The Osborne Landtill Was Used for Many Years by Numerous Companies and Individuals in and Around Grove City Es a Place to Dispose of Unwanted Waste

SUMMARY OF COOPER INDUSTRIES, INC. INVOLVEMENT IN THE INVESTIGATION OF THE OSBORNE LANDFILL RI/FS

The Osborne LandTill was used for many years by numerous companies and individuals in and around Grove City es a place to dispose of unwanted waste. In 1981, the U.S. Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Resources (DER) began their investigation of the need to clean up this site under the Comprehensive Environmental Response, Compensation end Liability Act (CERCLA or "Superfund"), 42 U.S.C. §9601 et sea. The efforts by U.S. EPA and Pennsylvania DER have involved the continuing cooperative effort of Cooper Industries, inc. whose C-B Reciprocating Division plant in Grove City used the Osborne Landfill to dispose of its foundry sand. EPA has identified parties who owned or operated this site, or who sent waste to it, including General Electric Corporation, Ashland Chemical Company, and Wolfe Iron & Metal Company (now Castle Iron & Metal). Typically, such parties, known as Potentially Responsible Parties (PRPs), attempt to reach agreement with the government to perform the investigative and remedial work at their expense. This avoids the need for the government to spend Federal Superfund monies for the task. It also has been shown that these privately funded projects are done more efficiently and at less cost than those done by government contractors. This is in the best interests of these PRPs, because the government can require them to reimburse the Superfund for all such expenses that are performed consistently with the National Contingency Plan (NCP), 40 C.F.R. Part 300. None of the other PRPs at the Osborne site has stepped forward to participate in the clean up or remediation of the site, or contribute financially to the high cost of doing EPA's bidding; EPA has not pursued them in an attempt to secure their participation. Cooper voluntarily came forward in early 1983 and has spent over $1.5 million since then studying the contamination and risks at the site, removing sources of contamination and securing the site. Cooper's participation in this effcrt has been one of continuing cooperation with EPA and DER, and Cooper stands ready today to take reasonable steps, in conjunction with other responsible parties, to protect the citizens of Grove City from any danger from this site. The history of Cooper's involvement is as follows. On January 14, 1963, EPA notified Cooper Industries and other PRPs that it was prepared to spend Superfund money to investigate the Osborne Landfill site and perform any necessary cleanup (Exhibit 1). This same letter demanded that Cooper identify which of the proposed activities it would be willing to undertake. Cooper was the only PRP to step forward and enter into discussions with the Pennsylvania DER and EPA and offer to take the actions demanded. By May 12, 1983, Cooper had

303247 submitted to EPA and DER a program which included the performance of a remedial investigation (RI), the implementation of interim remedial measures (including the removal of drums and other containers as well as contaminated soil from the site), and the preparation of a feasibility study (FS) to evaluate options for any additional remedial action that the RI might indicate would be required (Exhibit 2). On May 13, 1963, Thomas C. Voltaggio, Chief, Superfund Branch, U.S. EPA, Region III, responded to Cooper's offer by stating: [Respecting the implementation of certain initial remedial measures at the Osborne Landfill ... I acknowledge and applaud the willingness of Cooper industries, Inc. to implement these initial remedial measures. I find that the implementation of these measures, as described in your letter, would be consistent with the National Consistency Plan. (Exhibit 3). Dwight D. Worley, Chief, Division of Operations, Bureau of Solid Waste Management, PA DER wrote to Cooper on May 23, 1983, and reiterated Mr. Voltaggio »s praise and finding that the proposal was consistent with the National Contingency Plan (Exhibit 4). However, at a meeting on May 31, 1963, among DER, EPA and Cooper, EPA announced that it was rejecting Cooper's offer to do the work because, under EPA's then interim policy, the PRPs would not be allowed to undertake remedial action unless they committed in advance to perform whatever cleanup EPA determined was necessary after completion of the studies (Exhibit 5, Letter from James A. Rogers to Gene A. Lucero and Stephen R. Wassersug, June 16, 1983). EPA announced that it

30324* intended to have its own contractor, NUS Corporation, perform the RI and FS work. On June 16, 1983, Cooper objected to EPA's refusal to allow Cooper to perform the RI/FS, and Cooper reiterated its offer. Cooper continued to send its "site activity reports" to EPA and DER and to inventory and prepare for the removal of the drums and contaminated soil (Exhibit 6). EPA continued to "thank" Cooper for its "cooperation" in taking these actions at the site (Exhibit 7), and Cooper continued to respond quickly and helpfully to requests made by EPA (Exhibits 7 6 8). During June and July 1963, Cooper continued its efforts to reach agreement with the government to perform this work. Working with DER, Cooper developed a Consent Order and Agreement that incorporated to the maximum extent possible those elements EPA deemed essential (Exhibit 9). When an agreement acceptable to DER was reached, DER sent the proposed Consent Order and Agreement to EPA for comment (Exhibit 10). Thomas Voltaggio, Chief, Superfund Branch, U.S. EPA, Region III, responded that: Since Cooper's commitment to perform the remedial investigation consistent with the Agency's March 1983 Remedial Action Master Plan satisfies the National Contingency Plan ("NCP") and its commitment to perform the remedial cleanup satisfies the Agency's current requirements for a private party cleanup, we will defer to your request that the site be "State lead . . . ." (Exhibit 11, letter from Thomas C. Voltaggio (EPA) to Donald Lazarchik (DER)).

-4- As a result, on September 23, 1983, DER and Cooper entered into a Consent Order which required Cooper to do the work in lieu of the government or its contractors. This included the following: (1) identify types and quantities of wastes sent to the Osborne site; (2) implement specified interim remedial measures; (3) conduct an RI in accordance with a work Plan attached to the Consent Order, which was to meet the requirements of the National Contin- gency Plan (NCP); (4) upon approval by DER of the RI report, submit a proposed FS plan that meets the requirements of the NCP; (5) submit a final FS report to DER so that DER could issue a record of decision selecting a remedial alternative; (6) implement the remedial alternative selected by DER. (Exhibit 12, Consent Order and Agreement between EPA and DER). After signing the Consent Order and Agreement, Cooper proceeded with the project. On November 1, 1963, DER acknowledged that Cooper had satisfactorily completed the initial remedial measures in accordance with the Consent Order, and authorized Cooper to continue the site investigation phase (Exhibit 13). DER further acknowledged that Cooper had satisfactorily completed the first phase in less than half the time allotted in the order. Id. On December 16, 1983, DER

-5- 303250 acknowledged Cooper's successful completion of Phase II of the work plan pursuant to the Consent Decree, and again, credited Cooper with having completed the task in nearly half the estimated time allocated (Exhibit 14). On December 29, 1983, Cooper received a letter from the Appalachian Audubon Society stating: The Appalachian Audubon Society understands that one of your subsidiaries, Cooper Energy Service of Grove City, Pennsylvania, is in the process of cleaning up toxic wastes found at the Osborne landfill near Grove City in Mercer County. we want you to know we applaud their efforts. The initiative your company shows in this project is highly commendable. Thank you for keeping our environment and Grove City's water supply clean. (Exhibit 15). On June 19, 1984, the RI was completed in final form. In response to a request from DER and EPA, Cooper performed additional investigations for and evaluations of data at the site (Exhibit 16). On December 19, 1984, Cooper's consultant extracted and analyzed soil samples from the site even though this exceeded what Cooper had agreed to do (indeed exceeded what EPA and DER had asked Cooper to agree to do) in the Consent Decree (Exhibit 17). The analysis supported Cooper's earlier conclusions regarding soil contamination at the site, i.e. that the levels of contamination at the site were not affecting groundwater or surface water quality. Id.

-6- On January 20, 1985, Cooper stood ready and willing to perform a feasibility study, and requested approval from DER to begin. Id. In May 1985, DER requested Cooper to undertake an additional round of sampling (Exhibit 18, letter R.w. Teets (Cooper) to Abreu-Cintron (EPA), Sept. 16, 1985). Cooper, believing the additional sampling wasteful and unnecessary, appealed the request to the Pennsylvania Environmental Hearing Board. Id. On August 30, 1985, EPA also requested of Cooper additional sampling at the site; but the protocol was not the same as that established by DER in May. Id. In October 1985, DER withdrew its request for additional sampling because EPA had conducted five days of sampling at the site in late September (Exhibit 19). It was not until May 1986 that EPA sent some of the sampling results to Cooper. However, after reviewing the results, both EPA and DER concluded (as had Cooper) that no further investigative work was needed at the site, and authorized Cooper to take the next step, i.e. the feasibility study (Exhibit 20, letter July 7, 1986 P. Tan (EPA), and Exhibit 21, letter September 16, 1986 R. Roush (DER) to R. Teets (Cooper)). DER directed Cooper to proceed under the Consent Order and submit the FS plan. Id. On October 31, 1986, Cooper submitted the FS work plan in accord with the Consent Order and asked for approval to proceed with the FS and final remediation at the site (Exhibit 22, letter October 31, 1986 R. Teets (Cooper) to R. Roush

-7- (DER)). Cooper was given "conditional approval" by EPA and DER in January 1987 to proceed with the FS, indicating that certain further actions would be required to obtain full approval. On January 6, 1987, DER wrote to Cooper, enclosing a December 5, 1986 "draft" evaluation or Fred C. Hart's FS work plan prepared by EPA consultant, NUS Corporation (Exhibit 23 letter January 6, 1987 R. Roush (DER) to R. Teets (Cooper)). In its letter DER raised for the first time the issue of incorporating new requirements under the Superfund Amendments and Reauthorization Act of 1986 ("SARA"). SARA was passed in October 1986, more than three months after EPA and DER had determined that Cooper's RI was complete. The letter also attached an October 14, 1986, internal EPA memo in which the "Bioassessment Task Group" recommended further RI evaluation of the "wetlands" segment of the Osborne site. This recommenda- tion was first received by Cooper more than six months after EPA and DER had issued their determinations that Cooper had completed the RI in compliance with the NCP (Exhibit 19). Discussions among Cooper, EPA and DER followed, during which it was agreed that Cooper would revise the FS work plan and resubmit it. In the meantime, NUS Corporation issued another "draft" report, evaluating the RI report completed almost a year earlier (Exhibit 24). On June 24, 1987, Cooper submitted to EPA and DER a revised FS work plan (Exhibit 25), offered again to perform the work, and to enter into a written agreement with EPA and DER concerning Cooper's performance of

-8- the work (Exhibit 26, letter from Jack Montgomery to James Shack (DER) and Patricia Tan (EPA) dated June 24, 1987). m response to Cooper's second draft FS work plan, DER stated that it was asking EPA to reassume the lead on this project so that the FS could be financed with Fund money (Exhibit 27). Cooper replied to DER's information by letter dated October 16, 1987 (Exhibit 26, letter October 16, 1987 R. Teets (Cooper) to D. Lorenzen (DER)) and requested a meeting with DER to reiterate its previously stated desire to perform the "Remedial Investigation/Feasibility Study Work Plan in accordance with all applicable laws and regulations." Id. Instead of a response from DER, Cooper received a letter, dated October 22, 1987, from EPA notifying Cooper that EPA had assumed the lead governmental responsibility for the site, and that it was assigning NUS Corporation the task of completing "the Remedial Investigation and Feasibility Study (RI/FS) at this site using Superfund monies." (Exhibit 29, letter October 22, 1987 p. Tan (EPA) to R. Teets (Cooper)). Thus, EPA was assigning its contractor the task not only of preparing the Feasibility Study that Cooper had agreed to prepare, but also of performing an entire new Remedial Investigation, even though EPA had previously stated that the Remedial Investigation completed by Cooper in 1985 and confirmed by EPA in 1986 was sufficient. In its October 22 letter, EPA stated that it would select a remedy and issue a record of decision (ROD) after giving Cooper and other members of the public an opportunity to

-9- comment on EPA1s tentative selection of a remedy, id. Cooper first received a copy of EPA's "Draft" RI on June 9, 1989. On July 31, 1989, Cooper sent to EPA its comments on the "Draft" RI, identifying the erroneous premises upon which its conclusions had been based, and pointing out that nothing in this RI demonstrated circumstances different from those demonstrated in the RI performed by Cooper and approved by EPA (Exhibit 30). On August 16, 1989, representatives of Cooper met with Roy Schrock, Acting Chief, Western Pennsylvania Section, Superfund Division, U.S. EPA, Region III. At that meeting, Cooper stated its specific objections to EPA's draft RI/FS, explaining that EPA's preferred alternative for cleaning up the site — a $19 million proposition — overstated the risk and could accomplish nothing more than an alternative rejected by the draft FS which would cost nearly $13 million less. Mr. Schrock agreed that if, as a result of meetings between Cooper's consultants and EPA's contractor, EPA's contractor deemed Cooper's proposed slurry wall concept (the less costly alternative) technically acceptable, the slurry wall concept would be included in the Remedial Action Plan as the preferred remedial alternative. (Exhibit 31). Also on August 16, 1989, representatives from Cooper met with Thomas Voltaggio, Director, Superfund Division, U.S. EPA, Region III. (Exhibit 32). At that meeting Cooper reiterated its specific objections to the the proposed FS,

-10- stressing its objections to the schedule established by EPA. EPA's scheduled events required the signing of the ROD on or before September 30, 1989, even though public notice of the proposed ROD would not be published until late August or early September. Cooper demonstrated that the schedule did not provide adequate time for EPA to consider the public's comments on the proposed ROD and then incorporate consideration of those comments into EPA's decision on the final remedial plan. Mr. Voltaggio's comments suggested to Cooper that in reality the decision was already made, and that EPA's attitude did not match the apparent flexibility inherent in the official decision-making process. On August 18, 1989, as agreed with Mr. Schrock, representatives from Cooper, Calgon, Geo-Con and Hart Environmental (Cooper's consultants for the Osborne site) and NUS (EPA's contractor for the Osborne site) met to discuss the technical and cost aspects of the $6 million remedy proposed by Cooper. After reviewing the information presented by Cooper, the NUS representatives agreed that the slurry wall issues proposed by Cooper were more appropriate and more cost effective than those selected by NUS. NUS also agreed that the initial capital costs for the dewatering treatment in the proposed FS were overstated, and that a "phased treatment system" design for dewatering would greatly reduce long term operation and maintenance costs. (Exhibit 33). In spite of the results of the August 18, 1989, meeting, EPA published notice of its proposed action at the Osborne site in the evening paper in Sharon, Pennsylvania, on Friday, August 25, 1989. The notice stated that EPA had selected the $19 million remedy, and that public comment on the proposed FS should be postmarked no later than Saturday, September 23, 1989. Submitted by Cooper Industries, Inc. September 1, 1989

-12- t LEGAL SUP**VVCOOHtOOMMt«aWwVl CAANtOPD NEW JiRSCTOTOiC X^ XV- <£". />' - r.'£"^'^-w ~""- "•-•" cc: B. Stolb 1/28/83 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 6TM AND WALNUT STREETS PHILADELPHIA. PENNSYLVANIA 19106

'JAN 1 4 883 U\W DEPT. CERTIFIED MAIL RETURN RECEIPT REQUESTED

f Edgar A. Eircher ,; General Counsel Cooper Industries, Inc. First City Tower Suite 6000 Houston, Texas 77002 Dear Mr. Eircher: The United States Environmental Protection Agency (EPA) has documented the release and threatened release of hazardous substances, pollutants" and contaminants at the Osborne Landfill near Grove City in Mercer County, Pennsylvania. EPA Is anticipating to expend public funds at this site to conduct a remedial investigation and feasibility studies as further detailed below. Under CERCLA, and other laws, responsible parties may be liable for all moneys expended by the federal government to take necessary response action at uncontrolled hazardous waste sites, including investigation, planning, removal and remedial actions at these sites, and enforcement. Responsible parties under CERCLA Include the current and past owner and operator, and persons who generated the hazardous substances or were involved in transport, treatment or disposal of them at the site. Based on our review of EPA records, EPA has information that Indicates that you or your company may be a responsible party as defined by CERCLA* This letter is to notify you that EPA is currently planning to conduct the following studies at the Osborne site: 1. Further investigation to Identify the local hydrogeological characteristics to evaluate groundwater quality and movement in the vicinity of the site; and 2. Further investigation to define the extent of soil, air and surface water contamination at the site; and

V), ;.... \_. :--\ . : ' 303259

EXHIBIT 1 3. Feasibility studies to evaluate possible remedial actions to remove or contain hazardous substances, pollutants, and contaminants at the site. In addition to the above studies, other corrective measures may be necessary to protect public health, welfare or environment* These corrective measures may include, but are not necessarily limited to: 1. Implementation of initial remedial measures, e.g., securing the site to prevent contact with any potential hazardous or toxic materials at the site and/or removal of contaminated material from the surface; and / 2. Designing and Implementing the EPA approved remedial option for any groundwater, surface water, soil and air contamination; and 3. Providing any monitoring and maintenance necessary after remedial measures have been completed. EPA will immediately move forward with the remedial investigations and feasibility studies described above. However, you should notify EPA, In writing within fourteen (14) calendar days from the receipt of this letter, of the nature and extent of the corrective measures you may be.willing to undertake. Otherwise, EPA will assume that you decline to undertake voluntary site cleanup, and we may proceed with any necessary corrective measures. Your letter should indicate the appropriate name, address, and telephone number for further contact with you in addition to a statement of the activities you may be willing to undertake. Where you are already involved in discussions with EPA, State or local authorities or engaged in voluntary action, you should continue that activity and report the status of those discussions or that action in your letter. Please provide a copy of your letter to any other parties involved in those discussions. Your letter should be sent to: Lisa S. Seglin (3RC13) Attorney, Office of Regional Counsel U.S. Environmental Protection Agency Curtis Publishing Building Sixth and Walnut Streets Philadelphia, Pennsylvania 19106

303260 If you need further information on the nature and extent of release or threatened release or on our determination that you may be a responsible party, you may contact Ms. Seglin at (215). 597-8540. I hope that you will give these matters your immediate attention. Sincerely yours,

Stephen Wassersug, Director Air and Waste Management Div cc: Regional Counsel, Region III Director, Office of Waste Programs Enforcement Director, Office of Emergency and Remedial Response Associate Enforcement Counsel - Waste

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3C3263 COOPER INDUSTRIES

May 12, 1983

Thomas C. Voltaggio * ** Chief, Superfund Branch U.S. Environmental Protection Agency - Region III Curtin Building Sixth and Walnut Streets Philadelphia, Pennsylvania 19106 ' Dwight Worley Chief, Division of Operations Pennsylvania Department of Environmental Resources Commonwealth of Pennsylvania . P. 0. Box 2063 Harrisburg, PA 17120

Dear Messrs. Voltaggio and Worley: On January 14, 1983, the U. S. Environmental Protection Agency (US EPA) addressed to Cooper Industries, Inc. (Cooper), among others, a letter requesting, in part, . . . "implementation of Initial remedial measures, e.g. securing the {Osborne landfill) site to prevent contact with any potential hazardous or toxic materials at the site and/or removal of contaminated material from the surface. . ." A meeting was held by US EPA at the offices of the Pennsylvania Depart- ment of Environmental Resources (PA DER) on April 20, 1983, of those parties identified by the EPA as possibly responsible parties under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) including General Electric Company, Ashland Chemical Company, Wolfe Iron & Metal Company and Cooper. All the parties so identified by US EPA, including Cooper, contend there are no hazardous wastes at the Osborne landfill and deny responsibility for the presence of any such wastes found at said site. Nevertheless, Cooper as a long time resident and citizen of Grove City, Pennsylvania, and without waiving any of its rights to deny responsibility under CERCLA or any other Federal, State or Local law affecting it and without waiving any rights to claim reim- bursement, recoupment or damages against parties responsible under CERCLA or any other Federal, State or Local law for their use, contamination or cleanup of the Osborne landfill, 1s willing to implement the initial remedial measures which US EPA has determined to be necessary at this time at the Osborne site in Grove City, Pennsylvania. US EPA and/or PA DER shall be responsible for securing permission as necessary from any responsible parties, includino but not limited to the owner(s) in fee of the Osborne landfill site for Cooper to implement the initial COOPER INDUSTRIES. INC First CHy Tower Su-ie 4000. PO Box ««6 Q n O O £ A housion. Texas 77210 EXKIBIT 2 OV»<->**U ^ (7T3) 739-5*00 Page Two _ May 12, 1983

remedial measures. These initial remedial measures consist of: 1. Installation of a six (6) foot high chain link fence around the perimeter of the site. The length will be approximately 3,500-4,200 feet. Where possible, a minimum clearance of fifty (50) feet beyond the boundary of potentially hazardous substances will be provided. 2. Installation of a twenty-four (24) foot locking gate where the iron gate 1s now located. * 3. Signs warning of the potential hazards will be posted on the fence where it crosses former driveways or footpaths. The signs will be placed at a spacing of no less than one hundred (100) feet. 4. Drums and any other containers located on the surface of the site and which appear to contain or to have contained hazardous substances will be removed. Contaminated soil will also be removed where necessary to insure the safety of persons x_. undertaking activities at the site 1n the future. The implementation of these initial remedial measures shall be initiated within one (1) week of the date of your acknowledgment of this letter and shall be comoleted within six (6) weeks of the date of your acknowledgment of this letter. The implementation of these measures shall be as follows: 1. Cooper will submit for approval to US EPA and PA DER a proposed design for the required warning signs. 2. Cooper will arrange an initial joint site Inspection involving representatives of Cooper, Fred C. Hart Associates, Inc., US EPA and PA DER in order to reach Initial agreement on the location of the fence/gate/signs and on the extent of the drum/container/soil removal. at . Cooper will thereafter survey and mark the site 1n light of the initial agreement reached at the initial joint site inspection and -y will submit appropriate drawings to US EPA and PA DER. \-\ Cooper will thereafter arrange a second joint site inspection in order to reach final agreement on the location of the fence/gate/signs and on the extent of the drum/container/son removal. ^ Cooper will, prior to the drum/container/soil removal, submit to US EPA and PA DER the proposed method of transporting the material, the name and business address of the proposed transporter, the proposed method of disposing of the material and the name and •• business address of the proposed disposal site. The transporting and disposing of the material must be accomplished..in accordance with all applicable Federal, State and Local laws and regulations. 6. In the wake of the final agreement reached at the second joint site inspection and the approval-by. US EPA and PA DER of a design for the required warning signs and of the proposed transporting and disposing of removed material, Cooper will install the required fence and gate, post the required warning signs and Implement the required drum/container/soil removal. 7. Cooper will, prior to removal from the site of any equipment necessary for the Implementation of the remedial measures, arrange a final joint site inspection in order to reach agreement on any necessary final adjustments to the remedial measures. Cooper will permit representatives of US EPA and PA DER to Inspect the site at any reasonable time during the'implementation of the remedial measures. Cooper understands that its satisfactory completion of these initial remedial measures may not be construed as a limitation on the obligations of any responsible party or parties to the extent that additional remedial actions are necessary at the Osborne site. Sincerely yours,

A". BTrcher President and General Counsel

EAB/km ALL-STATE LEG*L 5uwLv co o*t COMMERCE D«^E en won:

30326'? ~sV>°' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY O ^ REGION III 6TM AND WALNUT STREETS PHILADELPHIA. PENNSYLVANIA 19106 131983 ?

MAY ie LAW BEPT,

Mr. Edgar A. Bircher Vice President and General Counsel Cooper Industries, Inc. First City Tower, Suite 4000 P.O. Box 4446 Houston, TX 77210 Dear Mr. Bircher: I have received your letter dated May 12, 1983 respecting the implementation of certain initial remedial measures at the Osborne Landfill site 1n Grove City, PA. I acknowledge and applaud the willingness of Cooper Industries, Inc. to implement these initial remedial measures. I find that the implementation of these measures, as described in your letter, would be consistent with the National Contingency Plan. Sincerely yours, i '(*- Thomas C. Voltaggio Chief, Superfund Branch

RECEIVED f MAY 1 8 683 F SAFETY AND WORKERS' COMPENSATION AMOMSnunON I

EXHIBIT 3 AU.-MATE LEGAL Su^.v CC ONE COMMERCE WVE CR*N*OflD NC* jCRSPr a

303269 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Post Office Box 2063 Harrisburg, Pennsylvania 17120 May 23,1983 (717) 787-7383 MAY 26 1S83 LAW DEPT. Mr. Edgar A. Bircher . Vice President and General Counsel **»*» Cooper Industries, Inc. cn^f.*P^MI. First City Tower, Suite «000 PREPAID 5 iSUSTR1ES' IKC • P. O. BOY btiLf, »,J^~^ ~TICIPATION OP no nr Houston*" *"^,^ T ~X™ ~W7721 0 CONfaP^I*TAkCTIOK* M»»«rii_ H POTENTIA''L* OWiHt An Dear Mr. Bircher: Re: Osborne Landfill : I have received your letter dated May 12,1983, regarding the implementation of certain initial remedial measures at the Osborne Landfill Site in Grove City, Pennsylvania. I acknowledge and approve the willingness of Cooper Industries, Inc. to implement these initial remedial measures. I find that the implementation of these measures, as described in your letter, would be consistent with the National Contingency Plan. Sincerely,

DWIGrtT D. WORLEY, Chief Division of Operations Bureau of Solid Waste Management

303270

EXHIBIT 4 . SUPPLY co ONE COMMERCE D»>V* CT»W«ORD NEW JE»SE* E

303271 SKADDEN, ARPS. SLATE, MEAGHER & FLOM 916 EIGHTEENTH STREET. N.W. /. .' «; : WASHINGTON. D.-C. 20OO6 R _____ ICDKi»n*J< C»••*- •.«•.. ^"^^ •* T>«»0 AVENUE am JTI.«OOO ONE BEACON tTKECT :«m ttj'ooot CM KOONET »OUAKE •nLMMBTOM.SELAWAIIE WiOl (30t) «X0'*XOO BY HAND Gene A. Lucero, Esq. (WH-527) Director, Office of Waste Programs Enforcement United States Environmental t Protection Agency t 401 M Street, S.W. Washington, D.C. 20460

Mr. Stephen R. Wassersug *rf^BLAWW DEP***•• T•• Director, Air and Waste Management Division United States Environmental Protection Agency - Region III Sixth and Walnut Streets Philadelphia, Pennsylvania 19106 Re: Osborne Landfill/Grove City, Pennsylvania Gentlemen: The purpose of this letter is to place in writing the intentions of Cooper Industries, Inc. ("Cooper") with respect to the Osborne Landfill near Grove City, Pennsylvania, in light of recent actions by the United States Environmental Protection Agency ("EPA" or the "Agency"). We also want to reiterate our deep disappointment that EPA has refused to allow Cooper to conduct the Remedial Investigation/Feasibility Study ("RI/FS"), and other possibly necessary remedial efforts, at the Osborne site. Cooper intends to take two steps in the near future: we plan to negotiate with the Pennsylvania Department of Environmental Resources ("DER") in the hope of reaching an agreement whereby Cooper will proceed with remedial investigative and cleanup work at the Osborne site. We also plan to bring an action against EPA in the United States District Court to enjoin the Agency from interfering with voluntary actions by Cooper and from incurring unnecessary federal expenses in a wasteful and redundant federal effort at this site.

