Pollution Report Profile - EPA OSC Response

Tank Car Corporation of America
Oreland, PA - EPA Region III
POLREP #20 - Re-Initiation of Response Action

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On-Scene Coordinator - Michael Towle, On-Scene Coordinator	10/19/2010
Time-Critical - Removal Action	Pollution Report (POLREP) #20
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.

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. The total funding now available for response actions is $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.

After obtaining formal access to the railroad property adjacent to the TCCA property, EPA re-initiated the response action at the Site.  Initial actions focused on characterizing the contaminants upon the railroad right of way, evaluating drainage from the TCCA property, evaluating details of the pending response action (such as erosion controls), and coordinating with the Site owner, users of the property, and State and Local government entities.  The OSC informed adjacent residents of the general nature of the pending response action and then re-initiated response activities on October 19, 2010.

A portion of the paint building along the northern boundary of the Site in the area of EPA's planned erosion controls was found to be partially collapsed and shows continued evidence of collapse.  EPA sought and received approval from the owner to remove a portion of the structure to facilitate the response action and improve safe working operations in the vicinity of the building.

OSC Myles Bartos will be assuming OSC responsibilities for all on-Site operations.  OSC Towle will remain involved until SEPTA work is completed.

Current Activities
The OSC met with the cleanup contractor (ERRS contractor)(WRS Compass) and the technical support contractor (START contractor) (Weston) on July 1, 2010, at the TCCA Site for the purpose of setting up and planning for the pending response action.

The Site was surveyed and a map was produced during the week of August 16th.

EPA completed an access arrangement with SEPTA (railroad) on July 26, 2010, and then conducted activities on the railroad right-of-way during the week of September 6th.  The activities intended to assist EPA 1) determine the depth of sandblasting grit which migrated onto the right-of-way and 2) find the location and condition of a pipe believed to exist under the tracks which may have conveyed surface water drainage from the TCCA Site.

Sandblasting grit was found to have completely buried the industrial siding alongside TCCA.  SEPTA identified a buried cable within the right-of-way which limited the EPA investigation (limited the use of certain equipment). The EPA investigation found between approximately 8 and 18 inches of sandblasting grit on the SEPTA right of way.  The EPA investigation was unable to locate a drainage pipe on the TCCA side of the SEPTA right-of-way.

The ERRS contractor was mobilized to the Site to investigate the suspected drainage pipe from the opposite side of the railroad tracks.  The pipe was found and inspected with a camera.  The pipe appears to be blocked with concrete.

Residents adjacent to the Site, users of the Site, the owner of the Site, and State and Local government were informed of the general nature of the action in early October.  Basically, the initial stages of the action will include the removal of some vegetation, installation of erosion and sedimentation controls, and consolidation of the sandblasting grit not impacted by lagoon waste.  Users of the Site were informed of the need to move certain equipment and materials stored at the Site in order to facilitate the response action.  The response action was subsequently initiated on October 19, 2010.

Planned Removal Actions
The planned Removal Actions are summarized in the Action Memorandum dated April 8, 2010. Basically, erosion controls and sedimentation controls are planned for installation, certain vegetation will be chipped and/or removed, certain debris will be disposed, and sandblasting grit not impacted by lagoon waste will be consolidated.

The planned erosion and sedimentation controls must include features to control and release storm waters from the Site in such a manner that sandblasting grit is not continually released from the Site. The controls need to be constructed in the vicinity of a partially collapsed building. EPA will need to remove a portion of the structure in order to proceed safely and effectively and in order to install the appropriate controls.

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