EPA Superfund
Record of Decision:
PB94-963925
EPA/ROD/R03-93/176
January 1995
Hunterstown Road Site,
Straban, PA
8/2/1993
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RECORD OF DECISION
BUNTERSTOWN ROAD SITE
DECLARATION
SITE NAME AND LOCATION
Hunterstown Road Site
Straban Township
Adams County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for the Hunterstown Road Site in Adams County,
Pennsylvania. The selected remedial action was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCLA), 42
U.S.C. SS 9601 et. seq.; and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. This decision is based on the
Administrative Record for this Site.
The Pennsylvania Department of Environmental Resources (PADER),
acting on behalf of the Commonwealth of Pennsylvania, generally
agrees, but has not yet concurred with, the selected remedy.
ASSESSMENT OF TEE 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, as
discussed, in Summary of Site Risks, 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 07 THE REMEDY
Fred Shealer, the owner of a septic tank cleaning business,
disposed of hazardous wastes and wastes containing hazardous.
substances obtained from several companies, on his property
during the 1970's and early 1980's. This ROD addresses ground
water, surface water, soil, and sediment contamination at the
Site. The ground water at the Site and in nearby residential
wells is contaminated above health based levels. Soils and
sediments have also been contaminated above health based levels
and the ecology of a stream at the Site has been damaged by Site
contaminants. The Selected Remedy will address the Principal
Threats at the Site which ate Dense Non-Aqueous Phase Liqu^flsg Q g J [^ Q
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(DNAPLs) in fractured bedrock, and the high levels of metals
contamination in soils and sediments. The selected remedy for
this Site addresses the long term threats present at the
Hunterstown Road Site.
The selected remedy is a final ROD, the scope and role of which
addresses all Site problems and principle threats at the Site to
the maximum extent possible. The selected remedy includes the
following components:
Ground Water .
• Extraction wells to capture all ground water above a
depth of 800 feet contaminated with Volatile Organic
Hydrocarbons (VOCs).
• Treatment of contaminated ground water by air stripping
followed by destruction of contaminants in the air stream
using catalytic oxidation.
• Discharge of the treated water to an on-Site stream in
compliance with NPDES limits.
• Deed restrictions prohibiting the use of wells on the
Shealer property.
• Ground water monitoring, including identification and
installation of monitoring wells in the regional ground
water discharge area from the Site and residential well
sampling.
Soils / Sediments '
• LAGOON AND STRESSED VEGETATION AREAS - Excavation and
off-Site treatment of two feet of soil, backfill excavation
and installation of a one foot deep soil cover.
• CORNFIELDS AND BORROW AREAS - Installation of a one foot
deep soil cover over a geotextile and subsequent
revegetation to prevent contact with contaminated soils.
_-"3?^
• DRUM BURIAL AREAS - No additional action (Previous
Removal Action Completed)
• EXTENDED SOIL COVER - Soil cover extended over
contaminated soils between Lagoon Area, Stressed Vegetation
Area and East Stream.
• EAST and WEST STREAM CONTAMINATED SEDIMENTS - Excavation
and of f-Site treatment and disposal. A R 3 0 8 7 M
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• Fencing around soil covers and landscaping along fencing
to minimize the visual impact on the community.
Surface Water
• No Current Action - The Selected Remedial Actions for
other media will reduce contaminant levels in streams by
preventing migration of contaminants via surface water
runoff and ground water discharge.
Wetlands .
• Replace Wetlands Permanently Damaged by Remedial Action
and Restore Impacted Wetlands Areas.
>;
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 except the PADER's ARAR requiring remediation of
ground water to background and Federal MCLs. EPA has justified a
waiver of these ARARS for ground water below a depth of eight
hundred feet. The selected remedy is cost-effective.
This remedy utilizes- permanent solutions and alternative
treatment 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 the selected remedy will result in hazardous substances
remaining onsite above health-based levels, a review under
Section 121(c) of CERCLA, 42 U.S.C. $9621(c) will be conducted
within five years after initiation of the remedy to ensure that
the selected remedy is providing protection of human health and
the environment.
'ju++t~e~€+^£:
Stanley Laskowski " Date
Acting Regional Administrator
Region III
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TABLE OF CONTENTS
FOR
DECISION SUMMARY
SECTION PAGE
I. SITE NAME, LOCATION AND DESCRIPTION . 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
IV. SCOPE AND ROLE OF RESPONSE ACTION 5
V. SUMMARY OF SITE CHARACTERISTICS 5
VI. SUMMARY OF SITE RISKS 13
VII. SUMMARY OF ALTERNATIVES 21
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES 39
IX. THE SELECTED ALTERNATIVE . . . 48
X. STATUTORY DETERMINATIONS 59
XI. EXPLANATION OF SIGNIFICANT CHANGES ........ 63
APPENDIX A FIGURES
APPENDIX B APPLICABLE OB RELEVANT AND APPROPRIATE
REQUIREMENTS
APPENDIX C RISK ASSESSMENT DATA TABLES
APPENDIX D RESPONSIVENESS SUMMARY
APPENDIX E ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISION
HDNTERSTOWH ROAD SITE
DECISION SUMMARY
I. SITE NAME. LOCATION AMD DESCRIPTION
SITE DESCRIPTION
The Site was created by the use of privately owned,
undeveloped property for waste disposal by the property owner and
is located about 1.5 miles northeast of downtown Gettysburg in
Straban Township, Adams County, Pennsylvania. A Site location
map is provided as Figure 1 (Appendix A). Topography in the area
is gently rolling. The Site and surrounding areas are semirural
with both farmlands and residences adjacent to the Site. The
Site occupies an approximate area of 22 acres, and portions of
the Site lie both east and west of Hunterstown Road, as shown on
Figure 2 (Appendix A).
There are three unnamed tributaries of Rock Creek which flow
adjacent to portions of the Site. These are referred to herein
as the West Stream, Middle Stream, and East Stream, as indicated
on Figure 2 (Appendix A). The West and Middle Streams join just
north of Shealer Road, and the East Stream joins the other
combined streams approximately 0.2 miles south of Shealer Road.
Site soils are primarily derived from erosion of the
underlying Triassic red bed shales. Based on the RI/FS, soil
encountered was typically two to twenty feet thick consisting of
gray silty clay/clayey silt with rock fragments. The rock
exposed in the vicinity of the Hunterstovn Road Site consists of
northwest dipping sedimentary rock of the Gettysburg Formation.
Ground water near the Site is a class II aquifer and is used
by nearby residents for drinking water if they are not in the
area served by the public water supply.
At the time of Site discovery, a lagoon, two drum burial
areas and widespread surface wastes were present at the Site.
SITE HISTORY
Frederick Shealer, the owner of the Site and the operator of
a septic tank cleaning business, disposed of wastes from several
companies in six areas at the Site. Wastes were disposed west of
Hunterstown Road in Drum Burial Area 1. The other areas are
located east of the road. All of these areas are shown on Figure
2 (Appendix A) and are briefly described as follows: 110011071,1.
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Dro Burial Area l
This area is located just east of the West Stream, and has
an approximate length of 440 feet and a width averaging 90 feet.
Several hundred drums of wastes were buried in this area.
Drum Burial Area 2
This area lies north of the access road and immediately west
of the Middle Stream. The approximate dimensions are 180 feet by
50 feet.
Cornfield Area
This area is comprised of the North and South Cornfields.
The North Cornfield is a roughly triangular open field located
north of the access road. This field is approximately 500 feet
wide at the base and about 800 feet in length. The South
Cornfield is a roughly square open field located south of the
access road. This field has approximate dimensions of 400 feet
by 400 feet* Tank truck loads of liquid wastes, including a white
clay-like material and domestic septic tank sludges, were sprayed
onto the ground. The septic wastes and sludges contained toxic
metals.
Lagoon Area
The Lagoon Area is described as sloping, with approximate
dimensions of 100 feet by 150 feet. Paint sludges from drums and
colored pigmented clay sludges from tanker trucks were placed in
the Lagoon Area. Sludges with a high liquid content (primarily
solvents) were discharged into small depressions (pools) created
by mounding the drier residual solids into embankments. The
solvents drained into the subsurface soil and bedrock. The area
is currently enclosed by a chain-link fence.
Stressed Vegetation Area
This area is located east of the South Cornfield and roughly
southwest of the Lagoon. It has approximate dimensions of 50
feet by 100 feet.. Tank truck loads of pigmented clay sludges
containing toxic metals were reportedly discharged into
depressions remaining after the removal of the top soil.
Borrow Area
This area is located along the east bank of the East Stream.
It has approximate dimensions of 175 feet by 175 feet. Drums of
waste, construction debris and bundles of insulation board
containing amosite asbestos were disposed of at the surface.
INVESTIGATIONS/REMOVAL ACTIONS
An investigation was initiated by the Pennsylvania
Department of Environmental Resources (PADER) into the dumping on
the Shealer property as a result of a complaint from the Adams
County Community Environmental Control Office. According to the
complaint, drums containing waste generated by the Westinghouse
Elevator Manufacturing Plant in Gettysburg were deposited on the
Shealer property in 1975.
flR3087i*5
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In January 1984, the PADER requested assistance from the EPA
to investigate the disposal site. The PADER also requested aid
in implementing any necessary immediate removal or remedial
response measures.
On March 22, 1984, the EPA issued a CERCLA $106 Unilateral
Administrative Order (Order) to Westinghouse. Westinghouse was
required to provide, within seven days of the effective date of
the Order, a sufficient temporary potable water supply to all
households where the EPA On-Scene Coordinator deemed such
remedial action was needed. The Order required Westinghouse to
remove, all sludges and liquid materials from the Lagoon. The
Order was supplemented on August 8, 1984 by a request to provide
potable water to additional homes in the Site area.
In April 1984, Westinghouse contracted O.K. Materials of
Findlay, Ohio, to remove drums from the Borrow Area and Lagoon,
and to remove the Lagoon embankment and sludge material. A
chain-link fence was also installed around the lagoon.
At the conclusion of the removal, the EPA initiated a site
investigation. Based on the results of this investigation, the
Site was proposed for the National Priorities List in October
1984. Its listing was finalized in June 1986.
In December 1986, Westinghouse removed two piles of bulk
asbestos from the Borrow Area. On March 10, 1987, the EPA and
Westinghouse signed a Consent Order requiring Westinghouse to
conduct an RI/FS at the Site.
In April and May 1987, Westinghouse undertook a series of
Site modifications, including: installing a hogwire fence around
the Lagoon, Borrow Area and eastern portion of the South
Cornfield, installing straw-bale dikes around the lower half of
the Lagoon and around the Stressed Vegetation Area, applying line
to the Lagoon and Stressed Vegetation Area, covering the Lagoon
with mulch, covering the Stressed Vegetation Area with mulch and
plastic sheeting, regrading the southwest corner of the Lagoon,
installing a silt barrier on the chain-link fence, removing
contaminated debris from the East Stream channel, and removing a
culvert and reshaping the channel in the East Stream.
In August 1987, Westinghouse conducted an assessment of th«
volumes and types of waste found within the two buried drum
areas. Based on this assessment, Westinghouse conducted a
removal of a large number of buried drums from December 1988
through May 1989.
In December 1988, Westinghouse initiated Phase I RI
activities. In August 1989, Westinghouse submitted the Phase I
Report for the RI/FS. In July 1990, Westinghouse submitted
Revision 1.0 of the Work Plan and a Sampling and Analysis Plan
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detailing Phase II field activities designed to fill data gaps
identified in the Phase I RI/FS Report. Phase II was initiated
in September 1990.
In August and September 1990, with EPA and PADER approval,
Westinghouse treated ponded water from the two drum burial areas
using an air stripper and discharged the treated water into the
Middle and West Streams. Discharge limits were provided by the
PADER and were met. The excavations were then lined with a
geotextile to differentiate between backfill and existing soil
and backfilled with clean fill. The disturbed stream segments
were restored to pre-existing conditions, as feasible, and
reseeded.
The final RI report and Risk Assessment were approved in
December 1991.
CERCIA ENFORCEMENT
The entities that have been identified as Potentially
Responsible Parties are Frederick Shealer, Westinghouse Electric
Corporation, Spectra-Kote Corporation, Susquehanna Pfaltzgraff
Company, Inland Container Corporation and Dai-Tile Corporation.
Fred Shealer, Westinghouse Electric Corporation and Spectra-Kote
all received Special Notice letters from EPA requesting
performance of the RI/FS. Susquehanna Pfaltzgraff, Inland
Container Corporation and Dai-Tile Corporation have received
General Notice Letters.
III. HIGHLIGHTS OF COMMUNITY PARTICIPMIOM
The RI/FS and Proposed Remedial Action Plan (Proposed Plan)
were released for public comment as part of the administrative .
record file on April 24, 1993, in accordance with Sections
113(k)(2) (B), 117(a), and 121(f)(l)(C) of CERCLA, 42 U.S.C.
SS 9613(k)(2)(B), 9617(a), 9621(f)(1)(6). These and other
related documents were made available to the public in both the
administrative record file located in Region III Offices and at
the Adams County Public Library; a notice of availability was
published- in the Gettysburg Times and The Hanover Evening Sun on
April 24, 1993. A public meeting to discuss the Proposed Plan
was held on May 5, 1993 in Cumberland Township, Pennsylvania.
The comment period was extended at the request of the public
until June 22, 1992. EPA's response to all comments on the
Proposed Plan and related documents received during the comment
period is included in the Responsiveness Summary in this ROD. In
addition, a copy of the transcript of the public meeting has been
placed in the administrative record file and information
repository.
AR30871*?
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SCOPE AMD ROLE OP RESPONSE ACTION
The principal ground water threat at the Site is from Dense
Non-Aqueous Phase Liquids (DNAPLs) that have migrated into
fractured bedrock beneath the water table at the Site. DNAPLs
are liquids that when mixed with water, are not miscible and
form a separate liquid phase heavier than water. Because only
tiny amounts of these compounds will dissolve in water, DNAPLs
that have migrated into bedrock will provide a source of ground
water contamination for a very long time. The principal threat
from surface soils is the impact on ground water from Lagoon
soils contaminated with vinyl chloride, the threat of ingest ion
of the hazardous waste in the Stressed Vegetation Area or
ingestion of soils contaminated with metals two orders of
magnitude above health based levels in the Stressed Vegetation
Area by small children.
The scope and role these proposed remedial actions would be
to prevent migration of contaminated ground water to residential
areas outside the water line, to reduce the size of the ground
water plumes and to remediate the aquifer to the maximum extent
practicable. The proposed remedial actions would also remove
wastes and. soils that contain hazardous substances at high levels
posing a threat to human health and the environment and prevent
human and ecological exposure to soils contaminated with
hazardous substances in surface soils at lower levels. These
remedial actions will address all Sit* problems and this is the
final Record of Decision for the Sit*.
V. SUMMARY OF SITE CHARACTERISTICS
GENERAL
The Site was created by the us* of private undeveloped
property for waste disposal by th* property owner and is located
about 1.5 miles northeast of downtown Gettysburg in Straban
Township, Adams County, Pennsylvania. A Site location map is
provided as Figure 1 (Appendix A). Th* Sit* occupies an
approximate area of 22 acres, and portions of the Site lie both
east and vest of Hunterstown Road, as shown on Figure 2 (Appendix
A). Fred Shealer disposed of liquid wastes, including solvents
and paint sludges in the Lagoon Area shown in Figure 2 (Appendix
A). Wallboard containing asbestos, and several drums were
disposed in the Borrow Area. Sludges containing toxic metals
were sprayed on the cornfields, whil* they were actively farmeVJ,
and drums containing wastes were buried in the two areas shown in
Figure 2 (Appendix A). Wastes containing very high levels of
heavy metals were placed in the Stressed Vegetation Area and this
waste is still present at the Site. All areas except the
Cornfields and the Stressed Vegetation Areas have had emergency
actions completed which removed concentrated wastes.
AR3087U8
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There are three unnamed tributaries of Rock Creek which flow
adjacent to disposal areas at the Site. These are referred to
herein as the West Stream, Middle Stream, and East Stream, as
indicated on Figure 2 (Appendix A). The West and Middle Streams
join just north of Shealer Road, and the East Stream joins the
other combined streams approximately 0.2 miles south of Shealer
Road.
Site soils are primarily derived from erosion of the
underlying Trias sic red bed shales. Based on the RI/FS, soil
encountered was typically two to twenty feet thick consisting of
gray silty clay/clayey silt with rock fragments. The rock
exposed in the vicinity of the Hunterstowh Road Site consists of
northwest dipping sedimentary rock of the Gettysburg Formation.
Water generally flows through bedding plane and vertical
fractures to the West-Southwest.
\
Ground water near the Site is a Class IIA aquifer and is
used by nearby residents for drinking water if they are not in
the area served by the public water supply. All residents with
known well contamination are using the municipal water line.
LAND USE
The Site and surrounding areas are semirural with both
farmlands and residences adjacent to the Site. The past land use
of the property was for farming and waste disposal. Mr. Shealer
is currently using the property behind his house adjacent to Drum
Burial Area l to park his trucks and store materials associated
with his business activities. Fences generally prevent access to
the areas on the east side of Hunterstown Road.. During 1991 and
1992 the fence around the North Cornfield was in disrepair, and
evidence of recreational vehicle use of the North Cornfield was
observed.
The Gettysburg area is experiencing substantial development
pressures and this trend is likely to continue. Large
undeveloped properties exist to the northeast and to the south of
the Site. The owner of the property to the northeast of the Site
constructed several homes and reportedly wished to construct
eighty new homes on his property. His property failed tests for
septic systems and he will have to install sewer lines to develop
the remainder of the property. EPA has informed the developer of
his potential liability if he installs numerous wells which
spread the contaminant plume. EPA understands that a property to
the south will also probably be developed for homes, and a large
industrial park is planned for somewhere in the Gettysburg area.
If deed restrictions on the Shealer property are not placed and
no actions were taken, it is quite possible that the property
could be used to develop homes, and therefore, consideration of a
residential future use is reasonable.
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EPA classes ground water aquifers using the following
criteria:
1) Special Ground Water - Class One - Highly vulnerable
ground water that is irreplaceable with no alternative
source of drinking water available to substantial
populations.
2) Current and Potential Sources of Drinking Water - Class
Two - Class IIA is water currently used and Class IIB is
water that could potentially be used.
3) Ground water not a potential source of drinking water
because of quality.
EPA considers this source of drinking water to be a Class
IIA aquifer. EPA policy required remedial action for Class I and
Class II aquifers if Maximum Contaminant Levels (MCLs) allowed
under the Safe Drinking Water Act are exceeded.
TOPOGRAPHY
Topography in the area is gently rolling. Drum Burial Area
1 has been backfilled and is a relatively flat field covered with
grass. The Borrow Area is best described as a shallow depression
with a high mound of debris in the center. The Lagoon Area
slopes to the southwest ending in a small pond with wetlands
vegetation. The Stressed Vegetation Area is a fairly level
wetlands area, which slopes slightly to the East Stream. The
North Cornfield slopes to the Middle Stream and the South
Cornfield gently slopes to the east and middle steams.
Surface water flows from Drum Burial Area 1 flows to the West
Stream. Surface water runoff from the Cornfields and Drum Burial
2 flows to the Middle Stream. Surface water runoff from the
Lagoon Area and the Stressed Vegetation Area flows to the East
Stream.
REGIONAL GEOLOGY
The natural soils of the Hunterstown Road Site have been
classified by the U.S. Soil Conservation Service (USSCS, 1967) as
part of the Klinesville-Abbottstown-Readington-Penn Association.
These soils are moderately eroded, gently to moderately sloping,
very shallow to deep shaley soils primarily derived from the
underlying Triassic red beds. These soils vary from somewhat
poorly drained to well drained.
Results from the test pits performed in 1987 and the RI
subsurface explorations indicate that natural soil encountered
was typically two to twenty feet thick consisting of gray silty
clay /clayey silt with rock fragments. AR308750
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8
The rock exposed in the vicinity of the Hunterstown Road
Site consists of northwest dipping sedimentary rock of the
Gettysburg Formation. The igneous intrusives have altered the
sedimentary rocks at the Hunterstown Road Site by increasing
their hardness and changing their color and chemical composition.
Such effects are a product of thermal metamorphism, where the
changes are due to heat rather than heat and pressure or just
pressure. In addition to the "baking" of the rock, hot water
contained within the sedimentary rocks and/or provided by the
magma also alters the mineralogy. The soft argillaceous red
shale, typical of the Gettysburg Formation, is altered by this
process to hard horafels colored dark red to dark purple to
black, as one moves closer to the instrusive. This color change
is due to the reduction of the iron minerals. The contact
metamorphism of the larger diabase masses generally penetrates
wall rock a distance of 15 to 20 feet and in some cases as much
as 100 feet (Stose, 1932). All of the sedimentary rock
encountered in this investigation of the Hunterstown Road Site
has been altered to horaf els, attesting to the proximity and
pervasiveness of the igneous intrusives encountered at the Site.
The estimated strike and dip calculated by using natural
gamma correlations for these borings is N41 degrees E dipping 26
degrees NW defining azimuths within the Universal Transverse
Mercator (UTM) system, with north located less than 1.5 degrees
counterclockwise of geographic north. Measurements from outcrops
in the area show a fairly close agreement to the borehole
measurements:
The rocks encountered at the Hunterstown Road Site are
fractured, as shown in the graphic discontinuities column of rock
core Borings HTB-1, HTB-2, and HTB-3 (RI report). The rock core
provides information regarding the joint spacing, dip, and
minerals present along joint openings. Joint orientation was
measured in 16 joints encountered along a railroad cut 2,000 to
4,000 feet east of the Hunterstown Road Site. All joints dipped
steeply, between 73 degrees and vertical.
The rocks of the Gettysburg Formation have little effective
primary porosity, and water is principally stored and transmitted
through an interconnected system of fractures consisting of the
bedding plane partings and steeply dipping joints.
REGIONAL HYDROGEOLOGY
Based on ground water level contours constructed from on-
Site wells, the overall horizontal direction of shallow ground
water flow is west to southwest, generally towards Rock Creek
with on-Site tributaries apparently acting as localized discharge
points. Based on a comparison of ground water levels in the
shallow (weathered) bedrock unit and surface water levfllhg ftfi 7 5 I
appears that the East Stream and the Middle Stream are"Ihwww
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hydraulic connection with the shallow bedrock flow.
Bedrock permeability test data were obtained from five
borings in the shallow weathered bedrock. Based on a calculated
average hydraulic conductivity and the gradient of 0.01 across
the South Cornfield, the average horizontal specific discharge
through the upper, weathered portion of the bedrock is expected
to be approximately 4 x 10-7 cm/s, or 10-3 feet per day (ft/d).
The actual seepage velocity associated with this fluid flux
depends strongly upon the porosity of the formation. Typical
values for bedrock range from 0.1 to 2 percent. Using this range
in porosities, the seepage velocity of ground water in the
shallow bedrock regime is expected to range from 2 x 10-6 to 4 x
10-4 cm/s, or 0.05 to 1 ft/d. This is the average velocity at
which dissolved constituents would be transported in the absence
of environmental attenuation factors such as adsorption,
diffusion, dispersion, and degradation.
A multilayered "sandwich" of alternating igneous sills
(granite) and homfels (altered siltstone) dip to the northwest
downward about 23 degrees. Water flows in deep bedrock wells
flows primarily within fractures in the hornfels between igneous
sills and less permeable hornfel layers. The sills and less
permeable horfels tend to confine the water but some vertical
fractures allow water to "leak" from one layer to a deeper layer
(Figure 3 - Appendix A). Contaminated ground water moves through
a complex network of bedding plane and vertical fractures to the
west-southwest. Additional monitoring wells would be needed
during the design of the remedial action to bound all of the
plumes at the Site.
A review of equipotential lines plotted on Figure 4-3 in the
Feasibility Study indicates a significant change in potential for
vertical ground water flow as you move from the eastern limits of
the Site to the western limits of the Site. These equipotential
lines are interpreted as an overall increase in permeability
(fracturing) as you move east to west across the Site.
Regionally, deep ground water at the Site is anisotropic,
with flow downdip along bedding planes to the northwest, but with
a strong component along strike to the southwest. Deep ground
water flow is affected by igneous intrusive* which cross bedding
planes and may act as hydraulic barriers to ground water flow.
The deep ground water flow regime may be affected by the presence
of mapped fracture traces oriented primarily N 15 degrees E and N
55 degrees E, which may act as preferential flow paths for ground
water flow to the southwest.
PRIMARY CONTAMINANTS
Based on the Remedial Investigation, the most significant
contaminants for ground water contamination at the Site have been
AR308752
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10
identified as: trichloroethene (TCE), 1,1,i-trichloroethane
(TCA), vinyl chloride, 1,1-dichloroethene, 1,1-dichloroethane,
and 1,2-dichloroethane. Vinyl chloride, however, has only been
detected in wells associated with the Lagoon Area.
Based on the Remedial Investigation, the most significant
contaminants for surface soil for the different areas of the Site
are as follows:
PRIMARY
CONTAMINANTS
BY AREA
Antimony
Barium
Copper
Chromium
Lead
Mercury
Vinyl
Chloride
1,1 - DCE
Borrow
Area
X
X
Lagoon
X
X
X
X
X
X
Cornfields
X
X
X
X
Stressed
Vegetation
X
X
X
X
X
X
The primary contaminants in East Stream sediments are lead,
chromium, copper, zinc and barium.
CONTAMINANT FATE AND TRANSPORT
The primary transport pathway of contaminants at the Site to
receptors is through ground water migration. Ground water
migration of COI appears to be their desorption from solids in
potential source areas and their subsequent infiltration into
ground water and more importantly, diffusion into ground water
from DNAgLs. The DNAPL would be ioeyu«ed of TCA and TCE. Once in
ground water, they are adyected and dispersed.
Trichloroethene slowly degrades in ground water sequentially
losing a chlorine atom to form diehloroethane, vinyl chloride and
finally ethylene gas. TCA degrades similarly to diehloroethane,
chloroethane and finally ethane gas. Vinyl chloride and 1,1 —
dichloroethene, two degradation products of TCE, are regarded as
more potent carcinogens than TCE due to their high slope factor
values. TCE that is not captured may eventually form these
compounds.
Any VOC-contaminated ground water discharging to streams
AR308753
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11
would be substantially diluted and the VOC contaminants would
quickly leave the surface water to air where they would be
further diluted and dispersed.
Metals present as particles in soils may be transported in
surface water runoff to streams and then off-site in stream flow.
Small amounts of metals may be dissolved in runoff and carried
downstream. Although present in surface wastes and subsurface
soils, metals have not migrated to ground water at large enough
concentrations to be detected. It is not unusual to find metals
mobility low when the pH of ground water is neutral and the
geology is.sedimentary. . '
EXTENT OF CONTAMINATION
• Ground Water - Forty monitoring wells were drilled and sampled
during the Remedial Investigation. Three separate and extensive
plumes of ground water contamination (Figures 4, 5 & 6 -
Appendix A) were identified from the Lagoon Area, Drum Burial
Area 1 and Drum Burial Area 2. The contaminants in the plumes
were primarily the solvent constituents Trichloroethene (TCE),
Trichloroethane (TCA) and their breakdown products. The
following table compares some of the highest levels of Volatile
Organic Contaminant (VOCs) concentrations found in the Phase II
RI to the allowable maximum contaminant levels (MCLs) of these
constituents under the Federal Safe Drinking Water Act. MCLs are
enforceable federal.standards.
Vinyl
chloride
1,1 DCE
1,1,1 TCA
TCE
MCL
2
7
200
5
Lagoon
1400
290
820
48.000
Drum
Burial 1
-
210
13,000
9,800
Drum
Burial 2
-
25
85
18
* - All units in parts per billion, (ppb)
The levels of VOC contamination are far above the federal
standards (MCLs) and ground water mediation is required.
Although toxic metals were found in soils at the Site, the
Remedial Investigation did not detect elevated levels of toxic
metals in ground water. This is often the case when ground water
is not acidic and when sedimentary rock is present which tends to
adsorb the metals.
AR308751*
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12
Most of the homes near the Hunterstown Road Site are served
by a public water line. During the RI, extensive residential
well sampling was conducted in the areas outside of the area
served by the water line. This sampling did not detect
contaminants in residential wells above drinking water standards.
EPA and Westinghouse also surveyed the home owners in the area
served by the water line and determined that all residents
contacted were using public water.
• Soil* and Surface Wastes
The following areas of soil contamination are shown in
Figure 2 (Appendix A).
* Borrow Area - Post removal sampling indicated residual
asbestos in this area, but asbestos was not detected during the
RI. One sample showed a lead concentration of 932 ppm in shallow
soil which is well above EPA's action level of 500 ppm.
* Lagoon Area Soil - Toxic metals (antimony, chromium,
copper, lead, mercury and zinc) were detected above background
levels. Lead was detected as high as 5,000 ppm, mercury at about
0.15 ppm and Vinyl Chloride was detected at about 0.6 ppm. . .
* Cornfield Area - Levels of barium, copper and lead above
background concentrations were identified in both Phase I and
Phase II soil samples. A Phase I surface soil sample had a lead
level of 1,700 ppm. Mercury was detected as high as 0.5 ppm in
this area. White layers of sludge are sometimes mixed with
Cornfield soils and contain up to 6,500 ppm of lead. Soil samples
that contained particles of this white material had elevated lead
levels, while soils that did not contain this material were
generally "clean". This material is widely spread through the
Cornfield and could not be easily separated. The. RI results and
EPA's records which show very large volumes of this sludge
disposed indicate a very large number of "hotspots" above action
levels. • These "hot spots" far exceed the lead action level of
500 ppm, but because of the large volume of soil, the average
lead levels are much lower (approximately 400 ppm).
* Stressed Vegetation Area - This is the only area of the
Site that still contains actual wastes rather than just
contaminated soils. In the Stressed Vegetation Area, levels of
barium (1,526), chromium (10,000 ppm), copper (7000 ppm), lead
(54,000 ppm), and zinc (1000 ppm) above background concentrations
are found to the south and west, with the highest levels found
immediately within the area and attenuating as you move beyond
the perimeter. The wastes in this area failed the Toxicity
Characteristic Leaching Procedure for lead (92 ppm) and as a
result, these wastes are classified by EPA as a RCRA
characteristic hazardous waste. .
AR308755
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13
* Drum Burial Area 1 - Area appears to contain levels of
VOCs above practical quantitation limits (aromatic and
chlorinated aliphatic hydrocarbons) in surficial soil samples
taken shortly after waste removal. Perimeter subsurface soil
sampling results indicate that VOCs have not migrated along the
soil-bedrock interface. Although some residual contamination
remains, the levels in soils are much lower than ground water
concentrations. For example, the compound of most concern in
ground water is TCE and its related break down products. TCE is
present in ground water at 26,000 ppb, but the highest level in
soil currently is 940 ppb. The gasoline constituents xylenes and
ethylbenzene are present in soils at higher levels than TCE, but
are not migrating significantly to Site ground water. The
excavation is backfilled with approximately four to five feet of
soil.
* Former Drum Burial Area 2 - Does not contain levels of
contaminants above practical quantitation limits.
• Surface Water and Sediments of Streams
* Surface water in the East Stream contains levels of lead
and other metals above background concentrations and chlorinated
aliphatics above .practical quantitation limits. These
contaminants have been found within 400 feet from the Borrow
Area, the Stressed Vegetation Area, the Lagoon Area; and in the
shallow ground water which discharges to the East Stream from
these three areas. East Stream sediments contained chromium,
copper, lead, and zinc above background concentrations and at
levels expected to impact stream life and plants. The Middle
Stream contained slightly elevated levels of zinc and bis-2-
ethylhexylphthalates in a limited section of the stream. The
West Stream did not contain elevated levels of contaminants.
VI. SUMMARY OF SITE RISKS
Overview
As part of the Remedial Investigation performed for the
Hunterstown Road Site, a risk assessment was conducted to
evaluate the potential impacts of the Site on human health and
the environment. Compounds of interest were identified separately
for four environmental media: ground water, surface water,
sediments and soil. The risks potentially associated with
exposure to these chemicals for each media were assessed.
Potential risks to human health were identified by
calculating the risk level or hazard index for each compound of
interest. Carcinogenic risks were calculated as the lifetime
incremental upper-bound risk (probability) of developing cancer
as a result of being exposed to the chemicals of concern under
AR308756
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14
the assumed conditions. Risk for noncarcinogens were evaluated
relative to a chronic reference dose (RfD), "which is an EPA
estimate of a daily exposure level for the human population that
is likely to be without an appreciable risk of deleterious health
effects during a lifetime. The ratio of the estimated dose to
the RfD for each compound of interest is called the hazard index.
If the hazard index exceeds one (1.0), there may be concern for
potential systemic effects. As a rule, the greater the value of
the hazard index above 1.0, the greater the level of concern.
The Risk Assessment uses a statistical analysis concept called
Reasonable Maximum Exposure (RME) to predict the highest
reasonable expected concentrations that a receptor might be
exposed to for use in the Risk Assessment. In calculating the
risks at the Site, the exposures evaluated assume more extensive
contact with the Site contaminants than is probably occurring, or
is likely to occur in the future. This concept produces a
conservative estimate of risk which is protective of receptors
including sensitive sub-populations.
Standard EPA methodologies were used in the Risk Assessment
for exposure times, chronic daily intake factors and key risk
exposure factors. Toxicity information was obtained from the
IRIS and HEAST toxicological data bases. The Risk Assessment was
reviewed and certified by the EPA Site toxicologist.
Exposure Media
Soils, sediments, surface and ground water are the media of
concern at the Site.
Compounds of Interest
Based on the Remedial Investigation, the most significant
contaminants for.ground water contamination at the Site have been
identified as: trichloroethene, 1,1,1-trichloroethane, vinyl
chloride, 1,1-dichloroethene, 1,1-dichloroethane, and 1,2-
dichloroethane. Trichloroethene is moderately toxic to humans by
ingestion and inhalation and is considered a probable carcinogen.
1,1,1-trichloroethane is moderately toxic to humans by ingestion
and inhalation routes and is currently not considered a
carcinogen. Vinyl chloride is moderately toxic by ingestion and
inhalation and is classed as a human carcinogen. 1/1-
dichloroethene is a poison by inhalation, ingestion, and
intravenous routes; moderately toxic by subcutaneous route; and
is currently considered to be a possible carcinogen. 1,1-
dichloroethane is moderately toxic by ingestion and is a possible
human carcinogen. 1,2-dichloroethane is a poison by ingestion;
moderately toxic by inhalation and subcutaneous routes; and is
considered a probable carcinogen (Sax and Lewis, 1989).
The following table compares some of the highest levels of
Volatile Organic Contaminant (VOCs) concentrations
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15
Phase II RI to the allowable maximum contaminant levels (HCLs) of
these constituents under the Federal Safe Drinking Water Act.
MCLs are enforceable federal standards.
Vinylchloride
1,1 DCE
1,1,1 TCA
TCE
MCL
2
7
200
5
Lagoon
1400
290
820
48,000
Drum
Burial 1
-
210
13,000
9,800
Drum
Burial 2
• -
25
85
18
* - All units in parts per billion, (ppb)
. Based on the Remedial Investigation, the most significant
contaminants for surface soil and sediments for the different
areas are as follows:
MAXIMUM
LEVELS
ppm
Antimony
Barium
Copper
Chromium
Lead
Mercury
Vinyl
Chloride
1,1 - DCE
Borrow
Area
1192
932
Lagoon
2369
1599
5015
0.15
0.61
0.29
Cornfields
7026
702
6545
0.51
Stressed
Vegetation
92
1526
7180
10029
54321
1.53
Absorption of antimony via oral and inhalation routes is low.
Pneumoconiosis has occurred in humans exposed by inhalation and
dermatitis has occurred in individuals exposed orally or
dermally. Adverse effects to humans following oral exposure to
soluble barium compounds include gastroenteritis, paralysis,
hypertension, ventricular fibrillation and central nervous system
damage. Copper has only minor effects on humans, but has
significant negative effects on plants and aquatic life.
Chromium VI has been classed as a human carcinogen for inhalation
AR308758
-------
16
exposure. Lead has been classed as a probable carcinogen based
animal experiments. Lead is toxic to humans causing alterations
in the hematopoietic and nervous systems. Mercury is absorbed
following inhalation exposure, but poorly absorbed following oral
exposure. Mercury is toxic to humans and especially -toxic to
aquatic life. Vinyl chloride is classed as a human carcinogen.
1,1 DCS has been classed as a possible human carcinogen.
Exposure Assessment
The following risk scenarios were evaluated in the risk
assessment:
Current Land Use Scenario
Oil-Site: Visitor Children
Off -Site: Near site adults, developing children and
young children.
Use Scenario
en-Bite: Construction workers, resident adults,
developing children, and young children.
Off -Site: Near-Site resident adults, developing
children and young children.
All scenarios and exposure assumptions are given in Tables 1
and 2 in Appendix C. Risk Assessment definitions and calculation
explanations are given in Table 3 in Appendix C. Carcinogenic
Slope Factors and Reference Do'ses along with their data sources
are given in Tables 4 and 5 of Appendix C. The full details are
in the risk assessment available in the Administrative Record.
Site Risk Characterization
The actual risk assessment evaluates many possible scenarios
to evaluate the risk, including but not limited to near-Site
adults, near-Site children, near-Site young children, on-Site
adults, on-Site children, on-Site young children, on-Site
construction workers, trespassing children and many others. The
detailed risk assessment is available in the administrative
record. The following table is based on the risk to children.
The scenarios for which the highest risks were generated in each
of the pathways and subroutes were used for risk evaluation in
order to be protective of human health. The exposure point
concentrations and risk associated with the various Site surface
soils are summarized below for a hypothetical case of children
living on the Site directly exposed to the contaminated soil
areas:
AR308759
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17
RME Exposure
Point
Concentrations
ppm
Antimony
Barium
Copper
.Chromium
Lead
Mercury
Vinyl
Chloride
1,1 - DCE
Borrow
Area
473
437
Lagoon
Area
19
2370
1599
5015
0.15
0.61
0.29
Cornfields
3710
451
56
3360
0.3
Stressed
Vegetation
Area
•
356
1320
2000
8950
0.40
SURFACE SOIL.S
Borrow Area
Lagoon Area
Stressed Vegetation
North Cornfield
South Cornfield
Incremental
Cancer Risk
8.3 x 10~8
1.7 X 10~4
2.1 X 10~6
7.9 X 10~8
2.5 X 10~7
Hazard Index
0.05
2.2
4.6
6.0
4.2
Only the Lagoon Area shows a higher incremental cancer risk
than EPA's trigger level of 1.0 x iO~4. However, all areas
except the Borrow Area have a higher hazard index than 1.0, above
which EPA usually considers taking an action. Except for the
Borrow Area, these levels indicate a clear need to take action.
It should be realized, however that these risk-based numbers were
calculated based on the risk to a person actually living in the
area containing the waste. This represents a worst case future
highly contaminated land use scenario.
Of several current use pathway scenarios for exposure to
soils, the highest risk is experienced by visiting (trespassing)
children who might periodically visit the site for limited
durations. The cancer risk to trespassing children was well
below EPA's trigger for action. The systemic risk or Hazard
Index was also very low for visiting children in all areas except
the North Cornfield which showed a higher, but acceptable HI (HI-
°-4>- 4R308760
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18
The cancer and systemic risk to near-Site residents from
soils was very low and would not require EPA action based on this
exposure scenario. The risk to on-Site construction workers was
also low for both carcinogenic and systemic effects.
' Under the current land use, the risk from the soil areas to
nearby residents would not require EPA action. Nevertheless/
where appropriate, EPA usually considers remedial action
necessary for soil areas based on future use. Additionally,
action may be needed to prevent exposure of trespassing children.
Ground Water
VOCs in ground water, in all three plumes at the Site, are
above the Maximum Contaminant Level (MCL) allowed in potable
water by the Safe Drinking Hater Act. The ground water under the
Fred Shealer property is grossly contaminated and poses
unacceptable cancer and systemic risks if it were used for
drinking water. This water is not used currently for drinking
and a deed restriction would be placed on the Shealer property to
prevent its use as drinking water in the future.
The risk to all categories of residents living near the.
Shealer property and drinking ground water is slightly above
EPA's trigger level of l x NT*. The Hazard Index (HI) is well
below 1.0 for the use of all categories of near-Site residents.
Based on the risk level, and MCL exceedences, EPA has a clear
justification to take action to remediate Site ground water.
Exposure point concentrations are highly variable and depend
on the location and depths of wells. The highest Site risks from
ground water use are derived from a future use scenario with on-
Site resident children drinking the water from wells in the most
contaminated portions of the plume on the Shealer property:
GROUND WATER
•
Lagoon Area
Drum Burial Area 1
Drum Burial Area 2
Incremental
Cancer Risk
7.0 x 10"2
4.5 X 10°
3.6 X 10"4
Hazard Index
47.3
2.4
0.2
Incremental cancer and systemic risks are. extremely high in
the Lagoon Area plume and in the plume associated with Drum
Burial Area l. Cancer risks are above EPA's trigger for action
in the plume associated with Drum Burial Area 2. MCLs are
greatly exceeded for VOCs in all three plumes.
AR30876I
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Surface Water and Sediment
Surface water from the three streams is not used by human
receptors and consequently, the risk from domestic use of surface
water was not evaluated for residents. The combined risk of
ingestion of surface water and sediments was evaluated for on-
Site visitor children. The highest cancer risk was associated
with the East Stream, but was still very low
6 x 10~8. This risk level does not require action based on human
health risk. The risk from systemic effects was also very low
with the highest risk associated with the East Stream (HI -
0.01). This risk level also does not require action based on
human health risks. The contamination in the stream does present
unacceptable ecological risks that are discussed below.
ECOLOGICAL ASSESSMENT
Assessment
Exposure pathways evaluated in the Risk Assessment included:
• exposure of terrestrial plants at the root level to
contaminants in soil and soil moisture.
• exposure of aquatic vegetation to contaminants in
sediment pore water and surface water.
• exposure of soil invertebrates to contaminants through
ingestion and dermal contact.
• exposure of benthic invertebrates to contaminants in
surface water and sediment.-
• exposure of higher level organism* through the food
chain.
Summary of Ecological Risk, QiflT^gtyrization
Soils
Potentially phytotoxic levels of the following metals were
detected in soil samples from these areas:
• Lagoon - antimony, chromium, copper, and lead
• Borrow Area - copper and lead
• Stressed Vegetation - antimony, barium, chromium, copper,
lead, mercury, and zinc
• Cornfields - Barium, lead, zinc, and copper
Concentrations of metals that may potentially pose a threat
to soil invertebrates were found in samples from these areas:
ftR308.762
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20
• Lagoon - Copper
• Stressed Vegetation - Copper, lead, and zinc
• cornfields - copper and zinc
Metals detected that may bioaccumulate and pose a risk to
higher organisms at the Site include: chromium, lead and zinc.
Surface Water
Some surface water samples from the East Stream had
concentrations of lead and copper that may pose chronic risks to
aquatic organisms. Chromium and zinc were detected at •
concentrations that may pose chronic risks to aquatic organisms
in the East and Middle Streams. Since metals in surface water
were detected at concentrations only slightly above the fresh
water Ambient Water Quality Criteria, risk to aquatic organisms
are not very: high. Toxicity testing on a surface water and
sediment sample from downstream of the Site showed no impact on
aquatic organisms downstream of the Site.
Sediments
High levels of metals, including lead, chromium, zinc and
copper were present in East Stream sediments. The levels were
high enough to be toxic to vegetation and to pose a risk to
aquatic organisms and benthic invertebrates in the East Stream.
This was confirmed during a Site visit by Westinghouse's
contractor and EPA's biologist. The visit was conducted to gauge
the health of the streams. Normal insect life was not found in
dead leaves and under rocks in the East Stream. The Middle and
West Streams were dry during this visit and were also dry during
every visit by the EPA project manager. Levels of phthalates and
zinc are somewhat elevated in a very limited area of the Middle
Stream near Drum Burial Area 2 and may pose a risk to aquatic
organisms present in this intermittent stream during very wet
periods.
S/tream Bioassay
Reference samples and a sample from 0.3 miles downstream
from the Site after the west stream, the Middle Stream and the
East Stream merge were collected. Surface water and sediment
samples were used in acute and chronic toxicity tests. The
following three tests were performed:
• Chronic Ceriodaphnia dubia Survival and Reproduction
Test From Exposure to Surface Water.
• Chronic Ceriodaphnia dubia Elutriate Survival and
Reproduction Test From Exposure to Elutriate; and
• Acute Hyallella azteca Sediment Toxicity Test From
Exposure to Sediment. AR308763
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21
Based on the bioassay analyses, there are no significant
statistical differences between the reference samples and the
samples taken downstream from the Site.
Rare or Endangered Species
No known populations of rare or endangered plant or animal
species or significant biological communities are present within
or in close proximity to the Site boundaries.
Relevant Risk Management Issues
The excess cancer risk levels for domestic use of ground
water are outside of EPA's acceptable risk range for both ground
water on the Shealer property and near the Shealer property.
Contamination in ground water is above the MCL's promulgated
under the Safe Drinking Water Act. Either of these conditions is
sufficient to require a Remedial Action for ground water. It is
important to note that a public water line serves residents
adjacent to the Shealer property and that there are no known
receptors using contaminated ground water as a source of drinking
water. Many residential wells are still in operation and are
used for watering lawns and gardens. Future purchasers of the
properties in this area may be. unaware of the problem. • . .
Additionally, there exists a threat for possible human health
risks if at sometime in the future, development occurs down-
gradient of the Site with installation of new wells.
The Site soils in the Lagoon, Cornfields and Stressed
Vegetation Areas, pose unacceptable ricks to human health from
direct contact for active residential UM of the Site. Soil lead
levels in excess of 500 ppm may contribute to an increase in.
children's blood lead levels, and remediation of such levels is
protective of human health. The Gettysburg area is developing
rapidly and homes could be built on the Site in the future if no
EPA action is taken. These areas and the Borrow Area also pose, an
ecological risk to plants, soil invertebrates and higher
organisms.
Sediments in an on-Site section of the East Stream and a
small section of the Middle Stream pose unacceptable ecological
risks to aquatic life and benthic organisms.
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present aa imminent and substantial
endangerment to public health, welfare, or, the environment.
VII. SUMMARY Or XLTERKATIVBS
The Feasibility Study reviewed a variety of
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22
determine if they were applicable to the contamination at the
Site. The technologies determined to be most applicable to these
materials were further explored to develop into remedial
alternatives for the Site. These alternatives are presented for
each area and discussed below. Many other technologies were
reviewed and screened out. This process is fully detailed in the
Feasibility Study found in the administrative record.
The Site has many different problems in many different areas
and media. For example, there are seven separate areas of soil
contamination, with differing contaminants, three separate and
distinct ground water contamination plumes, two contaminated
streams, and an impacted wetlands area along the East Stream.
The number of combinations and permutations of the possible
alternatives and different areas for an overall remedy is very
large. The Feasibility Study was simplified by developing a
group of generic alternatives for each media, so that a matrix of
alternatives and media could be produced. This substantially
simplified the tabular presentation of costs and other
information. The use of a common list of alternatives for each
media/area will also facilitate combining areas into an
integrated remedy for more than one area when appropriate.
Based on the RZ Report and the risk assessment, the following
environmental site media were identified.
Medina 1 - Drum Burial Area* l and 2 Ground water: Medium 1
consists of ground water associated with Drum Burial Area 1 and
ground water associated with Drum Burial Area 2. The compounds
of interest (COI) for Medium 1 are volatile organic compounds
(VOC).
Medium 2 - Lagoon Area around waters Medium 2 consists of ground
water associated with the Lagoon Area. The COI for Medium 2 are
the VOCs observed in Medium 1 and vinyl chloride.
Medium 3 - Stressed Vegetation Area Soils Medium 3 consists of
surface and subsurface contaminated soils and concentrated waste
residues in the Stressed Vegetation Area containing toxic metals.
Medium 4 - Borrow Area Soil: Medium 4 consists of portions of
surface soil and mounded soil/demolition debris in the Borrow
Area which contain lead and asbestos.
Medium 5 - Lagoon Area Soils Medium 5 consists of the portion of
surface and subsurface soils in the Lagoon Area which contain
toxic metals and VOCs, including vinyl chloride.
Medium 6 - South Cornfield Area Soils Medium 6 consists of the
portions of surface and subsurface soil in the South Cornfield
Area which contain toxic metals.
AR308765
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23
Medium 7 - Horth Cornfield Area Soil: Medium 7 consists of the
portions of surface soil in the North Cornfield Area containing
concentrations of toxic metals.
Medium 8 - Drum Burial Area 1 Soil: Medium 8 consists of the
portions of the subsurface soil in Drum Burial Area 1 containing
post-removal residual concentrations of VOC.
Medium 9 -Drum Burial Area 2 Soils Medium 9 consists of the
subsurface soil in Drum Burial Area 2 containing post-removal
residual concentrations of VOC.
Medium 10 - Surface Water: Medium 10 consists of surface water
from the East and Middle Streams containing VOC and metals due to
on-Site disposal activities.
Medium 11 - Stream Sediments: Medium 11 consists of a portion of
the East Stream sediments containing toxic petals and a portion
of the Middle Stream containing phthalates and zinc due to
disposal activities on-Site.
OROOMP WA^ER ALTERNATIVES: The following ground water remedial
alternatives were developed for Medium 1 (Drum Burial Areas 1 and
2) and for Medium 2 (Lagoon Area). Alternatives 2 through 5 are
designed to capture and remediate the ground water plumes in each
area. Alternative 6 is designed to more aggressively extract and
treat ground water from the aquifer.
All costs and implementation time-frames specified below are
scoping estimates based on the best currently available
information. Present Worth is the total cost of the remedy
including capital costs and 30 years of operation and maintenance
.of the remedial action, in current dollars. Because of the
complexity of the geology and the probable presence of DNAPLs,
the time frames to reach ground water cleanup goals are virtually
impossible to predict at this Site. Also, the extent and depth of
contaminant plumes have not been totally defined. A 30 year
operation cost estimate was used for ground water alternatives.
The "capture zone" for contaminated ground water at a depth of
less than 800 feet under Alternatives 2 through 6 must be
maintained until background levels of contamination are reached
for twelve consecutive quarters. All ground water contaminated
above background levels and at a practical depth (above 800 feet)
would be captured and treated. EPA waives the Commonwealths' s
background ARAR for ground water at a depth of greater than 800
feet on the basis of technical impracticability. EPA also waives
the Federal Maximum Contaminant Levels (MCLs) and Maximum
Contaminant Level Goals (MCLGs) for ground water at a depth
greater than 800 feet. The basis for the waiver is the
impracticability of remediation of ground water contamination
from DNAPLs in fractured bedrock at extreme depths. EPA's
AR308766
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24
technical experts on DNAPL sites believe that at some sites, such
as the Hunterstown Road Site, it may be appropriate to remediate
portions of the aquifer and invoke a waiver for a different area
of the aquifer. EPA is steadily gaining experience remediating
sites with DNAPLs in fractured bedrock and policy and guidance
are still evolving.
