United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/123
September 1991
&EPA Superfund
Record of Decision:
Hellertown Manufacturing, PA
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50272-101
. REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-91/123
3. Recipients Accession No.
Me and Subtitle
SUPERFUND RECORD OF DECISION
Hellertown Manufacturing, PA
First Remedial Action - Final
5. Report Date
09/30/91
7. Author(s)
8. Performing Organization RepL No.
9. Performing Organization Name and AoVlret*
10. ProjecVTaak/Work Unit No.
11. Contract! C) or Gr«nl(G) No.
(C)
(G)
12. Sponsoring Orgar&zation Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umit: 200 word*)
The 8.64-acre Hellertown Manufacturing site is an inactive spark plug manufacturing
facility in Northampton County, Pennsylvania, approximately 1.5 miles south of
Bethlehem. The site is bordered by commercial and residential areas, highway and
railroad transportation corridors, Saucon Creek, and a wetlands area. Onsite features
include a 124,000-square-foot building, and five lagoons totaling 500,000 cubic feet.
From 1930 to 1975, chemical wastes including TCE, zinc plating waste, chrome dip
waste, cleaners, and cutting oils generated during plating and degreasing processes
were disposed of onsite in the unlined lagoons. Waste from these activities then
seeped into the local soil and rock strata. In 1976, after the facility began
discharging treated wastewater into the municipal sewer system, the lagoons were
backfilled, closed in place, and covered with topsoil. The material used to backfill
the lagoons included rejected spark plugs, demolition material from road-building
activities, and soil excavated during construction of the nearby Bethlehem wastewater
treatment plant. Studies conducted in 1990 identified contamination by VOCs, metals,
and organic compounds in lagoon backfill, soil, and in onsite ground water. The
primary contaminants of concern affecting the soil and ground water and VOCs including
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Hellertown Manufacturing, PA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, DCE, PCE, TCE, vinyl chloride, xylenes), other
organics (PAHs), metals (chromium)
b. Identifiers/Open-Ended Term*
c. COSAT1 HeM/Group
AvailablBty Statement
18. Security Oaaa (This Report)
None
20. Security CUM (This Page)
None
21. No. of Pages
57
22. Price
(SeeANSI-Z39.18)
See liMtructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-91/123
'^ellertown Manufacturing, PA
rst Remedial Action - Final
Abstract (Continued)
benzene, DCE, PCE, TCE, vinyl chloride, and xylenes; other organics including PAHs; and
metals including chromium.
The selected remedial action for this site includes capping the former 3.5-acre lagoon
area with an impermeable asphalt and clay cover; pumping and onsite treatment of ground
water using air stripping; removing solids using a settling tank or clarifier followed by
filtration; discharging the treated effluent onsite to Saucon Creek; long-term ground
water monitoring; controlling surface water runoff; and implementing institutional
controls including deed restrictions. The estimated present worth cost for this remedial
action is $2,250,000.
PERFORMANCE STANDARDS OR GOALS: Ground water clean-up goals are based on SDWA MCLs or
State background concentrations, whichever is the more stringent. Chemical-specific
ground water clean-up levels include benzene 0.2 ug/1 (State background),
PCE 0.03 ug/1 (State background), TCE 0.12 ug/1 (State background), and vinyl
chloride 0.18 ug/1 (State background).
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RECORD OF DECISION
HELLERTOWN MANUFACTURING COMPANY
DECLARATION
Site N*me and Location
Hellertown Manufacturing Company
Hellertown Borough, Northampton County, Pennsylvania
Statement of Basis and Purpose
This decision document presents the final selected remedial
action for the Hellertown Manufacturing Company site, Hellertown
Borough, Northampton County, Pennsylvania, which was chosen. in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) , as amended by the Super fund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) , 40 C.F.R. Part 300. This decision
document explains the factual and legal basis for selecting the
remedy for this site.
The Commonwealth of Pennsylvania concurs on the selected remedy.
The information supporting this remedial action decision is
contained in the Administrative Record for this site.
Assessment of the Site
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S. C. § 9606, that actual
or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in
this Record of Decision (ROD) , may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the selected Remedy
This is the only planned response action for the site. This
remedy addresses both source control of five former lagoons which
are the source of the soil and groundwater contamination, and
groundwater remediation. Groundwater contamination represents a
primary threat; therefore, the extraction and treatment of
groundwater will be required. Soils on-site represent a low-
level threat and not a principal threat; therefore, a containment
remedy for source control will be required.
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The selected remedy includes the following major components:
-Placement of an impermeable cover over the entire former
lagoon area;
-Surface water runoff controls;
-Extraction and treatment of groundwater (air stripping and
solids removal) , with discharge to Saucon Creek;
-Long-term groundwater monitoring; and
-Deed restrictions.
Statutory Determinations
The selected remedy is protective of 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. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element.
Because this remedy will result in hazardous substances above
health-based levels remaining on-site, a review will be conducted
within five years after commencement of remedial action and every
five years thereafter, as required by Section 121 (c) of CERCLA,
42 U.S.C. § 9621 (c) , to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Edwin B. Erickson Date
Regional Administrator
Region III
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RECORD OF DECISION
HELLERTOWN MANUFACTURING COMPANY
TABLE OF CONTENTS
SECTION PAGE
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY 2
III. HIGHLIGHTS OF COMMUNITY INVOLVEMENT 2
IV. SCOPE AND ROLE OF RESPONSE ACTION 3
WITHIN SITE STRATEGY
V. SUMMARY OF SITE CHARACTERISTICS AND 4
EXTENT OF CONTAMINATION
VI. SUMMARY OF SITE RISKS 6
VII. DESCRIPTION OF ALTERNATIVES 10
VIII. SUMMARY OF COMPARATIVE ANALYSIS 13
OF ALTERNATIVES
IX. SELECTED REMEDY: DESCRIPTION AND 18
PERFORMANCE STANDARD(S) FOR EACH
COMPONENT OF THE REMEDY
X. STATUTORY DETERMINATIONS 24
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 27
GLOSSARY
FIGURES
Figure 1: Site Location Map
Figure 2: Location of All Soil Borings Drilled
Figure 3: Site Plan Shoving Well Locations
Figure 4: Approximate Area with Elevated Groundwater
Contaminants
Figure 5: Areas and Volumes [of Former Lagoons]
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TABLES
Table 1: VOCs.and Inorganic Compounds in Lagoon Soils
Table 2: VOCs and Inorganic Compounds in On-site and Off-
site Monitoring Wells (two pages)
Table 3: Key Risk Terms
Table 4: Reasonable Maximum Potential Risks Presented by
the Compounds of Concern in Surface Soil
Table 5: Reasonable Maximum Potential Risks Presented by
Showering with On-site Groundwater
Table 6: Reasonable Maximum Potential Risks Presented by
Ingestion of Compounds of Concern in On-site
Groundwater
Table 7: Summary of Potential Risks Presented by Exposure
to Compounds of Concern
Table 8: Cost Summary for Remedial Alternatives
Table 9: Selected Remedy Cost
RESPONSIVENESS SUMMARY
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RECORD OF DECISION
HELLERTOWN MANUFACTURING COMPANY
DECISION SUMMARY
I. SITE NAME. LOCATION. AND DESCRIPTION
The Hellertown Manufacturing Company site (the "Site"), is located
on Main Street (Route 412) in Hellertown Borough, Northampton
County, Pennsylvania. The Site occupies 8.64 acres and contains a
124,000 square foot building. The Site is located in a combined
commercial and residential area approximately 1.5 miles south of
Bethlehem, Pennsylvania (Figure 1) .
The Site is bordered by commercial businesses and residences to the
south, by the recently-completed Interstate Highway 78 to the
north, by Main Street and undeveloped vacant land to the east, and
a Conrail railroad and Saucon Creek to the west. Several
residences are located between the Conrail railroad and Saucon
Creek.
The Borough of Hellertown covers 1.4 square miles. It has a
population of 6,025 and a density of 4,034 persons per square mile.
The Borough maintains a public water supply which uses primarily
surface water. Groundwater is used for backup municipal water
supply. Residences within 0.5 miles of the Site are connected to
the public water supply. The Remedial Investigation ("RI") Report
identified seven wells within one mile of the Site, six of which
are residential. Of the residential wells, three are used for
drinking water, one is used for watering a lawn and washing cars,
and two are inactive. The residential wells were sampled during
the RI. None of the samples contained contaminants which exceeded
Maximum Contaminant Levels ("MCLs") established by the Safe
prinking Water Act ("SDWA"). Eight additional wells were
identified within approximately two miles of the Site. These wells
are used for either backup municipal water supply, irrigation, or
water level monitoring. The aquifer underlying the Site is
classified as Class IIA, a current source of drinking water.
The nearest body of surface water is Saucon Creek, located
approximately 600 feet west of the Site. It joins the Lehigh River
about 1.5 miles to the north of the Site. Saucon Creek is used for
recreational purposes and for fishing. Groundwater beneath the
Site flows to the west-northwest in the direction of Saucon Creek.
Groundwater in the vicinity of the Site discharges from the bedrock
to Saucon Creek.
There are no known endangered species or critical habitats within
the immediate vicinity of the Site. A wetlands area was delineated
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off-site near Saucon Creek.
II. SITE HISTORY AND ENFORCEMENT ACTIVITY
The Hellertown Manufacturing Company is an inactive spark plug
manufacturing facility that ceased operation in October 1982. The
Site was developed in 1918 as a spark plug manufacturing facility,
and acquired by the Hellertown Manufacturing Company, a wholly-
owned subsidiary of the Champion Spark Plug Company, in 1950. It
was sold to Paikes Enterprises, Inc., in 1988. The building is
currently used by a small laboratory and as warehouse space.
Spark plug manufacturing involved a plating process and a
degreasing operation using trichloroethylene. These processes used
various chemicals which resulted in the generation, storage, and
disposal of various wastes. Between 1930 and 1976, wastes were
disposed in five on-site lagoons with a total storage capacity of
500,000 cubic feet (referred to herein as the "former lagoon
area"). The lagoons were unlined, and allowed waste to seep into
the local soil and rock strata. According to a Preliminary
Assessment conducted by the Pennsylvania Department of
Environmental Resources, the waste disposed on-site included zinc
plating waste, chrome dip waste, cleaners, and cutting oils.
In 1965 a wastewater treatment system with sludge drying beds was
installed for treatment of plant wastewater. It was upgraded in
1972. By 1975 the treated wastewater was discharged to the
municipal sewer system and disposal in the lagoons was no longer
necessary. In 1976, the lagoons were backfilled, closed in place,
and covered with topsoil.
The plant also previously used five underground tanks for storage
of machine oil and fuel oil. In 1990 the contents of all tanks
were removed and one of the tanks was removed. The other four
tanks, which were in close proximity to the manufacturing building,
have been closed in place.
The Site was listed on the National Priorities List ("NPL") in
March 1989. In February 1988 Champion Spark Plug Company
("Champion") and EPA entered into an Administrative Order by
consent which required Champion to conduct a Remedial
Investigation/Feasibility Study ("RI/FS"). The purpose of the
Remedial Investigation was to collect data necessary to
characterize the Site; the purpose of the Feasibility study was to
develop and evaluate appropriate remedial alternatives. The work
was conducted by Environmental Strategies Corporation. The final
RI and FS Reports were submitted to EPA on August 20 and 21, 1991.
III. HTGtTLTGHTS OF COMMUNITY INVOLVEMENT
A Community Relations Plan for the Hellertown Manufacturing Company
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site was finalized in June 1987. This document lists contacts and
interested parties throughout government and the local community.
It also establishes communication pathways to ensure timely
dissemination of pertinent information. The draft RI/FS reports
and the Proposed Plan were released to the public in July 1991.
All of these documents were made available in both the
Administrative Record and at the Hellertown Borough Municipal
Center. A public comment period was held from July 26, 1991 to
August 26, 1991. In addition, a public meeting was held on August
13, 1991, to discuss the results of the RI/FS and the preferred
alternative as presented in the Proposed Plan for the Site. Notice
of the Proposed Plan and public meeting was published in the
Bethlehem Globe Times, the Allentown Morning Call, and the
Hellertown Vallev Voice. All comments which were received by EPA
prior to the end of the public comment period, including those
expressed verbally at the public meeting, are addressed in the
Responsiveness Summary which is attached to this Record of
Decision.
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The remedy selected in this ROD addresses pumping and treatment of
the contaminated groundwater emanating from the Site and
containment of the on-site contaminated subsurface soils. This is
the only planned response action for this Site.
EPA has classified this aquifer as a Class IIA aquifer, a current
source of drinking water, in accordance with the EPA document
"Guidelines for Groundwater Classification" (Final Draft, December,
1986). One goal of this remedial action is to restore contaminated
groundwater to its beneficial use as a drinking water source and to
background concentrations, if practicable. The primary risk to
human health and the environment is from ingestion of, and contact
with, groundwater from wells that contain contaminants above the
MCLs established under the Safe Drinking Water Act ("SDWA"), 42
U.S.C. §§ 300f to 300J-26. Pumping and treating groundwater is the
most expeditious way to reduce the contaminant levels that have
been detected.
Another goal of this remedial action is source control of
contaminated soils. The purpose is to protect human health and the
environment from exposure through direct contact, and to prevent
transport of soil contaminants into the groundwater in order to
protect groundwater for its beneficial uses and to meet groundwater
ARARs. (ARARs are applicable or relevant and appropriate federal
and state requirements that a selected remedy must attain).
