Paoli Rail Yard
Current Site Information
EPA Region 3 (Mid-Atlantic)Pennsylvania
EPA ID# PAD980692594
7th Congressional District
Last Update: January 2015
Conrail Repair Shop
Paoli PCB Site
Paoli Railcar Facility
Current Site Status
On May 5, 2011 EPA issued a Five-Year Review for the Paoli Rail Yard Superfund Site (Site). EPA is required to conduct this review to ensure that the remedy is protective of human health and the environment. As required, a similar review will be conducted every five years. The assessment of the Site by this, the first Five-Year Review, finds the Remedy has been constructed in accordance with the requirements of the Record of Decision (ROD), as modified by issuance of three Explanation of Significant Differences, and is functioning as designed. Cleanup standards for PCB-contaminated soils have been achieved on the rail yard property and at residential properties where soils were removed. In addition, the majority of PCB-contaminated sediments have been removed from stream areas impacted by the rail yard. Activities necessary to achieve all remaining cleanup standards and final site completion have been initiated. To achieve the final cleanup standards in the stream areas, sediments are removed, via vacuum truck, as they accumulate in designated deposition areas as part of the stream maintenance program. Operation and maintenance (O&M) of the rail yard portion of the Remedy includes operation of the groundwater treatment system to achieve final cleanup standards. Ground water monitoring is being conducted as required. The immediate threats have been addressed and there are no current exposures to site-related contaminants.
The review found the remedy is protective in the short-term and is expected to be fully protective when the remaining cleanup goals are achieved through continued O&M activities. Monitoring of ground water and sediments is expected to continue until these goals are met. The Institutional Controls required by the ROD, as modified, are being implemented and enforced pursuant to a settlement between the United States and the Rail Companies [Southeastern Pennsylvania Transportation Authority (SEPTA), National Railroad Passenger Corporation (Amtrak), and Consolidated Rail Corporation (Conrail)]. These restrictions apply only to the rail yard portion of the Site and are intended to protect the remedy without preventing re-use of the property in a manner that is compatible with the remedy. A copy of the final Five-Year Review Report is available.
The remedy is being conducted by the responsible parties under EPA's oversight. Cleanup of the rail yard, including the O&M of the ground water treatment system, is being conducted by the Rail Companies. Cleanup of non-rail yard areas, including the stream areas, is being conducted by American Premiere Underwriters (APU). EPA will continue to evaluate the sampling data collected by the responsible parties and oversee the various O&M activities at the Site. O&M of the rail yard portion of the Site may include upgrades or modifications to the groundwater extraction and treatment systems, including the installation of additional monitoring and/or extraction wells as necessary. EPA and the Rail Companies conduct regular inspections to assure that the containment cell and storm water management system, and the various erosion controls are properly maintained. Monitoring of the stream areas will continue to ensure all cleanup goals are met and restoration activities are successful.
Summary Rail Yard Cleanup
The cleanup of the rail yard incudes the following: 1) Excavation, on-site treatment and disposal of PCB- contaminated soils; 2) Installation of erosion and sedimentation controls to manage and control storm water runoff and erosion from the rail yard; 3) Decontamination and demolition of buildings and structures on the rail yard; and 4) Pumping of groundwater contaminated with fuel oil and benzene and long term groundwater monitoring.
Beginning in 1999, track and ties located in areas requiring soil removal, were removed and either recycled or sent to an approved disposal facility. Cleanup of the rail yard, began in 2001. Erosion and storm water run-off has been controlled with the construction of a retaining wall on the northern boundary of the yard along with the construction of several new storm water basins. All buildings, except for a few storage sheds, have been decontaminated, demolished and disposed of at approved facilities. Excavation and treatment of soils found to contain PCBs in concentrations exceeding 25 parts per million (ppm), the cleanup standard for the rail yard property, is now complete. Approximately 83,000 cubic yards of stabilized soils were placed in the on-site containment cell. The liner component was installed and the cell was seeded. Disturbed areas have been backfilled with clean soil and stone, the property was graded and storm water controls have been completed.
The groundwater portion of the cleanup began in 1990. A groundwater treatment and fuel oil recovery system was installed to address contamination in the area where the former rail yard maintenance shop was located. Historically, the fuel oil which leaked into the ground in this area was found to contain PCBs and elevated levels of benzene, toluene, ethyl benzene and xylene. The area, referred to as the fuel oil soils area, is currently covered with asphalt. The remedy does not require removal of the fuel oil soils, but requires that the asphalt cover remain intact and that the contaminated fuel oil soils be addressed by the operation of the groundwater treatment and fuel oil recovery system. The objective of the remedy is to: prevent any migration of fuel oil and PCBs from the rail yard; and to extract and treat benzene to achieve site cleanup standards.
