Major Investment Study / Draft Environmental Impact Statement   5. Affected Environment and Consequences     5.10 Hazardous Materials And Wastes

5.10 HAZARDOUS MATERIALS AND WASTES

5.10.1 REGULATORY SETTING

• Comprehensive Environmental Response, Compensation & Liability Act (CERCLA) 
• Resource Conservation & Recovery Act (RCRA) 
• Toxic Substances Control Act (TSCA) 
• Hazardous Sites Clean Up Act (HSCA) 
• Pennsylvania Department of Environmental Protection (PADEP) Storage Tank Program 
• PADEP Land Recycling Program (Act II)

5.10.2 METHODOLOGY

• SEPTA/BARTA may acquire property in future phases of the project. They or the current owners of these properties may incur regulatory and financial responsibility, and liability for investigation, assessment, and remediation of any contamination. 
• Contaminated materials, soils, and groundwater management issues may impact schedules and budgets for future project phases. 
• Contaminated materials, soil, and groundwater may impact project construction activities. 
• Excavation, demolition, renovation, and construction activities could expose construction workers to hazardous materials and/or result in a release to the environment. 
• Soil excavated but not reused on site will need to be characterized, transported, and disposed in accordance with Pennsylvania solid waste disposal requirements.

• Contaminated Materials: raw materials containing hazardous constituents and waste materials, including residual materials from industrial operations, commercial, and transportation operations, and certain building materials and debris. 
• Hazardous materials: solids, liquids, and gases containing chemicals that can be harmful to human health or the environment. This includes numerous industrial chemicals, friable asbestos, lead paint, and naturally occurring radon.

• Published federal and state databases 
• Aerial photographs and historical Sanborn Fire Insurance Maps (Sanborn Maps) 
• PADEP case files 
• Conversations with agency officials 
• State agency case files 
• Field views

• With minor exceptions, the alignment will be on or adjacent to active rail lines. While widening of the alignment will be necessary, it is expected that the widening and associated cut and fill, property acquisition or easements will be less than 100 feet on either side of the current tracks. 
• Construction access roadways are expected to be within 100 feet of the existing tracks.

Due to the long railroad use of the alignment and the equally long industrial history of many areas bordering the alignment, a simplifying assumption is that virtually every portion of the existing railbed potentially has some degree of contamination, although not necessarily at or above the threshold that would dictate mitigation activities. Further, the land adjacent to the railbed in several industrial corridors through which the alignment passes also has this potential. 

For the purposes of this project, a three-tiered risk system was developed to differentiate the relative probability of encountering hazardous materials at an alignment segment or station area. The three risk rating categories are described below.

"High" Relative Risk Segment - After a review of all available information, there is relatively strong probability as compared to the rest of alignment that the alignment segment has significant contaminated materials problems. ("Significant" contaminated materials would be conditions that warrant Phase II sampling with a reasonable probability that contaminant concentrations require compliance with Pennsylvania Act II guidance or disposal as other than clean fill). Conditions forming the basis for this rating may include: long history of industrial use of adjacent land; location within or adjacent to an active or former rail yard; or presence of certain types of listed sites (NPL, CERCLIS, LUST, RCRIS-TSD, CORRACTS, and Coal Gas) within 100 feet of the alignment or station area.

"Medium" Relative Risk Segment - After a review of all readily available information, there is a moderate probability, as compared to the rest of the alignment for the segment to have significant contaminated materials problems. Conditions forming the basis for this rating may include: alignment segment served by electric-powered rail vehicles which may have formerly used PCB-bearing fluids; history of nearby industrial operations; certain portions of rail yards or presence of certain types of listed sites (ERNS, RCRIS-SQG, SWF/LF, and RCRIS-LQG) within 100 feet of the alignment or station area.

"Low" Relative Risk Segment - After a review of all readily available information, there is a relatively low potential for significant contaminated material problems. The potential for such problems is limited to leaks or spills from railroad equipment or equivalent activities.

The findings of the contamination screening and evaluation are based on preliminary information only. Designation of an area as having high or medium relative risk should not be interpreted as the determination that this area is contaminated, only that there is the potential for contamination to be present. These designations are not intended to replace more detailed studies such as individual site assessments and subsurface soil and groundwater investigation. Rather, the screening is intended to be a guide for identifying areas of potential contamination along the proposed alignment, station and maintenance facility areas.

Field oriented technical studies will be required to determine the existence of contamination prior to property acquisition, excavation and grading for footprint widening, or station and maintenance facility construction. Potential contamination sites may extend beyond those identified in this report because of limited historical and regulatory information, illegal dumping practices, and spills and leaks from rail operations. 