EXHIBIT 5 Gene A. Lucero, Esq. Mr. Stephen R. Wassersug June 16, 1963 Page Two

On January 14, 1983, Mr. Wassersug sent a letter to Cooper notifying the company that it might be a potentially responsible party under the Comprehensive Environmental Response, Compensation and Liability Act ('CERCLA") with respect to the Osborne Landfill. The letter demanded that Cooper "evaluate ground-water quality and movement in the vicinity of the site," investigate "the extent of soil, air and surface water contamination at the site," and perform •feasibility studies to evaluate possible remedial actions to remove or contain hazardous substances, pollutants, and contaminants at the site." (I attach a copy.) ''Cooper immediately initiated actions, at great expense, to respond in a professional and timely manner to this apparently most serious EPA demand. As part of this effort, Cooper retained Fred C. Hart Associates, Inc., a well-known environmental consulting firm, to prepare a detailed proposal for an RI/FS. (Indeed, this writer was called upon by Cooper to screen consultants for their objectivity and reputation with EPA} we were assured by enforcement counsel in two Regions that Hart had provided able services in other hazardous waste cases for EPA.) On April 20, 1983, following a period of accelerated preparation by Cooper and the Bart firm, representatives of Cooper, the Fred C. Hart firm, and many State of Pennsylvania and EPA officials met in Meadville, Pennsylvania, to discuss the proposal by Cooper for a full-scale RI/FS for the Osborne site. Following this meeting, Cooper received EPA and DER approval to begin a site security and drum removal program at the Osborne site. On the assumption by all concerned that EPA and DER believed the Hart proposal for an RI/FS to be a more than adequate basis on which to continue discussion. Cooper and its consultants subsequently engaged in further dialogue with Region III staff with regard to desired changes in the Cooper proposal. To our knowledge. Cooper has acceded to all State and Federal requests for modifications to the RI/FS. '. On May 31, 1983, Edgar Bircher, Cooper's Vice- President and General Counsel, and I met with Messrs. Voltaggio, Baker, Shoener, and three officials of the State, in Philadelphia, to discuss EPA's failure to respond to the Cooper proposal for an RI/FS. At that time, Cooper offered to enter into a CERCLA administrative order requiring Cooper to investigate the type and amount of wastes present at the Osborne site, to study the extent of any soil contamination, and to complete a comprehensive groundwater monitoring program. Cooper proposed to include in the administrative order a specific schedule for the completion of individual tasks, together with a provision imposing penalties on

303273 Gene A. Lucero, Esq. Mr. Stephen R. Wassersug June 16, 1983 Page Three

Cooper for failure to meet any of these deadlines. Cooper offered to split samples with EPA and to allow state and federal authorities access to the site at all times to supervise the RI/FS. The administrative order would have required Cooper to prepare a detailed report on the results of the investigation and proposals for remedying any environmental problems at the site. I believe it fair to say that at no time has EPA expressed dissatisfaction with the substance of this proposal. EPA rejected Cooper's proposal to perform the RI/FS, citing a new EPA policy that precludes potentially responsible parties from conducting an RI/FS unless they also agree to conduct, or pay for, all ultimate cleanup determined by EPA to be appropriate. See EPA Memoran- dum, Interim Pre-Litigation Settlement Procedures in Hazard- pus Waste Cases at 5 (May 20, 1983).f/ EPA now plans to have its own contractor, NUS Corporation, conduct a virtually identical RI/FS that will take substantially more time, and will cost substantially more money, than the Fred C. Hart proposal. EPA apparently is being driven by a new national policy (designed to remedy other CERCLA administrative ills) to reject a good faith response to an earlier EPA demand for exactly the type of study embraced in the Fred C. Bart proposal. By so doing, EPA is rendering worthless the extensive time Cooper and outside experts have devoted to the preparation of the Hart proposal and negotiations with EPA, and the obvious substantial professional fees. At the risk of insufferable repetition, these expenses were incurred at EPA's request. We are, in effect, suffering from taking EPA's earlier CERCLA letter at face value. In addition to being an unwise policy, EPA's new approach — of refusing the voluntary investigatory and cleanup efforts of responsible corporations — flatly contradicts the mandates of CERCLA. Both the statute and the National Contingency Plan ("NCP") require EPA to select the most cost-effective approach to remedial activities and to allow potentially responsible parties to participate in remedial actions. Section 104(a) of CERCLA states as a

We have pointed out that even on its face the new EPA policy allows flexibility in particular situations. Yet we have not been accorded the opportunity of discussing with you how our voluntary efforts can be accomplished without doing violence to the spirit of the new policies. 303274- Gene A. Lucero, Esq. Mr. Stephen R. Wassersug June 16, 1983 Page Four precondition to any governmental expenditures (other than, perhaps, expenditures in response to an emergency) that the President must first determine "that such removal and remedial action will [not] be done properly" by a responsible party. In the NCP the Agency itself has imbedded this principle at every stage of the process — from earliest investigation to full cleanup. Because EPA's course of action is clearly improper, we will challenge the ability of EPA to recover costs which the Agency will be incurring. Cooper has, from the first day it was,notified by EPA, chosen a path of cooperation with the Agency. Cooper, even now, stands ready to complete its proposed RI/FS on a timely schedule, and would be prepared to work with EPA as well as the Pennsylvania DER in developing an environmentally sound and cost-effective remedial plan for the Osborne Landfill. However, unless EPA immediately reconsiders a course of action that is both unwise and illegal. Cooper will be forced to seek an injunction against EPA in federal court. Also, as noted above, Cooper intends to pursue with the State of Pennsylvania the establishment of a consensual program for investigation and cleanup at the Osborne site.

Sincerely yo

\*f*JL4 imes A.

Attachment cc: James M. Baker, Esq. Lisa K. Friedman, Esq. Edward Shoener Michael R. Steiner William R. Sierks, Esq. Patti J. Saunders, Esq. Edgar A. Bircher, Esq.

303275 303276 COOPER INDUSTRIES Reb.n w. T«« DirtCtor Stlctv Adminitirtnon and Worker* Comoenutton June 3, 1983

Mr. Ed Shoener Remedial On-Scene Coordinator Environmental Protection Agency Regency III Sixth and Walnut Streets Philadelphia, Pennsylvania 19106

RE: Osborne Landfill Activities / Dear Mr. Shoener: Following is a summary of recent and planned activities at the Osborne Landfill site, Grove City, Pennsylvania. Week of 5/2-6/83 1. On 5/4/83, a joint meeting was held at the site between representatives of EPA, DER, and Cooper, including the law firm of Skadden and Arps and Fred C. Hart Associates, Inc. A preliminary fence location was chosen and the extent of clean-up of surface wastes was discussed. 2. A grid was surveyed and marked at the site to reference all subsequent site activities. In addition, the surveyor, Norm Straub, P.E., started the deed search on the property to aid in the boundary survey. 3. Hart conducted an inventory of all drums on the surface of the site. Drum clusters were identified. Each drum in each cluster was identified and numbered. A drum inventory log sheet was filled out for each drum. Information recorded included, but was not limited to, a drum number, possible contents, label information, and the condition of the drum. The final count of drums at the site was 431 to be removed. 4. To provide information for competitively bidding removal and disposal operations, Hart ear-marked approximately 20*, or 15 of the 75 full, sealed drums for sampling. Preliminary plans for a remote drum opening device were discussed with Cooper engineers. 5. Hart conducted a low altitude fly-over of the disposal area to document existing conditions at the site and to aerially identify drum clusters and nearby spoils piles from deep mining operations.

P.rit Ci'V Tower. Suit* «000. » 0 Box 4446 Houston Texts 77210 739-5635 3 C 3 27 7

EXHIBIT 6 Page 2

Week of 5/9-13/83 1. Hart developed a safety plan in accordance with standard EPA safety protocol and the Mercer County Emergency Management Agency warning and procedure plan for Osborne. All concerned parties were notified as to types of operations to be conducted on-site, and dates that personnel would be on-site. Notified parties included DER, and local fire and hospital officials. 2. Tom Morahan met with Jim Rozakis and Pat Boyle of the' DER on 5/11 prior to the start of the drum opening and sampling operations. At that time DER was given the site safety plan, briefed on work accomplished at the site and activities planned for the week ahead. On 5/12, Jim Rozakis and Russell Crawford, also of the DER, observed opening and sampling operations on three drums at the site. 3. Hart designed and built, with the aid of plant machinists from Cooper's Grove City foundry, a remotely operated pneumatic drum opening device. The device, which could be operated from a distance of 100 feet, was designed and operated in accordance with the site safety plan. 4. Hart conducted drum and soil sampling at the site on 5/11-12 to provide background information for the RFP for disposal of surface wastes. Eighteen drum and two composite soil samples were collected. Analytical results should be back by the first week in June. 5. North American Fencing Corporation was selected to install the fence at Osborne. Ron Kaclik of North American Fencing Coporation visited the site on 5/11 and said there seemed to be no problems. Week of 5/16-20/83 1. On 5/18/83 Tom Morahan met with Jim Rozakis of DER at Osborne to finalize the location of the fence. The fence location was mutually chosen and marked in the field. The fence location was sketched onto a draft copy of the property boundary survey map in the field and approved by DER. A detailed map was then prepared and sent to the appropriate parties. 2. The trip report for drum sampling was finalized. The report .showed sample points, materials encountered, safety procedures, personnel and duties on-site, and analytical requests. The report also enclosed a copy of 303279 the site safety plan and a copy of the Mercer County Emergency Management Agency Warning and Procedures Plan for Osborne. Activities Weeks of 6/6-7/25/83 1. Fence installation will begin on 6/8/83 per verbal approval of fence location by Jim Rozakis, Russell Crawford, Pennsylvania Department of Environmental Resources, and Ed Shoner, EPA. Both EPA and DER are forwarding written approval of fence location to R. W. Teets. Fence completion anticipated by 6/24/83. 2. Final laboratory analysis of drum samples expected in Hart's office by 6/7/63. 3. 3id parameters to be sent out to perspective contractors by Fred C. Hart on 6/10/83. ^. Derspective bidders to meet on sight and review drums to be removed w^tn Fred C. Hart weeks of 6/13-20/83. £. Contractor selection to be made by Fred C. Hart week of 6/27/83. 6. Removal of drums by selected contractor will begin within one week of EPA and DER approval . ". Anticipated completion of drum removal within three weeks of EPA/DER approval. If you have any questions regarding Osborne Landfill activities or require additional information, please advise. Sincerely, 0 R. W. Teets SWTrmc cc: Edgar A. Bircher James D. Rozakis, DER, Meadville

3032-79 AU-JTAH UOAL SUPPLY CO ONE COMUSBCE OBivt CftANFORD »«EV. JCRSfvO cc: E. Bircher (with r. E. Scott f A I 522J * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^iftO^ REGION III 6TM AND WALNUT STREETS PHILADELPHIA. PENNSYLVANIA 19106 JUN 2 01963

Mr. Robert W. Teats, Director Safety Administration and Workers Compensation Cooper Industries First City Tower, Suite 4000 , P.O. Box 4446 Houston, Texas Dear Mr. Teats: Thank you for allowing Craig Moylan of Fred C. Hart to accompany and assist me during my inspection of the Osborne dump on Thursday, June 9, 1983. I inspected the proposed fence location and found it acceptable except for one area near the old lagoons next to the entrance gate. It appears as though the fence, as currently planned, may not completly enclose these lagoons. I suggested to Craig that Fred C. Hart compare the most recent aerial photographs to the older photographs, which show the full extent of the lagoons, and make sure the fence is extended to completely enclose the lagoons. Please notify me when the proposed fence boundary in this area is changed. I will notify Jim Rozakis of the DER of this matter and rely on him to make a field inspection to verify that the lagoons will be completely enclosed. In regard to my drum inspection, I found a large number of drums with labels of companies that may have been suppliers of products to local companies. These local companies may have disposed of the drums at the site. Craig Moylan has a fairly complete inventory of these drums. To assist me in my investigation, I would greatly appreciate it if you could tell me which of these drums were used and disposed of by Cooper. Again, thank you for your cooperation and I look forward to hearing from you in the near future. Sine

Shoener Remedial On-Scene Coordinator cc: J. Rozakis, PA DER J. Baker, EPA Legal Branch JUN 2 4 1983 SAFETY WO WORKERS' CGVPENSATKW MKJW!STR*T10N DEPARTMENT 303231 EXHIBIT 7 AU-SUTt UG*. SU*»i.Y CC ONE COWMEaCt Oa;.t CHAVOfC KE.'. jeHiE" i~yf

303232 cc: D. V'inship ' E. Scott

.d! COOPER INDUSTRIES Retort w. T« B Siftty AammuTrtron »n<3 Worktrt Corrotn$jtion

June 24, 1983

Mr. Ed Shoener Remedial On-Scene Coordinator United States Environmental ' Protection Agency Region III Sixth and Walnut Streets Philadelphia, Pennsylvania 19106 Dear Mr. Shoener: Pursuant to your recent request for documents pertaining to the Osborne Landfill, I enclose the following: (1) One copy of the Drum Inventory Log Book prepared by Fred C. Hart Associates, Inc. during their Inventory of surface wastes at Osborne. (2) One copy of the Summary of Surface Waste Sampling Operations at the Osborne Landfill conducted May 11-12, 1983 by Fred C. Hart Associates, Inc. I think that the documents provided are what you were looking for. If I may be of further assistance 1n this matter, please give me a call. Sincerely r

Robert W. Teets RWT:mc cc: James D. Rozakis, DER, Meadvllle Edgar A. Bircher

30328? HoiAtcniT.^ 77210 EXHIBIT 8 (713) 739-6635 . SU»P.v CO OM COMMf HCE DR

CMt SCACON S1*crr July 5, 1983 •mto-ooct C« ftODNCT (OUkK WIUUMOTOtt. OtL»W*« I»»OI By Telecopy James K. Baker, Esq. Attorney Office of Regional Counsel United States Environmental Protection Agency - Region III ' Sixth and Walnut Streets Philadelphia, Pennsylvania 19106 Re: Osborne Landfill Dear Mr. Baker: This letter is written in response to your letter of June 27, 1983, in which you "state the substance of the Agency's position regarding settlement via judicial consent decree for the Osborne Site." You indicate in that letter that the v , Agency needs to know within seven calendar days whether V Cooper Industries, Inc. ("Cooper") believes that it would be fruitful for it to continue settlement discussions with the federal government. In closing, you state, n[I]f a timely response is not received or if settlement via judicial consent decree is otherwise not possible, the Agency's contractor will begin the remedial investigation for the Osborne Site." As you know, representatives of Cooper have been meeting with representatives of the State of Pennsylvania in an effort to work out a consent agreement satisfactory to both those parties as to the Osborne Site. We embarked on that effort because it appeared the federal government would interpose such major hurdles to settlement that resolution of this matter without the need for litigation on the federal front was unlikely. However, as you are aware. Cooper has throughout the discussions on the Osborne Site maintained that it wished to carry out reasonable, voluntary remedial efforts as soon as possible — despite the fact that other responsible

EXHIBIT James H. Baker, Esq. July 5, 1983 Page Two parties have shown no willingness to cooperate in the slightest degree. Cooper remains eager to resolve its obligations under federal law without the need for government-initiated remedial efforts or litigation between the parties. Because we have proceeded with discussions with.the State of Pennsylvania, and those negotiations appear to be very productive, we hope to present to EPA the draft of an agreement between Cooper and the State of Pennsylvania, which agreement could provide the basis for resolution of the federal aspects of the Osborne matter. I assure you that the elements stated in your letter of June 27, which you deem essential in any federal agreement, have been reviewed carefully by representatives of both the State and Cooper, and that we have attempted to incorporate those principles in the agreement with the State. We hope to present to you a draft agreement by the end of this week. As you may be aware from conversations with attorneys for Pennsylvania, representatives of Cooper and the State met on Wednesday, June 29, and again on Friday, July 1, in an effort to draft a suitably specific consent agreement. Not wishing to wait until this week to let EPA know of the substantial progress being made on this front, I attempted to call you and Sheldon Novick last Friday, but was told that you were both out of the office. If you have any questions concerning this letter or the schedule of further negotiations with the State of Pennsylvania, please call me or Larry Starfield of this office. I would appreciate it if, in the future, when you send copies of letters such as the June 27 letter to attorneys representing other parties in this matter, you so note on the copy sent to me. Very truly yours. ' K7A^*^———' Rogers U cc: Patricia J. SaundersVEsq. William R. Sierks, Esq. Edgar A. Bircher, 10 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES 1200 Kossman Building Forbes at Stanwix Pittsburgh, Pennsylvania 15222-1376 (412) 565-5363 August 4, 1583

Lawrence E. Starfield, Esquire Skadden, Arps, Slate, Meagher & Flan 919 Eighteenth Street, N.W. Washington, D.C. 20006 { HE: Osborne Site Dear Larry: I have enclosed what I hope is the very last draft of the Osborne Consent Order and Agreement. In our last conversation, you and Jim expressed seme concern about the words "removal operations and construction of clean-up facilities" in Paragraph 20 of the proposed Consent Order and Agreement for the Osborne Site. The Department construes that phrase as not including long-term operation and maintenance of treatment facilities. It is the Departjrent's understanding that the Consent Order and Agreement will not address this issue and that the parties intend to resolve it in the future. The Department, of course, specifically reserves its rights to take any appropriate action regarding operation and maintenance. I expect a response from EPA in a day or two; I will contact you then, so we can get this document signed.

Very truly yours,

Patti J. Sawders Assistant Counsel PJS-.kad Enclosure cc: James A. Rogers Stephen Mims^ Edgar A. Bircher William Sierks Michael Steiner

EXHIBIT 10

303286 AU.-STATI UG&L fa.**.* CO ONE COMVEACC C*»'VE CMAI^ORO NEW JEMSE* OTtHf

303289 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REOION III tr« AW WALNUT tracers * , f KtLAOCXFKIA. PEMNSYI.VANIA IllOi ^T/^OT

In Reply *•*•* Tee 1A«0 ' GtO REC'D Donald Latarehik • Director* Buttiu of Solid wait* KanagaMnt ...r t A Pennsylvania Department of Environmental Resources rw.° P.O. frox 2043 •trriaturgr **nnaylvani« 17120 Dear Rr. Latarchikf • ' Ift ha** rsrievsd the administrative conttnt oro^r twa «*nt which th« PtnwylVAcia Dtpartaent -o£ BavirmMntal Miourctt (•DZKB) negotiated with Cooptr XntfuitritSt Inc. (•Cooptt1) lor t&e ttudy anti cleanup of th« Otborr.« itnofill tit* in Pin* Town- •hip, Mttrctr County, Pftftcsylvani* ("iite"). 9incv Cooper's ecMiUMnt to perfor* the rtMditl inv*itig«tlon conBiitent vith th« K9«ney't lurch 1112 lUwdiil Action K«tt«r Plan ittitfiM th« lUticrvAl Contin^etxey tUn ("KCP") «nd itt ocaaitMnt to perform the remedial cleanup eatiafiet tte Agency 'a current t«/quir«* ftente for * private per^y cletnup( we will defer to your requeat .that the site be *Btate lead* and the Agency will not now procMd with itt own rmdial int»iticiticn and lettibility atudy VltX/rs*) for t±ic site. lleaae note that the Agency has not waived ita atatutory duty to independently review the fcl/FS end deteraine the require* cleanup tase^ on curtpnt fcgancy requixesMntSt section 104 of the CGBtpraheniiTe Cnvironaental Maponsef Coopensation and Liability Act tty to the conetnt order and agx»e»ent« any prerieionf reUtlng to tte atandard of review of DBft'c decisions would net apply to the Aoe&oy, vhote dteisione are subject to review under itdercl jvidicial standards. Ry statf and I are pleased that SOT has taken the lead on this sit*. He will continue to •cnitcr the nature and pace of the work snd w* anticipate your continued cooperation* Plesee call ev at (215) S97-&492 it there ar* any turther Questions on this matter. Sincerely yours*

Tbeews C« Voltaggio Chief i fiup«rfund irsnch cct Gene A. Luoero directorf Office of Waate frograas CntorceMnt ^.< CO ONE "OMMEfilt O

12 lead - 8/4,83

CCMM3«EaLTH OF PENNSYLVANIA DEPARTMENT OF EHVUCtMENIM. RESOURCES

In the Hatter of: ______COCPER INDUSTRIES, DC. : Solid Haste Management Act Csborne Site : Solid and Hazardous Haste Pine Township : Disposal Mercer County . :

CONSBTT ORDER AND

The Cornonwealth of Pennsylvania, Department of Environmental Resources ("DER"), has determined the following facts: A. Cooper is an Ohio corporation registered to do business in Pennsylvania, f with a local business ***rr>** of: Cooper Biergy Services, Linooln Avenue, Grove City, PA 16127. B. Between 1963 and 1978, Janes Csborne, an individual now deceased, and Erroa Osborne owned and operated a landfill of approximately 15 acres adjacent to R.D. 4 in Pine Township, Mercer County, PA ("Osborne Site"). DER required Csborne to close the site in 1978. C. Since 1978, EcVard L. and Janet L. McDougall, individuals residing at R.D. 13, Grove City, PA 16127, have held equitable title to the Csborne Site. D. ffelter Sloan, an individual residing at Enterprise toad, Grove City, PA 16127, owns a snail portion of the Osborne Site near the treeline along the larger lagoon. E. Since the early 1950's and continuing until 1978, Cooper and other persons disposed of industrial, residual, and hazardous wastes and substances at the Osbome Site. Cooper disposed of foundry sands, carhite sludge, slag and other waste naterials. EXHIBIT- 12 303£"i-' F. The Osborne Site was not authorized by permit for the disposal of solid waste, as required by Section 610(1) of the Solid Waste Management Act, the Act of April 7, 1980, P.L. 380, 35 P.S. $6018.610(1), or its predecessor, the Act of July 31, 1968, P.L. 788, 35 P.S. §6001 et sea. (repealed July 7, 1980). The Site was permitted pursuant to the Waste Disposal Act, the Act of April 9, 1956, P.L. (1955) 1436 (repealed July 24, 1970), between 1964 and'l971 to accept slag, sand, sludge, carbide and waste paper. G. Samples of the soil and surface water at the Osbome Site revealed elevated levels of heavy metals as well as confounds on the United States Bxviron- nental Protection Agency's ("EPA") priority pollutants list. K. The disposal by Cooper and other persons of residual and hazardous wastes at the Csborne Site without authorization by permit constitutes a violation of Sections 301, 302, 401, 501 and 610 of the Solid Waste Management Act, 35 P.S. SS6018.301, 6018.302, 6018.401, 6018.501 and 6018.610, and a public nuisance. I. The disposal by Cooper and other persons of industrial wastes at the Osborne Site without authorization by permit constitutes a violation of Sections 301, 307, 401, 402 and 611 of the Clean Streams Law, the Act of June 22, 1937, P.L. 1987, as amended, 35 P.S. SS691.301, 691.307, 691.401, 691.402 and 691.611, and a public nuisance. J. EPA has identified Cooper, General Electric Company, Ashland Chemical Company, Wblfe Iron and Metal Company, and present and past owners and operators of the Csborne Site, as parties potentially responsible for remedial measures to abate the conditions at the Csborne Site, pursuant to the Comprehensive Environ-

-2- 303293 mental Response, Compensation and Liability Act, 42 U.S.C. S9601 et sec. (1980) ("CERCLA"). K. DEH's Bureau of Solid Haste Management contacted several partly, including Cooper, requesting voluntary cooperation in providing remedial action at the Osbome Site. L. All responsible parties other than Cooper have declined to participate in remedial measures at the Osbome Site. Cooper desires to cooperate and is willing to conduct necessary remedial measures. M. Cooper, in coordination with EPA and DER, has voluntarily started the implementation of initial remedial measures ("IBM's") at the Osborne Site, including: (1) Installation of a six foot high chain link fence around the perimeter cf the site; (2) Installation of a twenty-four foot locking gate; (3) Posting signs on the fence warning of the potential hazards at the site; (4) Removal of certain drums and other containers which appear to contain or to have contained hazardous substances; and (5) Removal of certain contaminated soil where necessary to insure the safety of persons undertaking activities at the site in the future. EPA has found that the implementation of these measures as described in Cooper's letters of May 12, 1983 to DER and EPA would be consistent with the National Con- tingency Plan ("N3>") promulgated at 40 C.F.R. $300.1 et sea., pursuant to Sec- tion 105 of CERCLA, 42 U.S.C $9605. CER has

-3- 303294 N. The parties wish to resolve this matter expeditiously and without sort to litigation. NCW, THEREFORE, this 3£> day of August, 1983, the parties intending to be legally bound and in consideration of the mutual covenants herein. Cooper consents to the entry of the following order: 1. Paragraphs 1 through 10, 12 through 17, and 20 of this Consent Order and Agreement constitute an Order of the Department, issued pursuant to Sections 104(7) and 602 of the Solid Waste Management Act, 35 P.S. $$6018.104(7) and 6018.602; Sections 5, 401 and 610 of the Clean Streams Law, 35 P.S. $$691.5, 691.401 and 691.610; and Section 1917-A of the Administrative Code, the Act of April 9, 1929, P.L. 177, as wended, 71 P.S. $510-17.

DOCUMENT PROCCJCTIO4 2. Within two (2) weeks from the date of this Consent Order and Agreement, Cooper shall provide DER with a list of the types and quantities of wastes produced by its Grove City facility and disposed at the Osbome Site between the early 1950's and 1978, along with all documents which contain such information.

INITIAL REMEDIAL MEASURES 3. Cooper shall complete implementation of the IRM's described in Cooper's letters of May 12, 1983 to DER and EPA by October 1, 1983 in a manner acceptable to DER. REMEDIAL DKESTTGftTICN 4. Cooper shall conduct a Ramedial Investigation ("RI") at the Osbome Site according to the work plan set forth in Exhibit A, which is incorporated herein as an obligation of this Consent Order and Agreement. The RI shall meet the requirements of CEROA and the NCP (40 C.F.R. $300.68(f)).