Based on records in EPA's files, up to 130,000 gallons of
waste from the Hestinghouse Elevator Plant was disposed at two
Superfund sites (10 drums/month for ten years). Most of the
waste was solvent sludge which went to the Hunterstown Road Site.
Based on a crude estimate making many assumptions, about 25,000
gallons of spent solvent was disposed in Drum Burial Area 1 and
about 40,000 gallons of spent solvent was disposed in the Lagoon
Area. Although this is a very rough estimate, it shows that a
large amount, of solvent with a very low solubility, was disposed
in a geological formation with a low permeability and slow ground
water movement. At the Hunterstown Site, the solvent would be
trapped in numerous small fractures in.the bedrock and would have
migrated downward to great depths in the bedding plane fractures.
This trapped solvent will slowly dissolve over a long period of
time substantially delaying the ground water cleanup. Although
DNAPLs were not observed in the well samples, EPA believes that
the Site history and ground water concentrations of solvent
constituents support their presence.
Although the above information does indicate a high
probability that DNAPLs are present, DNAPLs have not actually
been detected in well samples and EPA does not have long term
pumping data to show the ground water concentration
characteristics associated with the presence of .DNAPLs. When
DNAPLs are present and a pumping system is installed, ground
water contaminant concentrations drop dramatically and then level
out over a period of weeks or month*. After the initial rapid
decline in concentration, the ground water concentrations tend to
persist for years at the same levels. When the pumping system is
stopped, contaminant levels slowly increase to their pre-pumping
levels. The Pennsylvania Department of Environmental Resources
has indicated that they believe that this type of aquifer
response information is absolutely necessary to support a
technical impracticability waiver for the shallow aquifer (less
than 800 feet). EPA will attempt aquifer remediation of the
ground water at a depth of less than 800 feet, while recognizing
that the attempt nay not be successful. After the Remedial
Action is implemented and several years of data are collected,
EPA in consultation with the PADER may revise the cleanup goals
for the ground water above a depth of 800 feet.
Although monitoring wells have not been placed below 500
feet, the ground water gradient is downward and since the
concentration at 500 feet is about 1700 ppb of total VOCs, it is
reasonable to conclude that ground water at much greater depth is
AR308767
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25
contaminated above MCLs. Since the plume is not defined with
depth, remediation costs are uncertain and cleanup times would be
speculative.
Remediation of ground water below 800 feet would be
extremely expensive and would probably accomplish little
additional risk reduction at very high cost. The larger drill
rigs and special well construction techniques would drastically
increase costs. Locating the contamination as it travels
downward through unpredictable fractures would be difficult and
would require numerous wells. The Gettysburg Municipal Authority
supplied EPA with the depths of the seven municipal wells in the
Gettysburg Area. Five of the seven municipal wells are at a
depth of 500 feet or less, one well is at a depth of 635 feet and
one well at a depth of 900 feet. The Gettysburg MUA has informed
EPA that it is unlikely that future wells would be placed deeper
than 800 feet. Several test wells have encountered water with
very high dissolved minerals at depths near 800 feet, and the 900
feet deep well seems to be an exception. Only if the very deep
ground contaminated ground water re-emerges and discharges at
usable well depths far from the Site would it pose a threat. EPA
plans to address this issue as part of the remedial action
monitoring.well network. If contaminated ground water does
surface and discharge, it could then be captured and treated at
reasonable depth.
Because none of these alternatives can remove suspected
DNAPLs from the bedrock, an EPA review of the Site every five
years would be conducted to ensure continued protection of human
health and the environment.
Common elements of all ground water remedies except the No Action
Alternative: Installation of additional monitoring veils to
define further the contaminant pluses, quarterly ground water
monitoring for two years after remedy implementation and annually
afterwards/ annual selected residential wall sampling and
analysis, and deed restrictions on tte ihsaler property. The
number of extraction veils, pumping rates and locations are
estimated only, and vill be finalised during remedial design.
Alternative l - No Action: Under this alternative, no action
would be taken and is retained for comparison with the other
alternatives as required by the NCP.
Alternative 2 - Ground water Extraction With Treatment by
Chemical oxidation using UV Catalysist An extraction system was
developed for each ground water medium/unit based on the known
extent of the corresponding plume and the goal of trying to
achieve remediation of the plume. In the Feasibility Study, Drum
Burial Areas l and 2 ground water (Medium 1) is extracted from
six wells selectively screened to intercept bedding planes which
subcrop in the vicinity of Drum Burial Areas l and 2. The
AR308768
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26
extraction wells are located southwest of Drum Burial Areas 1 and
2. One shallow well (estimated depth of 50 feet) is designed to
extract ground water downgradient from Drum Burial Area 2. Two
shallow wells (estimated depth of 50 feet) and 3 deep wells
(estimated depth of 300 feet each) are designed to extract ground
water downgradient from Drum Burial Area l. The estimated
pumping rates for ground water at the Drum Burial Areas 1 and 2
contaminant plume are 38 and 2.5 gallons per minute (gpm),
respectively. Lagoon Area ground water (Medium 2) is extracted
from three shallow extraction wells (estimated depth of 50 feet
each), and two deep wells (estimated at 200 and 350 feet deep).
The extraction wells are located west and southwest of the Lagoon
Area. The estimated pumping rates for capture of the Lagoon Area
coi plume is 16 gpm. Both extraction system configurations pump
the extracted ground water to a single treatment plant, the
location of which will be defined during the remedial design.
Treated ground water is discharged to an on-Site stream.
Under Alternative 2, the extracted ground water would be
treated using chemical oxidation with UV catalysis and discharged
under appropriate controls to an on-Site stream. This process
consists of adding hydrogen peroxide to extracted ground water
and then exposing the qround water to ultraviolet light. This
treatment process effectively destroys vinyl chloride and most of
the other COI detected in the ground water, but may not
effectively treat chlorinated ethanes.
Alternative 3 - Ground Water Extraction With Treatment by Aqueous
Phase Carbon Adsorption: The extraction systems for Drum Burial
Areas 1 and 2 ground water and Lagoon Area ground water as
described for Alternative 2 would also be used for this
alternative.
For this alternative, extracted ground water would be
treated using aqueous phase carbon adsorption and discharged
under appropriate controls to an on-Site stream as determined
during the remedial design. The activated carbon would adsorb
contaminants from the ground water, and when spent would be sent
to off-Site treatment/disposal. Because aqueous phase carbon
adsorption does not effectively treat vinyl chloride, the
alternative is potentially applicable for Drum Burial Areas l and
2 ground water, but may not be sufficiently effective for the
Lagoon Area ground water.
Alternative 4 - Ground Water Extraction With Treatment by Air
Stripping (Volatilisation) and catalytic oxidation, of
Contaminants in Effluent Air: The extraction systems for Drum
Burial Areas 1 and 2 ground water and Lagoon Area ground water as
described for Alternative 2 would also be used for this
alternative.
For this alternative, extracted ground water would be
AR308769
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27
treated using air stripping, of VOCs from ground water with the
effluent air from the stripper treated by catalytic oxidation to
destroy VOCs. Catalytic Oxidation involves heating the air and
passing the air over a catalyst which promotes oxidation of the
VOCs to water, carbon dioxide and trace amounts of hydrochloric
acid. Water would be discharged under appropriate controls to
an on-Site stream the location to be determined during the
remedial design. This treatment process effectively treats vinyl
chloride and the other COI detected in the ground water.
Alternative 5 - Ground Water Extraction With Treatment by Air
Stripping (Volatilisation) and Vapor Phase Carbon Adsorption of
Contaminants in Effluent Air: The extraction systems for Drum
Burial Areas 1 and 2 ground water and Lagoon Area ground water as
described for Alternative 2 would also be used for this
alternative.^
For this alternative, extracted ground water would be
treated using air stripping (volatilization) with the effluent
air treated using vapor phase carbon adsorption to capture VOCs
and the water discharged under appropriate controls to an on-Site
stream as determined during the remedial design. When the carbon
is spent, it would be sent for off-Site treatment/disposal.
Because vapor phase carbon adsorption is not reliable for
treatment of vinyl chloride, this alternative is primarily
applicable for Drum Burial Areas 1 and 2 ground water.
Alternative € - Aggressive Aquifer Remediation Using Ground Water
Extraction with Air Stripping and Catalytic Oxidation of
Contaminants in Effluent Air: For this alternative, a ground
water extraction and treatment system with reinjection to more
aggressively remediate the aquifers would be implemented.
Additional monitoring wells would be required to monitor both
ground water levels and water quality in response to the expected
changes in hydraulic gradients. .
This extraction system would generate large volumes of water
containing relatively low concentrations of COI. It would be
necessary to pump and treat far more water than the other
alternatives. The extraction system for the aggressive aquifer
remediation includes the two extraction systems described in
Alternative 2, plus additional extraction wells ranging in depth
from 40 feet to 700 feet. The additional wells include one
shallow and two deep wells downgradient from Drum Burial Area 2,
two shallow wells and 11 deep wells downgradient from Drum Burial
Area 1, and one shallow well and 16 deep wells downgradient from
the Lagoon Area. In addition, a minimum of one rein ject ion well
would be installed on each side of the Drum Burial Area 2 plume,
and a minimum of one rein ject ion well would be installed on each
side of the Lagoon Area plume. The additional extraction wells
would be selectively screened to intercept bedding planes which
subcrop in the former source areas. The additional wells are
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located west and south of Drum Burial Areas l and the Lagoon
Area. The estimated pumping rate assumed for aggressive aquifer
remediation is estimated at 163 gpm. The extracted ground water
is pumped to a treatment area to be determined during- the
remedial design. Most of the treated ground water would be
discharged to an cm-Site stream. The remaining treated ground
water would be reinjected into the subsurface in an attempt to
flush the COI through the aquifers. A minimum total of four
reinjection wells, with an estimated injection rate of two gpm
per well, would be placed to accelerate the remedial ground water
action.
The extracted ground water would be treated using air
stripping (volatilization) and catalytic oxidation of the
contaminants in the effluent air stream from the stripper. The
water would be discharged under appropriate controls to an on-
Site stream. Volatilization and catalytic oxidation was selected
as the treatment process for this alternative based on the
effectiveness of this treatment process for all Site contaminants
and based on relative costs of the other treatment options.
SITE WIPE GROUND WATER ALTERNATIVES
A very large number of combinations and permutations of the
above ground water alternatives is possible. Medium l - (Drum
Burial Areas 1 and 2 ground water) and Medium 2 - (Lagoon Area
ground water) do not contain identical contaminants. Medium 2
ground water contains vinyl chloride. The best-suited treatment
alternative for each of these respective media is not necessarily
the same. Therefore, only eight Site-wide ground water remedial
alternatives were developed for final consideration, some of
which combine the previously identified alternatives for the two
different media.
The eight Site-vide remedial alternatives are as follows:
• Remedial Alternative A - No Action.
• Remedial Alternative B - Ground Water Extraction -
Chemical Oxidation of Contaminants Using UV Catalysis
Treatment Of Ground Water For Medium 2 (Lagoon Area
Ground Water); Aqueous Phase Carbon Adsorption of
Contaminants in Medium 1 (Drum Burial Areas l and 2
Ground Water).
• Remedial Alternative C - Ground Water Extraction -
Chemical oxidation Of Contaminants Using UV Catalysis
Treatment For Medium 2; Air Stripping of Contaminants
With Carbon Adsorption Of Contaminants From Effluent
Air For Medium 1.
• Remedial Alternative D - Ground Water Extraction -
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Chemical Oxidation Of Contaminants Using UV Catalysis
Treatment Of All Site Ground Water.
Remedial Alternative E - Ground Water Extraction -
Air Stripping of Contaminants and Catalytic Oxidation
Of Contaminants In Effluent Air For Medium 2; Aqueous
Phase Carbon Adsorption of Contaminants for Medium 1.
Remedial Alternative F - Ground Water Extraction - Air
Stripping of Contaminants and Catalytic Oxidation Of
Contaminants In Effluent Air For Medium 2; Air
Stripping Of Contaminants And Carbon Adsorption Of
Contaminants in Effluent Air For Medium 1.
Remedial Alternative G - Ground Water Extraction - Air
Stripping Of Contaminants And Catalytic Oxidation Of
Contaminants In Effluent Air For All Site Ground Water.
Remedial Alternative H - Aggressive Aquifer Remediation
- Ground Water Extraction - Air Stripping With
Catalytic Oxidation Of Contaminants In Effluent Air
COST OF SITE WIDE GROUND WATER ALTERNATIVES
Alternatives
A
B
C
'-. D
E
F
G
H
Time to
Implement,
Months
0
36
36
36
36
36
36
36
capital
Cost, 9M
0
2.0
1.9
2.0
1.9
l.t
1.7
3.5
Annual
out
$ Thousands
37
140
126
96
103
89
35
65
Total
PW Cost
$M
O.6
5.1
4.7
4.4
4.5
4.1
3.3
5.6
coMTMtlMATED BOIL ALTERMATIVE8; Past actions have removed
concentrated wastes from all areas of the Site except the
Stressed Vegetation Area. The following alternatives have been
developed for the remaining contaminated soil areas, except Drum
Burial Area 1 and Drum Burial Area 2. A matrix of the
alternatives evaluated for each area, the associated volume or
area or area addressed, and the Present worth Cost of each
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30
alternative is shown in Table «, Appendix c.
Alternative 1 - Ho Action: Under this alternative, no action
would be taken. This alternative is retained for comparison with
the other alternatives as required by the NCP.
Alternative 2A - Soil Cover: Option 2A is a soil cover with
drainage control consisting of area preparation, erosion
controls, surface drainage controls, placement of a geotextile
soil separator and one foot of clean soil, seeding, and
maintenance. Option 2A is primarily considered for the soil
media units which do not pose a significant potential cross-media
risk to ground water. These media units include Medium 3 -
Stressed Vegetation Area, Medium 4 - Borrow Area, Medium 6 -
South Cornfield, and Medium 7 - North Cornfield because the
contaminants in these media are relatively insoluble metals and
the potential for cross-media effects to ground water is minimal.
A soil cover limit contact with these media units by human and
ecological receptors and would mitigate potential transport of
contaminated soils to streams and sediments.
Alternative 2B - Low Permeability Cap* Option 2B is a low
permeability cap system consisting of Site preparation, erosion
controls; six inches or clean soil placed under a very low
density polyethylene geomembrane which complies with RCRA closure
regulations, a geonet, a geotextile, 24 inches of clean soil
cover, a cap drainage system, seeding, and maintenance. Option
2B is primarily considered for the soil media units which may
pose a potential risk to ground water. These media units include
Medium 5 - Lagoon Area and Medium 8 - Drum Burial Area l because
the COI for these media are relatively soluble organics and based
on the assessment of cross-media effects the potential for cross-
media effects to ground water exist. A low permeability cap
would mitigate potential cross-media effects to ground water, in
addition to meeting the remedial objectives of limiting contact
with the media by human and ecological receptors and transport of
contaminated soil to streams and lediasnts.
Alternative 3 - Excavate and Treat/Dispose Off-Site: This
alternative includes area preparation; erosion controls; surface
drainage controls; excavation, loading, and hauling of affected
soil; post-excavation sampling and analysis; treatment and
disposal at a permitted off-Site facility; backfill material and
placement of a geotextile soil separator and topsoil; seeding;
and maintenance. Treatment of the soil at a permitted off-Site
facility is anticipated to consist of thermal treatment
technologies (i.e., incineration) for the Lagoon Area or
stabilization and landfilling technologies for the other soil
areas. This alternative would limit contact with the soil media
units by human and ecological receptors and mitigate potential
cross-media effects to ground water, surface water, and
sediments.
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It is noted that alternatives involving excavation are not
considered for Medium 8 - Drum Burial Area i. Previous remedial
activities excavated wastes/affected soil and then backfilled the
excavation with clean soil thus limiting exposure control. Also,
the remedial action objectives for Medium 8 are to continue
exposure control and to mitigate potential cross-media effects to
the ground water. Additional excavation activities appear
redundant and potentially increase short-term risks.
Alternative 4 - Excavate, Stabilise on-Site, and Dispose Off-
Site: Under Alternative 4, the affected soil is excavated,
treated (i.e., stabilized) on-Site, and then disposed of off-Site
at a permitted facility. It is assumed that stabilization takes
place with the boundaries of the disposal unit (Corrective Action
Management Unit). This alternative includes Site preparation,
erosion controls, surface drainage controls, excavation of
affected soil, post-excavation sampling and analysis,
stabilization on-Site, TCLP verification, loading and hauling of
the treated soil, disposal at a permitted off-Site facility,
backfill material and placement of a geotextile soil separator
and topsoil, seeding, and maintenance. Alternative 4 is
considered for all soil area except Drum Burial Area 1. This
alternative would limit contact with the affected; soil media
units .by human and ecological receptors and mitigate potential
effects to ground water, surface water, and sediments.
Alternative 5 - Excavate, Soil Washing, and Dispose On-Site:
Under Alternative 5, the affected soil is excavated, treated on-
Site using a soil washing process, and then disposed of on-Site.
It is assumed that treatment takes place within the boundaries of
the disposal unit. In addition, this alternative includes Site
preparation, erosion controls, surface drainage controls,
treatability studies, excavation of affected soil, post-
excavation sampling and analysis, soil washing on-Site including
treatment of process water, analytical testing, backfilling of
treated soil, placement of a geotextile soil separator and
topsoil, seeding, and maintenance. Alternative 5 is considered
for all soil areas except Drum Burial Area 1. This alternative
would limit contact with the soil media units by human and
ecological receptors and mitigate against potential cross-media
effects to ground water, surface water, and sediments.
Alternative 6 - In Situ Stabilizations Under Alternative 6, the
affected soil is stabilized in place. In addition, this
alternative includes area preparation, erosion controls, surface
drainage controls, treatability studies, in-situ stabilization,
TCLP verification, placement of a geotextile soil separator and
topsoil, seeding, and maintenance. In situ stabilization
involves mechanical mixing and injection of the additives
(reagents) to produce the stabilized mass. A typical system
consist of one set of cutting blades and two sets of mixing
blades attached to a vertical drive auger. Conduits in the auger
AR308771*
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32
are used to inject the additives. This alternative is considered
for all soil areas except Drum Burial Area 1. This alternative
would limit contact with the soil media units by human and
ecological receptors and mitigate potential cross-media effects
to ground water, surface water, and sediments.
Although the North cornfield, the south Cornfield and the Borrow
Areas contain different levels and types of contamination, the
problems are similar (non-leaching inorganics) and the
remediation goals are therefore similar enough to combine for
cost analysis and remedy selection.
COSTS OF SOIL ALTERNATIVES MATRICES an
TIMES
Implementation times assume that the remedy for each area is
designed and constructed separately and that there are no
interactions with the other areas. If more than one soil
alternative is selected for an area, the combination would
lengthen the overall design and construction time. The overall
length of the Remedial Design and Remedial Action also involves
some interaction with ground water actions that may be taken at
the Site. A rough estimate of the total design time for most of
the combinations that may be selected is about eighteen months.
The Remedial Action construction time is more variable and will
depend on the technologies selected.
Stressed Vec
etation Area
Alternatives
1 No Action
2A Soil Cover
2B &CBA Cap
3 Excavate
Treat/Dispose
Off-Bit*
4 Excavate
8tabili«e/0n-8ite
Dispose Off -Site
5 Excavate, Soil
Washing, Dispose
Off-site
6 In Situ
Stabilisation
Capital
Cost,
$millions
0.0
0.02
0.03
0.28
0.25
0.17
0.11
Annual
out
(Thousand
0.0
0.47
l.C
0.5
0.5
0.5
0.5
Total FW
costs,
(millions
0.0
0.02
p.oc
0.32
0.26
0.17
0.12
Time to
Imple-
ment,
Months
17
24
17
24
24
25
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775
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33
Combined Cornfields and 'Bo^r-nu &T-
Alternatives
IMA &et 4 an
2A Soil cover
2B RCRA Cap
3 Excavate
Treat/Dispose
Off-Site
4 Excavate
Stabilise/On-Site
Dispose Off-Bit*
5 Excavate, Soil
Washing, Dispose
Off-Site
6 IB Situ
Stabilisation
Alternatives
1 Ho Action
2A Soil cover
2B RCRA Cap
3 Excavate
Treat/Dispose
Off-site (l)
4 Excavate
StabiliM/On-Sito
Dispose Off-Site
5 Excavate, Soil
Washing, Dispose
Off-site
6 in situ
Stabilisation
Capital
Cost,
$ail lions
Of)
1.4
2.8
12.40
11.23
7.32
4.93
Lacroo
Capital
cost,
Saillions
0.0
0.05
0.10
3.1«
0.76
0.50
0.33
O&M
$ Thousand
OA
39.5
131.9
39.6
39.6
39.6
39.6
n Area
Annual
out
SThousand
0.0
1.5
5.0
1.5
1.5
1.5
1.5
Total PW
Costs,
$aillions
• II
1.99
4.86
14.29
11.57
7.66
5.27
Total PW
Costs,
$millions
0.0
0.08
0.18
3.19
0.78
0.52
0.36
Tine to
imple-
ment,
Months
20
24
18
24
30
30
Tiae to
Imple-
•ent,
Months
......
17
24
18
24
28
28
(l) Treatment is off-Site incineration to aestroy xas
solvent constituents.
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Drum Burial Area l Alternatives - Previous actions removed drums
and contaminated soils from this area. Sections of this area that
contain residual contamination are below the water table at least
during high seasonal water tables. The bedrock below the
remaining contaminated soil is also a source of contaminants, and
ground water contamination levels are actually higher at greater
depths. The pits from the removal were already backfilled with
clean soil and therefore, a soil cover would not be beneficial.
The only alternatives considered were Alternative 1 No Action and
a Alternative 2 - RCRA cap to protect against leaching to ground
water. •
COST OF DRUM BURIAL AREA 1 ALTERNATIVES
Alterns-tive l No Action * Capital Costs, O&M, and
Present Worth = $0
Alternative 2 RCRA cap - Capital Cost = $ 0.3 million,
O&M = $ 14,000, Present Worth Cost - $ 0.53 Million
Drum Burial Area 2 Alternatives - Contamination was not found in
the subsurface soils that posed a threat and the pits were
backfilled with clean soil. No alternatives were evaluated.
SURFACE WATER COHTAMIHATIOH: Streams at the Hunterstown Road
Site are intermittent in nature. The base flows of the streams
are contributed from seasonal ground water recharge. A few
surface water samples from the East Stream have indicated that
contaminants from the Lagoon Area may be entering the stream from
ground water recharge or by surface runoff. After remedial
actions have been implemented for ground water and affected soil
areas, the potential for cross-media impacts to the stream would
be greatly reduced. Remediation of surface water is not
considered warranted at this time. Surface water monitoring
would be conducted after completion of the Remedial Action
construction to verify that no specific surface water action is
necessary. No Alternatives were evaluated.
COMTAMIHATEP SBpTympPB t Concentrations of mercury and lead
detected in East Stream sediment exceed health-based (chronic)
levels for surface soil. Potentially phytotoxic levels of
chromium and copper were also detected in a segment of the East
Stream. The stream segment with these above-background
concentrations extends approximately 400 feet downstream of the
Lagoon Area.
Bis (2-ethylhexyl) phthalate was detected at a concentration gt^^QQ 7 ~]
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35
may pose a risk to soil or benthic invertebrates in one sediment
sample from the Middle Stream. The phthalates appear to be due
to erosion control netting placed during the removal actions.
Zinc was detected in two sediment samples from the Middle Stream
at concentrations above the Site-specific cleanup level of 120
ppm recommended by EPA's Biological Technical Assistance Group
(BTAG) . Potential risks posed by Middle Stream sediments appear
to be limited to sections of the stream extending approximately
500 feet downstream of the lagoon to the Shealer Road crossing.
The following alternatives for sediment were developed:
Alternative 1 - Ho Action: Alternative 1 is a no action
alternative retained as a baseline for comparison with other
alternatives .
Alternative 2 - Excavate and Treat/Dispose off -site: Under
Alternative 2, the affected sediments are excavated (dredged) and
then treated/disposed of off -Site at a permitted facility. In
this alternative, the affected sediment would be dredged using
common equipment then loaded and hauled off-Site for treatment
and disposal at a permitted facility. For this media, off-Site
treatment by stabilization was assumed. Dredging technologies
can handle the volume of affected sediments and the shallow depth
of the affected sediments allows for the use of common equipment.
COST OF SEDIMEMT ALTERNATIVES
Alternative 1 No Action - Capital Costs, O&M, and
Present Worth - $0
Alternative 2 Excavate/Treat/Diapose Off-Site -
Capital Cost = $ 108,000, O&M • $0, Present Worth Cost =
$108,000.
VIII. Comparative Analysis of RCTe
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36
Modifying Criteria
• State acceptance
• Community Acceptance
COMPARATIVE ANALYSIS - GROUND WATER
EPA only carried the Site Wide Alternatives through complete
evaluation and the following comparative analysis applies to
the Site Wide Alternatives.
PROTECTION OF HUMAN HEALTH AMD THE ENVIRONMENT
Residents with wells in the known extent of the contaminated
ground water plume are using the existing public water line.
Potentially at risk residential wells not served by the
water line have been tested with no significant detections
of Site contaminants. All of the ground water alternatives
evaluated are protective of human health and the environment
except the Alternative A - No Action. All alternatives
except Alternative A would prevent further migration of
contaminated ground water at reasonable depths, would
identify potential discharge areas and would monitor for
Site contaminants. Under Alternatives B. through G,
contaminated ground water would be collected and treated
until safe levels of ground water contamination are reached.
Under Alternative H, an attempt would be made to more
aggressively restore the aquifer. Although safe levels of
contaminants might be reached sooner, the reinjection wells
needed to accelerate the remediation could pose a risk of
spreading contamination through fractures. This
counterbalances the advantage of faster remediation.
COMPLIANCE WITH ARAB*
None of the alternatives would totally comply with the PADER
ARAR to remediate all ground water to background. The
Pennsylvania ARAR for ground water for hazardous substances
is that all ground water be remediated to "background
quality" as specified by 25 PA CODE SS 264.97(1), (j), and
264.100(a)(9). None of the alternatives would totally
coaply with the Federal Safe Drinking Water Act which
requires remediation of all ground water in class IIA to
MCLs and MCLGs. Both the federal and state Safe Drinking
Water Acts set minimum standards for drinking water supplied
by municipal wells called Maximum Contaminant Levels (MCLs),
which are enforceable federal standards. Maximum
Contaminant Level Goals (MCLGs) are usually lower levels
than MCLs that EPA attempts to achieve if possible, and if
they are above zero. The ground water at the Site is
considered a Class IIA aquifer and non-zero MCLGs and MCLs
are exceeded at the Site. .EPA plans to waive these ARARs,
for ground water below 800 feet, on the basis of
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37
impracticability due to DNAPLs in bedrock and contamination
at extreme depths. Alternatives B through H would comply
with these ARARs for the ground water above a depth of 800
feet. The no action alternatives would not comply with the
state standards as set forth in 25 PA Code S 109.202, or the
federal standards as set forth in 40 C.F.R. Part 141.61 and
141.62.
All of the ground water alternatives except Alternative A
(no action) would have air emissions from the ground water
treatment unit and would comply with the requirements set
forth in 25 PA Code S 127.l2(a)(5), which requires that
emissions be reduced to a minimum through Best Available
Technology as defined in 25 PA Code S 121.1. The
alternatives would also comply with RCRA requirements of
Subpart AA (Air Emission Standards for Process Vents) of the
federal RCRA regulations, 40 C.F.R. S 264.1032, which are
relevant and appropriate for the air stripping operations
under the selected remedy. Under this ARAR, total organic
hydrocarbon emissions from the treatment unit must be less
than 1.4 kg/hr (3 Ib/hr) and 2800 kg/yr (3.1 tons/yr) or
reduce emissions by 95 weight percent. The remedial actions
must comply with Section 112 of the Clean Air Act (40 C.F.R.
S 61.63) which sets allowable emissions standards (NESHAP)
for vinyl chloride. These alternatives would also comply
with the TBC OSWER Directive 9355.0-28 which requires
control of hydrocarbon emissions in excess of 15 pounds per
day in ozone non-attainment areas.
All of the alternatives except the no action alternatives
would discharge treated ground water to an on-Site stream
and would comply with the substantive requirements of the
NPDES Regulations (25 PA Code S 92.31). Alternatives that
use UV catalysis (Alternatives B, C and D) might have
difficulty complying with the NPDES permit because some
compounds are resistent to UV oxidation.
On-Site ground water is above the TCLP level (500 ppb TCE)
(25 PA Code S 261.24) and must be managed as a hazardous
waste.
All-of the alternatives except Alternatives A, D, 6, and H
would produce some treatment residuals that must be managed
as a RCRA hazardous waste. Any residuals from treatment
must be managed in compliance with regulations promulgated
pursuant to the PA Solid Waste Act, which follow: 25 PA
Code S 262.11 (relating to hazardous waste determination),
and with respect to operations at the Site generally, with
the substantive requirements of 25 PA Code Part 264 Subpart
I, specifically SS 264.171 - 264.179 (in the event that
hazardous waste generated as part of the remedy is managed
in containers), and Subpart J specifically the substantive
HR308780
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38
requirements of 264.190, 264.192-264.199 (in the event that
hazardous waste is managed, treated or stored in tanks).
The alternative implemented will also comply with the RCRA
Land Disposal Restrictions set forth at 40 C.F.R. SS 268.1 -
268.5 related to the management of hazardous wastes
(including spent carbon from air stripping) generated as
part of the remedy.
LONG TERM EFFECTIVENESS AND PERMANENCE
Alternative H - Aggressive Aquifer Remediation would have
the highest rating in this category if successful
accelerating the cleanup. The long term effectiveness of
Alternatives B through G is satisfactory. These
Alternatives would capture and treat the plume at reasonable
depth until permanently safe levels are achieved. For these
alternatives the plumes are captured, VOCs are removed and
destroyed in a treatment processes, and a deed restriction
on well use placed on the Fred Shealer property. No Action
would obviously be rated low.
REDUCTION OF TOXICITY, MOBILITY OR VOLUME BT TREATMENT
All of the alternatives considered except the no action
alternative would ultimately reduce the toxicity by
destroying VOCs tnrough oxidation. Chemical Oxidation and
catalytic oxidation do this directly. Carbon adsorption
residuals would be sent off-Site for regeneration or
destruction, with the VOCs ultimately incinerated.
SHORT TERM EFFECTIVENESS
Alternatives B through 6 (pluM containment) can be
implemented more quickly than the Alternative H - Aggressive
aquifer remediation, which would require a more complicated
and extensive design. Obtaining access for placement of
more numerous wells under Alternative B could delay
construction.
IMPLEMENTABILITY
The implementability criterion relates to the technical and
administrative feasibility of an alternative. Alternative H
- Aggressive Aquifer Remediation is rated lower because of
the increased technical difficulty inherent in accelerated
restoration of a fractured bedrock aquifer contaminated with
DNAPLs. Technically, the reinjection aspect would be
difficult to implement because of the low and variable
permeabilities. Alternatives B through 6 are less difficult
to implement because of their simpler design and goals. The
treatment technologies are all proven and are generally
effective for the Site contaminants.
COST
The costs of the alternatives shown above are based on
capital costs and operation and maintenance expenses for 30
AR30878
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39
years. The time that it would take to remediate the aquifer
is a matter of conjecture because of the complex geology and
because large amounts of solvents which were disposed. The
costs of all of the alternatives are moderate at the Site
because of the low permeability of the aquifer. A limited
amount of water can be withdrawn from the formation which
produces lower than usual pumping and treatment costs.
Alternative G is the most cost effective alternative at a
present worth of 3.3 million dollars and the highest cost
alternative is Alternative H - Aggressive Aquifer
Remediation at 5.6 million dollars.
STATE ACCEPTANCE:
The Commonwealth of Pennsylvania's comments on the Proposed
Plan and draft Record of Decision stated that the
Commonwealth basically agrees with the selected remedy, but
disagrees on some of EPA's interpretations of the
Commonwealth's ARARs. EPA has not yet received a formal
position from the Commonwealth on concurrence with the
Preferred Alternatives set forth in the Proposed Remedial
Action Plan.
COMMUNITY ACCEPTANCE:
The selected remedial action was generally acceptable to the
community. See the attached Responsiveness Summary for
details.
COMPARATIVE ANALYSIS - SOILS
uvBKMiL PRUTECT1VEJIES8 OF HUMAN EXALTE AND TEE ENVIRONMENT
Laaoon Ar«« Soils
Alternative - 3 - Excavate and Treat/Dispose off-Site is the
most protective of human health and the environment because
contaminated soils are removed from the Site, are treated to
reduce their toxicity through proven technology and are
disposed off-Site. Alternative 4 - Excavate Stabilize On-
Site and Dispose Off-Site would also be protective if the
waste meets the disposal criteria of the accepting facility.
Since stabilization is questionable for VOCs, the waste may
not meet the facility's criteria. Alternative 6 In-Situ
Stabilization and Alternative 5 - Soil Washing would leave
treated soil on-site after treatment. Small, but probably
acceptable levels of contaminants would remain in the area.
Only Alternative 3 would destroy the vinyl chloride and
other VOCs in Lagoon Area soils.
Alternative 2A - Soil Cover and Alternative 2B are not as
AR308782
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protective, since ground water is very near the surface and
if the area were capped, ground water moving laterally
through the area could still transport contaminants to
ground water and to the East Stream. High levels of ground
water could also damage a low permeability cap. Alternative
1 - No Action is not protective since high levels of vinyl
chloride, other VOCs, mercury and lead have been found in
this area during the remedial investigation.
Stressed Vegetation Soils
Waste and soils in the Stressed Vegetation Area were tested
using the Toxicity Characteristic Leaching Procedure. The
test gave lead levels which exceeded the TCLP regulatory
limit. Therefore, waste and soils in this area is
considered a RCRA characteristic waste for lead. The area
contains up to 54,000 ppm of lead which is two orders of
magnitude above EPA's action level of 500 ppm. EPA
considers this to be a principal threat and favors treatment
to reduce the toxicity, mobility or volume at these levels.
Alternatives 3 - Off-Site stabilization/Disposal, 4.-
Excavate/Stabilize On-Site and Dispose Off-Site, and 6 •- In-
Situ Stabilization are rated highest with regard to overall
protection of human health and the environment. Due to the
potential for direct contact and the generation of airborne
dust, excavation activities in Alternatives 3 through 5
present potential short-term risks to remediation workers,
nearby residents, and ecological receptors. The soil cover
(Alternative 2A) or low permeability cap (Alternative 2B)
would not require excavation of the affected soil and
exposure to COI by human or environmental receptors would be
minimal. However, remedial actions which remove the
affected soil from the Site are viewed as more protective
over the long term than those which limit contact or
decrease the mobility of the COI at the Site.
Alternative 5 would also involve excavation, but the soil
would be put back in place after treatment and would produce
large quantities of contaminated water which would need
treatment prior to discharge to one of the streams. Thus,
the possibility of residual COI in the treated soil exists
and transportation or on-Site treatment of contaminated
water would be needed.
Cornfield* MM! Borrow Area
Lead and mercury are elevated in the Cornfields and lead is
present in the Borrow Area, but these metals have not been
detected in ground water. To EPA's knowledge, the metals
contamination is not derived from listed wastes and given
the overall concentrations in the soils, EPA would not
AR308783
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41
expect these soils to fail the TCLP for either lead or
mercury.
Alternatives 3 through 6 are rated highest in overall
protection because the contaminants are treated or removed
from the Site. This is offset somewhat by the potential for
direct contact and the generation of airborne dust,
excavation activities are a potential short-term risk to
remediation workers, nearby residents, and ecological
receptors. Although in situ stabilization would disrupt the
subsoil and would generate some dust, the potential short-
term risks would be less than those for alternatives
involving excavation (Alternatives 3 through 5). However,
alternatives which remove the contaminants from the soil are
viewed as being more protective over the long term than
those which decrease the mobility of the contaminants at the
Site. 'Alternatives 3 and 4 would rank similarly with regard
to overall protection. Alternative 5 would also involve
excavation, but the soil once treated would be put back in
place after treatment. Thus, the possibility of residual
contaminants in the treated soil exists.
Alternatives 2A - Soil Cover and 2B - RCRA cap although less
permanent and reliable .than treatment or disposal , these
remedial actions are sufficiently protective considering
soil concentrations and the fact that metals have not
contaminated ground water.
Bra Area 1
Drums and contaminated soils have already been removed and
the resulting pits backfilled with clean soil. Although
some volatiles were detected, the residual contamination is
in soils generally below the water table. This residual
contamination poses no direct contact threat and the
remaining contamination would not significantly affect the
time needed to remediate ground water due to the presence of
DNAPLs. The only alternative considered for this area is
Alternative l - No Action and 28 - RCRA Cap. Both
alternatives are fully protective, because the remaining
contamination would be addressed by the ground water
remedial action. However, the BCKA cap would probably not
be effective because of the high ground water table.
Contaminants that are leached from the soil will be
collected and treated by the ground water remedial action.
Therefore, if the cap were effective, it would only delay
cleanup of the soils and would not reduce risk.
Drum Burial Area 2
Contaminants in soils were not detected during the Phase II
Remedial Investigation. No action is necessary. RR*5nfl7ftU
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42
COMPLIANCE WITH ARAKS
Laooon Area Soils
Soils in the lagoon Area are contaminated with spent solvent
constituents as well as metals. These spent solvents are
derived from listed solvent wastes containing TCE and TCA.
Although these solvents were disposed before the effective
date of the RCRA, it is still relevant and appropriate to
treat solvent contaminated soils as listed wastes.
Therefore, any soils excavated would be subject to the RCRA
Land Disposal Regulations (LDR) 40 C.F.R. §5 268.1-268.5 if
the soil contains the contaminants TCE/TCA. These excavated
soils must be managed in compliance with promulgated
regulations pursuant to the PA Solid Haste Act, which
follow: 25 PA Code SS 262.11 (relating to hazardous waste
determination), and with respect to operations at the Site
generally, with the substantive requirements of 25 PA Code
Part 264, Subpart I, specifically SS 264.171 - 264.179 (in
the event that hazardous waste generated as part of the
remedy is managed in containers), and Subpart J,
specifically the.substantive requirements of SS 264.190,
264.192-264.199 (in the event that hazardous waste, is
managed, treated or stored in tanks).
Until very recently, excavation, treatment and placement of
soils back into the area of contamination was prohibited. A
recently enacted rule has been finalized which allows
treated soil to be placed back into a Corrective Action
Management Unit (CAMU). Alternative 4 - Excavate, Stabilize
On-Site and Dispose Off-Site might not comply with the LDR
which requires destruction of solvent wastes above treatment
standards including contaminated soils. All other
alternatives could comply with the LDR regulations since
placement would not occur.
RCRA closure regulations, specifically 25 PA Code SS
264.111(1),(2) are relevant and appropriate for this area.
All of the proposed alternatives except the No Action
Alternative could meet these requirements since a cover
would prevent direct contact, the ground water action would
collect and treat any contaminants leaching into ground
water and a well network would monitor the ground water
concentrations.
The PADER residual waste regulations, specifically the
substantive requirements of 25 PA Code S 287.101(d), are
relevant and appropriate for soils left in place.
Alternatives that involve off-Site disposal would be treated
as hazardous wastes and the management of which is more
stringent and would exceed these requirements for residual
AR308785
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waste.
All of the alternatives except the No Action Alternative
will destroy some of the already damaged wetlands and the
permanently destroyed wetlands would have to be replaced in
compliance with 25 PA Code S 105.451.
Stressed Vegetation Area
Since the wastes in the stressed vegetation are classified
as a RCRA characteristic hazardous waste, the RCRA
regulations regarding treatment, storage and disposal of
hazardous waste are applicable. These excavated soils must
be managed in compliance with promulgated regulations
pursuant to the PA Solid Waste Act, which follow: 25 PA
Code S 262.11 (relating to hazardous waste determination),
and with respect to operations at the Site generally, with
the substantive requirements of 25 PA Code Part 264, Subpart
I, specifically SS 264.171 - 264.179 (in the event that
hazardous waste generated as part of the remedy is managed
in containers), and Subpart J, specifically the substantive
requirements of SS 264.190, 264.192-264.199 (in the event
that hazardous waste is managed, treated or stored in
tanks). The alternative implemented will also comply with
the RCRA Land Disposal Restrictions set forth at 40 C.F.R.
SS 268.1 to 268.5 related to the management of hazardous
wastes. •
RCRA closure regulations, specifically 25 PA Code SS
264.111(1), (2) are relevant and appropriate for this area.
All of the alternatives except Alternative 1 - No Action and
Alternative 2 - Soil Cover would comply with the relevant
and appropriate RCRA regulations.
The PADER residual waste regulations, specifically the
substantive requirements of 25 PA Code S 287.101(d), are
relevant and appropriate for soils left in place.
Alternatives that involve off-Site disposal would be treated
as hazardous wastes and which are more stringent and would
exceed these requirements for residual waste.
All of the alternatives except the No Action Alternative
will destroy some of the already damaged wetlands and the
permanently destroyed wetlands would have to be replaced in
compliance with 25 PA Code S 105.451.
Cornfields and Borrow Area
Since the soils are not considered to be RCRA wastes, RCRA
closure regulations are not applicable and may be relevant,
but are not appropriate since leaching to ground water has
not been detected (No elevated metals in ground vate£)R 308786
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The PADER residual waste regulations, specifically the
substantive requirements of 25 PA Code § 287.101(d), are
relevant and appropriate for soils left in place.
Alternatives that involve off-Site disposal would be treated
as hazardous wastes and which are more stringent and would
exceed these requirements for residual waste.
Drum Burial Area 1
If a RCRA cap is the selected alternative, RCRA closure
regulations are Relevant and Appropriate since spent solvent
(a listed waste) was disposed in this area before the
effective date of RCRA. If a RCRA cap is selected, RCRA
closure regulations, specifically 25 PA Code SS
264.111(1), (2) are relevant and appropriate for this area.
If No Action is selected, hybrid closure could be used
including ground water monitoring and the pump and treat
system.
All of the alternatives except the No Action Alternative
will destroy some of the already damaged wetlands and the
permanently destroyed wetlands would have to be replaced in
compliance with25 PA Code S 105.451.
LONG TERM EFFECTIVENESS AND PERMANENCE
(All soil Areas)
With regard to long-term effectiveness and permanence at the
Site, technologies which involve off-Site disposal are
considered to be somewhat better than to those which wash,
immobilize, or cover the affected soil. Therefore,
Alternatives 3 and 4 are rated better with respect to this
criterion than are Alternative* 2A, 2B, 5 and 6. Because
Alternative 5 involves excavation and treatment, and
Alternative 6 involves stabilisation, they are considered to
be more permanent and rate higher with respect to long-term
protection than the cover systems. The No Action
Alternative is considered to be the least effective at the
Site in the long term.
REDUCTION 07 TOXICITY MOBILITY AMD VOLUME
(All Soil ATMS)
Each of the remedial alternatives, with the exceptions of
Alternatives 1, 2A, and 2B, include treatment and would
yield a decrease in the mobility of the cbl, the toxicity of
the affected soil, or the volume of the affected soil.
Alternatives 3, 4, and 5 are rated highest with regard to
this criterion because they involve treatment processes.
Alternative 6 is not rated as highly as Alternatives 3
through 5 because affected soil may be treated more
effectively ex situ than in situ. Alternative 5 - Soil ^nQ-jo
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45
Washing would increase the volume of waste by creating large
volumes of contaminated water which would have to be
treated.
Alternatives 2A - Soil Cover, 2B - RCRA Cap, and the No
Action Alternative would not achieve a reduction of toxicity
mobility or volume through treatment.
SHORT TERM EFFECTIVENESS
(All Soil Areas)
Alternative 2A - Soil Coyer,and Alternative 2B - RCRA Cap
would offer the greatest short-term effectiveness for the
lagoon soils because it could be implemented quickly.
Alternative 6, in situ stabilization, would rank next in
terms of this criterion. In situ stabilization would result
in less potential for direct contact and would generate less
dust than the alternatives involving excavation. Therefore,
Alternatives 3 through 5 are rated below Alternative 6. Of
the three alternatives which prescribe excavation of the
affected soil, Alternative 3 would be rated highest because
it is the most implemehtable. Alternatives 4 and 5 would be
rated lowest of the three with regard to short-term
effectiveness because they would be the most time-consuming
and most difficult to implement. Alternative 1, the No
Action Alternative, is the least effective in the short
term.
IMPLEMBNTABILITY
(All Soil Areas)
The most implementable alternative, aside from the No Action
Alternative, is Alternative 2A - Soil Cover. The
alternative which would be next with regard to ease of
implementation would be the low permeability cover
(Alternative 2B), followed by in situ stabilization
(Alternative 6). The three alternatives involving
excavation of the affected soil could not be as quickly or
easily implemented as the other alternatives. The
alternatives involving on-Site treatment would require
treatability studies. Of these, Alternative 3 would be the
most implementable, and Alternative 5 would be the least.
COST
The costs of the alternatives shown above are based on
capital costs and operation and maintenance for 30 years.
Costs for the soil alternatives are given in the Description
of Alternatives section above.
AR308788
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Lacroon Area
The cost of cover systems is much lower than the treatment
alternatives. The high cost of Alternative 3 is related to
the RCRA Land Disposal Regulations which require
incineration (or equivalent) of soils. The high cost of
Alternative 3 is justified because the area contains both
metals and solvents including vinyl chloride.
Stressed Vegetation Area
Costs of all of the alternatives are relatively low because
of the small area involved.
Cornfields and Borrow Area
\
The cost for treatment alternatives is very high because of
the large volume soil in this area with comparatively low
levels of contamination. Cover system costs are much less
but still are expensive because of the large area.
STATE ACCEPTANCE (All Areas):
The Commonwealth of Pennsylvania's comments on the Proposed
Plan and draft Record of Decision stated that the
Commonwealth basically agrees with the selected remedy, but
disagrees on some of EPA's interpretations of the
Commonwealth's ARARs. EPA has not yet received a formal
position from the Commonwealth on concurrence with the
Preferred Alternatives set forth in the Proposed Remedial
Action Plan.
COMMUNITY ACCEPTANCE (All Areas) I
The residents strongly supported Alternative 3 - excavation
and off-Site treatment/disposal of contaminated soils.
Alternatives 4 and 5 are rated lower, because treatment
occurs on-Site with some short term exposure risks.
Containment alternatives 2A, 2B and the No Action
alternatives were rated lowest.
COMPARATIVE ANALYSIS - flTflEAJf 8EPIMBNT8
For the purposes of the feasibility study, it was assumed
that remediation of the affected sediment would be in conjunction
with remediation of the affected soil (Media 3 through 7). In
Section 4.0 of the FS, two remedial alternatives were developed.
These include Alternative 1, the No Action Alternative, and
Alternative 2, excavation of the affected sediments and then
treatment and disposal of the sediment off-Site.
AR308789
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OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative 2 would meet the remedial action objectives for
the sediment of limiting exposure and. attaining ecologically
- based cleanup levels. Potential risks associated with the
dredging efforts could be minimized by safe working
practices. Alternative 1 would be the least protective to
human health and the environment.
COMPLIANCE WITH ARARS
The dredging operation of Alternative 2 would be carried out
in a manner to comply with most ARARs. However, because the
sediments are adjacent to wetlands, dredging operations
would constitute a wetlands disturbance. Wetlands would
have to be restored and the stream bed restored. The No
Action Alternative would comply with 25 PA Code S 105.451.
LONG TERM EFFECTIVENESS
Alternative 2 would be effective in the long term because
the affected sediment would be removed. Alternative 1 would
be the least effective.
REDUCTION OF TOXXCXTY MOBILITY AND VOLUME
Under Alternative 2, the sediment would be removed and taken
off-Site to be treated. The No Action Alternative would
result in no change, other than that which may occur due to
natural processes, in toxicity, mobility, or volume.
SHORT TERM EFFECTIVENESS
Alternative 2 should meet the remedial action objectives in
the short term. Protection to the community and workers
would be achieved by safe working procedures, proper
dredging techniques, and adhering to DOT regulations for
transportation. The No Action Alternative is the least
effective in the short term.
XMFLBMENTABILXTY
Alternative 2 would be readily implementable as would, of
course, the No Action Alternative.
COST
The net present worth costs for Alternative 2 are $0.08 M.
AR308790
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STATE ACCEPTANCE:
The Commonwealth of Pennsylvania's comments on the Proposed
Plan and draft Record of Decision stated that the
Commonwealth basically agrees with the selected remedy, but
disagrees on some of EPA's interpretations of the
Commonwealth's ARARs. EPA has not yet received a formal
position from the Commonwealth on concurrence with the
Preferred Alternatives set forth in the Proposed Remedial
Action Plan.
COMKUNZTT ACCEPTANCE:
Alternative 2 was generally acceptable to the community,
while the No Action alternative was unacceptable to the
community.
IX. THE SELECTED ALTERNATIVE
GROUND WATER
General Description and Selection Rationale
All Plumest Alternative a - Extraction of ground water above 800
feet deep that is contaminated above background levels.
Treatment of ground water by air stripping and subsequent
catalytic oxidation of the air stream from the stripper. The
treated water shall be discharged to aa oa-Site stream.
EPA is invoking the technical impracticability ARARs waiver
for all federal and state laws which require remediation of
ground water at a depth greater than 800 feet, based on disposal
of large quantities of chlorinated solvents in fractured bedrock
which EPA believes have migrated to great depth. EPA believes
that total remediation of this aquifer to background is not
possible given the Site history, geology and current contaminant
concentrations. The USGS reviewed the Remedial Investigation
Report and believes that DNAPLs may have migrated to over 2000
feet deep. Contamination above 2000 ppb has been observed at 500
deep in the plume from Drum Burial Area 1. The rationale for
this waiver is explained in detail on page 23 under "QRODNP WATER
ALTERNATIVES*1. Because DNAPLs have not been visually detected
and because data on the response of contaminant concentrations to
long tern ground water extraction is not available, EPA will
attempt to restore ground water at a depth of less than 800 feet
to background. After the Remedial Action has been implemented
and data collected, EPA in consultation with the PADER may revise
the aquifer cleanup standards in accordance with applicable
procedures of the NCP and CERCLA.
