UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch Street Philadelphia, 19103-2029

SUBJECT: Request fo r Approval and Funding for a Removal Action at the Westline Site, Westline, Lafayette Township, McKean County, Pennsylvania

FROM: Vincent E. Zenone, On-Scene Coordinatf -'.

TO: Bonnie Gross, Director Office of Preparedness & Response (3 HSOO)

I. PURPOSE

The purpose of this Action Memorandum is to request and document approval of the selected, time-critical Removal Action described herein for a portion of the Westline Site ("Site'"), Westline, Lafayette Township, McKean County, Pennsylvania. The objective of this removal action is to mitigate the public health and environmental threats associated with direct contact to hazardous substances present in surface and subsurface soil at the Site.

The On-Scene Coordinator ("OSC") has determined that the Site meets the criteria in Section 300.415 of the National Oil and Hazardous Substances Contingency Plan ("NCP") for initiating a Removal Action. Funding in the amount of $600,000, of which $500,000 comes from the Regional Removal Allowance, is necessary to address the threats identified in this Action Memorandum.

II. SITE DESCRIPTION AND BACKGROUND

A. Site Description.

1. Removal Site Evaluation

The Westline Site (EPA ID# PAD980692537) encompasses approximately forty (40) acres along Westline Road, in the Village of Westline, McKean County, Pennsylvania (see Figure OI). The Village of Westline is comprised of a mixture of seasonal residences and year-round homes. Kinzua Creek flows along the southeastern border of the portion of the Site.

AR300001 During the first half of the 1900s, the Day Chemical Company, a lumber processing plant operated on the site. Its chemical plant converted lumber into charcoal, methanol, and acetic acid. The Day Chemical Company deposited wood tar material containing phenolic compounds and polycyclic aromatic hydrocarbons ("PAHs") into on-site lagoons and into small canals that allowed the material to migrate downhill towards the banks of Kinzua Creek.

In 1952, a fire and explosion caused the faci lity to close. The owners left the plant's foundation, demolition debris, and a tar-like production waste containing high levels of PAHs. This waste material was disposed of, or flowed into, natural or excavated depressions located hundreds of feet away within the town. The Site encompassed most of the village of Westline and its adjacent streams, including Kinzua Creek and Turnip Run.

Jn July 1982, the Site was discovered during a routine inspection of oil operations in the Allegheny National Forest. Analysis of the wood tar showed that phenol and 2, 4- dimethylphenol were present at approximately 1,000 mg/k each. Both of these compounds, li sted as CERCLA hazardous substances, present in the wood tar deposits, posed a threat to people who come in direct contact with, inhale, or ingest wood tar or wood tar contaminated materials. The dominant and most widely distributed contaminants detected in the soi ls were PAI-ls. The dispersed waste tar deposits were up to nine feet thick. In addition, the town is located in a I 00-year flood plain, therefore, areas containing wood tar could be subject to erosion if a flood occurs, possibly causing contaminants to enter Kinzua Creek, a tributary to the .

In 1983, two (2) removal actions were initiated at the "main lagoon" on the Westline Site. During the first removal action, a cap was installed over the "main lagoon" near the Westline Inn. The cap was seeded to minimize erosion, and the removal action was completed on April 22, 1983. However, by August 1983, wood tar seeps were visible through the cap in several spots. Consequently, the OSC requested and received an extension beyond the 6-month limit, and a second removal action removed two thousand (2,000) tons of tar and contaminated soil from the '·main lagoon'· on the Westline Site. The cap was reestablished, and seeded to minimize erosion, and the removal action was completed on September 14, 1983.

On September 8, 1983, the Westline Site was added to the National Priorities List of the nation's most hazardous waste sites. Through a 1986 Record of Decision ("ROD"), EPA conducted a remedial action and addressed the remediation of wood tar and contaminated soil found in an on-site wood tar pit and in some of the interspersed wood tar deposits along Kinzua Creek.

