Pollution Report Profile - EPA OSC Response

Tank Car Corporation of America
Oreland, PA - EPA Region III
POLREP #38 - Feb 28 - Mar 5

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On-Scene Coordinator - Myles Bartos, On-Scene Coordinator	3/8/2011
Time-Critical - Removal Action	Pollution Report (POLREP) #38
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
The large lagoon load out was completed this week with 16 trucks being shipped (approximately 423 tons).  Total waste shipped from the large lagoon was approximately 8,972 tons.  The load out area will remain in the same location for loading out the small lagoon.  At the end of the project, this area will be cleaned and restored to grade.

Small lagoon removal operations began on 3/1/11.  Disposal began on March 3, 2011.  The material is being disposed at Waste Management GROWS landfill in Morrisville Pennsylvania. 30 truckloads of non hazardous waste with an estimated weight of 646 tons were hauled off. Approximately 646 tons have been disposed to-date.

A clarification for the requested and approved tonnage/volume is being sent to PADEP for review.  The original request mistakenly used tonnage as the nomenclature for units.  The correct nomenclature should have been cubic yards.  This administrative correction will be provided to PADEP for review and approval.    Subsequently, a request for additional cubic yards will also be generated and submitted to increase the disposal volume to 7,500 yards (equivalent to approximately 10,125 tons).  This should be submitted by next week.

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

ERRS contractors continue their efforts to minimize mud tracking and to minimize dust generation.

A 30 ft x 30 ft section, approximately 400 tons of the small lagoon waste that tested to be hazardous was removed and stockpiled onsite. The pile was placed on plastic and covered to reduce odors. This material will be shipped to Stablex for disposal.

ERRS stabilized the Site in preparation for heavy rains over the weekend.  This included temporary berms, french drains, and general grading to insure proper surface water management. The goal is to keep water draining first towards the middle of the Site and then flow back towards the tracks (the sediment pond).

ERRS and EPA worked on Saturday to complete these preparation efforts as well as remove and repair wind damage to an onsite structure.

Due to the expected increase in the small lagoon disposal volume/tonnage, the stockpiled sand may not be adequate volume to fill in the excavation.  ERRS looking at options to procure clean fill to bring the Site back to grade.

EPA continues to provide updates to the concerned residents, the Township, the State,  and other regulatory agencies as requested.

Planned Removal Actions
Continue disposal.

Continue backfilling, capping, and final grading.

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)	approx 646 tons	various	Waste Management , (GROWS), PA
Hazardous solids (small lagoon)		various
Non Hazardous solids (sands)		various