The RI Report indicates that existing levels of contaminants in the
soils are within EPA's acceptable incremental individual lifetime
cancer risk range of 10~4 to 10"6, based on direct dermal contact and
ingestion. No principal threats such as areas of highly toxic or
highly mobile wastes were found. Therefore, EPA has determined
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that contaminated soils are a low-level threat and not a principal
threat. However, rainfall infiltration into the soils can cause
contaminants in soil to continue to leach into the groundwater.
Therefore, the selected remedial alternative requires an
impermeable cover over the former lagoon area to minimize
infiltration of rainwater and to reduce the time needed to achieve
groundwater ARARs.
V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF CONTAMINATION
A. Site Characteristics
The Site is underlain by Cambrian and Pre-Cambrian rocks that have
been deeply weathered. The Tomstown Formation (also known as the
Leithsville Formation) lies directly under the Site and is composed
primarily of dolomitic limestones with varying amounts of lime-
containing shales and phylitic schists. Some highly weathered
sandstone lenses may be found in the formation as well. The
geologic structure of the rocks is extremely complex, which is
partly caused by extensive thrust faulting in the area. The
Tomstown Formation extends to a depth of approximately 1,000 feet,
with the upper few hundred feet reportedly containing all of the
water-bearing fracture. The bedrock in the vicinity of the Site is
overlain by saprolite and a mantle of undifferentiated alluvium and
colluvium. The combined thickness of these units ranges from zero
to 41 feet in the vicinity of the Site.
The bulk of the regional groundwater moves through carbonate-rock
formations, including the Leithsville Formation, that are most
likely interconnected hydraulically. Most of the water in the
carbonate-rock aquifers occurs in bedding-plane openings, joints,
fault zones, and fractures that have been enlarged by groundwater
dissolving minerals from the rock. The flow pattern in the bedrock
in the vicinity of the Site is complex; however, water level
measurements in monitoring wells indicate that groundwater is
discharging to Saucon Creek. There is generally a downward and
horizontal (westerly) groundwater flow in the alluvium/colluvium
mantle and an upward and horizontal (westerly) groundwater flow in
the Leithsville Formation.
B. Nature and Extent of Contamination
The primary source of site contamination was the wastewater
disposed in the five former lagoons. The lagoons were unlined,
allowing stored liquids to seep through the bottoms. The lagoons
and the underlying groundwater were sampled in the course of the
field investigations conducted during the Remedial Investigation.
Volatile organic compounds (VOCs), polynuclear aromatic
hydrocarbons (PAHs), and metals were found in the lagoon backfill
and underlying lagoon sediments in concentrations that exceed
background levels. VOCs and metals were found in groundwater at
concentrations that exceed background levels and MCLs. The
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estimated volume of the contaminated groundwater plume both on-site
and off-site is 49 million gallons. It covers an. area of
approximately 7.5 acres.
The former lagoon arear covers approximately 3.5 acres. The total
lagoon volume is 76,000 cubic yards. Lagoons vary in depth up to
about 28 feet maximum. The material used to backfill the lagoons
was obtained from different locations, and included rejected spark
plugs, demolition material (including asphalt) from road-building
activities, and soils excavated during construction of the nearby
Bethlehem, Pennsylvania, wastewater treatment plant. The fill
material probably contributed to the polynuclear aromatic
hydrocarbon (PAH) contamination found in the soil in the former
lagoon area. Disposal of wastes from the plating operation,
degreasers, and oils from the manufacturing process, as described
above, contributed to the elevated levels of VOCs and metals found
in soil and groundwater at the Site. Asphalt now covers the area
of lagoons 1 and 5, and a grass field covers the area where the
other three lagoons were located.
The scope of the Remedial Investigation included sampling studies
for all media that may be affected: surface and subsurface soils,
groundwater, sediment, and surface water. Approximately 65 soil
borings were taken on-site in the vicinity of the former lagoons.
Additional soil samples were taken near the process building. The
location of soil borings is shown in Figure 2. Samples were
analyzed for contaminants including PAHs, VOCs, metals and
inorganic compounds. A summary of VOC contamination in soils in
the former lagoon area is presented in Table 1. Samples indicate
that contamination is present throughout each lagoon soil profile
at levels that exceed background concentrations. VOCs were not
detected in surface soils, probably due to the fact that these
compounds volatilize easily. The contaminants of concern for soil
include: . trichloroethylene (TCE); 1,2-dichloroethylene;
tetrachloroethylene (PCE); 4-methyl-2-pentanone; carbon disulfide;
ethylbenzene; total xylenes; PAHs; chromium; total cyanide; and
cadmium.
TCE was the most frequently detected VOC in subsurface soils within
the lagoon area, with a maximum TCE concentration of 560
micrograms/kilogram ("ug/kg") sampled from •former lagoon 4.
Subsurface soil samples from the former lagoon areas contained
several base-neutral and acid extractable organic compounds,
particularly PAHs. PAH concentrations collected from the fill
materials and the residual lagoon sediments ranged from 830 ug/kg
to 108,000 ug/kg. PAHs were detected in samples from beneath the
base of each lagoon ranging in total concentration from 125 ug/kg
to 23,969 ug/kg.
Approximately 23 groundwater monitoring wells, both on-site and
off-site, were sampled on three occasions during the remedial
investigation. The location of groundwater monitoring wells are
shown in Figure 3. Water level measurements in the bedrock wells
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indicate that groundwater is moving west-northwest across the site
and that groundwater is discharging to Saucon Creek.
Samples' were analyzed for volatile and non-volatile organics,
metals, and inorganic compounds. Contaminants were found in
groundwater at concentrations that exceed background levels and
MCLs under" the Safe Drinking Water Act. MCLs were exceeded for
benzene, cis-1,2 dichloroethylene, trans-1,2 dichloroethylene,
trichloroethylene, vinyl chloride, and tetrachloroethylene.
Additional contaminants of concern for groundwater include acetone;
1,1,1-trichloroethane; beryllium; chromium; total cyanide; mercury/-
nickel; selenium; and antimony.
Groundwater sampling results are summarized in Table 2. Maximum
concentrations of the most frequently detected VOCs are: vinyl
chloride, 83 ug/1; TCE, 1700 ug/1; tetrachloroethylene, 22 ug/1;
total 1,2-dichloroethylene, 260 ug/1. A relationship between TCE
in subsurface soils and groundwater was established during the
RI/FS. Subsurface soils collected from former lagoon 4 contained
levels of TCE up to 560 ug/kg, which were the highest levels
detected in any lagoon; the corresponding groundwater in the wells
downgradient of lagoon 4 contained the highest concentration of
TCE.
Groundwater monitoring at the Site indicates that the VOCs have
moved through groundwater off-site toward Saucon Creek at levels
that exceed MCLs. The concentration of VOCs in wells decreased
between the lagoons and the creek, indicating that dispersion and
dilution is occurring. Stream and sediment samples were collected
from five locations along Saucon Creek and analyzed for volatile
and non-volatile organic compounds, PAHs, inorganic compounds, and
indicator parameters of water quality. No volatile organic
compounds were present in detectable concentrations. However, the
presence of organic compounds in groundwater monitoring wells
adjacent to Saucon Creek indicates that groundwater is a likely
contaminant pathway to the creek.
Four additional wells were sampled in June, 1991. A cluster of two
groundwater monitoring wells, CSP 20 and 21 (one shallow and one
bedrock well) was installed off-site 450 feet west of Saucon
Creek. TCE, toluene, ethylbenzene, and xylene were detected in
these wells. A second cluster of two wells was installed offsite
south of the site (wells CSP-22 and CSP-23). Well CSP-22 contained
TCE at 6 ug/1.
VT. SUMMARY OF SITE RISKS
As part of the RI/FS, a baseline risk assessment was conducted to
characterize the current and potential threats to human health and
the environment posed by contaminants in the groundwater, soil and
subsurface soil, the migration of contaminants to surface water,
and the leaching of contaminants from soil to groundwater, in the
6
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absence of remedial action. Table 3 provides a discussion of the
key terms used in the risk assessment described in the ROD. The
risk assessment consisted of identification of contaminants of
concern; toxicity assessment, exposure assessment, and risk
characterization. • •--
Current land use in the vicinity of the Site is residential and
commercial. According to information received from the Hellertown
Borough planning office, future land use is also expected to be
residential and commercial.
Groundwater beneath the Site is classified as a Class IIA aquifer,
a current source of drinking water. There are seven wells within
one mile of the Site, six of which are residential. Of the
residential wells, three are used for drinking water, one is used
for watering a lawn and washing cars, and two are inactive. The
residential wells were sampled during the RI/FS. None of the
samples contained contaminants which exceeded MCLs. Eight
additional wells were identified within approximately two miles of
the Site. These wells are used for either backup municipal water
supply, irrigation, or water level monitoring.
Populations at risk include:
(1) Persons who may use contaminated groundwater from the Site
now and in the future. The primary routes of exposure would be
ingestion, inhalation of volatile contaminants, and dermal
adsorption by adults and children.
(2) Persons who may come in contact with contaminated on-site
soils based on hypothetical residential use. The primary routes of
exposure would be inadvertent ingestion and dermal absorption of
contaminants by adults and children.
Use of an exposure scenario based on future residential use is
consistent with Agency policy described in "EPA Risk Assessment
Guidance for Superfund" (December, 1989) which requires
consideration of hypothetical residential use. The NCP requires
that groundwater which is suitable for use as a water supply be
protected and restored to its beneficial use.
C. Contaminants of Concern
The Risk Assessment compiled a list of contaminants of concern from
the results of the various sampling activities at the Site. These
indicator contaminants of concern were selected based on
concentrations at the site, toxicity, physical/chemical properties
that affect transport/movement in air, soil and groundwater, and
prevalence/persistence in these media. These contaminants of
concern were used in the Risk Assessment to evaluate potential
health risks at the site.
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The specific contaminants of concern in the subsurface soil which
were evaluated in Risk Assessment are trichloroethylene, 1,2-
dichloroethylene, tetrachloroethylene, 4-methyl-2-pentanone, carbon
disulfide, ethylbenzene, total xylenes, PAHs, chromium, total
cyanide, and cadmium.--
The specific contaminants of concern in groundwater which were
evaluated in the Risk Assessment are acetone, benzene, cis-1,2-
dichloroethylene, trans-1,2-dichloroethylene, trichloroethylene,
tetrachloroethylene, 1,1,1-trichloroethane, vinyl chloride,
beryllium, chromium, total cyanide, mercury, nickel, selenium, and
antimony.
D. Toxicitv Assessment
The results of the Risk Assessment revealed that the concentrations
of six contaminants in the groundwater exceed MCLs for those
contaminants. Benzene and vinyl chloride are classified as human
carcinogens based on epidemiological studies. Trichloroethylene
and tetrachloroethylene are classified as probable human
carcinogens based on toxicological studies performed on laboratory
animals. Scientific data collected to date is not sufficient to
classify cis and trans-1,2-dichloroethylene as carcinogens.
E. Exposure Assessment
The exposure assessment identified potential exposure pathways for
residential soils and groundwater at the Site boundary. The
potential for current exposure to surface and subsurface soils is
limited. The former lagoon area is covered with asphalt or a
grassy soil cover and the Site is fenced. There are no on-site
drinking water wells. Therefore, two hypothetical exposure
scenarios were developed, assuming the site was developed for
future residential use: (1) exposure to surface soil by adults
through dermal adsorption and by children via ingestion and dermal
adsorption, and (2) domestic use of groundwater by adults and
children through three routes: ingestion, dermal contact with water
while bathing or showering, and inhalation of indoor air
contaminants while bathing, showering, or cooking. For each
potential exposure pathway, exposure assumptions were made for
average and reasonable maximum exposure scenarios.
The contaminant intake equations and intake parameters were derived
from standard literature equations and data from EPA guidance
documents. Chronic daily intakes ("GDI") were estimated for
contaminants of concern in the baseline risk assessment. The
Reference Dose values ("RfD") for a substance represent a level of
intake which is unlikely to result in adverse non-carcinogen health
effects in individuals exposed for a chronic period of time. The
slope factor represents the upper 95 percent confidence limit value
on the probability of response per unit intake of a contaminant
over a lifetime (70 years) . (See Table 4 through 6 for values used
in the exposure assessment).
8
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F« Risk Characterization
The baseline risk assessment in the RI/FS quantified the potential
carcinogenic and non-carcinogenic risks to human health posed by
contaminants of concern in several exposure media. For the
Hellertown Site, the carcinogenic and non-carcinogenic risks were
determined for soil and groundwater. (See Tables 4 through 6 for
values used in the exposure assessment).
Carcinogenic risk is presented as the incremental probability of an
individual contracting some form of cancer over a lifetime as the
result of exposure to the carcinogen. Risk standards for non-
carcinogenic compounds are established at acceptable levels and
criteria considered protective of human populations from the
possible adverse effect from human exposure. The ratio of the GDI
to the RfD, defined as the hazard quotient, provides an indication
of the potential for systemic toxicity to occur. If the sum of the
aggregate hazard quotients does not exceed one, there is not a
concern for a non-carcinogenic public health threat.
