Frequently Asked Questions Regarding the Marjol Battery Site

On July 19, 2010, a heavy rain event (approximately 0.35 inches in 1 hour) occurred at the Marjol Battery Site (Site). The heavy rain eroded areas of the Site that were not yet stabilized with grass or erosion control materials. Due to the erosion, the stormwater that flowed through the north and south swales and into the basin was turbid and caused the discharge from the basin to exceed the turbidity standard. Flow from the basin was stopped as soon as the exceedance was observed. During the days following this initial turbidity exceedance, Gould diligently worked to enable discharge from the basin to occur within NPDES permit turbidity requirements. Several measures were taken to control the turbidity in the sedimentation basin including the addition of several hundred pounds of a flocculant (Pond Clear), placement of Floc Logs (used to remove sediment from water), and the placement of geotextile around the skimmer head (as an additional filter). On August 2, 2010, water in the sedimentation basin became clearer allowing discharge from the sedimentation basin to take place and continue without exceeding the turbidity standard.

Water samples (analyzed for total and dissolved lead) were collected at the discharge point during the initial July 19, 2010 turbidity exceedance and also during an exceedance on July 21, 2010. The dissolved lead results were all below the laboratory detection limit of 1.0 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

USEPA, PADEP, and Throop Borough were kept informed on stormwater management activities during the period from July 19 to August 2, 2010. A formal non-compliance report covering the period from July 19 to August 2, 2010 was submitted to PADEP on August 4, 2010. (Click here to review the July 19, 2010 Non-Compliance Report.) See below for a description of the daily stormwater management activities for the period from July 19, 2010 through August 2, 2010:

July 19, 2010 - On July 19, 2010, after a heavy storm in the late afternoon (over 1.5 inches of rain was received on July 19, 2010), there was a stormwater discharge above the performance standard. The skimmer was in the discharge position in accordance with the Stormwater Management Design Plan. After the heavy rainfall, AGC took a turbidity reading at the discharge point and the turbidity meter gave an “Error” message indicating that the levels were above the range of the instrument. The skimmer was flipped to discontinue flow from the basin and a flocculant (Pond-Clear) was added to the basin to enable the sediments to settle out of the water to the bottom of the basin. Samples of the discharge were taken for the monthly total and dissolved lead analysis. The dissolved lead result was below the laboratory detection limit of 1.0 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead result was 368 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

July 20, 2010 - On the morning of July 20, 2010, between 7:13 AM and 7:40 AM, the water in the basin appeared clear, and several readings were taken on the western side of the basin as follows:

69.8 NTU, 116 NTU, 92 NTU, 120 NTU, 122 NTU, 83.8 NTU, 99.1 NTU, 92.7 NTU, 117 NTU, and 89.8 NTU

Based on these readings, the skimmer was flipped at 8:28 AM. After water reached the discharge point at the perimeter fence, two readings were taken at the fenceline at 8:40 AM. The results were 61.4 NTU and 79.0 NTUs. In early afternoon (2:10 pm), AGC checked the basin again. The basin and the discharge appeared turbid. A turbidity reading of 2292 NTUs was obtained at the discharge point. The skimmer was again flipped to stop flow. Additional Pond Clear was added to the basin to further expedite sediments settling out of the water.

