December 18, 2008
On behalf of both Franklin & Marshall College and Lancaster General, we are writing to update you on the progress of the proposed Norfolk Southern Dillerville Railyard Consolidation Project.
Through much of the last year, the project partners sponsored numerous community meetings to keep our neighbors informed about the status of the project. These meetings ranged from small groups held in the communities that are near the project site, to a large public forum, attended by approximately 300 people, on June 19, 2008.
Most recently, on November 13, 2008, Manheim Township officials held a public meeting regarding the Pennsylvania Department of Environmental Protection’s Act 2 Program and our approval under it to remove the contents of the former municipal dump where a portion of the consolidated railyard will be located. About 60 residents attended the meeting.
Our desire, through these meetings and our Web site about the project, is to keep our neighbors informed about every aspect of the project. We also have committed to keeping the residents up to date as we reach milestones in the project’s schedule.
The purpose of this letter is threefold: first, to inform you about the tentative start date for removing the trash from the former municipal dump and transferring it to the Frey Farm Landfill; second, to renew our offer of additional neighborhood meetings as a means of keeping everyone informed about the project; and third, to provide another edition of Frequently Asked Questions (FAQ) for the project.
A contractor has been selected to perform the project’s environmental remediation work, which involves the safe removal of the contents of the former municipal dump on the property owned by the Lancaster County Solid Waste Management Authority (LCSWMA). Mobilization is expected to begin at the end of this month and sitework is scheduled to begin by mid-January. The contractor for the work is Days Cove Reclamation Company and the project manager is ARM Group, Inc. We want to assure you that the work undertaken by these experts will be done according to federal and state guidelines. These firms have extensive experience in performing waste removal projects and will use industry best practices to ensure the work is done properly and safely.
The majority of the removal action likely will take six months to complete. Please see the attached FAQ sheet for more details about the work to be performed.
Although we have done significant outreach to the neighborhood about this project, we understand that there may be residents who have been reluctant to raise questions in the larger public meetings. We came to this conclusion based upon several conversations we had with residents who attended the November 13, 2008, public meeting in Manheim Township. To encourage their participation, we have decided to offer additional small "living room" gatherings to discuss the project. If you are interested in hosting such a small meeting in your home for your immediate neighbors, please contact either of us to discuss possible dates.
Finally, we invite you to read the attached FAQ sheet covering the waste-removal process as well as several other topics for additional project information.
If you have any questions during the course of the project, please contact Keith Orris at 291-3868. We will continue to send letters as project milestones are achieved so that you are informed.
Keith A. Orris
Vice President for Administrative Services & External Affairs
Franklin & Marshall College
Office Phone: (717) 358-3868/E-mail: email@example.com
Executive Vice President for Strategic Implementation & Chief Mission Officer
Office Phone: (717) 544-1115/E-mail: firstname.lastname@example.org
Environmental Remediation Process
Where is the location of the property being remediated?
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.
Who will be performing the actual remediation work?
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.
Who will manage the project?
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.
How long will the work take to complete and when will it be performed?
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.
How will the trucks enter and exit the site and how many trucks per day will be operated?
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.
What measures will be taken to control and manage any encountered contaminants?
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.
How will the work be undertaken and monitored?
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 project's Web site 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.
How has the proposed layout of the project been designed and are there any viable alternatives?
The project partners retained Gannett Fleming (GF), a global, multi-disciplined engineering firm based in Harrisburg, for its expertise in railroad design. GF extensively studied alternative designs that balanced Norfolk Southerns (NS) operational and safety needs for the railyard, available land, vehicular traffic patterns on city streets and state roads, relationship to the AMTRAK tracks, existing transportation and railroad infrastructure, utilities, environmental impacts and the needs of Franklin & Marshall College and Lancaster General.
The Rail Road Action & Advisory Committees (TRRAAC) two proposed alternate sites were considered even before TRRAAC came into existence, and both sites were rejected because they failed to meet the important design criteria listed above. After more than two years of extensive review and consideration, the current plan is the only layout that has met the design criteria and project goals.
In addition, Norfolk Southern has reviewed TRRAACs two locations and has decided that neither option offers a viable alternative to the current proposal.
You may find GFs comments on TRRAACs two proposed alternate sites and why they do not meet the design criteria on our projects Web site.
Noise, Vibration, Air Quality & Light
How will the project impact the neighborhood, from a perspective of noise, sound, vibration and light?
We were concerned from the outset of the project about how it might impact the surrounding neighborhood. Based upon its railroad experience GF experts believed there would be no significant impact. To ensure this will be the case and to address the communitys and TRRAACs concerns, GF conducted a study of the potential impact of noise, vibration and air quality, as well as an overall health-risk assessment. We instructed GF to dedicate specialty scientists for these disciplines and to conduct the studies in a very conservative manner. Based upon its experience and relevant governmental regulations, GFs scientists believe our approach to these studies is extremely conservative.
