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Brodhead Creek

Stroudsburg, Pennsylvania
Proposed Plan Fact Sheet - June 1995

EPA Releases a Proposed Remedial Action Plan

On May 25, 1995, the U.S. Environmental Protection Agency (EPA) released its second Proposed Remedial Action Plan (Proposed Plan) for contamination at the Brodhead Creek Superfund Site. The Proposed Plan summarizes the results of the recently completed focused Remedial Investigation and Feasibility Study (RI/FS). It also explains various clean-up alternatives and highlights the alternative EPA prefers.

EPA divided the site into two areas called Operable Units (OUs). The first Proposed Plan, issued in 1991, addressed OU-1, free coal tar contamination in the site subsurface soils. This Proposed Plan for OU-2 addresses any residual coal tar and the contaminated groundwater at the site. Since any groundwater clean-up alternative may include addressing residual coal tar in the subsurface soils, EPA also evaluated alternatives for addressing subsurface soil contamination.

Unlike the Proposed Plan, this fact sheet is not a legal or technical document. The Proposed Plan can be reviewed at the information repository listed on Page 2. This fact sheet summarizes the information in the Proposed Plan, highlights EPA's preferred clean-up alternative, and reviews the site history. The public is encouraged to review the Proposed Plan which is located at the repository listed on page 3.

Site Contamination

A 1989 Remedial Investigation (RI) revealed coal tar contamination in the site's groundwater and subsurface soils. Groundwater is water that is located underground in rock formations called aquifers. Although the groundwater is contaminated, surface waters of the Brodhead Creek are not affected by the coal tar.

Pennsylvania Power & Light and Union Gas Company, the potentially responsible parties (PRPs) for site contamination, performed a focused RI for OU-2 to further look at the groundwater. This work was done under EPA oversight. In particular, they studied contamination in the deep aquifer below the site.

In May 1993, three bedrock wells were installed to determine how much the contamination was affecting the deep aquifer. The PRPs sampled the groundwater for volatile organic compounds (VOCs), semi-volatile organic compounds, dissolved metals, and cyanide. Sampling results revealed extremely small amounts of contamination present in the deep aquifer's groundwater.

In addition, a Risk Assessment was conducted to analyze the potential risks to human health and the environment posed by the groundwater. Currently, the shallow aquifer is being monitored as part of the remedy for OU-1. This monitoring data, along with results from the original investigation and information from the OU-2 investigation, was used to assess potential groundwater risks. The contaminants of concern in the shallow aquifer are polynuclear aromatic hydrocarbons (PAHs), benzene, and arsenic. No contaminants of concern were found in the deep (bedrock) aquifer.

According to the Risk Assessment, certain conditions at the site limit the current and future use of the groundwater from both the shallow and deep aquifers at the site and prevent the movement of coal tar off site.


Tuesday, June 6, 1995
7:00 p.m.

Monroe County Courthouse
Jury Assembly Room
Seventh and Monroe Streets
Stroudsburg, Pennsylvania

Cleanup Alternatives

The method (Alternative) that is used to clean up a hazardous waste site must meet several EPA requirements.

A Feasibility Study was conducted to look at a variety of technologies available to address contamination at the site. The technologies that were most applicable were developed into clean-up alternatives and reviewed by EPA. These alternatives are summarized below.

Alternative 1: No Further Action

This involves no further action beyond those activities already being conducted for OU-1. No further action would be taken to reduce the residual coal tar in the subsurface soils or to treat the groundwater. Creek and groundwater monitoring, which is part of the OU-1 remedy, would continue. In addition, as part of the OU-1 remedy, deed restrictions would be put in place to limit future use of the site.

Alternative 2: In-situ Stabilization/Solidification

In-situ stabilization involves the in-place blending of stabilizing materials with the contaminated soils. This would hold the contaminants in an inactive or static environment and reduce their ability to move into the ground-water. Studies would be required to select the best stabilizing materials for the soils.

Several site-specific conditions greatly limit application of this technology.

Alternative 3: In-situ Biological Treatment

In-situ bioremediation enhances the natural breakdown of contaminants in the subsurface soils and water without removing the surface soil. This is achieved by adding nutrients, oxygen, and in some cases, microorganisms to speed up the biodegradation of contaminants.

Several site-specific conditions greatly limit application of this technology.

EPA's Evaluation Criteria

EPA evaluates each alternative against the nine criteria below to select a preferred clean-up alternative.

  1. Overall protection of human health and the environment
  2. Compliance with applicable or relevant and appropriate requirements (ARAR)
  3. Long-term effectiveness
  4. Reduction of toxicity, mobility, or volume of contaminants
  5. Short-term effectiveness
  6. Implementability
  7. Cost
  8. State acceptance
  9. Community acceptance(Public Comment Period)

EPA's Recommendation

After evaluating the contamination studies, the risk assessments, and the proposed alternatives, EPA has chosen Alternative 1 - No Further Action as its recommended course of action for OU-2. The No Further Action alternative will be protective of human health and the environment.

Although the groundwater contamination poses a possible risk, several factors make it unlikely to be used, including an on-site levee and on-site wetlands. In addition, a municipal ordinance in the Borough of East Stroudsburg requires residents to hook up to the municipal water system. The Borough of Stroudsburg is currently developing a similar ordinance.

