United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/129
September 1991
&EPA Superfund
Record of Decision:
Hebelka Auto Salvage Yard,
PA
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50272-101
REPORT DOCUMENTATION 11. AEPOATNO.
. PAGE EPA/ROD/R03-91/129
I ~
3. R8c:IpIent8 Acc:888Ion No.
1188 81111 ~
SUPERFUND RECORD OF DECISION
Hebelka Auto Salvage Yard, PA
Second Remedial Action - Final
7. Aulh«(8)
5. A8porI D8ta
09/30/91
8.
a. PIIrforming Org8nIza1Ion Repl No.
II. F_follllina Ora8lnlz81lon N8me 8IId AddI888
10. ProJec1lTalllWorit UnIt No.
11. Contnct(C) or Gr8nt(G) No.
(C)
12. Spon8orIna OrpnuIIon NIIm8 8l1li ~
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(0)
13. Type of R8port . P8ttocl Covered
Agency
800/000
14.
15. Suf'FIemenWy No..
18. Ab8t1'11c1 (LIINt: 200 _rd8)
The 20-acre Hebelka Auto Salvage Yard site is an automobile junkyard in Weisenberg
Township, Lehigh County, Pennsylvania. Land use in the area is predominantly
agricultural, with four residential properties close to the site. The site is located
within the headwaters of the Iron Run subdrainage basin. From 1958 to 1979, and again
from 1989 to present, the site was used as an automobile junkyard and for salvage
operations. Scrap iron was recovered from used storage tanks that were disposed
onsite, some of which still contained organic chemicals. In addition, during the past
10 to 15 years, approximately 1,000 cubic yards of used battery casings have been
disposed of onsite in two piles, along with empty storage tanks and drums, junked cars,
and miscellaneous scrap metal. In 1985, EPA investigations identified elevated levels
of lead and chromium in soil and sediment. A 1989 Record of Decision (ROD) addressed
remediation of site areas with lead concentrations exceeding 560 mg/kg in soil, as well
as the piles of scrap battery casings above these soil areas. The ROD also provided
for removal and recycling of the battery casings, and excavation and treatment of soil
using cement- or lime-based fixation processes. This ROD was developed to address soil
outside of the high lead concentration areas, ground water, surface water, and air.
(See Attached Page)
17. Doc:un8It An8/y8I8 L D88cr1ptof8
Record of Decision - Hebelka Auto
Second Remedial Action - Final
Contaminated Media: None
Key Contaminants: None
Salvage Yard, PA
b. 1dIn1ItIer8I00000End8CI T81'1118
c. COSA11 FieIdIGrcq»
AVIiJ8bIIty St8I8ment
111. Securtty au. (1hI8 A8por1)
None
20. Securtty au. (1hI8 Paae)
Nonp
21. No. of P8Q88
24
I
n PrIce
(S88 At&-Z3S.18)
See 1M1I'Uc1i- on Re-
(4.77)
(Forney NTI&-35)
Dep8ftment 01 Commerce
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EPA/ROD/R03-91/129
Hebelka Auto Salvage Yard, PA
:econd Remedial Action - Final
Abstract (Continued)
However, because site investigations have found no evidence of contamination in the
media addressed in this ROD, there are no contaminants of concern.
The selected remedial action for this site includes no further action
monitoring ground water and surface water of Iron Run annually, and a
the creek. The estimated present worth cost for this remedial action
includes an annual O&M cost of $4,500 for 30 years. The cost for the
bioassessment is $125,000.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
other than
bioassessment of
is $66,300, which
follow-up
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Record of Decision
Bebelka Auto salvage Yard
Declaration
site Hame and Location
Hebelka Auto Salvage Yard
weisenberg Township, Lehigh County, Pennsylvania
statement of Basis and Purpose
This decision document presents the selected remedial action for
the second Operable Unit (OU 2) for the Bebelka Auto salvage Yard
site (the Site), in weisenberg Township, 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 Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. S 9601 ~~, and,
to the extent practicable, the National oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision
document explains the factual and legal basis for selecting the!
remedy for this site.
The information supporting this remedial action decision is
contained in the administrative record for this site.
The Commonwealth of Pennsylvania does not concur with the selected
remedy.
Description of the Selected Remedy
This Operable unit , is the second of two operable units planned for
the site.' The first operable unit (OU 1) addresses the removal of
lead in battery casings and soil remediation of soils with lead
concentrations above 560 mg/kg and comprises the following
components: . .
- Removal and recycling of approximately 1,000 cubic yards of
battery casings and
- Treatment of Lead-Contaminated Soil
< Excavation of approximately 2,000 cubic yards of lead
contaminated soil (lead concentrations over 500 parts
per million),
< Fixation of the excavated soil utilizing a cement- or
lime-based fixation process
. ~
< Deposition of the mixed material in a landfill that
the Commonwealth has permitted to accept.
OU 2 addresses soils outside of the high'lead concentration areas,
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air, groundwater, and surface water in the vicinity of the site.
EPA has determined that no further response action is necessary
beyond that selected for au 1.
EPA will continue to conduct monitoring at the site on an annual
basis, incl~ding conducting a bioassessment survey to verify that
no unacceptable exposure to risks posed by conditions at the Site
occur in the future.