1. Groundwater
Carcinogenic and non-carcinogenic risks for hypothetical
residential use of groundwater based in a reasonable maximum
exposure scenario are summarized in Table 7. The potential future
risk associated with chronic daily ingestion of on-site groundwater
is 10"3- The potential future risk associated with showering with
onsite groundwater is 3 x 10"4. TCE is the carcinogen that was
detected in groundwater at the highest concentration, and vinyl
chloride is the most potent carcinogen among the contaminants of
concern.
The aggregate non-carcinogenic hazard index for a future
hypothetical residential scenario was calculated at 0.9. Since
results do not exceed one, EPA believes there is no non-
carcinogenic health risk.
Because the baseline carcinogenic risk exceeds the risk range of
10"4 to 10"6, and because MCLs are exceeded, remedial action for
groundwater will be taken at this Site.
2. Soil
Potential carcinogenic and non-carcinogenic risks for ingestion of,
and dermal contact with, surface soil for a hypothetical
residential use scenario is also summarized in Table 7. The
lifetime excess cancer risk associated with exposure to total
carcinogenic PAHs in surface soil is 7 x 10"5. The non-carcinogenic
hazard index is less than one. Because the exposure to surface
soils represents a low-level threat and not a principal threat at
the Site, source control through containment is the selected
remedy.
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G. Environmental Risks
There are no known endangered species or critical habitats within
the immediate vicinity of the site. The Site is located in an
industrial/commercial-- setting that does not provide habitat
resources for wildlife.
Wetlands occupying 0.13 acres were identified adjacent to Saucon
Creek in the vicinity of the Site. Saucon Creek and the delineated
wetland are potentially affected by the migration of contaminants
through groundwater discharge. Surface water in the wetlands area
contained inorganic compounds and metals but no VOCs; sediments
contained metals and PAH compounds. It is not clear from the
sampling survey whether contaminants are present above background
levels and whether the wetland receives contaminants from
groundwater discharge or through storm drainage, or a combination
of both. Therefore, additional wetland soil, stream, sediment, and
surface water sampling will be required as part of the remedial
design study.
H. Summary
For a residential use scenario, use of groundwater at the Site
would result in a maximum excess cancer risk from exposure to
groundwater of one person in one thousand (10~3) . The lifetime
excess cancer risk associated with exposure to surface soil is
seven persons in one hundred thousand (7 x 10"5) . Noncarcinogenic
health effects are not expected from exposure at the present
detected levels of contamination in either on-site soil or in
groundwater.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
VII. DESCRIPTION OF ALTERNATIVES
A feasibility study was conducted to identify and evaluate remedial
alternatives for remediation of groundwater and-contaminated soils
in the former lagoon area. Applicable remediation technologies
were initially screened in the feasibility study based on
effectiveness, implementability, and cost. The alternatives
meeting these criteria were then evaluated and compared to nine
criteria required by the National Contingency Plan (NCP). The NCP
requires that a no action alternative be evaluated as a point of
comparison for other alternatives.
The six alternatives evaluated and their present worth costs are
described below. The alternatives describe final remedial actions
for source control and groundwater remediation.
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Alternative 1; No Action
$223,000
Under this alternative, no further action would be taken to control
the source of contamination. However, long-term monitoring of
groundwater would be implemented using existing monitoring wells to
monitor contaminant migration. Groundwater monitoring cost is
based on quarterly monitoring for 2 years, semi-annual monitoring
for an additional 3 years, and annual monitoring for the remaining
life of the project. Ten wells would be sampled and analyzed.
Under the no action alternative, the estimated time frame for
groundwater to attenuate naturally and meet MCLs is 46 years, and
to meet background concentrations, 68 years. Because this
alternative will result in contaminants remaining on-site, CERCLA
Section 121 (c) requires that a site review be conducted every 5
years.
The present worth cost for a 35-year period is $223,000. This
alternative could be implemented immediately.
Alternative 2; Institutional Controls
$224,000
This alternative would not require implementation of remedial
actions to address groundwater or soil contamination. Deed
restrictions would be imposed to prevent excavation of contaminated
soils on-site, and to prohibit on-site groundwater use for domestic
purposes, including drinking water. A long-term groundwater
monitoring program would also be implemented using previously
installed wells. Because this alternative will result in
contaminants remaining on-site, CERCLA Section 121 (c) requires
that a site review be conducted every 5 years.
The present worth cost for a 35-year period is $224,000. This
alternative could be implemented immediately.
Alternative 3: Impermeable Cover
$640,000
-Impermeable cover over former lagoon area
-Surface water run-off controls
-Groundwater monitoring
-Deed restrictions
This alternative would require that an impermeable two-foot clay
cover or equivalent be installed over the soil-covered former
lagoon area. The clay cover or equivalent would be covered with two
additional feet of topsoil and seeded with grass. Routine
monitoring and maintenance of the cover will be required. The
former lagoon area now covered with asphalt would be sealed with
another asphalt layer. Runoff from the graded cover and parking
lot would be collected and conveyed to a stormwater collection
system.
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This alternative would not involve groundwater remediation. As in
Alternative 2, deed restrictions and long-term groundwater
monitoring will be required. Because this alternative will result
in contaminants remaining on-site, CERCLA Section 121(c) requires
that a site review be-conducted every 5 years. The present worth
cost is _$640,000 (35 years). The impermeable cover could be
installed in one year.
Alternative 4; Groundwater Pumping and Treatment (Solids
Removal)
$1,806,700
-Groundwater pump and treat
-Groundwater monitoring
-Deed restrictions
This alternative would not require implementation of remedial
actions to address surface and subsurface soil contamination.
Groundwater would be collected using a series of extraction wells
and treated in an on-site treatment system for removal of suspended
solids using a settling tank and filtration system. The treated
groundwater would be discharged through a new outfall pipe that
would be installed from the Site to Saucon Creek. Groundwater
treatment for solids removal is expected to remove elevated levels
of metals but will not significantly reduce the levels of volatile
organic contaminants (VOCs) in the extracted groundwater. Treated
groundwater discharged to Saucon Creek would not be expected to
comply with all federal and state standards because of the level of
VOCs in the discharge. Solids collected from the solids removal
process would be sampled for compliance with RCRA requirements and
disposed off-site.
Periodic groundwater monitoring would be required for the life of
the project. Groundwater monitoring cost is based on quarterly
groundwater sampling for the first two years and semi-annually for
the remaining life of the project. Ten wells would be sampled.
Because this alternative would result in contaminants remaining on-
site, 5-year site reviews under Section 121(c) of CERCLA would be
required.
The present worth cost of this alternative is $1,806,700 (35
years). The time to reduce the groundwater contaminants based on
ARARs is estimated to be 30-40 years.
Alternative 5; Groundwater Pumping and Treatment (Solids
Removal and Air Stripping)
$1,836,100
-Groundwater pump and treat
-Groundwater monitoring
-Deed Restrictions
This alternative is similar to Alternative 4, except that
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groundwater would be treated using solids removal and air
stripping. Air stripping would treat the VOCs in the groundwater.
The air and VOCs exiting the air stripping column would be treated
by a carbon adsorption unit, if necessary, to meet federal and
State standards for a-i-r emissions. With the additional treatment
with air stripping, the treated groundwater discharge would comply
with NPDES" effluent limitations for discharge to Saucon Creek.
Monitoring requirements would be the same as Alternative 4.
The present worth cost of this alternative is $1,836,100 (35
years). The time it will take to reduce the groundwater
contaminants to ARARs levels is estimated to be 30-40 years.
Alternative 6; Impermeable Cover, Groundwater Pumping and
Treatment (Solids removal and air stripping)
$2,250,000
-Impermeable Cover
-Surface Water Runoff Controls
-Groundwater Pump and Treat
-Groundwater Monitoring
-Deed Restrictions
This alternative is a combination of Alternatives 2, 3, and 5.
Alternative 6 provides containment of contaminated soils as
described in Alternative 3, remediation of contaminated groundwater
as described in Alternative 5, and deed restrictions on the
property as described in Alternative 2.
The present worth cost of this alternative (35 years) is
$2,250,000. The time to implement this alternative is estimated to
be 30-40 years.
VTII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The six remedial action alternatives described above were evaluated
using nine evaluation criteria. The resulting strengths and
weaknesses of the alternatives were then weighed to identify the
alternative providing the best balance among the nine criteria.
These nine criteria are:
Threshold Criteria
-Overall protection of human health and the environment
-Compliance with applicable or relevant and appropriate
requirements
Primary Balancing Criteria
-Reduction of toxicity, mobility, or volume
-Implementability
-Short-term effectiveness
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-Long-term effectiveness
-Cost
Modifying Criteria
-Community acceptance
-State acceptance
A. Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected remedial
action be protective of human health and the environment. A remedy
is protective if it eliminates, reduces, or controls current and
potential risks posed through each exposure pathway to acceptable
levels through treatment, engineering controls, or institutional
controls.
Alternative 1, the no action alternative, does not include
treatment or controls, provides no reduction in risk, and is not
protective. Alternative 1 will therefore no longer be discussed
with regard to remediation of soils and groundwater.
Alternative 2, institutional controls (deed restrictions), would
minimize further access to the Site and use of the groundwater but
provides only minimal health protection and no environmental
protection. No provisions would be made to treat groundwater, to
reduce infiltration of rainwater into the lagoons, or to prevent
migration of contaminants from the Site.
Alternative 3 proposed placing an impermeable cover over all
contaminated areas where the former lagoons were located. This
alternative would be protective and would prevent potentially
adverse exposure risks associated with current and future site use
by eliminating exposure routes such as dermal contact and ingestion
of contaminated soils. Under alternative 3, no provisions would be
made to treat groundwater or to prevent migration of contaminants
in groundwater from the Site.
Alternatives 4 and 5 include extraction and treatment of
groundwater with discharge to Saucon Creek. Alternatives 4 and 5
would be protective. Public and environmental' risks from direct
contact and ingestion of contaminated groundwater would be
mitigated through treatment of the groundwater plume. The risk
from direct contact with soils on-site would still pose a low level
risk.
Alternative 6, which proposes a combination of an impermeable
cover, surface water run-off controls, extraction and treatment of
groundwater, long-term groundwater monitoring and deed
restrictions, provides the greatest overall level of protection.
Exposure to both soils and groundwater would be mitigated through
containment of soils and treatment of groundwater to risk-based
cleanup levels, therefore reducing potential risks to present and
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future residents in the area near the Site.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
Section 121(d) of CERCLA requires that remedial actions at CERCLA
sites at least attain legally applicable or relevant and
appropriate federal and State standards, requirements, criteria,
and limitations which are collectively referred to as "ARARs,"
unless such ARARs are waived under CERCLA Section 121 (d)(4).
Applicable requirements are those substantive environmental
protection requirements, criteria, or limitations promulgated under
federal or State law that specifically address hazardous substances
found at the site, the remedial action to be implemented at the
site, the location of the site, or other circumstances present at
the site. Relevant and appropriate requirements are those
substantive environmental protection requirements, criteria, or
limitations promulgated under federal or State law which, while not
applicable to the hazardous materials found at the site, the
remedial action itself, the site location or other circumstances at
the site, nevertheless address problems or situations sufficiently
similar to those encountered at the site that their use is well-
suited to the site. ARARs may relate to the substances addressed
by the remedial action (chemical-specific), to the location of the
site (location-specific), or the manner in which the remedial
action is implemented (action-specific).
Alternatives 4, 5, and 6 include groundwater remediation as a
component of the remedy. The contaminant levels for VOCs currently
in the groundwater plume exceed MCLs in the Safe Drinking Water Act
and also exceed the Commonwealth of Pennsylvania's criteria for
remediation to background concentrations. Once groundwater
treatment is implemented, remediation to groundwater levels that
meet federal and State ARARs will be required. Alternatives 5 and
6 (groundwater treatment with solids removal and air stripping) can
be designed to comply with all ARARs. Alternative 4 (groundwater
treatment with solids removal only) would not be expected to meet
federal and State ARARs because of the level of VOCs in the treated
groundwater discharged to Saucon Creek. Alternatives 4, 5, and 6
would also meet all action-specific ARARs relating to activities
performed as part of the remedy, including NPDES discharge and
design requirements, federal and State air emission requirements,
and treatment, storage, and disposal requirements for any waste
sludges generated during the groundwater treatment process.
Alternatives 3 and 6 require that the soil-covered former lagoon
area be covered with an impermeable clay layer or equivalent and
two feet of topsoil. The former lagoon area covered with asphalt
would be covered with a reinforcement layer and another asphalt
layer. (Contaminants that remain on-site in the former lagoon area
are not RCRA wastes and EPA has determined that the contaminants do
not pose a principal threat. Therefore, ARARs for RCRA closure are
not applicable or relevant and appropriate for this Site.)
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C. Reduction of Toxicitv. Mobility, or Volume
This evaluation criteria addresses the degree to which a technology
or remedial alternative reduces toxicity, mobility, or volume of
hazardous substances.--
Alternatives 2 and 3 are remedial actions that do not use treatment
technologies. The toxicity, mobility, and volume of the
contaminants would not be reduced, since the physical, chemical, or
biological characteristics of the waste would not be altered
through treatment.
