The approximate 8.8-acre property, currently owned by the Lancaster County Solid Waste Management Authority (LCSWMA), is located on the north side of the existing rail tracks and situated between the rear of the United States Postal Service facility on Harrisburg Pike to the east and the Little Conestoga Creek to the west.
Days Cove Reclamation Company (Contractor) of Annapolis, Md., was selected to complete the remediation work. This firm is a highly qualified environmental remediator with extensive landfill design, construction, operation and closeout experience. This Contractor has many years of experience with the handling of a broad range of waste types such as those present on the 8.8-acre LCSWMA parcel. The Company has a strong compliance history since its formation in 1992 until the present.
ARM Group, Inc. (ARM) of Hershey will be the project manager. ARM will supervise the Contractor, including its operation of environmental controls. ARM will be responsible for all of the prescribed environmental monitoring procedures, including the operation of monitoring instruments and related equipment; likewise, ARM will direct or otherwise implement all necessary measures to protect the health and safety of the workers and neighbors. As an independent environmental and earth resources consulting company, ARM has more than 10 years of experience in the field of environmental consulting and remediation. ARM conducted the environmental testing of the site and is therefore most familiar with possible contaminants that could be encountered and how to appropriately handle and properly dispose of them. The remediation will follow applicable federal and state regulations, and it will be completed according to industry best practices. ARM’s principals have been performing environmental investigation and remediation services for more than 30 years, and they have conducted dozens of environmental remediation projects in Lancaster County since the 1980s.
The Act 2 Remedial Investigation and Clean-up Plan that was approved by the Pennsylvania Department of Environmental Protection (DEP) estimates eight months to complete the work, including contractor mobilizing and demobilizing. Truck activity is not expected to occur during the entire work period, and most of the site work should be finished in six months.
The hours of operation have been approved as Monday through Friday from 6:30 a.m. to 5:30 p.m., and on Saturdays from 6:30 a.m. to 3 p.m. However, depending upon actual site conditions, weather and schedule, the Contractor may elect not to operate during all of these time periods.
We have discussed the work hours with Bob Desmarais, president of the Old School Lane Hills Neighborhood Association. We assured Bob that the Contractor would be respectful of the neighbors closest to the work area. Also, it was our intention that if Saturday work is required it will not begin before 7:30 a.m.
A construction entrance will be created at the western end of Vermont Avenue, a private road running along Baker Campus, extending from Harrisburg Pike to the site. Vehicles will then transition to an existing road on the Brick Yard property, which leads under the railroad tracks and enters the former dump area. Loaded trucks will retrace this route, going through a tire wash station before leaving the Brick Yard property and heading eastward on Vermont Avenue. The trucks will turn right on Harrisburg Pike, proceed through the traffic light and then turn left into the LCSWMA property. The trucks will loop back to the traffic light at LCSWMAs entrance, turn right on Harrisburg Pike and proceed to the Route 30 interchange and head west to reach LCSWMAs Frey Farm Landfill in Manor Township.
Using approximately 15 to 18 trucks, the Contractor will make between 56 and 70 round trips a day hauling the waste material to the landfill and returning with clean fill to place in the excavated areas. The 70-truck round trip estimate is conservative and the exact number of trips will not be known until the work is under way. To put this number into context, it is likely that on an average workday there will be eight to 10 trucks per hour entering or leaving the siteor about one every six or seven minutes.
As for noise created by the waste-removal process, sound levels are predicted to be naturally attenuated to typical daytime background levels (5055 dba) at a distance of between 400 and 800 feet from the site access road or from the active work area. Traffic and commercial activity on Route 30, Harrisburg Pike and Vermont Avenue currently creates consistent background noise (5055 dba). Trucking activity will occur for a relatively short period of time (most likely six months of actual activity). There is extensive vegetation as well as considerable distance from the site access road to the closest neighbors both of which will reduce sound transmission. Reasonable measures such as time and days of operation will be balanced with the scope of work. The goal is to minimize any short-term noise by balancing hours and days of operation with the amount of time necessary to complete the work so as to avoid extending the overall length of the job.