Declaration stateaent
The selected remedy has determined that no further remedial action
is necessary for au 2. EPA has determined that no further action
is necessary for au 2 because the site portions investigated as au
2 pose no current or potential threat to human health and the
environment and because the previous response action planned for
au 1 eliminates the need to conduct any additional remedial
action.
Because the remedy for au 2 will not result in hazardous
substances remaining on the site above health-based levels, the
five-year review will not apply to .this operable unit.
k~~
Edwin B. Erickson
~ EPA Regional Administrator
r. Region III
9-JP-9/
Date
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Summary of Remedial Alternative Selection
I. site. LocattoD aD4.~scriotioD
The location of the Hebelka Auto Salvage Yard (the "Site",
or the "Hebelka Site") is shown on Figure 1. The site is located
in Weisenberg Township, Lehigh County, Pennsylvania. The Site
comprises approximately 20 acres of property owned by the Estate
of Lovie M. Hebelka and is located within the headwaters of the
Iron Run subdrainage basin. Topographically the property is
positioned on the south side of a low, moderately steep hill
north of Interstate Highway 78 and Old Route 22 (the two highways
are parallel to each other running generally east-west) approxi-
mately 9 miles west of Allentown, Pennsylvania. The site is
bordered on the south by Old Route 22 and Interstate Highway 78;
on the east by Tercha Road and an agricultural field; on the
north by a second agricultural field; and on the west by a
Township Route T-541 and open, rural land. The general arrange-
ment of the Site is shown on Figure 2.
The Site has a maximum topographic relief of 100 feet with
elevations above mean sea level ranging between 510 and 610 feet.
Slopes on the site vary between 6 and 25 percent. The western!
half of the site exhibits a relatively uniform slope of between 7
and 10 percent downward from the northern extreme toward the west
and south. The eastern half of the site consists of a drainage
swale which extends from the site's northern extreme toward the
southern border with an average slope of about 6 percent. The
sides of the swale rise toward the east and west with relatively
uniform slopes of about 25 percent.
Overall, relatively few trees grow on the property. Trees
that are present tend to grow along the west or southern border,
except for a few sparse groups of trees scattered over the site.
Much of the site is covered by wild grass and weeds. only in the
relatively flat (7 percent and less) north-central area, which.
also happens to be near the highest elevations on the Site, is
the ground surface essentially bare except for the sparse groups
of trees.
The site appears to be in the process of being reactivated
as an automobile junkyard. Since the time of the first Record of
Decision (ROD) (1989), the number of junked automobiles on the
Site has increased dramatically. It is estimated that there are
now in excess of 150 junked autos on the property. Other stored
materials on the property include: scrap automobile tires and
lawn tractors, occasional piles of miscellaneous scrap or trash,
empty storage tanks, and empty drums. The major accumulation of
waste material, though, consists of discarded automotive batter-
ies now located in two distinct piles at the site.
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•o
08
x> .^
Qo
BASE MAP IS A PORTION OF THE U.S O.S. TDPTON, PA QUADRANGLE (75 MINUTE SERCS, 1965, PHOTOREVISEO 1972, PHOTOINSPECTEO I980X CONTOUR NTERVAL
TEN FEET.
FIGURE ' I
HEBELKA SITE, LEfflgH C0.t PA
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FIGURE 2
GENERAL ARRANGEMENT
HEBELKA SITE. LEHKSH CO. PA
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Four homes exist on or immediately adjacent to the site.
Two residences are located on adjacent land along the northwest
perimeter of the Site. A third home is located along the site's
southern property line and is surrounded by the Site on three
sides. The fourth home is the Hebelka home. It is located near
the southeastern corner of the Site which is also known as the
Hebelka Auto Salvage Yard. A mobile home which appears to serve
as an office and a frame shed are also located on the Hebelka
property near the southern boundary.
2.
site Historv and Enforcement Activities
The Hebelka'Site was purchased in 1958 by Mr. and Mrs.
Joseph Hebelka, both now deceased. The property is currently part
of the Estate of Lovie M. Hebelka. During the period between 1958
and 1979, and again from 1989 to the present the property was and
has been used as an automobile junkyard with periods of activity
involving salvage operations. These salvage operations involve
recovering scrap iron from used storage tanks, some of which have
been observed to still contain organic substances. At some point
during the past 10 to 15 years, two large piles (totaling approx-
imately 1,000 cubic yards) of used battery casings accumulated on
the site in addition to empty storage tanks, empty drums, junk .
cars, and miscellaneous scrap metal. The Pennsylvania Department!
of Environmental Resources (PACER) reported that operations on
the site allegedly ceased in 1979.
On December 15, 1985, the EPA Region III Field Investigation
team (FIT III) visited the site for the purpose of conducting a
Site Inspection (SI). The Site Inspection report revealed the
presence of two battery piles at the Site, termed the "eastern
pile" and the "western pile". The major contaminants identified
during the SI include lead in soils downqradient from the battery
piles and chromium in downgradient Iron Run sediments.
The Hebelka site was proposed for inclusion on the National
Priorities List (NPL) on June 1, 1986 pursuant to the Comprehen-
sive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. 55 9601 - 9675. A Phase I Remedial Investi-
gation and Feasibility Study (RIfFS) was conducted between March
1987 and March 1989 to examine the nature and extent of contami-
nation and to identify alternatives for remediating the Site
conditions. This Phase I investigation studied environmental
areas which were later identified as components of both OU 1 and
OU 2. Th&draft RIfFS reports were released to the public on
March 1, 1989. Subsequently a Phase II RI sampling event was
conducted in February 1991 to further delineate the extent of
le~d contamination both on the Site and in the surrounding envi-
ronment. The extent of contamination for the soils has been
delineated on a series of isocontours included on Figure 3.