Alternatives 4, 5, and 6 will result in the reduction of toxicity,
mobility or volume of site contaminants in groundwater through the
treatment technologies of solids removal for metals treatment and
air stripping for treatment of VOCs. Alternative 4 employs solids
removal only for groundwater treatment. Alternatives 5 and 6,
which use both solids removal and air stripping for VOC removal,
will result in increased reduction of toxicity due to treatment of
VOCs in groundwater. Contaminants released to the air during air
stripping may need to be treated with carbon adsorption, depending
on the concentration of contaminants released during air stripping.
The treatment process for solids treatment will result in sludge
which will require management as a solids residual. Neither
Alternative 4 or 5 provides any reduction of toxicity, mobility, or
volume of contaminated soils; Alternative 6, which employs an
impermeable cover, provides reduction of mobility of the
contaminants in soil but not toxicity or volume.
D. Implementabilitv
Implementability refers to the technical and administrative
feasibility of a remedy, from design through construction,
operation, and maintenance. It also includes coordination of
federal, State, and local governments to clean up the site.
All alternatives evaluated are considered implementable and use
technologies that have been recommended at other Superfund sites.
All alternatives require groundwater monitoring, and Alternatives
4, 5, and 6 will require monitoring of the treated groundwater
discharge. Monitoring activities and discharge requirements will
be developed in coordination with the Pennsylvania Department of
Environmental Resources ("the Pennsylvania DER").
Alternative 3 would be the easiest technology to implement because
the impermeable cover could be installed in approximately one year
and would require minimum operation and maintenance. Excavation
and grading would be required as part of implementation of this
remedy. Alternatives 4, 5, and 6, involving groundwater
remediation, present minimum technical difficulties in designing
and constructing a treatment system, but may require pilot studies
and additional groundwater investigations during the design stage.
The reliability of groundwater treatment systems involving solids
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removal and air stripping is well established and has been
demonstrated at other hazardous waste sites.
E. Short-Term Effectiveness
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 remediation goals are achieved.
None of the alternatives evaluated involve extensive construction,
excavation, or other remedial action measures that would pose any
appreciable short-term risks to the community and to workers during
construction and implementation. Workers will be required to wear
Level C protective equipment (protective clothing and respirator),
and Site perimeter air monitoring will be required during
construction activities. Alternative 3, placement of the
impermeable cover, can be completed in about one year and will not
involve excavation of the former landfill area except at the
surface where the new cover will be installed. No adverse effects
to workers or the community are expected. Alternatives 5 and 6
will require that an evaluation of air releases from the air
stripper be conducted during the design phase so that control of
the release of contaminants to the air can be evaluated.
F. Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time. This criteria evaluation includes the
consideration of residual risk and the adequacy and reliability of
controls.
Alternatives 1, 2, and 3 will result in more than minimal residual
risk from groundwater ingestion, dermal contact and inhalation
under the future use reasonable maximum exposure scenario, since
groundwater will not be treated or contained and ARARs will not be
attained. Institutional controls will only mitigate residual risk
at the Site by minimizing the use of groundwater at the Site. The
impermeable cover in Alternative 3 will result in minimal risk from
surface soils by preventing long-term direct contact and
inadvertent ingestion.
Alternatives 4, 5, and 6 will provide the greatest degree of long-
term effectiveness and permanence for groundwater remediation and
will result in minimal residual risk by attaining ARARs for
groundwater. Alternatives 4 and 5 will not prevent long-term
direct contact of soils.
G. Cost
This criteria examines the estimated costs for each remedial
alternative. For comparison, capital, annual O&M, and present
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worth costs are shown in Table 8.
H. State Acceptance
The Pennsylvania DER eencurs on EPA's selected remedy, Alternative
6. -
I. Community Acceptance
A public meeting on the Proposed Plan was held August 13, 1991 in
Hellertown, Pennsylvania. Comments received orally at the public
meeting and in writing during the public comment period are
referenced in the Responsiveness Summary attached to this Record of
Decision. Residents of the Borough of Hellertown have not objected
to the selected remedy. Champion Spark Plug Company has
recommended that EPA select Alternative 2, the institutional
controls alternative.
SD REMEDY; DESCRIPTION AND PERFORMANCE STANDARD(S) FOR
EACH COMPONENT OF THE REMEDY
EPA has selected Alternative 6 as the remedy for the Hellertown
Manufacturing Company Site. The selected remedy consists of the
following components:
-Placement of an impermeable cover over the entire former
lagoon area;
-Surface water runoff controls;
-Extraction and treatment of groundwater (air stripping and
solids removal) with discharge to Saucon Creek;
-Long-term groundwater monitoring; and
-Deed restrictions.
Each component of the remedy and its performance standard(s) will
be described in turn.
A. Impermeable Cover
The former lagoon area encompasses 145,000 square feet or 3.5
acres. (See Figure 5) . Former lagoons 1 and 5 are covered with an
asphalt parking lot which has several noticeable cracks. Former
lagoons 2, 3 and 4 are contiguous with the parking lot and are
covered with soil.
As part of the selected remedy, an asphalt and clay impermeable
cover shall be constructed over the entire former lagoon area. The
portion which is now covered with asphalt shall be covered with a
reinforcement layer and a new asphalt concrete cover. (The purpose
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of the reinforcement layer is to minimize cracking of the asphalt
concrete cover.) The portion of the former lagoon area which is
now covered with soil shall be covered with a two-foot compacted
clay cover or the equivalent, topsoil and grass. Both portions of
the cover shall be designed to achieve a permeability of no more
than 1 _x _10"7 cm/sec, which shall constitute the Performance
Standard. (This impermeable cover is not a RCRA cap and there are
no ARARs that are applicable, relevant or appropriate.)
As discussed above, the clay and soil portion of the cover shall be
designed to achieve a permeability of no more than 1 x 10"7 cm/sec.
Asphalt concrete is a hot-mixed and hot-laid mixture of asphalt and
graded aggregates which produces a harder, denser, and more
resistant surface than paving asphalt. Permeabilities ranging from
1 x 10'5 cm/sec to 10"' cm/sec can be achieved ("Lining of Waste
Containment and Other Impoundment Facilities," EPA Document 600/2-
88/052, September 1988). Thus, both the asphalt concrete and clay
portions of the cover will achieve equivalent permeability.
In order to maintain the Performance Standard of no more than 1 x
10"7 cm/sec, routine inspection and maintenance of the impermeable
cover shall be required until such time as EPA and Pennsylvania DER
determine that the Performance Standard for each contaminant in the
groundwater has been achieved to the extent technically practicable
throughout the entire area of groundwater contamination (an
estimated 30 to 40 years). Maintenance shall include repairs to
the asphalt portion of the cover as necessary to correct cracks and
the effects of settling, subsidence, erosion, etc., and the
cultivation of natural vegetation (grasses and weeds) on the clay
and topsoil portion of the cover to prevent erosion. Because the
selected remedy will result in contaminants remaining on-site, 5-
year Site reviews under Section 121(c) of CERCLA will be required.
B. Surface Water Runoff Controls
A storm water collection system consisting of catch basins and
drain pipes shall be constructed for the asphalt parking lot and
the entire former lagoon area. The Performance Standard for this
system shall be that it effectively collects storm water from the
parking lot and former lagoon areas and conveys it to an existing
storm drainage pipe on the northern boundary of the Site. (There
are no ARARs that are applicable, relevant or appropriate to this
system.) In order to maintain the integrity and effectiveness of
this storm water collection system, routine inspection and
maintenance of the system shall be required until such time as EPA
and the Pennsylvania DER determine that the Performance Standard
for each contaminant in the groundwater has been achieved to the
extent technically practicable throughout the entire area of
groundwater contamination (an estimated 30 to 40 years).
C. Extraction and Treatment of Groundwater
The selected remedy includes groundwater extraction, treatment and
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discharge, which shall be required until such time as EPA and the
Pennsylvania DER determine that the Performance Standard for each
contaminant in the groundwater has been achieved to the extent
technically practicable throughout the entire area of groundwater
contamination, both on-site and off-site (an estimated period of 30
to 40 years). (See Figure 4).
1. Groundwater Extraction and Treatment System
Groundwater shall be extracted using multiple extraction wells, the
exact location and number of which shall be determined during the
design of the groundwater recovery system. Recovered groundwater
shall be treated using an on-site treatment system. Suspended
solids shall be removed using solids settling in a settling tank or
clarifier followed by an on-line filtration unit. The groundwater
shall then be treated using a packed column airstripping unit.
Final flow rates and air stripper dimensions will be determined
during the remedial design. The treated effluent shall be
discharged to Saucon Creek through a new outfall pipe that shall be
constructed as part of the remedial action.
2. Performance Standards for Groundwater
The Performance Standard for each contaminant of concern in the
groundwater shall be the MCL for that contaminant (the federal ARAR
for public drinking water supplies under the Safe Drinking Water
Act) or the background concentration of that contaminant (the
Pennsylvania ARAR under 25 PA Code §§ 264.90 - 264.100), whichever
is more stringent. The background concentration for each
contaminant of concern shall be established in accordance with the
procedures for groundwater monitoring outlined in 25 PA Code §
264.97 before groundwater treatment begins. In the event that a
contaminant of concern is not detected in samples taken for the
establishment of background concentrations, the detection limit
for the method of analysis utilized with respect to that
contaminant shall constitute the "background" concentration of the
contaminant.
The MCLs for benzene, trichloroethylene, and vinyl chloride are set
forth at 40 C.F.R. § 141.61. The MCLs for tetrachloroethylene,
trans-l,2-dichloroethylene, and cis-l,2-dich'loroethylene were
published in the Federal Register at 56 Fed. Rea. 3593 on January
30, 1991. The MCLs, detection limits and appropriate analytical
detection methods for these contaminants of concern are listed
below:
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Contaminant MCLfua/1) Detection Limit fua/1
Benzene 5 0.20 603/602
Tetrachloroethylene 5 0.03 60V602
Trichloroethylene --5 0.12 6OT/602
Vinyl Chloride 2 0.18 eQV6Q2
Dichloroethylene 100 0.10 603/602
(trans-1,2-)
Dichloroethylene 70 0.12 524.2
(cis-1,2-)
Method 601/602 is found at 40 C.F.R. Part 136
Method 524.2 is found at 40 C.F.R. Part 141
3. ARAR Requirements Which Shall Be Met for Groundwater
The following ARARs shall be met, in addition to the federal and
state ARARs discussed under "Performance Standards," above, for
each contaminant of concern in the groundwater.
Since the treated groundwater will be discharged to Saucon Creek,
NPDES requirements and state water quality criteria under the
Pennsylvania Clean Streams Law are applicable. During the design
of the groundwater treatment system, specific discharge criteria
will be established by Pennsylvania DER as set forth in 25 PA Code
§§ 93.1 - 93.9.
Emissions from the air stripping tower, including benzene and vinyl
chloride, shall be monitored and, if required, a vapor phase carbon
adsorption or thermal destruction unit shall be installed to ensure
compliance with Section 112 of the Clean Air Act, 42 U.S.C § 7412
National Emission Standard for Hazardous Air Pollutants (NESHAPs) .
The relevant and appropriate NESHAP for benzene is set forth at 40
C.F.R. Part 61, Subpart L, and the relevant and appropriate NESHAP
for vinyl chloride is set forth at 40 C.F.R. Part 61, Subpart F.
During design of the air stripping unit, the Pennsylvania DER will
determine from actual design flow rates and VOC loading rates
whether emission controls need to be installed.
The removal of suspended solids in a settling tank will result in
the generation of small quantities of residual solids requiring
disposal. The exact quantity will vary with treatment flow rates.
These residual solids shall be tested to determine if they are a
RCRA hazardous waste. If they are, the RCRA storage and
transportation requirements for off-site disposal of these wastes
(40 CFR Parts 262-264), and the Department of Transportation Rules
for Hazardous Materials Transport (49 CFR Parts 107 and 171-179) ,
shall be met.
During all site work, Occupational Safety and Health Administration
(OSHA) standards set forth at 29 CFR Parts 1910, 1926 and 1904
governing worker safety during hazardous waste operations, shall be
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met.
4. Groundwater Remedy Implementation
During the conduct of-the RI/FS, EPA identified several springs (or
seeps) along Saucon Creek in the vicinity of the Site. It could
not be determined if there is a hydraulic connection between
groundwater on-site and the discharge of the springs. During the
remedial design period additional field work shall be conducted to
determine if these springs/seeps are a groundwater pathway for
discharge of contaminants to Saucon Creek. The springs/seeps may
discharge high levels of contaminants to Saucon Creek and may pose
a risk either to users of the creek or to persons or animals who
come into direct contact with the seeps. The design and
construction of the groundwater pump and treatment system shall be
coordinated with this investigation so that design and
implementation schedules are compatible. If necessary, a program
to remediate the discharge from the springs may be required. In
that event, EPA will issue an Explanation of Significant
Differences.
The wetland area adjacent to Saucon Creek is potentially affected
by the migration of contaminants through groundwater discharge.
Surface water in the wetlands area contained inorganic compounds
and metals - in particular, elevated levels of zinc. Sediments
contained metals and PAH compounds. The results of the sampling
survey in the RI/FS were inconclusive in determining whether
contaminants are present in the wetland area above background
levels and whether the wetland area receives contaminants from
groundwater discharge or through storm drainage, or a combination
of both. Additional wetland soil, stream, sediment, and surface
water sampling will be required as part of the remedial design
study. If necessary, a program to remediate the wetland area may
be required. In that event, EPA will issue an Explanation of
Significant Differences.
