PB95-963905
EPA/ROD/R03-95/194
April 1995
EPA Superfund
Record of Decision:
Westinghouse Elevator Company Plant
(O.U. 2), Gettysburg, PA
3/31/1995
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RECORD OF DECISION
WESTINGHOUSE ELEVATOR CO. PLANT
Operable Unit Two
(Soils)
DECLARATION
SITE NAME AND LOCATION
Westinghouse Elevator Company Plant
Cumberland Township
Adams County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for Operable Unit 2 (Soils) at the Westinghouse Elevator
Company Plant 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. §§ 9601 et. sea. ; 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, concurs
with the selected remedy.
DESCRIPTION OF THE REMEDY
The Westinghouse Plant was constructed in 1968 for the
manufacture of elevator and escalator components. Schindler
Elevator Corporation has leased and operated the plant building
since January 1989. This ROD addresses only, contaminated soils
at the Westinghouse Elevator Plant Site. The previous Record of
Decision, issued on June 30, 1992, selected extraction and
treatment of on-Plant and off-Plant ground water, using
extraction wells, air stripping of contaminants from ground
water, and carbon adsorption of the contaminants in the effluent
air stream.
The selected remedy for the soils at the Westinghouse
Elevator Plant is No Additional Action for this Operable Unit.
The other alternatives evaluated would produce little or no
environmental benefit at substantial cost. Although risks
presented by the soils are not above EPA's acceptable risk
levels, since the previous ROD for Operable Unit 1 addressed the
Applicable or Relevant and Appropriate Requirements ("ARARs") of
the Commonwealth of Pennsylvania with regard to the ground water
portion of the Site, this ROD will address ARARs for the soils
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portion of the Site. The Commonwealth's ARARs and the need to
evaluate the impact of the leaching of contaminated soils on
ground water of the Commonwealth required completion of the
Feasibility Study and a more detailed remedy selection analysis
in this ROD.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative
treatment 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 in the previous ROD for Operable Unit
1 will result in hazardous substances remaining onsite below the
ground water table and 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 ground water remedy to
ensure that the selected remedy is providing protection of human
health and the environment.
Thomas C. VoltaggJ Date
Division Di
Hazardous Waste Management Division
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 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
IV. SCOPE AND ROLE OF RESPONSE ACTION 6
V. SUMMARY OF SITE CHARACTERISTICS 7
VI. SUMMARY OF SITE RISKS 17
VII. SUMMARY OF ALTERNATIVES . 21
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES . 26
IX. THE SELECTED ALTERNATIVE 28
X. STATUTORY DETERMINATIONS 30
XI. EXPLANATION OF SIGNIFICANT CHANGES 32
APPENDIX A TABLE OF COSTS
APPENDIX B FIGURES
APPENDIX C RESPONSIVENESS SUMMARY
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RECORD OF DECISION
WESTINGHOUSE ELEVATOR CO. PLANT SITE
OPERABLE UNIT TWO (Soils)
DECISION SUMMARY
I. SITE NAME. LOCATION AND DESCRIPTION
Site Description
The Westinghouse Elevator Plant is located on approximately
90 acres of land along the vest side of Biglerville Road (Route
34), approximately 1.5 miles north of downtown Gettysburg in
Cumberland Township, Adams County, Pennsylvania (figure 1 -
Appendix B) . The Site coordinates are latitude 39° 51' 08" north
and longitude 77° 14' 21" west. The Plant is bounded to the
south by property that is part of the Gettysburg Battlefield
National Park; and to the west, north and east by residential and
small commercial properties (Figure 2-Appendix B). The closest
private residences are approximately 200 feet east of the Plant
building.
Prior to its current use, most of the property consisted of
farmland. A farm pond, approximately two acres in area, existed
on the property near what is now the main entrance to the
Westinghouse Plant. The Westinghouse Plant ("Plant") was
constructed in 1968 for the manufacture of elevator and escalator
components. The Westinghouse Electric Co. ("Westinghouse") began
operating the Plant following completion of construction and used
the solvents trichloroethene ("TCE") and 1,1,1-trichloroethane
("TCA") in the manufacturing process. Since January 1989 the
Plant has been leased and operated by the Schindler Elevator
Corporation ("Schindler").
The regional topography in the area of the Site is low to
medium relief, undulating terrain. Specifically, the Site slopes
moderately to the east, dropping in elevation from 600 feet above
mean sea level ("MSL") in the west to 525 feet above MSL in the
east.
Ground water is the only source of potable water in the area
and residents near the Site are dependent on municipal or private
wells. EPA considers this source of drinking water to be a class
IIA aquifer.
The Site is located within the watershed of Rock Creek, a
small southward-flowing stream located approximately three-
quarters of a mile to the east of the Plant. Two small
intermittent streams (Northern and Eastern Tributaries - figure
2-Appendix B) are present near the Site. Most surface water at
the plant is collected by a storm drainage system which
eventually discharges to the two tributaries. No flood plains or
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wetlands are present on the Plant property.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
The Plant has been in operation since 1968 as a
manufacturing Plant of elevator and escalator components and
continues operations currently. The manufacturing process
utilized by Westinghouse and continued to be used by Schindler
consists of several steps including parts delivery and unloading;
metal parts degreasing; rust prevention; primer and finisher
paint booth operations; oven drying; acoustical coating;
machining and sawing; adhesive application; final assembly; and
shipping.
Chemical feed materials used in many of the operations
include solvents, paints, cutting and lubricating oils, and
insulation board. The major solvent used up to 1975 was TCE,
after which time TCA was substituted for TCE. Waste materials
generated include spent solvents, paint sludges, spent oils and
greases, and excess insulation board. The processes which
generated the majority of hazardous or otherwise regulated wastes
related to contaminants found in ground water are described
below.
Metal parts degreasing operations remove thin coatings of
oil applied by the parts suppliers to bare metal surfaces
for corrosion prevention. Spent solvent saturated with oil
is containerized and stored in the drum storage area for
off-Site disposal.
Prior to 1975, a Triclene-phosphatizing process preceded
paint booth operations. Triclene-phosphatizing is a process
of producing a crystalline iron phosphate layer on steel
surfaces to prevent corrosion. Major ingredients include
TCE and phosphoric acid. Waste materials were either
drummed for storage in the drum storage area or pumped into
large holding tanks, located near the southwest corner of
the Plant, for off-Site disposal. The Triclene procedure
was eliminated in 1975 and replaced by a lead chromate
primer application process.
Machining and sawing operations utilize lubricating and
cutting oils. Some solvents are used to remove oils from
metal parts after cutting operations or to clean equipment
motors. Waste oils and degreasing solvents are drummed and
stored in the drum storage area for off-Site disposal.
Prior to 1981, drummed waste chemicals were stored in an
area located in the southern portion of the Plant. This
area is currently referred to as the 'old waste drum storage
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area. Drummed wastes are currently stored on a covered,
diked concrete pad referred to as the hazardous waste drum
storage area which is located near the shipping docks.
As a result of Plant operations, a number of potential
source areas for the detected contamination were identified at
the Site. These areas include the former solvent remote fill
line, the degreasing solvent storage tank location, pumphouse
area, railroad dock, and the old waste drum storage area. The
location of each area is shown on Figure 3-Appendix B. Each area
is briefly described below.
The former solvent remote fill line is located in the
southwestern portion of the facility. Beginning in 1980,
tank trucks containing fresh degreasing solvent filled a
storage tank in the interior of the building through this
buried line. Prior to 1980, degreasing solvent was
purchased and stored in 55-gallon drums. In 1985,
Westinghouse discontinued the use of the buried remote line.
This area is considered to be a potential source due to the
possibility of spills during filling operations or line
integrity failures.
Degreasing solvent is currently stored in an above-ground
tank located on a diked concrete pad in the courtyard of the
building. This tank is filled through the current remote
fill line. The fill connection is located at the south end
of the building and feeds directly to the tank. This area
is considered a potential source due to the possibility of
leaks, spills, or ruptures. In May 1991, a spill of about
twenty gallons of solvent occurred and was reported to the
PADER by Schindler. Schindler removed contaminated soil
along the concrete pad.
In the past, metal grates from the Plant's paint booths were
cleaned on a concrete pad in the pumphouse area, located at
the southwest corner of the Plant. Caustic solutions with
solvents were used to loosen excess paint build-up on the
grates. The loosened paint was then scoured off using a
steam cleaner. This is considered a potential source area
due to the nature of operations whereby solvent-contaminated
washwater may have been discharged directly into the
environment.
At the railroad dock area, located at the north end of the
Plant, solvent-coated metal chips and shavings that
accumulated at the bottom of degreasing tanks were stored in
metal bins prior to removal by truck for recycling.
Information in EPA's files indicates that these bins had
holes in the bottom to drain the solvent. This area is
considered to be a potential source due to solvent drippings
leaking out of the containers and migrating into the
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subsurface environment.
The old waste drum storage area is located on the southern
side of the building. Prior to 1981, drummed waste was
stored in this area until shipped for disposal. This is
considered to be a potential source due to the possibility
of spills. Testimony in the Merry v. Westinahouse Electric
Corporation. Civil Action No. 86-1673 (M.D.Pa.) action
describes several major spills in this general area.
In addition to the above-listed, potential sources, the
former pond area, located on the eastern side of the Plant is
considered a potential source based on the soil analyses. This
area may have become contaminated by migration of contaminants
from the pumphouse and railroad loading docks along a subsurface
channel in the bedrock surface identified in the RI report
(Figure 3-14 of the RI) . Westinghouse has alleged that some
drums may have been disposed in the pond before their ownership,
but no information has been supplied to EPA to support this
assertion.
