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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION H 841 Chestnut Building Philadelphia, Pennsylvania 19107 Office of Superfund Direct Dial (215) 597-8257 SE Pennsylvania Remedial Section Mal Code 3HW21 -«-- TV ' Re: H3l;-..-C>t>iJ*Jifi>rO!: Hay 18, 1992 FEDERAL EXPRESS Mr. Mark Travers Senior Project Manager de maximus, inc. 9041 Executive Park Drive Suite 601 Knoxville, TN 37923 SUBJECT: Novak Sanitary Landfill Additional Waste Characteristic Information for the RI Dear Mr. Travers. Enclosed is a report (titled "Information on File Review for Novak Sanitary Landfill" dated Xpril 15, 1992) generated by our oversight contractor, Dynamac, as a result of a review of PADER and EPA's files. Please incorporate their findings and attachments into your final Remedial Investigation report specifically into the Waste Characteristic portion (Section 4.3.1). Listed below is also the contents of an EPA internal enforcement confidential memorandum dated October 23, 1990. Since this memo was derived as a result of reviewing 104 (e) information available in the Administrative Record, its contents can be attached as part of the final Remedial Investigation and released to the public for comments. Please call if you have any questions . Sincerely, Cesar Lee (3HW21) Remedial Project Manager AR307957

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Page 1: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION H

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Office of Superfund Direct Dial (215) 597-8257SE Pennsylvania Remedial Section Mal Code 3HW21

-«-- TV 'Re: H3l;-..-C>t>iJ*Jifi>rO!:

Hay 18, 1992

FEDERAL EXPRESSMr. Mark TraversSenior Project Managerde maximus, inc.9041 Executive Park DriveSuite 601Knoxville, TN 37923

SUBJECT: Novak Sanitary LandfillAdditional Waste Characteristic Information for the RI

Dear Mr. Travers.

Enclosed is a report (titled "Information on File Review forNovak Sanitary Landfill" dated Xpril 15, 1992) generated by ouroversight contractor, Dynamac, as a result of a review of PADERand EPA's files. Please incorporate their findings andattachments into your final Remedial Investigation reportspecifically into the Waste Characteristic portion (Section4.3.1). Listed below is also the contents of an EPA internalenforcement confidential memorandum dated October 23, 1990.Since this memo was derived as a result of reviewing 104 (e)information available in the Administrative Record, its contentscan be attached as part of the final Remedial Investigation andreleased to the public for comments. Please call if you have anyquestions .

Sincerely,

Cesar Lee (3HW21)Remedial Project Manager

AR307957

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cMr. Mark Travers 2 May 18, 2992

Attachments

cc: R. Smith (3HW15)M. Snoparsky (3HW15)K. Markowitz (3RC21)J. Banks (3HW11)C.K. Lee (3HW51)M. Kef fron, DynamacM. Mustard, PADERL. Diamond, Hannoch Weisman

v7o attachmentsP. Anderson (3HW21)J. Newbaker (3HW15)

CL:cl/051S92.NOV

flR307958

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Mr. Mark Travers 3 May 18,1992

Contents of 10/23/90 Memo

The findings described below are based upon review of existingPRP Search documentation available in the Novak Sanitary Landfill(the Site) Administrative Record. These include the April 7,1937 PRP Search Report compiled by TechLaw, Inc. under TES, siterecords, CERCLA 104(e) responses and information provided by theSite's PRP Steering Committee.

A. AT&T Technologies, Ino.l oak wayBerkeley Heights, NJ 07922-2727

1. AT&T Technologies, Inc.'a (AT&T) 2/27/37 response to aCERCLA 104(e) information request states that dewateredwastewater treatment sludge was sent to the Site.

2. AT&T's 3/24/37 supplemental 104(e) response containsanalysis of the dewatered sludge. The analysis shows that thesludge contains such hazardous substances as chromium and lead.

3. AT&T's 4/122/33 104(e) response states that 9080 cubicyards of the sludge was sent to the Site for disposal betweenFebruary of 1972 and January of 1978.

B. American Hiokaloid CompanyEastern Workswalnutport, PA 18088

1. American Nickeloid Company's 10/30/87 104(e) responsestates that the wastes which it sent to the Site via Valleydisposal included empty nickel filter bags. These bags containedtrace amounts of nickel, a hazardous substance. The attacheddocumentation shows waste shipments through Valley Disposal from1931 through 1934.

C. Aabury Graphite Kila, Ino.P. O. Box 144Aabury, NJ 08802-0144

AR307959

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cMr. Mark Travers 4 May 18,1992

1. Asbury Graphite Mills, Inc. (AGM), in its 10/20/87104(e) response, states that Valley Disposal hauled wastes fromAGM's Bethlehem, PA plant to the Site for disposal from Januaryto October of 1984. These wastes included graphite dust. Anattached PADER Module I for this dust shows that it contains suchhazardous substances as barium, chromium, copper, lead, nickel,silver and zinc.

D. Caloric Corporation403 N. Main streetTopton, PA 19562-1499

1. Caloric Corporation's 10/2/86 104(e) response statesthat sludge from Caloric's wastewater treatment plant wastransported to the Site by NSL from March of 1977 until August of1980. Caloric states that the sludge contains porcelain enamelwastes from its enamel paint spray booths. Material Safety DataSheets attached to the response show that the paints containedsuch hazardous substances as zinc and chromium. In addition,Caloric used solvents, which contained hazardous substances, toclean its paint spray booths. These solvents would also be aconstituent of Caloric's sludge.

2. Caloric's 3/3/88 104(e) response states that the paintbooth scrapings were a component of the wastes hauled to the Siteuntil 1980.

E. Durkee-French Foods1001 8th AvenueBethlehem, PA 18018

1. Durkee-French Food's (DFF) 10/28/87 104(e) responseincludes copies of purchase orders for waste removal whichindicate that DFF sent its wastes to the Site from January of1983 until May of 1985. DFF states in its letter that its wastescontained miscellaneous maintenance materials such as paint cansand ink bottles. These materials are likely to contain hazardoussubstances.

F. 6AF Corporation1361 Alps RoadWayne, NJ 07470

1. GAF Corporation's 10/13/86 104(e) response states thatGAF sent wastes from it's Whitehall, PA plant to the Site fromJune of 1976 until September of 1980. GAF sold its Whitehall, Pafacility to Tarkett, Inc. in September of 1981.

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Mr. Mark Travers 5 May 18,1992

2. GAF's 3/3/33 104(e) response states that the wasteswhich it sent to the Site included asbestos fibers, asbestos felttrimmings and a sludge which contained asbestos and latex.

a. General Electric company3135 Baston TurnpikeFairfield, CT 06431

1. General Electric's (GE) 3/4/37 104(e) response includesa copy of its CERCLA 103 Notification. This Notificationindicates that GE sent such hazardous substances aselectroplating sludges, oils and solvents to the Site from 1956to 1960.

2. GE's 3/2/39 104(e) response states that it sent itswastes to the Site from the late-1950s until the mid-1960s andthat GE may have even transported some of these wastes to theSite. The wastes included sludges which contained such hazardoussubstances as copper, chromium, zinc and nickel. GE adds that itused Valley Disposal to haul away its "plant trash" in 1933 and1984.

B. General Machine corporationFourth and Furnace StreetsBmmaua, PA 18049

1. General Machine Corporation (GMC), in its 6/13/33104(e) response, states that it used Valley Disposal to haul awayits wastes from 1973 until 1980. CMC's wastes include limitedamounts of spent oils and solvents, both of which could containhazardous substances, an attached analysis shows CMC's wastes toinclude such hazardous substances as arsenic, chromium, lead,zinc, nickel and cyanide.

I. Ingersoil-Rand CompanyStandard Pump Division1 Pump PlaceAllentovn, PA 18105

1. Ingersoll-Rand Company's (IRC) 11/30/37 104(e) responsestates that its wastes were transported to the Site by E.Schneider & Sons. These wastes included incinerator ash andpaint booth wastes, both of which are likely to contain hazardoussubstances

2. IRC'3 6/17/33 104(9) response states that IRC'3incinerator ash was collected by B. Schneider & Sons and thatsome of this ash eventually was disposed of at the Site.

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o cMr. Mark Travers 6 May 18,1992

3. E. Schneider & Sons' 1/6/88 104(e) response states thatit removed IRC's wastes, including incinerator ash, from theAllentown plant from 1979 until 1985. Some of this waste wasthen hauled to the Site. The remainder was hauled loy ValleyDisposal.

J. Packaging Corporation of America1603 Orrington AvenueEvanston, Illinois 60204

1. Packaging Corporation of- America's (PCA) 10/23/87104(e) response states that the wastes from its Trexlertown,PAplant that were sent to the Site for disposal included waste inksolids and sludge. An attached analysis shows that the sludgecontains such hazardous substances as arsenic, chromium, lean andzinc.

2. PCA's 6/8/88 104(e) response states that waste inksludge was NOT sent to the Site.

K. Pennsylvania Power & Light CompanyTwo North Ninth StreetAllentovn, PA 18101

1. Pennsylvania Power & Light Company's (PPL) 2/19/87104(e) response states that its wastes were taken to the Site byValley Disposal from September of 1975 through September of 1984.The wastes included empty oil and paint cans which would mostlikely contain hazardous substances as constituents. PP&L'sletter also states that "from 1975 to 1977 PP&L may disposed ofcapacitors at this site, if so, the capacitors originallycontained PCBs." PCBs are a hazardous substance.

L. Stanley-Vidmar, ine.11 Grammes RoadAllentovn/ PA 18105-1151

1. Stanley-Vidmar, Inc. (Stanley), in its 11/11/87 104(e)response, states that its wastes were sent to the site fordisposal. Paint residues were amongst its wastes.

2. Stanley's 7/7/88 104(e) response contradicts itsearlier statements to EPA and states that Stanley as no knowledgethat its wastes went to the Site. Stanley admits that ValleyDisposal hauled away its wastes from 1974 until 1985. Part ofStanley's wastes between 1974 and 1980 consisted of a "peelfilmite with paint overspray" which may have been put into thedumpster hauled away by Valley Disposal. Attached MaterialSafety Data Sheets for the paints and paint-cleaning solventsused by Stanley at that time show that many of these materials

, contained hazardous substances.

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Mr. Mark Travers 7 May 18,1992

M. The Stroh Brewery Company100 River PlaceDetroit, Michigan 48207-4291

1. PADER documents for the Stroh Brewery Company (Stroh)facility in Fogelsville, PA (formerly owned and operated by the F& M Schaefer Brewing Co.) show that Schaefer had receivedapproval from PADER to dispose of label pulp at the Site.Analysis of Schaefer's wastes indicate that they contain suchhazardous substances as selenium, copper, zinc, arsenic, cadmium,

• chromium and lead.

2. Stroh's 12/14/37 104(e) response states that Strohcontracted with Valley Disposal for removal of its wastes in thelate 1970s. These wastes included brewhouse sludge and wastelabel pulp.

3. Attachments to Stroh's 6/1/33 supplemental 104(e)response include a PADER inspection report that states thatValley Disposal has applied for a hazardous waste transporter'slicense in order to haul Stroh's D002 (corrosive) waste.Attached RCRA quarterly reports show that Stroh sent itscorrosive hazardous waste (D002) to a disposal facility in SouthWhitehall Township, PA via Valley Disposal. The Site is locatedin South Whitehall Township, PA.

N. Tarkett Ino.2123 First AvenueWhitehall, PA 18052

1. Tarkett Inc.'s 9/17/36 104(e) response states thatTarkett sent its wastes to the Site for disposal. Among thesewastes was a sludge generated by Tarkett. It is most likely thatthis sludge contains hazardous substances. Attached ValleyDisposal documents show that Tarkett sent its wastes to the Sitefor the years 1931 through 1934 (at a minimum).

2. GAF's 10/13/36 104(e) response (see F.I., above) statesthat GAF sold its Whitehall, PA plant to Tarkett in September of1981. GAF's sludge contained such hazardous substances asasbestos.

O. Tyler PipeP.O. Box 35Maeungie, PA 18062

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o cMr. Mark Travers 8 May 18, 1992

1. Tyler Pipe's 9/15/86 104(e) response states that itsent its waste to the Site for disposal from 3/10/81 until12/14/84. These wastes include core butts, cupola bottoms, burntsand and slag. Attached documents (a PADER Module I and a TylerPipe analysis of its wastes) show these wastes to contain suchhazardous substances as arsenic, chromium, copper, lead andphenols.

ADDITIONAL FINDINGS

1. Alientown steel Fabricating Co., inc.260 Race StreetCatasauqua, PA 18032

a. Allentown Steel Fabricating Co., Inc. (ASF), in its10/14/87 104(e) response, states that it sent its wastes to theSite for disposal. Among these wastes were empty paint cans.

b. ASF's 9/2/88 104(e) response states that it sent about10 to 15 five-gallon cans per year to the Site for disposal. ASFclaims that there would have been about 4 millimeters of excesspaint thinner remaining in these cans at the time of disposal.Paint thinners commonly contain hazardous substances.

c. Follow-up questions will attempt to discover thetimeframe during which ASF sent its wastes to the Site, the exactconstituents of ASF's paints, paint thinners and cleaning agents(including copies of any available Material Safety Data Sheets),the nature of any maintenance wastes which may have been includedin the wastes sent to the Site and the names of employees whoworked at ASF when its wastes were being disposed of at the Site.

2. ChemLavn services Corporation8275 North High streetColumbus, OH 43085

a. ChemLawn Services Corporation (ChemLawn), in its12/9/88 104(e) response regarding its Allentown, PA branch,states that it sent its wastes to the Site via Valley Disposalfrom August of 1984 until October of 1984. These wastes includeda few gallons of material from the bottom of its recycle tank.This material contained 2,4-D, a hazardous substance.

b. Follow-up questions will look into ChemLawn's Allentownbranch and its practices regarding the triple rinsing ofpesticide containers during 1984 and whether these emptycontainers and the recycle tank bottoms were contained in thewastes which it sent to the Site for disposal.

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Mr. Mark Travers 9 May 18,1992

3. Cook Paint and Varnish CompanyP. O. Box 389Kansas City, Missouri 64141

a. The Bethlehem, PA facility of Cook Paint and VarnishCompany (Cook), according to Cook's 10/23/37 104(e) response,sent its wastes to the Site via Valley Disposal.

b. Cook's 12/19/83 104(e) response states that its wastesincluded empty containers from raw materials and finished goods.Cook explains that these containers were squeegied prior to beingdisposed. Also included in Cook's wastes was a solid gel coatwaste from tank cleaning. These wastes are likely to containhazardous substances based upon the type of products manufacturedby Cook.

c. Follow-up questions will try to determine theconstituents of Cook's raw materials, finished products and solidgel coat waste (including Material Safety Data Sheets and anyavailable analyses) as well as the dates during which Cook sentits wastes to the Site.

