PB98-963136
EPA 541-R98-147
March 1999
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Whitmoyer Laboratories
Jackson Township, PA
5/12/1998
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AMENDMENT TO THE RECORD OF DECISION
OPERABLE UNIT TWO
WHITMOYER LABORATORIES SUPERFUND SITE
I. INTRODUCTION
Site Name: Whitmoyer Laboratories Superfund Site
Site Location: Myerstown, Lebanon County, Pennsylvania
Lead Agency: U.S. Environmental Protection Agency, Region III
("EPA" or "Agency")
Support Agency: Pennsylvania Department of Environmental
Protection ("PADEP")
A Record of Decision ("ROD") for the Whitmoyer Laboratories
Superfund Site ("Site") for Operable Unit Two ("OU-2") was issued
on December 17, 1990. This Amendment to the Record of Decision
("Amendment") is issued in accordance with Section 117(c) of the
Comprehensive Environmental Response, Compensation and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act Of 1986 ("CERCLA"), 42 U.S.C. § 9617(c), and 40 C.F.R. §
300.435(c)(2)(I). This Amendment has been prepared to document
the nature of the change made to the selected remedy identified
in the ROD for OU-2; to summarize the information that led to the
making of the change; and to affirm that the revised remedy
complies with the statutory requirements of CERCLA § 121, 42
U.S.C. § 9621. The amendment fundamentally alters the remedy
selected in the ROD for OU-2 with respect to scope, performance,
and cost. This Amendment is incorporated into the Administrative
Record for the Site1.
New information became available following the issuance of
the Record of Decision which gave rise to the need for an
amendment. Specific information acquired during the remedial
design and related activities included the following:
1. Excavation of wastes located within the on-site vault
revealed four major categories of materials: contaminated soil;
aniline still-bottom tars; a mixture of carbon/tar; and calcium
arsenate sludge. Limited amounts of various debris (i.e., drum
carcasses, wood, etc.) were mixed within each category.
2. There are several RCRA-permitted treatment facilities
currently available to treat and dispose of the various
1 This Amendment pertains only to the ROD for OU-2. Three
RODs have been issued for the Whitmoyer Laboratories Site. The
RODs for OU-1 and OU-3 are explained in the Site history and are
unaffected by this Amendment.
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categories of wastes excavated from the vault. All of the vault
wastes except for the soils have been transported to off-site
treatment and disposal facilities (see the Explanation of
Significant Differences dated 12/28/94 and 11/7/95). Vault soils
are temporarily stored in an on-site hazardous waste storage
building.
3. Characterization of vault soils, bench-scale treatability
testing, and full-scale demonstration tests indicate that off-
site chemical stabilization followed by disposal in a Subtitle C
landfill is an appropriate alternative to the on-site
incineration remedy selected for vault soils in the ROD for OU-2.
The new information acquired and EPA's conclusions are discussed
in more detail below.
II. SUMMARY OF THE SITE HISTORY, SELECTED REMEDY AND PRIOR
MODIFICATIONS
The Whitmoyer Laboratories Site is the location of a former
veterinary feed additives and Pharmaceuticals manufacturing
facility. Production began at the Site in 1934 and in the mid-
1950' s, the facility began using arsenic in the production of
feed additives. Other products produced included a coal-tar dip,
used to treat skin disorders; piperazine, a worming agent; and
sulfa drugs, used to inhibit bacterial growth. In addition to
arsenic, a number of products manufactured by the facility
contained aniline, an organic chemical derived from benzene.
The original Site owner, C.W. Whitmoyer, Sr. sold the
facility to the Rohm and Haas Company in 1964. In 1978, Rohm and
Haas sold the company to Beecham Inc., who in turn sold the
facility to Stafford Laboratories, Inc. in 1982. Stafford
Laboratories, Inc. filed for Chapter 11 bankruptcy in mid-1984
and continued operations at the Site until January 1987.