INVESTIGATIONS
Investigations of alleged environmental problems related to
the Site were initiated in 1983, based on complaints from local
residents to the Pennsylvania Department of Environmental
Resources (PADER). PADER representatives visited the Plant in
1983 and collected samples from the Plant irrigation well and
from neighboring residential wells. Chemical analyses of these
samples confirmed the presence of Volatile Organic Compounds
("VOCs") including TCE and TCA in the on-Plant and off-Plant
ground water. Analysis of residential well samples continued
until alternative water supplies were provided by Westinghouse.
The residential well sampling indicated widespread contamination
throughout the area bounded by Biglerville, Table Rock and Boyd's
School Roads.
Subsequently, in October 1983, PADER sampled two suspected
source areas on the Plant property including soils from the
railroad dock and surface water samples from the old waste drum
storage area. Chemical analysis by both PADER and Westinghouse
indicated the presence of volatile organics in surface water,
ground water, and soil samples from the Site. In November 1983,
Westinghouse initiated the removal of 10 drums of contaminated
soil from the railroad dock area and 33 drums of contaminated
soil from the pumphouse area. The drums were manifested as a
hazardous waste and were sent to a secure landfill in New York
State. Figure 3-Appendix B shows these areas.
In January 1984, Westinghouse contracted R.E. Wright to
serve as a consultant. During 1984, Wright collected additional
water and soil samples from various locations at the Site,
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installed fifteen monitoring wells and conducted a pump test.
In 1984, Westinghouse installed water mains along
Biglerville Road and a portion of Boyd's School Road to provide
residents with access to the public water supply. Since 1984,
Westinghouse has installed additional mains along stretches of
Boyd's School Road, Cedar Avenue, Maple Avenue, and Apple Avenue.
Westinghouse also installed monitoring wells and sampled ground
water from these wells during this time. The extent of the
water lines is shown in figure 2 - Appendix B.
In June 1984, Westinghouse installed and began to extract
ground water at the Site and to operate an air stripping tower to
remove TCE and other VOCs from ground water. At a later time,
PADER ordered Westinghouse to continue the operation of the
stripping tower, but Westinghouse contested the Order. The
stripper has been shut down several times for various reasons and
then restarted. The stripper has generally been in operation
since February 1989 and currently treats about nine gallons per
minute of contaminated ground water. The stripper discharges to
the Northern Tributary, a stream along Boyd's School Road, and is
regulated by a National Pollutant Discharge Elimination System
("NPDES") permit.
On March 10, 1987, Westinghouse entered into a Consent
Agreement with EPA to perform a Remedial Investigation and
Feasibility Study ("RI/FS") of the Site. The Remedial
Investigation was completed in two phases: a) Phase I determined
the Site contaminants and hydrogeology and b) Phase II
investigated the extent of contamination. The Phase II Remedial
Investigation Report was completed on July 2, 1991 and a draft
Feasibility Study was submitted to EPA in October 1991, which
needed substantial modifications. Additionally, finalization of
the report was further delayed by the need to investigate soil
contamination from a TCA spill which occurred on May 3, 1991, at
which time Schindler was operating the Plant. Schindler removed
contaminated soils and sampled the area to verify the cleanup at
PADER's reguest. This area needed additional sampling and study
before a remedial action decision could be made on the Site's
soils. Therefore, to avoid further delay in the ground water
cleanup, EPA allowed Westinghouse to submit a revised Feasibility
Study that only addressed sediments, surface water, and ground
water at the Site. A Record of Decision ("ROD") for the Site's
ground water, surface waters and sediments was issued on June 30,
1992. The ROD selected extraction of ground water using two well
systems (see OU1 ROD) and treatment of the ground water by air
stripping. The extract ion/treatment system is currently in the
design phase. A supplementary Feasibility Study for soils was
completed by Westinghouse's contractor in December 1993.
CERCLA ENFORCEMENT
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An initial PRP search identified only Westinghouse as a
Responsible Party and only Westinghouse was issued a General
Notice letter for the RI/FS. However, the TCA spill at the Plant
that occurred in May 1991, prompted EPA to issue a General Notice
letter to Schindler Elevator Corporation. Following the issuance
for the ground water ROD on June 30, 1992, EPA issued Special
Notice Letters to Westinghouse and Schindler which encouraged
them to submit a good faith offer to perform the work called for
in the ROD. EPA did not receive a good faith offer from either
Westinghouse or Schindler, so on December 29, 1992, EPA issued a
Unilateral Administrative Order to Westinghouse and Schindler
compelling them to implement the selected remedial action for
ground water. Westinghouse agreed to comply with the order, but
Schindler declined, claiming that they had sufficient cause for
not complying with the Order.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Remedial Action Plan (Proposed Plan)
were released for public comment as part of the administrative
record file on February 3, 1995, in accordance with Sections
113(k)(2)(B), 117(a), and 121(f)(1)(G) of CERCLA, 42 U.S.C.
§§ 9613 (k) (2) (B), 9617 (a), and 9621 (f)(1)(G). 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 on February 3, 1995. A public
meeting to discuss the Proposed Plan was held on February 23,
1995, in Cumberland Township, Pennsylvania. The comment period
ended on March 6, 1995. 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.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The Principal 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 and the highly
contaminated ground water associated with the DNAPLs. This
threat is being addressed by the ROD for the Site ground water.
Soils studies during the Phase II investigation, the Risk
Assessment, and the additional courtyard soils study did not
identify any direct significant exposure risk to employees,
because the contamination is several feet below the surface or is
at very low concentrations. Residential exposure to soil was not
considered realistic because the site's ongoing present and
future use is as a limited-access industrial site. However,
contaminants may be leaching from subsurface soils, thereby
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contributing to ground water contamination slightly.
Contaminated soils will be addressed in this ROD. When EPA
addresses problems at a site in more than one ROD, EPA calls each
ROD an Operable Unit. Sediments, surface and ground water were
addressed under Operable Unit One and this ROD for soils will be
considered Operable Unit Two. EPA considers this a final action
ROD for the Site.
The only significant threat to human health and the
environment, identified by the RI, is from domestic use of
contaminated ground water. The overall remedial goals for all
Site media relate to this threat. The scope and role of the
selected alternative addressing ground water is to prevent
migration of all contaminated ground water to the extent
technically practicable, especially ground water in contact with
DNAPLs, to off-Plant residential wells and to restore the aquifer
to the extent practicable. This threat will be satisfactorily
addressed by the previous ROD for Operable Unit One.
V. SUMMARY OF SITE CHARACTERISTICS
GENERAL
The Westinghouse Plant is located on approximately 90 acres
of land along the west side of Biglerville Road (Route 34),
approximately 1.5 miles north of downtown Gettysburg in
Cumberland Township, Adams County, Pennsylvania (figure 1 -
Appendix B). The Gettysburg area has no large rivers nearby and
is very dependent on ground water. Yields from wells in the
Gettysburg Formation are relatively low and the area is
experiencing substantial development placing continuing pressure
on the current municipal water supply. The area has three
Superfund sites including the Hunterstown Road Site, the
Shriver's Corner Site and the Westinghouse Plant Site.
Additionally, a RCRA Site in downtown Gettysburg contaminated
several of the municipal wells which were shut down. Before the
contamination was discovered at the Westinghouse Plant Site, the
adjacent residential areas used private wells for full domestic
use. These areas are now served by water lines, but some
residents have declined to use public water and some residents
use their wells for watering gardens.
Prior to its current use, most of the Plant property
consisted of farmland. A farm pond, approximately two acres in
area, existed on the property near what is now the main entrance
to the Westinghouse Plant. The Westinghouse Plant was
constructed in 1968 for the manufacture of elevator and escalator
components by Westinghouse. Since January 1989 the Plant has
been leased and operated by Schindler.
The manufacturing processes at the Site consist of several
steps: parts delivery and unloading; metal parts degreasing;
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Triclene phosphatizing; primer and finisher paint booth
operations; oven drying; acoustical coating; machining and
sawing; adhesive application; final assembly; and shipping.
Chemical feed materials used in some of these operations include
solvents, paints, cutting and lubricating oils, and insulation
board. TCE was the primary solvent used at the Site until 1975
at which time TCA was substituted.
LAND USE
The Plant is bounded to the south by property that is part
of the Gettysburg Battlefield National Park (Figure 2 - Appendix
B) . The National Park Service (NFS) is concerned about the
limitations that the Westinghouse Plant contamination may place
on their ability to site a large well on park property. The NPS
is also concerned about the potential to contaminate a
residential well, just south of the Plant, and currently used by
NPS employees. This well has been tested and only a trace of
solvents was detected and the level was far below drinking water
standards (less than 1 ppb TCE).
Adjacent to the Plant property and north and east of the
Plant are residential and small commercial properties. The
closest private residences are approximately 200 feet east of the
Plant along Biglerville Road. A residential area is to the west
of the Plant about 1000 feet from the Plant building. Ground
water is the only source of potable water in the area and
residents near the Site are dependent on municipal or private
wells. EPA's Ground Water Protection Strategy classifies
aquifers based on 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. It is estimated that the total population within a
three mile radius that uses ground water from the same
hydrogeologic formation is 11,600.
TOPOGRAPHY
The regional topography in the area of the Site is low to
medium relief, undulating terrain. Specifically, the Site slopes
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moderately to the east, toward Rock Creek, dropping in elevation
from 600 feet above mean sea level ("MSL") in the west to 525
feet above MSL in the east.