4. W. R. Grace fi Co.62 Whittemore AvenueCambridge, Mass. 02140-1692 . ,

a. W.R. Grace & Co. (Grace), in its 11/3/37 104(e)response regarding its Fogelsville, PA facility (formerly PetersFertilizer Products), states that it sent its wastes to the Sitefrom the early 1970s until 1984. Grace states that these wastersincluded empty raw material bags, boxes and fiber drums which hadcontained small or trace amounts of hazardous substances. PetersFertilizer Products (Peters) operated out of an Allentown, PAfacility until it moved to the Fogelsville plant in 1978. Petershauled its own wastes to the Site until it moved to theFogelsville plant. (This would make Grace liable as atransporter in addition to its liability as a generator for theSite.) At that time, Valley Disposal transported Peters' wastesto the Site. Grace purchased Peters in 1979.

b. Material Safety Data Sheets attached to Grace's 9/12/39104(e) response show that the raw materials utilized by Grace inits manufacturing process contained various hazardous substances.

c. In an interview conducted by a private investigatorunder contract to the Site's PRP Steering Committee, WarrenGerman, a former driver at the Site, stated that empty ingredientbags were included in the wastes sent by Grace to the Site.

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o cMr. Mark Travers 10 May 18,1992

5. International Multifoods corporationMultifoods Tower33 south Sixth StreetMinneapolis, Minnesota 55402

a. International Multifoods Corporation (IMC), in its11/18/87 104(e) response, states that the wastes from itsFogelsville, PA plant were hauled away by Valley Disposal fromOctober of 1982 until September of 1986. These wastes includedempty oil and grease drums, which might contain hazardoussubstances, and pyrethrins gas containers. Pyrethrins is ahazardous substance.

b. Site documents show that IMC issued purchase orders to"Lou Novak Sanitary Landfill" in 1982, 1983 and 1984.

c. During interviews conducted by a private investigatorunder contract to the Site's PRP Steering Committee, former Siteemployees stated that IMC"s wastes were disposed of at the Site.

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CORPORATIONEnvironmental Services

INFORMATION ON FILE REVIEWNOVAK SANITARY LANDFILLOREFIELD, PENNSYLVANIA

Contract No: 68-W9-0005Work Assignment No: C03021

April 15,1992

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INFORMATION ON FILE REVIEWFOR

NOVAK SANITARY LANDFILLOREFIELD, PENNSYLVANIA

Contract No. 68-W9-0005Work Assignment No. C03021

Project No. P025-C01

Prepared FORMr. CesarLee

U.S. Environmental Protection Agency, Region HI841 Chestnut Street

Philadelphia, Pennsylvania 19107April IS, 1992

Prepared By:Dynamac Corporation

53 Darby RoadPaoli, Pennsylvania 19301

Written By: Reviewed By:

Michael Heffron Kirk'Project Manager Manager Geosciences Department

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Comments on Fite ReviewNovak Stnituy Landfill

Revision 0

1 TABLE OF CONTENTS

SECTION PAGE

1.0 COMMENTS ON FILE REVIEW .............................. 1

2.0 CONCLUSIONS ......................................... 3

U.S. Environmental Protection Agency Prepared by Dynamae Corporation V_ JApril 15,1992

/JR307969

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Comment! on File Reviewv ; Novak Sanitary Landfill

RevifionO

LIST OF ATTACHMENTS

ATTACHMENT 1 NOTIFICATION OF HAZARDOUS WASTE SITE :ELECTRIC 6/9/81

ATTACHMENTS SOLID WASTE DISPOSAL REPORT FOR GENERAL ELECTRIC,2/15/79

ATTACHMENT 3 WASTE ANALYSIS FROM FULLER COMPANY TO VALLEYDISPOSAL, 7/3/75

ATTACHMENT 4 LETTER: PADER INTERNAL MEMO ON KUNE FOUNDRIES,8/30/77

ATTACHMENT 5 LETTER: CALORIC CORPORATION TO PADER, 5/2/77

ATTACHMENT 6 LETTER; PADER BETHLEHEM OFFICE TO PADER READINGOFFICE, 5/5/78

ATTACHMENT 7 NOTIFICATION OF HAZARDOUS WASTE ACTIVITY

ATTACHMENT 8 LETTER: VALLEY DISPOSAL TO PADER, 12/30/81

ATTACHMENT 9 MODULE 1 AND CORRESPONDENCES ON F&M SCHAEFERBREWING CO. PULP SLUDGE

ATTACHMENT 10 LETTER AND MODULE 1: TYLER PIPE TO PADER, 1/27/81

ATTACHMENT 11 NEWSPAPER ARTICLE: SUNDAY CALL CHRONICLE, 5/23/82

ATTACHMENT 12 INFORMATION ON SINKHOLES ON-STTE, 3/27/85

U.S. Environmental Protection Agency Prepared by Dynamae CorporationApril 15,1992

ii

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Comment* on File ReviewNovak Sanitary Landfill

Reviiion 0

1.0 COMMENTS ON FILE REVIEW

• General Electric disposed of hazardous sludge at the Novak Landfill from 1956to 1960. A Notification of Hazardous Waste Site Form, submitted to EPA onJune 6,1981, identified Novak Landfill as its destination for F006 (Waste watertreatment sludges from electroplating operations) and F001 (Spent halogenatedsolvents used in degreasing)(See Attachment 1). A Solid Waste Disposal Report(1946-19791 by R.F. Gladu, dated February 15,1979, also reports that its sludgesand solvents were disposed at Novak Landfill during the early years of operation(See Attachment 2).

• According to a letter in the PADER files, dated July 3, 1975, the FullerCompany may have disposed of waste, consisting of primarily silica oxide andcalcium oxide, at the Novak Landfill (See Attachment 3).

• A letter dated August 30, 1977, states that discarded foundry sand from KlineFoundries will be disposed at the Novak Landfill (See Attachment 4). No otherinformation concerning this waste stream could be located in the PADER files.

• According to a letter dated May 2, 1977, Caloric Corporation generatedapproximately four (4) cubic yards a day of sludge for disposal in NovakLandfill. The sludge is from the neutralization of metal finishing rinse waters andalthough it contains hazardous constituents, according to the leachate analysis ofthe sludge, the material is non-hazardous. The duration of waste disposal fromthis facility is unknown. A brief letter in the PADER files states that CaloricCorporation also disposed of waste material from frit spray booths, collected inbarrels, at the Novak Landfill. No other information on description, quantity, oranalysis for this material was available (See Attachment 5).

• A letter dated May 5,1978 stated that Novak Landfill was requesting informationform PADER on the procedures for sludge disposal of wastes generated at ApolloMetals, Lie (See Attachment 6). No other information regarding this waste streamcould be located in the PADER files.

U.S. Environmental Protection Agency Prepared by Dynamae Corporation v,JApril 15,1992

AR30797I

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Comments on File Review', ' Novak Sanitary Landfill

Revision 0

• On October 11, 1980, Novak Landfill submitted a Notification of HazardousWaste Activity to treat/store/dispose and/or transport hazardous waste code U013(See Attachment 7). Waste code U013 could not be located in the Code ofFederal Regulations (40 CFR) Parts 190 to 299, July 1, 1989. This waste codemay have been delisted.

• A letter dated December 30, 1981, from Louis Novak to PADER, infers thatprior to 1981 Novak serviced accounts generating hazardous wastes (SeeAttachment 8). No other information on the disposal of hazardous wastes at thesubject site could be found in the PADER files.

• A letter from the PADER to F&M Schaefer Brewing Company, date August 28,1981, states that label pulp generated could be disposed at the Novak Landfillprovided that the pH of 12.5 be brought down to a pH of 7 before disposal (SeeAttachment 9). However, another letter from PADER, dated July 8, 1983, statesthat the landfill could no longer accept the label pulp because the analysis in theModule 1 reveal EP Toxicity leachate levels with lead at 16.6 mg/kg, which isconsidered a hazardous level (See Attachment 9). It should be noted that the 16.6mg/kg was the level of the solid waste analysis and that the leachate revealed only0.1 mg/1. Another letter from PADER, dated August 2, 1983, states that NovakLandfill can continue accepting the label pulp for four more months. The exactduration in which the label pulp was disposed at Novak Landfill is unknown,however, 936 tons a year were disposed.

• According to PADER files, dated January 27, 1981, Tyler Pipe disposed ofapproximately 5,540 cubic yards per year of core butts, cupola bottoms, burntsand, slag grinder and mullet from their Cupola Melting Operations in Mucungie,PA into the Novak Landfill (See Attachment 10). Although the wastes containedhazardous constituents, the EP Toxicity leachate levels classified the waste asnon-hazardous. The duration of waste disposal from this facility is unknown.

• According to a newspaper article in the Sunday Call Chronicle, dated May 23,1982, PCB-contaminated soil and other items, such as telephone poles fromPP&L's Siegfried substation were disposed at the Novak Landfill. According toa PP&L employee, at least one truckload of material saturated with PCB oils wastaken to Novak Landfill. A PP&L spokesman claimed that the materials removedwere 43.7 ppm PCBs and not subject to regulations. According to the article, Mr.Novak stated that the PCB spill material was buried in a separate hole coveredwith a foot of clay soil (See Attachment 11).

U.S. Environmental Protection Agency Prepared by Dynamae CorporationApril IS, 1992

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Comment* on HI* ReviewNovak Sanitary Landfill

Reviiion 0

2.0 CONCLUSIONS

Based on the file review, it appears the majority of the waste disposed at Novak Landfill wasmunicipal in nature. Novak Landfill serviced a large number of industries in the Allentown areafor municipal waste removal. The majority of the industries also disposed empty wastecontainers (5 gal. pails, bags, 55 gal drums, etc.) in with their municipal trash. While theseempty containers were not considered hazardous, per RCRA standards, the containers didcontain residual material that had hazardous constituents.

The sludges that were disposed at the subject site, with the PADER approval, containedhazardous constituents, but the leachate analysis conducted on the sludges revealed that theywere considered non-hazardous (RCRA standards).

General Electric may have been a major contributor of hazardous waste to the landfill from 1956to 1960. The information available suggests that hazardous sludges and possibly 55 gallon drumsof spent solvents may have been disposed at the subject site. The Site Analysis Plan preparedin 1989 by Bionetics Corporation for the Environmental Photographic Interpretation Center wasreviewed in order to assess the waste disposal areas in operation between 1956 and 1960. TheSite Analysis Plan presents an analysis of historical aerial photography of the Novak Landfill.Aerial photos from November 5, 1958, April 21, 1962, and June 27, 1964 were reviewed todetermine the disposal areas in operation. The following bullets summarize each of those yearsof disposal activities:

• November 5, 1958: The first evidence of disposal in the abandoned quarry isnoted in this photo. The interpretation notes refuse, and light toned material beingdeposited in the quarry. There was also a plume of smoke noted in the quarryarea. An excavation is noted on the southwest side of the quarry.

• April 21, 1962: According to the interpretation, there are more access roadsleading to the abandoned quarry and there is increased disposal activity in thequarry. There are approximately eight earth moving vehicles at the site. There isrefuse noted in the area south of the excavation to the southwest of the quarry.A new rod leads to another excavation area southeast of the quarry.

• June 27,1964: According to the interpretation, a large amount of disposal hasoccurred in the quarry. Additional refuse and junked cars are located to thesouthwest of the quarry. A disturbed, graded area is located in the northwestcorner of the site.

U.3. Environmental Protection Agency Prepared by Dynamae CorporationApril 15, 1992

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Comments on File ReviewNovak Sanitary Landfill

• Revision 0

Since the wastes at the landfill were mainly municipal with industrial wastes mixed in over theyears and there are no accurate records on waste quantities and disposal locations, it would beunproductive to conduct any more intrusive activities at the landfill. Based on the aerial photointerpretations, it appears that the hazardous wastes collected from G.E. were probably disposedin the bottom of the old quarry. It would not be feasible to conduct intrusive activities into thequarry since the hazardous wastes were probably buried under years of municipal waste disposal.Monitoring around the old quarry should be continued on a regular basis in order to detect anyground water degradation resulting from the hazardous wastes disposed in this area.

While conducting the file review information on past sinkholes at the site was uncovered.Sinkholes or dolines are very important indicators of joints or fractures underlying the area thathave been enhanced by solution. Because the area in which the dolines were identified is locatednear the southwest retention pond, this area should be studied in more detail during the remedialdesign for the construction of a larger retention pond. (See Attachment 12).

U.S. Environmental Protection Agency . Prepared by Dynamae CorporationApril IS, 1992

flR30797«.

Page 19: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT 1

AR307975

Page 20: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

___________/ Vol. *H. No. 3 / Wadnetrfay. AcritlS. 1S01 /

/. '/-V-PA Notification cNotification of Hazardous Waste Site \/•* IroJUf fMmw9 o"*J ^ *

»«<a tA«*i! af V ••" '*ma Jaiia/af ma «*<* ' klf«». "**

~'"'~~ PA0003007732to Notify: ' • ., • • « « * »

^ a aA mafma s-n 6g"gn! ETectHt Co.1fl01 South T2th St.

t— PA r-c— 1S1036, SJta Location: » • . u L*. j j*»•—«•*•> Novak UndfiH

a«waflt«atianaf iA«c<<a. . ROT 'LeMqh ' «^

C faftpft to Contact* •*-Jf, Robert Ehv.215-79 700

ef W««tt

Type: O>oo<«*(A« «cuien yowprtfar to csmpl«i«k S«i«er nt n«far WMI* fn»« aM uurct categema. «

.' yaw M not Uww in« jctxol «raai« tw« or towrc**. vow a/a^^ nr n M « *> Ska.

Can«f al Typo of Waata: Sawnra af Waata:ftaca an x MI ina ippfoo/i«a *<aea an X MI ina aoaroenata

Th« eata««r<«a fcato*Cnact aacft aa»i«ao<«

.rtvr

tna Mt af ftaxaraaua wa«ia« ana* ca«aa can M •«*>**« •*cantaoMif tna tf*. Na«Min aannnf tfla Suta in «*t<cn uv« MO ,

l,Qr "c-l**103.04.QramiiMfO

C O UaiAor'7. OO

W*«a />!Cia a u<*Ao«« Ho. a1 f. O Otftar (Stwcrfy) 11. O CWariol Caitfiicura————————————_— flO—————————————— 1X0

- -————————- 14. O $4m«anr- ff«f«M1S.HICO17. OIt. a Oinur (S0««fTi

I;

00tto« 2: Thia estiefl is a«a*ta&fa ta aar»ao« fjm.ni/ .»«* m«3031rtfv<attt<u f*0 C/X *an 2811.

f aacifl* Tyya af Waata:if A haa aw n«d a *x*r •*«»» iiwmdar fa aaeft Miaro»w« •*«>•iafM MI ma ««9u(3t«na wnaaf Sttsttn 3001 af MCAa. Cmw «n«aaaravrtaia towr«4i«>f «wmo«r in ma oaaaa er**«a*a. A caov of

*

flR307'976

Page 21: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

.ffcfffolef / Vol. 4<l. Na. 72 / Wednesday. ApnT is. isai /

G Itnown. £u4|«(,,«t<iU of Likary.ftafaaaaa ta U»« fnvJrenmant: • <~. 7»'«~. i>r **-i~;4 /.vV'>'V: •?.» ••'.'• » ••'.., »i-*' ftaca »«• x >A'in« toffcfaaftaia* lM*4a'ia<*0i<aca »«y kn***, tusaacsaavV* r.'Ji',.''. ''fl'JCno»w«.»fl'j«rte««atf 9 UU+r O Wa«»*

' Natat it«*ta H jwd I a/a oviiaqat C*n«J«i«<s masa «Mia wdf naiM I'A ana) Jtata anaj taul fovarrunanti M louttAf H* atsa»v •- ' •' ' .%••••«•______

tna *f actiM nartft. You may swlxiuuta a

,iptiortoisiui:;(0fltionai»: -. . ;TMi U a private land/til stta&iffll.fti operatton for1 •. Oescnaatnanittoryindgr'atant- '•>'' _ .• ISunlcfpal .trasft, wflldl W'uied'- il "tt« Tltd 50*$". SotM of.'...."rt.i'ff'-fl!l!!.<J'.5!lff.!?!!2««l* -..tha Aaulinj was 1n a-'ccmpany (jwrted and'drfven.truck, mostly

ed 5y-'contract haul«r..fc .•*;;.'•-•.j an n«w wasta was asoaaa* •'' • • • • • •. •. .-'...... - J tna, watta esma, from *»«v««l

•' •, any etfltf info/matiovi or eommants wrfticft«»y ftatp tfattf iM «« r—*

'.«•!»• ••' «.'';'. « • . - . /•I . '. .... i*t.* •.. « • • .^ \" I * * • * *

•;; •' v:V:?' •______ / ' 205189 •J S>gnaiu«» and Tidaj •'. • .