-4- 3C329S 5. No variance shall occur in performance of the RI fron the standards and specifications contained in Exhibit A unless Cooper obtains the prior written approval of DER for such variance. 6. Cooper shall perform the RI according to the following schedule in a manner acceptable to DER and in accordance with the tasks set forth in Exhibit A: Phase 1 - Indirect geophysical investigation ..../...... 30 workdays Phase 2 - Drilling of initial test borings and wells ...... 40 workdays Phase 3 - Sampling program ...... 15 workdays Phase 4 - Analytical program ...... 40 workdays Phase 5 - Data evaluation, report preparation and submission of final report ...... 30 workdays Cooper shall work at least five workdays per week, except when a national holiday occurs on a weekday. Cooper shall commence Phase 1 of the RI within ten (10) workdays of the completion of the IFM's or the signing of the Consent Order and Agreement, whichever is later. Phases 2 through 5 shall ocnnence no later than the next workday after Cooper notifies DER that the previous phase is complete. 7. Until DER certifies that the RI is completed, Cooper shall submit written monthly progress reports to DER and EPA by the fifteenth day of each month, describing the work accomplished during the prior calendar month. 6. Cooper shall provide access to representatives of DER and EPA to observe work on the RI at the Osborne Site. 9. Cooper shall promptly make available to DER and EPA all technical information developed while implementing this Consent Order end Agreement. Cooper shall notify DER and EPA in advance of any sampling, and shall split samples with

-5- 303296 those agencies upon request. Sampling and analysis shall be dene pursuant to EPA protocols, as set forth in Exhibit A. Cooper's samples shall be handled according to accepted chain of custody procedures as set forth in Exhibit B. 10. Cooper shall notify OCR upon completion of each of the five phases. Cooper's good faith notification of completion of each phase shall act to suspend the accrual of penalties outlined in Paragraph 22 and provide the effective date for determining whether any credits have accrued. Accrued credits may be used to extend the deadline for completion of subsequent phases of the RI. If CER determines that a phase is not complete, penalties pursuant to Paragraph 22 shall accrue according to the tears of Paragraph 12. Credits shall accrue when Cooper completes an RI Phase in less than the time specified in Paragraph 6, with one credit accruing for each workday not used. Each phase shall be deemed complete when all the elements of the phase as described in Exhibit A have been performed. 11. DER agrees, in conjunction with Paragraph 10, to review performance of each phase and indicate within twenty-one days after receipt of the notification whether it considers the phase satisfactorily completed. DER's determination that a phase is complete constitutes nothing more than agreement that all elements of the phase as set forth in Exhibit A have been satisfactorily accomplished for the purposes of Paragraphs 22 and 24, and shall not be construed as a finding that changes or additions to the scope of the work plan are not necessary to achieve compliance with CERdA, the NCP, the Solid Waste Management Act, and the Clean Streams Law. DER's determination shall not be available as a defense in or in mitigation of any action brought to secure compliance with CZROA, the NCP, the Solid Waste Management Act or the Clean Streams La*'. 12. DER agrees that, if it determines than an RI Phase has not been com- 303E97 -€- pleted in accordance with the standards and specifications set out in Exhibit A, it will so notify Cooper in writing, including a schedule for completion in its notification. Cooper shall expeditiously complete the Phase in accordance with the schedule. Any delay in completion of the Phase, and resulting penalties, will be calculated based en the new schedule, with credit given to Cooper fcr workdays finished ahead of tine under the schedule in Paragraph 6. 13. If new information is acquired during implementation of the RI which necessitates revision of the work plan, either Cooper or DER may request reasonable revisions by notifying the other party of such request in writing. The request shall include a description of the technical basis for the change (s) or addition (s) sought and a schedule for implementation. Cooper shall begin work within five (5) days after DER's written approval of the revision and schedule. upon approval, the revision and schedule shall be incorporated herein and become an obligation of this Consent Order and Agreement. DER specifically reserves its right to issue orders concerning revisions or changes to the RI or as otherwise authorized pursuant to the Acts cited in Paragraph 1. If Cooper is aggrieved by DER's determination regarding revision of the work plan, Cooper shall have the remedies available pursuant to Paragraph 25. COMMUNITY RELATIONS PLflN 14. Cooper shall cooperate fully with DER in developing and implementing a Community Relations Plan consistent with the NCP for the Osborne Site cleanup. Cooper agrees to assist DER in attending meetings, briefing local officials, and in otherwise implementing the Community Relations Plan. FEASIBILITY STUDY 15. Within twenty (20) days after final approval by DER of the RI, Cooper

-7- shall submit to DER for its approval a proposed plan for a feasibility study to identify and assess remedial alternatives. The plan shall include a schedule for submission of a draft Feasibility Study ("FS") and the submission of a final FS report. The plan for the FS and the FS shall be consistent with the Solid Waste Management Act, the dean Streams Law, the Rules and Regulations promulgated thereunder, and the procedures outlined in the NO3 at'40 C.F.R. $300.68 (a-j) and $300.70. If DER determines that the proposed plan cannot be approved, Cooper shall submit the necessary revisions within the tine specified by DER. After review and upon approval by DER, the plan end schedule shall be incorporated herein and become an obligation of this Consent Order and Agreement. If Cooper is aggrieved by DER's determination regarding the proposed plan for a feasibility study, Cooper shall have the remedies available pursuant to Para- graph 25. 16. Cooper shall perform the FS as set forth in the approved plan and schedule. OF dZANUP ALTERNATIVES 17. Cooper shall have the final FS report prepared and shall subnit it in a form acceptable to DER according to the schedule set forth in the approved plan for the FS. The final FS report shall discuss appropriate remedial alternatives and estimate the total time necessary for the implementation of each remedial alternative. 18. DER will submit the final FS report for public notice and concent. 19. EER win then issue a Record of Decision, which designates the acceptable remedial alternative, a schedule for implementation of the chosen remedial alternative, and the reasons for its selection. EER shall have the right to

-e- 3032S9 combine or otherwise revise the remedial alternatives discussed in the fin*T FS • report in determining the acceptable remedial alternative. The determination of the acceptable remedial alternative shall be mate consistent with CERCXA, the NCP, the Solid tfeste Management Act, and the dean Streams Law. DER's designation of a remedial alternative as acceptable shall not be construed as a guaran- / tee of its success; the designation shall not be available as a defense in or in mitigation of any action brought to secure compliance with CERCLA, the Solid Waste Management Act, or the Clean Streams Law. If Cooper is aggrieved by EER's designation of the acceptable remedial alternative. Cooper shall have the remedies available pursuant to Paragraph 25. IMPLEMENTATION CF CLEANUP 20. Cooper shall implement at the Osbome Site the removal operations and construction of cleanup facilities as set forth in die remedial alternative designated in the Record of Decision according to the schedule set forth in the Record of Decision. Cooper shall not be precluded from providing funds to a third party to implement the designated remedial alternative; however, doing so shall not relieve Cooper of its obligation under this Consent Order and Agree- ment to implement the designated remedial alternative. FORCE MUEURE 21. (a) Except as set forth in subparagraph (b) hereof, any failure by Cooper to complete the obligations imposed by Paragraphs 3, 4, 6, 12, 13, 15, 16 and 17 which is caused by circumstances beyond its control, and which Cooper, by the exercise of reasonable diligence was unable to prevent, shall not be a violation of Cooper's obligations and shall not result in liability for civil penalties set forth in Paragraphs 22 and 23. Grounds for delay for which Cooper ~~ 303300 -9- will not be held responsible include, but are not ll"rff?j to, the following: Acts of God, a court or administrative order initiated by EPA or other federal agency enjoining Cooper's work at the site, and unusual weather conditions interfering with work at the site. To the extent delay is caused by such circumstances, the time for performance hereunder shall be extended for a period of time up to or equal to the number of days of excused delay*' Increased costs or expenses in connection with the performance of the obligations of this Consent Order and Agreement shall not constitute a circumstance beyond Cooper's control. (b) Notwithstanding anything set forth in subparagraph (a) hereof, in no event shall DER grant any extension which, alone or in conjunction with any previous extensions, would result in any of the obligations in Paragraphs 3, 4, 6, 12, 13, 15, 16 and 17 being performed after January 1, 1985. (c) Cooper shall be entitled to the benefits of this paragraph only if Cooper promptly submits a written request for extension to DER, as provided in subparagraph (d). ' (d) Cooper shall notify DER of any delay which occurs in the performance of any of the obligations of Paragraphs 3, 4, 6, 12, 13, 15, 16 and 17. Such notification shall be in writing and shall fully describe the nature of the delay, the reasons for the delay, expected duration of the delay» and the actions which Cooper is taking to mitigate further delay. The Department shall determine the length of the extension to be granted based en information submitted pursuant to subparagxapns (c) and (d) hereof. If Cooper fails to provide such notice to the Department as required by this paragraph, within five (5) workdays of the occurrence of the delay, the provisions for extensions in subparagraph (a) shall not apply. 303301 -10- 22. If Cooper has not completed any of the phases or any revisions in t time period set forth in Paragraph 6, then it shall be liable for civil pen*1 ties in the amount of two hundred fifty dollars ($250.00) per day for the fir seven (7) calendar days of delay, and five hundred dollars ($500.00) per day : each subsequent calendar day on which it fails to complete performance. 23. If Cooper fails to submit a proposed plan for an FS within twenty (2 workdays after DDR's approval of the RI, or fails to timely perform any other obligations set out in the approved FS plan. Cooper shall pay a civil penalty < twc hundred fifty dollars ($250.00) per calendar day. 24. A delay of greater than the time period scheduled for completion of any phase or any revision required by this Consent Order and Agreement or other violation of the obligations of this Consent Order and Agreement shall entitle DER to pursue all available remedies and penalties for violation of a Depart- mental Order. Such remedies and penalties shall be in addition to, and not in lieu of, those imposed by the Consent Order and Agreement, including Paragraphs 22 and 23. APPEALABLE ACTIOM5 25. DER's determinations regarding necessary revision of the work plan (Paragraph 13), approval of the plan for the FS (Paragraph 15), and designation of a remedial alternative in the Record of Decision (Paragraph IS) shall be construed as appealable actions, pursuant to Section 1921-A of the Administrative Cede, 71 P.S. $510-21, and the Administrative Agency law, 2 Pa.C.S. $103 (a) and Chapters 5A and 7A, but Cooper waives its right to contest DER's right to take these artions. If Cooper is aggrieved by CCR's designation in the Record of

303302 -11- Decision, Cooper shall have the right to show that CER's determination of a remedial alternative is arbitrary, capricious, unreasonable or otherwise contrary to law, but shall limit its request for relief to a request that the En- vironmental Hearing Board, upon finding that the designated remedial alternative is arbitrary, capricious, unreasonable or otherwise contrary to law, re- mand the matter to DER. Cooper shall not request that the ^Environmental Hearing r Board modify the designated remedial alternative or substitute any of the remedial alternatives discussed in the FS. If the Environmental Bearing Board or reviewing court vacates the Record of Decision, CER reserves the right to elect another remedial alternative. The parties agree that the standard for review of the Record of Decision shall be whether it is arbitrary, capricious, unreascn- able or otherwise contrary to law. GENERAL CONDITIQG —————————————— 26. DER agrees that the costs incurred by Cooper in fulfillment of this Consent Order and Agreement are, in CER's opinion and belief, consistent with the NCP and G3CLA, and that DER will take Cooper's expense into consideration when it assesses the ultimate cleanup expenses allocated to the Csborne Site. Any money expended by Cooper pursuant to this Consent Order and Agreement and approved by DER will be credited in any final determination by CER or any reviewing body against Cooper's overall monetary liability with respect to the Osborne Site. However, Cooper's expense shall not be available as a defense nor in mitigation of any action brought to secure compliance with CERCLA, the NCP, the Solid Waste Management Act, or the Clean Streams law. 27. So long as Cooper complies with the teens and conditions of this Con- sent Order and Agreement, CER will withhold scope of work and other approvals

-12- 303303 for any remedial work proposed by any party not signing this Consent Order- and Agreement which would interfere with Cooper's ability to comply with this Consent Order and Agreement or would substantially duplicate Cooper's obligations under this Consent Order and Agreement. 28. Nothing in this Consent Order and Agreement authorizes any violation of any permit, law or regulation. CER specifically reserves all rights to institute civil, criminal, equitable and administrative proceedings for past, existing and future violations of any environmental law or regulation by Cooper or other persons. DER specifically reserves the right to sue for civil penalties or other relief for any discharge to ground or surface waters of the Commonwealth which has occurred at any time or may occur in the future and for any violation or condition which exists, occurs or is committed after the date of this Consent Order and Agreement. 29. Nothing in this Consent Order and Agreement shall impair or affect any right of contribution by Cooper against all other responsible parties for costs incurred in connection with the RI, FS, and any subsequent remedial action at the Csborne Site, and other miscellaneous associated costs, pursuant to the Uni- form Contribution of Joint Tbrtfeasors Act, 42 P.S. $8321 et sea., and other applicable law. Nothing herein shall restrict the right of Cooper to seek relief from other parties under applicable federal law, including Section 107 of CERCLA, 42 U.S.C. $9607. 30. Nothing in this Consent Order and Agreement shall be construed as a waiver or impairment of DER's right to take any available action against other persons liable under applicable la* for the conditions at the Csborne Site. . , Nothing in this Consent Order and Agreement shall be construed to alter other-

-13- wise applicable rules of liability and of contribution in any action involving Cooper or other responsible parties related to conditions at the Osborne Site. 31. Signature by CER to this Consent Order and Agreement constitutes agreement that, based on infomaticn currently available to CER, Exhibit A represents an appropriate work plan for an RI at the Csborne Site. 32. No agreement, approval or determination by CER pursuant to this Con- sent Order and Agreement shall be construed as a guarantee of success, waiver of further responsibility or determination of ultimate compliance with any law. 33. All correspondence with CER concerning this Consent Order and Agree- ment and required notifications shall be addressed to Russell Cr&rford, Regional Solid Waste Manager, Bureau of Solid Waste Management, 1012 Water Street, Mead- ville, PA 16335. 34. All correspondence with Cooper concerning this Consent Order and Agree- ment and required notifications shall be addressed to Edgar A. Bircher, Esq., Vice President and General Counsel, Cooper Industries, Lie., P.O. Box 4446, Houston, Texas 77210. 35. Cooper consents to the entry of this Consent Order and Agreement and waives any right it might have to appeal the issuance of this Consent Order and Agreement under Section 1S21-A of the Administrative Code, 71 P.S. $510-21, and the Administrative Agency Law, 2 Pa.C.S. $103 (a) and Chapters 5A and 7A. Nothing in this paragraph shall be construed as a limitation of Cooper's rights pursuant to Paragraph 25 to challenge the CER actions set forth therein. 36. Each undersigned representative of the parties to this Consent Order and Agreement certifies that he or she is fully authorized to enter into the terms and conditions of this Consent Order and Agreement and to execute and to legally bind such party to this document. 37. It is the intent of the parties hereto that the clauses hereof are severable and should any part of the clauses be declared by a court of law to be invalid and unenforceable, the remaining clauses shall remain in full force and effect as between the parties, their successors and assigns. 38. Any changes, additions, or amendments to this Consent Order and Agree- ment shall be set out in writing and signed by the parties. 39. Ohis Consent Order and Agreement shall be effective as of the last date of signature by the parties. The Agreement shall terminate upon CER's final approval of the work agreed to herein; the Order shall remain in effect as an Order of the Department.

FOR THE CO-MCtWEALTH OF FOR COOPER INDUSTRIES, INC. , DEPARTMENT OF RESOURCES

Eocar A. Bircher _ Vice-President and General Counsel Director

Patti J. -Saunders Assistant Counsel / Sadden, Arps, Slate, ifeagher & Flcm stries. Inc.

(DATE) ' ' (DATE)

(CORPORATE SEAL) 303306 -15- ATTACHMENT

WORK PLAN ' FOR SITE INVESTIGATION AT THE OSBORNE-LANDFILL

Prepared by:

FRED C. HART ASSOCIATES, INC. New York/Washington, O.C./Denver

V <-'

EXHIBIT A 303307 WORK PLAN

The site Investigation- of the Osborne Landfill to be conducted by Hart 1s designed to determine:

0 The types and quantities of wastes present at the site 0 The geological conditions and soil types present at the site 0 The extent of soil contamination 0 Groundwater flow direction and gradient e Groundwater quality c Surface water quality

Specifically, Hart will commence the site investigation program within 10 workdays of the notice to proceed as follows:

Task 1.0 - Indirect Geophysical Investigation

1.1 A standard magnetometry survey will be conducted at the site to Indicate the number, locations, and types of buried metal objects at the site. A commercially available magnetometer with at least a 10 gamma resolution will be utilized to obtain the magnetic field data.

Measurements will be taken and stored for data Interpretation. This Interpretation will include removal of diurnal magnetic field changes, magnetic profiling, the construction of magnetic contour naps and magnetic field modeling to determine the depth, mass, and type of object causing magnetic anomaly.

1.2 An electrical resistivity survey will be conducted around the perimeter of the site. The survey will be used as a prescreening tool to indicate subsurface geologic conditions. The survey Is designed to provide Information on the depth of the water table, the location of possible buried bedrock contacts and the relative thickness of saturated soils. The survey i eay also delineate possible zones of contaminated soil or groundwater and 30330?

. r*C9 C MART "I- the possible presence, locations and depths of nine shafts underneath the

Two parallel survey lines separated by 50-100 feet will be run around the perimeter of the site. These lines will be located above the strip mine walls and spoil piles. Apparent resistivities will be recorded and a profile will be developed for the survey area.

The indirect geophysical investigation program will be completed within 30 workdays after the commencement of this Task. ''

Task 2.0 - Drilling of Initial Test Borings and Veils

Hart will initially complete drilling of IS test borings and wells at . the site. All drilling will be supervised and Inspected by Hart hydrogeo legists who will make observations and measurements of all sampling activities and materials. These observations will be recorded in daily log books and on boring log forms. All split spoon samples will be taken in accordance with ASTK Standard D1586. All rock coring will be accomplished in accordance with ASTK Standard 02113-70. In addition, each split spoon will be checked with an Organic Vapor Analyzer to Identify zones of contamination. Color photographs will be taken of each sample to document its condition. All wells will be developed by a method suggested by the driller and approved by Hart. Development water generated at the leachate wells will be diverted to areas of the fill which will not permit surface runoff. The development procedure will be supervised by Hart hydrogeo legists to insure that wells are open to formations and that clear sediment-free water can be obtained for laboratory analysis.

The location of the test borings and monitor wells are shown in Fig- ure 1. The wells will be drilled by Llnlnger Drilling and Pumps, Inc., Greenville, Pennsylvania. Specifically:

2.1 At location DHW-1, one test boring will be drilled to a depth of approximately 300 ft. Split spoon samples will be taken to bedrock. Con- tinuous rock coring will then be utilized to sample the bedrock to a depth 3033G9 = c necessary to confirm bedrock conditions• a*t depth' underneath the site so •tha t • f\ contaminant migration can be assessed. This boring will be completed as a v^ 2 inch flush joint PVC deep monitoring well in the Burgeon sandstone. This monitoring well will be used as a deep well in a nest designed to evaluate the effects of potential artesian pressure heads on contaminant migration. The well construction diagram for this well is shown in Figure 2.

2.2 At location MMW-1, one test boring will be drilled to a depth of 200 feet. Split spoon samples will be taken to bedrock. Continuous rock coring will then be utilized to sample the bedrock to a depth necessary to confirm bedrock conditions at depth underneath the site'so that contaminant migration can be assessed. This boring will be completed as a 2 inch flush joint PVC deep monitoring well. This monitoring well will be used as a deep well in a nest designed to evaluate the effects of potential artesian pressure heads on contaminant migration. The well construction diagram for this well is shown in Figure 2.

f 2.3 Five perimeter monitoring wells will be drilled at locations UHW-1 ^ through UMW-5 to a depth not to exceed tne first relatively impermeable zone ^"^ encountered after drilling through the uppermost bedrock aquifer. This depth will be determined from data based on the deep borings. The typical well construction diagram for these wells is shown in Figure 2. They will be finished as open cased holes in the bedrock aquifer. The casing will be driven tightly into bedrock to prevent near surface leakage.

2.4 Four test borings will be drilled at locations LW-1 through LW-4 directly in the disposal area to characterize the subsurface materials. Standard 2-inch split spoon samples will be collected. Sampling will be continuous to bedrock.

Each of these borings will be completed as a leachate well to allow sampling of leachate and to evaluate the hydraulic properties of the foundry sand in the fill. Figure 2 shows the typical well construction diagram for these wells. Threaded 4 inch flush joint PVC will be used to avoid contami- •J nation by organic solvents. 303310 ._ r«cs c »A*T 2.S Four test borings will be drilled at locations SW-1 through SW-4 A in undisturbed soil surrounding the disposal area. Each of these borings will be completed as shallow wells to monitor water quality in the surface soils. The typical design for these wells Is shown in Figure 2. Threaded 4 inch Flushjoint PVC will be used to avoid contamination by organic solvents.

2.6 An Organic Vapor Analyzer (OVA) will be used in the survey mode to monitor the safety of all personnel during on-site drilling operations. In addition, the OVA will be used in the gas chromatograph ^GC) mode to identify potential zones of contamination in soil borings by headspace analyses.

2.7 All wells will be secured with a protective casing witn a locking cap. The wells will be surveyed for use in the determination of hydraulic conditions at the site. In addition, a detailed topographic survey of the landfill and the immediate vicinity will be developed. Accurate spatial locations and elevations of test borings and monitoring wells are reauired f so that groundwater depths and flow characteristics can be determined.

The drilling of initial test borings and wells will be completed within 40 workdays after the commencement of this Task.

Task 3.0 - Sampling Program

Hart will collect a total of 18 surface water, leachate, and groundwater samples. Specific sampling plans are as follows:

3.1 One surface water sample will be collected at each of the six locations shown in Figure 3. .

3.2 One composite leachate sample will be collected. The four leachate wells (LW1 through LV4) will be sampled. Equal portions of each well sample will be composited into one sample to identify types of materials found 1n the waste area.

3.3 One groundwater sample will be collected from each of the groundwater monitoring wells listed below: c Four Shallow Monitoring Wells (SV1 through SW4J ° Five Uppermost Aquifer Monitoring Wells (UMW1 through UMWS) ° One Middle Aquifer Monitoring Wells (MMW1) e One Deep Aquifer Monitoring Well (DMW1)

Before sampling all groundwater and leachate wells, accurate water level measurements will be taken to a precision of ±0.01 foot and recorded to determine the hydraulic gradient and flow direction. At least three well volumes will then be evacuated from each well to insure a representative sample. Equipment preparation, surface water sampling procedures, and chain-of-custody procedures will be conducted in accordance with standard EPA protocols as set forth in EPA Document 1600/2-80-016 (Samplers and Sampling Procedures For Hazardous Waste Streams, January 1980).

Groundwater Sampling Procedures will be conducted in accordance with Standard EPA protocols set forth In EPA Document ffSW-611 (Procedures Manual for Groundwater Monitoring at Solid Waste Disposal Sites, December 1980).

All samples will be iced immediately after collection and delivered to the laboratory within the holding times prescribed by the EPA methods for priority pollutant analyses outlined in Task 4. Chain-of-custody, as described above, will be maintained at all times.

The sampling program will be completed within IS workdays after the commencement of this Task.

Task 4.0 - Analytical Program

Each of the 18 samples collected will be analyzed for priority pollutants. All laboratory analyses will be performed by Environmental Testing and Certification (ETC) of Edison, New Jersey.

ETC will supply all bottles, preservatives, ice packs, shipping containers, analyses request forms, and chain-of-custody fores in accordance with the standard EPA protocols set forth in EPA Document f60012-80-018 (Samplers and Sampling Procedures for Hazardous Waste Streams). 303312- ruts C. *»R? »SSCC:*"ES «NC After receipt of the samples, ETC will prepare and analyze the samples for priority pollutants using EPA Method Nos. 624. 625, and 200.1 through 200.98. as set forth in the Federal Register. 3 December 1979, pages 69532 and 65940, and "Methods for Chemical Analysis of Water and Waste", EPA Docu- ment f600/4-79-020. respectively. ETC will report, with analytical results for each sample, the appropriate quality control/quality assurance information as outlined in the above EPA protocols.

Analytical results will, be recived within 40 workdays after the commencement of this Task. ,

Task 5.0 - Data Evaluation and Reportino Preparation

Hart will evaluate all the data developed during the site investigation and incorporate it in a report. The report will include a complete description of the field investigation, a record of boring logs and analytical data, and an interpretation of the data including detailed maps and subsur- f face sections. The report will specifically address types and quantities of wastes present at the site, the geological conditions and soil types present at the site, the extent of soil contamination,, groundwater flow direction and gradient in the surficial and uppermost bedrock aquifers, and groundwater and surface water quality. The report will also contain a risk assessment which will evaluate the public health and environmental concerns posed at the site.

If groundwater contamination is detected, the report will provide a comprehensive groundwater monitoring plan. The groundwater monitoring plan will set forth the number and location of wells and the sampling program needed to determine the concentrations, rate and extent of contaminant migration. The plan may include but would not be limited to such terns as permeability testing and geophysical testing.

The data evaluation and report preparation will be completed within f 30 workdays after the commencement of this Task.