July 21, 2010 - On July 21, 2010, additional turbidity readings were collected in the basin between 3 and 6 inches below the water surface. All readings in the basin were in the 40 NTU range. Based on these readings, the skimmer was flipped to allow discharge from the basin. Turbidity readings were once again collected at the discharge point immediately following discharge from the basin. Visual observations at the discharge pipe showed clear water consistent with the basin readings. However, the initial turbidity reading was 290 NTUs. After one minute of flow, the turbidity reading at the discharge point dropped to 190 NTUs. It is possible the initial 290 NTU reading at the discharge point was due to sediment within the discharge channel. A third turbidity reading was collected at the discharge point 10 minutes later; the reading was 140 NTUs. Approximately a half-hour later the discharge turbidity reduced to 16 NTUs. Based on these readings, discharge was allowed to continue with periodic monitoring until approximately 45 minutes later when the turbidity increased to 390 NTUs. The skimmer was then flipped again to prevent discharge form the basin. Further investigation revealed that the basin water was clear in the top few inches, but below that the turbidity was much higher indicating the Pond Clear was working, but that additional “doses” were needed. Samples for total and dissolved lead were collected on July 21, 2010. Two sets of samples were collected: one when turbidity was low and one when turbidity was high. The dissolved lead results were both below the laboratory detection limit of 1.0 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead results were .91 ug/L and 38.3 ug/L, respectively. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

Note: Due to questions on the accuracy of the initial turbidity meter being used, a second meter was sent to the Site and is being used to check the accuracy of the original meter.

July 22, 2010 - No discharge took place from the sedimentation basin. Additional Pond Clear was added to the basin on July 22, 2010.

July 23, 2010 - On the morning of July 23, 2010, ten turbidity samples were collected in the sediment basin. The turbidity readings were all well below the performance standard of 250 NTUs, with the highest result being 30.7 NTUs. Therefore, the skimmer was flipped to allow discharge from the sedimentation basin. A turbidity reading was collected at the discharge point shortly after discharge; the result was 161 NTUs. A turbidity reading collected 10 minutes later was 92.1 NTUs. The basin was checked approximately every hour throughout the day with all readings being below 65 NTUs until about 2 pm when the turbidity readings began to increase (97.6 NTUs at 2 pm and 181 NTUs at 3 pm). Due to the increase in turbidity in a short period of time, the skimmer was flipped to stop discharge from the sedimentation basin.

Additional flocculants (Floc Logs) were then added to the check dams and in the basin to assist with settling out the sediments from the basin. There was no additional discharge from the basin on July 23, 2010.

July 24, 2010 - On the morning of July 24, 2010, ten turbidity samples were collected in the sediment basin. The turbidity readings were all well below the performance standard of 250 NTUs, with all results being below 50 NTUs. Therefore, the skimmer was flipped to allow discharge from the sedimentation basin. A turbidity reading was collected at the discharge point shortly after discharge; the result was 124 NTUs. The discharge was monitored frequently and at approximately 7:40 am, in response to a turbidity reading of 177 NTUs, discharge from the basin was stopped.

After allowing additional time for sediments to settle out, the basin was re-evaluated in the afternoon. Turbidity readings were again collected in the sedimentation basin; all results were below 75 NTUs. The skimmer was therefore flipped again to allow discharge from the sedimentation basin. A turbidity reading was collected at the discharge point shortly after discharge; the result was 73.5 NTUs. The basin was checked approximately every half hour throughout the rest of the day with all readings being below 100 NTUs. At 5:40 pm discharge from the sediment basin was stopped for the weekend.

July 25 to July 27, 2010 - No discharge took place from the sedimentation basin.

July 28, 2010 - On the morning of July 28, 2010, ten turbidity samples were collected in the sediment basin. The turbidity readings were all close to the performance standard of 250 NTUs, so the skimmer was flipped (9:00 am) to allow discharge from the sedimentation basin. A turbidity reading was collected at the discharge point shortly after discharge (9:08 am); the result was 752 NTUs, so the skimmer was immediately flipped to stop discharge from the sedimentation basin.

Additional flocculant material (Pond Clear) was then added again to the sedimentation basin to assist with settling out the sediments from the basin.

July 29, 2010 - On the morning of July 29, 2010, ten turbidity samples were collected in the sediment basin. The turbidity readings were all close to the performance standard of 250 NTUs, so the skimmer was flipped (11:20 am) to allow discharge from the sedimentation basin. Turbidity readings collected at the discharge point just after discharge were just above the performance standard (highest being 300 NTUs), so the skimmer was immediately flipped (11:30 am) to stop discharge from the sedimentation basin.