In the early 1990s, EPA determined that the residual contaminated soil and wood tar material remaining on-site presented no potential carcinogenic ri sk based on an updated ri sk assessment using more recent risk criteria for PAHs. The selected remedial action for the I 990 ROD amendment was "no further action". Because some wood tar material remained on-site, EPA planned to monitor the site to prevent unacceptable exposure from the wood tar from recurring and a five-year review would be scheduled. The Site was removed from the NPL in 1992.

Conditions at the former Westline Superfund Site appear to have changed s ince the Site was removed from the NPL. Wood tar seeps on the surface have been observed in an on-

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AR300002 site area previously designated as "Area B" in the Feasibility Study prepared for the EPA's Remedial Program in 1986 (see Figure 02). Wood tar has also been exposed along the right-descending shoreline of and into Kinzua Creek. These changing conditions pose a threat to public health or the environment.

In the Fall of 2013, the owner of a seasonal residence located in "Area B" of the Westline Site (see figure 03) hired a contractor to install a new driveway to their seasonal residence. The contractor informed the landowner that deposits of a tar substance were observed in the area where the driveway was install ed. In the Spring of 2014, the owner visited the seasonal residence and observed wood tar seeping to the surface from areas on both sides of the new driveway. On July 15, 2014, after researching the history of the Westline Site, the owner contacted the OSC and requested assistance.

The OSC contacted the Commonwealth of Pennsylvania Department of Environmental Protection ("PADEP") Emergency Response Program ("ERP"), who defen-ed to PADEP Environmental Cleanup and Brownfields Program ("ECBP") and/or PADEP Hazardous Site Cleanup Act Program ("HSCA"), to determine if PADEP could take lead agency responsi bilities or otherwise participate in a removal action.

On October 2, 2014, EPA contractors collected samples of the on-site wood tar seeps from areas on both sides of the driveway and from the wood tar along the right­ descending shoreline of Kinzua Creek (see Figure 03). Sample analyses indicated the following:

Benzene Eth Iben zene

and the following semi-volatile organic compounds (SVOCs):

The OSC has continued coordinating and exchanging information with the McKean County Conservation District ("MCCD"), PADEP-ECBP, PADEP-HSCA, PADEP Waterways and Wetlands Program ("W&W"), Pennsylvania Fish & Boat Commission ("PAFBC"), Pennsylvania Department of Transportation ("P ADOT"), EPA Regional Biological Technical Assistance Group ("BTAG"), U.S. Fish & Wildlife Service (USFWS), landowners and local utilities (National Fuel Gas, Howard Drill ing Inc.). Taking into consideration the infonnation from the aforementioned entities, the OSC has concluded that the removal plan of action will be two concurrent phases of operation: actions to remove the wood tar from along the right-descending shoreline of Kinzua Creek, stabilize the shorelines, and mitigate future releases of wood tar into Kinzua Creek, and actions to remove and/or mitigate the surface seeps of wood tar on both sides of the driveway.

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AR300003 The USFWS member of BTAG has conducted a streamlined ecological risk assessment at the Site. They determined that Kinzua Creek is major tributary to the . The creek is classified as a cold water fishery supporting three trout species, sculpins, and other fish species. It is a wild trout stream that acts as a brook trout breeding and nursery area.

Total PAHs at 286.5 mg/kg, from analysis of the sample collected from wood tar seeping off-site along the right-descending shoreline of Kinzua Creek, exceed BTAG screening criteria for sediments by two orders of magnitude.

PAH Concentration Concentration

Anthracene Benzo(a )anthracene Chr sene Fluoranthene Fluorene Na thalene Phenanthrene P rcne total

Therefore, the hazardous substances releasing from the portion of the Site addressed by thi s Action Memo pose a threat to the health of the Kinzua Creek/Allegheny Ri ver ecosystem and its associated aquatic community.

