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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                                 8

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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                                10

      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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                                11

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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                                12

      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.
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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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