July 30, 2010 - Geotextile was placed over the skimmer head to act as an additional filter for the water prior to discharge. The skimmer was flipped at 11:25 am. A turbidity reading of 309 NTUs was immediately collected at the discharge pipe and the discharge was stopped at 11:29 am. Additional fabric was applied over the skimmer head and discharge was again initiated at 2:40 pm. Three turbidity readings at the discharge pipe were collected (254 NTUs, 274 NTUs, and 281 NTUs). The turbidity at the discharge point was 166 NTUs. Six more turbidity readings were gathered at the discharge point over a span of 25 minutes with an increasing trend toward but not exceeding the performance standard. At 3:20 pm discharge was discontinued after a turbidity reading of 249 NTUs was collected.

July 31, 2010 - No discharge took place from the sedimentation basin.

August 1, 2010 - No discharge took place from the sedimentation basin.

August 2, 2010 - Discharge from the sedimentation basin was initiated at 7:30 am based on visual observations of the water in the sedimentation basin. The observations clearly showed a reduction in turbidity in the basin and clear water was observed to at least a 1-2 foot depth. Discharge was permitted to continue after a reading of 48.3 NTUs was collected at the discharge pipe. Six turbidity readings were collected at the discharge point throughout the morning with results all well below the turbidity standard (highest result was 53.9 NTUs). The monthly discharge sample for August for total and dissolved lead analysis was collected at 11:20 am. The turbidity at the time of sample collection was 6.36 NTUs. The dissolved lead result was below the laboratory detection limit of 1.0 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead results was also below the laboratory detection limit of 1.0 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

STORMWATER DISCHARGE ABOVE THE PERFORMANCE STANDARD - MARCH 30 and 31, 2010

Over 1.5 inches of rain was received on March 30, 2010. The skimmer had been flipped to prevent water from leaving the basin. (Click here for Stormwater Sampling and Discharge information) When SCE and AGC representatives checked the Site in the evening during the rain event, there was flow coming from the discharge pipe due to a leak in the skimmer arm. AGC took a turbidity reading at the discharge point and the result was 77.5 NTUs at 7:30 pm. The basin had filled up to the point of almost going over the baffle, so AGC representatives flipped the skimmer to allow water to discharge from the basin. Shortly after flipping the skimmer, AGC checked the turbidity at the discharge point. The turbidity was 330 NTUs at 8:45 pm. The turbidity level is supposed to be below 250 NTUs for discharge, so AGC flipped the skimmer back into the closed position to stop water from flowing into the discharge channel. There continued to be some flow in the channel due to the leak in the skimmer arm.

On March 31, 2010, a turbidity reading was collected at the discharge point at 8:45 am. The turbidity result was 330 NTUs. A turbidity reading of 324 NTUs was collected at the discharge point at 9:30 am after additional BMPs (hay bales) were added in the channel outside the fence. Turbidity at the confluence of the discharge channel and Sulphur Creek was checked as well. Two turbidity readings were taken at this location: one was 152 NTUs and the other was 158 NTUs. This demonstrated that while compliance with the performance standard was not achieved at the discharge point, it was met before the water entered Sulphur Creek. As requested by AGC, SCE plugged the skimmer orifice inside the outlet structure around the skimmer orifice plate. Once the plug was in place, flow into the discharge channel was reduced by approximately 90%. AGC observed that by approximately 1 pm, all flow in the discharge channel had stopped.

Water samples (one for total lead and one for dissolved lead) were collected from the discharge point and were sent to the laboratory for analysis. The dissolved lead result was 4.4 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead result was 33.9 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

The skimmer and orifice were repaired during the week of April 5, 2010, to prevent further leaks into the structure.

USEPA, PADEP, and Throop Borough were notified of the turbid discharge. As is required, a non-compliance report was submitted to PADEP on April 6, 2010. (Click here to review the March 30, 2010 Non-Compliance Report.)

