PB97-963108
EPA/541/R-97/014
November 1997
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Brown's Battery Breaking,
Shoemakersville, PA
12/1996
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EXPLANATION OF SIGNIFICANT DIFFERENCES
BROWN'S BATTERY BREAKING
TILDEN TOWNSHIP, BERKS COUNTY, PENNSYLVANIA
A. INTRODUCTION
Statement of Purpose.
The Environmental Protection Agency, Region III (EPA) is
issuing this Explanation of Significant Differences (BSD),
pursuant to its authority in Section 117(c) of the Comprehensive,
Environmental Response, Compensation and Liability Act of 1980,
as amended (CERCLA), 42 U.S.C. § 9617(c), and the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP), at 40
C.F.R. § 300.435(c)(2)(i), for the July 2, 1992, Record of
Decision ("OU-2 ROD") issued for the Brown's Battery Breaking
Superfund Site (the "Site") in Tilden Township, Pennsylvania.
EPA is the lead agency for the Site and the Pennsylvania
Department of Environmental Protection ("DEP") is the support
agency. EPA has identified an aspect of the soils and casings
treatment portion of the remedy set forth in the OU-2 ROD that is
appropriate to change through this ESD. This change is being
made to allow the contaminated soils and casings treatment
portion of the remedy to be constructed at either a secondary
lead smelter in Reading, Pennsylvania, as called for in the
Record of Decision, or at any other location which is permitted
to treat hazardous waste and has been determined to be acceptable
to take CERCLA cleanup wastes pursuant to Section 121(d)(3) of
CERCLA and 40 C.F.R. § 300.440. EPA has determined that this
change does not fundamentally alter the remedy selected in the
OU-2 ROD with respect to scope, performance, or cost. In
accordance with 40 C.F.R. § 300.825(a)(2), this ESD will become
part of the administrative record file located in EPA Region III,
841 Chestnut Building, Philadelphia, PA 19107 and at the Hamburg
Borough Library, 35 North 3rd Street, Hamburg, PA 19526.
B. SITE CHARACTERISTICS.
The Site is an inactive lead-acid battery processing facility
located in Tilden Township, Berks County, Pennsylvania. The
facility recovered lead-bearing materials from automobile and
truck batteries from 1961 to 1971. The operation involved
breaking the vulcanized rubber battery casings, draining acid
from the batteries, and recovering the lead-alloy grid's, plates
and plugs.
From 1961 to 1965, the lead-recovery process used at the Site
consisted of placing batteries on their sides on a conveyer belt
that carried them to a hydraulic guillotine. The guillotine
sliced the top from each battery casing, allowing access to the
lead alloy grids. In the early years of operation, the open-top
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batteries were manually inverted and the sulfuric acid was poured
directly onto the ground, along with the battery grids. The
empty battery casings were deposited on the ground surface in
several areas of the site. Battery grids were loaded onto a dump
trailer for transport and resale.
From 1965 to 1971, the battery casings were rinsed with water to
remove residual lead, and the rinsewater containing residual lead
was collected in steel tanks. At the end of each work day, the
lead was recovered and shoveled into the dump trailer containing
the battery grids. The rinsewater was then dumped directly on
the ground. Casings were crushed after rinsing. The smaller
battery casing pieces were often used as a substitute for road
gravel both onsite and offsite.
DEP's predecessor agency, the Pennsylvania Department of
Environmental Resources ("DER"), initiated an investigation of
lead contamination at a dairy farm located near the Site in the
spring of 1980. The dairy farm had become contaminated through
the use of crushed battery casings as road cover. The Site was
identified as the source of the battery casings. Subsequent
testing conducted by DER and the Pennsylvania Department of
Health at the Site provided sufficient evidence to indicate that
a serious health threat existed on the Site. EPA studied the
Site in the fall of 1983 and conducted a Removal Action during
the winter of 1983 and spring of 1984. This Removal Action
consisted of excavation and consolidation of battery casings and
contaminated soils. In addition, this action included onsite
containment of the wastes beneath a low permeability soil cap
located in the southwest quadrant of the Site. This area is
referred to as the "containment area". The Site was placed on
the EPA Superfund National Priorities List (NPL) in June 1986.
EPA began a Remedial Investigation/Feasibility Study (RI/FS) for
the Site in 1988. The purpose of the RI/FS was to characterize
the extent of contamination at the Site, quantify risks to human
health, and evaluate potential environmental risks and remedial
alternatives. Site characterization included sampling and
analysis of surface and subsurface soil, ground water, surface
water, sediment, ambient air, interior dust and blood-lead levels
of onsite residents. A baseline risk assessment was conducted as
part of the investigation and includes quantification of risks to
human health. An evaluation of remedial alternatives is
presented in the Feasibility Study portion of the RI/FS report.
Major findings of the RI/FS include the following:
Onsite surface soils and shallow subsurface soils are
contaminated with varying concentrations of lead,
ranging from less than 500 mg/kg to 60,000 mg/kg.
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Soil and groundwater contamination resulted from onsite
deposition of battery wastes. These wastes included
crushed rubber battery casings, battery acid, and
metallic lead grids, posts, and plugs. These materials
remain onsite and must be addressed along with
contaminated soils.
The shallow groundwater aquifer onsite is contaminated
with lead, metals, dissolved solids and acid.
Lead is being transported from the Site to the adjacent
Schuylkill River.
The bedrock aquifer onsite is contaminated with
sulfate, cadmium, beryllium, manganese, dissolved
solids and acid.
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selected in the OU-2 ROD. The community residents expressed
their opposition, which began after EPA issued the OU-2 ROD,
through letters\of protest and the filing of a federal lawsuit
regarding alleged violations and environmental conditions at
Exide Corporation's Laureldale plant (the selected treatment
facility). However, the innovative technology remains more
beneficial to the environment than the contingent solidification
and off-site disposal remedy because it avoids the disposal of
large volumes of waste into crowded landfills. Given the public
opposition to the innovative technology being used at the
Laureldale facility, the ESD provides greater flexibility and
therefore a greater likelihood that the environmentally
beneficial innovative remedy can in fact be implemented.
Dj. SUPPORT AGENCY COMMENTS
The above changes to the remedy have been coordinated with DEP
pursuant to 40 C.F.R. § 300.435(c)(2)(i). DEP has concurred with
the changes to the selected remedy as described in this ESD by
letter dated September 25, 1996.
EL. AFFIRMATION OP STATUTORY DETERMINATIONS
Considering the new information that has been developed and the
changes that have been made to the selected remedy, EPA believes
that the remedy, as modified by this ESD, 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, and is cost-effective. In addition, the
revised remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum
extent practicable for this Site.
£._ PUBLIC PARTICIPATION ACTIVITIES
This ESD has been made part of the administrative record file and
is available for review at the two locations identified below:
United States Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
(215) 566-3157
Hours: 8:30 a.m. to 5:00 p.m.
Monday through Friday
or
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Hamburg Borough Library
35 North 3rd Street
Hamburg, PA 19526
(215) 562-2843
Hours: M, T, Th 1:30-8:30 P.M.
EPA has opened a public comment period from November 27, 1996 to
December 30, 1996 to solicit comments on this BSD. Comments
should be sent to:
Richard Watman
Remedial Project Manager
United States Environmental Protection Agency
Region III (3HW22)
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Thofaas c!" voltaggi^, Director
Hazardous Waste Management Division
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