EXPLANATION OF SIGNIFICANT DIFFERENCES No. 3 Jacks Creek/Sitkin Smelting & Refining, Inc. Superfund Site

I. INTRODUCTION AND STATEMENT OF PURPOSE

Site Name: Jacks Creek / Sitkin Smelting & Refining, Inc. Superfund Site

Site Location: Village of Maitland, Mifflin County, Pennsylvania

Lead Agency: U.S Environmental Protection Agency, Region III (EPA or the Agency)

Support Agency. Pennsylvania Department of Environmental Protection (PADEP)

This Explanation of Significant Differences (ESD) is being issued in accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, (CERCLA), 42 U.S.C. § 9617(c), and Section 300.435(c)(2)(i) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R §300.435(c) (2)(i), which require the EPA to issue an ESD where a remedial action will differ in any significant, but not fundamental, respect from that remedial action selected by EPA and described in a Record of Decision (ROD).

A ROD for the Site was issued on September 30,1997 and was modified by ESDs in April of 2001 and December of 2004, ESD No.-l and ESD No. 2, respectively. This third ESD modifies the long-term monitoring requirements of surface water, ground water, sediments and biota as set forth m the ROD. EPA has determined that no significant change in data quality or monitoring effectiveness will occur if sampling events to monitor contaminant levels in surface water, ground water, sediments and biota take place on a less frequent basis than that required in the 1997 ROD. Monitoring requirements are changed to reflect sampling of site-related contaminants on a frequency to be determined by EPA as further described in this document. The basis for this third ESD is discussed in detail in Section III. These differences to the remedial action do not fundamentally alter the remedy selected in the ROD with respect to scope, performance, or cost. EPA has concluded, and PADEP concurs, that the remedy selected in the ROD, as modified by subsequent ESDs, meets the objectives of the ROD.

Copies of the administrative record file upon which this decision is based, are located in the information repository at the EPA Region III offices in Philadelphia, Pennsylvania, the Mifflin County Library in Lewistown, and online at www.epa.gov/arweb/. This document will be incorporated into the Administrative Record maintained for this Site, as required by the NCP at 40 C.F.R. § 300.825 (a)(2). A detailed description of the ROD for the Site, along with the ESDs, is provided below, in Section II.

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II. SUMMARY OF THE SITE HISTORY, CONTAMINATION AND SELECTED REMEDY

The approximately 105-acre Jacks Creek/Sitkin Smelting & Refining Inc. Site (Site) is located in the village of Maitland in a rural farming area of Mifflin County, Pennsylvania. The Site J lies about five miles east of the Borough of Lewistown near the geographical center of the Commonwealth of Pennsylvania and is located at the border of Decatur and Derry Townships.

Land use at the Site is commercial/industrial and adjacent properties are designated for residential use. A total of 13 buildings were present on the Site, many of which were demolished during the remedial action. The Site contained two separate waste piles, the Ball Mill Tailings and the Aluminum Dross Piles, which have been consolidated and placed under a multi-layer cap in accordance with the 1997 ROD. A working railroad track runs from the southwest to the active scrap yard which occupies the western portion of the Site. Jacks Creek flows in a southwesterly direction along the northern perimeter of the Site, and surface water throughout the Site drains northward to Jacks Creek, a tributary of the Juniata River. The creek is approximately 20 feet wide with an average depth of three to five feet as it passes through the Site. During rain events the creek exhibits significantly increased flows immediately following the onset of a precipitation event and a rapid return to pre-rain conditions shortly after the end of the event due to the topography of the watershed. (Figure 1)

The prior owner of the property, Sitkin Smelting & Refining Inc. (Sitkin), operated at the 1

Site from 1958 until 1977, smelting non-ferrous metals. Sitkin's main products from the smelting operation were several types of brass and bronze ingots. Sitkin also operated a metal recycling operation that included aluminum, copper, and lead. Transformers and lead batteries were broken down on-site and recycled for their metal content. Sitkin also operated a Precious Metals Building where precious metals (gold, platinum) were reclaimed from used products.

Sitkin closed in 1977 when it declared bankruptcy. There has been no smelting or refining activity onsite since 1977. Joseph Krentzman and Sons, Inc. currently operates a scrap yard and utilizes about half of the 105-acre Site for a scrap metal and aluminum recycling business employing approximately 85 people. Soil contamination extended in an easterly direction from the Krentzman property onto the adjacent Noerr property and the Christian and Missionary Alliance (CMA) church property.

A Preliminary Assessment was done at the Site in March 1984, and a Site Investigation was performed in October 1985. Based upon the results of these investigations, the Site was proposed for inclusion on the National Priorities List (NPL) in June 1988, with final listing taking place in October 1989.