STORMWATER DISCHARGE ABOVE THE PERFORMANCE STANDARD - MARCH 14, 2010

As required when significant rain events occur, on March 14, 2010, AGC personnel conducted an Erosion and Sedimentation Control Inspection at the Marjol Site. The water in the basin and the discharge from the basin was turbid. A turbidity reading was taken for the water being discharged. (Click here for Stormwater Sampling and Discharge information) . The water was found to have a sediment load well above the performance standard: 1275 NTUs when it is supposed to be below 250 NTUs. AGC pulled the skimmer to stop discharge from the basin. SCE was called to the Site and applied Pond Clear in the basin and the discharge channel (to cause the sediments to drop out of the water). A leak was found in the outlet structure so water was still able to discharge but at a much slower rate and at a much decreased volume. After the Pond Clear was added, the discharge turbidity dropped to 205 NTUs.

The high flows of water in the discharge channel had blown out the silt fence and silt socks at the fence line, so SCE also placed additional silt socks outside the fence in a U-shape. When AGC left the Site on March 14, 2010, the turbidity levels in the discharge channel had dropped to 195 NTUs.

Water samples (one for total lead and one for dissolved lead) were collected from the discharge point and were sent to the laboratory for analysis. Dissolved lead was not detected at a detection limit of 1 ug/L. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead result is 18.2 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

SCE worked on March 15 and 16, 2010 to repair the leak in the outlet structure. Once the outlet structure was repaired, the discharge channel was allowed to drain and then repairs were made to the silt fence and silt socks. Hay bales were also placed on March 15, 2010. A turbidity reading was collected at the discharge point on March 15, 2010; the result was 223 NTUs.

USEPA, PADEP, and Throop Borough were notified of the situation on March 15, 2010. Lackawanna County Conservation District was also notified. As is required, a non-compliance report was submitted to PADEP on March 19, 2010. (Click here to review the March 14, 2010 Non-Compliance Report.)

The skimmer was lowered back down on March 16, 2010 to allow water from the basin to drain as it is designed to do. Turbidity readings after the skimmer was lowered were as follows: 11:30 am - 124 NTUs 11:40 am - 71.8 NTUs

STORMWATER DISCHARGE ABOVE THE PERFORMANCE STANDARD - JANUARY 25, 2010

As required when significant rain events occur, on January 25, 2010, AGC and SCE personnel conducted an Erosion and Sedimentation Control Inspection at the Marjol Site. During the inspection, they noticed that the water leaving the basin had much more sediment in it than normal. In taking the daily turbidity reading, (Click here for Stormwater Sampling and Discharge information), the water was found to have a sediment load well above the performance standard: 1785 NTUs when it is supposed to be below 250 NTUs. Upon investigating, they observed that the skimmer head had separated from the skimmer arm and the arm dropped below the surface of the basin allowing sediment-laden water from the bottom of the basin to be discharged through the outlet structure.

An additional turbidity reading was taken at the discharge point (2183 NTUs) and a series of turbidity readings were collected in the discharge channel, Sulphur Creek and the Lackawanna River.
                                        At the confluence of Sulphur Creek and the River: 119NTU, 116NTU
                                        Sulphur Creek below the discharge: 168 NTU, 145 NTU, 112 NTU
                                        Sulphur Creek at the discharge (rip rap): 1840 NTU, 1918NTU
                                        Lackawanna River below Sulphur Creek: 132 NTU
                                        Sulphur Creek above the discharge: 93.9 NTU, 90.0 NTU
                                        At the discharge point from the Site (fence): 2183 NTUs

Water samples (one for total lead and one for dissolved lead) were collected from the discharge point and were sent to the laboratory for analysis. The dissolved lead analysis showed a very small amount of lead in the water (0.094 ug/L). The laboratory sample that is used to determine whether there is contamination of the instrument or something else in the laboratory also showed about the same small amount of lead in it, which means that there was no detectable level of dissolved lead in the discharge water from the site. The NPDES permit standard for maximum dissolved lead for the Site is 650 ug/L. The total lead result was 64.4 ug/L. There is not an NPDES standard for total lead. The very low total and dissolved lead results provide reassurance that even though the turbidity levels were above the performance standard, there was NOT a release of lead from the site that would affect the creek or the river.

