Concerns from the research…

So far, the research has determined that it is not cheap to extend public drinking water supply systems, especially if the target location is at a higher elevation and under tough localized geographical and topographical conditions, and it was unclear if the purpose of the public drinking water system extension to the Benshoff Hill/Valley View and Linkville Road sections and other portions of central and southern Middle Taylor Township was due solely because of the Safe Drinking Water Act (SDWA) or if there were other reasons that public officials knew about. It has also been determined that the Riders (Rosedale) Disposal Area is an identified hazardous waster cleanup site.

The United States Environmental Protection Agency (US EPA) website for the Riders Disposal Area hazardous waste cleanup site indicated that Bethlehem Steel Corporation (BSC) wastes that were historically managed at the facility included waste pickle liquor, lime-stabilized waste pickle liquor sludge, ferromanganese sludge and slag, oils & grease, acid rinse water, coal tar sludge, zinc ore leach sludge, electric arc furnace (EAF) and other baghouse dusts, brass foundry waste, and filter cake from the wastewater treatment plant. And that these wastes were disposed at several areas at the Riders Disposal Area facility. The US EPA website goes on to indicate that the ferromanganese landfill (non-hazardous waste) was closed with a soil cover. The hazardous waste electric arc furnace (EAF) dust landfill was closed with a low-permeability cap. The non-hazardous waste hot forming sludge lagoon was clean closed by removing all waste, bulking and de-watering, as necessary, and disposing of the non-hazardous wastes in the Site 4 residual waste landfill. The Site 4 landfill has been closed with a soil cover and was capped with a low permeability geomembrane liner in 2005 and "re-closed" to reduce precipitation infiltration and impacts to groundwater and surface water. The hazardous waste spent pickle liquor treatment and disposal area closure permit has been approved, and the ferromanganese metal and slag are being mined under a state mining permit. Again currently being mined.

Review of the Fact Sheet

Information in the May 24, 2010 fact sheet as shown in the “Introduction 4” section of this website and entitled “Tecumseh Redevelopment Inc. (Formerly Bethlehem Steel Corporation, Johnstown - Riders Disposal Area) stated the following “PADEP completed an environmental indicator report and determination on February 28, 2003. PADEP concluded that human exposures are under control but that contaminated groundwater was not, based on elevated levels of iron, sulfate, manganese and chromium in groundwater, and impacted adjacent Hinckston Run and the lack of a cap on the Site 4 residual waste landfill and a spent pickle liquor area that is not closed”. In addition, the fact sheet states that “Heavy metals, cyanide, chloride, and sulfate are the main contaminants of concern at the Facility.” and “As part of the closure/post-closure requirements for these disposal units, the Facility continues to monitor groundwater, seeps and surface water as well as the condition of the final covers on the closed units.”

Review of Other Detailed Documents

Upon further examination of information on the US EPA website about the Riders Disposal Area hazardous waste cleanup site, there are two main documents present. These documents include the “Site Facts” and “Additional Site Information” portions of the website. These two documents are as follows:

Document # 1 - Overview

Part 2 of Document # 1 pertains to the migration of contaminated groundwater under control and has the question “Is groundwater known or reasonably suspected to be contaminated above appropriately protective risk-based levels (applicable promulgated standards, as well as other appropriate standards, guidelines, guidance, or criteria) from releases subject to RCRA Corrective Action anywhere at, or from, the facility?” The response to this question was “YES”. "Contamination" and "contaminated" as referenced in this line describes media containing contaminants (in any form, NAPL and/or dissolved, vapors, or solids, that are subject to RCRA) in concentrations in excess of appropriate levels (appropriate for the protection of the groundwater resource and its beneficial uses). Rationale and reference for the Part 2 question states, as noted in well summary tables and in the accompanying narrative discussion, several parameters exceed 25 Pa. Code Ch. 250 standards in downgradient wells: sulfate, iron, and manganese. While these parameters may be present in upgradient wells, they have been found to be significantly higher in some downgradient wells. Chloride and chromium have also been found to be elevated in some downgradient wells. This, combined with, Bethlehem Steel’s reported statistically significant differences in several parameters over the past 10 years, indicates impact to groundwater in slag and bedrock at Riders from the waste disposal units, in addition to any other causes (e.g. past upgradient surface mining and the slag itself).

