United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/108
December 1990
•&EPA Superfund
Record of Decision:
Whitmoyer Laboratories
(Operable Unit 2), PA
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50272-101
REPORT DOCUMENTATION 1'. REPORTNO.
~.. PAGE EPA/ROD/R03-91/108
1 ~
3. R8dp1enta Acce8&Ion No.
. ........,... Subft8
'ERFUND RECORD OF DECISION
..nitmoyer Laboratories (Operable
Second Remedial Action
7. AuIIIor(a)
5. Report Da1e
-
12/17/90
Unit 2), PA
8.
8. Performing OrpnIza1Ion Rept. No.
8. 1VIce46.., Qrp/nIz8tIon.... and AddN88
10. Ptojac:tlTulllWork lINt No.
11. ConIr8ct(C)" Gnnt(G) No.
(C)
(Q)
1~ SpaI..q Orgarmdon"" and ~
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
11. Type of Rapor1. PwrIod Covered
Agency
800/000
14.
15. SI.IIIIII8o-.wy No-
.-
; 18. Ab81r8cI (lJmIt: 2110 _rda)
The 22-acre Whitmoyer Laboratories site is an abandoned animal pharmaceutical
manufacturing facility in Jackson Township, Lebanon County, Pennsylvania. Land use in
the area is predominantly agricultural, and there are wetlands areas adjacent to the
site. Part of the site lies within the 100-year floodplain of the Tulpehocken
Creek-Union Canal, and an estimated 40 residences in the vicinity of the site use the
'erlying aquifer as their drinking water supply. From 1957 to 1964, Whitmoyer
Joratories, Inc., produced organic arsenicals on site. In 1964, the new site owners,
began storing concentrated wastes in an onsite concrete vault and, until 1971,
conducted onsite pumping and treatment of ground water and ocean dumping of wastes.
In 1977, sludge from ground water treatment was placed in onsite lagoons in the
eastern area of the site. Between 1978 and 1982, the site changed ownership twice,
and then in 1985, a RCRA site closure plan was filed. In 1986, EPA provided bottled
water: to residences with contaminated ground water. Onsite contamination of soil and
ground water has resulted from a combination of poor housekeeping, poor disposal
practices, and improper storage of hazardous materials. In 1986, arsenic
contamination was detected in nearby residential wells by EPA. When the site was
(See Attached Page)
17. Doc:uII*It An8Iy8Ia L DncripIDra
Record of Decision - Whitmoyer Laboratories (Operable Unit 2), PA
Second Remedial Action
Contaminated Media: debris, sludge
Key Contaminants: VOCs (benzene, PCE, toluene, xylenes), other organics (phenols),
metals (arsenic, lead)
b.~T-
Co COSAlI A8III/GnqI
18. ~ SI8I8awC
". S8cu1tyQau (tN8 Allport)
None
20. S8cu1ty Qau (TbI8 Pagel
None
21. No. of Pagea
84
~ PI1ce
cs- AHS-Z38.18)
SH IM/nICfIOM on"'-
(Formerly NTls.35)
0epaI1men\ of Commerce
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EPA/ROD/R03-91/108
Wh~moyer Laboratories (Operable Unit 2), PA
Second Remedial Action
'&
.cact (Continued)
abandoned in 1987, very little of the RCRA closure plan had been implemented. From 1988
to 1990, EPA removed the abandoned drums and laboratory wastes from the site. A 1989
Record of Decision (ROD) provided for offsite removal of concentrated liquids in
abandoned tanks and process vessels as the first operable unit (OU1). This ROD
- addresses OU2, which includes remediation of chemical vault and lagoon wastes, out-dated
-products, miscellaneous chemicals and feedstocks, and contaminated site structures. A
ROD for OU3 will addresses remediation of contaminated onsite soil and ground water.
Tae primary contaminants of concern affecting the debris and sludge are VOCs including
-benzene, PCE, toluene, and xylenes; other organics including phe~ols; and metals
including arsenic and lead.
The selected remedial action for this site includes excavating and incinerating onsite
. approximately 3000 cubic yards of high organic content vault wastes, and approximately
101 cubic yards of miscellaneous products and feedstocks, followed by
cement/pozzolan-based fixation, and disposing of the residual ash offsite; treating
approximately 1,500 cubic yards of low organic content vault wastes using fixation or a
similar fixation process, followed by offsite disposal; excavating and incinerating
onsite approximately 20 buried drums and 50 cubic yards of tank and process vessel
residuals, followed by treating any residual ash using fixation, and offsite disposal of
residuals; excavating approximately 24,000 cubic yards of arsenic-contaminated lagoon
wastes with levels above 10,000 mg/kg, followed by fixation of the hazardous lagoons
wastes; and disposing of residuals along with nonhazardous wastes and other products and
feedstocks offsite; demolishing buildings, associated tanks, vessels, processing
e, ~ment, and debris; incinerating onsite any combustible debris exhibiting the RCRA
a. .ic toxicity characteristic, followed by offsite disposal; coating and sealing
noncombustible permeable demolition debris prior to offsite disposal; surface .cleaning
of noncombustible impermeable demolition debris, which exhibit the RCRA arsenic toxicity
characteristic and contaminated onsite structures before offsi~e disposal; and offsite '
disposal or recycling of untreated unsalvaged demolition debris. The estimated present
worth cost for this remedial action is $45,800,000. There are no O&M costs associated
\ .
with this remedial action due to selection of offsite disposal for residuals.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific debris and surface water cleanup
goals were not provided, but cleanup will be based on RCRA, CAA, CWA, and State
standards. .
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RECORD OF DECISION
OPERABLE UNIT TWO
WHITMOYER LABORATORIES SITE
DECLARATION
SITE NAME AND LOCATION
Whitmoyer Laboratories Site
Lebanon County, Pennsylvania.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the second operable unit of
the Whitmoyer Laboratories Site (Site) in Lebanon County, Pennsylvania. This remedy was
chosen in accordance with the Comprehensive Environmental Response, Compensation and
liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA); and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the Administrative Record for this
Site.
The Commonwealth of Pennsylvania has not concurred witt'! the selected remedy.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine, based on the Administrative Recer:;
for this Site and, pursuant to Section 106 of CERCLA, 42 U.S.C. ~ 9606, that actual cr
threatened releases of hazardous substances from this Site, as discussed in "Summary of S/!e
Risks," Section VI, if not. addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial endangerment to the pul2k
health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This operable unit (OU) is the second of three operable units for the Site. The remedial ac~'c-
for the first operable unit (OU One) at this Site involved remediation of hazardous concentrate':
liquids which were abandoned at the Site. The remedial action for the second operable .~:- :
(OU Two) addresses concentrated was~es abandoned in a concrete vault; concentrated was:es
abandoned in two group~ of lagoons; outdated products and miscellaneous chemica s
abandoned in the buildings; and the buildings and related structures (tanks, process vesse s
etc.) located on the Site. These materials pose some of the principal threats at the Site ,;..-?
third operable unit, (OU Three) will address soil and groundwater contamination at the Site 3::::
possible remediation thereof.
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'-
The U.S. Environmental Protection Agency (EPA) has selected the following Remedial Action
for au Two. This Remedial Action addresses the hazards posed in au Two by treating the
me'st contaminated materials, and disposing of treatment residuals and. the materials
contaminated at low levels off Site, such that the materials will not require any long-term onsite
management.. .
The major components of the Selected Remedial Action are as follows:
, ,
./
'.
*
Excavation of the arsenic and organically-contaminated concrete vault-contents
[(4,500 cubic yards (CY)). the approximately 20 buried drums located east of the
vault, and an estimated 50 CY of residuals potentially present in the tanks and
process vessels not addressed under au One. " '
*.
Excavation of the approximately 24,000 CY of materials present in the lagoons
having an ars'enic content greater than 10,000 mg/kg (lagoon wastes),
*
, '
Removal of the approximately 1 01 CY of miscellaneous products/feedstocks from
the buildings. .
*
Surface cleaning of contaminated Site '. structures.
*
. Remediation of dangerous conditions existing in buildings outside of the Building
, 1-7 complex. ' . '.
..
Demolition of the Building 1-7 complex and all tanks, vessels, piping. process
equipment, and outdoor tank concrete dikes.
*,
Onsite incineration 01 the following: approximately 3,000 CY of high organic
content wastes present in the vault; the contents of the approximately 20 buried
drums; the estimated 50 CY of residuals potentially present in the tanks and
process vessels not being addressed under OU One; and the miscellaneous
products/feedstocks and combustible demolition debris exhibiting the RCRA
arsenic toxicity characteristic. The remedy selected by EPA is incineration that
meets all RCRA, NMQS, and NESHAPS requirements and that is demonstrated
to be safe during the remedial design phase of ROD implementation. ,
Axation of the incineration residuals and th~ approximately 1,500 CY of low
organic content wastes present in the, vault using a cement/pozzolan-based or .
other 'similar fixation process that provides equivalent protection. .
*
Fixation of the lagoon wastes exhibiting the RCRA arsenic toxicity characteristic
using an iron-based or other similar fixation process that provides equivalent
protection. .
2
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*
Coating and sealing the noncombustible, permeable demolition debris exhibiting
the RCRA arsenic toxicity characteristic.
*
Surface cleaning the noncombustible, impermeable demolition debris exhibiting
the RCRA arsenic toxicity characteristic.
*
Salvaging nonhazardous demolition debris, as feasible.
Disposal of the following in accordance with all applicable regulations: the treated
wastes; the untreated (nonhazardous) lagoon wastes; the untreated
(nonhazardous) miscellaneous pro'ducts/feedstocks; and the untreated
(nonhazardous) demolition debris that is not salvaged in off Site landfill(s).
The selected remedy is . Ppart of the long-term remediation of this Site and will be consistent
with the final remedy.
*
STATUTORY DETERMINATIONS
The selected remedial action is protective 01 human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. .
The Remedial Action Utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference for remedies which employ
treatment that reduces toxicity. mobility, or volume as a principal element. .
Because this remedy for au Two will not result in hazardous substances remaining onsite
above health-based levels, a 5-year review under Section 121 (c) 01 CERCLA, 42 use 9
9621 (c), will not apply to this action.
-
rlBf?~
Edwin B. Erickson
Regional Administrator
/2/17/90
I Dat9
3
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RECORD OF DECISION
' WHITMOYER LABORATORIES SITE
DECISION SUMMARY
A.
I. SITE NAME, LOCATION, AND DESCRIPTION
SITE NAME AND LOCATION
The Whitmoyer Laboratories Site (Site) is located on approximately 22 acres in Jackson
Township, Lebanon County, Pennsylvania, about 1 mile southwest of the Borough of Myerstown
(see Figures 1 and. 2). The Site lies betw~en the Union Canal of Tulpehocken Creek and the
, Conrail (Reading) Railroad. Fajrlane Avenue forms the Site's eastern boundary, while Creamery
Street adjoins the Site to the west.: \ " '
I .
1-;:- .
, A food storage warehouse is active in Building 18 on the Site. Land surrounding the Site is
predominantly farmland, with scattered farmhouses. A Sterling Drug, factory is located
2,000 feet east of the Site, while PJ Valves, a manufacturing plant, is located about 1,5OO1eet
to the south. A large active limestone quarry, locally referred to as the Calcite Quarry, is
located app~oximately 1.5 miles west of the Site.
B.
TOPOGRAPHY. SURFACE WATER. AND DRAINAGE
Topographic reli'ef on the' Site is moderate, varying in elevation from 493 feet in the southwest
corner to 449 feet in the northeast corner. The entire Site drains to Tulpehocken Creek, with
drainage being roughly perpendicular to the Creek axis. Portions of the Site are within the
1 ao-year flood plain of Tulpehocken Creek-Union Canal. '
. ' The Union Canal branches from Tulpehocken Creek just west of the Site and rejoins the Creek
near the Site's eastern boundary. Myerstown is the first downstream community, at a distance
of approximately 3I4th ofa mile. Tulpehocken Creek is a tributary to and joins the Schuylkill
River near Reading, Pennsylvania. The Schuylkill River flows into the Delaware River, which.
eventually empties into the Atlantic Ocean. Tulpehcicken Creek and the Schuylkill River serve
as drinking water supplies and irrigation sources downstream of the Site. The headwaters. of
' the section of Tulpehocken Creek which passes by the Site originate approximately 3 miles to
the northwest.
C.
GEOlorrt
The Whitmoyer laboratories Site is located within the Lebanon Valley, part of the Great Valley
portion of the Valley and Ridge. Physiographic Province. The valley is a topographic expression
of the underlying, relatively easily eroded carbonate bedrock units. The Site is underlain by
, carbonate bedrock of the Ontelaunee Formation, the youngest member of the Ordovician Age
Beekmantown Group. A thin mantle of cfayey residual soil overlies bedrock in the Site vicinity.
. Depths to bedrock in the Site's vicinity range from 0-19 feet, based on the Remedial
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BASE'IMP a A POftTON OF THE USG.S RICMLANO.PA QUADRANGLE (75 MINUTE SERIES, 1993, PHOTOREVISED 19691 OQMfOUN M1CRVML 2O'
FIGURE 1
LOCATION MAP
WHITMOYER LABORATORIES SITE, LEBANON COUNTY, PA
PJUS
I I oc =c : «natsj
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LEGEND
CONSOLIDATED
EXCAVATED
CONRAIL TRACKS
> •• t i- .••—-
400
SOUftCE- GENCHAL LAYOUT DRAWING, PREPAREDNESS. PREVENTION 5 CONTINGENCY PLAN, DEC. 22. 1982.
GENERAL ARRANGEMENT
WHITMOYER LABORATORjESJSj.TF YERSTOWN^ PA
FIGURE 2
rjus
OSJ
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Investigation (RQ. The depth to bedrock is greatest in the vicinity of Tulpehocken Creek and
the Union Canal. The Ontelaun.. Formation is described in regional literature as a light to dark
gray dolomite, which weathers to a dark grayish brown. The Ontelaunee Formation strikes
NSOOE to NaoDe predominantly, with an overall dip to the SE of approximately 3CI'. In the
Myerstown area, this formation is approximately 500 feet thick.
Soils in the area are primarily residual soils derived from weathering of the bedrock surface,
with some alluvium adjacent to Tulpehocken Creek. Based on the RI, the soils consist
predominantly of silt and clay. A thin veneer of organic-rich topsoil overlies the residual soils
throughout much of the area. Fill material is present in several locations within the Site
property boundaries. .
D;
HYDROGEOLOGY
The. carbonate bedrock units underlying the Lebanon Valley form the major aquifer in the area.
The various formations present, although differing somewhat in water-yielding capacity I are
considered to form a. single, large, heterogeneous, unconfined aquifer. The porosity of the
carbonate aquifer is. almost' entirely secondary, with fractures enlarged through solution
channeling forming the primary groundwater storage zones and migration pathways. ~
Groundwater flow directions in the region generally follow topography, then follow stream flow
direction in valley bottoms. In the Site area, portions of the groundwater flow both in
northeasterly and southeasterly directions, before generally following the course of the stream
to the east-northeast. Depth to groundwater ranges from 2 to 21 feet below land surface at
the Site. -, .
Recharge to groundwater in. the carbonate rock units is principally through precipitation
infiltration, with additional recharge due to groundwater migration from adjacent rock units, and
occasional surface water recharge during extended dry periods.
Groundwater beneath the Site is classified as a Class 2A aquifer, a current source of drinking
water. The groundwater is also used for industrial water supplies. Approximately 40 residences
in the Site vicinity have potable water supply wells tapping the aquifer. Twenty of these
residences have been placed on bottled water by EPA due to contamination of their water
supply from past Site activities. Large industrial users of groundwater include Sterling Drug,
Inc., Quaker Alloy Casting Co., and P.J. Valves Company.
The Myerstown Water Authority (Authority) provides potable water to the residents of
Myerstown. One of the Authority's reserve wells, No.8, taps the bedrock aquifer underlying
the Site. This well is utilized during periods of high demand. To date, contamination from the
Site has not been detected in this well.
E.
CLIMATOLOGY
The Whitmoyer Laboratories Site is located within the southeastern Piedmont Climatological
. Division of Pennsylvania. Second Mountain, which rises 1,500 feet along the north border, and
South Mountain, which rises 1,000 feet along the southern border. form the Lebanon Valley,
5
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in which the SIte Is located. The Lebanon Valley has a humid continental climate. Due to the
valley's location, weather systems. are typically' modified before reaching Lebanon County.
Weather extremes are most often the result of unusually strong weather systems.
The average annual precipitation at the Site is 42.3 inches. This precipitation is mostly evenly
distributed throughout the year. with slightly less precipitation occurring in the winter. The.
average annual snowfall is 27 inches. Evaporation at the Site is 36.3 inches; thus, net
precipitation is 6 inches. '
In the summer. high temperatures are generally in the mid-80s and the lows near SOOF; During
the winter the highs average in the upper 30s and the lows in the 208. The prevailing wind is
from the northwest in winter and from the west-southwest in summer. . ". '
r'
F.
. POPULAT10N AND ENVIRONMENTAL RESOURCES
. Lebanon County, according to the 1980 census, has a population of 109,829, and is classified
by the Commonwealth of Pennsylvania as a .5th Class. county. The population 01 Myerstown
. in 1984 was 3,270. Populations 011,296 and 4,683 reside within 1 ,and 3 miles 01 the Site,
respectively. .' . "
, '
Portions 01 Tulpehocken Creek, (Creek) adjacent to. the Site contain very small open water
. wetlands areas consisting 01 small pockets along the riverine system 01 the Creek and Union
Canal. Floodplain10rest wetlands exist starting approximately 3.5 miles downstream 01 the Site.
The area has some habitat value. with opossum, raccoon. numerous fish. a water snake, and
various songbirds observed during a 1986 EPA Site visit. .
Tulpehocken Creek has been proposed 10r inclusion on the Commonwealth 01 Pennsylvania's
scenic river system. with a .priority 1A status.. This designation is 10r streams which "have the
most urgent r:~ed 10r protection and immediate need 10r. additional study,. according, to a
Pennsylvania Department of Environmental Resources (PADER) official.
II., Site HISTORY AND ENFORCEMENT ACTlVmES
A brief chronology of Site history and enforcement activities follows.
1971
1977
1978
1982
An oil pipeline was constructed across the Site.
Whitmoyer Laboratories. Inc. (WU) formed.
WU begins production of organic arsenicals.
Rohm & Haas buys WU. Concentrated wastes placed in a concrete vaLllt
Groundwater pump-and-treat program initiated. Ocean dumping 01 wastes
begins. .'
Groundwater pump-and-treat and ocean dumping program terminated.
. Sludges from groundwater treatment consolidated in eastern lagoons.
Beecham Laboratories acquires WU.
Stafford Laboratories. Inc. purchases Wu.
1900 Circa .
1934 .
1957 .
.' 1964
6
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Stafford Laboratories, Inc. files for bankruptcy. Whitmoyer Laboratories Site
proposed for the National Priority Wst (NPL).
WU files aRCRA Closure .Plan with PADER, and changes its RCRA status from
. Treatment, Storage, or Disposal facility to a Generator facility.
Whitmoyer Laboratories Site finalized on the NPL EPA begins providing bottled
water to area residents with contaminated wells.
Stafford Laboratories, Inc. abandons facility, with very little, if any, of the RCRA
Closure Plan implemented. EPA initiates the Remedial Investigation/Feasibility
Study (RVFS).
EPA initiates an emergency response to remove abandoned drums from the Site.
This work continues into the summer of .1990. ..'
EPA selects a remedy for the concentrated liquids operable unit. Abandoned
laboratory wastes are packaged and disposed of by EPA. The Whitmoyer
Laboratories Site RI Report is finalized. Clarence W. Whitmoyer, former president
of WU, dies. U.S. Department of Justice, on behalf of EPA, files claim against
estate in Dade County, Florida. Special notice letters sent to PRPs for OU 1.
PRPs decline to perform Remedial Action.
1990 January- The concentrated liquids (first) operable unit Remedial Design is .
completed.
The Whitmoyer Laboratories Site FS which addresses the media making
up the second operable unit is finalized. Two former Site owners, Rohm
& Haas and SmithKline Beecham, propose to EPA a separate remedial
alternative for the vault wastes, lagoon wastes, and miscellane~us
productslfeedstocks.
1990 May- The concentrated liquids Remedial Action commences.
1990 September- Rohm & Haas and Smith Kline Beecham enter into consent order with EPA
under which they will extend public water services to residents affected
by the Site.
Concentrated liquids remedial action completed.
1984
1985
1986
1987
1988
1989
1990 February-
1990 September-
III. COMMUNITY RELATIONS HISTORY
In accordance with Sections 113 and 117 of CERClA, 42 U.S.C. Sf 9613 and 9617, EPA held
a public comment period from April 16, 1990 through June 16, 1990 for the second operable
unit Remedial Action (the subject of this Record of Decision) described in the Remedial
Investigation (RI) and Feasibility Study (FS) Reports and Proposed Plan released in April 1990.
A copy of the RllFS and the proposed plan was sent to each PRP or their representative(s).
The notice to .. public of the comment period, of a public meeting, and of the availability
of these documents was published in the Lebanon County Times on April 16, 1990. The RI
and FS Repor1l and the Proposed Plan were made available to the public in the Administrative
Record maintained in the EPA Region'" office and at the Myerstown Public Wbrary. A public
meeting was held on April 24, 1990 to outline the Preferred Remedial Action and to accept
comments from the attendees. A transcript of the public meeting was maintained in
accordance with 1117(a)(2) of CERCLA. U.S.C. 1 9617(a)(2). Written comments, including
some received after the close of the comment period, are addressed in the Responsiveness
Summary which is attached.
7
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I
All documents that form the basis for the selection of the remedial decisions contained in this
Record of DecI8ion are included in the Administrative ,Record, for this Site and can be reviewed
or referred to for additional information. '
IV. SCOPE AND ROLE OF OPERABLE UNrr
As with many Superfund Sites, the problems at the Whitmoyer Laboratories Site are complex. ' ,
, As a result, EPA is addressing portions of the Site contamination' using its emergency response
authorities, whereas' other portions are being addressed as a part of the remedial program.
A.'
EMERGENCY RESPONSE ACTIONS,
I
The approximately 800 drums that were abandoned at the Site are b8ing removed by EP A as '
, an emergency response action. This action is nearly complete. The laboratory wastes and
chemicals and production run samples abandoned at the Site were disposed as an emergency
response action. A public water supply line extension 'to residences with contaminated wells
is currently being designed and will be constructed as an emergency response action. While
the line is being designed, affected residences are being supplied by EPA with bottled water.
,B.
REMEDIAL OPERABLE UNITS
, ,
EPA has'divided U1e hazards at the Site into three operable units (OUs). These are as follows:
*
OU One:
Concentrated liquids abandoned in tanks and process vessels
*,
OU Two: '
Vault wastes, lagoon wastes, miscellaneous products/feedstocks,
and Site structures
*
OU Three: '
Contaminated soils and groundwater
EPA has already selected the cleanup remedy for OU One (the concentrated liquids) as
described in the Record of Decision for this Site dated June, 1989. The concentrated liquids
pose a principal threat at the Site, because of the potential for direct contact; tank/piping failure
with subsequenteontamination of Tulpehocken Creek; fire/explosion; and tank failure from,
flooding. This remediation ,was completed in September 1990. '
,The second 00, the OU addressed by,this ROD, includes concentrated wastes abandoned in
a concrete vauI; concentrated wastes abandoned in two groups of lagoons; outdated products
" and miscellaneous chemicals abandoned in'the buildings; and the buildings and ,related
structures (tanks. process vessels, etc.) located on the Site. The NQv~mber 1989 RI for the Site
documents that these materials pose some of the principal threats to human health and the
environment from the Site because of the following risks: possible ingestion or direct contact
with the materials; contaminant migration from the materials into the underlying groundwater
,that is a source of drinking water for local residents; and contaminant migration to surface
r
'8
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water. The purpose of this action is to prevent current or future exposure to the contaminated
materials and to reduce contaminant migration into groundwater and surface water.
The third OU will address contaminated groundwater and soils. For OU Three, a cleanup
remedy has not yet been selected by EPA. A separate FS has been prepared to identify and
evaluate remedial alternatives for contaminated soils and sediments. The results of the RI and
two feasibility studies will be used to identify additional remediation activities which may be
necessary for contaminated groundwater and soils. The third au Is currently proposed as the
finaJ response action for the Site. The proposed action for OU Two will be consistent with any
future response action taken at the Site. .
v. OPERABLE UNIT CHARACTERISTICS
Table 1 summarizes the Site materials to be remediated under OU Two. :rhese materials are
described as follows:
A.
VAULT WASTES
The vault waste medium consists 01 approximately 1,500 cubic yards (CY) of calcium-arsenic
sludge (lower vault wasfe) and 3,000 CY of various drummed organic/arsenic wastes and
. admixed soils (upper vault wastes) present in a concrete vault (see Figure 2). Also included
in the upper vault waste classification are approximately 20 drums buried just east of the vault
which are filled with approximately 5 CY 01 tar-like material ihat contains toxic ,organic.
chemicals, and an estimated 50 CY of residuals potentially present in the tanks and process
vessels not being addressed under OU One.
The concentrations 01 arsenic in the upper and lower vault waste samples were measured to
be about 12 and 15.7 percent, respectively. The total quantity of arsenic in the vault wastes
is estimated at 2,000,000 Ibs. The concentration of organics for the upper vault and lower vaL;i:
waste samples were measured to be about 14 percent and 0.2 percent, respectively. The'
organics observed in the vault waste samples and quantity estimates are aniline (900,000 Ibs),
n-nitrosdiphenylamine (450,000 Ibs) , benzene/xylenes/phenoVn-nitrosodiphenylamine (1.100
Ibs), and tetrachloroethene «100 Ibs). Cadmium is also present in the vault wastes in
significant quantities. Arsenic, cadmium, aniline, benzene, tetrachloroethene (TCE) , and ro-
nitrosodiphenylamine are classified by EPA as carcinogens; whereas arsenic, cadmit.;:'11
benzene, xylenes, PCE, and phenol are considered to be systemic toxicants.
The structural integrity of the vault Is questionable. The vault is underlain by karstic, sinkhole-
prone limestone. Because of their soluble nature, the vault contents pose an actuaJ or poten!'a!
threat to groundwater if no remediation occurs. Ingestion of and dermal contact with :~e
wastes are also possible now and in the Mure if no remediation occurs.
B.
LAGOON WASTES
The lagoon wastes consist 01 the iron-arsenic sludge and admixed soils which contain grea:e'
than 10,000 mg/kg (1 percent) arsenic. The lagoon wastes are located in the areas indica:e:
9
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TABLE I
" " " ,. "
...."Ic a.1I !n. PCB'
a.... Otll..
...,,- ".c.lptlo. ' ,.1- C..t_I...t.
,.t..t a....,. I....tlt, a....,. 1"..tH, a....,. ...""
Conc..t..tl.. Conc..t..u.. C..II..t..t I.. .....t H,
I .ppe. ....It ..u. I." C. ..,. H'.. .n I."'..' .~. .. i, "'.0'0 .~. d ..,", clO III. .
"'.'" .~.
I ...... ....u ....t. I.'" C' '.It ..... II." ,iu.... III. '.n '.'" III. cl ..,II. ct" III. '.'.".'
'.'" I~.
J Le,... ...u.. II.'" C. I.' ..... ,I." 'I. '08.'" III. U. 11,111, . .11. -. cl .11. r.a ...U.
'08 .11.
. 8..C.U._.". .. C' .. h.
',"~t.""'.toc". IS C' .- ........ n ---... .. _. -- ..
.."'''0.
" \ fl.'" L' .f
. .... .u_t..... '.'" c,u. I.' .c... UI UI UI U. UI U. pl"..,I.
JSt.... .,118 8Y..
...'."0" ..
us..
QUANtiFICATION or OPERABLE UNIT 2 MEDIA'
, ,NHITMOYBA LABORATORIES SITS'
LBBANON COUNtY. PENNSYLVANIA
&TBI
Mot belIeved to be eltnlrlcant or not applicable.
Ben.ene. Toluene, Eth,lben.ene, 1,lene.'
N I 1I-littroaoillphen,I..lne '
B..,Ph,N Ben.en" .,Ie.e, Phenol. n-nltro.odlphenyla.lne, '
P,BB.N Pentachlorophenol. BI.C2-ethlhe.,ltphthalate. n-nltrosodlphen,la.lne ,
...
, fl.
118
...
Moat pr08lnent c08pOUnd. Ob.er.ed. nu..rou. other c08pOUnd. vere detect.d.,
Pre.ent but cannot be calculated.
Building 1-1 c08ple.. vault. tan' dl'... plpln.. tan'.. and proce.. equlp81nt.
Bur face are. of cont_ln.ted .It., .tructure..
-------
in Figure 2. These areas cover approximately 2.0 acres. The totaJ estimated volume of lagoon
wastes is 24,000 CY. The average arsenic content 01 the lagoon was1es is 2.5 percent; the
lagoon Wast88 contain an estimated 1 ,500,000 Ibs of arsenic. The most prominent organics
measured in the lagoon waste samples are pentachlorophenol, bis(2.ethylhexyl)phthalate, and
n-nitrosodiphenylamine at a summed average concentration 01 about 12 mg/kg. The total
calculated quantity of organics in the lagoon wastes is about 700 Ibs. Bis(2.ethylhexyl)phthalate
is consider a carcinogen by EPA, whereas both pentachlorophenol and
bis(2.ethylhexyQphthaiate are considered systemic toxicants. The lagoon wastes are underlain
by karstic, sinkhole-prone limestone. Because 01 their somewhat soluble nature, the lagoon
waste contaminants may continue to leach into groundwater and thereby pose an actual or
potential threat to groundwater if left unremediated. .
c.