EPA began assessing Site conditions in 1984. However, when
the facility closed in 1987, the RCRA Closure Plan had only been
partially implemented. The Site was listed on the National
Priority List ("NPL") in 1986, and throughout 1987, EPA conducted
numerous sampling activities, both on- and off-site. In 1988,
EPA removed approximately 400 drums from the Site while beginning
a fund-lead Remedial Investigation/Feasibility Study. A ROD for
Operable Unit One ("OU-1") was issued on June 30, 1989 for the
consolidation, removal and treatment of concentrated liquids and
decontamination of 32 tanks and vessels. The OU-1 remedial
action was completed in September 1990.
The ROD for OU-2 was issued on December 17, 1990 and
addressed the concentrated wastes in the concrete vault, wastes
abandoned in two groups of lagoons, products and miscellaneous
materials abandoned in buildings, and the buildings and related
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structures. A complete description of the selected remedy as
well as EPA's rationale for the decision is presented in the ROD
for OU-2. The major components of the selected remedy are:
• On-site incineration of the high organic content vault
wastes (also referred to as the "upper vault wastes"), contents
of buried drums located adjacent to the vault, residual materials
remaining in tanks and process vessels, miscellaneous products
and feedstocks, and combustible demolition debris exhibiting the
RCRA arsenic toxicity characteristic.
• Fixation of lagoon wastes, incineration residuals, and low
organic content vault wastes.
• Surface cleaning and demolition of contaminated
structures.
• Coating and sealing all noncombustible, permeable
demolition debris exhibiting the RCRA arsenic toxicity
characteristic.
• Surface cleaning the noncombustible, impermeable
demolition debris exhibiting the RCRA arsenic toxicity
characteristic.
• Salvaging nonhazardous demolition debris, as feasible.
• Disposal of the following in off-site landfills: the
treated wastes; the untreated nonhazardous lagoon wastes; the
untreated nonhazardous miscellaneous products/feedstocks; and the
untreated nonhazardous demolition debris that is not. salvaged.
On December 30, 1990, the final ROD for Operable Unit Three
("OU-3") was issued. It addressed contaminated soils and adjacent
sediments, nonhazardous buildings, and ground water. The major
components of the remedy included treatment of heavily
contaminated soil and sediments, capping of remaining
contaminated soils and sediments, building demolition and
salvaging or disposal of debris, and pumping and treatment of
contaminated ground water.
On December 28, 1994, EPA issued an Explanation of
Significant Differences ("BSD") that modified the remedy to allow
the following materials to be incinerated at an off-site
facility:
Laboratory bottles;
Wooden debris from the vault;
Transformers (with and without detectable PCBs);
Crushed drums with adhering tar-like material;
"Unexpected" solid and liquid wastes from the vault;
Miscellaneous materials from on-site buildings;
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• Wooden tanks and process vessels; and
• Combustible demolition debris exhibiting the RCRA
arsenic toxicity characteristic.
An BSD No.2 was issued on November 7, 1995 that selected
off-site treatment and disposal of additional wastes originally
determined to be treated on-site. BSD No. 2 documented the
decision to: 1) incinerate the aniline still-bottom tars and
carbon/tar wastes excavated from the vault at off-site facilities
(several incineration facilities were subsequently used);
2) stabilize the calcium arsenate sludge; 3) incinerate wastes
with elevated levels of organic compounds, (i.e., fuel and waste'
oils, aniline residuals, and organic product residuals); and,
4) stabilize wastes with a limited amount of organic compounds
(i.e., floor sweepings, concrete residuals, wood, and debris).
III. REASONS FOR ISSUING THE ROD AMENDMENT
In the ROD for OU-2, the selected remedy for "upper vault
wastes" (UVW) was bulk excavation, followed by the following
treatment steps:
• on-site incineration in the presence of cement/pozzolan
fixative agents (to inhibit arsenic volatilization
during incineration);
• fixation of incineration residuals using a
cement/pozzolan-based process or similar fixation
process that provides equivalent protection; and
• off-site disposal of the treated residuals.
During implementation of the U.S. EPA-approved Remedial
Design ("RD") Work Plan, the responsible parties, collectively
known as the Whitmoyer Laboratories Private Study Group
("WLPSG") , excavated the UVW from the vault and segregated the
wastes into three treatability groups: (1) soil, (2) carbon/tar
mixture, and (3) tar. The characterization results for the
wastes in these treatability groups were provided to U.S. EPA in
the July 29, 1994 Vault Wastes Characterization Results Report
("Characterization Results Report"). Off-site incineration of
the carbon and tar wastes began in December 1996 and is expected
to be completed by January 1999.