Three ground water plumes shall be captured by extraction
AR30879I
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49
wells and treated by an air stripper to remove contaminants from
ground water. The effluent air stream containing contaminants
shall be treated by catalytic oxidation. All extracted ground
water shall be treated at a common treatment plant and discharged
to an on-Site stream. The area currently affected by the ground
water contamination is served by a municipal water line. This
remedial action shall prevent contaminated ground water from
leaving the Site. Catalytic oxidation shall destroy the
chlorinated compounds in the air stream, and was selected
primarily because of it's ability to destroy vinyl chloride, and
other VOCs thereby producing water vapor, CO2 and traces of
hydrochloric acid and chlorine. The pumping system shall be
maintained until background levels are met for twelve consecutive
quarters. A ground water monitoring system shall assess the
success of the extraction system. As part of the monitoring
requirement * the regional ground water discharge area for water
which escapes the capture zone of the extraction system shall be
identified and monitoring wells shall be placed in this area.
Because of the complexity of the hydrogeology, all locations of
wells, the treatment system, and the discharge location shall be
established during remedial design by EPA in consultation with
the PADER. This remedy has a capital cost of 1.7 million
dollars, annual O&M of about $35,000 and a total Present Worth
Cost of 3.3 million dollars. The extraction part of the remedy
shall meet all ARARs except: a) the PADER requirement for
remediation until background levels are reached (for ground water
below 800 feet) and b) the Federal requirement to remediate
ground water to MCLS and non-zero MCLGs (for ground water below
800 feet deep) . EPA waives those ARARs. The remedy will st.ill be
protective because there is only on* municipal well using water
at a greater depth and no new wells at this depth are
anticipated. The discharge shall meet all of the substantive
requirements of NPDES. The air emissions shall meet the
substantive requirements of 40 C.P.R. Part 264 subpart AA.
GROUND WATER
Performance
The performance standards for each component of the selected
Ground Water remedy are described in turn:
Ground Water Cleanup Levels t Background levels of contamination,
practically defined as no detection of VOCs using method EPA
524.2 Practical Quantitation Limits.
Area of Attainment: All of the ground water plumes associated
with the Drum Burial Areas and the Lagoon Area with detections of
VOC contaminants above a depth above 800 feet. The depth will be
referenced to the surface and method EPA 524.2 Practical
Quantitation Limits will be used.
Extraction Wells: A sufficient number of extraction wells shall
AR308792
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50
be installed to capture all ground water in the area of
attainment. The number, location and pumping rates to achieve the
performance standard of the capture zone shall be determined by
EPA, in consultation with the FADER, during the Remedial Design.
Monitoring Wells: A sufficient number of monitoring wells shall
be installed, as determined by EPA in consultation with the
PADER, to verify the performance of the remedial action. The
wells shall be located and constructed in a manner that permits
accurate characterization and monitoring of ground water and
contaminants throughout the Area of Attainment, including ground
water contamination present in bedrock fractures and other
discontinuities in the aquifer.
Period of Operation of Extraction Wells: The monitoring wells
shall be sampled quarterly for the first two years and semi-
annually thereafter until cleanup levels have been attained
throughout the area of attainment. Once these levels have been
reached, the monitoring wells shall be sampled for twelve
consecutive quarters and if contaminants remain at this level
throughout the Area of Attainment, the operation of the
extraction system shall be shutdown. Semi-annual monitoring of
the ground water shall continue for five years. If subsequent to
an extraction system shutdown, monitoring shows the ground water
concentrations of any contaminant of concern to be above cleanup
levels at any point within the Area of Attainment the extraction
well system shall be restarted and continued until the levels
have once more been attained for twelve consecutive quarters.
Semi-Annual monitoring shall continue until EPA and the PADER are
convinced that contaminants throughout the Area of Attainment
have reached stable cleanup levels.
Air Stripper: Extracted ground water shall be treated using a
packed column air stripper. Exact flow rates, air stripper
dimensions and effluent water contaminant levels shall be
determined by EPA in consultation with the PADER, during the
remedial-design. Since the treated ground water shall be
discharged to the stream in compliance with PADER NPDES
substantive requirements, the specific discharge criteria shall
be established by EPA during the Remedial Design of the remedy.
The stripper shall be designed to at least achieve these levels
subject to EPA approval.
Catalytic oxidiser: A catalytic oxidizer must reduce emissions
to the minimum attainable level, as determined by EPA, through
the use of the Best Available Technology (BAT), 25 PA Code S
127.12(a)(5).
Deed Restriction: A deed restriction shall be placed on the
Shealer property that shall prevent any use of ground water until
EPA and the PADER have determined. that the ground water has
reached cleanup levels. The property, subject to the deed
AR308793
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51
restriction is shown on Figure 7 (Appendix A).
Remedy Implementation: Prior to installation of the extraction
wells, additional monitoring wells shall be installed during the
Remedial Design to define the extent of the contaminant plumes.
The number of wells shall be sufficient to determine the edge
each plume as defined by non-detection of VOCs using EPA method
524.2 and Practical Quantitation Limits (PQLs). During the
Remedial Design, the regional ground water discharge area will be
determined and monitoring wells installed and sampled using EPA
method 524.2 and Practical Quantitation Limits. The number,
location and construction of these wells shall be approved by EPA
during the Remedial Design.
Five Year Review: Because DNAPLs and other inorganic
contaminants will remain as a source of future ground water
contamination, Five Year Reviews shall be conducted after the
remedy is implemented to assure that the remedy continues to
protect human health and the environment until all performance
standards have been met as determined by EPA. At Five Year.
Reviews, selected wells will be sampled, as determined by EPA,
for TCL volatiles, metals, semi-volatile* and pesticides to
assure that the remedy is protective of ground water.
CONTAMINATED SOILS
General Description and Selection Rationale
Lagoon Area Soils* Combination of Alternative 3 -
Excavation and Off-Site Treatment/Disposal and Alternative 2A -
Soil Cover. Contaminated soil would be excavated to a depth of
two feet and sent for off-site treatment/disposal of
approximately 1,200 cubic yards of contaminated soil. The soil
in the Lagoon Area will be excavated to a depth of at least two
feet. The Hazardous and Solid Waste Act (HSWA) Amendments to the
Federal Resource Conservation and Recovery Act (RCRA) set limits
for wastes known as the Land Disposal Restrictions LDR 40 C.F.R.
SS 268.1-268.5. Soils that contain volatiles above the RCRA LDR
treatment standards shall be incinerated to comply with the RCRA
LDR regulations. Soils that do not contain volatiles above this
level will be sent for off-Site solidification/disposal. The
degree of solidification needed to allow disposal at a commercial
facility will be determined during the Remedial Design. The
excavated area shall be backfilled with at least two feet of soil
and the soil cover described in Alternative 2A installed over the
entire Lagoon Area. The soil cover consists of placing a
geotextile as a visual indicator and on* foot of topsoil over the
area. The topsoil will be seeded and revegetated. The soil
cover shall overextend the excavation for five feet in all
directions. The primary purpose of the soil cover is to prevent
dermal contact and ingestion of soil, the cover is hot meant to
prevent leaching as in a RCRA cap. A secondary purpose is to
supply enough soil to the excavated area so that as the soil
AR30879U
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52
packs down over time, runoff will not be collected in a low area,
and the geotextile will provide a visual indicator of erosion.
The total Present Worth cost is about $3.3 million if all soil
must be incinerated, and could be as low as $1 million dollars if
most of the soil does not contain VOCs above treatment standards.
The Lagoon Area soil contains listed waste solvent
constituents. EPA has determined that it is relevant and
appropriate to subject these soils to the RCRA Land Disposal
Restriction (40 C.F.R. SS 268.1-268.5). Soils containing solvent
wastes with designations F001-F002 must meet the treatment
standard for these wastes which is based on the best available
technology (incineration). Incineration is available and a
proven technology to achieve these standards. The actual amount
of soil to be incinerated could be much lower than estimated in
the Feasibility Study. The relatively small amount of soil to be
excavated in the Lagoon Area makes off-Site incineration more
attractive than on-Site incineration. Excavation will prevent
leaching into ground water of vinyl chloride and dichlorethylene.
Excavation, solidification and disposal of the top two feet
of soil will remove the high levels of metals contamination from
the Site. Although metals have not been observed in ground water.
in the Lagoon Area, this may be due to the lime that was spread
by Westinghouse in this area in 1987 to immobilize metals. If
the absence of metals in ground water is due to the lime,
eventually, some leaching may occur. The permanence of
excavation and off-Site disposal is much greater than a soil
cover or cap, which would have to be maintained indefinitely.
Additionally, the southern section of the Lagoon Area is
currently a pond/wetlands area. A low permeability cap would not
prevent ground water from moving laterally through the lagoon
soils. High ground water levels could also damage the cap.
In addition to backfilling the excavation, the addition of a
soil cover will prevent compaction and creation of a low area to
trap and drain water through residual contamination.
This remedy will comply with only the relevant and
appropriate requirements, specifically 25 PA Code 264.111(1),(2)
under RCRA. This remedy is consistent with EPA's lead policy
which requires action for lead levels in soils above 500 ppm for
residential areas and consistent with EPA's risk management
policy which generally requires action when the hazard index is
above 1.0.
The high levels of metals pose a risk to the site ecology
and a potential future risk to human health if Site controls are
not maintained. This action is protective of human health and
the environment and shall comply with ARARs. AR308795
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53
Stressed Vegetation Area: Alternative 3 - Excavate, treat
and dispose of vast* and soils off-Bits and Alternative 2A -
Soil Cover.. Approximately 5,100 cubic yards of waste and
contaminated soil will be sent off-Site for treatment and
disposal. The area excavated shall be backfilled and a soil
cover installed over the entire area. The soil cover described
.in Alternative 2A shall be installed over the area. The soil
cover consists of placing a geotextile as a visual indicator of
erosion and one foot of topsoil over the area. The topsdil shall
be seeded and revegetated. The total Present Worth Cost is about
$0.34 million. The Stressed Vegetation Area contains some
concentrated wastes that would be difficult to separate from
.contaminated soils. Composite samples from this area failed the
toxicity leaching procedure for lead. The wastes have had an
obvious effect on vegetation in this area (yellow leaves instead
of green). The metals in this area have impacted the wetlands
ecology. Wastes and contaminated soils from this area would be
sent off-Site for solidification and disposal. Excavation of two
feet of soil would remove most of the metals contamination and
the backfill and soil cover shall prevent contact with the
remaining contaminants. The primary purpose of the soil cover is
to prevent dermal contact and ingestion of soil, the cover is not
meant to prevent leaching as in a RCRA cap. The addition of the
soil cover will also prevent creation of a low area to trap and
drain ground water through residual contamination and will be
part of an integrated soil cover for all contaminated areas.
Combined North and South Cornfields and the Borrow Areas
Alternative 2A - A one foot deep soil cover shall be installed
over a geotextile which shall be a visual indicator of erosion.
The field shall be seeded and the soil cover maintained. The
total Present Worth Cost of this alternative is about $2 million.
The North and South Cornfields contain numerous hot-spots of lead
and chromium contamination associated with a white material that
appears as lenses of friable material in the cornfield soil. The
Borrow Area contains some spots where lead exceeds EPA's action
level for lead in residential areas and probably contains some
residual asbestos several inches below the surface. A soil cover
shall prevent contact with these contaminants. A one foot deep
top soil cover shall be installed over a geotextile which shall
be a visual indicator of erosion. The areas shall be seeded and
the top soil cover maintained perpetually. Elevated metals have
not been detected in Site ground water and an arithmetic average
of lead levels in the Cornfields are just below EPA's action
level of 500 ppm, therefore, elimination of direct contact
through a soil cover and an encompassing chain link fence is
sufficiently protective. Analysis of ground water for metals at
five year reviews will be performed to make sure that the metals
remain immobile.
Drum Burial Area 1: Ho Additional Action. An extensive removal
action performed by Westinghouse Corporation removed the
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.54
drums and most contaminated soil from the area. The resulting pit
vas backfilled with clean soil and revegetated. Residual organic
contaminants are generally below the water table level and
contaminant levels in ground water are actually higher than in
the shallow ground water near the burial area. This indicates
that contaminants have moved deep into the bedrock fractures.
The remaining residual contamination shall be addressed by the
ground water remedial action which will collect the residual
contaminants as they leach from soils in the area. A low
permeability cap would reduce infiltration and would actually
retard the cleanup of contaminated soils.
Drum Burial Area 2: Ho Additional Action. Post removal action
residual contamination was not found during the RI.
Expanded Soils Soil Coverage: The dotted boundaries of the soil
areas shown in Figure 2 (Appendix A) are somewhat arbitrary and
were not established by numerous samples. Sampling prior to the
RI did detect some contamination between the Lagoon Area and the
East Stream. The Remedial Investigation also concludes that the
East Stream metals contamination is due to transport of
contaminants by surface runoff to the East Stream from the
Stressed Vegetation Area, the Lagoon and the Cornfields. The
runoff from these areas travels across the areas between the
Stressed Vegetation, the Lagoon Area, the South Cornfield and the
East Stream. EPA is extending the soil cover areas of the
Stressed Vegetation Area, the South Cornfield and the Lagoon Area
to encompass the areas between these units and the East Stream.
This will avoid leaving contaminated corridors between the soil
covers. During the Remedial Design, a sufficient number of soil
samples (as determined by EPA) will be collected and analyzed for
contaminants related to the Lagoon Area, Stressed Vegetation Area
and Cornfields to determine extent of the expanded coverage. On
the basis of this sampling and Site history, EPA during the
Remedial Design, will determine the exact extent of the expanded
coverage. The cost for this protection is moderate for the extra
protection: Capital Cost - $100,000, out - $3,000 and a Total
Present Worth Cost of $150,000.
Institutional Controlss A deed restriction on the use of the
property that has a soil cover installed as a remedial action
will prohibit use of the property for any purpose. A chain link
fence will also be necessary to protect the soil cover.
Recreational vehicle tracks have been observed at the Site, and
unrestricted access would allow this type of activity to erode
the soil cover. Landscaping will be used to minimize the
longterm impact of the containment aspects of the remedy on the
local community.
AR308797
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55
CONTAMINATED SOILS
Performance Standards
Lagoon Area Soils: At least the top two feet of soils shall be
excavated at the Lagoon Area, shown in Figure 2 (Appendix A).
During the Remedial Design, sufficient samples, as determined by
EPA, shall be taken to determine the area of soil that contains
VOCs above the RCRA Land Disposal Restriction treatment standards
for solvent wastes. That part of the excavated soils, and any
additional soils within the fenced area shown in Figure 2
(Appendix A), that contain volatiles above the Land Disposal
Restrictions Treatment Levels ("LDR") set by the Resource
Conservation and Recovery Act at 40 C.F.R. SS 268.1-268.5, shall
be excavated and sent for off-Site incineration to comply with
the RCRA LDR regulations. Excavated soils that contain VOCs at
levels below the RCRA LDR regulations will be sent off-Site for
solidification and disposal. Verification TCLP sampling of the
soil remaining at the Lagoon Area for lead, chromium, mercury,
vinyl chloride, TCE, and 1,1 DCE will be conducted. All soils
that constitute a characteristic RCRA hazardous waste shall be
removed.
The excavated area shall be backfilled with at least two
feet of soil, and a soil cover installed over the area.. The soil
cover shall bverextend the excavation for five feet in all
directions. The soil cover consists of placing a geotextile as a
visual indicator and one foot of topsoil over the area. The
topsoil shall be seeded and revegetated. The soil cover shall be
maintained perpetually and shall be inspected annually. The
geotextile will provide a visual indicator of erosion. If
geotextile is observed, the soil cover shall be repaired within
sixty days.
This remedy will comply with the relevant and appropriate
requirements, specifically 25 PA Coda $ 264.111(1), (2) under
RCRA.
Stressed vegetation Areas The top two feet of soil in the area
shown in Figure 2 (Appendix A) shall be excavated and sent off-
Site for solidification and disposal, verification TCLP sampling
of the soil remaining for barium, chromium, lead, and mercury
will be conducted. All soils that constitute a characteristic
hazardous wastes shall be removed.
The excavated area shall be backfilled with at least two
feet of .soil and a soil cover shall be installed over the area.
The soil cover consists of placing a geotextile as a visual
indicator of erosion and one foot of topsoil over the area. The
topsoil shall be seeded and revegetated. The soil cover shall
overextend the area by five feet in all directions. The soil
cover shall be maintained perpetually and shall be inspected ~ ft -. q fi
annually. The geotextile will provide a visual indicatoi fW v 0 / 3O
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56
erosion. If geotextile is observed, the soil cover shall be
repaired within sixty days.
Cornfields and Borrow Area: A soil cover shall be installed over
the North Cornfield, South Cornfield and Borrow Areas1 shown in
Figure 2 (Appendix A) . The soil cover consists of placing a
geotextile as a visual indicator of erosion and one foot of
topsoil over the area. The topsoil shall be seeded and
revegetated. The cover shall overextend the areas shown by five
feet in all directions. The soil cover shall be inspected
annually and if geotextile is observed, the soil cover shall be
repaired within sixty days.
Expanded Soils Coverage: The soil cover areas of the Stressed
Vegetation Area, the South Cornfield and the Lagoon Area shall be
expanded to encompass the areas between these units and the East
Stream. This action in conjunction with the South Cornfield,
Lagoon Area, and Stressed Vegetation Area will produce an
integrated soil cover. A sufficient number of samples in
locations to be determined by EPA during Remedial Design will be
collected and analyzed to define the contaminated corridors and
areas contributing to transport of contaminants to the East
Stream that will require expanded coverage. Soil samples will be
analyzed for contaminants associated with the Lagoon Area,
Stressed Vegetation Area, and Cornfields (See Page 10 above) .
The exact boundaries of the soil cover shall be determined by EPA
during the Remedial Design. The cover shall assure coverage of
unsafe levels of contaminants. A one foot deep top soil cover
shall be installed over a geotextile which shall be a visual
indicator of erosion. The areas shall be seeded and the soil
cover maintained perpetually. The soil cover shall be inspected
annually and if geotextile is observed, the soil cover shall be
repaired within sixty days.
Institutional Controls s A deed restriction shall prevent any use
of the property by the Site owner for storage or any other
purpose that may impact the remedy. A chain link fence will be
constructed to surround the Site sufficient to prevent access by
motor vehicles and children and to protect the soil cover.
SDRPACB
General Description and Selection Rational'e
Surface Water: Ho Current Action. The above remedial actions
for ground water and soil areas should reduce surface water
contaminants to levels which are acceptable.
SURFACE
Performance Standards
Surface Water: EPA, in consultation with the Natural Resource
Trustees and the Commonwealth of Pennsylvania, shall determine
AR308799
-------
57
which standards are protective of stream ecology and acceptable
levels of contaminants in surface water. The details of this
sampling shall be developed during the Remedial Design, and
approved by EPA in consultation with the Natural Resource
Trustees. East Stream surface water samples and surface water
samples after the confluence of the East Stream, Middle Stream
and West Stream shall be collected and analyzed for Site related
contaminants. The samples shall be collected and analyzed after
the remedial action is constructed and in operation and at the
five year review to make sure that the remedial actions at the
other areas have reduced contamination to the levels determined
in the standards selected by EPA in the East Stream and that the
Remedial Action has not impacted the surface water down stream of
the Site. Upon review, if EPA in consultation with the
Commonwealth and the Natural Resource Trustees determine that the
ecological risk from surface water is above acceptable standards,
EPA may take additional action to remediate surface water at the
Site.
SEDIMENTS
General Description and Selection Rationale
East Stream Sediments: East Stream sediments shall be excavated
from the area just upstream of the Lagoon and Borrow Areas to
Shealer Road. Contaminants are at a level expected to impact the
stream ecology. This was verified by a site visit by an EPA
biologist and by Westinghouse's contractor. Typical
invertebrates were not present in the stream from the Lagoon Area
to Shealer Road. Excavation of stream sediments in conjunction
with the soil and ground water remedial actions should eventually
restore the stream ecology. It will be necessary for EPA to use
appropriate professional field judgment to efficiently delineate
and remove contaminated sediments for a number of reasons. The
stream channel is extremely non-uniform, ranging from rock with
little or no sediment present to pools containing large amounts
of sediment, in some areas sediment is deposited over rock,
making delineation easy, but in other areas sediment is over soil
making delineation difficult. Some low lying areas not actually
in the stream channel contain sediment deposited during high
water events. The distribution of sediments is dynamic and may
change periodically as the result of storms. During the Remedial
Design, a; field study of the depth and location of sediments to
be removed along the stream shall be approved by EPA in
consultation with the Natural Resource Trustees and the
Commonwealth of Pennsylvania. EPA will visit the Site prior to
the remedial action and shall make modifications to the plan for
sediment removal if necessary.
The soil cover should prevent future transport of
contaminated soils into the streams. The Present Worth of this
remedial action would be about $100,000,
AR308800
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58
Middle Stream Sediments: A small segment of the Middle Stream
contained elevated level of zinc and bis(2-ethylhexyl Phthalate).
EPA's Biological Technical Assistance Group indicated concern
about the zinc levels at sample locations SD-17 and SD-18 in the
Remedial Investigation. During the Remedial Design, five feet
upstream and downstream and to a depth of six inches of sediment
shall be excavated at sample locations SD-17 and SD-18.
Verification samples will be analyzed for zinc only. A small
amount of sediment at these locations will be removed and sent
for off-Site treatment/disposal.
SEDIMENTS
Performance Standards '
East Stream Sediments: Contaminated sediments will be excavated
from the East Stream in locations and quantities sufficient to
restore the stream ecology in conjunction with the remedial
actions for the soil and ground water. EPA, in consultation with
the Natural Resource Trustees and the Commonwealth of
Pennsylvania, will delineate the areas of contaminated sediments
to be removed to achieve that goal, based on a preliminary field
plan and EPA's professional judgment and visual and other
observations in the field. The cleanup levels will be sufficient
to protect the stream ecology as determined by EPA in
consultation with the Natural Resource Trustees and the
Commonwealth of Pennsylvania. The contaminated sediments shall
be treated and disposed off-Site. Verification sampling shall be
conducted along the stream channel after the remedial action is
completed sufficient to ensure that the contaminated sediments in
areas of concern were removed and the clean-up levels achieved.
Kiddle Stream sediment*: Excavation and off-Site disposal of the
designated areas containing zinc above ecologically safe levels
as set by EPA and the Natural Resource Trustees shall prevent any
impact of the elevated areas of these contaminants to the stream
ecology.
WETLANDS AND ECOLOGICAL ACTIONS
General Description and Selection Rationale
Wetlands Replacement: The remedial actions will have an impact
on the wetlands areas in the Stressed Vegetation Area, the Lagoon
Area and a negative impact on the streams. Artificial wetlands
shall be constructed at the Hunterstovn Site in an uncontaminated
area to replace permanently destroyed wetlands. The most likely
location is along the Middle Stream at the northern section
adjacent the North Cornfield, however, the final location will be
determined by EPA during the Remedial Design. Restoration of
streams impacted by sediment removal is also required. The
estimated cost is less than $ 50,000 dollars.
Soil Cover Vegetation: As restitution for past damages to
AR30880
-------
59
transient wildlife such as migratory birds, the BTAG has
requested that the vegetative soil cover be seeded with plants
that are beneficial to wildlife. This shall be done if a seed
mixture of plants can be found that will not impede access for
normal maintenance and will not significantly increase
maintenance costs as determined by EPA.
WETLANDS AND ECOLOGICAL ACTIONS
Performance Standards
Wetlands Replacement: A wetlands delineation shall be conducted
during the Remedial Design so that the impacts of .the remedial
action oh wetlands acreage can be calculated and the size of the
replacement wetlands can be estimated. A shallow excavation
adjacent to the Middle Stream shall be constructed and planted
with wetlands vegetation. The acreage replaced shall be one for
one for wetlands permanently lost due to the remedial action, but
one for one shall be adjusted to consider three factors: 1) the
time for the replacement wetland to achieve the full function and
value of the impacted wetland; 2) the loss of function and value
of the impacted wetland from the moment of wetland loss to full
replacement; and, 3) if the replacement area already has
wetlands, to account for the impact to the function and value of
the wetland habitat. Wetland areas that will remain wetlands,
but have been destroyed by the remedial action must be planted
with wetlands vegetation as determined by EPA during the remedial
design.
X. STATUTORY DBTBRMIHMIOHfl
Under its legal authorities, EPJt's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health, and the environment. In addition,
Section 121 of CERCLA established several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for a site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a
statutory, .waiver is granted. The selected remedy must also be
cost-effe*tive and utilize treatment technologies or resource
recovery technologies to the maximum extent practicable.
Finally, the statute includes a preference for remedies that
permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes.
protection of HV'flTl Health and the BpTironitfTI^
The selected remedy will be protective of human health and
the environment by eliminating the threat posed by hazardous
substances at the Hunterstown Road Site. These hazardous
AR308802
-------
60
substances currently pose a threat to human health and the
environment due to potential exposure to contaminated ground
water, soils and sediments at the Site. Implementation of this
remedy would effectively eliminate the potential risk to human
health which may result from exposure to contaminated ground
water, soils and sediments from the Site and will eventually
restore ground water at the Site to beneficial uses. Because the
selected remedy would result in hazardous substances remaining
on-Site (DNAPLs), 5-year site reviews, pursuant to Section 121(c)
of CERCLA, 42 U.S.C. $9621(c), shall be required to monitor the
effectiveness of this alternative.
The Selected Remedy will control risks from domestic use of
the highly contaminated ground water on the Shealer property by
the implementation of a deed restriction on the use of ground
water. The Selected Remedy will also control the migration of the
contaminants to off-Plant residential wells using extraction
wells to create a capture zone that will prevent or substantially
reduce the movement of contaminated ground water from source
areas.
The Selected Remedy will use extraction wells to prevent the
further migration of contaminated ground water to areas not
served by the public water line and will eventually remediate
ground water background levels. The extraction wells must
operate until background levels have been achieved for ground
water above 800 feet.
Excavation of highly contaminated coils, placement of a soil
cover over moderately contaminated soils, and installation of a
fence will prevent exposure to contaminants in soils.
Excavation, treatment and disposal of highly contaminated soils
substantial reduces any future potential for leaching of metals
to ground water. Excavation, treatment and disposal will also
eliminate the impact and bioaccumulation of contaminants in the
food chain. Actions will be taken to restore or replace the
wetlands areas of the Lagoon and Stressed Vegetation Areas.
Excavation of contaminated sediments, elimination of
contaminated runoff, ground water discharge and stream
restoration will restore a healthy stream ecology at the Site.
Seeding the soil covers with ecologically beneficial plants will
benefit the ecology of the area.
The selected remedy will not pose any unacceptable short-
term risks or cross-media impacts to the Site, the workers, or
the community. The selected remedy will be readily
implementable.
AR308803
-------
compliance with
The remedy shall meet all ARARs except: a) the FADER
requirement for remediation until background levels are reached
(for ground water below 800 feet) and b) the Federal requirement
to remediate ground water to MCLS and non-zero MCLGs (for ground
water below 800 feet deep). EPA will waive those ARARs. The
remedy will still be protective because there is only one
municipal well using water at this depth and no new wells at this
depth are anticipated. These requirements are shown in Appendix
A.
The Commonwealth of Pennsylvania requires that contaminated
ground water be actively remediated to background (25 PA Code
Sections 264.90-264.100 and in particular, 264.97(i), (j), and
264,100(a)(9)).
EPA waives the state's background ARAR for ground water at a
depth of greater than 800 feet on the basis of technical
impracticability. EPA also waives the Federal Maximum
Contaminant Levels (MCLs) and Maximum Contaminant Level Goals
(MCLGs) for ground water at a depth greater than 800 feet. The
basis for the waiver is the impracticability of remediation of
ground water contamination from DNAPLs in fractured bedrock at
extreme depths. EPA's Technical Impracticability Panel (a
national EPA work group) was consulted on the use of the
technical impracticability waiver at the Hunterstown Site. The
panel believes that at some sites, such as the Hunterstown Road
Site, it is appropriate to remediate portions of the aquifer and
invoke a waiver for a different area of the aquifer. The remedy
will still be protective because only one municipal well is using
ground water at this depth and no new wells at this depth are
anticipated.
Based on records in EPA's files, up to 130,000 gallons of
waste from the Westinghouse Elevator Plant was disposed at two
Superfund sites (10 drums/month for tan years). Most of the
waste was solvent sludge which went to the Hunterstown Road Site.
Based on a crude estimate making many assumptions, about 25,000
gallons of spent solvent was disposed in drum burial area 1 and
about 40£000 gallons of spent solvent was disposed in the Lagoon
Area. Although this is a very rough estimate, it shows that a
large amount of solvent with a very low solubility was disposed
in a geological formation with a low permeability and slow ground
water, movement. At the Hunterstown Site, the solvent would be
trapped in numerous small fractures in the bedrock and would have
migrated downward to great depths in the bedding plane fractures.
This trapped solvent will slowly dissolve over a long period of
time substantially delaying the ground water cleanup. Although
DNAPLs were not observed in the well samples, EPA believes that
the Site history and ground water concentrations of solvent
constituents support the conclusion that DNAPLs are presfln^g Q 8 8 0 U
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62
Although monitoring wells have not been placed below a depth
of 500 feet, the ground water gradient is downward; and since the
concentration at 500 feet is about 1700 ppb of total VOCs, it is
reasonable to conclude that ground water at much greater depth is
contaminated above MCLs. Since the plume is not defined by
depth, remediation costs are uncertain and estimated cleanup
times would be speculative.
. Remediation of ground water below 800 feet would be
extremely expensive and would probably accomplish little
additional risk reduction at very high cost. The larger drill
rigs and special well construction techniques would drastically
increase costs. Locating the contamination as it travels
downward through -unpredictable fractures would be extremely
difficult and would require numerous wells. Only one operating
municipal well in the area is deeper than 635 feet deep and the
Gettysburg ?*UA is unlikely to place any future wells deeper than
800 feet.
Although the above information does indicate a high
probability that ONAPLs are present, DNAPLs have not actually
been detected in well samples and EPA does not have long term
pumping data to show the ground water concentration
characteristics associated with the presence of DNAPLs. When
DNAPLs are present and a pumping system is installed, ground
water contaminant concentrations drop dramatically and then level
out over a period of weeks or months. After the initial rapid
decline in concentration, the ground water concentrations tend to
persist for years at the same levels, when the pumping system is
stopped, contaminant levels slowly increase to their pre-pumping
levels. This type of contaminant concentration response is
strongly associated with the presence of DNAPLs. The
Pennsylvania Department of Environmental Resources has indicated
that they believe that this type of aquifer response information
is absolutely necessary to support a technical impracticability
waiver for the shallow aquifer (less than 800 feet). EPA will
attempt aquifer remediation of the ground water at a depth of
less than 800 feet, while recognizing that the attempt may not b«
successful. After the Remedial Action is implemented and several
years of data are collected, EPA in consultation with the PADER
may revise the cleanup goals for the ground water above a depth
of 800 feet.
Coat Effectiveness
The selected remedies are the most cost effective remedies
that are adequately protective of public health, and comply with
ARARs. The selected remedy uses treatment for highly
contaminated wastes, sediments and soils, but uses an inexpensive
containment remedy for more moderate levels of contamination.
The selected remedy will attempt remediate ground water at depth
AR308805
-------
63
that may be used in the future, but waives the cleanup
requirement at a depth where remediation would not be cost
effective for the risk reduction achieved.
Utilizati
m» AI* B«»<«niiT*r*«i Vmr*mrmv~*T T^flhnnl ntv4 mm +n t>tia M>v4num
EPA has determined that the selected remedial action
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized while providing the best
balance among, the other evaluation criteria. Of the alternatives
that are protective of human health and the environment and meet
ARARs, EPA has determined that the selected remedies provide the
best balance of trade-offs in terms of long-term effectiveness;
reduction in toxicity, mobility, or volume through treatment;
state and community acceptance; and the CERCLA preference for
treatment.
The selected remedy addresses the long-term, threats posed
by the Site contaminants at the Hunterstown Road Site. The
remedy is protective of human health and the environment, meets
ARARs, and is cost-effective. Treatment as a principal element
is provided for in the on-Site treatment of extracted ground
water prior to discharge. Treatment is also utilized for highly
contaminated wastes and soils in the Lagoon and Stressed
Vegetation Areas.
A fence surrounding.the areas that have a soil cover
installed is necessary to protect the soil covers. This was
anticipated, but not specifically discussed in the Proposed Plan.
Comments were received regarding the lack of sampling data
for the "Expanded Soil Coverage". Sampling of this area shall be
conducted during the Remedial Design prior to installing the soil
cover over this area.
EPA has, after discussion with the Pennsylvania Department
of Environmental Resources, reconsidered it's interpretation of
the Pennsylvania Residual Waste Regulations in the Proposed Plan.
EPA now considers the residual waste regulations requiring that
the remedy be protective, to be both Relevant and Appropriate for
contaminated soils remaining on-Site.
EPA after deliberation and discussion with residents will
extend all of the soil covers five feet in all directions to
assure coverage of Site contaminants.
AR308806
-------
APPENDIX A
-------
5000 nrr
REF-1 - SURFACE WATER BACKGROUN
(REFERENCE) SAMPLE LOCATION.
RtftRfcNCE;
U.S.C.S TOPOGRAPHIC MAPS OF GETTYSBURG. PA
AND BIGLERVILLE. PA. BOTH PHOTOREMSED IN
1973. SCALE: T - 2000*.
RGURE 1-1
SITE LOCATION MAP
HUNTERSTOWN ROAD STE R)/FS
STRABAN TOWNSHIP. AOAMS COUNTY. PCNMSYLV
GENERAL REVISION
APPROVED BY:
I DATfc
REVtSONS
WESTINGHOUSE ELECTRIC CORPORA
PITTSBURGH. PENNSYLVANIA
C Rtazo
CONSULTANIS
-------
HUNTERS-TOWN ROAD - CONTAMINATED AREAS
(Residual voc«)
FIGURE 1-2
SITE PLAN
HUNHMSWWM HOAO 911 NlAS
5TBA8AN TOWNSHIP. AOAUS COMFY. PtNNSYLVAM*
fNCPAKO FOR
WESTINCHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
(L..4 C A.b,.to.)
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-------
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Gettysburg Formation Hydrogeology
FRACTURE
PROJECTION
POTENTIOMETRIC
SURFACE
C
c
Conceptual novaae*! ol iMf footle orgaalc eompoundi is density Horn In ground water and In dilute
Purgeable organic
compound!.
In bulk masses
Puig«abtn organic
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-------
LXOOOM AURA PLUMB
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138
MOMIOMNG Kll AND
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COMPOUNDS (OCA)
IAGOOM •««
—10- wriMKo COMHM or IOUAL
CONCtNMAMNS OF 101U.
vauwi OM«MC
i(uoA)
NOUS:
I *NO* MOICOKS VOLADK OMAWC
COMPOUNDS NO) OtltCRO.
1 ACtTONt AMD UCIMtUNi
CMKKWJt AM HOI wauoto
M DC
1 CQHCfNmAIKMt AM f«OM
MOVtMKN. ItM SAHPUNO IWH1.
WIldlNCI
IOPOOIAPHV FMPAMO H
MAPT1NC CO..
fCAU: f-IOO-. (WAV. IM4)
S C A L C
FIGURE 4-1
TOTAL VOLATILE ORGANIC COMPOUr
LAGOON MONITORING WELLS
MUNimSIOMI HOAO Sill M/TS
S1K1HAN IO«NINP. ADAMS COUHIf. fCNMSUV/
MCMMO f 0«
WESTINGHOUSE ELECTRIC CORPORAT
PITTSBURGH. PENNSYLVANIA £i
C
-------
DRUM BURIAL ABBA 1 PLUMB
LEGEND:
t ABC A AIR ROTARY BORING IN WHICH
-16BFV MONITORING WELL WAS INSTALLED'
498.52 CROUNDWATER ELEVATION IN FEET
(MSL) ON APRIL 9. 1992
•M TOTAL CHLORINATED ALIPHATIC
HYDROCARBON CONCENTRATIONS (ug/l)
IN JANUARY 1992
•- top APPROXIMATE ISOCONCENTRATION OF TOTAL
CHLORINATED ALIPHATIC HYDROCARBONS
("fl/0
505
APPROXIMATE ELEVATION OF
POTENTIOMETRIC SURFACE IN FEET (MSL):
F-SERIES MONITORING WELLS
RCfERCNCE:
.TOPOGRAPHY PRtPAfltO BY CASIERN MAPPING CO..
PIF SaURCH, PENNSYLVANIA, SCALE: I* - 100'.
DA1EO: MAY. IB84
200
200 FEET
3
O
c
s
FIGURE 2 <
POTENTlOMnRlC SURFACE AND
VOLATILE ORGANIC CONCENTRATIONS |
F-SERIES MONITORING WELLS
S1MABAN
WESTINGHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
T\ai C »...„ A I..
-------
s
LECCNO:
HMW-I3AEA MOMTOMM «! AMD
^^ rn>irrni» • ntmt tm Tn
12
/*\
HUNTERSTOHM ROAD
DRUM BURIAL AREA 2 PLUMB
_s_i_
,
COHCCN1MAWM OT TOMi.
VM.AIU OMMMC
(UOA)
OMUU WMAl AftfA 1
OWIU KIHIAJ. AKA S
MRIMCO COMTOW or COUAL
WLATU OWAMC COM»OUHOt
(UOA) "
-------
HCiURE
II S A
If il I
n_ «•£ 2r Z ••»
SHEALER PROPERTY SUBJECT
TO DEED RESTRICTIONS
iliii ii
dIU "5 Ji
li
u a. P
5
E ui
O
K
AR308f
'7
-------
APPENDIX B
AR3088IU
-------
APPENDIX B
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
BUNTERSTOWN ROAD SITE
Chemical Specific ARARs
Relevant and Appropriate Requirements
1) The Pennsylvania ARAR for ground water for hazardous
substances is that all ground water be remediated to
"background" quality as specified by 25 PA code SS 264.90-
264.100 and in particular by PA code SS 264.97(1), (j), and
264.100(a)(9). The Commonwealth also maintains that the
requirement to remediate to background is also found in
other legal authorities.
Location Specific ARARs
1) 40 C.F.R. Part 6. Section 6.302fa) and Appendix A ARAR
which governs on-Site wetlands requirements.
. 2) 25 PA Code S 105.451. Dam Safety and Water Management.
These regulations passed pursuant to the Dam Safety and
Encroachments Act, 32 PS SS 693.1-693.27.
Action Specific ARARs
Applicable ARARs
1) Emissions Reduction from Stripper/Absorber. To the
extent that new point source air emissions result from the
implementation of the Remedial Alternative, 25 PA Code
5127.12(a)(5) is applicable, requiring that emissions be
reduced to the minimum obtainable levels through the use of
the Best Available Technology (BAT), as defined in 25 PA
Code $121.1.
2) NPDES Discharge requirements as set forth in 25 PA Code
SS92.31, includes monitoring requirements for the stripper
discharge. These requirements are established pursuant to
the PA Clean Streams Law, 35 P.S. S691.1 et sea.
3) RCRA Requirements. On-Site ground water is above the TCE
level (500 ppb) that qualifies for handling ground water as
a hazardous waste as specified in 25 PA Code 5 261.24.
Soils excavated in the Stressed Vegetation area are RCRA
hazardous wastes. The remedy to be implemented will comply
with the applicable requirements of 25 PA Code Part 262.11
(relating to hazardous waste determination) and with respect
AR3088I5
-------
to operations at the site generally, with the substantive
requirements of 25 PA Code Part 264, Subpart I, specifically
SS 264.171 - 264.179 (in the event that hazardous waste
generated as part of the remedy is managed in containers),
Subpart J, specifically the substantive requirements of SS
264.190, 264.192-264.199 (in the event that hazardous waste
is managed, treated or stored in tanks).
4) Land Disposal Restrictions set forth at 40 C.F.R.
Sections 268.1 - 268.5 related to the management of
hazardous waste generated as part of the remedy.
5) Sections of 25 PA Code, Chapter 102, specifically SS
102.4(a), 102.11 - 102.13, which require measures to prevent
erosion of soils disturbed during excavation.
\
c
Relevant and Appropriate Requirements
1) RCRA requirements of Subpart AA 40 C.F.R. 264.1032 (Air
Emission Standards for Process Vents) of the Federal RCRA
regulations, are relevant and appropriate for the air
stripping operations under the selected remedy. Under this
ARAR, total organic emissions from the catalytic oxidizer
must be less than 1.4 kg/hr (3 Ib/hr) and 2800 kg/yr (3.1
tons/yr) or reduce emissions by 95 weight percent. The
remedial actions must comply with Section 112 of the Clean
Air Act (40 C.F.R. S 61.63) which sets allowable emissions
standards (NESHAP) for vinyl chloride.
2) Relevant and Appropriate sections of the RCRA closure
regulations 264.111(1),(2) that require ground water
monitoring and permeable covers (Hybrid Landfill closure).
3) 25 PA Code S 287.101(d) for residual waste requires that
the remedy for contaminated soils left in place be
protective.
To Be Considered
1) Pennsylvania Water Quality Criteria (25 PA Code Chapter
93) as related to stripper discharge levels. Surface water
standards related to the use of surface water for drinking
water only and also for drinking water and consumption of
fish from the surface water. This criteria is established
pursuant to the Clean Streams Act, 35 P.S. SS 691.1 e£ seq.
2) TBC OSWER Directive 9355.0-28 which requires control of
hydrocarbon emissions in excess of 15 pounds per day in
non-.ttai.Ment are...
-------
3) Pennsylvania's Ground Water Quality Protection
Strategy, dated February 1992.
4) Water Quality Toxics Strategy, 25 PA code Chapter 16, for
water quality guidance
5) EPA OSWER Directive 9355.0-28, control of Air emissions
From Super-fund Air Strippers at Superfund Ground Water
Sites.
6) PADER "Air Quality Permitting Criteria for Remediation
Projects Involving Air Strippers and Soil Decontamination
Units" Guidance Manual.
7) EPA's Ground Water Protection Strategy which is used to
classify aquifers based on their use.
AR3088I7
-------
APPENDIX C
AR3088I8
-------
TABLE 8-4
HUMAN HEALTH EXPOSURE ASSUMPTIONS FOR THE FUTURE
LAND USE SCENARIO AT THE HUNTERSTOWN ROAD SITE
Receptor Bxpoetire Duration
HOUII
perDey Medium ' Pathway
Parameter Value Unit*
Comment*
CaaatnKilee 1 dty/e*. IS wt/yr. 2 yn
Werkan
2dty/wt, >Sm«4rr.2yn
Oeatte BiiHiatr
-Adeka 7dtyirwk.SOeAttyr.SOyn
24tyatot.24aAWyr.SOyn
7atytreA.SOcAiryr.Myn
1 ^bkBeeaJeMeV 4A etAeJejer Wk Hem
7 ••jriVw*, Jv wtwrjf , JO JIB,
7 deyarwk. M eAaryr. M yn
7atyereA.MaAarfe.Mytt
fllldita 7 day areA.S» eAaryr. S»yei
4etyeJeft.Mc4jaJya.Myie
7dayefeA.MeAiryr.Myn
7 dayareA. SO eAaryr. SO yn
7 dtyafmA. SO cAafyr, M yn
7 dayanA. SO eAaryr. SO yn
-Yetatj 7deytraA.IOeAiryr.Syn
ChUdrc. 4 dayamA. 24 mAtfyr.Syn
X» 7 dtytraA. SO wtiryt. S yn
3D 7 dtytfeA. SO wUfyi. S yn
(^ 7daytre».JO«AWyr. Jyn
CD
OO 7 daya/vk, JO wkt/yr. S yn
CD
1 Surface SoUi hcldealtl njeeMoe
Dental CoaUcI
UuUllee
1 ft*ewfaea Belli ItclaYaut hteHlea
DamalCeetact
SthiiaiioB
SurtaetSoUa behkaul hujcMloa
4 Dental Coattrt
24 WMfMloa (vole ted duel)
0.2S Piieuirmiitl
0,0 lekahaHB dhow)
featMeSeBt • hvaeiaaal taaatMoa
4 Dteawl Ceataet
24 Inhablloa (veto ted duet>
OfMetetWetfeM heatWliOA
0.2S DeBBtlCealael
0.1S khaUlta (Ao.tr)
Surface Solh ItcMeaUl hteHloa
Oteeedwalar btjenloa
0.1S . PeraulCoaucl
Inhalalloa (dwwet)
btull.eR.1.
Body Surface Ant
* Area Eiaeeed
SollAaVRect
Abiantloe Kate
•hatallee Bate
leteaUea Bale
Body Surface An*
* AnaBipaeed
SeHAdhtneee
Abeantlee Bate
bdwIHiaeBale
Body Walfht
htetlloe hate
Body Serfaea Arc*
* Area Biftaed
Sad Adhtreeca
Abetntloe BaU
UUIalha Bate
lageolloa Bale
* AtaaBiaettd
Ahaofflloe) Rale
lahahllaa Rate
Body WaajM
l*t*iu*BB*ie
Bae> Surface Ana
« Ana Biaeeed
Sell Adteneet
AbaoieUoe. Rala
lahalaUee Bait
laaeallae Bate
Body Surface Area
* AnaBxeeaed
AbunlloelUU
hAiltllaeRiit
Body Weight
Body Surface Ana
Soil Adheieeee
Abeorftloa IUK
hhaUlloa Ral*
h«eilloa Bile
Body Surface An*
Abtonlioa Rat*
Uulallo* Rale
100 mi/day
I.M •)
U» %
O.OI4S tftel
0.2S Xflu •
2.S aj3Jtf2
ll.t *
O.OI4S IffM
0.2S *rer
2.S ail/hour
TO K|
100 ayjfdiy
I.M »2
IM «
O.OI4S Kf/ai2
0.2S *rer
20 aiS/day
I.M ml
100 *
O.OOOS cet/ht
04 aiMr
TO K|
IW *>|fday
l.4( ml
1S.S» *
O.OI4S Kttel
0.1S «/hr
2S.2 a»V4ay
2 L/day
1.4* ml
lot f
O.OOOS cei/hr
O.e aiS/hr
JO J K|
200 etj/diy
0.7S ml
ll.a «
O.OI4S Kite]
0.2S «/hr
20 Hi/day
I.S Uday
O.TS ail
101 «
0.0001 cai/ht
0.6 tal/hr
IS.* K|
100*. of avenf c dally doat of 100 arg/dey (e)
SO* rcKeetiro for aduH (b)
terftc* in* fer haedt, forcami. ted hud (b)
valea dclcrethwd for Beak* toll (e)
I.S* abtMBIkej IbMi IS* ButrU effect (d)
bated ee natoniMe miilawai eipomre of 20 teJtoork-ety d>
100* of avcnte dairy doit of 100 o|/day (a)
SOtt petceallto tar aduR (b)
terface ana for haeet, forearm, and hud (b)
vilut dclemleed far potllrej tell (e)
I.S* tbaontlae IbMi IS* autrii effect (d)
htatd ee lUMeaHa auibnuei expoauie of 30 aiJ/oay (b)
Body Mlfhl lot adull(b)
100* of avenit dally doat of 100 rag/day (•)
Jfta eciceetlro for aduN (b)
aurtace area fot haaoa. fontrmi. tod head (b)
I.SC abtoraHaa Ibeei IS* eulrli effect (d)
hated OB reaioMble aaiilauai expown of 20 • J/dey d)
SO* aerctellla for adult attki (b)
calln body atwewd for ekower
Mine fot valet (e)
llfht activity level (b)
Body «eltU for aauh(b)
(MM welahled avetafe value for developtag ehltdrea (e)
eK«aa Mai body aurfece area fa child S-IS yn (b)
aurfaea area for haada. foreanni. aad hud (b)
vemt deumlaed far eoMla( toll (c)
I.J* abaomtloa IbMi IS* auirii effect (d) '
IBM wclabted cakulaled vane for chlldna (b)
anuatcd fot calltfrea
BMdlta total body eurface ant for child S-IS yn (b)
ealln body aiauaud for ahower eoreulltod la BW
value for water (c)
light activity level (b)
Tbae-wclfhted average body weight for developing child (b)
100* of avenge Mly dote of 200 mgfday fat youag cUU (a)
SOtheerctallle for adult (b)
wrface area fot haada. forearma. ud head (b)
value delemlaed for pollliHj toll (c)
I.S* ibiorptlaelbnei IS* mtlrli effect (d)
hated ee tuionibte aMtlmum aipoaun of 10 ml/day (g)
inuaMd fot ehlMtea
aaedlaa total body *urf*ce area lot child S - t yra
-------
TABLE 8-4 (con11)
HUMAN HEALTH EXPOSURE ASSUMPTIONS FOR THE FUTURE
LAND USE SCENARIO AT THE HUNTERSTOWN ROAD SITE
Hour*
Rcctptoi EipotOTO Donate* petlHy Medium
Prthway
Ptnmder Vcjue Unili
CommenU
ommiacenou
Ncar-eKelUaldtMa:
7d»y/wt.50wt/yr. 50yn
•0*vtlafl*|
0.15
74ayAnA, 50*4jyr. SOyr* 0.15
4daytot.Mwkyyr.50yi* I
1 daytat, M «*/yr. SOyre Irritate*1 Sell
2day/vk. 24wUyt.50yn 4
7dayfet.50wt/yr.50yn M
7dayAwt.50wk/yr,50yi*
7daytafe.50wk/yr.lOyre 0.25
hkilMlo«(ikowei)
h|CMlM Rile
Bo«y Surfie* Ana
DtnMlOMMI
2 L/diy
I.M •!
100 %
O.OOOt
0.«
20
100
II*
iciMMuble waM-c«M v«lue for i*ilu (b)
MIAAemet
0.25
20
10
7deyrwt.50«t/yr.50yr*
4day/*t.M»tSyr.50yre
0.1S
I
4 day/**, 24w*jyr.5«yri
3D
CO
o
00
GO
ro
CD
Tday/vk. Mok/yr. lyn 0.25
44qrtat.M«t4v.5)n* I
4*7/M. M*t/)rt. 5jm
bk«UUU<»)
hcU(Mtlh|MJ«
A. toUrtea HM! OOdaaca lor Soil b«ea1l«* tatei. Me«ora*Jluaa from I. W. Forter dated laauary 27. IH*.
IH*. BifOOiamPaclora lliaft.it. Office W HaiMb and Ba»lroa«nalil Aaaaaaaaca*. BPA/tWI-tMU
(e)UI BfA. IVM. »Tar*j>d ttiftmu Aiiiia«e»l Maainl. BFA/WWI-iMWI.
(d)Ha«Uy. I. IMS. Aiaiia^Ml rf Hu>> MA AaaetUltd WHt toyou* to CaiUaitnaltd Soil. Uak Aulyili. 5:2I»-102.
