United SMM
Environmental Protection
Agency
Office of
EfnefQeo
Remedwl ResponM
EPA/ROO/R03-S9/068
Much 1969
&EPA
Superfund
Record of Decision
Hebelka Auto Salvage Yard, PA
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50272-101
REPORT DOCUMENTATION i. REPORT Ha a.
PAGE EPA/ROD/R03-89/069 P
4. THeindSUtWt
SUPERFUND RECORD OF DECISION
Hebelka Auto Salvage Yard, PA
First Remedial Action
7. AuKuftt)
». Performing Orgclnlailon Item end Addree*
12. Spoiworing Organization Meme end AddreM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
«. nerlpHnfe Aceeeelon Mo.
B90 107574/AS
& Report De*
03/31/89
•.
•. Pertonnlna Orgenlaion Rept Me.
Mi PraiecVTeek/WefkUnMNe.
11. ConlracKC) or OnrttQ) No.
(C)
(0)
800/000
14.
18. Supplementary NoM
le. Abetect (Limit: 200 worde)
The 20-acre Hebelka site is located in a rural area of the Weisenburg Township in
Lehigh County, Pennsylvania.—The-site is bordered primarily-by agricultural fields;
however, three residences are located oh or immediately adjacent to the site. ' From
1958 to 1979, the property was used as an automobile junk yard with intermittent
periods of activity involving salvage operations. -Debris including two large piles of
battery casings, empty drums, junk cars, and scrap metal were accumulated on site. A
site inspection in December 1985 revealed lead in soil downgradient from the battery
piles, and chromium in downgradient sediments. Lead concentrations were highest in
surface soil samples (Oft) ranging from 200-65,000 mg/kg. This ROD addresses source
control; a second operable unit will address migration pathways such as downgradient
sediments and ground water. The primary contaminant of concern at the site is lead.
The selected remedial action for this site includes excavation and onsite fixation of
5,000 yd3 of soil, followed by offsite disposal of treated soil at a sanitary landfill;
excavation and recycling of 1,000 yd3 of battery casings; and soil backfilling and
revegetation. The estimated present worth cost for this remedial action ranges from
$6,073,436 to $6,884,652; the greater cost reflects the additional expense of disposing
of the battery casings if recycling is impractical. No O&M costs are expected.
17. Document Anelyele e. DMcrtpton
Record of Decision - Hebelka Auto Salvage Yard,
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: metals (lead)
PA
1*. Avril*bUty BtaMmwM
It. Security On* (IN* Ripen)
None
20. SKUtty CUM (Thte P>0>)
None
21. Ne.elP*gM
^9
22. Price
(SMANSI-ZM.1t)
SM InitrvcMont on flcwm*
i
OPTIONAL rOHM 272 (4-77)
(Forrariy NT1S-36)
t of CoimiwrM
-------
RECORD OF DECISION
SITE NAME AND LOCATION
Hebelka Auto Salvage Yard
Weisenburg Township
Lehigh County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Hebelka Auto Salvage Yard in Weisenburg Township, Lehigh
County, Pennsylvania, developed in accordance with the
Conprehensive Environmental Response, Condensation and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986, and to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan, 40 CFR Part
300. This decision is based on the administrative record file for
the Hebelka Auto Salvage Yard. The attached index identifies the
items that comprise the Administrative Record upon which the selection
of the remedial action is based.
The Commonwealth of Pennsylvania has concurred on the selected
remedy. A copy of the State's letter of concurrence is attached.
DESCRIPTION OF THE SELECTED REMEDY
The remedy described in this Record of Decision is the first of two
operable units planned for the site. This operable unit addresses
the source of the contamination by remediation of the battery
casings and contaminated soils. An estimated 5,000 cubic yards of
soil and 1,000 cubic yards of battery casings require remediation.
Additional remedial actions addressing contaminant migration
pathways (downgradient sediments and ground water) will be
determined in a second operable unit Record of Decision.
The selected remedy includes the following major elements:
- Recycling of battery casings.
- Excavation of lead contaminated soil, fixation of the
soil, utilizing a cement- or lime-based fixation process
and depositing the fixed material in a landfill that the
State has permitted to accept.
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DECLARATION
Tne selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment which reduces
toxicity, mobility, or volume as a principal element. Finally,
this remedy utilizes permanent solutions and alternative treatment
to the maximum extent practicable. Because this remedy will not
result in hazardous substances remaining onsite above health-based
levels, the five-year facility review will not apply to this action.
Date ——' Startfey L. Laskowski
Acting Regional Administrator
EPA Region III
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Summary of Remedial Alternative Selection
I. Site. Location and Description
The location of the Hebelxa property (the "Site") is shown on
Figure 1. The property occupies approximately 20 acres within the
headwaters of the Iron Run subdrainage basin. Topographically the
property is positioned on the south side of a low, moderately steep
hill north of Interstate Highway 78 and Old Route 22 (the two
highways are parallel to each other running generally east-west)
approximately 9 miles west of Allentown, Pennsylvania. The
property is bordered on the south by Old Route 22 and Interstate
Highway 78; on the east by Tercha Road and an agricultural field;
on the north by a second agricultural field; and on the west by a
Township Route T-541 and open, rural land. Tne general arrangement
of the site is shown on Figure 2.
The Hebelka property has a maximum topographic relief of 100
feet with elevations above mean sea level ranging between 510
and 610 feet. Slopes on the site vary between 6 and 25 percent.
The western half of the site exhibits a relatively uniform slope of
between 7 and 10 percent downward from the northern extreme toward
the west and south. The eastern half of the site consists of a
drainage swale which extends from the site's northern extreme
toward the southern border with an average slope of about 6 percent.
The sides of the swale rise toward the east and west with relatively
uniform slopes of about 25 percent.
Overall, relatively few trees grow on the property. Trees that
are present tend to grow along the west or southern border, except
for a few sparse groups of trees scattered over the site. Much of
the site is covered by wild grass and weeds. Only in the relatively
flat (7 percent and less) north-central area, which also happens to
be near the highest elevations on the site, is the ground surface
essentially bare except for the sparse groups of trees.
The materials stored on the site give evidence of its history
as an automotive disposal facility. The stored materials include
automobiles, tires, occasional piles of miscellaneous scrap or
trash, opty storage tanks, and empty drums. The major accumulation
of waste'Material, though, consists of discarded automotive batteries
now- located; in two- distinct piles.
1 ' • : 'V- . V
Three nones exist on or immediately adjacent to the Hebelka
property. One home is located on adjacent property approximately
1,500 feet northwest of the northwest corner of the Hebelka
property. A second home is located along the site's southern
property line and is surrounded by the Hebelka property on three
sides. The third home was owned by Lovie Hebelka. It is located
near the southeastern corner of the HebelJca property. A frame barn
and a frame shed are also located on the HebelJca property near the
southern boundary.
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BASE MAP IS A PORTION OF THE U.S.G.S. TOPTDN, M QUADRANGLE (7.5 MINUTE SERCS, 1965, PHOTOREVISED 1972, PHOTOINSPECTED I96OX CONTOUR MTERVAL
TEN FEET.
FIGURE * I
LOCATION MAP
HEBELKA SITE. LEHIGH CO.. PA
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GENERAL ARRANOEMgNT
HEB6LKA SITE. UEHK3H CO. P4
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II. Sitg History
The HebeLka Site was purchased in 1958 by Mr. and Mrs. Joseph
HebeLka, now deceased. The property is currently a part of the
estate of Lovie Hebelka. During the period between 1958 and 1979,
the property was used as an automobile junkyard with periods of
activity involving salvage operations. At some point during the
past 10 to 15 years, two large piles (totaling approximately 1,000
cubic yards) of used battery casings accumulated on the site in
addition to empty storage tanks, empty drums, junlc cars, and
miscellaneous scrap metal. The Pennsylvania Department of
Environmental Resources (FADER) reported that operations on the
site ceased on 1979.
On December 15, 1985, the EPA Region III Field Investigation
team (FIT III) visited the site for the purpose of conducting a
Site Inspection (SI). The Site Inspection report revealed the
presence of two battery piles at the site, termed the eastern pile
and the western pile. The major contaminants identified during the
Site Inspection include lead in soils downgradient from the battery
piles and chromium in downgradient Iron Run sediments.
The HebeUca Site was proposed for inclusion on the National
Priorities List (NPL) on June 1, 1986. A Remedial Investigation
and Feasibility Study (RI/FS) was conducted between March 1987 and
March 1989 to examine the nature and extent of contamination and to
identify alternatives for remediating the site conditions. The
RI/FS reports were released to the public on March 1, 1989.
III. Community Relations History
Although the HebelJca Superfund Site is located in a rural area,
residential properties are within close proximity.
In May 1986, EPA distributed a press release announcing that the
Hebelka site was proposed for the National Priorities List. Onsite
and telephone interviews were conducted with local residents and
officials in July 1987. No citizens group is associated with the
site, and EPA activities at the site have not been a major concern
to local residents.
As required in the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), an advertisement
was placed in the local newspaper announcing EPA's preferred site
cleanup alternative. Ine comment period lasted from February 24,
1989 through March 26, 1989. During the public comment period,
only one comment was received in the form of a letter from the
attorney for the children of the deceased site owner. The attorney
requested that EPA hold a public meeting. In response to that
request, EPA scheduled a public meeting for Thursday, March 23,
1989 at the Weisenburg Township building.
-4-
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The interim Administrative R«
repository at the Weisenburg Township Hall in Lehigh County,
Pennsylvania, on March 1, 1989. The proposed plan was available
for public comment on February 24, 1989.
IV. Scope and Role of Response Action within Site Strategy
This first operable unit is planned to address soil contamination
and battery casings on the site. Additional sampling will be
done to determine the necessity of a second operable unit to
address possible ground water and sediment contamination. The
remedy of this operable unit is consistent with any future remediation
at the site.
V. Description of Investigative Activities
The Hebelka Site was placed on the National Priority List
on July 1, 1987, based on the findings of the Site Investigation.
A remedial investigation of the site was initiated on March 3, 1987.
The onsite remedial investigation field activities included the
collection of samples from contaminant sources, surface and
subsurface soils, ground water, surface water, and sediment, as
well as the performance of aquifer tests (slug tests) and a biota
investigation along Iron Run. Onsite baclcground contaminant
levels were examined by cox. acting surface soil, subsurface soil,
and ground water samples. Soil borings and monitoring wells were
installed upgradient from the battery piles. The soil samples
were analyzed for lead, mercury, zinc, acidity, and alkalinity.
Ground water samples included both filtered and unfiltered samples
and were analyzed for Target Analyte List (TAL) inorganics, sulfate,
acidity, and alkalinity. Offsite background contaminants levels
were examined by collecting surface water and sediment samples
from locations upgradient from the Hebelka surface water discharge
to Iron Run. Surface water samples were unfiltered and were
analyzed for hexavalent chromium and TAL inorganics. Sediment
sample analyses included hexavalent chromium, TAL inorganics,
pesticides, and polycyclic aromatic hydrocarbons (PAHs).
Source contamination was investigated by collecting samples
from the battery pile material; from soil borings drilled under
and doungradient from each battery pile; and from surface soil
samples from a grid pattern around and downgradient from each
battery «pil*v The savples taken from the battery piles included
samples of the residual liquids and the residual solids found
inside the- battery casings, all of which were analyzed for lead,
mercury and acidity analysis. Additionally, representative samples
of the overall battery pile material (battery casings along with
residual solids and liquids) were collected for testing using the
Toxicity Characterization Leaching Procedure (TCLP) analysis for
the purpose of evaluating the hazardous characteristics of the
material as defined by the Resource, Conservation, and Recovery Act
(RCRA). soil boring samples were analyzed for lead, mercury, zinc,
acidity, alkalinity, cation exchange capacity (CEE), pH, and Qi
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(oxidation reduction potential). The resulting data provided
information regarding the depth and horizontal distribution of soil
contamination under and downgradient from each battery pile.
The potential for contaminant migration was addressed by
sampling surface soil along potential migration routes; sampling
ground water in downgradient monitoring wells; sampling surface
water and sediment at locations downgradient from the site;
performing aquifer tests (i.e., estimating the ground water flow
rate and direction); examining the ground water flow rate and
direction; and examining the biota in iron Run for indications of
adverse effects due to site-related contamination. The field
activities included provisions for the collection of 14 surface
soil samples from selected locations to investigate the presence of
previously unidentified contaminant sources and/or migration routes.
Because these samples served, in part, as a screening function, they
were subjected to a broader array of analyses, including Target
Compound List (TCL) volatile organics, TAL inorganics, pesticides,
FAHs, CBC (cation exchange capacity), pH, and EJi. Downgradient
surface water and sediment samples were subjected to the same analyses
as the background samples described earlier.
VI. Site Characteristics
The overburden soil on the site exists almost exclusively at
the lower elevations near the southern border. At the lower
elevations, the overburden thickness encountered in monitoring well
borings varied between 5.5 and 10.5 feet. At the higher
elevations, weathered bedrock was encountered within one foot of
the surface.
The bedrock under the site consists of the Bushkill member of
the Martinsburg Formation. The bedrock is composed of very broken
to moderately broken silty shale with quartz zones interbedded
throughout. The extent of fracturing tends to decrease with
increasing depth. Bedrock becomes increasingly calcareous with
depth, possibly indicating a formation change. The surface of the
bedrock slopes generally toward the southeast.
Ground water at the Hebelka Site flows toward the southwest,
generally parallel to the bedrock surface, through openings and
fractures in the ffertinsburg Shale with an average horizontal
hydraulic gradient of 0.063 feet/foot. The ground water also
exhibits a downward vertical hydraulic gradient (0.35 feet/foot
average), which tends to increase toward the southwest and may be
indicative of vertical leakage into the underlying carbonate layer.
Calculations from the slug test data indicate that ground water
is flowing toward the southwest at approximately 212 feet per year.
