PB99-963104
EPA541-R99-004
1999
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Whitmoyer Laboratories Site
Myerstown, PA
11/16/1998
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EXPLANATION OF SIGNIFICANT DIFFERENCES No 3
WHTTMOYER LABORATORIES SUPERFUND SITE '
I. INTRODUCTION
Site Name: Whitmoyer Laboratories Superfund Site
Site Location: Myerstown, Lebanon County, Pennsylvania
Lead Agency: U.S. Environmental Protection Agency, Region in
(EPA or the Agency)
Support Agency: Pennsylvania Department of Environmental Protection (PADEP)
* ^_ A S6C?rd °f Decision (K00) for me Whitmoyer Laboratories Superfund Site (Site)
for Operable Unit Two (OU-2) was issued on December 17, 1990 and a ROD for Operable
Unit Three (OU-3) was issued on December 31, 1990. This Explanation of Significant
Differences (ESD) which modifies the OU-2 and OU-3 RODs is issued in accordance with
Section 117(c) of the Comprehensive Environmental Response, Compensation and Liability
Act, as amended by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), 42 U.S.C. § 9617(c), and 40 C.F.R. § 300.435(c)(2)(i).
This ESD No. 3 has been prepared to provide the public with an explanation of the
nature of the changes made to the selected remedy identified in the RODs for OU-2 and OU-
3; to summarize the information that led to the making of the changes; and to affirm that the
revised remedy complies with the statutory requirements of CERCLA § 121, 42 U.S.C. §
9621. The proposed alternative does not fundamentally alter the remedy selected in the ROD
for OU-2 or OU-3 with respect to scope, performance, or cost; therefore, a ROD amendment
is not required. This ESD is incorporated into the Administrative Record for the Site.
New information became available following the issuance of the RODs for OU-2 and
OU-3 which gave rise to the need for an ESD. Specific information acquired during the
Remedial Design includes: (1) a detailed delineation of the lagoons which determined that
approximately 6,890 cubic yards (cy) of hazardous lagoon wastes require treatment prior to
disposal in an off-Site landfill; (2) the completion of bench-scale treatability tests which
demonstrated the ability to successfully treat hazardous soils and lagoon wastes off-Site; and'
(3) the passage of the Phase IV Land Disposal Restrictions which provides an alternate'
treatment criterion for soils. The new information acquired and EPA's conclusions are
discussed in more detail below.
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CONTAMINATION PROBLEMS, AND <§
Wh*tm?)yer Laboratories Site is the location of a former veterinary feed additives
C
md lfi - at *" » ta!934 and
mid-1950 s, the facility began using arsenic in the production of feed additives Other
products produced included a coal-tar dip, used to treat skin disorders; piperazine a
worming agent; and sulfa drugs, used to inhibit bacterial growth. In addition to aVsenic a
number of products manufactured by the facility contained aniline, an organic chemical
derived from benzene.
The original Site owner, Clarence W. Whitmoyer, Sr. sold the facility to The Rohm
and Haas Company in 1964. In 1978, The Rohm and Haas Company sold the facility to
Beecham Inc., who in turn sold the facility to Stafford Laboratories, Inc. in 1982 Stafford
Laboratories, Inc. filed for bankruptcy protection under Chapter 11 of the U.S. Bankruptcy
Code in mid-1984 and continued operations at the Site until January 1987.
EPA began assessing Site conditions hi 1984. However, when the facility closed ha
1987, the Resource Conservation and Recovery Act (RCRA) Closure Plan had only been
parually implemented. The Site was listed on the National Priority List (NPL) in 1986 and
throughout 1987, EPA conducted numerous sampling activities, both on- and off-Site. In
1988, EPA removed approximately 400 drums from the Site while beginning a fund-lead
Remedial Investigation/Feasibility Study. A ROD for Operable Unit One (OU-1) was issued
in June 1989 for the consolidation, removal and treatment of concentrated liquids and
decontamination of 32 tanks and vessels. The Remedial Action for OU-1 was completed in
September 1990.
