In 2002, Pennsylvania Department of Environmental Protection (PADEP) requested the assistance of the EPA Brownfields Technology Support Center (BTSC) in developing an efficient remedial strategy based on data collected during a previous Remedial Investigation (RI). The BTSC assisted PADEP with systematic project planning (SPP) for the Site, culminating in the development of a Statement of Work (SOW) in April 2003 that presented a HRSC approach for completing further investigation and remediation activities at the Site in a single mobilization. Using a contractor, PADEP completed a field investigation in February 2004 based on the recommended SOW.
Highlights of applying the Triad Approach for this project chiefly concern the SPP process, and include:
Other highlights include the dynamic sampling strategy and mobile laboratory program implemented at the Site based on the investigation approach outlined in the SOW.
|Site Name||Marino Brothers Scrap Yard|
|Site Type||Metal Recycling Facility|
|Site Regulatory ID||PADEP IRRSC-5-057|
|Project Lead Organization||Pennsylvania Department of Environmental Protection (PADEP)|
|Project Lead Type||State Lead|
|Regulatory Lead Program||State Remedial|
|Triad Project Status||Field Program Completed|
|Reuse Objective Identified||Yes|
|Proposed Reuse:||Recreational, Commercial/Industrial|
The Site occupies approximately 3 acres and operated as a scrap yard from the 1920s to 1998. Prior to the scrap yard, the property was occupied by a flour mill and a lumber yard. The property is currently owned by the Borough of Rochester and several buildings and pieces of process equipment remain on Site.
The Borough had planned on selecting a commercial or residential use redevelopment scenario for the Site. However, due to financial reasons, plans for redevelopment were stalled. Chosen remedies for the Site include deed restrictions and a cap. As of May 2012, remediation at the Site was in progress.
PADEP's investigation based on BTSC's recommendations concluded that site-wide characterization had been achieved, and that no more sampling was necessary to design and implement the remedial approach. The study found that 51 of the 87 sampling grid elements, comprising 9,150 cubic yards of soil ranging from the surface to 5 feet deep, would require remedial or removal action based on exceedances of site direct contact cleanup standards. The number of exceedances was highest for the metals lead, cadmium, chromium, and mercury. These metals displayed concentrations ranging as high as 11,000; 350; 1,300; and >600 milligrams per kilogram (mg/kg); respectively. Eleven of these grid elements also contained PCBs at concentrations above the hazardous waste threshold (50 mg/kg).
A total of 4,000 cubic yards of soil contained in 31 grids were assessed to be hazardous under Resource Conservation and Recovery Act (RCRA) criteria. Based on investigation results, PADEP in collaboration with project stakeholders finalized a remedial strategy of capping and deed restrictions. As of May 2012, redevelopment of the Site was not planned and remedy implementation was underway.
PADEP identified a need to develop a cost-efficient strategy for assessing the extent and managing cleanup of metals and PCB contamination in site soil. The overall objective was to develop and then implement remedial/removal alternatives to allow redevelopment of the site within the available budget.
The detailed systematic plan and CSM, as presented in the SOW and its supporting documentation, enabled PADEP to solicit and select a contractor, develop planning documents, and complete a field investigation.
PADEP's contractor concluded that the Site was characterized for later remedial action within a single mobilization using the on-site methods.
Cost and time savings have not been estimated at this time. However, a primary goal of the project was to use the Triad Approach to perform a DWS sampling program using multiple DSTs to increase data density, driving down ultimate removal costs by more effectively isolating and removing those contaminants requiring high cost disposal.
A CSM was developed based on available historic information and data collected during the previous RI at the Site.
Classical statistics software packages and DSTs were employed by members of the BTSC's project team to evaluate the extent of contamination in site soil and develop a sampling strategy. DSTs were also used to provide preliminary cost estimates for removal of soil volumes where contaminants would likely be classified as hazardous under RCRA.
A preliminary human health screening level risk analysis was conducted to develop site-specific standards based on recreational use exposure scenarios.
SPP activities performed for the BTSC identified soil-related exposure pathways as the only pathways of concern, and recommended a statistically-based, grid sampling approach for soil. A high-resolution sampling density was proposed, to be economically achieved through the use of field-based methods.
Field portable X-ray fluorescence (FP-XRF) was recommended as a potentially applicable field analytical technology with the understanding that a demonstration of methods applicability (DMA) study would be required to ensure the utility of the method.
Uncertainty management protocols recommended during the SPP process included increasing the sampling density in areas of the Site where decisions could not be made with an acceptable level of confidence. BTSC further recommended an adaptive program of QA/QC checks, method optimization, and real-time data review in the field by qualified personnel to monitor data quality and manage uncertainty.
Site decision-makers accepted the SPP approach and obtained buy-in from other site stakeholders.