Battery liquid and residual solid waste samples exhibited high
concentrations for lead and acidity. Lead concentrations in the
liquids ranged between 7,320 ug/1 (parts per billion) and 1,100,000
ug/1, and acidity values were as high as 66 mg/1 (as CaCO3). Lead
-6- C
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in the residual solids ranged between no,000 mgAg (parts per
million) and 361,000 mgAg with acidity values up to 210 mg/i. The
TCLP analyses of representative battery pile materials yielded lead
concentrations from 22,100 ug/1 to 48,600 ug/1. Lead was the only
metal for which the reported TCLP concentration exceeded the Extraction
Procedure (EP) Toxicity criteria for hazardous wastes (40 CFR Section
261.24). Tables 1 and 2 summarize the results of the sampling
data.
"•*?•«'-•• :tf «',*.
The analysis .of the samples collected from the onsite drums
did not reveal levels of contaminants that would indicate that the
drums are an additional source of significant contamination.
Background soil boring sample analyses indicate onsite,
background, and surface soil lead concentrations of 133 and 140
mgAg, compared to an expected average background concentration
range of 2 to 200 mgAg found in literature (Lindsay, 1979). Surface
soil contamination detected on the site consists primarily of lead
in soil under and near the battery piles. The surface samples (0
to 3 inches) from soil borings and the surface.soil grid samples
correlated well with respect to detected lead concentrations. The
deeper soil boring samples demonstrated that contamination was at
or below background concentrations at depths greater than 3 feet.
Lead concentrations were highest in surface soil samples collected
from borings located under the battery piles (typical nigh values:
5,090, 15,000 and 65,100 mgAg). Above-background surface soil
lead concentrations ranging between 200 and 3,000 mgAg are generally
confined to areas within 30 feet of a battery pile perimeter.
Exceptions do occur for an area northwest of the western
battery pile and two isolated locations west of and adjacent to
Tercha road. Figure 3 shows the extent and concentration of lead
contamination in the soil and Table 3 summarizes the surface soil
data.
Both filtered and unfiltered ground water sanples were collected
from onsite monitoring wells. Filtered samples were collected to
examine ground water for its dissolved metals content. Only one of
the 10 filtered sanples resulted in a reported metal concentration.
Lead was detected at a concentration of 6.8 ug/1 in that sample.
Unfiltered ground vafctr samples exhibited a range of lead
concentrations fran 13 ug/1 to 6,250 ug/1. The highest
concentration occurred in the sanple taken from the most
downgradtenfc monitoring well.
. •*
Offsite sarpling activities included surface water and sediment
samples from Iron Run, the unnamed tributary discharging from the
Hebelka property to Iron Run, and the storm water discharge serving
the highway south of Iron Run. The analyses of surface-^water
samples indicated little difference in water quality between
upstream and downstream (from the Hebelka Site) locations.
Additionally, no detectable levels of either lead or hexavalent
chromium were found in the surface water samples. Downstream
sediment samples showed metals concentrations between two and five
1C
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TABLE
SUMMARY OF ANALYTICAL RESULTS
BATTERY LIQUID SAMPLES
HEBELXA SITE, LEfiIGH COUNTY, PENNSYLVANIA
Compound
Lead
Mercury
Acidity
(C»C03)
Unit*
ug/i
ug/i
mg/l
Muaber of
Positive
Detections
froa
23 Samples
25
1
29
Minimum
Detected
Concentration
7,320
2.2
-34
Maxifflua
Detected
Concentration
1,100,000
2.2
6«
Average
Concentration
179,470
2.2
9.2
SUMMARY OP ANALYTICAL RESULTS
BATTERY SOLIDS SAMPLES
HEBELKA SITE, LEHIGB COUNTY, PENNSYLVANIA
Compound
Lead
Acidity
(CaC03)
Units
mg/ig
•g/i
Huaber of
Positive
Detections
froa
25 Saaples
25
25
Miniaua
Detected
Concentration
110,000
-§
Maxiaua
Detected
Concentration
361,000
210
Average
Concentration
214,320
14
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TABLE
COMPARISON OF EP TOXICITY CRITERIA AND TCLP
ANALYTICAL RESULTS
Contaminant
Arsenic
Barium
Cadmium
Chromium
Lead
Mtrcury
Selenium
Silver
EP Toxicityd)
Maximum
Concentration
(vg/D
5,000
100,000
1,000
5,000
5,000
200
1,000
5,000
TCLP Analytical
Results (ug/1)
Maximum
169
22
ND<2>
NO
48,600
NO
3.4
ND
Minimum
42.9
14
NO
NO
22,100
NO
3
NO
U) Reference; 40 CFR 261.24, Table 1
(2) NO » Not Detected
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e
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tftfC'. V^,*,
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/ i
A tUMOI SOL MMKI UOUTW
irrv TO ^*Q CONCENTRATIONS
0 LtM TMMI lOOM/W
I fiWATM TMM 100 M^«, MT LtM TM«M 200MB/W
2 • • 200 • • • • 400
j . . wo . . - . OOO •
4 • •« OOO . . - - Q000 •
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auu M ror
V, ' '^^Wfc
-^r^Mfe
-^m^
•' ' '' '' i i • /
- /'//•/
• A i : i I;
WESTERN AND EASTERN BATTERY PILES
HEBELKA SITE. LEHH3H CO.. PA
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TA3L2
SUMMARY 0? ANALYTICAL RESULTS
SURFACE SOIL GRID SAMPLES (0 TO 3 INCHES DEEP)
HEBELKA SITE, LEHIGH COUNTY, PENNSYLVANIA
Compound
lead (Western
Grid,
43 Samples)
Lead (Eastern
Grid,
34 Samples)
Units
mg/kg
mg/kg
Number of
Positive
Detections
from
43 Samples
43
34
Minimum
Detected
Concentration
23
34
Maximum
Detected
Concentration
11,000
32,000
Average
Concentration
1,121
2,112
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times higher than the concentrations detected in upstream sediment
samples. The major downstream contaminant detected was lead at a
concentration of 1,810 mgAg- A second sample collected 100 feet
further downstream, however, exhibited a lead concentration of
only 32 mg/kg.
Contaminant Transport and Need for Additional Study
A question regarding potential offsite migration of lead
contaminated ground water remains unanswered. Lead concentrations
in ground water, as determined by unfiltered ground water samples,
was detected at concentrations (6,250 ug/1). Tnis value was due
to the sample containing large amounts of soil particles and the
value does not represent a health concern. This well will be
resampled during the second round of sampling to characterize the
ground water. The following actions will be included in the second
round of sampling and addressed, if necessary, in a second operable
unit Record of Decision:
* Collect a second round of ground water' samples,
* Request data regarding treated water from water authorities
using downgradient ground water as a source of supply,
* Identify and possibly sample downgradient, domestic,
private wells.
VII. Risk Assessment
Inorganic lead may be absorbed by inhalation or by ingestion.
Absorption by either route contributes in an additive fashion to
the total body burden. Among adults, inhalation is the more
efficient of the two mechanisms. The fraction of inhaled lead
absorbed from the respiratory tract is approximately 40 percent,
while the fraction of ingested lead absorbed from the
gastrointestinal tract is approximately 10 percent. Tnese rates
may be higher in children and are of particular relevance in
assessing exposures in this sensitive subpopulation.
The toxicology of lead has been extensively reviewed.
Alterations in the nematopoetic (blood forming) and central nervous
systems '.are the primary toxic effects caused by exposures to lead.
Cognitiw and behavioral deficits are the focus of much current
research on relatively low levels of lead exposure.
Tne Centers for Disease Control (CDC) has determined that a
blood lead level in children of 25 ug/dl or above indicates excessive
lead absorption and constitutes grounds for medical intervention.
inat determination is based on the occurrence of enzymatic
abnormalities in the red blood cells at blood lead levels above 25
ug/dl and by the finding of neurologic dysfunction in children at
blood lead levels between 35 and 50 ug/dl. Further, the CDC
defines childhood lead poisoning at a blood lead level of 25 ug/dl
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in association with an erythrocyte protoporphyrin (EP) level of 35
ug/dl or above (CDC 1985). In its draft toxicological profile for
lead, CDC has also cautioned that concentrations greater than 500
to 1000 ppm could lead to elevated blood lead levels in children
inhaling or swallowing dirt. Recent findings of cognitive deficits
associated with lower blood lead concentrations may result in a
review of the adequacy of the existing CDC threshold level.
Exposure scenarios considered for potential contact with
contaminated surface soils include children who may be exposed to
onsite surface soil via dermal contact and accidental ingestion.
Adult dermal exposure may occur through work activities or occasional
contact. To provide a worst-case estimate of health effects, the
maximum concentrations of indicator compounds were employed.
For carcinogens, the estimated dose can be converted to
incremental lifetime cancer risk, which represents the probability
or range of probabilities that a carcinogenic effect will occur.
For known or suspected carcinogens, acceptable exposure levels
are generally concentration levels that represent an excess upperbound .
lifetime cancer risk to an individual of between 10~4 and 10"' using
information on the relationship between dose and response. Carcinogenic
risks of 10~4 to 10~7 correspond to one additional case of cancer
in 10,000 and 10,000,000 receptors exposed, respectively.
To evaluate the potential for noncarcinogenic effects, the estimated
daily dose is compared directly to reference dose. The ratio of the
estimated exposure level to an acceptable exposure level provides a
numerical indication of potential for adverse °-"->-r:s. To assess the
total potential for noncarcimogenic effects posed, a hazard index can
be calculated. When the hazard index is greater than one, the potential
for adverse noncarcinogenic effects is increased. When a hazard index
is less than or equal to one, no adverse noncarcinogenic effects are
expected.
A summary of the health and environmental risks associated
with the Hebelka Site is presented below.
* Accidental ingestion of onsite surface soils by children is
likely to pose a potential for noncarcinogenic health effects.
This is evidenced by the calculated worst-case hazard indices of
greater than one for all areas of the site. These hazard indices
can be attribute* to the presence of lead in surface soils.
* Carcinogenic risk estimates associated with accidental ingestion
of contaminated surface soils by children range from 1.63 x 10~8 to
2.52 x 10~5. The highest risk estimates are associated with
exposure to surface soils containing IftHs in the north-central
portion of the site.
* Dermal contact with onsite surface soils by children and adults
poses a minimal potential for noncarcinogenic health effects. The
calculated hazard indices are less than one; therefore, adverse
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1C
-------
effects associated with dermal exposure to surface soils are not
expected.
* Carcinogenic risk estiitates associated with dermal contact of
onsite surface soils by children and adults range from 1.67 x
10~12 to 1.39 x 10~5. The highest risk estimates are associated
with exposure to surface soils containing PAHs in the north-central
portion of the site.
* Long-term inhalation of air containing particulate lead at a
distance of 700 meters (the approximate distance to the nearest
receptor home) from the battery piles is unlikely to be associated
with adverse health effects.
The environmental risks of the sediment contamination will be
assessed in the second operable unit Record of Decision.
Action Objectives
The accidental ingestion of lead-contaminated soil and battery
pile material, and the accidental ingestion of, or dermal contact
with PAH contaminated surface soils, are the contaminants and exposure
pathways addressed in the Feasibility Study (FS). The risk posed
by elevated PAH contamination is very limited, having been detected
in only four surface soil samples, each from visually stained soils
covering only a few square feet. Additionally, all four samples
were collected from sampling points located within the much larger
areas (a total of 14,200 square yards, or 2.9 acres) of elevated
lead-contaminated soils and battery^pile materials. The potential
remedial actions developed in the FS, therefore, focus on the
remediation of lead-contaminated soils and battery pile materials.
The ground water data collected during the RI effort was
inconclusive. The standard protocols used for filtering
ground water samples in the field may have resulted in false
negative analytical results for dissolved lead. On the other hand,
the high turbidity in unfiltered ground water samples, as a result
of insufficiently developed monitoring wells, may have resulted in
artificially high analytical results for total lead. The RI data
currently available does not conclusively demonstrate the need for
ground water remediation. Therefore, potential remedial
alternatives for lead in groundwater are not developed in the FS.
Additional: remedial action addressing contaminant migration pathways
(downgradient sediments and ground water) will be determined in a
second operable unit Record of Decision.
The potential remedial alternatives are based on leaving a lead
concentration of 560 ing/kg in the soil. The 560 mg/xg level is
based on health risk calculations which consider a safe soil
ingestion scenario.
The volume of contaminated material on the site includes 1,000
cubic yards of battery casings and 6,900 cubic yards of lead-
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contaminated soil. Figure 4 shows the approximate area of
contaminated soil. The estimated volume is based on a 3- foot depth
of lead contamination in soil. The RI effort included soil boring
samples from the surface and depth of 3 feet. The analytical data
indicates that, with a single exception, the lead concentrations
detected in the 3-foot sample are below the cleanup concentration
of 560 mg/kg. No data is available to evaluate the lead
concentrations between the ground surface and the 3-foot depth.
VIII. REMEDIAL ALTERNATIVE EVALUATION
The Feasibility Study for the Hebelka site screened a number of
alternatives that could potentially achieve the remedial objective
of concern, which is to reduce contaminant levels in onsite soils
to levels that eliminate unacceptable risk to human health and the
environment (see Remedial Action Objectives).
All alternatives were evaluated using the following criteria:
* Protection of public health and the environment
* Compliance with applicable or relevant and appropriate
requirements (ARARs)
* Long term effectiveness and permanence
* Reduction of waste -Ability, toxicity, and volume
* Short term effectiveness
* Implementability
* Contnunity acceptance
* State acceptance
* Cost : •
These criteria were derived from the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) of CERCLA and the
Superfund Amendments and Reauthorization Act of 1986 (SARA.) . The
criteria relate directly to factors mandated in Section 121 (b)
(1) (A-G) of SARA. Utilizing these criteria, certain alternatives
were eliminated during the preliminary screening process. The
eliminated alternatives and the primary reasons for their
elimination may be found in the FS. Table 4 presents an outline of
the alternatives that remain after the preliminary screening.