(a) U.». »A. ItM. luMard Aniiai(
etfln tod? .uuK4 for *o«er
¥ftae fw ».lcr (c)
kiie4tcUMm(i>
.re.orku4>, torunii. Md ku4 Mrmllicd la B W (b)
•iwaiedrorcklldn*
wdlia loUl kedy mrfwe
-------
TABLE 8-3
HUMAN HEALTH EXPOSURE ASSUMPTIONS FOR THE CURRENT
LAND USB SCENARIO AT THE HUNTERSTOWN ROAD SITE
Receptor Bipown DuretkM
Houn
p« Dty
Medium
Ptthw«y
Parameter Value Unit*
Comment*
OHSnaUBCBTTOM
Vl*of
1 fcyfet. 11 wWyt. U yn
- *«**'• MIN
Urn-Ik.
7*y/»t. WMt/yr.Myn
twbc. SelU
bgculMlUt.
•o«> Smfw* Ant
1ST
0.1$
rr. Wyn 0.25
44kvM.MwWyr.Myn I
I4feyM.S4vWyr.10yn
DMMllOMUCI
Bo4yl«fK. AIM
AkMtyllMi IW*
h«cii)MllM*
% Am B»»ml
OoUAAeme.
7 «***.» •*»*•'•"•
MtUltailUM
0.0141
0.21
I.U
M.S K|
2
I.M
100
0.0001
0.4
100
0.0141
0.21
20
70
•2
ca/hr
•lAr
K/hr
«i
•mite Mlly eoM oocmillied to BW (t)
UU MitMlIk for eklMita lie* 1 to II (k)
MM of hMM. foKinu. u4 kud eoraulliea' to BW (k)
wm> for Mil. 2.77 K|tal for MWBCM (c)
I.SK MOM*UM UaM UK «tri« effect (d)
II* kowty QMioir hkMttloa nU foi *4uru (b>
WWM.O «»"«
7 *»**,» •**(. »M»
•* I*
? **fttX »wVyr.
•.a
i
4
M
0.21
7 Mytek, » «Wyf. S yn 0.2S
4 Myfok. 14 «Wyr. 1 yn
4M}M,M«Wyr.lyn
4 Myfok. M wWyr. 1 yn
44*ytat. 24«Uyr. Myn
4 **/•*. 14 «*/yr.
7oHyfok.10wWyf.Myn
74iyM.IOwWyr.$yn
to* MM* AIM
htilillni ftl- i-J
Bo4y Swfoco An*
KAraiBiMOe4
kh>Ullo*IUI*
7MyMt.WMVyi.lyM
4
14
SoUAoVieaco
0*4 4HM) MMlltlM lUt.
Bo4yWel|kl
2 L/«ty iiw«e4 for chlldra*
l.4t •! ou4luloUlko4yMrfK«.re«rorcUI4}-llyn(k)
101 K Mtlio koo> uumtt fcr Mowtr •onullicd to BW
0.000* ciWhr *.|M CM v«IM (et
•.« dl/hf WK4 a* light KtlvHy level (b)
Ml nJ/My lkMvcl(kic4cilculUc41«ikiororcUldRa(k)
IN at/My IbMi w«l|klc4 twnft vihiti for 4tvclof>ii* chlldreo (i)
21.1* K MMOfkMM.r«t*n». M4ke44*onBilUc4loDW(b)
0.0141 K|ta2 »•!». for Mil (e)
0.21 HAf I.IK ibMtyUc* llmci UK outrit effect <4)
21.2 «iV4iy Ito. welfhted cikvltud vthM for chlldni (k)
M.1 Kf ltaMw.lfkt«4.v«™t.»il«ifot4tvelopta«xkllJi«l(b)
1.1 LMty iiwoMd for tUMfci
0.71 •! eHMNuitoUlM4>«irfMeireiforcktU}-«yn(k)
100 « mln kodytwubu4 for Wtk
0.0001 coWkr vilw for witcr (c)
0.4 •!/» k«K4 on ll|k««llvll> level (b)
20 oil/ay ibM vcl(klc4 cikiilMe4 «I|M far youns cUI4na (k)
200 «I/4«y vikwforyoua|
-------
TABLE 3
CARCINOGENCIC AMD TOZICITY ASSESSMENT DEFINITIONS
and systemic risk for •the Risk Assessment Report available in the
Slope factors (SFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risk?
associated with exposure to potentially carcinogenic
contaminant (s) of concern. SFs, which are expressed in units of
(mg/kg-day)'1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure -at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the SF.
Use of this Approach makes underestimation of the actual cancer
risk highly unlikely. Slope factor is are derived from the results
of human epidemiological studies or chronic animal bioassays to
which animal- to-human extrapolation and uncertainty factors have
been applied (e.g., to account for the use of animal data to
predict efforts on humans) .
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
contaminant (s) of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of Mg/kg-day, are estimates of
lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of contaminant (s) of concern from
environmental media (e.g., the amount of a contaminant (s) of
concern ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans).
Weight of Evidence Classification for Carcinoqenicitv
Group Description
A Human Carcinogen
Bl or Probable Human Carcinogen
B2 Bl indicates that limited data is available, while B2
indicates that sufficient evidence in animals and
inadequate or no evidence in humans
C Possible Human Carcinogen
D Not classed as a human carcinogen
E Evidence of noncarcinogenicity for humans AR308822
-------
TABLE 4
TABLE 4-4
CARCINOGENIC TOXICirY DATA
Cancer Slope Factors
Cireiaogea (mg/Kg/diyH
COMPOUND f—Tfr~*i-n Source Oral u>..i^v». Source
METALS
Lad B2 BUS
Selenium B2 HEAST
Cadmium _ BI BUS _ 6.1 IRIS
Chromium _ A _ DOS _ 41 IRIS
Copper _ __ _ D _ PUS _ __ _ _
Manganeac D IRIS
Zinc
Maroay _ D _ IRIS _
Barium _ _
VOLATILE ORCANICS
Vmyicfalorid* A HEAST 1.9 0.294 HEAST
Otooethn* _ _ . _
l.l-Dichlorocthaac _ C PUS _ 0.6 _ 1.2 . IRIS
1.1-DichtoTOcdaac _ C BUS _ __ _ __ _
U-DJehtoroatfaea* _
U-DichloroBttoa* _ B2 _ HEAST _ 0.091 _ 0.091 IRIS
2~Butuoa* . D OUS
LU-Trichloroctfame D IRIS
Triemorottfacae _ B2 _ HEAST _ 0.011 _ 0.017 HEAST
LU-Triehlorocdune C BUS 0.057 0.057 BOS
T«trachloroghea» B2 HEAST 0.051 0.00182 HEAST
Tolmo» . D BUS '
EaylBaareae D BUS .
Xylmm • ' - D BUS ; •. ' '
SEMIVOLATILE OROANICS N
Bu(2-
-------
TABLE 5
COMPOUND
TABLE 4-5
SUMMARY OF TOXIOTY ASSESSMENT
Chrooic
Reference Dose* Ctaoa Slope Fecton
ng/Kg/d«y (ng/Kg/deyH
Source
Source
Onl
Onl
METALS
Lewi
SHrninm
Antimony
r..4»™..
Chromium*
Copper
Mangaaew
Zinc
Mttcmy
Barium
ND
ND
0.000*
0.0005
. -1
0.0*
O.I
03.
0.0003
0.05
ND
ND
ND
ND
S.7IE-07
ND
1.14E-04
ND
8.57E-05
0.0001
nus
nus
BUS/BEAST
HEAST
nUS/HEAST
HEAST
HEAST
HEAST
6.1 nus
41 nus
.
VOLATILE ORGANICS
Vinyl chlorine
Chlotaetfaaae
1.1-DicUonwhene
1.1-Dfchtooethane
1,2-DichloToetfaene
1.2-DicUoroethane
2-BntaneM
t.l.l-TriefaioroedMW
Tricblotoethene
LU-TrieUoroedHae
< Mediyl-2-pcnuaoaB
locncUotoecDe&e
Toluene
Ethyl Benzene
Xylene.
ND
ND
0.009
0.1
0.01
ND
0.05
0.009
ND
0.004
0.05
0.01
0.2
0.1
2
ND
0.029
ND
0.1
ND
ND
0.09
OJ
ND
ND
0.02
ND
057
0.29
O.OU
HEAST
QtlS
HEAST
UUSmEAST
OUS/HEAST
OUS^CEAST
DUS
DUSmEAST
nus
OUS/HEAST
DUS/HEAST
DUSAffiAST
1.9
0.6
0.091
0.011
0.057
0.051
0.294
1.2
0.091
0.017
0.057
0.00182
HEAST
nus
DUS
HEAST
nus
HEAST
SEMIVOLATILE ORGANICS
0.02
ND
nus
0.014
nus
PESTICIDES
DOT
0.0005
ND
nus
OJ4
nus
ABBREVIATIONS
BUS- bttftu«iXi*!aibimi!taaSjr«em
HEAST - Heeith Egectt Oiiiiiiiiiiini Sumn
* « CDXOBXIIB ui toxicsy VUOM WCTB UMB tot
Table* 1991
*I tooDCiQr VUBM
ND-ao4atB
NA-aotepplicaek
UMB rar cvcoQfBuc cfioctt*
-------
TAIIUiS-l
SUM. AI.TKKNATIVKS TOST SIIMMAMY •">
IHINTKKSTOWN NOAH sri >:
H:AS|||||.| IV STUDY
Ifeacriptlo*
UnilCotllc'
Medium)
Stressed Vegetation Am
Medium 4
Borrow Area
Mediums
Lagoon Ate*
Medium 6
South Cornfield Area
Medium 7
North Cornfield Arc*
Medium 1
Pram Bwial Ai«* 1
Medium 9
Drum R*vial Area 2
Area
(Sf)
S.IOO
i
J2.0J10
ift.nno
161.0110
22I.OUU
44.MBI
ViilMm
(CV)
4011
1.71X1
i.»n
7.000
9.0JW
AllerMllve No.
1
..Wl
..
..
•
..
..
2A
$VSF
S001M
JOI6M
to MM
$0.11 M
SIMM
<9
2H
$I2/SF
$0 06 M
SO 11 M
M 19 M
$1.94 M
S2.?4 M
$0)1 M
3
Min/ry
$0.12 M
tl 17 M
$3I9M<"
$J 65 M
$7 26 M
..
•
4
S6S4/CY
S0.26M
SI.IIM
S078M
$4 51 M
S5.I9 M
5
HJVCY
$0.17 M
$11 74 M
$O.S2 M
$1 01 M
$190M
«
S29IICY
$0.12 M
$051 M
$0.16 M
$209M
$26RM
-
CO
CD
CO
CO
: (•) Tmis shown mt cUlmMed taptlal MM! tmnalMM A nuifricnancc pfCHiri wiirth cinls (in millions of dollars). Tor this feasibility study, il is assumed thai both ihe
toil and f mundwaler alternative* will he Implemented in conjunction with each other. Ilius. costs shown do nm include grnundwater monitoring and deed
resiriclions hecause Ihesc c«m» are actounied for In the groundwaier alternatives .
(b)Allemalive I -NoAction !
Alternative 2A -SoilCover
Alternative 211 - Low Permeability Tap System
Alternative ) - l!»cavale and Treal/Uispose Off She
Alternative 4 . n»cavaie/Suhlllie On Slle/l>l»pow Off Site
Altemallve S -Ricavale. Soil Washing, and Dispose On Site .
Alternative 6 - In Situ Suhilizalirm
(c) Rw this feasibility study, unit costs fur the various aliemallves were developed using the l-agoon Area; refer to Appendix II for detailed costs analysis.
(d)' •-" indicates nm applicable
(e) IHW this feaslhilily study, the Alternative 3 treat/dispose method for the lagoon Area soils is incineration at a unit cost of S2.6S7/CY. Tor all other soil media, (lie
Aliematlve 3 treat/dispose method Is subiliialion and landfilling.
If) I'revkNis remedial atlivilies fm Medium 8 - Unim llurial Area I incluilcd hatkfillini! the arcj with clean soil fiilliiwing ilium icmiiv.il activities I hcrefiire. a noil
cover already exists for this aic:i Subsequently. Alicniiiiive 2 A for Medium A • I Hum llurial Area tnmisi imly ol insliiiiiiiMiiil controls such as fencing, deed
restrictions, and existing cover inaiiileiiiince. Net present w«Kth c«»ts associated with this ultcniativc w d hv niininiid.
S
o\
-------
APPENDIX D
AR308826
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Appendix D
RESPONSIVENESS SUMMARY
Hunterstown Road Superfund Sit*
Straban Township, Adams County, Pennsylvania
The Public Meeting Summary for the Hunterstovn Road Superfund
Site (the Site) is divided into the following sections:
SECTION I
SECTION II
SECTION Xir
Overview
This section summarizes recent actions at the Site
and the public's response to the remedial
alternatives listed in the Proposed Remedial
Action Plan (Proposed Plan). The Proposed Plan
outlines various cleanup alternatives available to
address Site contamination and highlights EPA's
preferred alternative.
Background on Community Involvement
This section reviews the history of community
interest and involvement in the Hunterstown Road
Superfund Site.
Summary of Major comments and Questions Received
During the Public Comment Period and EPA's
Responses - This section provides a summary of
commentors' major issues and concerns, and
expressly acknowledges and responds to those
issues raised by the local community. "Local
Community" may include local homeowners,
businesses, the municipality, and often
Potentially Responsible Parties (PRPs).
I.
Overview
In December 1991, EPA and the Pennsylvania Department of
Environmental Resources (PADER) approved the Remedial
Investigation report for the Site, which were developed by
Westinghouse Corporation. The Feasibility Study was completed
and approved in March 1993, and EPA subsequently released the
Proposed Plan for the Site on April 24, 1993. EPA held a public
meeting on Wednesday, May 5, 1993, at the Cumberland Township
Municipal Building to present the Proposed Plan and EPA's
preferred alternatives to the community. At this meeting,
community members had an opportunity to ask questions and make
comments regarding the results of the Remedial Investigation and
Feasibility Study and the cleanup alternatives listed in the
Proposed Plan.
EPA's preferred alternatives listed in the Proposed! Bi*n g g o 7
-------
addressed several areas of Site contamination including: ground
water, soil and surface wastes, surface water, and stream
sediments. EPA combined elements of the different alternatives
listed in the Proposed Plan to develop its preferred
alternatives.
The 30-day public comment period for the Site originally ran
from April 24, 1993, to May 24, 1993. However, due to a timely
request for an extension, EPA added an additional 30 days to the
comment period. The public comment period ended on June 22,
1993. Based on comments received during the public comment
period, EPA believes that most residents are generally supportive
of EPA's preferred alternative to address Site contamination.
However, some community members and Potentially Responsible
Parties have expressed concerns about various aspects of EPA's
remedy. The comments and questions received during the public
comment period, along with EPA responses, are listed in Section
III of this document.
II. Background on Community Involvement
Community interest in the Hunterstown Road Superfund Site
dates to 1980, when residents noticed, the accumulation of
deteriorating drums on the Site property. Interest in the Site
increased in 1983 when the Adams County Community Environmental
Control Office filed a complaint with PADER. After contamination
was discovered, local residents organized a group called the Good
Neighbors Against Toxic Substances (GNATS). The GNATS, which
represent concerned citizens in the area, have established an
ongoing community organization dealing with local, state, and
federal officials.
In June 1986, and September and December 1990, EPA conducted
community interviews with local residents and officials to
determine public awareness of and concerns about the Hunterstown
Road Site. EPA used these community interviews to develop a
Community Relations Plan. The Community Relations Plan addresses
community concerns about the Site and guides two-way
communication between EPA and the Site community. Residents and
local officials expressed concern about the impact of Site
contamination on the community. The major concerns included: the
roles of state agencies and EPA; the relationship between the
community and the potentially responsible parties (PRPs); ground
water contamination migrating off-site; health hazards.associated
with contamination; and development in the area. The interviews
revealed that community members were very familiar with the Site
and the Superfund process. However, some residents were
concerned with what they perceived as the slow progress of
cleanup actions.
EPA held public meetings before and during the initial
AR308828
-------
Remedial Investigation work to inform residents of current and
future Site activities. Attendance at these meetings, in March
and May 19.9.0, was average and consisted of both local officials
and residents. EPA distributed informational fact sheets in
August 1990, January 1991, and April 1993 to update the residents
of ongoing cleanup actions at the Site. Several informal
meetings with the citizens group were conducted over the past
several years. EPA has also met several times with local
officials to discuss the Super fund Sites and EPA's progress.
III. Summary of Major Comments and Questions Received During the
Public Comment Period and EPA's Responses
This section provides a summary of commentors ' concerns, and
expressly acknowledges and responds to comments made by the local
community during the local community during the public meeting
and comment period. The major comments made regarding the
proposed remedy for the Hunterstown Road Site can be grouped into
four categories:
A) Summary of comments made during the public meeting.
B) Comments submitted by the Commonwealth of Pennsylvania.
C) Comments submitted by residents and citizen groups.
C) Comments submitted by Potentially Responsible Parties.
c Meetjy"
This section summarizes maior comments and questions from
the public meeting on the Hunterstown Road Site and EPA's
responses to them. For additional details, see the attached
transcript of the public meeting. .
Proposed Remedial Action Plan
1. COMMENT: Is the Pennsylvania Department of Environmental
Resources (PADER) in agreement with EPA's preferred
alternatives for the Hunterstown Road Site? (pp. 35-36)
EPA RESPONSE: PADER had several weeks to review the Proposed
Remedial Action Plan for the Site, including EPA's
- preferred. alternatives. At the public meeting, PADER
expressed general agreement with the Proposed Plan presented
by EPAl*
2. COMMENT: Is it possible to extend the public comment period
for the Hunterstown Road Super fund Site? (p. 47)
EPA RESPONSE: Upon written request, EPA can extend the
AH308829
-------
public comment period an additional 30 days. (EPA did
extend the comment period to June 22, 1993)
3. COMMENT: What is EPA's definition of "the Site" as it is
used in the Proposed Plan? (p. 49) [Residents were concerned
that the ground water plumes extended widely and asked if
contaminated ground water under their properties would
technically make them PRPs.]
EPA RESPONSE: "The Site" as defined in CERCLA encompasses
all areas contaminated from known Site contaminants. EPA •
explained that it was not policy to notice residents as PRPs
for ground water that migrated to their properties through
no fault of the resident. EPA did explain that CERCLA does
give EPA the authority to order access to such residential
properties if not granted access to remedy the problem.
4. COMMENT: When will EPA determine the placement of the
proposed additional monitoring and extraction wells? (pp.
56-59)
EPA RESPONSE: The Hunterstown Road Site has a complex
geology which makes it difficult to determine the exact
extent and configuration of the ground water plume.
Because of this technical uncertainty, EPA will need to
collect additional data during the remedial design phase of
the cleanup to determine well locations. Additional
adjustments will have to be made during the remedial action
phase based on incoming data. Furthermore, EPA may need to
place monitoring and extraction wells on private properties.
EPA feels that a premature decision on well locations may
create unnecessary tension and conflict in the community.
It is EPA's practice to cooperate with the community to
avoid any unnecessary inconveniences. . .
5. COMMENT: What plans does EPA have for identifying and
monitoring contaminated ground water that re-emerges off-
site? Will the ground water plume reach the Gettysburg
municipal wells? (pp. 59-60, 75-76)
EPA RESPONSE: EPA or the Potentially Responsible Parties
(PRPs), with assistance from the United States Geological
Service (USGS), will place monitoring wells in off-site
areas identified as the potential ground water discharge
area for Site ground water. If contaminated ground water is
detected, it may be necessary to expand the ground water
remediation to this area. Gettysburg municipal veil #5,
which is south of the Site along Hunterstown Road, is the
only well close enough to warrant attention. The USGS and
AR308830
-------
EPA feel that well #5 is too far east of the contaminated
ground water plume to be impacted because of the bedding
plane orientation of the geology. The bedding planes
substantially restrict ground water movement in the
direction of well number 5. EPA has discussed the locations
of the municipal wells with the Gettysburg Municipal
Authority, and except for well number 5, all of the
municipal wells are near the center of Gettysburg, or are
west or south of Gettysburg.
6. COMMENT: Explain the following statement, from page 10 of the
Proposed Plan: "EPA usually considers remedial action
necessary for soil areas based on future use." (pp. 67-69) .
EPA RESPONSE: EPA requires risk assessments that evaluate
different risk scenarios and probable exposures to
contaminants. One scenario usually evaluated is future use
that is generally based on the land use of the surrounding
properties (residential, farmland, industrial). The most
conservative risk assessment scenario for future use assumes
that the Site will be used in the future for homes. If the
risk is unacceptable for a scenario, EPA will generally take
an action to reduce the existing risk to a risk appropriate
to the community setting surrounding the Site.
7. COMMENT: Explain which contaminated ground water plume, on
the Site property or off the Site property, was used in
calculating the future use scenario with children in the
Risk Assessment. Does this calculation include placing
institutional controls off of the Site property? (pp.69-70)
EPA RESPONSE: The future use scenario in the Hunterstown
Road Risk assessment assumes that children are living on-
Site and drinking well water from the most contaminated
section of the contaminant plume, which represents a worst
case scenario.
8. COMMENT: In its future land use assessment of off-site
areas, did EPA consider the possibility of residential land
development (which might include well construction) in areas
with ground water contamination? (pp.71-72)
EPA RESPONSE: The Proposed Plan calls for the cleanup of all
ground water up to 800 feet that is contaminated above
background levels. There is no practical legal mechanism
to place deed restriction on properties surrounding the
. Site. EPA has in the past sent letters to land owners
contemplating development of homes on property near the
Site, to warn them of their potanti** liability'. EPA will
• - - "> V : •-.''- « " " .-
AR30883I
-------
continue this policy in the future.
9. COMMENT: Did EPA and Westinghouse Corporation explore all
available cleanup technologies, including innovative cleanup
technologies, for ground water remediation before choosing
its preferred alternative and releasing the Proposed Plan?
(pp.72-74)
EPA RESPONSE: Westinghouse Corporation, with EPA oversight
and approval, evaluated a sufficient number of major, proven-
cleanup technologies for ground water cleanup that are
potentially applicable the Site. EPA does consider
innovative cleanup technologies, but also must consider
their reliability based on past success or failure.
\
t
10. COMMENT: What deed restrictions would be placed on the
Shealer property where the contaminated ground water plume
has spread? (pp. 76-77)
EPA RESPONSE: EPA's primary concern would be to restrict the
ground water use on the Shealer property. However, EPA
would also place restrictions on any areas of the Shealer
property with a soil cover, to prevent damage to the cover.
The soil cover areas would be fenced and reseeded.
11. COMMENT: A resident suggested that Westinghouse Corporation
should be required to remove the contaminated materials from
the Site as opposed to covering them. The resident felt
that tougher EPA laws could make a difference in
discouraging similar incidents in the future. .This resident
believed that EPA should have different cleanup requirements
for responsible, party leads, than for sites that are cleaned
up at taxpayer expense. The resident suggested that if
responsible parties are in favor of containment remedies,
then they should contain the hazardous substances on their
own property. An additional comment noted that the resident
was not in favor of the geonet/soil cover construction, (pp.
77-78, 80-81)
EPA RESPONSE: EPA explained that EPA merely carries out
the environmental laws promulgated by Congress. EPA applies
the same standards and policies regardless of whether the
work, is performed using the CERCLA trust fund (Super fund),
or is performed by responsible parties. Residents who would
like to see basic changes in the Superfund Act should
contact their elected officials.
EPA has developed policies that balance risk reduction
expense and efficiency. Hazardous wastes and highly
-------
contaminated soils, sediments or ground water are usually
treated to permanently reduce their toxicity, mobility or
volume. Large volumes of wastes, soils, or sediments with
relatively low levels of contamination are generally
contained rather than treated. Professional judgement must
be used between these two extremes.
Large volumes of wastes containing heavy metals including
lead were disposed at the Hunterstown Road Site in the North
and South Cornfields. One type of waste was a pigment used
to produce china, one waste was derived from rocks known as
feldspars imported from Canada for ceramic tile production,
another waste was derived from water treatment sludge from
printing inks, and another source was lead based paint.
Although these wastes do contain lead and other metals, the
metals are not very soluble and are less toxic that
compounds found in lead batteries or many other sources of
lead. Metals have not been found in ground water during the
investigation. The n\fln*|Tig!al average level of lead is below
EPA's action level, but numerous "hotspots" and the presence
of other metals justify a containment remedy. The least
expensive treatment alternative would be in excess of twelve
million dollars, and would accomplish little additional.risk
.reduction at. great expense. .
12. COMMENT: Explain the purpose of the geonet? (pp. 79-80)
EP& RESPONSE: The geonet is essentially a permeable plastic
cloth placed as a ground cover and buried by approximately
one foot of soil cover. The geonet is a visual indicator for
the EPA project manager to detect soil erosion. If the
geonet becomes visible, which can happen over time, then
erosion has occurred and maintenance of the soil cover is
necessary.
13. COMMENT: Will the Site be disturbed when the geonet is
installed? (pp. 80)
EVA RESPONSE* There will be some earth moved to remove the
vegetative cover and regrade the land. The geonet will be
place on the graded land, and one foot of topsoil will cover
the geotextile. The topsoil will be seeded and a new layer
of vegetation established.
14. COMMENT: How does EPA plan to "seal the edges" of the soil
• cover to prevent contaminants from migrating out of the
cover areas? (pp. 81-82)
AR308833
-------
8
EPA RESPONSE: The soil cover will extend slightly beyond
the contaminated areas to prevent exposure to contaminants
in the covered area. The purpose is not to keep
contaminants (metals) from migrating because they do not
appear to be migrating. The purpose is to prevent contact
with contaminated soils.
15. COMMENT: How does EPA intend to cover and maintain the
wetlands areas which are proposed for soil cover? (pp. 82-
83) .
EPA RESPONSE: The wetlands areas will not affect the
effectiveness and maintenance of the soil cover. If some
areas of low elevation remain, wetlands may be re-
established on the soil cover. However, the soil cover may
create areas that do not support wetlands vegetation as well
as in the past. As part of its selected remedy, EPA will
create a wetlands area on the Site.
16. COMMENT: How often will EPA monitor the discharge from the
proposed pump and treat system? (pp.83-84)
EPA RESPONSE: Sampling the discharge from the pump and treat
system would follow the standard National Pollutant
Discharge Elimination System (NPDES) monitoring process of
once monthly. However, the exact details of the pump and
treat discharge monitoring will be finalized during the
remedial design.
17. COMMENT: Will EPA hold a public comment period and public
meeting during the remedial design phase regarding the air
stripping tower.? (pp. 84-85)
EPA RESPONSEt Though a public comment period and public
meeting are not required by law, EPA will hold a public
meeting to discuss the progress of the Site remedial design.
EPA anticipates scheduling a meeting upon the completion of
30% of the remedial design.
18. COMMENT: What is the reference point (or beginning point)
for the implementation timeline outlined in the Proposed
Plan? (pp. 85-86)
EPA RESPONSES The implementation timeline outlined in the
Proposed Plan begins upon the completion of negotiations
with the PRPs. The timeline includes both the remedial
design and remedial action.
<...-'. ftR30883U
-------
19. COMMENT: Are the PRPs apportioning financial responsibility
for-cleaning up specific areas of the Site? (pp. 87-88)
EPA RESPONSE: No official agreements have been made between
EPA and the PRPs to date for the RD/RA; however,
negotiations will begin following the release of the Record
of Decision. Historically, the PRPs for the Hunterstown
Road Site have come to an agreement among themselves to
apportion costs by area of contamination on-Site. EPA
encourages cooperation between PRPs during the negotiations,
but EPA is primarily concerned with the complete funding of
the remediation and proper cleanup of the contaminants.
20. COMMENT: Residents at the public meeting were concerned that
EPA provide proper Site security, such as maintaining the
Site fence, and conducting routine Site inspections, (pp.
88-89)
EPA RESPONSE: The area on the west side of Hunterstown Road
does not pose a threat since the removal action has been
completed and since the Drum Burial Area 1 has been
backfilled. The West Stream is not contaminated and EPA
plans no future action for this stream. .
The lagoon area has a chain link fence around its
perimeter, and the fence has been kept in good condition.
A hogwire fence encloses the borrow area, the stressed
vegetation area and the south cornfield and although there
have been occasional problems in this wire fence, access to
the site by small children has been limited. The primary
problem has been maintenance of a fence around the North
Cornfield and maintenance of silt fences and tarps in the
stressed vegetation area. EPA will attempt to provide
better site security during the remedial design, and after
the remedial action is completed, the contaminated areas
will be covered and fenced. Site security will be an
important requirement whether the future work is performed
using the trust fund (Superfund) or by PRPs performing the
work under a Consent Decree or Unilateral Order.
21. COMMENT: Is the geonet and soil cover considered a permanent
remedy for the Hunterstown Road Site? If so, who will
oversee its perpetual care? (pp. 91)
EPA RESPONSE: The residents primary objection is to all
containment remedies, sinew they do require perpetual care.
The residents are very concerned about the impact on
property values due to the presence of waste at the Site and
the restricted use of the property.
This is a permanent remedy for the Site so long as the soil
AR308835
-------
10
cover is maintained, it is not as permanent as excavation
off•site disposal of wastes. The Responsible Parties or EPA
will oversee the site maintenance.
Remedial Investigation/Feasibility Study
1. COMMENT: Why does the Remedial Investigation data indicate
higher concentrations of contaminants in areas further from
the source of the buried drums? (p. 18)
EPA RESPONSE: The question, is related to why contamination
is higher at greater depth in the aquifer below Drum Burial
Area 1. EPA's records indicate that very large amounts of
solvent were disposed in both Drum Burial areas and in the
Lagoon Area. As discussed in great detail in the Record of
Decision, EPA consulted with the U.S. Geological Survey and
requested that they review the RI/FS for the Site. The US6S
is very knowledgeable about ground water movement in the
Gettysburg area and the Gettysburg geology. The USGS and
EPA believe that most of the solvents have migrated to great
depths through fractures. This is why the concentration
increases with depth and is one of the reasons why EPA .
waived the cleanup requirement for ground water below 800
feet. "
2. COMMENT: What are PADER's acceptable limits for lead levels
in soils? (p. 36)
PADER RESPONSE: PADER's lead task force has debated the lead
level issue for several years and has not set an official
standard to date. Originally, the lead levels were set at
200 parts per million, but that has been revised upward to
500 parts, per million, which is now the same as EPA's policy
for lead in soils.
3. COMMENTS Since EPA has a policy restricting any potentially
responsible party (PRP) from conducting a Site Risk
Assessment, why was Westinghouse Corporation allowed to
conduct the Risk Assessment for the Hunterstown Road Site.
(P-46)
EPA RESPONSE: The policy to restrict PRPs from conducting a
Site Risk Assessment was enacted approximately one- and a
half years ago. The Risk Assessment for the Runterstown
Road Site was initiated prior to the enactment of that
policy. However, an EPA toxicologist reviewed, critiqued,
' and certified the accuracy and thoroughness of the Risk
Assessment for the Site.
RR308836
-------
11
4. COMMENT: How deep were the ground water monitoring wells
drilled and, in comparison, how deep are the Gettysburg
municipal wells? (pp. 51-52)
EPA RESPONSE: EPA tested the ground water to a depth of
approximately 500 feet below the earth's surface. Most of
the Gettysburg municipal authority wells are approximately
at a depth of 500 feet below the earth's surface. One well
is approximately at a depth of 600 feet and one well is at a
depth of 900 feet.
5. COMMENT: A resident noted a contradiction between the
Remedial Investigation and Feasibility Study concerning the
presence of asbestos in the Borrow Area. The Remedial
Investigation stated that no asbestos was detected in the
soil,, whereas the Feasibility Study indicated a presence of
asbestos in the same area. The resident wanted to know at
what depth were soil samples taken to determine the
concentration levels of asbestos in the Borrow Area? (pp.
64-65)
EPA RESPONSE: Following the removal of two piles of bulk
asbestos in April 1984, a plastic tarp and several inches
of soil cover was.placed over the Borrow Area..During the
Remedial Investigation, samples were taken in the Borrow
Area at the surface to determine whether any asbestos
remained in the area. No asbestos was detected, but, as
explained in the Proposed Plan, deeper samples should have
been taken. Since the Remedial Investigation detected some
metals in this area, and since post removal sampling did
detect asbestos, EPA has selected a soil cover for this area
and this will provide adequate protection even if
significant levels of* asbestos were present below the
surface.
6. COMMENT: What is the source of xylene and ethylbenzene
(which are common constituents of gasoline) found in the
Drum Burial Area soil? Is the presence of these contaminants
related to the underground storage tanks located on the
adjacent property? (pp. 65-66)
EPA RESPONSEt It is unlikely that the storage tanks on the
adjacent property are the source of the xylene and
ethylbenzene detected in the Drum Burial Area, EPA and
Westinghouse had several veils placed to determine if
contamination was originating from the area currently
operated by Fred Shealer. These wells did not detect
contamination from the Shealer area. The source was
probably discarded solvent, oil or gasoline dumped in the
Drum Burial Area 1 pit.
AR308837
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12
Policy Questions and Comments
1. COMMENT: Does EPA have the authority to perform work on a
property contaminated by a Superfund Site without the
owner's consent or to place deed restrictions on a property
where the owner is not considered a potentially responsible
party (PRP)? (pp. 49-50)
EPA RESPONSE: EPA does have the authority to protect public
health and it can issue a unilateral order under extreme
circumstances where a property owner is uncooperative.
However, it is not EPA's practice to exercise that policy
unless all other options are exhausted.
2. COMMENT: Can a property owner be considered a PRP if ground
water contamination from a Superfund Site migrates to their
property? (pp. 50-51)
EPA RESPONSE: It would be extremely unlikely for EPA to hold
an owner of a property responsible for the migration of
contaminated ground water from a Superfund Site to the
owner's property. A potentially responsible party is defined
as an individual or company (such as owners, operators,
transporters, or generators) potentially responsible for, or
contributing to, the contamination problems at a Superfund
site.
3. COMMENT: A resident was concerned that land developers,
realtors, and future home owners may not be aware of the
problems caused by the Hunterstown Road Site unless an
authority, such as EPA or PADER, places a land use
restriction to alert these people. The resident wanted to
know if EPA or PADER have the authority to restrict a
residential or commercial developer from drilling wells into
the contaminated ground water to access drinking water?
(pp. 52-54)
EPA RESPONSE: EPA would have to issue an unilateral order to
every person involved with the property in order to properly
inform them, which is seldom initiated unless extraordinary
circumstances arise. According to PADER, local government
can pass an ordinance requiring a developer to demonstrate
the availability of potable water before beginning any
construction. EPA uses its public information process,
such as public meetings and fact sheets, to keep people in
the affected community informed.
4. COMMENT: A resident requested that EPA initiate
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13
which vill require sellers of single family homes to provide
a disclosure statement which informs the buyer of any
potential problems associated with a Superfund site located
in the local community, (pp. 54-55)
EPA RESPONSE: This would require more than a policy and
would actually require legislation. EPA suggests that
concerned residents contact their elected representatives.
Remedial Action Questions and Comments
1. COMMENT: Were there any contaminants contained in the
treated water discharged into the Middle and West streams
during the Drum Burial Areas 1 and 2 removal action. If so,
was a permit required to discharge the treated water? (pp.
61-62)
BPA RESPONSE: The treated water from the Drum Burial Areas
which contained volatile organic compounds was discharged
directly into the West Stream. However/ the West Stream
merges with the Middle Stream, which did not receive any
direct discharge of treated water. . Because a NPDES permit .
can take years to obtain, Superfund actions are exempt from
the formal permit requirement for on-Site discharges, but
must comply with the substantive requirements of an NPDES
permit. EPA and Westinghouse requested limits from the
State and the PADER supplied the limits for the discharge.
This was a limited discharge and involved only the water
that had temporarily filled in the Drum Burial 1 excavation.
Miscellaneous Quest!'
1. COMMENT: How do citizens contact the EPA Office of the
Inspector General and an EPA ombudsman? Explain the purpose
for contacting either of these officials, (pp. 37-38)
EPA RESPONSE: The EPA Office of the Inspector General is
available for citizens who wish to file a complaint
concerning misuse of EPA funds, fraud, waste, and abuse
relative to EPA programs. Citizens can contact Martin
Squitieri, Divisional Inspector General for Investigations
at (215) 597-9421 or (800) 352-1973. (When calling this
number from a touch-tone telephone punch 79421 when the
recording begins.) The EPA OSWER Omsbudsman is available to
help resolve problems and concerns of citizens groups,
environmental groups, and the regulated community. The
Omsbudsman does not have authority over regional decision
makers, but can act as a facilitator to help resolve
disputes. The current Omsbudsman, Mr. Robert Martin, may be
contacted at 8-202-260-9361.
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2. COMMENT: Has the community been provided with an Agency for
Toxic Substances and Disease Registry (ATSDR) community
assistance panel:, health consultations, and health
assessments? (pp. 40-44)
EPA RESPONSE: ATSDR conducted a Site Review and Update (SRU)
which is a preliminary health assessment. EPA included the
SRU and EPA's written response to the ATSDR SRU in the
Administrative Record prior to issuing the Proposed Plan.
The purpose of the Site Review and Update is to evaluate a
site's current conditions and. determine what further ATSDR
actions are needed. The SRU will ensure that assessments on
sites with the greatest potential for risk to human health
get a thorough reevaluation The SRU helps ATSDR establish
review priorities needed to get the job done within a
specified time. ATSDR does not perform a full Health
Assessment on all Superfund Sites. ATSDR has informed EPA
that they do not believe that a full Health Assessment is
needed at the Hunterstown Road Site. The ATSDR will perform
a health consultation and update the SRU, which will involve
interviews with residents and examination of health outcome
data to see if any unusual incidence of health problems has
occurred among necr site residents.
ATSDR will complete the health consultation soon, but
because they are completely separate from EPA, the
assessments are completed within a time frame set by ATSDR.
When finished, ATSDR will use the consultation to make
recommendations to EPA, but EPA is not required to follow
those recommendations. EPA's primary tool for risk
decisions is the Risk Assessment which is reviewed and
certified by an EPA toxicologist.
3. COMMEMT: Will ATSDR complete the health assessment by the
release of the Record of Decision? (P. 44)
EPA RESPONSE: ATSDR does not prepare full Health Assessments
for all Superfund Sites. ATSDR and EPA have agreed that a
full Health. Assessment is unnecessary. The health
consultation will not be completed before the Record of
Decision. EPA is not under legal obligation to wait for the
results of the ATSDR consultation and EPA believes that the
Risk Assessment developed under EPA oversight, and the Site
Review and Update developed by ATSDR provide a sufficient
risk basis for the Record of Decision. This is particularly
true, since ATSDR does not believe that a full Health
Assessment is warranted.
AR3088UO
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e Commowelt
GENERAL COMMENT: The Pennsylvania Department of
Environmental Resources basically agrees with the preferred
alternative remedy at the Hunterstovn Road site as stated in
the Proposed Remedial Action Plan. We appreciate the
willingness of the Agency to work with the State and the
opportunities we were given to discuss and comment on the
remediation.
We offer the following comments as clarification of certain
points and as a statement of the State's policy on several
issues. We ask that these comments be included in the
administrative record.
COMMENT: Although the Residual. Waste Regulations may not be
applicable to all portions of the selected remedy, they are
relevant and appropriate and therefore are ARAR's for this
site and should be discussed in relation to the selected
remedy. More detailed discussion is needed concerning the
waste left in place. If waste is left in place in site
soils, the Solid Waste Management Act and regulations
promulgated thereunder should be discussed as ARAR's for the
site.: Contaminated soil is a waste. Thus, for example, we
disagree with statements on page 35 of the proposed plan
that the residual waste regulations "do not apply to soils
left in place."
EPA RESPONSE: Haste that is excavated will be handled as a
hazardous waste and since the hazardous waste regulations
are more stringent than the residual waste regulations, they
will apply instead of the residual waste regulations. Some
aspects of the residual waste regulations are relevant and
appropriate specifically 25 PA Code. S 287.101(d). EPA
believes that the soil remedial actions are protective and
meet the intent of this section.
PADER has also asserted in discussions with EPA that the
residual waste landfill requirements of 25 PA Code 287 and
288, specifically Section 288.621-.624 may be relevant and
appropriate. These regulations pertain to the operation of
a Class III residual waste landfill and would require that
operators of such facilities install a clay cap or membrane
equivalent cap (In addition, these regulations prohibit the
operation of Class III landfills in certain ares, provide
fox ">r"*niH« requirements for acceptable wast*, and provide
for an attenuating soil base.).
In determining whether a requirement is relevant and
appropriate, EPA must consider whether the requirement
addresses problems or situations sufficiently similar to the
AR3088U
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16 .
circumstances of the release or remedial action contemplated
and whether the requirement is well-suited to the site. In
making this determination, EPA must consider, where
pertinent, ths factors set forth at 40 C.F.R^ S
300.400(9) (2) . Following is a brief discussion, within the
context of each area, of some of the reasons why these
requirements are not relevant and appropriate:
Lagoon Area; Water flows laterally through the lagoon area,
and therefore, a cap would not prevent leaching. The ground
water level is very near the surf ace (wetlands) in a large .
section of the lagoon area (the most contaminated area.) and
would destroy a cap. Additionally, leaching of metals to
ground water is not occurring, and a ground water extraction
and treatment system will collect and treat any VOCs which
leach from shallow soils. Therefore, a cap would actually
retard the cleanup of soils for VOCs, and this requirement
is not well suited to the. conditions at the Site.
Stressed Vegetation Area: The contaminants in the Stressed
Vegetation Area are metals. The purpose of a class III cap
is to prevent leaching, and elevated levels of metals have
not been detected in ground water. The highest levels of
metals will be removed and treated further reducing the
potential for leaching of metals. Additionally, the 'ground
water in this area is also very near the . surface and the
area is considered a wetlands area. Installation of a cap
is not well suited to the conditions at the Site.
Drum Burial Areas: These areas have been excavated and drums
and contaminated soils disposed off -Site. The remaining
contaminants are in soil below the water table or
periodically below the water table. Installation of a cap
would not prevent leaching. A ground water extraction
system will collect and treat any VOCs which leach from
subsurface soils. Therefore, a cap would actually retard
the cleanup of soils for VOCs and this requirement is not
well suited to the conditions at the Site.
Borrow Area and Cornfield Areas: These areas contain soils
contaminated with moderate levels of inorganic contaminants.
The primary purpose of a clay cap is to prevent leaching,
and elevated levels of metals and inorganics have not been
detected in ground water. The risk in this area is from
contact and ingest ion, and the installation of a class III
residual landfill cap is not well suited to the conditions
at the Site.
COMMENT: Pennsylvania certifies that the. background ground
water quality ARAR becomes an ARAR for soil by reason of the
hydrogeologic link to the ground water from the s
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17 .
Soils should be remediated to ensure that migration of soil
contaminants to groundvater do not cause groundwater
contamination concentrations to exceed background cleanup
levels.
EPA RESPONSE: EPA does not agree that there is a
"background" ARAR for soil. EPA does take into
consideration the potential effect of contaminated soil on
ground water and selects soil cleanup levels that EPA
believes are protective of ground water.
3. COMMENT: The selected alternative for the Lagoon Area and
Stressed Vegetation Area indicates that the soil will be
excavated to a depth of two feet. We would prefer to see
the excavation depth based on the level of contaminants
encountered during the remediation.
EPA RESPONSE: Lagoon area soil was contaminated by surface
disposal of wastes. A previous action removed the wastes and
most contaminated soils. Although metals have not been
detected in ground water, metals contamination at the
surface is still high. Excavation of the top two feet of
soil, will.remove the highest levels of contamination from
the site and will protect ground water if future conditions
would become more favorable for leaching. The excavation
will be backfilled and in conjunction with a soil cover,
will provide substantial protection from contact with any
remaining metals. The area of the lagoon is the area where
residual solvents are most likely to be present in surface
soils and one sample contained significant levels of vinyl
chloride which can form from TCE and biological activity.
The ground water in this area is very close to the soil
surface, and the excavation of two feet of soil will remove
most of the soil above the ground water table containing
solvents. The ground water extraction system will collect
and effectively treat any solvents in the subsurface soils,
and solvent levels are probably actually much higher in the
fractured bedrock. EPA does not believe that additional
excavation would significantly shorten the time for
completion of the ground water remedial action. Further
excavation would not decrease the risk from contact.
4. COMMENT: In the site risk section of the plan (page 9) it
is stated that a 500 ppm soil lead level is considered
"safe* residential areas, and lOOtTppsr is considered "safe*
for non-residential areas. The Department feels that at
most this can be termed "EPA's action level, as current
research does not establish that these are "safe" levels.
Furthermore, lead is a carcinogen.
AR3088i*3
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18
EPA RESPONSE: EPA considers 500 ppm to be a protective
level for lead in surface soils for residential areas. This
is related to a safe blood lead level for children. A
biokinetic model correlated with lead in house dust with
blood lead. Lead is not a proven human carcinogen, it is a
probable human carcinogen based on animal data.
5. COMMENT: On page 10, the proposed plan states that "EPA's
trigger level [is] 1.0 x 10"4. A level of 1 x 10-4 is
contrary to the language of the NCP, Section 300.430(e) and .
(f>, and the NCP Preamble which state that the; risk range
level point of departure is 1 x 10-6. The preamble states
that: a cumulative risk level of 10-6 is used as the
starting point (or initial "protectiveness" goal) for
determining the most appropriate risk level that
alternatives should be designed to attain.*1 55 F.R. 8718.
Section 300.430(f) states that: "overall protection of human
health and the environment and compliance with ARARS (unless
a specific ARAR is waived are threshold requirements that
each alternative must meet in order to be eligible for
selection." Based on this language, it is the
Commonwealth's position that 1 x 10-6 is the legally
applicable risk range level.
EPA RESPONSE: The NCP states at 40 C.F.R. §
300.430(e)(2)(i) (A) (2), "For known or suspected carcinogens,
acceptable exposure levels are generally concentration
levels that represent an excess upper bound lifetime cancer
risk to an individual of between 10-4 and 10-6 using
information on the relationship between dose and response.
The 10-6 risk level shall be used as the point of departure
for determining remediation goals for alternatives when
ARARs are not available or are not sufficiently protective
because of the presence of multiple contaminants at a site
or multiple pathways of exposure." The statement on page 10
of the proposed plan is not contrary to the NCP.
6. COMMENT: On page 38 in the Compliance with ARARS paragraph/
it is stated that the no action alternative would comply
with state ARAR's. He believe that this was meant to mean
that wetlands ARAR's would be met. The no action
alternative does not meet Solid Waste Management Act or
Clean Streams Law requirements and regulations concerning
toxic fBrtryfr^jiKr^ff in the waters of the Commonwealth.
The disruption of the wetlands is also a concern. Attempts
should be made to replace the wetlands with plant species
similar to those originally found*
EPA RESPONSE: EPA agrees. An 308C
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19
7. COMMENT: On page 9, it is preferable to state that the scope
and role is, among the other stated objectives, "to
remediate the aquifer to the maximum extent practicable".
RESPONSE: EPA has made this change in the ROD.
8. COMMENT: On page 27, we believe that Section 121(d) of
CERCLA does require remediation that at least attains MCLG's
established under the SDWA, including zero MCLG's.
RESPONSE: Section 121(d)(2)(A) states in pertinent part as
follows, "Such remedial action shall require a level or
standard of control which attains Maximum Contaminant Level
Goals established under the Safe Drinking Water Act [42
U.S.C. S 300f et seq.]...where such goals... are relevant
and appropriate under the circumstances of the release or
threatened release." Similarly the NCP at 40 C.P.R. S
300.430(e)(2)(i)(B) states, "Maximum contaminant level
goals, (MCLGs), established under the Safe Drinking Water
Act, that are set at levels above zero, shall be attained by
remedial actions for ground or surface waters that are
current or potential sources of drinking water, where the .
MCLGs are relevant and appropriate tinder the circumstances
of the release based on the factors in S 300.400(g)(2). If
an MCLG is determined not to be relevant and appropriate,
the corresponding maximum contaminant level (MCL) shall be
attained where relevant and appropriate to the circumstances
of the release." EPA believes that attainment of zero-level
MCLGs is not possible and, therefore, zero-level MCLGs are
not relevant and appropriate. In addition, EPA will attempt
to attain non-zero MCLGs only where it is relevant and
appropriate given the circumstances of the release.
Accordingly, EPA does not believe that the statute requires,
in every instance, remediation of ground water to MCLGs.
9. COMMENT: We also note that the exhaust air stream from the
stripper may need carbon treatment unless the treatment
employed destroys all the VOC's.
RESPONSE: EPA does not agree that the treatment of the
effluent air will need carbon treatment. The purpose of the
catalytic oxidizer is to destroy the air emissions which
will be low even before treatment. The catalytic oxidizer
must meet applicable and relevant and appropriate ARARs.
10. COMMENT: We believe that the groundwater treatment system
should be operated until the contaminant concentration in
the groundwater reaches background or until it is
flR3088U5
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20
demonstrated that it is technologically infeasible to
achieve background levels.
RESPONSE: EPA's Proposed Plan and this ROD require
remediation of ground water contaminated above background
levels and at a depth above 800 feet until background is
reached throughout the area of attainment.
11. COMMENT: Lastly, we feel that it is very important to locate
and monitor the discharge areas where'the deep contaminated
groundwater may surface.
EPA RESPONSE: This was an element of the Proposed Plan and
is now an element of the ROD.
The comments from the GNATS citizen group on appropriate
remedies for Site conditions were not received during the comment
period. At the public meeting, the.Co-chairmen indicated that
they had already submitted their comments on the remedial actions
that they prefer for the site, based on the FS and conversations
with the Remedial Project Manager. Therefore, although they were
not submitted during the comment period, EPA will respond to
their comments in their September 28, 1993 letter addressed to
Frank Vavra, the Remedial Project Manager for the Site.
Comments Submitted bv the GNATS Citizen Group
(Donald Waddel and Merle Hankey Co-Chairmen)
GENERAL COMMENT: The citizens group feels that a complete
cleanup should be conducted, and that all the contamination
that can be removed should be removed rather than contained.
EPA RESPONSE: EPA has developed policies for implementing
the Superfund Sites and these policies are subject to review
and comment when new rules are made. Comments are received
from the regulated community, citizens groups and
environmental groups. Current EPA policy and guidance is
that contamination at low to moderate levels over a wide
area or volume should be contained and contamination at very
high levels should be treated. Between these two,extremes,
EPA must use judgement and consider the coat and risk
reduction achieved.
1. COMMENT: Drum Burial Area 1- It would appear form the RI
results that there still is some contamination in the soil
at a depth of two to four feet. I was of the opinion that
AR3088U6
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21
this should be removed in order to successfully restore
ground water. However, after discussing my concerns with
Frank Vavra, his logic appears to be satisfactory.
Therefore, the area should be capped with clay to prevent
future contact.