Regional Geology
Prior to the Plant construction the natural soils were
classified by the U.S. Soil Conservation Service as part of the
Penn-Readington-Croton association. These soils are gently to
moderately sloping, shallow to moderately deep shaley soils
derived from the underlying Triassic red beds. These natural
soils were disturbed due to Plant construction activities. Based
on geotechnical information and summaries made by Paul C. Rizzo
Associates, a majority of the soil underlying the Plant is fill
material with a mixture of grain sizes from clay to boulders.
Some natural soil was encountered, with bed thicknesses between
two and four feet.
The Site is located within the Gettysburg Basin, one of a
number of discrete elongate sedimentary basins parallel to the
Appalachian orogen in eastern North America. These basins are of
early Mesozoic age (Late Jurassic-Early Triassic) and are
comprised largely of continental clastic rocks and accompanying
basic intrusive and extrusive igneous rocks (Froelich and Olsen,
1985). Geology local to the Site appears to be unmetamorphosed
sedimentary rock. The sedimentary rocks underlying the Plant are
mapped as the Heidlersburg member of the Gettysburg Formation.
The Heidlersburg member is described as a lacustrine (lake
deposited) series of red and gray arkosic sandstones, red
mudstones, and dark gray sandstones and shales (Root, 1988).
Site investigations have mapped the underlying stratigraphy as
being comprised of red and gray siltstones and shales overlain by
approximately two to ten feet of red to brown clay. Bedrock is
generally fractured and weathered in the upper fifty feet and is
encountered two to ten feet below ground surface (Rizzo, 1991).
Regional Hydroojeolocrv
Ground water in the vicinity of the Site is stored in and
transmitted through a complex system of interconnected fractures
consisting of bedding planes and steeply dipping joints.
Investigations have shown that there exists two flow regimes
(shallow and deep).
The shallow regime consists of the localized saturated soils
and weathered bedrock. Ground water flow direction in this
regime is generally to the east-southeast towards Rock Creek and
is primarily influenced by local topography, but bedding planes
still produce some anisotropic influence. The approximate ground
water gradient in the shallow regime is about 0.03 ft/ft. Net
permeabilities from packer tests for this zone ranged from 6 x
10"~5 to 5 x 10~3 cm/sec.
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The deep regime is below weathered bedrock and flow
direction is much more complicated and is strongly influenced by
the structure of the geology. The details of this site's complex
hydrogeology are discussed in the RI/FS and the Record of
Decision for Operable Unit One.
EPA believes that Rock Creek is the ultimate surface water
discharge point for contaminated ground water, since Rock Creek
is the only large stream that drains the Gettysburg basin.
Known or Suspected Sources of Contamination
After a review of Plant processes and extensive remedial
investigations at the Site, at least six potential sources of
contamination have been identified. During Phase I and Phase II
investigations, soil samples were obtained and analyzed from
these areas. After the Phase I investigation, the contaminants
that were related to disposal practices, that had significant
toxicity, and were detected at significant concentrations during
the Phase I investigation were identified as Contaminants of
Interest ("COI") . The Phase II investigation then focused only on
those contaminants. The laboratory results indicated that the
following Contaminants of Interest were detected at each area:
* Former Solvent Remote Fill Area/Old Waste Drum
Storage Area - No COI were detected.
* Degreasing Solvent Storage Tank/Courtyard Area -
No COI were detected in this area.
* Pumphouse Area - 1,1 dichloroethane and
1,1,1-trichloroethane detected during Phase I.
Contamination not detected in Phase II boring.
* Railroad Dock - Contaminated with VOCs before
removal action. Xylenes detected during Phase II.
* Old Drum Storage Area - No VOCs Detected.
* Former Pond Area - TCE; TCA; 1,1-dichloroethane;
1,2-dichloroethane; 1,1- dichloroethene and 1,2-
dichloroethene detected during Phase II.
The solvents TCE and TCA are heavier than water and will
dissolve only very slowly in ground water. When large amounts of
these solvents are spilled they may sink through the ground water
as a separate phase until they are trapped by solid rock or the
bottom of a fracture. They then will dissolve into ground water
over many years. These solvents are called Dense Non-Aqueous
Phase liquids ("DNAPLs"). EPA believes that DNAPLs have migrated
through the soil into bedrock at the Westinghouse Plant beneath
the water table and that this is the primary source of ground
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water contamination. It is impossible to calculate or estimate
the amount of DNAPLs present in the bedrock.
Identified Compounds of Interest
During the Phase I remedial investigation, a composite soil
sample from the Pumphouse Area contained 0.52 parts per million
of polychlorinated biphenyls ("PCBs"). This level is below the
EPA cleanup level for residential soils (1 part per million parts
of soil (ppm)) and well below the EPA cleanup level for
industrial soils (10 ppm). PCBs were not found in any other
samples during the Phase I RI. EPA did not consider PCBs a
contaminant of concern at the site and Phase II RI samples were
not analyzed for PCBs.
During the Phase I Remedial Investigation, composite samples
from the Remote Fill Area, the Pump House, and the Old Drum
Storage Area contained somewhat elevated levels of Polycyclic
Aromatic Hydrocarbons ("PAHs"). The levels of total PAHs were as
follows: 1) Remote Fill Area - 3.7 ppm; 2) Pumphouse Area - 5.2
ppm and 3) Old Drum Storage Area - 6.8 ppm. PAHs are very common
contaminants formed during combustion and are also present in
crude oil and coal. PAHs are deposited along roadways from
automobile and truck exhaust and are commonly elevated along
roadways and in industrial areas. When risks from carcinogenic
contaminants exceed 1 x 10~4 (the probability that 1 cancer
incidence will occur for 10,000 people exposed for a lifetime)
EPA generally takes action. Contaminant trigger levels based on a
10~4 risk at an industrial site for the most carcinogenic PAHs
such as benzo(a)pyrene is about 39 ppm. The acceptable level for
total PAHs which includes PAHs with lower risks would be even
higher. Additionally, during the Remedial Investigation, it was
learned that the Westinghouse Plant parking lot was resurfaced
with a commercial product that contains these compounds. One ,
compound Bis(2-Ethylhexyl)- phthalate was found in only one
surface sample and one subsurface sample at a different location.
This compound is added to plastics to reduce brittleness. Bis(2-
ethylhexyl) Phthalate is also a common environmental contaminant.
Westinghouse did not produce plastics at the Plant and EPA
believes that this was probably a lab contaminant. None of these
compounds were found in ground water at the site and they do not
appear to be moving. The compounds are not volatile and would
not pose a significant risk from inhalation. The contamination
is adjacent to an operating manufacturing facility and direct
ingestion of soil by children is extremely unlikely. At the end
of the Phase I remedial investigation EPA eliminated these
compounds (semivolatiles) from further study.
Metals and inorganic compounds were not found at elevated
levels and appear to be at the same levels as uncontaminated
soils near the Plant.
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Sporadic detections of common laboratory contaminants such
as methylene chloride, acetone, toluene, and tetrachloroethane
(PCE) were observed in soil samples. Methylene chloride and
acetone were the most frequently observed compounds in this
category, but was also found in sample blanks. Sample method
blanks are tests of the laboratory contaminant detection
equipment with clean samples. In other words, the equipment
detected methylene chloride in samples where it was known that no
methylene chloride was present. Methylene chloride and acetone
are commonly used to clean laboratory equipment and glassware.
Toluene and Tetrachloroethane were detected in only one or two
samples at very low levels. In any case, a remedy effective for
the contaminants of interest would also be effective for these
trace contaminants.
Based on the Remedial Investigations, COI for soil
contamination at the Site have been identified. The COI are TCE,
TCA, 1,1-dichloroethene, 1,1-dichloroethane, 1,2-dichloroethene,
1,2-dichloroethane, and xylenes. TCE is moderately toxic to
humans by ingestion and inhalation and is considered a probable
carcinogen. TCA is moderately toxic to humans by ingestion,
inhalation, skin contact, subcutaneous (beneath the skin), and
intraperitoneal (space between membrane that lines interior wall
of abdomen and covers abdominal organs) routes and is currently
not classified as a 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 carcinogen. 1,2-dichloroethene is a
poison by inhalation, ingestion, and intravenous routes;
moderately toxic by subcutaneous route; and is currently not
classified as a 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). Exposure to high levels of xylenes adversely affects the
central nervous system and irritates the mucous membranes.
Xylene has not been found to be either a mutagen or a carcinogen.
Contaminant Fate and Transport
In the environment, the COI are typically found dissolved
in fluids, adsorbed to solids, or volatilized into the air.
Potential transport mechanisms include advection, diffusion,
dispersion, dilution, degradation, volatilization, absorption,
and particulate transport, and are described as follows:
• Advection consists of the transport of a dissolved
species by virtue of the flow of the solvent (in this case,
ground water).
• Diffusion is a mechanism whereby solute distributions
within water spread due to random molecular movements.
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13
• Dispersion is an analogous spreading mechanism produced
by random velocity variations in the movement of water.
• Dilution is the process whereby the mixing of two
streams of water containing unequal concentrations of dissolved
species produces a single stream with an average concentration.
• Degradation is the process whereby compounds undergo
transformation or other biological or chemical reactions which
destroy them.
• Volatilization consists of the evaporation of certain
of the lighter compounds from water and soil into the gaseous
phase, which can be either the atmosphere or soil gas.
• Adsorption is the process whereby dissolved compounds
in fluids that come in contact with solid media become attached
to the surface of the solid. Adsorption is often reversible and
termed desorption.