For the remaining UVW treatability group, which consists of
approximately 1,400 yds of arsenic-contaminated vault soils,
WLPSG identified an alternative to the ROD selected remedy of on-
site incineration. Based on new information developed during the
RD, including characterization of the vault soils, extensive
bench-scale treatability testing, and full-scale testing, it was
demonstrated that off-site chemical fixation (a.k.a. stabiliza-
tion) and disposal of the treated soils at a Subtitle C landfill
is an appropriate alternative to on-site incineration.
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The rationale for the identification of stabilization as an
appropriate treatment technology for the vault soils, and its
identification of appropriate treatment levels are discussed
below, along with an evaluation of stabilization vis-a-vis the
remedy selection criteria specified in the National Oil and
Hazardous Substances Pollution Contingency Plan, as amended,
("NCP"), 40 C.F.R. Part 300.
IV. DESCRIPTION OP THE NEW ALTERNATIVE
As discussed in detail in the Characterization Results
Report, the vault soils contain primarily arsenic and relatively
low concentrations of organic compounds. With regard to the
organic content, the vault soils are more similar to the calcium
arsenate sludge excavated from the lower portion of the vault
(Lower Vault Wastes - "LVW"), which also contain primarily
arsenic, than to the UVW carbon/tar and tar groups which contain
elevated levels of arsenic and organic compounds. This
comparison is shown below.
Waste Group
Vault Soil
LVW
Carbon/Tar
Tar
Arsenic
Content
average %
9
20
11
10
Aniline
Content
average %
0.2
O.l*
10
10
maximum concentration
Because of the vault soils' chemical similarity to the LVW, for
which WLPSG demonstrated that stabilization provides effective
treatment, WLPSG undertook a series of bench-scale tests to
evaluate the effectiveness of stabilization. The results of
these treatability tests are summarized below.
As shown in the Characterization Results Report, the vault
soils exhibit only the D004 (arsenic) characteristic. Therefore,
the only potentially applicable Land Disposal Restrictions
("LDR") treatment standard for the soils is arsenic at 5 mg/L as
a constituent concentration in waste extract. 40 C.F.R. Part 268.
Although organic constituents were detected at low levels in the
soils, no applicable treatment standards exist for these
constituents under current regulations. Additionally, for soils
that are subject to LDR treatment standards, compliance with an
LDR treatment standard can be achieved by using a treatability
variance, as explained in U.S. EPA's Superfund LDR Guide #6A (see
Administrative Record). Under a treatability variance, an
alternate treatment level for soil with arsenic concentrations
greater than 10 mg/kg would be the achievement of greater than
90% reduction in TCLP-arsenic concentration.
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Bench-scale stabilization treatability tests.were conducted
in 1995 to identify a formulation that could feasibly and
consistently achieve the 5 mg/L arsenic LDR treatment standard
for D004 wastes. The investigation began with the chemical
formulation that WLPSG had demonstrated, after extensive bench-
scale tests, to be successful in treating the calcium arsenate
sludge to meet the LDR treatment standard. However, when applied
to vault soils, that formulation (and several other variations of
the formulation) was unable to achieve the 5 mg/L (arsenic) LDR
treatment standard, although virtually all of the formulations
tested were able to achieve a 90% reduction in the TCLP-arsenic
concentration.
Full-scale stabilization demonstration tests were conducted
in November 1996 to confirm that: 1) off-site stabilization can
be implemented at full-scale; 2) adequate reduction in leachable
arsenic (i.e., TCLP arsenic) can be achieved; and, 3) vault soils
will be accepted at one or more off-site disposal facilities in
accordance with the facility's Waste Analysis Plan and RCRA
permit requirements.