Part 3 of Document # 1 is also for the migration of contaminated groundwater under control and has the question “Has the migration of contaminated groundwater stabilized (such that contaminated groundwater is expected to remain within existing area of contaminated groundwater as defined by the monitoring locations designated at the time of this determination)?” The response to this question was also “YES”. "Existing area of contaminated groundwater" as referenced in this line is an area (with horizontal and vertical dimensions) that has been demonstrated to contain all relevant groundwater contamination for this determination, and is defined by designated (monitoring) locations proximate to the outer perimeter of "contamination" that can and will be sampled/tested in the future to physically verify that all contaminated groundwater remains within this area, and that the further migration of "contaminated" groundwater is not occurring. Reasonable allowances in the proximity of the monitoring locations are permissible to incorporate formal remedy decisions (i.e., including public participation) allowing a limited area for natural attenuation. Rationale and reference for the Part 3 question states that based on the summary information presented and the reports attached to the evaluation, there appears to be some connection between impacted groundwater, contamination of several seeps entering Hinckston Run and sediment deposited in Hinckston Run. Groundwater flows in the direction of and empties into Hinckston Run. While conditions appear to be improving over the past 10 years since closure and capping of the EAF Dust Landfill and clean closure of the Hot Forming Sludge Lagoon (and certainly compared to conditions in the 1970's and 1980's when the disposal units were in operation), impacted groundwater is expected to continue to migrate to Hinckston Run. However, with the capping of the Site 4 landfill in 2005, the planned mining through part of the Riders site (including the entire SPL area) starting 2007, the continuing decreasing trends in contaminant concentrations in seep, and the marked decrease in individual contaminants at seep 553 adjacent to the HW units, it appears that the dimensions of the area of contamination are stabilized. DEP considers the capping of the Site 4, the existing capped EAF Dust landfill and the planned clean closure of the SPL are via mining are the Final Remedies for this site.

Part 4 of Document # 1 again is for the migration of contaminated groundwater under control and has the question “Does contaminated groundwater discharge into surface water bodies?” The response to this question was again “YES”. Rationale and reference for the Part 4 question states that based on the information provided above, groundwater has been impacted by the waste disposal units and flows towards and discharges into Hinckston Run.

Part 5 of Document # 1 again is for the migration of contaminated groundwater under control and has the question “Is the discharge of contaminated groundwater into surface water likely to be insignificant (i.e., the maximum concentration of each contaminant discharging into surface water is less than 10 times their appropriate groundwater level, and there are no other conditions e.g., the nature, and number, of discharging contaminants, or environmental setting, which significantly increase the potential for unacceptable impacts to surface water, sediments, or eco-systems at these concentrations)?” The response to this question was “NO” - meaning that the discharge of contaminated groundwater into surface water is potentially significant. Maximum concentration as referenced in this line is as measured in groundwater prior to entry to the groundwater-surface water/sediment interaction (e.g., hyporheic) zone. Rationale and reference for the Part 5 question states that based on the information, concentrations of iron and manganese in down-gradient wells and seeps is over 10 times greater than the standards set forth in 25 Pa. Code Ch. 250 and the zinc concentrations of some seeps is greater than 10 times the standard set forth in 25 Pa. Code Ch. 16. However, it appears that the concentrations of these and other key parameters do not appear to be increasing (compared to data over the past 10 years of routine monitoring and to data obtained from the 1970's assessment of Hinckston Run). In some cases (e.g. cyanide, chromium, sulfate, chloride, aluminum, and zinc), the concentrations are decreasing. This trend is expected to continue.