Table 4 also presents the analysis of the remaining alternatives
according to the criteria listed above.
Alternative 1 - Mo Action
All alternatives considered must be judged against a "No
Action" alternative as required by SARA. This alternative involves
taking no actions at the Hebelka Auto Salvage Yard site to remediate
contaminated media. It does, however, include provisions for
installing a fence around the perimeter of contaminated areas, as
well as annual ground water monitoring and site inspection.
Effectiveness
-15-
-------
' ; ' • / X • ^—"\ \ 1 \
:; I; i I I ALf \\,
WESTERN AMD EASTERN BATTERY Pfl
CONTOun
HEBCLKA SITE. L£HK3H COL. PA
-------
TABLE 4
REMEDIAL ALTERNATIVE ASSESSMENT SUMMARY
HEBELKA SITE. LEHICII COUNTY. PENNSYLVANIA
roctof*
MIVK I
•o ftctloo
•LTKMIIlTIVC 1
Coppio*
ALTUMATIVE 1
Kucooolioo ood Oftcilo KM
Loodlil lioo.
•LTUMATIVf 4
>ici»itloo. riillioo,
Offolt* *npo*il
OLTMMATIVC %
ticivition. acid Loichlo*..
••4 Dupotol
•**» Ip4 »•«
Illllll f«
pociooloi •(
coot Ml ootod Mil *od
botloil**.
M: Pl«co J."> loot cop
ovoi coot OBIo*tod sail ood
fcolloi io» •
I S*M «• OBOVO (01
•oil. Sbip bottoito* t«
tocyclof.
soil
both to afl*il* •THk
li*a«(dau« !••*(•
*nd >hip
«•:
•oil
M: SMW •• •»>•»• far
••II. Ship b*lt»f!•• la
«»cyctor .
>•£»>*!• call ••{ ail od
cud k«tt«ii**; In
Bi>»tliB vtlk roil I and
€••••1 01 I !•• OOlOd
pi •<:•>»; pile* lload ••lit*
io o; ocid-
looch load cootoaIKOI ion
''OOj lt Of COOCtlUCt IOO
Ifoftic duiiof c«p ploco-
o«ol. Dual «u|i(l(oi«ion ond
MOIOOI io»pnalotf ood
dotool piotoctioo My bo
OutI potooliallr «ooocolod
by onco«oli«* of
cooloo)ioolod Mloiiol.
OutI *uppio»>ioo ood
loipiioloif ood dcfoi
ptotoctioo My bo
Ouit potooliolly 900010tod
by oocooattoo of
coolooioolod aoloiiol,
ojoioi iol boodlioo, dMilo«
Iho liootloo pcoccn.
•«•« •opyrooiioo ood oofiof
lOipnoloiy ood doiool
p«oloclloo aoy bo io«i Icolfic
90001«tod by olltito
Ctoocport of hoaofdou*
0*101lalt
NMIo Ikoio it o
tailiility of *
Ifloipoitot loo occidoot,
Iho piobobillly is lo«; IM
chooco of o tiontpotlot too
occidoot ploioolio^ •
tlifool to public hoiltb «od
lit* oovliooovol li ol*o
HIOIMl
didHplioo ftoo) Icolfic
fooocolod by oftolio
KOOOMft •( bO«OfdOV«
MbII* tb*i* U •
po»iblllty of o
Ifoo«poflot loo occldool.
Ibo pfokobillly ii l*«i Ibo
cbooco of • tionpulotio*
occld**t pf**oollb9 •
Ibfoot I* public b*ollb ood
Ik* *o»l««o«o«l !• all*
O> Alt Of Oil IVO 1
*• oltotootivo J
10
-------
TABLE 4
REMEDIAL ALTERNATIVE ASSESSMENT SUMMARY
HCBEUIA SITE, LEHICM OOUMTV. PENNSYLVANIA
TUP
rncloio
HWTIVt I
action
ALTCkMATIVC 2
Cnppino.
Kicavation and Off*it* KM
L*nof 11 I i no,
aLTMMTIVf 4
••cavatloo, rlaation, and
Off*Ito »l«poial
Sicevatioo. acid Lonckino..
•Ml ftlapotnl
Utoit T»<*
•> c»p
until *«f*t*ti*« cover
Ifoiioo cantial
•(••!•• «f
C««llf UCt !•
cunlial •*
c*«>t rucl !••.
K«>io« c»«ti*l ••••«••*
B*t«d co«»ltoclion
4ur•>!•*: I •••Ik.
tfui •!>••: I •amh.
1 •••Ik*.
*«t«4 const (ucl tun
1 oanth*.
emit !•»••.
• IH*
«ntl«l tut inf«ilian 01
a*l cantnct •(
•li»iiul*s Ik*
foi i*4«*ti«B *t 4* i mil
«41c iiltpvct !•••»<*
Mi Hi ••*•£• f«M»i
•I tlM i ••pact I •• ••*
Lonf-torm «i led
dopnnds on piopci licxncnl
ol vottOKOiar «oiMi*lod by
tko Icacktnf procots.
-------
TABLE 4
HEMKOIAL Al.TEHNATIVE ASSESSMENT SUMMAMV
IIEBEIKA SITE. LBH1GH COUNTV. PENNSYLVANIA
CAGE THREE
aLV
«I«B I
•LTCMMftTIVC 2
Ceppiae,
al.TBMtATIVC i
ticavalioa aad Of lute MCM*
l-andf illiaa
ALTUWATIVC 4
••cavaliea. Finaliaa, and
Of (•!(•
ALTKMUITIVI i
Excavation. Acid Le
••4 BUpotal
•eductiea «f
Taalcitf.
bltlly. ei
Value*
•a reductiae, la.
toilette, ••fciiitf •!
value* Milk (MfM«t t*
the tile a*d th*
irduclio* in t«iiclly Of
•o t«ductl*n in loiiclly •!
•e f*duction in
i«duc»*
cap
Nobility t«4ur«d by
COHl IK«B«I>I in MCM
••l COBtCCl »»ul«».
rf i|u«i»ili*> *f
Mould c*at*cl
path* I«MIH •• lh«
o(
•••!«:• luaotf.
»f
Nobilily t*duc«d. Cutiitc-
•••I ol ca*(«ain«l*d
K*t«ci«l> !• fiicd Bat
.
coaiari Milk XUIB walai .
Syatkalic liaai* mil
Vcluwt icduccd il ltalt*ry
!• l«CfCl«d.
ccducctf it
«••
•atar iafiliialiaa coat act
Milk caataaiiiiatad
•ataiiali. Haaily all
staiai watvi nill fua all.
Valuaw vill iaciea»e itith
Iha addittoa af •ataiiala
|a.q.. f>aillaad ca«aat at
liaa| la tia caataaiiaaal».
•acycliaq kallaiia* Kill
• laiaiia Iha «aliHM
lacieata at latult in a
awdaat aat dacraata.
•••Icily af aail aad .
battaiy aalai ial laducad to
acr*pl*bla la«al>.
Tiaalaaat piacaaa ^aaaiaia*
caataaiiaaiad vaala* (a. 9.,
•pent acid, alud^al
laqititlaf traata«at aad
diapotal. Vaalcity af
tliaaa waaiea dapaad oa
tiaatawal piacaa*.
Mobility of aaatle
caalaalaat iaa a**aniially
aliaiiaatad. Laad Ituai
Iraatad «atla»alaf Bay 01
atay aal ba aabila.
an fuio
Val laMiaa, tiaatiMtnl. no
caataoiaalad soil 01
«ii>4» velua* oil I
Valuaa of laad rual on
ia*idual aialci tal vill
dapaiid aa tfce liaalara
piecaaiaa salactad.
abillly
ioplaa»alad.
Ratily coatttiuctad.
Catily iaplaaaalad.
•acaval ioa aaaily
iapleaaated. riaadaa
pcacao ta^unat
•pacialiiad aqulpawal aad
labaf . Ipaca I*
avallabla (•> flaatlaa
ptacaaa afMial laa. •aack-
acala last* aa«d«d I*
•ollabillly •( fliatiaa
•ac**ai laa easily
laailaajaatad. Stion>| «c.id»
cequiiad fai this piocets
ate>catc aat caaMaictal ly
p>a»ea. •aack *cale lot*
a aacaeeity. aiioi tcale
leata advitable. Hccaavai y
•pacialiied •eltil* et|uip
•aat uy aat be available.
Sita-apacif ic lieatawnt
facility Bay aaed lo It*
cea*t
available aa Iha kite lor
balk placet* apei^rion *«
-------
TABLE 4
REMEDIAL ALTERNATIVE ASSESSMENT SUMMARY
HEBELXA SITE, LKH1GH COUNTY, PENNSYLVANIA
Ass*ssa*nt
rncteie
lapleajant-
abillty
(continued)
•
ftLTKHMATIVK |
•a act la*
AITKMMTIVC 1
•at lei y *>cavatioa and
shi|jn»ni to » recytlei
Kilt ba iBolaaeDted.
Mditianal lenedial action
la connect ion will* capped
•aiettals would ««f buaa* and
aa»ifaaa*nlal aapasuia and
tba atlandant iiss balitaan
Inspactlons ata •iat«al.
•o cafulatary paiails aca
ant It: tpatad ta^acdlnf
ansila aL'liwilias.
ft Italtaiy i«t;yclai would
naod allbai • HCM
Vtaaiaant, Staiaa^, ai
•Isposal |TW) pacvil, of
M».d.us -astas/aatstlsls
Itaaspaitad aftsita will
taajuifa aaatfasis and
llcansad naulais piitsusat
to IOU.
ALTUWkTIVl )
lsc««alian and Oflsitc mcu*
l.aMlf ill inq
San* as altaiaaliva 2.
II needed, olliei aia«k of
the site could ba subjected
to fenwdial aclivilie* «ilh
no advaxa impact on this
altaiaat ive.
Ho aonilofin*! .cquired.
s«sw as Allaiaaliva I.
San* as Altainatlva I
Ka«a as kltatnativ* 2
mi -.Ha HCIU disposal
1.. ilily a«st be j~..nl.d
HLTSJHUTIVK 4
Of (sits Disposal
Saaw as Altat*ati«« 1.
addition*! fenjadial action
un IK* fisad contaminated
awtefials is liaely to ba
1 in* coasuauna, and
es|iaas!va. If needed.
athef aiaas al the site
could be sub|*clad to
f*a*dial activities without
adversely iapacliaf «na
disposed fiaed aataiiala.
Mo ooaltocla« ra««lra4.
Sasw as ftltainativa 2.
San* as Altaiaative 2
Caa* as alternative 2
Off site alspaaal facility
neat ka aaralttotf ky State.
ALTUOUTIVK %
(acavat Ion. »nU Luachinq.
and a>ispusal
S*a* as kltacnallva 2.
Sane as nltetnativa t.
'
s)o monitof inf *e<|uiictl.
Tna contaminant
concentf at ion in iitr*ictl
•aleiisl would be veiifivd
by cheeiical analysis pi 101
to disposal.
San* as ftlteinai ive I
San* as Alteiaaiivc 1
San* as ftltainati.. J
JO
r !*i
-------
TABLE 4
HEMEOIAL ALTERNATIVE ASSESSMENT SUMMARY
MEBELKA SITE. LEHICH COUNTY, PENNSYLVANIA
Mi fIVI
M.TBMIAVIVB 1
*LTKMUTI¥E 2
kLTCUI&TIVK 1
l«c«v«ti*n a*4 Olf*tt« KM
(Ml
Ollttt* »l»p*>al
ALTUMUkTIVC 4
•«c«val ion, ftcld L**chl«t.
CMtl
U Mill
»(••*•« Meet*
Mlt> »«tt«I»
*».4M
«4M.M«
f4.4tl.IU
*•
I«M U Mill
NatUt
10
U.U4,»S2
M.OM.4M
W
U.073.4M
fll.II2.OM
$II.I%J.01>
-------
TABLE 4
H(MEDIAL ALTKHMATIVE ASSESSMENT SOMHAKV
HEBRIKA SITE. IBHIGM COUWTV. PKNMSVI.VANIA
PACK Sl»
*.»..»..t
r.c»...
Milk MUUU
•LVMMTIVC 1
•• ActlM
./
ALTKHMktlVl 2
C.w.in,
Fugitive dual 4ur 1*9
• Cl«»i» Air »cl of 1*7*
rullulioa Control
••9111*1 ten*
MutkCf protection dui 109
• OCNA <2» CM.
r*iik i»i», i«2»i
CrctiaH cu»tiol 4orin9
Comol •*4til*tlan*
(f» C«x»* Tit I* 2t.
Ch«|it«r l*2|
k«lt*if rccycl in9<4tafo««l):
le*«*p«i t«t ia«. «n4
• r«d»f«l OUT Kfol*
t i««4 <«9«i4ii>9
If •••p*(t«t >••>.
•••I* fat •<.•! i««-l«»«l
cattcculf •! >••• (li«i«» al
• BIO l*i l»»4 in iail.
•LTKMtktlVK >
CMCAVA! ion AIM! OCfsilc WCMA
L«mlt ill m<|
S«oc •« *ll*ln«tl«c 2
!»«•• •• *ll*in«li«« 2
Sue •• *ll*in»li«* 2
S— " •'••—»'- >
AI.TCBMATIVK 4
Olfltt* Ol>p«><)
S«M •• *ll«ruli«« 2
S«M •» »ll«t»«lt»» 2
SMM •» »li*iiMti** 2
S«M •• AllciMti** 2
SWIB «• »l««in»li«« 2
JtLTCHIIATIVI S
•M Dispanci
$••• •• kll*»«tlv* 2
S.~ .. All.,..ti.« 2
$••• •* ftll*l»«liv« 2
SUM » AltciiMlive 2
S— " •"••"•"« '
JO
-------
TABLE 4
REMEDIAL ALTERNATIVE ASSESSMENT SUMMARY
IIEBKLKA SITE, LEHICH COUNTY, PENNSYLVANIA
Aicaeeawat
racier*
Coapl ieac*
Milk AM*a
(cum lauedl
(Merell
Piitlecliea '
ilale aad
Accept aac*
ALTUMTlin 1
•a a* I lea
Previde* Hot ted) ceatrel
af tiek al ie«eellea ead
dei Ml caatacl. >eed
Ike State aad tke
Coa**»lt* da eel
ALTCBBATIVC 2
C*lf>«"e
MUM Melver i* MI
(eejuiied.
