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Request for Approval & Funding for Removal Action

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Request for Approval & Funding for Removal Action UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch Street Philadelphia, Pennsylvania 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 -'.<ZM,,;O Western Response Branch (3HS32) ~~ (,/ 2'- 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 Allegheny Reservoir. 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- 2 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. 3 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 Allegheny River. 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.
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