Pollution Report Profile - EPA OSC Response

Tank Car Corporation of America
Oreland, PA - EPA Region III
POLREP #41 - Mar 20-26

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On-Scene Coordinator - Myles Bartos, On-Scene Coordinator	4/4/2011
Time-Critical - Removal Action	Pollution Report (POLREP) #41
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
Heavy rains occurred much of the week.  The early part of the week did not include loading out small lagoon waste due to pending approval from PADEP for additional volume to the landfill and the inclement weather.

After approval on March 25th, ERRS equipment operators resumed the load out of small lagoon waste material.  Excavation of small lagoon waste, and backfill excavated areas with stockpiled sandblasting material also continued when weather allowed. The crew worked Saturday to catch up on disposal.

At total of 63 loads of small lagoon non hazardous waste with an estimated weight of 1,449 tons were shipped to Waste Management GROWS/ Tulleytown landfill in Morrisville Pennsylvania. 4763 tons to-date.

EPA continued to maintain "clean" and dirty" sides of the Site to minimize the potential for cross contamination.  In an effort to meet this goal, specific traffic patterns that have been established for Site workers as well as Site tenants continue to be enforced.

On-Site mud control and off-Site minimization efforts continue.  Trucks are directed to drive over an approximately 75 foot stone pad (with 2-3 inch stone) to knock off any mud from the tires.  The Township is aiding by sweeping the streets on a routine basis.  It is important to note that any mud tracked onto the streets is "clean" since the trucks do not enter the "dirty" portion of the Site.

Importing backfill from an off-site location continues as weather permitted and trucks were available.

The crew also repaired the fencing along the Eastern border of the Site.

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.

In addition to the standard equipment used EPA also conducted air monitoring around the Site using a more sensitive instrument called a PPB RAE.  This instrument measure concentrations of volatile organic compounds in parts per billion. The standard instrument (Multi RAE) detects in parts per million or PPM.  Parts per million is the unit measurement with which we traditionally use to evaluate worker safety.   This is also, depending on the contaminant, the unit measurement that OSHA uses.   Air monitoring with the PPB Rae continued to confirm the Area RAE findings that there are no levels of concern on the Site.  The PPB RAE did detect concentrations when within feet (generally 1-3) of the waste, but the levels were still below health concerns.  Additionally, the levels immediately and rapidly dropped as the distance from the waste increased.  It should be noted that while the odor is still present, the data indicates the concentrations are below levels of concern.

EPA continued outreach to the community through a variety of methods including the website, email, phone call, and door to door.

EPA also continues to coordinate with appropriate regulatory agencies as needed including the Township and Pennsylvania Department of Environmental Protection.

EPA is still estimating a mid April completion of major disposal and backfilling activities.  There will be some remaining restoration activities that go beyond as required.

Planned Removal Actions
EPA will schedule disposal of the RCRA hazardous material upon approval from the Environment Canada (Canada's equivalent of the EPA). This material will be disposed of at Stablex in Quebec, Canada.

EPA will begin final grading, restoration and decontamination of equipment as appropriate

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 4763 tons	various	Waste Management , (GROWS), PA
Hazardous solids (small lagoon)		various	Stablex Canada, Inc Quebec, Canada
Non Hazardous solids (sands)		various