Petar H. luoln. PTant Manager____ QM Jitwn«T« af 9«»a«« r»( ««d »aQ| Crtufh 17»h C «.* • Ota n«df «M.ti $ n tna lo/m ' __________

man snots**. ———————————— ' —— ' — "^•rt item At t of atrtar g«fiani j> o»mina . A7T»n*mjj!« ^ a* •»«»«!• O Oparaiar.ail.. ..........,.,..w..v...,. _______________?A *••

ma uo««i v»nicA t>ita in* sa« si

... _ pj_ ^ _mj f FJ t J' 9 FM ** F fa±. " at ^ %^ J T J ^ f

• Oinif • : . •' *' "———————:————£——— ——' v.

AR307977

Page 22: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT!

flR307978

Page 23: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

SOLID VASTe DISPOSAL

AtLEXTOWN PLANT

194$ - 1979

R. F. GLAQUeSVlSONHENTAL & FINISHING ?RCCISi£i l\:MANUFACTURING

Febrjary IS, 1979

f

205174

114622ftR307980

Page 24: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

-1-

INTRODUCTION——————— &?

The Allentown Plant was originally built by Carrier Corporation In 1925. The next

owner was the American Armament Company. During VIW II, the plant was opera tad by

Consolidated Vultee under the U. S.« Government as owner.

General Electric bought the plant from the government 1n January 1946 to manufacturetoasters. Plating operations were transferred periodically from Bridgeport and the

product line grew with the addition of grills,rotlsserle, and eventually, toaster

ovens and percolators.

As the business grew, the plant was expanded from the original area which includes f•present press rocm/buff/tcol room. A foundry building was added south of the main

building. Buildings 3 and 4 housed the No. 1 nickel and chrome operations transfers

from.Bridgeport. A major expansion 1n 1956 was the No. 6 Building to house a s s e / yoperations, with the new No. 6 plating machine In 1962. Further plating expansion

was made 1n 1973 with the addition of No. 10 Building and the large No. 10 platingmachine. The last major expansion In 1975 was Building 11 for shipping and recaivlr

Other structures have been added on the property from time to time for storage, etc.

A separate large parcel of property contains the regional warehouse built in 19S2and parking space.

The "Annex" space on Yultee Street Is leased, and comprises assembly operations.

;05175

SR30798I -

Page 25: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

- -2-

SANITARY SEWERAGE————— •Originally, sanitary sewerage was disposed 1n septic tanks on the' property sincemunicipal collection had not extended this far. When capacity was exceeded, it

«

pumped to the open county ditch. This ditch, which was under County control, stjust south of the Company property, and ran northerly along the west side of the

Reading Railroad through a slice of the GE property along to the Mack Truck propiwhere It went underground, and then again In an open ditch Into catch basins undithe railroad bridge Intersection at Eighth Street. These catch basins were pipe-

underground for about 300 feet to Trout Creek. Trout Creek empties into theLittle Lehlgh River and thence on to the Lehigh River, Delaware River, and the

ocean.

In the mld-1950's, the City extended municipal sewerage collection to this area,and hook- In was made to a new sanitary pipe Installed along the course of the oldditch. Along with this, a new 6 foot storm sewer pipe was installed to collectstorm water and direct It to the Trout Creek outfall.

205176

flR307982

Page 26: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

SOLID WASTE-————~ . »>

Solid waste Is divided into three categories when It comes to discussing thepractices followed since 1946:

.' I. Rubbish, garbage, paper, cardboard, etc.•

> II. Chemical sludges, filter cakes, dust collector dirt, process residues.III. Liquids, oils, solvents, degreaser tailings, hydraulic fluids.

I. RUBBISH, GARBAGE. PAPER, ETC.

In the beginning, this type of material was accumulated on a rubbish pile at asafe distance from the plant and burned on a dally basis. This practice wascommon to most Industries at the time, If they could carry out open burnin*'

W• without jeopardizing neighboring property. Periodically, once or twice a year,this burning pit was dug out and the material hauled away to different localdumps.

About 1952, an Incinerator was constructed to better contain the burning.

This was operated until the early 1960's when attention started to focus onJ? particulate emissions. It was shut down and shortly thereafter dismantled.co .^, Rubbish was hauled away from the plant on a'regular basis after abandoningUDCD tha incinerator. For the most part, the hauling was done by contractors, to aco •

lesser degree by own truck.

In the late 50's to the mid 60*s, dump sites were:

Novak, Orefield.20517

Page 27: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

-4-

The first two sites are still operating, but the site is new. ••• A• \\Eventually, in the late 60's, arrangements were made with«.services to take the material to • .This

arrangement continued until 1978 when

Alternate arrangements were made with ' for rubbish to betaken to *" This service 1s currently handling our

rubbish. '— '- '' "" " "

Cardboard 1s now baled and sold to a reprocessing collection service.

205178

flR30798l*

Page 28: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

-5-

II. CHEMICAL SLUDGES ^

With the advent of plating in 1947, there were chemical sludges.to be handled.

More .Innocuous in nature, they were always segregated from regular rubbish, atleast so far as handling and storage. They were mostly nickel and chromiumhydroxides, cleaner sludges, filter cake, buffing dirt, etc.

Originally, this material was pumped out to settling ponds at the rear of the

property, where*the heavier solids could settle, and the clear TTquid overfloweda weir to the ditch, after pH treatment. This crude system operated until 1953when the waste treatment plant was built.

The new treatment plant was designed to the best technology of the time andoperated under a state permit from 1954. Solids were pumped out to a lagoon,replacing the old settling ponds.

' In 1971, the state OS questioned the impermeability of this lagoon wnic.i result;in the construction of the 240,000 gallon holding tank in 1972. A 933logical suwas performed at the time by Lehlgh University. ,..•;•

Eventually, the lagoon was filled in to make way for the plant expansion of

Building 10 In 1973.•

When the settling ponds and lagoon were in service, they were dug out annually athe sludge hauled away to landfill sites. Old records are not available to she*exactly when and where this material was disposed, but best recollections indicathat the same dump sites were used, , Novak in Orafie^

, and

205173

AR307985

Page 29: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

When the hauling contract was switched from Novak to in the early 70'.'the sludqe was collected daily from tfie waste treatment filter discharge and— » . •hauled to the - There has been no more ground impound.™of sludge on the plant property since the construction of the holding tank and

the filling tn of the lagoon to build Building 10.

This disposal arrangement lasted up until October 1978 and was with theconsent of the state OER.^ •....

With the closing of the site, sludge Is now being hauled in a 20 yardcontainer to . .This secure landfill site was recommended by DER and formal approval of ourapplication is pending. The service is being performed byunder a formal scavenger service contract.

O

Occasionally, 1n recent years, we have had the need to pump out sludge from thebottom of the clarifier In Waste Treatment to perform repairs. This service hasbeen performed by either . ., both licensed and

permitted environmental services. Disposal has been at their own facility or oucurrent landfill site.

Another special arrangement covers the disposal of roll filter paper from thenon-stick coating operation spray booths along with sludge from the cleaning of

paint lines and guns. This material is hauled about once monthly to thelandfill in , and Is covered by a state permit.

2051SO

AR307986

Page 30: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

III. LIQUID -—

Liquid wastes include waste oils (lubricating and cutting), hydraulic oils,dirty solvents (alcohol, thinner), degreaser clean-out sludges, etc.

From the beginning, they were evidently never dumped into the ground on theplant site. Instead, they were drummed, and when a sizeable load wasaccumulated, they were hauled away.

Less is known as to the destination of this material in years gone by, but in aT'probability, 1t was hauled to the same landfills as mentioned before.

Oils, of course, were commonly used in the past for oiling secondary roads,but we know of no such practice here.

JCurrently, liquid sludge is taken by The hauler indicatesthat the material will be reprocessed.

PCS's are present In the large power transformers. These units are serviced Sythe GE Service Shop here in Allentown. On the few occasions in the past whenthey were serviced, the Service Shop Itself took back the waste material involvecOtherwise, we follow the latest Instruction from EPO Letter 141, April 13. 1973.

205131

0R307987

Page 31: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

rccPHonol

RECEIVEDei VISION er uuo

SEP25I978 "

/*I. '

WASTS TasArazsT SLUDCS'_VI ANALYZED 5Y SRAMOT ASSOCIATES• •

Conoonenb Mg/*Kg (Wet Basis)

Iron. (Fe) 211

Cs-sser (CuJ . . 90.4• v.Chrooiua CCr •C*J 6330

Zinc CZr.) 173

N'lckel (Ni) 4670

Cadmium (Cd) /0.98

Aluninum (Al) 1110

Xercur? (He) 0.0823

Chroaiua (Hfix-iveler.c) <.OOS

Chloride (Cl-) 283

Sclfate (S04*) 24

Cyanide (oT) <.009Phosphate (PO4S) 219

Silica (£102) _____ 647•

Xitrata CIO3")

«iHNAC£M£NT

77\

2760

.004

«f?30798e

Page 32: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

TEST

In addition to tha chemical analysis by Brandt Associates on5/15/73, a leaching tast was performed in the General SlectrieFinishing Laboratory as follows:?ROC2D(/aS

10 grama of sludge was mixed with 200 mil of distilled water,adjusted to desired pH with dilute nitric acid or sodium hydroxideas required, shaken' well, and permitted to settle over night.The sample was filtered and analyzed for heavy metals on an atomicadsorption spectrophotaneter. Samples were run for pH 5.0 thru9.5 at 0.3 pS increments. The results, expressed in parts permillion represent the metals redissolved from the sludge at therespective

M2TAL pH———— g-° 5.5 770 7.5 3.0 3.5

Cr 1.36 1.22 1.23 1.20 1.13 1.14

Ni 1.23 0.41 0.35 0.33 0.31 0.30

Fa 0.53 0.72 0.70 0.69 0.72 0.55

Cu 0.07 0.05 0.04 0.04 0.06 0.07

2n 0.11 0.12 0.11 0.12 0.13 0.11

Cd NO NO NO NO NO NO

NO - not detected

R. F. GladuSNVIHONZ ENTAL ENGINEER

RFG:ch

September 11, 197320518

flR307989

Page 33: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

BRAND! ASSOCIATES, INC. "/:o/79CONSULTING ANALYTICAL CHEMISTS Report No. J40.31622

Date: 11/12/79Sample No. 540-304-547Received: 10/31/79

Mr. Robert Gladu Sampled By: CustomerGeneral Electric Company1801 S. 12th St.Allentown, Pa 18103

Clarissa L. Orafco. labID.: BAI

LOG SAMPLE ID ._ .Date__._T1me547 Wst Trt Sludge

BAI . .__. UN- ___ COMPLETED ____CODE ANALYSIS 'ITS ' DATE BY————!——|4f100.7 Aluminum TJS)* "TT77 CLTT130.7 -Cadmium " • 11/7 aO 0.2135.7 CalciumO. 7 Chromium

ISO. 7 Cooper'55.7 Iron0.7 Lead85.7 Nickel255.7 line320.9 Chloride330.9 C.0.0.

11/7 CLO 106&J .11/7 ttO 115011/7 CLD 109IT/7 CLQ 25601V6 CLO 19.6IT/7 CL0 T2800TT/7 aO 17.TT/2 ttO 742.T1/6 CLO 42900

380.9 pH (B) 11/6 CLD 9.T410.9 +6 Chromium (A) 11/5 aO 0.028420.9 Cyanide435.9 Nitrate as N460.9 Phenol470.9 Total P04 as P4S5.7 SIHca

TT/7 OH 0.83011/8 CLO ... 0.50.IT/8 CLO -0.43TT/2 CLO W.4TT/7 CLD 1240

500 Moisture .. (C) TT/6 CLO 73.6556.9 Mercury (A) TT/6 CLD 0.296550.9 Total Organic Carbon " 11/6 CMK SO.576.9 Sulfate as S04 - " 11/S CMK 72.7

* The analytical results, high COO and low TOC values, strongly suggest, butdo not prove the presence of significant quantities of a reducing agent present1n the sludge. The measurable cyanide values In sludge In the absence of any _known usuage of cyanide In the operations suggest the presence of thlocyanataradical. This further strengthened by Increased cyanide values In the leacnatadue ta doube to hydrolysis of the thfocyanate.

" 205T85(A) « mg/kg wet (8) « pH units (C) - Wt X

.———flfl307990-

Page 34: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

BRAND! ASSOCIATES, INC .CONSULTING ANALYTICAL CHEMISTS ' ^POrt No. 540.33301

Date: 11/29/79 .&Sample No 540-304-54

Received: 10/31/79Completed: 11/29/79

Mr. Robert Gladu . W°rt °rdan-dGeneral Electric Company1301 S. 12th St.Allentown, Pa 13103

SAMPLE ID Data547 Wat Trt Sample Leachate *

8AIffli .asatt _U_ m „'"I S±S W it/acu150.9 CapperT55.9 IronJ60.9 LsadTfS.9 Hlckel210.9 Silicon255.9 Zinc320.9 Oilorida

Cyanlda

_ — - w«fcTT/23 aD T.35TT/28 aD 0.08.11/23 CLO O.T8.TT/28 aO -;0i2TT/23 aD 116..11/23 CLD 32.n/23 ao o.oaii/29 ao o.oos — - — •11/29 ao 13.9

Leachate Procedure using 107.781 grams of sample to 2000 ml.

205186

Page 35: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

2869 Sandstone Drive / Hatfield, Pennsylvania 19440 / 215-822-8996Genera to r: G€ncral Electric-Allentown

Waste Identification:Lab Code: Metal Hydroxide Sludge

K007[ T«t ParameterTotal ResidueTotal Dissolved SolidsTotal Volatile SolidsC.H

Cyan i desOil & GreaseAmmon i a , M

.».