At the request of the OSC, the USFWS planned for the stabilization of the Kinzua Creek shorelines. Their plan (see Figure 04) entails a significant channel realignment, moving the channel of the creek left of the bridge, and creating a significant bank fu ll bench/floodplain in front of the contaminated right river bank downstream of the brid ge. The river will be shifted to a relic al ignment upstream of the bridge, with a much larger radius bend coming into the bridge which will greatly reduce the shear stress along the river right bank. This plan also protects the river right abutment of the bridge, by building a bankfull bench around and in front of the bridge. The benches will be protected by the installation of rock vanes spaced along the bank full benches to move the high velocity flow out away from the benches to the center of the stream.

PADOT is currently in the planning stages to replace the Westline Road Bridge sometime within the next three (3) years. This plan also facilitates PADOT's plan.

In addition, the OSC has considered the best option to remove and/or mitigate the surface seeps of wood tar on both sides of the driveway. The OSC has consulted with and PADEP-W&W has identified applicable or relevant and appropriate requirements 4

AR300004 ("ARARs") associated with on-site wetland areas, described as Exceptional Value ("EV") wetlands, which may be impacted during the removal action.

During the course of the removal assessment, the OSC discussed the plans with the USFWS, PADEP, the McKean County Conservation District ("MCCD") and the landowner. PADEP identified the portion of the EV wetland that had been impacted during the landowner's construction of the new driveway. The driveway will likely be used as a construction entrance and/or staging area during the removal action, and will remain in place as part of the capping action to mitigate the release of wood tar.

The OSC will coordinate restoration of the areas on either side of the driveway with the USFWS and the areas will be stabilized with wetland type vegetation to meet the ARARs to the extent practicable. The USFWS member of the BTAG has already identified the wetland species within the areas of the proposed removal plan, and has provided expert consultation regarding the soil types required for backfill, plant species and seed mix to facilitate restoration of the wetland areas impacted by the selected removal plan (see Figure 05, pages I to 4).

The OSC intends to continue to utilize USFWS technical expertise for the duration of the removal action to ensure that the intent of ARARs are attained.

2. Physical Location/ Site Characteristics

The removal action is for a portion of the Site that is located in an area previously noted as "Area B" in the Feasibility Study prepared for the EPA 's Remedial Program in 1986; specifically on Lot A (Deed Book 538, Page 445) and Lot 2 (Deed Book 544, Page 617), collecti vely known as the "Wilson Camp" in the Village of Westline, Lafayette Township, McKean County, Pennsylvania (see Figure 3). The area surrounding the Site is rural, comprised of a mixture of seasonal residences and year-round homes. The Site includes part of Kinzua Creek, which is a tributary to the A llegheny River. Topographically, the Site is located at 41.7742780° N latitude and -78.7719440° W longitude.

In Area B, the wood tar was observed seeping from the surface in several locations, and also at depths of I, 2, and 3 feet; and an estimated 1,080 tons of wood tar remained on­ site in Area B when the Westline Site was delisted in 1992. The area of surface contamination being addressed by this removal action is an estimated 1,200 square feet.

The EPA is not aware of any threatened or endangered species or any historical landmarks or historically important buildings on the Site (see Figure 6).

3. Release or threatened release into the environment of a hazardous substance, or pollutant, or contaminant.

Wood tar waste containing elevated levels of CERCLA hazardous substances has been identified on the Site. The CERCLA hazardous substances, present in the wood tar deposits, pose a threat to people who come in direct contact with, inhale, or ingest \,vood

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AR300005 tar or wood tar contaminated materials. The current stream alignment at the reach of Kinzua Creek in the vicinity of the Westline Road bridge has exacerbated the exposure of the wood tar that is sequestered in the subsurface strata of Area B. The wood tar has become exposed along the stream bank just downstream of the bridge on the right­ descending shoreline. During warm months, the exposed tar liquefies and flows down the bank into this exceptional trout fishing stream. The hazardous substances that are released are readily absorbed by humans and wildlife. In addition, during wam1 weather months, the wood tar liquefies and rises to the surface and migrates from the banks and into Kinzua Creek.