• Particulate transport consists of the movement of
absorbed compounds by virtue of the movement of the particles to
which they are attached.
The dominant transport mechanism for COI at the Elevator
Plant Site is believed to be through ground water migration. COI
are carried to the ground water as precipitation infiltrates from
the surface to the saturated zone. A minor mechanism of
transport for the chlorinated aliphatic hydrocarbons (i.e., VOCs)
at the Elevator Plant Site is believed to be desorption from
unsaturated soils in potential source areas and subsequent
infiltration into ground water. The major mechanism for transport
is diffusion from Dense Non-Aqueous Phase solvents trapped in
bedrock below the water table. Once in ground water, these
compounds are advected and dispersed. COI in the ground water
move laterally downgradient in an easterly direction toward Rock
Creek, or move vertically downward.
Although not considered to be a significant transport
mechanism, some volatilization may occur from the potential
source areas. In the absence of other processes, volatilization
would be observed as a gradual decline of VOC concentrations in
the potential source areas. However, in the natural environment,
it is not possible to distinguish this process from other
attenuation factors.
Concentrations of certain chlorinated aliphatic hydrocarbons
in site soils could decrease with time due to degradation.
Bacteria can slowly dechlorinate VOCs, producing dichloroethenes
and vinyl chloride from TCE and dichloroethanes, and chloroethane
from 1,1,1-TCA. This mechanism may account for some of the DCA
and DCEs detected in site soils.
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• 14
Extent: of Contamination
An extensive ground water investigation has been completed
at the Plant Site which consisted of drilling, constructing and
sampling seventeen monitoring wells in Phase I. The wells were
logged during drilling and various geological tests were
performed during drilling to help define the Site geology. An
additional eleven wells were drilled and constructed during Phase
II and all twenty eight wells were sampled. The ground water
investigation results are fully detailed in the Administrative
Record for the first Operable Unit (ground water). This ROD will
focus on the results of the soils investigation.
The Remedial Investigation was conducted in two phases: a)
Phase I of the investigation determined the contaminants of
concern and the physical conditions at the site such as soil
types and geology, b) Phase II of the Remedial Investigation
defined the extent of contamination and gathered further
information on site conditions. Phase I RI soil investigation
activities included samples from two test borings (PTB-1 and
PTB-2) and sampling and analysis of composite surface soil
samples collected from each of the five potential source areas
shown on Figure 3 - Appendix B. Potential source areas were
identified based on review of plant process operations. Phase II
RI soil investigation activities included laboratory analysis of
selected soil samples taken from twelve test borings (PTB-3
through PTB-11, PTB-11A, PTB-12, and PTB-13). Test boring
locations are shown on Figure 3 - Appendix B. Based on the
analytical results from the test borings, the Former Pond Area
was identified as a sixth potential source area.
The following summarizes the investigation results for
these compounds in each soil area:
Remote Fill Area/Old Drum Storage Area: No chlorinated solvent
compounds of concern detected in any samples.
Degreaser Storage Tank/Courtyard Area: No chlorinated solvent
compounds of concern were detected in surface soils or subsurface
soils during the Phase I and Phase II remedial investigations,
Boring samples taken after the courtyard solvent spill cleanup
also indicated no chlorinated solvents in surface soils.
However, low concentrations of chlorinated solvents were detected
in deeper boring samples. The maximum levels detected were: 130
ppb of TCA and 190 ppb of TCE.
Pumphouse Area: Composite surface samples taken during the Phase
I investigation detected a maximum of 432 ppb of Trichloroethane
and 89 ppb of 1, i-dichloroethane. Boring samples taken in this
area during the Phase II investigation did not detect these
contaminants even in the surface sample (0-2 feet deep).
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15
Railroad Loading Dock: Surface soils in the vicinity of this
area have previously been removed, and the excavation has been
left open, but filled with aggregate stone. Approximately two
feet of soil remains above the bedrock surface in this area.
The Phase I RI composite soil samples were collected from
the bottom of the excavation. A Phase II RI test boring (PTB-11)
was also located within the excavation. Xylenes (total =5.1
ppm) were detected in the test boring soil sample, but were not
detected in the composite surface soil sample.
The site history would lead EPA to believe that the xylenes
in this soil are from a spill which occurred after the 1984
removal action. Because of the physical situation (a small open
pit) , EPA believes that the spill would have been confined to the
pit. Conseguently, the lateral extent of impacted soils in the
Railroad Dock Area is considered to be limited to a radius of
about one foot from boring PTB-11. Additionally, if the lateral
extent were somewhat greater, EPA's remedial decision would not
be significantly effected.
Xylenes are a common component of gasoline and are not very
toxic. The Resource Conservation Recovery Act ("RCRA") is the
federal law that regulates hazardous wastes. Xylenes are also a
commonly used solvent, and if used as a solvent and discarded are
considered a listed RCRA hazardous waste regardless of it's
relatively low toxicity and concentration. Xylenes are also a
listed hazardous waste pursuant to the Pennsylvania Solid Waste
Management Act. The PADER cleanup level for direct contact for
xylenes is 100,000 ppm. The PADER cleanup level for protection
of ground water is as follows: o-xylene 3 ppm, m-xylene 5 ppm,
and p-xylene 5 ppm. The m-xylene soil concentration was 0.75
ppm, which is well below the PADER cleanup level. EPA does not
have an analysis of the p-xylenes/o-xylene by isomer, but
published data on the major source of mixed xylenes indicates
that the o-xylene/p-xylene ratio is about 1:1. Based on a total
p+o xylene concentration of 4.3 ppm the estimated concentration
of o-xylene is therefore 2.15 ppm and the estimated concentration
of p-xylene is also 2.15 ppm, well below PADER cleanup levels.
Additionally, EPA's calculations based on mathematical modeling
estimate a much higher safe cleanup level (over 2,600 ppm total
xylenes) than the PADER cleanup level. Also, the ground water
action selected for Operable Unit One will collect any xylene
that leaches to the ground water and no xylene has been detected
in site ground water.
Former Pond Area: The Westinghouse Elevator Plant was
constructed on top of a pond which was filled in prior to
construction. About half of the pond is actually under the
building and other structures, and about half is under a grassy
area in front of the building. Subsurface soil samples from
borings PTB-4 and PTB-6 in the vicinity of the Former Pond Area
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16
had detectable levels of VOCs, primarily TCE, The Former Pond
Area is now a grassy landscaped area in front of the Westinghouse
Plant building. This is not an area that would have been used
for industrial activities and its purpose is aesthetic not
functional. There is no record that this area was ever used for
industrial purposes.
Although this area does not appear to be a spot where
surface contamination occurred, the ground water in this area is
the most contaminated. There are several possibilities that
could explain this fact:
1) Westinghouse suggested during the RI that the pond which
was filled in could have contained the contamination before the
Elevator Plant was built. EPA investigated this hypothesis but
could not find support for this assertion.
2) Solvent spills in the railroad loading dock and the
Pumphouse Area could have migrated downward through the porous
soils until bedrock was encountered and then flowed downhill
along the bedrock surface shown in Figure 3-14 of the RI. Once
solvent encountered the low area of the pond, it would then be
trapped and would slowly infiltrate the fractures in the bedrock.
EPA believes that this is the most likely scenario.
It is possible that the VOCs detected in subsurface soil
samples in the Former Pond Area may be indicative of contact of
the soil with highly contaminated ground water or soil gas from
the ground water, and not from soil contaminants leaching to
ground water from this area, especially given the relatively low
VOC concentrations (i.e., approximately 700 parts per billion
(ppb) maximum in the subsurface soil versus 30,000 ppb in the
ground water). At least one sampling event showed ground water
close to the level of the bottom of the pond borings (RI figure
3-16 showed a water level of 532 feet Mean Sea Level).
Another possibility is that the soil could have been
contaminated by leaks from the currently operating ground water
extraction system. Several times in the past, the pipe which
carries water from well PMW-1 to the plant air stripper leaked
and needed repair. The ground water from these leaks could have
caused the low level of contamination. Regardless of the cause,
EPA does not view this area as a source of contamination because
of the low concentrations.
Based on the concentrations found in soils during the RI,
EPA has calculated that all soils would pass the Toxicity
Characteristic Leaching Procedure which determines whether the
soils would be classified as a characteristic hazardous waste
based on the concentration of hazardous constituents. However,
the contaminated soils are considered to be listed wastes
pursuant regulations promulgated under the Pennsylvania Solid
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17
Waste Management Act because they contain constituents derived
from spent solvents. Soils containing TCE or TCA would be
classified as F001 listed waste, and soils containing xylene
would be classified as F003 listed waste (See, 25 PA CODE §
261.31).
The Remedial Investigation, the Risk Assessment and the
Feasibility Study reports are available in the administrative
record. The Risk Assessment report considers the toxicology of
the site contaminants, the exposure pathways to human and
ecological receptors and evaluates the threat to human health and
the environment. The Feasibility Study is a scoping study of
possible technologies that could be used to remediate the site.
VI. SUMMARY OF SITE RISKS
As part of the Remedial Investigation performed for the
Westinghouse Plant Site, a Risk Assessment ("RA") was conducted
to evaluate the potential impacts of the Site on human health and
the environment. In the RA, chemicals of potential concern were
identified for detailed evaluation based on the RI sampling
results. The Risk Assessment then evaluated the potential health
and environmental risks associated with exposure to these
chemicals for each media.
Potential risks to human health were identified by
calculating the risk level or hazard index for such chemicals.