4
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POOR QUALITY
ORIGINAL
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3.
Biahliahts of community particiDation
Although the Hebelka Site is located in a rural area,
residential pr~ertie~-are within close proximity. In May 1986,
EPA distributed a press release announcing that the Hebelka site
was proposed for the NFL. Onsite and telephone interviews were
conducted with local residents and officials in July 1987, in
late 1990, and also throughout the first eight months of 1991.
No citizens group is associated with the Site, and EPA activities
at the Site have not been a major concern to local residents.
As required in the CERCLA Section 117 (a), 42 U.S.C. S 9617
(a), the RI/FS Reports and the Proposed Plan for the Hebelka site
(OU 2) were released to the public for comment on July 24, 1991.
These two documents, along with other documents relevant to this
decision, were made available to the public in both the adminis-
trative record located in information repositories maintained at
the EPA Docket Room in Region III and at the Weisenberg Township
Administration Building. The notice of availability for the
Administrative Record was published in the Allentown Morning Call
on July 25, 1991. A public comment period on the documents was
held from July 25, 1991 through August 24, 1991. Comments which
were received are addressed later in this document in the Respon~
siveness Summary. There was no public meeting held for OU 2. !
ScoDe and Role of ODerable Unit (OU 2) or ReSDonse Action
within Site Strateav
As with many Superfund sites, the problems at the Hebelka
site are complex. As a result, EPA has organized the remedial
work into two operable units at the site.
4.
The Hebelka site was placed on the NPL on July 1, 1987,
based on the findings of the SI. As described above there are two
operable units for this Site. Both of these operable units were
investigated in two separate sampling events; referred to as
Phase I Sampling and Phase II Sampling. The prime focus of the
Phase I sampling was the areas of highest lead concentrations in
the soil with some additional work to insure that all OU 1 soil
areas were identified. Phase II work was structured to determine
if lead was migrating off-site via air, surface water and/or
groundwater, and to further evaluate the extent of lead contami-
nation in soils, with the prime focus of this investigation on
the areas-outside of the OU 1 area.
OU 1 addressed the areas of the Site with lead in soil
concentrations above 560 mg/kg and the piles of scrap battery
casings lying on top of these soil areas. The chosen remedial
alternative for OU 1 were described in a ROD which was issued on
March 31, 1989. The soil areas identified in the RI document for
OU 1 have been subsequently slightly modified in the RIfFS
6.
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documents and in Figure 3 to be defined as the area with lead
concentrations above 500 mg/kg. This modification was done to
place this action in accordance with the most recent lead-in-soil
policy establiShed for~PA Region III. This change will be
formally proposed for OU 1 in the near future through an Explana-
tion of Significant Differences. The remedial action for OU 1 is
currently in. the design phase with the design expected to be
complete by January 1992. This remedial action for OU 1 will
address the principal threats from the Site, namely the areas of
high concentrations of lead in the soils.
The Phase I remedial investigation of the site was initiated
on March 3, 1987. The onsite remedial investigation field activi-
ties included the collection of samples from contaminant sources,
surface and subsurface soils, ground water, surface water, and
sediment, as well as the performance of aquifer tests (slug
tests) and a biota investigation along Iron Run. Based on the
results obtained in the Phase I testing, including the resulting
Risk Assessment, the Phase II sample work was structured to
define the extent of contamination for lead in each of the
environmental media and to answer the four specific questions
listed below.
OU 2 addresses the soils outside of this high concentration!
area; the air in the vicinity of the Site; the groundwater in the
vicinity of the Site (including the nearby home well water); the
nearby stream water and the stream sediments.
As a result of the ROD for OU 1 several issues remained
unresolved. These were:
A) Whether the lead from the site was migrating off-site to
either the surface or ground waters?
.\
B) Whether lead from the Site was affecting nearby home drinking
wells?
C) What is the full extent of lead contamination on the site?
[Note: During the Phase t sampling event it was thought that
the contaminated soil area was between the two battery
piles, however, the Phase I sampling determined that the
high lead levels were actually located to the west of the
western battery pile. Therefore, the extent of the contami-
nation had to be defined through a second sampling event.]
D) Whether lead from the site was affecting biota in the nearby
Iron Run Creek?
To answer these questions, a Phase II sampling event was
scheduled for the Site. This event was coordinated with PADER and
actual sampling at the site occurred during February 1991.
7
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The potential for contaminant migration was addressed by
samplinq surface soil alonq potential migration routes; sampling
qround water in downgradient monitorinq wells and from nearby
residential weIls; samp~inq surface water and sediment at loca-
tions upgradient and downgradient from the site; performing
aquifer tes~s (i.e., estimating the ground water flow rate and
direction); examininq the ground water flow rate and direction;
and examining the biota in Iron Run for indications of adverse
effects due to site-related contamination. The field activities
conducted durinq the Phase I event included the collection of 14
surface soil samples from selected locations to investigate the
presence of previously unidentified contaminant sources and/or
miqration routes. Because these samples served, in part, as a
screeninq function, they were subjected to a broader array of
,analyses, includinq Target Compound List (TCL) volatile organics,
TAL inorganics, pesticides, PAHs, CEC (cation exchange capacity),
Ph, and Eh. Downqradient surface water and sediment samples were
subjected to the same analyses as the background samples de-
scribed earlier. Based on the hundreds of surface soil samples
obtained and analyzed durinq both Phases of testing, EPA has been
able to develop a reasonably accurate profile of the lead contam-
ination on the Site and the delineation of the two operable
units.