Cadmi unChromium /rr "*"*i.tiad

*••»! en *.j£iCHv-rl(.i ~ "

11 .,, ,._ ,__ rl'ri*atirtq Val'^e[gni labilityCorrosivityReactivityTotal Organic Halogens

fcj ———————

Total Analysis24.12%No riltraee6.22%613.4 ma/1731 mg/15.11 mg. 1

1.62 mg/10.49 mg/1274 mg/10.02 mg/1

/

214.1 -7/i0.576 - 7/1

32.450 Hter/10.06 mc/10.62 mo/1

JUL&. . 3J. _ . __..-LJLQ. -'3/11 ____J!2.i50 ?C/L.Not Acplicable

Waste is NOT icrWaste is :.'OT co:Wasta is MOT resMot 2et^rnr. -ad9,500 .-: t1,230 -T, L

^ £>VJ?

*•*" . •> . . — • - «•

. .

•— - - ——— - ——— -

itable, ser ?3.26rosive, per 75.26ctive, per "5.251

r

————————————— ' ' ——— 'INot Recuired 10.84% !0.39% :5.75 :2.2 mg/1 |13 mg/1 i

<0.6 mg/1

<"0.001 mg/l0.074 mg/10.80 mg/1<0.001 mg/L

A 7* mtj/1 < • --'

0.119 -ng/l,O.OOfl -^7/L490 sa l

-JIL.OJ 2,^7/10.012 ma/'

-iSSLv :*

I £T 1 \ «C J

. (g) (3)(g) (4)0.061 mc/L648 mg^i. o>9-_fl , 2Upl O 7378. 1 mg/ t

Page 36: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENTS

flR307993

Page 37: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

FULLERCOMPANY

July 3, 1975

Valley Disposal •R. D. #1Allentown, fa. 18102

Attention: Mr. Louis Novak

.Gentlemen: '

; As -per our telephone conversation of a few days ago/ thefollowing 'is a typical chemical analysis of the material ofwhich we are looking for a means of disposal.

CHEMICAL ANALYSIS(% Wt. Dry Basis)

Si02 ..................19%A1203 ................ 4%Fe203 ................ 4%CaO ..................60%MgO .................. 3% .

- KaO ..........;....... 0.5%Na20 ..:.............. 0.3%•S .................... 0.8%C .....<....... ....... 0.2%LOI .................. 3.2%C02 .................. 5.0%

The iron is in the .form, of ferric oxide. The bulk densityof the material varies from 60 to 65 pounds per cubic foot.

Because the facility for manufacturing this material isonly an experimental plant, the amount of disposable material.will vary. We do not anticipate manufacturing more than 10 yd.3.-a week and, on the other hand, there may -be periods of severalweeks. when no material will be made.

.We appreciate your, efforts in helping us to find a sourceof disposal of the material.

Sincerely yours,COMPANY/0

"Thomas R. Lawall, Manager'Process Group

TRL:hw 'R&D: Department

.124 BRIOGE ST.. CATASAUOUA. PA. 18032 TELEPHQN2: 21S-264-6OTI TWX: S1Q-6SVSS1S TEL«X: 084-7443 CABLE: COLPULLER• SUSSIOtARY OF GENERAL AMSRiCAN TRAMSPQaTATIOfSJ CORPORATION fl P H 7 Q Q I

Page 38: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

cc: James K. Rogers (2)Novak Sanitary Land Fill, Inc.

/1R307995

Page 39: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT 4

Page 40: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

August 30, 1-S77

Application 39-304-008Kline FoundriesLower Hacungie ToxmshipLehigh County

TO:John B. MoyerRegional Director

rnoifc ' E. S. Washko •>Division of Solid Waste ManagementReading Regional Office

Release application for plan approval to constructsand culler and associated rotoclone for emissioncontrol of operations at the gray iron foundry.

Discarded foundry sand will be collected and disposedof at existing permitted Novak Landfill.

be: Rdg..£ile. < E.

0R307997

Page 41: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENTS

SR307998

Page 42: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

CALORICA DIVISION Of "AVTHION COMPANY

TOPTON. PENNSYLVANIA

AMCA COOC 21* «83-2131

Mr. Emil WashkoDirector of Solid Waste ManagementDepartment of Environmental Resources16 Angelica StreetReading* Pennsylvania 19611

Dear Mr. Washko:

May 2, 1977

RECEF/ED

MAYS J877.MANAGEMENT

In accordance with directions from the Division of Solid WasteManagement/ the Caloric Corporation, Top ton, Pennsylvania, hassubmitted a preliminary sample of its waste sludge for analysisto M. J. Reider Associates, Inc., 107 Angelica Street, Reading,.Pennsylvania, a Department of Health approved laboratory (No.11-39). The results of the analyses follow.

The waste treatment process which generates the sludge beingevaluated, consists purely of physical - chemical treatment ofmetal finishing wastes. Details of the process have been filedwith the Department of Environmental Resources, and have "Beenawarded Permit No. 0676203 on. September 9, 1976. Briefly,however, the process treats approximately 0.28MGD of metal finishing rinsewaters with high calcium lime to pH 7-9, then a poly-electrolyte is added prior to flocculation, and the neutralizedwaste .is passed through a clarifier where the solids are settledout. The sludge from the bottom of the clarifier is drawn offperiodically into sludge holding tanks , and finally it is de-watered by passage -through a pressure filter. Sludge generationis presently estimated at approximately four (4) cubic yardsdaily. This sludge would be collected as necessary by anddeliverd to Novak's Sanitary Land Fill, Inc., R.D.fl, Allentown,Pennsylvania, which is a landfill licensed by the State ofPennsylvania. The composition of this sludge will be:

Alkalinity, as CaCO3 (1% slurry) 70 mg/1Arsenic 0.00003%Cadmium 0.00009%Chloride 0.016%Chromium . . ' 0.30%Copper 0.005%Iron, total . • 7.08%Cyanide 0.0003%Fluoride 0-.013%'Lead. 0:0016%Manganese . 0.035%Mercury . 0.000003%Nickel 0.61% .

piflR307999

Page 43: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

• Zinc 0.0051Nitrata as N 0.0002%Nitrogen, total 0.0069%pH 9.3Phenol 0.000%Soacific Conductance 1200.Sulfata 4.30%Selenium 0.0019%

i Phosphorus, as P 0.0013%Solids 26.75%Moisture 73.25%

The sludga will not contain acrolein, chloropicrin, dimethylsulfata, dinitrobenzene, dinitrophanol, nitroaniline, orpantachlorophenol. Furthermore, the prasanca of any chromiumis only•temporary. A closed loop avaporativa recovery systemhas bean installed and operational sinca April 13, 1977, whichwas designed to kaap all chromium compounds out of the wasta-watar. Within a few weeks it is axpactad that any fugitivechromium salts will ba flushed from tha wastawatar system.

A laachata test was also performed by Raider Associates on thapreliminary sludga sample which was submitted with tha followingresults:

Alkalinity, as CaC03 (phanolphthalaih) 15. mg/1Alkalinity, as CaCC>3 (methyl orange) 35. mg/1Arsenic . . 0.000 mg/1Cadmium 0.0007 mg/1Chloride 12.0 tag/IChromium . f **"*" * 0.0045 mg/1

•• Coppar / aiT*""""- ^ 0.0015 mg/1Iron, total / «uJC£n T"*"*-? °-092 "9/1 •

* Cyanide ' / 'c, -'** *ii£) / 0.000 mg/1Fluorida / "'' •<* ,„. / 3.70 mg/1

. Laad . / «fo»j '.• ., / 0.005 mg/1Manganese / . ^ #/'/ j 0.002 mg/1Mercury /"* ' \GP ^ I 0.0010 mg/1Nickal ' - J'«A,5ivr / 0.02S mg/1Zinc ^ * 17 0.0037 mg/1Nitrata, as N " 0.002 mg/1Nitrogen, total . 0.032 mg/1 - ••-pH 3.SPhenol .0.009 mg/1Phosphorus, as P . 0.007 mg/1Specific Conductance ' 320.Sulfata - - 146.9 mg/1Selenium 0.000 mg/1Total Solids 237.0 mg/1Suspended Solids 0.2 mg/1

Based upon these preliminary results, Caloric requests that itbe re-authorized to discharge its sludge at the Novak SanitaryLand Fill, and furthermore that Novak Sanitary Land Fill begranted permission to receive this sludge.

Very/truly ycfars,

,-„rry/H. islias_nvipMnmantal Pro//

Page 44: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

I*July 31, 1978

Application No. 36-318-02736-318-026

Caloric CorporationTopton Borough, Berks CountyJohn B. MoyerRegional Director

Era-11 S. WashkoDivision of Solid Waste ManagementReading Regional Office

Solid waste material generated from frit spraybooths 1s collected In barrels and disposed of as anIndustrial waste at the permitted Novak Landfill.Application for plan approval by the Bureau* of A1rQuality can be released.

be: Reading fileCaloVfc Corp.-Permit 100534 - Novak

G. ParksE. Washko

SR30800!

Page 45: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT 6

Page 46: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

OA.U1 U-47 ,•«'• » CC *WCA».TM OK

May S, 1978

SUBJECT: Novak Disposal SitePermit 1100534

, South Whitehall Township, Lehigh CountyTO: Emil S. Washko

Division of Solid Waste ManagementReading Regional Of'Carl F. GitschieSolid Waste SpecBethlehem Office

On 1 Hay 1978, a conference was held with,Louis J. Novak Jr., son of the owner and operatorof Novak Disposal Site located in South, WhitehallTownship, Lehigh County, at his request.

The Novak Company, doing business as Valley Disposal,requested information concerning the procedure for thedisposal of sludge material generated by Apollo Metals,Inc., 10014th Avenue, Bethlehem, for disposal on .theNovak Disposal Site, Permit 1100534.

This specialist will provide the necessary.information and modules for this application at thetime of the next visit to the site.

flR308003

Page 47: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT?

AR308001*

Page 48: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

i i *****»•_:•/• .o•«f«*TA•rraii y1.0. N&.

?kutx'l. 3li»x i( .n the IMC* a: left. If any of

ir ,1. HAME Or IH-!M

NOVAK L/iMlif-'ILLRlittl S WHITEHALL

'oSess ALLCriTauri, FA

IU>LOCATION RDtH S WHITEHALL

ALLEMTQUM, FA i

inform.i:<wn en the lj&*l i: if»coffeet. «t».l\-i a !in;lhrou-;'i ii »nd :up3'.v t e esrr««t informationin t>« aupropriate icetion bt sv*. II the tab*) isecmplete nrd correct. Icavt lumt I. II. tnd litbslew blank. If you did not receive « preprintedlabel, eomp.'st* ail itsnis. "Installation" mc<ni a»in !c ti:c where hazardous wi«t i» genera t:d,treated, stored and/or ditsOMd'o'. or « trtnt*porter'* prineiotl place of tutin<rw. PIUM referto the INSTRUCTIONS FOR FILING NOTIFI-CATION before computing this form. Theinformation requested *»•*:•« is requi'td by |4W(Section 30 1O c( skt Rotwr<.t Conservation andRecovery Ac').

ftp- . _FOR OFFICIAL USEj__________________

COMMENTS_________________f pi r't.'- '.•' i f •? u

f I'*INSTALLATION'S E*A I.O. NUMflCtt DATK r n -

. tt tfav )

I II M.U IMxy / ... "

...NAME OFreAtL*TIC». aB|«|Y r|«a ^

STREET OR P.O. BOX

CITY OM TOWN

a m n 1 1 1 1 n i n n 1 1 1 1 1 1 1 1ST. Zll> COOC

HI. LOCATION OF 1MSTA LLAT10N SSTMSCT OR MOUTE NUMMCRi i n inn n in 11CITY OR TOWNrrmfrmini 1 1 1 - 1 M . I - I i ST.

iizif CODE

IV. INSTALLATION CONTACT JggggJEffgpgTg S SJ ^NAME AND TITVE flw*. /?«£. 4 /O* tttfc) PHONE NO. (ores cad* A BO.)

I I I I I MV. OWNERSHIP

A. NAME or INSTALLATION'S LCCAL OVTNCK

I! Mo II I M M I M I I M M MM M M MMH. TYFC OF OwMtRSH" t(tnltr »>!• eypropriett Ittttrtnto boxl VI. TYPE OF HAZARDOUS WASTE ACTIVITY (enter "X"in the appropriate boxfulf

NON-FEDERAL

gA. CENEItATION Q 6. TRANSPORTATION (complttt H«m VU|r - rE.wBr,« ---

c. TREATf*TO«e/OIS»OSr O- UNOEKCflOUNO IMJECTtON

VII. MODE OF TRANSPORTATION (tnnsponeTt only - enfgf "AT"In rtc tppnpriate boxfaH J JiaDO. IfAlU Sc.MtCHV*Ar DO. WATER D*- OTHERu *» •* ••

VHI. FIRST OR SUBSEQUENT NOTIFICATION gS BSSS fT ff ^Mark "X" in ths appropriate box to indicate whether this ii f cur installation's tirn notification of hazardous waste activity or a subsequent nctif iiiicIf this ii not your first notiMeation. enter your Installation's 2?A 1&. NuT.bsr In the tpa«e prcvidsd below.

C. INSTALLATION'S CPA I.O. NO.

I A. rtfc»T NOTiriCATION n O. :UOS£3UXNT NOTjrfCATION feomptttt lt*m O

IX. DESCRIPTION OF HAZARDOUS WASTES., |?ita:» 50 ta the i-'rvtr:* o( t >: fsrm anil tirevida xh« requested information.

EPA ?om 3707 12 IOC5J CONTINUE ON HEVSRSe

Page 49: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

OF HAZARDOUS Vf AST5S (continued from frontj ggy^ZAROOUS WASTES FROM NON-SPECIFIC SOURCES. Snter the four-digit number from 40 CFR Part?SV.3lto each l«ad haxantou* ' I <»Xj*te from non— specific sources your installation handles. Cite additional sheets if necessary. ' £

— — ^— — • — —— — — — — - —— - —————— S

nn l»

•____le)

II*• . 1«

12

3 fcV

1 II 3. HAZARDOUS W/AST5S FROM SP2CIPIC SOURCES. Snter the four-digit number from 40 CFR Pan 281J2 for each listed hazardous waste fromj ssecifte industrial sources your installation handles. Us* additional sheets if necessary.

IS

2S

14

Oi.2S

IS

2t 22

2Sn'« ——22.

IT

ii.— '•23

•L.

n

la

24

10

y

C. COMMERCIAL CHEMICAL PRODUCT HAZARDOUS WASTES. Enter the four-digit number from 40 CFR Part 231.33 for each chemical sua>stance your installation handles which may be a hazardous waste. Use additional sheets if necessary.