The ROD for OU-2 was issued hi December 1990 and addressed the concentrated
wastes hi the concrete vault, wastes abandoned hi two groups of lagoons, products and
miscellaneous materials abandoned hi buildings, and the buildings and related structures. A
complete description of the selected remedy as well as EPA's rationale for the decision is
presented hi the ROD for OU-2. The major components of the ROD for OU-2 are:
• On-Site incineration of the high organic content vault wastes, contents of buried
drums located adjacent to the vault, residual materials remaining hi tanks and process
vessels, miscellaneous products and feedstocks, and combustible demolition debris
exhibiting the RCRA arsenic toxicity characteristic;
• Fixation of lagoon wastes, incineration residuals, and low organic content vault
wastes;
• Surface cleaning and demolition of contaminated Site structures;
• Coating and sealing all noncombustible, permeable demolition debris exhibiting the
RCRA arsenic toxicity characteristic;
• Surface cleaning the noncombustible, impermeable demolition debris exhibiting the
RCRA arsenic toxicity characteristic;
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• Salvaging non-hazardous demolition debris, as feasible; and
• Disposal of the treated wastes, the untreated non-hazardous lagoon wastes the
untreated non-hazardous miscellaneous products/feedstocks, and the untreated non-
hazardous demolition debris that is not salvaged in off-Site landfills.
On December 30, 1990 the final ROD for OU-3 was issued. It addressed
contaminated soils and adjacent sediments, non-hazardous buildings, and groundwater The
major components of the remedy included:
• Treatment of heavily contaminated soil and sediments;
• Capping of remaining contaminated soils and sediments; -
• Building demolition and salvaging or disposal of debris; and
• Pumping and treatment of contaminated groundwater.
On December 28, 1994 EPA issued an BSD (BSD No. 1) that modified the remedy to
allow the following materials to be incinerated at an off-Site facility:
Laboratory bottles;
Wooden debris from the vault;
Transformers (with and without detectable PCBs);
Crushed drums with adhering tar-like material;
"Unexpected" solid and liquid wastes from the vault;
Miscellaneous materials from on-Site buildings;
Wooden tanks and process vessels; and
Combustible demolition debris exhibiting the RCRA arsenic toxicity characteristic.
A second BSD (BSD No. 2) was issued on November 7, 1995 that selected off-Site
treatment and disposal of additional wastes originally determined to be treated on-Site. BSD
No. 2 documented the decision to: 1) incinerate the aniline still-bottom tars and carbon/tar
wastes excavated from the vault at Off-Site facilities (several incineration facilities were
subsequently used); 2) stabilize the calcium arsenate sludge at an off-Site facility; 3) conduct
off-Site incineration of wastes with elevated levels of organic compounds, (i.e., fuel and
waste oils, aniline residuals, and organic product residuals); and 4) stabilize wastes with a
limited amount of organic compounds (i.e., floor sweepings, concrete residuals, wood, and
debris) at an off-Site facility.
An Amendment to the ROD for OU-2, the third modification to die selected remedy,
was issued on May 12, 1998. The Amendment to the ROD for OU-2 selected off-Site
stabilization and disposal of vault soils. The original remedy selected for this waste stream
was on-Site incineration followed by stabilization of residual wastes and off-Site disposal.
The third modification to the remedy eliminated die need to construct an on-Site incinerator
by allowing the final waste stream originally selected for on-Site incineration to be taken to
an off-Site location for treatment and disposal.