MISCELLANEOUS PRODUCTS/FEEDSTOCKS
The miscellaneous products/feedstocks medium consists 01 numerous drummed or bagged
materials manufactured or routinely used by Whitmoyer Laboratories, Inc., which were
abandoned inside the buildings at the Site. Based on sampling of portions of this medium,
approximately 61 CY 01 these materials (mostly arsenic-contaminated corn meal) are believed
, to be RCRA characteristic hazardous wastes, while 35 CY are believed to be nonhazardous
(about one-half being beef liver concentrate). Five CYof materials are presently unclassifiable;
for this ROD, they will be considered as RCRA characteristic wastes because of arsenic toxicity,
Because 01 their diverse nature and small volume, the miscellaneous products were not
chemically analyzed in detail. The primary contaminant of the, hazardous wastes is believed
to be arsenic. The 101 CY 01 miscellaneous products/feedstocks present current and future
risks of ingestion, dermal contact, and groundwater and surface-water contamination. if left
unremediated.
D;
SITE STRUCTURES
The Site structures medium consists 01 the production buildings, process equipment and piping;
above-ground and underground tanks, and concrete dikes. All 01 the buildings onsite, with the
exception 01 Buildings 10 and 18, were 10und to be contaminated with arsenic-containing dusts.
The maximum dust-loading observed in wipe samples collected during the RI was 0.764 mg
arsenic per square centimeter. Air within the buildings was sampled under quiescent
conditions. Arsenic concentrations in air as high as 0.4 ug/m3 were measured during the RI.
Arsenic concentrations 01 the dust collected on the air fitters were calculated to average
8,100 mgJkg. About 25,000 square feet (SF) of ro01 material, 58,000 SF 01 flooring and wall
materials in Buildings 1, 2, 3, 6, and 7. (the Building 1-7 complex), and process equipment in
the Building 1-7 complex are contaminated with arsenic. Some of these materials are 50
heavily contaminated with arsenic that they exhibit the RcRA characteristic ot arsenic toxicity.
Some 01 the materials that exhibit the arsenic toxicity characteristic also exhibit the cadmium
toxicity characteristic. Simulated roof runoff collected during the RI contained as much as 94
mg/l arsenic. Other contaminated Site structures include tanks, process vessels, and related
piping contaminated with concentrated liquids residuals; asbestos located in drums (4 CY) and
on piping (2,800 linear teet) in the Building 1-7 complex; the vautt concrete structure; and the
outdoor tank concrete dikes. .
10
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If no remediation occurs, the arsenic-contaminated dusts present actual or potential future
ing~on/lnhaldon threats. Precipitation contacting contaminated building materials can
contaminate groundwater and surface water at present and in the future. .
VI. SUMMARY OF SITE RISKS
The objective of this section is to estimate the potential for adverse health or environmental
effects incurred by human or ecological receptors exposed to the materials making up au Two
under the exposure scenarios eStablished in the RI Report for the Whitmoyer Laboratories Site.
This section characterizes the potential noncarcinogenic, carcinogenic, and environmental risks
associated with au Two. EPA guidelines for the use of dose-additive models are used to
combine the risks for indMduai chemicals to estimate cumulative risks for the mixtures found
onsite,' assuming the toxicological endpoints are the same. This section summarizes the risk
assessment presented in the Whitmoyer laboratories Site RI Report, which was finalized. in
November 1989. . .
A.
HUMAN HEALTH RISKS
-. -
For human health risks, both carcinogenic risk and the potential'fornoncarcinogenic effects are
.. presented. . Carcinogenic risk is evaluated by determining the excess lifetime cancer risks
(ELCRs) for actual or potentially exposed individuals.. ELCRs are determined by multiplying the
contaminant exposure dose with the cancer potency factor (cancer slope factor). These risks
are probabilities that are generally eXpressed in scientific notation (!A, 1 x 1Q-6). An ELCR
of"1x10-6 indicates that, as a plausible upper bound, an indMduai has a one in one million
, chance of developing cancer as a result of Site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a Site. .
Cancer potency factors (CPFs) have been developed by EPA's Carcinogen Risk Assessment
V~rification Endeavor workgroup for estimating lifetime cancer risks associated with exposure
. to potentially carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-dayt 1, are'
multiplied by the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper
bound estimate of the ELCR associated with exposure at that intake level. The term .upper
bound" reflects the conservative estimate of the risks calculated from the CPF. Use 01 this
.' approach makes underestimation of the actual cancer risk highly unlikely. Cancer potency
. factors are derived. from the results of human epidemiological studies or chronic animal
bioassays to whichanimal-to-human extrapolation and uncertainty factors have been applied.
"
i
I
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed 88 1M hazard quotient (HQ) [or the ratio 'of estimated intake derived from the
. ,contaminant concentration'in a given medium to the contaminant's reference dose (AtD)]. The
HO is also referred to as the Dose/RfD ratio. By adding the Has for all contaminants within
a medium or across all media to which a giVen population may reasonably be exposed. the
Hazard Index (HI) can be generated. The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a single medium or across
media. .
11
-------
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RIDs, which are
expressed In units of mglkg-day, are estimates of acceptable lifetime daily exposure levels for
humans, indudlng sensitive Individuals. Estimated intakes of chemicals from environmental
media ~ the amount of a chemical ingested from contaminated drinking water} can be
compared to the RfD. RfDs are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied ~ to account for the use of animal data to
predict effects in humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic health effects to occur.
The following risk summary is presented by medium for the various OU Two media. Following
the medium-by-medium summary, a discussion of the groundwater exposure pathway is
presented since all of the OU Two media actually or potentially threaten groundwater.
1.
Vault Wastes
The contaminant concentrations and exposure pathways for the vault wastes are briefly
described above in Section V.A. above. The exposure pathways are groundwater consumption,
dermal contact, and accidental ingestion. The groundwater pathway is discussed below.
Potentially exposed individuals for the dermal contact and accidental ingestion pathways include
Site trespassers who may access the vault wastes through portals in the side of the vault
structure. A conservative accidental ingestion exposure scenario of 10 exposures over a'90-
day period for a 45-kg child was assumed in the risk assessment. Based on this scenario, an
HO of 30 and an ELCR of 1.94 x 10-3 was calculated for the upper vault waste (based',on
sample results from tarry material in the upper vault), and an HO of 38 and an ELCR of 2.45
x 10-3 was calculated for the lower vault sludge, for the arsenic contamination only. Thus.
accidental ingestion of the w~te by a receptor trespassing across the Site results in a. HQ
exceeding unity (i.e., adverse noncarcinogenic health effects are possible under the conditions
of the risk assessment) and ELCRs in excess of 1 X 10-3 (i.e., under the conditions of the.risk
assessment, the carcinogenic risk is greater than the CERCLA acceptable ELCR of between:.' a-
4 and 1 0-6). '. - . :
-.
Organic chemical contamination is also present in the vault wastes. For example, the tar sample
from the upper vault wastes contained 11 % aniline. Concentrated aniline is acutely toxic to
humans. Aniline penetrates the skin rapidly and induces methemoglobinemia in those persons
sufficiently exposed. Death can result from a significant exposure. Aniline is also classified by
EPA as a probable human carcinogen. Risk from accidental ingestion of organic contaminants
in the vault wastes were not quantitatively assessed during the RI.
The potential for direct exposure to the vault wastes is expected to increase in the future
because of the eventual deterioration of the wooden vault roof.
2.
Lagoon Wastes
The lagoon wastes are covered by a' soil cap. Although this soil is contaminated, arsenic
concentrations do not exceed 10,000 mg/kg. Thus, the soil cap is not considered to be a part
of the lagoon ~aste medium, but will be addressed in the ROD for au Three. Since the lagoon
12
-------
wastes are not present on the surface, there is no present dermal contact or accidental
ingestion threat from these wastes. There is a potential for these exposures in the Mure if the
. wastes are not remedlated and excavation occurs in the lagoon areas., . .'
. The primary exposure pathway 10r the lagoon wastes is the groundwater pathway. Precipitation
infiltration through the lagoon wastes was modeled in the RI Report, using the Hydrologic
Evaluation of Landfill Performance (HELP) model. For the eastern (consolidated) and western
(excavated) lagoon areas, infiltration of 13.4 in/yr and 14.0 in/yr, were predicted by the model. .
. This infiltration rate corresponds to a total percolation rate 01 921 gallons per day, for the
eastern .Iagoon area only. the groundwater pathway is discussed in more detaii'in Section
VIA.S below. ..' .
3.
Miscellaneous ~roducts/Feedstocks
The miscellaneous products/feedstocks are presently housed in the Site buildings and are
. readily accessible to Site trespassers. These trespassers could be exposed via the dermal
contact or accidental ingestion pathways. Becal,Jse 01 the relatively small volumes and diverse
natures 01 the miscellaneous products/feedstocks, a quantitative risk assessment 10'r the dermal
contact and accidental ingestion pathways was not conducted during the RI. However. much
.01 the materials are known to be contaminated with arsenic in significant concentration~, ,(For
. example, some of the abandoned materials are pure arsanilicacid product.) '. Arsenic is a
. known human carcinogen; Exposure to arsenic in excess of existing standards/cr,iteria ~,
the' arsenic reference dose) may aJso result in noncarcinogenic health effects in humans.
Human trespassers may be adversely affected if exposed' to 'these materiaJs. Thus, the
miscellaneous products/feedstocks pose an actual or potential threat to the health of human
trespasser~.' ".
Many of the materials are known to exhibit the RCRA characteristic of, arsenic toxicity, Thus,
, these materials could release substantial quantities of arsenic when coritactedby precipitation
This could occur if the building conditions deteriorate further in the Mure, if no remediation
.' occurs.. Precipitation 'that has contacted the arsenic-contamin'ated miscellaneous
products/feedstocks could run off and potentially contaminate groundwater and/or surface
water. The surface-water pathway was not quantitatively analyzed. The groundwater pathway
is discussed in further detail below. . ' ,"
4.
'. Site Structures
As described In Section V, nearty all. of the Site building interiors are coated with arseniC-
contaminated dust. This dust. presents an accidentaJ ingestion threat to' workers if they
occupied the UlYemedlated buildings in the Mure. This exposure pathway was modeled in the
RI using two methods, Method 1 and Method 2. Method 1 assumes that the workers inges:
0.1 gram/day of dust at their workplace. Method 2 assumes the worker contacts the intencr
surfaces 01 the building, and subsequently ingests dust adhering to 59 cm2 01 the hand surface
area (the inside surface area 01 the fingers and thumb). Both methods assume the workers'
are exposed 10r 250 days/year over a 4O-year work period, and weigh 70 kilograms (kg),
13
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LEGEND
"MfUU.ratCOMnUMMIOl.MaiM
aŁ-
' i«*fnn8O-'
-POTENTIAL UDCATIONS OT OMS1TE LANDFILL
ONSITE LAMDFH.L- POTENTIAL LOCATIONS
WNTMOYER LABORATORIES SITE. MYERSTOWN. PA
F*OU«E 3
IMUS
OORPORATOTSJ
-------
Using the dust arsenic concentrations calculated from the building air data and Method 1, Has -
ranging from 1 to 23 and ELCRs ranging from 2.34 X 1 cr2 to 1.4 x 1 cr3 were calculated (see
Table 2). UsIng Method 2 and the RI building wipe sample data, Has as high as 361 and
ELCRs approaching unity were calculated (see Table 3). Thus, adverse noncarcinogenic health
effects are possible and there is a significant excess lifetime cancer risk under the-conditions
of the risk assessment. - -
Elevated arsenic concentrations were measured in the building air under quiescent conditions
during the Rt Th~ building air presents an inhalation threat to workers employed in the
buildings in the Mure if the buildings are not remediated. This exposure pathway was modeled
in the RI risk assessment, assuming that the workers were exposed a hours/day, 2,50 days/year
for 40 years. Other assumptions include a 1.3 m3/hr breathing rate and a worker weight of 70
kg. Based on the RI air data, reasonable worst case scenario ELCRs as high as 1 .15 x 10-
-- 3 were calculated (see Table 4). Thus, there is a significant excess lifetime cancer risk under
the conditions- of the risk assessment. Because there is - no inhalation reference dose for
arsenic, the RI did not calculate Has for this exposure scenario.
Precipitation causing leaching of contaminants from the building materials and subsequently-
contamin~ting groundwater or surface water is a current and Mure exposure scenario. Roof
runoff from a simulated precipitation event was collected and analyzed during the RI. Arsenic
- concentrations as high as 9.4 mg/l were measured in the runoff. This concentration is more
- than 100 times the Commonwealth of Pennsylvania water quality standard for Tulpehocken
- Creek at the Site of 50 ug/l arsenic and the Safe Drinking Water Act Maximum Contaminant
Level of 50 ug/l arsenic; which is a relevant and appropriate regulation for groundwater.
-Building contaminant mobilization could increase in the Mure if building conditions deteriorate.
Risk from direct exposure to contaminated building runoff was not quantitatively as~essed. the
groundwater pathway is further discussed below. -
As much of the Building 1-7 cOmplex and process equipment are wooden, there could be a
potential contaminant release from a fire set by vandals. Arsenic is a metal that volatilizes at
rather low temperatures. Also, building organic contaminants and their toxic byproducts could
be released during a fire. Risk from this exposure pathway was not quantitatively assessed.
- -
- -
The building conditions have deteriorated since the Whitmoyer Laboratories plant was
abandoned in 1987. Current unsafe conditions include corroded metal walkways and missing
railings. Trespassers could be pQtentiaily harmed by these conditions.
The -Map 01 FIood-Prone Areas,- published by the United States Geologic Survey, and the
Flood Insurance Rate Map, published by Federal Emergency Management Agency, both show
portions of the Buflding-~-7 complex to be in the 100-year floodplain (elevation 559 above Mean
Sea Level, see figure 3). Severe flooding could possibly mobilize contaminants present in the
lower.levels of the buildings (building materials and dusts), with a release of contaminants to
the Tulpehocken Creek waters. This exposure pathway was not quantitatively assessed.
14
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HAZARD
TABLE 2
INDICES AND CANCER RISK LEVELS FOR
THE DaST INGESTION SCENARIO
WHITMOYER LABORATORIES SITE
LEBANON COUNTY, PENNSYLVANIA
Sampling Location DOI./RfD Eltimated Excess
Ratiol Lifetime Cancer Risk
Building 2, rirlt rloor 7 7 . 10-3
. 10-3
luilding 7, rint rloor 1 1.4 .
Building 9, rirlt Ploor 23/5 2.34 . 10-21
5 . 10-3
/ symbolizes duplicate
-------
TABLE 3
HAZARD INDICES'
AND CANCER RISK LEVELS FOR ARSENIC CONTENT .OF WIPE
COLLECTED WITHIN PROCESS BUILDINGS
WHITMOYER LABORATORIES SITS
LEBANON COUNTY, PENNSYLVANIA
SAMPLES
HAZARD INDICES
ht P100r 2nd Floor . 3rd P100r
Bu Ild I nC)
NU8ber
P If C P M C P W C
BulldlnC) 1 1.97 0.7 lID 9.2' NO 0.93
Building 2 )].6 NO 0.8 25 0.75 0."
BulldlnCJ] 1.04 NO 2.1 4.5 7.0 0.7
Building 4 4.64 NO
BulldinC) 5 2.7 ND ND 11.6 ND NO ND 1.04 ).1
Building 6 361.]- )) 14.2 36 1.16 0.5- 11
BulldinC) 7 12.2 5.6 0.58
Building 8 5.6 NO 1.57 NO ND
BuildlnCJ 9 9.7 0.49- NO
BulldlnCJ U NO ND ND NO ND ND
"'.
BuildlnCJ II 1.04 ND ND
..
BuildlnCJ 18 NO ND
- Duplicates were averaC)ed
Blanks spaces Indicate that
P . 'loor
W . Mall
C = Ceil i nCJ
no analyses were perfor.ed.
-------
TABLE ]
HAZARD INDICIS AND CANCER RISK
WHITMOYER LABORATORIES SITE
LEBANON COUNTY, PENNSYLVANIA
PAGE ft6..
LEVELS FOR ARSE~IC CONTENT 0' WIPE SAMPLES COLLECTED WI1HIN PROCESS BUILDINGS
CANCER RISK BSTIMATBS
Bu lld! nCJ 18t 'loor 2nd Ploor Jrd Ploor
"'.ber
. II C , .. C , .. C
Bulld!nCJ 1 2.0. 10-J 7.1 . 10-. ND 9.5 . lO-J ND 9.5 . 10-.
Bulld!nCJ 2 ).4. 10-2 ND 8.) . 10-. 2.6 . 10-2 7.7 . 10-. 5 . 10-.
Bulld!nCJ) 1.0. lO-J ND 2.1 . 10-J 4.5 . 10-) 7.1 . lO-J 7.1 . 10-4
Bul1dlnCJ 4 4.1. lO-J ND
BulldlnCJ 5 2.1. 10-) NO ND 1. 2". 10-2 ND ND ND 1.1 . 10-) ].1 . 10-)
BUlldlnCJ 6 .. ).4 . 10-) 1.5 . 10-2 ].6 . 10-2 1.2 . 10-) 5 . 10-4 1.1 . 10-2
Build! nC) 1 1. 2 . 10-2 5.7 . 10-) 5.9 . 10-.
BulldlnCJ 8 5.1. 10-) ND 1.6 . IO-J ND ND
BulldlnCJ 9 9.9 . 10-) 5 . 10-.. ND
BulldlnC) 10 NO NO ND ND NO ND
BulldlnCJ 11 1.1 . lO-J NO ND
BulldlnC) 18 NO NO ND
. Duplicates "ere averaCJed
..Cancer risk approaches unity
, .. 'loor
.. . ...u
c .. CeU!nC)
-------
"
TABLE 4
CANCER RISK LEVELS FOR ARSENIC CONTENT OF
AIR WITHIN PROCESS BUILDINGS
WHITMOYER LABORATORIES SITE
LEBANON COUNTY, PENNSYLVANIA
Supling Station E.tiaated Ixcessl
Litetime Cancer Risk
Building 1, Second '100r 1.15 x 10-3
Building 2, Pint P100r 5.76 x 10-4
Building 7, Pirst Floor. 1.99 x 10-4
Building 8, Pirst P100r 5.29 x 10-4
luilding 9, Pirst P100r 1.13 x 10-3.
1 Maximum contaminant levels are evaluated
-------
5.
Groundwater
As identified In the RI, the groundwater at the Site and downgradient of the Site is highly
contaminated. Peak concentrations of arsenic and other organics ~, tetrachloroethene)
measured in the groundwater exceed Safe Drinking Water Act (SDWA) Maximum Contaminant
Levels (MCLs) by a factor of about 3,000. ELCAs and Has for the onsite/near-Site groundwater
(residential use-reasonable worst case scenario) approach unity and exceed 6000, respectively.
This scenario assumes residential use of the Site and consumption of the most contaminated
groundwater at a rate of 2 liters/day for 70 years by a 7o-kg adult. The risk data indicate
potential adverse carcinogenic and noncarcinogenic effects under this exposure scenario.
The materials addressed in OU Two are likely to be contributing to the groundwater
contamination and woul~ continue to contaminate groundwater in the Mure if left unremediated.
With time, as the buildings and vault structure continue to deteriorate, contaminant contributions
to groundwater from the OU Two materials would likely increase. . ,
B.
ENVIRONMENTAL RISKS
Based on the aquatic biota survey and fish tissue sampling conducted during the RI, no
evidence of impacts on the ecosystem from the Site was observed. Fish tissue arsenic
concentrations were below 2 mg/kg, the method detection limit. Sensitive benthic species, tl.,
stoneflies and mayflies, were found in downstream waters of Tulpehocken Creek. (There are
no endangered species or natural resources of special concern in the vicinity of the Site.)
Thus, contamination from the materials addressed in OU Two do not appear to be impacting
the ecosystem currently. As the buildings and vault structure continue to deteriorate over time.
contaminant contribution to surface water and sediment could potentially affect the ecosystem
in the Mure if no remediation occurs.
In summary, actual or threatened releases of hazardous substances from the materials making
up OU. Two, if not addressed by implementing the response in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
VII. DESCRIPTION AND COMPARISON OF ALTERNATIVES
Based on the RI risk assessment for the OU Two materials, EPA developed the following
remedial action objectives to protect human health and the environment:
1.
Prevent human exposure (dermal contact, ingestion, inhalation) to au Two
materials having contaminants in concentrations greater than carcinogenic (ELCR
greater than 1 Q-4 to 10-6) and noncarcinogenic (Hazard Index greater than 1)
risk-based levels.
2.
Prevent human exposure (dermal contact, ingestion) to drainage from process
buildings having contaminant concentrations greater than
carcinogeniC/noncarcinogenic risk-based levels (ELCR greater than 10-4 to i a-
6/Hazard Index greater than '1) risk-based levels.
,
15
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3.
Prevent migration' (via leaching) of contaminants that would result in groundwater
contamination In excess of' MCLs (!A. 50 ug/l arsenic and 5 ug/l PCE) and/or
, carcinOQ.enlC/noncarcinogenic risk-based Cleanup levels (ELCR greater than 1 (J
, .. to 1o-c'/Hazard Index ~reater than 1)., '. ." ..., .
4.
, ~. .',
Prevent migration (via runoff, flooding, erosion) of contaminants that would result
. in surface-water contamination in excess of Pennsylvania Water Quality StSDdards
. . ~ 50 ug/l arsenic), Federal Ambient. Water Quality Criteria, and/or
carcinogeniC/nonCarcinogenic risk-based cteanup levels. .
5.
. Comply with chemical-specific, location-specific, and action-spe,cific applicable
or relevant and appropriate regulations' (~)t including .RCRA land disposal
restrictions. .'. '. .
Based on data available in the RI and FS Reports, the following OU Two materials will need to
. be remediated' to achieve the remedial action objectives:.' . '. .
. "'. '. {
'*
Vault Wastes - Estimated .volume is 4,500 cubic yards. .
. Lagoon Wastes. - Estimated volume is 24,000. cubic yards~. ".'
Miscellaneous Products/Feedstocks - Estimated volume, is 1 01 .cubic yards.
Site Structures - Dust-contaminated areas. Estimated area is 350,000 square feet
Site Structures - Contaminated materials (Building 1-7 complex, vault structure,'
tank dikes, piping, tanks, and 'process equipment).. Estimated volume is 5;000
cubic ,yards.
*
*
*
*
, . ,
The Superfund process requires that the. alternative chosen to clean. up a hazardous waste Site'
meet severat criteria. The alternative must protect human health and the environment, be c9st- ,
effective, and meet the requirements 01 environmental, regulations. Permanent solutions to
contamination problems shOuld be developed wherever practicable. These solutions should
reduce the volume, toxicity, or mobility of the contaminants. Emphasis is also placed on
treating the wastes at the Site, whenever, this is practicable, and on ,applying innovative
technologies to clean up the contaminants. .
EPA studied a variety of technologies to see if they were. applicable for use on the vault wastes,
lagoon wastes, miscellaneous productslfeedstocks, and Site. structures.' The technologies
determined to be most applicable. to these materials were developed into remedial alternatives.
Because of the c:Iff&rent nature of each of the materials constituting au Two, separate remedial
. alternatives for e8Ch waste class (medium) were developed. These alternatives are presented
and discussed below. The remedial alternatives developed by the former Site owners and
presented to the EPA are also described and discussed:' .
. A.
VAULT WASTES
Alternatives 1 through 5 for the vault wastes are numbered to, correspond with the numbers in
the FS Report. Alternative 6 is the alternative presented by the. former Site owners prior to
. r
16
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issuance of the Proposed Plan for OU Two. Alternative 7 Is a separate alternative proposed
by the former owners in their comments on the Proposed Plan. The alternatives are the
following: . .
*
Alternative 1:
Alternative ,.2:
Alternative 3:
Alternative 4:
Alternative 5:
Alternative 6:
Alternative 7:.
No Action
Bulk Excavation/landfill (Onsite)
Bulk Excavation/Fixation/Landfill (Onsite or Offsite)
Bulk Excavation/lncineration/FixationlLandfili (Onsite or Off Site)
Bulk ExcavationNrtrification/Landfill (Onsite or OffSite)
On-5ite Enhanced Solids Containment System
Bulk Excavation/Landfill (OffSite)
*
*
*
*
*
*
1..
Alternative 1: NO ACTION
The Superfund Program requires that the .no action. alternative be evaJuated at every Site to
establish a baseline for comparison with the other alternatives. Under this alternative, EPA
would take no actions other than annual groundwater monitoring around the vault and
performing reviews every 5 years. There are no ARARs associated with this alternative .
Alternative 1 would not comply with the CERCLA preference for a remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. While no capital costs'
would be incurred under this alternative, annual operation & maintenance (O&M) costs are'
estimated to be $7,100. This alternative has a present-worth cost of $109,000, and can be
implemented immediately. .
/
2.
Alternative 2:. BULK EXCAVATION/lANDFILL (ONSITE)
Under this alternative, the vault wastes would be excavated and placed in a new landfill located..
onsite. The landfill would be designed to meet or exceed RCRA landfill standards (40 CFR Part~
264, Subpart N), which have been determined to be relevant and appropriate. RCRA standards
are not applicable to Alternative 2 since the wastes are being consolidated within the same
area 01 contamination. The Whitmoyer Laboratories Site is underlain by limestone (carbonate)
bedrock. Studies by the Pennsylvania Topographic and Geologic Survey have shown that the
limestone beneath the Site can be dissolved by infiltrating rainwater and groundwater passing
through it. Over time, this dissolution could destabilize the overtying rock and soil, and cause
them to cave in (sinkhole collapse). To provide protection against landfill failure, the landfill
liner base would be designed to minimize threats posed by sinkhole collapse. Deed restrictions
prohibiting future uses would be placed on the landfill area, Since the wastes would remain
onsite, long-term O&M would be conducted to monitor the groundwater around the landfill and
to ensure the Integrity of the cap, in compliance with 40 CFR 264.117, and 5-year reviews
would be conducted. The vault structure would be addressed under the Site structures
medium. The vault waste excavation would be backfilled with soil and regraded. Alternative
2 would not comply with the Pennsylvania hazardous waste facility siting criteria in Title 25.
Chapter 75.425, which prohibit the construction of a hazardous waste landfill over limestone
or carbonate formations. These criteria have been determined to be relevant and appropriate.
Alternative 2 would also not comply with the CERCLA preference for a remedy that employs
17
-,
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treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
cost of this alternative is $1,027,000. with annual O&M costs estimated to be $22.900. This
. alternative has . present-worth cost of $1,379,000. The estimated time to imptement this
. alternative is approximately 24 months. . .
3.
Alternative 3: BULK EXCAVATION/FIXATION/LANDFILL lONSITE OR OFFSITE)
The maior features of this alternative include excavation. of the 4.500 cubic yards 01 vault
wastes. onsite micrOencapsulation of the upper vault wastes,onsite cemenVpozzolan-based
fixation .of the lower vault wastes. and landfilling of the treated wastes .ither onsite or off Site.
The vault structure would be addressed under the Site structuresmedil.!m. The . vault waste
. excavation area would be backfilled with soil and regraded. ~
The 3000 CY of upper vault wastes would be microencapsulated in a solid matrix ~, asphalt)
. onsite in accordance with RCRA standards for miscellaneous treatment units (40 CFR Part 264,
Subpart. X). The microencapsulation unit would be mobilized. operated. and closed according
to the requirements of 40 CFR 264.600, et sea. The effectiveness of microencapsulation
processes in treating the upper vault wastes is uncertain. A treatability study would be required
: prior to full-scale implementation to validate the proposed treatment. The specific type of
. microencapsulation process to be used would be determined in the Remedial Design phase
. through the treatability study. engineering design and analysis. and competitive bidding
. process; Because the upper vault wastes are a mixture. of K101 wastes. K102 wastes I and
. arsenic' characteristic wastes; some or all of the upper vault wastes also exhibit the toxicity
characteristic for cadmium; and Alternative 3. constitutes treatment. RCRA Subtitle C is
applicable. RCRA.land disposal restriction treatment standards for these wastes are 5.0 mgil
arsenic (for arsenic characteristic (DOO4) wastes); 5.6 mg/l arsenic (for the listed wastes), as
measured by the Extraction Procedure (EP) Toxicity Test or Toxicity Characteristic Leachate
Procedure (TCLP); and 1.0 mg/l cadmium (as 'measured by the TCLP) for cadmium
characteristic (DOO6) wastes. Treated K101 and K102 nonwastewaters must contain less than
14 mg/kg .nitroaniline and 13 mg/kg ortho-nitrophenol. respectively, prior to land disposal to
comply with RCRA land disposal restrictions (40 CFR Part 268). (A national capacity extension
for arsenic characteristic nonwastewaters and K101 and K102 nonwastewaters is in effect until
May 8; 1992.) All upper vault wastes exhibiting the toXicity characteristic for cadmium must
meet the cadmium treatment standards. in addition to the tre.tment standards for the listed
wastes and arsenic characteristic wastes. If effective. the microencapsulation process sho u! C
achieve these treatment standards. .
The lower vault wastes would be fixated onsite using a C$menVpozzolan-:based method cr
. anoth.er similar fixation process that provides equivalent protection.' in 'compliance with t~.e
requirements of ReM standards for miscellaneous treatment units (40 CFR Part 264. Subpa~
. X)~ A treatability study was conducted using cemenVlime-based fixation methods on the lower
vault. wastes during the RVFS. This treatment reduced the arsenic leachability of the wastes
by approximately 99.94% to 5.4 mg/l. as measured by the TCLP. This level is slightly lowe:
than the applicable 5.6 mg/l arsenic RCRA land disposal restriction treatment standard for the
lower vault wastes (K084 wastes). (A national capacity extension for K084 nonwastewaters is
in effect until May 8. 1992.) The lower vault wastes are also characteristic (0006) wastes
because of cadmium toxicity. The fixation process should achieve the DOO6 land disposa:
'",
.\
18
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,.-
restriction treatment standard. The exact fixation technique employed would be determined in
the Remedial Design phase through engineering design and analysis and the competitive
bidding pr0C888. The fixation unit would be mobilized, operated, and closed a~ding to the
requirements of 40 CFR 264.600, et sea. '
Metal drums and other debris would be separated from the upper vault wastes prior to the
treatment. step to protect the processing equipment. These drums and debris would be
cleaned and disposed in accordance with hazardous waste container regulations (40 CFR
261.7). ' .