Jl37

" • •*43

n 34 as

41

n4?

as

4*

ffl>. LISTED INFECTIOUS WASTES. Snter ths four—digit number from 40 CFR Part 281J4 for each listed ruizardous wasts from hospitals, veterinary

, hespitsls. medical and research laboratoriei your installation hsndles. Uie additional shwts if necesary.1 SO 31 33n 34 aat S. CHARACTERISTICS Of NON-USTEO HAZARDOUS WASTES. Mark "X~ In ttw boxss corresponding to the characteristics of non-listed1 razardous wastes your installation handtss. (Se*4QCfa?ara2St t-23M4.J

* *

D*» IOVNITABLSJ D2* CO»I»OSIV« ' . DS. REACTIVE * ' D4* TOXICI (0001) ' . (O002| ' . • |aOOS| (OOOOf

certify under penalty of few fftfff / kart personally examined and am familiar wftft the Information submitted, {a this and sH •< '-J attsched documents, and that based on my inquiry of tkose individuals immediately responsible for obtaining the information,! / bellere thst the submitted information is true, accurate, and complete. I am aware that there are significant penalties for sub-mitting false information, including the possibility of fine and imprisonment.ISNATWMC NAMK at omciAi. TITLE (typ* of print! DATE Sian r1*iJ>A Fersr37CO-12 (6-80) REVERSE

I

-IAR308006

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ATTACHMENTS

flR308007

Page 51: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Phone 395-f

VALLEY DISPOSALDiv. of Novak Landfill Corp.

MODERN SANITATION EXPERTSP.O. Box RO. 1 Allentown, Pa. 18102

Dec. 30, 1981

Mr. John H. Parsons

Wernresville, Pa.

Dear Mr. Parsons:I am writing this letter in reference toour conversation concerning your letterof Dec. 17» 1981, on the monitoring wellsfor Hazardous Waste Dumping.

There is no further need for us to persuea permit to dump Hazardous, since we nolonger service accounts generating them.

Please letter this letter serve as officialnotice to cancell any applications we havefilled out in the past, concerning hazardouswaste disposal.

If there are any questions please call.

IN/sn

flR308008

Page 52: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENTS

flR3Q8009

Page 53: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Departcent of Environmental Resources

Ifcrrstown, PA 19401215 631-2420

March 22, 1°<33

Mr. Richard £. KranzManager of EngineeringF It M Schncfer Brewing CocpanyP. 0. Bo:c 2568Allentown, PA 18C01

Dear f-*r. Kranz:

I an in receipt of a letter froa you dated rJarch 11, 19S3 concerningcorrespondence received fron csrr Uernersville Office authorizing the dispose! oflabel pulp ndised with spent rfiatocaceous earth.

This letter does not say this waste can be disposed of at the rtovak SanitaryLandfill. Therefore, it is necessary that any disposal site which wishes toaccept this vaste subcit a nodule ITo. 1 to tliis office in order to obtainapproval to accept this uaste.

This rrjdjle I'o. 1 can be submitted by tiie flovelc Sanitary Landfill but I will bechecking with our operations staff to coke sure that there are no cnjoroperational problems At this facility.

When we first got involved with sites in Lettish Coucty, an inspection wasconducted at the JTovak Sanitary Landfill and it was noted that* tliere is grosscontamination of a doungradi£nt nonitoriii veil end there is leechate beingdischarged off of the landfill site. Because of these problems, I a= not infavor of grantins an approval for this waste to gp to that particular landfillsite unless our optjrations staff advises oe that there are no longer any cisjoroperatioiuil problems at this facility.

If you have any other questions concerning this, please 5sel free to contACt ne.

Very truly yours,

C-: u.Solid vZasts Facilities Supervisor

Re JHOS3

Page 54: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

THE F. & M. SCHAEFER BREWING CO.LEHIGH VALLEY BREWERY, P.O. BOX 2563. ALLENTOWN, PA. 13001 • (215) 395-4311

March 11, 1983OUR 142NO YEAR

Mr. Larry LunskCommonwealth of PADept of Environmental ResourcesNorristown Regional Office1375 New Hope StreetNorristown PA 19401

RE; Residual Waste Landfill IngDear Mr. Lunsk:

Attached 1s a letter from your Wernersville office that authorizesthe disposal of label pulp mixed with spent dlatomaceous earth. Thiswas authorized to reduce the label pulp pH to a level that was classi-fied as non-harardous. When this letter was written by your officewe were hauling our residual material to the same landfill that youare now questioning. I assume that at that time they had the appro-priate permits for residual waste or your office would not have author-ized the procedure as stated in the letter. 4

My only intent is to dispose of our waste in the most costeffective method that complies with O.E.R. procedures.

Please advise If I can be of further help.

RECEIVEDDIVISION 0?SC:.OVYASTP

Richard E. KranzManager of Engineering

jlhatt.

AR3080II

Page 55: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

Reading Regional OfficeUernersville, Pennsylvania 19565

Telephone 215 678-5657

August 28, 1981

Mr. A. S. Vanek, P.E. 'Supervisor of Engineering -F & M Schaefer Brewing Co. "" • •Lehigh Valley BreweryF. 0. Box 2568Allentown, FA 18001

Dear Mr. Vanek: * .

Your correspondence dated August 27, 1981, regarding neutralization ofORMrE (label pulp) has been reviewed by representatives of this office.

The proposal to mix the label pulp with spent filter powder (DE) syrupcombination in a neutralization process Co reduce the label pulp from pE 12*5 toapproximately pH 7.0 is acceptable to the department. ir---'

»-

This neutralization process will result in the label"pulp not exhi-biting the .characteristics of corrosivity and therefore not meeting thedepartment's definition of hazardous waste.

If there is any question regarding the above, please do not hesitate tocontact this office.

. ..- Sincerely yours,

Leon L. KuchinskiRegional Solid Waste Manager

LL&fh

dc:

Page 56: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

f T&ste&jgfr.'1^ "_"" INTER-OFFICE COMMUNICATION

•a?**''>••*TO: L. ?ray DATS: S/7/S1

i

FROM: A. S. Vanak COPY TO: 0. Macssar

SU3JSCT: Aegroved Industrial Waata Haulars

As per my conversation with Mr. Leon Xuchinski, ?A Dapt. ofSnvironaantal Rasourcas (215-573-5S57), only Mr. L. Novak(Novak13. Landfill and Vail ay Disposal -haulers) is ?A approved.

Mr. B. Reasar (Raasar's Autoaatad Rafusa Systeas) is anapproved hauler'but'roast usa Colabrookdala Landfill or anotherapproved landfill. .Christsan Landfill is not approved forindustrial wasta par Mf.';L. Kuchinaki. •/'.'."

L. S. Vanek. ,- •' •: •'••' . • ' • ,

. . • • ' - - . - , . - . - - - '

.:..— ':-••••'

?U?.CHASI::G-

ca ci f«: «

Page 57: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

coM^W

Depsrtneht of Environnental Resources

1375 :few !bpe StreetI'orristown, PA

215 631-2420

July S, 1933

Mr. Louis NbvakfJovaU Sanitary Landfill, Inc.R.D. tflAllentown, ?A 131Q2

Dear ?Jr. Ifoysk:

The Industrial Uaste >todulc i7! concerning die disposal of bottle label pulpgenerated by the EI-W Schaeffer Brewing Corpany at your landfill has beenreviewed.

According the analysis information subnitted as part of the Module #1, theappears to be hazardous because tine leachate aialysis indicate the concentrationof lead to be 16.6 ml per Vilograa. Therefore, this vraste cannot be approvedfor disposal at your landfill. If you vere accepting this wnste in the* past,you cust cease t±»e acceptance of this waste upon receipt of tiiis letter.

It: you 1'<avc any cuestions, plense contact ae.

Ver/ tnily yours,

H. UEJSKSolid Uastc Facilities Supervisor

cc: R.E. Kranz, RW Schaeffer Brewing ComoanyRe 2SICO

Page 58: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

NOSRISTOWN» *

CR>SWM.*14t R«. 4/81

PA DEPARTMENT OF ENVIRONMENTAL RESOURCESBUREAU OF SOLID WASTE MANAGEMENT

MODULE 1OAT8 PREPARED

OATS REVISEDDEPARTMENT USS ONLY

REQUEST FOR APPROVAL TO TREAT, STORE, OR DISPOSE OF A HAZARDOUS OR RESIDUAL WASTE STREAM

SES INSTRUCTIONS 3EPOR3 COMPLSTtNQ THIS FORM

I. GENERAL INFORMATION (must be completed by TSO facility)

A. Treatment, Storage, or Disposal Site

1. Name of facility Novak Sanitary Landfill Inc._______________

Address ______RD 11 , Allentwon PA 18102

Municipality South Whitehall Township County Lehlqh

2. Identification number (If applicable) |p| At Dl 01 71 911 1 61 01 81 41 21

3. Solid waste permit number(s) for treatment, storage or disposal facility to be utilized

4. Facility contact person

Name Lou Novak • Title PresidentPhone no. 215/395-6251

3. Generator of the Waste

1. Name of company The F & M Schaefer Brewing Company________

Mailing address P.O. Box 2568. Allantown PA 18001________

Location of site if differentfrom mailing address Rt. 22 & 100, Fogelsville PA 18051____

Municipality Fogelsvllle___________ County ______Lehlgh

2. If a subsidiary, nameof parent co. _____The Stroh Brewery Company___________

3. Identification number (if applicable) iP I A J O l f l l S l f i l f i o

4. Company contact person

. Name R. E. Kranz___________________ title Mgr. of Engineer—^—^___^^_ . __ _ ^ —~»>vPhone no. 215/395-7533______

flR308015

Page 59: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

DATE PREPARED

DATE REVISED

MODULE 1, PAGE 2

DEPARTMENT USE ONLY

II. WASTE DESCRIPTION (Must be completed by Generator)

A. General Properties

1. pH range 7 to fi_____ (based on past analyses or knowledge)

2. Physical state:i

a.* D liquid (less than 20% solids by c. C solid (equal to or greater than 20%dry wt. or fiowable) by dry wt. and non-flowabie)

* *

b. O gas (ambient temperature and d. O Check here if c. above was checkedpressure) and waste contains free liquids.

3. Physical appearance:

Color Gray_____________ Odor Papery______•_________

Number of solid or liquid phases of separation _____________

Describe each phase of separation soggy paper labels with some free water

4. U.S. DOT proper shipping name UN/NA number, and hazard class (if applicable):

5. Typical volume of waste to be shipped to treatment storage or disposal facility:

a. Monthly . 78 _______ q&xf tons (circle one)

b. Annually 936 _____ ___xgaJ., tons (circle one)

6. Treatment or disposal frequency: 94 ____ p times per year; D one time

7. Current volume. to be shipped to treatment storage or disposal facility 18 tons/wk{p(., tons (circle one)

8. a. Is the waste a hazardous waste as defined in 75.261? D .Yes CJ No

b. If yes, describe the hazardous waste according to its description and hazardous wastenumber in 75.261.

9. Has the waste been delisted as a hazardous waste by OER? 5^ Yes O No D N/AIf yes or N/A, check the appropriate box(es) in Item 10.

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MODULE 1. PAGE 3DATS PREPARED

DATE REVISEDDEPARTMENT USE ONUY y J

10. Is the waste a residual waste or a delisted hazardous waste? & Yes D NoIf yes, check the following box(es) as applicable:

Q discarded commercial chemical product O process wasteQ tank bottomO off-specification species D infectious waste

Q baghousa dustO manufacturing chemical intermediate Q wastewater treatment plan residue (Industrial)CT still bottomQ spent catalyst Q wastewater treatment plant residue (sewage)O flyash Q water treatment plant residueQ bottom ash O incinerator residue

D acid mine drainage treatment sludgeD slag O spill residueO foundry sandD S02 scrubber sludge XX other (specify) Bottle label pulp________

3. Chemical Analyses — Please attach the following:1. Tha results of tha total analysis of the waste as described in tha instructions.

2. Tha results of tha leaching tests as described in tha instructions and tha leaching method.

3. A description of tha sampling method. composite sample -

4. Tha range of'concentrations of the constituents based on knowledge or past analyses.

C. Process Description and Schematic — Please attach the following:1. Tha substantiation for a confidentiality claim as described in tha instructions, if portions

of tha information you have submitted are confidential.

2. A detailed description of tha manufacturing and/or pollution control processes producingtha hazardous or residual wasta as specified in tha instructions.

3. A schematic of tha manufacturing and/or pollution control processes producing thahazardous or residual wasta as specified in the instructions.

III. Liner Compatibility Evaluation (must ba completed by TSD facility)

. Attach tha results of the liner compatibility evaluation or supporting data as specified in theinstructions.

AR3080I7 .

Page 61: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

C. PROCESS DESCRIPTION

The machine 1s Identified as a "Soaker". Returned beer bottlesare carried thru the machine dipping them Into various hot caustic(NaOK) compartments. The action of the caustic pH 12+ 1s to loosenthe labels and letting them collect 1n the bottom of the compartments.Periodically the compartments are cleaned out and hauled to a disposalsite.The wasted labels were classified as hazardous because of causticity,however, with D.E.R.'s approval the pulp 1s now being neutralizedwith DE & syrup.

HR3080I6

Page 62: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

OATS PREPARED

DATE REVISED

MODULE 1, PAGE 4

DEPARTMENT USB ONLY

IV. PROPOSED TREATMENT STORAGE, AND/OR DISPOSAL METHOD (must be completed byTSD facility. Usa additional sheets if necessary.)

' A. Proposed Treatment Method

B. Proposed Storage Method and Length of Storage

C. Proposed Disposal Method• Step Ii One foot layer of clean clay soil.Step 2: Label pulp will be spread evenly by 2 -.Step Ji Ona foot of clean clay soil over top.

V. ALTERNATIVES TO PROPOSED TREATMENT AND/OR DISPOSAL METHOD (must ba completedby generator. Usa additional sheets if necessary.)

A. What Other Treatment, Disposal, Recycle, Reuse, or Reclamation Method(s) Can ba Used?Briefly describe viabta alternatives to your proposal. -

B. Why was the Treatment and/or Disposal Method in Section IV Chosen?

AR3080I9

Page 63: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

GATE PREPARED5-9-BS

DATE REVISED

MODULE 1. PAGE S

06PABTMENT USE ONIY

VI. CERTIFICATION OF GENERATOR

I certify under penalty of law that I have personally examined tnd am familiar with the information submitted inthis and all attached documents, and that based upon my inquiry of those Individuals immediately responsible forobtaining the information, I believe that the submitted information is true, accurate and complete. I am aware thatthere are significant penalties for submitting false Information. Including the possibility of fine and imprisonment.

Name of Responsible ..M c . M/.runv « . MOfficial JAMES J . H c E V O Y T ^ e Plant ManagerOfficial _____________________________________ _________

Signature \xte. —1-»- \>\V-vJi'M ,<——\__________ Date C^vol >/ \ • v ^ " •

T>k«n. nworn tnd tubierlMd bifer* i

NOTARYSEAL

) /T ° //rK< o- s L o u- scLIjs+ j —

/MASY ANNE STOKES. Natary Public. FcjcJsvate. lehish Co«nry. Pa.

% Commission Expires May 28.1984" •

VII. CERTIFICATIOIVI OF REGISTERED PROFESSIONAL ENGINEER FOR TREATMENT STORAGEAND/OR DISPOSAL FACILITY :

This is to certify that I have personally reviewed all engineering information contained in the accompanyingmodules, drawings, specifications, and other documents which are part of this application and that I have foundit to .be of good engineering quality, true and correct, and Is in conformance with the requirements of theDepartment of Environmental Resources, and it does not. to the best of my knowledge, withhold informationthat Is pertinent to a determination of compliance with the requirements of the Department.

