Marjol Battery Site
 
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Final (100%) Remedial Design
 

The Final (100%) Remedial Design document was submitted to USEPA and PADEP on April 11, 2008 and was approved by USEPA/PADEP on May 8, 2008.  The Final Design presents Gould’s proposal on how the Final Remedy will take place, what will be done, and what the Site will look like after the remedy is implemented.  It addresses USEPA and PADEP comments on the Pre-Final (90%) Design, Throop Borough comments on the Preliminary Land Development Plan and initial comments of the PADEP and Lackawanna County Conservation District on the NPDES permit application. Additional comments on the NPDES permit application received after April 11, 2008, were incorporated into the final 100% Design construction document.

This web page provides an overview of the remedial activities as proposed in the Final Design (Click Here for the Overview), information on proposed construction phasing (Click here for Construction Phasing), and a summary of permitting for implementation of the Final Remedy (Click here for Permitting).

NOTE: The 100% Remedial Design document fills two 3” binders and as such is too large a document to put on this web site. The 100% Design document, however, is available for review at the Marjol Community Relations Office at 502 George Street in Throop (please call 570-383-9313 or e-mail Lisa Ayers at layers@advancedgeoservices.com for an appointment) or at the Marjol Battery Site Repository located at the Throop Municipal Building, 436 Sanderson Street in Throop, PA.

OVERVIEW OF REMEDIAL ACTIVITIES AS PROPOSED IN THE PRE-FINAL DESIGN
Implementation of the Final Remedy for the Marjol Battery Site generally includes the following activities:

 

Note: Items updated (changed from the 90% Design) in the 100% Design are highlighted in green below.  The 100% Design also contains a revised Community Relations Plan for the Site.  (For information on the revised Community Relations Plan, click here.)

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Site Preparation

  • Establishment of the Support Zone (a “clean” area for office and equipment trailers, etc.), Decontamination Area, and Access Roads - The existing infrastructure will be used as much as possible, but alternate or additional items will be added as needed. Additional office and equipment trailers will be mobilized by the Contractor. An office trailer may also be mobilized by Throop Borough. These trailers will be staged at the existing support zone at the start of work. There will, however, be a point during construction when all trailers will be moved to a second support zone (at the northeast corner of the facility) to allow for excavations at the existing trailer location. The main entrance at Delaware Street will be used, except when excavation and restoration are occurring at the entrance. During the time period when the Delaware Street entrance is being excavated and restored, the existing Woodlawn Street entrance south of the existing trailer area will be used for personal vehicles. Delivery vehicles and trucks will not enter the Site during the time period when the Delaware Street entrance is closed. Deliveries will be sequenced to occur prior to the entrance being closed so that adequate materials are present for work activities to continue. Traffic on Borough roads will be minimized to the extent possible but there will be traffic going into and leaving the Site especially during mobilization, cap construction, and demobilization. The details of road protection will be determined based on Throop Borough requirements.
  • Road Protection and Traffic Control - Due to the anticipated traffic required for construction activities, the sewer line at Delaware Street will be protected with steel plates as required by local officials. Coordination with local officials has occurred to plan traffic routes for transport of materials to and from the Site during remedy implementation.
  • Security - Gould will provide a 24-hour-per-day site security guard during active construction and demobilization.  In addition, the Contractor will establish procedures to prevent unauthorized entry into the Site and to document all visitors. 
  • Installation of Dust Control Measures and Erosion Control Measures - Dust control will be provided by water spray and covering stockpiles at the end of each work day. Air monitoring for dust and lead will be conducted during all phases of soil disturbance to ensure that the surrounding community is protected. (Click here for more information on air monitoring during construction.) Erosion and sediment control measures, consisting primarily of silt fencing, hay bales, silt socks, construction entrances, check dams, gabion mattresses, and temporary diversion channels and berms, will be installed to control sediment in runoff from impacting non-contaminated areas and to control surface water from impacting construction operations.
  • Clearing and Grubbing - In select areas of the North Woods where excavation is less than or equal to 12 inches in depth, clearing of vegetation, brush and trees less than 12 inches in diameter will occur to prepare areas for excavations and consolidation. In these select areas, trees 12 inches or greater in diameter will be protected. In all other excavation areas, all vegetation, brush and trees will be cleared. The chipped material from the clearing of these trees is considered clean and will not be placed in the Containment Area. Grubbed materials from within the areas of contamination are assumed to be contaminated and will be disposed of in the Containment Area.
  • Fence and Road Removal - Existing fencing and access roads will be removed as needed to construct the Containment Area and to excavate/consolidate contaminated materials.  Road demolition debris from outside the Containment Area footprint will be placed in the Containment Area.  Alternate fencing will be installed as needed during construction to maintain site security. Permanent replacement fencing will be installed at the completion of construction and as needed for long-term site security.
  • Well Abandonment and Modification - Some of the monitoring wells that are in the proposed cap area or that will no longer be needed will be filled (abandoned) and some of the existing wells will be made higher so they can be used for long-term monitoring. One new well is being installed to replace an existing well that requires too much extension to be practical.
  • Utility Location and Abandonment - Any existing utilities including electric, water, sanitary, storm, telephone and gas which are present in excavation areas or the Containment Area will be located, disconnected and abandoned, or relocated prior to excavation or Containment Area construction.
    Electric, communications, water and sewer service to the existing trailer location will be maintained as long as possible, and terminated immediately prior to excavation in those areas. Electric and communications service will be provided at an alternate trailer location when this happens. Water service will be maintained to the Site as needed for dust control at all times.
  • Construction of a new Stormwater Basin - Construction of a new stormwater basin will occur because the old stormwater basin is located in the area of the cap footprint. Once the new basin is constructed, stormwater flow will be diverted to the new basin and the old basin will be removed from service. The following drawing shows the proposed location of the new stormwater basin.  The new basin will discharge into Sulphur Creek just as the current basin does.  During construction, only water running over clean areas will be directed into the new stormwater basin.  Water running over contaminated areas will be directed onto the cap area.  During construction, a skimmer will be used to take water out of the basin and leave sediment behind in the basin. This protects Sulphur Creek and the Lackawanna River while construction is going on. The basin also will have a baffle in it that also helps keep sediment in the basin. Once construction is complete and grass is growing on all disturbed areas, the skimmer and the baffle will be removed.
  • Demolition of On-Site Structures - The Drum Storage Area, trailer, and existing stormwater diversion structures will be demolished, and demolition debris will be placed in the Containment Area. The curbing/barriers at the Low-Haz and High-Haz Stockpile perimeters will be demolished concurrently with stockpile removal and placed in the Containment Area or alternatively, they may be decontaminated and reused as necessary.