Specialized air pollution control equipment would be applied during the microencapsulation step
to capture contaminants in the exhaust air and thus ensure compliance with the relevant and
appropriate National Ambient Air, Quality Standards (NMQS) (40 CFR Part SO).
The treated wastes would be placed in either a new onsite landfill or an existing offSite landfill. '
Because of the treatment step, placement is occurring. The landfills would be designed in
accordance with the applicable RCRA landfill standards (40 CFR Part 264, Subpart N). If the
wastes were landfilled onsite, the landfill base would be designed to minimize the threat of
sinkhole collapse. Deed restrictions prohibiting Mure uses would be placed on the landfill
area. In addition, long-term O&M would be conducted to monitor the groundwater around. the
landfill and to ensure the integrity of the cap, in compliance with 40 CFR 264.117, and S-year
reviews would be conducted. The onsite landfill option would not comply with the Pennsylvania
hazardous waste facility siting criteria in Title 25, Chapter 75.425; which prohibit the construction
, of a hazardous waste landfill over limestone or carbonate formations. These criteria have been
determined to be 'applicable. The offsite landfill option would comply with all ARARs.
Alternative 3 would comply with the CERCLA preference for a remedy that employs treatment
to reduce toxicity, mobility, or~volume as a principal element. The estimated capital costs of
this alternative are $10,700,000 and $15,900,000 for the onsite and offSite landfill options,
respectively. Annual O&M costs for the onsite landfill option are estimated to be $35,200.
There are no annual O&M costs for the offSite landfill option. The estimated present-worth
costs of this alternative are $11,300,000 and $15,900,000 for' the onsite and off Site landfill
options, respectively. The estimated time to implement this alternative is approximately 36
months.
4.
Alternative 4: BULK EXCAVATION/lNCINERATION/FIXATlON/LANDFlll (ONSITE OR
OFFSITE\
The major f88Iur88 01 this alternative include excavation of the 4,500 cubic yards of vault
wastes, onsltelnclneration 01 the wastes which will destroy the organics and leave the arsenic
in a form amenable to fixation, fixation 01 the incineration residuals, and landfilling of the treated
wastes either onsite or offSite. The vault structure would be addressed under the Site
structures medium. The vault waste excavation would be backfilled with soil and regraded.
19
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I,
I
Prior to incineration, the upper vault materials would be subjected to grinding and crushing
followed by screening to protect the other process equipment. The'vault wastes would be
incinerated onslte in accordance with RCRA 4() CFR Part 264, Subpart 0 standards. ,The
specific type, 01 incineration process ~, rotary kiln) would be determined in the Remedial
Design' phase through engineering design and analysis and the competitive bidding process.
The incineration unit would be mobilized, operated, arid closed according to the requirements
of RCRA Part 264 Subpart 0, 40 CFR 264.340 et seQ. These requirements are applicable to
, the vault wastes (K084 , K1 01, K102, and arsenic and cadmium characteristic wastes), because
treatment and disposal 01 hazardous waste are occurring. Specific operating practices
necessary to meet the performance objectives, including a 99.99 percent destruction and
removal efficiency (DRE) 01 stack emissions as required by Subpart 0 01 RCRA, would be
,determined through a trial burn at the Site after the installation 01 the incineration unit.
Specialized air pollution control equipment would be applied during the incineration step to
captu're contaminants in the exhaust air and thus ensure compliance with the relevant and
appropriate NAAQS (40 CFR Part SO) and National Emissions Standards for Hazardous Air
Pollutants (NESHAPS) (40 CFR Part 61, Subpart N). Additionally, the vault wastes would be
incinerated in the preseQce of the cement/pozzolan fixative agent(s). A treatability study for the
lower vault wastes indicated that cement/lime presence inhibited arsenic volatilization during the
thermal treatment step. ,The cement/pozzqlan would later be hydrated during the fixation step,
The incineration residuals would be fixated onsite using a cement/pozzolan-based process or
" another similar fixation process that provides equivalent protection, in compliance with the'
:requirements 01 RCRA standards for miscellaneous treatment units (40 CFR Part 264; Subpart
, X); The e?Cact cement/pozzolan-based fixation techniqu~ employed would be determined in the
,Remedial Design phase through engineering design and analysis and the competitive biddinf.
process. The fixation, unit would be mobilized, operated, and closed' according to the
requirements of 40 CFR 264.600, et seQ. ' '
A treatability study was conducted on the lower vault wastes during the RifFS using incineration
followed by cement/lime-based fixation methods. This treatment essentially destroyed all of the'
organics. The arsenic mobility 01 the wastes was reduced by approximately 99.98%. Thus,
,Alternative 4 would be expected to comply with the applicable arsenic-based RCRA land
disposal restriction treatment standards at 40 CFR Part 26810r the vault wastes. The proposed
treatment would also be expected to comply with cadmium-based treatment standards, RCRA
land disposal restrictions (40 CFR Part 268) are applicable to the vault wastes becaus,e
placement is occurring., (A national capacity extension 10r K084, K1 01, K1 02 and arsenic
characteristic nonwastewaters is in effect until May 8, 1992 - see 55 FR 22520.)
, '
The treated wastes would be placed in either a new onsite landfill or an existing offsite landfill
Because 01 the treatment step. placement is occurring. The landfills would be-designed in
accordance with the applicable RCRA landfill standards (40 CFR Part 264, Subpart N). If the
wastes were landfilled onsite, the landfill base would be designed to minimize the threat of
, sinkhole collapse. Deed restrictions prohibiting future uses would be placed on the landfill
area. In addition, long-term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity 01 the cap,in accordance with 40 CFR 264.117, and 5-year
reviews would be conducted. The onsite landfill option would not comply with the Pennsylvar:a
hazardous waste 1acility siting criteria in Title 25, Chapter 75.425, which prohibit theconstruct:on
20
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of a hazardous waste landfill over limestone or carbonate formations. These criteria have been
determined to be applicable. The offSite landfill option would comply with all ARARs.
Alternative 4 would comply with the CERCLA preference for a remedy that employs treatment
to reduce toxicity, mobility, or volume as a principal element. The estimated capital costs 01
this altemative are $15,250,000 and $20,500,000 for the onsite and offSite landfill options,
respectively. Annual O&M costs for the onsite landfill option are estimated to be $24,900.
There are no annual O&M costs for the offSite landfill disposal option. The estimated present-
worth costs of this alternative are $15,630,000 and $20,500,000 for the onsite and off Site landfill
options, respectively. The estimated time to implement this alternative is approximately 36
months.
5.
Altemative 5: BULK EXCAVATIONNITRIFICATlON/LANDFILL COnsite OR OFFSite)
The major features of this alternative include excavation of the 4,500 cubic yards of vault
wastes, mixing the vault wastes with' soil or other Site wastes to dilute the organic content of
the mixture to 5 percent, onsite vitrification of the wastes, and landfilling of the treated wastes'
either onsite or offSite. The vault structure would be addressed under the Site structures
medium. The vault waste excavation would be backfilled with soil and regraded.
The 4,500 CY of vault wastes would be excavated and mixed onsite with soils or other materials
with a low organic carbon content. Other Site wastes could be used if suitable. This mixing
would occur to achieve a mixture organic carbon content of approximately 5 percent, the
maximum content that existing vitrification equipment can handle. The mixture would be placed
in an onsite trench and heated with electricity flowing through electrodes until the mixture
formed a pool of molten glass. Organic contaminants would be destroyed during heating,
whereas metal contaminants would become trapped in the glass during the subsequent cooling
step: The vitrification. would occur in accordance with RCRA standards lor miscellaneous
treatment units (40 CFR Part 264, Subp~ X). These standards are applicable to the vault
wastes' (K084. K1 01, K102, and characteristic -wastes) because treatment and disposal are
occurring; The vitrification unit would be mobilized, operated, and closed according to the
requirements of 40 CF,;R 264.600, et ug. A treatability study would be conducted prior to full-
scale implementation to validate the proposed treatment. The specific operating parameters
of the vitrification unit would be determined in the Remedial Design phase through the
treatability study, engineering design and analysis, and competitive bidding process.
Specialized air pOllution control equipment would be applied during the vitrification step to
capture contaminants in the exhaust air and thus ensure compliance with the relevant and
appropriate NMOS (40 CFR Part 50) and National Emissions Standards for Hazardous Air
Pollutants (NESHAPS) (40 CFR Part 61, Subpart N). Residuals from the air pollution control
system would be vttrified in subsequent batches.
Essentially all of the organics in the vault wastes would be destroyed. The arsenic mobility of
the wastes would be reduced by approximately 99.99%. Thus, Altemative 5 would be expected
to comply with the applicable RCRA land disposal restriction treatment standards for the vault
wastes. RCRA land disposal restrictions (40 CFR Part 268) are applicable to the vault wastes
21
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because placement Is occurring. (A national capacity extension for arsenic charact"eristic
nonwastewaters and 1<084, K1 01, and K102 nonwastewatersis in effect until May8,1992.)
. .
The vitrified Wastes would be placed in either a new onsite landfill or an existing offSite landfill.
Because of the treatment step, placement is occurring. The landfill~ wO'Jld be d~signed in
accordance with the applicable RCRA landfill standards (40 CFR Part 264,Subpart N). If the
wastes were landfilled onsite, the landfill base would be designed to minimize the threat of
sinkhole collapse. Deed restrictions prohibiting Mure uSes would be placed on the landfill
area. In addition, long-term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity of the cap, in compliance with 40 CFR 264:117, anQ 5-year
reviews would be conducted. The onsitelandfill option would not comply with the Pennsylvania
hazardous waste facility siting criteria in Title 25, Chapter 75.425,' which prohibit the construction
ofa hazardous waste landfill over limestone or carbonate formations. These criteria have been
. determined to be appliCable. The offSite landfill option would comply with aU ARARs. .
. Alternative 5 would comply. with the CERCLA preference for a remedy that employs treatment
. to reduce toxicity, mobility, or volume as a principal element.. The estimated capital costs. of
this alternative are. $34,270,000 and $58,000,000 10r the onsite and off Site landfill options, .
respectively. Annual O&M costs for the onsitelandfill option are estimated to be.$35,200.
There are no annual O&M costs for the off Site landfill dispOsal option. . The estimated present-
worth costs of this alternative are $34 ,aoo; 000 and $58,000,000 for the onsite. and off5ite landfill .
options. respectively. . The estimated time to implement this alternative is approximately 36
. months~ . . . '. . .
6. .
Alternative 6: ON-SITE ENHANCED SOliDS CONTAINMENT SYSTEM
Under the former owners' onsite containment proposal (Alternative. 6),the, vault 'wastes and
structure would be excavated and placed in a new landfill c6nstructed onsite and the
excavation would be backfilled with soils excavated during construction of the landfill.' The
. landfill would be designed to meet or exceed RCRA landfill standards (40 CFR Part' 264, .
. SubpartN), which have been determined to be relevant and appropriate. RCRAstandards are
. not applicable to Alternative 6 since the wastes are being consolidated within the same area
of contamination: To provide protection against sinkhole collapse and subsequent landfill
. failure, a foundation preparation program would be implemented prior to landfill construction.
The program would consist of (1) geophysical surveying of the landfill area; (2) drilling
exploration borings on a selected grid pattern and at any geophysical anomalies; (3) pressure
grouting any voids discovered in the exploration bOrings; (4) removing any soil above bedrock
and any easily removable rock and (5) placing aggregate in bedrock joint openings and above
. the bedrock surface. Deed restrictions prohibiting Mure uses would be Rlaced on the landfill
. area. Since 1hewastes remain onsite, 5-year reviews would be conducted. Also, an
unspecified maintenance and monitoring program would be implemented. Alternative 6 would
not comply with the Pennsylvania hazardous waste facility siting criteria in Title 25,
Chapter 75.425, which prohibit the construction of a hazardous waste landfill over limes~one
or carbonate formations. These criteria have been determined to be relevant and appropriate.
Alternative 6 would also not comply with the CERCLA preference for a remedy that employs
. treatment to 'reduce toxicity, mobility, 0(' volume as a principal element. Cost estimates were
not provided in. the former owners' proposal. Costs are likely to be slightly higher than the
22
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estimated Costs for Alternative 2.
approximately 18 months.
The estimated time to implement this alternative is
7.
Alternative 7: BULK EXCAVATION/LANDFill COFFSrTE)
Under this atternative, the vault wastes would be excavated and placed in an existing off Site
RCRA Subtitle C (hazardous waste) landfill. The vault waste excavation would be backfilled with
. soil and regraded. The landfill would be designed to meet or exceed all RCRA landfill
standards (40 CFR Part 264. Subpart N). which have _been determined to be applicable.
Because the vault wastes are a mixture of K084 wastes. K101 wastes. K102 wastes, and arsenic
characteristic wastes; some or aU of the vault wastes also exhibit the toxicity characteristic for
cadmium; and Alternative 7 constitutes disposal Ci.e., placement) under RCRA, RCRA Subtitle
C is applicable. RCRA land disposal restriction treatment standards for these wastes are
5.0 mg/l arsenic (for arsenic characteristic (0004) wastes); 5.6 mgJI arsenic (for the listed
wastes), as measured by the Extraction Procedure (EP) Toxicity Test or Toxicity Characteristic
Leachate Procedure (TCLP); and 1.0 mg/l cadmium (as measured by the TCLP) for cadmium
characteristic (DOO6) wastes. Treated K101 and K102 nonwastewaters must contain less than
14 mg/kg nitroaniline and 13 mg/kg ortho-nitrophenol, respectively, prior to land disposal to
comply with RCRA land disposal restrictions (40 CFR Part 268). All vault wastes exhibiting the
toxicity characteristic for cadmium must meet the cadmium treatment standards, in addition to
the treatment standards for the-listed wastes and arsenic characteristic wastes. (A national
capacity extension for arsenic characteristic nonwastewaters and K101 and KW2
nonwastewaters is in effect until May 8, 1992.) Alternative 7 would ,",ot comply with the 0006
land disposal restrictions for the vault wastes. Alternative 7 would also not comply with the
CERCLA preference for a remedy that employs treatment to reduce toxicity, mobility, or volume
as a principal element. '
Detailed cost estimates were not provided in the former owners' proposal. Costs are likely to
be somewhat higher than the estimated costs' for Alternative 2. The estimated time 'to
implement this alternative .is approximately 6 to 9 months.
8.
COMPARATIVE ANALYSIS OF ALTERNATIVES - VAULT WASTES
. .
EPA'8 8elected remedy for the vault wastes Is cement fixation (Alternative 3) for the lower
vault wastes, and Inclner~lon followed by fixation (Alternative 4) for the upper vault
. ,wa~e8. The treated wastes would be landfilled at an offSlte hazardous waste disposal
facility. This combination of atternatives will be referred to hereafter as the selected remedy
for the vault wastes.
The seven vauIt-was1e remedial action alternatives described above and the selected remedy
were evaluated under the nine evaluation criteria in the NCP 40 CFR 3OO.43O(e)(9) as set fo~h
in -Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA"
(EPA, October 1988), EPA Directive 9355.3-02 .Draft GuidanCe on Preparing Superfund Decislcn
, Documents: The Proposed Plan and Record of Decision,. and .Guidance on Prepanr;g
Superfund Decision DocumentS: The Proposed Plan, The Record of Decision, Explanation cf
Significant Differences, and the Record of Decision Amendment" (EPAl540/~/OO7, July 1989
23
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Interim Final}. These nine criteria can be further categorized .into three groups: threshold
criteria, primary balancing criteria,~d modifying criteria, as follows:
Threshold Criteria
Overall protection of human health and the environment. '
Compliance with applicable or relevant and appropriate requirements (AMRs)
Primary Balancing Criteria
. *.
*
*.
.*
*.
*
Long-term effectiveness'. "
Reduction of toxicity, mobility or volume through' treatment
Short-term effectiveness .
Implementability
Cost.
*
Modifvina Criteria
" *
*
Community Acceptance'
State Acceptance
. .
'These evaluation criteria; which measure the overall feasibility and acceptability of the remedy I
relate directly to requirements in Section 121 of CERCLA, 42 U.S.C. Section 9621. . Threshold
. ,criteria must be satisfied in order for a remedy to be eligible for selection. Primary balancing
criteria are used to weigh major trade-offs between alternatives. State and community
acceptance are modifying criteria formally taken into account after public cOmment is received
on the Proposed Plan. The evaluations are as follows: " .
Overall Protection of Human Health and the EnvIronment. A primary' requirement of
CERCLA is that the' $elected . remedial action be protective 01 human health and the
environment. A remedy is. protective if it reduces current and potential risks to acceptable
levels under the established risk range posed by each' exposure pathway at the Site.
. .
. '
If offS'rte landfill disposal is implemented, Alternatives 4 and 5 and the selected remedy would
provide protection of human health and the environment by'eliminating, reducing, or,controlling
risk through treatment. engineering controls, or institutional controls. Alternatives 4 and 5 would
be slightly more protective than the selected remedy since the minor amount of organic
. contamination In the lower vault wastes would also be destroyed during implementation of
these alternallV88. While there are risks associated with arsenic volatilization during the
incineration or vttrtftcatIon steps of Alternatives 4 and 5 and the selected remedy, these risks
would. be reduced to acceptable levels through the use 01 specialized air pollution control
equipment Alternative 3 with offSlte landfill disposal would be someWhat less protective than
the selected remedy since the organic contamination in the upper vault wastes would not be
. destroyed. Alternative 7 would be less protective of hum'" health and the environment than
the selected remedy since the wastes would not be treated to destroy the organic contaminants
in the upper vault wastes and immobilize the arsenic in both the upper and lower vault wastes
prior to offSite landfill disposal.
24
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Alternatives 2 and 6 would be less protective of human health and the environment than the
selected remedy since the wastes would not be treated to destroy the organic contaminants
in the upper vault wastes and immobilize the arsenic. in both the upper and lower vault wastes
prior to onsite landfill disposal. The alternatives that include onsite landfilling (Alternatives 2 and
6, and the onsite landfill options for Alternatives 3, 4, and 5) would be less protective of human
health and the environment than the selected remedy because of the potential of landfill failure
from sinkhole formation or other causes. Onsite landfill failure could result in a substantial
release of contaminants to groundwater.
The "no action" alternative is not protective of human health and the environment; therefore,it
is not considered further in this analysis as an option for the vault wastes.
Compliance with Applicable or Relevant and Appropriate Requirements. Under ~121 (d) of
CERCLA. 42 U.S.C. S 9621 (d), and EPA guidance, remedial actions at CERCLA Sites must
attain legally applicable or relevant and appropriate Federal and state environmental standards,
requirements, criteria and limitations (which are collectively referred to as "ARARs"). Applicable
requirements are those substantive environmental protection standards, requirements, criteria.
or limitations promulgated under Federal or state law that specifically address hazardous
material found at the Site, the remedial action to be implemented at the Site, the location of the
Site, or other circumstances at the Site. Relevant and appropriate requirements are those
substantive environmental protection standards, requirements, criteria or limitations which, while
not applicable to the hazardous materials at the Site, the remediSJ action, the Site location. or
other circumstances, nevertheless address problems or situations sufficiently similar to tti.ose
encountered at the Site that their use is well suited to that Site.
The ARARs and nonpromulgated advisories and guidances issued by Federal, State, arid local
governments ("To-Be-Considered" material) for the vault remedial action are discussed below.
Alternatives 3; 4, and 5 and the selected remedy would meet the applicable or relevant and
appropriate requirements (ARARs) of Federal and State laws if the treated wastes are landfilled
. offSite~ Pennsylvania law does not allow construction of a hazardous waste landfill immediately
above carbonate bedrock. Thus, the alternatives that include onsite landfilling (Alternatives 2
and 6, and the onsite landfill optigns for Alternatives 3, 4, and 5) would not comply with this
ARAR. An ARAR waiver would be required to implement these alternatives. Alternatives 3.4,
and 5 and the selected remedy would be expected to comply with the RCRA land disposal
restriction standards for the vault wastes (40 CFR Part 268). Alternative 7 would not comply
with RCRA land disposal restrictions; an ARAR waiver would be required to implement this
alternative. CERCLA establishes a preference for alternatives that incorporate treatment:
Alternatives 2. 8, and 7 do not conform with this preference.
Long-term Effectfyenesa and Permanence. The long-term effectiveness and permanence
criterion addresses the long-term protection of human health and the environment once
remedial action cleanup goals have been achieved, and focuses on residual risk that will rema!n
after completion of the remedial action.
25
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. The selected remedy would reduce the hazards posed by the vault wastes by destroying the
organic compounds present In the upper vault wastes and fixating the wastes. The long-term
risk of exposure to the treated wastes at the Whitmoyer Laboratories Site would be eliminated
by placing the tr_ed wastes in an offSite landfill. .
. With offSlte landfill disposal, Alternatives 4 and 5 would be silghUY more effective ir, the lo~g
term and permanent than the sel$Cted remedy since the minor amount of organic contamination
in the lower vault wastes would also be destroyed. Alternative 3 with offSite landfill disposal
would be slightly. less protective than the selected remedy since the upper vault waste organic
contamination would not be destroyed.. .
Alternatives 2 and. 6 and the onsite landfill options of Alternatives 3, 4, and 5 would be less-
'effective in the long-term because of the potential for. landfill failure. If deed restrictions are not
effective, direct exposure to the wastes in the Mure could result from construction activities.
. . .
Alternatives 2, 6, and 7 do not include treatment of the vault's arsenic contamination to a less
mobile state; Also, organic contaminants are not destroyed or immobilized under these
alternatives. Thus, these alternatives are. significantly less effective in the long term and less
. permanent. . .
Reduction of Toxicity, Mobility, or Volume of the Contaminants. Through Treatment. This
evaluation criterion addresses the degree to which a technology or remedial alternative reduces
toxicity, mobility, or volume of hazardous substances. Section 121 (b) of CERCLA, 42 U.S.C.
. 59621 (b), establishes a preference for remedial. actions that permanently. and significantly
. reduce the toxicity, mobility, or volume of hazardous substances over remedial actions which
'. will not result in such. reduction. .. .
. Alternatives 3, 4, and 5 and the selected remedy would treat the wastes to reduce toxicity.
mobility,. or volume. The seleCted remedy would eliminate the toxicity of the organic
contaminants in the upper vault wastes by thermal destruction, and would reduce the mobility
of the arsenic in the wastes by fixation. Alternative 3 reduces the mobility of the organic and.
. arsenic contaminants by microencapsulating the upper vault wastes and, fixating the lower vault
wastes. Alternatives 4 and 5 would eliminate the toxicity of the organic contaminants in the
'wastes by thermal destruction,' and would reduce the mobility of arsenic by fixation in a cement
matrix for Alternative 4 and encapsulation in a. glass matrix for Alternative 5. .
Alternatives 2. 8, and 7 achieve no reduction in toxicity, mobility, or volume. Disposal without
treatment is the least preferred option' under CERCLA.
Short-term ErrectIv--. Short-term effectiveness addresses the period of time needed to
achieve protection of human health and the environment and any adverse impacts that may be
posed during the construction and operation period until cteanup goals are achieved.
26
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The selected remedy could be implemented within an estimated 36 months from the date of
this Record of Decision. All other alternatives would require an equal length of time, except
Alternative 2. which would require 24 months for implementation; Alternative 6, which would
require 18 months for implementation; and Alternative 7, which would require 6 to 9 months for
implementation.
There is a'potential risk associated with arsenic volatilization, under Alternatives 4 and 5 and
the selected remedy. This risk would be reduced to acceptable levels by the use of specialized
air pollution control equipment. Under the selected'remedy, Alternative 7, and the off Site landfill
disposal options of Alternatives 3, 4, and 5, there is some minor, short-term risk of exposure
to the community during transportation of the treated wastes offSite. Only minimal, short-term
risks are associated with Alternatives 2 and 6 and the onsite landfill disposal option of
Alternative 3, if I?roper adherence to worker safety procedures occurs.
Implementabllfty. The implementability criterion addresses the technical and administrative
feasibility of a remedial alternative, including the availability of materials and services needed
to implement the alternative.
The various alternatives have few associated administrative difficulties that could delay
implementation. Permits would be required for the off Site disposal of treated or untreated
wastes. To confirm the suitability of the technology, treatability studies would be required prior
to implementation for Alternatives 3 and 5. For Alternatives 3, 4, and 5, and the selected
remedy, treatment equipment and skilled workers are available but limited. The technology.
equipment, and specialists required to implement Alternatives 2, 6, and 7 would be readily
available. Since offSite disposal without treatment (Alternative 7) would not comply with RCRA
land disposal restrictions (40 CFR Part 268), off Site landfill capacity may be unavailable. For
all of the alternatives, monitoring of air and water during implementation would be required.
For each alternative but Altern'atives 2, 6, and 7, monitoring of the treated wastes would also
be required. Long-term monitoring of landfill leachate and leak detection zones would be
required for Alternatives 2 and 6, and the onsite landfill options of Alternatives 3. 4, and 5.
, -
As microencapsulation (a component of Alternative 3) is a relatively new technology. limited
data are available on the effectiveness of this process in immobilizing the arsenic and organic
contaminants present in the upper vault wastes. Thus, microencapsulation of the upper vault
wastes is less reliable than the other treatment-based alternatives of. incineration followed by
fixation, and vitrification.'
Cost. CERCLA requires selection of a cost-effective remedy (not merely the lowest cost) that
protects human health and the environment and meets the other requirements of the statute.
Project costs Include all construction and O&M costs incurred over the life of the project. An
analysis of the present-worth cost for each alternative described in this Record of Decision has
been completed. These costs are discussed in the alternative descriptions and below.
The present-worth cost of the selected remedy is $18,400,000. The lowest-cost alternative is
Alternative 2 at $1,379,000. The highest cost alternative is Alternative 5 with offSite disposal.
at $58,000,000. The other FS alternative costs are presented in the alternative description
sections. The former owners' proposals, Alternatives 6 and 7, do not incfude a cost estimate.
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Costs for AlternatIves 6 and 7 are likely to be slightly higher than the estimated costs for
Alternative 2.
State Acceptance. The Commonwealth 'of Pennsylvania has not yet concurred in the selected
remedy. .
Community Acceptance. A public meeting on the Proposed Plan was held April 24, 1990 in
Lebanon County, Pennsylvania. Comments received from the public during the comment
period are referenced in the Responsiveness Summary attached to this Record of Decision.
B.
LAGOON WASTES
Alternatives 1 through 6 for the lagoon wastes are numbered to correspond with the numbers.
. in the FS Report. Alternative 7 is the alternative presented by the former Site owners. The
. alternatives are the f~lIowing: .
*.
*
*
Alternative 1: No Action
Alternative 2: Bulk Excavation/Landfill
Alternative 3: Bulk Excavation/Fixation/Landfill .
Alternative 4: Bulk Excavation/lncineration/Fixation/Landfill
Alternative 5: . In-situ Vitrification
Alternative 6: Capping . . ....
Alternative 7: On-5ite Enhanced Solids Containment System
*
*
*
*
1.
. Alternative 1: NO ACTION
Under the Superfund program, the -no action- alternative is req~ired to 'be evaluated at every
Site to establish a baseline for comparison with the other alternatives. Under this alternative,
EPA would take no actions other than annual groundwater monitoring around the lagoon Sites.
and performing reviews every 5 years. There are no ARARs associated with this alternative
Alternative 1 would not comply with the CERCLA preference for a remedy that employs
. treatment to reduce toxicity, mobility, or volume as a principal element. While no capital costs'
would be incurred under this alternative, annual operation & maintenance (O&M) costs are
estimated to be $7,100. This alternative has a present-worth cost of $109,000, and can be
implemented immediately. .. .
2.
Alternative 2: BULK EXCAVATION/LANDFILL
All 24,000 CYof lagoon wastes (containing greater than 1% arsenic) would be excavated ar.d
placed in either a new onsite landfill or in existing off Site landfill(s). The excavated area wo.~!d
be backfilled with soil and regraded. The petroleum products pipeline and pump statlcr.
passing through the lagoon area may have to be abandoned or relocated during excavation
The onsite landfill would be designed to meet or exceed all RCRA landfill standards (40 C F H
Part 264, Subpart N), which have been determined to be,relevant and appropriate for the onSl:e
landfill option~ RCRA standards are not applicable to the onsite landfill 'option of Alternative 2
since the wastes are being consolidated within the same area of contamination. For the onsl:e
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landfill option, the landfill liner base would be designed to minimize threats posed by sinkhole
collapse. Deed restrictions prohibiting Mure uses would be placed on the landfill area. Since
the wastes would remain onsite, long-term O&M would be con~ucted to monitor the
groundwater around the landfill and to ensure the integrity of the cap in accordance with 40
CFR 264.117, and 5-year reviews would be conducted. The onsite landfill option of Alternative
2 would not comply with the Pennsylvania hazardous waste facility siting criteria in Title 25,
Chapter 75.425, which prohibit the construction of a hazardous waste landfill over limestone
or carbonate formations. These criteria have been determined to be relevant and appropriate.
. RCRA land disposal restrictions (40 CFR Part 268) were not determined to be applicable for
the lagoon wastes because placement is not occurring. EPA is undertaking a RCRA land
disposal restriction rulemaking that will specifically apply to soil and debris. (The lagoon wastes
will be primarily a sludge/soil mixture when excavated.) Until that rulemaki.ng is completed, the
CERCLA program will not consider RCRA land disposal restrictions to be relevant and
appropriate to soil and debris that do not contain RCRA-regulated wastes.