An operation and maintenance plan for the groundwater extraction
and treatment system shall be required. The performance of the
groundwater extraction and treatment system shall be carefully
monitored on a regular basis and the system may be modified, as
warranted by the performance data collected • during operation.
These modifications may include, for example, alternate pumping of
extraction wells or the addition or elimination of certain
extraction wells.
It may become apparent during implementation or operation of the
groundwater extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the Performance Standards over some
portion of the contaminated plume. If EPA and the Commonwealth of
Pennsylvania determine that implementation of the selected remedy
demonstrates, in corroboration with hydrogeological and chemical
evidence, that it will be technically impracticable to achieve and
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maintain the Performance Standards throughout the entire area of
groundwater contamination, EPA and the Pennsylvania DER may require
that any or all of the following measures be taken, for an
indefinite period of time, as further modification(s) of the
existing system: . .__
1) long-term gradient control may be provided by low level
pumping, as a containment measure;
2) chemical-specific ARARs may be waived for those portions of the
aquifer for which EPA and Pennsylvania DER determine that it is
technically impracticable to achieve further contaminant reduction;
3) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above Performance Standards; and
4) remedial technologies for groundwater restoration may be re-
evaluated.
The decision to invoke any or all of these measures may be made
during the 5-year reviews of the remedial action. If such a
decision is made, EPA will amend the ROD or issue an Explanation of
Significant Differences.
D) Lona-Terro Groundwater Monitoring
A long-term groundwater monitoring program shall be implemented to
evaluate the effectiveness of the groundwater pumping and treatment
system. Monitoring wells shall be installed in the area of
groundwater contamination and sampled for an estimated 30 to 40
years, until such time as EPA and the Pennsylvania DER determine
that the Performance Standard for each contaminant of concern has
been achieved to the extent technically practicable throughout the
entire area of groundwater contamination. The number and location
of these monitoring wells shall be specified in the design of the
extraction system. Sampling shall be on a quarterly basis for the
first two years and on a semi-annual basis thereafter.
An operation and maintenance plan for the groundwater monitoring
system shall be required.
E) Deed Restrictions
As soon as practicable, restrictions shall be placed in the deed to
the Site to prohibit (1) excavation of contaminated soils; and (2)
the use of on-site groundwater for domestic purposes, including
drinking water. The continuing need for these restrictions will be
re-evaluated during the 5-year Site reviews under Section 121 (c) of
CERCLA.
23
-------
X. STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. Section-121 of CERCLA also requires that the selected
remedial action comply with ARARs, be cost-effective, and utilize
permanent treatment technologies to the maximum extent practicable.
The following sections discuss how the selected remedy meets these
statutory requirements.
A. Protection of Human Health and Environment
Based on the baseline risk assessment for the Site, potential
exposure to VOCs in drinking water through ingestion, inhalation,
and dermal contact, was identified as the principal risk at the
Site. Potential exposure to soils was not determined to be a
principal threat based on the level of contaminants in soil and the
baseline risk assessment.
The selected groundwater remedy protects human health and the
environment by reducing levels of contaminants in the groundwater
to ARARs through extraction and treatment. The risk level is
reduced to the 10"6 level or less. The source control remedy will
also protect human health and the environment by placing an
impermeable cap over the contaminated soil, thereby preventing
exposure through inhalation, ingestion, and dermal contact. A risk
level of 7 x 10"5 for carcinogens will be attained. In addition,
containment of contaminated soils will eliminate the source of
continued contaminant loading to the aquifer by minimizing the
infiltration of rainwater and the subsequent leaching of
contaminants to the aquifer.
During the RI/FS investigation the Summers model for groundwater
contamination transport was used to estimate the concentration of
TCE in soils that would result in a concentration of TCE in
groundwater of 5 ug/1, the MCL. TCE was used in the model because
it represents the highest VOC contaminant concentration in both
soil and groundwater. Depending on the assumptions used in the
model, the calculated allowable TCE concentration in soil which
would achieve a groundwater concentration of 5 ug/1 ranged from 124
ug/kg to 1103 ug/kg. The 95 percent upper confidence level of TCE
in soil samples collected from the lagoon area is 99 ug/kg, the
mean value is 64 ug/kg, and the median value is 25 ug/kg. Since
the measured TCE concentration of 99 ug/kg is less than the range
of TCE values calculated with the summers model, the model predicts
that the contaminant concentration of TCE in soil will not degrade
groundwater to levels that exceed MCLs based on assumed
infiltration rates once the impermeable cover is in place.
Implementation of Alternative 6 will not pose any unacceptable
short-term risks or cross-media impacts to the Site or the
community.
24
-------
B. Attainment of Applicable or Relevant and Appropriate
Requirements of Environmental Lavs
All ARARs will be met by the selected remedy.
1. Chemical Specific ARARs
The selected remedy shall be designed to achieve compliance with
chemical specific ARARs related to groundwater, ambient air
quality, and surface water at the Site. The Safe Drinking Water
Act specifies MCLs for drinking water at public water supplies.
Some contaminants of concern identified for the Site have MCLs
which are relevant and appropriate for this remedial action. The
MCLs shall be achieved for benzene, trichloroethylene,
tetrachloroethylene, cis-l,2-dichloroethylene, trans-1,2-
dichloroethylene, and vinyl chloride throughout the entire
contaminated groundwater plume. These MCLs are listed in Section
IX.C.2 above.
The Commonwealth of Pennsylvania standards specify that all
groundwater containing hazardous substances must be remediated to
"background" quality pursuant to 25 PA Code §§ 264.90-264.100, and
in particular, 25 PA Code §§ 264.97(i), (j), and 264.100(a)<9) .
The Commonwealth of Pennsylvania also maintains that the
requirement to remediate to background is found in other legal
authorities. The method(s) by which background levels will be
determined are set forth under the description of the selected
remedial alternative. These background levels shall be attained as
part of this remedial action unless EPA and the Commonwealth
determine that attaining such levels is technically impracticable,
or they are waived under CERCLA Section 121(d).
The selected remedy will meet the NESHAP requirements of the
federal Clean Air Act for vinyl chloride and benzene as specified
in Section IX.C.3 above.
The requirements of Subpart AA (Air Emission Standards for Process
Vents) and BB (Air Emission Standards for Equipment Leaks) of the
federal RCRA regulations set forth at 40 C.F.R. Part 264 are
relevant and appropriate (and, depending upon the levels of
organics in the extracted groundwater and treatment residuals) may
be applicable to the air stripping operations under the Selected
Remedy. These regulations require that total organic emissions
from the air stripping process vents must be less than 1.4 kg/hr (3
Ib/hr) and 2.8 mg/yr (3.1 tons/yr).
2. Action-Specific ARARs
Section IX.C.3 above describes how the selected remedy will meet
the requirements of the following ARARs: (1) the federal National
Pollutant Discharge Elimination System (NPDES) under the Clean
Water Act; (2) the Pennsylvania Clean Streams Law; (3) OSHA
standards governing worker safety during hazardous waste
25
-------
operations; and (4) RCRA storage and transportation requirements
and the Department of Transportation Rules for Hazardous Materials
Transport, if the latter become applicable, relevant or
appropriate.
To the extent that new-point source air emissions result from the
implementation of the remedial alternative, 25 Pa. Code §
27.12(a)(5) will apply, requiring that emissions be reduced to the
minimum obtainable levels through the use of best available
technology (BAT), as defined in 25 Pa. Code § 121.1.
Prior to the treatment of the groundwater, the groundwater will be
tested to determine if it is a RCRA hazardous waste. If it is a
RCRA waste, the air stripper will be designed in accordance with
RCRA treatment standards 40 C.F.R. Part 264 and 25 Pa. Code
Chapters 260 through 265 and Chapter 270.
3. Location Specific ARARS
No location specific ARARs have been identified relative to this
Site.
c. cost Effectiveness
The selected remedy is cost-effective in providing overall
protection in proportion to cost, and meets all other requirements
of CERCLA. The NCP, 40 C.F.R. Section 300.430(f)(ii)(D), requires
EPA to evaluate cost-effectiveness by comparing all the
alternatives which meet the threshold criteria - protection of
human health and environment and compliance with ARARs - against
three additional balancing criteria: long-term effectiveness and
permanence; reduction of toxicity, mobility or volume through
treatment; and short-term effectiveness. The selected remedy meets
these criteria and provides for overall effectiveness in proportion
to its cost. The estimated present worth cost for the selected
remedy is $2,250,000. A detailed cost estimate is shown in Table
9.
D. Utilization of Permanent Solutions and Alternative Treatment
shnolocries to the Maximum Extent Practicable
EPA has determined that the selected remedy 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 those alternatives evaluated that are
protective of human health and the environment and meet ARARs, the
selected remedy provides the best balance of tradeoffs in terms of
long-term and short-term effectiveness and permanence, cost,
implementability, reduction in toxicity, mobility, or volume
through treatment, State and community acceptance, and preference
for treatment as a principal element.
26
-------
Under the selected remedy, treatment of groundwater using both
suspended solids removal and air stripping will provide a greater
degree of reduction of toxicity, mobility, or volume than the other
alternatives evaluated. Alternative 6 will reduce contaminant
levels in groundwater and reduce the risks associated with
ingestion of the groundwater to the maximum extent practicable, as
well as-provide long-term effectiveness.
The selection of containment of contaminated soils using an
impermeable cover is consistent with Superfund program policy of
containment, rather than treatment, for wastes that do not
represent a principal threat at the site and are not highly toxic
or mobile in the environment. The impermeable cover reduces
mobility, reduces risk to human health and the environment, and
provides short-term effectiveness and long-term effectiveness, if
the cover is properly maintained.
E. Preference for Treatment: aa a Principal Element
The selected remedy satisfies, in part, the statutory preference
for treatment as a principal element. Alternative 6 addresses the
primary threat of future direct contact and ingestion of
contaminated groundwater through treatment using suspended solids
removal and an air stripper. Since the contaminated soil does not
constitute a principal threat, treatment is not required.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Hellertown Manufacturing Site was
released for public comment on July 26, 1991. The Proposed Plan
identified Alternative 6 as the selected remedy. EPA reviewed all
written and verbal comments submitted during the public comment
period. No significant changes to the remedy, as it was originally
identified in the Proposed Plan, were necessary. EPA has updated
the cost estimates for alternatives 4, 5, and 6 set forth in the
Proposed Plan based on the increased capital cost of installing a
new outfall pipe to Saucon Creek and updated groundwater monitoring
costs.
27
-------
GLOSSARY
Administrative Record: An official compilation
of documents, .data, reports, and other
information that is considered important to the
status of and decisions made relative to a
Superfund site. The public has access to this
material.
Apofcable or noiovant and Appropriate
Requirements (ARARs): The federal and state
requirements that a selected remedy must
attain. These requirements may vary among
sites and alternatives.
Aqurer A zone below the surface of the earth
capable of producing water, as from a well.
Comprehensive Environmental Response.
Compensation and Uabsty Act (CERCLA), or
Superfund: A federal law passed in 1980 and
modified in 1986 by the Superfund
Amendments and Reauthorization Act The
Act created a trust fund, known as Superfund,
to investigate and dean up abandoned or
uncontrolled hazardous waste sites.
Fractured Bedrock: Breaks in underground
rock formations caused by intense folding or
faulting.
Ground water Water found beneath the
earth's surface in geologic formations that are
fully saturated. When it occurs in sufficient
quantity, ground water can be used as a water
supply.
Present Worth: A term used to indicate the
discounting of sums to be received in the
future to their present value equivalent, or the
amount which will accumulate to that sum if
invested at prevailing interest rates.
Record of Decision (ROD): A legal document
that describes the final remedial actions
selected for a Superfund site, why the remedial
actions were chosen and others not how
much they cost, and how the public
responded.
Remedtel Investigation/Feasibfflry Study
(RI/FS): A two-part study of a hazardous
waste site that supports the selection of a
remedial action for a site. The first part, the Rl,
identifies the nature and extent of
contamination at the site. Tn%second part,
the FS, identifies and evaluates alternatives for
addressing the contamination.
Voiatle Organic Compounds (VOCs): Organic
liquids that readily evaporate under
atmospheric conditions. Examples of VOCs
include vinyl chloride and trichtoroethylene
(TCE).
Hazard Index: A value used to evaluate the
potential for noncardnogenic effects that occur
in humans.
National PrtortfMUtfpPl): EPA's tot of the
nation's top priority hazardous waste sites that
are eigtole to receive federal money for
response under Superfund,
Operable Unt (QU): A portion of a Superfund
site that has been conceptually separated from
the rest of the site to stow for easier
management
POOR QUALITY
ORIGINAL
-------
S««rct: USCS 7 S-
Strut r*pi|ri|lic Htf
H*llirtt«*
POORQUALIIY
ORIGINAL
-------
Figure 2
I .K.IIKMI nl All Soil II , Dulled
al (he l-oiiiu-f
-------
Ill
CSP I
Scato
HO
CSP 12
Silo
Legend
CS»> 1(1) UomllH.ig Wt-i
•M. t iMif «§s cm»u««nDii
ESC «»«•«•
Sue rt«o Shuwmf Well I .uttuuu!