Potential carcinogenic risks are identified by the risk level
(i.e. a 1.0 X 10~° risk level indicates one additional chance in
1,000,000 that an individual will develop cancer). EPA's
acceptable risk range for Superfund cleanups is between
1.0 x 10~4 to l.o x 10~6. If the risk exceeds 1.0 x 10~4 EPA
generally will take action to reduce the risk to within the
acceptable risk range. EPA's point of departure for cleanup
levels of carcinogens, once it has been decided that an action
will be taken is 1 x 10~6. The actual cleanup level can be
between 1.0 x 10~4 to 1.0 x 10~6 depending on site conditions.
The hazard index identifies the potential for individuals to
be adversely affected by chemicals that damage human organs
(poisons). 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 estimates the Reasonable Maximum
Exposure (RME) for possible receptors. This concept produces a
very conservative and protective estimate of risk. The risk
associated with the site soils are summarized below:
The only VOC contaminated soils are adjacent to the
Westinghouse Plant Building on private property and any exposure
of residents or children to these soils would be of very limited
duration, even if trespassing occurred. Soils have been removed
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18
from the Pumphouse Area and •the railroad loading dock where
concentrations of contaminants were high. These areas were
sampled in Phase II and no contamination in surface soils was
detected. The contaminated soil in the Former Pond and Courtyard
Areas is deep and poses no significant risk of direct contact.
The risk of inhalation of contaminants by maintenance workers was
not evaluated in the risk assessment as a reasonable scenario
because of the depth of contamination, the low concentrations,
and the fact that these areas are below open space where
dispersion of contaminants will occur. The Courtyard Area is in
an area not accessible to the public and contamination is also
well below the surface. None of these areas are considered by
EPA to present a significant direct contact risk to the public.
Risks are presented in Table 8-8 of the Risk Assessment and
can be summarized as follows: 1) The only exposure to the Plant
soils is to Plant maintenance workers. The exposure scenario is
based on incidental ingestion and dermal contact with soils by
maintenance workers as shown in Table 8-2 of the Risk Assessment
Report. 2) The risk is extremely low to these workers for both
systemic effects (poisons) and for cancer risk. For site related
chemicals, the hazard index for these workers is virtually 0 (no
effect) and the estimated cancer risk is 1.5 x 10~7 (1.5 cancers
for ten million people exposed) as shown in table 8-8 of the Risk
Assessment Report. EPA's Health based cleanup levels are also
compared to the maximum soil concentrations found in each area as
shown in Table 1-5 of the Final Feasibility Study summarized
below:
COMPARISON OF HUMAN HEALTH BASED LEVELS
WITH DETECTED LEVELS IN SURFACE SOILS
SOIL AREAS
Railroad
Loading Dock
Pumphouse Area
Courtyard Area
CONTAMINANTS
Xylenes
1 , 1-DCA
1,1,1-TCA
1,2,-DCA
1,1,1-TCA
1,1,2-TCA
1,2-DCE
TCE
HEALTH BASED (c>
CLEANUP LEVELS
(ug/kg)
1,000,000,000
1,000,000,000
931,000,000
31,000
931,000,000
50,000
10,000,000
260,000
MAXIMUM(d>
CONC.
DETECTED
(ug/kg)
5,100
89
432
2
130
2
8
190
NOTES: (a) Surface soil is defined as soil at less than 24 inches
depth
(b) Contaminants that were found in each area at significant
concentration levels.
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19
(c) From ReTeC Risk Assessment, 1991.
(d) From RI report, 1991 and courtyard investigation, 1992
The Pennsylvania Department of Environmental Resources has also
published cleanup levels based on direct contact risks that are
given below:
PADER CLEANUP STANDARDS FOR CONTAMINATED SOILS
DECEMBER 1993
SOIL AREAS
Railroad
Loading Dock
Pumphouse Area
Courtyard Area
CONTAMINANTS
Xylenes
1,1-DCA
1,1,1-TCA
1,2-DCA
1,1,1-TCA
1,1,2-TCA
1,2-DCE
TCE
HEALTH BASED
CLEANUP LEVELS
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20
of a "To Be Considered (TBCs) •• standard for the Site. The soil
cleanup levels in this document were produced using a math model
that is similar to the Summers.Model to estimate the leaching of
contaminants from soils to ground water. The published FADER
cleanup levels based on the Crest Model and the EPA cleanup
levels based on the Summers Model are compared to actual soil
concentrations in the following tables:
FEASIBILITY STUDY LEACHING RESULTS FROM THE SUMMERS MODEL
SOIL AREAS
Railroad
Loading Dock
Pumphouse Area
Courtyard Area
CONTAMINANTS
Xylenes
1,1-DCA
1,1, 1-TCA
1,2-DCA
1,1,1-TCA
1,1,2-TCA
1,2-DCE
TCE
SOIL CLEANUP
LEVELS
PROTECTIVE OF
GROUNDWATER
MCLS
(ug/kg)
2,653,200
No MCL
1,794
28
12,282
113
1,386
255
MAXIMUM
CONG.
DETECTED
(ug/kg)
5,100
89
432
2
130
2
8
190
PADER CLEANUP STANDARDS FOR CONTAMINATED SOILS
COMPARED TO ACTUAL SITE CONCENTRATIONS
SOIL AREAS
Railroad
Loading Dock
Pumphouse Area
Courtyard Area
CONTAMINANTS
o-xylene
m-xylene
p-xylene
1 , 1-DCA
1,1, 1-TCA
1,2-DCA
1,1, 1-TCA
1,1,2-TCA
1 , 2-DCE
TCE
SOIL CLEANUP
LEVELS
PROTECTIVE OF
GROUNDWATER
Level 2(a>
(ug/kg)
3,000
5,000
5,000
500
1,000
300
1,000
800
600
2,000
MAXIMUM
CONG.
DETECTED
(ug/kg)
2,150
750
2,150
89
432
2
130
2
8
190
Notes: (a) Levels for spills more than one year old.
(b) Estimated values from total xylene analysis.
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21
It should be noted that for the xylenes, both the Summers Model
and the FADER's Crest leaching model predict some leaching to
ground water from the Railroad Loading Dock. However, xylenes
have not actually been detected in site ground water samples.
EPA considers actual ground water data to be more reliable than
hypothetical math modeling results. Based on the results of both
leaching models and the actual ground water data, EPA does not
believe that the railroad loading dock is significantly
contaminating the ground water at the site.
Ecological Impacts
EPA does not expect any significant impact on terrestrial or
aquatic life from Site soils. The Site is an industrial property
surrounded by highly developed residential, commercial and
industrial areas. The soil areas are adjacent to or inside the
operating elevator plant. No known populations of rare or
endangered plant or animal species or significant biological
communities are present within or in close proximity to the Plant
boundaries.
The Superfund process requires that the alternative chosen
to clean up a hazardous waste site meet two threshold criteria:
protect human health and the environment, and meet the
requirements of environmental regulations (Applicable or Relevant
and Appropriate Requirements—"ARARs"). EPA's primary balancing
criteria are: long term effectiveness and permanence, short term
effectiveness, reduction of volume, toxicity, or mobility of the
contaminants, cost effectiveness, and implementability. EPA's
modifying criteria are State and community acceptance.
The Feasibility Study reviewed a variety of technologies to
see if they were applicable to the contamination at the Site.
The technologies determined to be most applicable to these
materials were further developed into remedial alternatives.
These alternatives are presented and discussed below. Many other
technologies were reviewed and screened out. This process is
fully detailed in the Feasibility Study which can be found in the
administrative record located in the Adams County Public Library
at 59 East High Street, Gettysburg PA.
All costs and implementation time-frames specified below are
scoping estimates based on best 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.
The process options remaining from the screening process are
no action, a low permeability cover, and off-site disposal. Due
to the small number of feasible and effective process options,
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22
there are only two decisions to be made for each medium: whether
or not to take any further action; and, if additional action is
taken, whether to cover or to excavate and dispose of off site.
These choices are discussed for each medium in the following
sections.
As required by the ROD for Operable unit One (ground water),
EPA will review the Site every five years to ensure continued
protection of human health and the environment.
Soil Area 1 - Railroad Dock Area Surface Soils
This medium consists of the soils remaining at the bottom of
the excavation in the Railroad Dock Area. The only COI for this
medium are xylenes (total), which were detected at levels nearly
five orders of magnitude below the health based cleanup level
(see page 18 and 19 above). The Feasibility Study evaluated the
potential of rainfall to leach contaminants from soil and to
transport the contaminants downward to contaminate ground water.
A mathematical model called the Summers Model was used for this
evaluation. From the results of the Summers Model, flushing of
xylenes from this medium might result in contaminant transfer to
ground water. Therefore, the remedial action objective for this
media is to reduce the potential for leaching effects. Leaching
calculations based on the Summers model indicate that xylene
concentrations could be as high as 2,600 ppm without
contaminating ground water above the MCLs allowed by the SDWA.
The PADER leaching model would indicate a level of about 10-13
ppm of total xylenes as a safe level. Regardless of modeling, no
xylene has actually been detected in ground water although
several wells monitor ground water associated with this area.
This strongly indicates that the level of xylenes at the loading
dock is not degrading ground water and analysis of the actual
conditions is much more reliable than modeling predictions of
ground water conditions.
Although soil contaminated with spent xylenes is considered
a hazardous waste, a low permeability cover as required by the
Pennsylvania Solid Waste Management Act is not considered
appropriate for this medium due to its limited areal extent. The
alternatives considered for this media are no action and
excavation with off-site disposal.
Alternative l - No Additional Action
Under this alternative, no additional action would be taken
to reduce possible leaching effects from soil to ground water.