Existing site conditions will also prevent future exposure to contaminated subsurface soils. The slurry wall will prevent the free coal tar from entering Brodhead Creek. In addition, the remedy for OU-1 will reduce the highest concentrations of coal tar and increase the natural degradation of coal tar in the soils.

EPA's preference of Alternative 1 is only a recommendation. EPA seeks community input, and may change its selection based on citizen feedback.

Information Repository

EPA has set up public information files (Information Repository) to provide community access to documents on the Brodhead Creek Site. EPA encourages the community to visit the repository and review the site information files. The repository includes the Administrative Record file, which contains the complete Proposed Plan, technical reports, and other site documents used by EPA to select a clean-up remedy. The repository is located at:

Stroudsburg Borough Building
Seventh and Sarah Streets
Stroudsburg, PA 18360
(717) 421-5444
Hours: Mon.- Fri. 8 a.m. - 5 p.m.

Public Comment Period

The release of the Proposed Plan begins a 30-day public comment period which runs from May 25, 1995 to June 23, 1995.

EPA will review all comments and questions received during the comment period before selecting a final remedy for OU-2.

EPA encourages the community to review the Proposed Plan and submit written comments* to:

John Banks (3HW23)
Remedial Project Manager
U.S. EPA, Region III
1650 Arch Street
Philadelphia, PA 19103-2029

* Written comments must be postmarked by June 23, 1995.

Public Meeting

EPA will hold a public meeting to discuss the Proposed Remedial Action Plan. Officials from EPA will be on hand at the meeting to present information, answer any site-related questions, and accept any relevant comments. An official transcript of the meeting will be taken and later placed in the information repository. All interested community members are invited to attend. The meeting date, time, and location are:

Tuesday, June 6, 1995
7:00 p.m.

Monroe County Courthouse
Jury Assembly Room
Seventh and Monroe Streets
Stroudsburg, Pennsylvania 18360

Site Background

The Brodhead Creek Site occupies approximately 12 acres in the Borough of Stroudsburg, Monroe County, Pennsylvania. The site lies on the west bank of Brodhead Creek between the Route 209 and Interstate 80 bridges. Union Gas Company is a successor to companies which operated a coal gasification plant from approximately 1888 to 1944. A black, tar-like liquid known as coal tar was a waste product from plant operations. Coal tar contains chemicals which can pose a risk to human health and the environment.

In 1917, Pennsylvania Power & Light purchased a section of the Union Gas Company facilities. From 1917 until the 1960s, Pennsylvania Power & Light acquired additional properties, including property owned by Union Gas Company.

From 1981 to 1984, EPA and the Pennsylvania Department of Environmental Resources (PADER) studied the site and took several actions to contain or eliminate immediate threats caused by contamination. These actions included constructing barriers to reduce and stop the flow of coal tar off-site and excavations to recover coal tar. Pennsylvania Power & Light also studied the site from 1981 to 1982 and, in 1982, removed approximately 8,000 gallons of coal tar from an underground depression on the site.

In 1982, EPA placed the site on the National Priorities List, its list of sites targeted for potential cleanup under the Superfund program. In 1987, following negotiations with PADER, Union Gas Company and Pennsylvania Power & Light entered into a Consent Order. Under the terms of this Consent Order, the two companies agreed to conduct a Remedial Investigation and Feasibility Study.

In order to manage the site cleanup effectively, EPA divided the site into two sections called operable units. Operable Unit 1 (OU-1) includes the two subsurface areas of pooled coal tar on the site. Operable Unit 2 (OU-2) includes the remainder of the coal tar, as well as groundwater. Groundwater is fresh water located in rock formations below the earth's surface that can supply wells and springs.

After reviewing the Remedial Investigation and Feasibility Study reports, EPA issued a Proposed Plan explaining its preferred cleanup method for OU-1. EPA reviewed public comment and, in 1991, issued a Record of Decision for OU-1 which announced EPA's plan to recover the subsurface pooled coal tar contamination.

On September 2, 1992, EPA, Pennsylvania Power & Light, and Union Gas Company entered into a Consent Decree and agreed to design and implement the remedy for OU-1. In addition, the two potentially responsible parties subsequently agreed to conduct a Remedial Investigation and Feasibility Study for OU-2. The process to be used for OU-1 is called the Contained Recovery of Oily Wastes (CROW). The CROW process involves injecting hot water into the contaminated areas to flush out the pooled coal tar. The coal tar will then be pumped out and taken off-site for disposal. The excess water used during the CROW process will be cleaned before being discharged into Brodhead Creek.

On July 14, 1994, EPA issued an Explanation of Significant Differences (ESD) which revised the performance standards of the interim remedy for OU-1. At this time, the CROW system has been constructed and is expected to become operational in Spring 1995.

On June 3, 1992, Pennsylvania Power & Light and Union Gas Company entered into a Consent Order with EPA to conduct the Focused Remedial Investigation and Feasibility Study for OU-2 to further investigate groundwater contamination at the site.

Things To Remember

For more information

on the Brodhead Creek Superfund Site, please contact:

Community Involvement Coordinator
Bill Hudson
(215) 814-3214

Region 3 | Mid-Atlantic Cleanup | Mid-Atlantic Superfund |EPA Home | EPA Superfund Homepage

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