Numerous removal actions were performed by EPA at the Site beginning m 1990. Several of the removal actions were designed as interim measures to both limit erosion of contaminated soils into Jacks Creek and to restrict site access. Erosion control measures included construction of diking, placement of riprap in runoff channels, and an attempt to revegetate flood plain areas with soil-stabilizing grasses in May 1991. To limit the contaminants reaching Jacks

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Creek, a temporary cap was installed on the Ball Mill Tailings Pile, and several on-site lagoons were partially drained. An eight-foot-high chain link fence was installed around the eastern portion of the Site. Drums and other containers of bulk chemicals were over-packed, removed from the Precious Metals Building, and then disposed of at an off-site treatment facility. An investigation and removal action of onsite radioactive telegraph/teletype machine static eliminators was also conducted. This equipment was removed from piles of telegraph machinery and shipped off-site to a disposal facility. These removal actions were completed in January 1992. Additional low-level radioactive equipment was identified and disposed of off-site from a six-acre area during the remedial action.

Between 1990 and 1993, Gannett Fleming conducted a Remedial Investigation /Feasibility Study (RI/FS) under the direction of EPA to identify the types, quantities, and locations of -contaminants and also to develop ways of addressing the contamination problems. As part of the RI, a number of samples, including air, water, soil, and waste, were collected from different areas of the Site. A benthic survey and fish tissue sampling for PCB's and heavy metal toxicity were also conducted in the area of Jacks Creek adjacent to the site. An inventory of the Site and its buildings was performed, and a number of drums and vats were sampled.

The ROD for Jacks Creek was issued on September 30, 1997 and addressed the soils, sludge, waste piles, sediment in Jacks Creek, drums and vats, battery casings, and buildings. A complete description of the selected remedy as well as EPA's rationale for the decision is presented in the ROD. The major components of the selected remedy were:

• Excavation followed by off-site treatment (stabilization) and disposal of soils contaminated with lead, the principle threat waste, with concentrations above 40,000 ppm. ESD No. 1 was completed in April of 2001, which changed the off-site stabilization and

' disposal called for in the ROD to on-site stabilization and placement of the treated soils under the multi-layer cap on-site

• Excavation and consolidation of waste pile materials and soils containing between 1,000 and 40,000 ppm lead. Removal of Jacks Creek sediments exceeding 110 ppm lead located in the immediate vicinity of the Site by vacuum dredging and consolidated with the contaminated soils and waste pile material.

• The consolidated waste pile materials, soils, and sediments were covered with a multi-layer cap, which includes a two-inch limestone layer below the multi-layer cap consisting of a barrier layer, a drainage layer and a seeded topsoil layer. The barrier layer is composed of a high-density polyethylene geomembrane, and the drainage layer is composed of six inches of sand. The topsoil layer was seeded with grass in order to vegetate the entire consolidation area.

• Excavated areas were restored with clean fill to the original grade and then seeded in order to revegetate all areas except for the scrap yard. v

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• Structurally unsound buildings on-site were demolished.

• The drums and tanks were collected and transported off-site for proper disposal.

• Institutional controls are to be implemented on Site to restrict excavation or disturbance of the capped area, limit use of other areas of the Site to industrial activities and prohibit the installation of new onsite drinking water wells.

• An eight-foot-high fence was constructed on the northern side of the active scrap yard in order to completely fence the Site on all sides.

• Storm water controls were installed to divert stormwater away from the capped area

• Long-term monitoring of ground and surface water, as well as the fish and benthos in Jacks Creek are required to be conducted.

• Fish consumption advisories were required to be posted along Jacks Creek near the Site.

© Long-term maintenance of the multi-layer cap, storm water controls, and fence are required to be conducted to ensure proper functioning of these components.

The Responsible Party group implemented several remedial action (RA) components in 2001. These actions included the removal of soil with lead concentrations in excess of 1,000 mg/kg from the CMA church property; the characterization and disposal of 320 drums, demolition of nine buildings, removal of four underground storage tanks, and demolition of four above ground storage tanks. The remainder of the RA began in September of 2002 and was completed in November 2004. Approximately 75 acres of the Site were remediated through the excavation of contaminated soil and waste. Approximately 200,000 cubic yards (cy) of soil and waste were excavated from the Site and consolidated beneath the multi-layer cap. The RA also resulted in the on-site treatment of 9,500 cy of contaminated soil, installation of 650,000 square feet of a multi-layer cap, restoration of two acres of wetlands; installation of five stormwater management basins, and removal of 50 cy of contaminated sediment from Jacks Creek.

On November 18, 2004 EPA/PADEP conducted a Pre-Final Inspection and identified only minor items needing to be completed and institutional controls needing to be implemented. At the time the ROD was written it was not known that soil contamination extended in an easterly direction from the Krentzman property onto the adjacent Noerr property and that contamination existed adjacent to the Krentzman Building. ESD No. 2 identified the need for additional institutional controls pertaining to the Noerr property and Krentzman Building in order to limit the potential for human exposure to unacceptable risks posed by contamination remaining on-site, including requirements to protect workers, limit soil disturbance, and prevent use of the Noerr property portion of the Site for residential purposes.

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III. DESCRIPTION OF SIGNIFICANT DIFFERENCE AND THE BASIS FOR THOSE DIFFERENCES

This ESD No. 3 identifies and explains the additional significant changes that are being made to the remedy described in the September 30, 1997 ROD. These changes will not fundamentally alter the scope and performance of the combined requirements of the remedy described in the ROD. The changes to the remedial action provided for in this ESD are the modification to the monitoring frequency of surface water, ground water, sediments and biota.