303313

.£. r«er c HART ASSCCATCS INC UMW1

CORNFIELD

SW1

0UMW2 AMMVVI

INACTIVE LAGOON

DEEP MONITORING WELL UPPERMOST AQUIFER MONITORING WELL SHALLOW WELL O LEACHATE WELL

FIGURE 1 : MONITORING WELL LOCATION MAP o 5 atu

tu ae o

•"^«" ~ •~—^•••••"fX.x^vK'r': tu I jifc&'SfcxI i I. jiffff '•'''•S' o. tu UoJ

30331S w I

CORNF1ELO

INACTIVE LAGOON

O SURFACE WATER SAMPLING LOCATION

FIGURE 3 : SURFACE WATER SAMPLING LOCATION MAP EPA-600/2-80-018 c January 1980

SAMPLERS AND SAMPLING PROCEDURES FOR HAZARDOUS WASTE STREAMS

Efflil R. deVera, Bare P. Simons, Robert D. Stephens and David L. Stora California Department of Health Services Berkeley, California 94704

Grant No. R806692010

Project Officer Richard A. Carats Solid and Hazardous Waste Research Division Municipal Environmental Research Laboratory Cincinnati. Ohio 45268

MUNICIPAL ENVIROKHEKIAL RESEARCH LABORATORY •OFFICE OF RESEARCH AKD DEVELOPMENT U.S. ENVIRONMENTAL PROTECTION AGENCY CINCINNATI, OHIO 45268

EXHIBIT B 303211 CONTENTS

Foreword ...... *...... iii Abstract ...... iv Figures ...... vi Tables ...... vii i. Introduction ...... i 2. Conclusions ...... T .... 3 J. Rp«v»o3i»ndacie»riS ...... 4 ^. Saaplers ...... 5 Composite liquid waste sampler ...... 5 Solid waste samplers ...... 9 Soil samplers ...... 13 Procedure for use ...... i« Pond sampler ...... 20 S. Preparation for Sampling ...... j& 6. Sampling Procedures ...... 26 General considerations ...... 26 Sample handling ...... 39 Field lo< book ...... &x Chain of custody record ...... 42 Sample analysis request sheet ...... 42 Scop It delivery to the laboratory ...... 42 Shipping of cample ...... 45 7. Receipt and Logging of Sample ...... 46 8. Preservation and Stornge of Samples ...... 48 References ...... 50 Appendices ...... 52 A. Development of the composite liquid ...... 52 waste sampler (Coliwasa) ...... B. Parts for constructing the coliwasa ...... 62 C. Checklist of iteas required in the field ...... 63 sampling of hazardous wastes ...... D. Random sampling ...... 6? E. Systematic errors in using the coliwasa ...... 68

303318 rule, however, is to record sufficient information co that someone can reconstruct the campling situation without reliance on the collector's f-\ memory. The log book must be protected and kept in a cafe place. . CHAIN OF CUSTODY RECORD To establich the documentation necessary to trace cample possession from the time of collection, a chain of custody record must be filled out and accompany every cample. This record becomes especially important when the cample ic co be introduced as evidence in a court litigation. An example of a chain of custody record ic illustrated in Figure 13. The record must contain the following minimum information: Collector's sample number Signature of collector Date and tiae of collection Place and address of collection Waste type Signatures of persons involved in the chain of possession Inclusive daces of possession SAMPLE ANALYSIS REQUEST SHEET The sample analysis request sheet (Figure 14) is intended to accompany the cample on delivery to the laboratory. The field portion of this form eust be completed by the person collecting the sample and should include most of the pertinent information noced in che log book. The laboratory portion of this form is intended Co be completed by laboratory personnel and to include: Name of person receiving the cample Laboratory cample number Dace of sample receipt Sample allocation Analyses to be performed SAMPLE DELIVERY TO THE LABORATORY Preferably, the cample must be delivered in person co che laboratory for analysis as coon as practicable—usually che case day as che campling. Consult Section 8 when cample preservation is required. The sample muse

42 California Department of Health Collector's Sample No, Hazardous Materials Laboratory CHAIN OF CUSTODY RECORD - — Hazardous Materials

Location of Sampling: _ Producer _ Hauler Disposal Site Other: Company's Name Telephone ( ) Address '• number street city state sip Collector's Name Telephone ( ) signature Date Sampled Time Same led hours Type of Process Producing Waste Waste Type Code Other *- Field Information

Sample Allocation: I. name of organization 2. name of organization 3. name of organization Chain of Possession 1. signature CiCle inclusive dates 2. signature title inclusive dates 3. signature CiCle inclusive dates

Figure 13. Example of chain of custody record 43 3G3S«20 AU.-STATI UGA» sm*;.* co ONC couucfttt 3a«vf c**»**o*o NEW jiHSEv on>it

303321 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES 1012 Water Street **** **" Meadville, Pennsylvania 16335 Telephone: A. C. 814/724-8526 November 1, 1983

Subject: Osborne Landfill Phase I Completion ^3W ~ "-33 Mr. Edgar A. Bircher, Esq. « «-.- i,s- ,Vice President & General Council / L-*:. -"V a*«* Cooper Industries, Inc. P. 0. Box 4446 Houston, Texas 77210 Dear Mr. Bircher? In response to your letter of October 13, 1983, this shall constitute formal notice pursuant to Paragraph 11 of the Consent Order & Agreement that the Department has reviewed Cooper's Phase I activities at the Osborne landfill. The Department considers this phase, as described in Exhibit A of the Consent Order & Agreement, to be satisfactorily completed as of October 7, 1983. It is expected that a full written report on this activity will be included as part of the feasibility study report to be submitted pursuant to Paragraph 15 of the Consent Order & Agreement. Eight workdays were used to complete Phase I and therefore a credit of J22yorkdays has accrued which may be used to extend subsequent deadlines. W< If you have any questions regarding this natter, please feel free to contact me. Sincerely,

Russell L. Crawford Regional Solid Waste Manager Bureau of Solid Waste Management RLC/JDR/skg

wovr

EXHIBIT 13 303322 PAT! LCGA. fcj»P^ CD ONE COtME^C! DB VI Cft»N«O<»Z MEA J|BSt- 0*016

303325 RECEIVED DEC20B83 fteidirllSf Pmylvt^li 15335 TelephoneT«i«Kfc««M:. *««. Cr . £14/724-652•>•! >•*•»»» uc«*6e December 16. 1983 Subject: Osborne LanofllT Mercer County, Pennsylvania iir. Edgar A. Bircher Vice President & General Counsel Cooper Industries* Inc. P. 0. tJox 4446 f Houston, Texas 77210 Dear Mr. Bircher: On November 23, 1933 Donna Skinner, Regional Hydrogeologlst, and I net on-site with Frank Slmunlc, Cooper representative, to confirm completion of Phase II per Paragraph 6 of the Consent Order & Agreement between Cooper Energy Services and the Department of Environmental Resources. It was agreed that all IS wells contained In Exhibit A of the Work Plan nave oeen drilled as field located on October 7, 1933. With the preliminary field data supplied and the addition of the Task VI wells. It Is felt that the Intended scope of the Work Plan Task II will be satisfied entirely. The reasons that necessitated the Inclusion of Task VI may upon the final report outcome dictate other Investigation activity. Therefore, November 22, 1983 1s the date considered by the Oepartment for tne completion of Paragraph 6, Phase II of the Consent Order & Agreement. In calculating your schedule requirements according to Paragraoh 6, the following was used to determine a total credit of 19 days: Phase II/Start Date October 10, 1983 Targeted 40 work day end date December 2, 1983 National holidays/3 Columbus Day, Octooer 10 Veterans Day. November 11 Thanksgiving Day, November 24 December 2 + 3 workdays results In the actual end date being December 7, 1933. S workday extension for well depths at 25X nore than expected. December 7 plus S workdays results In the final actual end date being December 14, 1983. Final Actual Conviction November 22, 1933, yields 15 workdays credit. Force majeur - weather days 3 (Noveaoer 11 has been requested also, but Is denied since November 11 «ras also a credited national holiday). October id, November 10, November 15

EXHIBIT 14 «r. Edgar A. Bircher -2- December 16, 1933

Phase III sampling program.conmenced on Wovemoer 23, 1933, however, ' i due to a request oy DER your scheduled sampling date had to be delayed 4 V workdays. Therefore, 4 days credit Is given to Phase HI completion thereby allowing until December 19 for completion. Please feel free to contact me if you have any consents or questions : regarding the contents of this letter. Sincerel

A. Patrick Boyle ' Regional Operations Chief Bureau of Solid Waste Management dPB/skg cc: Mr. Robert Teets, Director, Safety Administration & Workers Compensation dr. Frank Simunlc, Supervisor, Facilities Engineering 6 Planning Mr. Edward Schoener, U.S. EPA, Region III Mr. Russell Crawford, Headvllle Regional Office

303325 *.* CC O*A COVWFPCC 0

303326 Society"

December 22, 1983

Cooper Industries P.O. Box 4446 Houston, TX 77210 Dear Mr. Cizik, The Appalachian Audubon Society understands that one of your subsidiaries, Cooper Energy Service of Grove City, Pennsylvania, is in the process of cleaning up toxic wastes found at the Osborne landfill near Grove City in Mercer County. ^~-^ We want you to know we applaud their efforts. The initiative your company shows in this project is highly commendable. Thank you for keeping our environment and Grove City's water supply clean.

v Kathy Cnbari Conservation Chairperson 623 Frances Drive Harrisburg, PA 17109

cc: Ed Bircher Tom Campbell Joe Coppola Steve Mims P^'.'C Carl Plesnicher Bob Teets CE3 28 833 U/IK DECEIVED U

EXHIBIT 15 100% Recycled Pacer AU..STAU LIC>*k Su»*t.v CO ONE COWWEtCE 0*>'vt CfUN«ORD NEA

303328 COOPER INDUSTRIES

October 22,

Mr. Russell Cravford Regional Solid Waste Manager Pennsylvania Department of Environmental Resources Bureau of Solid Waste 1012 Water Street Meadville, Pennsylvania 16335 Re: Osborne Remedial Investigation Report Dear Mr. Cravford: Thank you for your letter of September 19, 1984 in which you noted "overall the Osborne Remedial Investigation Report clearly documents the work done At the site". Further, your acknowledgement that it appears there is presently no significant groundwater contamination occurring at the site and there is no compelling need for extensive additional vork at this time, is correct. During the past year. Cooper Industries has spent in excess of 5700,000 in completing the Remedial Investigation, in accordance with the Consent Order and Agreement reached with your agency. Each task of the Work Plan included in that agreement and approved by your agency has been completed. The following information, prepared with the assistance of our consultant, is in consideration of your contents of September 19, 1984 and reinforces the discussions held with your agency and the representatives of the Environmental Protection Agency at your Meadville offices on Friday, October 12, 1964. 1. T??cs and Quantities of Waste Disposed of at the Site The Environmental Protection Agency has identified a number of generators contributing waste to the Osborne Landfill including General Electric, Wolfe Iron and Steel, Ashland Chemical, Channel Lock and Cooper Energy Services. Both General Electric and Cooper Energy Services submitted to the Environmental Protection Agency a Notification of Hazardous Waste Site, as required by section 103(c) of CERCLA, which identified a number of wastes as having been disposed of at the Osborne facility. In those notices, the following materials were identified: F017 - Spent paint, U013 - Asbestos, F003-005 - Spent nonhalogenated solvents and F001-002 - Spent halcgenated solvents.

CCS-».ES..NC. 303?29 F rs: C.ty "c*tr Snte 4CCC PC 2s* «-»6 EXHIBIT 16 * Page 2

Furthermore in response to the Environmental Protection Agency's request for additional information under CERCLA, section 104(e), Cooper Energy Services submitted its records. From these records, a documentation of types and quantities of waste produced and disposed of at the Osborne site between the early 1950's and 1978 can be assumed.. Within the documents, the following wastes are identified: Waste coolants, waste sand, waste acid, waste solvents, scrap metal, cast iron dust, cooling system sludge, air filtration sludge, scrap carbide (lime) sludge, excavation debris, slag and waste oils. It is not known if the Environmental Protection Agency made a similar request of General Electric, or If General Electric responded to such a request and provided similar documentation of the wastes they disposed of at the Osborne site. As a result of our complete and thorough Remedial Investigation at the Osborne site, you will find in the report on page 10 of Section 3 WASTE TYPES AND QUANTITIES, that our leachate wells identified a' limited number of pollutants at low and isolated concentrations. Of the waste disposed of at the site, only generally low concentrations of benzene, nickel and chromium were detected. In fact, the Pennsylvania Department of Environmental Resources' filtered samples of leachate well analysis showed lead levels at less than 10 ug/1, mercury levels at less than 1 ug/1, and arsenic levels at less than 10 ug/1. The concentration levels identified suggest that most of the lead, mercury and arsenic was due to suspended solids and therefore do not travel in groundwater as readily as they would if in solution. Our records clearly established the vast majority of waste deposited at the site by Cooper was foundry sand. 2. Soil Contamination In accordance with the agreed upon Work Flan as attached to the Cooper - Department of Environmental Resources Consent Order and Agreement, no chemical analysis of soil samples was required. As stated in the' Work Flan, in Section 2.5, "Four test borings will be drilled at locations SW-l through SW-4 in undisturbed solid surrounding the disposal area. Each of these borings will be completed as shallow wells to monitor water quality in the surface soils". Also stated in Section 3.2, "One composite leachate sample will be collected. The four leachate wells (LW-i through LW-4) will be sampled. Equal portions of each well sample will be composited into one sample to Identify types of materials found in the waste area". In order to characterize the types and quantities of wastes present at the site a wide variety of methodologies and observations were utilized including: a. Review of old aerial photos and mapping of soil types; b. Understanding of past strip Dining and waste disposal operations; c. Kagnetometry survey; d. Test borings, soil sampling and OVA field analysis; e. Installation of leachate wells and sampling and analysis of composite leachate samples; f. Inventorying, comprehensive sampling and analysis of surface wastes and observations during site surface cleanup (IBM).

303330 Page 3

After utilizing the above techniques, etc., it was concluded on page 111-10 of the Remedial Investigation Report that most of the waste by volume is foundry sand. The OVA field screening of test boring samples Indicated very little contamination above the water table. Below the water table, chemical analysis of leachate wells identified only a limited number of priority pollutants at low concentrations. Not only should the leachate samples represent worst case contamination (i.e., high concentrations of a composite mixture of contaminants drained from the entire waste mass Including "hot spots") but they also represent those contaminants which would have the potential to migrate from the site. In any case, given the relatively low levels of contaminants found and considering the waste quantities as the entire mass of waste materials disposed, additional data refinements such as indicating hot spots or determining maximum and minimum ranges of contamination within the waste mass should not be needed for the purpose of assessing relevant risks posed by the site. Waste quantities were determined by taking the entire volume of disposed materials, In mass, and calculating the volume from numerous cross-sectional areas. These volume calculations and backup data can be found in Appendix G of the Remedial Investigation Report. 3. Groundwater Flow Direction, Gradient and Interaction (a) Eureccn Sandstone On October 8, 1984, Cooper took an additional round of water level measurements from all the monitoring wells at the Osborne site. The data is plotted on the hydrograph (See. revised Figure V-9 attached). This new water level data verified the groundwater flow direction in the Burgeon aquifer beneath the site to be towards the northeast (See revised Figure V-8 attached). This latest set of water level readings indicates the flow to be even more definitively pointing away from the Grove City municipal wells with a more convincing gradient of roughly eight feet (8 ft.) per 500 feet across the site. The flow direction which is more towards the east provides additional justification for the use of DMW-l as an upgradient monitoring well. As Indicated by the hydrograph (Figure V-9) in March and April. 1984, sufficient time had not elapsed for water levels to completely stabilize since the drilling, logging, pumping and sampling of the wells. However since that time, six months have passed and this latest set of water level data substantiates our understanding of groundwater flow directions within the Burgeon aquifer. The flow direction being away from the Grove City wells would Indicate the pumping of the municipal well field should have little to no measurable effect on water levels or the aquifer beneath the site. To our knowledge, other than the Grove City wells, there are no other off-site receptor wells in the area that are open to the Burgeon aquifer.

303351 Page 4

(b) Eomewoed Formation The latest set of water level readings taken October 8, 1984 were plotted as shown on the revised Figure V-7. This new water level data substantiates the flow in the Eomewood aquifer to be predominantly to the south. This would be consistent with the "hydrologic island" concept of groundwater flow towards the boundaries. The unusually high water levels in Well UMW-5 is considered an anomaly due to local conditions and does not appear to have a significant effect on water levels in the other UMW wells. It Is expected that the higher water levels in the vicinity of well UMW-5 would not Influence regional flow but would cause a local converging effect of groundwater flow beneath the site. In any event, whether the flow in the Bomewood aquifer is to the south or to the southeast would have little bearing on potential risks to receptor wells because In either direction the Eomewood aquifer would likely discharge Into near surface groundwater flow systems shortly after leaving the site. (c) Shallow Water Table Flew Figure V-6 did not include water level measurement for well SW-l because this well is screened in fill soil deposits which are not hydraulically connected with the fill soil deposits at the disposal site. By referring to one of the subsurface sections, this well was installed upon the ledge of the high wall which is roughly 30 feet higher in elevation than the rest of the SW and LW veils at the disposal site. Due to the complexity of the surface soils at this site from glacial erosion and deposition and past strip Bluing activities, it would be difficult to say at what locations and to what degree the off-site ponds and nearby streams are hydraulically connected to the shallow water table. To determine the influence of off-site surface water bodies on groundwater flow at the site would likely require considerable off-site veil installation and groundwater level measurements. At this time, we do not see why this would materially add to the report. (d) Connequenessing Aquifer To limit the scope of work and still achieve the objectives of the Remedial Investigation, our program was designed to intercept the uppermost aquifers or the most likely pathways for contaminant migration. In addition to the Burgeon aquifer, the major aquifer supplying water to the Grove City wells and the aquifer with the highest flow rate was included within the scope of the Investigation. In any event, none of these more likely pathways shoved contamination of any significance.

303333 Page 5

(e) Aquifer Intcreonnectedness As shown on the revised Figure V-9, the new water level data obtained October 8, 1984 more accurately depicts the long-term water level elevations within each aquifer. As explained at a previous Cooper, Bart and Department of Environmental* Resources meeting, the water level fluctuations during March and April of 1964 were due to destabilizing effects of water levels after drilling, geophysical logging, well pumping and evacuation in preparation for sampling, at the end of the well installation program. More specifically, the increase in water levels in veil DMW-1 and contemporaneous decrease in water levels in veils UHW-3 and LW-4, for instance, was due to leakage through well DMW-3. During the drilling and geophysical logging of well DMW-3, water was observed flowing down from upper zones (e.g., Eomewood) to lover zones (I.e., Burgeon) through this open hole. At the time, this open hole had not yet been completed as deep well DMW-3 with the upper aquifers sealed off from the deeper one. An example of the lack of interconnectedness is the subsequent recovery in water levels in wells UMW-3 and LW-4 after completing and sealing well DMW-3. In fact, even during the rather extensive pumping of wells DMW-2 and DMW-3, in preparation for the April, 1984 sampling trip while the vater levels dropped sharply in DMW-1, the vater levels vere still recovering in wells UMW-3 and LW-4. On page IV-9 of the Remedial Investigation Report, it is stated that "most surface runoff generated on the site or flowing onto the site ends up on the ponds and recharges the groundwater system". In any case, as such, these areas should cot need to be addressed as a continuing source of leachate generation through the waste materials since no contamination of significance was found. As stated previously, the site geology and especially the near surface soil deposits are very complex due to glacial erosion and deposition, strip mining and subsequent disposal activities. For this reason, the construction of flow nets would require considerable additional well installation and water level information and, in any event, would not add materially to the Remedial Investigation Report. (f) Pump Testing As stated in the Osborne Site Void Investigation Report, the purpose of the three-hour pumping test was to evaluate the volume of the void encountered during the drilling of the monitoring veils near station N-2 and 4«00. As stated on page 11-24 of the Remedial Investigation Report, the three-hour pumping test was adequate for concluding that the vater vas entering the veil from a rather extensive void area. Although apparently cot provided in the Remedial Investigation Report, vater levels in well DMW-2 vere monitored and showed co effects from the pumping test. This well was installed in the Eomewood formation directly beneath the pumping well.

303333 Page 6

4. Effects of Coal Mining The references which were mistakenly left out of the list of reference in Section VIII include: * R.E. Wicans, R. Eayatsu, R.G. Scott, L.F. Moore and M.B. Studies, Examination and Comparison of Structure: Lignite, Bituminous and Anthracite Coal, Preprints of the Coal Chemistry Workshop, August 26 and 27, 1984, Stanford Research Institute. * Michael W. Gang and Donald Langmuir, Controls on Heavy Metals in Surface and Groundwaters Affected by Coal Mine Drainage; Clarion River - Redbank Creed Watershed, Pennsylvania, 5th Symposium on Coal Mine Research, National Coal Association, 1974. 5. The two lime deposit areas shown in Figure II-7 are estimated to be only three to five feet deep and very small in area. They evolved through the deposition of lime used in the production of acetylene. Due to its small volume relative to the remaining wastes disposed on site, characterization would produce little substantive information necessary for the feasibility study. Further, analytical results from sampling of the well water from SW-2 (screened in glacial deposits) and LW-4 (screened in mice spoils and glacial deposits) indicate no apparent significant contamination that may relate to the lime deposits. 6. OVA Monitoring The "soil" (primarily foundry sand) is contaminated by interstitial vater which is best sampled by veils. LW-1 is a veil from which a vater sample was obtained and analyzed in a laboratory and the results are provided in the Remedial Investigation Report (see Table V-2). The ocly sample ic LW-1 which shoved non-methane hydrocarbon by OVA-GC analysis was S-6 (see page 11-16). The primary purpose for using the OVA in the field is to test for non-methane hydrocarbons. This is cot only an accepted method, but it is encouraged by EFA for government-funded investigations of hazardous waste sites. 7. Sediment sampling ic nearby swamps acd streams is cot within the scope of the Consent Order and Agreemect Work Plan. Besides constituting off-site remedial Investigation efforts, such sediment sampling would not reveal sediment contamination from the site. As coted oc page IV-5 of the Remedial Investigation Report, the site drainage patterns at the site are such that ponding ic the disposal area occurs with subsequent direct groundwater recharge acd co surface runoff. Consequently, contaminant transport via surface runoff Is cot possible. 8. The groundwater sampling acd analysis program presented ic the Remedial Investigation Report satisfies the scope of the Consent Order and Agreement Work Plan. The fluctuations above and below the comparative criteria are veil within the level of precision for the concentration levels detected. The fluctuations are cot significant for purposes of developing the scope of a feasibility study since the coccectrations detected are cot significant enough to warrant groundwater restoration. Tables V-2 acd V-3 should have shown ug/1 uclts.

303334- Page 7

9. Resistivity Survey The resistivity survey was conducted in accordance with the approved Work Flan. Ic addition, a resistivity soucding was conducted. The data was suspect due to the amount of clay within the fill soil, which for the most part, rendered it useless. The most useful and meaningful format for presecticg and interpreting resistivity profile data is by plotting the data poicts on a map. Ic this way, each value can be compared to those surrounding it for the purpose of recognizing anomalies. 10. Creundwatcr Modeling As stated on page V-16 of the Remedial Investigation Report, "Appendix E represents a series of hypothetical groundwater models developed to indicate the potential migration of contaminants from the site through the groundvater system. The models, assumptions, calculations and results are found in Appendix E". The models demonstrate, as a gross indication, the percent reduction In potential contaminant levels in the aquifers due to simple mixing and flow through dilution. All other attenuating properties were ignored. The simple analytical models chosen for application in this study have been verified at numerous other sites. Ic the application of these models at the Osborne site, very conservative worst case conditions were assumed. Ic some cases, the assumptions chosen vere even unrealistically conservative. For example, ic the model application to the Burgeon aquifer* contaminants from the site vere presumed to be present Ic this aquifer acd flowing towards the Borough veils, even though this has been shown cot to be the case. Verifica- tion of these groucdwater models vould ocly be necessary if the report claimed to predict precise levels of contaminants under actual groundvater conditions at the site. If anything, the use of these models, under the assumptions chosen for this cite, would be errorlng on the side of conservatism. 11. Risk Assessment Chapter VI of the Remedial Investigation Report presents a very comprehensive risk assessment which considers cot only pathways but also the source and receptors as is explained on pages VI-1 through VI-8. To our knowledge, there is co EPA guideline as to what constitutes a standard risk assessment for a Remedial Icvestigatioc Report. We are somewhat confused about the comments under point 11. What the Remedial Investigation Report does say regarding the source of contamination oc page VI-2 is: "A major finding of the risk assessment is that all available evidence oc the source icdicates that the amount acd degree of contamination is extremely low. At the time that the site was originally identified, the number of drums oc the surface suggested that the source of contamination might be severe. The information developed during the Remedial Investigation has shown that not to be the case. 303335 Page 8

The chemical analysis of the wastes present in drums and subsequently removed from the site identified low concentrations of two (2) organic acd eight (8) inorganic priority pollutants. The maximum concentration of any organic priority pollutant in these filled acd sealed drums was 0.5Z. The concentration of inorganic priority pollutants was in the low parts-per-million range with the exception of one measurement of lead. Eence, the waste itself, as represented in drums at the site, was not highly toxic. The chemical analysis of leachate found at the site indicated a low risk. The leachate veils contained a limited number of priority pollutants at low parts-per billion levels and in Isolated concentrations."

/ The analysis of drum contents was fully presented in Tables III-l, HI-2, HI-3 and HI-4 of the Remedial Investigation Report. Siccerely,

Robert W. Teets, Director Safety Administration and Environmental Affairs RWT:ja cc: Richard Zinn Nick DeBenedictis Ed Shoner Barry Lawson Carl Plesnicher E. A. Bircher Attachments bcc: Frank Simunic Rick Dorrler J.R. Coppola Dave Winship Mike O'Brien Dick Maddox S.W. Flehn Tom Campbell

303336 -••{•-{-1 i i i i i $ i t ?• S . • - " ill.»«.*. v HiI Kouv* nanvi 1^m iiAt1 IIA»n Ivu viivm u REVISED OCTOBER 6\1«e4 FIGURE V-8 POTENTIOMETRIC SURFACE IN THE BURGOON FORMATION OSBORNE SITE (SCALE IN FT.) •RED C. HART ASSOCIATES. IMC _...„__.__ 3 j}3 3 38v^ REVISED OCTOBER e\ioc4 FIGURE V-7 CSCAH 111 FT.) | POTENTIOMETRIC SURFACE IN •eo*TOU* UH,, A.OV. i..r ARE HOT SHOWN I THE HOMEWOOO FORMATION out TO ir oimwHCf m HEAD I OSBORNE SITE FRED C. HART ASSOCIATES. INC. ll-tUTt LfOAl tJ^.1 CC CWC COMMEHCt Oft'VE CBANfOfi- NC* AASEV

30334^ COOPER INDUSTRIES

January 30, 1985

Mr. Richard K. Z1nn Regional Environmental Protection Director Department of Environmental Resources Commonwealth of Pennsylvania 1012 Hater Street Meadvilie, PA 16335 Dear Mr. Zlnn: In response to Mr. Rozakis' letter of December 4, 1984, attached are results of the soil samples taken at the Osbome Landfill on December 19, 1984 by environmental engineers of Fred C. Hart Associates, Inc. Hart's analysis of these results confirms the technical conclusions reached In the Osborne Site Remedial Investigation Report, submitted to your agency on June 25, 1984. In their June 25 report, Fred C. Hart Associates, Inc. concluded that, "there 1s a minimal risk to public health from soil contamination at the Osbome site," and that the concentrations of materials found are consistent with samples examined from published studies of areas discharging wastewater near coal mines. The levels of contamination found at the site and the effectiveness of the pathways to transport these contaminants are not adversely Impacting groundwater or surface water quality at the Osborne site. The results of the soil samples taken on December 19 further substantiate the comments of your agency's Regional Solid Waste Manager, Mr. Russell Crawford, in his letter to me of September 19, 1984 where he said, "It appears there Is presently no significant groundwater contamination occurring at this Site." As a responsible citizen of the Grove City community, Cooper Industries stepped forward and assumed the full burden of the remedial Investigation at the Osborne Landfill. We entered Into a Consent Order and Agreement with your agency on the extent and nature of work to be done. We hired a highly respected expert In environmental matters, Fred C. Hart Associates, Inc., to assist and guide us In the remedial Investigation. After receiving Hart's comprehensive analysis of their findings and conclusions that the site does not present a threat to public health, we submitted their Report to you on June 25, 1984 for your review and approval. After a series of meetings on the contents of the Report and, after several requests for clarification on the findings of the Report, you asked us to go beyond what we had committed to do and conduct additional studies at the Site. In a spirit of cooperation and 1n an effort to bring the matter to a final

COOPER INDUSTRIES. INC. EXHIBIT 17 First Crty fewer SoUe '000 PO Box <"6 Houston fern WO (713) 739-5400 James C. Rozakis January 30, 1985 Page 2

conclusion, we agreed to honor your request. The results of this additional study confirm the technical conclusions reached 1n the Remedial Investigation Report prepared by Fred C. Hart and submitted to you seven months ago. The Osborne Landfill does not present a threat to public health. We feel strongly that we have lived up to all of our commitments to your Agency and that the additional report we are submitting herewith should lay to rest any questions you may have regarding the completeness and accuracy of the study we completed last June. After spending nearly SI million dollars and many hours of work by Cooper personnel and management on this phase of the project, we 'feel we have complied with both the letter and the spirit of our agreement with your Agency, and we do not Intend to proceed further until we receive your approval for the Remedial Investigation Report. As soon as we receive your approval, we will Immediately begin a feasibility study to determine the most cost effective method of cleaning up and permanently closing the Osborne Landfill. Of further concern to us 1s the lack of activity on the part of your Agency In gaining the participation of other generators who deposited waste material at the Landfill such as General Electric, who 1s known to be a significant generator by your Agency as well as the United States Environmental Protection Agency. Since Cooper was only one of several generators at the Site, we are requesting that appropriate action be taken Immediately against the other generators to make them bear their share of the cost of the Remedial Investigation, feasibility study and clean up of the Osborne Landfill.

