October 14, 2008

Engineering Testimony

Re: Act 2 Release Liability for the Proposed Notice of Intent to Remediate the McIntosh Road Site 

Department of Environmental Protection

Kathleen G. Horvath

Chief, Special Projects Section

Environmental Cleanup Program

909 Elmerton Avenue

Harrisburg, PA 17110-8200

Dear Ms. Horvath:

As a follow up to our meeting at your office on October 6, 2008, I asked a former  resident and retired Penn DOT engineer to provide first hand testimony of the  operations of the former Baltimore Tar Site. (Enclosed)  

Please note that his testimony is not edited, and his communication is in the format  I received via electronic mail at 2:53 pm on Monday, October 13, 2008.

The additional detailed significance of this Testimony is that it describes potential  contamination at the location of aggressive earth moving activities, indicates the need to sample the Creek bed, and outlines DEP regulations for drilling and coring all corners of  the area to test what has leached into the ground.  

In addition, it is unclear if this site can pass DEP's cleanup liability protection program  if disposal of waste came after 1980 -the year the Solid Waste Management Act took effect.

Respectfully submitted,

Eric Epstein, Chairman, SWAN

4100 Hillsdale Road 

Harrisburg, Pa 17112 

(717)-541-1101

Enclosure: Testimony 

cc:

William J. Kosmer, Pennsylvania Department of Environmental Protection

Lower Paxton Township Board of Supervisors

Lower Paxton Township Planning Commission

Dauphin County Conservation District

Lauri Lebo, Community Relations Coordinator, Pennsylvania DEP

                       Testimony

Eric

I am familiar with the property from the 1960's to present. The plant manufactured and stored asphalts, emulsions and cutback asphalts. Growing up in the area there were large tanks for storage on the hillside. On the hill side and to the rear of the tanks  equipment and machinery was stored. In this area there were also 50 gal. drums of materials  sitting for years rusting not empty. 

These plants had spills and over flow of materials, broken fittings and pipes created  spills and leaks. While in these early years there was none to minimal regulation over these operations. PennDot in the last 10-15 years eliminated the use of cutback asphalts. PennDot  and  the Asphalt Quality Improvement Task Force have declared wasted asphalt (roadway material)  as a hazardous material. Only to be stored on an approved pad and for not more  than a year and at the end of the year all 4 corners of the pad area must be drilled and cored to test what has leached into the ground as per DEP.  

In this type of processing asphalt for different uses there was the use and need for  chemicals to make the asphalt more solvent but still allowed the asphalt material to work as a  tack material for aggregate. There have been different materials used. There was the need to  make asphalt soluble. Most asphalts are equally solble in carbon disulfide and in carbon tetrachloride. Because carbon tetrachloride is not as flammable it is the solvent most commonly  used. There was always a test and materials used to keep the flash point of asphalt  materials  and by products down to a lower level.

Cutback asphalts is asphalt cement that is liquefied by blending with petroleum solvents or diluents. upon the exposure to atmospheric conditions the diluents evaporate leaving the asphalt  cement to perform its function. (RC) Rapid curing asphalt composed of asphalt cement naphtha or gasoline type diluent of high volatility. (MC) Medium Curing asphalt uses kerosene and  medium volatility dilutents Asphalt emulsions containing water and emulsifying agents

In this processing there were leaks of tanks and spills in moving materials from storage tanks  to transportation and distribution tanks. There are noe required catch basins to be constructed.  I believe the majority of materials at this plant could have gone into the ground though not  intentionally.

At this point someone is moving material in what I see as one of the volatile areas of this  property intentional or not? There are other places to test at out fall drainge areas from the  paved area between the buildings.

I can spend more time and depth on this if needed, let me know what you may want me to  be more clear on.