Hutiiici IIMC Sue. Ikllcnuwn. tam>yl»i»
IVNIOIdO
Ainvno yood
Figure 3
-------
Figure 4
Approximate ' - with Elevated Groundwalcr Conumiiunu
Former HMC Helleitown. Pennsylvania
-------
Figure 5
08
|5 ID
oo
I
2
1
4
5
Area I
Arc. 2
Area}
Am Dep* Volume
(•qumfeei) (fog (ooUcyante)
15*00 n 9.150
11500 24 U.IOO
11300 22 9.170
31.200 n 32300
I4JOOO 25 12^00
93.100
26300
24.800
Ufooa Sun AppnoinUe
SlunyWiUOISLF.)
Scale (fi)
ESC
ENVIRONMENTAL STRATEGIES CORPORATION
OaZtUMburflPHw SUteOW
Vlwina.Vbglnia22ia2
70^821 3700
Areas and Volumes for Remediation Alicmaiives
Former HMC Siie
-------
Table 1
Voiaflt Qrpnfe
Tridilaroetbykae
Xyim(tgaO
1 J-Dfchlaroed»ylBoe* (tool)
Vinyicfakridi
560
27
77
64
620
130
8
1
21
2
2
2
mitfrn
66
35
19
15
14
14
21
H
4
4
1
1
TTi» 0al umber of anptes «ilyxcd is 85.
ftan Lifoaa Nd 4 it ri»
Sodfcnn
Cy«kto(BttO
Flaaridt
SuMM»
17/17
17/17
17A7
17/17
17/17
10/17
17A7
17A7
5-
641 -
8 •
8460 .
91 -
2-
1 -
150 •
16
146^00
520
7SJOO
M20
496
5
5,100
10
34^54
103
25.720
322
70
3
1.757
4
14,780
35
11423
55
1
' OJ
13
t/ Viloet repartad it not daeettd wen included by Mtomtnf the compooid
POOR QUALITY
BO-2-3-5.«tfBO'3-3-5ooOeaDdiBOctttarl99a
-------
Table 2
™"1* from Oute Gromdwtter Maaitaring WeD Scopiet tt d»
Fanner Heitonown MmfKarinf Company Facility
Mnca Jane, sod September 1990 (ugyl)
Frequency of
B«yUtam
Copper
Irea
Mtgnetiam
Mingmeee
Mercuty
Nickei
saw
Sodiam
Cy«nde(io«0
Fluoride
Sulfue
21/36
4/36
34/36
15/36
12/36
33/36
3636
33/36
4/36
20/36
10/33*
7/30
36/36
22/36
13/36
27/36
36/36
34 -
1 -
12JOO •
10 -
5 -
59 -
2,680 -
4 •
02 •
4 •
2 •
3 •
10.800 •
20 •
12 -
60 •
63.000 •
50,200
4
819JOOO
86
243
91.300
318^00
2^70
0.7
7S
110
40
93^400
2J040
1J080
1^00
580jOOO
5,891
1
196,097
21
26
11.727
108,039
510
0.1
19
13
6
29.053
190
87
378
473,336
Levdflrt
1555
ND (c)
75^22
7
ND
3.780
43,673
52
ND
7
2
ND
8093
21
4
127
110.333
V Values reponad M not deacad wen
ulalf the detection UnM. SimpliifttmCSP-2,CSP«*,CSP-5A.CSP-5B.CSP4,CSP-7,
CSP-10. CSP-11. CSP-12, CSM3.iDdCP-14 «v> igtakdta A»c«icahrionof te
CSP-1. CSM, mtCSM ***** to Iteck. IM, mA S«pMta 199a
i Qraandwaer Mootatef Wells tt the
Fanner Holknowii Mnatetoring CoapDy Fteflity
Mirch, Jane, ad September 1990 (a^)
Freqaeocyaf
Rjn|e of Detected
Acetone
l^-Dichloroeti)yleoe« (tool)
Tetnchloroedjyiene
1,1,1-THchloroetiune
Tiichloroetbyleae
Vinyl chloridi
6/36
5/36
32/36
16/36
3/36
36/36
6/36
50 •
2 -
4 -
1 •
7 -
2 -
20 •
270
93
260
22
25
1.700
83
40
15
99
15
13
364
30
-------
Table ;.-.
i Ofltte OrooDdwttr Mootarinf Wefl Sampfes u the
AMimfjiLJiifMg Coopcoy Faculty
Much, June, ad September 1990 (ug/I)
Frequency of
Rage of Detected
Beckgroond
Aluininuni
Beryllium
Chromium
Copper
Iron
Magnesium
Mangueee
Mercury
Nickd
Zinc
Fluoride
7/7
2/7
7/7
2/7
3/7
6Y7
7/7
6V7
1/7
2/7
4/7
677
103
3
44.700
72
23
198
20,900
8
45
15
100
17
510,000
372
315
280,000
427,000
9.580
1
297
950
1.100
35.036
4
175,286
66
59
50.176
127.757
1.838
OJ
53
173
329
1.955
ND (c)
75322
7
ND
3.780
48,678
52
ND
7
21
127
«/ Values reported M not detected were iadoded by Mmming die
detected in grouodwiier
b/ Background fevdi KB the men caoceomdou of
ample* CSP-1, CSP-& and CSP-9 collected in March, Jooe, nd SefMemter 1990.
c/ ND • Noe deM»d in beckgrooBd
1 J-Dichloraeibyleaei (tool) 1/7
LLl-TUcfaloraedwe 1/7
TUcbJeRMdryleae ,-• 2/7
18
4
19-51
5
3
12
•/ Vatam reported Moot detected were iadoded by Mrammf diet
•t htlf tfw detection Umic
POOR QUALITY
ORIGINAL
-------
Table 3
Key Risk Terms
Carcinogen: A substance mat increases tne incidence of cancer.
Chronic-Daily Intake (COI): The average amount of a chemical in contact with an
individual on a aaily oasis over a suostannal portion of a lifetime.
Chronic Exposure: A persistent, recurring, or long-term exposure. Chronic exoosure
may result in health effects (sucn as cancer) that are delayed in onset, occurring long
after exposure ceased.
Exposure: The opportunity to receive a dose through direct contact with a chemical or
medium containing a chemical.
Exposure Assessment: The process of describing, for a population at risk, the
amounts of chemicals to which individuals are exposed, or the distribution of exposures
within a population, or the average exposure of an entire population.
Hazard Index: An EPA method used to assesa the potential noncarcinogenic risk. The
ratio of the COI to the chronic RfO (or other suitable toxicrty value for noncarcinogens) is
calculated, if it is lesa than one. then the exposure represented by the COI is judged
unlikely to produce an adverse noncarcinogenic effect A cumulative, endpoint-specifio
HI can also be calculated to evaluate the risks posed by exposure to more than one
chemical by summing the COI RfO ratios for att the chemicals of interest exert a similar
effect on a particular organ. This approach assumes that multiple subthreshold
exposures could result in an adverse effect on a particular organ and mat the
magnitude of the adverse effect will be proportional to the sum of the ratios of the
subthreshold exposures. If the cumulative) HI is greater, than one, then there may be
concern for public health risk.
Reference DOM (RfD): The EPA's preferred toxicrty value for evaluating
noncarcinogenic effects.
Risk: The nature and probability of occurrence) of an unwanted, adverse effect on
human life or health, or on the environment
Risk Assessment The characterization ot the potential adverse effect on human life or
health, or on the environment According to the National Research Council's
Committee on the Institutional Means for Assessment of Health Risk, human health risk
description on the potential adverse hesith effects based on an
i of reeulta of eptdemtologic, cartes*, toxicologic, and environmental research;
ton from those results to predict the types and estimate the extent of health
t humans under given condition* of exposure; judgements as to me number and
eristics of persons exposed at various intensities and durations; summsry
judgements on the existence and overall magnitude of the public-hearth program; and
characterization of the uncertainties inherent in the process of inferring risk.
Slope) Factor The statistical 95% upper confidence limit on the slope of me dose
response relationship at low doses for a carcinogen. Values can range from about
0.0001 to about 100,000. in units of lifetime risk per unit dose (mg/kg-day). The larger
the value, the more potent is the carcinogen, i.e.. a smaller dose is sufficient to increase
the ris* of cancer.
POOR QUALITY
ORIGINAL
-------
Table 4
Reasonable Maximum Potential Risks Presented by die Compounds of Concern in Surface Soil
95%UCL
Exposure
ncrniralinn
PAHs
Resident Chrooic
Daily Intake
3.000 (d) 6.5E-06
Cancer
Slope Factor
llfnlkMal
11.5 (e)
Cancer
Weight of
B2(c)
Excess Lifetime
RiaLlc) '
7E-05
Reference Dose
08
33 ID
OQ
Noncaicinogenic Effects (f)
Naphthalene
Acenaplhene
Fluorene
Phenanthrene
Aniht
Fluoranthene
Pyrene
0.297
0.292
O.S16
3.187
1.431
0.679
0.349
1.6E-06
l.SE-06
2.7E-06
1.7E-05
7.7E-06
3.6E-06
1.8E-06
0.0040
0.0600
0.0400
0.0029
0.3000
0.0400
0.0300
D
ND(h)
D
D
D
D
D
Hazard Index
4E-04
3E-05
7E-05
6E-03
3EX)5
9E-05
6E-05
6E-03
a/ 95% upper confidence limit on the arithmetic mean.
b/Sum of the exposures from inadvenent ingestion and dennal absorption
of soil contaminants.
c/ Resident chronic daily intake (GDI) x cancer slope factor.
d/ Total carcinogenic PAHs expressed in benzo(a)pyrene equivalents.
See Table 6-16.
e/ Value for benzo(a)pyrene.
f/ Only noncarcinogens with RfDs are considered.
g/CDI divided by RfD.
h/ND = not determined.
Hazard Quotient (a)
-------
Table 5
Reasonable Maximum Potential Risks Presented by Showering with Onsite Groundwater
9S%UCL
CQIDDQUDd
Benzene
Teuachloroethylene
Trichloroeihylene
Vinyl chloride
0.022
0.019
0.503
0.040
Noocaroinogenic Effects (e)
1.1.1-Trichloroethane
0.017
Chronic Daily Intake (mg/kg/day)
4.9E-07
4.2E-07
1. IE-OS
8.8E-07
8.8E-07
3.4E-04
2.3E-04
6.6E-03
6.8E-04
Total (b)
3.4E-04
2.3E-04
6.6E-03
6.8E-04
Cancer Slope
Factor (c)
Cancer
Weight of Excess Risk (d)
F-YJik/KrC
0.0290
0.0018
0.0170
0.2940
Reference
A
B2
B2
A
IE-OS
4E-07
1E-04 ;
2E-04
5.2E-04
5.2E-04
0.3000
D
3E-04
Hazard
Quotient (f)
2E-03
a/ 95% upper confidence limit on the arithmetic mean.
b/ Sum of exposures from dermal absorption and inhalation of VOCs.
c/ Cancer slope factors for inhalation exposures.
O O d/CDI x cancer slope factor.
32 30 e/ Only noncarcinogejis with inhalation RfCs are evaluated.
O O V CDI divided by RfC.
-------
Table 6
Reasonable Maiimum Potential Risks Presented by Ingestion of Compounds of Concern in Qrodte ntmnujwaKr
HO
08
OQ
II
•—I
Carcinogenic Effect*
Benzene
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Beryllium
Acetone
U-Dichloroelhylenes (total)
Tetrachloroethylene
I.l.l-Trichloroethane
Chromium
Mercury
Nickel
Selenium
Cyanide
95%UCL
Exposure
0.0220
0.0190
0.3030
0.03%
0.0014
O.OS9S
0.1230
0.0190
0.0170
0.0288
0.000
0.026
0.023
0.157
a/ 95% upper confidence limit on the arithmetic mean.
b/CDI x cancer slope factor.
c/CDl divided by RfD.
e/ Chronic oral RfD for trans- 1.2-dichloroeihylene.
(J Chronic oral RfD for chromium VI.
g/ Chronic oral RfD for seknious acid.