4. National Priorities List (NPL) Status

At the present time, the Site is not on the NPL, and it is not contemplated that the Site will be included on the NPL. The Site was removed from the NPL in 1992.

5. Maps, pictures, and other graphic representation

See Figures 0 1 through 07.

B. Other Actions to Date

1. Previous actions

As discussed previously in Section II. A.I.

2. Current actions

As discussed in Section II.A. I, the EPA conducted removal site investigation activities in each of the years from 2014 through 2016. These investigations concluded that both VOCs (most notably Benzene and Ethylbenzene) and SVOCs (most notably 2, 4 - Dimethylphenol, 2 - Methylnaphthalene, 4 - Methyphenol (p-Cresol) and Naphthalene) are present in wood tar buried beneath the surface in Area B, and present in the release of wood tar seeping to the surface (right descending shoreline of Kinzua Creek and either side of the driveway). The goal of this removal action is to mitigate the effects of the current release of wood tar affecting approximately 1,200 square feet of surface of Area B, and to prevent the future release of wood tar from the subsurface of Area B.

C. State and Local Authorities' Roles

1. State and local actions, to date.

State and local agencies have participated in the removal assessment, identifying ARAR.s and providing logistical support. There are no removal actions currently being undertaken or planned by either State or local agencies.

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AR300006 2. Potential for continued State, local response

Neither the Commonwealth of Pennsylvania nor the local government has the resources available to conduct a removal action at the Si te. However, it is anticipated that these organizations will act in a supporting role throughout the removal action and •.vi ii participate in post removal site control(s) as may be applicable.

III. THREAT TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

The contaminants identified at the portion of the Site addressed by this Action Memo are hazardous substances as defined by Section 10 I (14) of CERCLA and are listed in 40 CFR, Table 302.4. Analytical data from samples collected at the Site indicate that hazardous s ubstances, VOCs and SVOCs, are present in the surface and subsurface soil at elevated concentrations that may present a tnreat to the publi c health and the environment.

The USFWS member of BTAG has conducted a streamlined ecological risk assessment at the Site. They determined that Kinzua Creek is major tributary to the Allegheny Ri ver. The creek is classified as a cold water fi shery supporting three trout species, sculpins, and other fi sh species. It is a wild trout stream that acts as a brook trout breeding and nursery area. Total PAI-Is at 286.5 mg/kg, fro m analysis of the sample collected from wood tar seeping off-site along the right-descending shoreline of Ki nzua Creek, exceed BTAG screeni ng criteria fo r sediments by two orders of magnitude.

Research has shown that tumors developed in laboratory animals when they were exposed, through either inhalation or ingestion, to one of several VOCs and/or SVOCs compounds. Dermal contact with mixtures of carcinogenic VOVs and/or SVOCs can cause skin disorders in both humans and animals.

Conditions at the portion of the Site addressed by this Action Memo meet the requirements of Section 300.4 I 5(b) of the NCP for the undertaking of a CERCLA removal action. Factors from Section 300.41S( b) of the NCP that support conducting a removal at the portion of the Site addressed by this Action Memo include:

A. 300.415 (b)(2)(i) - "Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants"

Elevated levels of Benzene, Ethyl benzene, 2, 4 - Dimethylphenol, 2 - Methylnaphthalene, 4 - Methyphenol (p-Cresol), and Naphthalene, each a CERCLA designated hazardous substance, are present in the wood tar present on­ site. Benzene is a known carcinogen. Contaminants of concern identified in the surface soil would pose a health risk to the on-site residents and their guests, not to mention the occasional unwary people who visit the village of Westl ine for recreation (fishing, hiking, hunting, etc.) coming into direct contact with these

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AR300007 hazardous substances. According to the OSC's interviews with the cun-ent owner of the property, residents and visitors to Westline and many animals access the Site to Kinzua Creek. Bear, deer, fox, skunk, possum, rabbits, turkeys, and snakes have been observed on a regular basis. Kinzua Creek supports a number of species of fish including Brook Trout, Brown Trout, Rainbow Trout and sculpins. The contaminated areas are not fenced and are easily accessible.