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Containment Area Construction

Following clearing and grubbing, the existing surface within the Containment Area will be graded and rolled to create a smooth surface for waste consolidation. A minimum 10-foot-wide perimeter berm will be constructed to provide additional airspace volume for waste placement and to create a stable surface for anchoring the layers of the cap. It is anticipated that Containment Area preparation and construction will occur in two phases to minimize the size and duration of the disturbed area.

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Waste Excavation and Handling

Contaminated soils and battery casing material will be excavated from areas outside of the cap area to minimize the size of the cap, to remove the material from areas of possible pothole subsidence and to provide isolation from the Five-Foot coal seam. Based on the results of the PDI, adequate isolation from the Five-Foot seam is provided by excavating any battery casing material that is located within 12.5 feet (2.5 times the seam thickness) of the subcrop of the Five-Foot seam in weathered rock.

Waste excavation and placement includes the following steps:

  • Excavation of contaminated soil and waste material from outside of the Containment Area footprint;
  • Consolidation of contaminated soil and waste material within the Containment Area; and
  • Solidification of the uppermost layer of waste within the Containment Area with cement-based reagents before placement in the cap area.

While many of the construction details will be determined by the Contractor and then approved by Gould and EPA/PADEP, it is anticipated that the excavation, transport, and placement of contaminated material into the cap area will be sequenced in a manner to minimize the potential for cross-contamination of remediated (clean) areas, to minimize double-handling of wastes, to produce an even distribution of waste types allowing for wastes suitable for solidification to be placed in the uppermost waste layer and materials with the highest lead concentrations to be placed at the bottom of the Containment Area, and to minimize the area requiring temporary cover during winter demobilization. As required by the 2006 RCRA Consent Order, confirmatory sampling will be conducted at the bottom of excavation areas.

It is anticipated that waste materials will be transported in covered off-road dump trucks. Access roads will be constructed on-site as needed to allow the dump trucks to travel from an excavation area to the Containment Area without entering public roadways.

The uppermost layer of waste will be solidified prior to placement. This layer is considered to be the first layer of the cap. The 100% Design calls for placement of 3 lifts of solidified material to be placed and compacted for a final thickness of 18 to 24 inches.