Sincerely,

Robert W. Teets Director, Risk Management and Environmental Affairs

CJP003/ar/gmb Attachments cc: R. Crawford N. Debened1ct1s v H. J. Lawson V_^ i J. D. Rozakis File 303342 O«COMUE«CS D

303343 COOPER INDUSTRIES

September 16, 19C5

Hector M. Abreu-dntron CERCLA Remedial Enforcement Section (3HW12) U.S. Environmental Protection Agency 841 Chestnut Building Philadelphia, Pennsylvania 19107 Re: Osborne Site, Grove City, Pennsylvania Dear Mr. Abreu-Clntron: This 1s 1n reply to Mr. Wassersug's letter to me of August 30, 1985, concerning the captloned site. That letter was received by my office on September 6, 1985. Due to the fact that the U.S. Environmental Protection Agency has, along with the Pennsylvania Department of Environmental Resources, been an active participant 1n overseeing the Implementation of the Osborne Site Consent Order's Remedial Investigation completed by Cooper Industries June 25, 19S4, and the fact that Cooper has Implemented and completed many additional tasks (I.e., soil samples, water samples, borings) suggested by both agencies and not Included 1n the original Work Plan approved by the Pennsylvania Department of Environmental Resources, Cooper 1s hereby notifying you that 1t declines to become Involved In yet another testing program as outlined 1n your letter. Your letter maintains that the proposed additional testing program 1s "necessary" to complete the Remedial Investigation for the site. Contrary to the assertions 1n your letter. Cooper maintains that the Remedial Investigation 1s now complete and Cooper Intends to comply with Its remaining obligttlons under the Consent Order and Agreement with the Pennsylvania Department of Environmental Resources dated September 20, 1983. Responding to several of the comments 1n your letter, Cooper: (1) disagrees that the additional sampling plan proposed 1n your letter 1s necessary to complete the Remedial Investigation; (2) maintains that the completed P.emedlal Investigation confirms there 1s no release or threatened release of hazardous substances at the site (contrary to the assertions 1n your letter); and (3) 1s appalled that after nearly three (3) years of negotiations and Involvement et the site, the Environmental Protection Agency refuses to take a firm position on closure of the site, and In fact has found 1t necessary to warn Cooper in your letter that "the factual and legal discussions contained 1n this letter . . . are not Intended to be and cannot be relied upon as e final Agency position on any matters set forth herein1^

EXHIBIT 18

COOPER INDUSTRIES. INC. City Tower Suite 4000 F>0 Bo* 4446 Houston Texas T7210 (713)739-5400 Page 2

To review the background et the site. Cooper, as one (1) potentially responsible party, but not the only potential responsible party, came forward alone in September, 1983, and executed a Consent Order and Agreement with the Pennsylvania Department of Environmental Resources. In connection with the Consent Order and Agreement, Cooper has expended nearly $1 million at the s1*e conducting, among other things, sampling end testing. !n fact, at the Pennsylvania Department of Environmental Resources's request Cooper has performed work above and beyond the obligations Cooper assured under the Consent Order and Agreement. This effort hes confirmed, In Cooper's view, that the site poses no threat to man or to the environment. Thus, Cooper has reasonably concluded that the Feasibility Study phase of Us work should be commenced so that the site can be closed as promptly as possible. Unfortunately, however, the Pennsylvania Department of Environmental Resources in a letter dated May 22, 1985, requested that Cooper pcKonn additional testing at the site, which testing Cooper believed to be redundant end unnecessary* Cooper has taken en appeal to the Pennsylvania Environmental Hearing Board from the aforementioned letter of the Pennsylvania Department of Environmental Resources. Cooper had two (2) primary objectives 1n appealing the additional testing order by the Department of Environmental Resources. First, and most Important, Cooper views the additional testing es wholly unnecessary and economically wasteful. Second, Cooper felt it could not seriously consider the request because the Pennsylvania Department of Environmental Resources declined to provide any assurance that no further testing would be required or, alternatively, to discuss the circumstances under which the Pennsylvania Department of Environmental Resources might request further testing, depending upon the results of the proposed testing. Cooper's adamant position 1s that the data it has generated et the site 1s statistically significant end accomplishes the purposes of the Remedial Investigation phase of the Consent Order and Agreement. The Pennsylvania Department of Environmental Resources's requested additional testing constitutes flnencielly Irresponsible "overkill". Your letter dated August 30, contains a testing plan different from that requested by the Pennsylvania Department of Environmental Resources in Its May 22, 1985, letter. Cooper feels fortunate that It did not Implement the Pennsylvania Department of Environmental Resources's request when made 1n May, 1985, because the Environmental Protection Agency apparently now has agreed with Cooper that et least some of the tests requested by the Pennsylvania Department of Environmental Resources were unnecessary end the Environmental Protection Agency has dropped them from Its plan. On the other hand, the Environmental Protection Agency has added additional tests to the Department of Environmental Resources's plan, confirming Cooper's fear that there will be no end to the requested testing. For quite some time, it has been Cooper's analysis that neither the Environmental Protection Agency nor the Pennsylvania Department of Environmental Resources were willing to reach a conclusion on the eppropriete testing et the site, notwithstanding the Pennsylvania Department of Environmental Resources's express approval of the Work Plan attached to the Consent Order end Agreement end the Environmental Protection Agency's knowledge of, end failure to express eny objections to, that plen. Cooper has shown such en extraordinary spirit of cooperation in the cleanup of the Osborne Site, end hes assumed obligations which the vest majority of potentially responsible parties nationwide have refused in similar circumstances. The Envlronrental Protection Agency end the Pennsylvenle Department of Environmental Resources should not lose sight of the fact that 1t 1s reasonable for Cooper to ask that testing end sampling be concluded once the available data is statistically significant end provides e basis for accurate

303345 • Pace 3 conclusions as to the hazardous materials, 1f any, present onsite. It Is unreasonable to expect Cooper to continue testing at Osborne, as 1* Us effort were e "leboratory" experiment unencumbered by pragmatic considerations of cost and benefit. This letter 1s without prejudice to Cooper's right to oppose the testing proposed by the Environmental Protection Agency end the Department of Environmental Resources in any form evailable to Cooper, Including the courts end administrative agencies. Should the testing proposed by the Environmental Protection Agency ever be undertaken, Cooper requests the opportunity to monitor the testing end esks that the Environmental Protection Agency contect the Individual designated below In advance of the testing so that Cooper ray have e designated representative or representatives e vail able onsite to observe end monitor. Finally, and without prejudice to our opposition to your proposed action as steted ebove, we feel 1t Is Incumbent upon the Environmental Protection Agency to look to other potentially responsible parties for contribution to the Investigation end cleanup of the Osborne site. Sincerely, U.

Robert W. Teets, Director Risk Management end Environmental Affairs RWT:ja J1m Baker (USEPA) E.A. Bircher J.S. Drelscharf »i.W. Montgomery, Esq. C.J. Plesnicher Petti Saunders, Esq. (PA-DER) Stephen R. Uessersug (USEPA) Dwight Worley (PA-DER)

bcc: A.E. Riedel Tom Campbell Bruce Stolbe Frank S1mun1c Mike O'Brien .

30334.5 I!

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303343 .^^-

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Post Office Box 2063 Harrisburg, Pennsylvania 17120 Buraau of Solid Wast. Manaoemant October 80'lfl85 717-783-7816

Mr. Robert Teets Director of Safety Administration and Environmental Affairs Cooper Industries, Inc. First City Tower, Suite 4000 ' P.O. Box 4446 ' Houston, TX 77210 Dear Mr. Teets: The Pennsylvania Department of Environmental Resources (PADER) is withdrawing our request for additional on-site and off-site sampling at the Osborne Site that was outlined in our letter dated May 22, 1985. Because of your unwillingness to proceed with the campling program we requested the Environmental Protection Agency (EPA) to spend Superfund monies to complete the Remedial Investigation (RI) work that was administered during the week of September 23 through September 27,1985. The sampling that occurred was outlined in a letter submitted by the EPA to Cooper Industries on August SO, 1S85. Once EPA receives the analytical results of the field investigation, they will incorporate the results into a supplemental RI Report. Then the supplemental RI report will be submitted to the PADER for review and approval. After that time we will be contacting you regarding the performance of the Feasibility Study. If you have any questions regarding this matter please do not hesitate to contact me. Sincerely,

Dwight D. Worley, CKief Division of Emergency and Remedial Response

RECEIVED

WOV5 1385 EXHIBIT 19 t RISK trtAw'.C'ic'.-its'T AND ENVIRONMENTAL AFFAIRS 20

303350 j/ RECEIVED •f>.vV JUL141986 /*^% UNITED STATES ENVIRONMENTAL PROTECTION AGEI CY REGION III J?!SK MANAGEMENT AND . ENVIRONMENTAL AFFAIRS Building Philadelphia, Pennsylvania 19107TUT

Hr. Robert V. Teets, Director Risk Management and Environmental Affairs Cooper Industries, Inc. First City Tower, Suite 4000 P.O. Box 4446 Houston, Texas 77210 Dear Hr. Teets: On June 26, 1986 Randy Roush, Site Project Officer for the Pennsylvania Department of Environmental Resources (PADER) and Patricia Ten, Osborne Site Project Officer for the US Environmental Protection Agency (USEPA), met to discuss the status of the Remedial Investigation activities thus far completed at Osborne. Based on a review of the Remedial Investigation Report dated June 1984, prepared for Cooper Industries, Inc. by Fred C. Hart Associates Inc; split sample results provided by you in a letter dated January 8, 1986 concerning the September 23-26, 1985 EFA sampling program; and recently completed sampling analyses of samples obtained by EFA during the September 23-26, 1985 EFA sampling program, both Mr. Roush and. Ms. Tan have agreed that the necessary remedial investigation activities at the Osborne site have now been completed . EFA and PADER jointly would like to meet with you to discuss these sample results, their impact on the remedial investigations performed to date and a schedule for completion of the next step; the Feasibility Study. Please call Randy Roush at (717) 783-7816 who will be coordinating this meeting. Ve look forward to hearing from you. Sincerely,

Patricia M. Tan , "'Environmental' Engineer Osborne Site Project Officer Enclosures _ cc: Kathy Hodgklss, USEPA Steve Klano, USEPA Randy Rousch, PADER Patti Saunders, PADER Dan Becker, PADER i > EXHIBIT 20

303351 » co ONE COMMENCE o*t:vc CMN*one NEA JERSCV

30333:- COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Post Offica Box 2063 Karrisburg. Pennsylvania 17120 September 16,19S6 717-7*3-7816 Buraau of Wasta Management

Mr. Robert W. Teets Director of Risk Management and Environmental Affairs Cooper Industries . RECEIVED First City Towers, Suite 4000 / P. O. Box 4446 Houston, TX 77210 SEP 2 51986 ENVIRONMENTAL AFFAIRS Re: Osborne Site, Grove City, PA f Dear Mr. Teets: The Pennsylvania Department of Environmental Resources (DER) and the United State Environmental Protection Agency (EPA) concur that the Remedial Investigation for the above- referenced site is complete, now that we have all the EPA soil sampling data that was conducted in September 1985. Cooper Industries may now proceed with the Feasibility Study (FS) to identify and assess remedial alternatives. The FS shall be conducted in accordance with the Solid Waste Management Act, the Clean Streams Law, the regulations promulgated thereunder, EPA's Guideline on Feasibility Studies Under CERCLA Uune, 1985), CERCLA, and Section 300.68 of the NCP, 50 Fed. Reg. 47973 (November 20, 1985) (to be codified to 40 CFR, Paragraph 300.68) and any future revisions which become effective before the submission of the final FS report. The proposed plan for the FS must be submitted to DER for approval within twenty (20) days, pursuant to Paragraph 15 of the Consent Order and Agreement (1983). The plan shall include a schedule for submission of a Draft FS and the Final FS Report. If DER determines that the proposed plan cannot be approved, Cooper shall submit the necessary revisions within the time specified by DER. If you have any questions regarding this matter, please do not hesitate to contact me. Sincerely,

Randy L. Roush Division of Emergency and Remedial Response

EXHIBIT 21 303353 303354 RotwrtW.TMts Director Risk Management COOPER INDUSTRIES infl Enwonmermi Affa'

October 31, 1986

Mr. Randy Roush Chemist Department of Environmental Resources Bureau of Waste Management Fulton Building, 7th floor Third & Locust Streets Harrlsburg, PA 17120 Re: Osborne Feaslbitty Study and Work Plan Dear Mr. Roush: Attached 1s the Osborne Feaslbltty Study and Work Plan as agreed upon 1n the Osborne Consent Order and Agreement. The management of Cooper Industries, Inc. looks forward to your approval of this Work Plan so that we can begin Its Implementation and reach a final remediation at this site. If you have any questions as you review the attached plan, please call me. Your cooperation Is appreciated In this matter. Sincerely,

^. U-

M8/rwt Attachments ...... cc: Patricia M. Tan U.S. EPA bcc: Wendy Hawthorne C.J. Plesnlcher S. Drelscharf ; Dan Rlesel — COOPER INDUSTRIES. INC Jack Montgomery Fint City Tower. Suite 4000. P.O. Box 4446 / ^ EXH1BIT " 30335S OSBORKE FEASIBILITY STUDY AND WORK PLAN

PURPOSE

In compliance with the Consent Order and Agreement between the Pennsylvania Department of Natural Resources (PADER) and Cooper Industries, a Feasibility Study (FS) will be conducted to Identify and assess remedial action alternatives and recommend the cost appropriate remedial action. This Work Plan defines the major tasks required to carry out the FS. A schedule for performing the various tasks and for completing the FS 1s also provided.

SCOPE

The Feasibility Study consists of seven (7) tasks; as described Individually 1n greater detail In the following sections.

Task 1 • Description of Current Situation Task 2 • Selection of Preliminary Technologies Task 3 - Development of Remedial Alternatives Task 4 - Initial Screening of Alternatives Task 5 - Evaluation of Alternatives Task 6 - Preliminary Report Task 7 • Final Report

Task 1 - Description of Current Situation

The site's background and environmental concerns will be summarized In order to outline the purpose and need for additional remedial responses and to account for remedial measures taken to date. This summary of baseline Information and risk conclusions will be primarily from the Remedial Investigation Report (RI). In addition, all currently available data on the site will be used Including the following: •2-

1. Cooper's responses to PADER/EPA comments on the RI, October, 1984 v, 2. Fred C. Hart letter on soil sampling, January 22, 1985 3. Fred C. Hart soil sample data from the EPA/NUS sampling program conducted at the site In September, 1985 4. EPA/NUS Field Trip Report for Osborne disposal, September 11, 1986 S. Quality Assurance Review of the above, dated September 11, 1986

Task 2 - Selection of Preliminary Technologies

Based on the site, specific problems and statement of purpose Identified In Task 1, a master 11st of potentially feasible remedial technologies- consistent with the Task 3 alternatives will be developed. This 11st will be screened based on site conditions, waste characteristics, costs and Implementation requirements to eliminate technologies that would be unreliable or prove extremely difficult to Implement at this site.

Task 3 • Development of Remedial Alternatives

Remedial alternatives will be further developed on the basis of objectives \^/ established for this site as follows:

1. Establishment of Remedial Response Objectives

The existing data and reports have demonstrated that a remedial approach focusing on source controls for the site most closely meets the objectives of the National Contingency Plan (NCP) and the levels of risk posed by existing site conditions. Major objectives currently being considered for potential remedial response efforts Include the following:

a. Implementation of site aesthetics b. Control of potential direct contacts, 1f any c. Control of potential air releases, 1f any d. Control of surface water run-on and potential contamination associated with site drainage, If any

303S57 -3-

2. Identification of Remedial Alternatives v Remedial alternatives will be developed Incorporating final response objectives with alternative technologies developed 1n Task 2.

Task 4 - Initial Screening of Remedial Alternatives

Four (4) broad considerations will be used as a basis for the Initial alternatives screening: technical feasibility, public health, environmental effects and cost. More specifically, the following factors will be considered: / 1. Technical Feasibility - Technologies that may prove extremely difficult to Implement,, will not achieve the remedial objectives 1n a reasonable time period, or will rely on unproven technology will be modified or eliminated.

2. Public Health • Only those alternatives that satisfy the response objectives and contribute substantially to the protection of the public health, welfare, or the environment will be considered further.

3. Environmental Effects - Alternatives posing significant adverse environmental effects will be excluded.

4. Cost - An alternative whose cost far exceeds that of other alternatives will usually be eliminated unless other significant benefits may also be realized. Total costs will Include the cost of Implementing the alternatives and the cost of operation and maintenance. Cost screening will be conducted only after the technical feasibility, public health and environmental screenings have been performed.

Task 5 - Detailed Evaluation cf Remedial Alternatives

During this task, an evaluation of the effectiveness of alternative remedies that pass through the Initial screening In Task 4, will be accomplished as follows:

3035S? -4-

1. Technical Analysis - The technical analysis will, as a minimum:

^ a- Describe appropriate technologies b. Discuss how the alternative does (or does not) comply with specific requirements of other environmental programs. When an alternative does not comply, a discussion of how the alternative prevents or minimizes the migration of wastes and public health or environmental Impacts will be presented with special design needs that could be Implemented to achieve compliance. c. Outline operation, maintenance and monitoring requirements of each alternative. '' d. Identify and review facilities proposed to be utilized for off-site waste disposal to ensure compliance with applicable RCRA and other EPA environmental program requirements, both current and proposed. Potential disposal facilities, 1f required, will be evaluated to determine whether off-site management of site wastes could result 1n a potential for a future release from the disposal facility. e. Identify temporary storage requirements, off-site disposal needs, and transportation plans, If any. ••>, f. Describe whether any off-site alternative results In permanent treatment or destruction of the wastes, and, If not, the potential for future releases to the environment. g. Outline safety requirements for remedial Implementation (Including both onsite and off-site health and safety considerations, as appropriate). h. Describe how the alternative could be phased Into Individual operable units. The description will Include a discussion of how various operable units of the total remedy could be Implemented Individually or 1n groups, resulting 1n a significant Improvement to the environment or savings In cost. 1. Describe any special engineering requirements or site preparation considerations.

303359 -5-

2. Env1ronmental Analvs1s V An Environmental Assessment (EA) for each alternative will be performed. The EA for each alternative will Include, at a minimum, an evaluation of beneficial effects of the response, adverse effects of the response, and an analysis of measures to mitigate adverse effects.

3. Public Health Analysis

Each alternative will be assessed In terms of the extent to which 1t mitigates potential long-term Impacts to public health both during and after completion of the remedial action. The assessment will describe the levels and characterization of the contaminants onsite, potential exposure routes, and the potentially affected population. The effect of "no action* will be described 1n terms of short-term effects and long-term exposures and resulting public health Impacts. The relative reduction 1n public health Impacts for each alternative will be compared to the no action alternative. For source control measures or when criteria, standards, or guidelines are'not available, the comparison ^—/ will be based on the relative effectiveness of technologies.

4. Institutional Analysis

Each alternative will be evaluated based on relevant Institutional needs. More specifically, regulatory requirements, permits, community relations, and participating agency coordination will be assessed.

5. Cost Analysis

The costs for each feasible remedial action alternative (and for each phase as appropriate) will be presented as present worth costs and will Include the total cost of Implementing the alternative and annual operating and maintenance costs. Monetary costs and associated nonmonetary costs will be Included as appropriate. A distribution of costs projected over time will also be provided.

303360 -6-

6. Evaluation of Most Cost-Effective Alternative • • • • Alternatives will be compared using technical, environmental and economic criteria. At a minimum, the following areas will be used 'to compare alternatives:

a. Present Worth of Total Costs - The net present value of capital and operating and maintenance costs also must be presented. b. Environmental Effects - Only the most Important effects or Impacts will be summarized. Reference will be made to supplemental Information* arrayed 1n a separate table, 1f necessary. c. Xechnlcal Aspects of Implementing the Remedial Alternatives - The technical aspects of Implementing each remedial alternative relative to the others will be clearly delineated. Constructablllty, reliability and durability will be summarized for each alternative. d. Information on the Extent to Which Remedial Alternatives Meet the Technical Requirements and Environmental Standards Which are Relevant and Appropriate Under the Circumstances - This Information will be arrayed to Identify differences 1n how the various remedial alternatives satisfy relevant and appropriate environmental standards. e. Information on Community Effects - The type of Information that will be provided 1s the extent to which Implementation of a remedial alternative disrupts the community (e.g., traffic, temporary health risks, and relocation). f. Health Information - Each alternative will be compared to assess the relative degree of public health risk reduction achieved. A cost/risk reduction ratio will be developed for each alternative.

Tjpsk 6 - Preliminary Report

A preliminary report presenting the results of Tasks 1 through 5 will be prepared. The preliminary report will be submitted to PADER. An outline of the draft report 1s attached as Appendix A.

3033G1 -7-

Task 7 - Final Report v A final report will be prepared for submission to PADER and EPA, due four weeks following written comment and review of PADER subject to paragraph 25 of .the Consent Order and Agreement. The report will Include the results of Tasks 1 through 6 and will Include any supplemental Information In appendices. This report will also Include a responslveness summary on public comments received.

SCHEDULE

The following outlines a prepared schedule for completion of-'the seven (7) tasks above:

WEEKS AFTER APPROVAL TASKS______OF WORK PLAN Task 1 - Description of Current Situation a. Summarize current database 2 Task 2 - Selection of Preliminary Technologies a. Develop master 11st 3 ^__^/ b. Screen master 11st 4 Task 3 - Development of Alternatives a. Establishment of remedial response objectives 4 b. Identification of remedial alternatives 6 Task 4 - Initial Screening of Alternatives a. Technical Feasibility 7 b. Public Health 9 c. Environmental Effects 8 d. Cost 10 Task 5 - Evaluation of Alternatives a. Technical Analysis 16 b. Environmental Analysis 18 c. Institutional Analysis 20 d. Public Health Analysis 22 e. Cost Analysis 22 f. Evaluation of Cost-Effective Alternatives 24 Task 6 - Preliminary Report a. Write Report 28 ^^^ b. Review and Comment by PADER 32 Task 7 - Final Report < weeks following PADER's written review & comment 303SG2 APPENDIX A

OUTLINE OF OSBORNE FEASIBILITY STUDY

1.0 INTRODUCTION 1.1 Site Background Information a. Site history b. Site hydrogeology 1.2 Nature and Extent of Site Hazards a. Contaminants found b. Degree of concern ' 1.3 Interim Remedial Measures Completed to Date a. Partial removal - surface cleanup b. Off-site disposal/treatment - landfill, Incineration c. Restricted access - site security fencing and signs

2.0 IDENTIFICATION AND SCREENING OF AVAILABLE TECHNOLOGIES 2.1 Listing of potential available technologies 2.2 Screening of available technologies

3.0 REMEDIAL ACTION OBJECTIVES 3.1 Site Aesthetics 3.2 Control of Direct Contact 3.3 Control of Air Releases 3.4 Control of Surface Water Run-on and Site Drainage

4.0 IDENTIFICATION AND SCREENING OF REMEDIAL ALTERNATIVES 4.1 Potential Remedial Alternatives 4.2 Screening of Remedial Alternatives a. Technical feasibility b. Public health c. Environmental effects d. Cost 5.0 ENGINEERING ANALYSIS OF FINAL ALTERNATIVES 5.1 Performance 5.2 Reliability 5.3 Implementabillty 5.4 Safety

6.0 EVALUATION OF INSTITUTIONAL REQUIREMENTS OF EACH FINAL ALTERNATIVE 6.1 Compliance with State and Federal Standards and Local Requirements 6.2 Permit Requirements 6.3 Community Relations 6.4 Coordination with Other Agencies ''

7.0 EVALUATION OF ENVIRONMENTAL IMPACTS OF EACH FINAL ALTERNATIVE 7.1 Beneficial Effects 7.2 Adverse Effects 7.3 Mitlgatlve Measures

8.0 ASSESSMENT OF PUBLIC HEALTH IMPACTS OF EACH FINAL ALTERNATIVE 8.1 Sources of Mechanisms of Chemical Releases .. . 8.2 Exposure Pathways 8.3 Qualitative Analysis of Potential Public Health Threats

9.0 DETAILED COST ANALYSIS OF EACH FINAL ALTERNATIVE 9.1 Cost Estimates a. Capital costs b. Operation and Maintenance Costs 9.2 Present Worth Analysis 9.3 Cost Sensitivity Analysis

10.0 RECOMMENDED REMEDIAL ALTERNATIVE 10.1 Matrix Summary of Engineering, Institutional, Public Health, Environmental Effects and Cost Factors 10.2 Recommended Remedial Approach

11.0 APPENDICES

303364- «u.

23 303S6S I ta^a^*w««l£ COMMONWEALTH OF PENNSYLVANIA V' IsS±^±± DEPARTMENT OF ENVIRONMENTAL RESOURCES v ««i,.4.v.w.L,,A Post Office Box 2063 Harrisburg,. Pennsylvania 17120 January 6,1987 717-783-7816 Bureau of Waste Management RECEIVED Mr. Robert W. Teets Director, Risk Management and JAN 131987 Environmental Affairs RISK MANAGEMENT AND Cooper Industries, Inc. ENVIRONMENTAL AFFAIRS First City Towers, Suite 400 P. O. Box Wtf6 Houston, TX 77210 Dear Mr. Teets: Thank you for your submission of the Osborne Feasibility Study and Work Plan. Both EPA and PA DER have reviewed this Work Plan and have made the following comments: I. EPA Comments: 1. Please refer to the EPA Bioassessment Task Group memo (Attachment No. 1) which addresses environmental concerns and recommendations according to the NCP criteria (40 CFR 300.68) for assessment of wetlands resources. 2. Please refer to the Draft Evaluation Report Review of the Feasibility Study Work Plan (Attachment No. 2) prepared by NUS Corporation. 3. TASK 2 - Technologies should be identified in relation to the site-specific problem and then alternatives developed. The objectives of site remediation are: a) public health and safety assurance, b) groundwater and drinking water protection, c) soil protection, and d) surface water protection. The consideration in establishment of these objectives is the degree of remediation required. 4. TASK 3 - Control of surface water run-on/run-off and potential contamination associated with site drainage, both to groundwater and surface water. 5. TASK * - a) Technical Feasibility - The feasibility of implementing the remedial measures and its reliability will be evaluated, b) Public Health - The degree of environmental protection which the remedial measure can provide will be evaluated. c) Environmental Effects - The environmental effects created by implementation of the remedial measure will be evaluated, d) Cost - The cost for implementation, operation, and maintenance will be evaluated. "eTThe availability of areas for contaminated soil disposal (if necessary) will be evaluated. Elimination of remedial alternatives during the screening phase must be accompanied by an adequate explanation of the reasons for elimination. Cost alone is not a sufficient reason for eliminating a particular alternative. Elimination of any alternative during the screening phase must meet with the approval of the lead agency.