NOTICE: It is an offense under Pennsylvania Crimes Code to affirm a false statement in documents submittedto the Department.

Name AnaLn LJ.

Signature

Date fHA.y X/. Jf f>3

Address I L ~) u 2-s/ntZPROFESSI

r/jt?Phone No.

HAROLD W. CAMPBELLSEAUOfV"

Page 64: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Hesa Environmental Laboratories304 Park Av<*nue

Strou<Jsbur3r Pennsylvania 13350

SPA LJO * 33-116

• 5/02/33

Job Number : 03213.00

F 3 M SCHAEFER BREWING CO.ROUTE 22 S US 100PO * 12173 C4FOGEUSvILLE» PA 13051 .

Number : 2715 (Continued)

Test Description ' Result Method

.045 Seleniua 0.10 MG/KG 1011050 Silver * 1.24 MG/KG 101'.022 Copper • 3.73 101.062 MOLYBDENUM <1.66 MG/KG 101 .iO?5 Zinc 15.3 HG/KG 1010054 SULFZDE '<1.76 MG/KG 137

JOTS : All Results expressed in ad/1 unla-ss otherwise, specified

AR30802I

Page 65: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Hess Environmental Laboratories*J304 Park Avenue ' .

Stroutittbur.tr Pennsylvania 18360

. EPA "; Lrfb * 38-116

5/02/83

.Job Nut.be r : 03213.00y-

F t K SCHAEFER BREWING CO.ROUTE 22 t US 100PO t 12178 C4 . .FOGELSVILLE t PA 18051'

.Saeple -Number $ 2715''

'.Date Sampled JTine Sampled * —— -Sailed Bv . CLIENT

."Sample Tvpe : SOLID WASTELocation « -——

Date Received : 4/11/83 --

Date Tested 5 ——•

* ' **•* "

test Description ' Result Method

.0023 SOLIDS TOTAL . V5.5Z * 139-.0104...,.- SOLIDS VOLATILE " 1.03Z ' —— •.0925 PH .(UNITS) ' 7.8 135. 0024 CYANIDE - <0.084 HG/KG 407•2018 . OIL AND GREASE 3970 HG/KG 413...1010 Barium • " ' 6.64 KG/KG • 101,1005 Arsenic . 0.09 MG/KG 101:4015 ' Cadffiiun " .0.83 MG/KG 101.1020 . Chrooiuo ' . . 4*15 MG/KG 101._1030 Lead •" 16.6 MG/KG 101•1035 MERCURY . <0.03 MG/KG 103..1016 NICKEL ... <lt66 MG/KG 101

- . » ; • • • • • - • • - . . ''-. NOTE * All Results expressed in &£/l unless otherwise specified

Page 66: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

*

Hess £nv!rcnme:Tt2i Laboratories.*} * ' KminmmcntalisisandLikirntoryAnnlysts.

[W Park Avenue. Stmudsburg. IVnnsyivnnia'IVk-phone (717) 421-1550.

Hay 6, 1933

7 & M Schaefer Brewing CompanyXoute 22 & U.S. 100Attn: Charlia 3aird/PO # 12173 C4Foagalsvilla, PA 13051

RE: Sample #2715 (Solid Waste)

This sample has a pH value of 7.3 which falls within the pErange of 2 - 12.5, therefore by definition, this sample does notextiibit the characteristic of corrosivity. In addition this sampledoes not react, explode or generate toxic gases when mixed with water.It is relatively stable and does not contain cyanide or sulfide. Thisvasta can therefore be considered non-reactiva.

Sincerely

W. Prosser, Jratory Director

GH?/kag

Page 67: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Hess Environmental Laboratories304 Park Avenue

Stroudsbur.tr Pennsylvania 18360•

EPA Lab * 38-116

5/06/83

Job Number : 03213.00

F t M SCHAEFER BREWING CO.ROUTE 22 * US 100PO * 12178 C4FOGELSVILLEf PA 18051

Sample Number I 3015

Date Sampled * —-—•-• • Time Sampled . J -——

Sampled By ' : CLIENT

.Sample Type t SOLID WASTELocation

Date Received : 4/11/83

Date Tested : ———

Test Description Result Method

0925 ' PH (UNITS) 7.8 1352018 . OIL AND GREASE 7.2 4130039 NITROGEN/AMMONIA 30.2 4122910 Phenols 4020 UG/L 2090024 CYANIDE <0.010 • 407 .1086 ANTIMONY - <0.20 . ——1005 .Arsenic <2.0 UG/L 1011010 ' Barium 0.55 • 1011015 Cadmium .0.03 101 ^ o1020 Chromium 0*05 . 101 . . ' QQ1009 CHROMIUM/HEXA <2.0 UG/L 101 O1030 Lead 0.10' ' 101 . C*3

-£CNOTE t All Results expressed in mg/1 unless otherwise specified ex

Page 68: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

4 ' . 304 Park Avenua* ' . Stroudsburs* Pennsylvania 13360

£PA Lab * 33-116

3/06/33

Job Number : 03213.00

F S M SCHAEFER BREWING CO.ROUTE 22 I US 100PO * 12173 C4FOGELSVILLE, PA 13051

Sample Number • 3015 (Continued)

Test Description Result Method

1035 MERCURY <0.20 UG/L 1031016 NICKEL 0.05 1011045 Selenium ' 4.5 UG/L ' 1011050 Silver ' 0.04 1011022 Copper 0.09 1011062 MOLYBDENUM . <0.04 . 1011095 Zinc • 0.39 101'2004 . TOTAL ORGANIC HALIDE 44 ——3011 COD 3400 4062006 TOTAL* ORGANIC CARBON 1740 ——0104 SOLIDS VOLATILE 2310 ——3930 . SOLIDS DISSOLVED 6160 139

NOTE : All Results expressed in aa/1 unless otherwise specified_ , • •

Comment : *EP TOXICITY LEACHATE

Page 69: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

/'Jtt CO-

Departrsect of Dnvironaer.tal Resources

1375 r&r Itopc Street?Jorri3town, ?A V

215 631-2420

August 2, 1933

Mr. Lcuis JtovakHovak Sanitary Landfill, Inc.RD '?!Allenccwn, PA 18102

Dear Mr. Ibvalc

ai-fditioosl information Involving the disposal of IB tons per week of bottlelabeled pulp Qenerated by the FK1 Schaefcr Brewing Cocpnny has be«jn reviewed byour staff. A teqpcrary epprovxil for the disposal of this uastc is bcin*. grantedto you for e four (4) tsxitii period bogicnint; with the (into of this letter.During chis tic« the generator of this vaste ta st sake other disposalarrangesosits . The reason fbr this decision is that we feel that your site isscill not acceptable for the regular disposal of residual waste in nr&ition tocunicipal waste. This is due to operational probleaa concerning oKitA inatigiof downg adient uonitoring veils and improper Isschatc canagenent at the land-fill site. Uheil I asa escurcd by our operations field staff tl-sat your ImdfSlllis beinji q«rated in compliance with Chapter 75, our Solid Uaste JtmageoKxtRules and Regulations, co lurther cansidsrction vill be given to any ounicipalsewage sludge or xesidual type waste stress to be disposed of at your sits.

If you havts any other questions ooncarning this, please fbcl /rec to contact ne.

Very truly yours, ":;;

a. T»SK,Solid Waf.ta Fncilltics Siipervisor

cc: rtc. R. E. KrsnsMr. Joe PocponiKe Q22S

flR308026

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Hess Environmental Laboratories,Environmentalists and Lab304 Park Avenue. StroudsTelephone (717) 421-1530.

... -.Environmentalists and Laboratory Analysts. fcJJjEpgffi C/7/?/oro' '.'=•-304 Park Avenue. Stroudsburg. Pennsylvania 18360. A/v

July 21, 1983

Pa. Department of Environmental ResourcesBureau of Solid Wasta1375 New Hope StreetA tea: Mr. DineshNorristown, PA 19401

HE: HESS SAMPLE NUMBERS 2315 AND 3015

Dear Mr. Oinesh: «

Tha methods which our laboratory utilizes in tha performance ofall Pennsylvania Module 1 (ER-SWM-14) tasting ara listed on theenclosed table.

Tha Solid Wasta Sample 2715 was subjected to tha EP ToxicityTest Procedure. Tha initial pH of tha sample was 7.3 and it wasadjusted downward to a pH value of 4.3 with 0.5 N Acetic Acid. Ablank was also processed by this method. Tha total time the wastewas subjected to this procadura is 24 hours.

Sincerely,

David C. ScholtzAssistant Director ofLaboratory and Operational Services

DCS/kag

A Division of R. K. R. Hess Associates. $R308027

Page 71: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Hess Environmental Laboratories.Environmentalists and Laboratory Analysts.304 Park Avenue. Stroudsburg. Pennsylvania 18360.Telephone (717) 42M550.

The methods which our laboratory utilizes in the performanceof all Fa. module 1 (ER-SWM-14) testing Is as follows:

Total Solids Std. Methods 14. Edition. Method 208GVolatile Solids Std. Methods 14 Edition. Method 208GpH 40 CFR Part 250 (Mon. Dec. 18, 1978),

Part IV, Appendix IVCyanide E?A SW-846, Method 8.55Oil and Grease Std. Method 14 Edition. Method 502DArsenic EPA SW-846, Method 8.51Barium EPA SW-846, Method 8.52Cadmium EPA SW-846 .Method 8.53Chromium EPA SW-846 .Method 8.54Lead EPA SW-846 .Method 3.56Mercury EPA SW-846 .Method 8.57Nickel EPA SW-846 .Method 8.58Selenium EPA SW-846 .Method 8.59Silver . EPA SW-846 .Method 3.60Copper EPA-600/4-79-020, Method 220.1Molybdenum EPA-600/4-79-020 .Method 246.1Zinc • EPA-600/4-79-020, Method 289.1Sulfide EPA-600/4-79-020 .Method 376.1

LEACHING TESTS - EP Toxicity. Leachate Test Procedure

pH EPA-600/4-79-020, Method 130.1Oil and Grease EPA-600/4-79-020, Method 413.1Nitrogen/Ammonia EPA-600/4-79-020, Method 350.2Phenols EFA-600/4-79-020, Method 420.1Cyanide EPA-600/4-79-020, Method 3.55Antimony EPA-SW-846, Method 8.50Arsenic EPA-SW-846, 'Method 8.51Barium EPA-SW-846, Method 8.52Cadmium EPA-SW-846, Method 8.53Chromium EPA-SW-846, Method 8.54Chromium &• 6 EPA-600/4-79-020, Method 218.4Lead EPA-SW-846, Method 8.56Mercury EPA-SW-846, Method 8.57Nickel EPA-SW-846, Method 8.58Selenium ZPA-SW-846, Method 8.59

AR308028C _t U vr v — A. Division of R. K. R. Hess Associates.

Page 72: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Silver EPA-SW-346, Method 3.50Copper EPA-600/4-79-020, Mathod 220.1Molybdenum EPA-600/4-79-020, Mathod 246.1Zinc EPA-600/4-79-020, Mathod 289.1COD EPA-600/4-79-020, Mathod 410.1TOG EPA-600/4-79-020, Method 415.1Volatile Solids EPA-600/4-79-020, Mathod 160.4Dissolved Solids EPA-600/4-79-020, Method 160.1

Total Oragnic Halogen - Absorption with mierocauloaetricdetection.

AR308029

Page 73: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

ATTACHMENT 10

Page 74: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Tyler. Texas 75/10.

Tyler PipeSubsidiary ofTyler Corporation

January 27, 1981

Ronald F. KlinikowskiSolid Waste Facility SupervisorDepartment of Environmental ResourcesBureau of Solid Waste ManagementWernersville, PA 19565

Dear Mr. Klinikowski:

The solid waste produced at the East Penn Foundry andidentified as the "Grinder and Resin Sand Muller Waste"was analyzed in our laboratory using the appropriate EPAmethods for chemical analysis.

The analysis of the Solid Waste itself was by nitric aciddigestion for extraction of the metals.

Sincerely yours,

Bobby LTCXSmithTechnical Services Manager

BS/nm

EnclosureAttachment B.4.

cc: T. StewartT. Brungard

•A'R30803I

Page 75: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

Tyitr. Texas 75710.

Tyler PipeSubsidiary ofTyler Corporation

January 27, 1931

Ronald F. KlinikowskiSolid Wasta Facility SupervisorDepartment of Environmental ResourcBureau of Solid Waste ManagementWernersvilla, PA 19565

Dear Mr. Klinikowski:

The solid waste produced at tha Hasidentified as tha "Grinder and Readwas analyzed in our laboratory usirmethods for chemical analysis.

Tha analysis of tha Solid Wasta itsdigestion for extraction of tha mat

Sincaraly yours.

Bobby L.C/smithTechnical Sarvicas Manager

BS/nm

EnclosureAttachment 3.4.

cc: T. StewartT. Brungard

4R308032

Page 76: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

LABORATORY ANALYSIS REPORTjCaboMtorjes-c~~..™ LUI Si""11*Nu G l24732

Date RsDorW'j .1/12/8Date Submitted 12/23/S

Sootts Stevens- 8-. McCc-y Inc. P. 0. No. Le&nerd J. U«

Tyler pipe fount/ry wastes Attn: Lt«n WackelSaraoles coll*ct.*d 12/23/80 by • LW/PG

ANALYSIS AS RECEIVED LAB CODE

Arsenic 1.82 OUHS 145-54-0:Cadaiiuffi < 0.1 DOSJ ' 149-54-03Chraaium 24. ppm 1S1-54-OJCopper 40.4 ppm 153-54-01Lead 62. S pom 155-S4-01Mercury < 0.05 ppm 1S9-S4-0:Molybdenum < 10. ppm 160-54-01Nickel < 5. ppm 161-S4-OJSelenium (Fluorimetric) < O.S pom 164-54-02Silver < 2. ppm 164-54-01PH 11.47 200-24-CCOil (Soxhlet Ext.) . 0.11 % -236-23-01Total Organic Carbon 0.164 2 by wt. 999-20-0:Phenolics . 2.33 pum 999-23-02Ammonia Nitrogen <25.0 pom 979-23-CCTotal Cyanide .39 oom 999-23-0

THE above analyses were performed on a composite of four foundry wastesubmitted by Len Ueckel. The composite was prepared by LLI as

Core butts 10% by volume collected 12/23/30 1200 bx LW.-TGCupola bottom 102 by volume collected 12/23/80 1200 by LU/PGBurnt sand 40 '/. by volume collected 12/23/80 1200 by LU/PGSlaq ' 40S by volume collected 12/23/80 1200 by LU/PG

The pH was performed on a 5 % solution.

Grinder and Resin Trace AmountSand MullerWaste See attached analysis sheet

Samp Prep 10.00

INV TO- Spotts Stevens & McCoy In 26S.OO 154 Respectfully submittedLancaster Laboratories. Inc.

MAIN LABORATORY:2425 New Holland Pike. Lancaster, Pa. 17601 • (717) 656-2301 CN , (U&A*FRANKUN DIVISION: r .... - U.