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The three modifications to the selected remedy were strongly supported bv the
community, the elected officials, and PADEP, all of whom oprJed JSon Of o
mc
, , on Of on Site
mcmeraaon m the original remedy. On-Site incineration was selected m^Staal ROD
°ff- to
HI. BACKGROUND ON LAGOONS
TbC I3f T* 3t ^ WUttn(Ver ^oratories Site were formed during past Site
T f, r8' Pr?r t0 1964' prOC6SS Wastewater from Site operations was Seated
l^nn -fi? ? g a calcium-arsenic slu<^ and reportedly discharged into an on-Site
lagoon This agoon was excavated in 1964 and the calcium-arsenic sludge was placed in
on-Site concrete vault. Beginning in 1965, extracted groundwater from all on-Site pu
S2,f T ™ *«*."** ferric sulfate to-precipitate iron-arsenic compounds an
discharged into the original lagoon, seven newly created lagoons in the same area and
rnn tO ** west wcre eventually «wavated and
consolidated into the eastern lagoon area (hence the terms "excavated lagoons" and
consolidated lagoons"). The consolidated lagoons were then reportedly capped with
approximately one foot of clean soU. The entire lagoon area covers approximately two
acres. It should be noted that for purposes of the Remedial Design and Remedial Action the
lagoons were separated from other on-Site activities and are referred to as Operable Unii
rive.
The original selected remedy for the lagoon wastes as described in the OU-2 ROD is
bulk excavation, followed by on-Site iron-based fixation of hazardous lagoon wastes and off-
Site .disposal of the treated hazardous wastes and untreated non-hazardous wastes. According
to the OU-2 ROD, lagoon wastes were defined as iron-arsenic sludge and admixed soils
which contain greater than 10,000 mg/kg (1 percent) arsenic.
The Draft Consolidated Lagoons Delineation Report, Operable Unit Five (May 13
1998) describes the following three waste streams which characterize the consolidated lagoon
area! °
area:
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• 3,840 cy of non-hazardous lagoon materials (< 10,000 mg/kg total arsenic and
<5 mg/L TCLP-arsenic);
• 5,950 cy of non-hazardous lagoon wastes (> 10,000 mg/kg total arsenic and •
<5 mg/L TCLP-arsenic); and
• 6,890 cy of hazardous lagoon waste (>5 mg/L TCLP-arsenic).
The ROD fro OU-2 required on-Site fixation followed by off-Site disposal of the hazardous r
lagoon wastes and off-Site disposal of the non-hazardous lagoon wastes without treatment.
Non-hazardous lagoon materials were to be treated as soils since they did not meet the ROD
definition for lagoon wastes (containing greater than 1 % or 10,000 mg/kg total arsenic).
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OU-3 tt***** 0" -
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of soils that require treatment prior to d^oS ^ ^^ ^ mOdified
Underlying Hazardous Coanm C' BeCaiKe there "= "°
d. UniveLl TreaJn
0«, treaoncnt
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area was conducted subsequent
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<"S
In August 1995, GeoTrans conducted additional groundwater analyses to evaluate the
relative impact to groundwater from the various potential source areas at the Site These
data were presented in the Remedial'Design, Additional Well Installation and Sampling
Report (GeoTrans, June 1996). The results indicate that arsenic concentrations nfthe
groundwater do not appear to change significantly as it crosses the excavated lagoons Thus
the historic formation of the excavated lagoons, the relatively low levels of arsenic *' the
excavated lagoon area, the low levels of TCLP arsenic, and the apparent relatively lesser
impact to ground water indicate that the excavated lagoons behave in a manner more similar
to soils than lagoons. For these reasons, EPA has determined to address the excavated
lagoons as soils during the implementation of the remedy selected in the ROD for OU-3.
According to the ROD for OU-3, the selected remedy for heavily contaminated
unsaturated soils is excavation, followed by on-Site iron-based fixation, and off-Site disposal
Heavily contaminated soils are defined as those for which TCLP levels of arsenic exceed 5
milligrams per liter (5 mg/L).1 This is the same criteria which defines hazardous soils under
RCRA.