EXHIBIT 23 303366 Mr. Robert W. Teets - 2 - January 6,1987 6. TASK 5 - 0), Should describe the environmental impacts created by the remedial alternatives and methods necessary to mitigate adverse effects. Once the • requirements of each alternative have been developed, the detailed evaluation of each alternative's ability to meet objectives identified for remediation at the Osborne Landfill Site will be completed. 7. Add to TASK 5, Comment No. 2 of Attachment No. 2 • The potential for the remedial alternative to minimize or eliminate the release of contaminants into the environment will be determined. Management requirements and other Institutional concerns will also be considered as an indication of reliability. 8. Add to TASK 5, Comment No. 5 of Attachment No. 2 - Costing procedures should be standardized to the extent possible so that estimates are comparable. 9. Add to TASK 5, Comment No. 6 of Attachment No. 2 - On-site and off-site safety requirements during implementation of the alternatives will be considered. This includes evaluation of health hazards associated with remedial actions, such as the release of toxic fumes during excavation activities. 10. General Comments - A) No mention of environmental concerns, (i.e., impact on marsh). B) As a result of the evaluation process: 1) Identification of alternatives; 2) screening of alternatives; and 3) evaluation of alternatives. The agency can then select the most cost-effective and environmentally-sound remedial alternative after a public comment period. This alternative will have been identified as the lowest cost alternative that is technically feasible, reliable, and adequately protects the public health and environment. C) If the Treatability Studies are to be carried out, then bench scale or pilot studies need to be performed if this alternative is selected. II. PA DER Comments; 1. TASK 5, Public Health Analysis - A quantitative and qualitative risk assessment must be conducted in accordance with the Superfund Health Assessment Manual (May 1915) and the Endangerment Assessment Manual (August 1985). II. Appendix A3.0 - Remedial Action Objective - Add 3.5 Control of Groundwater Contamination From Contaminated Soils. Add 3.6 Containment of Residual Contaminants in Soil. III. Appendix A ft.O - Add E. Reasons for Eliminating Alternatives. IV. Appendix A 8.0 - Add 8.1 Fate and Transport. Add 8.3 Qualitative and Quantitative... V. Appendix A 9.0 - Add C. Costing Methodology.

303367 Mr. Robert W. Teets - 3 - January 6, 1987 Both agencies would like to schedule a meeting, at your earliest convenience, to discuss these comments and to incorporate new SARA requirements into the Feasibility Study. If you have any questions regarding this matter, please do not hesitate to contact me. Sincerely,

M^^.^ Randy L. Roush Division of Emergency and Remedial Response Attachments Bureau of Waste Management

303363 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Wheeling Office 303 Methodist Bldg.. 11th & Chapline Streets Wheeling, West Virginia 26003 Osborne Site - Peoannendations Cor Rioassessment ——OATC H. Ronald Preston, Chief (SESSO),'1"3 RECEIVED JAN IS ft? T0 Pat Tan (3HW12) Enforcement Project Officer RISK MANAGEMENT AND ENVIRONMENTAL AFFAIRS The Bioassessment Task Group net Friday, October 3, Wfifi, and made reoomen- daticns for the remedial investigation at the Osborne cite. 'Wetlands including swstplands such as those located iirvnediately to the south and southwest of — the mine spoils area of the cite are a valuable natural resource. The nuggested studies were recommended to address the requirement according to NCP criteria (40CFR 300.6B) for assessment of wetlands resources! for determination of the extent of contamination; and for passible impact of contamination and proposed remedies to natural resources and environmentally sensitive areas. A preliminary description (from a U.S. FWS eite visit) of the wetlands at the site indicate that an approximately in acre area contains diverse freshwater marsh vegetation (i.e....* cattail, spike rush, spatterdock, soft rush) and supports varied wildlife species. Identification of the types and delineation of the boundaries of the wetlands in the area and determination of the possible inpacts to the wetlands should be documented in the HI/PR and ROD. The following are the i specific reoswnendations for further study suggested by the Task Group: 1. A wetlands assessment should be performed which includes taking two cores to establish the depth of wetlands or swanpland peat and possible extent of contamination. The wetlands assessment may be conducted by either the contractor for the remedial investigation or by the FIMPR of the Environmental Services Division. 2. A selective scan of priority pollutants shoud be conducted on five samples of wetland soils. Analyses should include base-neutral and acid extractables, volatiles, and heavy metal contaminants attributed (previously documented) ~~ to the site. The per cent organic matter and grain size of the sampled soil Also should be determined. 3. Two different soil elutriate testa (freshwater algae vfi hour test and Microtox) should be conducted to determine toxicity of soil from two sites in the wttlands. The reconroended sampling locations are at the inflow or closest entry point of contamination and at the outflow or furthest distance from the source of contamination. Samples should be taken ten feet inside the boundary of thn wetland and each sample will require approximately ten pounds of soil. Pesults of these tests will demonstrate the effectiveness of the clean-up efforts to date. However, if results show high toxicity, further bioassessment (i.e., bioassays) are reoocmended.

303369

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Page 2 If you have any questions, please contact Ron Preston, Chairman, Bioassessment Task Group at (304)233-1271, Cindy Rice of the U.S. FWS (814)234-4090 or Alyce Fritz, NOAA CTC (597-3636). cc: Bioassessment Task Group Kathy Hodgkiss, 3HW12

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303371 'J i. * ' O C *.

^_ y TABU? ^* CONTENTS

1.0 IKTHODUCT10K ; 2.0 ra MORX PZAH EVALUATION i 8.1 TASK i - DESCRXPTZOK OF CtTRRENT 2 fXTUATZOK 2.2 TASK 2 • iXLlCTIOH CT PREL1K1NARV 3 TICKKOLOOII8 2.3 TASK 3 • OXVSLOPXEKT Of REMEDIAL 4 AXfftRHATXVlf 2.4 TASK 4 - INITIAL fiCtZZKZHG OF MHEDIAL 5 ALTtWATIVM 2.5 7A6X B • DETAILtD SVALUATZOK OF R£K£DXAL 6 ALTERKATIVI8 S.« TASK < - PMELXXXHXAY BXPCAT 7 ^, 2.7 TASK 7 • FZKAL XlPOftT 7 2.8 fCXZDULX I

303372 1.0 The raviev And evaluation of the FS Work Plan, prepared by Cooper Industrial, Inc., vsra conducted in accordance with Teak l (Activity 2) et the Final Work plan for review of FS document!, datad Auguit 6, 191 e. Tha UK III Team hat raviawad background information prior to evaluating tha FS Work Plan te determine vhathar tha a cop a of vork and technical approach eatiefiea tha requirement! for conducting * feasibility atudy, as aat forth by tha National oil and Xaiardoua Substances Pollution Contingency Plan (NCP) (40 em J00.68) November 20, 1916. Available information partaining to tha Oaborn* Landfill site vaa ebtainad fron tPA filas shortly aftar tha initiation ef this Vork Assignment in May 191 f. This information consisted of reports, lattara, and aemee from tha EPA, tha Pannsylvania Dapart&ant of Environmental Resources (PADZR), and tha raaponaibla party. To davalop an understanding ef tha eite hiatory aa vail aa ita physical and ehaaical character iatic» , tha folloving deevmanta vara raviavad prior to evaluating tha FS Work Plans e Kaoadial Action Xastar Plan* Ofberna sita, prepared by NUS Corporation for CPA, Karoh 1983. o Propoaad Site Investigation Program for the Oiborne Landfill, prepared by Fred c. R&rt Aaaociatea, Inc., for Cooper Induatriei, date unknown. e oaborna Site Haaadial Znveatigation Report, praparad by Fred C. Hart Aaeociates/ Inc., for cooper Industrial, ffune 1984. o Kiacellaneeua ocrreapendenca betvaan EPA, PADER, and tha responsible party or their consultant. Additionally, a site vieit vae conducted by tha REX III Site Manager and engineer en Septembar if, 1986, to nak« visual observations of the aita in ordar te fa&iliariz* tht raviev team vith the site layout and surroundings. 2.0 »H The R£K III review feeuaad on evaluating the acopa of vork, idantified aa Tasks i through 7 ef the FS Work Plan vith raapact te tha require&enta of tha NCP and the SPA Guidance

30337j:» on feasibility Studies under CERCLA* The Objective of this evaluation .ie te determine whether the Osbome Landfill Site FS Vork Plan provides a etrategic and logical plan for evaluating remedial alternatives, bassd en these requirements. The overall objective ef any RI or FS vork plan ie to describe the epproaeh (plan) that vill be taken te obtain the ultimate goal or eencluaion. The FS Work Plan for the Osbome Landfill Site doea not alvaye provide enough information for tha reviewer to fully understand the general approach for undertaking the FS. This vas due te the eoneiaa format in which the report vaa presented. Because of this, tha vork plan vae difficult to evaluate against EPA guidance and the HCP. / The Beet critical deficiency in the FS Vork flan centers en tha feilure to properly scope end implement the feasibility study proeasa, ae outlined in the NCP end SPA guidance. Specifically, the relative order and pregraesien ef the initial Teaks 1*3 need te be revised so that remedial action objectives can be established at the outset of the etudy. Additionally, the proposed feasibility study should include tha formulation of General Response Actions (GRAs) and cleanup criteria prior to selecting and eereening remedial technologies. The FS Vork Plan fails to establish remedial action objectives at the proper stage of tha study and does not recognise the need to identify GRAs or cleanup objectives* The following sections ef this report provide comments and recommendations when applicable. Each section vill focus on one of the seven taake that are described in the FS Work Plan. The comments and recommendations reflect the general approach for seeping and implementing the FS, ae outlined in the subject FS Vork Plan. 2.1 TASK i • DESCRIPTION OF CURRENT SITUATION ye . i » CRAs should be established for each contaminant source and pathway that ware identified in the remedial investigation* Some examples ef GRAs include; no eetion, onsite disposal, or alternate water supplies (refer to the EPA Guidance en Feasibility studiee Under CSRCLA for developing GRAS) . Corresponding remedial action obi actives and cleanup criteria, te be used to evaluate preliminary remedial technologies, alec need to be formulated at this stage of the etudy. Following the establishment cf GRAs, technologies can be identified which may be appropriate to remediate or mitigate a specific contaminant source or pathway. The formulation of re&edial action objectives and cleanup criteria provides the framework in which the preliminary technologies will be screened against. The FS Work Plan needs to address these issues*

303374 wa. 9 * Zn order to evaluate the adequacy of the present data base, the FS work Plan ehould state that tha following information will be included under Task l ef the FS reportt 1) Kaiardeus waste sources should include descriptions ef thsir varieties, quantitiaa, physical and chemical characteristics, and range of concentrations. 2) Migration pathways such as tha subsurface, atmospheric, surface, and biota should be summarised* , 3) Pressnt and potential receptors, including descriptions ef land use, location of residential wells, and sensitive environmental areas (i.e., wetlands) should be discussed. 4) Potential and present impacts (i.e., quantitative risk' assessment) to the public health and environment with regard to contaminant source(s), migration pathways, and receptors is required. 2.2 TASK 2 - SELBCTJON OF PRELIMINARY TECHNOLOGIES eoiment wo. i - The selection of preliminary remedial technologies should be evaluated againat the remedial action objectives and cleanup criteria. The resulting technologies should then be eereened by additional criteria includingt technical feasibility; ability to protect the public health and environment; cost considerations) and Institutional rsstraints such as ARARS and ether Federal or Itlti guidelines. fhe ff Vork plan neede to clearly establish the basis for identifying preliminary technologies. Clarification is warranted regarding the statement "a master list of potential feasible remedial technologies censistsnt with Task 3 alternatives vill be developed". cattaent we> 9 * The scope of work under Task 2 does not describevhat criteria vill be used-to select appropriate technologies• EPA's "Handbook for Remedial Action at Waste Disposal Sites" (us EPA 1982) ehould be referred to in order to ensure that all remedial technologies vill be evaluated under thie task. Additionally, special consideration should be given to technologies which permanently contain, iaaobiliie, recycle, or destroy the contaminants. Documentation should be provided for technologies that are excluded from further consideration.

303375 ti t. i r y o „ o » ; o 0 ; y / c e!

2.3 TASK 3 - DIVELOPXENT OF REHEDZAL ALTERNATZVES wo. i * Clarification ie needed regarding the statement t&at "Remedia" l alternatives vill be developed...*11. Neither Tasks l nor 2 discuss the development of any alternatives. MO. a - with regards to the major objectives that are being considered for the site, no mention ie made to control groundwater contamination from migrating from the sits, under the P.CRA regulations (subpart F, 40 CFR 264), corrective actions must attain a groundwater cleanup standard (i.e., KCLS,). These standards may be applicable or relevant in this ease and ehould be investigated. Therefore, an objective to control the migration (or remediate the groundwater) nay be justified. As mentioned previouely, remedial action objectives should be developed earlier in the FS. wo. _a - Although the FS Work Plan states that the remedial approach will focus en sourcs controls, management of migration controls may be necessary vhere haiardeus substances (groundwater) have migrated from the original source area and pose a threat to the public health er environment (i.e., exceed relevant and applicable public health er environmental standards, guidance, er advisories) . Management of migration controls should not bs excluded during the development of the work plan. Documentation of reasoning for not considering management of migration controls, if applicable, should be discussed in the FS report. e we. * - The work plan does not discuss the developmenl t of ARARs, vith respect to the EPA requirement which etates that at least one alternative be developed ae part of the feasibility study in each of the following categories t o Alternatives for treatment er disposal at an off- sits facility approved by EPA, as appropriate i o Alternatives which attain applicable and relevant Federal public health or environmental standardei e Alternatives which exceed epplicable and relevant public health er environmental standards) e Alternatives which do net attain applicable or relevant public health er environmental etandarde but which will reduce the likelihood ef preeent or future threat from tha hasardous substances.

303376 This must includs an alternative which closely approaches the level of protection provided by the applicable or relevant standards and meets _ ciRCLA's objectives of adequately protecting public health, welfare, and environment) and o He action alternative. 'The identification of remedial alternatives should include* as a minimum, ens alternative for etch of the five categories listed above. This should be eenductad prior to the initial screening ef alternatives, The FB report •hould dieeuss those situations where no feasible alternatives can be identified for a given category. This is not described under thie task. 2.4 TASK 4 - INITIAL SCREENING OF REKEDZAL ALTERNATIVES cemment we. i - The FS Work Plan lists "Technical Feaeibility" of technologies as one of the four factors in which the preliminary alternatives vill be screened. This is not necessary since Teak 2 hae already eddresssd the scrsening of technologies. EPA guidance and tha NCP identify only three factors for which alternatives are te be screened againat (eest, public health, and environment) . Clarification ie warranted regarding the need te screen remedial technologies twice. we . a - when alternatives are eliminated from further consideration, the feasibility study must document the rationale for excluding each alternative* The FS Work Plan should indicate that this will occur as recommended in EPA guidance on Feasibility Studies. We . l « A present worth analysis should be aplemented at this etage ef the feasibility etudy. The FS Vork Plan makes no mention of this under the ecope of vork for coat screening. (See Section 2.S.2.2 of the FS Guidance Document.) 2.6 TASK 8 « DETAILED EVALUATION OF REKEDZAL ALTERNATIVES Ma. i - Due to the loeational factors of the site (the wetlands area and the potential for mine subsidence), thS n Vork Plan Should address these factors which would be considered during the evaluation of remedial alternatives.

303377 we. a * The technical analysis ef the demonstrated performance and implementability of the alternatives is net included in the ecepe of verk under this task. Additionally, it is net clear if "the technical analysis ef alternatives vill evaluate the "useful life" ef the technologies. The F8 Verk Plan should include a discussion ef these fectors since the FS report outline (Appendix A) has idsntified their inclusion in the report. MO. a - The environmental analysis doss net discuss tha need to undertake a Wetland Assessment. sines the southwestern portion of ths study area has been determined te be a wetland area, a Vetlands Assessment must be conductsd as part of the feasibility study psr EPA guidance. Information en remedial actions for wetlands can be obtained from the U.S. Department ef Interior, U.S. Department ef commerce, and the U.S. Corps of Enginsere. Wo. 4 « Regarding tha statement "For source control measures or when criteria, standards, or guidelines are not available, the comparison vill be based en the relative effectiveness ef technologies." Zt is recommended that the responsible party consult EPA Headquarters for further guidance en determining some type ef -criterion for which the alternative can be evaluated, such a criterion may be a health risk factor (i.e., 10*, 10 v) for a particular exposure pathway. Zf no criterion can be established, the relative effectiveness of the technology would be the basis for comparing alternatives. As mentioned earlier, the criteria, standards, er guidelines for source control measures should be established during the identification of cleanup criteria. fl o . s - The scope of vork for analysing the institutional factors of the remedial alternatives is too general, which does not provide enough detail te determine how this analysie will be performed. Additionally, it is not clear en how Cooper industries vill asssss "participating- agency coordination" ae described in the scope ef vork. we . 6 • The scope of work for conducting a cost analysis dees not mention the need to perform a sensitivity analysis, as identified in the Ft report outline (Appendix A) . Additionally, sources to be used in estimating caste (i.e., vender estiaates, costing guidance documents) should be discusssd in order to evaluate the formulation of cooper's cost analysis.

303378 2.6 TASK 6 - PMLIKZNARY REPORT we. l • The proposed FS report outline in Appendix A does net correlate with the task descriptions in the text ef the vork plan. The outline identifies items which are net discusssd in the text and vice versa. This makes the work plan very hard to fellow* ______- The proposed FS report format does not ndicate an Executive Summery* It is recommended that thie be included in the report. The Executive Summary should provide a brief overview of the study and analyses for determining the recommended remedial action. Haior topice to be included in this section include! (1) th% purpose and 'objectives of the feasibility study, (2) the background ef the eite, (3) selected remedial alternatives that vere evaluated, and (4) the recommended remedial action and its advantages ever other alternatives. Additionally, tables and figures should bs used, when possible, to summarise costs or other pertinent information* we . a - The Introduction (Section 1.0 ef the FS report) ehould include the objectives of the remedial action. Presently, the proposed report format (Appendix A ef the FS Vork Plan) shows that the remedial action objectives vill be presented in Section 3.0 ef the report, following the "Identification and Screening cf Available Technologies'* (Section 2.0) . This does not appear to be a logieal order since tha first step in the feasibility study is to identify the objectives of remedial ections in terms of specific goals (i.e., cleanup criteria, general response actions , source control versus management of . migration) . Based on these goals, remedial technologies are proposed and evaluated. The FS report format proposes the opposite (e.g., identifies technologies prior to identifying objectives). eaaaent We . 4 * The site background information ehould include a description of its physiographic characteristics and site location* These items are not listed en the proposed FS report format. 2.7 TA8K 7 - FZKAL MPORS No comments*

303379 S.8 SCHEDULE ee«nent we. i * The twenty-eight week schedule to prepare a draft FS report seems excessive, based en typical FS durations. normally, the FS is conducted concurrent vith the RI and the period following the RZ tasks, which rspresents the development of the FS report, requires approximately four weeks. However, this situation is different since the RZ vas performed in 1913 and 1984, prior to EPA guidance. Nevertheless, the time frame to complete Tasks 1*6 should be en the order of 12 to is Veek».

e 303380 AU-STATC us*. sw»v CO Out COMMENCE DAIVE CUN^OMO «* JC^SEY O

24 303331 ••' •> *.* J

DRAFTJVALUATION REPORT —" REVIEW OF REMEDIAL INVESTIGATION REPORT

OSBORNE LANDFILL SITE MERCER COUNTY, PENNSYLVANIA MARCH 13, 1987 W. A. NO. 25-3438.01

NOTICE

The information in this document has been funded by the United States Environmental Protection Agency (U.S. EPA) under REM III Contract No. 68-01-7250 to Ebasco Services Incorporated (Ebasco). This document is a draft and has not been formally released by either Ebaeco or the U.S. EFA. As a draft, this document should not be cited or quoted, and is being circulated for comment only. * EXHIBIT 24 30333:; EBASCO SERVICES INCORPORATED______EBASCO One O»toto vaiioy. i..M 4U. 2300 uncom n.gnw«y • e*st. tangnwne. PA W047 (2l5i 752 4212

March 11, 1987 RM/3/87-0038 Response Required

Ms. Patricia Tan CERCLA Enforcement Section U.S. Environmental Protection Agency Region III 841 Chestnut Street Philadelphia, Pennsylvania 19107 Subject: REM III Program - EFA Contract Ho. 68-01-7250 Work Assignment No. 25-3438 Osborne Landfill Site - Draft Evaluation Report Evaluation of the Responsible Party's Remedial Investigation Report Dear Ms. Tan: The REM III Team is pleased to present this draft report, which documents the review and evaluation of the responsible party's Remedial Investigation (RI) Report. This evaluation report is a product of technical reviews that were conducted by the REM III staff experienced in hydrogeology, civil engineering, biology, toxicology and chemistry. The review and evaluation of these documents specify if sufficient information has been collected to satisfy the requirements of the Superfund Amendments and Reauthorization Act (SARA) of 1986 and the National Contingency Flan (NCP). The Osborne Landfill Site RI Report contains major data gaps with respect to defining the extent of groundwater contamination and the direction of groundwater flow. In addition, the risks to the public health and environment are not quantitatively defined. In order for the responsible party to conduct a feasibility study (FS) that would comply with SARA and allow EFA to select an adequate remedial alternative, the data gaps should be resolved and a quantitative risk assessment performed. This evaluation report discusses these deficiencies and their effect on conducting the upcoming feasibility study. Ms. Fatritia Tan . U.S. Environmental Protection Agency March 11, 1987 - Page 2 RM

Please feel free to call me et 215-752-0212, or our Site Manager, Mr. Raymond F. Wattras, at 412-788-1080 to discuss our evaluation of the responsible party's RI Report. Very truly yours,

Richard C. Evans, F.E. Regional Manager, Region III cc: Mr. E. Shoener - EFA Region III Mr. K. Graham - EFA Region III Dr. K. K. Yates - 2PMO Dr. M. Amdurer - ZFMO Mr. A. Bomberger - NUS Mr. R. Hattras - NUS

303384- MARCH 13, 1987

DRAFT EVALUATION REPORT REVIEW OP REMEDIAL INVESTIGATION REFORT

OSBORNE LANDFILL SITE MERGER COUNTY, PENNSYLVANIA

EFA WORK ASSIGNMENT NUMBER 25-3438.01 UNDER CONTRACT NUMBER €6-01-7250

PREPARED BY: NUS CORPORATION PITTSBURGH, PENNSYLVANIA

APPROVED BY: EBASCO SERVICES INCORPORATED LANGEORNE, PENNSYLVANIA

PREPARED BY: APPROVED BY:

RAYMOND P. HATTRA5 RICHARD C. EVANS, P.E. SITE MANAGER REGIONAL MANAGER, REGION III NUS CORPORATION EBASCO SERVICES INCORPORATED TABLE OF CONTENTS

SECTION ' - PAGE 1.0 INTRODUCTION 1 2.0 BACKGROUND 1 2.1 SITE DESCRIPTION 1 2.2 SITE STATUS 2 3.0 REMEDIAL INVESTIGATION EVALUATION MATRIX / 3 4.0 EVALUATION MATRIX SUMMARY 11 5.0 TECHNICAL REVIEW COMMENTS ON 18 TEE REMEDIAL INVESTIGATION REPORT

ii 1.0 INTRODUCTION The REM III Team, under the United States Environmental Protection Agency (EFA) REM III Contract No. 68-01-7250, has reviewed and evaluated the Remedial Investigation (RI) Report dated, -Junp }$&& for the Osborne Landfill Site in Grove City, Mercer County, Pennsylvania. This review and evaluation was conducted in accordance with Task 4 of the Work Assignment Amendment No. 1 to the Final Work Flan, dated August S, 1986. The RI Report was reviewed to assess if the criteria for a remedial investigation (~R~i), as established by the National Contingency Plan (NCP) and the Superfund Amendments and Reauthorization Act (SARA) of 1966, were satisfied by the findings of the study that was undertaken by Fred C. Bart •* '*« A«!c^afrocf Tng»Tf for Coopeif~indus"t"rTe~s, the responsIbTe~T>a"fty (RP). Additionally, the RI Report was reviewed to determine if sufficient information has been collected to properly 'evaluate remedial alternatives that would meet the requirements of SARA. Section 2 of this report provides a brief description of the history of the Osborne Landfill Site. An evaluation matrix is included in Section 3. The evaluation matrix provides a mechanism for determining the completeness of the RI Report with respect to meeting the requirements identified in the NCP (40 CFR 300.68). This matrix was developed by using the EPA Guidance on Remedial Investigations Under CERCLA and the NCP. A summary of the evaluation matrix is included in Section 4 of this report. This summary corresponds to the matrix and details the completeness and content of the applicable section(s) in the RI Report. Section 4 also identifies areas requiring clarification and/or further information in order to satisfy both the NCF criteria and EPA guidance. Technical comments pertaining to the RI Report and appendices are provided in Section 5. 2.0 BACKGROUND 2.1 SITE DESCRIPTION The Osborne Landfill Site is located in Fine Township, Mercer County, Pennsylvania, approximately one-half mile east of Grove City. The site area encompasses approximately 15 of 80 acres of an abandoned coal strip mine. This tract of land is currently owned by Mr. Edward McDougal. From the 1950s until 1963, the site was operated as a dump by Mr. Samuel Mooney. This operation continued under the ownership of Mr. James Osborne from 1963 until 1978, when the landfill was closed by the Pennsylvania Department of Environmental Resources (PADER) (Bart, 1984). A fence with a locking gate surrounds the site • perimeter to restrict site access.