Xylene concentrations in soil would naturally attenuate due to
biological activity and flushing of the xylenes by infiltrating
rain water. As mentioned previously, a ROD has been issued for
ground water remediation. Thus, under the no additional action
alternative, xylenes which are currently in Railroad Dock Area
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23
surface soil would ultimately be remediated by the ground water
extraction and treatment system already being designed.
Alternative 2 - Excavation with Off-Site Disposal
Under the excavation/disposal alternative, a small volume of
soil near boring PTB-11 would be removed to the bedrock surface
and taken to an off-site disposal facility. Transport and
disposal would be executed in accordance with local, state, and
federal regulations. The excavated area would be backfilled with
clean soil. The costs of Alternative 1 and 2 are compared below:
No Action
Excavation
Time to
Implement
(Months)
—
1.5
Capital
Cost $
— —
4,397
Annual
O&M $
—
50
Total
Present
Worth $
—
5,261
This medium consists of surficial soils in the vicinity of
the pumphouse which contained detectable levels of VOCs and
PCB-1254 during the Phase I RI. The areal extent of this medium
is based on the analytical results of a composite sample from
five sampling locations (see Figure 3 - Appendix B). Detected
levels of VOC contaminants in the composite sample were at least
three orders of magnitude less than the health-based levels
presented in the risk assessment (see page 18 and 19 above).
From the results of the Summers Model, flushing of VOCs from soil
may result in transfer of VOCs to ground water. Thus, the
remedial objective for Pumphouse Area surface soil is to reduce
the potential for leaching effects (i.e., reduced infiltration to
ground water). It should be noted that a shallow boring in this
area did not detect contamination during the Phase II
investigation.
The Pumphouse Area is still used by the facility and is
subject to the need for access to perform maintenance work and
other uses. The area is also very irregular in shape and is
adjacent to plant structures such as a water tank and the
pumphouse building. A low permeability cap would be impractical
in this area and was screened out. The remedial alternatives
presented for this medium are no action, an asphalt cover, and
excavation with off-site disposal.
Alternative 1 - No Additional Action
Under the no action alternative, VOCs in the Pumphouse Area
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24
would be leached from the soil by surface water infiltration and
thereby transfer to ground water. Contaminants transferred from
the soil to ground water would be captured and treated by the
ground water remediation system. Contaminants in Pumphouse Area
soil would thus ultimately be remediated by ground water
extraction and treatment.
Alternative 2 - Asphalt Cover
For this alternative, an asphalt cover would be constructed
over the grassy area in the vicinity of the pumphouse. The
asphalt cover would decrease infiltration such that transfer of
Contaminants in surface soils to ground water would be reduced.
Alternative 3 - Excavation with Off-Site Disposal
Under the excavation/disposal alternative, a small volume of
soil would be removed and taken to an off-site disposal facility.
Transport and disposal would be executed in accordance with
local, state, and federal regulations. The excavated area would
be backfilled with clean soil.
The costs of Alternatives 1, 2 and 3 are compared below:
1-No Action
2 -Asphalt
Cover
3 -Excavation
Time to
Implement
(Months)
— '
3
2
Capital
Cost $
— —
9,742
221,329
Annual
O&M $
— —
600
400
Total
Present
Worth $
—
20,117
228,245
Soil Areas 3 and 4 - courtyard Area soils
Soil Areas 3 and 4 consist of the surface and subsurface
soils in the Courtyard Area containing VOCs above detectable
limits. The primary COI is 1,1,1-TCA which overflowed from the
solvent storage tank while it was being filled in May 1991. As
previously noted, maximum detected levels of VOCs in the
Courtyard Area soils do not exceed health-based cleanup levels
(see pages 18 and 19 above). Thus, Courtyard Area soils are
addressed in this study due to concern for potential leaching
effects which could potentially degrade ground water.
As discussed in Section 2.4 of the Feasibility Study, the
results of the Summers Model indicate that Courtyard Area soils
do not constitute a significant threat of contamination to ground
water. The concentration of contaminants in ground water due to
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25
contaminants in soils would not exceed EPA's risk based levels
based on the the Summers Model. The Summers Model is a highly
conservative mathematical model which estimates the leaching of
contaminants from soils and the resulting ground water
contamination levels. The Summers model does not predict risks
exceeding a 10~4 risk of cancer or a hazard index exceeding 1
(systemic effects). Concentrations are also below FADER soil
cleanup standards. Consequently, Courtyard Area soils are not
considered to pose significant risks to human health or the
environment. Therefore, the remedial action objective for
Courtyard Area surface soils is satisfied by existing conditions,
and no action is needed for the Courtyard Area soils.
Concentrations of contaminants in Courtyard Area soils will
gradually attenuate due primarily to leaching from soils to
ground water and due to bioactivity. Contaminants in soils will
ultimately be remediated by the treatment of ground water. The
nature and extent of contaminants in soil and subsequent need for
soil remediation would be reassessed if active ground water
treatment is terminated in the future. No additional action
needs to be taken and no additional costs need to be incurred.
Subsurface Soils
This medium consists of subsurface soils in the vicinity of
the Former Pond Area which contain VOCs above detectable limits.
According to the risk assessment, there is no plausible pathway
of direct exposure to this medium. These soils are addressed in
this study at the request of the EPA out of concern for potential
leaching effects which could potentially degrade ground water.
From the results of the Summers Model, flushing of VOCs from this
medium might result in leaching of contaminants to ground water.
Thus, the remedial objective for this area would be to reduce the
slight potential for leaching effects (i.e., reduce infiltration
to the ground water).
Excavation and disposal off-site is not considered a
reasonable alternative for the subsurface soils in the Former
Pond Area. Much of the former pond is under the elevator plant
building (Figure 5 - Appendix B) such that only partial
excavation would be possible. Excavation would be less
protective of workers during implementation than alternatives
which would not create a possibility of direct contact with
impacted soils. In addition, EPA does not consider these soils
to be a significant source of contamination. Remedial
alternatives considered appropriate for Former Pond Area
subsurface soils consist of no action and a low permeability
cover system.
Alternative l - No Additional Action
Under the no action alternative, conditions would be
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26
maintained to reduce possible leaching effects from soil to
ground water. Contaminant concentrations in soil would naturally
attenuate due to anaerobic degradation and flushing of the
contaminants by both infiltrating surface water and the
fluctuating ground water table. Any contaminants transferred
from the soil to ground water would likely be captured and
treated by the ground water remediation system. Thus, under the
no action alternative, contaminants which are currently in.the
Former Pond Area subsurface soils would be remediated indirectly
by the ground water treatment system.
Alternative 2 - Low Permeability Cover System
Approximately 75 percent of the Former Pond Area is not
covered by the plant building or the parking lot. Under this
alternative, the "uncovered" portion of the Former Pond Area
would be covered with a low permeability cover.
The cover system would consist of a six inch soil base
layer, a 40 mil geosynthetic barrier layer (like a swimming pool
liner), a geotextile drainage layer and an eighteen inch thick
soil cover that would be seeded with grass.
The costs of the alternatives are given below:
No Action
Low
Permeab i 1 i ty
Cover
Time to
Implement
(Months)
—
. 6
Capital
Cost $
— —
68,558
Annual
O&M $
—
800
Total
Present
Worth $
— —
82,391
A low permeability cover system would reduce infiltration
such that transfer of contaminants in subsurface soils to ground
water would be minimized. Contaminant levels in the subsurface
soils would attenuate very gradually due to natural physical,
biological, and chemical processes. Contaminants leaching into
the ground water would be collected and treated by the ground
water extraction and treatment system.
VIII,
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
In this section the remediation alternatives are compared to
each other using the nine criteria that EPA uses in the decision
making process.
Protection of Human Health and the Environment: Since there
is no significant contact risk from the contaminants in the soil
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27
areas, and since the Remedial Action selected for ground water
will address any risk from leaching, all of the Remedial Actions
listed for each soil area, including No Additional Action, would
be sufficiently protective. •'
Compliance with ARARS: The Alternatives that involve
excavation and off-site disposal of contaminated soil would
comply with all ARARs, including the Pennsylvania Solid Waste
Management Act hazardous waste closure regulations (See, 25 PA
CODE §§ 264.110-264.119 and 264.300-264.316) since all
contaminants would be removed from the site. The alternative
that involves a low permeability cover would comply with the
relevant and appropriate portion of the Pennsylvania Solid Waste
Management Act closure regulations. The no action alternative
and the asphalt cover would not comply with the Pennsylvania
Solid Waste Management Act closure regulations.
Long Term Effectiveness and Permanence: The Alternatives
that involve excavation and off-site disposal of contaminated
soil would have the highest long term effectiveness and
permanence since contaminants would be removed from the Site and
could pose no risk at all. The No Additional Action alternative
would have the next highest rating because rainwater will leach
contaminants into the ground water which will be collected and
treated, effecting the second fastest method of removal of
contaminants. The contaminants would be captured on activated
carbon and the contaminants ultimately destroyed when the carbon
is disposed. The asphalt cover and low permeability cover are
rated lowest in this category since contaminants would leave the
soils at a slower rate.
Reduction of Toxicity Mobility and Volume: The Alternatives
that involve excavation and off-site disposal of contaminated
soil would have the highest rating since contaminants would be
removed from the site and treated so that they could pose no risk
at all. The No Additional Action would have the next highest
rating because rainwater will leach contaminants into the ground
water which will be collected and treated. The contaminants
would be captured on activated carbon and the contaminants
ultimately destroyed when the carbon is disposed. The asphalt
cover and low permeability cover are rated lowest in this
category since contaminants would leave the soils at a slower
rate and a higher percentage of contaminants would escape the
soil via soil gas.