Prior to testing, each facility obtained at least one
representative sample of the vault soils for analysis of TCLP-
arsenic and TCLP-aniline. Each facility also conducted post-
treatment verification analysis for TCLP-arsenic and TCLP-aniline
following treatment of each batch. The vault soils are
characterized as a RCRA hazardous waste for arsenic only (0004
waste code) . As such, TCLP-arsenic is the only applicable LDR
treatment standard for the vault soils. Although organic
constituents were detected at low levels in the vault soils, no
applicable treatment standards exist for these constituents under
current regulations. Therefore, the LDR treatment standard for
arsenic is the only treatment standard that applies. An
evaluation of the pre- and post-treatment TCLP-aniline
concentration was recommended by U.S. EPA to determine the effect
the full-scale stabilization process had on the leachability of
aniline.
Full-scale demonstration tests were conducted at the US
Ecology (Beatty, Nevada) and Chemical Waste Management (Emelle,
Alabama) RCRA Subtitle C facilities where similar testing for the
lower vault wastes were previously conducted. Both facilities
achieved a greater than 90% reduction in TCLP-arsenic, with US
Ecology achieving a reduction of 95.8% and 98.1%. Although
bench-scale testing revealed a substantial decrease in TCLP-
aniline (88%), full-scale testing at both facilities indicated an
increase in TCLP-aniline (see Administrative Record for Results
of Full-Scale Tests for Upper Vault Soils).
WLPSG contacted US Ecology and Chemical Waste Management in
the Spring of 1997 regarding the level of leachable aniline from
the stabilized soils. A representative from each facility
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coordinated with the appropriate regulatory agency (Nevada
Department of Environmental Protection and EPA Region IV,
respectively) to ensure that they were aware of the organic
constituents in the soil and EPA Region Ill's plans to amend the
ROD for OU-2 to stabilize the vault soils. Both the Nevada
Department of Environmental Protection and EPA Region IV
indicated they would support the issuance of the Region III
treatability variance to stabilize the vault soils (i.e., achieve
a reduction in TCLP-arsenic greater than 90%) and were not
concerned with the relatively low levels of leachable aniline.
Based on the results of the bench-scale and full-scale
tests, it has been demonstrated that stabilization of the soils
can comply with the applicable LDR treatment standard for arsenic
through the use of a treatability variance. The fixation
formulation identified through WLPSG's extensive testing can
consistently and feasibly reduce TCLP-arsenic concentrations by
more than 90%. An evaluation of off-site stabilization vis-a-vis
the remedy selection criteria specified in the.NCP is presented
below to support the conclusion that off-site stabilization is an
appropriate alternative to the ROD-selected remedy of on-site
incineration of the vault soils.
V. EVALUATION OF ALTERNATIVES
Overall Protection of Human Health and the Environment
Both on-site incineration followed by stabilization of
residuals and off-site stabilization rely on immobilization of
the arsenic to protect human health and the environment, and do
not result in the destruction of arsenic, the principal hazardous
constituent of the soils. Both remedies provide adequate
protection of human health and the environment.
The concentration and/or mobility of the relatively minor
organic constituents of the soils are not expected to be
significantly impacted by the chemical additions necessary during
off-site stabilization of the soils. Chemical conversion (e.g.,
oxidation) and physical depletion (e.g., volatilization) during
the stabilization process may reduce the concentration of the
organic constituents. Although the relatively minor organic
constituents of the soils may not be destroyed as they would be
in incineration, the relatively low concentrations of these
constituents remaining after off-site stabilization and disposal
in a Subtitle C landfill would be expected to present
insignificant risk to human health and the environment.
Stabilized soils will be disposed at a Subtitle C landfill
constructed with liners and leachate collection systems. As a
result, off-site stabilization of soils and disposal of the
treated soils at a Subtitle C facility would provide protection
of human health and the environment by l) immobilizing arsenic,
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the principal hazardous constituent in the soil, and other
constituents of the soils, and 2) significantly reducing the
potential for exposure to the treated soils. In addition, off-
site stabilization of the soils would eliminate potential
exposures from potentially hazardous emissions that may occur
during on-site incineration of the soils, thus providing to the
community around the Whitmoyer Site (or off-site incinerator) a
greater level of overall protection than that provided by the ROD
selected remedy.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Off-site stabilization of the vault soils will comply with
LDR treatment requirements with the use of a treatability
variance as discussed above, and all other applicable state and
federal ARARs. This signed Amendment to the ROD for OD-2 by the
EPA Region III Regional Administrator hereby provides the
treatability variance required to perform the stabilization of
the vault soils.