It is believed that the freeze/thaw in the basin caused the skimmer head to separate from the skimmer arm. A site inspection had been performed by AGC on January 22, 2010 and the skimmer head was attached correctly at that time and the basin surface was frozen.

SCE repaired the skimmer on January 26, 2010. Dewatering through the skimmer resumed once the skimmer was repaired. AGC collected the following turbidity readings to document that the water at the surface of the basin that was being discharged was below the 250 NTU performance standard:
                                        At discharge pipe – 59.9 NTUs
                                        At discharge point from the Site (fence) – 65.1 NTUs
                                        In basin: Range from 35.8 to 84.5 NTUs

USEPA and PADEP representatives were on Site on January 25, 2010 and notified of the situation. Throop Borough was notified on January 25, 2010 and its Compliance Liaison was on Site on January 26, 2010. Lackawanna County Conservation District was also notified. As is required, a non-compliance report was submitted to PADEP on February 1, 2010. (Click here to review the January 25, 2010 Non-Compliance Report.)

INCIDENT REPORT - DISCHARGE OF MUDDY WATER INTO SULPHUR CREEK - JULY 28, 2008

On July 28, 2008, muddy water was discharged from the Marjol site into Sulphur Creek. The discharge lasted for about a half hour to forty minutes and was in violation of site procedures. Fortunately, the water that was discharged, although muddy, was from the new basin which was only collecting water from areas of the Site that were not contaminated. AGC collected two sediment samples at the location where the basin water discharges into Sulphur Creek. The two samples had lead readings that were below the detection limit of the instrument so there was no evidence of a release of lead-contaminated sediment into the river. Throop Borough also tested the sediments in Sulphur Creek but those results aren’t available yet either.

Even though the discharge was from clean areas, the incident should not have occurred, and Throop Borough should have been contacted sooner. These are both significant errors that called for reconsideration of site procedures.

Gould voluntarily shut down construction operations at the Site on Wednesday, July 30, 2008, in order that the incident which occurred could be properly addressed. A meeting was held on Thursday, July 31, 2008, to discuss the incident and develop a set of procedures such that this type of incident does not happen again in the future. Representatives from Gould, AGC, SCE, PADEP, USEPA, Throop Borough, Representative Frank Andrews Shimkus, and members of the press were in attendance at the meeting.

At the meeting, AGC reviewed the measures that Gould, AGC and SCE proposed to prevent any such incident from happening again.

●    Directives to stop an activity will be given visually as well as orally using a handwritten “STOP”, flag or pre-determined signal.

●    Daily operational meetings will be held to discuss the next day’s work and develop contingency plans in the event that something unexpected happens.

●    If an established procedure is modified, then a test run will be conducted to ensure that the modified procedure will accomplish the objectives.

Changes were made on SCE’s on-site personnel as well to improve internal communications and communications with AGC. Changes were also made in AGC staffing and procedures at the site to emphasize the need to inform Borough officials immediately of any unexpected event of possible public concern.

Both USEPA and PADEP stated that they did not have a problem with work resuming on Friday, August 1, 2008. PADEP required that a detailed report on the incident be provided to it, and they conducted their own investigation. (Click here to review the NPDES non-compliance report on the incident.) Throop Borough has been provided a copy of the report.

(Click the dates below to read articles and an editorial from the Scranton Times.)

- Article, July 30, 2008

- Article, July 31, 2008

- Article, August 1, 2008

- Editorial, August 1, 2008

(Click here to go back to the Stormwater Management System page.)

Page Last Modified Wednesday January 12, 2011 02:12:02 PM