Since start-up in 1990, the groundwater recovery and treatment system has been modified several times. Due to recent reductions in the amount of fuel oil recovered, active fuel oil recovery has been discontinued. However, the on-site wells are monitored for the presence of fuel oil. If present, oil will be manually removed from the wells. If necessary, based on results of the monitoring program, active fuel oil recovery may resume. In January 2005, a pump was installed in monitoring well (MW-22) in an effort to address the remaining area where benzene was present in groundwater above EPA's cleanup standards. Contaminated groundwater was pumped and treated via carbon adsorption and then discharged to an on-site underground infiltration gallery. The pump and treat system was shut-down in November 2007 due a small leak, and as an alternative to performing repairs, the Rail Companies began implementation of an in situ chemical oxidation pilot study in the area of MW-22. Several applications of oxidants have been conducted to date. Sampling results indicate that benzene levels have been decreasing since the in situ treatment began and are currently below performance standards.
Summary of Non-Rail Yard Area Cleanup
The cleanup of contaminated residential and stream areas began in November 2001. Areas containing soils and sediments with PCB concentrations greater than 25 parts per million (ppm), which required treatment at the rail yard, were prioritized for cleanup. Approximately 1000 cubic yards of contaminated soils and sediments was removed and delivered to the rail yard in 2001. In 2004, approximately 200 additional cubic yards of > 25 ppm PCB-contaminated soils and sediments removed from floodplain areas was delivered to the rail yard. Based on the sampling results, all PCB contaminated soils and sediments with concentrations > 25 ppm have been removed from the residential properties and stream areas, treated at the rail yard, and placed in the containment cell.
Approximately 9,000 cubic yards of non-rail yard soils and sediments with PCB concentrations less than 25 ppm were excavated from residential properties and floodplain areas and placed in the designated debris placement area on the rail yard. Confirmation sampling was conducted to assure that residential properties met the property-wide cleanup standard of 2 ppm. All residential areas have been fully restored. Large flood plain areas remediated have been restored and will be monitored in accordance with O&M plan.
Approximately 150 cubic yards of PCB contaminated "wet" stream sediments were removed from several in-stream locations via vacuum truck. With EPA's approval, these sediments were taken to an approved off-site facility. Sediments were dewatered and placed in an approved landfill. To minimize disturbance to the tributaries and streams and achieve the 1 ppm cleanup standard in all impacted areas, additional sediments are being removed from a limited number of depositional areas as they accumulate. Tributaries and streams will continue to be monitored to ensure the cleanup and restoration activities are successful.
The Paoli Rail Yard Site includes the 28-acre Rail Yard Property, the surrounding residential areas and the approximately 400 acre watershed north of the Rail Yard Property. The Rail Yard consists of an abandoned electric train repair facility and a commuter rail station. The Penn Central Corporation was the original owner and operator of the facility. The facility is currently owned by Amtrak and is operated by the Southeastern Pennsylvania Transportation Authority (SEPTA). Prior to SEPTA, during Amtrak's ownership, Conrail operated the Rail Yard. Commuter trains were serviced, repaired, and stored at this facility. Routine maintenance and repair of railroad cars involved electrical equipment that contained PCBs. Until 1986, the Rail Yard was unsecured and easily accessible; residents and commuters regularly used it as a shortcut to reach both the train station and surrounding commercial properties.
In the late 1970s, both the EPA and the Pennsylvania Department of Environmental Resources (now called Pennsylvania Department of Environmental Protection or PADEP) inspected the Rail Yard. Amtrak, Conrail, and SEPTA (the Rail Companies) were required to determine the extent of contamination and to correct any problem areas. The Rail Companies collected samples, cleaned up, and further studied the area. In 1985, samples taken in 1984 were made available to the EPA, indicating a severe PCB problem at the Rail Yard. These sample results were verified, and in 1986, the EPA filed a complaint seeking an order to require the Rail Companies to limit access to the Rail Yard, control the movement of PCBs from the Rail Yard, conduct sampling and analysis, and to clean up the Rail Yard. The Rail Yard is surrounded on three sides by residential communities, and on the fourth side, by commercial facilities.
Site ResponsibilityThis site is being addressed through federal, state, and potentially responsible parties' actions.
NPL Listing HistoryOur country's most serious, uncontrolled, or abandoned hazardous waste sites can be cleaned using federal money. To be eligible for federal cleanup money, a site must be put on the National Priorities List. This site was proposed to the list on January 22, 1987 and formally added to the list August 30, 1990.