Resident Chronic
Daily Intake
(mallfo/flyu)
2.7E-04
2.3E-04
6.2E-03
4.8E-04
1.7E-05
1.7E-03
3.5E-03
5.4E-04
4.9E-04
8.2E-04
5.7E-06
7.5E-04
6.6E-04
4.5E-03
Cancer
Slope Factor
1/fmgAg/day)
0.029
0.051
0.011
1.9
4.3 '
Reference Dose
0.1
0.02 (d)
0.01
0.09
0.005 (e)
0.0003
0.02
0.003 (0
0.02
Cancer
Weight of
A
B2
B2
A
B2
D
ND
B2
D
ND
D
ND
ND
D
Hazard Index
Excess Risk
fanner boundl flrt
KE-06
IE-OS
7E-05
9E-04
7E-05
1E-03
Hat/and Quotient (c)
2E-02
2E-01
5E-02
5E-03
2E-01
2E-02
4E-02
2E-01
2E-01
9E-01
-------
Table 7
ceadil RUks tamed by Expanse to Compomds of Concern
•t the Fanner Hdknown MMjfntmfnpmg Fvility
Total PmbwtyRijki
Bxce
iPufawcv
ingeseco atd 7E-OS 6E-03
with foil
Reasonable maximum showering with groundwiter 3E-04 2E-03
Reasonable maximum ingestion of groundwiier 1E-03 9E-01
POOR QUALITY
ORIGINAL
-------
Table 8
Cost Summary for Remedial Alternatives
Alternative
l-No Action
2-
Institutional
Controls
3-lmpermeable
Cover
4-GW Pumping
and Solids
Removal
5-GW Pumping,
Solids
Removal , Air
Stripping
6-Alt 3 + Alt
5
Capital Cost
$0
$1,000
$285,000
$685,000
$698,000
$983,000
Annual O&M
COSt
$48,000 (Yrs
1&2)
$16,600 (Yrs 3
to 5)
$8,300 (Yrs 6
to 35)
Same as
Alternative l
$37,000
$96,000 (Yrs 1
& 2)
$65,000 (Yrs 3
to 35)
$97,000 (Yrs 1
& 2)
$66,000 (Yrs 3
to 35)
Present Worth
Cost
$223,000
$224,000
$640,000
$1,806,700
$1,836,100
$2,250,000
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Table 9
Selected Remedy Cost
Co*
Capital Coats
Impermeable Cover
Cover
Storm Drainage
Design
Supervision
Management Oversight
Subtotal, capital coat
Contingency
Subtotal Capital Cost
Groundwater Treatment
Pump Test*
Recovery Well*
Well Pump*
Sedimentation Tank
Pump and Control*
Filter
Stripping Tower
Tower Appurtenance*
Power Drop
Effluent Pipe
Subtotal, capital coat
Design and Supervision
Administration
Subtotal
Contingency (30%)
Subtotal Capital Cost
Total Capital Co*
$150,000
15,000
20,000
18,000
16,000
219,000
65,700
$285,000
$120,000
80,000
8,000
2,000
6,000
1,000
10,000
40,000
5,000
175,000
447,000
51,000
40,000
$537,000
161,000
698,000
$983,000
Annual Operation A Maintenance)
Impermeable Cover
Management and Maintenance!
Oroundwater Treatment
Well Sampling
Well Sample AnaJyeto
Efffluent Analyst*
Maintenance
Power
Management
$8,000
12,000-24,000
5,000-24,000
4,000
13,000
2,000
30,000
TOTAL PRESENT WORTH COOT
(5%, 35 year*)
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RESPONSIVENESS SUMMARY
HELLERTOWN MANUFACTURING COMPANY SITE
HELLERTOWN, PENNSYLVANIA
This community relations responsiveness summary is divided into the following
sections:
Overview! This section discusses EPA's preferred alternative for
remedial action.
Background; This section provides a brief history of community interest
and concerns raised during remedial planning at the
He Her town Manufacturing Company Site.
Part I; This section provides a summary of commentors' major issues
and concerns, and expressly acknowledges and responds to
those raised by the local community. "Local community" may
include local homeowners, businesses, the municipality, and
not infrequently, potentially responsible parties (PRPs).
Part II; This section provides a comprehensive response to all
written comments received and is comprised primarily of the
specific legal and technical questions raised during the
public comment period. If necessary, this section will
elaborate with technical detail on answers covered in Part
I.
Any points of conflict or ambiguity between information provided in Parts I
and II of this responsiveness summary will be resolved in favor of the
detailed technical and legal presentation contained in Part II.
OVERVIEW
In August 1991, EPA announced the public comment period and published its
preferred alternative for the Hellertown Manufacturing Company Site, located
in Hellertown, Northampton County, Pennsylvania. EPA screened six possible
alternatives to remediate site contamination, giving consideration to nine key
evaluation criteria:
• Threshold criteria, including
Overall protection of human health and the environment
— Compliance with Federal, State, and local environmental and
health laws
• Balancing criteria, including
Long-term effectiveness
Short-term effectiveness
Reduction of mobility, toxicity, or volume
— Ability to implement
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Cost
• " Modifying criteria, including
State acceptance
Community acceptance.
EPA carefully considered state and community acceptance of the remedy prior to
reaching the final decision regarding the remedy.
The Agency's preferred remedy, Alternative 6, includes the following measures
for remediation of contaminated groundwater and soil at the site:
Placement of an impermeable cover over the entire former lagoon
area;
Surface water runoff controls;
Extraction and treatment of groundwater (air stripping and solids
removal), with discharge to Saucon Creek;
Long-term groundwater monitoring; and
Deed restrictions.
In EPA's judgment, this alternative provides the best balance with respect to
the nine standards EPA must consider when choosing a remedy.
BACKGROUND
To obtain public input on the Proposed Remedial Action Plan (Proposed Plan or
PRAP), EPA held a public comment period from July 26, 1991 to August 26, 1991.
EPA's community relations efforts included:
• Preparation of an updated Community Relations Plan in June 1991
• Preparation and distribution of a Proposed Plan Fact Sheet in July
1991
• A public meeting on the Proposed Plan on August 13, 1991.
Those in attendance at the meeting included local area residents, state and
local officials, news media representatives, representatives from EPA, and
representatives from companies interested in the site activities and clean-up
decisions. EPA also preceded the public meeting with briefings for State and
local officials.
Public notification of the August 13, 1991 meeting was issued to local media
and to area residents and federal, State, and local officials on EPA's site
mailing list, which was developed with the Community Relations Plan and
periodically updated. EPA notified the public of the date and time of the
meeting and announced the public comment period in newspaper display ads
placed in the July 25, 1991 editions of The Bethlehem Globe Times, The
Allentovn Morning Call, and The Valley Voice.
In addition, EPA established a site information repository at the Hellertown
Borough Municipal Building. The repository contains the Community Relations
Plan, the Remedial Investigation/Feasibility Study (RI/FS) report, and other
relevant documents. EPA's Administrative Record file for the site, which
encompasses the key documents the Agency uses in selecting the site remedy,
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also is housed at the repository.
Finally, EPA prepared a Proposed Plan Fact Sheet and distributed it to
individuals on the site mailing list and/or in attendance at the public
meeting. This fact sheet outlined activity at the site and provided a summary
of alternatives, including EPA's preferred alternative, for remediation of
contaminated groundwater and soil at the site.
PART Xi SUMMARY OF COMMENTORS' MAJOR ISSUES AND CONCERNS
This section provides a summary of commentors' major issues and concerns, and
expressly acknowledges and responds to those raised by the local community.
The major issues and concerns on the proposed remedy for the Hellertown
Manufacturing Site received at the public meeting on August 13, 1991 and
during the public comment period, can be grouped into five categories:
A. Implementation of the Remedy
B. Superfund Process
C. Soil Cleanup/Lagoon Area
D. Groundwater Cleanup
E. General Site Area Issues
The questions, comments, and responses are summarized below.
A. Implementation of the Remedy
• A citizen asked how long it will take to begin the remediation process,
and if monitoring will continue until then.
EPA Response: The actual starting date is not known at this time. After the
ROD is signed, EPA will enter into a period of negotiation with the
potentially responsible parties ("PRPs") for the design and implementation of
the actual remedy. This process can take up to two years. Monitoring will
continue on a quarterly basis until then, and at least semi-annually during
remedy implementation.
• A citizen asked why the remedial alternatives did not include excavation
and off-site disposal of contaminated materials.
EPA Response: Some of the contaminants found were at depths of 20 to 25 feet.
To excavate that amount of soil and the primary contaminants of concern would
require an extraordinary expense. The proposed impermeable cover over the
area of concern would minimize any further migration of those contaminants to
the groundwater and would meet the objective of protecting human health and
the environment.
• A citizen asked if any innovative technologies like vapor extraction
were considered to cut remediation time and overall costs.
EPA Response: Other alternatives were considered, but were not included in
the final six alternatives because of either cost, effectiveness, or both
factors combined.
• A citizen asked how far the deed restrictions will extend.
EPA Response: The deed restrictions will include the property and the lagoon
area. The restrictions will prevent excavation of contaminated soil on-site
and will prohibit groundwater use for domestic purposes.
• A citizen asked who will be paying for the cleanup. Will the citizens
know the work is progressing toward the desired goals?
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EPA Response: Basically, Superfund is divided into two separate phases. In
the first phase, the Remedial Investigation and Feasibility Study (RI/FS) or
study phase, EPA looks for PRPs who may have created or contributed to
problems at the site. Whep.EPA first entered the RI/FS phase for the
Hellertown Manufacturing Site, a consent order was negotiated with Champion
Spark Plug Company to perform that phase.
After the initial investigation is complete, EPA evaluates the data and makes
a final decision on how the site will be cleaned up. This is documented in
the Record of Decision (ROD). After the ROD is signed EPA will enter a second
negotiation phase with the PRPs for the actual implementation of EPA'a
selected remedy. If negotiations in the second phase are successful, the PRPs
will agree to implement the selected remedy. The PRPs' commitment to
implement the ROD is memorialized in a Consent Decree signed by the PRPs and
the United States Government and entered into by a judge in federal district
court. Typically the PRPs hire a contractor to carry out the actual cleanup.
EPA has oversight of the contractor, approves all work and design plans, and
oversees construction and operation of the alternative.
If EPA cannot get a responsible party to negotiate and agree to implement the
selected remedy, EPA may order it to do so. In addition, there is a trust
account, the Superfund (monies appropriated both from Congress and from a tax
levied on the petroleum and chemical industries), to clean toxic waste sites.
EPA may use this money to carry out the cleanup if negotiations with the PRPs
are unsuccessful. In that event, EPA may pursue the party later for cleanup
costs.
• A citizen expressed concern about the sight and noise of the equipment
used in the cleanup process and about the content of the ground water
treated through the air stripping process.
EPA Response: The exact specifications of the equipment will be addressed
during the design phase and will depend on many factors including ground water
flow rates, the necessary pumping capacity, and the packing material needed
for the air stripper. Typically this kind of equipment is housed in a
structure that is slightly larger than a backyard lawn or utility shed, with
an air discharge unit that might extend slightly above the structure for air
dispersion purposes. Basically, these units have removal efficiencies.of
approximately 96 to 98 percent and any discharge would be in compliance with
the state air requirements. Noise from the process should be minimal, since
the equipment will be enclosed in the structure. EPA will hold further
meetings to discuss the actual design concepts as the planning continues.
• A citizen asked if EPA will continue to pursue the outlined alternatives
in spite of the sparse community turnout at the public meeting. Could
there ever be a situation where someone could persuade EPA to pursue a
less stringent alternative?
EPA Responded: EPA is mandated by Congress to protect human health and the
environment by choosing the best alternative for cleaning up the site.
Alternative 6 is the remedy EPA determined to be best suited for this site.
State and community acceptance are two of the nine criteria considered in
selecting a remedy. If EPA receives a significant number of comments that a
community does not like the remedy that has been selected, the remedy may be
re-evaluated and another may be selected.
B. Super fund Proce»
• A citizen asked if tests for maximum acceptable levels of contaminants
were conducted in both soil and water. What standards were used to
measure contaminant levels?
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EPA Response: Yes, both soil and groundwater were tested at the site.
Thirty-six soil borings were drilled and 101 samples were taken at various
depths among the 36 borings. There are a total of 22 wells on-site from which
groundwater contamination levels and the gradient and flow of the groundwater
were determined.
A series of tests were run on the samples and the results identified what
contaminants were found and at what concentrations. When contaminants are
identified at levels that exceed Maximum Contaminant Levels for a certain
contaminant, for example five parts-per-billion for trichloroethylene in
groundwater, that indicates to EPA that there is a problem that warrants
attention. Groundwater sampling indicated that maximum contaminant levels are
exceeded at this site for vinyl chloride, benzene, dichloroethylenes(cis-l,2
and trans-1,2), trichloroethylene, and tetrachloroethylene.
A citizen asked if EPA and PADER allow hazardous wastes resulting from
a leaking underground storage tank to go to a soil treatment facility by
claiming the waste is not hazardous but only residual? Is it true that the
TCLP limit is 100 times less stringent than the drinking water standards for
identical contaminants?
EPA Response: The TCLP is a laboratory test procedure used to determine the
level of contaminants that will leach from waste soil. The leachate is
analyzed to determine if the contaminants in the leachate will result in the
waste being classified as a hazardous waste. Analysis of drinking water is a
direct analytical analysis and not a leaching test. Therefore, it is not
possible to directly compare TCLP analysis with drinking water standards and
to say that the TCLP limit is 100 times less stringent than drinking water
standards. If wastes from an underground storage tank are determined to be a
hazardous wastes, then the wastes are disposed of in accordance with federal
and State hazardous waste regulations.
• A citizen expressed concern about the appearance of EPA personnel on-
site in protective gear during the initial investigation at the site.
EPA Response: During the RI, the people conducting the on-site sampling were
wearing protective clothing. This is a precautionary measure that EPA takes
on all Superfund sites because hazardous materials may be present and the
nature or location of the materials are unclear. To an outsider, the
appearance of personnel in protective gear might suggest imminent danger, but
at the time EPA cannot be sure how bad it may or may not be.
• A citizen asked if anyone has applied for or received a Technical
Assistance Grant (TAG). If not, is it too late to apply for a TAG?
Could a technical advisor participate in the ROD?
EPA Response: No one has applied for or received a TAG for the Hellertown
Manufacturing Company Site. It is not too late to apply for a TAG, but in all
likelihood it could not be issued in time for input on the upcoming ROD.
However, a technical advisor could be helpful during the Remedial
Design/Remedial Action (RD/RA) stage.