Under the offSite landfill option, the lagoon wastes would be separated into two separate
fractions. One fraction would consist of lagoon wastes which would be demonstrated to be
nonhazardous under RCRA. This fraction would be disposed in an industrial (solid) waste.
landfilL The second fraction would be managed as hazardous waste. RCRA Subtitle C would
be applicable to the off Site disposal of the wastes being managed as hazardous wastes since
placement would be occurring. The offSite landfill option would comply with all ARARs if the
lagoon wastes are landfilled by May 8, 1992. (There is a RCRA land disposal restriction
capacity extension until this date - see 55 FR 22520.) tf the lagoon wastes are directly
landfilled off Site after this date, this action would not comply with the RCRA land disposal
restrictions for characteristic wastes since some or all of the wastes would be expected to have
TCLP and EP Toxicity . leachate concentrations above 5.0 mg/l arsenic.
Both the onsite and off Site landfill options will comply with the relevant and appropriate NAAQS.
Alternative 2 would not comply with the CERCLA preference for a remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
costs of this alternative are $4,890,000 and $18,440,000, for theonsite and off Site landfill
options, respectively. Annual O&M costs for the onsite landfill option are estimated to be
$22,900. There are no annual O&M costs for the offSite landfill disposal option. The estimated
present-worth costs of this alternative are $5,375,000 and $18,440,000 for the onsite~ and off Site
landfill options, respectively. The estimated time to implement this alternative is approximately
24 months. .
3.
Alternative 3: BULK EXCA VA TlON/FIXA TlON/LANDFILL
The major features of this alternative include excavation of the 24,000 cubic yards of lagoon
wastes (contaJnJng greater than 1 % arsenic), segregation of th~ wastes into nonhazardous and
hazardous fractions, onsite iron-based fixation of the hazardous fraction, and landfilling of the
treated hazardous wastes and untreated nonhazardous wastes either onsite or offSite. The
lagoon waste excavation would be backfilled with soil and regraded. The petroleum products
.pipeline and pump station passing. through the lagoon area may have to be abandoned or
relocated during excavation. .
29
'-
/
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Following excavation, the lagoon wastes would be separated into hazardous and nonhazardous
fractions. The nonhazardous fraction would consist of lagoon wastes which would be
demonstrated to be nonhazardous in accordance with 40 CFR Part 261. This fraction would be
" disposed directly In an industrial (solid) waste landfill. The second fraction would be managed
. as hazardous waste. .
..
The lagoon wastes being managed as hazardous wastes would be fixatedonsite in accordance
with RCRA standards for miscellaneous treatment units (40' CFR Part 264, Subpart X). The
. fixation unit would be mobilized, operated, and closed according to the requirements of 40 CFR
264.600, et sea. A treatability study would be conducted prior to full-scale implementation to
validate the proposed treatment. The specific operating parameters for the fixation process
would be determined in the Remedial Design phase through the treatability study, engineering
design and analysis, and the competitive bidding process. Because some of the lagoon wastes
exhibit the RCRA characteristic of arsenic toxicity and Alternative 3 constitutes treatment, RCRA
Subtitle C is applicable. The RCRA land disposal restriction treatment standard for these
wastes is 5.0 mg/l arsenic, as measured by the EP Toxicity Test or TCL? (A national capacity
extension for these wastes is in. effect until May 8, 1992.) The fixation process should achieve
this treatment standard. The treated lagoon wastes should no longer be RCRA characteristic
wastes; they would be considered residual wastes under Pennsylvania law (25 PA Code,
Chapter 75). The untreated nonhazardous wastes would also be considered to be residual
wastes. .
, The treated' wastes and untreated nonhazardous wastes would be placed in either a new onsite
landfill or an existing offSite landfill. Because of the treatment step, placement is occurring.
If the waStes were landfilled onsite; the landfill would be designed in accordance with RCRA
landfill standards (40 CFR Part 264, Subpart N). These standards have been determined to be
relevant and appropriate for the onsite landfill option because of the elevated arsenic
concentration of the treated and untreated wastes and the potential for mismanagement. For
. the onsite landfill option, the landfill base would be designed to minimize the threat of sinkhole
collapse~ Deed restrictions prohibiting future uses would be placed on the landfill area. In
addition, long-term O&M would be conducted to monitor the groundwater around the landfill
. and to ensure the integrity of the cap, in accordance with the relevant and appropriate 40 CFR
264.117, and S-year reviews would be conducted. The onsite landfill option would not comply
with the proposed Pennsylvania residual waste landfill siting criteria,' which prohibit the
construction of a residual waste landfill over sinkhole-prone limestone or carbonate formations.
These criteria are 'o-be-<:onsldered8 material (TBC). For the offSite disposal option, industrial
(solid) waste management regulations would be applicable since all of the wastes being
disposed would be nonhazardous. These ARARs ~hould ~ met.
Alternative 3 would. cOmply with the CERCLA preference for a remedy that employs treatment
to reduce toxicity, mobility, or volume as a principal element. The estimated capital costs of
this alternative are $10,500,000 and $22,900,000 for the o'nsite and offSite landfill options,
respectively. Annual O&M costs for the onsite landfill option are estimated to be $35,200
There are no annual O&M costs for the offSite landfill disposal option. The estimated present-
worth costs of this alternative are $11,100,000 and $22,900,000 for the onsite and off Site landfill
options, respectively. The estimated time to implement this alternative is approximately 36
months.
30
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4.
Alternative 4: BULK EXCAVATlON/INCINERATlONIFIXATlON/LANDFILl
The major features of this alternative include excavation of the 24,000 cubic yards 01 lagoon
wastes containing greater than 1 % arsenic, segregation of the wastes into nonhazardous and
hazardous fractions, onsite incineration of the hazardous fraction to destroy the organics
present and to leave the arsenic in a form more amenable to cement/pozzolan-based fixation,
fixation of the incineration residuals, and landfilling of the treated and untreated nonhazardous
wastes either onsite or offSite. . The lagoon waste excavation would be backfilled with soil and
regraded. . The petroleum products pipeline and pump station passing through the lagoon
area may have to be abandoned or relocated during excavation.
Following excavation, the lagoon wastes would be separated into hazardous and nonhazardous
fractions. The nonhazardous fraction would consist of lagoon wastes which 'would be
demonstrated to be nonhazardous in accordance with 40 CFR Part 261. This fraction would
, be disposed directly in an industrial (solid) waste landfill. The second fraction would be .
managed as hazardous waste.
. The lagoon wastes being managed as hazardous wastes would be incinerated onsite in
accordance with RCRA Part 264, Subpart 0 standards. The specific type of incineration
process ~, rotary kiln) would be determined in the Remedial Design phase through
engineering design and analysis and the competitive bidding process. The incineration unit
would be mobilized, operated, and closed according to the requirements of RCRA Subpart 0,
40 CFR 264.340 !1 sea. These requirements are applicable to the lagoon wastes beca~se
some of the wastes exhibit the arsenic toxicity characteristic and treatment is occurr,ing.
Specific operating practices necessary to meet the performance objectives, including a 99.99
percent destruction ~d removal efficiency (ORE) of stack emissions as required by Subpart 0
. of RCRA, would be determined through a trial burn at the Site after the installation of; the
incineration unit. Specialized air pollution control equipment would be applied during .the.
incineration step to capture contaminants in the exhaust air and thus ensure compliance with
the relevant and appropriate NAAQS (40 CFR Part SO) and NESHAPS (40 CFR Part 61, Subpart
N). The wastes would be incinerated in the presence of the cement/pozzolan fixative agent(s).
The cement/pozzolan would later be hydrated during the fixation step.
The incineration residuals would be fixated onsite using a cementlpozzolan-based process or
another similar fixation process that provides equivalent protection, in accordance with the
requirements of RCRA standards for miscellaneous treatment units (40 CFR Part 264, Subpart
X). Th~ exact fixation technique employed would be determined in the Remedial Design phase
through engineering design and analysis and the competitive bidding process. The fixation unit
would be mobilized, operated, and closed according. to the requirements of 40 CFR 264.600,
et sea. '
A treatability study was conducted on the lagoon wastes during the RVFS using incineration
followed by cement/lime-based fixation methods. Based on the treatability study results, the
arsenic mobility of the wastes should be reduced by approximately 82 percent. Thus,
Alternative 4 would be expected to comply with the applicable 5.0 mg/l arsenic land disposal
restriction treatment standard for the lagoon wastes. RCRA land dispo~ restrictions (40 CFR
Part 268) are applicable to the lagoon wastes because placement is occurring. (A national
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capacity extension for these wastes is in effect until May 8, 1992.) The treated lagoon wastes
should no longer 'be RCRA characteristic wastes; they would be considered residual wastes
under Pennsylvania law. The untreated nonhazardous wastes would also be considered
residual wast... '
. . . ,
After treatment,' the' treated wastes and the untreated nonhazardous wastes would be 'placed
in, either a new onsite landfill or an existingoffSite landfill. Because of the treatment step, '
placement is occurring. If the wastes were landfilled onsite, the landfill would be designed in
accordance with RCRA landfill standards (40 CFR Part 264, Subpart N). These standards have
I
been determined to be relevant and appropriate for the' onsite landfill option because of the,
elevated arsenic concentration of,the lagoon wastes and the potential for mismanagement.
, For the onsite landfill option, the landfill base would be designed to minimize the threat, of
!',' sinkhole collapse. 'Deed restrictions prohibiting Mure uses would be placed on the landfill '
area. In addition, long-term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity of the cap in accordance with 40 CFR 264.117 .Post closure
care and use of property", and 5-year reviews would be conducted. The onsite landfill option
would not comply with the proposed Pennsylvania residual waste landfill siting criteria" which
prohibit the construction of a residual waste landfill over sinkhole-prone limestone or carbonate
formations. These criteria are TeC material. 'For the offSite disposal option, industrial (solid)
, waste management regulations would be applicable since the treated and ,untreated wastes
, would be nonhazardous. These ARARs should be met. ' ' '
" ,
, "
, ',Alternative 4 would comply with the CERCLA preference for a remedy that employs,treatment'
',to reduce toxicity, mobility, or volume as a principal' elerhent. The estimated capital co'sts of
this alternative are $60,570,000 and $80,700,000 for the onsite and offSite landfill options,
respectively. Annual O&M costs, for the onsite landfill, option are estimated to be $40,200,
There are no annual O&M Costs for the offSite landfill disposal option. The ,estimated present-
worth costs of this alternative are $60,630,000 and S80,7oo,000 for the onsiteand off Site landfill
options, respectively. The estimated time to impleme"t this alternative is approximately 36
months. ' . ,
5.','
Alternative 5: IN-51TU VITRIFICATION
Under Alternative 5, the approximately 7,000 CY of lagoon wastes (containing greater than 1 %
arsenic) located in the western lagoon area would be excavated and mixed with the,'
approximately 17,000 CY of lagoOn wastes in the eastern lagoon area. The excavation would
, be backfilled with soil and regraded. The petroleum products pipeline and pump station
. passing through the lagoon area may have to be abandoned or relocated during excavation,
The mixture would then be heated in place using electricity passing through electrodes until
the mixture formed 'a pool of molten glass. The minor organic contaminants ,.would be
destroyed during heating, while the metal contaminants would become trapped in the glass
duting the, subsequent cooling step. The vitrification would occur in accordance with RCRA
,standards for miscellaneous treatment units (40 CFR Part 264, Subpart X). 'These standards
have been determined to be relevant and appropriate to the vitrification step because
placement is not occurring prior to or during the treatment step. The vitrification unit would be
mobilized, operated, and closed according to the requirements 0140 CFR 264.600, et seQ, A
treatability study would be conducted prior to full-scale implementation to validate the proposed
32,
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. treatment The specific operating parameters 01 the vitrification unit would be determined in the
. RemedlaJ Design phase through the treatability study, engineering design and analysis. and the
competitive bidding process. Specialized air pollution control equipment would be applied
during the vltrtftcation step to capture contaminants in the exhaust air and thus ensure
compliance with the relevant and appropriate NMQS (40 CFR Part SO) and NESHAPS (40 CFR
Part 61, Subpart N). Residuals from the air pollution control system would be vitrified in
subsequent batches.
The treated wastes would either be placed in an existing oftSite landfill, or covered with a cap
designed to meet the RCRA landfill closure requirements in 40 CFR 264.310. If the treated
wastes were capped in place, a groundwater removal (drainage) system would be placed
around the wastes to prevent groundwater contact with them. Also, deed restrictions would
be placed on the disposal area and 5-year reviews would be conducted. Consistent with the
. relevant and appropriate requirements 01 40 CFR 264.117, long-term O&M would be conducted
to monitor the groundwater around the treated wastes and to ensure the integrity 01 the cap.
For the off Site disposal option, placement would occur during the disposal step. The arsenic
mobility 01 the wastes would be reduced by approximately 90% during treatment. Thus, the
vitrified wastes should be nonhazardous. (Alternative 5 would be expected to comply with the
applicable 5.0 mg/J arsenic land disposal restriction treatment standard for the lagoon wastes.)
Therefore, industrial (solid) waste management regulations would be applicable. These ARARs
should be met .
Alternative 5 would comply with the CERCLA preference for' a remedy that employs treatment
to reduce toxicity, mobility, or volume as a principal element. The estimated capital costs of
this alternative are $15,900,000 and $24,200,000 for the onsite disposal and oftSite lane/iil
options, respectively. Annual O&M costs for the onsite disposal option are estimated to be
$28,100. There are no annual O&M costs for the offSite landfill option. The estimated present-
worth costs of this alternative. are $16,400,000 and $24,200,000 for the onsite disposal..and
oftSite landfill options, r~spectively. The estimated time to implement this alternative 15
approximately 36 months.
6.
Alternative 6: CAPPING
Under Alternative 6, the approximately 7,000 CY of lagoon wastes (containing greater than 1::irO
arsenic) located in the western lagoon area would be excavated and placed on top of tr.e
.approximately 17,000 CY 01 lagoon wastes in the eastern lagoon area. The excavation wO~ie
be backfilled with soil and regraded. The petroleum products pipeline and pump stat.c::
passing through 1M lagoon area may have to be abandoned or relocated during excavatlcn
The consolidated wastes would be covered with a cap designed to meet the relevant ar,d
appropriate RCRA landfill closure requirements in 40 CFR 264.310. A groundwater remo'. ai
(drainage) system would be placed around the wastes to prevent groundwater contact with
them. Deed restrictions would be placed on the disposal area, and 5-year reviews would be
conducted. Consistent with the relevant and appropriate requirements 01 40 CFR 264' 1 7.
long-term O&M would be conducted to monitor the groundwater around the consolidated
wastes / and to ensure the integrity 01 the cap.
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';0
Alternative 6 WOUld not comply with the CERCLA preference for a remedy that employs
,treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
cost of this 81t8mat1ve is $524,000. , AnnualO&M' costS are estimated to be $31,400. 'The
estimated present-worthcost of this altemative is $2,000,000. The estimated time to implement'
, this ,altemative Is approximately 1 a months. ' , ,
7.
Alternative 7: ON-Site ENHANCED SOLIDS CONTAINMENT SYSTEM
,Under the former owners' proposal (Altemative 7)"the lagoon wastes containing greater than
2% arsenic would be excavated and placed in a new landfill constructed onsite' and the
excavation area would be backfilled with soils excavated' during construction of the landfill. The
landfill would be d&signed to meet or exceed RCRA'iandfili standards (40 CFR Part 264,
, Subpart N), which have been determined to be relevant and appropriate. RCRA standards are
not applicable to Altemative 7 since the wastes are being consolidated within the same ' area
of' contamination. To provide protection against sinkhole collapse and subsequent landfill
failure, a foundation preparation program would be implemented prior to landfill construction.
The program would consist of (1) geophysical surveying of the landfill area; (2) drilling
, exploration borings on a select&d grid pattem and at any geophysical anomalies; (3) pressure
, grouting any voids discovered in the exploration borings; (4) removing any soil above bedrock
and any easily removable rock and (5) placing aggregate in, bedrock joint openings and above
the bedrock surface. Deed restrictions prohibiting Mure uses would be placed on' the landfill
, ' area. Since the wastes remain onsite" 5-year. reviews would be conducted. Also, ' . an '
. unspecified maintenance and monitoring program would ~ implemented. Altemative 7 would
not' comply with the Pennsylvania, hazardous waste facility' siting criteria h, Title 25, Chapter
75.425, which' prohibit the construction of a 'hazardous waste, landfill oyer lim&stone or
carbonate formations. These criteria t1ave been determined to be relevant and appropriate.
Alternative 7 would also not comply with the CERCLA preference for a remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. Cost estimates were
not provided in the former owners' proposal. Costs are ,likely to be lower than the estimated
costs for Altemative 2 since only lagoon wastes 'containing greater than 2% arsenic are being
addressed. Alternative 2 (and the other altemative~) address all 'lagoon materials containing
greater than 1 % arsenic. The estimated time to implement this altemative is approximately 1 8 '
months~ ", ,,',,"
, 8~
COMPARAtivE ANALYSIS OF ALTERNATIVES - LAGOON WASTES
EPA'. selected remedy tOr the lagoon waste Is excavation of the approximately' 24,000
, CY or mat""'" pr_nt In the lagoons having an arsenic content greater than 10,000
mg/kg, fixation of those lagoon wastes exhibiting the RCAA arsenic toxicity characteristic'
using an lrorrb..8d or other .Imltla, fIXation proc- that provides equivalent protection,
'and offalte dI8po881 of all lagoon wastes In accordance with all applicable regulations.
The seven lagoon waste remedial action alternatives described above were evaluated under the
nine evaluation criteria in the NCP. The evaluations are as follows:
Overall Protection. The offSite disposal. options of Altematives 3, 4, and 5 would provide
protection of human health and, the environment by eliminating,' r~ucirig, or controlling risk
34
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through treatment, engineering controls, or Institutional controls. Alternatives 4 and 5 would
be slighUy more protective than Alternative 3 since the minor amounts of organics in the lagoon
wastes being managed as hazardous wastes would be destroyed during implementation of
these alternatives. Although there are risks associated with arsenic volatilization during the
incineration or vitrification steps of Alternatives 4 and 5. these risks would be managed through
the use of specialized air pollution control equipment.
Alternatives 2, 6, and 7 would be less protective of human health and the environment than
Alternatives 3, 4, and 5 since the hazardous lagoon wastes would not be treated to immobilize
the arsenic contamination. The alternatives that include onsite containment of the lagoon wastes
(Alternatives 6 and 7, the onsite landfill options for Alternatives 2, 3, and 4, and the in-place
capping option for Alternative 5) would be less protective of human health~d the environment
than the offSite disposal option of Alternatives 3, 4, and 5 because of the potential of
containment system failure from sinkhole formation or other causes. Containment system failure
could result in a substantial release of contaminants to groundwater.
The -no action- alternative is not protective of human health and the environment; therefore, it
is not considered further in this analysis as an option for the lagoon wastes.
Compliance with ARARs. The oftSite disposal options 01 Alternatives 3, 4, and 5 would meet
their respective ARARs. Pennsylvania law does not allow construction of a hazardous waste
landfill immediately above any carbonate bedrock (Title 25, Chapter 75.425). Thus, Alternative
7 and the onsite landfill option of Alternative 2 would not comply with this ARAR. The
proposed Pennsylvania residual waste landfill regulations do not allow construction of a resid,yal
waste landfill immediately above any sinkhole-prone carbonate bedrock. Thus, the onsite
landfill options of Alternatives 3 and 4 would not comply with this TeC. Alternatives 3, 4, and
5 would be expected to comply with applicable RCRA land disposal restriction standards. The
oftSite landfill option of Alternative 2 would not comply with the RCRA land disposal restric1i,on
standards if the lagoon wastes are not landfilled by May 8, 1992. (There is a RCRA land
disposal restriction capacity extension until this date - see 55 FR 22520.) EPA is currently
undertaking a RCRA land disposal restriction rulemaking that will specifically address soil and.
debris. This rulemaklng may change the status of the RCM land disposal restriction ARAR for
the lagoon wastes. Alternatives 2, 6. and 7 would not comply with the CERCLA preference
for treatment. .
Long-term Effectiveness and Permanence. The offSite disposal option of Alternative 3 would
reduce the hazards posed by the lagoon wastes by fixating the arsenic in the wastes being
managed as hazardous waste and disposing the treated wastes and untreated nonhazardous
wastes In an oftStte landfill.
The offSite disposal options for Alternatives 4 and 5 would be slightly more protective than the
Alternative 3 offSite disposal option since the minor organic contamination in the lagoon wastes
being managed as hazardous waste would be destroyed.
The alternatives that include onsite containment of the lagoon wastes (Alternatives 6 and 7. the
onsite landfill options for Alternatives 2, 3, and 4, and the in-place capping option for Alternative
5) would be less protective 01 human health and the environment than the offSite disposal
35
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-. . ~
, , "
.' ' options because of the potential for the containment system to fail from sinkhole formation or
other causes. The enslte containmerit system would require long-term maintenance, and
'portions of It might need to be replaced in the Mure. If de8drestrictions are not effective,
direct exposure to the wastes in the Mure could result from construction activities. .
Alternative 6 and the In-place capping option of Alternative 5" are 'less protective than the other
alternatives that include landfill disposal (Alternatives 2," 3,,4, and 7, and ,the off Site disposal
. option of Alternative 5) since the wastes would not be contained in a landfill.
-' -' .
Alternatives 2,: 6, and 7 do not provide for treatment of the mobile arsenic contamination in the
lagoon waste. '
,', "Reduction of Toxicity, Mobility, or Volume of the .ContamlnantsThrough Treatment.
, Alternatives 3,4, and 5 would treat the wastes being managed as hazardous waste to reduce
, toxicity, mobility, or volume. Alternative 3 would reduce the mobility of the arsenic in these'
" wastes by fixation with iron. Alternatives 4 and 5 would eliminate the toxicity of the organic
contaminants in these wastes by thermal destruction, and would reduce the mobility of arsenic
by fixation in, a cement matrix for Alternative 4 and encapsulation in a glass matrix for,
" Alternative 5.' , " , , ,
No reduction in toxicity, mobility, or voiume is realized for Alternatives 2, 6, and 7. Disposal
',without treatment is the leaSt preferred option under CERCLA. ' '
Short-term Effectlven....' Alternative 3, 4, and 5 could be implemented within an estimated"
'36 months from the date of this ROD. ,Alternative, 2 would require 24 months' for
implementation, and Alternatives 6 and 7 would require 18 months-,fo,r implementation. '
There is a potential risk associated with arsenic volatilization under Alternatives 4 and 5. ' This
. 'risk would be managed through'the use ot specialized air pollution control equipment. There
." is some minor, short-term risk of exposure to the community during transportation 01 the wastes.
: , offSite under the offSite landfill disposal options of Alternatives 2, 3, 4, and 5., If worker safety
procedures are properly fO,lIowed, only minimal, short-term risks are associated with Alternatives
,6 and 7' and the onsite landfill disposal options of Alternatives 2 and 3.
Implementabillty. The various alternatives have few associated administrative difficulties that
could delay implementation. Permits would be required for the offSite disposal of the treated
or untreated" wastes. . Treatability studies would be required prior to implementation of
Alternatives 3 8nd5, to confirm the suitability of the technology. For Alternatives 3, 4, and 5,
. treatment equipment and skilled workers would be available but limited. The technology I
, ': equipment, and specialists required to implement Alternatives 2, 6, and 7 would be readily
available.' For" of the alternatives, monitoring of air and water during implementation would
be required. For Alternatives 3, 4, and 5, monitoring of the treated wastes would also be
required. Long-term monitoring of landfill leachate and leak detection zones would be required
for Alternative 7 and" the onslte disposal options of Alternatives 2, 3, and 4.
CoSt.," The present-worth cost of the offSite disposal option of Alternative 3 for the lagoon
wastes is $22,900,000. The lowest-cost alternative is Alternative 2 (onsite landfill option), at
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$5,375,000. The highest cost alternative is Alternative 4 with offSite disposal, at $80,700,000.
The other FS'8It8matJve costs are presented in the alternative description sections. The former
owner's proposal, Alternative 7, does not include a cost estimate. Alternative 7 costs are likely
to be somewhat lower than the estimated costs for Alternative 2.
State Acceptance. The Commonwealth of Pennsylvania has not yet concurred in the selected
remedy.
. Community Acceptance. A public meeting on the Proposed Plan was held April 24 in
Lebanon County, Pennsylvania. Comments received from the public during the comment
period are referenced in the Responsiveness Summary attached to this Record 01 Decision.
. C.
MISCELLANEOUS PRODUCTS/ FEEDSTOCKS
Alternatives 1 through 5'for the miscellaneous products/feedstocks are numbered to correspond
with the alternative numbers in the FS Report. Alternative 6 is the alternative 'presented by the
former Site owners. The alternatives ~re the following:
*
Alternative 1: No Action
Alternative 2: Bulk Excavation/Landfill
Alternative 3: Bulk Excavation/Fixation/Landfill
. Alternative 4: Bulk Excavation/lncineration/Fixation/Landfill
Alternative 5: Bulk ExcavationNrtrification/Landfili
Alternative 6: On.site Enhanced Solids Containment System
H
*
*
*
*
*
1.
Alternative 1:. NO ACTION
The -no action- alternative is required under the Superfund program at every Site, to establish
a baseline for comparison with the other alternatives. Under this alternative, EPA would take
no actions other than performing reviews every 5 years. Since the miscellaneous
products/feedstocks were disposed of or abandoned after .1980, and some of the wastes exhibit
the RCRA arsenic toxicity characteristic, those wastes exhibiting the characteristic are hazardous
wastes and must be managed accordingly. -No action- does not comply with RCRA Subtitle
C. hazardous waste management regulations. Alternative 1 would also not comply with the
CERCLA preference for a remedy that employs treatment to reduce toxicity, mobility, or volume
as a principal element. While no capital costs would be incurred under this alternative, annual
O&M costs are estimated to be $7,100. This alternative has an estimated present-worth cost
of $109,000, and can be implemented immediately. .
2.
Alternative 2: BULK EXCAVATION/LANDFILL
The 101 CY 01 miscellaneous products/feedstocks would be excavated and segregated into
hazardous and nonhazardous wastes. The nonhazardous wastes would be disposed in an
offSite landfill legally able to accept these wastes. The hazardous wastes would be placed in
either a new onsite landfill or an existing offSite RCRA Subtitle C landfill. Because of the
relatively small volume 01 hazardous miscellaneous products/feedstocks, onsite disposal would
only occur if an onsite landfill is constructed for another one 01 the Site's waste streams. The
.37
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onsite or offSite hazardous waste landfill. would be designed to meet or exceed all RCRA landfill
standards (40 CFR Part 264, Subpart N);. which have been determined to be relevant and
appropriate for the onsite landfill option and applicable for the offSite landfill option. RCRA'
landfill standards are not applicable to the onsite landfill option of Alternative 2 since the wastes
, would be consolidated within the same. area 01 contamination. .
For the onsite landfill option the landfill liner base would be engineered to minimize the threats'
posed by sinkhole collapse. Deed restrictions prohibiting Mure uses would be placed on the
landfill area.. If the wastes were landfilled onsite long-term O&M wOlJld be conducted to monitor
the groundwater around the landfill and to ensure the integrity 01 the cap in accordance with
40 CFR 264.117, and 5-year reviews would be conducted. The onsite landfill option of
. Alternative 2 would not comply with the Pennsylvania hazardous waste facility siting' criteria in'
Title 25, Chapter .75.425, which prohibit ,the construction .01 a hazardous waste landfill over.
limestone or carbonate formations. These criteria have been determined to be relevant and
appropriate., RCRA land disposal restrictions (40 CFR Part 268) were not determined to. be '
applicable for the miscellaneous products/feedstocks because placement is not occurring.
RCRA'Subtitle C is applicable for the,hazardous miscellaneous products/feedstocks off Site
landfill option since placement would be occurring. The offSite landfill option would comply
.with RCRA land disposal restrictions (40 CFR: Part 268) if the hazardous miscellaneous
. products/feedstocks are laridfilled by May 8, 1992. . (There is a RCRA land disposal restriction
capacity extension until this date - see' 55FR22520.) If these wastes are directly landfilled
off Site after this date, this action would not comply with the'RCRA land disposal restrictions for
characteristic wastes. The offSite landfill option would comply with all other RCRA Subtitle,C
'ARARs;' '. .
. .
Both the onsite and offSite landfill options are intended to comply with the relevant and'
. appropriate NMQS (40 CFR Part SO). Alternative 2 would not comply with the CERCLA
preference for a remedy that employs treatment to reduce toxicity, mobility, or volume, as a
principal element. The estimated capital and present-worth costs of this alternative are $13,900
and $82,500, for the onsite and offSite landfill options, respectively. There are no annual O&M
costs for'the onsite and offSite landfill disposal options. (Estimated annual O&M costs for the
onsite landfill option are contained in the cost estimates for the other wastes that the
miscellaneous products/feedstocks would necessarily be disposed with.) The estimated time
t6 implement this alternative is approximately 24 months. . .
3;
. .
Alternative 3: BULK EXCAVATION/FIXATION/LANDFILL
The 101 CYoI miscellaneous products/feedstocks would be excavated and segregated' into .
. hazardous and nonhazardous wastes. The nonhazardo'us wastes would be disposed in an
offSite landfilllegaJly able to accept these wastes. The hazardous wastes would be fixated with
cement/pozzolan-based or other similar materials,either onsite or offSite. Following fixation
these wastes would be landfilled in either a new onsite landfill or an existing offSite landfiil
Because 'of the relatively small volume of hazardous miscellaneous products/feedstocks, onslte
. disposal would only occur if an onsite landfill is constructed for another one of the Site's waste
streams. . . . . . .