The results of the studies, and a summary page for each, are listed on our Web site.
The studies results indicate that based upon federal governmental regulations and guidelines the potential impact of the noise, vibration and air quality from this project is well below impact criteria and levels that would require mitigation steps.
Even though the noise studies indicate that no mitigation is necessary, the project partners have committed to installing a feature that would reduce existing and future noise along the rail tracks adjacent to the Colleges Brick Yard property. This feature will most likely be a raised earthen berm planted with evergreens, which is an effective noise-dampening device.
Regarding the question of light pollution from the new yard, there will be no tall directional lighting fixtures. Instead, standard municipal streetlights (cobra light fixtures mounted to wooden poles) will be installed along an access road and at several locations in the yard. Consequently, there will not be the light pollution as there might be from tall commercial or industrial light fixtures.
Have the project partners responded to TRRAACs concerns?
The Dillerville Yard Consolidation project was announced more than two years ago. TRRAAC was formed a little more than a year later. During this period, the project partners have been very responsive to TRRAACs questions and concerns. For instance:
1. We have answered in detail all of the voluminous inquiries submitted by TRRAAC and its consultants. For transparency purposes, the original letters and the responses can be found on the projects Web site. We requested TRRAAC publish these materials on their Web site as well.
2. Members of TRRAAC were invited to participate as municipal representatives in a February 13, 2008, focus group to receive an in-depth briefing on the project. We followed TRRAAC representatives suggestion not to hold the public meeting until the results of the noise, vibration and air-quality studies were complete, which in turn delayed the public meeting to mid-June.
3. We followed TRRAAC representatives request to work with PennDot to amend its standard public meeting format to incorporate a group question-and-answer session, which is not typically included.
4. On April 10, 2008, we offered to share equally the cost of a qualified independent engineer to review the proposed plans andresults of studies to determine if the design could be improved or if another alternate location would be better. The proposal was to have TRRAAC, Manheim, Lancaster and East Hempfield townships share the cost of this study with the project partners, and to have the project as the client to eliminate any of the funding parties from unduly influencing the engineers results. TRRAAC rejected our proposal, though it now claims that alternate sites have not received sufficient consideration.
5. On June 16, 2008, we invited TRRAAC leaders to meet with GF to discuss TRRAACs two alternate plans. GF reviewed how and why features of the two alternates were considered and rejected early in the design process and how other aspects fail to meet Norfolk Southerns operational needs. We provided specific reasons why these two alternate plans do not work.
Since this meeting, the project partners contacted Donnelly Printing and they reconfirmed their unwillingness to sell any of their land to make the existing yard larger. In addition, Norfolk Southern confirmed that they have reviewed TRRAACs two suggested locations and do not consider them viable alternatives to the current proposal.
6. At the June 19, 2008, public meeting, TRRAAC informed us it was going to retain an engineering firm to review GFs design and offer ideas for improvement. TRRAACs engineer attended the public meeting. We agreed to meet with TRRAAC when its study was complete to consider any ideas and suggestions. We also indicated that the results of the study would need to be received by late summer in order to have an opportunity to incorporate any acceptable suggestions into our projects design. We are not sure if this study was completed because TRRAAC has not contacted us about the report.
Correspondence regarding these offers are on the projects Web site.
7. TRRAAC expressed concern about the noise, vibration and air-quality impacts of the project. We delayed the project by several months and incurred additional costs to have GFs specialty scientists conduct environmental studies into these topics. The results of these studies confirmed that any impact would be well below any federal governmental regulation that would require mitigation steps of any kind.
8. Without any laboratory testing of samples, TRRAAC claimed that asbestos-containing flooring material (ACM), supposedly buried in the former municipal dump, would be friable (airborne) and could become a health risk to the community. Samples of 12 different types of flooring material that we collected from the dump in April, 2008, showed that only two of the 12 samples were found to contain asbestos, and that in both ACM samples it was organically bound to the flooring material and consequently non-friable. To date, except for anecdotal claims by TRRAAC, there is no evidence of the existence of friable ACM in the former dump site.
9. TRRAAC claimed that health risks would be created from removing the material in the dump. In response, we instructed ARM Group to include in the Act 2 remediation plan an extensive section that is the basis of the Health and Safety Plan, which will be used in performing the removal work. This level of health and safety procedural detail is typically not included in an Act 2 application (clean-up plan) but was supplied to show our commitment to full disclosure and openness with respect to the projects details. DEP approved the projects Act 2 cleanup plan because it concluded that the materials at the site can be removed safely and without harm to the community.
10. The project partners met with TRRAAC representatives earlier this month to listen to their concerns, which had been explained in prior settings and correspondence. The partners responded again to their main concerns.