8
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5.
SummarY of Site Characteristics
The overburden soil on the Site exists almost exclusively at
the lower elev~ions near the southern border. At the lower
elevations, the overburden thickness encountered in monitoring
well borings varied between 5.5 and 10.5 feet. At the higher
elevations, .weathered bedrock was encountered within one foot of
the surface.
The bedrock under the site consists of the Bushkill member
of the Martinsburg Formation. The bedrock is composed of very
broken to moderately broken silty shale with quartz zones inter-
bedded throughout. The extent of fracturing tends to decrease
with increasing depth. Bedrock becomes increasingly calcareous
with depth, possibly indicating a formation change. The surface
of the bedrock slopes generally toward the southeast.
Ground water at the Hebelka Site flows toward the southwest,
generally parallel to the bedrock surface, through openings and
fractures in the Martinsburg Shale with an average horizontal
hydraulic gradient of 0.063 feet/foot. The ground water also
exhibits a downward vertical hydraulic gradient (0.35 feet/foot
average), which tends to increase toward the southwest and may be
indicative of vertical leakage into the underlying carbonate!
layer. Calculations from the slug test data indicate that ground
water is flowi~g toward the southwest at approximately 212 feet
per year.
Battery liquid and residual solid waste samples in the OU 1
areas exhibited high concentrations for lead and acidity. Lead
concentrations in the liquids ranged between 7,320 ug/l (parts
per billion) and 1,100,000 ug/l, and acidity values were as high
as 66 mg/l (as CaC03).. As expected, lead levels decreased rapid-
ly, almost in direct correlation with distance from the battery
piles in ~he OU 1 area. At a average distance of 75 meters from
the areas of highest lead in soil concentrations, the lead in
. soil concentrations approximated background levels. It was noted,
however, that the extent of the area of highest (2,000 ppm) lead
concentration has, apparently increased approximately 10% between
the time of the Phase 1 Sampling to the time (approximately
eighteen months) of the Phase II sampling. It is thought that
this is due to both environmental conditions and the renewed
industrial activity in these areas. TCLP analyses were conducted
on lead contaminated soils as part of the ROD for OU 1. These
tests were- conducted in accord with the protocol set forth in 40
C.F.R. section 261.24. None of the soils or sediments defined as
part of OU 2 for this decision failed this test.
Background soil boring sample analyses indicate onsite,
background, and surface soil lead concentrations of 133 and 140
mg/kg, compared to an expected average background concentration
range of 2.. .to 200 mq/kg found in literature (Lindsay, 1979).
9
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Surface soil contamination detected on the Site consists primari-
ly of lead in soil under and near the battery piles. The surface
samples (0 to 3 inches) from soil borings and the surface soil
grid samples c~relateawell with respect to detected lead
concentrations. The deeper soil boring samples demonstrated that
contaminatiop was at or below background concentrations at depths
greater than 3 feet. Lead concentrations were highest in surface
soil samples collected from borings located under the battery
piles (typical high values: 5,090, 15,000 and 65,100 mg/kg).
Above-background surface soil lead concentrations ranging between
200 and 3,000 mg/kg are generally confined to areas within 30
feet of a battery pile perimeter. Exceptions do occur for an area
northwest of the western battery pile and two isolated locations
west of and adjacent to Tercha road. Figure 3 shows the extent
and concentration of lead contamination in the soil.
Both filtered and unfiltered ground water samples were
collected from onsite monitoring wells in both the Phase I and
Phase II sampling. Filtered samples were collected to examine
ground water for its dissolved metals content. Only one of the
10 filtered samples in Phase I resulted in a reported lead
concentration. Lead was detected at. a concentration of 6.8 ug/l
in that one sample. [Note: the current Federal Safe Drinking
Water Act Maximun Concentration Level (MCL) is 15 ug/l]. This
monitoring well was resampled during the Phase II sampling event
and no dissolved lead was found at that time. None of the 10
filtered monitoring well samples in the Phase II sampling con-
tained dissolved lead. Unfiltered ground water samples exhibit-
ed a range of lead concentrations from 13 ug/l to 6,250 ug/l.
There was no correlation between the unfiltered lead concentra-
tions and the surface soil lead contamination. The highest
concentration occurred in the sample taken from the most down-
gradient monitoring well. If the observed lead concentrations in
groundwater were attributable to the Site, the readings from the
monitoring wells would have been expected to be more homogenous.
Offsite sampling activities included surface water and
sediment samples from Iron Run, the unnamed tributary discharging
. from the Hebelka site to Iron Run, the storm water discharge
serving the highway south of Iron Run and eleven residences
bordering the site. The analyses of surface-water samples
indicated little difference in water quality between upstream and
downstream (from the Hebelka site) locations. Additionally, no
detectable levels of either lead or hexavalent chromium were
found in the surface water samples. Some of the home well
samples showed traces of lead, however, these levels were well
below EPA action levels and consistent with values obtained from
homes with recent plumbing work. The residential samples were
obtained in each case from the tap not the well itself. The Phase
II downstream sediment samples, from Iron Run, exhibited a gener-
ally increasing trend (in lead concentrations) downstream of the
confluence. .with the intermittent stream from the Site, but the
10
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maximum downstream concentration was only 159 mg/kg. The Phase II
bioassessment (preliminary) study showed that these lead concen-
trations apparently had no impact on stream biota.