3033*1 The site is bordered to the north by a wooded area, to the south by Pine Street Extension, to the east by a cornfield, and to the west by mine spoils, which are overgrown with small trees and vegetation. A wetland area of approximately 15 acres in size is located south of the mine spoil pile and borders the southwest portion of the site. A small intermittent stream emerges from this wetland area and flows under the Pine Street Extension in a . southeast direction. In the early 1900's, a 1500-foot long pit was excavated in a southeast to northwest direction beginning near Pine Street (Bart, 1984). The strip Bine highwall is located near the eastern border of the site. A cornfield is adjacent to the top of this highwall. The mine spoils are located along the western portion of the site. Three small ponds are situated at the base of the highwall. The largest pond (Fond No. 3) is located at the northeast corner of the site and encompasses roughly 1 acre. It was reported to be roughly 30-35 feet deep (Bart, 1964). A small intermittent stream enters this pond from the north. The second pond (Fond No. 2) is located south of the large pond and is estimated to be one-half acre in size. The smallest pond (Pond No. 1) is situated about 100 feet south of the second pond. The ponds receive surface water runoff but there is no surface water discharge from them* Rather, the ponds' water levels were reported to fluctuate with the water table (i.e., the ponds recharge the groundwater). Nineteen test borings and monitoring wells were constructed to determine the geologic conditions at the site. These wells monitor the water table aquifer, the Clarion Formation, the Bomewood Formation, the Upper Connoquennessing Formation, and the Burgoon Formation. No monitoring wells are constructed outside of the site boundary. Domestic wells are constructed in the upper portion of the Clarion Formation. The Grove City munieipaL-vell is constructed in the Bomevsod Formation. 2.2 SITE STATUS Cooper Industries is the primary generator of wastes at the site and signed a consent order with PADER in October, 1963 to conduct an RI/FS and to clean up the site. Approximately 600 drums and 45 cubic yards of contaminated surface coils were removed in the summer of 1983 by Cooper Industries (USEPA, 1964). A remedial investigation was conducted by Fred C. Bart Associates, Inc., a consultant to Cooper Industries. The RI report was submitted to PADER in June 1984. The '?emedial investigation focused on the extent and nature of ogroundwater and surface water contamination at the site. The /6hallo£X wells indicated the presence of lead (60 vg/1) and •*'. Nickel (31 vg/1), which exceed EFA Drinking Water Standards (Bart, 1984). Wells monitoring the leachate exhibited benzene (109 V9/l)» nickel (67 vg/1), chromium (60 V9/D* lead (260 vg/1), mercury (4.2 vg/1) and arsenic (33 pg/1).

303382 '«>T

(_^ -Pentachloropheno l' ,was detected in the Clarion Formation and the " Burgoon Formatign. The_Burgeon Formation also indicated the presence of is(2-ethylhexyi*)phthalat§> The following priority pollutants including,——bis(2-ethylhexyl)phthalate (24 vg/1)-, ethylbenzene (19 vg/l)r toluene (12 vg/1), chromium (13 ug/1), cadmium (10 vg/l)r and nickel (13.4 vg/1) were detected in the Bomewood Formation. Surface water samples were collected from the two intermittent streams, the swamp area, and Ponds 2 and 3. Bigh concentration of iron (260 to 6020 vg/1) were detected in both ponds and the intermittent stream which emerges from the wetland area (19,500 vg/D* Samples taken from the swamp area revealed zinc (66-4809 V9/D* lead (96 vg/D* copper (5-68 vg/l)r and nickel (11-15 vg/1). The swamp area also exhibited phenol (12 vg/1) and di-n-butyl phthalate (3.57 vg/1). Priority pollutant organics -including chloroethane (7.1 vg/l)« 1,1-dichloroethane (6.3 vg/D* 1,1,1-trichloroethane (1.4 vg/1), and trichloro- ethylene (0.6 vg/1) w«re present in the onsite ponds (Hart, 1984). Organic analysis of waste samples obtained from drums detected the presence of ethylbenzene, ortho xylene, ethyl methyl benzene, and assorted hydrocarbons. These pollutants were reported as a percentage of the total waste content rather than • ppm or ppb. The percentages of these compounds, detected in the drums, were reported as follows: to^ * '/ • ethylbenzene (less than 0.1 - less than 100%) • ortho xylene (0.2 - 0.5%) • ethyl methyl benzene (0.5 - 1.0%) • assorted hydrocarbons (0.5-3.0%) A Feasibility Study Work Flan was submitted to PADER by Cooper Industries in October 1986. This work plan has not been approved by EPA as of March 1987. 3.0 REMEDIAL INVESTIGATION EVALUATION MATRIX The Evaluation Matrix is provided in the following pages of this report to provide the user with a checklist by which a comparison can be made between the information in the RI Report, and the requirements of the NCF and EPA Guidance on Remedial Investigations Under CERCLA. The matrix has five column headings which show 1) NCF criteria reference 2) If existing information has satisfied applicable NCF criteria 3) If the information is presented or addressed, but not considered complete with respect to meeting the NCP criteria

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303396 4) If the information is not provided to satisfy the NCP criteria 5) The section of the RI report which addresses the NCP criteria The matrix is supplemented vith a separate text section (Section 4.0) which contains an expanded evaluation of the RI Report as it pertains to meeting the requirements of the NCP. The evaluation matrix should be reviewed concurrently with this section of the report. Most of the criteria for undertaking and completing a remedial investigation ware not adequately net by the' RP. Data limitations for characterizing the extent of contamination and public health risks were noted throughout the report. Additionally, potential groundvater migration pathways may have to be re-evaluated by the RP, based on our evaluation. The . ^ p<" RI_Reppjrt__Ja.il£_lo— generate— *nf-f.*f*»r\t f«ta with respect to v &£ ' evaluating and selecting potpntjpj re.ipgjial alternatives. " r*'' fi- *•.,« 4.0 EVALUATION MATRIX SUMMARY vv^*** '•.•• „«» .• I A general discussion for each subheading of the Evaluation Matrix is provided in thie section. Each summary is referenced, by. heading and number, to the corresponding section of the yy matrix. The summaries provide information pertaining to the degree that a specific NCP criterion has been addressed by the findings of the RI Report. A. Public Eealth, Welfare, and Environmental Concerns Associated with Existing Site Conditions. t P«/T *V" 1. Potential Receptors at Risk .*« /*/ Section VI, Risk Assessment, of the JU Report qualitatively *$i ^ characterizes... th§. public hi<h ricks"~ppaed~~by... th~e afte , *** contaminants. The risk characterization provides a "traditional'*' fi v>f sburce-paThway-receptor analysis". Six pathways were identified ^'.^ r" and discussed in this section of the report. The following additional pathways should be addressed* , *•• •— •— — —— ——— — ~ dermal exposure to soils ingestion of soil by children > f ^ , ^^ ., '-——-- i of particulates * £/\ «? _ ., Qualitative risks to the public health were reported to be minimal to none, based on groundwater flow direction and theoretica_l_g.reyndwater contaminant dispersion modeling. This is unacceptable. DomefiVTe veij gjFptj'g gfauld be' ob'tapTeji, jin order ^o _es tabli£lL>-the. ^present., health^. rlAiu. Additionally, groundwater flow directions were based on one_ set of w^ter level it measurement from a limited number of wells. Section 5.0 ot. uus report provides additional comments regarding this issue. \ \ -11- * Based on the data presented in Table V-l, preliminary^ v calculations indicate that the cone of depression for the ? Grove City municipal well could extend beneath the site. This > potential receptor should be addressed in the report. The risk characterization also did not include an evaluation of the site's impact qn__the wetland area that is adjacent to the site. These criteria ne'ed to be evaluated in order to establish adequate remedial alternatives. The following recommendations apply to meeting the NCP criteria for public health, welfare, and environmental concerns: • Undertake a wetlands study to determine the site's impact on this sensitive area. • Obtain additional sets of water level data to confirm P^Vx groundwater flow direction. • Sample domestic wells to support theoretical modeling study. The Grove City municipal well should also be sampled. • Conduct a quantitative risk assessment. Include dermal exposure of surface waters and soils, inhalation of , • participates, ingestion of soils by children, and r> v—y ingestion and dermal contact of groundwater. ° 2. Likely Pathways of Exposure at Site Sections V and VI of the RI Report discuss various contaminant and exposure pathways that are associated with the site. As mentioned previously, direct contact with onsite soils need to be assessed, based on the potential accessibility to the site by children. Additionally, ingestion and inhalation of soils should be evaluated and assessed. ^ *-»» Based on a limited amount of collected data, four groundwater pathways were identified and assessed by the RP. These pathways may need to be re-evaluated, based on our review of the RI report and appendices. This is discussed further in Section 5.0 of this report. 3. Contribution of Contaminants Sections III, IV, and V of the RI report characterize the surface and subsurface wastes, surface water quality, and groundwater quality, respectively. A discussion on the impact of the site contaminants, if any, on air quality was not provided. Justification for not undertaking an analytical Jt%, evaluation of the ambient air is necessary. Also, an evaluation . or discussion regarding the contribution of site contamination *—' to the food chain,is warranted. This is especiallyjtrue for the

-12- 303S92 s swamp and wetland, areas that are adjacent to the western and southern portions of the site. 4. likelihood of Future Releases ' » Based on the RI report, all surface drums and 45-cubic yards of contaminated soils were removed from the site as part of an Initial Remedial Measure (IRM). Based on the magnetometry survey, buried ferromagnetic materials were present through the entire central area of the disposal area. However, no test pits . were excavated to confirm whether the buried metal objects were ' refuse er drums. in addition* only a limited numEer—61 test borings were drilled in the area that exhibited high ' magnetometer readings. Therefore* it cannot be concluded that ' «•> other drums (sources) do not exist throughout the former „ %s disposal area. ***"., B Although only 45-cubic yards of contaminated soils were **" excavated, the estimated volume of the disposal area was reported to be approximately 233*000 cubic yards. Since only^Ttff four test borings were drilled through .the former disposal area* f'T ' it_can__not~J?e.jstatedithat the "only .ma ior 'component of this areat^- is foundry sand. Additionally* the eoil~aaaplee obtained from "' these boreholes were not analyzed for any priority pollutants. Only field screening with an OVA was performed on the subsurface soil samples. Based on the limited amount of analytical data from the test boring program, there is a potential for additional releases to the groundwater from either existing buried drums or_highly contaminated, fiubsyr.face soils. , „,„ & In order to fully determine whether there is a potential for future contaminant releases to the environment* the following studies may be appropriate: • Excavate a series of test pits through the forme~ disposal area to confirm the assumption that magnetometer readings were due to refuse. • Obtain soil samples for full Hazardous Substance List (ESL) pollutants in order to characterize subsurface soils. These samples can be collected from the test pits and/or from additional test borings. B. Hazardous Substances Present 1. Source Identification and Characterization Section III of the RI Report characterizes the surface and subsurface wastes at the site. The surface wastes were identified as the 603 drums that were removed from the site and disposed in 1983. Additionally* 45-cubic yards of contaminated ^ soil were removed and disposed; however, th*> degree and nature*^*^ * of the contaminated soil was not provided in the report. Also,

-13- 303393 subsurface wastes were not characterized, as mentioned V_> previously in this report. . 2. Substance Types The contents of the onsite drums were adequately defined with respect to their physical and chemical types. 3. Substance Containment Section IIIB of the RI Report* Characterization of Surface Hastes* adequately discusses this NCP criterion. 4. Hazardous Properties of Chemical Substances Samples obtained from selected drums were analyzed for priority pollutant organics* RCRA metals, polychorinated biphenyls* pE* flammability* ignitability* BTU content, compatibility* and corrosivity. The following contaminant properties were not discussed in the report: Persistence Toxicity { Tr' Density ^ <*T« Solubility lf ' ' M* Volatility Reactivity \^/ . *- -i Thenp-parameterfl would—influence the migration of .contaminants ) through the_vajripus pathways. "Based "on" the fact that/, contaminated surface'soils were identified and removed, these? properties should be discussed for each contaminant in order to \ determine their potential to migrate into the air* subsurface/ soil, or groundwater. No analytical parameters were reported for onsite surface or subsurface soils. The hazardous properties of contaminants in these media were not discussed. "7 5. Quantities Present In order to evaluate potential reroediaV^alternatives, the quantities^ of various, wastes *in_each_media * needs to be addressed.*""The RP has estimated that the former disposal area is comprised of 233*000 cubic yards of soil. It was concluded in the report that the majority of this waste is foundry sand. 7 ./;>«/ This was based on four borings through the disposal area. It is V recommended that soils analyses through either test pits and/or ) additional soil borings be obtained to delineate for former disposal area. These activities would generate sufficient data • to quantify the amount of contaminated subsurface soils, if any, at the site.

-14- 303400 6. Concentration and Distribution Present ' ". -J The distribution of contaminants* including contaminant type . concentrations, were not cfaaxgcte*rized_for the soils, (surface and subsurface), sediments, surface " and—biota—(fish. or iMcroinvertehratefl). Additional studies should be undertaken to obtain sufficient data in order to quantitatively characte_rJL»«L public health and environmental T • adsorption J These properties need to be addressed in order to characterize health and/or environmental risks. It should be noted that adsorption applies mostly to the potential for contaminants to migrate through the soils; however* no analytical data for soils (surface or subsurface) were presented in the report. <&lsp, the CN risk assessment (Section VIJ does not include jan__evalu.ationTof '

C. v Hazardous Substance Migration Potential 1. Extent _of Current Migration The extent of migration in the surface soils* subsurface soils, sediments, air, and the wetland area has not been adequately defined. Surface and subsurface soil data should be obtained to identify the current migration of contaminants. Although groundwater data have been collected, they dq_npj__chaxa£££rl£e offjEite — migration. Groundwater data exists only for onsite locations. Additional monitoring points should be established for_ cfi tical of f s i t e "locations' "(•rrel — domestic — weTTs")7 "The*" _ coojcent rat ions at .. potential receptors is_ not adequate 'when "actual" :data_gft^be^obtained^yjlal8amplins. ' ' 2 . Extent of Potential Migration * ' ** "f The extent of potential migration of contaminants is undertaken in a risk assessment to characterize public health or environmental risks for a "no action* alternative. The RI Report (Section VI, Risk Assessment) addresses the potential for contaminants to migrate via surface water runoff, surface water transport, and various groundwater pathways. Migration of subsurface and surface soil contaminants into the groundwater should be addressed. To do this* analytical data for these media would have to be collected. Modeling of soil contaminant

-15- 303S01 concentrations into the groundwater pathway would then be appropriate to define the extent for potential migration of soil contaminants. Potential migration of contaminants to the air and biota were not addressed. A discussion regarding this possibility is warranted to meet the NCP criteria. D. Bydrogeologic Factors 1. Geologic Characterization The criterion for identifying the geologic characteristics of the study area are addressed in the RI Report; however* the REM III Team does not agree with many of the /findings . The following two issues /apply; 1) Shales generally have very low permeabilities when unfractured. Hgweygrf *•*•>*» pr«»«i«>ngV r»f frnrt"res can increase the DP nubility by nrrVr*; *f »«yjn<»ndA. As 6 some degree of fracturing can be expected in each of the rock units present beneath the site* the shale formations should not be considered as having no capacity to transmit water* although their permeability is low in comparison to typical sandstones. • 2) Additional site-specific geologic cross sections are needed to present an adequate picture beneath the study area. Hell locations and screened • intervals should be shown in the cross sections. The cross sections^ should be_integrated more closely with the^b1rln'g~rojgs_ to show 16caT~"variat'io'ns*"in stratigraphy* formafloh thicknesses* dips, etc. 2. Grcundvater Characterization Section V of the RI Report outlines the regional and site geologic and hydrogeologic conditions. This section does_not provide_ sufficient... information—til--meet _ the NCP criteria for. characterizing qreundwater_ baaed on the following~~~R£M~III~Team fin'dings : 1) Transmissivity is only presented for the Burgeon "Formation. 2) There does not appear to be an adequate resolution of groundwater flow direction in the Eomewood Formation, based on the data presented. It appears that there may be some component of groundwater flow te^ the north as well as the south. Also* there is a Ta'ck of groundwaTe'r monrt"orTng~"poirits""for this formation downgradient of the former disposal area (between monitoring wells UMW-3 and UMW-4 ) .

-16- 303(102 r~""^ 3) Groundwater flow direction in the Burgoon Formation is v not well defined, baaed on the data presented. As mentioned in the text and ehovn in Figure V-8, groundwater within the Burgoon Formation appears to be flowing northeast in the immediate site area (based on limited data). The text also indicates that the ultimate discharge point is several miles north of the site along Wolf Creek. This discharge point would be near Interstate 80 at an elevation of 1250 feet. The potentiometric surface of the Burgoon Formation at the site is 1249 feet* with a gradient of approximately 0.002. Based on this gradient, the potentiometric surface of the formation at the groundvater discharge point would be about 1220 feet* which is well below the level of Holf Creek. Therefore* the Burgoon Formation is not discharging to Holf Creek at this point* contrary to the text. 7 4) Flow rates have little^or..jo supportingr * ^ data. 3. Soil Characterization ^ • A limited amount of engineering properties data were obtained through Standard Penetration Tests. No information was obtained or provided for adsorption coefficient properties. This information is helpful in determining the migration potential '\_s for contaminants in subsurface soils. 4. Surface Water Characterization Section IV* Surface Hater, satisfies the NCP criteria for identifying drainage patterns, water quality, and uses. Data on the stream sizes, flow rates and stream classification are necessary to fully characterize the study area surface waters. C. Climate 1. Precipitation Average annual rainfall and evapotranspiration is provided in Section IV for the site. This NCP criterion has been satisfied. 2. Temperature No information regarding monthly average temperatures was provided in the report. 3. Hind Speed and Direction Data pertaining to average wind speed and direction were not included in the RI Report. These data are necessary to evaluate the potential health effects of remedial technologies of V_x alternatives such as excavation or air stripping.

-17- 3C3403 F. Compliance with Governmental Requirements ^^ ~~? 1. Federal Requirements ^" All fsflfijaj—requirements.—inrlnriJrig **n** for should be identified. Only EPA's Interim Drinking Hater Standards and Ambient Hater Quality Criteria have been identified for comparison of site contaminants. 2. State Requirements " State requirements for groundwater quality* surface water quality, amTvetland areas were not identified. 3. Existing and Potential Exceedanee of Applicable Requirements Groundwater and surface water contaminant levels were compared with EPA Interim Drinking Hater Standards and Ambient Hater ~ Quality Criteria. These data should also be compared with WlLf ' Maximum Contaminant Levels (MCLsi and Acceptable Daily Intake (ADD values where applicable. ~~~"~ 5.0 TECHNICAL REVIEW COMMENTS OK THE REMEDIAL INVESTIGATION

The following comments were generated by the REM III Team, which co'nsisted of a hydrogeologist* a toxicologist, an environmental engineer* and a biologist. Seetion-Pq. No. ___ Comments___ 11-12 Split-spoon sampling is not done^fln accordance with ASTM Standard D2113-70^ as noted in the text. ASTM Standard D-15B6 applies to split-spoon sampling. 11-13 . tow levels of contamination* which are less than 1 ppm, would not be detected with an OVA. Priority pollutant analysis should have been performed on a portion of the samples to confirm OVA results. It has been our experience that OVA results do not correlate well with laboratory analytical results. 11-20 Packer testing was performed at intermittent elevations in two borings* DMH-2 and -3. These tests were designed to measure in-situ permeability in "representative" zones of rock. For hydrogeologic purposes, it is equally important to measure_permeajjility at lithologic contacts where~Kbrizj>ntal bedding plain fracturinc _mi.ght_be_.'pr_§s.ent. The resultant permeaoiiities for the rock zones 303401 Seetion-Pg. No. Comments ___ , ______should not be used to represent horizontal flow in the bedrock aquifers. If used* caution should be noted. 11-20 The statement regarding little or no potential for vertical migration of contaminants to underlining aquifers should be changed to reflect higher potentials due f to the existence of fractures. (Contami- nants were detected in the shallow* middle* and deep aquifers). tr 11-24 The statement is made that a lack of drawdown in the Eomewood formation during he pumping test indicates that there is a lack of significant hydraulic connection between the Clarion and Eomewood Formations. According to the text, water levels were monitored in CMW-1 and the pond during the test* neither of which is set in the fiomewood Formation. If no significant drawdown was observed in the pumped formation (Clarion)* J>Q «*fl**flcart' draudmm would__b e — expected— _JLtcn — an — underlying H ' foimatinn— Has the Bomewood Formation '• monitored? / 11-24 and 25 Hhy did the pumping rate stabilize at 250 gallons permit (gpm) at 20 minutes? Has a 250 gpm pump used? 11-27 A statement is made that only 1 well was installed in the Upper Connoquenessing formation; however* on page V-13* a statement is made that no wells were installed or open to this formation. This needs to be clarified. 11-27 A statement is made that very little of the\ Upper and Lower Connoquenneseing groundwater I is used for water supply; however, l^r iM-Mitt, — Eifture V-2__ indicates jthat the Grove City/ " f/VT//^«v municipal water supply "is^fccreened in the\c-rt**- Lower Connoquennessing. This needs* to be] clarified. Additionally, Figure V-13 shows' that the Grove City municipal wells are screened in both the Upper and Lower Connoquennessing Formation and in the Burgoon Formation. The Upper and Lower Connoquenessing Formations are not adequately monitored to determine potential risks to the public. __ 303403 Section-Po. No. Comments______

11-34 The Burgoon -monitoring wells (DMW-1,2,3) have only one set of measurements. A mjpiiBqm ef thrge_ifi expected to provide a valid assessment of water levels. The Eomewood monitoring wells have inconsistent water levels on March IS* specifically wells UMW-3 and *4. Please clarify. Strip mine pond elevations should be taken to correlate with monitoring well water levels. 11-36 General terms such as "low toncentrations* yJ are used without justification. For . example, a *low^ .benzene level of 109ug/l corresponds to a risk of 372~xTO-«Tf ,' ingested over a long period of time. This 1 risk level exceeds EPA standards. HI-5 Haste samples were analyzed for PCBs and RCRA metals. These samples should have been analyzed for ESL. Also* the detection limit for PCB analysis 'was extremely high (10 mg/kg). HI-6 Types and depths of buried wastes at the * site could not be properly assessed since only jour borings penetrated this area, wHIch ~ia approximately 15 acres. - HI-10 S7/.y^ Concentrations of benzene* which were r,j tai, considered to be "low" by the RP, are above , RMCL standards. Additionally, chromium, ,--x' ""mercury, and lead were greater than IPDWS, ..,' u/Ati€ Dut considered to be "low" in the report. * . HI-10 ' Conclusions drawn by the RP have indicated that the analysis of waste present in the drums showed low concentrations of a limited . /number of priority pollutants. The RI •f J Report listed the concentration as \ "percentages". It should be noted that > J 3 percent of assorted hydrocarbons is equal h(< / to 30*000 ppm. With this in mind* ethyl I benzene was reported as "less than 100" percent. This is not a low concentration as stated in the text.

-20- 303403 Seetion-Pg. No. Comments ______

• IV-9 Seasonal flooding of the site may be a- mechanism for surface water (and contaminant) migration from the site. A "**'»•••"** flooding episode is described on page XX-27.0"***!* No mention of off site migration of T"" if/ floodwaters is included in the description. ** IV-11 Laboratory detection limits are not related to acceptable health risks. For many contaminants* the 10-6 risk may originate from levels much lower than these detection/ limits. In addition* there is no\ information regarding field and reagent blanks* duplicates, surrogate recoveries and other QA/QC information. The laboratory' OA/QC practices given in Appendix F are not f . completely applicable to the analyses J * performed at this site. IV-11 The fact that receptors might not be present at certain areas near the site does not reduce the need for assessments in these areas.. Both present and future potential i*« risks, using hypothetical receptors, are *r w(/^required to be assessed. V-4 It is aqui eludes or .zone s which do not allow A,.-Tr.,."-.. groundwater flow. Although shales generally have a much lower primary porosity than sandstones , secondary porosity _ ( fractures ) for . migration. As a result* shales' 'may be '• .„ considered aquitards but should not be considered aqui eludes. ~ V-ll As stated previously *./no drawdown would be expected in the Eomewood Formation or the ^» onsite ponds as a result of the pumping YU Af£ tests if the water level in the pumped W&' "*V£'/ formation (Clarion) was not itself drawn <-v •'•••if down by the pumping* as apparently the case A* *•'•**'••"' at the site. The statement that the pond And mine would have a poor hydraulic 411 »'r connection and that the underclay separating u,.. the Eomewood Formation from overlaying Cw^ aquifers acts as an impermeable layer are < not conclusions that can be drawn from thee Y(, pumping test results. 1-t,Jil'itl'1't '. * *' 'v—s Section-Pq. No. Comments ______^^

V-ll Downward flow * of groundwater is probably impeded by the coal underclay beneath the \ A • site; however* based on the presence of low ieveifi-. of contaminants in the underlying" aquifers, vertical groundwater migration is not prevented completely. V-12 Based on Figure V-6 and the water table contours, there does not appear to be enough monitoring wells along tht downgradient «dg* of the site to provide sufficient water quality data regarding shallow groundwater from leaving the site. Large data gaps exist between well location SH-2 and SH-3, ) and to the east of LW-4. < v'12 ~.M*i-&**\iivi\ Hater level in SH-1 was not included on the contour map. What explanation is there for the anomalous high level in SH-l (1300.6 feet). V-13 !**•.!,i* tAn/ .There does not appear to be adequate rtt resolution of groundwater flow direction in Eomewood Formation, based on the data presented. It appears that there may be some component of groundwater flow to the north as well as the south, based on the data. Also, there is a lack of groundwater monitoring points for the Eomewood Formation downgradient of the disposal area (between MWs UMW-3 and -4) as shown in Figure V-7. V-13 Groundwater flow directions in the Burgeon") ,.- Formation are not well defined, based on thep"' data presented. As mentioned in the text I i?^ and shown in Figure V-8, groundwater within (>ji- \J the Burgoon Formation appears to be flowing } to the northeast in the immediate site area/ (based on the limited data). V-13 The RI Report states that recharge raises water levels in the Eomewood Formation at well UMW-S as an explanation for the high water levels. There is no documentation to support this statement. Actually* the site data indicates that recharge is probably not a significant factor. The boring log for UMW-5 shows that the underclay is present and not eroded as suggested in the text. The reason for the higher water level in "^ UMW-5 needs to be explained. i-//^y i*--:«c/-.' -22- 3C3403 c >. Section-Po. Mo. Comments

V-19 With respect to the water table aquifer, five domestic wells have been identified in >f the report. Hell logs should be included in*-';'!; the report. V-19 Croundwater flow in the Clarion Aquifer is ••'*£ pfoBably governed by the deep mine system r" and is structurally controlled. Structure contour maps need to be prepared (deep mine <**«"•• maps are needed). If flow direction is S-i;-v ^ expected to be south, an explanation and . documentation is needed since only one well /''^ »'"•••- (CMW-1) was constructed in this formation. r.li'j (i.e., Bow can flow direction be determined f^t „*)• using one well?) Here deep cine /•„,_. discharge/seep points determined and c .***•*' sampled? J, fip<| L V-21 r/T/t /'Flow direction in the Bomewood pathway was "><*'*1 #' 'as*C ) etated to oe south. This is not defendable Ke^f ' * borings (3) cannot be confirmatory evidence ...,,_>*,*« of the absence of fractures in bedrock *~- £«, formations beneath the site. V-27 «wjVr6/ , The fact that some contaminants were not T'Vi^ *'. ( present above the EFA recommended detection ue< y-.»<, «^ recommended limit of 10**4. J sei-ru,v 0"

-23- 303400 Section-Pq. Ko. Comments

Appendix E With respect- to hydraulic gradients* how were the gradients calculated? 'The Burgoon value is incorrect. Gradient (i) is approximately! I foot • 0.002 (N-NE) 500 feet Hith respect to vertical migration* the permeability (3 x 10-9 ft/sec) for the underclay .is based on an NRC reference. This is not applicable to the site-specific conditions. Either field or laboratory permeability tests on the clay are acceptable.