The on-site handling, loading, and pre-transportation
preparation of the vault soils will be conducted in accordance
with the following Applicable or Relevant and Appropriate
Requirements (ARARs):
a) Federal Requirements
• 40 C.F.R.§261.3; §261.7; §261.10; §261.24 and §261.33 - RCRA
Regulations for Hazardous Waste Identification;
• 40 C.F.R. Part 264, Subparts I, L, CC, and DD - Standards
for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities: Use and Management of
Containers; Waste Piles; Air Emission Standards for Tanks,
Surface Impoundments, and Containers; Containment Buildings.
b) State Requirements
• 25 PA Code §261.3; §261.7; §261.10; §261.24 and §261.33 -
Pennsylvania regulations for Hazardous Waste Identification;
• 25 PA Code Chapter 264, Subparts I, L and T - Pennsylvania
regulations for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities: Use and
Management of Containers; Waste Piles; Containment
Buildings;
• 25 PA Code §123.1 and §123.2 - Pennsylvania regulations for
air pollution control of fugitive emissions.
In addition to the compliance with ARARs, compliance with
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all applicable federal, state, and local statutes, regulations
and ordinances regarding the off-site transportation, storage,
treatment and disposal of vault soils and debris is required.
Long-term Effectiveness and Permanence
The long-term effectiveness of off-site stabilization with
disposal in a Subtitle C landfill would be similar to that for
on-site incineration, since both alternatives would rely on
immobilization and engineering controls to minimize potential
exposure to arsenic. Although incineration would enhance long-
term effectiveness and permanence through destruction of organic
contaminants, stabilization has been shown to reduce the mobility
of arsenic in vault soils.
deduction of Toxicity t Mobility, or Volume Through Treatment
The ROD selected remedy of on-site incineration would
decrease the toxicity of the wastes by physically altering the
organic contaminants in the soil. However, incineration would
not reduce Che toxicity or volume of the principal hazardous
constituent, arsenic, and could potentially mobilize arsenic into
the environment. According to the ROD remedy, vault wastes would
be incinerated in the presence of cement/pozzolan fixative agent
to inhibit arsenic volatilization during the thermal treatment
step. Given the low organic content of the vault soils, any
reduction in the volume of soil by incineration would be more
than offset by the addition of these fixative agents.
Furthermore, fixation of the incineration residuals using a
cement/pozzolan-based process would further increase the final
volume of treated soils.
Off-site stabilization would virtually eliminate any
potential for arsenic to be mobilized into the environment
because arsenic mobility would be reduced by greater than 90% and
the treated soils would be disposed in a Subtitle C landfill with
liners and a leachate collection system. The addition of
stabilizing agents to the soils would increase the soil volume;
however, this increase is expected to be comparable to the volume
increase resulting from on-site incineration followed by
stabilization of the residual material.
Short-term Effectiveness
The period of time needed to complete the stabilization of
the soils is expected to be approximately six months. WLPSG has
identified at least two facilities that can accept and treat the
soils, which decreases the amount of time needed to complete the
remedy. This is significantly less than the amount of time-
required to incinerate the soils either on-site or even at an
off-site location. On-site incineration would take several years
to implement and raise serious concerns regarding the potential
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for arsenic volatilization and accidental releases. Off-site
incineration haa been selected in the two previous ESDs to treat
wastes requiring incineration. However, due to the limited
capacity of off-site incinerators that are able to accept
arsenic-contaminated waste streams and the amount of site wastes
still waiting to be treated, it would be approximately one year
before the facilities could even begin to treat the vault soils.
Completion of off-site incineration would likely take several
years and require long-term storage either on-site or at an
alternate location.
Off-site transportation under either alternative would be
conducted in accordance with all ARARs. Under these require-
ments, transportation risks would be very low for both
alternatives.