5.10.3 AFFECTED ENVIRONMENT

The affected environment for contaminated and hazardous materials includes:

• Industrial corridors along several areas of the alignment, such as Conshohocken and Royersford, contain active, inactive, and former industrial operations and certain commercial operations (e.g., fuel storage and distribution, commercial laundries) located adjacent or proximate to the existing Norfolk Southern and SEPTA R6 alignments 
• The Norfolk Southern and SEPTA R6 railbeds, including sidings and active and former railyards 
• Buildings along the alignment or in station/parking areas that will be either renovated or demolished.

• Many of the industries and commercial operations actively or formerly operating in the Schuylkill River Valley used, stored or generated hazardous or contaminated materials. These materials include heavy metals, acids, bases, chlorinated and nonchlorinated solvents, coal tars, and petroleum products. 
• All active, inactive, and former industrial properties and certain types of commercial properties (referred together as industrial properties) near the existing railroad beds will be assumed to contain hazardous or otherwise contaminated waste materials, soil, and/or groundwater, unless information to confirm the absence of such contamination is readily available. 
• Some contaminants are more mobile in the soil and groundwater environments than others. Contaminants having relatively high solubility in water will more readily migrate vertically through the soil above the water table and laterally in groundwater. Contaminants with low solubility in water (for example PCBs) are less mobile and less able to migrate. 
• Some contaminants with low solubility, such as PCBs and chlorinated pesticides (e.g., DDT), tend to strongly adsorb to fine-grained soil particles. These contaminants tend to accumulate in areas of sediment deposition, such as floodplains, stream channels, and drainage ditches. 
• In locations where a contamination source is between the railroad bed and the Schuylkill River, contaminants capable of migrating will likely travel down gradient toward the river and away from the alignment. 
• Contaminants in soil or groundwater adjacent to the alignment (and below the elevation of the alignment) that are not disturbed by project construction and operation are not likely to pose a threat to project construction workers or system passengers.

• Potential sources of contamination to railbeds include: fuel oil, lubrication oil, hydraulic oil, and PCB-bearing oil drips/leaks from locomotives, railcars, track equipment, storage tanks and service vehicles; major petroleum product releases due to equipment failure, accident, or vandalism; minor spillage over a long period or major spillage of certain freight; and (possibly) lead paint flaking from railcars and overhead bridges. 
• Older railbed ballast and fine-grained subballast materials from Norristown east are assumed to potentially contain PCBs at some concentration unless information to confirm the absence of such contamination is readily available. 
• Soil in areas adjacent to railyard fueling operations will be assumed to be potentially contaminated with fuel oil.

• All buildings erected before 1978, when asbestos was banned from new building materials, will be assumed to potentially contain asbestos-bearing materials unless its absence is reliably confirmed. Flaking paint will be assumed to be potentially lead-bearing unless lead's absence is reliably confirmed. Buildings operated during the twentieth century will be assumed to have stored heating oil in underground tanks, which may have leaked unless otherwise confirmed. The rock or sediments beneath a building to be renovated or newly-built will be assumed to be a source of naturally-occurring radon gas unless otherwise confirmed. 
• Soil and fill materials beneath existing station/parking areas and proposed areas in urban or industrial settings will be assumed to be potentially contaminated, unless absence is reliably demonstrated.

5.10.4 CONSEQUENCES

There will be no hazardous materials or waste related to the No-Build Alternative

TSM Alternative

In the TSM Alternative, the park-and-ride facility at Port Kennedy will be situated on an industrial waste landfill, known to contain asbestos-containing materials. The landfill was closed in accordance with a PADEP-approved closure plan in the 1980s. Groundwater monitoring performed during the 1980s showed no indication of organic chemical contamination. The soil cap was graded for the addition of a parcel parking lot that was never built. It is possible that grading for the park-and-ride may require movement of some of the landfilled materials. Any work activities, including modification to the landfill soil cap or contents, will require coordination with PADEP and Upper Merion Township. Precautions to protect construction workers and nearby residents will be required if the landfill cap and contents are moved (see Section 5.10.5, Mitigation).

The TSM also includes construction of additional rail through Abrams Yard where there is a relatively high probability that some contaminated soil will be encountered during excavation. Exhibit 5.10-2 Relative Risk Segments [PDF] lists the segments of the TSM alignment identified as having high and moderate relative risks with respect to the presence of potentially contaminated or hazardous materials. 

