Pollution Report Profile - EPA OSC Response

Tank Car Corporation of America
Oreland, PA - EPA Region III
POLREP #19 - Revised Action Memorandum Signed

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On-Scene Coordinator - Michael Towle, On-Scene Coordinator	5/22/2010
Time-Critical - Removal Action	Pollution Report (POLREP) #19
Start Date: 1/29/2007

Site Description
See previous POLREPS for Site description information.  A summary of the removal site evaluation (characterization) conducted is contained in the document "Summary of Removal Site Evaluation Analytical Data", dated February 2, 2010, posted to the web at www.epaosc.org/tcca.  In general, the Site contains inorganic and organic contamination of soil (primarily sandblasting grit) and shallow underground water (contaminated by former lagoon contents and tank releases).  Additionally, the Site's ground water and surface water exiting the TCCA property contains detectable concentrations of Site-related contamination.  Finally, samples collected from residential properties adjacent to the Site and from dirt alongside the roadways leading from the Site contain detectable concentrations of inorganic and/or organic contaminants attributable to the Site.

The TCCA Site contains a large amount of sandblasting grit contaminated by inorganic contamination (e.g., lead) and organic contamination (e.g., polycyclic aromatic hydrocarbons (PAHs)).  The Site formerly contained lagoons; the residuals in these lagoons contain high concentrations of organic contaminants such as benzene, naphthalene, and PAHs and these contaminants have entered into the subsurface soils and shallow underground water.

The Site property continues to be used by numerous businesses for storage of equipment and materials.

A prospective purchaser of the Site discussed a potential purchase with the Pennsylvania DEP.  However, the purchase did not occur.  Based upon the analytical results of the samples collected during the removal site evaluation and an evaluation of the potential threats posed by the hazardous substance contamination at the Site, EPA Region III approved additional funding to conduct additional response actions at the Site.

On April 8, 2010, EPA Region III approved an additional $2,255,803 for continued response actions at the Site.  The total funding now available for response actions is now $2,650,469.  The response action will generally include actions intended to consolidate onto the TCCA property those hazardous substances posing a threat which have migrated from the property and to minimize further release of hazardous substances from the Site through a combination of disposal and covering actions.

Current Activities
On June 30, 2009, samples had been were collected from soil located alongside Walnut Avenue.  These samples were collected in response to comments received at the June 17, 2009, community meeting at which EPA was advised that soil migrates along Oreland Mill Road especially during rain events.  The soil is thought to originate from the TCCA Site.  The analytical results indicated low levels of Site-related contaminants.  Samples were also collected along Oreland Mills Road on August 19, 2009.  Again the analytical results of the samples suggest low levels of Site-related contaminants.  In general, the roadside sample data indicate that hazardous substances may be able to migrate from the Site.

On October 24, 2009, EPA collected samples of surface water presumed to be draining from the Site through a pipe under the railroad tracks and then exiting onto properties located north of the Site.  The samples indicated that hazardous substances attributable to the Site are present in the surface waters draining from the TCCA property.

The PA DEP had been coordinating with a prospective purchaser of the property to evaluate the potential for remediation under PA's Land Recycling Program (Act 2).  However, the prospective purchaser has not submitted information to PA DEP indicating that it intended to purchase and/or remediate the property.  Subsequently PA DEP and EPA considered further response actions would be conducted by the government.  EPA has initiated a search for parties potentially responsible for the contamination by investigation of the records contained in the TCCA offices.

There continues to be no legal access to the railroad right of way needed in order to fully characterize the contamination at the Site and implement response actions which may be needed to minimize further off-property releases of contamination.

The ERRS contractor continues to be temporarily demobilized until the OSC can obtain access to the area require response actions.  Parts of the area requiring response actions are occupied.  Additionally, the OSC finds that the portion of the response action which may disturb organic contamination should be conducted during cold weather time periods in order to minimize odors.

Planned Removal Actions
The planned Removal Actions are summarized in the Action Memorandum dated April 8, 2010.

Next Steps
Coordinate with TCCA owner and tenants to develop a plan for implementation of the response action. Currently, the land is used by several entities.

Continue to attempt to gain access to the railroad right of way in order to characterize the extent of contamination and evaluate off-Site drainage pathways. The area must be evaluated in order to develop proper erosion and sedimentation controls.

Key Issues
Access to the Site and adjacent properties is not established

Disposition Of Wastes

Waste Stream	Quantity	Manifest #	Disposal Facility
Hazardous Waste Liquids (USTs)	13,330 gallons	various	Republic Environmental Hatfield, PA
Hazardous Waste Liquids (AST-2)	14,011 gallons	various	Republic Environmental Hatfield, PA
Non Hazardous Liquids (AST-1)	14,590 gallons	various	Republic Environmental Hatfield, PA
Non Hazardous Solids (AST-4)	31840 pounds	552437	Republic Environmental Hatfield, PA
Non Hazardous Liquids (Ammonia)(AST-5)	7518 gallons	various	Vickery Environmental, Vickery, OH
Hazardous Waste Solids (USTs)	387 tons (est)	various	CasieEcology, Vineland, NJ
Hazardous Waste Liquids (UST-4)	8356 gallons	various	Giant Resource Recovery, Sumter, SC
Hazardous Waste Solids (UST-4)	25,632 pounds	004352265	Green America Recycling, Hannibal, MO
Hazardous Waste Debris (UST-4)	1500 pounds	004352265	Waste Management, Emelle, AL
Flammable Liquids(drums)	165 gallons	004352265	Ross Incineration, Grafton,OH
Flammable solids	300 pounds (est)	004352265	BuzziUnicem, Cape Girardeau, MO
Phosphoric Acid	55 gallons	004352265	WastePath, Calvert City, KY
Non Hazardous Liquids (drums)	140 gallons	004352265	WastePath, Calvert City, KY
Non Hazardous Soil (around UST-4)	209.42 tons	various	Commonwealth Environmental, Hegins, PA
Waste Fuel	760 gallons	77436	Enviromental Recovery Corp., Lancaster, PA
Non Hazardous solids (UST residue from scrapping ops)	300 pounds	001	Modern Landfill,York,PA