Impl eaten tabi lity
WLPSQ has identified adequate off-site treatment and
disposal capacity for the soils and at least two facilities that
can accept and stabilize the soils. For the on-site incineration
remedy, a facility would need to be designed, constructed, and
tested to ensure it would not pose an unacceptable risk to the
surrounding community. As a result, incinerating the wastes on-
site would be a much more complicated remedy to implement with a
greater potential for delay. Incinerating the wastes at an off-
site location would be a less complicated remedy to implement
when compared to on-site incineration; however, as discussed
above, the time required to implement off-site incineration is
several years longer than the time required to stabilize the
soils and place them in a Subtitle C landfill.
Cost
The present-worth cost for stabilization of the 1400 yd1 of
soils is expected to be approximately $685,000, including
transportation costs to Beatty, Nevada. On-site handling costs
are not included but would be a constant factor regardless of the
treatment: implemented. Off-site incineration costs range from
$2.4 - 3.1 million, depending on the facility performing the
incineration. On-site incineration costs would be significantly
higher than the cost to incinerate at an off-site facility.
State Acceptance.
The Commonwealth of Pennsylvania did not concur with the
selection of the on-site incineration remedy. On July 22, 1996
PADEP indicated that they support modifying the ROD to treat
vault wastes at off-site locations where possible. PADEP
concurred with the two ESDs which selected off-site treatment
locations for wastes originally selected for on-site incineration
and on-site stabilization. On January 9, 1998 PADEP concurred
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with the proposed Amendment to the ROD for OU-2.
Community Acceptance.
Community concerns have been raised regarding the safety of
on-site incineration since EPA proposed the remedy in 1990.
Several homes are immediately adjacent to the Site and a grammar
school is located approximately 1/2 mile north of the Site. EPA
discussed the strategy to treat the vault wastes at off-site
locations during several public meetings since the issuance of "
the ROD in 1990. During each discussion, the citizens and local
officials present strongly supported the selection of off-site
treatment facilities and continued to express strong concerns
regarding on-site incineration. On-site incineration was
selected in the OU-2 ROD because off-site facilities were not
available to incinerate the arsenic-contaminated wastes in 1990.
VI. SUPPORT AGENCY COMMENTS
All of the above changes to the remedy have been coordinated
with representatives of PADEP pursuant to 40 C.F.R.
§ 300.435(c)(2). PADEP submitted a letter on Janaury 9, 1998
concurring with the changes to the selected remedy as described
in this Amendment to the ROD for OU-2.
VII. AFFIRMATION OF THE STATUTORY DETERMINATIONS
EPA has determined that the revised remedy complies with the
statutory requirements of CERCLA § 121, 42. U.S.C. § 9621.
Considering the new information that has been developed and the
changes that have been made to the selected remedy, EPA believes
that the remedy remains protective of human health and the
environment, complies with Federal and State requirements that
are applicable or relevant and appropriate to this Remedial
Action as described in the ROD for OU-2 for this Site, and is
cost-effective. In addition, the revised remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this Site.
VIII. PUBLIC PARTICIPATION
A draft of the Amendment to the ROD for OU-2 was released
for public comment as part of the Administrative Record file on
February 3, 1998. The Administrative Record also includes the
RODs for OU-1, OU-2 and OU-3, and all documents that formed the
basis for EPA's selection of the cleanup remedy in the RODs. A
summary of the proposed Amendment and other related documents and
the information upon which it is based have been included in the
Administrative Record file and the information repository for
this Site. The Administrative Record is available for public
review at the locations listed below:
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U.S. EPA, Region III
841 Chestnut Building
Philadelphia, PA 19107
Hours: Mon. - Fri., 9:00 a.m. - 4:00 p.m.
Whitmoyer Community Library
199 North College Street
Myerstown, PA 17067
The notice of availability of these documents was published
in the Lebanon Daily News on February 3, 1998. The public was'
provided thirty (30) days from the notice date to submit
comments. Two letters were received during the public comment
period and have been added to the Administrative Record. Both
letters were from elected officials who stated their support of
the proposed Amendment to the Record of Decision.