? P.O. Box 467, 3 Bamett Ave.. Waynesboro. Pa. 17268 - (717) 762.9127 J- Wilson Hc• Instrumental Analxsii Prc !«

flR308033

Page 77: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

LABORATORY ANALYSIS REPORTj> Lancaster£abmtanes. u.i «—i. *. s 1=4732

Date Reoort«'J .1./12/B1Date Submittsd 12/">'V3C

Sootts Stsvens & McCoy Inc. P. 0. No. Lsc-n&rd : Jl-sc

Tylar pips fauntii'y w^stas Attn: L*-n WackalSaraolas call«»cl*d 12/23/80 by LW/PG

ANALYSIS AS RECEIVED LAS CODE

Araanic 1.32 aoa 145-54-02Cadaiiuia < 0.1 DO?-- ' 149-54-01Chraaiuia 24. ppm 151-54-01-Copoar 40.4 oom 153-54-01-Lead 62.5 corn 155-54-01Msrcury < 0.05 ppm 1S9-S4-02:Molybdanum < 10. ppm 160-54-01Nickal < 5. ppm 161-54-01Salanium <Fluorimatric) < 0.5 pom 164-54-03Silvsr < 2. ppm 164-54-01pH 11.47 200-24-00Oil (Soxhlat Ext.) 0.11 % -236-23-01Total Orqanic Carbon 0.164 S by wt. 999-20-02Phanolics . 2.33 ocm 999-23-02Ammonia Nitroqsn <2S.O pom 979-23-COTotal Cyanida .39 oom 999-23-02.

'THE abova analyses wara parfortnad on a composite of four foundry wastsutmittad by Lan Uackal. Tha composita was prepared by LLI as fo-llc-w

Cora butts 10% by voluma collscUd 12/23/30 1200 b/ LW/PGCupola bottom 10% by voluma collsctsd 12/23/80 1200 by LU/PGBurnt sand 40X by voluma collected 12/23/30 1200 by LU/PGSlaq ' 40% by voluma collactsd 12/23/30 1200 by LU/PG

Tna pH was performed on a 5 % solution.

Grinder and Resin Trace AmountSand MullarWaste See attached analysis sheet

Samp Prep 10.00

INV TO- Spotts Stavans & McCoy In 265.00 154 Rsspactfully submittedLancastar Laboratories./-Tnc.

MAIN LABORATORY:2425 New Holland Pike. Lancaster. Pa. 17601 • (717) 555-2301

tf/, FRANKUN OIVISION: t fJi1a«« U^i^eha^ ft A MrtrJ* P.O. Bo. 487, 3 3amea Ave.. Waynesboro. Pa. 17268 • (717) 762-9127 J- Wilson Harsha/ «•*•• "flr.• Instrumental Anal/si-s Prc !<••

AR308U3U

Page 78: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

i s/79 INDUSTRIAL WASTE DISPOSAL AT PERMITTED SITES

MODULE NO. 1

• 1. Describe in detail on a separate sheet the manufacturing process(es) generating thewaste(s) and list the raw materials as well as intermediates and final products containedin each waste.

2. Include an analysis of the waste itself and a leachate analyses of the waste. Theanalyses must contain but need not'be limited to the following parameters unlessthe applicant has specific knowledge of the absence of any of these parameters:

Percent Solids ArsenicpH CadmiumChemical Oxygen Demand • • CopperTotal Organic Carbon . . ChromiumOil/Grease • LeadTotal Dissolved Solids. .• Mercury

^^/ . Total Volatile Solids ' Molybdenum• Specific Conductance ' ' Nickel•Ammonia-Nitrogen SeleniumPhenol SilverCyanide

If codisposal with municipal refuse is proposed, use ASTM Method B or EPA'sextraction procedure for leaching the waste. Otherwise, use ASTM Method A. Useappropriate Standard Methods of Analysis or EPA's methods for the chemical analyses.

For the analysis of the waste itself, use a nitric acid digestion for extraction of themetals. An organic analysis may be required if the waste contains appreciable amountsof organics. ' •

1R308035

Page 79: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

SH-Sw.vi-14: s/73 INDUSTRIAL WAoTfc ^iorXlSAL AT PSrtMlii TcO SITES

MODULE NO. 1

1. Describe in detail on a separate sheet the manufacturing procsss(es) generating thewaste(s) and list the raw materials as well as intermediates and final products containedin each waste.

2. Include an analysis of the waste itself and a leachate analyses of tha waste. Theanalyses must contain but need not'be limited to the following parameters unlessthe applicant has specific knowledge of the absence of any of these parameters:

Percent Solids ArsenicpH CadmiumChemical Oxygan Demand • • CopperTotal Organic Carbon . . ChromiumOil/Grease • LeadTotal Dissolved Solids. .• MercuryTotal Volatile Solids MolybdenumSpecific Conductance ' ' Nickel

• Ammonia-Nitrogen SeleniumPhenol SilverCyanide

If codisposal with municipal refuse is proposed, use ASTM Method 3 or EPA'sextraction procedure for teaching the waste. Otherwise, use ASTM Mathod A. Useappropriate Standard Methods of Analysis or EPA's methods for the chemical analyses.

For the analysis of the waste itself, use a nitric acid digestion for extraction of themetals. An organic analysis may be required if the waste contains appreciable amountsof organics.

AR308Q36

Page 80: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

5A-SWM-148S/79 ,

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES PERMIT NUMKM OP

BUREAU OF SOLID WASTE MANAGEMENT O.SEOSAL SlTeDATE tf -PAflEO

INDUSTRIAL WASTE DISPOSAL AT PERMITTED SITESMODULE NO. 1

13. Primary Characteristic Secondary CharacteristicInorganic OrganicG Acid G Oil & Oily Sludge G Heavy MetalsG Alkaline G Paint & Pigment Residue G Other Metals

* G Cyanide G Plastic, Pasticizers, Resins, G SulfidesElastomer Residues

G Filter Aids & Clays G Solvent G Hexavalent ChromiumG Heavy Metal ' G 'WWT Sludge G OrganicG *WWT Sludge G Pesticides G HalogenatedG Pesticides G Still Bottoms, Heavy Residue G SulfonatedG Catalyst G Pharmaceutical Waste G Inorganic13 Other, describe G Other, describe 23 Other, describe. Sand, ash, clay and _____________ Arsenic, chromium, copper

siag uee attacned - lead and phenols were atanalysis) .. detectable level (see

/ 14. Hazards attached analysis).G Toxic Substance G PoisonG Skin Irritant . G Explosive

• G Respiratory Irritant G CarcinogenG Corrosive to Steel G Reactive, acidQ Corrosive to Concrete G Reactive, waterG Corrosive, other G Reactive, otherG Flammable £8 Other, describe non-hazardousG Cyanogen

C. DISPOSAL METHOD: (describe applicable items)

Type of disposal (Le., landfill, lagoon, pond, etc.). Landfill (see attached permit)_____ .

DESIGN SPECIFICATIONS.

1. Liner type (i.e., concrete, asphalt, clay, etc.) and thickness. N/A •_______________

^ 2. Leachate collection and treatment capability at site for waste to be disposed of. (Describe)N/A '

•WASTCWArCK TNCATMCMT IUUOCC

/JR308037

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S/79

COMMONWEALTH OP PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES '«RMIT N"""* °'

BUREAU OF SOLID WASTE MANAGEMENT __2!291*kSiTt.OATS ?r -PAR so

INDUSTRIAL WASTE DISPOSAL AT PERMITTED SITESMODULE NO. 1

13. Primary Characteristic Secondary CharacteristicInorganic OrganicG Acid G Oil & Oily Sludge G Heavy MatalsG Alkaline G Paint & Pigment Residue G Other Matals

* G Cyanide G Plastic, Pastidzers, Resins, G SulfidesElastomer Residues

G Filter Aids & Clays G Solvent . G Hexavalent ChromiumQ Heavy Metal Q *WWT Sludge Q OrganicG 'WWT Sludge G Pesticides G HalogenatedG Pesticides G Still Bottoms. Heavy Residue G SulfonatedG Catalyst G Pharmaceutical Waste G Inorganic03 Other, describe G Other, describe £3 Other, describe' Sand, ash, clay and ____________ Arsenic, chromium, copper

siag isee attacned lead and phenols were <analysis) -• detectable level (sea '^-

14. Hazards attached analysis).G Toxic Substance G PoisonG Skin Irritant . G ExplosiveG Respiratory Irritant G CarcinogenG Corrosive to Steel G Reactive, acidQ Corrosive to Concrete G Reactive, waterG Corrosive, other G Reactive, otherG Flammable S3 Other, describe non-hazardousG Cyanogen

C. DISPOSAL METHOD: (describe applicable items)

Type of disposal (La., landfill, lagoon, pond, etc.). Land/111 (see attached permit)_____ .

DESIGN SPECIFICATIONS.

1. Liner type (i.e.. concrete, asphalt, clay, etc.) and thickness.

2. Leachate collection and treatment capability at site for waste to ba disposed of. (Describe)

N/A '•WA»T«WAT»I» TJtCATMCMT ((.UOOK

AKOUOUOO

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«.*-S»»M— U-S/79

r COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES 'CMMIT NUMSCM OK

BUREAU OF SOLI D WASTE MANAGEMENT•DATE PREPARED

INDUSTRIAL WASTE DISPOSAL AT PERMITTED SITESMODULE NO. 1

A. DISPOSAL SITE INFORMATION:1. Facility Name: Novak Sanitary Landfill, Inc.

2.

3.4,

S.»•

6.

7.

Facility Location: South .Whitehall Township (Lehlgh County)

Facility Owner: Louis J. NovakFacility Mailing Address: R- 0- *1 . Allentown, PA 18104

Facility Manager: Louis J. Novak Telephone No. (215) 395-6251

Facility Contact: Louis J. Novak Telephone No. (215)395-6251(Qirion rmoontibl* (or providing dati fof tnl* iurv«yl

Does the facility discharge industrial wastes to a municipal sewer system? __ __ Yes _If yes. name of system

8. . Does the site have a leachate treatment facility? _ _ Yes _If yes, attach discharge standards.

9. If the site is a landfill, attach last monitoring analysis. If last analysis is more than threemonths prior, attach a current analysis to this module.

B. DESCRIPTION OF SPECIFIC WASTE:1. Companv origin of waste (name and address): Tyler Pipe Division, P. 0. Box

Macunqle, PA 18062

X No••••MM

X No^ ^ B

(3)

35,

Company Contact: Tom Brungard Telephone No. (215) 966-34912.

3.

4.

5.'

6.

Treatment: Is waste conditioned prior to disposal? 'No How? NA.

Disposal: Present Method Landfill

Provide and attach, special characteristics of this waste which determine the method of disposalinclude chemical analysis, physical description, precent of water and leaching analysis relative todisposal proposal. Provide the date of all data submitted.What difficulties do disposal of this waste presently present? None

What difficulties are anticipated for the disposal of this waste in the future? None

AR308039

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g iagioaal Office'./ernersvilla, Pannaylvania 19565

213 678-3637

Harch 3, 1981

Tyler Pipa Division?. 0. 3ox 33Kacungia, Pennsylvania 13C62 i>•'

Attention: Hr» Too Srungard

Ganclcaaa:/

Your application for Industrial Vase a disposal at Pernitted Sices, IHodula !fo. 1 for disposal of coro. butts, cupola bottoaa. burat aaod aad slaj •wastes ganaratad by Tylar Pipe OiTijioa, ?. 0. Box 33, Uacuagia, ?A has b«ea jravlawad, '

V^> 'The application is approved for disposal at Bovak Sanitary Landfill,

Inc., South Whitehall Township, l«hl£!i County, vita, the stipulation chat Ithis approval la contingent upon tha landfill's accoptanca of cha oatarlal*

If you oavo any questions, plaaao do not hesitate to contact thisoffica.

Sincaraly,

Ronald F. SlinikovakiFacilities 5up«rviaor

SFKifh

ees Joba J. Orancky, ?.£•Spotts, Stavans and HcCoy, Ice*

b

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ATTACHMENT 11

/1R3081HI

Page 85: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

S H lE T) — *> to <O >« "5-0 c _

a-D* « | g

S e

«*£ SsfiliisAi111 3rfS«*SiS3 .881 S-? s.*.:: =.s e.2«s=

I IsNHi51|l|2v4o-s-;asl«j5«a?

•S

o.IU

Page 86: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

cJ KJssible thundershowers. high inTI the southeast at 10-15 miles perth a 70 percent chance of showers orA vlostly cloudy tomorrow with a, gh in the low 70s.ged from the east at.9 m.p.hi-with ak* east at 8 p.m. The high *-.1 m.. and the tow was 49 (9C) at 3( precipitation as of 10 p.m.

i

nderstorms across tha southern Plainsyesterday, with storms over Arkansasi i tornado.it of Hughes. Ark., west of Memphis.

•est Memphis. Ark., and hail the size ofu if Little Rock.• .d across northern Texas and overstorm watches were issued for northa. Kentucky and Tennessee.• -oss the Appalachians to the middlei 78 inches of rain, and Crewe,Va..3 M minutes. Washington. D.C., got 1.13

j. cool and temperatures only jn the 50si :ioa and tea Midwest. - ..auon at 3 p.m. EOT ranged from <SI degrees at Gila Bend, Am., and

i jnderstorms are forecast over theI most of the East Coast, with sunny 'ind the West.e cted with highs in the 60s and 70s in) n the southern half of the nation, withrtwi peaking near 100.

60

«..- **„,. *»«» 40Q<9

PCS levels are a subject of great controversy_ _. . because EPA considers oils with levels below SO

rvintim i AH Pmm Pan* s 1 PPm to be non-PCB. But EPA also says there areContinued From Pan* 31—— PP ^ ^ afe leve,s {or p£3$> whichsubstation. They're trying to sell the irans- are believed to cause various ailments and dis-formen to scrap dealers, because the trans- cases from skin rashes to cancer. Last year, aformers contain significant amounts of valuable federal court ordered EPA to review its 50 ppracopper, but they don't know when they will be cut-off, and EPA is expected to finalize newremoved from the site. regulations by August

They didn't leave the units inside the substa- PP&L contends PCBs do not pose any serioustion fence because they feared purchasers mi ght health risk.hit high-power lines with cranes when loading the The company employee, who agreed to talk totransformers onto trucks. ^ caU-Chronicle u u, identity was not revealedPP&L used its own cranes to move the , said earlier this month at least one truckload of

transformers outside the substation between Feb. material saturated with PCB oils was loaded at22 and March t. Siegfried and taken to the Novak Landfill in South

• The sprawling Siegfried substation, one of Whitehall Township.PP&L's oldest and largest, covers a hillside along HS said the truck came from Valley Disposal.the Leaigh River opposite Route 145 between which is operated by Novak's.