B. 300.415 (b)(2)(iv) - "High levels of hazardous substances or pollutants or contaminants in soils, largely at or near the surface, that may migrate"

Analytical information indicates that elevated levels of Benzene, Ethyl benzene, 2, 4 - Dimethylphenol, 2 - Methylnaphthalene, 4 - Methyphenol (p-Cresol), and Naphthalene, each a CERCLA designated hazardous substance, are present in the wood tar present on-site. Information from the previous removal and remedial activities at the Westline Site indicates that most of the wood tar in Area B was covered by soil and vegetative cover when the Westline Site was delisted in 1992. Current observations indicates that the wood tar is migrating via seepage to the surface and into Kinzua Creek.

C. 300.415 (b)(2)(v) - "Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released"

Precipitation events could result in the soluble chemical component of the wood tar to allow for migration into the wetland area, groundwater and/or Kinzua Creek. The groundwater transports hazardous substances such as phenols and PAHs from the subsurface wood tar into Kinzua Creek, and/or rainwater runoff transports hazardous substances from the surface wood tar seeps into Kinzua Creek, and the subsurface wood tar migrates directly into Kinzua Creek. The migration of hazardous substances could increase the exposure of and potential toxicity to aquati c biota.

The wood tar has a high proportion of phenolic compounds, which are soluble, with solubility increasing with increased temperatures. During wann months, the exposed wood tar on either side of the driveway liquefies· and flows over the surface. In addition, during warm weather months, the wood tar along the right­ descending shoreline liquefies and can migrate into Kinzua Creek, an exceptional trout fishing stream. The hazardous substances that is released is readily absorbed by humans and wildlife.

D. 300.415(b)(2)(vii) - "The availability of other appropriate federal or state response mechanisms to respond to the release."

The OSC has coordinated with the Commonwealth of Pennsylvania and confirms that the Commonwealth presently has no plans for response actions at the Site.

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AR300008 IV. ENDANGERMENT DETERMINATION

Actual or tlu·eatened releases of hazardous substances from the Site may present an imminent and substantial endangennent to public health, welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

Proposed action description

The objective of the removal action is to eliminate the threat of exposure to hazardous substances, pollutants, or contaminants present in surface and subsurface soil at the poriion of the Westline Site addressed by this Action Memo and to stabilize the shorelines ofKinzua Creek to mitigate future exposure of wood tar. The EPA will mobilize personnel, equipment and materials to the Westline Site and, working in conjunction with the USFWS through the EPA-BTAG, will complete the following removal actions:

A. Remove the wood tar from along the right-descending shoreline of Kinzua Creek, and stabilize the shorelines to mitigate the future potential of additional quantities of wood tar from being released into Kinzua Creek (Figure 3):

1. Clear the brush and grade the soil upstream access point via extension of Blauser Drive to Kinzua Creek and establish a temporary stockpile area for rock necessary for shoreline stabi lization; 2. Clear the brush and grade the so il downstream access point via extension of Dancing Lane to Kinzua Creek and establish a temporary stockpile area for rock necessary for shoreline stabilization; 3. Remove trees and stumps along right-descending shoreline to facilitate excavation of wood tar; 4. Establish limits of excavations as identified from previous investigations; 5. Excavate wood tar from right-descending shoreline of Kinzua Creek (Figure 3); 6. Dispose of all excavated wood tar and associated contaminated soil at an off-site facility that is in compliance with CERCLA 12l(d)(3) and 40 CFR 300.440; 7. Stabilize the Kinzua Creek shorelines to mitigate the release of wood tar along the right-descending shoreline of Kinzua Creek and to mitigate the potential for future release of wood tar into Kinzua Creek and its adjoining shorelines: a. Excavate new channel alignment; b. Fabricate bankfull benches; c. Excavate new channel under the river left web of the Westline Road Bridge (Figure 2); d. Install in-stream straight rock vanes; e. Install rock sills;