Note: If materials encountered during excavation activities are not consistent with materials related to battery recycling operations, the materials will be set aside and properly contained to prevent releases. The materials will be fully characterized, including radiation screening. Any material that would pose a release hazard, such as a liquid waste, or that has a high radiation reading will be disposed of off-site in accordance with State and Federal regulations.

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Additional Soil Sampling and Excavation Areas

Composite sampling for total lead was conducted on December 12, 2007 at an undeveloped, privately-owned residential lot east of the North Woods on Martarano Drive. An access agreement was obtained from the property owner prior to sampling. Sampling was conducted to fill a data gap in this area. Portions of this property will be excavated and the material consolidated into the cap area during construction activities in the North Woods.                                                                                                                                            

A data gap was identified at an area at the southeast corner of the North Woods in the Catherino Street right-of-way. This area will be composite sampled in accordance with the CMI Work Plan during construction and areas with soil lead results above 500 ppm will be excavated.
 

Dust Control

During construction activities, and in particular, during soil disturbance activities, the "No Visible Dust" rule will be strongly implemented.  Soils that are set for excavation will be watered down before they are moved and every effort will be made to keep from creating dust.  In order to be sure that construction activities are not impacting the air, air monitoring will be conducted during construction for all phases of soil disturbance to ensure that the surrounding community is protected. Three types of air monitoring will be conducted: site perimeter, real-time and personnel.

  • Site perimeter monitoring - this will consist of ambient air monitoring for lead using the high-volume sampler method, which is what has been used for the past 20 years at the Site. This sampling will determine if air lead is being emitted from the Site. Results with this type of monitoring are not immediate as the air collection filters have to be sent to a lab for analysis.  Perimeter air sampling will be conducted on a 6-day rotating schedule with 5 samplers running simultaneously for a 24-hour period.
    (Click here for recent ambient air monitoring results.)

During construction, two of the air monitors that are currently at the Site will be relocated to provide additional information for the community. One will be placed just inside the perimeter fence on Delaware Street where it will be visible to anyone driving near the Site; this will provide air lead data for residential areas adjacent to the Site. The other was relocated to the Mid-Valley Secondary Center on February 27, 2008, as requested by Throop Borough’s Planning Agency and Engineer. This monitor will provide air lead data near the local schools.

  • Real-Time air monitoring (Near Field Zone monitoring) - this type of air monitoring will determine if dust is migrating outside of the immediate work area so that additional dust control measures can be implemented before any dust can move off-site. This monitoring will consist of hourly, real-time particulate (dust) monitoring with a hand-held aerosol monitor equipped with a data logger at locations upwind and downwind of the work zone during all phases of work with potential for significant release of dust (i.e., during soil excavation, backfill, waste placement, and cap installation).  Real-Time monitoring provides immediate information on the amount of dust (not just lead) being generated.
  • Personnel air monitoring (Work Zone monitoring) - this type of air monitoring will be performed to determine if site workers are wearing appropriate personal protective equipment. The monitoring will be time-weighted average air monitoring for lead exposure.  Results are not immediate as air filter canisters have to be sent to the lab for analysis.

More details will be provided on the air monitoring once the contractor develops a more specific sequence for construction activities.

River Monitoring

Sediment samples will be collected for total lead analysis from the Lackawanna River quarterly during construction (and after a significant storm event or if there would appear to be a release from a contaminated area) and the first year of post-construction to make sure there are no releases of lead due to soil disturbances during construction activities.  Monitoring of the existing storm water management basin will not be conducted during construction as the basin will be removed from service.

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Storm Water Sampling and Discharge

Storm water from the clean areas of the site will be collected in a new storm water management basin. Sediment that is carried along with the storm water will settle out in the basin. Storm water collected in the basin will be released to Sulphur Creek after a 24-hour holding period in the basin to allow sediments to settle out. Note that storm water falling on contaminated areas of the site will not flow into the basin, but will be retained within the contaminated areas by berms.