EPA originally estimated that approximately 61,000 cy of heavily contaminated soils
and sediments existed at the Site. The distribution of saturated vs. unsaturated soils was
unknown at that time. The volume of heavily contaminated unsaturated soils is now
anticipated to be approximately 5,000 cy. Additionally, as a result of the recent Phase IV
Land Disposal Restrictions (LDR) (63 Fed. Reg. 2855 (May 26, 1998)) effective August 24,
1998, an alternate treatment criterion for soils is codified at 40 C.F.R. § 268.49 (i.e.,
treatment to achieve 90% reduction for constituents requiring treatment and capped at'10
times the UTSs). Therefore, for D004 soils, rather than requiring treatment for arsenic to
the UTS of 5.0 mg/L, 40 C.F.R. § 268.49 allows an alternate treatment standard for soils of
a 90% reduction in TCLP-arsenic concentrations, capped at 50 mg/L. Therefore, while all
5,000 cy of heavily contaminated unsaturated soils would still need to be excavated and
removed from the Site, the soils requiring treatment prior to disposal would be those
exhibiting TCLP-arsenic concentrations greater than 50 mg/L and to the UTSs for all UHCs.
The volume of soil requiring treatment is being refined based on the data collected during the
soil delineation program.
Heavily contaminated soils were originally defined by the ROD as
soils with arsenic concentrations greater than 1,000-mg/kg. Based
on a June 20, 1995 letter to EPA from the Whitmoyer Laboratories
Private Study Group (WLPSG) and accepted by EPA on March 11, 1996-,
the defining criteria for heavily contaminated soils was modified
to 5 mg/L TCLP-arsenic. The selection of 1,000 mg/kg of arsenic
as the action level for treatment in the ROD was based on a
statistical correlation between total arsenic concentrations in
soil and arsenic concentrations in the resulting leachate. This
correlation was developed by EPA using the standard TCLP testing
procedures. Rather than rely upon the statistical correlation
between total and leachable arsenic, EPA determined it was
appropriate to directly measure the leachability of the soil
{i.e., conduct TCLP analysis) to determine if treatment was
required prior to disposal.
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Results of Bench-Scale Testing
scale treatabihty testing on more heavily contaminated lagoon wastes, found duSng fce
delineation sampling conducted in November 1997. The previously dentifiedSon
^ hdutit^0^la8T ??** agaiD Pr°Ved £° <* SU™ l£«££ this
ws H^ Whitmoyer laboratories Private Study Group's (WLPSG's) April 30
£«^™L* T/f *bUity T"' ^^ t0 USEPA Comments °» Ben^-Scaie
Treatability Testing Results Report and Presentation of Results from Follow-up Bench-Scale
Testing on Consolidated Lagoon Materials.
Summary of New Information Obtained Since the OU-2 and OU-3 RODs
resoecto v? ^?i°U~3 R°?SuWere issued' several P*«» of new information with
respect to the consolidated lagoons and heavily contaminated unsaturated soils have been
identified. As described above, EPA originally estimated that up to 24,000 cy of lagoon
materials might eventually require treatment. Because of additional delineation refinements
that have occurred during various Site investigations, it is now expected that 6 890 cy of
hazardous lagoon wastes will need to be treated. The volume of heavily contaminated
unsaturated soils to be treated has similarly changed based on additional delineation work and
the recent modifications in regulatory and administrative requirements. In addition the
ability to successfully treat these materials off-Site has since been demonstrated. '
Based on the characteristics of the hazardous lagoon waste and heavily contaminated
unsaturated soils, the applicable treatment requirements for these wastes, and its pre-design
work to date, EPA has determined that the off-Site fixation of hazardous materials is
consistent with the nine evaluation criteria for remedy selection established under the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), as discussed
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.-^,
below.
soils w^nmv^!0!11 **, *? ^^^^ l^oon waste ^ heavily contaminated unsaturated
n™ J°, I P e? iIeVd °f °Vera11 Protection at least equivalent, if not greater than mT
^W^5r,saTffi2;arsrfiL:i;*
MSBS^^SZL^M^'K^S '
U^T?? n° u Rfek °f °n"Site ^P08"*6 to fogitiye dust and reagent emissions would be
prevented. Furthermore, transportation risk would be reduced given the lower volume nf
wastes to be transported (since treatment reagents would not be added to Ae wasted Site
nnt-otl i traasP°ct^ ^ to low a««e hazard posed in the event of any spill of
untreated lagoon waste or contaminated soils.
