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water was then dumped directly.on the ground. Casings were crushed after rinsing. The smaller
battery casing pieces were often used as a substitute for road gravel both onsite and offsite.
In the Spring of 1980, DEP's predecessor agency, the Pennsylvania Department of
Environmental Resources ("DER"), investigated lead contamination at a dairy farm located near
the Site. The dairy farm had become contaminated through the use of crushed battery casings as
road cover. The Site was identified as the source of the battery casings. Subsequent testing
conducted by DER and the Pennsylvania Department of Health at the Site provided sufficient
evidence to indicate that a serious health threat existed on the Site. EPA studied the Site in the
fall of 1983 and conducted a Removal Action during the winter of 1983 and spring of 1984. This
Removal Action consisted of the temporary relocation of Site residents and excavation and
consolidation of battery casings and contaminated soils. In addition, this action included onsite
containment of the wastes beneath a low permeability soil cap located in the southwest quadrant
of the Site. This area is referred to as the "containment area". The Site was placed on the EPA
Superfund National Priorities List ("NPL") in June 1986.
EPA began a Remedial Investigation/Feasibility Study ("RI/FS") for the Site in 1988. The
purpose of the RI/FS was to characterize the extent of contamination at the Site, quantify risks to
human health, and evaluate potential environmental risks and remedial alternatives. Site
characterization included sampling and analysis of surface and subsurface soil, ground water,
surface water, sediment, ambient air, interior dust and blood-lead levels of onsite residents. A
baseline risk assessment was conducted as part of the investigation and includes quantification of
risks to human health. An evaluation of remedial alternatives is presented in the Feasibility
Study portion of the RI/FS report.
Major findings of the RI/FS include the following:
Onsite surface soils and shallow subsurface soils are contaminated with varying
concentrations of lead, ranging from less than 500 mg/kg to more than 60,000
mg/kg.
Soil and groundwater contamination resulted from onsite deposition of battery
wastes. These wastes included crushed rubber battery casings, battery acid, and
metallic lead grids, posts, and plugs. These materials remain onsite and must be
addressed along with contaminated soils.
The shallow groundwater aquifer onsite is contaminated with lead, metals,
dissolved solids and acid.
Lead is being transported from the Site to the adjacent Schuylkill River.
The bedrock aquifer onsite is contaminated with sulfate, cadmium, beryllium,
manganese, dissolved solids and acid.
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£L SIGNIFICANT DIFFERENCES
Selected Remedy For Bedrock Groundwater in the OU-2 ROD
The objective of the bedrock ground water portion of the OU-2 ROD (1&, pumping and treating
the bedrock aquifer after further study of the aquifer to trace the extent and direction of
contaminant movement) is to reduce the concentration of metal contaminants to background
levels so as to eliminate any impact of the Brown's Battery Site on the local groundwater and
surface water.
The Soils and Casings portion of the OU2 ROD is not modified through this ESD.
Description of the Significant Differences
This ESD modifies the groundwater portion of the Selected Remedy to revise the cleanup
standard for lead with which the groundwater portions of the Selected Remedy must comply,
both in the Shallow Alluvial Aquifer as well as the Deep Bedrock Aquifer. The Performance
Standards to be achieved by the Selected Remedy, as specified in Sections IX.B.2. and IX.B.3. of
the OU2 ROD, are also modified to reflect this revision.
EPA has now concluded that certain requirements that were formerly considered Relevant and
Appropriate are Relevant but no longer Appropriate to the Site because the more stringent
groundwater cleanup requirements described in the OU-2 ROD and set forth in 25 Pa. Code
Sections 264.97(i) and 264.100(a)(9), which necessitated cleanup of groundwater contamination
to background levels, are appropriate to the management of hazardous wastes at RCRA .
Treatment, Storage and Disposal facilities, rather than facilities such as the Site which has been
inactive since 1971.'
PADEP has identified 5 ug/1 as the cleanup standard for lead in groundwater, pursuant to Act 2,
35 P. S. §§ 6026.101-6026.909, as set forth in recently issued statewide, health-based
remediation standards, 25 Pa. Code 250, Subchapter C (27 Pa. Bull. 4181, August 16, 1997)
("Act 2 Standards"). EPA accepts the Act 2 Standard for lead (5 ug/1) for ground water cleanup
at this Site. The cleanup level of 5 ug/1 is the Medium Specific Concentration ("MSC") for lead
specified in the Act 2 Standards, 25 PA Code Chapter 250, Appendix A, Table 2.
1 25 Pa. Code Sections 264.97(i) and 264.100(a)(9) were not "Applicable"
regulations because disposal of hazardous wastes at the Site occurred before these regulations
became effective.
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For all other contaminants listed in Tables 1 and 2 of the OU-2 ROD, EPA has determined that
Act 2 does not, on the facts and circumstances of this remedy, impose any requirements more
stringent than the Federal standards. The relevant and appropriate requirements are the Federal
Maximum Contaminant Levels ("MCLs") and non-zero Maximum Contaminant Level Goals
("MCLGs") specified as the national primary drinking water levels at 40 C.F.R. Section 141.11-
141.16 which were promulgated pursuant to Section 300g-l of the Public Health Service Act, as
amended by the Safe Drinking Water Act, 42 U.S.C. Sections 300fetseq.
IL SUPPORT AGENCY COMMENTS
The above changes to the remedy have been coordinated with DEP pursuant to 40 C.F.R.
§ 300.435(c)(2)(i). DEP has concurred with the changes to the selected remedy as described in
this ESD. A copy of the concurrence letter is attached.
IL AFFIRMATION OF STATUTORY DETERMINATONS
Considering the new information that has been developed and the changes that have been made
to the selected remedy, EPA believes that the remedy, as modified by this ESD, 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, and is cost-effective. In
addition, the revised remedy utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this Site.
£ PUBLIC PARTICIPATION ACTIVITIES
This ESD has been made part of the administrative record file and is available for review at the
two locations identified below:
United States Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
(215)566-3157
Hours: 8:30 a.m. to 5:00 p.m.
Monday through Friday
and
Hamburg Borough Library
35 North 3rd Street
Hamburg, PA 19526
(610) 562-2843
Hours: M, T, Th 1:30-8:30 P.M.
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EPA has opened a public comment period from January 12, 1998 to February 10, 1998 to solicit
comments on this BSD. Comments should be sent to:
Richard Watman
Remedial Project Manager
United States Environmental Protection Agency
Region III (3HS22)
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Abraham Ferdas, Acting Director Date
Hazardous Site Cleanup Division
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