•afar ta teat o( tkle
dnramat Cor additional
aRAle.
dtfecl ceatact ceatrel led
ceat telled ky aeiiedlc
laapecllea aed aaleieeeace
•e ceaaakte were received
(or tkle elteraetlve. !
•LTUWkTIVI I
piavieleae le MCM, due oa
VI/90, Mf pi •elude
ceela^e vilkont
pf elf eeiaent . If IKeie
vexet ace precluded, ae
MUM valvai lei
pcetfeala*al| Hill ka
••^uiiad I* laplaaaei ikie
el tef native eflei 5/i/90.
Refer to text of thle
• iek froe> ensile
eccepteble 10 tke
roaauoltf.
ALTWBATIWK «
Wf.U. •l.pe.al
tea* ae alternative 1
Re(er to text of tkle
docyaeat (or additional
OAle.
ptek al laa.aetlea aad
direct ceatect cent relied
ceaf i aed la f i «ed aat r i e
ead edditlaaallf kv
Coaanalty accept tkle
elteraetlve.
•LTKMIATIVt i
ead •iepaeel
tmm» ft alteraativa I
Refer to text o( thle
docuarat (or additional
MAR*.
• iak (reel eaelle
caataaiiaai iaa el ie>iee«e
-------
This alternative is not considered effective in the short and
long term, as ingestion of lead contained in the soil and casings
remains a viable pathway. Since continued ingestion of lead is
possible, this alternative is not protective of public health and
the environment.
Reduction or Mobility, Tbxicity, or Volume:
The no-action alternative does not achieve the statutory
preference for remediations that permanently and significantly
reduce toxicity, mobility, or volume of the hazardous substance,
lead, found at the site.
Cost:
The present worth cost estimates for this alternative range
between $84,000 and $108,000.
Iirplementabi lity:
The annual ground water monitoring and site inspection of the
no-action alternative will be easily implemented.
Conpliance with ARARs:
The no-action alternative would not comply with the applicable
or relevant and appropriate requirements for a CERdA cleanup.
State and Community Acceptance:
The no-action alternative is not acceptable to the State
or the community because this alternative would leave contamination
onsite.
Alternative 2 - Carping
This alternative involves capping the two areas of contaminated
soil where lead exceeds the cleanup goal of 560 parts per million
with 24 inches of imported soil and 6 inches of topsoil to eliminate
the ingestion and direct contact exposure pathways. The battery
casings will be shipped offsite for recycling. In addition to
eliminating the ingestion and direct contact pathways, the soil cap
will also significantly reduce air emissions, infiltrating
precipitation, and surface runoff from the contaminated material.
Short-term Effectiveness:
During the cap placement, (and battery casing excavation and
transport), dust may be generated. Fugitive dust control procedures,
e.g., wetting, may be required. If dust generation is significant
at the site, workers will be required to wear personal protective
equipment during activities where they may be exposed. Exposure of
the nearby community is not anticipated. There is the potential
-24-
-------
for erosion of the capping material until the vegetation program
becomes effective. Erosion control measures will be implemented to
minimize the erosion potential.
It is estimated that cap placement will be completed one month
after the remedial contractor has mobilized at the site.
Long-term Effectiveness:
If the cap is properly placed and maintained, the ingestion and
direct contact pathways will be eliminated in the long term. The
surface water and ground water pathways are not believed to be of
concern at the site. However, if the cap is disturbed by future
activities at the site, there is the potential for human exposure
to the contaminated soil.
To ensure that the cap remains effective, periodic inspections
(and maintenance, if necessary), will be required. Periodic
maintenance of the cap is expected to be required. Inspections and
maintenance will be the responsibility of the Commonwealth of
Pennsylvania. Five-year reviews of this remedy, if implemented,
will also be required under section 121 (c) of CERCLA. Deed
restrictions will also be required to ensure that the cap is
undisturbed, and is not used for farming and gardening.
Reduction of Mobility, Tbxicity, or Volume:
Although this alternative does not include treatment of the
contaminated material, Alternative 2 will reduce the mobility of
the lead contaminant for the direct contact by ingestion, air, surface
runoff, and ground water pathways by reducing infiltration from
precipitation. Since treatment of the waste is not a principal
element of this alternative, Alternative 2 does not meet the
preference for remedial actions that reduce toxicity, mobility, or
volume expressed in Section 121(b)(l) of CERCEA.
Implementabi 1 ity :
The technologies proposed for this alternative are all
demonstrated and ocmnercially available. Since all of the remediation
will occur onsite, no permits are anticipated to be necessary.
See CERCLA Section 121 (e) .
A water supply for dust control and cap vegetation will need to
be developed under this alternative.
Cost:
Estimated costs for potential remedial alternatives are
summarized in Table 4. Present worth cost estimates for Alternative
2 range from $409,000 to $456,000; the greater cost reflects the
additional cost of disposal of the battery casings if recycling is
impractical because of the unavailability of a vendor. It has been
-25-
-------
assumed that recycling of the battery casings will require expenditures
only for excavation and haulinq. The cost estimates do not anticipate
either payments to a recycler for accepting the battery casings or
payments by the recycler in exchange for the casings.
Compliance with ARARs:
The only contaminant-specific ARARs pertinent to the capping
remedial alternative is the NAAQ standard for lead, which is
codified in the Clean Air Act of 1976 and the Pennsylvania Air
Pollution Control Regulations. As stated above, water sprays are
will be be used to control fugitive dust emissions. By this method
the accepted standard is not exceeded.
No location-specific ARARs will be activated by the proposed
remedial alternative.
Several action-specific ARARs will be applicable or relevant and
appropriate for capping remediation. All onsite workers must meet
the requirements of OSHA under 29 CFR, Parts 1910, 1926, and 1904.
Additionally, worker exposure to air contaminants must be kept
below allowable concentrations (threshold limit values) set by the
American Conference of Governmental Industrial Hygienists (ACGIH) .
Erosion control measures under the Pennsylvania Erosion Control
Regulations, PA Code Title 25, Chapter 102 must be taken to reduce
erosion.
RCRA capping is not an applicable requirement for wastes
disposed prior to 1980 that are left on site. RCRA capping
standards may be relevant and appropriate requirements that
would not be met be this capping^method. See U.S. EPA. 1986b.
Covers for Uncontrolled Hazardous Waste Sites, EPA/540/2-85/
-002. RCRA ground water monitoring, closure and post-closure
requirements are not applicable requirements for wastes disposed
prior to 1980 and left on site, but may be relevant and appropriate
requirements for a land disposal unit. RCRA closure and postclosure
requirements would not be met by this alternative remedy. See
40 CFR Section 265, Subparts F and G; 25 PA Code Sections 75.265(n) ,
(o).
•Die contents of the battery casings may exhibit the
characteristic of EP Toxicity (40 CFR Section 261.24) for lead. If
so, any land disposal will be subject to the land disposal
restrictions of RCRA Section 3004(g), 42 U.S.C. Section 6924(g).
To date, there are no land disposal restrictions applicable to
characteristics wastes such as EP Toxicity lead. The statutory
deadline for promulgation of such restrictions is May 1990. If
treatment standards are promulgated prior to off site disposal, the
disposal of EP Toxic battery casings must meet the treatment standards.
The offsite disposal of battery casings must meet the
CERCLA offsite policy, OSWER Directive No. 9834.11, Nov. 13, 1987,
and CERdA section 121(d)(3).
-26-
-------
Overall Protection:
Exposure to the battery casings and soil onsite will be
eliminated under this alternative. Therefore, the risks associated
with dermal contact and ingestion will be eliminated. A periodic
inspection and maintenance program as well as ground water monitoring
are necessary to guarantee the continued protectiveness of this
alternative.
State and Community Acceptance:
The State requested that the lead-contaminated soil be removed
from the site; therefore,'the State does not concur with this
alternative. The community did not comment on this alternative.
Alternative 3 - Excavation and Offsite RCRA Landfilling
This alternative involves excavating the contaminated soil and
transporting it for offsite disposal at a RCRA hazardous waste
landfill. This alternative will eliminate the • ingestion and direct
contact exposure pathways.
The battery casings will be shipped offsite for recycling.
If battery recycling is impractical, then the battery casings will
be disposed of in a RCRA landfill. Alternative 3 will result in no
material remaining onsite that could harm human health or the
environment.
Short-term Effectiveness:
During the casings and soil excavation, dust may be generated.
Fugitive dust control procedures, e.g., wetting, may be required.
If dust generation is significant at the site, workers will be
required to wear personal protective equipment during activities
where they may be exposed. Exposure of the nearby community is
not anticipated.
There is the potential for erosion of the disturbed soils that
remain onsite, until the vegetation program becomes effective.
Erosion control measures will be implemented to minimize erosion
potential.
This alternative includes offsite transportation of contaminated
soil and casings. As the site is located in a rural setting and
there is an access to Interstate 78 within 2.3 miles of the site,
minimal community description due to vehicular traffic is
anticipated. The probability of a transportation accident is low.
If a transportation accident were to occur, it is unlikely that a
situation presenting a threat to public health and/or the
environment would result, due to the nature of the contaminated
material.
It is estimated that the excavation of the casings and soil
-27- 3 C
-------
and their removal will be completed one month after the remedial
contractor has mobilized at the site.
Long-term Effectiveness:
If all of the hazardous substances posing a threat to human
health and the environment are removed from the site, this threat
will be eliminated.
If the battery casings are recycled offsite, both the lead
and plastic associated with the casings will likely be recycled.
At the present time, the market for rubber casing material is soft.
This material could either be used as filler, burned for its EflU
value, incorporated into a rubberized asphalt roadway, or disposed
in a sanitary landfill, once it has been decontaminated by the
recycler.
Reduction of Mobility, Toxicity, or Volume:
Although this alternative does not include treatment of the
contaminated material (unless recycling is considered treatment),
the alternative will reduce the mobility of the lead contaminants
by placing them in a double-lined and multi-layer capped landfill
with a leachate detection system. Since treatment of the waste is
not a principal element of this alternative, Alternative 3 does not
meet the statutory preference for remedial actions that reduce
toxicity, mobility, or volume of the soil.
Implementabi lity:
The technologies proposed for this alternative are all
demonstrated and commercially available. No permits are anticipated
to be required for onsite activities. See CERCIA Section 121 (e).
EPA must obtain hazardous waste generator status for the site. The
soil and casings shipments must be manifested and transported by a
licensed hazardous waste transporter in accordance with the requirements
of 25 PA Code Sections 75.262 and 75.263, and the receiving RCRA
facility must be a permitted facility which satisfies the requirements
of CERCIA Section 121 (d) (3) and the CERCLA offsite policy, OSWER
Directive No. 9834.11, Nov. 13, 1987.
A water supply for dust control and disturbed soil vegetation
will need to be developed under this alternative.
Cost:
Estimated costs for potential remedial alternatives are
summarized in Table 4. Present worth cost estimates for Alternative
3 range from $3,525,000 to $4,487,000; the greater cost reflects
the additional cost of disposal of the battery casings if recycling
is impractical.
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Conpliance with ARARs:
The only contaminant-specific ARARs pertinent to the excavation
and offsite landfilling remedial alternative is the NAAQ standard
for lead, which is codified in the Clean Air Act of 1976 and the
Pennsylvania Air Pollution Control Regulations. As stated above,
water sprays are will be used to control fugitive dust emissions;
thus the accepted standard is not exceeded.
No location-specific ARARs will be activated by the proposed
remedial alternative.
Several action-specific ARARs will be applicable or relevant and
appropriate for this remedial alternative. All onsite workers must
meet the requirements of OSHA under 29 CFR, Parts 1910, 1926, and
1904. Additionally, worker exposure to air contaminants must be
kept below allowable concentrations (TLVs) set by the American
Conference of Governmental Industrial Hygienists (ACGIH). Erosion
control measures under the Pennsylvania Erosion Control Regulations,
PA Code Title 25, Chapter 102, must be taken to reduce erosion.
RCRA generator, transport, TSD, and possibly recycling provisions
will become action-specific ARARs for this alternative. See 25
PA Code Sections 75.262, 75.263. All offsite shipments must be
properly manifested, placarded, and transported by a licensed
hazardous waste transporter. The receiving facility(ies) must be a
RCRA interim status or permitted facility which satisfies the
requirements of the CERCEA offsite policy and CERdA 121(d)(3).
Any soils and debris left onsite must meet clean closure standards
pursuant to 25 PA Code Section 75.265(t).
The contents of the battery casings may exhibit the
characteristic of EP Toxicity (40 CFR Section 261.24) for lead. If
so, any land disposal will be subject to the land disposal
restrictions of RCRA Section 3004(g), 42 U.S.C. Section 6924(g).
To date, there are no land disposal restrictions applicable to
characteristics wastes such as EP toxic lead. The statutory
deadline for promulgation of such restrictions is May 1990. If
treatment standards are prorulgated prior to offsite disposal, the
disposal of EP Toxic battery casings and CERdA soil and debris
must meet the treatment standards.
The offsite disposal of battery casings and CERQA soil and
debris must meet the CERdA offsite policy, OSWER Directive No.
9834.11, Nov. 13, 1987 and CERdA section 121(d)(3).