EPA RESPONSE: A clay cap would delay the cleanup of residual
soil contamination. The backfill prevents contact with
contaminated subsurface soils.
2. COMMENT: Drum Burial Area 2 - It would appear from the test
results that this area .has been satisfactorily cleaned up.
No further action is needed at this time.
EPA RESPONSE: No response necessary.
3. COMMENT: Lagoon Area - The test results for this area show
high levels of VOCs which consist of chlorinated aliphatic
hydrocarbons. For this reason and to prevent future .
migration into the ground water, this area needs to be
excavated and the soil disposed of off site in order to.
successfully treat the ground water. The area should then
be backfilled and capped with clay to prevent, future
exposure.
EPA RESPONSE: A clay cap would delay the cleanup of residual
soil contamination. The backfill and soil cover will
prevent contact with remaining contamination in subsurface
soils.
4. COMMENT: Stressed Vegetation Area - According to test
results, there is an elevated concentration of metals in
this area. This area needs to be excavated and disposed
off-Site. The area should be backfilled with soil and
returned to its natural setting, a wetland.
EPA RESPONSE: EPA agrees.
5. COMMENTS Borrow Area - Like Drum Area 2, it would appear
from test results that the area was satisfactorily cleaned
up. However, the area needs to be capped with a foot of top
soil to prevent future contact with soil.
EPA RESPONSE: EPA agrees.
COMMENT: Stream Sediments - It would appear that the East
Stream sediments contain contaminants. Due to possible
HR308814
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22
exposure, these sediments need to be excavated and
backfilled and returned to natural wetlands.
RESPONSE: EPA generally agrees, but backfilling is
unnecessary.
7. COMMENT: According to test results, the surface and
subsurface soil contains heavy metals not just limited to
lead. Also, detected.was mercury, barium, copper and zinc.
The human health-based levels are constantly changing for
these metals. Who is to say what they will be in two
months, or a year from now. The objective is to limit
contact by humans and ecological receptors. The top 12
inches of soil needs to be removed and replaced with topsoil.
to prevent future contact and these fields placed back into
productive use.
In 1986, the Superfund Amendments and Reauthorization Act
(SARA) required EPA to emphasize cleanup remedies that treat
rather than simply contain contaminated waste to the maximum
extent practicable and to use innovative waste treatment
technologies.
EPA Region III will soon issue the Record of Decision
(cleanup plan) for the Hunterstown Road Site. This is their
opportunity to choose a cleanup remedy that will adequately
protect the public from adverse health and environmental
consequences in the future. Please insist that cleanup
action is instituted that will permanently remove the toxic
waste from the Site rather than choosing a remedy that
simply contains waste. Containment remedies do not reduce
the waste volume, or toxicity and have not been proven
reliable to prevent their mobility.
Instead of allowing the waste to be contained on the Site,
the waste should be removed and treated or returned to the
facilities that created them.
EPA RESPONSE: Since metals have not: been observed in ground
water, the risk to human health is from contact exposure. A
fence and one foot of soil over a geotextile will prevent
human contact with Site contaminants even if health based
levels, changed. Health based levels are the trigger for
action -and EPA is taking an action for the Cornfields and
Borrow Area. •,..,
The numerical average mercury content in the Cornfields is
about 0.1 ppm. The Reasonable Maximum Exposure (RME)
mercury concentration the Cornfields is about 0.3 ppm. Some
background samples contained mercury as high as 0.06 ppm.
The numerical average lead level .in the cornfieldj|umfiri£gl n
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23
average level is about 300 ppm for twenty nine samples for
soils at a depth of less than two feet. The SHE lead
concentration in the Risk Assessment for the concentration
for lead in the Cornfields is about 330 ppm. Background
lead levels averaged about 60 ppm, and EPA's currently
approved safe level of lead in residential areas is 500 ppm.
The most conservative biokinetic model and the "Three Cities
Study" suggests that a safe lead level could be as low as
200 ppm.
The contamination in the Cornfields was related to a white
chalk-like material that is widely distributed in the
Cornfields. This white material was sampled and it was this
sample which yielded the high levels of lead (6500 ppm).
The Remedial Investigation report indicates that when
particles of this white material are present, the lead and
metals are high and when the white material is not present,
most metals are close to background levels. Westinghouse
informed EPA that this material will powder under stress and
could not be separated from soils by screening or other
mechanical techniques. The contamination is present as
numerous "hotspots" in the Cornfields and this pattern of
wide spread contamination of a very large volume of soil
suggests containment remedies are most appropriate even
.considering the SARA mandate for treatment.
Although the contaminant concentrations in the Cornfield are
sufficient to take action, the volume of waste and the cost
of treatment and disposal for the Cornfield Soils are very
high. The selected remedy is protective and cost effective.
8. COMMENT: After reviewing the entire draft Feasibility Study
and discussing the water treatment proposals with Frank
Vavra, it would appear extraction, with treatment by Aqueous
Phase Carbon Adsorption would be the best solution.
RESPONSE: EPA has selected extraction wells, but has
selected air stripping and catalytic oxidation as the
treatment for contaminants in the effluent air from the
stripper. Catalytic oxidation will effectively treat vinyl
chloride, while aqueous carbon adsorption will not.
GENERAL RESPONSE: EPA appreciates the interest and
assistance of the GNATs group, although EPA is unable to
satisfy the GNATs preference for the Cornfield remedy, and
several aspects of other selected alternatives, the GNATs
group has had a significant influence on the selection
process and the remedies that have been selected. EPA
appreciates the information and assistance given by the
GNATS group and looks forward to their continued involve|$$ 0 8 8 4 9
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"... 24
during the remedial design.
bv Mr. Donald Waddel
COMMENT: I have reviewed the Proposed Remedial Action Plan
many times since the Public Meeting of May 5, 1993, at the
Cumberland Township Building. We agree with the Proposed
Remedial Action Plan except for the South and North
Cornfield. The objective is to limit contact by human and
ecological receptors. The top 12 inches of soil needs to be
removed, and replaced with clean top soil to prevent future ,
contact and which would allow these fields to be placed back
into productive use.
RESPONSE: See above response to comment number 8
immediately above regarding the selection of the Cornfield
remedial action.
Llv Raatxai
• Comments Prepared for .{
Spectra-Kote Corporation;
Susquehanna Broadcasting Company;
Pal-Tile Corporation;
and Inland Container Corporation bv;
ENSR Consulting and Engineering
GENERAL COMMENT: Overall, ENSR is generally in agreement
with the preferred options proposed by the EPA for managing
the soils and stream sediment. However, on-Site management
of lagoon soil containing metals only and stream sediment
should be considered as a viable option in the .final
remedial action plan. Soil and sediment from the lagoon and
stream sediment areas could be placed in other areas
proposed for soil covering and geotextile membrane
placement. Based on metals concentrations observed in the
soil and steam sediment, this alternative would be
compatible with other proposed EPA preferred alternatives
for managing similar soils. Specific comments relating to
the proposed EPA preferred alternatives for lagoon soils and
stream sediments are discussed below.
EPA RESPONSE: No response necessary. EPA will respond to
th« specific, comments that follow the above summary.
LAGOON AREA SOIL
l. COMMENT: This medium consists of the portion of surface and
subsurface soils which contains metals and volatile organic
compounds, including vinyl chloride. As noted on page 7 of
AR308850
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25
the FRAP, antimony, chromium, copper, lead, mercury and zinc
have been detected above background levels. Lead was
detected as high as 5,000 ppm, mercury at about 0.15 ppm,
and vinyl chloride at about 0.6ppm.
The EPA's preferred options consists of excavating the soil
to a depth of two feet followed by off-site treatment and
disposal of the soil. Following excavation, the area would
be backfilled and covered with a geotextile membrane and
soil cover. Soils having volatiles above the RCRA Land
Disposal Restriction (LDR) treatment standards would be
excavated and sent for off-site solidification/disposal. It
is not clear how the distinction between volatile organic
compounds (VOC) and non-contaminated VOC soils would be
implemented.
EPA RESPONSE: The RCRA Land Disposal Restriction (LDR) is
relevant and appropriate for solvent contaminated soils,
since spent chlorinated solvents are listed RCRA wastes,
specifically F001 and F002. Under these regulations, once
soil is excavated, it is subject to the LDR regulations. The
RCRA Land Disposal Restriction sets treatment levels for
solvent constituents found in these listed wastes. If
solvent constituents in excavated soils are below, these
levels, they already would meet the treatment standard and .. .
could be disposed in a hazardous waste landfill without
treatment. Of course since the residue from the incinerated
soil would still contain metals and would probably need to
be solidified before a landfill would accept the residue.
During Remedial Design, sufficient samples will be taken to
identify the areas of soil that must be sent for
incineration. The Remedial Design will also require testing
the batches of soil before disposal, and the sampling
details will be determined during the Remedial Design.
COtQOXm ENSR agrees that incineration will be an effective
approach for treating soil containing volatile constituents.
However, off-site solidification/disposal of soil that does
not contain VOC above treatment standards is not a cost-
effective approach, and does not appear to be warranted
given the other preferred options being proposed by the EPA.
As noted in the PRAP on page 7, both lead and mercury, the
primary metals identified in the soil, are below the levels
detected, in the cornfield, soils. However, on-site
management of the soil is being proposed as the preferred
option for the cornfield soils, while off-site management is
being proposed for the lagoon soil. The highest lead and
mercury levels in the cornfield soil have been measured at
6,500 ppm and 0.5 ppm, respectively which are higher
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26 . . •
the highest levels detected in the lagoon area soil.
A more reasonable approach would be to clearly identify
soils that contain VOC above the LDR treatment standards and
excavate the soil for off-site incineration. The area could
then be backfilled and covered with a geotextile membrane
and soil cover. Under this approach, initial efforts would
be made to delineate and separate soils into two categories:
soil containing VOC and soil that does not. By segregating
the soil in this manner, soil requiring off-site
incineration could be identified and approximately handled. •
Soil not found to .contain VOC above the treatment standards
could be left in the lagoon area and covered. If acceptable
to EPA, it may be possible to excavate the soil and place it
in other areas where proposed remediation would include soil
covering (i.e, cornfields and borrow area).
Removal of soil containing VOC and covering the remaining
soil in this manner would reduce environmental and public
health risks, as well as address land disposal restrictions
for VOC. The lagoon area is also contiguous to the
cornfield and borrow areas, and therefore, the metals
containing soil that would remain on-site would be localized
to. one area of the Hunterstown Road site.
RESPONSE: EPA agrees with the comment that excavation and
incineration is the appropriate Remedial Action for the
shallow soils contaminated with listed waste solvents. EPA
also agrees with the approach to do further sampling to
identify and segregate soils that must be sent for
incineration. EPA in this ROD has taken this approach.
EPA does not agree with the comments which suggests that
heavy metals are higher in the Cornfields than in the Lagoon
Area. For example, the above comment states that the
highest lead level is 6500 ppm, while the highest lead level
in the Lagoon Area is about 5000 ppm. Although this
statement is true, it drastically misrepresents the
situation. The numerical average lead level in the Lagoon
Area based on three surface samples (less than 2 feet) is
about. 2300 ppm, while the Cornfield numerical average level
is about 300 ppm for twenty nine samples. The Reasonable
Myviimm Exposure (RME) lead concentration in the Risk
Assessment for the Lagoon Area is about 5,OOO ppm, while the
RME concentration for lead in the Cornfields is about 330
ppm. Th* numerical average mercury content in both the
Lagoon Area and the Cornfields is about 0.1 ppm. The RME
mercury concentration for the Lagoon is 0.15 and the RME
concentration for the Cornfields is about 0.3 ppm.
Additionally, the concentration pattern is very different in
the Lagoon and Cornfield Areas. The Lagoon Area was grossly__
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27
contaminated with solvents and metal sludges that were
removed by Westinghouse under EPA oversight. EPA expects
widespread contamination throughout this area, but with the
metals mostly confined to the surface soils. During
sampling, plan negotiations Westinghouse argued against
taking a large number of samples in the Lagoon Area because
Westinghouse conceded that metals contamination was
widespread in the area. It was on this basis that EPA
allowed Westinghouse to take very few samples in the fenced
area compared to the other contaminated areas.
The contamination in the Cornfields was related to a white
chalk-like material that is widely distributed in the
Cornfields. This white material was sampled and it was this
sample which yielded the high levels of lead (6500 ppm).
The Remedial Investigation report indicates that when
particlas of this white material are present, the lead and
metals are high and when the white material is not present,
most metals are close to background levels. Westinghouse
informed EPA that this material will powder under stress and
could not be separated from soils by screening or other
mechanical techniques.
The contamination is present as numerous "hotspots" in the
Cornfields and this pattern of wide spread contamination of
a very large volume of soil suggests containment remedies
are most appropriate. The surface soil in the Lagoon Area
is highly contaminated and is a relatively small volume of
material. The removal actions also detected a wide spectrum
of chemicals which were not detected during the RI, but the
sampling data inside the fenced area is very limited (3
samples). The metals have not leached into ground water, but
EPA is mindful that during the removal actions, the lagoon
and stressed vegetation area were treated with lime to
prevent metals from leaching. EPA believes that it is
prudent to remove the very high levels of metals in the
lagoon-area to be protective. Also, the high levels of
metals are detrimental to soil invertebrates and could be
bioaccumulated.and move up the food chain. This situation
requires treatment and disposal rather than containment as
suggested in this comment.
STEAM SBDIMBHTS
COMMENT tThis medium consists of a portion of the East .
Stream sediments containing metals and a portion of the
Middle steam containing phthalates and zinc (see PRAP, page
13). The metals identified in the steam sediment include
copper, chromium, lead and zinc, with lead being the primary
constituent of interest. The highest level of lead observed
in the sediments is 4,300 ppm.
AR308853
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28
As noted in the PRAP on page 38, for the purposes of the
Feasibility Study (FS), it was assumed that remediation of
the affected, sediment would be conducted in conjunction with
remediation of the. affected soil, which included media 3
through 7. The FS considered only two remedial options
which included Alternative 1, No Action and Alternative 2,
excavation of the affected sediments and then off-site
treatment and disposal. It is not clear why excavation of
the sediments and placement of the sediment in an area
proposed for soil covering was not considered.
Consolidation of this material, which represents a volume of.
approximately 100 cubic* yards, with other metals impacted
soil should be considered. Possible options would include
the cornfield, borrow and lagoon areas, if the EPA approves,
since the proposed preferred remediation alternatives for
these areas include soil covering.
EPA RESPONSE: The East Stream sediment concentrations are
relatively high and for the same reasons that EPA has
selected solidification and off-Site disposal for metals
contaminated lagoon area soils listed above, EPA believes
off-Site treatment and disposal are appropriate. The volume
of contaminated sediments is relatively small and the cost
of treatment and disposal is moderate. The sediments are
being removed from the stream for ecological reasons. EPA
believes that it is inappropriate to simply move the
contaminants to benefit the stream invertebrates and
wetlands vegetation and then transfer them to a different
area of the site where soil invertebrates and terrestrial
plants will be exposed and impacted. The action suggested
in this comment would not satisfy the natural resource
trustee's concerns.
Prepared for Westintrhouse Electric Corporation
t> QnTs Riter
COMMENT Me. 1: (Page 3, Paragraph 5) The operator of the
facility, Mr. Frederick Shealer, ia not identified by the
Proposed Plan as a Potentially Responsible Party (FRF) . We
believe that previous documents related to the site have
identified Mr. Shealer as a PRP.
EPA RESPONSE: The ROD identifies Mr. Shealer as a PRP.
C
MMENT No. 2: (Page 8, Paragraph 1) The description o* the
current conditions at Drum Burial Area 1 should indicate
that a soil cover (minimum five feet in thickness) is in
place on top of the soils effected by residual
contamination.
ftR30885i*
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29
EPA RESPONSE: EPA agrees.
COMMENT No.3: (Page 12, Paragraph 1) The portion of the
Proposed Plan states that the Middle and East Streams were
dry during every visit by the U.S. Environmental Protection
Agency (USEPA) project manager. We believe that the
Proposed Plan intended to state that the Middle and West
Streams were dry. Based on our observations, the East
Stream has a low level of surficial flow during most periods
and the West Stream is typically dry.
EPA RESPONSES EPA agrees.
COMMENT,Mo. 4: (Page 14, Paragraph 3) The discussion here
regarding speculation on the amount of spent solvent that
may have been disposed at various site locations may be
misleading. The amount indicated appears to be
significantly larger than the volume reported to be
generated by Westinghouse. In addition, similar speculation
regarding disposal of materials produced by other generators
is not provided.
EPA RESPONSE: EPA looked at several sources of information
to obtain the "guesstimate" of spent solvent amounts. EPA
agrees that substantial uncertainty is associated with this
very crude estimate of solvents disposed. EPA is merely
trying to show the rough magnitude of solvents disposed. It
is clear that the volume was large and this is relevant to
the potential for DNAPLs at the Site. EPA is unaware of
solvent disposal by PRPs other than Westinghouse. EPA has
received information that indicates that most of the waste,
by volume, disposed at the Site was from PRPs other than
Westinghouse., but they did. not dispose of solvents. The
volume of their wastes was not relevant to the discussion of
the: potential for DNAPLs in bedrock.
COMMENT No. 5s (Page 15, Paragraphs 2,3, and 4) The
discussion here implies that it is technically likely that
groundvater can be effectively remediated at depths up to
800 feet at this site. We believe that groundwater
remediation at depths of greater than 500 feet may prove to
be extremely difficult given the complex stratigraphy and
hydrogeologic conditions encountered at the Hunterstown Road
site. The schedule and cost estimates provided in the
Proposed Plan appear to be based open the information
provided in the Feasibility Study (FS) Report'. The FS
assumed that groundwater remediation would focus on depths
of less than 500 feet. The authors of the FS Report believe
that groundvater remediation to a depth of 800 feet may not
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30
be practical. Groundwater extraction and recovery systems
installed in steeply dipping fractured bedrock have not yet
been demonstrated to be successful on a consistent basis at
depths greater than 500 feet.
While groundvater remediation to a depth of 800 feet may be
a goal, the USEPA may not wish to imply that this goal is
readily achievable. This implication would be misleading.
EPA RESPONSE: EPA agrees that it will be extremely
difficult to remediate this aquifer to background to a depth.
of 800 feet. EPA has tried to discuss these difficulties in
the ROD. EPA understands that the estimate and schedule in
the FS is based on remediation to 500 feet of depth. EPA
believes that even this estimate for ground water to 500
feet is subject to substantial uncertainty, and could be
less or more than the estimated cost in the Feasibility
Study. EPA believes that it will only be possible to
accurately estimate costs after additional wells are placed,
some additional pump test data is collected and a
preliminary design has been completed. At that time, EPA
may issue an Explanation of Significant differences if the
cost are substantially different than in the FS, but the
current costs are accurate enough to issue a decision.
Since there are no alternatives other than pump and
treatment that are feasible, and since aquifer remediation
is required to meet ARARs and to be protective, the selected
remedy would remain the same even if cost are significantly
higher or lower than in the FS. Also, after a pump and
treatment system generates aquifer response data, EPA in
consultation with the PADER may determine that remediation
to background is not possible and may select different
cleanup levels or plume containment as an appropriate goal.
COMMENT Ho. 61. (Page 27, Paragraph 2) The recommended
alternative for the Lagoon Area soils is a combination of
excavation with off-site incineration and the installation
of a •oil cover.
The basis for differentiating which soils in the Lagoon Area
are sufficiently impacted to warrant off-site incineration
is proposed by the USEPA to be the RCRA Land Disposal
Restriction Treatment Standards for VOCs.
W* believw that in-place closure of these soils is fully
consistent with relevant RCRA requirements is the
alternative that is most highly ranked by the feasibility
study using the criteria of the National Contingency Plan
(NCP). Only ,10 percent of the remedial
investigation/feasibility study (Rl/FS) soil samples from
the Lagoon Area were contaminated above the cleanup
HR308856
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31
standards cited in the final RI/FS and risk assessment. The
principal threat posed by this disposal area has been
subjected to a removal action as described elsewhere in the
Proposed Plan and the removal action was successful.
Should the USEPA nonetheless elect to require off-^site
incineration for some of the residential soils remaining in
this area, the criteria for requiring off-site incineration
should be substantial exceedance of the site-specific
cleanup levels of volatile organic compounds (VOCs) in
soils, as described in the RI/FS and risk assessment. A
sampling program should be instituted during the remedial
action to identify^ those soils which require off-site
incineration based upon substantial exceedance of RI/FS
cleanup levels. Such a sampling program would be mandatory
for this type of remedy to be viewed as cost effective under
the NCP criteria for cost effectiveness. The unit cost of
off-site incineration is extremely high. As the RI/FS data
show that only a small portion of the soils in this unit are
impacted above the site-specific cleanup levels, a design
phase sampling program to differentiate materials requiring
off-site incineration from other soils is warranted.
RESPONSE: EPA has had several discussions with WestinghoUse
regarding the problems associated with installation of a
RCRA capon the Lagoon Area. The natural ground water level
in the most contaminated section of the Lagoon Area is
actually above ground level forming a pond. The Lagoon Area
is also on a hill which slopes to the East Stream. A
closure (capping) remedy presents several problems. The
shallow ground water could flow laterally through the soil
under the cap transporting contaminants to the local
discharge point of the East Stream. High ground water
levels could damage the cap. These concerns were sent to
Westinghouse in EPA's. comments on the Feasibility Study,
dated October 9, 1993. Westinghouse's response to EPA's
comments- was that the ground water extraction system would
lower the ground water sufficiently to prevent lateral
movement and damage to the cap. EPA's response was as
follows: ' .
EPA is not convinced that the ground water extraction system
will capture all of the water that may move laterally
through the lagoon area soils during high water events and
will probably discharge to the East Stream. Discharge from
this area to the East Stream seems to be occurring currently
since VOC's have been detected in the East Stream. No
modeling or calculations were submitted to support.
Westinghouse's position that the water table would be
lowered enough to avoid this problem and that all
contaminants will be captured by a pump and treat
EPA will consider the risk of release through later?
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32 .
movement or ground water to be possible and will rate this
alternative accordingly.
Westinghouse responded to the FS conditional approval nemo
with comments in a letter dated April 1, 1993 that again
indicated that the pump and treat system or a modified pump
and treat system could lower the ground water sufficiently
if a collection trench were installed on the western side of
the lagoon area. No supporting technical information was
supplied to increase EPA's confidence that this was viable.
Soil in the area was not extensively sampled. Phase II RI
Work Plan negotiations with Westinghouse were difficult and
lasted over six months. During negotiations, Westinghouse
argued that little would be gained by extensively sampling
the area in the lagoon since they expected to find high
levels of contamination. Westinghouse also asserted that
the-removal action had taken away the soil "almost to
bedrock". Since Westinghouse conceded that the area inside
the lagoon was contaminated, EPA accepted a limited number :
of samples to generally assess the concentration and
required test pits to determine how deep the remaining soil
was to obtain a volume for remedial action. The test pits
showed that soil depth ranged from 2 to 12 feet.
Westinghouse only agreed to tafc» two surface samples in the
actual lagoon area. EPA also needed to determine the
lateral extent of the contamination to obtain a volume of
soil for remedial action. Westinghouse did agree to borings
outside of the Lagoon Area to determine the lateral extent
of contamination. The 10 % samples showing contamination
that were mentioned in the letter were those in the actual
Lagoon Area. It is not surprising that the areas outside
the Lagoon Area sampled below the surf ace showed much lower
levels of contamination and these comprise the majority of
samples taken. Both Phase II RI surface samples inside the
Lagoon Area showed high levels of contamination. Post
removal samples also showed high levels of contamination in
the Lagoon Area and some removal samples showed high levels
of- contamination between the lagoon and the East Stream.
EPA will conduct testing of the top two feet of soils during
the Remedial Design to make sure that only those soils above
the RCRA LDR treatment standard are sent for incineration.
t-*a*pmpr MO. 7t (Page 28, Paragraph 5) The USEPA has proposed
extending the soil cover for the Cornfields to an area that
has not previously been subjected to soil sampling. The
concerns expressed by the USEPA regarding possible
contamination in this area are well taken. However, it is
recommended that in lieu of mandating remediation of this
area based upon possible but undocumented contamination, the
HR308858
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33
ROD should provide for RD sampling of this area for the
applicable compounds of interest. Mandating remediation in
the absence of supporting validated data to document
contamination above site-specific cleanup standards would
not appear to be consistent with the NCP. A sampling
program would be both cost effective and protective in that
the soil cover for the Cornfields would be extended (if
necessary) during design based upon validated scientific
data.
EPA RESPONSE: Since these areas were the source of
contamination of the East Stream, and since the contaminants
had to travel across, the areas that EPA has selected for
extension of the soil cover, EPA believes that these areas
must be contaminated. However in response to this comment,
EPA has modified the ROD to include sampling of these areas
prior to extending the soil cover to the East Stream.
COMMENT No. 8: (Page 30, Paragraph 2) As previous stated in
comments to other USEPA documents, Pennsylvania Department
of Environmental Resources (PADER) management has publicly
indicated that its February 1992 policy document on ground :
water protection is the agency's position as regards ground
water remediation. This policy document does not mandate •
cleanup to background where technology limitations exist, as
they clearly do for this site.
EPA RESPONSE: As previously explained to Westinghouse
several times during the Feasibility Study for this Site,
the state ARAR is to remediate ground water to background
levels. Page 71 of the transcript of the public meeting has
a statement from Mr. James Spontak, PADER Compliance
Officer: "One of the comments the state made, we wanted the
ground water remediated to background quality and EPA put
that in the [Proposed] Plan for us". The PADER's policy
document does allow the flexibility to waive the cleanup to
background levels/ but as a practical matter, the state
generally requires compelling technical evidence to justify
a waiver.
COMMENT No. 9s (Page 36, Paragraph 4) The discussion
regarding reduction of toxicity, mobility, and volume via
treatment should be expanded for the soil areas that contain
VOCs to account for the synergistic relationship between the
soil and groundwater remedies.
The probable fate of mobile residual VOCs that could remain
in any of the soil units after remediation is eventual
leaching, migration to the extraction wells and treatment on
site with destruction of the VOCs by the catalytic oxidation
system installed to treat groundwater. The statutory- qnoo C q
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34
preference for treatment with destruction of the
contaminants is indirectly, but effectively, achieved for
the soil units by the selected groundwater remedy.
EPA RESPONSE: EPA agrees with the ultimate fate, but the
discussion of the criteria for toxicity, mobility and volume
applies to the direct remedy discussed. EPA has made
reference to the ultimate disposition of contaminants that
leach from soils and will be collected.
GENERAL COMMENT: Westinghouse appreciates the USEPA
extending the comment period of this Proposed Plan. The
document was well prepared and we believe with minor
modification, as suggested by these comments, will result in
a very protective remedy that also ranks well under the
other K-JP criteria for remedy selection.
RESPONSE: EPA agrees.
AR308860
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1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2
3 ' ' • ' '
4
5 . Public Meeting on the Proposed Remedial
Action' Plan for the Hunterstown .Road
6 Superfund Site located in Straban
Township, Adams County, Pennsylvania
7
8 . '.....'
9 •'•'•• • ' • '
Transcript of the public meeting held on
10 Wednesday, May 5, 1993 at the Cumberland
Township Municipal Building, Gettysburg,
11 Pennsylvania.
.12
13
14 • ' ' .-••'-.'•
.. . Virgiria Moseley, Community Relations Coordinator
15 Frank Vavra, Remedial Project Manager
Bruce Rundell, Geologist
16 Jeffrey Pike, Chief, Western PA Remedial Section
Jim Spontak, Department of Environmental Resources
17 '
18
19
20- " • • - :' •''••'
Alicia K. Wooters, RPR
21 5620 Carlisle Pike
New Oxford, PA 17350
22 . Official Court Reporter
23
24
AR30886!
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Page
2
PRESENTATIONS:
3
Virginia Moseley 3.-8
4
Frank Vavra . 8-14
5
Bruce Rundell 14-18
6
COMMENTS AND QUESTIONS 34-91
7 • ' '
8
9
10
11
12
13
14
15
16
17
18
1*
20
21
22
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25
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27
HR308862
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1 " Wednesday, May 5, 1993
. 2 Cumberland Township
3 Transcript of public meeting for the United States
4 Environmental Protection Agency, held at the Cumberland
5 Township Municipal Building, the following proceedings were
6 held:
7 (Beginning at 7:02 p.m.)
6 VIRGINIA MOSELEY: Good evening everyone. Thank
9 you for coming out on this very rainy night. My name is
10 Virginia Moseley, and I am the Community Relations
11 Coordinator for the Hunterstown Road Superfund Site. I know
12 some of you .are probably used to dealing with a community
13 relations person by the name of Amy Barnett. Amy is home.
14 taking care of her first born son who was born in March.
15 She's a very busy young lady, so I will be the community
16 relations coordinator for this site. My cards are out on
17 the counter. When you came in, hopefully you got them. If
18 not, please help yourself to one on the way out.
19 What we're going to do tonight is just briefly take a
20 look at where we are in the superfund process at the
21 .Hunterstown Road site. Then I'm going to tell you a little
22 bit about the proposed plan meeting and the reason we're all
23 here tonight, introduce some of our panel members and then
24 I'll be turning the program over to the people who will be
25 giving their presentations.
AR308863
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 You received several handouts when you came in tonight
2 and one of them looks like this. If you would turn to that,
3 find that one. I want to point out where we are here in the
4 system and you will notice -on the handout that you were
5 given that the proposed plan has been highlighted in yellow'.
6 So briefly starting at the top, we have the site
7 discovery, then the preliminary assessment, which is the -
8 evaluation of existing site-specific data. The site
9 inspection, collection of air, soil, water samples from the
10 site and nearby areas. Then we went on to do the hazard
11 ranking system, which is shown here BRS on your handout
12 which is a mathematical approach to assessing the risks that
13 are posed at the site. Then we have the listing on the
14 national priorities list, NPL list we refer to it. Then we
15 have remedial investigation, feasibility study.
16 You will see now we are down here for the proposed
17 plan. That is the reason that we're here tonight. Proposed
18 plan. You'll see next to that it says public comment. . So
19 we are here this evening to receive your comments, your
20 questions and your comments during this proposed plan.
21 . We have a thirty day public comment period. That is
22 required by federal regulation. Now, the plan was released
23 and a notice was published in your two local newspapers on
24 April 2,4. That was a Saturday. The notice of-the plan and
25 this meeting appeared in the Hanover Evening Sun and in the
Alicia K. Hooters, RPR
Official Court Reporter AR30886U
-------
1 Gettysburg Times. So the public comment period as I said is
2 30 days and that will remain open until May 24. That gives
3 you the public and other members.of the public who are not
4 here this evening an opportunity to submit your comments and
5 - your questions both, in person orally tonight and also
6 written questions. You are able to send them in and I'll
7 show you where in just a moment.
8 • • • The EPA is going to review all of the comments and all
9 the questions that are received during this thirty day
10 period. These are all going to be looked at and listened to
11 before making a final selection of the site clean up
12 alternatives. Your comments are going to be incorporated in
13 what EPA calls a responsive summary and that will be made.
14 part of the administrative record both at EPA headquarters
IS and,at the' local information repository which here in
16 Gettysburg is at the Adams County Library on Baltimore
17 Street.
18 You notice this evening we have a stenographer present.
19 She will be recording your questions and your comments when
20 we get to that part of the meeting. You can also review the
21 plan. We have some copies this evening out on the counter.
22 There is a copy at the repository at the library as well and
23 you can submit comments and questions in writing.
24 We have a facts sheet out there on the counter. I
25 think most of you here this evening have already received
Alicia K. Wooters. RPR AR308865
Official Court Reporter
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1 one. The facts sheet looks like this and on the inside on
2 page two you will see where your comments if you care to
3 write, some. If you think of- some more after the meeting
4 tonight, certainly send them in and you'll see they are to
5 be addressed to Frank Vavra, who is the remedial project
6 manager who will be giving a presentation this evening.
1 If there are any questions about that, make sure you
8 " have this or ask one of us before you leave, when you came'
9 in this evening you were asked to sign our attendance list.
10 I hope everyone did that. The reason we do that is so that
11 we can send mailings out to you to keep you informed of
12 what's going on at the site. We use the mailing list to
13 send things such as this fact sheet so it really behooves
14 you to give us your name and address. It's very important
15 so we can keep in touch.
16 One of the other things you received tonight is an
17 agenda. Would you kindly pull out the agenda. It's two
18 pages clipped together. Let's just take a moment to look at
19 what's going to happen tonight. Presentations will be given.
20 this evening by Frank Vavra, who is the remedial project
21 manager and Bruce Rundell, who is a geologist for the EPA.
22 We also have present this evening Jeff Pike, who is EPA
23 section chief and Jim Spontak, who is compliance specialist
24 with the Pennsylvania Department of Environmental Resources.
25 We also have present this evening a representative from
Alicia K. Wooters, RPR
Official Court Reporter
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1 Congressman Goodling's Office. Would you care to stand and
2 identify yourself? Any other Local officials, elected
3 officials or representatives of elected officials this
4 evening?
5 (No response.)
6 .. VIRGINIA MOSELEY: Going on to the second page,
7 just a couple of ground rules before we get started. We •
8 want to draw your attention to the fact that the topic of
9 this meeting tonight is the Hunterstown Road Superfund Site,
10 so we ask you please to keep your comments and your
11 questions very specific to this site. We had note cards and
12 pencils out at the counter if anyone is reluctant to stand
13 and give a question .or a comment, if you would like to write
14 them on a card, we'd be more than happy to bring them to the
15 appropriate person, so feel free to do that. They are in
16 the back at the counter if you want them or need them.
17 Now, if you want to ask a question or make a comment,
18 we ask that you raise your hand to be identified and we
19 would appreciate it if you would give your name at that time
20 so that our stenographer can record that. That's at your
21 discretion. We ask that you do that, but you are not
22 obliged to if you are not comfortable with that. Any
23 questions or comments so far on anything that I've said?
24 • (No response.) -
25 VIRGINIA MOSELEY: Okay, we will go into our
. «oot«., *,* «R308867
Official Court Reporter
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1 presentation and we would like to ask that you would hold
2 your questions until the end of the presentations. Please
3 jot something down and when the gentlemen are through,, they
4 will ask you when they are ready for questions, without
5 further ado I would like to introduce to you Frank'Vavra,
6 the remedial .project manager for Hunterstown Road.
7 • FRANK VAVRAt I do want to keep the meeting .
8 informal, and the reason we're asking you to defer your
9 questions until after we are finished is simply so I can get
10 through the technical material. We had previously had two
11 meetings in this building to present the results of a
12 remedial investigation and feasibility study including the
13 risk assessment .prior to this time. Tonight the primary
14 focus is the alternatives that were evaluated in the
15 feasibility study, and EPA's preference for the alternatives
16 we think will produce the best results in cleaning up the
17 Superfund Site.
18 . After that we will have a very informal session where
19 we're going to discuss any of your questions. We will go
20 b'ack, if we need to pull slides out and discuss them, we
21 will do that. I would like to give a quick overview of the
22 results of the RI and some the alternatives we looked at and
23 what we think is the best solution to the site problems.
24 I..would guess that everyone in this room,knows where
25 the site is but in case they don't, the site is located to
8
Alicia K. Wooters, RPR AR30886,
Official Court Reporter
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1 the northeast of Gettysburg. It's along Shealer Road just
2 as you come in off of Route 30 -into downtown Gettysburg.
3 This is an overview of the site and it shows the
4 different areas of the site that had problems in the past.
5 What I wanted-to highlight in discussing these areas is the
6 fact that although we are looking at some, final remedies for
7 the site, there has been a substantial amount of EPA action
8 done by Westinghouse and EPA to mitigate many of the site
9 problems previously. What I would like to point out is
10 these two areas had very large numbers of drums that were
11 buried at the Superfund Site. Those were removed in 1989 in
12 a fairly extensive removal action performed by Westinghouse
13 under EPA oversight. This area noted as the borrow area had
14 asbestos piles, it had lead contamination and there were
15 past actions by Westinghouse on the EPA oversight to remove
16 the asbestos and to take mitigating measures, which included
17 placing some small amount of soil and stabilizing that area
18 for future exploration.
19 This area is known as the lagoon area and it contained
20 solvent sludges, it contained paint wastes and other
21 metallic wastes. Again back in the mid '80's this had been
22 removed by Westinghouse in an extensive removal action and a
23 chain link fence was placed around that area. There is a
24 stream which runs through these areas and there.were fences
25 placed to prevent contaminants from moving into that area
flR308869
Alicia K. Wooters, RPR
Official Court Reporter
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1 also. .' .
2 The stressed vegetation area had tarps placed over this
1 area which: cotrrtained again metal wastes containing lead,
4 antimony and other toxic metals. The cornfields had
5 previously been used for disposal of some sludges from a
6 truck which basically went up and down the cornfields and
7 sprayed material on the cornfield's.
8 We have three streams at the site. We have the west
9 stream, the middle stream and the east stream. Many of
10 these contaminants have been deposited into these areas
11 along the east stream and that was investigated, and
12 remedial investigation has been previously discussed at some
13 of the prior meetings.
14 Other protections for the public included extension of
15 water lines. This is the area of the site, east stream,
16 middle stream, west stream. One drum burial area was
17 located here. One drum burial area located here. The
18 lagoons were in this area and the ground water contamination
19 is located in this general vicinity and you can see the
20 people in that area are served by a water line and EPA
21 .during remedial investigation verified that in several
22 surveys of residents to make sure that everyone was
23 knowledgeable about the problem and that anyone in the area
24 of ground water contamination was in fact using.the
25 municipal water supply.
10
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 Additional actions were taken by Westinghouse under EPA
2 oversight to further protect the public and many samples of
3 residential wells were taken along Old Harrisburg Road.
4 Some concerns of off site, of nearby residents involved lead
5 contamination in some of the metals that were present in the
6 cornfields, and I believe Merle Hankey and Don Waddell
7 raised the issue what about when this area was being farmed,
8 rototilling could have spread the lead into some of the
9 surrounding areas and we did do some limited sampling and
\
10 based on our results .and also based on the contaminant
11 distributions in the cornfields, we do not believe that
12 there is off site metals contamination of concern. Those
13 are things that have happened in the past to prevent the
14 immediate threat from the site and a lot of them were quite
15 extensive.
16 During remedial investigation we went and explored
17 further to see what residual contamination remained in these
18 areas and to try to determine how widespread it was, where
19 it had migrated to and other things that would help us
20 determine what the appropriate remedy for the site would be.
21 • The results of the remedial investigation basically
22 showed that in this drum burial area there were residual
23 volatile contaminants. These are materials that are
24 . . solvents, sealants, gasoline type compounds, but they were
25 relatively low levels and this area had been excavated and
AR30887I
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 the drums had been removed. Contaminated soils had also
2 ' been removed and it had been extensively sampled at the enc.
3 of that., drum, removal activity. The remaining contaminants
4 are below the water table much of the time. Because there
5 is considerable contamination down in the bedrock•beneath
6 that, we believe the most appropriate way to address that in
7 gerieral is to handle it with'whatever action we plan to take
8 for ground water.
9 A similar situation in this drum burial area.
10 Contaminated soils and drums were removed and on sampling
11 the area came up basically clean. The two cornfields
12 contained lead and mercury and EPA evaluates areas to
13 determine whether they ace safe in two ways. One, EPA looks
14 at the risk from cancer. And the second way that EPA looks
15 at risks is systemic risk, the risk of say a poison. The
16 effect on organs and the cancer risk was low in this area,
17 however, it did have unacceptable hazard indices. That
18 means that the risk — if a child were to live on the site
19 and ingest that soil over a protracted period of time, that
20 -would pose an unacceptable risk. The risk assessment also
21 showed for people living nearby there were no unacceptable
22 risks from the soils. Trespassing children were a limited
23 duration also posed no unacceptable health risk but someone
24 actually living there, it is outside EPA's risk range and so
25 for future use it would require mitigation.
met. ..'Lt.... m «R308872
Official Court Reporter
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1 -The lagoon area was sampled and it. contained high
2 levels of toxic metals and one of two samples contained
3 contamination as vinyl chloride, which is carcinogenic.
4 Because solvents were disposed .in this area, they are~ also
5 subject to some of EPA's hazardous waste regulations under
6 the Resource Conservation and Recovery Act. The risk levels
7 for cancer and the hazard index for someone actually.living
8 at the site, were unacceptable. Those soils are still, at
9 unacceptable levels for EPA.
10 This east stream is a pathway we studied and we found.
11 contamination as we would have expected from run off from
12 the lagoon area and a burial area and the cornfields had
13 carried some contaminants•down into the sediments. There
14 were relatively low, 'very low levels of contaminants in the
15 water itself and tended to be in the stream. A very limited
16 stretch of the stream had a high level of zinc and what's
17 known as phthalate. Phthalate is a plasticizer put in
18 polyvinyl chloride plastic. PVC plastic to soften the
19 plastic but it's toxic at certain levels and can have an
20 affect on wildlife or aquatic life.
21 There is a very limited section of the stream that
22 EPA's biological technical assistance team believes needs
23 action. Because large amounts of solids were disposed in
24 the lagoon area, the drum burial area two and drum burial
25 area one, there were extensive plumes of ground water
AR308873
Alicia K. Hooters, RPR
Official Court Reporter
-------
1 contamination and at this point I'm going, to turn the
2 presentation over to our geologist, Bruce Rundell and let
3 you explain the situation with respect to the ground water.
4 BRUCE RUNDELL: The Hunterstown.Road site is
5 underlined by rocks that make up what's called the
6 Gettysburg formation. These rocks are composed of
7 sandstones, siltstones and shales that were deposited two •
8 hundred million years ago. When they were deposited, they
9 were deposited in streams, in lakes, in horizontal, flat
\
10 environment, one layer on top of another sort of like
11 stacking up books or papers.
12 When this was going on, there was faulting in the area
13 on the western side of Gettysburg really and what we have is
14 a large fault that as these sediments were being deposited
15 there was movement down on the western side of Gettysburg
16 and basically what we ended up with is a wedge of these
17 sedimentary rocks sort of like this along this fault where
18 this wedge is two to three thousand feet thick.
19 As they slowly got buried, these sediments become
20 cemented together and turn into rocks. As that occurs, the
21 beds of similar material cement differently than other beds
22 and you gat along these contacts between a pile of sand and
23 a pile of mud, you tend to have what are called bedding
24 plane fracturea which are basically thin cracks. That's
25 pretty much where the ground water is forced to move along
14
Alicia K. Wooters. RPR RR3088 , 4
Official Court Reporter
-------
1 these cracks. In other words, they'd be restricted to
2 flowing between these two books.
1 This figure here is a block diagram. It's like if you
4 took a square out of the earth, this is what it would look
5 like. We have these alternating beds of different material,
6 shales and muds and these .thinner layers of sands. The
7 sands are where we find most of these bedding plane
8 fractures. Therefore, most of the ground's water flow is
9 restricted to these sandy layers.
10 Also due to the forces of the earth, you do get cracks
11 in between these but there are a lot less of them than there
12 are of the bedding plane fractures, so most of the water is
13 restricted to these beds with a little bit of movement
14 possible between the beds.
15 * What also this figure shows is how contaminants move
16 in this environment. If you have a spill at the surface and
17 what we have at the Hunterstown Road site is primarily
18 solvents and other kinds of organics, these solvents, you
19 can sort of picture them like oil in that they don't readily
20 dissolve in water. The only difference between the solvents
21 and oil is that the solvents we're looking at are heavier
22 than water, so they don't float on top of the water table.
23 They sink, because they are heavier than water. What we
24 have is these move down through the soil and enter the
25 bedrock. Some of it is dissolved slowly and enters as a
is AR308875
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 dissolve phase in the ground water- Other parts just
2 continue down due to gravity, as in a sense an ooze, and
.3 it's controlled by gravity so it slides down these bedding
4 plane fractures and basically just goes down further,and
5 further with dip.
6 That's unfortunately what we see at the Hunterstown
7 Road site is that this in a sense slime of solvents extends
8 to great depth. We have wells that have very high
9 concentrations at five hundred feet, three hundred feet and
10 basically what we believe is that they can continue to keep
11 going and we're not exactly sure to what depth. We do know
12 that the basin is two to three thousand feet thick, so
13 theoretically -fe could have two thousand feet of
14 contamination going down.
15 One other thing that this figure shows that the
16 contamination is pretty much restricted to the bedding plane
17 fractures that come to the surface underneath the spill
18 area. What you see here primarily goes down this. It's not
19 really affecting this water bearing zone over here or this
20 one over here. Sometimes it can cut across where these
21 ' other breaks in the rock are and may affect the water
22 bearing zone further down but that depends primarily on the
23 ground water flow directions and how many of those fractures
24 are really oat there.
25 So during the investigation we put in a number of
16 HR308876
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 wells all over the site and this figure shows the existence
2 of contamination of the three areas. This is the lagoon
3 area. It's supposed to be blue. It turned sort of green-.
4 This is drum burial area two in green and drum burial area
5 one in red. What these lines are are equal concentration
6 lines of contaminants for the total volatile organics.
7 • What you see here emanating from the lagoon area in the
8 center of the plume is very high concentrations of'total
9 volatiles. This number is hard to read, but it says ten
10 thousand so basically anything within the circle has
11 concentrations greater than ten thousand parts per billion
12 total volatile organics. This next line is one thousand.
13 This final line out ..here is one hundred. The exact limit to
14 where we go, zero is probably out here/ but we don't really
15 know exactly where that is.
16 . For drum burial area two, moving up this has a lot less
17 contamination. This inner circle is one hundred parts per
18 billion. This little circle here has concentration similar
19 to this real big circle from the lagoon area. This outer
20 'circle is ten parts per billion total volatiles.
21 At the drum burial area one you see a little bit
22 different in that the highest concentration, this ten
23 thousands out here and not really right next to where the
24 drum burial area is. In these, the highest concentrations
25 are really close to what we believe is the ARARS.
I"7
- " Alicia K. Wooters, RPR AR308877
Official Court Reporter
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1 - MERLE HANKEY: Why is that?. Why is that ten
2 thousand further away from drum burial area in relationship
3 to. the other areas?
4 BROCE RUNDELL: It's a number of things but when
5 they were depositing all these drums here and breaking them
6 open, I guess the model that we use is a slug of
7 .contaminants moved down early in the plume's history and the
8 biggest slug is further down, dipped down those bedding
9 planes and what's left behind are still high concentrations
10 greater than a thousand is pretty high, is sort of like the
11 slime but the bigger pool is further down. In these areas
12 the pool, the larger volume of contaminants are closer to
13 the surface. . "..•'••
14 FRANK VAVRA: You might point out though we don't
15 have wells deep enough. We consulted with the U.S. Geologic
16 Service when we were looking at the RI and FS and trying to
17 make some decisions on the ground water, and it was USGS
18 opinion that we could have what we call dense non-aqueous
19, phase liquid*. .The oily layer of contaminants down to
20 depths as deep as two to three thousand feet.
21 If you were to sink a well in the lagoon area bedding
22 plane which is angled down, we have a plume up near the
23 surface but it could well be if you were able to put a 15
24 hundred foot well there, you might find much greater levels
25 of contamination there than you have near the surface.
'*
18
Alicia K. Wooters, RPR RR308878
Official Court Reporter
-------
1 What we think is we have a well deep enough at
2 Hunterst.own to find that greater concentration plume with
3. the lagoon area. We just think there is a good chance
4 that's so deep we haven't detected it.
5 3'RUCE RUNDELL: To illustrate that point we have
6 this picture. It's a cross section sort of like that block
7 diagram. If you were to take a slice through the earth,
8 this is a picture of it. What we have here, these are our
£ wells to different depth. This is, see here, depth and feet
10 and *»e have our different strata that make up the rock
11 formation. These are our water bearing zones. These big
12 dash lines are what we call equal potential lines and they
13 are based on the water level in these individual wells.
14 . For instance, the water level in this well has an
15 elevation of 515. The elevation in this well is hard to
16 read, 530 or something like that, so based on that it's sort
17 of like a map of pressures. Sort of like the same way the
18 weather man does to figure out where the highs and lows are.
19. He looks at all the barometers around the country and draws
20 these lines of equal pressures. From the equal pressures we
21 can tell which way ground water wants to flow. It wants to
22 flow from areas of high pressure or high elevation to areas
23 of low pressure or the low elevations.
24 What we've found at this site is there is a very strong
25 predominantly downward grading. The ground water wants to
*
19
Alicia K. Wootersi J»R • AR308879
Official Court Reporter;: : -.-..-..
-------
1 move down. That's what these green lines .show is the path
2 at which the ground water would like to flow. It is as you
3 remember restricted by these planes but those planes do have
4 cracks cutting them so it can, the flow can go across these
5 water bearing zones but would like to stay within them.
6 This red line is how we have envisioned the direction of the
7 plumes.. This is where the lagoon area is. This is drum
8 ' burial area two and drum burial area one.
9 What this hashed area is are equal concentration lines
10 . likevl showed you on the last map except they are in a
11 vertical plane and this is what Frank was referring to
12 earlier in that we have wells in the lagoon area that go
13 here sort of in the heart of this part and then this next
14 well — well, this is 23 thousand parts pec billion. This
15 well down here has 382, but we really don't know exactly
16 what it is down here. That's why you see these dashed
17 lines. This 23 you know could extend further down or it
18 could be 40. It's an unknown.
19 This is the drum burial area two and you. see a much
20 smaller area of leas concentration. This deep well here is
21 18 parts per billion and this over here is the drum burial
22 area one. What we did find after this figure was made, we
23 installed some more wells and the concentrations went up
24 instead of going down. We had hoped that going down this
25 bedding plane past this 671 parts per billion we'd drill out
20 AR308880
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 here and we'd get 50 or some low number but in fact what we
2 found was the concentration has increased and that's where
3 the idea of that slug developed.
4 Another thing you'll notice in between these two we
5 have wells that have nondetects so it sort of helps show and
6 separate these three plumes. The big question is to what
7 depth does contamination go. And also this is a recharge
8 area, and like everything else if you have a recharge area,
9 somewhere yoti have a discharge area where ground water will
10 come to the surface and discharge to a creek. The basin is
11 two thousand feet deep.
12 There is ground water at two thousand feet and three
13 thousand feet. As you go deeper, the time at which that
14 water was in contact with the rocks grows to a long, long
15 time. The water down at two thousand feet is thousands and
16 thousands of years old. It's been in contact with the rocks
17 a long time. It's been able to dissolve some of those
18 rocks. The quality of water decreases as you get down. If
19 you have a two thousand foot well, you'd be drinking salt
20 water. It's not really drinkable as far as humans are
21 concerned. There is water down there and it is possible for
22 the contamination to get down that far.
23 W« talked to USGS geological survey about where this
24 ground water might com* up and that's part to be included in
25 our remedy. We'll be investigating that and monitoring it
AR30888I
Alicia K. Hooters, RPR
Official Court Reporter
-------
1 as wel-1.