• A citizen asked if there was any possibility that the documents in the
Administrative Record file could be made available for public view at
some time other than normal business hours for people who are unable to
view them during the day.
EPA Response: EPA will consider having that information made available at
another location, possibly the public library.
C. Soil Cleanup/Lagoon Area
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• A citizen expressed concern about soil contamination as a result of
leaking Underground Storage Tanks (USTs) that were discovered at the
site.-
EPA Response: Five USTs, used to store fuel and machine oil, were located at
the facility. - The soil around the tanks was excavated and samples were taken
from all sides to determine if anything leaked into the soil. No evidence of
soil contamination was found. There was evidence of some residue left in the
bottoms of the tanks, four of which were cleaned, filled with inert material,
and, because of their location immediately adjacent to the building, left in
place. One of the tanks was removed completely.
• A citizen asked about the soil composition in the site area, expressing
concern about its infiltration rates.
EPA Response: While the general soil composition in the area is of the
Washington Silt loam, the lagoon areas were backfilled with materials from
off-site and most likely are no longer of the same composition. Regardless of
the soil composition though, the purpose of the impermeable cover is to
prevent any rainwater infiltration into the contaminated soil area.
• A citizen disputed information that the lagoons were drained and dredged
and wanted to know the results of soil borings in the lagoon area.
EPA Response: According to the Remedial Investigation Report, the lagoons
were drained, dredged, backfilled with construction debris and rejected spark
plugs, and covered with a layer of soil. EPA did not find a significant
concentration of contaminants in the topsoil covering the lagoons. Deeper
samples did indicate a layer, of about a foot or two, that showed higher
concentrations of contaminants. Below that layer the soil was clean, which
allowed EPA to determine where the bottom of the lagoons had been.
D. Oroundwater Cleanup
• A citizen asked what exactly are Maximum Contaminant Levels. Are the
standards the same for drinking water and for soil?
EPA Response: Maximum Contaminant Levels (MCLs) are the maximum permissible
levels of organic and inorganic contaminants allowed in public water supplies
for drinking purposes. These levels are established by the EPA under the
authority of the Safe Drinking Water Act. There are no MCLs for soil. .
• A citizen asked if the groundwater recovery system will capture
everything that is above Maximum Contaminant Levels.
EPA Response: Yes. In the design phase, EPA will develop a conceptual model
to outline contamination boundaries and levels of contaminants, and identify
appropriate locations for wells and necessary pumping rates. The ultimate
goal of the cleanup process will be to return the entire.aquifer to its
beneficial use as a drinking water aquifer, which will require the attainment
of MCLs.
• A citizen asked if any fractures, caverns, or solution channels were
identified in the limestone under the site. If so, what would prevent a
horizontal flow of contaminants through the limestone that would carry
them to Saucon Creek?
EPA Response: EPA installed a number of wells on and off the property and
encountered fractured bedrock underneath the site. Current information
indicates that contaminants have already leached, and are continuing to leach,
from the former lagoon area into the bedrock aquifer. The contaminants then
migrate with the groundwater into Saucon Creek. Additional sampling of Saucon
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Creek will be required during the remedial design.
• A citizen asked if there was a provision in any of the alternatives for
a vertical physical barrier to prevent further migration of contaminants
through the ground water.
EPA Response: No. Since there is a fractured bedrock aquifer, a physical
barrier is not a viable engineering alternative.
• A citizen expressed concern about the contaminants reaching Saucon
Creek. If the water table were to rise, could contaminants leach faster
and reach levels that could pose a threat to wildlife?
EPA Response: Current information indicates that the groundwater is flowing
in the direction of Saucon Creek. A change in the water table should not
cause any significant changes in the level of contaminants.
• A citizen asked about the results of tests conducted on wells west of
Saucon Creek.
EPA Response: Low levels of BTEX compounds (benzene, toluene, ethylene and
xylene), which typically indicate some kind of petroleum or gasoline, were
identified in the wells west of the creek.
• A citizen expressed concern about wells that the city of Bethlehem may
have drilled in the Saucon Park area several years ago.
EPA Response: Municipal wells in the area are used only for emergency backup
drinking water supply purposes, irrigation, and water level monitoring. The
U.S. Geological Survey also has some wells in the area to monitor water levels
for their own study purposes.
• A citizen asked if there has ever been an inventory of groundwater
outlining the extent of pumping in the general area of the site. If
pumping conditions were changed, could that alter the flow of the
contaminated plume? Does EPA know if there will be future groundwater
pumping in the area?
EPA Response: As part of the investigation, the entire Hellertown area was
evaluated and well locations were identified. If pumping rates increased
dramatically in close proximity to the site, it is possible that the direction
of flow of the contaminated plume could change. However, EPA does not expect
any new wells to be installed in the site vicinity and any existing wells are
far enough away that they will not impact the site.
• A citizen asked if the groundwater in the site area is connected to the
large cone of depression affected by the New Jersey Zinc mine.
EPA Response: According to U.S. Geological Survey reports, the site is
outside the influence of the New Jersey Zinc mine.
E. General Site Area Issues
• A citizen asked what part of the site is still owned by Champion Spark
Plug.
EPA Response: None. To EPA's knowledge, the entire complex, including all
the previous lagoon sites, is now owned by Paikes Enterprises,Inc.
• A citizen asked if any part of the former factory is currently occupied.
Is there any danger of exposure to contaminants at the facility or on
its property?
-------
EPA Responsei The former factory building is currently occupied by two
companies. Benchmark Analytics runs a laboratory in the front and Hill
Imports used the back as a warehouse. As the site stands now, there is no
exposure to contaminants. .The building is clean, and as long as no one is
drinking the groundwater or coming into contact with the contaminated soils
twenty feet- below the surface, there is no immediate risk involved with the
site.
• A citizen expressed concern about the presence of drums left after past
site work and about the overgrowth of vegetation around the site area.
EPA Response: EPA is aware of the drums and the vegetation overgrowth and
will consider these issues during the design of the selected remedy.
• A citizen expressed concern about property values suffering as a result
of proximity to the site.
EPA Response: EPA recognizes that this is a concern for homeowners in the
Hellertown area. EPA's goal is to clean up the contamination associated with
the site as quickly and efficiently as possible. The Remedial Action could
begin within the next year and will be a major step in returning the area to a
safer, cleaner state.
PART XI: RESPONSE TO WRITTEN COMMENTS
This section provides technical detail in responding to written comments or
questions on the Hellertown Manufacturing Company Site. These comments were
received from the law firm of Gilberg and Kurent on behalf of Champion Spark
Plug Company in correspondence dated August 26, 1991 and September 5, 1991.
• A review of various ROOs for sites similar to the former Hellertown
Manufacturing Company Site from fiscal year 1982 through the present
revealed that at least three RODs selected a remedial alternative of no
action and/or institutional controls. The remedy for the Hellertown
Manufacturing Site is significantly more rigorous and costly than the
remedy proposed for the Dorney Road Superfund Site (wellhead treatment
using activated carbon filtration for current water users). Dorney Road
is a nearby Site characterized by hydrogeologic conditions and
contaminants of concern similar if not identical to those found at the
Hellertown Site.
EPA Response: EPA must consider each site on a case-by-case basis when
issuing a Superfund Record of Decision. EPA considers in detail the nine
balancing criteria and other factors, such as site-specific risk factors, site
conditions, the amount of waste to be treated, etc. The fact that the
Hellertown Site is located in close proximity to the Dorney Road Site and has
similar hydrogeological features and contaminants does not indicate that the
same remedial alternative should be selected for both sites or that the cost
of remediation will be the same for both sites. The fact that three other
RODs (Western Sand and Gravel Site, Westline Site, and Oak Grave Sanitary
Landfill Site) out of the hundreds of RODs signed by EPA select a different
remedy for groundwater remediation is not conclusive in any way.
• Pumping and treatment has been proved by EPA and other scientific
institutions to be ineffective in fractured bedrock systems.
EPA Response: No scientific information has been provided to EPA for this
site which indicates that it is technically impracticable for groundwater
pumping and treatment to reduce contaminants in the groundwater to MCLs and
background concentrations. No site-specific information has been presented to
demonstrate that a combination of natural attenuation and institutional
8
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controls is the only feasible remedial action alternative.
EPA has classified the aquifer underlying the site as a Class ZIA aquifer, a
current source of drinking,water. For a Class IIA aquifer, the National
Contingency Plan and Agency groundwater policy require active groundwater
restoration using pumping and treatment. They also require periodic
evaluation of the effectiveness of such systems, as discussed in the ROD under
Section IX, "Selected Remedy."
• The use of pumping and treatment does not achieve the objectives and
requirements of CBRCLA, as amended by SARA.
EPA Response: EPA disagrees. As discussed in detail in the ROD, the pumping
and treatment alternative meets all objectives and statutory requirements of
CERCLA, as amended by SARA.
• Institutional Controls satisfy the nine criteria established under the
NCP and, therefore, meet the intent of CERCLA as amended by SARA.
EPA Response: EPA disagrees. The two threshold requirements of CERCLA are
that the selected remedial action be protective of human health and the
environment and that it at least attain ARARs. The institutional controls
discussed in Alternative 2 are proposed deed restrictions. Deed restrictions,
would bar future excavation of contaminated soils in the lagoon area and the
use of groundwater at the Site, but they are not a permanent treatment remedy,
they will not provide sufficient health protection, and they will not attain
the groundwater ARARs. Groundwater ARARs are identified in the ROD as MCLs
and background concentrations for each contaminant in the groundwater.
• Long-term effectiveness and permanence of feasible remedial actions at
the former Hellertown Manufacturing Company Site are achieved almost
exclusively by existing institutional controls, existing land use
patterns, and proposed deed restrictions.
EPA Response: Long-term effectiveness and permanence refers to the ability of
a remedy to maintain reliable protection of human health and the environment
over time. This criteria evaluation includes the consideration of residual
risk and the adequacy and reliability of controls. Alternative 2 does not
effectively meet this evaluation criteria compared with groundwater pumping
and treatment. Alternative 2 will result in more than minimal residual risk
from groundwater ingestion, dermal contact and inhalation, since groundwater
will not be treated or contained and ARARs will not be attained. Deed
restrictions will only minimize the use of groundwater at the site and prevent
excavation of contaminated soils in the lagoon area. Existing and future land
use patterns include residential use in the immediate vicinity of the Site,
further requiring mitigation of residual risk by groundwater pumping and
treatment.
The selection of institutional controls for the former Hellertown
Manufacturing Company Site is consistent with other Superfund sites with
similar risks.
EPA Response: EPA disagrees. As previously stated, EPA must consider each
site on a case-by-case basis when issuing a Superfund Record of Decision. EPA
must consider in detail all of the nine balancing criteria, statutory
requirements, and other site related factors, which include, but are not
limited to, site risk. To compare remedial actions at Superfund sites based
only on similar site risks is not consistent with CERCLA program and statutory
requirements.
• There is no risk of human exposure to potential contaminants in
groundwater because local ordinances require residences to use public
-------
water supplies.
EPA Response: The aquifer underlying the Site is classified as Class IIA, a
current source of drinking,water. The Remedial Investigation Report
identified seven wells within one mile of the Site, six of which are
residential:. -Three of the wells are used for drinking water, one is used for
watering a lawn and washing cars, and two are inactive. Eight additional
wells were identified within two miles of the Site. Some of these wells are
used for backup municipal water supply.
Local ordinances requiring residents to use public water supplies do not
satisfy the requirements of the National Contingency Plan to return
groundwater to its beneficial use as a drinking water source and to protect
against current and future exposures to contaminants.
• The Site has not affected the surrounding natural environment.
EPA Response: The results of the Remedial Investigation are inconclusive
regarding environmental risks and impact to the surrounding natural
environment. EPA agrees that there are no known endangered species or
critical habitats within the immediate vicinity of the Site. However, Saucon
Creek and adjacent wetlands are potentially affected by the migration of
groundwater and by several springs or seeps along Saucon Creek identified by
EPA. EPA and the Department of Interior believe that the results of the
sampling survey conducted during the RI/FS did not adequately characterize
background concentrations of organic and inorganic contaminants, including
metals, in the stream and wetlands area, and was inconclusive in determining
whether contaminants from the Site adversely impact Saucon Creek, sediments,
and adjacent wetlands. During the remedial design study additional studies in
the area will be required.
• The selection of institutional controls is consistent with EPA guidance
for sites that have hydrogeological constraints such as fractured
bedrock.
EPA Response: EPA has classified the groundwater aquifer as a Class IIA
aquifer, a current source of drinking water. The National Contingency Plan
and Agency groundwater policy, as described in the document entitled "Guidance
on Remedial Actions for Contaminated Groundwater at Superfund Sites," require
rapid restoration of groundwater that is a current or potential source of
drinking water, through pumping and treatment. They also require periodic
evaluation of the effectiveness of such systems, as discussed in the ROD under
Section IX, "Selected Remedy." Natural attentuation to health-based levels is
used only as a baseline for comparison with active groundwater pump and treat
alternatives. Champion estimates the time required for natural attentuation
of groundwater to background concentrations to be 68 years, which is
considerably longer than the EPA estimate of 30 to 40 years to restore
groundwater to its beneficial use using a pumping and treatment alternative.
Furthermore, the RI/FS does not present any scientific d.ata or mathematical
model to support the contention that natural attenuation will restore
groundwater to background concentrations.
10
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