The PADEP project manager was the principal decision maker for the Site. Other stakeholders with input to the site decisions included the Borough, PADEP's contractor (URS Corporation [URS]), and potential developers (specific roles/expertise not identified). Through its contractor Tetra Tech, the BTSC provided technical support to the PADEP project manager during the SPP phase of the project. BTSC's support was provided in the areas of chemistry, statistics, geoscience, engineering, and risk assessment. Upon selection as PADEP's contractor, URS assembled a technical field team, along with in-house equipment and procured vendors (including on-site and off-site laboratories) to support the field program.
At the time the SOW was prepared, the proposed remedy for the Site involved the excavation and removal of soil with contaminant concentrations above site-specific risk-based concentrations. BTSC proposed a DWS to support this approach by providing data to further refine the nature and extent of contamination at the Site, and then, in the same mobilization, removing or containing contaminated surface and subsurface soil and disposing of the contaminated soil at an appropriate disposal facility or as appropriate on-site.
The DWS required field-based methods and real-time decision making to assess when the investigation was complete in accordance with criteria established in the decision logic. Fixed-base laboratory analyses were used in combination with the field-based methods to limit costs, provide back-up for the on-site laboratory, and assure completeness of the cleanup. The DWS proposed by BTSC and implemented by URS consisted of an initial 50-by-50 foot grid sampling approach that encompassed the entire Site. An initial direct-push technology (DPT) sampling location was established randomly within each grid element. Samples were collected from prescribed depths down to 5 feet below ground surface (bgs) at each location and submitted for on-site analyses. Based on the results obtained, additional focused sampling was performed in certain grid elements to further define the scope and extent of the future remedial action. In order to increase sampling density and decision certainty, the dynamic sampling approach split each grid element of concern into four smaller grid elements (25-by-25 foot) to further resolve the contaminant distribution.
PADEP implemented the sampling approach largely in accordance with BTSC's recommendations; however, different field-based methods were used (see below). In addition, the field program ended when contaminant delineation was considered complete, versus the initial plan of proceeding directly into remedial/removal action.
Refer to the project points of contact identified at the end of this profile for additional information concerning how real-time decision making and communication occurred.
Decision logic diagrams were developed to assist the field team in applying the analytical data to make decisions regarding excavation and segregation of contaminated soil (e.g., how deep an excavation should be in a given grid element based on soil boring data from that grid element). Decision logic diagrams were provided to PADEP in BTSC's SOW.
PADEP considered FP-XRF as the field-based method for metals in accordance with BTSC's recommendations, and performed a DMA study in November 2003. The DMA identified that the FP-XRF vendor (STL) selected could not meet method reporting limit requirements, thus, an alternate mobile laboratory method (Inductively Coupled Plasma Spectrometry [ICP]) was selected for metals.
URS hired New Age/Landmark Mobile Laboratory Services (New Age/Landmark) to perform on-site ICP and gas chromatography (GC) analyses after STL's FP-XRF equipment was rejected. In addition, Pace Analytical Services Inc. (Pace) fixed-base laboratory in Export, PA was utilized to split samples for Toxicity Characteristic Leaching Procedure (TCLP) Metals, as well as for quality control (QC) purposes (to provide back-up and confirmatory data for on-site total metals analyses). Based upon field results obtained from New Age/Landmark, a split from the sample with the highest metal concentration in a particular grid was couriered to Pace's laboratory for TCLP analysis. These analyses allowed URS to determine which grids with high metals concentrations would be considered RCRA hazardous or nonhazardous.
The evolving analytical approach for the investigation demonstrated the importance of establishing contingencies as part of DWS.
TQRS not prepared
The quality assurance/quality control (QA/QC) program involved the analysis of standard QC samples (duplicates, spikes) and other method QC checks, along with limited real-time review of analytical data and QA/QC results in the field. Later reviews and verification analyses by New Age/Landmark Technologies, Inc., following demobilization required correction and resubmittal of PCB results.
Commercially available statistical software packages and the DSTs, FIELDS and SADA, were used by the BTSC during the SPP process to evaluate historical data and develop the technical approach for the project. BTSC also developed recommendations for PADEP and its contractor for design of a data management system for real-time data evaluation based on these DSTs.
A database and plots were developed for each grid element characterized in the field investigation to correlate the total results versus TCLP results. Based on the data interpretation process, a total of 4,000 cubic yards of soil contained in 31 grids were assessed to be RCRA hazardous due to TCLP metals exceedances.
After the investigation report was finalized, a remedial action plan was developed. As of May 2012, Site remedial action was in progress with a chosen remedy of capping and deed restrictions.
November 10, 2003 through November 20, 2003 - DMA samples collected and analyzed by XRF.
December 4, 2003 through February 4, 2004 - Site sampling grid is surveyed, sample locations within grids determined, sampling conducted, and samples analyzed by on-site and off-site laboratories.
|Marino Brothers SOW (23.5 MB)|
To update this profile, contact Cheryl T. Johnson at Johnson.Cheryl@epa.gov or (703) 603-9045.