Build Alternatives

Contaminated and hazardous materials impacts may occur when properties must be acquired and when excavation and grading must be performed. Property acquisition may or may not include transfer of responsibility for liabilities, including for those associated with contamination. Excavation and grading can expose workers to contaminated material and generate material for off-site disposal. Soil excavated and not suitable or required for reuse on-site will need to be characterized, transported, and disposed of in accordance with regulatory requirements as either clean fill or contaminated material. Renovation and demolition of older buildings will require the assessment and removal of asbestos-bearing materials, underground tanks, and management of lead-based paint. 

Twenty-three percent of the overall alignment (16.9 miles) for the build alternatives was classified as high relative risk illustrated in Exhibit 5.10-2 Relative Risk Segments [PDF]. The Wyomissing to Norristown segment, where footprint widening will require extensive cut and fill, contains 11.9 miles of this classification. Within Upper Merion the alignment passes through, but does not encroach on, the Tyson's Superfund Site and a small portion of the asbestos-related Superfund Site at Valley Forge National Historical Park. Neither site is anticipated to pose a significant impact to the project. 

Relative risks of the presence of potentially contaminated or hazardous materials at station locations are presented in Exhibit 5.10-3 Relative Risk-Station Areas [PDF]. Stations from Wyomissing through Port Kennedy will be either renovated or newly built. Seven of these station areas are anticipated to have high relative risks with respect to the potential presence of contaminated or hazardous materials. Station areas along the R6 lines from Norristown to Philadelphia are active and only minor grading work is anticipated. Acquisition issues and major excavation are not programmed for these areas. Station areas within Philadelphia associated with Alternatives 1D, 1E, 5E, and 5ET are anticipated to have a moderate amount of excavation and grading. The proposed maintenance facility is situated within Abrams Yard and has a relatively high probability to be underlain by contaminated materials. The Belt Line improvements are for the most part in areas of rock cuts and bridges. These areas are expected to be of generally low relative risk.

Substantial excavation for track alignment will be necessary for all build alternatives at Port Kennedy to link the main line to the King of Prussia/Port Kennedy segment. The excavation work will require the penetration of the aforementioned landfill cap and excavation of asbestos-bearing landfilled materials. All activities involving modification to the landfill soil cap on contents will require coordination with PADEP and Upper Merion Township. Precautions to protect construction workers and nearby residents will be required (see 5.10.5 Mitigation). Excavation, transport on-site or off-site disposal of all landfilled material must be in accordance with all applicable PADEP requirements.

For those areas of the proposed alignment where property acquisition and/or extensive excavation and grading are not required, there will be minimal or no contaminated materials impacts. Characterization and disposal of material removed during any modest roadbed regrading can be handled consistent with the owner/operator's waste management program. 

5.10.5 MITIGATION

The SVM project can seek to avoid or minimize potential liability associated with contaminated properties by performing field inspections and, where appropriate, phase two site assessment of properties to be acquired. If a property is found to be contaminated, and acquisition of the property is unavoidable, SVM can coordinate with PADEP in accordance with Act 2, to assure that the SVM construction does not impede site clean up or exacerbate contamination. Typically, the seller will be required to clean up the property and indemnify SVM for any potential environmental liability. If the seller does not have the financial resources to conduct the cleanup, SVM would clean up only the portion of the site directly impacted by SVM construction, and will carry out the least expensive and most expeditious cleanup plan approved by PADEP.

With regard to the Port Kennedy industrial waste landfill, asbestos-containing material is known to be present, and mitigation measures are available to protect the construction workers and nearby residents during construction. During the project's Preliminary Engineering phase, a program of boring, sampling and analytical testing must be performed to more fully characterize the magnitude, extent, condition, and type of asbestos in areas that will be graded or excavated. Plans and specifications for work in this area will identify the presence of the identified materials and requirements to protect human health. The construction contractor will be responsible for developing a management plan to meet the plans and specifications, protect workers, and protect nearby residents and the environment.

Operation of the SVM system will require the use of hazardous materials such as petroleum fuels, lubricants, brake fluids, coolants, solvents, and paints. These materials will be stored in accordance with PADEP and EPA regulations. Wastes accumulated or generated as a result of maintenance activities are subject to PADEP permitting requirements. Spill response and emergency response procedures will be developed in accordance with the operating entity's operating procedures or will be by SVM personnel in the event of a hazardous material/petroleum product/waste release within or adjacent to SVM property or operations. SVM will obtain the necessary permits for storage of hazardous wastes associated with operation and maintenance of the SVM system.

SVMetro.com Copyright © 2006 Lucius Kwok