38'
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The hazardous miscellaneous products/feedstocks would be fixated in accordance with RCRA
standards for miscellaneous treatment units (40 CFR Part 264, Subpart X). Because of the
relatively smaavolu~e of hazardous miscellaneous products/feedstocks, onsite fixaijon of these
wastes. would onJy be implemented if onsite fixation is applied to one of the other Site waste
- streams. If onsite fixation occurs, the fixation unit would be mobilized, operated, and closed
according to the requirements of 40 CFR 264.600, et sea. The specific operating parameters
for the fixation process would be determined in the Remedial Design phase through engineering
design and analysis, and the competitive bidding process. Because Alternative 3 constitutes
treatment, RCRA Subtitle C is applicable. The RCRA land disposal restriction treatment
standard for the hazardous miscellaneous products/feedstocks is 5.0 mg/l arsenic, as measured
by the EP Toxicity Test or TCLP. (A national capacity extension for these wastes is in effect
until May 8; 1992.) The fixation process should achieve this treatment standard. Following-
treatment, the wastes should no longer be RCRA characteristic wastes; they would be
considered residual wastes under Pennsylvania law (25 PA Code, Chapter 75). The untreated
nonhazardous wastes would also be considered to be residual wastes.
ced in either a new onsite landfill or an existing off Site landfill. Because of the treatment step,
placement is occurring. Onsite landfilling would only occur if a landfill is constructed onsite 10r
another one ,of the Site's waste streams. If the wastes were landfilled onsite, the landfill would
be designed in accordance with RCRA landfill stand~rds (40 CFR Part.264, Subpart N). These
standards have been determined to be relevant and appropriate for the onsite landfill option.
For the onsite landfill option, the landfill base would be designed to minimize the threat of
sinkhole collapse. Deed restrictions prohibiting Mure uses would be placed on t~~ landfill
area. In addition, long~term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity of the cap, in accordance with the relevant and appropriate
40 CFR 264.117, and 5-year reviews would be conducted. The onsite landfill option would not
comply with the proposed Pennsylvania residual waste landfill siting criteria, which prohibit the
construction of a residual waste landfill over sinkhole-prone limestone or carbonate formations.
These criteria are TeC material. For the offSite disposal option, industrial (solid) waste
management regulations would be applicable since the treated wastes would be nonhazardous.
These ARARs should. be met. .
Alternative 3 would comply with the CERCLA preference for a remedy that employs treatment
to reduce toxicity,' mobility, or volume as a principal element. The estimated capital and
present-worth costs of this alternative are $50,900 and $271 ,000, for the onsite and off Site
landfill options, respectively. There are no annual O&M costs for the onsite and off Site landfill
. disposal options. (Estimated annual O&M costs for the onsite landfill option are contained in
the cost estimates for the other wastes that the treated miscellaneous products/feedstocks
would necessarily be disposed with.) The estimated time to implement this alternative is-
approximately 36 months. -
4.
Alternative 4: BULK EXCAVATION/INCINERATION/FIXATION/LANDFILL
r.
The 101 CY' of miscellaneous products/feedstocks would be excavated and segregated into
hazardous and nonhazardous wastes. The nonhazardous wastes would be -disposed in an
offSite landfill legally able to accept these wastes. The hazardous wastes would be incinerated
39
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onsite or offSite, with the Incinerator residuals being fixated with cement/pozzolan-based or
other similar materials. ,Because of the relatively small volume of hazardous miscellaneous
products/feed8tocks, onsite incineration of the wastes would 'only be 'implemented if onsite
incineration is Implemented for the vault or lagoon wastes. After treatment, the treated wastes
would be placed in either a new onsite landfill or an existing offSite landfill. Because ofthe
relatively small volume of hazardous miscellaneous products/feedstocks, on site disposal would
only occur if an onsite landfill is constructed 10r another one of the Site's waste streams.
The miscellaneous, products/feedstocks' would be incinerated to destroy, the organic
,contaminants and to leave the metals in a form amenable to cement fixation, in accordance
with RCRA 40 CFR Part 264, Subpart 0 standards. The specific type of incineration process
,,(!A. rotary kiln) would be determined in the Remedial Design phase through engineering
design and analysis and the competitive bidding process. "onsite incineration occurs, the
incineration unit would be mobilized, operated, and closed according to the requirements of
" RCRA Subpart 0, 40 CFR 264.340, et sea. These requirements are' applicable because the
,hazardous miscellaneous products/feedstocks are hazardous wastes. Specific operating
" practices necessary to meet the performance objectives, including a 99.99 percent destruction
and removal efficiency (DRE) of stack emissions as required by Subpart 0 01 RCRA, would be
determined through a trial burn at the Site after the installation of the incineration,' unit.
Specialized air pollution control equipment would be applied during the incineration step' to
.; ,capture contaminants in the exhaust air and thus ensur, compliance with the relevant and
,appropriate NMOS (40 CFR Part SO) and NESHA,PS (40 CFR Part 61, Subpart N).
,', The hazardous miscellaneous products/feedstocks would be incinerated in the presence of the
cement/pozzolan-based fixative agent(s): A treatability study 10r the vault wastes indicat~dthat
cement/lime presence inhibited arsenic volatilization during the thermal treatment step. The
, cement/pozzolan would later be hydrated, during the fixation step. '" '
. , . . .
'./ . ~
The incineration residuals would be fixated using-cement/pozzolan-based or other similar
, methods, in accordance with the requirements 01 RCRA standards for miscellaneous treatment
'units (40 CFR Part 264, Subpart X). The exact fixation technique employed would be
determined in the Remedial Design phase through engineering design and analysis and the
competitive bidding process. "onsite treatment occurs, both the incineration and fixation wou Id
take place onsite using mobile equipment. The ohsite fixation unit would be mobilized,
operated, and closed according to the requirements 01 40 CFR 264.600, et sea." '
, '
" ,
, Alternative 4 would be expected to comply with the applicable 5.0 mg/1 arsenic land disposal
restriction treatment standard for arsenic toxicity characteristic wastes. RCRA land disposal
restrictions (40 CFRPart 268) are applicable to the wastes because placement is 'occurring,
(A national ~ extension 10r these wastes is in effect until May 8, 1992.) Following
treatment, the wastes should no longer be RCRA characteristic wastes; they would be
considered residual wastes under Pennsylvania law. '
, After treatment, the treated wastes would be placed in either a new onsite landfill or an existing
offSite landfill. B~use of the treatment step, placement is occurring. "the wastes were
, landfilled onsite, the landfill would be designed in accordance with RCRA landfill standards (40
CFR Part 264, Subpart N). These standards have been determined to be relevant and
40
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appropriate for the onsite landfill option. For the onsite landfill option, the landfill base would
be designed to minimize the threat. of sinkhole collapse. Deed -restrictions prohibiting Mure
uses would be placed on the landfill area. In addition, long-term O&M would be conducted
to monitor the groundwater around. the landfill and to ensure the integrity of the cap, in
accordance with the relevant and appropriate 40 CFR 264.117, and 5-year reviews would be
conducted. The onsite landfill option would not comply with the proposed Pennsylvania
residual waste landfill siting criteria. which prohibit the construction of a residual waste landfill
over sinkhole-prone limestone or carbonate formations. These criteria are TeC material. For
the offSite disposaf option, industrial (solid) waste management regulations would be applicable
since the treated wastes would be nonhazardous. These ARARs should be met.
Altemative 4 would comply with the CERCLA preference for a remedy that employs treatment
to reduce toxicity, mobility, or volume as a principal °element. The estimated capital and
present-worth costs of this alternative are $291,000 and $371 ,000 for the onsite and off Site
landfill options, respectively. There are no annual O&M costs for the onsite and offSite landfill
disposal optio~s. (Estimated annual O&M costs for the onsite landfill option are contained in
the cost estimates for the other wastes that the treated miscellaneous products/feedstocks
would necessarily be disposed with.) The estimated time to implement this alternative is
approximately 36 months.
5.
Alternative 5: BULK EXCA VA TlONNrTRIFICA TlON/LANDFILL
The 101 CY of miscellaneous products/feedstocks would be excavated and segregated into
hazardous and nonhazardous wastes: The nonhazardous wastes would be placed in an off Site
landfill legally able to accept these wastes. The hazardous wastes would be mixed with soil
or other Site wastes to dilute the. organic content of the mixture to 5 percent, and vitrified
onsite. Mixing the miscellaneous products/feedstocks with other materials is necessary to dilute
the overall organic content to a level that the vitrification equipment can handle. Because of
the relatively small volume of hazardous miscellaneous products/feedstocks, vitrification would
only be implemented if vitrification is implemented for another Site waste stream. The vitrified
wastes would be placed in either a new onsite landfill or an existing offSite landfill. Onsite
landfilling would only occur if a landfill is constructed orisite for another one of the Site's waste
streams. .
The hazardous miscellaneous products/feedstocks would be excavated and mixed onsite with
soils or other materials with a low organic carbon content. Other Site wastes could be used
if suitable. This mixing would occur to achieve a mixture organic carbon content of
approximately 5 percent. the maximum content that existing vitrification equipment can handle 0
The mixture would be placed in an onsite trench and heated with electricity flowing through
electrodes untl the. mixture formed a pool of molten glass. Organic contaminants would be
destroyed during heating, whereas metal contaminants would become trapped in the glass
during the subsequent cooling step. The vitrification would occur in accordance with RCRA
standards for miscellaneous treatment units (40 CFR Part 264, Subpart X). These standards
are applicable because treatment and dispOsal are occurring. The Vitrification unit would be
mobilized, operated, and closed according to the requirements of 40 CFR 264.600, et sea. The
specific operating parameters of the vitrification unit would be determined in the Remedial
Design phase ~rough engineering design and analysis and the competitive bidding processo
41
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\
, ,
Specialized air pollution control equipment would be applied during the vitrification step to
capture contami1ants in the exhaust air and thus ensure compliance, with the" refevant and
,appropriate NMOS (40 CFR Part SO) and NESHAPS (40 CFR Part 61 ,Subpart ,N). Residuals
from the air pollution control syste,." would be vitrified in subsequent batches.
',~ Alternative 5 wOuld be expected to comply with the applicable 5..0 mg/l arsenic land disposal
restriction treatment standard for the hazardous miscellaneous productslfeed$tocks. RCRA land
disposal restrictions (40 CFR Part 268) are applicable to these wastes because placement is '
occurring. (A national capacity extension for these wastes is in effect until May 8, 1992.) The
treatment step should render the wastes nonhazardous. "
The vitrified wastes would be placed in either a new onsite landfill or an existing off Site landfill. '
Because of the treatment step,placement is occurring: If the wastes werelandfilled onsite, the,
landfill would be 'designed in accordance with RCM landfill standards (40 'CFR .Part 264,
, Subpart N). These standards have been determined to be relevant and appropriate for the,
, orlsite landfill option. For the onsite landfill option, the landfill base would be designed ,to
, mini'mize the threat of sinkhole collapse. Deed restrictions prohibiting Mure uses would be,
placed on the landfill area. In addition, long-term O&M would be, conducted to monitor the'
" groundwater around the landfill and to ensure the integrity of the cap, in accordance with the'
relevant and appropriate 40 CFR 264.117, and s.year reviews would be conducted. The onsite
, landfill option would not comply with the proposed Pennsylvania residual waste landfill siting
criteria, which prohibit the construction of a residual waste landfill over sinkhole-prone limestone '
, or carbonate formations. These' criteria' are TBC material. For the offSite, disposal option,
industrial (solid) waste management regulations would be applicable since the treated wastes
would be nonhazar~ous. These ARARs should be met. ' ' , , ' '
, ,
, Alternative 5 would comply with theCERCLA preference for a remedy that employs treatment,
to reduce toxicity, mobility, or volume as a principal element. The estimated capital 'and'
pre'sent~worth cOsts of this alternative are $1 ,067,000 and $1,962,000 for the onsite and off Site
, 'landfill options, respectively. . There are nc 1nnual O&M' costs for the onsite aJ:"d off Site landfill
, disposal options. (Estimated ann~aI O&t. ISts for'the onsite lan~1I option are contained in
; the cost estimates for the other wastes mat the treated miscellaneous products/feedstocks.
would necessarily be disposed with.) The estimated time to implement this alternative is
, approximately 36 months. .'
6.
Alternative 6: ON-SITE ENHANCED'SOLIDS CONTAINMENT SYSTEM
, , )
'..
Under the former owners' proposal (Alternative 6), the miscellaneous products/feedstocks wo ul d
"be excavated 8nd placed in a new landfill constructed onsite. The landfill wo'uld be designed
to meet or exceed RCRA landfill standards (40 CFR Part 264, Subpart N), which' have been
, determined to be relevant and ,appropriate. RCRA standards are not applicable to Alternative
" 6 since the wastes are being consolidated within the same area of contamination. To provide
protection against sinkhole collapse and subsequent landfill failure, a foundation preparation
program would be implemented prior to landfill construction. The program would consist of
(1) geophysical surveying of the landfill area; (2) drilling exploration borings' on a selected grid
pattern and at any geophysical anomalies; (3) pressure grouting any voids discovered in the
exploration borings; (4) removing any soil above bedrock and any easily removable rock; and
. "
42
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(5) placing aggregate in bedrock joint openings and above the bedrock surface. Deed
restrictionsprohibi'ting Mure uses would be placed on the landfill area. Since the wastes
remai~ onsIte, &-year reviews would be conducted. Also, an unspecified maintenance and
monitoring program would be implemented. Alternative 6 would not comply with the
Pennsylvania hazardous waste facility siting criteria in Title 25, Chapter 75.425, which prohibit
the construction of a hazardous waste landfill over limestone or carbonate formations. These
criteria have been determined to be relevant and appropriate. Alternative 6 would also not
comply with the CERCLA preference for a remedy that employs treatment to reduce toxicity,
mobility, or volume as a principal element. Cost estimates were not provided in the former
owners' proposal. Costs are likely to be slightly higher than the estimated costs for Alternative
2. Th~ estimated time to implement this alternative is approximately 18 months.
7.
COMPARATIVE ANAL VSIS
PRODUCTS/FEEDSTOCKS
OF
"
ALTERNATIVES
MISCEllANEOUS
EPA's selected remedy for the mi8cellaneoue productalfeedetocks Is Alternative 4, with
the wastes exhibiting hazardous characteristics being Incinerated onaite In a mobile
Incineration unit, followed by onalte fixation of the Incinerator 88 and landfilling of the
fixated wastes offlste. The nonhazardou8 miscellaneous feedstocks would be directly
deposited In an offeite landfill. .
The six miscellaneous products/feedstocks remedial action .alternatives described above w,ere
evaluated under the nine evaluation criteria in the NCP. The evaluations are as follows: ~
Overall Protection. Alternatives 3, 4, and 5 would provide protection of human health and the
environment by eliminating, reducing, or controlling risk through treatment, engineering controls,
or institutional controls. Alternatives 4 and 5 would be slightly more protective than Alternati'/e
3 since Alternative 3 would not result in the destruction of organic contaminants in the
hazardous miscellaneous. products/feedstocks.
. .
Alternatives 2 and 6 would be less protective of human health and the environment than
Alternatives 3, 4, and 5 since the hazardous wastes would not be treated to immobilize the
arsenic in the wastes.
The .no action. alternative is not protective of human health and the environment, and is net
considered further in this analysis as an option for the miscellaneous produ~/feedstocks
Compliance with AMRa. The offSite disposal options for Alternatives 3, 4, and 5 would meet
their respective AMRs. Pennsylvania law does not allow construction of a hazardous waste
landfill immediately above any carbonate bedrock. Thus, Alternative 6 and the onsite landfill
option of Alternative 2 would not comply with this ARAA. The proposed Pennsylvania residual
waste landfill regulations do not allow construction of a residual waste landfill immediately
above any sinkhole-prone carbonate bedrock. Thus, the onsite landfill options of Alternatives
3, 4, and 5 would not comply with this TBC. Alternatives 3, 4, and 5 would be expected :0
comply with the applicable RCRA land disposal restriction standards for the miscellaneous
products/feedstocks. .The offSite landfill option of Alternative 2 would not comply with :~e
43
'\
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RCRA land disposal restriction standards if the hazardous miscellaneous products/feedstocks
are not landfiUed by May 8, 1992. (There is a RCRA land disposal restriction capacity extension
until this date.) Alternatives 2 and 6 would not comply with the CERCLA preference for
treatment. ' ,
long-term Effectlvenesa and Permanence. The oftSite disposal option of Alternative 4 would
reduce the hazards posed by the hazardous miscellaneous products/feedstocks by thermally
destroying the organic contaminants and fixating the metals in the incinerator ash. The lon9-
term risk of exposure to the treated wastes and untreated nonhazardous wastes at the
Whitmoyer Laboratories Site would be reduced by placing these wastes in an oftSite landfill.
Alternatives 4 and 5 would be slightty more protective than Alternative 3 since Alternative 3
would not result in any destruction of organic contaminants.
"
The. atternatlves that include onsite containment of the miscellaneous products/feedstocks
. (Alternative 6 and the onsite landfill options of Altem~tives 2, 3, 4, arid 5) would be less
protective of human health and the environment than the oftSite disposal options because of
the potential for the on site landfill to fail from sinkhole formation or other causes. , The onsite
landfill would require long-term maintenance, and portions of it might need to be replaced in
the Mure." deed restrictions are not effective, direct exposure to the wastes, in the Mure
could result from construction activities.
Reduction of Toxicity, Mobility, or Volume 0' the Contaminants Through Treatment.
Alternatives 3,4, and 5 would treat the hazardous wastes to reduce toxicity, mobility, or volume.
Alternatives 4 and 5 would eliminate the, toxicity of the organic contaminants in the hazardous
wastes by thermal destruction. Alternatives 3 and 4 would reduce the mobility of the metals
in the hazardous wastes by fixation in a cement matrix, whereas Alternative 5 would reduce the
metals'mobility by encapsulation in a glass matrix. ' "
-'
No ~eduction in toxicity, mobility, or volume is realized for Alternatives 2 and 6. Disposal
without treatment is the least preferred option under CERCLA.
, , -
. Short.term Effectlven.... Alternatives 2 through 5 could be implemented within an estimated
24 months from the remedy selection date. Alternative 6 could be implemented in18 months.
, .
, ,
There is some minor, short-term risk of exposure to the community during transportation of the
wastes off Site, under the offSite treatment options of Alternatives 3 and 4 and the oftSite landfill
disposal options of Alternatives 2, 3, 4, and 5. "worker safety procedures are properly
followed, only minimal short-term risks are associated with Alternative 6 and the onsite landfill
disposal option of Alternatives 2 through 5.' , '
ImplementabDlty.The various alternatives have few associated administrative difficulties that
- could delay implementation. Permits would be required for the offSite disposal of the treated
or untreated wastes. For Alternatives 3, 4, and 5, treatment equipment and skilled workers
would be available but limited. The technology, equipment, and specialists required to
implement Alternatives 2 and 6 would be readily available. For all of the alternatives, monitoring
,of air and water during Implementation would be required. For Alternatives 3, 4, and 5,
monitoring of the treated wastes Would also be required. Long-term monitoring of landfill
44
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leachate and leak detection zones would be required for Altematlve 6 and the onsite landfill
options of Altematives 2, 3, 4, and 5.
Cost. The pr8l8nt-worth cost of the offSite disposal option of Altemative 4 is $371,000. The
lowest-cost alternative is Altemative 2 (onsite landfill option) at $13,900. The highest cost
altemative is Altemative 5 with offSite disposal, at $1,962,000. The other FS alternative costs
are presented in thealtemative description sections. The former owner's proposal, Alternative
6, does not include a cost estimate. Alternative 6 costs are likely to be slightly higher than the
estimated costs for Altemative 2. '
State Acceptance. The Commonwealth of Pennsylvania has not yet concurred in the selected
remedy.
Community Acceptance. A public meeting on the Proposed Plan was held April 24 in
Lebanon County, Pennsylvania. Comments received from the public during the comment
period are referenced in the Responsiveness Summary attached to this Record of Decision.
, '
D.
Site STRUCTURES
. ~~ i
The onsite containment program proposed by the former owners did not address the Site
structures, with the sole exception of the vault structure. Under the former owner containl1)ent
program, the vault structure would be placed in the on-5ite enhanced solids containment
system. Since the former owner containment program did not address the majoriti. of
contaminated Site structures, it will not be considered a Site structure remedial altemative,and
will not be discussed further in the analysis of Site structure remedial altematives.
The remedial alternatives for the Site structures are numbered to correspond with the aJterna'tive
numbers in the FS Report. The alternatives are the following:
*
, Altemative 1:
Altemative 2:
Alternative 3:
Altemative 4:
No Action, '
Demolition/Bulk Excavation, Surface Treatment/Landfill
Demolition/Bulk Excavation, Surface Treatment/Incineration/Landfill
Demolition/Bulk Excavation, Surface TreatmenWrtrification/Landfili
. ~ ~
*
*
*
1.
Altemative 1: NO ACTION
The 8no actior1' alternative is required under the Superfund program at every Site, to establish
a baseline for comparison with the other alternatives. Under this altemative, EPA would take
no actions oth8f than performing reviews every 5 years. Since hazardous wastes were treated
in the Site 1xM8g& after 1980, the Site structures were abandoned after 1980, and some of
the structures exhibit the RCRA arsenic and cadmium toxicity characteristics, RCRA Subpart
G dosure regulations (40 CFR 264.111) would be applicable to the structures. Also, since
precipitation runoff from the Site structures is adding significant concentrations of contaminants
to Tulpehocken Creek, Clean Water Act (CWA) direct discharge standards (40 CFR Part' 22)
are applicable. 8No action. would not comply with the RCRA dosure and CWA direct discharge
regulations. Alternative 1 WOuld also not comply with the CERCLA preference for a remedy that
employs treatment to reduce toxicity, mobility, or volume as a principal element While no
45
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capital costs would be Incurred under this alternative, annual operation & maintenance (O&M)
costs are estIm8t8d to be $3,600. This alternative has a present-worth cost of $55,600, and
can be implemented immediately.' ,
2.
, ,
Alternative 2: DEM0UT10N/BULK EXCAVATION. St.,JRFACE TREATMENT/LANDFILL
"
Under Alternative 2, all of the Site structures with surface contamination, would be surface,
cleaned. Dangerous conditions existing in buildings outside 01 the Building 1-7 complex would
be remediated. The Building 1-7 complex and all tanks, vessels, piping, process equipment
and outdoor tank concrete dikes would be demolished and excavated. The demolition debris
would be ground, crushed, screened, and magnetically separated, as appropriate; and
, ,segr$gated into nonhazardous and hazardous components. The nonhazardous components,
would be disposed in an onsite landfill or an offSite landfill legally able,to accept the debris. ,
The hazardous materials would be placed in, either an onsite landfill or, an offSite RCRA
Subtitle C landfill. .'
The surface decontamination wo'uld be conducted in accordance with RCRA closure regulations ':
for structures (40 CFR 264.114). The, specific type of cleaning process used would be
, determined in the Remedial Design phase through engineering design and ~alysis and the
., competitive bidding process. ' Cleaning residuals would e~er be managed i~ an onsite,
groundwater treatment system, if, constructed, or at an offSite facility legally able to a.~pt the
~~ ' "
, '
. "
During demolition, downgradlent air monitoring would be conducted to evaluate P9tential risks
to the community. if necessary, remedial measures would be taken to cOntrol air releases.
" Since some of the' Site structures contain asbestos, Occupational Safety and, Health
Administration (OSHA) construction standards (29 CfR 1926.58) ,w~uld be applicable to the,
demolition.' "
For the onsite landfill option, the landfill would be designed to meet or exceed all RCRA landfill
standards (4OCFR Part 264, Subpart N), which have been determined to be relevant and
appropriate. RCRA standards are not applicable to the onslte landfill option of Alternative 2
since the hazardous materials are being cOnsolidated within the same area of contaminatic;m.
The landfill liner base would be designed to minimize threats pos8d by sinkhole collapse. Deed
restrictions' prohibiting future uses would be placed on the landfill area. Since the wastes
would, remain onsite, long-term O&M would be CC?nducted to monitor the groundwater around
the ,landfill' and to ensure the Integrity of the cap, in accordance with 40 CFR 264.117, and 5-
'year reviews would be conducted. The onsite I~dfill option of Alternative 2 would not comply
with the Pennaytvania hazardous waste facility siting criteria 'in Title 25,Chapter 75.425'for the
hazardous SIt8 atructures, and the proposed Pennsytvania residual waste landfill siting criteria'
for the nonhazardous Site structures. These criteria prohibit the construction of a hazardous
or residual waste landfill over sinkhole-prone limestone or carbonate formations. These criteria
have been determined to be relevant and appropriate for the hazardous Site structures (the
hazardous waste siting criteria are promulgated), and ,T8C material for the, nonhazardous Site
structures (the residual waste criteria are presently proposed). RCRA land disposal restrictions
(40 CFR Part 268) were not determined to be applicable for the hazardous ~ite structure wastes
because placement is not occurring. EPA is undertaking a RCRA land disposal restriction
../
46
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1--
rulemaking that will specifically apply to soil and debris. Until that rulemaking is completed, the
CERCLA program does not consider RCRA land disposal restrictions to be relevant and
appropriate to debris that does not contain RCRA-regulat,ed wastes.
For the offSite disposal option, the hazardous Site structures would be disposed in a hazardous
waste landfill, and the nonhazardous structures in an industrial (solid) waste landfill. The off Site
landfill option would not comply with the RCRA land disposal restrictions for cadmium'
characteristic (0006) wastes. There is a RCRA land disposal restriction capacity extension for
arsenic characteristic (0004) nonwastewaters until May 8, 1992
(55 FR 22520). If the materials exhibiting only the arsenic (and not the cadmium) toxicity
characteristic are directly landfilled offSite before this date, this action would comply with the
RCRA land disposal restrictions for arsenic characteristic wastes. EPA is currently undertaking
a 'RCRA land disposal restriction rulemakingthat will specifically address debris. This
rulemaking may change the status of these RCRA land disposal restriction ARARs.
Alternative 2 is intended to comply with the applicable RCRA closure standards, OSHA asbestos'
standards, CWA direct discharge standards, and Federal Floodplains Management and
Executive Order (E.O. 11988); and the relevant and appropriate NMOS (40 CFR Part SO).
Alternative 2 would not comply with the CERCLA preference for a. remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
. costs of this alternative are $2,000,000 and $4,000,000, for the onsite and offSite landfill options,
respectively; Annual O&M costs for the onsite landfill option are estimated to be $3,600. There
are no annual O&M costs for the offSite landfill disposal option. The estimated present-worth
. costs of this alter~'ative are $2,056,000 and $4,000,000 for the onsite and offSite landfill options,
respectively. The estimated time to implement this alternative is approximately 24 months.
/
. .
3.
Alternative 3: DEMOLITION/BULK
TREA TMENT/lNCINERATION/LANDFILL
EXCAVATION.
SURFACE
Under Alternative 3, all of the Site structures with surface contamination would be surface
cleaned. Dangerous conditions existing in buildings outside of the Building 1-7 complex would
be remediated. The Building 1-7 complex and all tanks, vessels, piping, process equipment,'
and outdoor tank concrete dikes would be demolished and excavated. The demolition'debris
would be ground, crushed, screened, and magnetically separated, as appropriate; and
segregated into nonhazardous and hazardous components. The nonhazardous components
would either be disposed in an onsite landfill or an offSite landfill legally able to accept the
debris, or saIv8ged. The hazardous m~terials would be divided into three groups: combustible
materials (such 88 the wood flooring); impermeable materials (such as the steel tanks); and
permeable mIII8rIaIs (such as the concrete dikes). The' combustible materials would be
incinerated, with the ash being fixated with cemen1/pozzolan-based materials. The impermeable
materials would be surface cteaned. The permeable materials would be coated and sealed to
immobilize the contaminants. The treated wastes would be placed in either a new onsite landfill
or an existing offSite landfill.
The surface decontamination would be conducted in accordance with RCRA closure regulations
for structures (40 CFR 264.114). The specific type of cleaning process ~ steam or water
47
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washing, 01' sandblasting) would be determined in the Remedial Design phase through
engineering de8ign and analysis and the competitive bidding process. Cleaning residuals
. would either be managed In' an onsite groundwater treatment system, if, constructed, or at an
offSite facility legally able to accept the waste.
, During demolition, downgradlent air monitoring would be conducted to evaluate potential risks
to the community. If necessary,' remedial measures would be taken to control air releases.
Since some of the Site structures contain 'asbestos, Occupational Safety and Health
Administration (OSHA) construction standards (29 CFR 1926.58) would be applicable to the
demolition~ . . .
The, combustible hazardous Site structures would be incinerated onsite or off Site , with the
incinerator residuals being fixated with cement/pozzolan-based or other similar materials.
Because' of the relatively small volume of combustible hazardous Site structures, onsite
incineration of the wastes would only be implemented if onsite incineration is implemented for
the vault or lagoon wastes. The combustible materials would be incinerated to destroy the
organic contaminants and to leave the metals in a form amenable to cement fixation, in '
ac~rdance with RCRA 40 CFR Part 264, Subpart 0 standards. The. specific type of
.' incineration process (!A. rotary kiln) would be determined in the Remedial Design phase
. through engineering design and analysis and the competitive bidding process. If onsite
incineration occurs, the incineration unit would be mobilized, operated, and closed according
. to the requir.ments of RCRA Subpart 0, 40 CFR 264.340, et!!g. These requirements are
applicable because the hazardous combustible Site structures are hazardous wastes. Specific
operating practices necessary to meet the per10rmance objectives, including a 99.99 percent
: destruCtion and removal efficiency (DRE) of stack emissions as required by Subpart' 0 of RCRA
would be determined through a trial bum at the Site after the installation of the incineration unit.
Specialized air pollution control equipment would be applied during the incineration step to
. capture contaminants in the exhaust air and thus ensure compliance with the relevant and
appropriate NMOS (40 ~FR Part SO) and NESHAPS (40 CFR Part 61, Subpart N).
. The incineration residuals would be fixated using cement/pozzolan-based or other similar
,methods, in accordanc.=;! with the requirements of RCRA standards for miscellaneous treatment
units (40, CFR Part 264, Subpart X). The exact fixation technique employed would be
determined in the Remedial Design phase through engineering design and analysis and the
competitive bidding process. If onsite treatment occurs, both the incineration and fixation would
take place onsite ,using mobile equipment. The on site fixation unit would be mobilized
operated, and closed according to the requirements of 40 CFR 264.600, et HQ.