-24- 303411 25 OYNAMACS CORPORATION

EXHIBIT 25 Corporate Headquarters: Dynamac Corporation The Dynamac Building 11140 Rockvllle Pike Rockville, MD 20852

AlamedaCA CamarilloCA DahlgrenVA Dayton OH Fort Lee NJ Lexington Park MD London UK Norfolk VA • Panama City FL Research Triangle Park NC . Rockville MD

303412 SECOND DRAFT

FEASIBILITY STUDY WORK PLAN

OSBORNE SITE

Prepared For: Cooper Industries

Prepared By: Environmental Risk Management Division Dynamac Corporation

Prepared On: June 11, 1987

303413 WORK PLAN

TABLE OF CONTENTS

SECTION PAGE 1.0 Introduction and Purpose . i

2.0 Historical Perspective 3 2.1 Investigation History 3 2.2 Cooper's Preliminary Findings 4 2.3 EPA/PADER Responses 6 2.4 Current Status 6

3.0 Summary of Existing Data 8 3.1 Environmental Setting 8 3.1.1 Location 8 3.1.2 Site Use 10 3.1.3 Physiography 11 3.1.4 Site Drainage 13 3.1.5 Geology 13 3.1.6 Hydrogeology 21 3.1.7 Adjacent Land Uses 23

3.2 Problem Assessment 26 3.2.1 Nature and Extent of 26 Contamination 3.2.2 Potential Exposure Pathways 29 3.2.3 Preliminary Assessment of 31 Public Health Concerns 3.2.4 Preliminary Assessment of 53 Environmental Concerns 3.2.5 Key Issues 53

30341J TABLE OF CONTENTS (continued)

SECTION PAGE 4.0 Proposed Outline Scope of Work 56 4 . 1 Introduction 56 4.2 Work Plan Objectives 57 4.3 Development of Data Quality 59 Objectives 4.4 Development of Detailed Sampling 62 Plan 4.5 Development of QA/QC Plan 62 4.6 Development of Health and 62 Safety Plan 4.7 Development of Public Health 68 Assessment 4.8 Completion of Feasibility Study 69 4.8.1 Introduction and Purpose 69 4.8.2 Development of Remedial 70 Response Objectives 4.8.3 Identification of ARARs and Other 72 Potential Cleanup Criteria 4.8.4 Selection of Preliminary 75 Technologies 4.8.5 Initial Screening of Remedial 77 Alternatives 4.6.6 Detailed Evaluation of 80 Remedial Alternatives 4.8.6.1 Detailed Technical 80 Evaluation 4.8.6.2 Detailed Institutional 82 Evaluation 4.8.6.3 Detailed Evaluation of 82 Public Health Requirements

30341: TA.PI-F OF CONTENTS (continued)

SECTION PAGE 4.8.6.4 Detailed Evaluation of 83 Environmental Impacts 4.8.6.5 Detailed Cost Analysis 83

4.8.7 Completion of Draft Feasibility 85 Study Report 4.8.8 Completion of Final Feasibility . 85 Study Report

5.0 Project Organization and Schedule 86 5.1 Proposed Staffing 86 5.2 Project Schedule 86

30541.6 1.0 INTRODUCTION AND PURPOSf

This document presents a draft work plan for a Feasibility Study at the Osborne Landfill site in Grove City, Pennsylvania. This -work plan has been prepared by Dynamac Corporation's Environmental Risk Management Division on behalf of Cooper Industries' Inc. in response to:

o "Draft Evaluation Report Review of Remedial Investigation Report11 dated March 13, 1987

o January 6, 1987 PADER/EPA comments, on the October 31, 1986 Osborne Feasibility Study and work plan

o Verbal comments received from PADER/EPA on March 19, 1987 and subsequent phone conversations with NUS and EPA on May 29, 1987 and June 3, 1987 respectively

The purpose of this document is to provide an organized description of the methodology to be applied to complete the Feasibility Study for the Osborne Landfill site in accordance with SARA and NCP requirements. Given the number of outstanding issues raised by EPA and FADER with respect to cite characterization, potential risks and the adequacy of the existing data base to complete the engineering aspects of the feasibility study, this document has also been designed to serve as the vehicle for proposing an outline^data collection program. This program is intended to significantly enhance the existing data base summarized for the most part in the

303417 June 1984 Remedial Investigation Report completed by Cooper Industries Inc. under a consent order with PADER.

Correspondingly, the rest of the document includes:

o a brief description of the site's history as a Superfund site

o a brief summary of the environmental • setting and the potential environmental and public health problems posed by the site and the key issues that must be resolved

o a proposed scope of work defining what efforts will be completed to implement a detailed sampling plan and feasibility etudy

o a proposed project organization and schedule

A variety of appendices aleo provide information on proposed approaches to be utilized to complete the forthcoming campling plans, QA/QC plans, health and safety plans and public health assessment, as well as a summary of selected technical clarifications to EPA/PADER's comments on the RI and the originally proposed FS work plan.

303413 2.0 HISTORICAL PERSPECTIVE

2.1 Investigation History

The Osborne Landfill site ie located in Pine Township in Mercer County, Pennsylvania. The cite consists of an abandoned coal strip mine which was subsequently used ae a disposal area from the 1950s until 1978 when the cite was closed by PADER. 'PADER subsequently brought the site to the attention of the USEPA by nominating the site for inclusion in the Superfund program. Following this action, the USEPA identified several potentially responsible parties, including General Electric Company, Ashland Chemical Company, Wolfe Iron and Metal Company and Cooper Energy Services (a subsidiary of Cooper Industries, Inc.) as potentially having disposed of waste materials at this location. Subsequently, with the exception of Cooper Industries, Inc., all of the above noted potentially responsible parties allegedly refused to voluntarily assist in supporting the remedial activities mandated at this site under CERCLA.

Cooper Industries, Inc., in coordination with the USEPA, negotiated a consent order and agreement with PADER to complete a remedial investigation (RI) at the site as well as an initial remedial measures program consisting of inventory and removal of potentially hazardous soils and drums located throughout the closed site. These efforts were initiated in the cummer of 1983.

-3- As noted, Cooper Industries was also required to complete an RI at the site as per a Remedial Investigation Hork Plan which was incorporated into the PADER/Cooper concent agreement. Major components of thie RI field investigation included:

o proton magnetometry survey o electrical resistivity survey o test borings and drilling o OVA field survey o geophysical borehole logging o downhole TV logging o aquifer testing o monitoring well installation o mine void investigation o coil, eurface water and groundwater campling o RI report preparation

2.2 Cooper's Preliminary Findings

Cooper's preliminary findings are summarized in Table 2-1 of thie document and in chapter VI, Rick Assessment of the 1984 RI report. The report 'e conclusion that "the risks to the public health and the environment are extremely low" was based largely upon:

o characterization of the waste materials ae being of generally low potential hazard due to their source (primarily foundry cands) and the relatively low

.4. 30341:9 TABLE 2-1 SUMMARY OF 1984 RI RISK FINDINGS

POTENTIAL EXPOSURE RISK CONCLUSION COMMENTS PATHWAY

Disposal Area Surface No risk Very low levels of Water Pathway contaminants in eurface water samples, no cur- face vater runoff Southwest Corner No rick No evidence of contami- Surface Water Pathway nation Water Table Ground- Minimal to no Relatively low levels water Pathway risk of metals and organice, lack of receptors Clarion Groundwater Minimal to no Low levels of con tain i- Pathway risk nante, lack of receptors Homewood Groundwater Minimal to no Relatively low levels Pathway risk of metals and organice, presence of background contaminants due to leaching of coal consti- tuents, closest potential receptor evaluated utilizing groundwater model Burgoon Groundwater Minimal to no Very low levels of Pathway rick contaminante, hydrogeologic separation from upper aquifers, lack of downgradient receptors

303421 concentrations of contaminants measured in leachates directly within the waste

o the low concentratione of organice and metals in the later sampling rounds from immediately beneath the cite in the various aquifer formations

o the lack of receptors for the various potential migration pathways

2.3 EPA/PADER Responses v p .•»»«•*• *"**

Ae noted in early 1987, EPA formally responded to the Osborne Landfill Site Remedial Investigation Report. These responses were » prepared considering the more recent requirements of the National Contingency Plan, the requirements of the newly reauthorized Superfund (SARA) , as well as more recent policy and implementation guidance originating within EPA. A brief summary of the comments provided by EPA is provided in Table 2-2. In brief, EPA has taken • the position that the exieting RI data base must be substantially enhanced if the data needs and data quality objectives mandated by SARA are to be met.

2.4 Current Status . %

From 1984 to early 1987, intermittent EPA/PADER/Cooper negotiations took place in an effort to finalize the RI. In addition, EPA undertook a test pit and soil campling program at the cite in 1985 to

-6- TABLE 2-2

SUMMARY OF EPA COMMENTS ON RT

ISSUE EPA COMMENT

Adequacy of Source Defini- Generally inadequate for current tion requirements due to lack of a more complete characterization of the physical and chemical character of the surface and subsurface waste materials Adequacy of Pathway Defini- Generally inadequate for current tion requirements due to limited on and off-cite data on geology and hydrogeology, lack of data on contaminants in surface coil and air pathways and limited data on contaminants in surface water runoff. pathway Adequacy of Receptor Defini- Generally inadequate for current tion requirements due to inadequate data base on potential off-eite groundwater transport and lack of consideration of future receptors Adequacy of Risk Conclu- Generally inadequate for current eions requirements given the above

-7- further clarify the source issue. That data was reported by NUS in a report dated September 11, 1986. However quality control problems allegedly significantly reduced the validity of the data set. Split camples results were provided to PADER by Cooper Induetries, Inc. •

Currently, EPA, PADER and Cooper Industries are negotiating the scope of the feasibility etudy for the site. These negotiations include the collection of whatever additional data ie necessary to characterize the cite, complete a more quantitative risk assessment and complete a feasibility etudy which will meet the requirements of SARA and the NCP.

3.0 SUMMARY OF EXISTING DATA

3.1 Environmental Setting

3.1.1 Location

As depicted in Figure 3-1 taken from the RI report, the Osborne eite ic located about one half mile east of Grove City, in Pine Township, Mercer County, Pennsylvania. The eite ie eituated north of Pine Street Extension in an abandoned coal strip mine approximately 15 acres in cize.

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SCALE'l"tZ4,OOOFT FIGURE 3-1 SITE LOCATION MAP OSBORNE SITE DYKAMACOORP. 303423 The boundaries of the cite are demarcated by relatively prominent topographic features such ae piles of mine spoils at the western boundary and a highwall at the eastern boundary of the eite. Beyond the mine spoils, to the couth and west, extend low lying brush and wetlande. A email stream and the Pine Street extension form the southern boundary of the cite. Currently, a chain link fence, installed ae part of the Initial Remedial Measures undertaken at the site by Cooper, demarcates the boundaries of the area where pact alleged disposal of various wastes has occurred.

3.1.2 Site Use

Usage of the Oeborne eite began in the 1900'e when the eite was operated as a coal cine. Deep mining of the Brookville coal under the present highwall was followed by strip mining of the coal expoeed at the bedrock interface near the 1,300 elevation datum. Strip mining continued up to the present location of the highwall demarcating the eastern boundary of the eite.

From the 1950*6 until 1963, Mr. Samuel Mooney operated the eite as a disposal area. Disposal activities continued under the ownership of, Mr. James Oeborne from 1963 until 1978 when the eite was closed by PADER. Currently, the eite ie in the ownership of Mr. Ed McDougell who also owns the cornfield located to the east on top of the highwall.

~10~ 303426 During the 1960'e and 1970'e, materiale disposed at the Osborne eite , , allegedly included industrial wastes, with lesser amounts of municipal refuse. Although quantities of slag, scrap metal, wood, paper, and plaetic matter are found scattered around the entire eite, the existing data suggests that the primary material disposed was foundry sand. All disposal activities were conducted within the 15 acre topographic valley created by the past coal etrip mining operations.

3.1.3 Physiography

Figure 3-2, taken from the RI report, shows the'current surface featuree at the eite including the pond locations, the extent of the piles of mine spoils at the boundaries of the eite and the enclosed disposal area. Determination of the areal extent of the spoils piles and the disposal area boundaries was apparently based on aerial photo interpretations and field observations completed during the remedial inveetigation.

In the early 1900's, when the cite operated as a coal etrip mine, a 1,500 foot long surface pit wae excavated in a southeast to northwest direction beginning near Pine Street. Early topographic maps demonstrate the existence of an elongated pond in the pit between the north and south walls of trie stripped area. Ae a result of subsequent filling activities, which apparently commenced in the southeast eection near Pine Street, only the northweeternmoet third of thie ponded area remains. Presently, two smaller ponds are located southeast of the original pond along the base of the highwall

303427 STR£X

N-l N-_ N-S 1 3 1 HE. AlttUC. 1 FIGURE 3-2 SURFACE FEATURE \ LOCATION MAP GRID SPACING • 100 FT. OSBORNE SITE DYNAMAC CORP. 303428 to the northeast. A small intermittent stream enters thenroost northerly pond from the north. There is no apparent surface drainage out of this area, however, a wetland area and an intermittent small stream are located immediately south of the mine spoils pile.

3.1.4 Site Drainage

As part of the 1984 Remedial Investigation undertaken by Cooper at the Osborne site, topographic maps were developed establishing the current site drainage patterns and addressing the potential for off-site migration of contaminants via surface water runoff. Figure 3-3, which was also taken from the RI report, indicates that with the exception of a small area on the southern boundary of the site, the current topography prevents roost surface runoff generated on the site, or flowing onto the site, from leaving the site. Instead, surface runoff drains into the ponds which primarily discharge via groundwater recharge. An exception to the above general drainage pattern is a small area to the south of the entrance gate where surface water drains into the intermittent stream forming the southern boundary of the site.

3.1.5 Geology •

The Osborne site is located on the glaciated Allegheny plateau. Bedrock geology in the Grove City area consiste of nearly flat lying sedimentary rocks of late Paleozoic age. The eite eite on the

303429 12+00

S-4 $-5 S-2 SH A M-l N-2 N-3 N-4 N-5 FIGURE 3-3 DRAINAGE MAP GRID SPACING* 100 FT. OSBORNE SITE DYNAMAC CORP. 303420 western flank of the Pitteburgh-Huntington Basin. Generally, bedrock formations exhibit a southward regional dip of about 14 feet per mile. Major fractures occur along bedding planes. Although the area is not located within a tectonically active zone which could -have caused faulting, some joints may occur in the area. Figure 3-4, modified from the RI report, shows a generalized stratigraphic column for the Grove City area. Table 3-1 lists the geology and hydrogeology of the lithologic units in the area. Figure 3-5, also from the RI report, represents a geologic cross section of the Osborne site.

In brief, deposition of sediments in the Mississippian and Pennsylvanian periods of the late Palezoic era was cyclic, and gradational sequences of rock types found in this area are continually repeated in the stratigraphic record. As a result, lithologies vary with depth, and various formations may contain coal, V__/ limestone, sandstone, shale, clay, or any combination of these. Although the formations themselves may be regionally extensive, locally, formations may interfinger with other beds or may disappear completely.

Historically, glacial erosion has resulted in an undulating bedrock surface. The subsequent deposition of glacial material in the bedrock valleys left bedrock highs or "hydrologic islands" of bedrock (Poth, 1963). These "islands" control regional groundwater and, to some extent, surface water flow throughout the area. The Osborne site is located at the edge of such a "hydrologic island" as illustrated on Figure 3-6. Of note, as the glaciers eroded bedrock to form the "hydrologic islands", coal was exposed at the

-15- 303431 HYOROQEOLOQIC f SIGNIFICANCE

KENT SANDY. 8ILTY TILL - SHALLOW (86 FT.) • I • jr* <£« *'N WATER TABLE AQUIFER (VARIABLE)

CLARION ' '•'•'•'•' '• •' ''/.I 8ANDY 8HALE' 0«ANHEL. ^^ ^**••• •> • ^ •* iiiniiiiiiiiiiroiiiii!iiiiiiiiKiiiiiiiiiiiiiiiiiinnTHHfTtiRifnfnmiimtttttmH«fHmMftMmNt«MMl nfi A fc|f%ftT_*%MC BD^S^SbT%/lt f C ————— potentlalVquIclud*

MEDIUM TO COARSE GRAINED HOMEWOOD SANDSTONE, 8HALY NEAR TOP- (66FT.) LOCAL AQUIFER

MERCERC10-16FT.) SHALE -potential aqulclude UPPERMEMBER: SANDSTONE • AQUIFER Ul CONNOQUENESSING MIDDLE MEMBER: SHALE* («OFT.) potential aqulclude LOWER MEMBER: SANDSTONE- AQUIFER SHALE - potential aqultard

BURQOON* (ttOFT.) SANDSTONE * MUNICIPAL WELL AQUIFER

HEMPFIELD f SHALE - potential aqulclude

FIGURE 3-4 GENERALIZED STRATIGRAPHIC COLUMN OSBORNE SITE DYNAMAC CORP. 30343ft S, if • = S « I _« I -5 - » s t,*5fll!<»«&* «=£ *f. •if? E« * ***» fliital i *' T, «-r i i £i_t

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^? K * * * " fS5 S S = S ' sr ISis II .2I 5T 2T -2 w £5 ; ^ £ £ : s » I 11 1 i 2 M

303433 303/134 /•*\ HYDROLOOJC ISLAND MARGIN

AFTER HART, 1983

FIGURE 3-6 0 £ 1 & HYDROLOGIC ISLAND MARGINS SCALE IN MILES OSBORNE SITE DYNAMAC CORP. 303435 glacier-bedrock interface near the 1,300 foot elevation datum. Subsequently, to permit removal of the coal, overburden was typically ^-^ removed, or "stripped". At the Osborne location, the strip mine was operated until it reached the previously mined area where coal had already been removed by deep mining operations on the northeast side (high wall) of the site.

Underlying the glacial deposits is the Clarion formation, consisting of shale, sandstone, and coal. Due to mining activities, the Clarion formation is present near the Osborne site only under the cornfield to the east of the highwall. Beneath the Brookville coal seam, lies a basal underclay commonly called "fire clay". The clay layer was found in every boring installed during the RI and appears to be continuous under the site. Underlying this underclay is a cyclic repetition of lithologic units consisting of sandstones and shales. i Based on regional and site specific data, the sandstone units typically act as aquifers, while the shale units may act to retard or prevent groundwater flow depending upon the degree of fracturing in these units. The Komewood formation is the uppermost bedrock aquifer beneath the underclay layer.

Progressively deeper, the upper and lower Connoquenessing sandstone aquifers are capped by the Mercer shale formation and the middle shale member of the Connoque.nessing formation. Limited on-site information suggests that these layers may act as confining layers in isolating the deeper aquifers from the near surface aquifers in the vicinity of the site.

-20- 303/136 Underlying the Connoquenessing formation is the Burgoon formation. The Burgoon formation is composed of two units, a shale unit and a sandstone unit. The shale unit is approximately 10 feet thick and overlays the sandstone unit. The lower sandstone unit is relatively permeable.

3.1.6 Hydroereoloay

Most of the site appears to be in a groundwater recharge area, receiving infiltration from rainfall and surface water inflow. Under these conditions, groundwater would be expected to migrate vertically downward depending upon the extent to which the underclay and shale zones overlying the Komewood formation minimize vertical flow. Since the hydrogeologic data and aquifer tests performed on these shale zones, as part of the RI, indicated that these units may be relatively impermeable, groundwater at this site is likely diverted horizontally to discharge at the sides of the "hydrologic island".

Figure 3-7, from the RI report, provides a map of the water table at the Osborne site. This figure suggests that groundwater under water table conditions flows to the southeast. Based on information gathered during the Osborne site void investigation report (Hart 1983), there is also reason to believe that the site is also in • limited hydraulic connection with the groundwater in the mine void zone near well CKW-l.

-21- 303437 X

(129046

FIGURE 3-7

(6CALE IN FT.) WATER TABLE AT MEASUREMENTS TAKEN DECEMBER OSBORNE SITE THROUGH 6, 1669 As taken from the RI report, Figure 3-8 shows the potentiometric surface in the Homewood formation. Based on the existing information, groundwater flow in this formation appears to be to the south. As noted, the location of the disposal site and strip mine is at the margin of the "hydrologic island". Therefore the coal seam and underclay apparently have been eroded away to the west, south and east beyond the site. Correspondingly, the Homewood appears to be in hydraulic connection with surface waters, predominantly in a downgradient direction from the site. Under these conditions, groundwater may discharge to surface waters. Under certain conditions, however, surface water may also recharge the water levels in underlying bedrock formations. This condition may be found in the Homewood formation in the area of well UMW-5.

As revised from the RI report on October 8, 1984 (See Responses to DER/EPA Comments on RI Report, October, 1964), Figure 3-9 shows the potentiometric surface map in the Burgoon aquifer. Groundwater in this aquifer is flowing to the east. Given the "hydrologic island" concept, the discharge area for the Burgoon aquifer may be located well beyond the area of the site, and the recharge area may be potentially several miles up Wolk Creek to the north and west of the site and Grove City.

3.1.7 Adjacent Land Uses

The land immediately surrounding the landfill is agricultural in nature. Effects of the past mining operations are evident near the

-23- 303459 «'**••%• lino.*?11278.1')

1277' e too toe

I i FIGURE 3^8 (9CALI IN FT.) POTENTIOMETRIC SURFACE IN 'CONTOUH LINfl AIOVI UtT AM NOT SHOWN THE HOMEWOOO FORMATION OU9 TO 19* OlFF.ftlNCI IN HfAO OSBORNE SITE DYNAMAC CORP. 303440 /r

1248.8' «etn-t (1146.43*)

REVISED ocToeep axita* FIGURE 8-9 POTENTIOMETRIC SURFACE IN THE BURGOON FORMATION (SCALZ IN FT.) OSBORNE SITE DYNAMAC CORP. 30344! site. Adjacent to the top of the highwall on the north is a large cornfield owned and farmed by Mr. Ed McDougal, present owner of the Osborne site. The area to the east is mostly wooded. New homes have recently been built to the north, along Enterprise Road, several older rural homes also exist to the east. South and east of the landfill are low-lying brush and wetlands on both sides of Pine street. N

3.2 Problem Assessment i ! While the existing data for the site appears to demonstrate that the site poses a relatively low risk to human health and the environment, it is also clear that given the nature of the disposal activities and the complexity of the geology in particular, the existing database is limited and may not be sufficient to satisfy the current SARA / requirements.:J) In that context, the following sections provide an overview of the potential problems posed by the site and the key issues that must be resolved in the additional data collection program and the forthcoming feasibility study.

3.2.1 Kature and Extent of Contamination

Table 3-2 provides an overview of the types of contaminants found in • the RI investigation and the subsequent NUS soil study. While the bulk of this data is presented directly in the RI, the following conclusions can be drawn:

-26- 303442 TABLE 3-2 OVERVIEW OF CONTAMINANTS IDENTIFIED BY MEDIA

MEDIA COMMENTS

Air No quantitative data is available although qualitative air quality data collected utilizing a portable GC during the field investigation and interim 'remedial measures program suggests that large quantities of non-methane organics are not being released into the air column Surface Wastes Approximately 600 drums were stored and removed from the site during the 1983 interim remedial measures program. Drummed materials included various waste types including organic liquids with/without high halogen contents, inorganic liquids, sludges and solids. In summary, chemical analyses of selected drums indicated low concentrations of RCRA metals and PCBs with high BTU values and generally low pHs. A total of ten priority pollutants (2 organics/ 8 inorganics) were identified in six composite samples from the drums Surface Soils Only a limited amount of data on surface soils was collected during the interim remedial measures program. This data generally indicated slightly acidic conditions and low levels of RCRA metals. Additional surface samples were collected from test pits by EPA/NUS in September of 1985. A total of 53 chemicals (32 organics, 12 metals) on the Hazardous Substance List (HSL) were identified in the NUS samples. A total of 52 chemicals (37 organics, 15 metals) . on the HSL list were identified in the duplicate samples provided to Cooper Industries. Of note, significant QA/QC problems were allegedly experienced with the NUS data. In addition, it is not clear that this data is representative of surface conditions since the sampling effort allegedly concentrated on those locations at which releases from drummed materials had apparently occurred.

-27- 303443 MEDIA COMMENTS

Surface Waters Surface water data as presented in the RI report included analytical results from PADER sampling efforts in 1977 and 1980, EPA sampling efforts in 1981 and 1982 and Cooper sampling results from 1983. This data indicated generally low to elevated levels of metals and low levels of organics Subsurface Wastes The RI resulted in the collection of relatively little direct analytical data on contaminants in subsurface wastes. Limited data available from historical records and from the on-site test borings completed during the RI appears to indicate that the bulk of the on-site wastes consists of foundry sands. The most relevant data from the RI on the nature of the subsurface waste materials consists of the analytical data from the monitoring wells installed directly in the waste materials. Data from these "leachate" wells identified a limited number of primary pollutants at generally low concentrations including the following chemical species: benzene, 1,1,1-TCA, vinyl chloride, TCE, total xylene, nickel, chromium, lead, mercury, beryllium, thallium, iron, manganese and arsenic. Additional subsurface soil data was collected as a result of the EPA/NUS sampling efforts. This effort consisted of excavating and sampling subsurface soils at seventeen on-site locations. Subsequent chemical analyses resulted in the identification of 58 chemicals (38 organics, 20 metals) on the Hazar- dous Substance List (HSL) from the various locations and depths sampled. Analysis of the duplicates provided to Cooper Industries resulted in the identification of 52 chemicals (40 organics, 12 metals) on the HSL list. Again, it is not clear whether this data . is representative of subsurface conditions since the sampling effort focused only on three locations where buried drums or other wastes were located. Groundwater Groundwater at the site was sampled in December of 1983 and January and April of 1984. In general, low levels of cadmium, chromium, lead, nickel, zinc, benzene, Bis(2-ethylhyxyl)Pthalate, ethylbenzene, toluene, TCE, pentachlorophenol, etc. were detected at the site in various formations at different times. 3034H- o overall the surface materials collected and disposed in the interim remedial measures program typically would not be considered highly hazardous

o the limited information on surface water and soils suggests that surface materials/ have not been significantly contaminated with materials other than those expected to be associated with the apparent source of most of the waste materials (i.e. heavy metals resulting from foundry operations)

o while little information on subsurface materials is available, the generally better than expected quality of the leachate and the largely uncontaminated nature of the deeper aquifers suggests that either (1) significant quantities of contaminant are not present in the fill, (2) that these contaminants were present but have already been flushed out of the waste materials, or (3) that contaminants are present but have not yet been released (i.e. buried drums)

3.2.2 Potential Exposure Pathways

Table 3-3 provides a summary of the potential exposure pathways associated with the Osborne Landfill site. In general, while several pathways may be hypothetically available, existing site conditions and/or the lack of receptors appears to limit to some extent the existing potential for exposure to contaminants affiliated with the site.

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