,. . u L "Valley Disposal is the contractor we used."• The Call-Chronicle learned about the trans- said PP4L spokesman Bert Daday. "We presumeformers from a PP&L employee, who also said a Valley Disposal is using their own landfill, but 1large amount of stone and other ma terial can' . Say specifically.saturated with low-level PCB oil from tha substa-tion was dumped at a sanitary landfill in LehighCounty earlier this month. p ^ oii atR9 £„„ a leaking transformer

The employee also claimed 2.000 gallons of oil that was taken out of service, pumped out. and secontaining low concentrations of PCBs recently with the others outside the substation.leaked-from a storage tank at the substation. Company officials said - and an EPA at-

Company officials acknowledge there was a toraey in Philadelphia agreed - that it b - -\leak but don't believe that much oil escaped. And Uleral to dispose of material containing Ithey claim there's nothing wrong with taking underSOpprainalandfUL />SumtJS'&Sf ^ bdOW M Ppm to a B«t» spokesman for the Stata Department oflandfill for disposal. Environmental Resources said a chemicalPP&L officials admit they don't know exactly analysis of material containing any level of PCB:

how much oil was lost when a valve on the storage must ba done and submitted to DER before thatank broke, but they contest tha 2,000-gallon stuff is dumped at a landfill.flgt *1 _, - , • ' , William Pounds iaDER's bureau of solidTheir original estomate was that only about wasla management la Harrisburg said tha stata100 gallons leaked, though they admit they may • • - - -never know exactly how much was lost because ___ _they don't know how much oil was in the tank. concentntions'below 50 ppm.

They say they recovered 8,000 gallons from if that's not done, he said, "we could considerthe tank, which has an 18.000-galloa capacity. The it illegally disposed."tank contains no gauges and isn't connected to On Friday Pounds and other DER officialsany alarm system, but PP&L said it is checked wer, ^ to say if that was dona in tha case of""""' ** the material from the PPiL substation.

: "Our interpretation of

must see the analysis and approve the dumping.even if someone contends the material has PCS

covered March IS. because a decision was madeto empty the tank to repair the defective valve."It was more than a drip," said Gibbons. , ,_ . _,_„. ...Lou Novak. operator of tha landfill, said he

dida't know any PCB wastes were included in ttMW4WM4 ***f «• UU WUKil AM Wild U*AM*«I|II «/4fcCMa.«* —11— *W!« B M.»*IB

tha substation. They say the spill evidence they eariJ5r tr?.mOTtJu, , ,, _,._ ., ^ ^saw shows it went no farther than 30 feet from the The PP&L employee indicated hundreds oftank and that not much got into the ground pounds of stone and soil were hauled away, butbecause tha soil was frozen. Novak said there were only a couple shovels f ulPPiL says ii was not necessary to report that He said mostof the material was w«.ceram

incident to the U.S. Environmental Protection connectors Mdpoles. Ha said his men s— «d upAgency because tha'oil was contained at tha site the poles for firewood. i Iof tha spill and the oil was non-PCB - with a PCB "w« *»'» **1 involved in anything h*-rfd-concentration of 33.2 ppm. ous." said Novak. "There's enough clean garb.

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y V^/have to turn away that we don't need anythinghazardous."

- He said more than a year ago DER did advisePP1L to have material from a low-level PCBspill at Siegfried taken to his landfill. But Novaksaid such material isn't mixed in with the otherga "sage. He said it's buried in a separate hole andcovered with a foot of clay soil.

State and federal environmental officials in-* dicated PP&L generally is very diligent in its

handling of PCB wastes. The employee who told'.o the Call-Chronicle about the Siegfried substationid. incidents agreed, saying: "I don't know if they •

were misled as to how the stuff was going to bedisposed of or not."

'*" The employee also contended PP&L normally.seals all wastes containing any level of PCBs in

it drums, takes them to a storage area, and then hasthem hauled to a landfill "suitable for that kind ofwastes." He noted the company goes to great

toe time and expense to make sure its employeesi know how to properly handle PCBs.

PP&L officials denied that non-PCB wastesare sealed in drums and taken to special landfills.

in- EPA officials in Philadelphia seemed mostinterested in the legality of the old transformers

s> being stored outside the substation."We have to run through channels here, and

see if it warrants an investigation." said the EPAattorney. "Whether It's legal or illegal depends on

'" > number of other findings. We're casting noV ddgment with the few facts we do have. It would

a. v—ie a little unfair to make accusations."According to PP&L testing labels on the scrap

If transformers, only one of the eleven has a PCBe rating above SO ppm. It's listed as containing

PCBs at 100 ppm. which EPA considers moredangerous "PCs-contaminated" oiL (One of the

.& other 10 transformers has an illegible label, and113 another bean no label.)."3 After PP&L was told the valve on the 100 ppm

transformer was briefly opened last week, the4. company did another test on the oil in it and the

ground beneath the valve. The new sample>£ showed the contents in the transformer containJ0f PCBs at 125 ppm. But the ground sample showed

levels at only 3.3 ppm." c PP&L officials explain the large differencetj. . between the stuff in the ground tnd the staff In the

transformer by saying PCBs tend to settle to thebottom of the tank. The company took its sample

* from a faucet that is slightly lower than the largevalve. The PCBs on the ground were released

"* from the large valve.ilhe

•Dl•at

LOTTERIESSat.. May 22. 1982

PENNSYLVANIA NEW JERSEY•a. \. /Daily Number Big-4 Pick-Itn gVf 731 4124 603

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Beading Olatrict OfficeJuna 29, 1982

SUBJECT: Disposal of ?C3 Contaainatad WaataAC Hovak's Landfill Inc.I.D. 100334South Whitehall TownshipLohigh County

TO: Brace 3eidlerOparaticna Supervisor

PROM: Michael 6. KaloliaSolid tfaata Specialise

On May 25, 1982, aftar an article in Morning Call reported that ?C3contaminated soil had bean disposed of in Novak'a Landfill, I apolca to LouisNovak, Jr. concerning the incident* Mr. Novak stated that 7alley Disposal hadraooved a ten cubic yard and a fifteen to twenty cubic yard rolloff con-tainer froa PPL's Siegfried Substation on the data la question. At the cine ofthis conversation, the ten cubic yard container had not been dusped and aninspection of its contents revealed only cut up wooden telephone poles. Thefifteen to twenty cubic yard container had previously been dusped ia thelandfill's desolltlon disposal area, and according to Mr. Novak, containedwooden poles, brush, and approzlaataly one cubic yard of soil.

The arrangement for disposal of waste by PPL was set up by JoeKaglovitz of PPL. According to Mr. Novak, there had been no mention of any PCBcontaminated wasta when the arrangements had been made, and he had no reason tobelieve that this waste was any different from waste previously disposed of froaPPL.

MGM:fh

flR3'080l*5

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ATTACHMENT 12

Page 90: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY …it removed IRC's wastes, including incinerator ash, from the Allentown plant from 1979 until 1985. Some of this waste was then hauled

DON RITTER • .AMWJu mc(ISI) 129-4411

COMM-SSr M rTTB ™f S DISTRICT O~,C«, , J

ToumtM ~——•**———— " ~'~ ———"" " — ""——— ttiij «**•!• "~ "°U

«iipfro»ni I ... _..._ ____.HIUINKI COMMISSION «•»__«.• - -— ^* ^» AASI ffl «ii OITBKM. Po*.m.v*M» itioiOMMtuieMONueunrrvAMa SSaSgUIJJtOn, ».C. 205 Id <ai*l4j* MiooorcRATtoM IM nmorc •

ROOM 70S^

tM44(211) Mi I3tl

April 12, 1984

Mr. Joseph PomponlPennsylvania Department ofEnvironmental Resources520 East Broad StreetBethlehem, Pennsylvania 13013Dear Mr. Pomponl:

I am writing on behalf of my constituents, Nicholas and Debra Pldstawskl,of R.D. 1, Box 242B, Allentown, Pennsylvania 13104. They have recentlycalled and written my office regarding problems they have been experiencingfor the past year which they feel are caused by the Novak Landfill In SouthWhitehall Township. These problems are more clearly defined In theirenclosed letter.Since 1t 1s critical that this problem be addressed before the situationbecomes even more severe, I would appreciate your response to the allegationsmade In the Pldstawskl's letter. It would also be helpful 1f your officecould furnish me with a report of the actions you have taken In regard tothis problem and any future plans you have for testing and clean up of thissituation.If you have any further questions or/comments <]n this matter, please contactmy staff assistant, Robin Crawford/at 366-091p. Thank you for your cooper-ation.

icerelyi

DON RITTiMember of Congress

OR: reEnclosure

APR 13 1284-• OiST. OFFICE

'.'/.RES.

flR308LU7

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ii

||

V

C! us to tike more w-t&r s;.-.!•:.•. ii-o : ov.:- . . ••..:.-..r-i\oe and siy in-laws.s ' ./hen asking him what kind ol" _• -j-:«i*iu 1; _-. :.-5ut in our water he

replied ths-t it is .bactsris.. jrvsent i** &sil -iid tt-t eitherground had gotten into ox;r v/ell or th:.ty:our ae.)tic system couldbe causing the problem. This is very .-. I1.-:.* ticnr'ile since myin-laws have their own well :_.iivi the s. ii-; t. ct-sriu is ^recant.I asked him v.'here they measure the pciivt or elevation" from (howhigh they can dump) and he told lie a cor.ci-ote slab located

j behind Novak1 s garage on Pc.rkla.iid Terrace- iioad. He -said he didn'ttrust Costello, Novuk's eii inc.or, and his readings because hisown readings showed that this trench • skovJLd be full and closed

I down. But they continue to d-.*r.i; in this a r*e trench.L had also taken a, -wv.il: tar-Licr in the dr.y tnd ooa«rved

that on our .property, adjacent to this wo..e:i, this corn field isI los-ded v/ith paper, 'when I iLsi.sd uil.y v;h. t v.\.a to be doae v.bvut.

this "garbage", he replied, "Thv.t'o tl.« v.-i.vi,'-1 ud shrog ed hi.sshoulders. If the stumps froa the covr. st. lLa vcren't thero,

| this garbage v/ould be bloving ou uy li.v;u. God liiry r -ke the v:ind •but he doesn't dump the garble tLerol

i Y/hen v/alking along the b ci ys-rd to ay in-lsws hoiue to t;l-:e} the v/ater sample there, I asked hin if he ca«.liud the 3VEIICE.

He replied, "That's because he (Kovaic) is not covering the garblei dumped there." \7hen asked \7h-it he Y/E.S jioing to do s boxit it heI said that the landfill should be fined but if "they dp it for

one they hc.ve to do it for every one". I don't c.rc c.bout unycno*~~ else. I want action to be teUten u.t t.-*is lu..di'ill. The ..laws werej made to protect eoyle like uo ;>.i! I bc-iove" ti t-j uhould be1 ' enforced. Kike also told cie ti;-.-I th.vro is :. sv-.cii-J. division of

the D2R that deals with by-ctori.-- in •;«. tv*r uxd Uov: -to treut it. I'mvery interested in this beiug uoiie-. He j-lao s; id tii.-t if thebu.cter.ia shows again in the v/i.tcr, hv /ir*«j \vc\tcr i:c..t to us is nota bad idea. Who pays for this?

There are also a few other points I'd like to touch on.7/hen this landfill was opened in -the 1 50 ' s, the original p'eraitV/&s issued to recover lost farm li-.nd caused by ti ninehole. Mymother-in.-lfew signed & .japcr to tl.is Cix^cct. ::ov; '.-.ovik has gonebeyond the original, permit. .;hy v;c.:i this ullw-.vod. ..ccordiiic; tothe USR, no li idfill now, cc- i c.*-i% v~ i~ •- -ii— "i— c -..roc. but siv-cethis one is on a- permit from L: .'. "c- *•;.- ^^c, it i:.. ok. I do.i't

cj with tiiat. Again, the I'.--.va ; j-c> ..-iotccti:.., i^clAnother point is a fev: ciiilioios lcc..ted tt the_ *— ._ _m - - . ^« * •

_ _ __ open , _ _ _runoff froa tha whole lt.cic.iiil'. is r iso dra-iaod into this

earner.

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OA-iOl - 12*7 COMMONWCACTMO*

Murcli J7,

SUBJECT: NOVAK LANDFILL*100534South Whitehall TownshipLehigh County

TO:

3ruca BeitlerRegional Operations Supervisor

f*OMl Joseph P. PomponiField Operations Supervisor

Visit to the above site accompanied by Manduke and Rajkotia onMarch 27, 1935 pursuant to complaints of possible sink holesreveals following:

1. A sink hole was seen in the sedimentation pond.The size was approximately three feet in diameterand four feet deep. Adjacent to the sink hole ina westerly direction existed two depressions whichmay indicate future sink holes. The visible sinkhole lies in a direct line northeast of tha sinkhole at the treeline off the landfill property.It seems as if the new sinkholes are extendingtoward trenches 4 and S.

2. Above tha trench area, there has been depositedapproximately five truck loads of foundry sand.The owner indicated that the foundry sand camefroa Tyler Pipe Company. Mixed with the sandwas a sizeable amount of solidified tar.

3. The recycling area continues to be operated ina very haphazard manner. Mixed with recyclablecardboard and paper, evidence of plastic bagswith nonrecyclable materials, one empty fivegallon can labeled chromic acid, some type ofresidual waste in plastic bags and materialscattered on and off the concrete pad. Bettermanagement of the bailed material was evidenton this visit.

In as much as tha new sink holes seem to be headed toward Trench4, any new wastes dumped in this area may contribute toward achronic groundwater problem.

jPP/bal

flR3Q8Dt»9-

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DYNAMAGCORPORATIONEnvironmental Services

53 Darby RoadPaoli, PA 19301

Telephone: 215-839-3900Fax: 215-889-9474

April 15, 1992

Mr. Cesar LeeU.S. Environmental Protection Agency841 Chestnut StreetPhiladelphia, Pennsylvania 19107

Subject: File ReviewNovak Sanitary LandfillWork Assignment No. C03021

Dear Mr. Lee:

On April 2, 1992, Michael Heffron of Dynamae reviewed PennsylvaniaDepartment of Environmental Resources' {PADER) file on NovakSanitary Landfill. The waste management files at the Wilkes BarrePADER Office were reviewed in order to obtain any backgroundinformation on past waste disposal practices, waste types, andquantities, and any available analysis of wastes.

On April 10, 1992, the PRP's 104e letter responses were reviewed.The responses were reviewed in order to determine if any additionalwaste streams should be added to the information in the RI Report.Several of the files that were reviewed were ENFORCEMENTCONFIDENTIAL, and a brief summary of the files was located and isenclosed for your review.

On April 13, 1992, the EPA CERCLA files were reviewed in order toobtain any additional information that may not have been containedin the other files reviewed.From the information contained in the files, it appears that themajority of the wastes accepted at the landfill were municipalwastes. The were several sludge-type wastes accepted at thelandfill with PADER approval, and hazardous wastes from GE. Thefollowing pages summarize the wastes, other than municipal,accepted at the landfill and the documents discussing these itemsare provided in the attachments.

Corporate Headquarters: Tha Dynamae Building. 2275 Research Boulevard. Suite 500. Rodeville. MD 20850-32$ ft J 0 8051

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There are two copies, one bound and one unbound for yourconvenience. There is also a disk which includes the comments andconclusion.

If you have any questions or comments, please feel free to contactme at (215) 889-3900.

Sincerely,

Michael HeffronProject Manager

cc: Donna McGowan, U.S. EPA Region III CERCLA RPORobert Stecik, Jr., Dynamae, Philadelphia OperationsKirk McCutcheon, Dynamae, Geosciences Manager

AR308052