Date t W. Michael McCabe, Regional Administrator
. EPA Region III
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RESPONSIVENESS SUMMARY
FOR THE
AMENDMENT TO THE RECORD OF DECISION
OPERABLE UNIT TWO
WfflTMOYER LABORATORIES SUPERFUND SITE
MYERSTOWN, LEBANON COUNTY, PENNSYLVANIA
Public Comment Period
February 3,1998 through March 4,1998
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Responsiveness Summary
Whitmoyer Laboratories Superfund Site
Myerstown, Lebanon County, Pennsylvania
This Responsiveness Summary is divided into the following sections:
L Summary of Major Comments and Questions Received During the
Public Meeting aqd EPA Responses
This section documents comments and questions during the February 10,
1998 Public Meeting which was held at the Jackson Township Municipal
Building in Myerstown, PA.
IL Summary of Major Comments and Questions Received During the
Public Comment Period and EPA Responses
This section provides a comprehensive response to all significant
comments received in writing by EPA during the Public Comment period.
Part Ir Summary of Commentors* Major Issues and Concerns During the Public Meeting
This section provides a summary of commentors' major issues and concerns and EPA's
response to those issues and concerns during the February 10,1998 public meeting. A copy of
the complete transcript from that meeting is included in the Administrative Record.
"Commentors" may include local homeowners, representatives from nearby businesses, elected
officials, and representatives of potentially responsible parties ("PRPs").
1. A local elected official stated his support for the ofisite treatment of she wastes but also
expressed concern for the people residing in the area where the wastes are to be treated.
EPA Response: The facility that will be treating the soils is permitted, designed, and built to
receive such -waste and conduct the required treatment activities. Facilities such as these are
located in areas in order to have a minimal impact to the surrounding area
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2. A citizen inquired about the method of transporting the wastes from the Whitmoyer
Laboratories Site.
EPA Response: Wastes'will be shipped from the site via rail cars or trucks. Rail cars are
carefully lined and covered prior to shipment. Wastes are transferred into large containers if
transported via truck. All rail cars and trucks will be inspected before leaving the site.
3. A citizen inquired about the level of hazardous waste in the soil.
EPA Response: Arsenic is in soils at levels up to JO to 12 percent and aniline can be detected at
up to 2 percent.
4. A local elected official requested an update on the ground water treatment facility.
EPA Response: The ground water treatment facility-will treat up to 250 - 300 gallons of
contaminated ground water per minute. The extraction wells will capture approximately 97% of
the plume and construction is anticipated to be completed in April 1998.
5. During the update on future site activities, a citizen requested clarification on future
modifications to the Record of Decision in regard to onsite and adjacent surface soils.
EPA Response: EPA has not made any decision to modify this portion of the Record of Decision
at this time, although changes are being considered. Soil samples are being collected to gather
additional information needed to make a recommendation, which will be subject to public notice
and comment prior to EPA's final decision.
6. An attendee at the meeting requested information regarding the length of time to pump and
treat the ground water, the level of contamination remaining after treatment, and the presence of
organic chemicals.
FJ>A Response: Pumping will likefy take several decades, the arsenic cleanup level is SO parts
per billion, and various organic chemicals such as aniline, tetrachloroethene, and
1,2-dichloroethene are also present
7. A citizen requested additional information about the stabilization process.
EPA Response: EPA requested the Design Engineer to describe the process, Ms. Jennifer
Bryson of ENVIRON described that stabilization is a two-step process. The first step is a
patented process which converts the arsenic into a form that makes it more easily bound to other
compounds. The second part of the process is to add a cement-like mixture to solidify the
material prior to disposing it into a lined cell in a hazardous waste landfill. The landfill is then
covered with a multi-layer cap.
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Part IL Summary of Major Comments and Questions Received in Writing During the
Public Comment Period
1. Pennsylvania Senator David J. Brightbill submitted a letter supporting the Amendment to the
Record of Decision stating that "EPA has proven flexible and responsive to input from nearby
communities by finding a different solution to this problem [other than on-srte incineration]."
EP4 Response: No response was necessary.
2. Pennsylvania Representative Peter J. Zug also submitted a letter supporting EPA's proposed
Amendment to the Record of Decision, stating that..."this proposal will provide a safe, effective
alternative to on-site incineration."
EPA Response: No response was necessary.
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