Short Term Effectiveness: The Alternatives that involve
excavation and off-site disposal of contaminated soil would have
the highest rating since contaminants would be removed from the
site in a very short period of time. The No Additional Action
would have the next highest rating because rainwater will leach
contaminants into the ground water which will be collected and
treated. The asphalt cover and low permeability cover are rated
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28
lowest in this category since contaminants would leave the soils
at a slower rate.
Implementability: The No Additional Action is obviously the
easiest to implement. The excavation option for the railroad
loading dock only involves excavation of two cubic yards of
surface soil and would be very easy to implement. Excavation of
subsurface soils to pristine levels at the other soil areas would
be extremely difficult and could pose a risk to existing building
structures. Installation of an asphalt cover on the Pumphouse
Area soils would be very easy. Installation of a low
permeability cover in the Former Pond Area could be done, but
would be more difficult than usual because of the need to
integrate with existing structures. Installation of a low
permeability cover in the Courtyard Area was rejected during
screening because this is in an area inside the plant structure
and is still in use by the Plant. Integrating a low permeability
cover into the building structure would be difficult and might
need to be periodically disturbed by the need for maintenance of
drains and other utilities
Cost: The costs of the alternatives shown above are based
on capital costs and operation and maintenance for 30 years. The
costs are given in the Description of Alternatives section above
and in Table 1 - Appendix A. All of the alternatives evaluated
except the No Action alternative involve significant costs for
little or no incremental environmental protection.
State Acceptance: The Commonwealth of Pennsylvania concurs
with the Preferred Alternative.
Community Acceptance: No comments were made in opposition
to the preferred alternative or arguments made for a different
alternative at the public meeting held at the Cumberland Township
Municipal Building on February 23. EPA did not receive any
comments on the Proposed Plan during the comment period.
Soil Area l - Railroad Dock Area surface soils
Alternative Number 1 - No Additional Action: There is no
significant contact risk from surface soils. The contaminant
xylene is a common component of gasoline and is biodegradable.
Xylenes have relatively low toxicity compared to the chlorinated
solvents. PADER has published cleanup levels based on the risk
of contact with contaminated soils at 100 ppm for xylenes in soil
and EPA's estimate of a safe level for xylenes is even higher.
Xylenes have not been detected in ground water at the
Westinghouse Plant Site and this indicates that leaching of
xylenes currently present at about 5 ppm in the site soil is not
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29
significantly affecting site ground water. This is confirmed
(within model uncertainty) by ground water leaching models.
Although xylenes are relatively non-toxic, xylenes that have been
used as solvents and discarded are considered a listed hazardous
waste (F003) pursuant to Pennsylvania Solid Waste Management Act
regulations (See 25 PA CODE § 261.31).
The volume of contaminated soil is very small (2 cubic
yards), and the total volume of xylene present in the soils is
very small (about 10 cubic centimeters of this gasoline
component). Any xylene which does leach into ground water will
be captured and treated in the pump and treatment system
currently being designed. No additional action is needed to be
protective of human health and the environment. The selected
remedy requires No Additional Action for soils contaminated with
very low levels of listed RCRA hazardous waste. Therefore action
specific ARARs do not apply, and the only ARARS for the Site
soils are the Pennsylvania Solid Waste Management Act hazardous
waste closure regulations which require a low permeability cap
(See, 25 PA CODE §§ 264.110-264.119 and 264.300-264.316). The
soils are contaminated with listed waste solvent constituents
which makes them subject to the capping requirements. EPA is
waiving this ARAR on the basis of "Greater Risk to Human Health
and the Environment" and "Equivalent Standard of Performance"
waivers. Since the ground water under the contaminated areas
will be collected and the contaminants ultimately destroyed,
leaching of the contaminants is desirable. Capping these areas
would reduce the natural leaching and delay the cleanup and
destruction of the soil contaminants.. Accordingly, the "Greater
Risk to Human Health and the Environment" waiver is an
appropriate waiver. By leaving the contaminants in place,
without a cap, the contaminants will be collected effectively by
the pump and treat system. Accordingly, the "Equivalent Standard
of Performance" waiver is also appropriate.
Soil Area 2 - Pumphouse Area Soils, Soil Areas 3 and 4 -
Courtyard Surface and Subsurface Soils and soil Area 5 -
Former Pond
Alternative Number l - No Additional Action: In these
areas, surface soil contamination was not present during the most
recent sampling events, or was present at very low levels that do
not pose a significant contact risk to human health and the
environment. Subsurface soils are also contaminated at
relatively low levels and only pose a slight potential risk to
ground water at the site. The Record of Decision for Operable
Unit One (ground water) selected pump and treatment of ground
water as the Remedial Action. EPA believes that large amounts of
solvent have migrated down into the bedrock and are now the
primary source of contamination. The highest levels of total
chlorinated solvent in subsurface soils is about 0.6 ppm while
ground water has shown solvent contamination as high as 80 ppm.
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30
The pump and treat system is in the design phase and will address
the minor incremental risk to ground water from leaching of these
soils.
CERCLA requires EPA to conduct its remedial actions in
compliance with all environmental laws, identified before the
Record of Decision, if they are applicable or if they are
relevant and appropriate for the situation. These requirements
are commonly referred to as ARARs. The selected remedy requires
No Additional Action for soils contaminated with very low levels
of listed RCRA hazardous waste. Therefore action specific ARARs
do not apply, and the only ARARS for the Site soils are the
Pennsylvania Solid Waste Management Act hazardous waste closure
regulations which require a low permeability cap. (See, 25 PA
CODE §§ 264.110-264.119 and 264.300-264.316). The soils are
contaminated with listed waste solvent constituents which makes
them subject to the capping requirements. EPA is waiving this
ARAR on the basis of "Greater Risk to Human Health and the
Environment" and "Equivalent Standard of Performance" waivers.
Since the ground water under the contaminated areas will be
collected and the contaminants ultimately destroyed, leaching of
the contaminants is desirable. Capping these areas would reduce
the natural leaching and delay the cleanup and destruction of the
soil contaminants.
In summary, the preferred alternative is believed to provide
the best balance of trade-offs among alternatives with respect to
the criteria used to evaluate remedies. Based on the information
available at this time, therefore, EPA believes that the
preferred alternative will protect human health and the
environment, will comply with ARARs or justify a waiver, would be
cost effective, and will use permanent solutions to the maximum
extent practicable. The preferred alternative will not directly
satisfy the preference for treatment as a principle element, but
indirectly the contaminants will leach to the ground water, be
collected and treated by the pump and treat system or will
degrade due to bioactivity. No additional costs would be
incurred.
X. STATUTORY DETERMINATIONS
Under its legal authorities, EPA'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, 42 U.S.C.§ 9621, 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-effective and utilize treatment technologies or
resource recovery technologies to the maximum extent practicable.
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31
Finally, the statute includes a preference for remedies that
permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes.
Protection of Human Health and the Environment
The selected remedy will be protective of human health and
the environment because the risks from these areas are below
EPA's trigger levels for direct contact and because any leaching
of contaminants to ground water will be addressed by the pump and
treat system selected by the ROD for Operable Unit One.
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.
Compliance with ARARs
The Record of Decision for Operable Unit One (June 30, 1992)
addressed all the ARARs concerning the ground water remedy at the
Site. Among the ARARs addressed in the ROD for Operable Unit One
was the Pennsylvania ARAR for ground water which requires that
all ground water be remediated to "background" quality as
specified by 25 PA CODE Section 264.90-264.100 and in particular
25 PA CODE Section 264.97(i), (j), and 264.100(a)(6) and (9).
This ARAR was waived on the basis of greater risk to human health
and the environment and the technical impracticability waivers.
Reference can be made to the ROD for Operable Unit One for a full
discussion of the ARARs discussed therein.
The selected remedy requires no additional action for soils
contaminated with very low levels of listed RCRA hazardous waste.
Therefore action specific ARARs do not apply, and the only ARARS
for the Site soils are the Pennsylvania Solid Waste Management
Act hazardous waste closure regulations which require a low
permeability cap. (See, 25 PA CODE §§ 264.110-264.119 and
264.300-264.316). Because the soils are contaminated with listed
waste constituents, these ARARs are applicable. EPA has waived
these ARARs on the basis of "Greater Risk to Human Health and the
Environment" since capping would retard the leaching of
contaminants to the ground water extraction and treatment system,
and on the basis of "Equivalent Standard of Performance" since
collection and treatment of the leached contaminants by the
ground water extraction and treatment system is a more effective
remedy than immobilizing them under a cap system.
Cost Effectiveness
No additional cost would be incurred by the selected remedy.
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32
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Practicable
Contaminant concentrations do not justify treatment.
Contaminants leaching into the ground water will be captured by
the pump and treat system selected by the ROD for the first
Operable Unit. The contaminants will be removed by the air
stripping unit, captured by a carbon adsorption air control unit
and the contaminants will ultimately be destroyed when the carbon
is regenerated.
XI. EXPLANATION OF SIGNIFICANT CHANGES
There are no significant changes from the Proposed Plan.