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AR300009 f. Install R-6 toe protection; g. Fabricate a bankfoll bench under the ri ver right web of the Westline Road Bridge; h. Dismantle relic railroad bridge pier, recycle and reuse stone and concrete sections from dismantled railroad bridge pier; 1. Dismantle relic railroad bridge abutment, recycle and reuse stone and concrete sections from dismantled railroad bridge abutment; J. Excavate gas line trench, coordinated with the gas utility company relocation of gas line(s) crossing above the creek via the relic railroad bridge and burying of gas line(s) under the creek; k. Implement site (shoreline) stabilization, restore vegetation and creek bed per guidance from the USFWS through the EPA-BTAG; I. Prepare as-built survey and report to facil itate post removal site control.

B. Actions to remove and/or mitigate the surface seeps of wood tar on both sides of the driveway:

I. Utilize the driveway to access wood tar seeps on either side of the dri veway; 2. Remove small trees, shrubs, vegetation and stumps on either side of the driveway to faci li tate excavation of wood tar; 3. Establi sh limits of excavations as identified from previous investigations; 4. Excavate wood tar and associated contaminated soil from both sides of the driveway; 5. Backfill with high organic matter soil to pre-existing grade as recommended by USFWS to facilitate restoration of the wetland area(s) on either side of the driveway; 6. Implement Site stabilization, restore wetland vegetation per guidance from the USFWS through the EPA-STAG; 7. Prepare as-built survey and report; 8. Dispose off-site all wood tar and associated contaminated soil excavated pursuant to #4 above, at a facility in compliance with CERCLA 12 1( d)(3) and 40 C.F.R. 300.440.

B. Contribution to remedial performance

The Site is not on the NPL. The response measures proposed in this Action Memorandum will contribute effectively to any long term remedial action with respect to the release or threatened release of hazardous substances at the Site.

C. Applicable or Relevant and Appropriate Requirements {ARARs)

ARARS that are within the scope of this removal action will be met to the extent practicable, considering the exigencies. Federal ARARs determined to be applicable for the proposed scope of work include those in the project include the PA Clean Streams Law, the PA Dam Safety and Encroachments Act, Chapters 102 and 105 of PADEP's rules and regulations, and the substantive requirements of the PA water obstruction and encroachment permits.

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AR300010 D. Estimated Costs

Extramural Costs Total Costs Regional Allowance Costs (This cost category includes estimates fo r ERRS contractors, subcontractors, Jetter contracts, orders for services, notices to proceed, alternative technology contracts.) $450,000.00

Regional Allowance Costs (This cost category includes estimates for inter-agency agreements with other Federal Agencies): USFWS interagency agreement with EPA-ERT through EPA3-BTAG $ 50,000.00

Other Extramural Costs Not Funded from the Regional Allowance: START Contractor $ 0.00

Subtotal, Extramural Costs $500,000.00 Extramural Costs Contingency (20% of Subtotal, Extramural Costs) $ 100,000.00

TOTAL REMOVAL ACTION PROJECT CEILING $600,000.00

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

If the actions described in this Action Memorandum are not conducted, the release and threat of release of hazardous substances or pollutants or contaminants will continue to exist at the Westline Site. Delayed action or no action to address wood tar present in the surface and sub-surface will result in the continued release of the chemical constituents of \.vood tar in Area B of the Westline Site and will increase the risk of exposure to the humans and wildli fe that utilize the Site and its vicinity. Delayed action or no action increases the threat of off-site migration of wood tar and would increase the overall extent and cost of the cleanup. Without immediate actions to mitigate the release and potential release of hazardous substances or pollutants or contan1 inants at the Site, potential tlueats posed to human and ecological receptors may increase.

VII. OUTSTANDING POLICY ISSUES

There is no known outstanding policy issue associated with the Site at the present time.