Part 6 of Document # 1 again is for the migration of contaminated groundwater under control and has the question “Can the discharge of contaminated groundwater into surface water be shown to be currently acceptable (i.e., not cause impacts to surface water, sediments or eco-systems that should not be allowed to continue until a final remedy decision can be made and implemented )?” The response to this question was again “YES”. Rationale and reference for the Part 6 question states that as evidenced, the condition of several seeps and sediment/surface water sampling points, point to an impact from the Riders site and there appears to be a correlation to the waste disposal units. The condition of Hinckston Run clearly suffers as it flows past the Riders site. Not only do the concentrations of chemical contaminants increase along this section of the stream, the benthic and fish population and diversity drop. The latter is due in part to poor habitat, but seems to be partly due to impacted environmental conditions as well. However, the Pennsylvania Department of Environmental Protection (PA DEP) considers that the capping of the Site 4 landfill in 2005 and the planned mining of a portion of the Riders Site, including mining through the SPL area (which will be in effect a clean closure action), are the Final Remedies for this site at this time. Contaminant concentrations continue to show a decreasing trend, which is expected to continue. TRI is required to continue groundwater, seep and surface water monitoring through the post-closure period so PA DEP will be able to determine if these Final Remedies are working as expected or other remedies may be needed.

Part 7 of Document # 1 again is for the migration of contaminated groundwater under control and has the question “Will groundwater monitoring/measurement data (and surface water/sediment/ecological data, as necessary) be collected in the future to verify that contaminated groundwater has remained within the horizontal (or vertical, as necessary) dimensions of the existing area of contaminated groundwater?" The response to this question was again “YES”. Rationale and reference for the Part 7 question states that Bethlehem Steel Corporation is required to continue to monitor the site (groundwater, seeps and surface water) under the terms of the 1996 approved closure plan for Site 4 and the closure/post-closure permit for the hazardous waste units (TRI has opted to stay with this permit and not enter into a COA with PA DEP) to determine any changes and to conduct time-trend analyses of monitoring parameters. (Note: In the information as provided above, it is unclear how Bethlehem Steel Corporation can continue to monitor anything associated with the site as they are no longer in control of the property.)

Document # 1 has an original approval date of 02/24/2003 and has an approved revision on 11/14/2006.

Document # 2 - Overview

Part 2 of Document 2 pertains to current human exposures under control and has the question “Are groundwater, soil, surface water, sediment or air media known or reasonably suspected to be contaminated above appropriately protective risk-based levels (applicable promulgated standards, as well as other appropriate standards, guidelines, guidance and criteria) from releases subject to RCRA Corrective Action (SWMUs, RUs or AOCs)?” The response to this question was “YES” for groundwater, surface water, sediment and subsurface soil. "Contamination" and "contaminated" as referenced in this line describes media containing contaminants (in any form, NAPL and/or dissolved, vapors, or solids, that are subject to RCRA) in concentrations in excess of appropriate levels (appropriate for the protection of the groundwater resource and its beneficial uses). Rationale and key contaminants for items in the Part 2 section were listed as such:

  • Groundwater: Parameters exceed MCLs at 25 PA Code Chapter 250 in groundwater down-gradient from the disposal areas.

  • Surface water: Seeps from site discharge into Hinckston Run.

  • Sediment: Sediment at seep discharge locations sampled.

  • Subsurface soil: SPL area may potentially still contain residue from HW land application.

There are various tables in this section of the report which show sulfate, iron (total), chloride, chromium (total), and manganese (total) concentrations in the Site 4 Residual Waste Landfill and the EAF Dust Landfill/SPL Area and various testing results for aluminum (total), cadmium, calcium (total), chloride, chromium, cyanide, iron (total), manganese (total), nitrate, sulfate, and zinc at various locations at Riders/Hinckston Run seeps. Tables also show testing results on Hinckston Run sediments for aluminum, cadmium, calcium, chloride, chromium, cyanide, iron, manganese, nitrate, PCB, sulfate, and zinc and various testing results for aluminum (total), calcium, calcium (total), chloride, chromium, iron (total), manganese (total), nitrate, sulfate, and zinc of the Hinckston Run stream. It also has various test results of Hinckston Run fish samples.

Part 3 of Document 2 pertains to current human exposures under control and has the question “Are there complete pathways between contamination and human receptors such that exposures can be reasonably expected under the current (land and groundwater use) conditions?” The response to this question was again “YES” - meaning pathways are complete for any contaminated media - human receptor combination. A summary exposure pathway evaluation table was provided to show potential human receptors that could come in contact with contaminated media. Of significance was the listing for “residents” which lists “NO” for groundwater, surface water, sediments, and subsurface soils. Rationale and reference for the Part 3 question states that there are no groundwater users down-gradient of the Riders site that are hydro-geologically connected to impacted waters at Riders and Hinckston Run is not used for drinking water and is not routinely used for fishing.