Coating and 8MIIng Would be considered appropriate for the concrete diking, concrete bloCk
walls and ftoor8, and asbestos (during handling). The exact coating and sealing technique
employed would be determined In the Remedial Design phase through engineering design and
analysis and the competitive bidding process.
Salvaging would consist of auctioning off decontaminated structures. Scrapped metal may alsc
be sold to the steel industry for reuse. .
48
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Alternative 3 would be expected to comply with the applicable 5.0 mg/1 arsenic and 1.0 mg/l
cadmium RCRA land disposal restriction treatment standards for arsenic and cadmium toxicity
characteristic wastes, respectively. RCRA land disposal restrictions (40 CFR Part 268) are
applicable to the wastes because placement is occurring. (A national capacity extension for
arsenic characteristic wastes is in effect until May 8, 1992.) Following treatment, the wastes
should no longer be RCRA characteristic wastes; they would be considered residual wastes
under Pennsylvania law (25 PA Code, Chapter 75).
The treated wastes and untreated nonhazardous wastes would be placed in either a new onsite
landfill or an existingoffSite landfill. "the wastes were landfilled onsite, the landfill would be
designed in accordance with RCRA landfill standards (40 CFR Part 264, Subpart N). These
standards have been determined to be relevant and appropriate for the onsite landfill option.
For the onsite landfill option, the landfill base would be designed to minimize the threat of
sinkhole collapse. Deed restrictions prohibiting Mure uses would be placed on the landfill
area. In addition, long-term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity of the cap, in accordance with the relevant and appropriate
40 CFR 264.117, and 5-year reviews would be conducted. The onsite landfill option would not
comply with the proposed Pennsylvania residual waste landfill siting criteria, which prohibit the
construction of a residual waste landfill over sinkhole-prone limestone or carbonate formations.
These criteria are TBC material. For the offSite disposal option, industrial (solid) waste
management regulations would be applicable since the treated wastes would be nonhazardous.
These ARARs should be met.
~,,' .
: Alternative 3 is intended to comply with the applicable RCRA closure standards citedabo.ve.
OSHA asbestos standards, CWA direct discharge standards, and Federal Floodplains
Management and Executive Order (E.O. 11988); and the relevant and appropriate NAAQS.
Alternative 3 would also comply with the CERCLA preference for a remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
costs of this alternative are $2,440,000 and $4,100,000, for the onsite and offSite landfill options,
. respectively. Annual O&M costs for the onsite landfill option are estimated to be $3,600. There
. are no annual O&M costs for the offSite landfill disposal option. The estimated present-worth
costs of this alternative are $2,500,000 and $4,100,000 for the onsite and off Site landfill options,
respectively. The estimated time to implement this alternative is approximately 36 months.
4.
Alternative 4: DEMOLITION/BULK
TREA TMENTNITRIFICATlON/LANDFILL
EXCAVATION.
SURFACE
Under Alternative 4, all of the Site structures with surface contamination would be sunace
cleaned~ Dangerous conditions existing in buildings outside of the Building 1-7 complex would
be remediated. The Building 1-7 complex and all tanks, vessels, piping, process equipment,
and outdoor tank concrete dikes would be demolished and excavated. The demolition debris
would be ground, crushed, screened, and magnetically separated, as appropriate; and
segregated into nonhazardous and hazardous components. The nonhazardous components
would either be disposed in an onsite landfill or an offSite landfill legally able to accept the
debris; or salvaged. The hazardous materials would be divided into three groups: combustible
materials (such as the wood flooring); impermeable materials (such as the steel tanks); and
permeable materials (such as the concrete dikes). The combustible materials would be vitrified
49
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. .
onsite. The metal contaminants would become trapped In the glass during the subsequent
cooling step. The Impermeable materials would be surface cleaned. The permeable materials
would be C08t8d. and sealed to immobilize the contaminants. The treated wastes would be
. placed In either . new onsite landfill or an existing offSite landfill. .
The surface decontamination would be conduct8d in accordance With RCRA clos~re regulations
for structures (40 CFR 264.114). The specific type of cleaning procesS used would be
determined in the Remedial Design phase through engineering design and analysis and the
competitive bidding process. Cleaning residuals would. either be managed in an onsite
groundwater treatment system, if constructed, or at an offSite facility legally able to accept the
wa~e. .
.'-0:-
. .
. .
During demolition, downgradient air monitoring would be conducted to evaluate potential risks
to the community. If necessary, remedial measures would be taken to control air releases.
. Since some of the Site structures. contain asbestos, Occupational Safety and -Health
Adminination (OSHA) construction ~dards (29 CFR 1926.58) would be applicable to the
demolition~ .
I~
. .
The combustible haZardous Site structures would be mixed with soils or other materials with
a low organic carbon content. Other Site wastes couJd be used if suitable. This mixing would
. occur to achieve a mixture organic carbon content of approximately 5 percent, the maximum
content that existing vitrification equipment can handle. The mixture would be placed in a
. trench and heated with electricity flowing through electrodes until the mixture formed a pool of
molten. glass. Organic contaminants would be destroyed during heating, whereas metal.
contaminants would become trapped in the glass during the subsequent cooling. step. The
vitrification would occur in accordance with RCRA standards for miscellaneous treatment 'units
(40 CFR Part 264, SubpartX). These standards are applicable to the hazardous combustible
Site'structures because treatnient and disposal are occurring. The vitrification unit would be
mobilized, operated, and closed according to the requirements of 40 CFR 264.600, et sea. The
specific operating parameters of the vitrification unit would be determined in the Remedial
Design phase through engineering design and analysis and the competitive bidding process.
. Specialized air pollution control ~uipment would be applied during the vitrification step to
. capture contaminants In the exhaust air and thus ensure compliance with the relevant and
appropriate NAAQS (40 CFR Part SO) and NESHAPS (40 CFR Part 61, Subpart N). Residuals
. from the air pollution control system would be vitrified in subsequent batches.
Coating and sealing would be considered appropriate for concrete and block walls and floors.
and asbestos (during handling). The exact coating and sealing technique employed would be
determined In the Remedial Design ph~e through engineering design and analysis and the
competitive bidding process.. .
Altematlve 4 would be expected to comply with the applicable 5.0 mg/l arsenic and 1.0 mg/I
cadmium RCRA land disposal restriction treatment standards for arsenic (0004) and cadmium
(0006) toxicity characteristic wastes. RCRA land disposal restrictions (40 CFR Part 268) are
applicable to the hazardous wastes because placement is occurring. (A national ~apacity
extension for DOO4 nonwastewaters is in effect until May 8, 1992.) Following treatment, the
50
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wastes should no longer be RCRA characteristic wastes; they would be considered residual
wastes under Pennsylvania law (25 PA Code, Chapter 75).
The' treated W8St8S and untreated nonhazardous wastes would be placed in either a new on site
landfill or an existing offSite landfill. If the wastes were landfilled onsite, the landfill would be
designed In accordance with RCRA landfill standards (40 CFR Part 264, Subpart N). These
standards have been determined to be relevant and appropriate for the onsite landfill option.
For the onsite landfill option, the landfill base would be designed to minimize the threat of
sinkhole collapse. Deed restrictions prohibiting Mure uses would be placed on the landfill
area. In addition, long-term O&M would be conducted to monitor the groundwater around the
landfill and to ensure the integrity of the cap,' in accordance with the relevant and appropriate
40 CFR 264.117, and 5-year reviews would be conducted. The onsite landfill option would not
comply with the proposed Pennsylvania residual waste landfill siting criteria, which prohibit the
.construction of a residual waste landfill over sinkhole-prone limestone or carbonate formations.
These criteria are rec material. For the offSite disposal option, industrial (solid) waste
management regulations would be applicable since the treated wastes would be nonhazardous.
These ARARs should be met.
Alternative 4 is intended to comply with the applicable RCRA closure standards cited above,
OSHA asbestos standards, CWA direct discharge standards, and Federal Floodplains
Management and Executive Order (E.O. 11988); and the relevant and appropriate NMOS.
Alternative 4 would also comply with the CERCLA preference for a remedy that employs
treatment to reduce toxicity, mobility, or volume as a principal element. The estimated capital
costs of this alternative are $5,490,000 and $7,400,000, for the onsite and offSite landfill options,
respectively. Annual O&M costs for the onsite landfill option are estimated to be $3,600. There
are no annual O&M costs for the offSite landfill disposal option. The estimated present-worth
costs of this alternative are $5,500,000 and $7,400,000 for the onsite and offSite landfill options,
respectively. The estimated time to implement this alternative is approximately 36 months.
COMPARATIVE ANALYSIS OF AL TERNATNES - SITE STRUCTURES
5.
EPA's selected remedy for the alte structures 18 Alternative 3 with offlste disposal. All of
the site structures with surface contamlnatJon would be aurface cleaned. Dangerous
conditions exJatJng In buildings outside of the the Building 1-7 complex would be
remedlated. The Building 1-7 complex and all tanka, vessels, piping, and process
equipment would be demolished and excavated. Nonhazardous debris would either be
disposed In an offalte landfill, or salvaged. The hazardous materials would be treated by
either Incineration followed by fixation; surface cleaning; or coating and sealing. The
treated waat88 would be landfliled offalte.
The four Site structures remedial action alternatives described above were evaluated under the
nine evaluation criteria in the NCP. The evaluations are as follows:
Overall Protection. Alternatives 3 and 4 would provide protection of human health and the
environment by eliminating, reducing, or controlling risk through treatment, engineering controls,
or institutional controls.
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Alternative 2 would be less protective of human health and the environment than Alternatives
3 and 4 since the hazardous wastes would not be treated to either destroy or immobilize. the
contaminants.
.. The remedial options that Include onsite landfi/llng of the Site structures (the onsite landfill
,. options for Alternatives 2, 3, and 4) would be less protective of human health and the
. environment than the offSite disposal options because of the potential of landfill failure from
sinkhole formation or other causes. Landfill failure could result in a substantial release of
contaminants to groundwater. . .
The .no action. alternatiVe is not protectiVe of human health and the environment,. and is not
considered further in this analysis as an option for the Site structures.
Compliance with ARARa. The offSite disposaJ option for AlternatiVes 3 and 4 would meet their
respective ARARs. Pennsylvania law does not allow construction of a hazardous waste landfill
immediately above any carbonate bedrock. Thus, the onsite landfill option of Alternative 2
would not comply with this ARAR. The proposed Pennsylvania residual waste landfill
regulations do not allow construction of a residual waste landfill immediately above any
sinkhole-prone carbonate bedrock. The onsite landfill options of Alternatives 3 and 4 would.
not comply with "this TeC. AlternatiVes 3 and 4 would be expected' to comply with the
applicable RCRA land disposal restriction standards for the Site structures. " The offSite landfill
. option of AlternatiVe 2 would not eomplywith the RCRA land disposal restriction standards for
DOO6 wastes. EPA is currently undertaking a RCRA land disposal restriction rulemaking that'
will "specifically address debris. This rulemaking may change the status of the Site structures
RCRA land disposal restriction ARAR. AlternatiVe 2 would not comply with the CERCLA
preference for treatment.
Long-term Effectlven... and Permanence. The offSite disposal option of Alternative 3 would
reduce the hazards posed by the Site structures by surface cleaning Site structures having
contaminated surface buildups; remedying dangerous conditions in the buildings; demolishing
the most contaminated structures; thermally destroying the organic contaminants and fixating
the metals in the demolished combustible materials; surface cleaning the demolished
impermeable materials; and immobilizing the contaminants in the demolished permeable
"materials. The long-term risk 0' exposure to the treated wastes at the Whitmoyer Laboratories
Site would be reduced by placing the wastes in an offSite landfill. AlternatiVes 3 and 4 would
be more protective than Alternative 2 since the contaminants would either be destroyed or
immobilized by treatment.
The altemative8 that include onsite containment of the Site structures debris (the onsite landfill
- options of Alt8m8tives 2, 3, and 4) would be less protective of human health and the
. environment than the alternatives with offSite disposal options because of the potential for the
onsite landfill to fail from sinkhole formation or other causes. The onsite containment system
would require long-term maintenance, and portions of it might need to be replaced in the
future. If deed restrictions are not effective, direct exposure to the wastes in the Mure could
result from construction activities.
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Reduction of TaxJcfty, Mobnlty, or Volume of the Contamlnanta Through Treatment.
Alternatives 3 and 4 would treat the hazardous debris to reduce toxicity, mobility, or volume.
Alternatives 3 8nd 4 would eliminate the toxicity of the organic contaminants in the combustible
materi" by thermal destruction, and would reduce the mobility of the contaminants in the other
hazardous Site structures using immobilization technologies. Alternative 3 would immobilize the
metals in the combustible materials by fixating the incinerator ash, whereas Alternative 4 would
reduce the mobility of the metals in the combustible materials by encapsulating them in a glass
matrix.
No reduction in toxicity, mobility, or volume is realized for Alternative 2. Disposal without
treatment is the least preferred option under CERCLA. .
Short-term Effectlvenesa. All of the alternatives could be implemented within an estimated 24
months from the date of this ROD.
There is some minor, short-term risk of exposure to the community during transportation of the
wastes offSite under the offSlte incineration option of Alternative 3 and the off Site landfill
disposal options of Alternatives 2, 3, and 4. If worker safety procedures are properly adhered
, to, only minimal, short-term risks are associated with the onslte landfill disposal options of the
remedial alternatives.
.~..- .
Implementability. The various alternatives have few associated administrative difficulties that
could delay 'implementation. Permits would be required for the offSite disposal of the. treated
or untreated wastes. For Alternatives 3 and 4, thermal treatment equipment and skilled ,workers
would be available but limited. The technology, equipment, 'and specialists required to
implement Altemative 2 would be readily available. For all 01 the altematives, monitoring of air
and water during implementation would be required. For Alternatives 3 and 4, monitoring of
the treated wastes would also 'be required. Long-term monitoring 01 landfill leachate and leak
detection zones would be required for the onsite landfill options of Alternatives 2, 3, and 4,
Cost.. The present-worth Cost 01 the offSite disposal option 01 Altemative 3 is estimated to be
$4,100,000. The lowest-cost altemative is Altemative 2 (onsite landfill option) at $2,056.000
The highest cost alternative is Altemative 4 with offSlte disposal, at $7,400,000. The other
alternative cost estimates are presented in the alternative description sections.
State Acceptance. The Commonwealth of Pennsylvania has not yet concurred with Ir. e
selected remedy.. .
Communfty Acceptance. A public meeting on the Proposed Plan was held April 24 11":
Lebanon County, Pennsytvania. Comments received from the public during the commert
period are referenced in the Responsiveness Summary attached to this Record of Decision
VIII. THE SELECTED REMEDY
Based upon consideration of information available for Operable Unit Two of the Whitmoyer
Laboratories Site, including the documents available in the Administrative Record,'an evaluatlcr.
53
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of the risks curr8r1tly posed by the Site, the requirementS of CERCLA, the detailed evaluation
of alternatives, 8nd community input; both EPA and the CommonwealtO of Pennsylvania have
selected the toIowIng alternatives as the remedy to be implemented for the operable unit.
A.
VAULT WASTES
Alternative 3 (cement/pozzolan-based fixation) for the lower vault wastes, and Alternative 4
(incineration followed by cement/pozzolan fixation) -for the upper vault wastes. The wastes
would be treated to comply with RCRA land disposal restrictions prior to being landfilled at an
off Site hazardous waste disposal facility. The remedy for the upper vault wastes is incineration
that meets all RCRA. NMQS, and NESHAPS requirements and that is dem~:mstrated to be safe
during the remedial design phase - of ROD implementati~n. -
B. -
LAGOON WASTES
Alternative 3 (iron-based fixation), with the wastes ultimately being landfilled off Site at an
- intermediate (solid) waste disposal facility. The treatment would render the hazardous wastes
nonhazardous. - - -
C:
MISCELLANEOUS PRODUCTS/FEEDSTOCKS
Alternative 4. Wastes exhibiting hazardous characteristics would be incinerated onsite in a
mobile incineration unit, followed by cement/pozzolan-based fixation of the incinerator residuals. -
This treatment will render the treated wastes nonhazardous. The treated wastes and
nonhazardous miscellaneous products/feedstocks wo.uld be disposed in an offSite intermediate
(solid) waste disposal facility. -
D.
SITE STRUCTURES
Alternative 3,.- with the hazardous combustible Site structures being incinerated onsite and the
- treated wastes being landfilled offSite at an intermediate (solid) waste disposal facility-
Treatment of - the hazardous wastes would render them nonhazardous. -
The estimated present-value cost of this selected remedy is $45,800,000; as follows:
"'"7"
Medium
- Present-value Cost
TOTAL COST -
$18,400,000
$22,900,000
$371,000
$4.100.000
$45,800,000
Vault Wastes
Lagoon Waste8
Miscellaneous Products/Feedstocks
Site Structures .
The major components of the selected remedial action are as follows:
54
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*
Excavation of the concrete vault contents [(4,500 cubic yards (CY)], the
8PP"oximately 20 buried drums located -east 01 the vault, and an estimated 50
CY of residuals potentially present in the tanks and process vessels not being
8ddressed under OU One.
*
Excavation of the approximately 24,000 CY of materials present in the lagoons
having an arsenic content greater than 10,000 mg/kg (lagoon wastes).
Removal of the approximately 101 CY of miscellaneous productslfeedstocks from
the buildings. -
*
*
Surface cleaning 01 the Site structures with surface contamination.
*
Remediation 01 dangerous conditions existing In buildlngs- outside of the Building
1-7 complex.
*
Demolition 01 the Building 1-7 complex and all tanks, vessels, piping, process
equipment, and outdoor tank concrete dikes.
*
Onsite incineration of the approximately 3,000 CY 01 high organic content wastes
present in the vault; the contents of the approximately 20 buried drums; the
estimated 50 CY 01 residuals potentially present in the tanks and process vessels
not being addressed under OU One; and the miscellaneous productslfeedstocks
and combustible demolition debris exhibiting the RCRA arsenic toxicity
characteristic. The remedy selected by EPA Is incineration that meets all RCRA
NMQS, and NESHAPS requirements and that is demonstrated to be safe during
the remedial design phase of ROD implementation.
*
Fixation of the Incineration residuals and the approximately 1,500 CY of low
organic content wastes present in the vault using a cement/pozzolan-based or
other similar fixation process that provides equivalent protection.
*
Fixation 01 the lagoon wastes exhibiting the RCRA arsenic toxicity characteristic
using an Iron-based or other similar fixation process that provides equivalent
protectioo. -
*
Coating and sealing the noncombustible, permeable demolition debris exhibiting
the RCRA arsenic toxicity characteristic. -
*
- Surface cleaning the noncombustible, impermeable demolition debris exhibiting
the RCRA arsenic toxicity characteristic.
*
Salvaging nonhazardous demolition debris, as feasible.
55
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,
,
! .
.
DIsposal of the treated wastes; the untreated (nonhazardous) lagoon wastes; the
untreated (nonhazardous) miscellaneous products/feedstocks; and the untreated
(nonhazardous) demolition debris that is not salvaged in offSite landfill(s), in
8CCOrdance with all applicable regulations.
These alternatives will significantly reduce or eliminate the actual and potential threats to public
health and 1I1e environment posed by the OU Two materials, and are consistent with EPA's
strategy for remediation of the Site. .
<.\
IX. STATUTORY DETERMINATIONS
Under its legal authorities, EPAis primary responsibility at Superfund Sites is to u'ndertake
remedial actions that are protective of human health and the environment. In addition, Section
. 121 of CERCLA establishes several other statutory requirements and' preferences. These
specify that when complete, the selected remedial action for this Site must comply' with
applicable or relevant and appropriate environmental standards established under Federal and
State environmental laws unless a statutory waiver is granted. The selected remedy also must
be cost~ffective and utilize treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a preference for remedies that perma-
nently and significantly reduce the volume, toxicity, or mobility of haZardous wastes. The
following sections discuss how the selected remedy for this Site meets these statutory
requirements. .' . .'
A.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Based on the risk assessment developed for OU Two materials, actual or potential exposure
pathways include groundwater consumption, dermal contact, accidental ingestion, and
inhalation. Additionally, risks are presented by the potential for a fire at the Site and the unsafe
conditions in the buildings onsite. The selected remedy addresses these risks (protects human
health and the environment) by destroying the organic contamination in the upper vault wastes,
hazardous. miscellaneous products/feedstocks, and hazardous combustible Site structures;
reducing the mobility of the arsenic in the incineration residuals and the lower vault wastes
using a cement/pozzolan-based or other similar fixation process; reducing the mobility 01 the
. arsenic in the hazardous lagoon wastes using an iron-based or other similar fixation process;
reducing the mobility of contaminants in the noncombustible, permeable demolition debris
exhibiting- the RCRA arsenic toxicity characteristic by coating and'. sealing these materials;
removing cont8mlnantS from the noncombustible, impermeable demolition debris exhibiting the
RCRA arsenic tr»dcity characteristic by surface cleaning; salvaging nonhazardous demolition
debris, as fe"'; disposal of the treated wastes, the untreated (nonhazardous) lagoon wastes,
the untreated (nonhazardous) miscellaneous products/feedstocks, and the untreated
(nonhazardous) demolition debris that is not salvaged in offSite landfill(s) to further reduce
. contaminant mobility and access to these materials; surface cleaning of the Site structures with
surface contamination to eliminate ingestion/inhalation exposure; and remediation of dangerous
conditions existing in buildings outside of the Building 1-7 complex to prevent accidents. Both
"carcinogenic and non-carcinogenic risks from the contaminant sources identified in this Record
of Decision will be eliminated from this Site through the treatment/removal of those sources.
56
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The selected remedy will not pose any unacceptable short-term risks or cross-media impacts
to the Site, the workers, or the community. While there are risks associated with arsenic
volatilization during the incineration, these risks would be reduced to acceptable levels through
the use of specialized air pollution control equipment. Since metals cannot be destroyed, there
will be some long-term risks associated with the metal (mostly arsenic and cadmium)
. contamination; however, the heavily-contaminated materials will be treated prior to disposal to'
reduce the mobility of the' heavy metals, and the treated and untreated materials that are not
salvaged will be placed into an offSite landfill for proper long-term management.
B;
ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
The selected remedy will attain all applicable or relevant and appropriate requirements for the
Site, the OU Two materials, and the actions that will be implemented. The major ARARs include
, the following:
*
Action-Specific ARARs - RCRA Subtitle C closure requirements (40 CFR Part 264,
Subpart G) will be met for the Site structures; Incineration of the upper vault
wastes, hazardous miscellaneous products/feedstocks, and hazardous
combustible Site structures will comply with RCRA Subtitle C incineration
requirements (40 CFR Part 264, Subpart 0). The incineration residuals, the lower
vault wastes, and the hazardous lagoon wast~s would be fixated in accordance
with RCRA Subtitle C miscellaneous treatment unit standards (40 CFR Part 264,
Subpart X). Materials transported offSite will meet the CERClJ\ offSite disposal
policy and comply with Federal transportation regulations (40 CFR Parts 262 and
263; 49 CFR Parts 107 and 171-179) and Pennsylvania regulations (Title 25,
ChaDter 263) for material transport. During contaminated material demolition,
excavation, and treatment, air monitoring will be performed to ensure that any
air emissions comply with Clean Air Act (40 CFR Parts 50 and 61) and
Pennsylvania air quality regulations (Trtle 25. ChaDters 123. 127. and 1311-
Occupational Safety and Health Administration (OSHA) asbestos standards (29
CFR Part 1926) will be met during Site structure demolition. OSHA requirements
(29 CFR Parts 1904, 1910, and 1926) will be met for workers engaged in remedial
activities. Vault waste treatment will be monitored to ensure compliance with
RCRA SubtitJe C land disposal restrictions (40 CFR Part 268) prior to off Site
transport and landfilling. Treatment of the wastes exhibiting the characteristic
of arsenic toxicity (hazardous lagoon wastes, hazardous miscellaneous
products/feedstocks, and hazardous Site structures) will be scrutinized to confirm
that the treated waste is no longer hazardous, prior to disposal at an approved
offSIte facility. The offSite landfill accepting the treated vault wastes will comply
with RCRA Subtitle C standards (40 CFR Part 264, Subpart N)., The off Site landfill
accepting the treated and untreated lagoon wastes, miscellaneous
products/feedstocks. and Site structures will comply with RCRA Subtitle D and
state industrial (solid) waste management regulations. Excavation activities will
be in accordance with Pennsylvania requirements for erosion control (25 P A
Code, Chapter 102).
57
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-.
C.
.
Chemical-Specific ARARs - RCRA Subtitle C and Commonwealth of Pennsylvania
requirements for identification of listed and characteristic hazardous wastes (40
CFR Part 261 and 25 PA Code, Chapter 261, respectively) will be complied with'
during the remediation of au Two materials. Air emissions during remedial
activities will be monitored for compliance with Clean Air Act (40 CFR Parts 50
and 61) and Pennsylvania air quality regulations (25 PA Code, Chapters 123,
127, and 131). Clean Water Act (40 CFR Part 122) and Pennsylvan,ia (25 PA
Code, Chapter 92) direct discharge. standards would be. met by the. Site
structures remediation. .
locatlon-Speciflc ARARs - Remediation of the Site structures will be' conducted
in accordance with the Federal Floodplains Management and Executive Order
. (E.O: 11988). .
.
. Other Criteria, Advisories, or Guidance to be Considered- In determining that
. inc;inerator arsenic emissions levels present acceptable carcinogenic and.
. noncarcinogenic risks. to the nearby community, EPA used advisory levels and
guidelines that are 'o-be-consideredM for the remedial actions.. These are:.
EP A-established reference dose for arsenic. ..
EPA-establishedcarcinogenic potency factor for arsenic.
. .
The selected. remedy satisfies. the CERCLA preference' for remedies that'
incorporate treatinent as a principal component.
COST-EFFECTIVENESS
. .
The estimated present worth cost of the selected remedy for au Two is. $45,800,000. EPA and
the. Commonwealth of Pennsylvania believe the selected remedy is cost-effective in mitigating
the risks posed by the OU Two materials in a reasonable period of time (an estimated 36
. months) and meets all other requirements of CERCLA. Because the. majority of organic
contaminants present in the OU Two materials will be destroyed, the metal contaminants in the
RCRA-listed wastes (following treatment) and wastes exhibiting the arsenic and 'cadmium
toxicity characteristics Will be treated to reduce mobility, and the treated and untreated.
nonhazardous (Iow-level threat) wastes will be disposed in an appropriate landfill (or salvaged.
as appropriate). the selected remedy affords a high degree 01 long-term effectiveness and
. permanence. Although the no-actionalternatives, the excavation!landfill alternatives, and the
enhanced solidi containment system alternative can be implemented at lower costs, these
alternatives do not Provide 10r permanent treatment and are not as effective in protecting
. hunian health and the environment In addition, the no-action alternatives and the enhanced
. solids containment system alternative do not meet ARARs; the excavation/landfill alternatives
with offSite disposal for the vault wastes and Site structures do not meet ARARs; and the
. excavation/landfill alternatives with offSite disposal will not meet ARARs after May 8, 1992 fer
. the lagoon wastes and miscellaneous products/feedstocks.
58
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D.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating all of the OU Two materials that are considered listed hazardous wastes (following
treatment by incineration and/or fixation) or exhibit the RCRA toxicity characteristic, the selected
remedy addresses the principal threats posed by the OU Two materials through the use of
treatment technologies. Therefore, the statutory preference for remedies that employ treatment
as a principal element is satisfied.
E.
UTIUZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT (OR
RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM EXT~NT PRACTICABLE.
EPA and the Commonwealth of Pennsylvania have determined that the selected remedial action
represents the maximum extent to which permanent solutions and treatment technologies can
be utilized while providing the best balance among the other evaluation criteria. Of the
alternatives that are protective of human health and the environment and meet ARARs, EPA and
the Commonwealth of Pennsylvania have determined that the selected remedy provides the
best balance of trade-offs in terms of long-term effectiveness and permanence; implementability;
short-term effectiveness; reduction in toxicity, mobility, or volume through treatment; state and
community acceptance; and the CERCLA preference for treatment of the OU Two materials.
The selected remedy addresses the principal threats posed by the OU Two materials. The
remedy is protective of- human health and the environment, meets ARAAs, incorporates
treatment as a principal element; and is cost-effective. The major tradeoffs that provide the
basis for the selection decision are implementability, cost, and short-term effectiveness
Because of the unproven nature of microencapsulation technology on the arsenic and organic
contaminants in the upper vault wastes, the selected remedy is more reliable than alternative
combinations that include microencapsulation of these wastes. Ttie selected remedy is more
cost effective than other ~lternative combinations that are protective, incorporate treatment.
meet ARAAs, and are equally reliable. There is less short-term risk associated with the selec:ec
remedy than for those alternative combinations that inctude thermal treatment (incineration :r
vitrification) of the lower vault wastes and/or the lagoon wastes. Therefore. the selected remecy
was determined to be the most appropriate remedy for Operable Unit Two at the Whitmoyer
Laboratories Site.
\
X. EXPLANAT10N OF SIGNIFICANT CHANGES
The Proposed Plan for Operable Unit Two at the Whitmoyer Laboratories Site was released ':r
comment in AprIl 1990. The Proposed Plan identified EPA's preferred alternative. E=;'
reviewed all of the comments submitted during the public comment period. Upon review :~
these comments, it was determined that no significant changes to the remedy, as it ...as
originally identified in the Proposed Plan, were necessary. .
59
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Appendi~ A
IU»P~ICA8LE 0' RELRYAIr!' AND APPROPRIATB "BOOIRJfIBIft'S
OPERABLB UNIT"'" .. . .
~1'lIIOYBR LABORA'rORIBS S."'a.
Stantard, ~equire..nt,
Criterion or Li.itaU.n
~.o~l-8D8clfic ._.~
.cIA Ba.a~dou. .a.te
IdentU icatlon
".a~dou. ...te Identification
Clean Air Act (CAAt AI~
""don.
CAA Air ..i..ion.
:\..
Air QualitJ .egulatlon.
Clean .ate~ Act Di.cha~,e
'tanetard.