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AR300011 VIII. ENFORCEMENT

The property owner has been cooperative and has granted written access for work at the Westli ne Site. The OSC has provided the EPA Removal Enforcement Section with information as may be available to pursue any and all enforcement actions pe11aining to the Westline Site. See attached Confidential Enforcement Addendum.

The total cumulative EPA cost for this removal action that will be eligible for cost recovery, based on full-cost accounting practices are estimated as fo llows:

COST CATEGORY AMOUNT Direct Extramural cost 600,000 Direct Intramural Cost 60,000 Subtotal Direct Costs 660,000 Indirect costs (Indirect Regional Cost Rate 112.98% 745,668 Estimated EPA Costs eligible for Cost Recovery 1,405,668

The total EPA costs for this Removal Action based on full-cost accounting practices that will be eligible for cost recovery are estimated to be $1,405,668. 1

IX. RECOMMENDATION

This Action Memorandum represents the selected Removal Action for the Westline Site located in Westline, Lafayette Township, McKean County Pennsylvania, developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP. This decision is based on the Administrative Record for the Site. The documents in the Administrative Record include:

1. Federal On-Scene Coordinator's Report [Michael Zickler, OSC], Emergency Response/Immediate Removal Action, Westline, Pennsylvania - 1983 2. WESTLINE FEASIBILITY REPORT - July 1986 3. WESTLINE EPA ROD R0386024 - July 1986 4. WESTLINE FINAL PROJECT SUMMARY REPORT MARCH 1989 5. WESTLINE EPA ROD R0390086 - March 1990 6. WESTLINE EPA ROD R0390507 - March 1990 AMENDMENT

1 Direct Costs include direct extramural and direct intramural costs. Indirect Costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a Removal Action. The estimates are fo r illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estim ate nor deviation of actual costs from this estimate will affect the United States' right to cost recovery. 12

AR300012 7. Federal Register: Notice of Intent to Delete Westline Site from the National Priorities List: Request for Comments -December 17, 199 l 8. Validated Electronic Data - 11 /07/2014. 9. Westline Data Comparison Table - 03/ 18/2015.

By signing this Action Memorandum, you are also hereby establishing the documents listed above as the Administrative Record supporting the issuance of this Action Memorandum, pursuant to Section l l 3(k) of CERCLA and EPA Delegation No. 14-22.

Because conditions at the Westline Site meet the Removal Action requirements of the NCP, I recommend your approval of the proposed Removal Action. The total Removal Action Project Ceiling, if approved, will be $600,000, of th is, an estimated $500,000 comes from the Regional Removal Allowance. Please indicate your approval or disapproval below.

Action by the Approving Official:

I have revie'vved the above-stated facts and based upon those facts and the information compiled in the documents described above, I hereby determine that the release or tlu-eatened release of hazardous substances at and/or from the Site presents or may present an imminent and substantial endangerment to the public health or welfare or to the environment. l concur with the recommended removal action as outlined above.

Date: 1 A~O~D:_~~-~- ·~ ~ ~----­ _ __,_t/_+-7,}{,t;> -- -

Bonnie Gross, Associate Director Office of Preparedness & Response Hazardous Site Cleanup Division EPA Region 3

ATTACHMENT: Enforcement Confidential Memo Figures OI tlu·ough 06

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Figure 05 page 2 of 4 OBL-FACW SEED MIX

