenance.
Perimeter fencing removed during work activities will be
reinstalled, or replaced with a new fence.
Surface water run-off and infiltrated flow from the cap drainage
layer will be managed by swales along the cap perimeter or will be
allowed to sheet flow away from the cap. The
permanent stormwater management system at the Site was designed in accordance with all state and local
regulations. The removal of trees during excavation activities
will increase the amount of water flowing in the north eastern area
of the Site, so a permanent stormwater diversion berm will be
installed along the eastern property line to prevent flow from
exiting the Site in that direction.
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Off-Site Verification Sampling
Off-site verification sampling will be performed prior to and
following remedial activities to confirm that remedial activities
did not cause off-site contamination. Five locations are
proposed for sampling in areas that were previously remediated.
A total of 20 samples will be collected from each location during
the pre-construction and also during the post-excavation sampling
events. Ten samples from each location will be sent to a lab
and analyzed and the remaining ten samples will be archived for
future analysis if required.
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Proposed Post Remediation
Maintenance and Monitoring
- Post Remediation Maintenance will include mowing and
maintenance of the stormwater management basin.
- Mowing - the Site, including the cap area, will be mowed for
turf establishment. Mowing will be conducted twice yearly during the
growing season (May to October).
- Stormwater Management Basin Maintenance - maintenance will
include measures to control burrowing animals, removal of
accumulated sediment and maintenance of the discharge structure.
- Post- Construction Monitoring will include site
inspections and sampling of groundwater and river sediment.
- Site Inspections - site inspections will focus on the
integrity of the cap area, the erosion and sedimentation controls,
the stormwater management features, the access roadways, site
security, and the general condition of the Site. During the first 6
months following implementation of the final remedy, inspections will be performed
monthly. During the remainder of the first year and second year following
implementation of the final remedy, the inspection frequency will be quarterly.
Inspections will be conducted semi-annually for years 3 through 30.
- Groundwater Sampling - groundwater sampling will be
conducted to ensure that contaminants are not released following
implementation of the the final remedy. Four existing
monitoring wells and one newly installed replacement well will be
sampled before and after construction. Groundwater sampling will occur quarterly for the first year post-construction
and annually thereafter.
- River Sediment Sampling - sediment samples will be
collected from nine locations in the Lackawanna River and sent for
lead analysis on a quarterly basis during construction and for the
first year of post-construction.
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PROPOSED CONSTRUCTION PHASING
Due to the size of the project, it is anticipated that Corrective
Measures construction activities will be conducted during two
construction seasons with winter shutdowns from December through
March, at a minimum. It is anticipated that construction would be
phased as follows:
- Season 1: Construction of proposed sedimentation basin, access
roads and support zone and excavation and placement of a portion of
the waste within
the Containment Area; and
- Season 2: Completion of excavation and placement of the
balance of the waste
within the Containment Area and solidification of the upper layer of
waste, cap installation and Site restoration.
Between construction phases, in areas where waste placement is
not yet complete, a temporary, 6-inch-thick soil cover will be
constructed over the surface of placed wastes or where the existing
soil cover or pavement has been disturbed. The area of temporary
cover required between Phase 1 and Phase 2 is anticipated to be 5
acres. This temporary soil cover will be seeded as part of erosion
control measures.
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PROPOSED PERMITTING
Although it does not appear that any Federal permits are required
for the implementation of the Final Remedy, there are State, County,
and Local permits and approvals that are
required. A summary
of the various permits follows below:
State and County Permits
1) A General National Pollutant Discharge Elimination
System (NPDES) Permit Application for Stormwater Discharges
Associated with Construction Activities was submitted to PADEP on
December 21, 2007. PADEP then notified Gould that an Individual
NPDES Permit would be required instead of a General NPDES permit.
Gould submitted an Individual NPDES Application to PADEP on January
25, 2008. The 30 day public comment period for the Individual NPDES
Permit began on March 8, 2008. A Public Hearing was held on April
16, 2008. PADEP will respond to the public comments raised and
will direct Gould to make any
required changes if necessary and issue the permit.
2) It was determined that water from the new stormwater management
basin will be discharged into Sulphur Creek (similarly to the
existing basin), versus directly into the Lackawanna River.
Therefore, a permit for discharge into regulated Pennsylvania waters
is not needed.
3) PADEP granted Gould a waiver on a wetlands permit for the proposed
filling of the existing basin on September 4, 2007.
4) On October 22, 2007, the PADEP Bureau of Air Quality determined
that an operating permit was not needed for waste solidification
using a pugmill during remedial activities.
5) On December 18, 2007, the PADEP Bureau of Air Quality determined
that an operating permit was not needed for a Passive Gas Vent in
the Cap. On February 20, 2008, Gould submitted a revised request for
a determination of minor significance for installation of more than
one gas vent in the cap; this request was approved.
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Throop Borough Permits
1) A trailer occupancy permit will be requested for
temporary office trailers that will be used to support remediation
activities conducted by the Contractor, Gould, USEPA and PADEP. The
zoning for the Site allows temporary use of office trailers for one
year from the date approval is granted. As it is likely that the
trailers will be needed for up to two years, Gould will request
approval for two years as a special exemption use pursuant to the
Throop Borough code.
2) A zoning permit was obtained on January 24, 2008, for
installation of a new permanent fence at portions of the Site
perimeter.
3) On December 4, 2007, Gould submitted a Stormwater Management Plan
as part of the Preliminary Land Development Plan to the Borough
Planning Commission along with information on proposed dust control
and street protection/traffic control measures. The Stormwater
Management Plan is required by the Borough's Stormwater Management
Ordinances. On December 20, 2007, Gould received comments on the
submission from Robert Nitch of Peters Design Group, on behalf of
the Throop Borough Planning Agency. Gould responded to Mr. Nitch’s
comments on January 16, 2008. The Throop Borough Planning Agency’s
comments will be incorporated into the 100% Design. The applicable
portions of the 100% Design will then be submitted to the Planning
Agency as a Final Land Development Plan.4)
Gould is in the process of discussing with Throop Borough whether a
building permit is needed for the work and will resolve will resolve
that question before the start of construction.
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