Threats and Contaminants
Erosion of soils from the Rail Yard has contaminated nearby Valley Creek and its tributaries with PCBs. In addition, residential properties located near the Rail Yard were also found to be contaminated with PCBs. While the rail yard facility was still in operation, car shop workers were found to have elevated levels of PCBs in their blood.
Direct contact with contaminated soil was the main health threat to the general public. However, this threat has been substantially reduced by fencing the Rail Yard property in 1986. Soil excavations on the Rail Yard and in residential areas, which began with early removal activities in 1989 and have been recently completed as discussed above, have further reduced the risk from direct soil contact.
Cleanup of contaminated sediments in the stream areas has begun and will continue as necessary to achieve the 1 ppm clean standard for the tributaries and streams. The State banned fishing in nearby Valley Creek when PCBs were found in fish and creek sediments. Valley Creek flows through Valley Forge National Historic Park.
Contaminant descriptions and risk factors are available from the Agency for Toxic Substances and Disease Registry, an arm of the CDC.
The direct contact threat has been substantially reduced by limiting access to the Rail Yard by fencing, installed in 1986, and by the soil excavations discussed above. Extensive sampling of the Site by the Rail Companies, the State, and the EPA characterized the contamination. Based on the early sampling results, three basins were constructed by the EPA to prevent erosion of contaminated soils. Early activities, beginning in 1989, included, the removal of 3500 cubic yards of contaminated soils from 35 residential properties. EPA paved the parking lot and other high-use areas of the car shop in 1987 to prevent the spread of the PCB-contaminated soils from vehicular and foot traffic.
EPA signed a final Record of Decision (ROD) in July 1992 requiring excavation and treatment using a solidification process for approximately 28,000 cubic yards of contaminated Rail Yard soils. The ROD also requires excavation of contaminated soil from residential areas and contaminated stream sediments. Additionally, a system to recover fuel oil from the groundwater began operating in 1990. EPA and PADEP negotiated with the Rail Companies to conduct the Rail Yard portion of the remedy. On April 17, 1997, the Rail Companies signed an Early Action Order agreeing to conduct the remedial design of the Rail Yard remedy. In April 1999, a federal court approved the negotiated consent decree. The consent decree requires the Amtrak, Conrail, and SEPTA to pay $500,000 to EPA and $100,000 to PADEP as compensation for prior removal activities involving the site, and to perform all remaining response actions at the Rail Yard Property. The settlement also obligates the parties to pay $850,000 to federal and state trustees to settle claims for damage to natural resources.
In addition to those activities discussed under "Current Site Status" above, activities conducted at the Rail Yard since May 2001 include: clearing and grubbing; removal of debris including rail and ties; installation of new security fencing and improvements to existing fencing; construction of haul roads to manage construction vehicles during soil cleanup activities; construction of two new storm water retention basins; preparation of areas on the Rail Yard to accept Non-Rail yard soils and stream sediments with low levels of PCBs; and the construction of an on-site containment cell to accept treated soils. In the Fall of 2001, the Rail Companies began processing contaminated Rail Yard soils which were excavated as part of the above construction activities. In addition, a retaining wall was constructed along Central Avenue to aid in providing permanent erosion control.
On September 30, 1996, EPA issued an Order to APU (successor to the Penn Central Corporation), to conduct the cleanup of contaminated residential areas and stream sediments. Per EPA's requirements, residential soils are to be cleaned up to an average concentration of 2 ppm PCBs at each individual property. In November 2001, EPA approved a final design for the cleanup of residential properties. The cleanup of residential soils began shortly thereafter. Excavated residential soils were taken to the Rail Yard for containment and/or treatment.
During the Summer of 2001, sampling of the stream sediments along Valley Creek and Little Valley Creek and their tributaries was conducted to determine where cleanup is required. The stream sediments are to be cleaned to a concentration of 1 ppm PCBs.
Sampling conducted at the head of the Hollow Road Tributary identified high levels of PCBs in the soils and sediments in and around the area which was previously fenced to restrict access. PCBs were detected in this area at concentrations up to about 200 ppm, much higher than other downstream areas, as a result EPA approved a plan to conduct an expedited removal of contaminated soils and sediments form this area. In December 2001, with EPA's oversight, UMC excavated approximately 500 cubic yards of contaminated soils and sediments from the head of the Hollow Road Tributary. Following excavation activities, the area was re-sampled and preliminary results indicate that the cleanup goal of 1 ppm was achieved. All excavated soils and stream sediments were taken to the Rail Yard for treatment and the area has been restored to prevent future erosion. Additional cleanup activities conducted in the stream areas are discussed above under "Current Site Status".
EPA continues to coordinate with Tredyffrin and Willistown Townships, as well as Chester County, on a plan to develop the Site after the remediation is complete. A Transportation Center is planned for the Rail Yard property.