Part 4 of Document 2 pertains to current human exposures under control and has the question “Can exposures from any of the complete pathways be reasonably expected to be significant (ie. potentially unacceptable levels) because exposures can be reasonably expected to be 1) greater in magnitude (intensity, frequency, and/or duration) than assumed in the derivation of the acceptable levels (used to identify the contamination); or 2) the combination of exposure magnitude (perhaps even though low) and contaminant concentrations (which may be substantially above the acceptable levels) could result in greater than acceptable risks?” The response to this question was “NO” - meaning cannot be reasonably expected to be significant. Rationale and reference for the Part 4 question states that PA DEP considers the only potential exposure pathways to be via trespassers, workers, and construction workers and such exposures would be short in duration or controlled in accordance with hazardous materials contingency plans and in any case would not involve acutely hazardous constituents.

Document # 2 also has an original approval date of 02/24/2003 and has an approved revision on 11/14/2006.

Summary of Research and Reviews

Of particular concern in the Fact Sheet are conclusions that indicate that human exposures are under control, but contaminated groundwater was not, based on elevated levels of iron, sulfate, manganese and chromium in groundwater, and impacted adjacent Hinckston Run and the lack of a cap on the Site 4 residual waste landfill and a spent pickle liquor area that is not closed. And the statement that indicates that heavy metals, cyanide, chloride, and sulfate are the main contaminants of concern at the facility.

Of particular concern in both of the Documents are tables that show test results of potential contaminants to surface water, groundwater and subsurface soils including contamination from aluminum, ammonia, chloride, cyanide, chromium, iron, lead, nitrates, manganese, sulfate, and zinc. Also of concern are statements that indicate that there appears to be connection between impacted groundwater, contamination of several seeps entering Hinckston Run and sediment deposited in Hinckston Run, and impacted groundwater is expected to continue to migrate to Hinckston Run - meaning that groundwater is impacted. Other parts of the reports indicate that based on the information, groundwater has been impacted by the waste disposal units and flows towards and discharges into Hinckston Run.

However, most concerning in the Documents are statements that indicate that there are no groundwater users down-gradient of the Riders Disposal Area site that are hydro-geologically connected to impacted waters at Riders and that Hinckston Run is not used for drinking water. There may be no groundwater users now, but there were prior to the extension of the public drinking water system out of Johnstown to the residents of the Valley View/Benshoff Hill and Linkville Road sections and beyond in central and southern Middle Taylor Township. The users were nearly all residents who accessed their drinking water from the “rogue” pumphouse site/lot and system or any current residents who may use drilled wells to access groundwater for own use. Individual wells may not have been for drinking water purposes; however, landowners could have used the water for other uses like agriculture, gardening, landscaping, or recreation (swimming pools).

My Letter to the US EPA…

Following all the research as compiled thus far in this website, I felt compelled to do something about this. I generated and sent a letter to the United States Environmental Protection Agency (US EPA). This letter outlined concerns associated with the Riders Dump (Rosedale) Disposal Area hazardous waste cleanup site and it’s impact to the residents of Middle Taylor Township. The letter outlined potential contamination of groundwater, use of that water by the residents of the Benshoff Hill/Valley View and Linkville Road sections of central and south Middle Taylor Township, and posed questions about the extension of the public water system out of the City of Johnstown. The letter was dated August 30, 2013 and is provided in the link below.

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Response from the US EPA…

The United States Environmental Protection Agency (US EPA) respectfully responded to my letter dated August 30, 2013. A representative from the US EPA called to discuss the contents of the letter on September 20, 2013. In addition, the US EPA also responded by formal letter dated September 24, 2013. Most of the response focused on provisions of the Safe Drinking Water Act (SDWA). The US EPA formal response letter is provided in the link below.

Response from US EPA dated 09/24/13 about Inquiry on the Riders Disposal Area hazardous waste site dated 08/30/13