Direct di.charge .tandard.
Locati..-8Decific .....
rederal rloodplaln. .anage..nt
CHaUon
.0 cr. Part 261
25 PA Code, Chapter 261
.0 cr. Part 50
. ..0 cr. Part 61
25 PA Code, Chapter.
121, 121 and.l]l.
.0 cr. Par t 122
25 PA Code, Chapter '2
..acutive Order 11'"
o.8cr!Dt!on
.cIA re,ulatlon. for ha.ardou8
.a.te identification
..nn.Jlvanla regulation. for
ha.ardou. .a.te Identification
.atlonal -.blent Air QualltJ
Standard.
.atlonal ..I..lon. Standard.
for Ba.ardou. Air Pollutant.
Penn.Jhania air quality.
regulationa
Clean .ater Act .tandard. for.
direct dl.charge.
.enn.Jlvanla direct dl.char,e
.tandard.
rederal floodplain. ..nage..at
regulation. .
D18cu88toa
!~
All _die
'.. ,'j
, :.t
'f
A11 -.dIe
All -.die
Incineration and
vitrification option.
onl,
All _die
Site atructure. .-diu.
onl,
Site .tructure. ..diu.
onl,
lite atructur.. ..diu.
onl,
-------
Appr Ii. A
APP: IUILE OR RELEVIUft' AND APPROPRIATE RBOUIRBlmtl.rS
OPEROLB UNIT TWO - . . .. . -
IIIIlftIOYBR ~'!'ORIES SITE
Page ~
Standard, Require..nt,
Cr: ',ter Ion orL181t8Uo,
Actl..-8D8eiflc a.a~.
IeRA Structurea Cloaure
IeRA Incineration
IeRA Niacellaneoua 7reat.ent
u.s.. Depart.ent of
Tran.portation (DOT) Wa.te
7ranaportation
RCRA Ha.ardou. Wa.te
Tran.portation
Waate Tranaportation
Occupational Safet, and Heaith
Ad8iniatration (OSBA) Aabeato.
Nanage..nt
08.. MOr.er Protection
.c.. Land Dlapoaal Reatrlction.
IeRA Ha.ardou. Wa.te Landfill
Citation
410 CPR Part 2641,
Subpar t G
410 cn Part 2641
Subpart 0
410 CPR Part 2641,
Subpart I
419 CPR Part. 107 and
171-179
410 CPR Part. 262 and
26]
. 25 PA Code" Chapter- 26]
2t CPR Par t 1926
29 CPR Part. 19041,
1910, and 1926
410 CPR Part 268
410 CPR Part 2641,
Subpart N
Doac ri Dtion
leRA regulaU,on. for cloaure
of atructures
leRA regulation. for ha.ardou.
.a.te Incinerators
leRA regulations for
.i.cellaneou. treat..nt units
DOT regulation. for .aste
transport
leRA regulations for the
tran.port of ha.ardoua .aate'
Penn.,l.ania regulation. for
.aate tran.portation
OSHA regulation. for aabe.to.
ra..al
OSHA regulation. for the
protection of .orker.
RCRA re.triction. on the land
di.po.al of hazardous .a.te
RCRA requlre.ents for .olid
.a.te landfi I h
Dhcu....,
Site .tructure. ..diu.
onl,
Incineration option.
onl,
Phation and
vitrification option.
All -dia
All ..dia
All _dia
Site atructurea -.diu.
onl,
All ..dia
All _dia
All .edia
-------
AppendiJr A
APPLJCA8L.E OR RELEV~ AND APPROPRIA~E~BOUI~S
OPBRABLB UNIT TIIO . .. .
IRIIftIOYBR I.A8ORA~IES S:rTE
Page Thr.. .
Standard, aequire.nt,
Cr I ~.r Ion or Lt.l.t,Uoa
Ictt..-8aeclflc...... tee.t'.)
IeIA 80lld .a.t. Landfill
lolld ...te Kanag...nt
.ro.ion Control
ReRA Landfill Clo.ure and
P08t -Cl08ure .
CltaUon
ReM Subtl Ue D
"
25.~ Code, Chapter 25
. '.
"'~criDt~on .
RC~ requlre..n~. for .olld
..ane landfUli
Criteria for dUDg and
.0peraUng landfU18
25 P. Code, Chaptel' 102. .I'08,l.on contl'ol Uait. on
. ..ca.aUon act hltle.
40 cra Part 264
ReRA regulation. for landfill
cl08ure.and po8t-clo8ure
. .
DIaCU88i..
all ..dla ..cept the
.ault aedlua
all ..dla
au _dla
all ..dla
-------
RESPONSIVENESS SUMMARY
. OPERABLE UNIT TWO
WHITMOYER LABORATORIES SITE
JACKSON TOWNSHIP, LEBANON COUNTY, PENNSYLVANIA
From April 16, 1990 through December 3, 1990, the U.S. Environmental Protection Agency
(EPA) held. a public comment period on the Proposed Plan and the Remedial
Investigation/Feasibility Study (RI/FS) for Operable Unit Two of the Whitmoyer Laboratories Site
in Lebanon County, Pennsylvania. This responsiveness summary summarizes comments on
the Proposed Plan. and RI/FS pertinent to Operable Unit Two that were expressed by local
officials, state officials, and other interested parties; and provides EPA responses to the
comments. .
This responsiveness summary is divided into the following sections:
* Overview . .
A.
*
Background on CommunitY Involvement
*
Summary of Comments Received during Public Comment Period and Agency
Responses
*
Remaining Concerns
OVERVIEW
At the time of the public comment period, EPA had already identified a preferred alternative fer
Operable Unit Two of. the Whitmoyer Laboratories Site.. EPA's recommended alternat:'.e
addressed the vault wastes, lagoon waste, miscellaneous products/feedstocks, and structures
at the'site: The preferred alternative specified in the Record of Decision (ROD) for Operac e
Unit Two involves:
*.
surface cleaning of the site structures which have surface contamination;
*
remediation of dangerous conditions existing in buildings outside of the BUIIC,,;
1-7 complex;
*
demolition of the Building 1-7 complex and all tanks, vessels, piping, process
equipment, and outdoor tank concrete dikes;
*
incineration followed by fixation and offsite disposal for the upper vault wastes
hazardous miscellaneous products/feedstocks, and hazardous com bu s:! c. e
demolition debris;
*
fixation of the lower vault wastes and hazardous lagoon wastes, followed :.
offsite disposal; - -
-------
/
*
coating and sealing the noncombustible, permeable hazardous demolition debris,
101l0wed by offsite disposal;
*
surface cleaning the noncombustible,impermeable hazardous demolition debris,
followed by o11site disposal; .
*
salvaging nonhazardous dem91ition debris,' as feasible; and
disposal oP the nonhazardous miscellaneous' products/feedstocks, the
nonhazardous lagoon wastes, and the nonhazardous demolition debris tha~ is
not salvaged in offsite landli11(s).' .
*
..:.,..
The community did not submit any' comments. on the prelerred alternative. The Jackson
Township Board 01 Supervisors is opposed to the incineration of the upper vault wastes onsite.
The present owner 01 a property that contains some 01 the lagoon wastes (Buckeye Pipe Line
Company) questions EPA's recommendation of excavating, fixating, and disposing the lagoon
wastes offsite. They also question the prudence and cost-effectiveness 01 onsite incineration
of the upper vault wastes. The former site owners, Rohm & Haas and Smith Kline Beecham,
support the alternatives of excavating the Operable Unit Two materials and either placing them
in a landfill onsite or hauling them offsite for landfill disposal. The onsite landfill proposed by
the: former owners would be designed to meet or exceed existing landfill requirements and
would be constructed with multi-layer liners and caps. This alternative, however, does not meet
Commonwealth 01 Pennsylvania siting requirements for either hazardous or residual waste
landfills. No treatment of the wastes would occur under either 01 the alternatives' preferred by
the former owners. .
B.
BACKGROUND ON COMMUNITY INVOLVEMENT
. There has been consistent community interest in the Whitmoyer Site since its proposal for
listing in 1984. Public meetings continue to attract approximately 50-70 local residents as well
as most major local media. In spite of this interest, however, there have been no attempts to
. organize any formal special interest groups to address the Site or . apply for a Technical.
. Assistance Grant. . ..' . '.'
Further, with respect to Operable Unit Two, there has been little community interest in the
remedy proposed by EPA for that Operable Unit. Nonetheless, this responsiveness summary
in addition to responding to comments formally submitted, will also address issues raised by
the community at the public meetings for Operable Unit Two.
While this appears to remain true for the local citizenry, concern 01 local officials over EPA,'s
proposed plan for Operable Unit 2 has been more apparent. This is evident in some very
precise questioning from local officials and a formal request for an extension of the public
comment period. Much of this Responsiveness Summary addresses these concerns directly
2
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C.
SUMMARY OF COMMENTS RECEIVED DURING PUBUC COMMENT PERIOD AND
AGENCY RESPONSES
Comments raised during the public comment period for Operable Unit Two of the Whitmoyer
Laboratories Site are summarized below. EPA responses to the comments are provided. The
cOll1ments are categorized by relevant topics.
Consideration 01 Offsite Landfilling Alternative
1.
As noted above, the former Whitmoyer Laboratories, Inc. owners urged EPA to consider
offsite disposal without treatment for the vault wastes, lagoon wastes, and miscellaneous
products/feedstocks. They stated that offsite disposal without treatment was not
included in the Feasibility Study (FS) alternatives..
EPA Response: Offsite disposal without treatment was an FS alternative for the lagoon
wastes, miscellaneous products/feedstocks, and site structures (in all cases, Alternative
28). This alternative was considered in detail in the FS and was included in the
Proposed Plan for public comment. In fact, the remedy selected by EPA for Operable
Unit Two includes offsite disposal without treatment for all nonhazardous lagoon wastes
and miscellaneous products/feedstocks, and the non-hazardous site structure demolition
debris which is not salvaged.
~". ;
, ;"
EPA did not develop in the FS the alternative of oftsite disposal without treatmenUor
the vault wastes, because, at the time 01 the FS report and Proposed Plan preparation.
doing so would not comply with the Resource Conservation and Recovery Act (RCRA)
land disposal restrictions (LORs), further set forth at 40 CFR Part 268, in effect at the
time (Le., would have been illegal). (The vault contains K084, K101, K102, 0004. and
D006 wastes). On May 8, 1990, EPA revised the LORs to allow offsite landfilling of the
vault wastes without treatment until August 8, 1990. . After that time, landfilling without
treatment of the vault wastes would again not comply with LORs. Since offsite disposal
of the vault wastes without treatment could not be completed prior to that date. this
alternative does not comply with the applicable LOR regulations. EPA has determined
that a waiver of this applicable regulation is not justified, as no treatment 01 the principal
threats at the site would occur under this alternative and an acceptable method:f
treatment is available. .
EPA has also considered in detail the alternative of oftsite disposal without treatment .::
the hazardous lagoon wastes, (0004 wastes), miscellaneous products/feedstocks. arc
site structures (0004 and DOOS wastes). Offsite disposal of these wastes withcLt
treatment can legally occur until May 8, 1992. However, EPA has not selected th's
alternative as the remedy for these materials, because, unlike the selected remecy.
which immobilizes the waste through fixation, thus preventing leaching, the owne~s
alternative. simply relocates the untreated wastes thus leaving them subject to leach" ~
of hazardous materials. This potential for leaching and migration of the hazardous
materials clearly makes the owner's alternative less effective in the long-term, and less
permanent since this offsite alternative also does not comply with the CERC~:"
preference for treatment.
.3
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The former Whitmoyer Laboratories, Inc. owners commented that all of the lagoon
wastes should be managed as if they are non hazardous wastes under RCRA, since
" some of the wastes are only marginally hazardous. "
2.
EPA ResDonse: Wastes that exceed TCLP regulatory levels are RCRA Subtitle C
"hazardous wastes" and must be managed pursuant to RCRA Subtitle C and related
regulations. Wastes that do not exceed TCLP regulatory levels, and are not otherwise
RCRA Subtitle C hazardous wastes do not have to comply with the aforesaid statute and
regulations. """ "
3.
The former owners commented that the presence of cadmium in the upper vault wastes
would n"ot alter the applicability of the LDR national capacity variance for arsenical
wastes to the upper vault wastes.
EPA ResDonse: This comment is incorrect. Land disposal of the upper vault wastes is
: "". ..- restricted after August 8, 1990, the day that cadmium LDRs took effect.
Consideration of the Onsite Enhanced Solids. Containment System
The owner of the property which contains some of the lagoon wastes (Buckeye Pipe
Line Co. L.P.) commented that placement of the untreated vault and lagoon wastes in .
the onsite enhanced solids containment system, as proposed by the former owners, is
a technically satisfactory solution, particularly if clay is used. instead 01 aggregate. to fill
cracks in the rock surface. "
4.
"EPA ResDonse: EPA gave serious consideration to" the onsite enhanced solids
containment system proposed by the former owners. While this alternative is less costly
than the selected remedy, EPA believes that the selected remedy is cost-effective in
mitigating the risks posed by the OU Two materials in a reasonable period of time (an
estimated 36 months) and meets all other requirements 01 CERCLA.Because the
majority 01 organic contaminants present in the OU Two materials will be destroyed
under the selected alternative, the metal contaminants in the RCRA-listed wastes.
" . (following treatment) and' wastes exhibiting the arsenic and cadmium toxicity'
characteristics will be treated to reduce mobility, and the treated and untreated'
nonhazardous (low-level threat) wastes will be disposed in an appropriate landfill (or
salvaged, as appropriate), the selected remedy" affords a high degree of long-term
effectiveness and permanence. Although the enhanced solids containment system
alternative can be implemented at a lower cost, this alternative is less protective of
human health and the environment, is less effective in the long-term and is less
permanent as it does not involve treatment 01 the principal threats posed by this
operable unit;. does not reduce toxicity, mobility, or volume through treatment; and does
not comply with the CERCLA preference lor treatment. In addition, the enhanced soli~s
containment system alternative does not comply with the applicable Pennsylvania siting
requirements. Given these considerations, the selected remedy was chosen by EPA
instead of the onsite enhanced solids containment system alternative.
~
4
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I~
Roasting of the Upper Vault Material
'J.
The former owners commented that the use of roasting on the upper vault material will
endanger human health and the environment. The Jackson Township Board 01
Supervisors and State Senator David J. Brightbill also expressed concerns about this
possibility .
EPA Response: The remedy selected by EPA is a roasting that meets all RCRA, NAAQS,
and NESHAPS requirements and that is demonstrated to be safe during the remedial
design phase of ROD implementation. In response to the public concerns expressed
about the risks of roasting. EPA refined its preliminary estimates of arsenic emissions
and risks to human health from the roasting program. The results of this evaluation are
presented in a technical memorandum entitled "Arsenic Volatilization, Capture, and
Risks Resulting from Incineration of the Upper Vault Waste" (Ebasco Services Inc..
September 1990). hereafter referred to as the upper vault waste incineration technical
memorandum. (This document is available in the Myerstown Public Library.) This
evaluation concluded that, under reasonable exposure scenarios. the incremental risks
of contracting cancer because of the upper vault waste roasting program would be
significantly less than 1 in 1,000.000. EPA believes that this is well within the range of
carcinogenic risks which are protective of human health. Noncarcinogenic risks were
also calculated to be well within the acceptable range. Thus. only minor, acceptable
risks should result from the upper vault waste roasting program. Further, the ROD
discusses performance standards for the roasting remedy which are designed to keep
the risks at acceptable levels. More specifically, the ROD at page 29 states roasting
would be performed in accordance with RCRA 40 CFR Part 264, Subpart 0 standards.
The specific type of roasting process would be determined in the Remedial Design
phase through engineering design and analysis and the competitive bidding process.'
The roasting unit would be mobilized, operated. and closed according to the
requirements of RCRA. Part 264, Subpart O. 40 CFR 264.340et sea. Specific operating
practices necessary to meet the performance objectives, including a 99.99 percent
destruction and removal efficiency (ORE) of stack emissions for organic contaminants
as required by Subpart 0 of RCRA would be determined through a trial burn 01 upper
vault waste prior to any full scale roasting at the Site. Specialized air pollution control
equipment would be applied during the roasting step to capture contaminants in the
exhaust air and thus ensure compliance with the relevant and appropriate National
. Ambient Air Ouality Standards (NMOS) (40 CFR Part SO) and National EmisSions
Standards for Hazardous Air Pollutants (NESHAPS) (40 CFR Part 61, Subpart N).
EPA recognizes there are uncertainties associated with the upper vault waste roasting
program. For this reason, EPA plans to conduct test burns at a pilot-scale testing
facility (possibly the EPA Incineration Research Facility in Arkansas) and trial burns using
the full-sCaJe roaster (incinerator) prior to start-up of the remediation. Only if the results
of these tests confirm that roasting of the upper vault wastes can be condl:Jcted while
adequately protecting human health and the environment will EPA proceed with the full.
scale roasting program.
5
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,7.
6.
The former owners commented that the 'est burn" necessary for design of the upper
vault waste roasting system would be conducted ~t the Whitmoyer Site. .
EPA ResDOnse: This "test burn" will likely be conducted at an offsite research facility
. such as the EPA Incineration Research Facility in Arkansas. ' .
The former owners commented that the risk assessment methodology used in EPA's
" refined assessment of the risks associated with upper vault waste roasting (as presented
in the. upper vault waste incineration technical memorandum) is contrary to standard
Superfund methodology. If different assumptions were utilized in the exposure
scenarios, very significant risks to human health from the proposed roastin'g may have
been predicted by the assessment. j . '.
EPA Response: The methodology used in the refined assessment of risks associated
with upper vault waste roasting is consistent with current EPA guidance, as eXDressed
in "Risk Assessment Guidance for. Superfund, Volume I, Human Health Evaluation
Manual (interim final)" (EPA, December, 1989).
Furthermore, the refined risk assessment included many conservative assumptions. For.
examplehhe risk was calculated assuming a person resided at the point of maximum
. stack fallout, even though the modeling showed this point to be in an open field. Also,
, the cancer risk calculations use a cancer' potency factor for arsenic which has been
conservatively derived by EPA, so that it would be very unlikely that the estimated'
'cancer risk from an exposure would be underestimated. Given.. conservative
assumptions such as these inherent in the tefined risk assessment methodology, It !s
unlikely that .the risk to the community from roasting of the upper vault wastes IS
underpredicted by the refined assessment.
. .
The 'remedy selected by EPA is a roasting that meets all RCRA, NMOS, and NESHAPS
requirements and that is demonstrated to be safe during the remedial design phase cl
ROD implementation~ Consequently,concerns raised about the safety of roastingc~c'
. not pertain to the safety of EPA's selected remedy,- as that remedy, by its owns ter~s
is safe; concerns raised about the safety of roasting, rather, pertain to the feasibility cl
implementing EPA's selected remedy. Although the former owners have criticized the
refined risk assessment, they have not demonstrated that implementation Of E PA s
selected remedy is infeasible. EPA believes that it has sufficient information at this ::n"',e
to believe that implementation of its roasting remedy will be feasible. The refined rs"
assessment is only one component of that information.
Additionally, EPA believes that the 12 inch soil mixing zone used in the risk assessme,:
for the incineration option is not unreasonable given the potentially soluble nature of !f'i?
. fallout constituents. .
. {'
8.
The former owners commented that roasting would increase the toxicity of the treate:
. wastes by converting any organic arsenic compounds in the wastes to more tC)
inorganic arsenic compounds.
6
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9.
10.
11 .
EPA ResDonse: The particular organic arsenic species, if any, in the upper vault wastes
have not been identified. It is possible that the organic compounds present are more
toxic .than inorganic arsenic.
Even though organic arsenic forms will likely be converted to inorganic arsenic under
the selected remedy, the advantages of the selected remedy (e.g., destruction of organic
contaminants and immobilization of arsenic) far outweigh this potential drawback.
The former owners (in "Comments of the Whitmoyer Laboratories Private Study Group
on the NUS/Ebasco Final Technical Memorandum Regarding Arsenic Volatilization,
Capture, and Risk," Environ, December 1990) commented that a lower arsenic inhalation
absorption factor was used in the upper vault waste incineration technical memorandum
risk assessment than in the FS risk assessment, with no technical basis for making this
"arbitrary" reduction. The result of this reduction is to reduce the estimated level of
inhalation. risk.
EPA ResDonse: The risk assessment presented in the upper vault waste incineration
technical memorandum utilized the most recently available inhalation absorption factor
(EPA Integrated Risk Information System, September 1990). This absorption factor was
,also recognized by the former owners in their document "Comments on ,Risk
Assessment Issues for Operable Unit 3 of the Whitmoyer Laboratories Site". Karch and
Associates, Inc., September 1990. ' -
The former owners commented that the estimate presented in the FS report and the
upper vault waste incineration technical, memorandum that the average arsenic content
of the upper ,vault waste is 12% is not supported by the existing data, and that a 21 %
concentration may be more accurate.
EPA ResDonse: The EPA estimate of a 12% arsenic concentration was derived by
considering all available information. It appears that one of the data points used by the
former owners in their calculations is an outlier. This sample result (75% arsenic) could
only be obtained if either metallic arsenic or pure arsenic trioxide was present in the
vault. These substances were not known to be used or generated at the Site. Thus.
the true arsenic concentration for this particular sample is likely to be much lower.
Also, the upper vault contains significant quantities of soil. During the.1964-65 cleanup.
soils with concentrations as low as 0.3% arsenic were placed in the vault. Given this
information, EPA believes its estimate is reasonable.
The former owners commented that the estimate presented in the upper vault waste
incineration technical memorandum that only 5% of the arsenic placed into the upper
vault waste incinerator would volatilize lacks a solid scientific foundation.
EPA ResDonse: This estiiT'late was derived using all available scjentific data. While no
treatability data were directly collected regarding volatilization of arsenic during roasting
01 the upper vault. wastes, there is sufficient evidence that calcium addition prior to
roasting will likely result in 5% or less of the arsenic volatilizing. Calcium addition during
roasting tests conducted as a part of the lower vault waste treatability study inhibited
7
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arsenic volatilization; betWeen 0 and 9.2% of the arsenic volatiUzed during the tests.
These results were achieved despite the fact that the lower ,vault waste sample
submltt8d for treatabiUty testing purposely contained some still bottom wastes from the
upper vault, to present a worst-case.treatment scenario. Five percent volatilization was
selected as a conservative assumption, since better results were achieved during the
testing, even though. no optimization attempts to minimize: arsenic volatilization were
made." . . .' .
The five percent assumption is also supported by results achieved at other similar
settings. Only between 2% and 7% of the arsenic present in the feed yolatilized dUring
incineration 01 sludge in a mobile incinerator at Denney Farms, Missouri (''The F ate of
Heavy Metals in EPA's Mobile Incineration System"; J. P.Stumbar et aI., September'
. 1989, pr~sented at the 1989 International Symposium on Combustion in ,'Industrial
Furnaces and Boilers). 'Incineration testwork on arsenic-oo, '\tamin, ated soil from the Baird
and McGuire Superfund Site indicated that the addition ~f excess. calcium inhibited
arsenic volatilization ("Pilot-Scale Incineration of Arsenic-Contaminated Soil from the Baird
and McGuire Superfund Site", EPA, May. 1990). No attempt t6' optimize retention of
arsenic in the ash was made, however. (Robert Mournighan, EPA-ORD. See "Summary
of Whitmoyer Laboratories Meeting of November 30,1990" (EPA memo)). Incineration
.testwork conducted by the EPA Incineration .Resear~h Facility on a syntheti~ waste
mixture containing arsenic and other metals in a . clay matrix revealed that between only
3.2% and 11.2% of the arsenic present i.nthe feed (normalized data) volatilized' during
incineration (liThe Behavior of Arsenic in a Rotary Kiln Incinerator"; A. C. Thurnau, August
, 1990, presented at the 21 st Annual Meeting of The Fine., Particle Society, American
: Institute of Chemical 'Engineers). ,In these last two studies; it was noted that. arsenic
. volatilization increased with increasing temperature. The proposed upper vault waste
roaster (incinerator) will operate at relatively low temperatures (around 6000C to 700°C)
Finally, research conducted at the Montana College of Mineral Science and Technology ,
showed that calcium addition led to high arsenic retentions (better than 97%)' during
" high-temperature smelting operations. Formation of relatively insoluble calcium arsenate
during this work was confirmed. by x-ray diffraction (" Fixation of. Arsenic in Copper
. Smelter Flue Dust", A. K. Mehta, Master's thesis). . .
. 12.
. . .
. ~ . .
A more precisears~nic volatiUzation. rate: will be obtained during the remedial. design
phase of ROO' implementation, during the test burns of the upper vault ,waste. ThiS
information will be used byEPA in its decision whether to proceed with implementation
of the roasting remedy, which, as noted above, requires the roasting to be periormed
safely and incompliance with all RCRA,NAAQS, and NESHAPS requirements: " '
In their comments, the. former owners stated that cement/lime addition to the vaL;~t
. wastes prior to roasting was not contemplated. in the Proposed PI~n. '
1--
EPA ResDonse: This is not the case. Cement/lime addition to the upper vault wastes
prior to roasting was a part of the preferred alternative suggested in the Proposed Plan
and is a portion of the selected remedy.. ".'. .
8
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13.
14.
15.
The former owners questioned whether calcium could be effectively mixed with the upper
vault waste prior to introduction into the roaster (incinerator).
EPA ResDOnse: EPA believes that excess calcium could be effectively mixed with the
waste using conventional materials handling equipment (e.g., a pug mill). The exact.
mixing system to be used will be identified during the Remedial Design and through the
competitive bidding process. If necessary, the tarry still bottoms present in the upper
vault waste could be preheated to reduce their viscosity prior to mixing.
The former/owners commented that the absence of existing calcium-arsenic compounds
in the upper vault waste as compared with the lower vault waste may lead to significant
arsenic volatilization. .
EPA Response: EPA believes that adding calcium (cement and/or lime) to the upper
vault wastes prior to roasting in excess of stoichiometric requirements will result in the
inhibition of arsenic volatilization. This belief will be confirmed during test burns and trial
burns to be conducted prior to the start-up of full-scale remediation.
The former owners commented that the EPA estimate of 99.3 percent arsenic removal
in air pollution control devices is unsupported. EPA acknowledged that there is no
known air pollution control device for capturing arsenic particulate emissions in a 1986
Record of Decision for the Pepper's Steel Superfund Site. The FS report stated that
vapor-phase arsenic is not captured by any known air pollution control equipment.! The
arsenic removal efficiency. data cited by EPA in their upper vault waste incineration
technical memorandum are marketing predictions with little scientific or technical basis.
Available data indicate that removal efficiencies for volatilized arsenic are in the 85%
range.
EPA Response: EPA believes that there are several effective techniques for capfuring
arsenic particulate emissions, including electrostatic precipitators, baghouses, '" high
efficiency particulate filters, and packed tower absorbers. The FS did not state~ that
vapor-phase arsenic is not captured by any known air pollution control equipment
Vapor-phase arsenic can be removed from exhaust gases using several types of air
pollution control equipment (e.g., packed tower absorbers). . .
The arsenic removal efficiency data cited by EPA in the upper vault waste incineration
technical memorandum consisted of measurements made in pilot-scale incineration units,
full-scale fixed-base incineration units, full-scale mobile incineration units, and operating
copper smelters. The data from the full-scale.units were developed during trial burns
subject to regulatory scrutiny. These data are believed to be valid and demonstrate that
arsenic removals of 99.3% or greater in air pollution control devices are achievable.
The 85% removal data cited by the former owners was from tests conducted on soils
from the Baird and McGuire Superfund Site. In these tests only a one-stage ionizing
wet scrubber was used for pollution control, and no attempts to optimize operation of
this device were made. (Robert Mournighan, EPA-ORD. See USummary of Whitmoyer
laboratories Meeting of November 30, 1990" (EPA memo». For co",!parison, the
9
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Chemical. Waste management Port' Arthur incinerator used a four-stage air pollution
control deviCe. During implementation of the upper vault waste roasting remedy ,the air
pollution control system will likely contair:1 more stages than the system used for the
Baird and McGuire study, in order to achieve the targeted arsenic removal efficiencies.
, If additional stages need to be added to standard mobile incinerator pollution control
syst~ms to meet the removal targets, this will be done. .
16.
The former owners commented that it appears that vendor information supplied by
Ogden Environmental. Services, Inc. (as cited in the upper vault waste incineration
technical memorandum) is the basis for the 99.3% arsenic removal efficiency estimate.
Furthermore, 'the calculation used to derive the 99.3% r~moval estimate contains an
. important error. ,.'.
. EPA ResDonse: This estimate is based on all of the arsenic removal data cited in the
upper vault waste incineration technical memorandum. and not just the Ogden
information. In fact, the, 99.3% arsenic removal efficiency was presented to' Ogden.
. initially as the preli'minary upper removal target (see Appendix 1 of the upper vault waste
incineration technical memorandum).. . .
17.
.EPA agrees that the calculation presented on page. 5 of Appendix 1 of the upper vault
. waste incineration technical memorandum regarding Ogden's bag house removal, .
. efficiency is incorrect. . The calculated 86% removal only applies to partiqulate arsenic.
. Using the same calculations and assumptions presented in the memorandum, the.
.. correct arsenic removal percentage is 98.2%. This indicates that if the assumptions are
. correct, the Ogden system is used to conduct the roasting, and a 99.3% arsenic removal
efficiency is targeted, Ogden would have to demonstrate a higher removal efficiency
using their suggested air pollution control devices than reported, or they would have to '
add on additional air pollution control devices to meet the target.
'The former owners commented arsenic removal effici~ncies at Whitmoyer may be much
different than historical arsenic removal efficiencies measured from other operating
incinerator air pollution, control devices, since the feed arsenic concentration will be
much higher. .
18.