11
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1-
6. Summary of site Risks
The risks-Posed DY this Site to the nearby environment are
due to the presence of inorganic lead. Inorganic lead may be
absorbed by Jnhalation or by ingestion. Absorption by either
route contributes in an additive fashion to the total body
burden. Among adults, inhalation is the more efficient of the
two mechanisms. The fraction of inhaled lead absorbed from the
respiratory tract is approximately 40 percent, while the fraction
of ingested lead absorbed from the gastrointestinal tract is
approximately 10 percent. These rates may be higher in children
and are of particular relevance in assessing exposures in this
sensitive subpopulation.
The toxicology of lead has been extensively reviewed.
Alterations in the hematopoietic (blood forming) and central
nervous systems are the primary toxic effects caused by exposures
to lead. Cognitive and behavioral deficits are the focus of much
current research on relatively low levels of lead exposure.
The Centers for Disease Control (CDC) has determined that a
blood lead level in children of 25 ug/dl or above indicates
excessive lead absorption and constitutes grounds for medical
intervention. That determination is based on the occurrence of
enzymatic abnormalities in the red blood cells at blood lead
levels above 25 ug/dl and by the finding of neurologic dysfunc-
tion in children at blood lead levels between 35 and 50 ug/dl.
Further, the CDC defines childhood lead poisoning at a blood lead
level of 25 ug/dl in association with an erythrocyte protoporphy-
rin (EP) level of 35 ug/dl or above (CDC 1985). In its draft
toxicological profile for lead, CDC has also cautioned that
concentrations greater than 500 to 1000 ppm could lead to elevat-
ed blood lead levels in children inhaling or swallowing dirt.
Recent findings of cognitive deficits associated with lower blood
lead concentrations may result in a review of the adequacy of the
existing CDC threshold level.
Exposure scenarios considered for potential contact with
contaminated surface soils include children who may be exposed to
onsite surface soil via dermal contact and accidental ingestion.
Adult dermal exposure may occur through work activities or
occasional contact. To provide a worst-case estimate of health
effects, the maximum concentrations of indicator compounds were
employed. -
For carcinogens, the estimated dose can be converted to
incremental lifetime cancer risk, which represents the probabili-
ty or range of probabilities that a carcinogenic effect will
occur. For knoWn or suspected carcinogens, acceptable exposure
levels are generally concentration levels that represent an
excess upperbound lifetime cancer risk to an individual of
12
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between'10-4 and 10-6 usinq information on the relationship
between dose and response. Carcinoqenic risks of 10-4 to 10-6
cor~espond to one additional case of cancer in 10,000 and
1,000,000 receptors -e~osed, respectively.
To eva~uate the potential for noncarcinoqenic effects, the
estimated daily dose is compared directly to reference dose. The
ratio of the estimated exposure level to an acceptable exposure
level provides a numerical indication of potential for adverse
effects. To assess the total potential for noncarcinoqenic
effects posed, a hazard index can be calculated. When the hazard
index is qreater than one, the potential for adverse non-
carcinoqenic effects is increased. When a hazard index is less
than or equal to one, no adverse noncarcinoqenic effects are
expected.
A summary of the health and environmental risks associated
with the Hebelka Site is presented below, and in Table 1:
*
A comparison of lead concentrations detected in samples
collected durinq the residential well survey to available
standards indicates that metals concentrations, includinq
lead, observed in the residential well samples are less than
the current Federal action level which is set at 0.015 mq/l:
The maximum lead concentration detected in the residential
wells was 0.0026 mq/l. This fact and the facts that lead was
not detected in any filtered onsite monitorinq well samples
durinq the Phase II samplinq event and that, the residential
wells where measured lead levels occurred are situated both
up and down qradient from the Site, suqqestinq that the low-
level lead concentrations (less than 0.003 mq/l) detected in
the residential wells are not the result of lead miqration
from the site. The low-level lead concentrations observed
are most likely due to other sources, possibly lead in
pipinq or solder or natural lead levels in the qroundwater.
Accidental inqestion of onsite surface soils by children is
likely to pose a potential for noncarcinoqenic health ef-
fects~ This is evidenced by the calculated worst-case hazard
indices of qreater than one for all areas of the Site.
These hazard indices can be attributed to the presence of
lead in surface soils. While this is of concern at this
site, the surface soils, where in excess of the soil action
level of 500 mq/kq are beinq addressed under the response
action described in the ROD for OU 1 and the forthcominq ESD
on lead-in-soil cleanup levels. Therefore, by definition,
the other soil areas looked as part of OU 2, are below the
Federal action level.
*
*
Carcinoqenic risk estimates associated with accidental
inqestion of contaminated surface soils by children ranqe
from 1.37 x 10-11 to 2.52 X 10-5. The hiqhest risk esti-
13
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.
mates are associated with exposure to surface soils contain-
inq PAHs in the north-central portion of the Site. These
areas are the same as those beinq addressed under OU 1 and,
therefore;-~re -net of concern for the purposes of OU 2.