The 1997 ROD long-term monitoring requirements for site-related contaminants in surface water, ground water, sediments and biota require sampling every six months, to commence after the remedy has been completed. A review of sampling data conducted over the course of six years indicates that monitoring frequencies may be modified with no significant change in data quality or monitoring effectiveness. This ESD provides flexibility in the sampling schedule by permitting EPA to periodically adjust monitoring frequencies based on a review of historical monitoring results and revise frequencies accordingly. The changes discussed, below, are based on EPA's review of semiannual monitoring results from March 9, 2005 to the present.

Upstream and downstream surface water samples collected from Jacks Creek have consistently revealed that contaminant concentrations are below Pennsylvania water quality standards. The sampling performed as part of the 1993 RI/FS demonstrated that the Site was not adversely impacting surface water quality and therefore remediation was not necessary. Long term monitoring of surface water over the past six years has shown that the surface water is not adversely impacted by migration of contamination from the Site. Consequently, pursuant to this ESD, surface water monitoring will be discontinued because it is not needed at this time to evaluate the effectiveness of the remedy.

Groundwater monitoring data indicates that the Site groundwater is not being impacted by the consolidated/capped materials. Sampling results indicate that all groundwater contaminants' of concern meet MCLs. Sampling for copper, lead and zinc, the contaminants of concern, will continue on a semi-annual basis, and samples will be taken and analyzed for the Target Analyte List (TAL) compounds once every five years beginning March 2014. The timing of the TAL sampling will allow for a detailed groundwater analysis prior to the April 2016 Five Year Review (FYR) and thereafter for subsequent FYRs.

Presently, the Site does not appear to be having a significant impact on observed biological conditions within Jacks Creek. Biota monitoring will take place once every five years, beginning March 2014 to provide data to perform a detailed biota analysis prior to the April 2016 FYR and then subsequent FYRs.

Sediment monitoring shall continue on a semi-annual basis as sediment data from Jacks Creek continues to periodically fluctuate above the lead cleanup standard of 110 ppm and ecologically protective levels for zinc and copper.

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This ESD revises monitoring frequencies of surface water, ground water, sediment and biota based on a review of data that demonstrates that a change to the frequency will ensure continued data quality and monitoring effectiveness at the Site. Reducing the monitoring frequency pursuant to this ESD does not preclude EPA from increasing the monitoring frequency if necessary in the future.

IV. SUPPORT AGENCY REVIEW

In accordance with 40 CFR § 300.435(c)(2), all of the above changes to the remedy have been coordinated with representatives of PADEP. PADEP concurred with this modification to the remedy on July 9, 2012.

V. AFFIRMATION OF STATUTORY DETERMINATION

EPA has determined that the revised remedy complies with the statutory-requirements of CERCLA Section 121, 42 U S.C. § 9621. Considering the new information regarding the impact of Site contaminants on surface water and groundwater that has been developed and the changes that have been made to the selected remedy through the ESDs, EPA believes that the remedy remains protective of human health and the environment, complies with all Federal and State requirements that are applicable or relevant and appropriate to this remedial action as described in the ROD for this Site, and is cost-effective. In addition, the revised remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable for this Site.

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VI. COMMUNITY INVOLVEMENT

A notice of availability of this ESD and a brief explanation of its contents will be published in a.local newspaper following its execution in accordance with the requirements set forth in NCP section 300.435(c)(2)(i). This ESD and the supporting documents which contain the information which form the basis for modifying the selected remedy have been included in the Administrative Record for this Site as required by the NCP at 40 CFR § 300.825(a)(2). The Administrative Record is available for public review online at www.epa.gov/arweb and at the locations listed

Mifflin County Library 123 North Wayne St. Lewistown, PA 1704-41650

EPA Region IIP 6th Floor Docket Room 1650 Arch Street Philadelphia, PA 19103 (215) 814-3157

below

^/'Ronald/L'Borsellino, Director Hazardous Site Cleanup Division

Date:

i M EPA, Region III

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N O T E S ^

MAPPING COMPILED P.Y PHOTOGRAMME1RIC METHODS FROM AERIAL PHOTOGRAPHY EXPOSED

0.1/30/99. MAP CONTROL WAS DERIVED FROM CONVENTIONAL AND GLOBAL POSITION FIELD

SURVEY TECHNIQUES PROVIDED BY LAND * MAPPING SERVICES. COPYRIGHT D9/99; LAND H MAPPING

7 TANK LOCATIONS WERE NOT SURVEYED AMI) Minitl.D HI QJNMIll l.'l h APPROXIMATE

JACK'S CREEK SUPERFUND SITE MAITLAND. MIFFLIN COUNTY, PENNSYLVANIA

SCALE IN FEET

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SITE F E A T U R E S

Advanced GeoServices Corp. 1055 Andrew Drive Suite A

West Chester. Pennsylvania 193B0 (610) 8 4 0 - 9 1 0 0

. FAX; (610) 8 4 0 - 9 1 9 9

FIGURE: 1

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