Overall Protection:
Exposure to the battery casings and soil onsite will be
eliminated under this "clean closure" alternative. Therefore, the
risks associated with dermal contact and ingestion will be eliminated.
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State and Connunity Acceptance:
The State commented that the lead-contaminated soil should
be removed from the site; therefore, Alternative 3 is acceptable to
the State. The connunity has not commented on this alternative.
Alternative 4 - Excavation. Fixation, and Offsite Disposal
Alternative 4 is a treatment alternative. This alternative
involves excavating the contaminated material, fixing it with a
Portland cement- or lime-based method, and disposing the waste
matrix in an offsite sanitary landfill. This alternative will
eliminate the ingest ion and direct contact exposure pathways. The
battery casings will be excavated and shipped offsite for recycling.
Short-term Effectiveness:
Dust may be generated during the soil excavation, site preparation
and equipment setup, and landfill preparation. Fugitive dust control
procedures, e.g. , wetting, may be required. If dust generation is
significant at the site, workers will be required to wear personal
protective equipment during activities where they may be exposed.
Exposure of the nearby commity is not anticipated.
There is the potential cor erosion of the disturbed soils that
remain onsite, until the vegetation program becomes effective.
Erosion control measures will be implemented to minimize erosion
potential.
It is estimated that the casings and soil excavation, fixation,
and waste matrix disposal will be completed within three months
after the remedial contractor has mobilized at the site.
Long-term Effectiveness:
If all of the contaminated material posing a threat to human
health and the environment is excavated, fixed, and disposed in a
landfill offsite, this threat should be eliminated.
There are concerns about the long-term durability of the
fixation waste matrix. Lead, sulfate, and clays and silts have all
been reported in the literature as cement-setting retardants.
Difficulties from tflese materials should be overcome by adjusting
the cement/Vaste ratio upward to offset these effects.
If this remedial alternative is selected, bench-scale tests
should be conducted to ensure that the wastes can (1) be fixed
properly despite their large lead, sulfate, and clay and silt
contents, and can (2) withstand acidic and wetting/drying degradation.
The fixation waste matrix will be hauled to an offsite
landfill that tne State has permitted to accept this type of
waste. Permitted landfills are constructed with bottom liners
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that inhibit any leachate from entering the environment and are
capped with a liner to prevent rainfall infiltration from entering
the landfill. Tne landfill will provide long term protection from
potential degradation mechanisms, acidic attack, and wetting and
drying.
Reduction of Mobility, Toxicity, or Volume:
Treatment of the contaminated material is a principal element of
this alternative. Tne lead contaminants' mobility will be reduced
by placing the contaminants in a cement matrix, followed by
disposal in an offsite permitted municipal landfill. Since treatment
of the waste is a principal element of this alternative, Alternative
4 meets the statutory preference for remedial actions that reduce
toxicity, mobility, or volume.
Implementabi 1 i ty:
The technologies proposed for this alternative are all demonstrated
and commercially available. However, the proper ratio(s) of waste
to cementing materials and additives has yet to be determined.
Therefore, the long-term reliability of the fixation process has
not been demonstrated. If bench-scale testing is conducted
properly and appropriate safety factors applied (i.e., the
cement/waste ratio is conservatively selected) the cement matrix
should be durable in the long term.
No permits are anticipated to be required for onsite activities.
See CERCLA Section 121 (e). For the recycling of battery casings,
EPA must obtain hazardous waste generator status for the site.
Additionally, the casings shipments must be manifested and transported
by a licensed hazardous waste transporter, in accordance with the
requirements of FA Code Sections 75.262 and 75.263.
A water supply for dust control and the fixation process will
need to be developed under this alternative.
Cost:
Estimated costs for potential remedial alternatives are summarized
in Tablft.4. Present worth cost estimates for Alternative 4 range
from $6,073,436 to $6,884,652; the greater cost reflects the
additional cost of disposal of the battery casings if recycling is
impractic&l.
Compliance with ARARS:
The only contaminant-specific ARARs pertinent to the excavation
and off site landfilling remedial alternative is the NAW3 standard
for lead, which is codified in the Clean Air Act of 1976 and the
Pennsylvania Air Pollution Control Regulations. As stated above,
water sprays will be used to control fugitive dust emissions; thus
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the accepted standard is not exceeded.
No location-specific ARARs will be activated by the proposed
remedial alternative.
Several action-specific ARARs will be applicable or relevant and
appropriate for this remedial alternative. All onsite workers must
meet the requirements of OSHA under 29 CFR, Parts 1910, 1926, and
1904. Additionally, worker exposure to air contaminants must be
kept below allowable concentrations (TLVs) set by the American
Conference of Governmental Industrial Hygienists (ACGIH). Erosion
control measures under the Pennsylvania Erosion Control Regulations,
PA Code Title 25, Chapter 102, must be taken to reduce erosion.
The treatment of hazardous wastes in a mobile treatment unit
is subject to the tank requirements of RCRA Subpart J as applicable
and/or relevant and appropriate for design and operation of tanks,
40 CFR Sections 264.111 to 264.114, closure and post-closure care
requirements for tanks under 40 CFR Section 26.4.197 and 25 PA Code
Section 75.264(r); and RCRA closure and post-closure requirements
under 40 CFR Section 265 Subpart G and PA Code Section 75.265(o).
The solidification treatment process will result in changing
an EP toxic RCRA characteristic hazardous waste to a noncharacteristic
waste. The treated waste, which is nonhazardous, is not subject to
RCRA land disposal restrictions at the present time and will be
disposed of in a Subtitle D State permitted solid waste landfill.
Characteristic wastes will be restricted from land disposal
without prior treatment as part of the Hazardous and Solid Waste
Amendments, Land Disposal Restrictions (LDRs). The statutory deadline
to establish treatment standards for CERCLA soil and debris that
includes characteristic waste is May 1990. If the treatment standards
are promulgated prior to offsite disposal of the treated wastes from
this site, LDR will be an applicable requirement. The fixation
technology included as part of this alternative represents one of
the best available technologies for metals contaminated soils.
This technology must comply with the LDRs for characteristic wastes
once they are promulgated by either meeting the treatment standards
or by obtaining a treatability variance.
Th» offsite disposal of CERCLA soil and debris is subject to
the requirements of the EPA's Office of Solid Waste and Emergency
Response's (OSWER) Revised Procedures for Implementing Offsite
Response Actions Policy, OSWER Directive No. 9834.11, Nov. 13, 1987,
and CERCLA Section 12l(d) (3). EPA should make a determination that
there are no environmentally significant releases at the Subtitle D
landfill prior to the landfill's acceptance of the CERCLA nonhazardous
waste.
The contents of the battery casings may exhibit the
characteristic of EP Toxicity (40 CFR Section 261.24) for lead.
If so, any land disposal will be subject to the land disposal
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restrictions of RCRA Section 3004(g), 42 U.S.C. Section 6924(g).
To date, there are no land disposal restrictions to applicable to
characteristics wastes such as EP Toxicity lead. The statutory
deadline for promulgation of such restrictions is May 1990. If
treatment standards are promulgated prior to off site disposal, the
disposal of EP Toxic battery casings and CERCLA soil and debris
must meet the treatment standards.
The offsite disposal of battery casings must meet the
CERCLA Offsite policy, OSWER Directive NO. 9834.11, Nov. 13, 1987
and CERCLA section 121(d)(3).
Action-specific ARARs under RCRA, which are applicable to
offsite transportation of the battery casings for recycling are
RCRA transporter requirements in 25 PA code Section 75.263 and
75.263.
Any soils and debris left onsite must meet clean closure
standards pursuant to 25 PA Code Sections 75. 265 (o) and (t).
Overall Protection:
Exposure to the battery casings and soil onsite will be eliminated
under this alternative. Therefore, the risks associated with dermal
contact and ingestion will be eliminated.
This alternative will seal the waste materials in a cement casing;
and thereby reduce the EP toxicity of the lead in the soil. The
process of fixation will transform the soil frorr-, -. hazardous to a
solid waste. The material will then be transpoc --.-a offsite and
deposited into a Subtitle D state permitted landfill.
State and Community Acceptance:
The State requested that the lead-contaminated soil be removed
from the site; therefore, Alternative 4 is acceptable to the State.
The community has not contented on this Alternative.
Alternative 5 ~ Excavation. Acid Leachin, and Diso-<>
Alternative 5 is aigo a treatment alternative. This alternative
involves excavating the contaminated materials, leaching the lead
contaminants with fluosilicic acid in a mobile treatment unit,
and returning the leached ("treated11) soil to the site for disposal
on the ground surface.
The fluosilicic acid process involves pretreating the excavated
materials with an ammoniacal solution to convert lead oxides and
sulphate to lead carbonate, acid leaching the lead carbonate with
fluosilicic acid, electroplating the dissolved lead for recycling,
further leaching of the soil with nitric acid to remove metallic
lead, and wastewater treatment of the ammoniacal, fluosilicic acid
bleed, and nitric acid solutions. The soil may have to be neutralized
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prior to disposal. All wastewater will be hauled offsite for treatment
and disposal.
The alternative, if successful, will provide a "clean closure"
for the site. See 40 CFR Sections 265.111 and 265.258; 25 PA Code
Section 75.265(t). The ingestion and direct contact exposure pathways
will be eliminated. The battery casings will be shipped off site
for recycling.
Short-term Effectiveness:
The short-term effectiveness of this alternative depends on the
treatment and disposal of lead-contaminated waste streams from the
the acid leaching treatment process. The treatment and disposal of
the waste streams are included in the remedial alternative as offsite
activities.
Dust may be generated during the battery casings and soil exca-
vation, site preparation and equipment setup, and clean soil disposal.
Fugitive dust control procedures, e.g., wetting, may be required.
If dust generation is significant at the site, workers will be required
to wear personnel protective equipment during activities where they
may be exposed. Exposure of the nearby community is not anticipated.
It is estimated that the casings and soil excavation, leaching,
and "clean" material disposal will be completed within three months
after the remedial contractor has mobilized at the site.
Long-term Effectiveness:
4
If all of the contaminated soil and casings posing a threat to
human health and the environment is excavated and has its lead content
removed by leaching, the threat from this material should be eliminated.
It is currently anticipated that any "hazardous11 waste-bearing sludges
generated by the wastewater treatment process will be disposed of off-
site in an appropriate manner, eliminating any potential future onsite
risk from this material.
The likelihood that acid leaching will meet the remedial action
objectives at the site cannot be predicted. Fluosilicic acid leaching
has only been conducted at one site (the united Scrap Lead [USL] site
in Olio)1, and only on a bench scale (Phillips, 1988). The soil there
was generally much more contaminated than the HebelXa soil. Typically,
process recovery efficiencies are higher for more contaminated soils,
so the 99 percent recovery efficiency of bench-scale tests at USL may
not be directly transferable.
The Hebelxa soils probably have a higher silt and clay content
than the USL soils. It may prove harder to leach lead from soils with
a high clay content than other soils. This phenomenon was noticed
with ethylenediaminetetraacetic acid (EDIA), and was attributed to
binding strength and steric hindrance.
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The U.S. Bureau of Mines (USEM) reduced the soil lead concentration
to 400 irgAg in the bench-scale tests at USL. USBM believes the
remaining lead is metallic (from chips off the battery posts and grids),
and could be removed by leaching with a stronger solution of nitric
acid than that used in the bench-scale tests.
Typically, bench-scale testing under laboratory conditions give optimal
contaminant removal efficiencies. The lead removal efficiency in the
field at HebelJca may be much less than that experienced in the lab at
USL, especially if the clays and silts at HebelJca interfere with the
process.
Another potential problem is that existing mobile equipment may not
be designed to withstand fluosilicic acid. This acid is so strong
that it will dissolve glass. If existing equipment is not suitable
for this process, special equipment may have to be designed and built.
The most contaminated soil sample at HebelJca contained 65,100 mg/kg
lead. To reduce this concentration to 560 mg/kg lead, 99.1 percent
removal efficiency 'would be required. The average soil lead
concentration is much lower than the above figure. Of the 48 samples
where lead was positively detected at the site, the average lead
concentration was 1,692 mgAg. This figure includes samples with
lead concentrations below +•!••(? proposed remedial action levels. If
the average lead concentiac.-..-. of soil to be remediated is 2,000
mgAg, 72 percent removal efficiency would be required to achieve
soils concentrations of 560 mg/kg.
Intuitively, acid leaching with acids other than fluosilicic acid
should be effective on contaminated material with an average lead
content of 2,000 mg/kg. However, no references were identified in
the literature to provide a degree of confidence that the lead
remedial action level can be achieved by acid leaching with any
other acid. Benchscale tests should be performed prior to implementing
and acid leaching remedy at the HebelJca Site.
Reduction of Mobility, Toxicity, or Volume:
Treatment of the contaminated material is a principal element of
this alternative. The toxicity of the contaminated soil and casings
will be reduced by removing the majority of lead from than prior to
disposal back en site. The removed lead will either be electroplated
for recycling or precipitated for disposal in a secure landfill. .
Thus, tJ»volone of lead-contaminated material will also be substan-
tially reduced. The-toxicity, nobility, and volume of the precipitated
lead will be a function of the precipitation process selected. Since
treatment of the waste is a principal element of this alternative.
Alternative 5 meets the statutory preference for remedial actions
that reduce toxicity, mobility; or volume.
Implementabi lity:
As presented in this section, there are several unknowns associated
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with the technical feasibility of Alternative 5. It is uncertain
whether mobile equipment presently exists which is capable of handling
the strong acids proposed for this alternative. If inobile equipment
is not presently available, process equipment will have to be designed
and built.
It is unclear whether acid leaching will be able to achieve the remedial
objectives on a commercial scale. At a minimum, bench-scale testing
should be initiated prior to implementing this alternative, if selected.
Technical problems associated with designing an effective acid leaching
system could lead to schedule delays.