2 I guess I can turn this back over to Frank and he can
3 go over the remedial plans.
4 FRANK VAVRA.: I think .Bruce did an excellent job
5 in describing the technical problem specific .to the site.
6 One thing EPA is also wrestling with is the general problem
7 for sites such as Hunterstown Road. As we mentioned, there
8 is a substance called a dense non-aqueous phase liquid. If
9 you took a can of paint solvent and poured it into a glass
10 of water, it would form a lighter just like salad forms an
11 oil water layer and you would have the contaminate on the
12 bottom of the glass. It wants to sink. It's heavier than
13 water. It doesn't want to dissolve and will dissolve.
14 sparingly*over a very, very long period of tine.
15 There are a lot of sites like this across the nation
16 where we have had solvent spills. They are used in many,
17 many operations. In some geologies there is a very good
18 chance that you can remediate these and succeed and do it in
19 a very short finite period of time.
20 • Probably the most difficult site to clean up for ground
21 water i«where you spill these type of materials into
22 fractured bedrock, because the material drops down into
23 little crevices, it gets trapped and it's going to
24 cedissolve into the water very slowly over time and
25 disperse. There are a lot of different positions on tttis.
22
Alicia K. Wooters, RPR AR308882
Official Court Reporter
-------
1 There are very well known hydrogeologists who think at sites
2 like these the aquifer has terminal cancer and EPA shouldn't
3 try to do anything. The bulk of hydrogeologists believe if
4 we can't totally remediate it, we can sling the plume and
5 T.ake sure the contamination doesn't spread further. This is
6 reflected in EPA's preference for an alternative that we
7 believe is protective but to recognize the difficulty
8 inherent in trying to clean up and to mitigate risk at a .
9 site such as this.
10 Therefore, we looked at essentially two alternatives
11 that were developed by a Westinghouse contractor. One is a
12 pump and treat alternative that will extract the ground
13 water and pull the plume in at reasonable depths and then
14 there is another alternative where we try to remediate the
15 ground water on an accelerated basis. You're pumping more
16 water. Some of the water is reinjected to try to flush out
17 the aquifer by forcing additional water through that.
18 ' There are two extraction alternatives we looked at.
19 EPA doesn't believe to go below eight hundred feet is going
20 to be productive. I think to drill wells of that depth
21 through son* very hard rock just tracking this through the
22 crevices would be a monumental task and no one is using the
23 ground water at those depths and the quality also declines.
24 Therefore, we looked at the two extraction
25 alternatives, but they are dealing with water above eight
23
Alicia K. wooters, RPR AR3Q8883
Official Court Reporter
-------
1 hundred feet. It's not an arbitrary number. It is a
2 judgmental number, .but'-'what-we. decided in consultation witt
3 USGS is eight hundred feet is the depth of the deepest well
4 in the Gettysburg area. To go beyond that is.probably not
5 productive.. This is not a selected, remedy.
6 We are here to take public comment. We expect to have
7 comments from the public. We expect to have comments
S submitted by the responsible parties at the site. These are
9 the alternatives that were evaluated. Remedial action
10 alternative A, no action. Remedial alternative B, ground
\
5
11 water extraction, chemical oxidation using UV catalysis.
12 Ground .water extraction with treatment by aqueous phase
13 carbon absorption in burial areas one and two. The reason
1.4 it's divided irico two pieces is that the plumes do not
15 contain identical contaminants. There is one area of the
16 ground water near the lagoon that had what we call vinyl
17 chloride and there are many technologies will not work for
18 vinyl chloride.
19 Therefore, the lagoon area ground water we looked at on
20 a two part basis. Splitting the ground water up and some of
21 these are combined for site wide remedies. Chemical
22 oxidation using UV catalysis. This is a process where
23 peroxide is added to the ground water and ultraviolet light
24 splits the molecule apart and releases oxygen which destroys
25 the contaminants.
24
Alicia K. Wooters, RPR AR308881*
Official Court Reporter
-------
1 It*s almost the same technology if anyone has soft
2 contacts and they add peroxide to that, it destroys organics
3 that accumulate, on the lens-.
4 Carbon absorption is a very proven technology.
5 Activated carbon has been used to remove contaminants from
6 foods and many other options. It's widely used in remedial
7 activities. This alternative would involve passing water
8 through an activated carbon bed for the one area of the site
9 and in the other area of the site the more aggressive
10 oxidation UV catalysis,
11 Remedial alternative C, ground water extraction with
12 chemical oxidation using UV again and air stripping and the
13 air stripping process water trickles down through a tower
14 that is packed with little plastic balls and air flows up
15 and the volatile contaminants dissolve from the .water and go
16 into the air. Then they will be captured as they pass
17 through an activated carbon bed and that is the other
18 technology that was evaluated.
19 . Ground water extraction, chemical oxidation of
20 contaminants using UV for off site ground water. Ground
21 water extraction air stripping and catalytic oxidation for
22 the lagoon area and aqueous phase carbon absorption for drum
23 burial areas. Basically the same technologies we talked
24 about just looking at different combinations of how we can
25 do this and what might be more cost effective.
25 .
Alicia K. Wooters, RPR AR308885
Official Court Reporter
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1 Alternative F, ground water extraction, air stripping
2 and catalytic oxidation for the lagoon area. Air stripping
3 carbon absorption for the drum burial areas.
4 Alternative G, ground water extraction, air stripping
5 catalytic oxidation for off-site ground water. These
6 alternatives with the catalytic oxidation water passes down
7 through the stripper, air comes up through the stripper and
8 absorbs the contaminants and then it passes over a heated
9 catalyst bed which destroys the chemicals as it oxidizes
10 them. Your end products are carbon dioxide, water vapor and
11 some traces of chlorine probably lower than what comes out
12 of your dishwasher.
13 .Alternative G is ground water extraction, air stripping
14 and catalytic oxidation of contaminants in ground water and
15 that is EPA's preferred alternative.
16 Alternative B is aggressive aquifer remediation. This
17 is the one we're going to extract at a more rigorous rate
18 and reinject and EPA did not prefer that for several
19 reasons. One, with reinjection you introduce a degree, of
20 unpredictability.
21 By injecting.water into the formation you could force
22 it to * crack where you don't want it to go. Also in ground
23 water remediation sites like this it's more effective in
24 many cases to pump at a lower rate or to do what EPA calls
25 false pumping. Tou pump for a while/ shut the pumps down,
26
Alicia K. wooters, RPR flR308886
Official Court Reporter
-------
I let the "contamination build up and collect it and treat it
2 efficiently. . .
3 The-other way is to extract it ".lowly and treat it a-t a
4 rate where it contains enough contaainants to make it cost
2 effective. These give you some of the costs of the
6 remedies. I'm not going to belabor all these. The proposed
7 plan is out. I realize this can be a little dry.
8 Unfortunately, Hunterstown Road has so many different areas
9 and so many different alternatives evaluated, this becomes
10 necessarily complex, but I at least wanted to give you an
11 overview.
12 EPA looked at the soil areas and they are evaluated
13 from no action, soil cover, under the soil cover' about a
14 foot arid a half soil would be put over a geotextile. This
15. is simply like a plastic cloth. It allows water to
16 penetrate it. It's not a membrane liner like a low
17 permeability cap for hazardous waste. What that would do,
18 it would be a visual marker. If the soil were to erode away
19 . in the future, you could see the liner and know you had to
20 do something with that soil.
21 A low permeability cap is a cap where either several
22 feet of clay or something like a swimming pool liner is
23 placed over that clay and it prevents water from going
24 through the waste underneath it and absorbing contaminants
25 and moving into the ground water. The water will run off of
27
Alicia K. Wooters, RPR AR308887
Official Court Reporter
-------
1 the cap. and it basically keeps water from leaching through
2 the waste. .
3 Excavate, treat and dispose off site. The material
4 would be excavated. It would be treated depending on its
5 nature. If it contained organics, i-t would be incinerated.
6 If it were containing metal wastes, then a technique called
7 solidification/ which involves mixing something almost like
8 making cement. There are. several additives that are
9 involved. The soil or the waste is mixed with these
10 additives and it sets up into a hard mass and water cannot
11 pass through it easily and it reduces the Leaching by a very
12 large amount. Tiny amounts of materials can still pass.
13 through into the ground water, but it reduces it by in many
14 cases greater than ninety percent. Sometimes greater than
15 ninety-nine percent depending on the technology.
16 Excavate, stabilize on-site and dispose of off-site.
17 It's essentially the same thing I talked about stabilization
18 but in. this case rather-than sending it off site for that
19 treatment it .would be treated on site and then sent to the
20 disposal area. .
21 Excavate, soil washing and dispose off site. The name
22 basically tells you what's happening there. The material is
23 mixed with water or water containing another solvent to help
24 disperse contaminants from the soil and then the soil is
25 separated and then that water needs to be treated.
28
Alicia K. Wooters, RPR
Official Court Reporter
-------
1 In*situ stabilization. This is very similar to that
2 making cement type technology but instead of digging the
3 material up -and mixing it in what we call a pug mill with
4 the additives. It is a machine that travels over the
5 surface and mixes these into the soil, sort of rototills it
6 into it and forms a solidified mass on the surface which
7 prevents leaching.
8 These technologies were looked at across the board for
9 all the different soil areas and to try to simplify things
10 as much as I could, areas that contained similar
11 contaminants EPA lumped into one group to try to deal with
12 those in their remedy selection for that area rather than
13 have to go through it over and over again for each area when
14 there were similarities.
15 The stress vegetation area is represented there and EPA
16 favors excavate, treat and dispose of off site. The stress
17 vegetation area contains very, very high levels of toxic
18 metals. I believe there was one sample at 50 thousand parts
19 per million of lead. EPA's action level is five hundred so
20 it's grossly in excess of what we would leave. That level
21 would generally demand treatment.
22 We combined the cornfields and the borrow area into one
23 unit because they both contained relatively low compared to
24 the stress vegetation area metals and other inorganic
25 contaminants and EPA's preferred alternative for this area
AR308889
Alicia K. Hooters, RPR
Official Court Reporter
-------
1 is a soil cover.
2 Orie thing EPA has to deal with is lead levels, and
3 there has been a controversial issue across the country.
4 EPA has had to make a lot of difficult decisions as to how
5 to set lead levels. There was a study done that I talked
6 with a citizens group where there is some indication if soil
7 outside a house is above two hundred parts per million, then
8 that vould pose an unacceptable risk. That is based on one
9 mathematical model. The standard mathematical model has
10 yielded safe levels for residential areas of five hundred.
11 We recently had a directive from our headquarters as of
12 right now that five hundred parts per million level is what
13 we should be using as a general rule.
14 The cornfraids do contain other contaminants, they
15 contain mercury and they did have, if a child 'were living on
16 the site actually eating the soil there with no other
17 preventive measures, it did have unacceptable hazard indices
18 and did require action. But we believe that the soil cover
19 is adequate to prevent exposure. This area has not leached
20 metals into the ground water, and we believe that placing a
21 soil cover would prevent exposure by trespassing children
22 'and ia fully protected for this area.
23 The lagoon area undoubtedly was the worst area of the
24 site. Very large amounts of solvents were disposed there.
2.5 Very toigir levels* of lead, chromium and other toric metals
30
Alicia K. Wooters, RPR
Official Court Reporter
AR308890
-------
1 includrng mercury were discovered there before the removal
2 action. Also samples taken not. by Westinghouse but by EPA's
3 emergency response people showed a multitude of other
4 compounds. Different organic materials, phenyls, other
5 things at low levels.
6 During the P.I a lot of that was not detected, but there
7 is still some risk there could be soil samples that we
8 haven't, found and the lagoon area does still contain
9 unacceptable levels of metals and an unacceptable hazard
10 index. EPA's preference is to excavate and treat and
11 dispose off site. This would involve taking about two feet
12 of soil from the lagoon area and sending it for off site
13 treatment disposal. Soils that contained volatiles would be
14 incinerated and soils that contained primarily metals would
15 be solidified*
16 Other alternatives that were evaluated is drum burial
17 area one, since all the waste had been taken out of there
18 and all the residue, all contamination remained, the only
19 thing evaluated was a low permeability cap to prevent
20 leaching through that material. Since the ground water
21 table is often above that level and because the levels are
22 relatively low compared to some of the contaminants that
23 Bruce already showed you that are very deep in the bedrock,
24 we believe that we should just deal with this efficiently
25 with one unit with the ground water.
31
Alicia K. Wooters, RPR
Official Court Reporter
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1 Drum burial area two contaminants weren't detected and
2 for those soils we don't believe there is any additional
3 action warranted. Sediments in the east stream were
4 contaminated and we proposed removal of those sediments from
5 the east stream and from a very small section of the west
6 stream. The surface water does contain low levels of local
7 volatile organic hydrocarbons and it does contain particles
8 ' of metals that have washed down from these other
9 contaminated soil areas. We believe what will happen when
10 we take the mitigated measures for the other areas that will
11 be eliminated, the contaminated ground water will not
12 discharge to those streams and the metals will not be
13 transported by surface water run off. We believe no action
14 is needed at this time, and we will reappraise this after
15 the remedy is completed to make sure that hypothesis is
16 correct.
17 One other alternative was the cost.of wetlands
18 replacement. This gives you an overview of what EPA is
19 proposing graphically. This is the east stream that travels
20 between the lagoon and the borrow area. This is the area
21 that contains the contaminant sediments. This is the lagoon
22 area. This is the stress vegetation area. The dotted areas
23 here, these kind of shaded areas are areas that EPA should
24 be excavated and treated off site and disposed of. This
25 area that's crass hashed, EPA believes is appropriate to
32
Alicia K. Wooters, RPR AR308892
Official Court Reporter
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1 place^a soil cover and one thing EPA is also proposing is
2 these dotted Lines were fairly arbitrary. Westinghouse
3 contractor never determined them by large amounts of .
4 statistical sampling. They are fairly arbitrary in nature
5 and since clearly some run off could have occurred down
6 slope from these areas, that soil cover .should be extended
7 over these areas.
8, This is drum burial area one., no action. Drum burial
9 area two, no action and this is the section of the middle
10 stream that had low levels, low levels but levels that were
11 still of concern to EPA's biologist that ve plan to also
12 remove. Because the stress vegetation area, the lagoon area
13 and this sediment right here, all are in the wetlands area.
14 . Whenever one of EPA's remedies impacts the wetlands,
15 EPA is required to go back and replace the value of that
16 habitat. We coordinate with DOI and fish and wildlife
17 service and other agencies that have responsibilities for
18 wetlands and EPA is proposing creating an artificial
19 wetlands at the inlet to the middle .stream and all this
20 probably needs to be is some excavation to create a shallow
21 area that will hold water after rain and can build up
22 cattails and other things and possibly when the soil cover
23 is reseeded it can be reseeded with vegetation that's
24 beneficial to wildlife.
25 Rather than drag you through all these individual
33
Alicia K. Wooters, RPR AR308893
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1 costs, -let me come up with the total. The total for the
2 remedial action EPA is proposing is about nine point two
3 million dollars. It's detailed and broken out in the
4 proposed- plan and a Lot of things we talked about tonight
5 already have been summarized in the fact sheet.
6 At this point in time I'm done with my technical
7 presentation. I want to emphasize that EPA has not selected
8 this remedial action. This is what EPA believes are the
9 best alternatives for the site and it is soliciting comments
10 on these alternatives and this is why we are here tonight
11 and I guess I'll turn it over to Virginia. Do you want to
12 say anything?
13 VIRGINIA MOSELEY: If you're ready for questions,
14 do you want to leave that up or do you want to turn that
15 over. I do have a couple of questions on cards, but first I
16 would like to know if anyone in the audience has a question,
17 if you would like to stand and state your name and your
18 question or your comment for either Mr. Vavra or for Bruce
19 Rundell on their presentations this evening. If you have
20 any other questions as they specifically relate to the
21 Hunterstown Road Superfund Site.
22 VIRGINIA MOSELEY: Yes, sir?
23 DON WADDELL: My name is Don Waddell, and I would
24 like to comment on the news press release for this meeting;
25 I don't know, I received my fact sheet yesterday. Merle
34 &R30889l»
Alicia K. Wooters, RPR
Official Court Reporter
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1 received his today. Congressman Goodling did not receive
2 his at all yet. I think whoever sent them out done a poor
3 job. In the paper, I did not see it in the paper. Merle
4 told me Last night it was in the paper that you mentioned
5 back -- •
6 VIRGINIA MOSELEY: Saturday the 24th of April it .
7 was in two papers and then again on Monday in two papers.
8 . DON WADDELL: And the night was wrong. In .other
9 words, it mentioned Thursday night instead of tonight. I
10 think if we would have had the right information out ahead
11 of time/ we would have had more people here/ more concerned
12 citizens. What can I say, but I mean, I just got my fact
13 sheet yesterday. Congressman Goodling did not get his yet.
14 I called DC today and he did not have it. He did not know
15 anything about this meeting. He's on the mailing list.
16 Merle received his today, so I assume he'll receive his
17 tomorrow. That's a continent I'm very much concerned about.
18 VIRGINIA MOSELEY: Appreciate the comment.- They
19 were mailed but last week., and we'll certainly look into why
20 they weren't received before that. Does anyone else have
21 any comment or question, anything to add?
22 MERLE BANKET: Merle Hankey. My question is for
23 Mr. Spontak of Pennsylvania Department of Environmental
24 Resources. I'd like to know what OER's opinion of EPA's
25 proposed alternatives here and if you agree with what the
35
AR308895
Alicia K. Wooters, RPR «woo 33
Official Court Reporter
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1 EPA proposes to do.
2 JIM SPONTAKi EPA sent as the draft proposed .plan-
3 several weeks ago. We had ample opportunity to review it.
4 I.t was reviewed by myself, my supervisor and hydrogeologist.
5 We have no -- we are in agreement. Let's say it that way.
6 We are in agreement with their proposed plan. There are
7 certain limits and values we need to discuss with them but
8 those will be handled in the design stage and in the ROD
9 stage, but basically we are in agreement with everything
10 they" are proposing and the way they intend to do it.
11 MERLE HANKEY: And another question concerning
12 what Mr. Vavra said is EPA's acceptable limits for lead,
13 what is DER's acceptable limits for lead?
14 JIH SPQNTAK: That is still being worked on. we
15 have something called a lead task force who has been
16 wrestling with this problem for probably three years now.
17 We originally set the lead limits at two hundred but that
18 has been revised upward and it's still under discussion.
19 EPA used to go with a thousand parts per million lead level.
20 Now they drop it to five hundred. I can say personally five
21 . hundred seems like a reasonable number because of the
22 exposure pathways here.
23 RESIDENT: Five hundred parts per million for
24 lead, what kind of standard are you quoting there?
25 JIM SPONTAKs I don't understand your question.
3fi
Alicia K. Wooters, RPR 18308896
Official Court Reporter
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1 " RESIDENT: I thought you were talking about lead.
2 JIM SFONTAK: Yes, I ant. .
3 RESIDENT:. What kind of standard are you quoting?
4 Did you say five hundred parts per million? what kind of
5 standard are -you quoting?
6 FRANK VAVRA: That's a policy for soils. Lead in
7 soils. .
8 RESIDENT: Policy for soils.
9 VIRGINIA MOSELEY: Any other questions? Yes, sir.
10 MERLE HANKEY: I have a whole lot. So, you know,
11 like it's going to be awhile if anybody else would like to
12 ask some questions.
13 VIRGINIA MOSELEY: I do have two.cards that were
14 turned in; The first question is how do citizens get.in
15 touch with, one, an EPA ombudsman and two the EPA inspector
16 general? Please explain their rights. I assume you mean
17 the people's rights. Who would like to take that?
18 JEFFREY PIKE: The inspector general for EPA is
19 available for citizens who want to make a complaint or
20 whatever about actions that the agency is taking. I don't
21 . have their number handy, but they do have an eight hundred
22 number. We can track that down and provide that to you if
23 you want to come up and ask us afterwards we'll get that.
24 Also our general number with our regional office can provide
25 that and that general number is 215-5*7-980.0. and they can
37
Alicia K. Wooters, RPR AR308897
Official Court Reporter
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1 provide-or connect you with the regional inspector general.
2 I'm not familiar with the £2A ombudsman process. I'm not
3 sure how I can address that.
4 AL PETERSON; That's out of headquarters and- we'll
5 get you that number. Virginia will get it for you. I don't
6 think it's an eight hundred number, but we'll find a way for
7 you to get in touch with them. .
S RESIDENT: Would you explain the rest of my
9 question? Explain their rights regarding the inspector
10 general and the ombudsman.
11 JEFFREY PIKE: I'm not familiar with the ombudsman
12 so I can't really explain that, but the rights being people,
13 any citizen can call and make a complaint.
14 MERLE HANKEY: Concerning?
15 JEFFREY PIKE: EPA actions.
16 RESIDENT: Could you explain their rights and what
17 the inspector general can do for them and what the ombudsman
18 can do for them?
19 JEFFREY PIKE: I'm not really that familiar 'what
20 they can and can't do. I don't really know how to address
21 your question*
22 AL PETERSON: Let m« take a shot at it. The
23 inspector general, if you have a specific complaint that you
24 want to allege that we've been ineffective and we have been
25 unsatisfactory and we have been incomplete in our handling
38
Alicia K. Wooters, RPR
Official Court Reporter
AR308898
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1 of something, they will take your allegations and
2, investigate them with.any evidence that you have to provide
3 and check them against any documentation that we can offer
4 to substantiate what we have done and that's the inspector
5 generals job.
6 The ombudsman is a liaison between you and the agency
7 and•they are a headquarters function. If you feel as a
8 citizen, or as a citizens group feel you are not get-ting
9 adequate responsiveness from us, that we are not responding
10 to your concerns completely or adequately, that we're in any
11 way offending a citizens group or any of those kinds of
12 lines, the ombudsman will intervene and try to liaison
13 between the region and the citizens group.
14 Maybe we're not hearing something right, and the
15 ombudsman will come in as a totally disinterested third
16 party because as a region we may have something we proceeded
17 along a certain track and sometimes you get blinders on or
18 just because people are involved, the ombudsman can come in
19 as that third party and help bring your concerns to us so we
20 can start working more closely together.
21 RESIDENT: Do you have any idea where they could
22 call for this?
23 AL PETERSON: I do not know where it is right now.
24 It's a new person. He's only been in the job a couple of
25 months. I have not been in touch with the person myself,
39
Alicia K. Wooters, RPR »°308899
Official Court Reporter
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1 but we will get you a name and a phone number. If you want
2 to make sure that Virginia has your, name and number and
3 we'll get it to you. We'll also get it in another fact
4 sheet for. you.. In case you're wondering who this guy is,
5 I 'm Al Peterson and I'm her boss.
6 RESIDENT: What's your position?
7. . AL PETERSON:. I'm the chief of the superfund
8 community relations section.
9 RESIDENT: Your telephone number?
10 AL PETERSON: 215-597-9905.
11 RESIDENT: Chief of?
12 AL PETERSON: Superfund Community Relations
13 Section. . . ' . • .
14 VIRGINIA MOSELEY: I'll read the last card and
15 then we can go back to direct questions if that's all right.
16 The other question is, has the community been made aware of
17 and been provided with an ATSDR, one, community assistance
18 panel; two, health consultations; three, health assessments.
19 If not, why not and when?
20 FRANK VAVRA: ATSDR did what was called an SRU
21 which is a preliminary evaluation. After the feasibility
22 study they will then submit a complete health assessment
23 from their perspective. The SRU has been submitted. I
24 believe the health assessment has not been submitted.
25 MERLE BANKET: What is the time frame for that
40
Alicia K. Wooters, RPR AR30891
Official Court Reporter
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1 having 'to be submitted?
2 ' FRANK VAVRA: I'm not responsible for that. ATSDR
3 works under a separate group. They periodically as they
4 schedule reviews, they will request information or documents
5 from me and I provide those documents.
6 MERLE HANKEY: I understand that that's not your
7 responsibility that it is the ATSDR's responsibility but
8 under SARA weren't they given a certain time frame they had
9 to provide these health studies or these studies be done.
10 JEFFREY PIKE: Yes, there was a time frame.
11 MERLE HANKEY:. These studies were not done. They
12 did not follow the time frame. :
13 JEFFREY PIKE: I-know a lot of them are still
14 ongoing and they have bad problems keeping up with, the -
15 schedule.
16 . MERLE HANKEY: The health studies have been
17 initiated.
18 VIRGINIA MOSELEY: I would like to call on Felicia
19 . Daley, who is a former employee of ATSDR and currently
20 working for EPA.
21 FELICIA DALEY: The ATSDR is a health assessment.
22 There is a difference between a health study and health
23 assessment. The health assessment, they are mandated by law
24 to have them put in a certain time frame but the time frame.
25 is not mandated by SABA. Tn« time frame was set by the
AR30890I
Alicia K. Wooters, RPR
Official Court Reporter
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1 agency.. They have not met those time frames. They are
2 behind in doing health assessments on all the sites that a
3 on the APL list. In terms of where they are in the process
4 for this particular st'te, I'm not.--sure,-but they do take the
5 information that was gathered, the'technical information
6 that's gathered by EPA and they look into that and assess
7 just from a public health standpoint. It's separate from
8 EPA so EPA:'has no bearing on it. They can't — all ATSDR
9 does is make recommendations to EPA or recommendations to
10 the\state. It is not by law that EPA has to follow those
11 recommendations either. They just make recommendations on
12 things to protect the public health.
13 In terms of the health consultation process, that
14 process is not an automatic. It's different. What the
15 health consultation is is a quick usually one or two
16 question report that's done real fast to give an answer to
17 most times to EPA about a particular contaminate or
18 particular problem at a site. It's usually done in what's
19 called the emergency response phase if there's an emergency
20 response action at a Superfund Sit*. That has to come at
21 the request of either the state or EPA. It's not done
22 automatically across the board. A health consultation, is
23 not don* on every site but a health assessment is. When
24 they get them done they are behind, but they are by law
25 mandated to do a health assessment oh all NPL sites.
Aiici. K.'Lt«.. *PR 1R308902
Official Court Reporter
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1 - RESIDENT: Thank you. Miss Daley, can I follow-up
2 on that because this is rather important. You mentioned,
3 Miss Daley, that the human health effects were the things
4 that were addressed but in point of fact ATSDR's mission is
5 to quote, mitigate adverse human health effects and
6 diminished quality of life resulting from exposure to
7 hazardous substances in the environment and that's the thing
3 we would like to see addressed at all superfund sites.
9 It fails to take in the health assessments to date, as
10 far as we know, have failed to take in the
11 psychopathological aspects of exposure, has nothing to do
12 with the MCL's or simply exposure to contaminants in their
13 environment and this so far as we know has not been
14 addressed. If it has been addressed at any EPA sites, we
15 would really like to know about it. We would like to see
16 .that the second part of the mission where it says health
17 effects and diminished quality of life resulting from
18 exposure to hazardous substances of the environment, we
19 would like to see that action take place.
20 FELICIA DALE?: It's a separate agency, ma'am.
21 ATSDR is a separate agency from EPA.
22 RESIDENT: Working with EPA?
23 FELICIA DALE?: They work in conjunction but EPA
24 has no saying on the bearing of what happens at ATSDR and
25 vice versa.
43
Alicia K. Wooters, RPR
Official Court Reporter
UR308903
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1 - RESIDENT: They don't recommend to each other?
2 FELICIA DALEY: We cecommend to EPA period.
3 RESIDENT: That's what I'm asking. You're with
4 EPA?
5 FELICIA DALEY: Now, yes.
6 VIRGINIA MOSELEY: We would be happy to continue
7 that, and I'm sure Miss Daley would make herself available
8 after the meeting and give you some names and. numbers so you
9 can address that to the appropriate people, and I thank you
10 for bringing that up. We will take care of that.
11 FRANK VAVRA: Just before we leave the ATSDR
12 issue, Merle, you and Don should know in fact that's under
13 way. When I last met with you, I discussed the fact I had
14 spoken with ATSDR and in fact because of some of Don's
15 concerns, his personal concerns with his family, I made a
16 special phone call back in the office to the ATSDR
17 representative and asked them to include a specific
18 follow-up on the people that you thought might have been
19 impacted and they indicated when they did the health
20 assessment they would make those contacts.
21 DON WADDELL: Nobody has contacted us. That's the
22 point. At this point nobody knows anything about it.
23 MERLE BANKEY: My concern was would there be a
24 recommendation from ATSOR before your ROD is given?
25 FRANK VAVRA: I think it's unlikely.
44
, w
Official Court Reporter
Alicia K. Wooters, RPR AR3089CH*
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1 - MERLE HANKEY: Can you press for it?
2 FRANK VAVRA: I-can. go back to the office and
3 check the status.
4 MERLE HANKEY: I'd appreciate it. This is
5 something we have been waiting for for a long time. We have
6 been coming to these meetings for ten years. I've aged a
7 hell of a lot in the last ten years. I'm still waiting for
8 this, information and I'haven't gotten it.
9 FRANK VAVRA: Jeff is probably going to kick me
10 under the table for this. Frankly, you look at the risk
11 assessment that was done with respect to this site, it's
12 this thick by people that have been knowledgeable about the
13 site for years. Frankly ATSDR has been criticized much in
14 the past because they don't have the manpower to really do a
15 full blown job on this and if you really believe that
16 putting somebody on this for a couple of weeks to take a
17 look at it is going to do a better job than the index risk
18 assessment that was done specifically for that site in very
19 great detail and reviewed by EPA's toxicologist, I don't
20 know —: I don't know you're going to get anything superior
21 out of that. If you're looking for a higher level, I don't
22 think that's where you'll find it. I think the most
23 detailed risk assessment evaluation is the one that's been
24 mailed to you. That's a personal opinion.
25 MERLE HAHKEZt If you want to give a personal
AR308905
Alicia K. Wooters, RPR
Official Court Reporter
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1 opinion, several years ago the EPA stopped allowing the
2 responsible parties to do the risk assessment; isn't that,
3 correct? I think there was a reason for that. It's like
4 the fox guarding the chicken house. They no longer allowed
5 responsible parties to do the risk assessments. Whether you
6 had people go over or not, I personally don't trust a risk
7 assessment that Westinghouse paid for. I want somebody
8 else's word on this other than Westinghouse. That's all I'd
9 like to see before a ROD is issued.
10 VIRGINIA MOSELEY: That is being entered in the
11 . record.
12 - JEFFREY PIKE: Can I follow up on that? .You're
13 right, there has been a new policy, I think it's about a
14 year and a half, two years old that for all newer EPA will
15 do the risk assessment itself. The work done here was prior
16 to that or at least the order we're doing this work under
17 was prior to that. This risk assessment was done with
18 responsible parties but our toxicologist will have reviewed
19 that work and critique that and prior to the issuance of the
20 ROD because it is a responsible party produced risk
21 assessment, the toxicologist has to certify the risk
22 assessment. The EPA toxicologist.
23 MERLE BANKEY: Okay, thank you.
24 VIRGINIA MOSELEY: Yes, sir.
25 KEN BIRDs My name is Ken Bird. Follow-up to Mr.
46
Alicia K. Wooters, RPR AR308906
Official Court Reporter
-------
1 Waddell's comment about the notice here, what is EPA's
2 policy about possibly extending, the comment period? You
3 mentioned the site is very complex. People have just gotten
4 the fact sheet now. Some people probably just picked up the
5 remedy. Possibly extending it a few. weeks to give people
6 some more time to look at this complex situation and how you.
7 go about requesting EPA to do that.
8. . JEFFREY PIKE: We have a thirty day comment .
9 period. There is a lot of material to review. If people
10 feel 'there is more material than amount of time they feel
11 they can put into looking at that, if you will send us a
12 request for an extension, we can grant a thirty day
13 extension.
14 I want to also add that we're trying to keep the
15 project moving. It has been a long time until this
16 information is available. Please consider whether you
17 really need an extra 30 days for that. If we do receive the
18 request, and I think the address is on the handouts, we can
19 extend.
20 KEN BIRD: Somebody could say a month from today
21 or something which is not 30 days.
22 JEFFREY PIKE: What our policy is we extend the
23 period 30 days from the end of the original period, it vould
24 be a total of 60 days if someone were to request an
25 extension. We are not in a habit of giving a five day
AR308907
Alicia K. Wooters, RPR
Official Court Reporter
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1 extension or whatever. Thirty days or nothing.
2 . KEN BIRD: I guess I have to write a letter to
3 request it.
4 DON, WADOELL,: Can't, they request verbal tonight?
5 That's how it's been done in other meetings.
6 JEFFREY PIKE: I'm only hesitating* now. We
7 received a request last year from another site like that,
8 and we didn't get a comment from that person. •
9 VIRGINIA MOSELEY: I want to remind you too that
10 copies of the plan have been made available tonight. They
11 are here, so you don't have to go to the library, copies of
12 the fact sheet which summarize very concisely what's in the
13 plan and also the names of the people and the addresses of
14 the people involved if you have any questions or comments.
15 Addressing the issue that people did receive these just
16 recently, we do have a gentleman here from the press and I'm
17 sure the members of the community are going to be made well
18 aware of what's available and where it's available, and we
19 encourage everyone to comment. That's why we're coming out
20 here to get your comments. They don't have to be physically
21 present this evening. You can certainly call us, write us,
22 however you want to continue to comment on this. Does
23 anyone else have a question? We will remain. Do we have
24 more?
25 MERLE BAMXEYt Yes.
48 .
Alicia K. Wooters, RPR flR3089Q«
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1 ' VIRGINIA MOSELEY: Okay, do you want to continue?
2 MERLE HANKEY: . First of all, I'd like to ask you
3 several questions concerning some things that I may
4 understand and may not understand about, your proposed plan
5 and the way some things are discussed in here. If you'd
6 like to look at your proposed plan or you might be able to
7 follow me oh this. I'm on page two of the proposed plan, .and
8 .it says as used in this plan "The Site" will mean the
9 Hunterstown Road Superfund Site which encompasses all
10 contaminated areas.
11 Now, I would like to know just exactly what does that
12 mean? Does that specifically mean the property that is
13 owned by Fred Shealer or will you consider the boundaries of
14 the. site, all areas that are also contaminated ..where the
15 ground water is contaminated?
16 FRANK VAVRA: That's a circular legal definition
17 that even in fact encompasses all areas contaminated.
18 MERLE HANKEY: It could be off of Fred Shealer's
.19 property? . • .
20 FRANK VAVRA: That's correct.
21 MERLE HANKEY: What specific rights by naming off
22 of Fred Shealer's property as part of the site, does that
23 give the EPA authority to go on that property and take
24 remedial action or do you have to have the approval of the
25 property owner? In other words, what I'd Like to get at,
49 AR308909
Alicia K. Wooters, RPR
Official Court Reporter
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1 what I understand about this, in your drawing here of drum
2 burial area•-number one, Frante, where this, extends way
3 beyond--
4 FRANK- VAVRA: The ground water plume.
5 MERLE HANKEY: The ground water plume, way beyond,
6 way beyond.
7 FRANK VAVRA: Yes.
8 MERLE HANKEY: If you were to come in here, could
9 you put deed restrictions on these properties -that are not
10 Fred Shealer's property? Can you prevent a property owner
11 who is not Fred Shealer and didn't do any dumping, can you
12 put deed restrictions on their properties to prevent them
13 from using the ground water?
14 FRANK VAVRA: Could it be done in theory .
15 hypothetically, yes, but it's not EPA practice to do so.
16 EPA does have the authority to protect public health and can
17 issue a unilateral order under circumstances where they
18 cannot get cooperation in addressing the site. However,
19 that's just simply not the way EPA works with the public.
20 Typically where any of these sites, if there are responsible
21 patties, EPA compels the responsible parties to seek access
22 agreements.
23 MERLE HANKEY: To go into that a little bit
24 further, if you're a property owner of a Superfund Site, you
25 could potentially be a responsible party.
50 AR3089IH
Alicia K. Wooters, RPR
: Official Court Reporter
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1 - FRANK VAVRA: No. No, I don't think so.
2 JEFFREY PIKE:. I think in the grand scale, yes.
3 FRANK VAVRA: Right, but not with this particular
4 instance where you have ground water under those areas.
5 MERLE HANKEY: What I'm getting at,, would EPA ever
6 invoke any kind of a rule or law that somebody who is not a
7 property owner where there was surface contamination but
9 only where there is ground water contamination, could they
9 be ever named as a responsible party, because they didn't
10 maybe completely agree with what EPA wants to come on their
11 property and could you invoke any kind of rights to come on
12 their property and do it?
13 FRANK VAVRA: If you called me up I'd pick up the
14 phone and call the lawyer on the site. I don't imagine EPA
15 would ever try to be that heavy handed. I can't speak for
16 every region and every person that works in the agency but
17 that would not be normal. That would be highly unusual.
18 MERLE HANKEY: My area of concern with my
19 discussion on this is exactly the ground water plume as it's
20 leaving that drum burial area number one. You're testing,
21 as your testing has shown, your testing has only gone down
22 to what? Four hundred eighty-five feet approximately, in
23 that neighborhood?
24 FRANK VAVRA: Roughly five hundred feet.
25 MEPLg HANKEY: The municipal authority wells in
51
Alicia K. Hooters, RPR An3.083 I I
Official Court Reporter
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1 the ar-ea it's my understanding go down to a depth of eight
2 hundred feet.
3 FRANK VAVRA: The deepest well is eight hundred
4 . feert.
5 MERLE HANKEY: Potentially if there is a developer
6 in that area who is looking to develop the land next to that
7 site and if he can't hook on to municipal water, he's going
8 to have ta'drill his own. wells and he might get into that
9 zone right there. Is there anything that the EPA can do to
10 protect or DER can do such as any type of land use
11 restrictions, restrictions on subdivisions or anything Like
12 that to be sure that people in the futuce don't go out. and
13. punch wells and bring water into people's homes, because.you
14 know and I know we can't smell this stuff, we can't feel it,
15 we can't taste it. We don't know it's in the water. To
16 protect people maybe from realtors, developers whatever who
17 maybe know or don't know this Superfund Site is there.
18 There's a potential foe development around these sites.
19 It's zoned residential.
20 FRANK VAVRA: I understand your concern. I tried
21 to follow-up on this with both the state and the local
22 officials. My understanding is there's really no one that
23 has the authority right now to put individual deed
24 restrictions on. The only way that could be accomplished is
25 EPA would have to probably issue a unilateral order to each
52
Alicia K. Wooters, RPR AR3089. .
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1 and ev-ery person that was involved and my understanding is
2 to date that would be something totally new. That, hasn't
3 been done except in extraordinary circumstances.
4 I think one of the problems is that the Gettysburg
5 municipality in talking to the director of development, it's
6 only recently even there were building codes placed in this
7 area. Before that there weren't. In some other local
8 government structures it would be possible to do that. With
9 the Gettysburg situation, all the investigation I have done
10 to
-------
1 - JIM SPONTAK: That's correct. I believe Frank, to
2 the local • municipal-ities saying there-are contaminations in
3 this area. That's why the public information process is
4 going on. We're trying to make the public aware
5 contamination does exist in this area.
6 RESIDENT: Can you tell me why EPA, I mean a
7 government agency initiates policies all the time and given
8 the seriousness and the credibility, what Mr. Hankey is
9 asking here, why couldn't EPA instigate and implement a
10 policy such as the Maryland general assembly just within the
11 last weeks passed legislation requiring the sellers of
12 single family homes to have a disclosure statement attached
13 which has relationship to telling them what's in the area.
14 If there's- even a landfill in the area or any kind of
15 hazardous or regulated materials in the area. EPA could
16 certainly based on the knowledge you have and especially you
17 know where all the sites are. If you initiated a policy to
18 require this and then that would give a blanket protection
19 in all Superfund Site communities.
20 Mr. Hankey has a valid point and I support it. It's
21 very difficult for multiple municipalities around the state
22 to get into. It would take years if ever for this to happen
23 but you have tbe capability of relieving this situation for
24 everyone. Could you consider that?
25 JEFFREY PIKE: He will take that back as an issue.
54
Alicia K. Wooters, RPR AR3089
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1 I thinJc to date the agency has used the approach it's a
2 local governmental issue for them to look into these
3 restrictions but it is an issue I'm sure comes up many
4 times. We will raise it as an issue to our ground water
5 policy makers. . •
6 RESIDENT: Jeff, you're United States
7 Environmental Protection Agency, why don't you invoke your
8 powers to protect blanketly? Just blanket- everybody .with
9 that protection rather than waiting for municipalities to do
10 it who may never do it and then leave people at risk.
11 BRUCE RUNDELLs One thing to consider is that
12 we're an agency and we're governed by the laws that the
13 federal government write for us and that's where our
14 authority comes from. In our federal system, the federal
15 government does not assume all responsibility for
16 everything. They delegate certain things to the states and
17 to the local authorities. Your example of Maryland, it was
18 the Maryland State Legislature, the congressional body that
19 made the state law. It wasn't the Maryland Department of
20 Environmental Protection. It waa a law passed. There is a.
21 difference between policy and law. For the EPA or any
22 government agency to go out and in a sense put restrictions
23 on private property without the consent of the property
24 owners, we would get in a lot of trouble for that. It's
25 really a legal issue about property rights that needs to be
55
Alicia K. wooters, RPR AR3089I5
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1 addressed by legal elected authorities whether it's state,
2 localr or federal.
3 VIRGINIA MOSELEY: I thank you for your comments
4 and I certainly think they are very well taken and they have
5 been entered into the record. 1 would like to bring the
6 discussion back once again to Hunterstown Road Superfund
7 Site .which in fact is the reason we are here this evening,-
8 and as I said, those comments have been entered in the
9 record.
10 \ DON WADDELL: I think all these comments are
11 related to. the site.
12 VIRGINIA MOSELEY: I hear you talking about policy
13 in general.
14 DON WADDELL: I think basically we'r« concerned
15 about what we have gone through and we are concerned about
16 correcting this in the future for future sites and so on. I
17 think it all pertains to the site. Okay, go on. Hove on.
18 Unlike the Westinghouse site public meeting you had the
19 monitoring wells all placed and the additional wells all
20 pinpointed. This particular plan does not. I have trouble
21 .figuring out why that was not completed before you had this
22 meeting.
23 PRANK VAVRA: I think one of the things you have
24 to recognize, Don, is at the Westinghouse plant, site, Bruce
25 talked above this earlier, and again I didn't want to get
56
Alicia K. Wooters, RPR AR308~16
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1 too bogged down in technical details of each particular
2 remedy because there was so much to cover.
3 However, at the Hunterstown Road site, we have a
4 downgradient where at the Westinghouse plant site we had an
5 upgradient. It was a relatively simple situation to look at
6 the Westinghouse plant site and know exactly where we had to
7 place some pumping wells which were fairly limited in nature
8 right along in that contaminated bedding plane and then to
9 create some wells off site to capture where it escaped the
10 first capture zone.
11 However, although it's indicated in the ROD, you'll
12 notice where those locations are indicated there is a
13 caveat. This became an issue with Westinghouse because
14 there had been a graphical glitch in one of the scales on
15 that drawing. However, at the very bottom of that there was
16 a qualifier that said this is merely conceptual and that the
17 actual locations were to be determined during remedial
18 design.
19 This situation is much more complicated than the plant.
20 At the plant sit* the bedding planes.that Bruce talked about
21 were pointed down like this. Because it was next to a
22 creek, it appeared to be in a discharge zone. We had
23 greater pressures at depth in many of the units than we did
24 higher. This indicates that water was flowing up
25 discharging to the creek. In. discussions with DSGS, they
57
Alicia K. Wooters, RPR ""308917
Official Court Reporter
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1 confirmed that and said they weren't at all surprised by
2 that. The net ef feet was it tended to limit the downward
3 migration of contamination and moved it upward.
4 .In this situation, we have contamination at great depth
5 and while we have quite a few wells in the area, we don't
6 have enough wells to absolutely pin down exactly what the
7 plume looks like and its exact extent and we're going to
8 have to see how the aquifer responds there after we get some
9 wells in.
10 This design for Hunterstown Road site because of
11 complexity is likely to iterative. We will place wells. We
12 will see what happens. We're probably going to have to
13 adjust well locations, add additional wells as it
14 progresses-. It was actually at my direction to Westinghouse
15 that I asked them not to place those wells for the reason oi
16 technical uncertainty at this point in time. We are not in .
17 agreement. To come to an agreement where wells will be
18 placed will probably involve several meetings with our
19 geologist and Westinghouse and the other PRP's to decide
20 where these wells should be placed to affect the capture
21 zones we want to do. This is going to have to be determined
22 during remedial design and it's somewhat iterative.
23 Also, placement of wells often it's not just one place
24 that you can go to. Some of these wells axe likely to
25 involve other people's properties. I see no point in
»* SR3089I8
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1 puttiifg a well on a map that's likely to change in getting
2 some property owner upset about its location. We're going
3 to have to design these. We're going to interact with the
4 community and find out what are the acceptable locations and
5 where we can do this without causing someone too much —
6 DON WADDELL: Some of those wells may have to be
7 drilled in the Twin Oaks area. That's the development
8 there, because that's the way the plume is moving. .
9 MERLE HANKEY: Southwest.
10 DON WADDELL: It's going to surface somewhere. In
11 my understanding through discussions with you and different
12 other people, it's going to surface probably in around the
13 Rock Creek area, which is immediately behind Twin Oaks; is
14 that correct?
15 FRANK VAVRA: I'd have to have a map showing the
16 Twin Oaks development. I don't think so. The USGS —
17 DON WADDELL: Twin Oaks is between the plume now
18 and Rock Creek.
19 FRANK VAVRA:. If I'm sounding stupid, Bruce,
20 correct me. This is kind of the planes that we talked
21 about. The idea is that let's say this here area in blue is
22 drum burial area one. The idea is that it would move down
23 through that hydrogeologic unit and eventually reemerge.
24 This depth from what you're talking about would probably be
25 the Twin Oaks development where we believe it's too deep,
59
Alicia K. Wooters, RPR
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1 but I'll freely say we need more wells. We need to know
2 that. At this point in time that plume has not been closed.
3 it has to be.
4 As part of the proposed plan we talked about
5 identifying this area with the help of USGS is either doing
6 the work or providing oversight and direction to the PRP's
7 who conduct this study and we will identify this discharge'
8 area and we'll place monitoring wells down in that area.
9 USGS said that also most of this may be going so deep it
10 will take a very, very long tine period to emerge. It may
11 not even have gotten there yet.
12 JIM SPONTAK: That discharge area may be many,
13 many miles away from that. I think I know where you're
14 talking about. That Isn't that far away.
15 DON WADDELL: Then you go many, many miles that
16 you're talking about, then you're talking about Gettysburg
17 municipal wells, because they are two mile away.
18 FRANK VAVRA: We also looked at that and consulted
19 with USGS.and the well, I guess it's well number five that's
20 south along Hunterstown Road, that was the only one close
21 • enough to be of immediate concern and they believed that it
22 was too fat. X think it's too far to the east of that.
23 It's on tha sane side of the ROD as th« lagoon and the
24 bedding plane dips go this way. The municipal-wells will be
25 pulling water from an area over here.
60
Alicia K. Wooters, RPR AR308921
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1 - MERLE HANKEY: Quarter of a mile from where you
2 said it may surface, which is two wells and one Gettysburg
3 municipal authority is using right now is not well number
4 five.
5 FRANK VAVRA: We can talk, you can show me on a
6 map what your concern is. We looked at the well locations
7 that we know about to date. I understand they were placing
8 some new wells when I talked to the MUA and they told me
9 those were far away from the area of contamination. In
10 fact, we sent them a map showing the corridors of
11 contamination. We were concerned about either development
12 or placement of industrial park or any new municipal wells.
13 My understanding is they stayed far away from those areas in
14 placing their new wells, but I could certainly get you more'
15 information on that after the meeting and follow-up on the
16 issue.
17 MERLE HANKEY: Page five and six of the plan you
18 discuss the site environmental history. Back when you did
19 the removal—
20 FRANK VAVRA: I'm sorry?
21 MERLE HANKEY: Page five and six. Back when you
22 did the drum removal area from the burial areas/ it says
23 here that Westingbouse used an air stripper and discharged
24 the treated water into the middle and west streams. Was
25 that treated water water containing volatiles? What did
6i AR30892I
Alicia K. Wooters, RPR
Official Court Reporter
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1 that water contain?
2 FRANK VSVRAr That contained valatiles. I
3 it was discharged into the west stream which merges with the
4 middle stream. I don't believe it was directly discharged.
3 MERLE HANKEY: Did they require any permits to do
6 that? . • . '
7 FRANK VAVRA: Yes.
8 . MERLE HANKEY: Did they obtain those permits?
9 FRANK VAVRA: They got the limits from DER. Shaun
10 Rosenberger was the project officer at that point.
11 MERLE HANKEY: Did that require an MPD's permit?
12 FRANK VAVRA: I think it's equivalent.
13 MERLE HANKEY.: With MPD is .there is a public
14 comment period? In fact, until I got this I didn't'reven -
15 know it was done out there. I didn't know there was a
16 discharge into the stream out there.
17 FRANK VAVRA: The MPD's permitting requirement
18 takes a lot of work to get that and often years to do that.
19 If the people had to go through that to discharge a small
20 amount of water as we did this remedial work, none of these
21 sites would ever get cleaned up. Merle.
22 JIM SPONTAK: There is a waiver under the law says
23 they just have to meet the substantial requirements of
24 permit. They don't have to get the permit. They have to
25 meet the limits. Ar long as we approve tfa* limits, that's
AR308920
Alicia R. Wooters, RPR
: Official Court Reporter
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1 fine and it was only done on a temporary basis as Frank
2 said.
3 MERLE HANKEY: I was concerned about that. I
4 didn't, know it was done over there. It was my understanding.
5 that the stuff was hauled off site.
6 FRANK VAVRA: No.
7 MERLE HANKEY: To another facility.
8.,. , KEN BIRD: Could I clarify that? The water we're.
9 talking about, Mr. Hankey, is the hole was dug and the drums
10 were taken off site, any water in excavation was taken off
11 site. It was left open for a couple of years and it filled
12 with water. That is the water they are talking about
13 discharging. It wasn't any water during the actual removal
14 action. The hole was left open in both one and two. .That
15 is when it was taken off site a couple years later. It was
.16 treated with the air stripper.
17 MERLE HANKEY: I don't believe it was several
18 years. Several years means two years.
19 KEN BIRD: I don't know, a year later. I don't
20 know exact date.
21 FRANK VAVRA: I believe it was a year and a half.
22 BROCE RONDELL: Z think the point is it was
23 treated before it was put in the streams. Run through the
24 air strippers.