Dermal contact with onsite surface soils by children and
adults poses a minimal potential for noncarcinogenic health
effects. The calculated hazard indices are less than one;
therefore, adverse effects associated with dermal exposure
to surface soils are not expected. As above, the surface
soil areas of even this minimal concern are those to be
addressed by OU 1.
.
Carcinoqenic risk estimates associated with dermal contact
of onsite surface soils b~ children and adults ranqe from
1.67 x 10-12 to 1.39 x 10-. The hiqhest risk estimates are
associated with exposure to surface soils containinq PAHs in
the north-central portion of the Site. As this area is
.covered under OU 1 for this Site, the residual risk is less
than 1 x 10-8, therefore, in accord with the NCP, this is
below the action level.
.
Lonq-term inhalation of air containinq particulate lead at a
distance of 700 meters (the approximate distance to the ~
nearest receptor home) from the battery piles is unlikely to
be associated with adverse health effects.
.
Aquatic biota in Iron Run are not adversely effected by
Site-associated hazardous constituents. Exposure of terres-
trial biota to surface soils is of potential concern. To
address this concern EPA will conduct a bioassessment study
as part of the follow-up monitorinq program.
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Exposure Scenario
time
Ingestion of Groundwater~ Filtered Groundwater <1
Residential Wells <1
Ingestion and dermal
contact of Contaminated
Surface Soils2
Ingestion of Sediment3
TABLE 1
-- Ris){ -Characterization Summary
Hebelka Site, Lehigh County, Pennsylvania
Lead Conta~ination
Hazard Quotient
Excess Life-
OU 12
Cancer Risk
NC
NC.
OU 12
3.23
NC
Inhalation of Airborne
Particulates
*
*
NC = Not Calculated (less than 10-6)
1
Based on the values determined in the above table no
remedial action is necessary to remediate the ground-
water.
2 OU 1 - exposures under this route will be addressed'
through the remedial action to be performed for OU 1
for this Site
2
The values associated with contact with the surface
soils, are not included since the surface soils with
actionable concentrations of lead are to be remediated
as part of OU 1.,
There is some concern about the hazard quotient for the
exposure from the ingestion of stream sediment. The
hazard quotient is based on a value determined during
the 1989 sampling event. The 1991 stream sediment
-sampling event showed much lower levels. Furthermore,
as part of this Phase II investigation a bioassessment
of the stream biota was performed which characterized
the stream biota as being unaffected by the elevated
lead levels in the sediment. Based on this determina-
tion it has been decided that the best course of action
is no remedial action, however EPA will continue to
monitor the stream biota for potential adverse impacts.
3
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The monitoring program is described in the selected
remedy (below) and will continue until, as part of the
five year review process for OU 1, a determination to
redu~-, or d1scontinue the monitoring is made.
statutorY Deteraination8
7.
The Commonwealth of Pennsylvania has an ARAR for groundwater
for hazardous substances which states that all groundwater must
be remediated to "background" quality. This requirement has been
interpreted from the Commonwealth's Code 25 PA 55264.90 - 264.-
100, specifically 25 PA Code 55264.97(i) and (j) and 5264.-
100(a) (9). The Commonwealth also maintains that the requirement
to remediate to background is also found in other legal authori-
ties. This ARAR is not triggered at this site because the fil-
tered monitoring well samples (other than one low level sample
from the Phase I sampling) indicated that lead was not present in
the groundwater. Although lead was determined present in the
resiaential wells, EPA believes that the lead detected is due to
lead present in home plumbing systems, and are not Site related.
In addition, the lead levels determined present in the residen-
tial wells may constitute background levels. While it is true
that lead was determined present in the unfiltered ground water.
samples, EPA Regional policy is that the risk determinations at !
this Site, for groundwater, be based on the filtered samples.
Therefore the "no action" remedy selected is protective of human
health and the environment.
8.
Selected R..edv
EPA has determined that no further action is necessary for
OU 2 at the site because these site portions (lead-in-soil
concentrations under 500 mg/kg, groundwater, surface water, air)
investigated for OU 2 pose no current or potential threat to
human health and the environment, and the response which shall be
taken pursuant to the ROD for OU 1 will eliminate the need for
any further remedial action. However, monitoring shall be con-
ducted to verify that no unacceptable exposures to potential
hazards posed by conditions at the site occur in the future.
Monitoring of the groundwater and the nearby stream and
sediment will be performed on an annual basis to verify that the
exposure to lead does not rise above the existing Federal maximum
concentration levels. The basis for continued monitoring is two-
fold: First, EPA will be performing a substantial amount of
remedial activities related to OU 1, and even though there has
been extensive documentation regarding all of the locations of
high lead contamination, EPA wants to assure these response
actions do not result in any increases in lead level exposures;
Secondly, the site continues to be used for various industrial
operations on the property including auto salvage work and there
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is a potential that this on-going industrial activity may spread
the existing contamination.
Furthermot'1Jr, an annual groundwater and stream water and
sediment monitoring program will be implemented at this site.
This monitoring program will consist of a minimum of ten samples
composed of "a mix of monitoring wells, residential wells, stream
water, stream sediment, and stream biota (bioassessment). The
samples will be analyzed for lead, the contaminant of concern at
this Site.
The annual cost of the monitoring program is approximately
$4,500 and the present worth cost for a 30-year period is approx-
imately $66,300. For costing purposes, it has been assumed that
the samples would be analyzed for lead only, the primary contami-
nant at the Hebelka Site.