Acid leaching technology, especially the use of fluosilicic
acid, has not been developed into a commercial process yet. The
degree to which these processes are developed by the time remediation
is implemented is not predictable.
While acid leaching is used in the mining industry for copper and
uranium recovery, there is little acid leaching for hazardous waste
remediation experience in the United States (EDEA leaching has been
attempted on two site on a pilot scale). Therefore, there may be a
shortage of contractors willing to competitively bid on the
remediation contract.
No permits are anticipated to be required for onsite activities.
See CERCIA Section 121(e). For the recycling of the battery casings,
EPA must obtain hazardous waste generator status for the site.
Additionally, the casings shipments must be manifested and transported
by a licensed hazardous waste transporter in accordance with 25
PA Code Sections 75.262 and 75.263. A water supply for dust
control, the acid leaching process, and disturbed soil vegetation
will need to be developed under this alternative.
Cost:
Estimated costs for potential remedial alternatives are summarized
in Table 4. Present worth cost estimates for Alternative 5 range
from $11,153,000 to $11,212,000; the greater cost reflects the
additional costs of disposing the battery casings if recycling is
impractical.
Compliance with ARARs:
The only csntantinant-specif ic ARARs pertinent to the excavation and
offsite landfilling remedial alternative is the NAAQ standard for
lead, which is codified in the Clean Air Act of 1976 and the
Pennsylvania Air Pollution control Regulations. As stated above,
water sprays will be used to control fugitive dust emissions, so as
not to exceed the NAAQ standard.
No location-specific ARARs will be activated by the proposed remedial
alternative.
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Several action-specific ARARs will be applicable or relevant and
appropriate for this remedial alternative. Ml onsite workers must
meet the requirements of OSHA under 29 CFR, Parts 1910, 1926, and
1904. Additionally, worker exposure to air contaminants must be
kept below allowable concentrations (TLVs) set by the American
Conference of Governmental Industrial hygienists (ACGIH) . Erosion
control measures under the Pennsylvania Erosion Control Regulations,
PA Code Title 25, Chapter 102, must be taken to reduce erosion.
The treatment of hazardous waste in a mobile treatment unit
is subject to the tank requirements of RCRA Subpart J as applicable
and/or relevant and appropriate for design and operation of tanks,
40 CFR Sections 264.111 to 264.114, closure and post-closure care
requirements for tanks under 40 CFR Section 264.197 and 25 PA Code
Section 75.264(r), and RCRA closure and post-closure requirements,
40 CFR Section 265 Subpart G.
Residues remaining after treatment would be lead precipitates
and acid filtrate. Lead precipitates will be RCRA characteristic
waste (EP Toxicity) and must be disposed of in an off site RCRA
landfill. RCRA generator and transporter requirements would be
applicable, 25 PA Code Sections 75.262, 75.263. Acid filtrate may
be a hazardous waste and, if hazardous, will require treatment in
a RCRA facility prior to rJ:-r-..-il. Offsite treatment and/or disposal
of lead precipitates and acid filtrate will have to meet RCRA land
disposal restrictions, the RCRA Offsite Policy, OSWER Directive Mo.
9834.11, Nov. 13, 1987 and CERCLA Section 121 (d) (3).
The contents of the battery casings may exhibit the
characteristic of EP Toxicity (40 CFR Section 261.24) for lead. If
so, any land disposal will be subject to the land disposal
restrictions of RCRA Section 3004(g), 42 U.S.C. Section 6924(g).
To date, there are no land disposal restrictions to applicable to
characteristics wastes such as EP Toxicity lead. The statutory
deadline for promulgation of such restrictions is May 1990. If
treatment standards are promulgated prior to offsite disposal, the
disposal of EP Toxic battery casings must meet the treatment
standards.
The offsite disposal of battery casings must meet the
CERCLA Offsite policy, OSWER Directive No. 9834.11, Nov. 13, 1987
and CERCIA section 121(d)(3).
Any soils and debris left onsite must meet clean closure
standards pursuant to 40 CFR Section 265.258, 25 PA Code Sections
75.265(0) and 75.265(t).
Overall Protection:
Exposure to the battery casings and soil on site will be eliminated
under this alternative. Therefore, the risks associated with dermal
contact and ingest ion will be eliminated. Lead from the soil and
casings will be dissolved in an acidic solution under this remedy.
-------
This dissolved lead will either be electroplated and recycled, or
precipitated and disposed of in a secure landfill. In both cases
the lead will be removed from the site, allowing a "clean closure".
State and Community Acceptance:
The State and the community have not commented on this alternative.
Sunmarv of Comparative Analysis
Alternative 1, No Action, is not protective of human health and
the environment. Therefore, it should be eliminated from further
consideration.
Among remaining alternatives, all are expected to be protective.
However, all remaining alternatives are not expected to satisfy the
preference of CERCIA Section 121(b)(l) for permanent remedies. In
particular, Alternative 2, capping, and the disposal option of
Alternative 3 do not meet SARA'S direction for a permanent reduction
to toxicity, volume, or mobility. In comparison, Alternatives 4
and 5 reduce the toxicity and mobility of the lead. Alternative 4
has a slight disadvantage in that there is a dramatic increase in
volume from the fixation process.
Alternatives 4 and 5 both rate high in long term effectiveness
and permanence, as the lead-contaminated soil is permanently
immobilized or extracted. Similarly, alternative 3, offsite disposal,
is a permanent solution to the extent that the contamination is
placed in a RCRA landfill. The RORA landfill will keep the soil
dry, protected from acidic moisture, which is a condition that
would leach the lead from the soil.
All alternatives have acceptable short-term impacts. The main
concerns are dust and erosion. Protective measures can be designed
for the remediation process to safeguard against these potential
problems.
In addition, all alternatives would be designed to meet the
ARARs for the site and the contamination. The soil is a RCRA
Hazardous Waste but proper facilities and technology exist to handle
the contamination.
Alternative 2, capping, and Alternative 3, offsite disposal,
are the most implementable as they both use proven excavation and
construction techniques. The process could commence immediately
after designing the remediation and will conclude in approximately
6 to 12 months. In addition, the pool of contractors for this work
is large, which would create competitive bids. Alternatives 4 and
5 require design studies to identify the specific process for the
site. These studies would be bench- and pilot-scale and would be
conducted for volume and strength of the materials used in each
process. The design studies will cause a delay to the remediation
r; •:
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of the site and incur additional cost.
Generally, the comnunity has not expressed a preference for .v\y
particular alternative. Rather, they are concerned that the remedy
be effective and that adverse short-term inpacts on human health
during the remediation be prevented.
X. Selected Remedy
Ttie selected remedy for the HebeLka Auto Savage Yard is
Alternative 4: Excavation, Fixation, and Offsite Disposal.
The selected remedy comprises:
Removal of the battery casings from the property and
recycling the casings. If recycling is impractical,
the casing will be disposed in a RCRA landfill.
Excavation of lead-contaminated soil, fixation of the
soil, utilizing a cement- or lime-based fixation process,
and depositing the fixation matrix in a Subtitle D State
permitted municipal landfill.
Soil backfill and revegetation.
Alternative 4 achieves the best balance in meeting the evaluation
criteria. For this alternative, a treatment facility will be con-
structed at the site to fix the contaminated soils. A typical
process for treating soils consists'of mixing the soils with a
cement-like fixative (cement, pozzolan, lime, clay), a reducing
agent, and various proprietary chemicals. The actual additive com-
position and its ratio will be determined by pilot-testing during
the design phase.
As required by Section 121 of CERCLA, Alternative 4 is protective
of human health and the environment, reduces the volume and toxicity
of contamination, will be designed to attain ARARs, and utilizes
permanent solutions and alternate treatment technologies to the
maximum extent practicable. In addition, the selected remedy satisfies
the statutory preference for employing treatment which significantly
reduces the mobility,, toxicity and/or volume of hazardous substances
as a principal element. This alternative is a cost-effective solution
in that it achieves the Remedial Action Objectives and meets the
best balance of evaluation criteria at the least cost.
This alternative achieves a long-term, permanent solution and is
readily implementable. It should be noted that Alternative 5 would
be similarly effective but would be twice as expensive. Alterna-
tives 2 and 3 do not provide the reduction in toxicity, volume
and/or mobility that Alternative 4 does.
The draft Feasibility study for this site describes Alternative
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4 as including the construction of an onsite landfill for the final
disposal of the fixation matrix. The State of Pennsylvania cormented
that the fixation matrix should !oe disposer.! in a landfill permitted
to accept such waste. In this Record of Decision, EPA has included
the State's contnents and has therefore chosen as part of the selected
alternative the offsite disposal of the fixation matrix in a State
Subtitle D permitted landfill.
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/16/86.
2) "Proposal of Update 4," Federal Register, dated 9/18/85.
3) Memorandum to 0. S. EPA from Mr. Can* Lucaro regarding community relations
at Superfund Enforcement sites, dated 8/28/8S.
4) Groundvater Contamination and Protection, undated by Mr. Donald V.
Feliclano on 8/28/85.
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. Virtaa Redeman and Mr. Gene Lucero re: Policy on Ploodplalns and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6) Guidance on Remedial Investigations under CERCLA, dated 6/85.
7) Guidance on Feasibility Studies under CE1CLA. dated 6/85.
8) "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGrav entitled "Community Relations Activitaa
at Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2," Pederal Register, dated 10/15/84
11) EPA Groundvater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmlttal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
13) "Proposal of Update 1," federal Register, dated 9/8/83.
14) Community Relation! in Superfund: A Handbook (interim version), dated
9/83.
IS) "Propeeel of First fatlonal Priority List." Federal Register, dated
12/30/il^
16) -Expanded Eligibility List," Federal Register, dated 7/23/82.
* •
17) "Inter!* Priorities List," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System A User's Manual
(undated).
19) Pield Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located la EPA Region III office. 3 C
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HEBF.r.ftfl
ADMINISTRATIVE PPrQRD FILE *
INDEX DP DOCUMENTS
SITE IDENTIFICATION
preliminary Assessment/Site Inspection Reports
1) Report: Potential Hazardous W?ste Site. Preliminary
Assessment. Hebelka property, prepared by Mr. James A.
Dolan, Pennsylvania Department of Environmental Resources,
6/24/85. P. 1-15.
2) Report: Sj,te Inspection of Hefrelka Property, prepared by
NUS Corporation, 11/7/85. P. 16-224. References are listed
on P. 94-95 and 222-223.
3) Memorandum to Ms. Vickie Province, U.S. EPA, from Mr. Mrinal
K. Biswas, Roy P. Weston, Inc., re: Hebelka Property - Trip
Report, 4/30/87. P. 225-233.
Correspondence and Supporting Documentation
1) Letter to Mr. Joseph Hebelka from Mr. C. f. Gitschier,
Pennsylvania Bureau of Land Protection, re: Notice of
violation, 7/3/78. P. 1-2.
2) Letter to Mr. George J. Kanuck, Esq., Worth Law Offices,
from Mr. Carl P. Gitschier, Pennsylvania Bureau of Land
Protection, re: Meeting scheduled for October 4, 1978,
9/25/78. P. 3-3.
3) Letter to Mrs. Lovie Hebelka from Mr. Michael G. Maiolie re:
Transmittal of the laboratory analysis for the sample taken
on October 20, 1982, 1/5/83. P. 4-5. The laboratory
analysis is attached.
4) Letter to Mrs. Lovie Hebelka from Mr. Michael G. Maiolie re:
Results of the laboratory analysis for the soil sample taken
adjacent to the pile of battery cases, 3/3/83. P. 6-6.
* Administrative Record Pilt available 2/28/89.
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
6?.
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ENFORCEMENT PLANNING
potentially Responsible Party General Correspondence
1) Letter to Mr. Daniel Dellicker, East Penn Manufacturing
Company, from Mr. Thomas C. Voltaggio, U.S. EPA, re: 104(e)
information request, 12/12/83. P. 1-2.
2) Letter to Mr. Peter W. Schaul, U.S. EPA, from Mr. Daniel G.
Dellicker, East Penn Manufacturing Company, Inc., re:
Involvement with disposal of waste materials at the Hebelka
property, 12/22/83. P. 3-5. The 104(e) information request
is attached.
3) Letter to Ms. Patricia Tan, U.S. EPA, from Ms. Rebecca
White, GCA Corporation, re: Identifying additional
potentially responsible parties, 4/17/86. P. 6-7
4) Letter to Mr. Donald A. Wojton, East Penn Manufacturing
Company, Inc., from Mr. Bruce P. Smith, U.S. EPA, re:
Notice letter, 5/20/86. P. 8-14. A letter regarding East
Penn Manufacturing Company involvement with disposal of
waste materials at the Hebelka property, an envelope, and a
104(e) information request are attached.
5) Letter to Ms. Patricia M. Tan, U.S. EPA, from Mr. Wallace
Putkowski, Carbon Service Corp., re: Information in reply
to a letter dated June 18, 1986, 6/25/86. P. 15-19. An
envelope, a certified mail receipt, and a 104(e) information
request are attached.
6) Handwritten letter to Ms. Tan [sic] from Ms. Lovie M.
Hebelka re: Records pertaining to the dumping of
battery casings, 9/19/86. P. 20-34. The following are
attached:
a) an envelope;
b) an information request letter addressed to Ms.
Lovie Hebelka;
c) two certified mail receipts;
d) a notice letter addressed to Ms. Lovie Hebelka;
•) a letter regarding involvement with Reeser's
Landfill;
f) an envelope;
g) two certified mail receipts;
h) a 104(e) information request letter addressed
to Ms. Lovit Helbelka.
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7) Letter to Mr. Richard Bernhard, Wolff Petroleum Equipment
Service, from Mr. Bruce p. Smith, U.S. EPA, re: 104(e)
information request, (undated). P. 35-48. The following
are attached:
a) a certified mail receipt;
b) an envelope;
c) a letter in response to the 104(e) information
request letter;
d) seven transfer documents.