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Appendix A
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TABLE 1
SUMMARY OF COSTS
Alternative
Time to
Implement^
(Months)
Capital
Cost
($)
Annual
J$L
Total Pieseut
Worth
($)
Medium! -Railroad Dock Area Surface Soils
No Action
Excavation with Off-Site Disposal
Medium 2 - Pumphouse Area Surface Soils
No Action
Asphalt Cover
Excavation with Off-Site Disposal
Medium 3 - Courtyard Area Subsurfafy in months for implementing drsig" activities an<1 construction activities for each individual
SOil media. ]fa»&*fr. it ^ ?5P1"**I *t«tt Q* »«1 media will he reniftdiated in eonjtmctMTi »ith eaeh nrhyr and that the duration for
remediating the conit'iBPd ntcdii> units will be less than the ?ltn of indivdual tnrdia
Reported value represents annual operation and maintenance costs; costs for monitoring and five-year reviews are included in the
costs for Operable Unit One.
•-• indicates not applicable.
rU7-J75/93
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Appendix B
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FIGURE 1-1
SITE LOCATION MAP
ELEVATOR PLANT SITE SUPPLEMENTAL PS
CUMBERLAND TOWNSHIP. ADAMS COUNTY. PENNSYLVANIA
PREPARED FOR
SCALE (MILES)
WESTINGHOUSE ELECTRIC CORPORATION
PITTSBURGH, PENNSYLVANIA
U.S.G.S. TOPOGRAPHIC MAP
GETTYSBURG QUADRANGLE
SCALE: 1:24.000-PHOTOREV»SED 1973
Rml C Rtao Associates. Inc.
CONSULTANTS
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WESTINGHOUSE
ELEVATOR PLANT
Gettysburg Battlefield
National Park Property
WUS SAUPUO 8CTVICCN 1981- I9M
«*US SAMPUO BtrvntCN UAV-JUNC 1104
COUI'OUNO NOT DtltCttO
MA->U AVtNUC
CCOAR AvtNUt
ARCnS SCNVICCO BY GCTTTSBURC
UUMOPAi AUIMORITY PUMJC WATCH
SUPMV UHtS
RtfCilCKCt;
TAKCN rNOU MAP PRCPARCO 6V UCTCAI/
COOV. MAY 10. 18(7, SCAt£: f-400'.
o 400 MO rett
FIGURE 1-10
RESIDENTIAL WELL SAMPLING
PU8UC WAttR
SUPPLY UNC
MAY-JUNE 1984
•CS1MGHDUSC PLAN I SITE NI/TS
CUUMRLANO KWNSMP. AOAMS COUMTY. PCNNSYIVANIA
WESTINCHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
Riul C Rliio AnoetaU.. IDO
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Westinghouse Elevator Plant Superfund Site
Investigated Soil Areas
WESTINGHOUSE ELEVATOR PLANT
OLD WASTE DRUM
STORAGE AREA
Map ccurto ,y ol Paul C. RizjoAssociales. Inc.
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f Figure 4 -;:•-'
s\J( \\v\\ v V •;
/?5< '. V \ >-.\ \ .., .' !;^.f
ii>xCT« "pv.JJr^
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-EXTENT (T
FORMER FUND
ARE.\ Or FORMER POND
*
ARf;< TO BE CAPPED
UNCER ALTERNATIVE 2
I. CXIVINC COilWIIONS At.O POND LOCATION
TAKIH FROM PA11 C. K-IIO ASSOCIAKS
OfM-ONC HOS. .V-375-Bia? AND 87-J7i-BIO«
OATIO: 6-12-OJ ECAlt: T - JOO1
2. TOP KRM-HIC AND UII1I.V M/P. COUlUM FAOu
J. f. Rift SURvr.. -CAlt: C » IOO'.
OAfiO: JAM. 26. 1«6e
SCALE
too rtn
FI3UR: 4-1
CAF'PPEO AREA
ALTERNATIVE 2
FORMER fONO AREA
•irVAFUN PlAi:T SIIJ SUPPlCUMIM IS
ClUBCR-AND TOWNSH,'. ATluS COUKTV.
PiiCPAftCD f(M
WESTNCHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
FVii C Run Attoculu. lac.
censuiivira
£
Ui
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APPENDIX C
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Appendix C
RESPONSIVENESS SUMMARY
WESTINGHOUSE ELEVATOR COMPANY PLANT SITE
OPERABLE UNIT 2 (Soils)
ADAMS COUNTY, PENNSYLVANIA
This community relations responsiveness summary is divided into
the following sections:
SECTION I: Overview : This section discusses EPA's selected
remedy for the Westinghouse Elevator Company Plant Site Soils.
SECTION II: Background: This section provides a brief history
of community interest and concerns raised during remedial
planning at the Westinghouse Elevator Company Plant Site.
SECTION III: Summary of Commentor's Manor Issues and Concerns;
This section provides a summary of commentor's 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) .
On February 3, 1995, EPA announced the public comment period
and published its preferred alternative for soils at the
Westinghouse Elevator Company Plant Site, located in Adams
County , Pennsylvania .
When EPA issued its Proposed Plan on February 3, 1995, it
also opened a public comment period that was due to end on March
6, 1995. EPA held a public meeting at the Cumberland Township
Municipal Building on February 23, 1995 to present the Remedial
Alternatives for the Westinghouse Elevator Plant soils and to
take public comments on these alternatives. During this comment
period, EPA only received written comments from the Commonwealth
of Pennsylvania. EPA did not receive comments or questions about
the Preferred Alternative during the public meeting.
II. BACKGROUND
In 1983, problems were discovered at three geographic
locations in the Gettysburg area that included the Hunterstown
Road, the Westinghouse Elevator Co. Plant, and the Shrivers
Corner Sites. The community became very concerned and formed a
citizens group "Good Neighbors Against Toxic Substance (GNATs)"
that vigorously lobbied EPA, the PADER and local congressmen for
the solution to the environmental problems present at the
Gettysburg sites. This group was knowledgeable regarding site
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histories and gave EPA substantial input during the past years.
The three sites were placed on the National Priorities List
(NPL) and removal actions were performed that addressed the
immediate site threats. Surface waste removal and alternative
water supplies helped reduce the risk from these sites. The
GNATs continued to comment and voice their concerns throughout
this process. The GNATs had their own newsletter and were very
active. At the Westinghouse Plant Elevator Corporation Plant
Site, public water lines were extended to all areas with VOC
contamination and Westinghouse Electric Corporation offered
connection to these lines at their expense. Reportedly,
Westinghouse also entered into legal settlements with some
residents.
A Record of Decision for Operable Unit 1 was issued on June
30, 1992. Consent Decree negotiations did not yield an agreement
and EPA issued a Unilateral Administrative Order (UAO) to both
Westinghouse Electric and Schindler Elevator on 12/29/92. The
UAO was modified in February 1993, and Westinghouse agreed to
comply with the UAO. The Project is currently in the design
Phase and pilot operation of the extraction wells should begin
during the summer of 1995.
Perhaps as a result of the reduction of risk, settlements,
more frequent communication with EPA, and the very long time
frame inherent in the remedial Superfund process, general
interest in the sites has declined, although the leaders of the
citizens group are still very interested in the progress at these
sites. The three most active members of the GNATs have been Mr.
Merle Hankey, Mrs. Mary Kennedy and Mr. Donald Waddel. EPA
appreciates the assistance given by these individuals in
identifying problems at the Gettysburg Sites. Press coverage of
the Site was extensive in the early to mid-1980s, but has
declined in the last several years.
EPA has had substantial interaction with the public
throughout the site history as shown by the public meetings on
April 2, 1984, April 22, 1985 and October 23, 1986. These
meetings discussed all three Gettysburg Superfund Sites and
covered both Remedial and Removal Actions. A tour of the Plant
was conducted by EPA to inform residents and Congressman
Goodling's office about the Site in December 1986.
Additional public meetings were conducted specific to the
Remedial Investigation/Feasibility Study (RI/FS):
a) April 5, 1988 - Meeting on RI/FS Work Plans.
b) March 8, 1990 - A pre-public meeting to discuss the
sites with most active members of GNATs.
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c) May 31, 1990 - Meeting on Phase I Remedial
Investigation/Phase II Sampling and Analysis and Work Plans.
d) September 1990 - Public Affairs meetings with GNATs
members residents and local officials.
e) December 1990 - Meetings with GNATs members and local
officials.
f) August 28, 1991 - Meeting to discuss Phase II Remedial
Investigation results with residents and GNATs members.
g) May 6, 1992 - Public meeting to discuss Feasibility
Study and the Proposed Plan for operable unit 1.
h) February 23, 1995 - Public meeting to discuss the
Feasibility Study and the Proposed Plan for operable unit 2
(Site Soils). Those in attendance at the meeting included
local area residents, a member of the GNATs citizens group,
representatives from the Pennsylvania Department of
Environmental Resources, and the Adams County Commissioner.
EPA's Office of Public Affairs has periodically issued Fact
Sheets for the Site over the past years to update residents and
local officials. These have been well received.
A notice of availability of the Proposed Plan for Operable
Unit 2 (Soils) was published in the Gettysburg Times February 3,
1995. This document, the transcript of the public meeting, the
RI/FS, the community relations plan and other supporting
documentation for the Proposed Plan was made available at that
time in the Administrative Record file located in the Adams
County Public Library.
III. SUMMARY OF COMMENTORS' MAJOR ISSUES AND CONCERNS
A) Written comments submitted during the comment period -
None received.
B) Summary of comments made during the public meeting - No
comments or questions from the public during the meeting.
C) Written comments submitted by the Commonwealth of
Pennsylvania during the public comment period- None
EPA has been working with the PADER throughout the
development of the Proposed Plan and the Record of Decision
to make sure that EPA complies with Pennsylvania's laws and
regulations.
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