Fixation of the hazardous lagoon waste and heavily contaminated unsaturated soils to
meet applicable LDR treatment standards and disposal of the treated waste at a Sufcitie C
facility eligible to accept CERCLA wastes pursuant to 40 C.F.R. § 300.440 (Procedures for
Planning and Implementing off-Site Response Actions) would comply with Suite and fedend
Applicable or Relevant and Appropriate Requirements (ARARs).
The long-term effectiveness and the reduction in toxicity and mobility of materials
treated at an off-Site facility would be the same as that for on-Site fixation. In addition the
otf-Site fixation of the hazardous lagoon waste and heavily contaminated unsaturated soils
could be completed in a shorter period of time than that needed for on-Site fixation because
of the reduced remedial design efforts for off-Site versus on-Site fixation. Potential risk
associated with transportation of materials and exposure to treatment emissions is expected to
be reduced with off-Site fixation because of the lower quantity of wastes that would require
transportation and because chemicals would not have to be transported to the Site for on-Site
fixation. The risk posed by a possible spill of untreated lagoon waste or soils during
transportation would be low given the physical composition of the waste.
Based on the expected reduced volume of hazardous lagoon waste and heavily
contaminated unsaturated soils to be disposed, the bench-scale success in treating the waste to
acceptable levels, and the pre-design evaluation of an eligible, Subtitle C treatment facility
EPA is confident that off-Site fixation and disposal is implementable.
The present-worth cost for off-Site fixation of the hazardous lagoon waste and heavily
contaminated unsaturated soils is expected to be lower than that for on-Site fixation due to
reduced transportation costs, and reduced on-Site engineering costs since treatment would
occur off-Site. The approximate cost-savings for modifying the remedy to allow for the off-
Site treatment of wastes is $4,250,000.
Based on public meetings held to date, EPA expects the community would support
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•" "-• of -»
concerns regarding this new regulation are not anticipated since ite^aTSE*
requu-ements do not change the location or volume of soil thafwm belted
.
V. SUPPORT AGENCY COMMENTS
1 °f ^ ab°Ve ChangeS to *** remedv ^ teen coordinated with representatives of
pursuant to 40 C.F.R. § 300.435(c)(2). PADEP submitted a letter on Sr 29
1998 concurring with the changes to the selected remedy as described in this ESD
VI. AFFIRMATION OF THE STATUTORY DETERMINATIONS
of CEftClfirST2 ^V^T1^ remedy C°mplies With ** statutoiy requirements
of CERCLA § 121, 42 U.S.C. § 9621. Considering the new information that has been
developed and the changes that have been made to the selected remedy, EPA believes that
the remedy remains protective of human health and the environment, complies with Federal
and State requirements that are applicable or relevant and appropriate to this Remedial Action
as described in the RODs for OU-2 and OU-3, and is cost-effective. In addition, the reused
remedy utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable for this Site. u*&uuum
VH. PUBLIC PARTICIPATION
This ESD and the supporting documents which contain the information which form
the basis for modifying the selected remedies, have been included in the Administrative
Record for this Site. The Administrative Record also includes the RODs for OU-1, OU-2
and OU-3, and all documents that formed the basis for EPA's selected remedy. The
Administrative Record is available for public review at the locations listed below:
U.S. EPA, Region m
1650 Arch Street
Philadelphia, PA 19103-2029
Hours: Mon. - Fri., 9:00 a.m. - 4:00 p.m.
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Whitmoyer Community Library
199 North College Street
Myerstown, PA 17067
News irf la^Nove^?^? °f ^ dOCUmentS wm * Published * ** Lebanon Daily
,,n rA ^ r 1998> ** "rfonaational meeting to discuss the progress of the clean
DecTm^rf^T ? v6 "S*"1 ^ M dCSCribed above' wil1* ^5 on "
December 1, 1998 at the Jackson Township Building located in Myerstown, Pennsylvania.
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