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REMEDIAL RESPQNS^ PLANNING
Work Plans
1) Report: Statement of Worlc f?r Soil Borings and
Installation at the Hebellca gifce. Lehioh County. PenniSyl-
vania prepared by Mr. George J. Latulippe, NUS Corporation,
6/87. P. 1-61.
2) Report: Statement of Work for Surveying and Topographic
Mapping Seryices at the flebflka Site, Lehiqh County.
Pennsylvania prepared by Mr. George J. Latulippe, NUS
Corporation, 6/87. P. 62-122.
3) Report: Final Field Operations Plan. RI/PS, Hebelka
Weisenberg Township. Lehigh County . Pennsylvania, prepared
by Mr. George J. Latulippe, NUS Corporation, 7/87. P. 123-
236.
4) Report: Final Work Plan „ Remedial Investigation/Feasibility
Study* Hebelka Site, Weiaenbqrg Township. Lehiqh C.PuntYi
Pennsylvania,, prepared by Mr. George J. Latulippe, NUS
Corporation, 7/87. P. 237-346. References are listed on P.
346.
5) Memorandum to Mr. Francis Burns, U.S. EPA, from Ms. Theresa
A. Simpson, U.S. EPA, re: Transmit tal of the Quality
Assurance Review for the Hebelka Site Field Operations Plan,
7/13/87. P. 347-366. The Plan is attached.
«
6) Memorandum to Mr. Francis Burns, U.S. EPA, from Ms. Theresa
A. Simpson, U.S. EPA, re: Transmittal of the Quality
Assurance Review for the Hebelka Site Final Field Operations
Plan, 8/12/87. P. 367-385. The Plan is attached.
Remedial Investigation/Feasibility Study Reports
1) Reports Draft Remedial Investigation Report. Volumes I-II.
Hebelka Site. We is anbury Township. Lehigh County. Pennsyl-
vania. prepared by Mr. George J. Latulippe, NUS Corporation,
4/88. P. 1-452. References are listed on P. 158-160 and
452. The Laboratory Chemical Analytical Data is presented
in Appendix 0.
2) Repoitt Draft Feasibility Study. Hebelka Site. Waiaenburg
Township. Lehigh County. Pennsylvania, prepared by Mr.
George J. Latulippe, NUS Corporation, 6/88. P. 453-646.
References are listed on P. 581-585. The Detailed Analysis
of Alternatives is presented in Section 4.
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Health Risk/E^dangerment Assessment
1) Letter to Mr. Abraham Ferdas, U.S. EPA, from Mr. Stephen D.
Von Allinen, U.S. Department of Health and Human Services,
re: Transmittal of the draft Preliminary Health Assessment
for the Hebelka Site, 11/8/88. P. 1-10. The draft
Preliminary Assessment is attached.
Correspondence and Supporting Documentation
1) Notice of Receipt to Ms. Patricia Tan, U.S. EPA, from Ms.
Barbara J. Gontz, Pennsylvania Department of Environmnetal
Resources, re: Hazardous Substance Response Trust Fund,
6/10/86. P. 1-3. A letter regarding the proposed Superfund
project to be funded by the U.S. EPA is attached.
2) Memorandum to Mr. Fran Burns, U.S. EPA, from Ms. Kathryn
Davies, U.S. EPA, re: Review of Preliminary Workplan,
5/15/87. P. 4-4.
3) Memorandum to Mr. Fran Burns, U.S. EPA, from Ms. Kathryn
Davies, U.S. EPA, re: Review of Hebelka Draft Remedial
Investigation/Feasibility Study Workplan, 6/18/87. P. 5-6.
4) Letter to Mr. Richard C. Evans, EBASCO Services Incor-
porated, from Mr. Fran Burns, U.S. EPA, re: Comments on
the Hebelka Draft Work Plan, 6/25/87. P. 7-9.
5) Memorandum to Mr. Fran Burns, U.S. i?A, from Mr. H. Ronald
Preston, U.S. EPA, re: Comments on the Hebelka Draft Work
Plan, 7/6/87. P. 10-10.
6) Memorandum to Mr. Francis Burns, U.S. EPA, from Mr. Robert
C. Runowski, U.S. EPA, re: Comments on the Hebelka Draft
Work Plan, 7/9/87. P. 11-13. A Routing and Transmittal
slip is attached.
7) Letter to Mr. Fran Burns, U.S. EPA, from Mr. Charles J.
Kulp, United States Department of the Interior, res
Comments and questions on the Draft Work Plan for the
Hebelka Site, 7/13/87. P. 14-15.
8) Memorandum to Mr. Fran Burns, U.S. EPA, from Mr. Tim
Sheehan, Pennsylvania Department of Environmental Resources,
res Transmittal of comments on the Draft Work Plan for the
Hebelka Site, 7/20/87. P. 16-20. The comments on the Draft
Work Plan and a Pennsylvania Department of Environmental
Resources receipt are attached.
9) Memorandum to Mr. Francis Burns, U.S. EPA, from Mr. Peter
Stokely, U.S. EPA, res Hebelka Site Visit, 6/14/88.
P. 21-22.
5
60
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CONGRESSIONAL CpRRESPONDENCE
1) Letter to Mr. William C. Bucciarelli, Pennsylvania Depart-
ment of Environmental Resources, from Representative William
J. Klingaman, Jr., State of Pennsylvania House of Represen-
tatives, re: Transmittal of a letter concerning the
condition of the junkyard owned by Mr. Joseph Hebelka,
4/14/78. p. 1-2. The letter is attached.
2) Letter to Mr. Reynold G. Reinert, Weisenberg Township, from
Representative William K. Klinaman Jr., State of Pennsyl-
vania House of Representative, re: Action taken in
connection with the "Highway Beautification Act of
1965," 4/14/78. P. 3-3.
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Rela
1) Report: Revised Final Conumjnitv Relations Plan. Hebelka
Site. Weisenbe.rq Township. Lehigh County. PennaylYan^-a«
prepared by Ms. Carrie C. Dietzel, EBASCO Services, Inc.,
3/17/88. P. 1-18.
4C
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EPA WORK ASSIGNMENT NO. 120-3LJ4
CONTRACT NO. 68-01-7250
EBASCO SERVICES INCORPORATED
DRAFT
RESPONSIVENESS SUMMARY
HEBELKA AUTO SALVAGE Y;_?D SITE
WEISENBERG TOWNSHIP
LEHIGH COUNTY, PENNSYLVANIA
MARCH 1989
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This Responsiveness Summary documents concerns and comments
regarding proposed remedial actions for the Hebelka Auto Salvage
Yard Site as the comments and concerns were expressed to the US
Environmental Protection Agency (EPA) by members of the
community surrounding the site. The remarks were presented
during the public comment period, and they addressed EPA's draft
Remedial Investigation/Feasibility Study (RI/FS) report and a
Proposed Plan to remediate contamination associated with two
piles of battery casings located on site. In addition to
summarizing public comments, this document also summarizes EPA's
responses to the comments and concerns expressed.
The Responsiveness Summary is organized as follows:
1.0 Overview
2.0 Summary of Community Involvement
3.0 Summary of Comments and Responses Regarding the
Proposed Plan for Hebelka Auto Salvage Yard Site
4.0 Remaining Concerns
Attachments:
A. List of Community Relations Activities
B. EPA Fact Sheet - Hebelka Auto Salvage Yard
1.0 OVERVIEW
The public comment period for the Hebelka Auto Salvage Yard Site
began on February 23, 1989, and extended to March 26, 1989. At
the request of legal counsel for the Hebelka family, and to
facilitate public commenting, EPA held a public meeting at the
Weisenberg Township Municipal Building in Fogelsville,
Pennsylvania on March 23, 1989. Approximately twenty members of
the public attended, and from the general tone of the meeting,
most of these appeared to be members or supporters of the
Hebelka family.
At the meeting, EPA discussed the Superfund process, the
availability of site-related documents, and the purpose and
duration of the public comment period. A technical
presentation, describing the Remedial Investigation (RI) and its
results, was also presented. EPA explained that the focus of
the Agency's Proposed Plan was the battery-casing piles located
onsite and the extremely high levels of lead contamination found
in underlying and adjacent soils. EPA also explained that
additional sampling of offsits surface water and sediment will
be conducted in the near future to determine whether lead
contamination from the site has migrated beyond the site
boundaries.
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The preferred alternative outlined by EPA for addressing the
battery casings and associated lead contamination would involve
removal of the battery casings, excavation of contaminated soil,
fixation of contaminated soil with a cement-like bonding agent,
and disposal of the stabilized soils at a permitted, offsite
landfill. An attempt would also be made to recycle the battery
casings; however, if this should prove to be impossible, the
casings would be disposed at a permitted hazardous waste
landfill. This alternative would meet federal Superfund
requirements by permanently reducing the volume of contaminated
materials at the site and by decreasing the mobility and
toxicity of the contaminated soils to levels that meet public
health and environmental standards.
2.0 SUMMARY OF COMMUNITY INVOLVEMENT
In 1986, the Hebelka Auto Salvage Site was proposed for
inclusion on the National Priorities List, and the EPA published
public notices in the most widely read local newspapers to alert
members of the community concerned. Neither EPA nor local
officials recall receiving any inquiries about the site.
Interviews with residents, whose properties adjoin the site,
were conducted by EPA ir. j-ci 1987. At that time, varying levels
of site awareness were revealed ranging from no knowledge of the
site to concerned awareness. Most residents stated that they
would like to be apprised of site-related developments and of
the project schedule. No citizens' groups developed to monitor
site-related activities. Local officials' concerns, in
mid-1987, focused on the remedial project schedule and the
potential future-use restrictions that may encumber the site
following cleanup activities.
3.0 SUMMARY OF COMMENTS AND RESPONSES RBQARDINO THE PROPOSED
PLAN FOR THE AUTO BALVAQB YARD 8IT1
This section summarizes issues and concerns expressed by the
public and EPA's responses to then. The issues and concerns
raised v«r* considered by EPA in the final decision-making
process associated with the selection of a remedial alternative
to address ths onsite battery-casing piles and related
contaminants. All of the comments summarized below were
presented during the question-and-answer portion of the public
meeting, and more than 70 percent of them were presented either
by individuals with the surname Hebelka or by legal counsel for
the Hebelka family.
Comments and concerns were grouped into the following general
categories :
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A. Cost/Necessity of Proposed Remediation
B. Extent of Contamination and Pathways of Migration
C. Possibility of Contaminant Sources Unrelated to Hebelka
Site
D. The Proposed Remedial Alternative
E. Risks Associated with the Site
F. Liability Associated with the Site
G. EPA Superfund Program
A. Cost/Necessity of Proposed Remediation
Numerous statements were made by the Hebelkas, their attorney,
and other area residents regarding projected costs associated
with the Superfund remediation of the Hebelka site and the
nearby Reesers Landfill site:
1) Comment: EPA has spent $1 million on the Reesers site,
located half a mile from the Hebelka site, and
approximately $600,000 on the Hebelka RI/FS.
Implementation of the Proposed Plan at the Hebelka site
is expected to cost an additional $5 million, yet it is
uncertain that the remedial actions will improve
conditions. Several individuals said this was too much
money to spend without a guarantee of benefit and with
no clear determination that contamination is actually
migrating from the battery casings. They questioned
whether it represents responsible use of taxpayers'
money to address problems that are merely "potential"
problems.
m
EPA Responses It is not true to say that implementation
of the Proposed Plan for the Hebelka site will not
guarantee benefit. The preferred alternative would
eliminate the battery casings and the lead-contaminated
soil from the site, and consequently, health risks
associated with the site would be reduced. The lead
concentration levels in onsite soils are very high—up
to 60,000 parts per million—and are potentially
dangerous. They cannot be allowed to remain at the site
because, in addition to posing a risk of exposure now,
there is no way of knowing how the site may be used in
the) future. There is no way to assure that future users
of the site will not be threatened by lead
contamination, if it is allowed to remain in its present
.location.
EPA will conduct additional surface water, sediment, and
groundwater sampling in the Spring to determine whether
site-related contaminants are migrating from the site,
as suspected. The monies in the Superfund that will be
utilized are the result of a tax on the petrochemical
industry and not on local residents.
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2. Comment: A resident said that $5 million is a lot of
money, and he inquired how the money will be spent and
whether cleanup activities could be performed more
economically by a private company, or by the site
owners, than by the EPA.
EPA Response: The reason implementing the Proposed Plan
will cost so much money is that the Hebelka site is a
hazardous waste site. Workers involved in the
implementation activities require proper protective
clothing and equipment. In addition, only a few
companies are permitted to haul or dispose hazardous
wastes, and in order to secure and maintain their
permits, these companies must meet and sustain specific
federal, state, and local requirements. They must also
perform monitoring and testing procedures and upgrade
their facilities and services, as requirements change
and technology advances. Consequently, the cost of
using services and facilities that can handle hazardous
wastes is high.
EPA hires private companies to conduct remedial
activities, but the majority of the cleanup cost is for
the handling and stabilization of the lead-contaminated
soil, rather than for removal of the battery casings.
This makes it unlikely that costs can be reduced
significantly.
3. Comment: The Hebelka'a attorney charged that EPA is
acting irresponsibly in making cleanup decisions without
considering the financial burden it may be placing on an
individual responsible party and indicated that he
believed the no-action alternative is intended to
present EPA the option of doing nothing, rather than
sacrificing responsible parties to financial ruin. He
inquired what limitations are placed on remedial costs.
EPA's Response: There is no authority written into the
laws governing Superfund that says the financial
responsibility of the Potentially Responsible Parties
(PRP») Bust be considered before EPA takes remedial
action. EPA is considering actions for the Hebelka site
because of the- high concentrations of lead found in the
soil* Whether or not the site currently poses a public
health risk, it poses an environmental risk, and the
Agency will spend whatever is necessary to clean it up.