As requested by Throop Borough Council, the storm water in the basin will be sampled before being discharged into Sulphur Creek. The basin storm water sampling plan consists of the following:

  1. Collect real-time information that can be used for timely action – The water discharge from the basin will be sampled using a turbidity meter. The water will be sampled every day that water is discharging from the basin. The turbidity meter will provide instant information on the amount of sediment that is being released. Lead contamination is expected to bind to the sediment. Years of water and sediment sampling at the site have documented that this is the case.  The turbidity information will be used to take immediate action if sediment levels are too high. If necessary, flocculent will be added to the basin to settle out the sediment.
  2. Collect lab data of storm water – The water discharge from the basin will be sampled on a periodic basis and sent to a lab for lead analysis to confirm that contaminated material is not discharging from the basin.
     

Containment Area Capping

The proposed cap area is 9.7 acres in size. The proposed footprint of the cap has been designed such that the cap will be within the existing fence line and at a distance of at least 300 feet from occupied dwellings. The proposed cap is expected to be able to accommodate all of the contaminated material that is going to be excavated and consolidated during the final remedy. At this point, it is not expected that any contaminated material will have to be removed from the Site.

The layers of the cap, from top to bottom, will consist of the following materials:

  • Vegetative (grass) cover (to help prevent erosion);
  • 6 inches topsoil (to retain water in order to sustain vegetation and to keep the roots of non-woody vegetation from reaching the drainage layer or geosynthetics);
  • Minimum 18 inches cover soil (functions similarly to the topsoil and also, like the vegetative cover and the topsoil, contributes to eliminating direct contact with contaminated soil);
  • Double-sided geocomposite drainage layer (creates a preferential path for water to flow into a perimeter collection system; geonet with geotextile bonded to both sides);
  • 60 mil textured LLDPE geomembrane (minimizes infiltration of rain water into the underlying materials);
  • 8-ounce geotextile (to protect the geomembrane from damage or puncture by the underlying solidified waste material); and
  • 18-to-24-inch solidified layer comprised of soil-cement (provides an extra layer of protection to prevent erosion of waste materials and releases to air and surface water in the unlikely event of a breach in the overlying layers of the cap until the breach could be repaired).

           

 

Passive Gas Vents

Even though gas generation from the material placed in the cap is expected to be minimal because the quantity of biodegradable material (the type of material that creates gas) is small compared to the overall volume of material in the Containment Area, passive gas vents will be installed at the highest point in the cap and on the sides towards the residential properties as required by USEPA and PADEP. The passive gas vents will allow gases generated by decomposition of biodegradable waste to exit the cap prior to building up at the underside of the cap.

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Restoration and Water Management

  • Following completion of excavation activities and confirmatory sampling, excavation areas will be backfilled and graded to the extent necessary to achieve drainage. Disturbed areas will be hydroseeded to restore vegetative cover.
  • An access road will be constructed around the Containment Area to facilitate long-term operations and maintenance.
  • Perimeter fencing removed during work activities will be reinstalled, or replaced with a new fence.
  • Surface water run-off and infiltrated flow from the cap drainage layer will be managed by swales along the cap perimeter or will be allowed to sheet flow away from the cap. The permanent storm water management system at the Site was designed in accordance with all state and local regulations.  The removal of trees during excavation activities will increase the amount of water flowing in the north eastern area of the Site, so a permanent storm water diversion berm will be installed along the eastern property line to prevent flow from exiting the Site in that direction.

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Off-Site Verification Sampling

Off-site verification sampling was performed prior to and will be performed following remedial activities to confirm that remedial activities did not cause off-site contamination.  Five locations were sampled in areas that were previously remediated.

A total of 20 samples were collected from each location during the pre-construction sampling.  Ten samples from each location were sent to a lab and analyzed and the remaining ten samples will be archived for future analysis if required.        

 

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Proposed Post-Remediation Maintenance and Monitoring

  • Post-Remediation Maintenance will include mowing and maintenance of the storm water management basin.
    • Mowing - the Site, including the cap area, will be mowed for turf establishment. Mowing will be conducted twice yearly during the growing season (May to October).
    • Storm water Management Basin Maintenance - maintenance will include measures to control burrowing animals, removal of accumulated sediment and maintenance of the discharge structure.
  • Post-Construction Monitoring will include site inspections and sampling of groundwater and river sediment.
    • Site Inspections - site inspections will focus on the integrity of the cap area, the erosion and sedimentation controls, the storm water management features, the access roadways, site security, and the general condition of the Site. During the first 6 months following implementation of the final remedy, inspections will be performed monthly. During the remainder of the first year and second year following implementation of the final remedy, the inspection frequency will be quarterly. Inspections will be conducted semi-annually for years 3 through 30.
    • Groundwater Sampling - groundwater sampling will be conducted to ensure that contaminants are not released following implementation of the the final remedy.  Four existing monitoring wells and one newly installed replacement well will be sampled before and after construction.  Groundwater sampling will occur quarterly for the first year post-construction and annually thereafter.
    • River Sediment Sampling - sediment samples will be collected from nine locations in the Lackawanna River and sent for lead analysis on a quarterly basis during construction and for the first year of post-construction.