In addition to a monitoring program, a bioassessment fOllow-
up study shall be implemented for Iron Run to ensure that remedi-
al actions taken at the Site, as well as ongoing salvage opera-
tions do not adversely impact biota in Iron Run. A typical bio-
assessment follow-up study would consist of a macro invertebrate
study as well as semi-annual analysis of surface water and .
sediment samples collected from three locations in Iron Run. The!
study would be implemented for an approximate two-year period
following and including the remedial action period. The total
cost of such a study is approximately $125,000.
The results of the monitoring program together with the
results of the bioassessment follow-up study will be reviewed as
part of the five year review to be performed for OU 1 consistent
with the requirements of Section 121(c) of CERCLA; 42 U.S.C. S
9621(C) and 40 C.F.R. S 300.430(f) (4) (ii) of the NCP.
7.
BxDlana~ion of SiaDifican~ Chana..
There are no significant changes between the "no action"
remedy presented in the proposed plan for this OU 2 and that
selected in this decision document.
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RBSPOHSXVBHBSS SUMMARY POR KBBBLKA AUTO SALVAGB YARD SXTB
A. OVBRvxn
At the time of the public comment period
25, 1991 to August 24, 1991, EPA had proposed
action" remedy with continued monitoring for
(OU) 2 of the Hebelka Auto Salvage site.
which ran from July
a preferred "no
the Operation Unit
In response to the proposed plan and the documents contained
in the administrative record developed for this remedy, the EPA
received only two written comments (received from two potentially
responsible parties (PRPs). The issues raised in these written
comments are addressed below:
B. summary of Written Comments Received During the PUblic Comment
PeJ:iod
aebelka Enterprises Xnc., the corporation established by some or
all of the heirs of Joseph and Lovi. Kebelka submitted the
following comments regarding the proposed plan:
.
. comment: As a result of #4 monitoring well being drilled through
soil with lead levels of 65,100 mg/kg, and no .
decontamination of the drilling and boring rig during Phase
I testing, the groundwater tests in the monitoring wells
farthest from the battery casing piles continue to indicate
lead concentrations in excess of state and federal
standards. We urge EPA to remediate the groundwater to
background levels.
Response: EPA again denies the allegation presented by the
Hebelkas that the work performed during the Phase I Remedial
Investigation caused any contamination of the groundwater.
This allegation was made by these responsible parties at the
time of the Record of Decision (ROD) for the first operable
unit and EPA, and its authorized representatives, did, at
that time, and continues to maintain that it is untrue. It
is also untrue that EPA failed to decontaminate the drilling
equipment between drilling monitoring wells. The lead level
in the surface soil around the location of #4 monitoring
well is not 65,100 mg/kg as alleged, but rather in the range
of 50D mg/kg as indicated in the isoconcentration contour
map included as figure 3 in. this ROD. Furthermore, analyses
of the monitoring well samples from the Phase II testing (as
contained in the Remedial Investigation report which is part
of the Administrative Record) show no dissolved lead in the
groundwater at #4 Monitoring Well or any of the monitoring
wells sampled.
1
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Commen~: During Phase I testing, Iron Run stream sediment sample
#4 detected PCB 1260 at 550 ug/kg and 560 ug/kg at sediment
sample #6. No effort was made during Phase II testing to
review or '"'test -for further PCB contamination. We urge EPA to
investigate the extent of PCB and pesticide contamination in
Iron Ru~ stream and to remediate Iron Run to federal
standards.
Response: While it was noted that PCBs were detected in several
sediment samples during the Phase I sampling event, the
subsequent risk analyses, presented in the Record of
Decision for OU 1, for this substance showed the levels
present to be below actionable levels of concern. .
Furthermore, EPA's investigation of this site has not shown
PCBs to have been a contaminant of concern.
Commen~: Phase II surface soil sampling location map note #1
state: SW/SD-07 to be field located upstream from SW/SD-08.
.Final Phase II Field sampling Analysis Plan states: TWo
locations, SW/SD-07 and SW/SD-08 are located upstream of the
Hebelka property......these locations will be situated so as
to identify possible contamination from highway run-off.
Operable Unit 2 Remedial Investigation Report indicates no
SW /SD-07 at all, while sample SW /SD-08 was not received by ~
the laboratory. We feel these missing samples have skewed
the lead level results in Iron.Run stream. We urge EPA to
conduct further testing to d~termine lead levels in Iron Run
stream as a result of run-off from Interstate #78 and Old
Route #22.
Response: The primary goal of the Remedial Investigation of Iron
Run was to ascertain the levels of lead and to determine if
the levels measured were high enough to warrant remedial
action. A secondary goal was to ascertain the source of any
elev~ted lead measurements. The stream sampling performed
during the Phase II investigation showed that the stream
lead concentrations were not high enough to presently
warrant further action, however, as a follow-up
precautionary measure EPA has decided to conduct additional
bioassessment studies of Iron Run. Furthermore, based on the
sediment analyses conducted both above and below the Hebelka
Site, the source of elevated lead levels in the stream in
this area is from drainage ditch from the Hebelka Site.
Commen~1 one commenter who was unfamiliar with the
investigation history of the site requested a
meeting. This request was not received during
comment period.