25 MERLE HANKEY: It was my understanding that
63
Alicia K. Wooters, RPR AR308923
Official Court Reporter
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1 anything that came into those drum buriaL areas as far as
2 leaching into those areas were removed off site in tank
3 trucks. I didn't know- anything had, been stripped on the
4 site and until I read this it was news to me, and I was just
5 wondering how it took place and what exactly was in the
6 water that was treated.
7 . DON WADDELLi. In the feasibility study.,, it. talked
8 about the borrow area indicating about asbestos and
9 indicated that several feet of cover was put on and then
\
10 during the RI they said that they sampled it and there was
11 no asbestos. However, in the feasibility study they said it
12 was. How deep did they go whenever they took their samples,
13 their second set of samples? •
14 FRANK VAVRA: My understanding of chronology is
15 there was a removal action. First there were large piles
16 taken away, and I believe there was a subsequent removal
17 action where some residual was taken away and then there was
18 about four inches, four inches of straw and two inches of
19 soil. There was a relatively small amount of cover placed
20 over top of plastic tarp. This was done by the removal
21 • group.
22 The sampling that was done in the borrow area, it was
23 various levels, many of those were near the surface and
24 you're probably correct they should have teen taken deeper
25 and in fact I think I've even discussed that in the proposed
64
Alicia K. Wooters, RPR AR30892tf
Official Court Reporter
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1 plan in-the background. I was not aware of that at that
2 point in time that that cover had been placed and
3 unfortunately the documents were in the removal group
4 apparently not in the file room when I was doing- the
5 sampling locations. Those materials were probably, I will
6 admit, probably most of those samples were taken from too
7 shallow a horizon. I discovered that later on and it's part
8 of my decision to include that borrow area as part of. the •
9 soil cover to make sure that there is enough safety factor
10 there for the amount of residual asbestos that's left there.
11 A soil cover is fully protective and that's what would be
12 done in most cases for asbestos contamination.
13 MERLE HANKEY: This is concerning drum burial area
14 one behind Fred Shealer's house. What you say here on page
15 eight at the top is TCE present in ground water at 26
16 thousand parts per billion but the highest level in soil
17 currently is nine hundred forty parts per billion. The
18 gasoline constituents, xylenes and ethylbenzene are present
19 in soils at higher levels than TCE but are not contaminating
20 the ground, water.
21 What would have been the source of the xylenes and
22 ethylbenzene and have the underground fuel storage tanks
23 been removed.
24 FRANK VAVRA: The xylenes were at the bottom of
25 the pit. They are unrelated in my opinion to Fred Shealer's
65
AR308925
Alicia K. Wooters, RPR vw^cg
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1 tanks on his active property. AS you know that was brought
2 to my attention by Mary Kennedy approximately a year and a
3 half ago,, and 1 followed up with o.ur underground storage
4 tank program and" they contacted the state. EPA does not
5 have enforcement authority for Fred's property. It's not
6 part of the Superfund Site.
7. We have wells, located that, would intercept
8 contamination emanating from Fred's property down to the
9 ground water table and in fact that was looked at to see if
10 in fact that could have been a cause. You can look, in
11 fact, some of the wells are even delegated S. I believe FS
12 for Fred, Fred Shealer. They actually were trying to see if
13 his property .could have been causing some of the
14 contamination behind there and we do not find those oily
15 contaminants. Those are very common contaminants,
16 constituents in gasoline. All the petroleum companies add
17 very large amounts of xylenes and toluene in gasoline to
18 bring the octane up.
19-- MERLE HANREY: What would have been the source of
20 them in the pit? Did any of the responsible parties have
21 that in their waste streams?
22 FRANK VAVRA: If Z had to take a wild guess, I
23 wouldn't be surprised if in fact Fred Shealer was the source
24 of that. It could have been old drums of gasoline or oil or
25 something of that nature.
AR30892f
Alicia K. Wooters, RPR
Official Court Reporter
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1 - MERLE HANKEY: Since this isn't your
2 responsibility as to whether the tanks have been removed or
3 not it falls into the lap of DER then, doesn't it?
4 FRANK VAVRA: They have enforcement authority.
5 MERLE HANKEY: I'll direct my question to Mr.
6 Spontak. Mr. Spontak, do you have any information as to
1 whether those tanks have been removed?
8 JIM SPONTAK: None whatsoever.
9 MERLE HANKEY: Can you find out?
10 . JIM SPONTAK: I can find out if they are
11 registered and what information we have on file about his
12 tanks.
13 DON WADDELL: . As you know, Frank, I am very much
14 concerned about your recommendation for the cornfield. You
15 received a letter that I wrote sometime last year voicing my
16 concerns. On page ten next to the last paragraph, quote,
17 "EPA usually considers remedial action necessary for soil
18 areas based on future use." Would you explain that, what
19 that means?
20 FRANK VAVRA: What that means is that, for
21 instance, if EPA, if there are MCL, maximum contaminant
22 level violations of drinking water where contaminants are in
23 drinking water on a property, they are not outside that
24 property. No one outside that property is using that
25 drinking water and no one seems to have contaminated wells,
67
' -
Alicia K. Wooters, RPR .««««A«-,
Official Court Reporter flR308927
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1 even if the property owner doesn't plan to use that water
2 for drinking water, we would still generally try to nritrgatfe
3 aquifer contamination and reach those standards.
\
4 It's a similar concept on the Hunterstown Road site in
5 that we have contaminants on the site in the lagoon
6 vegetation area and cornfields that right now are not
7 impacting people. People surrounding that site are not
8 impacted by the soils based on the calculations and the risk
9 assessment. However, if someone were to live there without
10 taking any additional mitigating measures, then they would
11 be exposed to unacceptable risk and this is why we have
12 triggered action and it's the basis for the remedies we're
13 proposing.
14 DOIT WADDELL: My understanding of that statement .
15 is entirely different than yours. I thought it meant that
16 you would consider the future use of the soil. In other
17 words, like I said in my letter, turn it back to its
18 intended use, farm lands and whatever and EPA does not
19 consider that in their decision. What it was used for
20 before?
21 • FRANK VAVSA: EPA does consider that. He are to
22 weigh that against other factors. We do consider, we do
23 consider future use. The future use I was referring to and
24 the way it was used in that paragraph is in the discussion
25 of risk.
68
Alicia K. Wooters, RPR
Alicia K. wooters, KFK «Donaft««
Official Court Reporter HnJU8928
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1 For instance, if you go to the risk.assessment, they
2 Look at risk from a multitude of scenarios. They can look
3 at risk to off-site residents. They can look at near site
4 residents. They, can look at people living on the site if
5 nothing were done. They can look at children. They can
6 look at young children because the risks across the board
7 are not the same for everyone. Children are more sensitive
9 to certain contaminants.
9 What I was referring to with future use, the future use
10 scenario where somebody actually lived on the site and how
11 that blends into risk and why I have to take an action.
12 Essentially it's laying out the justification for taking
13 .action. EPA also considers in its decisions the .future use
14 of that property and weighs that against the cost of .
15 restoring that property to its past use.
16 MERLE HANKEY: We're going to get into a
17 discussion about future use of the ground water and the
18 associated risk. According to the statement on page eleven,
19 the highest site risks from ground water use are derived
.20 from a future use scenario with children drinking the water
21 • from wells in the most contaminated portions of the plumes
22 on the Shealer property. Does that mean the plumes on the
23 Shealer property or does that mean the plumes that are now
24 off of the Shealer property? -
25 FRANK. VAVRA: That's assuming that if we placed —
69 AR308929
Alicia K. Wooters, RPR
Official Court Reporter
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1 do you remember the graphs that Bruce had that showed the
2 contaminant levels and it showed the heart of contamination.
3 The highest levels, that risk assessment assumed that you
4 popped the well in the very worst part of that plume. You
5 found the most contaminated portion of ground water and you
6 had those children drinking that ground water.
7 MERLE .BANKET: Whether it be on the Shealer. -
8 property or off Shealer property?
9. FRANK VAVRA: Right. In either case.
\
10 ' MERLE HANKEY: You can put institutional controls
11 on Fred Shealer's property but as we discussed before,
12 you're going to have a lot harder time placing institutional
13 controls off of Fred Shealer's property and what my concern
14 was with this, are they taking in the possible future use
15 into their future use scenario that they are not going to be
16 on Fred Shealer's property with these institutional
17 controls, they are going to be off site, off property?
18 . FRANK VAVRA: Of course. All this, is trying to do
19 is point out the maximum risk because EPA looks at these
20 areas for trigger levels and all this is doing is it's
21 • pointing out where tb« ground water contamination is well
22 above the trigger levels that would mobilize EPA to take
23 action for that ground water plume.
24 It's stating here's the worst case, it's-really bad.
25 We have got to do something. That's all it's saying. It's
76 Bfi30893P
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1 not saying the off site water doesn't have to be remediated.
2 It's not saying that children drinking the off site water
3 would be okay. It's just showing that we have got a very
4 strong trigger.for action. That is all the point that's
5 making-.
6 JIM SPONTAK: If I can add something to that. One
7 of the comments the state made, we wanted the ground water
8 remediated to its background quality and EPA put that in the
9 plan for us. As technologically feasible it can be done.
10 You can't pump water up for seven hundred, eight hundred,
11 nine hundred feet, you can't do it. They will try to.
12 remediate the ground water until the contamination is gone.
13 I think that's what you're getting at.
14 MERLE HANKEY: Well, I looked at this and I saw
15 your calculations and how you cane up with a hazard index
16 and I was just concerned, because I'm not totally
17 understanding of all of this, but I can read what is here
18 and what I had read was that my understanding that this
19 concern, the portion of the plume on the Sbealer property'
20 which we know you can put institutional controls on for the
21 us* of ground water and there is a water line in that
22 neighborhood but there are people that could possibly buy
23 property out there and develop it and use that property and
24 I just wondered if that was also taken into consideration in
25 the calculations.
71 AR30093J
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.1 . FRANK VAVRA: It says all water contaminated above
2 background and above eight hundred feet in depth.
3 MERLE EANKEY: In your summary of alternatives,
4 the feasibility study reviewed a variety of technologies to
5 determine if they were applicable to the contamination at
6 the site. Who determined what technologies were to be
? considered? In other words., Westinghpuse contractor, were .
8 they given a list of all possible alternatives, the
9 technologies to use for ground water remediation, for soil
10 remediation or did they just have a list from somewhere
11 else.
12 In other words, were all the possible, were all the
13 possibilities explored, all the innovative technologies
14 explored. You were given a certain amount of technologies
15 to remediate the soil, a certain amount of technologies to
16 remediate the water. If it's going to take thirty years to
17 remediate the water or longer, that's too long. If there's
18 another technology that might be faster, it could be
19 explored. What I was wondering is or what I'd like to know
20 is where did Westinghouse come up with their — or their
21 contractor cone up with the list of alternatives? From
22 looking at their list of alternatives, they don't have all
23 the latest innovative technologies listed there.
24 ~' FRANK VAVRA: What do you mean by latest
25 innovative technology? What d& you have in mind?
'. »ucu *.7Lt.». »* OR308932
Official Court Reporter
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1 * MERLE HANKEY: The EPA has a group called the
2 superfund innovative technology evaluation program.
3 FRANK VAVRA: That's a site program and
4 essentially what the site program is, I wouldn't quite call
5 it experimental technologies but those are,technologies that
6 are under development and there are cases where the site
7 program identifies a technology they want to test out and 'in
8 fact they will send bulletins across the regions to see if
9 we have certain sites that fit a category.
10 • Also if an RPM reads there a certain technology that
11 has promise, they can contact the office of research and
12 development. I think you have to be reasonable in what is
13 expected in the feasibility study. There were numerous
14 technologies that were evaluated. I think all the major
15 classes were. I can't guarantee that every single
16 technology that's possible was evaluated but what I can tell
17 you is I looked through the screening process and all the
18 major ones that have potential in my opinion for this site
19 were looked at. If they weren't, we don't have to stay with
20 those. We would have included something in the comments to
21 add something to those.
22 DHAPLs and fractured bedrock, pomp and treat are still
23 the way people are attacking this. There is a lot of talk
24 about biotechnology but that's far from proven and in a
25 fractured bedrock system you have to inject nutrients down
73 AR308933
Alicia K. Wooters, RPR
Official Court Reporter
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1 there and you can't control that very well.
2 All this is detailed in the feasibility study and I-
3 think Riso did a pretty good job of listing the major
4 technologies, and I agreed with the general reasons for
5 screening out the ones that were screened out.
6 There is also citizens as well as wanting innovative
7 technology you have to also be concerned about the
8 reliability and the proven track record of the remedy
9 selected for the site. Yes, we want to select innovative
10 technology where it looks promising and has a good chance of
11 success, but your neighborhoods are not experimental
12 programs. I have to as project manager make sure things are
13 selected that have a good probability of being successful.
14 MERLE HANKEY: It seems we're guinea- pigs. We
15 drank the water and stuff. Now everybody is going to wait
16 and see what happens to us. My main concern, was every
17 possibility explored? I think you answered that, if you
18 were satisfied.
19 FRANK VAVRA: I was satisfied with what was looked
20 at. I want to add, we had meetings with Westinghouse and
21 . Paul Riso and we essentially told them in addition to the
22 things they looked at, we had certain things we definitely
23 wanted them to include. Westinghouse wasn't necessarily in
24 agreement in all the things we wanted to look at either.
25 Yes, we were certainly involved in the process.
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1 " MERLE HANKEY: On page 15 under ground water
2 alternatives, you may have discussed this before, but I'm
3 not exactly sure how this is going to be done. At the
4 bottom of page 15. in talking about the remediation of ground
5 water at the very bottom, "Only if the very deep ground
6 water re-emerges and discharges at usable well depths far
7 from the site would it pose a threat. EPA plans to addces.s
8 this .issue as part of the remedial action monitoring well
9 network. If contaminated ground water does surface and
10 discharge, it could then be captured and treated at
11 reasonable depth."
12 My question here is how would this be determined? How
13 would you know that the stuff is re-emerging? Row will you.
14 know when- it's re-emerging and where it's re-emerging just •
15 by your monitoring well network?
16 FRANK VAVRA: No. We had OSGS review this. The
17 person that reviewed it, Charles Wood, has extensive
18 background in the Gettysburg formation. He's helped
19 municipalities locate its municipal wells. He's written •
20. books and articles on the Gettysburg formation. He
21 understands it pretty well.
22 EPA, because they are concerned about this type of
23 issue, has number one, for our site, we consulted with them
24 and we got advice to what the ultimate discharge points
25 might be. They suggested to us technical means for
flR308935
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1 identifying those areas and as I stated earlier either USGS
2 will do that work and they can do it pretty modestly or th&
3 PRP's will do the work and USGS will be looking over their
4 shoulder to identify those areas. Then monitoring wells
5 would be placed in that area where USGS and EPA
6 hydrogeologists believe.has a high probability of
7 re-emerging, we would try to identify that area. If in fact.
8 you would find contamination, then it might be necessary to
9 place a pumping system at that point. We know that it's
10 escaping. We know it's going down the great depth. We plan
11 as part of monitoring requirements of proposed alternative,
12 we would identify that area and try to take appropriate
13 action. • . " .
14 •'•''' MERLE HANKEY: My concern here is that if there-is
15 a possibility that it could pose a threat that you find it
16 in time.
17 On page 16, "Common elements of all ground water
18 remedies" that paragraph where you talk about deed
19 restrictions on the Shealer property. Just what exactly
20 would those deed restrictions be?
21. FRANK VAVRA: The deed restriction would be
22 primarily for the use of ground water on his property and if
23 in fact this proposed plan were to be accepted and issued as
24 a record decision unchanged, it would probably also place
25 restrictions on any areas that were covered by the sail
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1 cover.' He simply couldn't use that area as farmland or
2 something else. Essentially the soil covers would be
3 reseeded. There would be a fence enclosing those areas to
4 prevent damage by our recreational vehicles or whatever* It
5 would lock them out and it would be reseeded. We would
6 relandscape around the fence with shrubs or something like
7 that to try to buffer it for the neighborhood. Those are.
8 "the type things.
9 MERLE HANKEY: It will be green but it won't be
10 clean in other words?
11 FRANK VAVRA: Clean is a relative term, Merle. We
12 have to look when we select — we have to look when we
13 select these at the .amount of risk reduction we're getting
14 for the dollar spent. If you're talking between two million
15 and 19 million to try to remediate to take that away and
16 fill the landfill up with the huge amount of cubic yards at
17 that site, removing it from one place to another, it just
18 doesn't make a lot of sense. You're not getting a risk
19 reduction for the dollar on that.
20 MERLE HANKEY t I think personally if a company
21 . like Westinghouse comes out and they come out and they have
22 somebody dispose of waste on someone else's property or
23 however it ended up out there on Shealer's property . that the
24 stuff ought to be removed from the site. I think that would
25 give Westinghouse and all the other companies that might
AR308937
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1 think in the future about doing something like that not be
2 given an alternative like, okay, well instead of* having- to
3 spend 15 million dollars to remove the stuff from the site
4 like it should be done, we're only going to have to pay
5 point zero three million dollars and. cover it up with dirt
6 and plant grass on it and not have to worry about it.
7 I think that if.the EPA gets tough enough or I'm sorry
8 if you had laws tough enough, you could enforce some of
9 these things. Maybe a lot of these companies wouldn't do
10 this kind of thing in the future. I think some of these
11 companies should be made examples of. The people in the
12 neighborhoods, whether they own that property or whether
13 they live around it shouldn't have to live with that stuff
14 there. .They *ve lived with it in the neighborhoods' for over
15 20 years. Now it's time for it to be gotten ride of. Let
16 it go back to Westinghouse or the other companies. Let them
17 put it on their lands and cover it with a geonet and put
18 grass on it and let them babysit it for the next 50 years,
19 but I think it ought to be gotten out of our neighborhoods.
20 FRANK VAVRA: Your problem and your frustration go
21 back to some of the discussions we have had in the past.
22 You really believe there should be two standards. You
23 appreciate in situations where there's no — when identified
24 the tax payer money in many cases needs to be considered and
25 you do have to look at the risk reduction for the amount of
78 AR308938
Alicia K. wooters, RPR
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1 money spent, but where you have a company there really
2 should be no limits even if it's an old tire, they should
3 have:to take it away. That's not the way EPA policy works.
4 There is one set of limits based on risk. We have to follow
5 that policy both on enforcement sites and on Superfund
6 sites.
•7 . MERLE HANKEY: I understand. I'm. sorry. I blow.
8 up sometimes but ten years has taken a toll on me. ' To. get
9 into a discussion about the geonet, just exactly how does
10 the geonet work and what does it do?
11 FRANK VAVRA: The geotextile. what we're putting
12 down, it's essentially a plastic cloth. Its purpose is not
13 to prevent water from moving through it. In fact, it should
14 , be-permeable. It's supposed to be permeable. What it does
15 for me as project manager, I look at a soil cover and if we
16 put a foot and a half soil on top of this geotextile which
17 is visually, you can tell that from soil, my concern is we
18 could put a soil cover if the PRP's would not maintain that
19 soil cover properly over, time it could be eroded. How do
20 you tell that? I mean, you're not going to be able to go
21 out there with a survey routinely day after day and tell in
22 fact it eroded and now the other soil is exposed. So the
23 purpose of thi« is by placing that geotextile over the area
24 before the soil cover is placed if you can see, if you can
25 see the geotextile, then that means that you've gotten down
AR308939
Alicia K. Hooters, RPR
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1 and your soil cover is eroded and it needs maintenance.
2 It's a visual indicator. Like a soil cover has been darcagec
3 and eroded. That's the purpose.
4 MERLE HANKEY: Does the geonet get put down over
5 bare ground? On these sites you have vegetation. You have
6 shrubs. You have plant life. You have trees. Is all that
.7 .stuff taken off there before the geonet is put down?
8 FRANK VAVRA: No. They are going to have to do
9 some site preparation.
10 . MERLE HANKEY: Disturbing the site?
11 FRANK VAVRA: There will be some benefit to that
12 because what will happen, they do the earth moving, it's
13 going to move some of that material around. The highest
14 levels within one or two feet of surface and as they —
15 MERLE HANKEY: Seventy-two inches is pretty
16 contaminated, down to seventy-two inches also you know.
17 FRANK VAVRA: Maybe isolated. Not on an average,
18 Merle. The material would be taken away. The vegetative
19 cover removed and then regraded and then the geotextile
20 placed on top of that and then the soil cover laid down.
21 MZHLB HANKEY: You know how I feel. I don't like
22 th« geonet. I think the stuff ought to be removed and it
23 ought to be not fooled with anymore. Just taken away and
24 get rid of it and put some clean soil on it and.let some
25 cornfields go back in there and that will be fine.
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1 " FRANK VAVRA: Even if we were to do that, that's
2 not how the site would work. A.S we stated earlier, we have
3 dense non-aqueous phase liquids down at bedrock. We're
4 going to have a pump and treat system. We're going to be
5 pumping wells.located on that property. We're going to have
6 many folds to capture that water and transport it to a
7 treatment system. Probably a lot of that will be under
8 ground- It won't be that visually evident but the point is
9 that use because of ground water cleanup is going to be
A
10 restricted regardless until the ground water is cleaned up,
11 which is likely to be a fairly long time.
12 DON WADDELL: You're planning on putting the
13 . netting over the borrow area including the stress vegetation
14 area and both cornfields?
15 FRANK VAVRA: That's correct. Before we do that'
16 we'll be excavating the stress vegetation area and the
17 lagoon area and treating those soils, backfill and then the
18 soil cover will cover the whole area.
19 DON WADDELL: What about the edges of this thing?
20 Bow do you seal the edges that you say prevent the
21 . contaminants from moving down but what about lateral. I
22 mean, water going under this net, how do you seal that?
23 PRANK VAVRA: Those metals are not traveling. If
24 they were traveling to any significant extent,.you'd see
25 them in the ground water.
si AR3089M
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1 , JEFFREY PIKE: We would also make sure the cover
2 extends far enough we have the contaminated areas covered.
3 It wouldn't be traveling laterally.
4 MERLE FJANKEY: You are going to go beyond the
5 bounds of contaminated areas and put geonet and soil?
6 FRANK VAVRA: You can see what we plan up there.
7 MERLE HANKEY: . Okay. That doesn'.t really ., .
8. explain-- • •
9,. FRANK VAVRA: My point is, the way their
10 contractors identified these areas with the dotted, you can
11 see we're over extending. In addition, we have added an
12 alternative that was not included in the FS the EPA
13 developed, of adding this segment to cover these in addition,
14 because we believe the amount of topsoil that was indicated
15 in the FS is insufficient for a good vegetative cover so we
16 would add additional topsoil over here with the soil cover
17 that would over extend these areas after they were
18 excavated. It would table these areas which I said were
19 quite .likely to be contaminated. During the RI, samples
20 were not taken from this area. They are outside the area,
21 but we think it's prudent to extend the cover out to the
22 stream.
23 DON WADDELL: On the wet area, wetland area, how
24 does that work? You say you got the stressed ajrea and the
25 borrow area and even some of the lagoon area is wetland, how
... Vv-, -; •• AR3089U2
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1 does that netting work in a wetland area? How do you cover
2 it or how do you maintain it?
3 FRANK VAVRA: It's not going to make any
4 difference. You're going — they are going to do the site
5 preparation. They'll place the netting, then they'll place
6 the soil cover and they'll reseed. Some areas that are low
7 enough may actually reestablish some wetlands type
8 . vegetation but then some areas will be a little higher
9 because of the soil cover and they may not be able to
10 support the wetlands vegetation as well and therefore,
11 that's why we propose creating that wetlands area down at
12 the other end of the site, to replace areas that have been
13 damaged by remedial action.
14 MERLE HANKEY: Concerning the discharge from your
15 pump and treat system going into the stream, how often would
16 that discharge -be monitored to see that they are complying
17 with the regulations for the limits or whatever? How often
18 would that be checked to make sure the pumping system is
19 working?
20 FRANK VAVRA: this is a proposed plan at this
2-1 point in time. I haven't finalized that exact detail.
22 • MERLE HANKEY: Is there a standard?
23 JEFFREY PIKE: Follow the standard MPD'S
24 monitoring process, once monthly.
25 MERLE HANKEY: That would be require ah MPD'S
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1 permitr that would be monthly.
2 FRANK VAVRA: It doesn't require a permit.
3 3ischargtng- on site does not require a permit. We have to
4 meet levels acceptable to DER, but we don't have to go
5 through the paperwork requirements required in a MPD'S
6 permit, we just have to meet those levels. Monitoring is a
7 substantive requirement and as Jeff pointed out we have to
8 comply with whatever it was.
9 DON WADDELL: Is there going to be a public
10 meeting whenever you determine where the stripping tower
11 will be located and so on? Is a public meeting required for
12 that? In other words, you won't put it in somebody's back
13 yards without first talking to them? .
14 FRANK VAVRA: I don't believe there's a public
15 meeting required under CERCLA. We would certainly intend to
16 have one and it's common to have one in the early phases of
17 design. We have already talked about what my initial
18 thoughts are about some of the places.
19 DON WADDELL: We didn't talk about if there would
20 be a public comment period or something.
21 FRANK VAVRA: There's not a true public comment
22 period included in that we would do public interaction and
23 we certainly will get the citizens opinions during that
24 design.
25 JEFFREY PIKE: We'd like to get enough through the
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1 design process so we have to show you proposed locations,
2 etc. so we would commit to have a meeting or come out and
3 meet individually with interested groups or people at that
4 time.
5 DON WADDELL: Do you have any time frame for that?
6 JEFFREY PIKE: Generally as far as a meeting
7 format would be appropriate around 60 to 90 percent design,
8 about that far through the process, we would have locations
9 proposed, etc. The time frame on that for design and Frank
10 can address that.
11 FRANK VAVRA: I think we'd have to have
12 interaction earlier than that in this particular instance.
13 Especially since because of the complexities of -design,
14 we're leaving some of these issues open. I would tend to
15 think that during the preliminary design, like thirty
16 percent design/ we would come out and talk to the residents.
17 MERLE HANKEY: When you have your breakdown here
18 showing all your costs and everything and your time to
19 implementation, what exactly is the time for implementation?
20 In other words, when does that start? When does that 17
21 months start?
22 FRANK VAVRA: Timed implement includes the design
23 phase.
24 MERLE HANKEY: That's what I wanted to know.
25 FRANK VAVRA: It assumes you're done all the
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1 negotiations phase. It's not from tonight. It's time to
2 implement.
3 MERLE HANKEYr I just wanted to (enow what point in
4 time after tonight would that start. After this would be
5 included as part of the design phase, right?
6 FRANK VAVRA: This would include both the design
7 and remedial action. . .
8 MERLE HANKEY: In other words, the actual design
9 and construction clean up?
10 FRANK VAVRA: Right. From the time that we had an
11 agreement with PRP's or from the time that we had a
12 contractor where we received bids and accepted them and they
13. were ready to roll and started under the fund, that time
14 frame. I have to tell you that time frame is very loose.
15 One of the things this is a scoping, this is a scoping
16 design, Merle, and frankly, until you start getting into
17 detail design and seeing the interactions of all these
18 things that are finally selected at this point in time, this
19 is not a remedy. We haven't selected a remedy. We're
20 proposing one and until we have that and know how we're
21 going to sequence everything, those numbers are going to
22 have a lot of slack in them. There is just no way around
23 that.
24 - MERLE HANKEY: I can understand how time frames
25 can be loose because whenever we had a meeting with EPA six
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1 years -ago concerning the RI/FS we were told it was going to
2 take eighteen months.. Now here we .are six years later, so
3 we know how time frair.es can expand.
4 Concerning the responsibilities of the responsible
5 parties for these sites, do you have individual areas of
6 responsibility? Like do some of them have certain things
7 that they are responsible for like ground water? You have a
9 •multitude of responsible parties here. Are there separate
9 responsibilities for this site?
10 FRANK VAVRA: We don't have a ROD let alone an
11 agreement at this point in time. What I can tell you is in
12 out records, .and it's factual, is that the responsible
13 parties came to agreement among themself in the past as to
14 how much was paid for each area. However, during remedial
15 design, remedial action that could change drastically.
16 MERLE HANKEY: Because I remember you said
17 something before at one of the public meetings that because
18 there were different types of wastes that were disposed in
19 different areas that maybe there would be different areas
20 that would be different responsible parties
21 responsibilities.
22 FRANK VAVRA: That's correct. Westinghouse
23 requested that we tie certain wells to certain units that we
24 were exploring so they could help apportion costs among
25 themself. EPA doesn't really care what those individual
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1 agreements are or who does what, we only care we get the
2 site cleaned up and we do' whatever we can to facilitate
3. that.
4 MERLE-HANKEY: I agree. Fencing for the site.
5 Once a decision is made that these things are going to be
6 done on the site and your final record of decision, are
7 these areas going to be fenced and made off limits or just
8 what is the story on the fencing? In other words, I have
9 seen some pretty shoddy fencing materials used that turn
10 into dilapidated fencing. Is there going to be any kind of
11 appropriate fencing put around these areas?
12 FRANK VAVRAs I think you have to be specific. I
13 think for any soil cover that we have we clearly have to
14 limit access to that. It can be destroyed. I know even at
15 the site I have seen evidence of RV tracks and things like
16 that out at the site. Once we put a soil cover on, that
17 simply can't persist. We have had protracted discussions
18 with Westinghouse over site security and fencing. I agree
19 with you. I'm not all that happy with site security myself
20 right not*. During the remedial action it will be written
21 . into the ROD specifying what needs to be done and we will
22 have adequate security for those areas.
23 MERLE HANKEY: Site security on these sites has
24 been really sloppy. It originally started out it was
25 .supposed to be monthly inspections on these sites and then
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1 the last thing I heard it was quarterly inspections, and I
2 requested .information through Freedom of Information Act and
3 it looked like quarterly inspections were missed on these
4 sites.
5 It doesn't look like you guys are enforcing these
6 inspections. At the very least, enforce the inspections,
7 make sure the security fences on these sites are still in
8 place to keep people out of those areas. I can: see. .it from
9 Shriver's Corner, the fence lays down, the fabric filter
10 fence lays down and it will lay there for six months. I can
11 get some response if I call somebody about it, but I don't
12 feel I should have to call somebody. They should be out
13 there inspecting that site regularly like they are required.
1.4 to under their what. Section 106 order or consent agreement •
15 or whatever they had.
16 FRANK VAVRA: They do submit the information. I
17 just received recently a report from them that indicated the
18 fence had been down and it had been placed and repaired. I
19 was out there today and I looked at it and it is up. You're
20 right, it's only a snow fence and it doesn't take a whole
21 lot to knock that down and that's part of the problem.
22 MERLE HANKEY: This follows into your soil cover
23 over the geonet. Are they going to b« a lot more
24 responsible in their investigations of the soil cover on the
25 geonet or can we expect there's going to be great areas that
Alicia K. Wooters, RPR
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1 are going to end up being exposed and what's it going to
2 take? Is it going to take citizens having to look out over
3 the field with binoculars to report this or can we expect
4 that something is going to be adequately provided here?
5 FRANK-VAVRA: I think the problem is the actual
6 fence installed there is not very durable. A snow fence
7 simply is not durable. It can be knocked down by wind or
8 kids or whatever. We need something permanent and that's
9 what we would be doing to protect the remedy.
10 MERLE HANKEY: What I was discussing was the lax
11 investigation that is taking place right now. If you put
12 this geonet down and you cover it with soil and low and
13 behold the only way we can tell if everything is okay is if.
14 we see this geonet. If they aren't doing the inspections
15 like they aren't doing them now, nobody will know. It's not
16 being covered properly. I'm hoping in the future these
17 inspections are looked after a little bit more closely.
18 JEFFREY PIKE: Your comment is noted and we will
19 also consider that when we get to the next phase of working
20 out agreements with people to do this work and take that
21 . into consideration when we develop those agreements and the
22 requirements of that.
23 MERLE HANKEY: Hopefully this will be my last
24 question or comment. -
25 JIN SPONTAK: For the state's part, I have been on
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1 those, sites every month at least once a month.
2 MERLE HANKEY: Concerning the cornfields and the
3 geonet and the soil cover; we have a project life of
4 approximately thirty years for the ground water, the soil
3 net or the net, the geonet, the soil cover is going to be
6 there forever? Is that what we can assume?
7 JEFFREY PIKE: Yes. It's a containment remedy..
8 - . MERLE HANKEYt It's going.to require perpetual'
9 care like a cemetery? Can we expect that's going to be done
10 perpetually? It's a good comparison, perpetual care like a
11 cemetery.
12 That's all I have. Thank you.
13 VIRGINIA MOSELEY: Any other questions or
14. comments? •
15 Okay, if there are none, we will be staying, so if you
16 think of anything before you leave, please come up and ask
17 the gentlemen individually. I will be in the back. If
18 anyone wants some information sent, I will be glad to
19 accommodate you. Thank you very much for coming this
20 evening. We appreciate your attendance.
21 (Adjourned at 9:27 p.m.)
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I hereby certify that the proceedings and evidence are
contained fully and accurately in. the notes taken by me on
the trial of the above cause and that this copy is a correct
transcript of the same.
DATED: May 24, 1993
Alicia K. Wooters, RPR
HR308952
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APPENDIX E
AR308953
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HUNTERSTOWN ROAD
ADMINISTRATIVE RECORD TILS
INDEX OF DOCUMENTS
i. SITE:
1. Report: Site Inspection of Hunterscown Road Site.
prepared by NUS Corporation, 3/26/85. ?. 100001-
100189.
2. Report: A Field Trip Report for Gettysburg NPL Sites.'
.prepared by NUS Corporation, 12/12/85. P. 100190-
100272.
3. Report: Hvdreoeeloaic Evaluation for Hunterstown Road
Sit^e. prepared by NUS Corporation, 1/3/86. P. 100273-
100342.
4. Memorandum to Mr. Charles J. Walters, U.S. EPA, from
Mr. Stephen Margo1is, Department of Health and Human
Services, re: Health Assessment, 3/5/86. P. 100343-
100348. Table 1, Comparison of the Maximum- Element
.. Concentrations Reportedly Found in Surface Soil at the
Hunterstown Road Site With Literature Values Reported
Tor Supposedly Uncontaminated Soils in the United
States, is attached.
5. Memorandum to Mr. Francisco Barba, U.S. EPA, from Mr.
Bruce Molholt, U.S. EPA, re: Information on soil lead
contamination at the site, 8/22/86. P. 100349-100349.
6. Report: A Field Trip Report for Hunterstown Road.
prepared by NUS Corporation, 9/22/86. P. 100350-
100397.
Administrative Record File available 6/25/92,
4/20/93 and 4/23/93.
-------
II- REMEDIAL SMFQRCSMEMT PLANNING
Si?rnL^f?r^rnr^6a?atter °f: • H"««rSC3wn *°ad
200027 III-87-5-DC, 3/4/87. p. 2000C1-
AR308955
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III. REMEDIAL RESPONSE PLANNING
1. Memorandum to Mr. Harold Byer, U.S. EPA, from Mr. Gar-.-.
Glenn, Mr. Thomas Fromm, and Mr. Bruce R. Pluta, NUS
Corporation, cet Samplings, plan-,: 7/8/86. ?..-.. 3Q&OQ1-
3 0*00 0.3*. K hand-drawn site sketch is attached.
2". Report: Site Work Plan. Remedial Action. Lacroon Area.
Hunterstown Road Site. Gettysburg. Pennsylvania.
prepared by Remcor, Inc., 4/3/87. p. 300004-300055.
3.. Report: Assessment of Suspected Waste Disposal Areas.
Huncerstown Road Site/ Gettysburg. Pennsylvania-..
prepared by Remcor, Inc., 10/87. P. 300056-300200.
A cover letter is attached.
4. Report: Quality Assurance Project Plan. Remedial
' Investigation/Feasibility Study. Hunterstown Road Site.
Straban Township. Adams County. Pennsylvania, prepared
by Paul C. Rizzo Associates, Inc., 11/86. P. 300201-
300372.
5". Letter to Mr. Steven Hirsch [sic],. U.S. EPA, from Mr.
Kenneth J. Bird, Paul C. Rizzo Associates, Inc., re: .
Audit of Lancaster Laboratories inorganic analysis
capabilities, 11/4/88. Pi.. 3JQ.Q373-3Q0446. Appendix. H,
Laboratory Evaluation Checklist, a- Performance
Evaluation Report, and an inorganic analyses data
package are attached.
6. Letter to Mr. Frank Vavra, U.S. EPA, from Ms. Beth F.
Cockcroft, Paul C. Rizzo Associates, Inc., re: Audit
of Lancaster Laboratories for inorganics and organics,
6/13/89. P. 300449-300487. A letter and Appendix K,
.Laboratory Evaluation Inorganic Checklist, are
attached.
77 ' "Report: • Hiase T Report. Volume 1 of~?T HemediaX"
Investigation/Feasibility Study. Hunterstown Road Site.
Adams County. Pennsylvania, prepared by Paul C. Rizzo
Associate*, Inc., 8/4/89.. P. 300448-300755..
8~. Report: Phase I Report. Volume 2' of 2. RemediaL-
Invegtioation/Feaaibilitv Study. Hunterstown Road Site.
Mama County, Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 8/4/89. P: 300756-301318.-
9i. Reporti
fM^V Blan PAMA^IAI T
County. Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 10/23/89. P. 301319"301415'^o3Q895r
-------
10. Report: Sampling and Analysis Plan. Remedial
Investigation/Feasibility Study._ Huncerstown Road 3iie.
Straban Township. Adams County. Pennsylvania, prepares
by Paul C. Rizzo Associates, Inc., 10/23/39.
P. 301416-301460.
11. Report": PTiase r QA Grata Validation Summary Reeort,
Hunterstown Road Site. Adams County, Pennsylvania.
prepared by Paul C. Rizzo Associates, Inc., 2/16/90.
P. 301461-301980.
12. Report: Work Plan. Remedial Investigation/Feasibility.
Study. Hunterstown Road Site. Straban Township. Adams
County. Pennsylvania, prepared by Paul C. Rizzo.
Associates, Inc., 7/16/90. r. 301991-302078.
13. Report: Campling -and Analysis Plan. Remedial
Investigation/Feasibility Study. Hunterstown Road Site.
Straban Township. Adams County. Pennsylvania, prepared
by Paul C. Rizzo Associates, Inc., 7/16/90. P. 302079-
302149. The following are attached:
a) a:cover letter;
b) Vable SAP-1, Compounds of Interest for
Hunterstown Road Site;
. • J '••..'.'
>v. cj,, table SAP-6, Summary of Proposed Phase II"
.- Monitoring Wells;
d) a monitoring well locations map;
•) a-proposed cornfield grid system;
t) an Addendum to the Sampling and Analysis Plan
for Additional Monitoring Hells.
14. Organic Data Validation, Case 15230, 12/12/90. .
Br. 302150-302205. K cover memorandum is attached.
15. Inorganic Data Validation, Case 15321, 1/11/91.
P. 302206-302229. A cover memorandum is attached.
16. inorganic Data Validation, Case 15321, 1/14/91.
r. 302230-302246. Ar cover memorandum is attached.
17. Organic Data Validation, Case 15321, 2/28/91'.
P; 302247-302298. A cover memorandum is attached.
IB,. Organic Data. Validation, CSM 15321 4/10/91.
P. 302299-302408. A cover memorandum is attached.
AK308957
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19. Report: Final Remedial Investigation Report, Remedial
t'nvesriqac-toTi/Feasibilicv Study. Vglume 1 af- "*>• Tex-.,,
Tables, and Figures. Huncerstown Road Si~e. Aciams
Councv. Pennsylvania, prepared by Paul C. Rizzo
A&sociaces, Inc., 10/3.1/9.L. E-....302409;-3a2676^
20. Report: Final Remedial Investigation Reoorr. Remedial
investigation/Feasibility Study. Volume 2 of 7; .
Appendices A and B. Hunterstown Road Site. Adams
County. Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 10/31/91. P. 302677-302984.
21- .Report; Final Remedial Investigation Report. Remedial
tnvestiaaciorr/Feasibilitv Study. Volume 3 of-7:*--
Appendices C. D. E. and F. Hunterstown Road Site*. Adams
Counev. Pennsylvania, prepared by Paul C. Rizzo
* Associates, Inc., 10/31/91. P. 302985-303480.
22. Report: Final Remedial Investigation Report. Remedial
Investigation/Feasibility Study. Volume 4 of 7;
Appendix F continued. Hunterstown Road Site. Adams
County. Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 10/31/91. P. 303481-304005.
23. Report: Final Remedial Investigation Report. Remedial-
Investigation/Feasibility- Study. Volume 5 off 7.;-.
Appendix F continued. Hunteratown Road Site. Adams
Countv; Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 10/31/91. P. 304006-304539.
24. Report: Final Remedial Investigation Report. Remedial
Investigation/Feasibility Study. Volume 6 of 7!
Appendices G. H. I. and J. Hunterstewn Road Site. Adams
County. Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 10/31/91. P. 304540-304984.
25. Report: Appendix K. Risk Assessment for Hunterstevn
* Road Site. Volume 7 of 8s Report and Appendix'A. " "
prepared by Remediation Technologies, Inc., 11/91.
P. 304985-305459. A cover letter is attached.
•
26. Letter to Mrs. Eileen Massaro, Hestinghouse Electric
Corporation, from Mr. Francisco Barba, U.S. EPA, re:
Comments and requirements for the improvement ofrthe
Rl/rs Work Plan Phase I after review of the report,
9/18/87. P. 305460-305468. , .
23.- Memorandum.to Ms.. Karen M. Helper.* U.S. EPA, from Mr.
Steven R. Btrsh, OtS. EPA, re: Metals concaiaiaafion.
information, 10/5/87. P; 305469-305470.. A handwritten
note requesting a description of the metals
contamination and a list of PRP's for the site are atta
&R308958
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2B. Letter to Mr. Steven Hirsh, U.S. EPA, from Mr. C-ecr?e
Mehaffie, PADER, re: Comments on the woric Piarr,
10/16/87. P. 305471-305473.
29. Letter to Mr. Steve Hirsh, U:S. EPA, from-Mr. Charles
J. Kulp, U.S. Department of the Interior, re: Comments
on the Work Plan, 10/21/87. P. 305474-305475. Figure
4-2, Map of Locations for Surface Water/Sediment
Sampling, is attached.
30. Memorandum to Mr. Steven R. Hirsch [sic], U.S. EPA,
from Ms. Kim A. Kariya, U.S. EPA, re: Comments on the
Work Plan, 11/12/87. p. 305476-305477.
31. Report: Work Plan. Remedial Investigation/feasibility
Study. Hunterstovn Road Site. Straban Township. Adams
County. Pennsylvania, prepared by Paul C. Rizzo
Associates, Inc., 2/11/88. P. 305478-305553.
32. Letter to Mr. Steven Hirsh, U.S. EPA, from Mr. George
Mehaffie, PADER, re: Review of the revised Work Plan,
3/10/88. P. 305554-305554.
33. Report: Site operations Plan. Remedial Investigation/
Feasibility Study. Huhterstown Road Site. Straban
lownshio. Adams County. Pennsylvania, prepared- by Paul.
C. Rizzo Associates, Inc., 3/29/88. P. 30555T-305607.
34. Memorandum to Mr. Steven Hirsh, U.S. EPA, from Ms.
Diann Sims, U.S. EPA, re: Quality Assurance Project
Plan Review, 4/28/88. P. 305608-305625. The review is
attached.
35. Memorandum to Mr. Steven Hirsh, U.S. EPA, from Mr. John
Scalera, U.S. EPA, re: (fork Plan and Quality Assurance
Project Plan Review, 5/4/88. P. 305626-305642. The
review is attached.
-v
36. Memorandum to Mr. Steven Hirsh, U.S. EPA, from Mr. John
Scalera, U.S. EPA, re: Quality Assurance Project Plan
Review, 9/8/88. P. 305643-305663. The review and a
letter regarding approval of the RI/FS woric Plan dated
February 1988 and the RI/FS Site Operations Plan dated
March 1988 an attached.
37. Report * Contingency -Plan. Remedial Iflveat-iaation.
Hunterstown Road Site. Hestinohouae Electric
Corporation, prepared by Paul C. Rizzo Associates,
Inc., 11/11/88. P. 305664-30568-4.
flR308959
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38. Repott: Qualify Assurance Proiect Plan. Remedial
Investigation/Feasibility-. Study. Hunterstowrt Ssad 5iTg.
Scraban Township, Adams County. Pennsylvania, oreparsc
by Paul C. Rizzo Associates, Inc., 11/11/38.
P. 305685-305857.
39. tetter to Mr-. Steven Hirsh, U.S". EPA, from Mr. Kenneth
J. Bird, Paul C. Rizzo Associates, Inc., re: Response
to the Quality Assurance Project Plan and Contingency
Plan for the Shriver's Corner Site and Westinghouse
Plant Site, 11/14/88. P. 305858-305858.
m
40. Letter to Mr. Steven Hirslu U.S. EPA, from Mr* -Kenneth'
J» Bird, Paul. C. Rizzo Associates, Inc.,, re.: Response
to the Quality Assurance Project Plan and Contingency
Plan for Kunterstown Road Site, 11/14/88. P. 305859-
305861. The responses to comments are attached.
41. Memorandum to Mr. Steven Hirsch [sic], U.S. EPA, from
Mr. John Scalera, U.S. EPA, re: Recommendation for
approval of the Quality Assurance Project Plan,
11/30/88. P. 305862-305862.
42. Letter to Mr. Steven Hirsh, U.S. EPA, from Mr. Patrick
F. 0'Hare, Paul C-. Rizzo Associates, .Inc., re:
Proposal for additional, data, validation personnel, for
the Gettysburg Projects, 1/6/8*. F. 30586-3-305366. T7.
resume of Mr. Kenneth Bird is attached.
43. Letter to Mr. Donald Haddel froa Mr. Fran* vavra, U.S.
EPA, re: Discussions concerning access to the Haddel
property during the Kunterstown Road RI/FS and Mr.
. Waddel's issues of concern, 3/1/89. P. 305867-305867.
44. Letter to Mr. Paul Jack, Westinghouse Electric Company,
from Mr. Frank Vavra, U.S. EPA, re: Concerns about the
delays in the RI/FS implementation at Shriver's Corner,
Hunterstown Road, and the Westinghouse. Elevator Plant
and request for a meeting between Westinghouse and EPA
to discuss issues, 5/4/89. P. 305868-305869.
45T. Letter-to--Mr, Paul Pi Jack, Westinghouse Electric
Coapany, froa Mr. Frank Vavra, U.S. EPA, re: Request
for an extension of the approved Work Plan schedule for
the Hunterstown Road Site and discussion of additional
issues related to the work Plan schedulest 6/1/89.
P; 305870-305870.
4£* Memnrinduti to Mr> Frank Vavra, QL&> EPJW from, ME. P«t«r
Stokely, U.S. EPA, re: Wetland Assessment, 6/26/89.
P. 305871-305875. References are attached.
AR308960
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47. Letter to Mr. Timothy Basilone, Westinghouse Electric
Company, from Mr. Fran* Vavra, U.S. EPA, re: Guidance
on EPA's requirement's1 for the Pttase II Worjc Flan's char
Westinghouse was required to submit under the current
RI/FS Consent Orders for the Shriver's Corner, the
Hunterstown Road, and the Westinghouse Plant sites,
8/3/89. P.'305876-305880.
48. Memorandum to Mr. Frank Vavra, U.S. EPA, from Ms. Linda
Hoist, U.S. EPA, re: Comments on the review of the
RI/FS Report for surface water quality concerns,
11/15/89. P. 305881-305885. Attachment 1, Ambient •
Hater Sample Concentrations Which Exceed Pennsylvania
and/or EPA Aquatic Life and/or Human Health Criteria,
Attachment- 2, Detection Levels Which Exceed
Pennsylvania and/or EPA Ambient Water Quality Criteria
For Aquatic Life and/or Human Health, and a routing and
transmittal slip are attached.
49. Letter to Mr. Frank Vavra, U.S. EPA, from Oynamac
Corporation, re: Assessment of the accomplishment of
the Phase I Objectives, the fulfillment of National
Contingency Plan (NCP) and Rl guidance requirements,
the assessment of the data quality, and the development
of recommendations for additional information,
11/22/89. P. 305886-305892.
50; Memorandum to Mr. Frank Vavra, "T.S. EPA, from Ms. Alyce
Fritz and Mr. Robert Davis, U.S. EPA, re: Comments on
the Bioassessment Work Group's review of the Phase I
RI/FS, 11/30/89. P. 305893-305893.
51. .Letter to Mr. Timothy R. Basilone, Westinghouse
• Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Sampling of the bottom of the drum removal area,
12/6/89. P. 305894-305895.
52. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, tr.S. EPA,
re: Meeting scheduled to discuss EPA's Phase II Work
Plan requirements for the RI/FS for Hunterstown Road
and Oral Removal, Shriver's Corner/Gulp and
Westinghouse Plant Site, 1/4/90. P*. 305896-305896.
53. Latter to Mr. Frank Vavra, U.S. EPA, from Mr. Bruce
. Beach, Oynamac Corporation, re: Comments on the
information presented in the Work Plan and In the
Sampling and Analysis Plan, 1/5/90. P; 305897-305906.
Figure U, Residential WelT Data, Figure 2, Monitoring
Nell Locations, and Figure 3> Sampling interval* Gross-
Section, are attached.
W30896
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54. Memorandum to Mr. Frank Vavra, U.S. EPA, frca Ms.
Phoebe C~ Rabbr U.S. EPA, ret Comments, on the
•Westinghouse Trio" Work Plans and specific comments =.-.
the Hunterstown Road site, 1/9/90. P. 305907-305912.
A checklist for environmental and community relations
factors, iff. RT/FS/ROD documents^ is- attached.
55. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Understanding .of ground water, soil sampling-, and
bioassessment requirements, 2/9/90. P. 305913-3059L&=.
Figure 4-1, Monitoring Well Locations, a memorandum, •
.dated January 29, 1990, regarding comments . on, upstream.
control,, and a letter, dated December 22, 1989, "'
regarding technical questions and transcription errors
related to the documents submitted for the Westinghouse
Plant, Shriver's Corner, and Hunterstown Road sices are
attached.
56. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Additional comments from EPA and other agencies
.... involved in the Super fund process for the RI/FS of
T Hunterstown Road and Drum Removal, 2/15/90. P. 305919-
305929. * checklist for environmental and community '
relations factors, in RI/FS/ROD documents. Attachment 1,..
Ambient-Water Sample Concentrations Which Exceed
Pennsylvania and/or EPA Aquatic Life and/or Human
Health Criteria, and Attachment 2, Detection Levels
Which Exceed Pennsylvania and/or EPA Ambient Water
Quality Criteria for Aquatic Life and/or Human Health,
are attached.
57. Memorandum to Mr. Greg Cry stall, U.-S. EPA, from Mr.
Frank Vavra, U.S. EPA, re: Junkyard with drums located
near the study zone, 2/26/90. P. 305930-305932.