29% Fox Sedge, PA Ecotype (Carex vulpinoidea, PA Ecotype) 10% Eastern Bur Reed (Sparganium americanuml 10% lurid (Shallow) Sedge, PA Ecotype (Carex lurida, PA Ecotypel 9% Nodding Sedge, PA Ecotype (Carex gynandra, PA Ecotypel 5% Redtop Panicgrass, PA Ecotype (Panicum rigidulum (P. stipitatum), PA Ecotype) 5% Hop Sedge, PA Ecotype (Carex lupulina, PA Ecotype) 3% Swamp Milkweed, PA Ecotype (Asclepias incarnata, PA Ecotypel 3% Soft Rush (Juncus effusus) 3% Rattlesnake Grass, PA Ecotype (Glyceria canadensis, PA Ecotypel 3% Blue Vervain, PA Ecotype (Verbena hastata, PA Ecotype) 2% Boneset, PA Ecotype (Eupatorium perfoliatum, PA Ecotype} 2% Fringed (Nodding) Sedge, PA Ecotype (Carex crinita, PA Ecotype) 2% Square Stemmed Monkevflower, PA Ecotype (Mimulus ringens, PA Ecotypel 2% Woolgrass, PA Ecotype (Scirpus cyperinus, PA Ecotype) 2% Many leaved Bulrush, PA Ecotype (Scirpus polyphyllus, PA Ecotypel 2% Purplestem Aster, PA Ecotype (Aster puniceus (Symphyotrichum puniceum), PA Ecotype) 1% Ditch Stonecrop, PA Ecotype (Penthorum sedoides, PA Ecotype) 1% New York lronweed. PA Ecotype {Vernonia noveboracensis, PA Ecotype) 1% Tussock Sedge, PA Ecotype (Carex stricta, PA Ecotype) 1% Turtlehead, PA Ecotype (Chelone glabra, PA Ecotype} .,, 1% Joe Pye Weed, PA Ecotype {Eupatorium fistulosum, PA Ecotype} \S' 1% Mud Plantain (Water Plantain), NV Ecotype (Alisma subcordatum (A. plantago-aquatical, NY Ecotypel ,C 1% Northern Long Sedge, PA Ecotype (Carex folliculata, PA Ecotype) ~ 1% Nodding Bur Marigold, PA Ecotype (Bidens cernua, PA Ecotype) 0 (JI Applied at 20 pounds per acre -0 0 l0 ~ w 0 ~

~ AR300020 SHRUB LIST

• Black chokeberry (Aronia melanocarpa) • Nannyberry (Viburnum lentago) • Smooth alder (A/nus serrulata) • Spicebush (Lindera benzoin) • Black elderberry (Sambucus nigra)

i, Planted in mixed clusters with 5-foot spacing ,,@ based on soil moisture and canopy cover C \0 ~ ~ 0 -t\ ~

AR300021 Pennsylvania State Historic Preservation Office PENNSYLVA NIA HISTORICAL ANO MUSEUM C0MM1SSI 0N

June 13, 2016

Larry Brannaka U.S. Fish and Wildlife Service 110 Radnor Road, Suite 101 State College, PA 16801

Re: File No. ER 2016-1460-083-A FWS Waiver 16: Kinzua Creek Stream Restoration Project, Lafayette Twp., McKean Co.

Dear Mr. Brannaka:

Thank you for submitting information concerning the above referenced project. The PA State Historic Preservation Office (PA SHPO) reviews projects in accordance with state and federal laws. Section 106 of the National Historic Preservation Act of 1966, and the implementing regulations (36 CFR Part 800) of the Advisory Council on Historic Preservation, is the primary federal legislation. The Environmental Rights amendment, Article 1, Section 27 of the Pennsylvania Constitution and the Pennsylvania History Code, 37 Pa. Cons. Stat. Section 500 et seq. (1988) is the primary state legislation. These laws include consideration of the project's potential effects on both historic and archaeological resources.

There may be historic buildings, structures, and/or archaeological resources locatecfin or near the project area. In our opinion, the activities described in your proposal should have no effect on these resources. Should the scope and/or nature of the project activities change, the Pennsylvania State Historic Preservation Office (PA SHPO) should be contacted immediately.

If you need further information ir:, this matter please consult Kira Heinricl1 at (7 17) 705-0700 or [email protected]. If you need further information concerning historic structures please consult Emma Diehl at (717) 787-91 21 or [email protected].

Sincerely,

~~--;.~ 1 b.,/,vt_ _ ..... Douglas C. Mclearen, Chief Division of Archaeology & Protection

cc: DEP, Northwest Regional Office

DCM/tmw

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