Respons.: This person was contacted by phone and informed of the
availability of tbe administrative record for the Site~ He
was unaware that this existed and agreed to read it.
remedial
pUblic
the public
2
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C. Concerns Raised by the pennsylvania Department of
Environmental Resourc.s (PACER)
By letter dated August 22, 1991 the Commonwealth of
Pennsylvania commented on both the final Feasibility study and
the Proposed-Plan. The Commonwealth's comments on both of these
documents are addressed below:
peasibilitv study Comments:
Comment: Since other metals (othe~ than lead) have been found in
the previous sampling events, the groundwater samples (in
follow-up studies) should be analyzed for TAL metals.
Response: Analyses for TAL metals were conducted during the Phase
I testing. Based on these results and the subsequent risk
assessment, performed for the Record of Decision for
~perable Unit 1, it was determined that the risks posed by
these other metals, were below the risk levels for action.
Furthermore, while there were other metals found, in trace
quantities, there was no direct link between the presence of
these metals and the site.
Comment: There is some confusion over which RIfFS document
addresses which operable Unit.
Response: The draft RI, which was issued in 1988, but never
finalized, addressed both Operable units 1 and 2 and was
based on testing which EPA now refers to as Phase I testing.
Phase II testing was conducted in February 1991 and also
addressed both operable Units. The results of both Phases of
testing are being incorporated into a single RIfFS document
for the Site.
ProDosed Plan comments
Comment: PACER is concerned if the lead levels determined to be
present in the home well samples is dissolved lead as
opposed to total lead.
RespoDse: As indicated_in the work plan for the Phase II sampling
all of the lead analyses were for dissolved lead. The lead
levels determined to be present in some home wells are below
the established Maximum (Allowable) Concentration Levels
(MCLs). There is no apparent correlation between the
groundwater flow and the location of the homes experiencing
"lead in water" levels, ~, low lead levels were detected
both upgradient as well as downgradient from the site.
Based on the location of the homes and EPA's past experience
with this type of analysis, it appears that the lead levels
found.-are most representative of low level contamination due
3
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to lead in the residential plumbing system (samples were
obtained from the tap not the pump).
Comment: PADER~eels that the description of the proposed
groundwater monitoring need to be expanded and clarified and
that a_comprehensive survey of all nearby wells should be
conducted.
RespODse: As part of the Phase II sampling event, EPA contacted
every nearby resident for permission to sample their home
well. EPA sampled every nearby well where permission was
granted. EPA contacted approximately 16 homes and was
granted permission to sample 11 of those home wells.
comment: Requested clarification of Page 3, Column 1, Paragraph
2, Sentence 2. (see response)
Response: Sentence is clarified to read as follows:
. EPA's Present concern, as defined by this Operable Unit
(II), is the extent and degree of the lead contamination
both on the Hebelka Site, the groundwater, the nearby
surface stream and its sediments.
Comment: Summary of site Risks on page 3, second column should
specify onsite or offsite soils and at what levels these
risks are associated with.
Response: The risk levels for. lead exposure are clarified in the
risk assessment portion of this OU 2 Record of Decision.
Action levels were determined based on the EPA Policy
comment: Regarding the risk assessment on lead levels in the
stream sediment, PADER stated" the lead levels of biota
tissue were not analyzed for bioaccumulation and/or
biomagnification in the food chain."
Response: EPA agrees with this comment and
potential environmental impact of the
Even though test results indicated no
biota, part of the decision calls for
bioassessment of Iron Run in the area
is concerned with the
lead on stream biota.
impact on the stream
an expanded
of this Site.
Comment: The RI/FS finds that there is some risk associated with
long term ingestion of on-site groundwater which is contrary
to the risk stated in the proposed plan.
Response: It should be noted that lead was only found in the
unfiltered samples from the monitoring wells on the site.
The filtered samples showed no lead present, indicating that
the lead present is in the particulate form. Furthermore,
the on-site monitoring wells are not used for drinking water
purposes.
4
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Comment: PADER requests that additional explanation be provided
in the discussion on the potential risks from OU 2.
Response: The dlScuss10n section in the decision document on risk
assessment from the various routes of exposure has been
expanded to provide additional clarification.
Comment: The preferred "no action" alternative should be
evaluated under the nine criteria for environmental
comparative analysis.
Response: In accord with the EPAGuidance to Developing
Superfund No Action, Interim Action, and contingency Remedy
RODs (OSWER Publication: 9355.3-02FS-3) April 1991,
summarization of Comparative Analysis of Alternatives are
not required for "no action" decisions.
Comment: Deed restrictions or a notice in the deed should be
. considered for this site due to the associated risk.
Response: As presented in the decision document, the risks for
this operable unit are below Federal action levels. The
Commonwealth may chose, as a separate matter, to discuss th~
issue of deed restrictions with Lehigh County officials. The
personal representative for the Estate of Lovie Hebelka is
in the process of preparing a deed for the Hebelka property
which will provide certain restrictions due to the CERCLA
response actions planned for the site.
Comment: The proposed No Action alternative does not meet the
Pennsylvania ARAR for groundwater.
Response: In accord to EPA Policy regarding No Action Decisions
(ref. OSWER Publication 9200.5-2161) "If the baseline risk
assessment and the comparison of exposure concentrations to
chemical-specific standards indicates that there is no
unacceptable risk to human health or the environment, and
that no remedial action .is warranted, then the CERCLA 5121
cleanup standards for selection of a Superfund remedy
including the requirement to meet ARARs are not triggered."
5
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