Figure 2-1, Site Location Map and Figure 2-6,
Residential .weir. Locations, are attached. -- .
58. Letter to Ms. A.C. Zeitz, Columbia Gas Transmission
Corporation, from Mr. Frank Vavra, U.S. EPA, re:
Precautions and mitigative measures that would: be
needed as a result of the construction of the planned
gas line that is located in the vicinity of the three
Superfund sites, 3/28/90. P. 305933-305934.
59. Report: Response to U.S. EPA Co"""*nt3, Hunterstown
Road Site. ?fmt.dili tnvegtieration/FeaaihilJ
prepared: fcy Pauls C~ Rizzo Associates, me.,
F. 305935-305960.
AR308962
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60. Report: Assessment of Compounds of interest,
Huncerstown Road Site, St^ratpan Township. Adams. Cour.tv,
Pennsylvania, prepared by Paul C. Rizzo Associates,
Inc., 4/23/90. P. 305961-305992. A trar.smittal letter
is. attached.
61. Letter to Mr. Frank Vavra, U.S. EPA, from Ms. Margaret
A. Zak, Westinghouse Electric Corporation, re:
Abbreviated sampling plan outlining bioassessment
sampling locations and parameters at the Hunterstown
Road and Shriver's Corner sites, 6/5/90. P. 205993-
305997. Figure 1, Sampling Locations Bioassessment
Program at Hunterstown Road Site, and Figure 2,
Sampling Locations Bioassessment Program, ac. Shriv.er' s
Corner Site, are attached.
62. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Unresolved issues with Hunterstown Road and
Shriver's Corner, 6/12/90. P. 305998-306005. An
asbestos removal, area sketch, a Hunterstown Road Drum
Removal Area RI Sampling sketch. Figure C-l,
Preliminary Site Map, and a certified mail receipt are*
attached. . .
63. Letter to Mr. Timothy R. Basilone, Westinghouse
.:• - 'Electric Corporation, from Mr. Frank Vavra, tT.S.. EPA,
re: Resending of unresolved issues letter, 6/21/90.
P. 306006-306007. A certified mail receipt is
attached.
64. Handwritten note to file from Mr. Frank Vavra, U.S.
EPA, re: Metal detection in soil and surface waters,
8/13/90. P. 306008-306010.
65. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Kenneth
J. Bird, Paul C. Rizzo Associates, Inc., re: Revised
Table SAP-1, Compounds of Interest, RI/ES, Huntecstawn
Read Site, 8/20/90. P. 306011-306012. The table is
attached.
66. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Kenneth
J. Bird, Paul C. Rizzo Associates, Inc., re: sampling
and Analysis Plan modifications for the Hunterstown
Road Site, 8/29/90. PT 306013-306023. The
modifications are attached.
67. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. FranJt Vavra, OLS— EPJU
re: Comments on the revised Hunterstown Road work Plan
and Sampling and Analysis Plan, 8/29/90. P. 306024-
306031. The following are attached:
10 AR308963
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a-X: Table-SAP:-!/" Compounds.--of. Interest; •.
b) Table SAP-6, Summary of Proposed Phase ::
Monitoring Wells;
c) Figure 4-1, Monitoring Well Locatians;
d) Figure 4-2, Proposed Cornfield Gcid System; .
e) a certified mail receipt.
68^ Letter to Ma. Margaret Zak, Westinghouse. Electric
Corporation, from Mr. Frank Vavra, U.S:. EPA,. re:;;;R'islc
Assessment method for handling non-detection of
compounds of interest, 10/4/90. P. 306032-306033.
69. Letter to Ms. Margaret Zak, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re:
Notification of change in Remedial Project Managers for
the Shriver's Corner Site and information on the
benthic survey work planned at the Hunterstown Road
Site, 10/22/90. P. 306034-306035.
* •
70. - Letter to Mr. Frank Vavra, U.S. EPA> from Mr. Kenneth
J. Bird,- Paul. C. Rizzo Associates, Inc., te: Revised
tables for the RI Report, 1/14/91. 9. 306036-306037.
71. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman and Mr. Kenneth J*. Bird, Paul C. Rizzo
Associates, Inc., re: Notification of installation of
Hells HMN-10CL and PW-1 for Westinghouse Electric
Corporation, 1/17/91. P. 306038-306041. Figure 1,
Monitoring Well and Test Boring Locations, and Figure
2, Pumping Well PW-1, Installation Details, are
attached.
72. Letter to Mr. Vincent and Mrs. Mary Kennedy from Mr.
Frank Vavra, U.S. EPA, re: Substances in the small
stream and wetlands adjacent to Don Waddel's cornfield,
3/12/91. P^ 3(16042-306042.
73. Report: PffBltotllffrT R*vi*w of Data and Risk Assessment
laauea for ^he Hunterstown Road Site, prepared by
Remediation Technologies, Inc., 5/91. P. 306043-
306097.
74 » Latter to, Mr. .Tiaothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Fran* Vavra> tt_S~ .EWW,.V.
re; Determination if removal actions are necessary at
the Westinghouse Plant Site and the Hunterstown Road
Site, 5/21/91. P. 306098-306099.
11 AH308961*
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75. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Ror.ali F.
KiiniJcowski, PADER> re.: Comments on. the irait Orsur.i
water Treatability Study WorJe Plan, 5/22/91.
P. 306100-306102. A memorandum, dated May 13, 1391,
containing the comments is attached.
76. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman and Mr. Patrick F. O'Hara, Paul C. Rizzo
Associates, Inc., re: The Addendum to the Sampling ar.d
Analysis Plan and the proposal to drill and install two
additional monitoring wells at the site, 5/28/91.
P. 306103-306113^ • Table 4-12, Ground Water Samples,
Summary of Analytical Results, and Figure 1, Monitoring
Well and Test Boring Locations, are attached..
77. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Bruce w.
Beach, Dynamac Corporation, re: Comments on the Ground
Water Treatability Study, 5/29/91. P. 306114-306116.
78. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Comments on review of the Work Plan for the Ground
Water Treatability Study dated April 1991, 6/11/91.
P. 306117-306120.-
79. Report: Molecular Alteration/Stabilization Technology,
- prepare* by Wastechr Inc., 6/11/91. Pv 306121rr30615L.
80. Letter to Ms. Margaret Zak, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re:
Comments from EPA's toxicologist on the preliminary
review of the Data and Risk Assessment Issues, 6/12/91.
P. 306152-306158. A memorandum, dated June 10, 1991,
containing the preliminary review comments is attached.
81. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vav.ra, U.S. EPA,
ret Approval of the Addendum for the Sampling and.
Analysis Plan, Additional Monitoring wells, and RZ/FS,
and agreement with the well placement and depths of the
proposed wells, 6/20/91. P. 306159-306160. A
certified mail receipt; is attached.
82. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Agreement to extend the deadline for submittal of
the Risk Assessment, 7/1/91. P. 306161-306161.
/TO308965
12
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il~ Lett.ec. tor. Mr.. Larry Stednhour from Mr. sracJt Vavra*
U.S. EPA, re: Well sampling and ground water
contamination, 7/1/91. P. 306162-306169. Table 2-13, '
Off-site Well Locations and Addresses, Table 2-19,. Cff
site Well Analytical Data, and. Figure. 2~S, Residential
Well Locations, are attached.
84. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Dave
Morgan, Remediation .Technologies, Inc., re: Comments
on the Preliminary Review of Data and Risk Assessment
Issues, 7/24/91. P. 306170-306171.
as. Memorandum, to Mr. Dotv Herote and Ms. Diane E._.
U.S. EPA, from Mr. Frank Vavra, U.S. EPA, re:
Notification of Federal Natural Resource Trustees,
7/30/91. P. 306172-306174. A Covenant Not to Sue
background information sheet is attached.
86. Letter to Mr. Ron Klinokowski [sic], PADER, from Mr.
Erank Vavra, U.S. EPA, re: Request for comments on the
Risk. Assessment and identification of the major state
ARARs for the site, 7/30/91. P. 306175-306176.
•
87. . Report: Work Plan. Ground Water Treat ability Study. .
Hunt erst own Road Site. Straban Township, arfamj .County,
Pennsylvania, prepared by Paul C. Rlzzo Associates,-
Inc., 8791. P. 306177-306243.
88. Memorandum to Mr. Frank Vavra, U.S. EPA, from Ms. Susan
G. McDowell, U.S. EPA, re: Areas of concern under NEPA
on the draft RI Report and the Risk Assessment Report,
8/5/91. P. 306244-306250. A fact sheet about the
Section 106 Review is attached.
89. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Ray
V. Mihailovich, U.S. EPA; re: Comments on the
analytical data- for the east, middle, and west- -. —
receiving streams, 8/8/91. P. 306251-3062252.
90. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr.
Reginald F; Harrl*, U.S". EPA, re^ A- summary and
support information on the Baseline Risk Assessment,
8/15/91. r. 3062533-306254.
91. Facsimile caver sheet to Mr. Frank Vavra, U.S. EPA,
from Ms. Margaret Zak, Westinghouse Electric
Corporation, re: Proposal found in the files from the
plumber- involved with water: line installations: at, tile-
plant site, 8/19/91. P. 306255-306258. The Proposal
and a meeting agenda are attached.
fcR30896r
13
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92. Memorandum to Mr. Jeffrey A. Pike, U.S. EPA, frcm Mr.
Joseph. W. Kunz., re.: Review of the. draft Phase IL. ?.I
Report, 8/19/91. P. 3C6259-306262. The review ar.cf a
routing and transmittal slip are attached.
33. Hunterstown Road Feasibility Study, Evaluation cf EPA's
preferred operable units and minimum possible
alternatives, 8/20/91. P. 306263-306264.
94. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Bruce
Rundell, U.S. EPA, re: Hydrological Review of the RI
Report, 8/21/91. P. 306265-306267. Figure 2-9,
Monitoring Well and Test Boring Locations, is attached.
95. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr.
Andrew Fan, U.S. EPA, re: UST regulations and closure
requirements, 8/21/91. P. 306268-306269. A routing
and transmittal slip is attached.
96. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman, Paul C. Rizzo Associates, Inc., re:
Addendum to clarify the Ground Water Treatability Study
Work Plan, 8/28/91. - P. 306270-306270.
97. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Bill
Foster, U.S. EPA, re: Public water supply lines, water
quality problems-, and classification as a Class II-A
aquifer, 8/30/91. P. 306271-306272. A routing and
transmittal slip is attached.
98. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. David A.
Sehock, Dynamac Corporation, re: Review of the Phase
II RI Report, 8/30/91. P. 306273-306291. The review
is attached.
99. Letter to Mr. Timothy R. Basilone, westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
-• re:; Approval ofV the Work Plan for the Ground.Hater
Treatability Study, 9/4/91. P. 306292-306292.
100. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Ronald F.
Klinikowski, PADER, re: Comments on the review of the
Ground Water Treatability Study Work Plan, 9/6/91.
P. 306293*306294.
101. Memorandum to Mr. Frank Vavra, 0.3. EPA, from Mr.
Robert S. Davis, U.S. EPA, re: Review of the Risk
Assessment and comments, specifically on the middle
stream. 9/16793,. fe.. 306295-306299.
AR308967
14
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1Q2-. Mcmorarrdunr ca Mr-.. Frank Vawrav U.S.. ESK,. fr=tMr- 2^1.
Foster, U.S. EPA, re: Status of Gettysburg MA's
compliance with Safe Drinking Water Ace (SDWA)
regulations, 9/17/91. B. 3.Q6.300-3.QS301. A routing ar.i
transmirtal slip is attached.
103. Letter to Mr. Frank Vavra, U.S. EPA, from Ms. Ruth
Bishop, FADER, re: Comments on the Risk Assessment
review, 9/20/91. P. 306302-306303.
104. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A^ Baughman,.Paul C- Rizzo Associates, Inc., re:.
Notification that Westinghouse Electric Corp.orac.ion
intends to begin the aquifer pumping test as parr of
the Ground Water Treatability Study, 9/23/91.
P. 306304-306304.
\
A
105. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Comments on the Phase II Remedial Investigation
Report, 9/30/91. P. 306305-306331. The following are
attached:
•
a) a memorandum regarding the Baseline Risk
Assessment-, dated August 15, 1991;
b) a memorandum regarding the Hydrologic Revie
of Hunterstown Road Site RI Report, dated
August 21, 1991;
c) Figure 2-9, Monitoring Well and Test Boring
Locations;
d) a-memorandum regarding unclear issues under
NEPA, dated August 5, 1991;
•) erf act: sheet entitled "A-Five-Minute. Look, at.
Section 106 Review."
106. Letter to Me. Frank Vavra, U.S. EPA, from Mr. David A.
Schoek, Dynaaac Corporation, rer: Oversight activities
conducted on October 1-2* 1991 at the site, 10/7/91.
P. 306332-306335.
107. Letter to Ms. Margaret Zak, Westinghouse Electric
Corporation, froa Mr. Frank Vavra, U.S. .EPA, re:
Documentation of. the methods of data analysis and othe
ia«u«s-related-to-water sampling* 10/9/91. P^
306337.
AR30896o
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108. Letter to Mr. Franfc Vavra, U.S. EPA, from Mr. Willisr.
A. Baughman and Mr. Kenneth' J. Bird, Paul C. Rizzo
Associates, Inc., re: Submission of the Addendum Tr
the Sampling and Analysis Plan for U.S. £?A review and
approval, LO/11/91. P. 306338-306343. figure 1, Sire
Location Map', Figure 3—4, Site Geologic Map and
Location of Geologic Section, and Figure 3, Residential
Well Locations, are attached.
109. Letter to Ms. Margaret Zalc, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re: Site
Security and request for fencing around the site,
10/15/91. P. 306344-306345. A site map is attached.
110. Memorandum to Ms. Margaret Zak, Westinghouse Electric
v Corporation, from Mr. Frank Vavra, U.S. EPA, re: Final
• comments on the Ecological Assessment, 10/17/91.
P. 306346-306348.
111. Memorandum to Mr. Reginald F. Harris, Mr. Roy Smith,
Ms. Bernice Pasquini, Mr. Robert Davis, Mr. Joe Kunz,
Mr. Bill Foster, Mr. Robert Koroncai, Mr. C.K. Lee,
U.S. EPA, Mr. Wayne Naylor, UST, Mr. Don Henne, U.S.
Department, of the Interior, and Pat Bently, National
Park Service, from Mr. Frank Vavra, U.S. EPA, re:
. .., Submission of the Feasibility Study, 10/24/91.
P-. 30*349-306350.
112. Letter to Ms. Margaret Zak, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re:
Information from the field trip taken on October 22,
1991, 10/28/91. P. 306351-306353. Figure 2-8, Surface
Water and Sediment Sample Locations, is attached.
113. Letter to Mr. Frank Vavra, U.S. EPA, from Ms. Margaret
A. Zak, Westinghouse Electric Corporation, re: Middle
stream alignment. 10/31/91. P. 306354-306355. Figure
I/ Middle Stream Surface Water and Sediment Sample
Locations, is attached.
114. Latter to.Mr. Frank Vavra, U.S. EPA, from Ms. Margaret
*.. Zak, Wastinghouse Electric Corporation, re: Trip
report, 11/5/91. P. 306356-306358. A letter, dated
October 24, 1991, regarding results from the field
examination of surface water resources is attached.
115. Memorandum to Mr. Bob Davis, U.S. EPX, from Mr. Frank
Vavra, U.S. EPA, re: Elevated phthalate levels in the
middle stream, 11/12791. P.. 3063.59-306359.
AR308969
16
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Lie. tetter co Ms. Margaret Z'afc, Wescingttouse E-lecrrir
Corporation, from Mr. Fran* Vavra, U.S. E?A, re:
Review of the revised Phase II RI and finding of
inadequacies with: Westixghouse' s responses -3. E2A' s
comments, 11/15/91. P. 306360-306367. Two ropography
maps are attached.
117. Report: Field Trio Report. Hunterstown Road Superf-jr.d
Site. Straban Township. Pennsylvania, prepared by
Dynamac.Corporation, 11/22/91. P. 306363-306403.
A cover letter and an inorganic data validation report.
is atrachedv .
118. Letter to Mr. ChucJc Hull, U.S. EPA, from Mr. Abraham
Ferdas, U.S. EPA, re: Notification that waste from
Westinghouse Plant and Hunterstown Road NPL Sites'
response action will be. shipped to a facility in Ohio
for treatment and/or disposal, 11/27/91. P. 306404-
306405.
119., Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman, Paul C. Rizzo Associates, Inc., re:
Results from the residential well survey, 11/27/91.
P. 306406-306432. The residential well sample.analyses
results ace,attached,
120. Letter to Mr. DicJc Smoyer, Adams County Courthouse,
from Mr. Frank Vavra, U.S. EPA, re: Potential problems
for construction of an industrial business part in the
Gettysburg area, 12/3/91. P. 306433-306437. Figure
4-1, Total Volatile Organic Compounds, Drum Burial Area
•Monitoring Wells, and Figure 1-1, Site Location Map,
are attached,.
121. Letter to Ms. Margaret Zak, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re_r Task
2; Ground Water Sampling of 31 wells along Old
Harriaburg Road, 12/6/91. P. 306438-306440. A
certified mail receipt is attached.
122. Latter to Mr. Frank Vavra, U.S. EPA, from Mr. William
Jk. Banghman, Paul C. Rizzo Associates, Inc., re:
notification of sampling and analyzing waste from the
Stressed Vegetation Area at the site, 12/6/91.
P. 306441-306443. Figure 1, Site Plan, and Figure 2,
Stressed Vegetation Area Sampling Locations, are
123. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
re: Two unresolved issues at the site, 12/12/91.
P. 306444-306446. A certified mail receipt is attachec
17 AR308970
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124. Letter to Mr. Fran* Vavra, U.S. EPA, frcm Mr. ?acnr.<
F. O'Hara, Paul C. Rizzo Associates, Inc., re:
Additional. nan.ito.Eing well iastalLaxian and subsurface
exploration at Dram Burial Area No. 1, 12/12/?I.
P. 306447-306448. Figure 4-2, Total Volatile Organic
Compounds. Drum Burial Area Monitoring Wells, is
attached.
125. Letter to Mr. William Scott, Jr. from Mr. FranJc. Vavra,
U.S. EPA, re: Recommendation to test the wells for
volatile organic hydrocarbons using method 524.2,
12/13/91. P. 306449-306452. A site map and a
certified mail receipt are attached.
126. Memorandum, to Mr. Jeffrey A. Pike, U.S. E£A, from..Mr-
Joseph W. Kunz, U.S. EPA, re: Comments from the draft
FS review, 12/13/91. P. 306453-306454. The comments
are attached.
127. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. FranJc Vavra, U.S. EPA,
re: Four areas that require additional work before RI
approval could be granted, 12/14/91. P. 306455-306458:
Figure 4-2- Total Volatile Organic Compounds, Drum
Burial Area Monitoring Wells, and a certified mail
receipt are attached.
128. Letter to Mr-. Kenneth J. Bird, Paul C. Rizro.
Associates, Inc., from Mr. Frank Vavra, U.S. EPA, re:
Approval of the use of Wadsworth Laboratories to avoid
delay in obtaining analytical results from the ground
water effort and requirement of PE samples for any
•method 524 tests, 12/17/91. P. 306459-306461. PL-
certified mail receipt is attached.
129. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William'
A. Baughman, Paul C. Rizzo Associates, Inc., re: List
of residents which are connected to the Gettysburg
r Municipal Utility Authority public water, supply,
12/19/91. P. 306462-306465. The list is attached.
130. Latter to Mr. Frank Vavra, U.S. EPA, from Ms. Margaret
JU Zak, Neatinghouse Electric Corporation, ce:
Information on the residential well sampling that is
being completed as part of the RI at the -site, 1/3/92.
P. 306466-306472. A letter, dated December 20, 1991,
regarding the residential well survey, a list of
addresses, and a well questionnaire form are attached.
AR308971
18
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'131. Letter to Mr. Ctonaid Lott from Mr. Willianr A. 3aug:vrar.,
Paul C. Rizzo Associates, Inc., re: Transmittal ;f
soil and ground water analytical results for samples
collected on.'Mr. John/Lact'-s property, 1/3/92.
F. 306473-306474.
132. Report: Treatabilitv Investigation. Remedial
Investigation/Feasibility Study. Hunterstown Road' Site^
St^raban Township, Adams County, Pennsylvania, orepared
by Paul C. Rizzo Associates, Inc., 1/10/92. ?". 306475-
306731.
133. Letter to Mr. Frank Vavra, U.S..EPA, from Mr. William
A. Baughman, Paul C. Rizzo Associates, Inc., re:
Analytical results from the resampled waste from the
Stressed Vegetation Area, 1/20/92. P. 306732-306758.
The Analytical Report is attached.
134. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman and Mr. Kenneth J. Bird, Paul C. Rizzo
Associates, re: Assessment of Municipal Well No. 5,
1/20/92. P. 306759-306771. The following are
attached:
a*. Figure 1, Site Location Map;
b) Figure 2, Monitoring well and Test Boring
Locations;
c) Figure 3, Residential Well Locations;
d) Figure 4, Assessment of Municipal Well No. 5
Pumping Impacts;
e) analytical data.
135; Memorandum to Mr. Frank Vavra, U~.S."EPA, from- Ms. .
Theresa A. Simpson, U.S. EPA, re: Organic data
validation report, Case 17336, 1/23/92. P. 306772-
306830. The report is attached.
136. Latter to Mr. Allen Potter from Mr. Douglas E.
Spicuzza, Paul C. Rizzo Associates, Inc., re: Public
water system acknowledgment and release, 2/12/92.
P. 306831-306831.
137. Letter to Mr. Patrick O'Rara, Paul C. Rizzo Associates,
Inc., from Mr. Frank Vavra, U.S. EPA, re: Risk based
level for 1,1 OCA used in the leaching calculations,
3/4/92. P. 306832-306832.
AR30897?
19
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138. Letter to Mr. Timothy Basilone, Westinghouse Electric
Corporation, from Mr. FranJc Vavra, U.S. EPA, re:
Questions and comments, on the Treatanility
Investigation Report, 3/9/92. P. 306833-306334.
139. Report: Draft Feasibility Study Report. Hur.tersrc-wn
Road Site. Straban Township. Adams County.'
Pennsylvania, prepared by Paul C. Rizzo Associates,
Inc.,.3/31/92. P. 30683S-307162.
140. Letter to Mr. FranJc Vavra, U.S. EPA, from Mr. Kenneth
J. Bird, Paul C. Rizzo Associates, Inc., re: Response
to EPA comments on the Treatability Study Report,
4/7/92. P. 307163-307166. The response is attached.
141. Report: Sample Analysis Report. Hunterstown Road
Suoerfund Site. Straban Township. Adams Councv.
Pennsylvania, prepared by Dynamac Corporation, 4/13/92.
P. 307167-307247.
142. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Kenneth
J. Bird, Paul C. Rizzo Associates, Inc., re: Summary
of previous remedial actions at the site, 4/16/92.
P. 307248-307266. The following are attached:
a) Table 3, Hazard Characterization Analysis.
• • • Data; ' . • • . ' ' . • . • • '
b) Table 4, EP Toxicity Leachate Analysis Data;
e) Table 5, Selected Volatile Organic Compound
Data;
d) Table 6, Volatile Organic Compound Analysis
Summary;
e) Table 7, Total Metal Analysis Summary;
C). Table 8, Seal-Volatile Compound Analysis
Summary;
g) Table 9, Phenols and Cyanide Analysis
Summary;
h) Table 10, Summary of Assessment Data.
143. Report: Tranaaittal. Additional Monitoring Walls. Drum
Burial Area 1. Pjffe
-------
144. Letter ro" Mr. Clrarles Winrow, Gettysburg Building
Corporation, from Mr. William A. Baughman, Paul c.
Rizzo Associates, Inc., re: Residential well results,
4/21/9Z. P-... 30.7O5-3Q772Q. Twenty-three letters -3
residents containing their well' results, are it.tach.ed.
145. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Peter Schaul, U.S. £?A,
re: Necessary changes to be made in the Feasibility
Study before it circulates for review, 5/1/92-.
P. 307731-307737. Two memoranda regarding the changes
•. .• are attached. . •••.--•'
146. Report: Field Trip Report. Hiinterstown Road Superfund
Site. Straban Township. Adams County. Pennsylvania.
prepared by Dynamac Corporation, 5/11/92. P. 307738-
307756.
147. Report: Sample Analysis Report. Hunt erst own Road
1 .. .. ^ Super-fund Site. Straban Township. Adams County.
"*"*- . Pennsylvania, prepared by Dynamac Corporation, 5/11/92.
P. 307757-307816.
148. Letter to Mr. Heinz and Mrs. Mathilde Gaubatz from Mr.
William AV Baughaan, Paul C. Rizzo Associates, Inc. ,.
re: Residential well sample results, 5/20/92.
P. 307817-307818.
149. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. William
A. Baughman, Paul C. Rizzo Associates, Inc., re:
Figures 1 through 6 related to an additional subsurface
investigation of Drum Burial Area 1, 6/5/92.
P. 307819-307824. Figures 1,2,3,5, and 6 are attached.
150. Letter to Mr. Peter. Schaul, U.S. EPA, from Mr. Timothy
R.. Baailone, Westinghouse Electric Corporation, re;:
Response to EPA's comments on the draft Feasibility
Study Report, 6/5/92. P. 307825-307845. A proposed
outline for the revised report is attached.
151. Letter to Mr. William o. Steuteville, U.S. EPA, from
Mr. Timothy R. Basilone, Westinghous* Electric
Corporation, re: Security and site stabilization
methods, 6/30/92. P. 307846-307849. A facsimile cover
letter and two Quarterly Inspection Reports are
• . . .attached. . " ....•':..'
1327 t*tt«r to MT. Frank Vavra, U;S. EPA, froar «-.
F. O'Hara and Ms. Beth F. Cocker oft, Paul C. Rizzo
Associates, Inc., r»: Explanation of soil
stabilization process and demonstration, 7/9/
P. 307850-3078S1.
*
21
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153. Handwritten, comments on the Hunterstown Road
.Feasibility Study, prepared by Mr. C.K..Lee, 3/12/92.
P. 307852-307852. •
154. Memorandum to Mr. Frank Vavra, U.S. EPA, from Ms. Carol
Ann Gross, U".S. EPA, re: Correction on Feasibility
Study, 8/.17/92. P. 307853-307853.
155. Memorandum to Mr. Jeffrey Pike, U.S. EPA, from Mr.
Joseph W. Kunz, U.S. EPA, re: Comments on the draft •
Feasibility Study, 8/18/92. P. 307854-307857, The
review and a routing and transmittal slip are attached.
156. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr.
Robert S. Davis, U.S. EPA, re: Preliminary STAG
comments on the Feasibility Study, 8/18/92. p. 307853-
307859.
157. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Bruce
Rundell, U.S. EPA, re: Hydrogeologic review of the
Feasibility Study, 8/31/92. P. 307860-307862.
158. Memorandum to Mr. Frank Vavra, U.S. EPA, from Mr. Jack"
Kelly, ATJDR, re: Site Review and Update (SRU)
document, 9/3/92. P. 307863-307881. The Site Review
and Update is attached. . .
159. Memorandum to Mr. Frank Vavra, U~.S. EPA, from.Mr.
Robert Davis, U.S. EPA, re: Review of the Feasibility
Study, 9/3/92. P. 307882-307882.
160. Memorandum to Mr. Jack Kelly, ATSDR, from Mr. Frank
Vavra, U.S. EPA, re: Response to SRU comments, 9/8/92.
P. 307883-307892. The following are attached:
a) a letter regarding an additional subsurface
investigation of Drum Area 1;
b) Figure 1, Site Plan;
c) Figure 2, Potentiometric Surface and Volatile
Organic Concentrations F-Series Monitoring
Wells;
d) Figure 3, Potentiometric Surface and Volatile
Organic Concentrations tf-Series. Monitoring
Wells;
*1 Figure. S, Hydrogeologic Section B-B;
f) Figure 6, Hydrogeologic Section C-C.
22 AR308975
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161. "Letter to Mrv Frank Vavra, U~.S. EPA, front Kr. Carl
Rodzewich, Dynamac Corporation, re: Comments or. rl-.e
draft Feasibility Study, 9/9/92. P. 307893-307313.
Ten- Home well- Quesci.artna.ires are. attached.
162. Report: Comments on the Draft Feasibility Study
(7/92) . Hunterstovm Road Site. Straban Townshio. Ada?.s
County. Pennsylvania, prepared by Dynamac Corporation,
9/9/92. P. 307914-307930.
163. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. James S.
Spentak, PAQER, re: Comments on the draft Feasibility
Study Report, 9/9/92. P. 307931-307932.
164. Memorandum to Mr..Frank Vavra, U.S. EPA, from Mr.
Reginald F. Harris, U.S. EPA, re: Comments on the
Feasibility Study, 9/16/92. P. 307933-307934.
165. Letter to Mr. Timothy R. Basilone, Westinghouse
Electric Corporation, from Mr. Frank Vavra, U.S. EPA,
. re: Comments on the draft Feasibility Study, 10/9/92.
P. 307935-307956. Two memoranda containing comments on
the Feasibility.Study are attached.
Lfife. Report:' Fi^al Feasibility Studv. Hunterstown Road
Site, 3<^^tean Township. Adams County. Pennsylvania.
prepared by Paul C. Rizzo Associates, 12/18/92.
P. 307957-308554. Two transmittal letters are
attached.
167. Letter to Mr. Gordon Taylor, Westinghouse Electric
Corporation, from Mr. Frank Vavra, U.S. EPA, re:
Comments on toe Revised Feasibility Study, 3/8/93.
. P. 308555-308559.
158. Memorandum to-Mr. Francisco Barba, U.S. EPA, from MS.
Libby Rhoads, U.S. EPA, re: Wetland areas that may be
impacted by the site, 3/21/86. P. 308560-308560.
L69. Memorandum to Mr. Charles Halters, U.S. EPA, from Mr.
Jeffrey A. Lybarger, ATSDR, re: Health consultation of
asbestos mounds at the site, 9/4/86. P. 308561-308574.
A. letter regarding new information about contaminated
areas around the former dump site, migration of
contaminants from these areas and the former dump site,
.land use, and the proximity of residences to the
is attached.
M308976
i
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23
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170. Letter to Mr. Gordon Taylor, Westinghouse Electric
Corporation, from Mr. FranJc Vavra, U.S. EPA, re: E?A'3
review of. Westinghouse's response to. EPA's comments,
3/8/93. P. 308575-308580. A certified mail receipt is
attached.
171. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Gordon
Taylor, Westinghouse Electric Corporation, re:
Comments for inclusion in the administrative record,
4/1/93. P. 308581-308585.
172. Letter to Mr. Gordon Taylor, Westinghouse Electric
Corporation, from Mr. FranJc Vavra, U.S. EPA, re:
Present Worth Costs and implementation times, 4/6/93.
P.. 308586-308589. The following are attached:
a) a Ground Water Actions table;
b) a Stressed Vegetation Area table;
c) a Combined Cornfields and Borrow Area table;
d) a Lagoon Area table.
173. Letter to Mr. James S. Spenta)c, PADER, from Mr. FranJc
Vavra, U.S. EPA, re: Request for.scate applicable or
relevant end appropriate requirements (ARARs) and NPDES
discharge limits for the streams at the site,
(undated). P. 308590-308591.
174. Letter to Mr. FranJc Vavra, U.S. EPA, from Mr. James S.
Spontalc, PADER, re: Response to request for state
ARARs, 4/6/93. P. 308592-308594.
175. Letter to Mr. FranJc Vavra, U.S. EPA, from Ms. Beth F.
Cocfccroft, Paul C. Rizzo Associates, Inc., re: Soil
volume calculations, 4/6/93. P. 308595-308663. The
soil volume calculations and a revised Table 4-1 are
attached.
176. Letter to Mr. Janes Spontak, PADER, from Mr. Frank
Vavra, U.S. EPA, re: Draft Proposed Plan, 4/8/93.
P. 308664-308665.
177. Letter to Mr. FranJc Vavra, U.S. EPA, from Mr. Gordon T.
Taylor, Westinghous* Electric Corporation, re: U.S.
EPA letter dated April 6, 1993 concerning estimated
costs and schedules for various remedial alternatives,
4/15/93. P. 308666-308667.
178. Memorandum to file from Mr. Frank Vavra, U.S. EPA, re:
Response to comments for inclusion in the
administrative record from Westinghouse, 4/21/93.
P. 308668-308670.
AR308977
24
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179. Memorandum to.'Mr, Fran* Vavra, U.S. £?A, frrrr Mr.
Reginald F. Harris, U.S. EPA,, re: Certification cf
Human Health Risic Assessment far the site, 4/22/93.
P. 308671-308671.
180. Proposed Remedial Action Plan, Hunterstown Road Site,
Straban Township, Adams County, Pennsylvania, 4/22/93.
P. 308672-308720.
AR308978
25
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IV. REMOVAL RESPONSE PROJECTS
1. Memorandum to Mr. Jeff Pifce, CJ.S EPA, from 3.2T. Khona,
Wescon Sper, re: Water and soil sample analysis,
1/9/85. P..400001-400050. The following are attached:
a) two memoranda regarding resampling;
b) a summary of lab QC;
c) a Hunterstown Road data summary;
d) three site maps;
e) three Chain of Custody Records;
f) a letter regarding test results;
g) 38 pages of laboratory testing data.
2. Memorandum to Mr. Jeffrey Pike, (T.S. EPA, from Mr.
Richard Brunker, U.S. EPA, re: Possible current
exposure hazards, 8/26/85. P. 400051-400051.
3. Memorandum to Mr. Charles J. Walters, Agency for Toxic
Substances and Disease Registry (ATSDR), from Acting
Director, Department of Health & Human Services, re:
Health Assessment, 3/5/86. P. 400052-400057. Table 1,
Comparison of the Maximum Element Concentrations
Reportedly Found in Surface Soil at the Hunterstown
Road Site with Literature Values. Reported for
Supposedly Uncontaminated Soils in the United States,
is attached.
4. Memorandum to- Mr. Charles Walters, ATSDR, from Mr. Jay
Rodstein, U.S. EPA, re: Observations made at the site
and a request for reevaluation, 8/4/86. P. 400058-
400068. The following are attached:
a) a memorandum regarding soil and sampling
results;
b) a summary of analytical results on phtalates
and metals;
e) a Chain of Custody Record;
d) four pages on semi-volatile hazardous
substance list compounds;
•) metal analytical results for project 03-8605-
58;
f) a site sketch.
5. Memorandum to Mr. Francisco Barba from Mr. Bruce
Molholt, U.S. EPA, re: Soil lead contamination,
8/22/86. P. 400069-400069.
26 AR308979
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ff. Memorandum ra Mr. Cirarles waiters, A7SDR", frcrr• Acri.-:r
Director, Department of Health & Human Services, re: '
Health consultation of asbestos-mounds, 5/4/36.
P.-. 40.0070-4000.71.
7. Memorandum to Mr. Charles Walters, ATSDR, from Actir.y
Director, Department of Health & Human Services, re:
Reevaluation and review of site and supplemental
environmental data, 9/26/86. P. 400072-400083.
8. Letter to Mr. Leo Brausch, Remedial Corporation, frcm
Mr. Steven H. Cochenour, International Technology.
Corporation, re: Additional laboratory soil analysis-,
S/13/87. P. 400084-400092. The following are
attached:
a) two lab reports on bulk sample analysis for
asbestos;
b) a-letter regarding four soil samples;
e) Table 1, Metals Analysis Summary for Remedial
Corporation;
d) . table 2, 1,. 1, I-Trichloroef h a ne and
Trichloroethylene.Analysis Summary of Soil
Samples for Remedial Corporation;
e) two Chain of Custody Records;
f) handwritten notes from Leo M. Brausch.
9, "Report: Field Report. Test Pit Exploration Oversight.
Hunterstown Road Site. Straban Township. PA. prepared
by Aepco, Inc., 9/23/87. P. 400093-400155. Two cover
letters are attached.
10. Letter to Mr. William D. Steuteville, U.S. EPA, from
Mr. Patrick K. Radigan, Westinghouse Electric
Corporation* re: Removal project repo.rts, 10/8/87.
P; 400156-400225. The following are attached:
a) September 29r 1987 Project Report for
Aabestos Area Stabilization, Hunterstown Road
Site;
b>X September 23, 1987 Project Report for Lagoon
Area Stabilization, Hnnterstown Road- Site;
c) May 29, 1987 Project Report for Remedial
Action at the Lagoon Area, Hunterstown Road
S4tt/ AR 3089 80
: 27
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d) 28 Field Activity Daily Logs;
e) 17 training- session documentarien- recoris';
f) a site map;
g) February 3, 1987 Project Report fcr Asbestos
Removal Services, Hunterstown Road and
Shriver's Corner Sites;
h) Table 1, Site Activity Summary.
11. Report: Post Excavation Sampling and Analysis Plan.
Hunterstown Road Site, prepared by Paul C. Rizzo •
Associates, Inc., 3/28/89. P. 400226-400231.
12. Report: Addendum to Site Work Plan. Asbestos Removal
Area. Hunterstown Road Site. Gettysburg. Pennsylvania.
prepared by Remcor, (undated). P. 400232-400245. Two
site maps are attached.
AR30898
28
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Vs: . COMMUNITY rsTOLVEMEHT/cowGHESsroNAL C
1. Report: Community Relations Plan for the Hunterstcwr.
Road Suoerfund- Sire, prepared, by Dynamac Carporaci.or.,
3/5/91. P. ,500001-500053.
2. Letter co Mr. Edwin B. Erickson, U.S. EPA, frcm Mr.
Bill Goodling, U.S. House of Representatives, re:
Concern over the uncooperative approach that the
primary responsible party appears to be taking coward
the RI/FS for the three sites, 6/4/90. P. 500054-
500Q54..
3".' Latter to. Mr. Frank Vavra, U.S. EPA, from Mrs. Mary F.
Kennedy/ re: Hell water testing and request to receive
analytical results, 7/15/91. P. 500055-500055.
4: 'Letter to Mrs. Mary Kennedy from Mr. Frank Vavra, U.S.
EPA, re: Information on well water testing and stream
sediment samples, 8/1/91. P. 500056-500056.
5. Letter to Mr. Fred Shealer from Mr. Frank Vavra, U.S. .
EPA, re: Underground storage tanks, 9/5/91.
P. 500057-500057..
6. Letter to Ms. Ruby Reefer from Mr. Frank Vavra, U.S.
EPA, re: Concern about contamination of property/
11/19/91. P. 500058-500062. Figure 4-1, Total
Volatile Organic Compounds, Lagoon Monitoring Wells,
Figure 4-2, Total Volatile Organic Compounds, Drum
Burial Area Monitoring Wells, and Table 2-19, Off-Site
Well Analytical Data, are attached.
7. Letter to Mr. Frank Vavra, U.S. EPA, from Mr. Donald H.
Waddel and Mr. Merle L. Hankey, Jr., re: Concerns
...... about the cleanup, a/28/ 92. P.. 5000 63-500066. An_
envelope is attached.
8. Letter to interested parties from U.S. EPA, re:
Information, on. the- three, local sites listed on the-
National Priorities List (NFL), 9/2/86. P. 500067-
500071. A' fact sheet describing the Superfund Remedial
Program is attached.
'^_
9. Letter to Ms. Eloise Wilson, Cumberland Township Board
of Supervisors, from Mr. Charles A. "Pete" Bentley,
O»&* EPA, re>t Confirmation of public meeting tin* and,
date, 10/9/86. 7. 500072-500072.
AR308982
29
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10. Memorandum to EPA, from Ms. Mary F. Kennedy and Mr.
Donald H. Waddell, re: Comments to memorandum daces
September 26, 1986 concerning the health csnsultaticr.
of the site, 10/10/86. F. 500073-500075.
11. Press Release from U.S. EPA Environmental News entitled
"Public Meeting co Discuss Status of Superfund
Activities at Gettysburg Area Superfund Sices," .
10/16/86. P. 500076-500076.
12. Press Release from U.S. EPA Environmental News entitled
"Asbestos Removal to Begin at Hunterstown Road
Superfund Site," 12/9/86. P. 500077-500077.
13.. Letter to Mr. .Francisco Barba, U.S. EPA, from Mr. Rex
r. Brien, Slap, Williams fi CuJcer, rer Testing co-
determine the presence of toxic metals in well water,
U2/10/86. P. 500078-500078.
14. Press Release from U.S. EPA Environmental News entitled
•Removal Action to Begin at
3/20/87. P. 500079-500079.
•Removal Action to Begin at Hunterstown Road Site,
15. Press Release from U.S. EPA Environmental News entitled
•Remedial Planning to Begin at Hunterstown Road
Superfund Site," 3/26/87. p. 500080-500080.
16. .Latter to the Honorable Bill Goodling, U.S. House of
Representatives, from Mr. Edwin B. Ericfcson, CT.SV EPA,
re: Response- to concern of the citizens near the site
and assurance that no current health risk exists,
5/4/89. P. 500081-500083. A letter requesting
information on the presence of PCS's at the site is
attached.
17. U.S. EPA Public Notice entitled "The U.S. Environmental
Protection Agency Announces a Public Meeting for the
Hunterstown Road, Shriver's Corner, and Westinghouse
Elevator Plant Superfund Sites," The Evening Sun.
5717/90. P. 500084-500084.
18. U.S. EPA Fact Sheet, Hunterstown Road Site, Adams
County., Pennsylvania, 1/91. P. 500085-500086.
19. U.S. EPA Fact Sheet, Shriver's Corner Site and
Hunterstown Road Site, Adams County, Pennsylvania,
8/91. P. 500087-500090.
30 AR308983
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20. tecccr ca rhe Honorable* HI II Gocdlirrg1, 'J.5'. Zovse cf:-
Representatives, from Mr. Edwin B. Erickson, U.S. EPA,
re: Citizen opposition of potential remedial actisr.s
at tite site, 11/27.92. P- 5-fl.0091-5aOQ.96. A- iectec
dated September 28, 1992 regarding concerns about r.w.e
cleanup of the site and its cover letter are attached.
21. Letter to Mr. Don Waddel, Good Neighbors 'Against Toxic
Substances (GNATS), .from Mr. Frank Vavra, U.S. E'PA, re:
Feasibility Study and delay of Proposed Plan, 4/16/93.
P. 500097-500097.
22. Letter to- Mr. Merle Hankey, GNATS', from Mr.
Vavra, U.S. EPA, re: Feasibility Study and delay of
Proposed Plan, 4/16/93. P. 500098-500098.
23. National Priorities List Site Information Sheet,
Hunterstown Road, Straban Township, Pennsylvania,
(undated) . P. 500099-500099.
24. U.S. EPA Public Notice entitled "U.S. Environmental
Protection Agency Announces a Public Meeting .Wednesday,
August 28 at 7:00 p.m., Cumberland Township Municipal
Building, 1370 Fairf ield Road, Gettysburg, " Gettysburg
(undated) .. R. SOOLOO-S&QIOO. . • .,- •-. '.
31
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BIBLIOGRAPHY OF SITE SPECIFIC GUISANCS
1. Guidance for Conducting Remedial Invest igatisr.s a. id.
Feasibility Studies Under CERCLA. prepared ay
OSWER/OERR, 10/1/88.
OSWER #9355.3-01
2. Superfund Federal-Lead Remedial Project Management:
Handbook (Draft), prepared by OERR, 12/1/86.
OSWER #9355.1-1
3. Interim Guidance on Potentially Responsible Party
Participation in Remedial Investigations and
Feasibility Studies, prepared by J.W. Porter/OSWER,
5/16/88.
OSWER #9835. la.
4. Applicability of Land Disposal Restrictions to RCRA and
CERCLA Ground Water Treatment Reinfection Superfund
Management Reviewt Recommendation No. 26. prepared by
O.R. Clay/OSWER, 12/27/89.
OSWER #9234.1-06
•
5. Superfund LDR Guide #1 Overview of RCRA Land Disco-sal
Restrictions (LDRs) . prepared by OERR, 7/1/89.
OSWER. #9347. 3-01FS
6. Suoerfund LDR Guide #2 Complying With the California
List Restrictions Under Land Disposal Restrictions
(LDRa) . prepared by OERR, 7/1/89.
OSWER I9347.3-02FS
7 . Superfund LDR Guide f3 Treatment Standards and Minimum
Technology Requirements Under Land Disposal
Restrictions (LDRai . prepared by OERR, 7/1/89.
OSWER 19347. 3-0 3FS.
8. Suoerfund LPP Qvilde 44 Complying With the Hammer- .
Restrictions Under Land Disposal Restrictions (LDRs) .
prepared by OERR, 7/1/89.
OSWER I9347.3-04FS
9« ^uc*r^fUTl'i LPPi ?ntde #5 Determining When Land Disposal
Raatrtetionis (LDRa) Are Apelie**^^ ^7 CERCLA Restaonse
Aetiona. prepared by OERR, 7/1/89.
OSWER 19347. 3-OS7S
10. Superfund LDR Guide #6A Obtaining a Soil and Debris
nee For Remedial Actions, prepared by
OERR, 7/1/89.
OSWER #9347. 3-06TS
32 AR308985
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11. Suoerfund LDR Guide f7 Determining When Land Sisocsal
Restrictions (LDRs) Are Relevant and Appropriate ~~
CERCLA Response Actions. prepared by OERR, 12/1/39.
OSWER 19347. 3-08FS
12.. Applicability of the HSWA Minimum Technical
Requirements Respecting Liners and Leachace Ccllec-icn
Systems, prepared by J. SJcinner/OSW, 4/1/85.
OSWER 19480. 01(35)
13. Innovative Technology - Best Solvent Extraction Process
f Quick Reference Fact Sheet 1. prepared by OSWER,
OSWER I9200.5-253FS
14. Innovative Technology - Glveolate Dehalooenation TQuicic
Reference Fact Sheet!. prepared by OSWER, 11/1/89.
. vOSWER I9200.5-254FS
15.. Innovative Technology - In-Situ Vitrification fQuiek
Reference Fact Sheet 1. prepared by OSWER, 11/1/89.
— -•• OSWER I9200.5-251FS
•r~
.16. Innovative Technology - Slurry-Phase Biodeoradation
fQuiek Reference Fact Sheet 1. prepared by OSWER,
'
OSWER 19200. 5-2S2FS
17. Innovative Technology - Soil Washing fQuielc Reference
Fact sheatl. prepared by OSWER, 11/1/89.
OSWER I92Q0.5-250FS
18. RCRA Ground-Water Monitoring Technical Enforcement
. Guidance Document (TEGD) . prepared by U.S. EPA, 9/1/86.
OSWER »9950.1
19.. A Guide on Ref*dial -Actions for Contaminated Ground
Water fQuielc Reference Face Sheet 1. prepared by OSWER,
4/1/89.
OSWER I9283.1-2FS
20. f**^CIA Co«"»lianee With Other Laws Manual (Draft) .
prepared by OERR, 8/8/88.
OSWER #9234.1-01
21 . ARARa Q'S I K'S F Quick Reference Pact Sheet 1. prepared
by OSWER, 5/1/89.
OSWER 4923-4. 2-01TS
i
22. ARARa Short Guidance Quarterly Report f Quick Reference
Pact sheatl. prepared by OSWER, 12/1/89.
OSWER 19234.3-001
33 : ; AR308986
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23. ARARs Short Guidance Quarterly Report" 'Quick P.efgre.-.re
Fact Sheet I. prepared by OERR/OPM, 3/1/3C.
OSWER #9234.3-001
24. CERCLA Compliance with Other Laws Manual - CERCLA
Compliance With State Requirements fQuick Reference
Fact Sheet 1 . • prepared by OSWER, 127 1./ 8 9.,
OSWER *9234.2-05FS
25. CERCLA Compliance With Other Laws Manual - CSRCLA
Compliance With the CWA and SDWA fQuicfc Reference Fact
Sheet 1 . prepared by OSWER, 2/1/90.
OSWER 19234. 2-06FS
26. CERCLA Compliance With Other Laws Manual - Overview of
ARARa - Focus on ARAR Waivers fQutelr Rgf ererrce- raef
Sheet 1 . prepared by OSWER, 12/1/89.
OSWER 19234. 2-03FS
27. CERCLA Compliance With Other Laws Manual - Summary of
Part II - CAA. TSCA. and Other Statutes fQuiclc
Reference Face Sheet 1. prepared by OERR/OPM, 4/1/90.
OSWER 19234. 2-07FS
28. CERCLA Compliance With Other Laws Manual Part II;
Clean Air Act and Other Environmental Statutes and
State Requirement a. prepared by OERR, 8/1/89.
OSWER 19234.1-02
29/. Control or* Air Emissions Frea Suoerfund Air Strippers
at Superfund Groundwater Sites, prepared by
OSWER/OAQPS, 6/15/89.
OSWER *9533.0-28
30. RCRA ARARa; Focus on Closure Requirements fQuielc
Reference Fact Sheet 1 . prepared by OSWER, 10/1/89.
OSWER » 9234. 2-0 4FS
31. Applicability of Land Piapcsal Restrictions to RCRA and
on Supcrfund'
26. prepared by
O.R. Cl*y/OSWER, 12/27/89.
OSWER 19234.1-06
32. SMDarfmtd LPR Guide IS Determining When Land Disposal
HsiatftegiQna (LDRa> AM Applieabla to CERCIA
Actions, prepared by OERR* 7/1/89.
OSWER 19347. 3-OSFS
AR308987
34
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33. Sucerfund_lDR Guide »6A Obtaining a Soil ar.d Zeeris
Treat ability Variance For Remedial Aenr.ts. prepares ~
OERR, 7/1/89. . "'
OSWER #9347.3-06FS
34. Superfund LDR Guide *TDetermining 'When Land Disposal
Restrictions (LDRs), Are Relevant and Appropriate to
CERCLA Response Actions, prepared by OERR, 12/1/39.
OSWER #9347.3-08FS
35. Risk Assessment Guidance For Superfund. Volume I. Human
Health Evaluation Manual, prepared by OERR, 9/29/89.
OSWER #9285.7-01a
36. Risk Assessment Guidance For Superfund. Volume II.
Environmental Evaluation Manual, prepared by OERR,
3/1/89.
EPA/540/1-89/001
37. The Remedial Investigation - Site Characterization and
Treatabilitv Studies fQuick Reference Fact Sheet I,
prepared by OSWER, 11/1/89.
OSWER #9355.3-01FS2
38. Community Relations in Superfund; A 'Han^^oolc (Interim.
Version). prepared by OERR, 6/1/88. .=
OSWER 19230.0-03B
39. Interim Guidance on Potentially Responsible Parry
Participation in Remedial Investigations and
Feasibility Studies, prepared by J.W. Porter/OSWER,
5/16/88.
OSWER 19835.la
35 /JR308988
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