EPA ResDonse: While it is true that other historical data were obtained fr9m the
, incineration of wastes with lower arsenic concentrations, arsenic removal efficiencies are
not expected to be substantially different. (R. E. Mournighan, ,"Comments on PRP
Presentation on Whitmoyer Superfund Site 11./2/90 at Region III Office). For example
copper smelters typically have elevated arsenic concentrations in their feed, and their
removal efficiencies are comparable with incineration data. The effectiveness of the air
pollution control system will be verified during test burns and trial burns prior to start.
up of the full-scale upper vault waste remediation. .
The former owners commented that, for many of the studies cited by EPA, a mass
balance was not obtained, and that the arsenic not accounted for may have been
emitted as a vapor. If this is the case, and arsenic emissions are much higher than
10,
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19:
20: .
21..
reported, the risks due to roasting may be' underpredicted by the upper vault waste
incineration technical memorandum. '
EPA Resoonse: For incineration studies, closure of a mass balance within +20% is
considered good. In evaluating the studies, EPA believes the arsenic not accounted for
is present within the incineration system as a coating on the walls, and did not escape
as a vapor. The efficiency of the arsenic vapor measurement system was verified during
quality assurance/quality control tests run during the studies. (Robert Mournighan, EPA-
ORO. See "Summary of Whitmoyer Laboratories Meeting of November 30, 1990" (EPA
memo)). Therefore, EPA believes the use of normalized data from these studies is
appropriate. . .
The former owners impliec;t in their comments that the FS predicted 15,300 pounds of
arsenic would be released into the air during roasting of the vault wastes.
EPA Response: The FS did not predict that 15,300 pounds of air would be released
into the air during roasting. Rather, this worst-case estimate was generated to
demonstrate that substantial quantities of arsenic could be released into the atmosphere
if the air pollution control system was improperly designed or operated. In their
reanalysis of the risks posed by upper vault waste roasting, EPA calculated a likely
arsenic release estimate of 400 pounds (see the upper vault waste incineration technical
memorandum). ' .
The former owners commented that the FS stated that the use of an air pollution control
system such as that in use in the New Consort Plant "may not be achievable [at ,the
Whitmoyer ,site] using available technology" (FS, pg. 4-21).
EPA Response: The former owner comment is a misquote. The FS did not indicate that
use of the New Consort Plant system "may not be achievable"; rather, the FS stated that
a 700F offgas temperature may not be achievable. If the New Consort plant design IS
determined to be the optimal air pollution control system for roasting of the upper vault
wastes, use of that system is readily achievable. -
The former owners implied that a system identical to the New Consort air pollutlcn
control system will be used at Whitmoyer during the roasting of the upper vault. anc
commented that safe operation of this system is very unlikely.
EPA Resconse: The New Consort system was only cited in the FS as an example~f
an air poDution control system that could be used at Whitmoyer to reduce air emissicr.s
to acceptable level$; it is not described as the'system that EPA will use. The exact a'f
pollution controls system to be used at the Whitmoyer. Laboratories Site will ce
determined during the Remedial Design for the vault waste remediation. That syster;;
will be designed to meet the performance standards discussed in response #5 above
. Any system chosen will be tested in a trial burn to ensure safe operation at the Site. anc
subsequent operation will be'monitored to maintain the performance standards spec:fiec
above.
11
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22.
. The former owners commented that products of incomplete, comburstion (PICs)
generated -during roasting could present a significant risk to human health and the
. environment. . . .
. .
EPA ResDonse: CurrentEPA regulatory guidance recommends that all hazardous waste
incinerators be required to operate at carbon, .monoxide levels below' 1 00 parts per
niillion volume on a 1-hour, average. This guidance will be followed at the Whitmoyer
Laboratories Site. All evidence compiled to date by EPA indicates that PIC emissions
will not pose a significant health risk when carbon monoxide emissions are below this
level. ("Guidance on PIC Controls for Hazardous Waste Incinerators", EPA, April 1989).
23;
, .
The former owners commented that roasting of the upper vault wastes. will likely result
. in the formation, and release of highly toxic byproducts, including arsine gas and'
nitrogen oxides. According to the .former owners, the upper vault waste incineration
technical memorandum underestimates nitrogen oxides emissions by at least fifty times.
.'
. ..
EPA ResDonse: Although it is possible that arsine gas may form as an intermediate at
some point in the combustion (roasting) reaction, it is unlikely that significant
concentrations.' would escape the highly turbulent oxidizing atmosphere of the
incinerator's secondary combustion chamber. '.
. ' Nitrogen oxides are produced by all combustion processes. Emissiqns from a well
operated incinerator consist almost exclusively of nitric oxide (NO) and nitrogen dioxide
(N02)' Although these compounds do cause adverse health effects at relatively high
concentrations, it is misleading to characterize them as Hhighly toxic". No adverse health
effects from nitrogen oxides would be expected from the roasting of the upper vault
wastes. '. .
~..' '. '.'<--
Overall, nitrogen oxides treatment'requirements are risk- and ARAR-driveri.. Without any.
nitrogen oxides treatment, the modeled maximum quarterly concentrations for nitrogen
,oxides is 17 ug/m3. This figure is much less than the comparable annual average
. nitrogen oxides standard of 100 ug/m3 under the Clean Air Act. '. : '. '.
, Air pollution control devices utilized for arsenic removal (e.g., packed tower absorbers)
w'ouid also be expected to remove the majority of nitrogen oxides volatilized during the
roasting step. The ability of wet scrubbers to remove nitrogen oxides will be evaluated
during the test and trial burns. If'determined necessary, other' nitrogen oxides air
'poliution control devices (e.g;.'catalytic systems) can be considered.
.24.
The former owners commented that the FS report and the upper vault waste incineration
, technicat memorandum did' not address,the potentially high sodium content of the
waste. If high ,concentrations of sodium are present in the upper vault wastes, the
tendency of sodium to "glassify" could result in reduced arsenic removal efficiencies in
the air pollution control devices, resulting in higher arsenic emissions than predicted.
. '
EPA ResDonse: While glassification (slagging) problems are possible, there are several.
factors particular to the Whitmoyer roasting (incineration) remedy which indicate that this
12
I
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is not a concem. The first and most important factor is that slagging and volatilization
are temperature dependent. The temperature ItO be employed in the primary chamber
during roasting of the upper vault wastes would be approximately eoooc to 700DC. This
temperature is lower than those typically employed in the incinerators (800DC plus)
where slagging problems have been noted in the past. Thus, slagging-related problems
may not emerge at the lower temperatures present in the roasting unit. A second factor
is 'that the operating timeframe of the roasting unit is relatively short (approximately 90
days). Thus, slagging, which typically is a long-term concern, may not present a
problem over such a short timeframe. Ongoing monitoring will be used to detect there
is any decrease in arsenic removal efficiency (from slagging or other causes). Since
slagging-induced degradation (if any) would be slow, corrective actions, such as
equipment ,cleaning or replacement, could readily be implemented. The proposed test
burn and trial burn will be used to identify if slagging is a concern; and, if it is,
corrective measures to address it.
25.
The former owners commented that the stack height used in, the FS to estimate risk to
the offsite community from roasting (65 meters) is questionable, and does not conform
with Good Engineering Practice.
EPA Response: Good Engineering Practice (55 FR 17862) designates that a maximum
acceptable stack height should be the greater of: (1) 65 meters; or (2) the height of a
nearby structure plus 1.5 times the lesser dimension of the height or width of the nearby
structure, to avoid significant adverse aerodynamic effects. Since the greater of these
two terms at Whitmoyer is 65 meters, 65 meters was used in the air emissions modeling,
The actual stack height to be used will be determined during the Remedial D~sign,
26.
The former owners commented that some of the modeling assumptions used in
estimating the atmospheric dispersion and deposition of arsenic emitted from th,e stack
during the proposed roasting, including the validity of the Industrial Source Complex
(ISC) model itself, were faulty, and therefore EPA's modeling effort may significantly
underpredict the risk. For example, in the upper vault waste incineration technical
memorandum, EPA assumed two mean particle diameters, 0.5 microns and 2.0 microns
without apparent scientific basis. Similarly the degree of reflection by particles settling
from the atmosphere are unsupported, and wet deposition of both particulate matter and
vapors was not considered. .'
EPA ResDOnse: The ISC model is a generally accepted model for evaluating incinerator
emissions in flat or rolling terrain such is present at Whitmoyer. For example. EPA
recently used this model for the evaluation of metals emissions from incinerators located
on flat or rolling terrain, in connection with the EPA-proposed standards for restrlct,ng
these emissions (55 FR 17862).
EPA revised the ISC model assumptions presented in the FS report to more accurately
estimate the likely fate of stack emissions. For example, the revised air modeling eHon
was conducted separately with two different particle sizes, 0.5 microns and 2 microns
Historically, metals emissions from high-temperature devices such as incinerators ~a'ie
13
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I
1-
been measured to be around the range of 0.5 microns to 2.0 microns (Air Pollution.
H.W. Parker, P.E.,Prentis Hall Inc., 1977). The degree of reflection by settling particles
is calcul8ted directly by the ISC model. Also, 5 years of meteorological data were used
. in the reftned modeling effort. The effects of wet deposition on the overall deposition
rates 01 arsenic have not been demonstrated to be significant. EP A protocols do not
recommend adjustment of the ISC model for wet deposition. For the expected particle
diameters of arsenic exiting the incinerator stack (0.5 to 2.0 microns), there is evidence
that the effects of wet deposition are negligible ("On the Effect of Electric Charge on th~
. Scavenging of Aerosol Particles. by Clouds and Small Raindrops," P. K. Wang et af.
Journal 01 Atmospheric Sciences,35:1135-1143, as cited in "Incorporation of Wet
Deposition in the Industrial Source Complex ModelN, C. A. Bowman, Jr. et aI., APCA
1981 Annual Meeting). In summary, EPA believes its ISC modeling assumptions
presented in the upper vault waste incineration technical memorandum are appropriate
for site conditions and the anticipated roaster operating conditions. .
27.
The former owners commented that there are no treatability data supporting the cement
fixation treatment of the upper vault incinerator ash, and that this treat;T1ent may actually
increase the amount of arsenic leaching out of this waste. .
EPA Response: While no treatability data were 'directly collected regarding fixation of
. the incinerator ash from the upper vault wastes, there is sufficient evidence supporting
. selection of this technology for remediation, Treatability data from three disparate
Whitmoyer Laboratories Site waste streams (the lower vault wastes, the lagoon sludges,
. and contaminated solis) all showed cement fixation to effectively fixate these substances'
incinerator ash, when the wastes were incinerated (roasted) in the presence of cement.
Treated waste Toxicity Characteristic Leachate Procedure (TCLP) . leachate ' arsenic
. concentrations were significantly lower than the TClP arsenic concentrations measured
for untreated samples. These results were achieved despite the fact that the lower vault
waste sample submitted for treatability testing purposely contained some still bottom
wastes from'the upper vault, to present a worst-case treatment scenario. (It is likely that
portions of the upper vault waste will unavoidably be mixed with the lower vault wastes
during the excavation step.) Thus, there is evidence that cement fixation will be effective
in the fixation 01 the upper vault waste incinerator ash.
28;
The former owners commented that large amounts of arsenic will leach out of the
cement-fixated waste if there is any exposure to atmospheric conditions.
EPA ResDOnse: The RifFS treatability data indicate that small quantities of arsenic may
be rel888ed from the cement-fixated wastes over extended periods (e.g., 1000 years) if
open exposure of these wastes to atmospheric carbon dioxide and acid rain is
permitted~ However, this possibility will be precluded by placement of the treated waste
in a hazardous waste landfill in a manner that should not expose the treated wastes to
substantial quantities of atmospheric carbon dioxide or acid rain. . .
14
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29.
The former owners commented that the limited availability 01 mobile incinerators will
result in delays for the proposed treatment of the upper vault wastes.
EPA Resoonse: While minor delays are possible, these will not have a significant effect
on overall remediation 01 the site. The actual operation 01 the incinerator is expected
to be only 90 to 120 days and will therefore be able to be scheduled in such a way as
to minimize any impacts on site remediation should any delays materialize.
30.
The owner 01 much 01 the land containing the lagoon wastes commented that the
volume of materials to be incinerated is too small to be economical.
EPA Response: It is unclear what the commentator means by "economical." The ROD
discusses the cost-effectiveness of the selected remedy. In addition, "Thermal
Remediation Industry - Markets" Technologies" Companies," Cudahy and Eicher,
Pollution Engineering, November 1989, justifies cost-effective use 01 incinerators at sites
having volumes, 01 material to be incinerated similar to the upper vault waste roasting
volume (6,000 cubic yards),
Cement Fixation of the Lower Vault Material
31.
32.
The former owners commented that the selected remedy makes no sense, sinc'e the
volume of the lower vault wastes is vastly increased following treatment and the' same
end result (Iandfilling) would be reached without treatment. ':
EPA Response: The fixation of arsenic will not increase the volume 01 arsenic; however,
the volume of the fixated material will increase by the amount of fixative agent: The
effects of the fixation, however, will be to reduce the leaching of arsenic. The offsite
landfilling of untreated arsenic would ~ot reduce the leaching of arsenic at the landfill,
The selected remedy reduces the mobility of the treated wastes by approximately 99:4%,
complies with the CERCLA preference for treatment, and is significantly more protective
01 human health and the environment because of the immobilization of arsenic. As the
former owners pointed out in their submittal entitled "Performance Evaluation of EPA's
Preferred Alternative and ERM's Proposed Enhanced Containment System for the
_Whitmoyer Laboratories Site", hazardous waste landfills are prone to leakage. Leakage
of leachate from the untreated lower vault waste would present a significant risk to
human health and the environment. Therefore, the end results are clearly different. In
addition, the RCRA LDR's prohibit (subject to any capacity extension) the oHsite
landfilling 01 untreated arsenic wastes. .'
The former owners commented that the 5.4 mg/l arsenic leaching result for the treated
sample that is used as the FS basis for reduction in mobility calculations and
demonstration of compliance with LDRs is greater than the RCRA toxicity characteristic
level of 5.0 mg/l, necessitating disposal of the treated waste in a hazardous waste
landfill.
15
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33.
EPA ResDOnse: While it is true that the particular result cited is greater than 5.0 mg/I '
arsenic, the result shows that the proposed treatment can achieve a 99.94 % reduction
in arsenic mobility and comply with the pertinent LDRs. Optimization of the treatment
process during the remedial design may result in treated waste leachate results less
than 5.0 mg/l arsenic. (No proprietary fixation reagents were utilized in the RifFS
treatability study. Use of these reagents could lower treatment costs, result in a reduced
volume of treated wastes; and increase the reduction in mobility.) Regardless of whether
the treated wastes' leachate concentration exceeds 5.0 mg/J or not, the treated material
must be placed in a hazardous waste landfill, since the lower vault waste is a RCRA-
listed waste. EPA has determined that delisting of the lower vault waste following
treatment is unwarranted, since, following treatment, the material would still contai~
approximately' 3% arsenic.. ",' "
The former owners commented that cement fixation treatment of the lower vault is' based
upon inadequate sampling, inadequate treatability studies, and inconsistent data, For
example, the sample submitted for treatability testing indicate,d thatthe lower vault waste
is heterogeneous. ""
, EPA Response: EPA believes that the treatability study is adequate, that the sampling
for the study was adequate, and that the data were consistent. The purpose of the
, study was to determine whether cem~nt fixation of arsenic in the lower vault would
reduce the leaching of arsenic compared to the leaching of untreated arsenic. To test
the effect ,of fixation on the arsenic in the lower vault, EPA purposely created ,a worst-
case sample by mixing some upper vault still bottom wastes with the lower vault wastes
Nonetheless, the fixatior) satisfactorily reduced the leaching, of arsenic in the fixated
sample. 'EPA believes that the results will apply to all lower vault wastes as former
employees of Whitmoyer Laboratories report that the lower vault waste is relatively
homogeneous. In addition, further optimization of, the treatment process will occur
during U1e remedial design phase of the project. '
34'. '
The former owners commented that significant quantities of arsenic leached out of the,
cement.fixated lower vault waste treatability sample during curing, potentially invalidatrg ,
~d~ ' ' ' ,
EPA Response: The former owner conclusion is based on the fact that more arseniC
leached out of the treated sample following 5 days of curing than leached out af1er 2S
, days of curing. This just shows that until the curing is complete, leaching will occur Ira:
exceeds TCLP levels. Once curing has been completed, treatability studies show :~a~
TClP limits will not be exceeded. " ' , .
35.
The former owners commented that the treated material is very unstable at varying pr--s
citing certain treatability study results. '
EPA Response: The former owners compared the arsenic removed in two ditfere:-:
extraction procedures., One was a single stage TCLP extraction, the other the sum :;'
the arsenic removed in three distilled water extractions. The difference in results is c~e
16
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to analytical variability and the different extraction procedures used, rather than instability
of the fixated wastes.
Iron Fixation of the Lagoon Wastes
36.
The former owners commented that all of the lagoon wastes should not be treated if
only some of the wastes are hazardous.
EPA ResDonse: EPA agrees. In its selected remedy for the lagoon wastes. EPA
modified its preferred alternative to show that any excavated lagoon wastes that are
,shown to be non-hazardous using RCRA-approved procedures may be directly landfilled
offsite, with no treatment being required. ,(It is uncertain what portion of the lagoon
wastes will be deemed non-hazardous following excavation, since mixing the lagoon
wastes with soils, which will likely occur during the excavation process, may cause the
entire mixture to become hazardous. Also, it may be more economical to manage
marginally non-hazardous lagoon sludges as hazardous wastes than to statistically verify
that they are nonhazardous.) ,
37.
The former owners commented that selection of the iron fixation remedy for the lagoon
wastes is insupportable. '
EPA ResDonse: While no iron fixation treatability data for the lagoon wastes were
generated during the RifFS, treatability data generated for the site soils and the
, successful application of iron fixation technology at other sites support the selection of
this remedy. The viability of the selected remedy will be confirmed during bench-scale
optimization studies to be conducted during the remedial design for the lagoon wastes.
38.
The former owners and the owner of much of the land containing the lagoon wastes
commented that there is sufficient iron present in the lagoon materials for the arsenic
to be bound in iron-arsenic compounds, and that the iron fixation treatment is
unnecessary.
EPA ResDonse: While the lagoon materials have a significant iron content, some or all
of these materials presently have leachable arsenic concentrations high enough for them
to be considered RCRA "toxic characteristic" hazardous wastes. Therefore such "toxic
characteristic" hazardous wastes will require additional iron-based fixation before
disposal to comply with the Remedial Action objectives to treat principal threats.
Excavated materials that do not manifest th'e RCRA Subtitle C characteristic for toxicity
will not be fixated.
39.
The former owners commented that iron fixation treatment will not provide any
measurable reduction in arsenic mobility, and makes no sense.
. .
EPA ReSDonse: RifFS soils treatability data indicate that iron fixation will reduce the
arsenic leachability of the soils by greater than 90%. Significant, measurable reductions
in the arsenic leachability 01 the lagoon wastes are also expected. Additionally. the
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selected remedy of iron fixation treatment will comply with RCRA LDRs and conform with
. the CERCLA preference for treatment. EPA believes that this is the best means to assure
protection of human health and the environment.
40.
The former owners commented that EPA selected samples for TCLP analysis based on
the results of sampling and analysis for total arsenic, and, that the results were therefore
biased. "
EPA Response: The selective sampling protocols cited by the former owners (i.e.,
submitting only the most contaminated samples for TCLP analysis) were not followed
by EPA. Samples for TCLP analysis were selected at the same time that samples for
other analyses (including arsenic) were selected, without any available information on
the samples' level of contamination. By sampling without related information, EPA does
not believe that any sampling bias existed. -
41.
The former owners commented that simplifying assumptions used in estimating the
volume of lagoon materials resulted in inaccurate volume estimates for the lagoon
wastes. "
. EPA Response: EPA believes that any assumptions used in the RifFS to estimate the
volume of lagoon materials is generally reliable as an estimate of the volume. EPA's
belief rests on historical data as to the nature and extent of the lagoons and additional
information gained from sampling during the Remedial Investigation. Further, the remedy
, selected, for the lagoon waste is health based and depended on response technology
rather than on volume.
42.
The owner of much of the land containing the lagoon wastes commented that the RifFS
inadequately considered the expense associated with excavation near the pipeline and
pump station.
EPA Response: EPA believes the remediation cost estimate for such excavation is
reasonably accurate. EPA addressed what it believes are the cost items related to that
excavation. The owners have not identified any additional cost items or provided
information that shows EPA estimates to be inaccurate. A more refined cost estimate
will be prepared during the remedial design. '
43.
The former owners commented that lagoon wastes should be considered to be those
wastes containing greater than 2% arsenic, rather than greater than 1 % arsenic. as
specifi8d-1n the FS.
EPA R88DOnse: The 1 % arsenic level was selected based on the RI results. Specifically.
many of the samples containing between 1 % and 2% arsenic in the lagoon areas had
visible iron-arsenic sludge. Since this sludge'likely was responsible for the majority of
the arsenic in these samples, EPA feels it is appropriate to classify this material as
lagoon waste (as opposed to contaminated soils). EPA retained this definition in the
selected remedy.
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Treatment of the Miscellaneous Products/Feedstocks
44.
The former owners commented that the proposed treatment of the miscellaneous
products/feedstocks is not justified.
EPA ResDonse: Only those materials considered RCRA hazardous wastes will be treated.
Treatment of the material is necessary to achieve the LOR treatment standard of 5.0 mg/I
arsenic prior to landfilling. While regulations in the Land Disposal Restrictions do permit
avoidance of the prohibitions, until May 8, 1992, on disposal of such untreated wastes,
those exceptions are not health-based. The ROD remedy is health based and is
intended to be protective of health and the environment. Protectiveness in this instance
means complying with the prohibition. In additions, the proposed treatment significantly
reduces the mobility of the metal contaminants, destroys the organic contaminants,
treats the principal threat posed by the miscellaneous productsl1eedstocks, and complies
with CERCLA preference for treatment. In addition, the proposed treatment significantly
reduces the mobility of the metal contaminants, destroys the organic contaminants,
treats the principal threat posed by the miscellaneous productsl1eedstocks, complies
with CERCLA preference for treatment, and is protective of public health and the
environment. .
45.
The former owners commented that incineration of the miscellaneous
products/feedstocks will contribute to an unacceptable risk to human health and the
environment.
:.,
EPA ResDonse: See response #5 above.
Demolition of the Site Structures
46.
The former owners commented that remediation 01 the site structures is unnecessary
and is likely to increase the risks to human health and the environment. Since the
building material samples come from interior building locations that are not exposed to
water or solvents, these materials are not likely to leach arsenic under normal
conditions~ .
EPA -- ~se: Remediation of the site structures is necessary. Runoff from the
buildinsrroofs exceeds EPA's characteristic hazardous waste concentrations, and either
infiltrates Into the groundwater or enters Tulpehocken Creek. Under present conditions,
large quantities of rainfall leak through the roofs. This rainfall contacts the contaminants
inside the buildings and is collected in a sump. Water in this sump typically contains
400 mg/I arsenic, which is well in excess 01 the RCRA characteristic hazardous waste
criterion of 5 mgJI. This water must be periodically remediated, or the sump will
overflow. If the buildings were occupied without cleanup, building contaminants would.
threaten the workers via the inhalation and ingestion pathways. Additionally, future
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47.
48.
49.
building uses would mobilize the contaminants (e.g., from floor cleaning). Dangerous
conditions within the buildings present risks to future building users and trespassers,
if left Ll'W'8mediated. ,Also, a fire in the buildings could release large quantities of,
contaminants into the environment-. ' , " "
The former owners commented that results from air -sampling within the buildings do 'not
exceed Occupational Safety and Health Administration (OSHA) and National Institute for
Occupational Safety and Health (NIOSH) standards for arsenic., Thus, remediation of
the site structures based on these air sampling results is not warranted.' _."
, EPA Response: While the air sampli'ngresultsmay show arsenic concentrations in air,
to be below OSHA standards and NIOSH recommended levels, the, baseline. risk
assessment in the FS performed for the Site considered the air sampling results and
concluded that an unacceptable excess lifetime cancer risk existed for persons
occupying and working in the buildings. The remedy selected for remediation of the
site structures,. by eliminating ,the source of the unacceptable risk, eliminates the risk.
", . . v
.' '"
. I
, ,
The former owners commented that remediation of ..asbestos in the buildings is
unwarranted, since it is not currently friable.' ..
> ,
EPA Response: While the asbestos is not currently friable, due. to exposure to' the
.' elements and continued cycles of freezing and thawing. wetting .and drying it would
, likely become friable over time. Friable asbestos presents risks to building occupant's
The former owners commented that isolated areas of contamination within the Building
1-7 complex should ,be remediated, rather than demolition of the entire building complex.
Contaminated wood materials could be removed, and contaminated concrete could, be'
coated' and sealed in place. New roofs could be constructed on top of the existing
roofs, to preclude precipitation contact with the existing building roofs and building
interiors.' , , .
. ,
. EPAResponse: EPA believes it is more cost effective to demolish the entire Building 1-
7 complex.. It would be extremely difficult and less cOst-effective to remove ,all of the
heavily contaminated building materials (e.g., wooden floors) from' the Building 1-7
complex while maintaining the integrity of the building structl.!re. Additionally, the,
selected remedY is muCh more effective in the long-term and permanent.
50~
The f~ owners commented that neither the FS nor the ProposeQ Plan explain how
hazardous site structures materials will be segregated from nonhazardous materials
during remediation, or which ex~ct procedure will be used for coating and sealing
hazardous .noncombustible permeable site structures.' .
, EPA Response: Details such as these will be addressed during the remedial design
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51.
52.
General,
53~
54.
L.,
The former owners commented that neither the FS nor Proposed Plan addresses how
contaminated water generated during the site structures remediation will be managed.
EPA R88DOnse: If moderate pressure water is used for surface cleaning (sandblasting
is another option), this water could be treated in either an onsite groundwater treatment
system (if constructed), in a temporary onsite treatment system, or at a permitted offsite
facility (see p. 4-90 of the FS). These options will be considered and completely
evaluated during Remedial Design.
The former owners commented that demolition of the Building 1-7 complex would result
in significant releases of fugitive dusts.
EPA Resoonse: Fugitive dust emissions during demolition are expected to be minor.
Contaminated dusts inside the buildings will be collected during the surface cleaning
program taking place prior to demolition. If necessary, air pollution controls, such as
wetting the building materials. will also be utilized to minimize fugitive dust releases.
Buckeye Pipe Une Company L.P. commented that there are no reports or suggestions
that any of Buckeye's operations have ever caused or contributed to contamination of
the site. .
EPA Resoonse: The liability of potentially responsible parties will be determined in'the
future.
The former owners commented that the failure to collect arsenic speciation data during
the RI made the risk assessment and FS of limited value. The risk assessment
assumption that ~II arsenic detected is inorganic arsenic may lead to a substantial
overestimation of risk. Also, the potential effectiveness of various treatment schemes
could be affected by the arsenic form. .
. EPA Resoonse: During RI/FS scoplng, the former owners commented that all analyses-
for valences of arsenic (speciation) should be eliminated. ("Technical Assessment of the
Need for Immediate Removal of Vault/Lagoon Contents at Whitmoyer Laboratories Site'
January 1987). This comment was incorporated into the RI.
In general, organic arsenic compounds are less toxic than inorganic forms of arseniC
, There.. exceptions to this rule. however. Presently, there are inadequate toxicology
data to determine the carcinogenic potential for organic arsenic compounds.
Assuming that a substantial percentage of the arsenic contamination detected dunng
the RI is organic arsenic, the risk analysis based on the assumption that all arsenic
present at the site is inorganic may have overestimated the noncarcinogenic and
carcinogenic risks calculated for the site. For example, assuming that the percentage
of orga~ic arsenic is 50 percent and assuming that organic arsenic is one-tenth as
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< I
. potent a carcinogen as inorganic arsenic, the predicted excesS lifetime cancer risk would
be approximately one-half the risk assuming 1 00 percent inorganic arsenic. However,
, -given the very high arsenic concentrations measure<;t at Whitmoyer, the assumption that
organic arsenic is prominent at the site does little to alter the overall conclusion that the'
Operable Unit 2 materials present substantial noncarcinogenic and carcinogenic risks,
and require remediation. The assumption of 100 percent inorganic arsenic adds a
measure of conservatism to the risk assessment, and did not affect EPA's selection of
the remedy for Operable Unit 2.
Nearly all of the remedial decisions reached by EPA. for 'Operable Unit Two are
supported by treatability studies. Thus, treatment using the selected remedies has been
shown to be effective for the forms of arsenic present at the site on a bench-scale.
55.
The former owners commented that the failure to use efficient screening technologies
during the Ailed to increased number of sample loCations, an extended AI schedule, .
and increased project costs. For example, geophysics could have detected drum burial
area BA-2, rather than its unexpected discovery during the AI. . . .
EPA Aesponse: In this comment, the former owners imply that too many sample~rwere
collected. In other portions of their comments, the former owners comment that
. insufficient numbers of samples were collected for the vault wastes,lagoon wastes, soils,
and groundwater. -. ,
There are several alternate investigatory approaches that can be utilized during an RI.
, EPA focussed its AI by having an extensive screening program, including an extended
{~, review of historical documents, interviews with former employees, a review of historical
air photos, a fracture trace analysis, and a'n evaluation of existing wells for AI usability.
Based on the extensive database developed from the re~ew of historical. documents and
interviews with former employees, use of geophysics :wasevaluated and eliminated as
a cost-reduction step. ' . . " . . . ' ,
56,
The former owners provided numerous comments on the soils and groundwater media
study. ' .
EPA Aesponse: Comments related to the'soils and groundwater media will be addressed,
in the Aesponsiveness Summary for Operable Unit 3. .
D.
REMAINING CONCERNS
, .
An issue that EPA was unable to address during remedial planning activities was how much'
of the cleanup will be paid by potentially responsible parties. EPA has not received offers to
. pay for these costs to date; however, as parties agree to pay costs, and/or conduct work at .
the site, or do so in response to enforcement actions, EPA will make public that information
.'.'~
." i
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