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PROPOSED CONSTRUCTION PHASING

Due to the size of the project, construction activities will be conducted during two construction seasons with winter shutdowns from December through March, at a minimum. It is anticipated that construction would be phased as follows:

  • Season 1: Construction of proposed sedimentation basin, access roads and support zone and excavation and placement of a portion of the waste within the Containment Area; and
  • Season 2: Completion of excavation and placement of the balance of the waste within the Containment Area and solidification of the upper layer of waste, cap installation and Site restoration.

Between construction phases, in areas where waste placement is not yet complete, a temporary, 6-inch-thick soil cover will be constructed over the surface of placed wastes or where the existing soil cover or pavement has been disturbed. The area of temporary cover required between Phase 1 and Phase 2 is anticipated to be 5 acres. This temporary soil cover will be seeded as part of erosion control measures.

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PERMITTING

A summary of the various permit submission and approvals follows below:


State and County Permits

    1) A General National Pollutant Discharge Elimination System (NPDES) Permit Application for Stormwater Discharges Associated with Construction Activities was submitted to PADEP on December 21, 2007. PADEP then notified Gould that an Individual NPDES Permit would be required instead of a General NPDES permit. Gould submitted an Individual NPDES Application to PADEP on January 25, 2008. The 30-day public comment period for the Individual NPDES Permit began on March 8, 2008. A Public Hearing was held on April 16, 2008.   An Individual NPDES Permit was provided by PADEP on May 12, 2008.  Changes to the work activities are submitted to the County for permit modifications.


    2) It was determined that water from the new stormwater management basin will be discharged into Sulphur Creek (similarly to the existing basin), versus directly into the Lackawanna River. Therefore, a permit for discharge into regulated Pennsylvania waters is not needed.

    3) PADEP granted Gould a waiver on a wetlands permit for the proposed filling of the existing basin on September 4, 2007.

    4) On October 22, 2007, the PADEP Bureau of Air Quality determined that an operating permit was not needed for waste solidification using a pugmill during remedial activities.

    5) On December 18, 2007, the PADEP Bureau of Air Quality determined that an operating permit was not needed for a Passive Gas Vent in the Cap. On February 20, 2008, Gould submitted a revised request for a determination of minor significance for installation of more than one gas vent in the cap; this request was approved.  On April 28, 2008, the PADEP Bureau of Air Quality determined that an operating permit was not needed for the Passive Gas Vent system in the Cap.

     

                                               
                                                                                                                          
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Throop Borough Permits

    1) A trailer occupancy permit was requested for temporary office trailers that will be used to support remediation activities conducted by the Contractor, Gould, USEPA/PADEP, and Throop Borough. The zoning for the Site allows temporary use of office trailers for one year from the date approval is granted. As it is likely that the trailers will be needed for up to two years, SCE Environmental Group requested approval for two years as a special exemption use pursuant to the Throop Borough code.  The Zoning hearing board granted the request on May 20, 2008. 

    2) A zoning permit was obtained on January 24, 2008, for installation of a new permanent fence at portions of the Site perimeter.

    3) On December 4, 2007, Gould submitted a Storm Water Management Plan as part of the Preliminary Land Development Plan to the Borough Planning Commission along with information on proposed dust control and street protection/traffic control measures. The Storm Water Management Plan is required by the Borough's Storm water Management Ordinances. On December 20, 2007, Gould received comments on the submission from Robert Nitch of Peters Design Group, Throop Borough Engineer, on behalf of the Throop Borough Planning Agency. Gould responded to Mr. Nitch’s comments on January 16, 2008.  As recommended by the Throop Borough Engineer, the Throop Borough Planning Agency approved the Land Development Plan for Implementation of the Final Remedy on May 5, 2008.  Based upon this recommendation, Throop Borough Council accepted the Land Development Plan by motion on May 13, 2008. 

     

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Click here to learn more about current project information and the Schedule.

 

Check back periodically to learn about upcoming phases of work.

Page Last Modified Monday October 13, 2008 10:26:26 AM

 

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