ARM Group will ensure that the extensive steps described in the projects Health and Safety Plan (HASP) will be taken by the Contractor to maintain compliance with applicable state and federal environmental regulations, as well as industry best practices for this type of work to ensure our neighbors safety and the safety of all project workers.
These measures include excavating the site in small, tightly managed cells or strips, limiting exposed excavation to no more than three or four cells at a time. This prevents the entire site from becoming an open excavation pit by limiting excavations to only small work zones.
Second, water misters will be used to moisten the material being removed, as appropriate, to reduce dust and to effectively bind substances together. The moistened material will be placed in tri-axle dump trucks with tarps tightly covering the material. The trucks will drive to the Frey Farm Landfill in Manor Township for proper disposal.
Third, with respect to the management of asbestos-containing material (ACM) at the site, a primary concern has been whether ACM, where present, is friablethat is, able to be reduced to powder by hand pressure, when dry. This is a determination that will be made by an on-site licensed asbestos inspector employed by ARM Group. If friable ACM is found, then special waste-management procedures (leak-proof containerization) will be employed, as required by federal regulations. It is worth noting that extensive testing at the site has revealed no friable asbestos. Moreover, it is also important to remember that when encountered, ACMs, whether friable or non-friable, will be kept wet, such as by the use of portable mister or soaker systems, and will be managed and removed according to all applicable state and federal regulations. In this manner, they will be kept in a condition that is not prone to produce dust in association with waste excavation and handling activities.
Environmental controls that will be routinely employed by the Contractor in association with waste excavation and loading, and in association with soil backfilling and compaction include portable water mister and soaker systems to prevent or otherwise effectively mitigate the occurrence of particulates in air (dust), and water-containment systems that will direct filtered water either to a discharge into the LASA sewer system, or in the case where water does not contact waste materials, a discharge to established erosion and sedimentation controls (silt fencing and level spreaders, etc.).
Direction as to the need for the operation of the dust suppression systems will come from ARM Group who will operate three different types of air-monitoring programs; personal air monitoring; work-zone air monitoring and perimeter air monitoring. Perimeter air-monitoring stations will be established at the immediate up-wind and down-wind locations on the site boundary, with respect to the location of active waste handling activities. The details of these three distinct monitoring programs are fully described in the project HASP.
Simply stated, each air-monitoring program will combine the use of hand-held instruments that will generally produce real-time measurements of dust, asbestos fiber and lead particulates in air concentrations, with stationary filters that are collected initially on a daily basis, and then later, depending upon results, on a weekly basis for off-site laboratory analyses of samples collected for dust, asbestos fiber and lead particulate testing. Likewise, hand-held instruments will be employed to monitor the work zone for the presence of landfill gas and for other chemicals (volatile) in air. Hand-held instruments that will be employed for these purposes include: combustible gas indicator; photoionization detctor, integrating sound level meter; ambient dust monitor; fiber analysis meter; and X-Ray fluorescence analyzer (XRF).
The monitoring program will be continuously conducted while all waste-handling operations are active, and the results of monitoring will be constantly compared to established action levels for the project. These action levels have been set at the applicable levels prescribed by the Occupational Safety and Health Administration (OSHA), or by National Institute for Occupational Safety and Health (NIOSH), or via applicable federal (EPA) regulations; these numerical action levels are known as permissible exposure levels (PELs) or EPA Action Levels, and ARM will utilize the hand-held instruments and the results of the stationary monitoring devices to monitor and to take whatever actions are needed to maintain compliance with these standards.
To reiterate, these protocols for measuring air quality at the property perimeter and in the work zone are detailed in the HASP for the project. Also, a considerable amount of project details are provided in the Act 2 Remediation Plan that we filed with the Pennsylvania Department of Environmental Protection. Each remediation project of this type is required to have a HASP developed and in place prior to beginning each project. Our document is now available on the projects Web site at www.fandm.edu/railyard.xml under the Act 2 tab.
Through the measures outlined in our HASP and the professional experience of the project manager and Contractor, the remediation work will be performed in compliance with applicable OSHA, NIOSH and EPA regulations and in accordance with best practices of the industry. This will ensure that any risk, while very small, will be managed aggressively on a real-time basis, and fully mitigated.