Pollution Report Profile - EPA OSC Response

Tank Car Corporation of America
Oreland, PA - EPA Region III
POLREP #37 - Feb 21-27

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On-Scene Coordinator - Myles Bartos, On-Scene Coordinator	2/28/2011
Time-Critical - Removal Action	Pollution Report (POLREP) #37
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 Time Critical Removal Action is ongoing and current activities are described in the next sections.

Current Activities
93 truckloads of non-hazardous large lagoon waste was shipped offsite to Clean Earth in Morrisville, PA.  This volume equates to approximately 2,211 tons of material.  To date, approximately 8,548 tons of non-hazardous large lagoon waste has been disposed from the large lagoon.

3 truckloads of non-hazardous C&D (scrap wood, concrete, etc) were properly disposed offsite.

The excavated area of the large lagoon continues to be backfilled with the stockpiled sand.  The sandpile is roughly one third of its peak volume and will continue to be reduced as backfilling continues.  The sand continues to be backfilled to approximately 1-1.5 feet below final grade.  A marker fence, orange plastic, is being placed on top and then covered with a minimum of 12 inches of clay material.  On top of the clay material is approximately 4 inches of compacted gravel.  The clay is being imported from an "clean" off-site location.   Photos of the various stages/layers are available on the website.

The final grade diverts the majority of the water towards the center of the Site and towards the railroad tracks (into the sediment pond).  Special care is being taken to avoid routing water towards residential properties. It is important to note that runoff control is a "water management" issue concern and not a health based concern.

Air monitoring continues around the Site, as per the air monitoring plan.   Odors continue to be present during the excavations and truck loading.  However, air monitoring indicates no levels of concern.

ERRS contractors continue their efforts to minimize mud tracking and dust control as needed.  ERRS also collected additional samples in the small lagoon area to meet the disposal regulatory requirements of the Pennsylvania Department of Environmental Quality.  This sampling was necessary based on the anticipated increase in waste volume noted in the prior POLREP.

EPA continued outreach with concerned residents near the Site via email, phone, and the website.

Members of EPA upper management and the EPA Inspector General's office visited the Site on February 23rd.  The goal was to familiarize them with an active removal Site, including daily operations, regulations, and authorities.

Planned Removal Actions
Begin excavation and disposal of small lagoon materials.

Continue backfilling and capping of large lagoon.

Key Issues
To date, we have not encountered shallow groundwater that necessitates the use of the water treatment tanks on the Site. We are evaluating the need to keep the system.

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
Non Hazardous Construction Debris	approx 600 tons	various	Minerva Enterprises
Non Hazardous solids (large lagoon)	approx 8548 tons	various	Clean Earth, Morrisville, PA
Non Hazardous solids (small lagoon)		various
Hazardous solids (small lagoon)		various
Non Hazardous solids (sands)		various