B. Extent of Contamination and Pathways of Migration
1. Comment: Two residents inquired if EPA had sampled
sediment upstream of the site and whether the Agency
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planned to sample the groundvater used by residents of
Haafsville, a community located about a quarter-mile
downgradient of the site.
EPA Response: EPA is not going as far as Haafsville at
this time, but the Agency intends to do additional
sampling downgradient from the Hebelka property. If no
contamination is revealed, there would be no reason to
sample any further. Filtered groundwater samples taken
to date have been clean, and there is no current concern
for the groundwater.
Upstream samples revealed no significant lead levels in
the sediments.
Comment: The Hebelka family's attorney asked several
questions regarding whether EPA could show a definite
link between the site and elevated lead levels in
offsite sediments located downstream. He contends that
the lead from the battery casings is immobile, that it
does not leach, and that site-related literature
indicates there is no actual problem.
EPA Response: There is contamination. In addition to
onsite soil contamination, EPA found elevated lead
levels in sediments of Iron Run and in an unfiltered
groundwater sample. As there are no other known sources
of lead contamination in the area, the Hebelka site is
most likely the source of the Iron Run sediment
contamination, but a definite. cr-,r.action has not yet
been established.
There is definitely a problem associated with the site
or the project would not be continued. The levels of
lead in soils and sediment exceed the action levels
established by the Agency for Toxic Substances and
Disease Registry (ATSDR) and by the Centers for Disease
Control (CDC). EPA must, therefore, take action.
Although the lead found in the soil is primarily located
within 30 to 60 feet of the battery casing piles, EPA
believes additional sampling is required to the. west of
tn>« waste piles. The lead does not appear to have
leached much over time; however, lead is more mobile in
an acidic environment, such as that at the site, and' the
potential for lead to migrate is real. EPA believes
that contamination of the Iron Run sediments indicates
that lead from the site has migrated in the past. If
so, it could migrate again. In addition to leaching,
lead could become airborne in dust, if a dry season
occurred. Then it might be inhaled by humans.
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3. Comment: A member of the Hebelka family suggested that
EPA is being dishonest in saying that upstream sediments
revealed no significant lead levels. He stated that
contamination cannot be established by degree: medium is
either contaminated or it isn't.
EPA Response: The question of contamination is a
question of degree. In drinking water, the Federal
guidelines state that water containing more than
50 parts per billion is unsafe.
C. Possibility of Contaminant Sources Unrelated to the Hebelka
Site
1. Comment: At numerous times during the public meeting,
the question was raised, by the Hebelkas and their
attorney, that sediment contamination in the Iron Run
may be related to runoff from nearby Route 22 because
motor vehicle emissions contain lead. The attorney
reminded EPA that lead was also found in an unfiltered
groundwater sample from a well located in an area
adjacent to Route 22.
EPA Response: It is true that motor vehicles emit
lead. However, EPA believes that the lead levels found
in the sediment and the unfiltered groundwater are too
high to be attributed to highway runoff. Nevertheless,
EPA will conduct additional sampling to determine if
there is a connection between the contaminated media and
highway runoff.
2. Comment: The Hebelka family's attorney questioned EPA
about a groundwater monitoring well located near a
culvert that directs water from an intermittent stream
under the roadway to Iron Run. He suggested that
groundwater test results from the well, which indicated
no evidence of contamination, also suggest that surface
water running from the battery casing piles through the
stream is clean.
E9& Response: The groundwater well does not indicate
th« condition of the surface water. What EPA has said
is that sediment downstream of the culvert exhibits
elevated lead levels and that it could only arrive at
that location via the surface water.
3. Comment: The Hebelka's attorney and a family member
suggested that if contaminants have migrated from the
battery casing piles, they have done so because of EPA
activities during the RI/FS when a bulldozer was
brought onsite to move some of the casings, and a well
was subsequently installed in the contaminated soils.
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EPA Response: When EPA works on a site, specific safety
precautions are initiated before any work is performed,
and all equipment is decontaminated before it is removed
from the site.
D. The Proposed Remedial Alternative
1. Comments A resident wanted to know the volume of
contaminated soils that EPA intends to remove from the
site and what will be used for fill. Another resident
wondered if groundwater monitoring would be conducted
after the remedial activities concluded.
EPA Response: EPA plans to excavate approximately 4,000
cubic yards of contaminated soils. Clean fill of a type
similar to the soils removed will be used for backfill.
Groundwater monitoring will continue to ensure that no
lead is present.
2. Comment: A resident wanted to know whether EPA might
consider a "dry stream" as a remedial alternative. The
family attorney asked if the remedial alternative was
final and what would be used to bond the soil.
EPA Response: A 'ary stream1* alternative would not
work. A battery company wouldn't be able to extract
enough lead from the soil to make it a profitable
venture.
EPA has not yet finalized the remedial alternative
selection. The Agency issued a Proposed Plan on
February 24th and is currently conducting a public
comment period. All comments received during that time
will be considered in the decision process.
The remedial alternative proposed by EPA will bond
contaminants in the soil with a cement-like mixture.
The precise proportions of this mixture, soil, and lime
will be determined during treatability studies.
E. Risks Associated with the Site
Cosmeat: Two residents were interested in human health
risks and the Hebelka's attorney asked what risk the
site actually poses. One of the residents wondered how
many people might be harmed by the Hebelka site over the
next 100 years, while the other asked what quantity of
contaminated soil would have to be consumed to represent
a significant risk.
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EPA Comment: The risk to human health from lead
contamination in its present form at the site is from
direct contact and subsequent ingestion, particularly by
children, and from inhalation of lead-laden dust during
dry periods. Lead is known to cause central nervous
system disorders and is especially hazardous to young
children.
For additional information regarding toxicity and human
health, write or call Dr. Richard Brunker at the EPA
address given on the fact sheet distributed to each of
you.
2. Comment: Several persons suggested that air pollution,
lead water lines in the city supply system, and auto
accidents pose a greater risk to human health than the
Hebelka site. They concluded that it would be wiser to
spend money on these problems than on the Proposed Plan
implementation.
EPA Response: Superfund is not meant to address those
problems. There are other programs that do address
issues such as clean air and lead in drinking water.
Superfund was created by a very significant tax levied
against the petrochemical industries and it is meant to
be used for toxic waste site remediation. It cannot be
used otherwise.
3. Comment: A resident asked if EPA equates Hebelka with
Love Canal, and the Hebelka family attorney suggested
that it is just as likely that, at some point in the
future, developers may disturb the landfill site in
which EPA is proposing to dispose excavated soils, as it
is that those soils may be disturbed if left onsite.
EVA Response: Hebelka is not a Love Canal, but the
premise is the same. Site accessibility is not
necessarily limited to what can be done in this decade.
In the present time, facilities used for hazardous waste
disposal must be licensed to accept hazardous waste and
permitted by the states in which they are located.
Therefore, the city, the county, the state, and the
facility owner and operator all have records of the
facility. These facilities are permanently recorded,
and the information accompanies their deeds.
F. Liabilities Associated with the Site
1. Comment: Numerous residents expressed concerns regarding
the Hebelka family's liability associated with the
8
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site. They stated that it was unfair to hold the family
responsible for the site when the hazards associated
with the disposal of batteries was unknown during the
years when the site was active. Some residents
suggested that EPA should be pursuing the manufacturers
of the batteries. One resident said that battery
manufacturers should be required to recycle old
batteries.
EPA Response: Liability issues are handled by the
Department of Justice (DOJ) and specific negotiations
between DOJ and the responsible parties are
confidential. Superfund does allow EPA to attempt to
recover remedial costs, and site owners can be held
liable. The status of negotiations concerning the
Hebelka family are between their attorney and DOJ and
are unknown to EPA remedial and community relations
personnel.
The Agency has attempted to find out which companies
manufactured the batteries disposed on site, but there
are no records to help to locate those manufacturers.
Responsible Parties (RPs) under Superfund can include
site owners and operators, manufacturers and generators,
and haulers who brought materials to a site. EPA may
pursue any and all of these for cost recovery, but a
link must be established between the site and each RP.
No such links have been found for the Hebelka site.
«
2. Comment: Residents asked if the Hebelkas or the local
community would be billed for the site cleanup and if
EPA could take the Hebelkas' property, if costs exceed
the property value.
EPA Response: The Hebelkas' liability is not known to
those of us present. It is a DOJ issue, but the local
community will not be held liable. Site remediation
costs far exceed property value, but EPA does not take
title to property. Costs are covered by the Superfund
and those costs not recovered are absorbed by the fund.
3. Comment: A Hebelka family member asked if EPA has a
current lien against the property and what restriction
will be placed on the deed after cleanup activities
conclude. He also asked if there will be ongoing
maintenance requirements. The family lawyer asked if
the EPA spokesman would recommend the family join other
litigants, if a lien has been placed against the
property.
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EPA Response: Although the EPA spokesman stated that a
lien is likely, he was unable to state positively if one
exists. He again recommended contacting the DOJ
regarding both the lien and future litigation.
Regarding deed restrictions, there should not be any
because the contaminated soils and the battery casings
will be removed from the site. The site will be
considered clean under Superfund and any maintenance
that may be needed will be the state's responsibility.
G. The Superfund Process
1. Comment: Several questions were asked about general
liability under the Superfund law. Residents wondered
if a person could be held liable for a hazardous waste
site that existed prior to that person's acquisition of
the property.
EPA Response: The site owner is always potentially
responsible, but EPA tries to identify and locate as
many RPs as possible.
2. Comment: A family member inquired how the Hebelka
property was first identified as a possible Superfund
site and whether EPA was intending to address all farm
dump sites under the program. The number of sites under
Superfund investigation was also requested.
EPA Response: The details associated with listing the
Hebelka site on the NPL were unknown to the EPA
spokesman. He stated, however, that once a site is
brought to EPA attention it must be investigated on its
individual merits. Sites are not compared, and the
total number does not affect the listing of new sites.
Thirty-thousand sites are currently under investigation
for possible NPL inclusion, but they are not all farm
sites. In addition to Superfund, the federal government
operates other programs that address situations which
may affect public health or the environment.
3. Coament: The Hebelka family's lawyer inquired what
would happen if additional contamination is found in
Iron Creek after the site is considered to be clean. He
also asked whether EPA is required to weigh the risks
associated with any site against those posed by other
sites.
EPA Response: Superfund would allow EPA to deal with
the contamination at that time, but EPA intends to avoid
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the situation by performing an additional round of
sampling to establish whether the presnt contamination
in the creek is, in fact, coming from the Hebelka site
or from the highway.
Superfund does not require that the risks posed by
various sites be compared. Site remediation is based
only on the significance of the risk at the site, and
that is determined according to established criteria.
4.0 REMAIMINQ CONCERNS
Members of the Hebelka family stated that they believe EPA has
erred in placing their property on the Superfund list and
charged that the Agency has singled out their property rather
than pursue "real problems." One family member requested that
it be entered into the record that the family intends to
litigate.
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ATTACHMENT A
LIST OF COMMUNITY RELATIONS ACTIVTTTFS
The following activities were conducted for the Hebelka Auto
Salvage Yard Site:
o EPA published notices in local newspapers announcing
proposal of the Hebelka site to the NPL - 1986.
o EPA conducted interviews with local residents and officials
to determine the level of public interest and concern -
July 1987.
o A Community Relations Plan, based on the community
interviews was developed - August 1987.
o A Proposed Plan, discussing the RI/FS and EPA's preferred
alternative was presented to the public - February 1989.
o Public Announcements of the Proposed Plan and a Public
Meeting were published in local newspapers - February 1989.
o A Public Meeting was held - March 1989.
o A Public Comment Period regarding the Proposed Plan was
held - February 1989 to March 1989.
o An Official Transcript and a Responsiveness Summary
concerning the Public Meeting were prepared - March 1989.
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ATTACHMENT B
SUPERFUND FACT SHEET
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SUPERFUND PROGRAM TACT SHiiET
I'-S. ZPA HE5ELKA AUTO SAL'/AG
I1ARCH 1989 LEHIGH COUKTY, PENN
Introduction
The U.S. Environmental Protection Agency (EPA) has released for
public comment, a draft Remedial Investigation/Feasibility Study (tCl/FS)
for the Kebelka Auto Salvage Yard in Weisenburg Township, PA. Based on
these reports, EPA in consultation with the Commonwealth of Pennsylvania,
has recommended the remedial alternative that it believes will work nose
effectively At the Hebelka Auto Salvage Yard.
Site Background
The Hebelka property occupies approximately 20 acres within the head-
waters on the Iron Run subdrainage basin. Topographically, the property
is positioned on the south site of a low, moderately steep hill north of.
Interstate Highway 78 and Old Route 22 (the two highways parallel each
other running generally east-west) approximately 9 miles west of Allentown,
Pennsylvania. Over the past 10 to 15 years, salvage activities have
resulted in the accumulation of approximately 1,000 cubic yards of
discarded automotive battery casings in addition to automobiles, empty
storage tanks, enpty drums, and miscellaneous scrap metal.
Extent'of Contamination
Battery liquid and residual solid waste samples exhibited high
concentrations for lead and acidity. The battery casings were subjected
to the extraction test of the Resource Conservation Recovery Act (RCRA)
and found to leach quantities of lead that exceeded the RCRA threshold
level and, therefore, the casings are classified as hazardous material.
Background soil boring sample analyses indicate onsite, background,
surface soil lead concentrations of 133 and 140 parts per million (ppm).
Surface soil contamination detected on the site consists primarily of
lead in soil under and near the battery piles. The deeper soil boring
samples demonstrated that contamination was at or below background
concentrations at depths greater than 3 feet. Lead concentrations were
highest la surface soil samples collected from borings located under the
battery piles (typical high values: 5,090, 15,000 and 65,100 ppm.) Above-
background surface-soil lead concentrations rsnging between 200 and 3,000
ppm are generally confined to areas within 30 feet of a battery pile
perimeter.
EPA's risk assessment of the lead contaminated soil for the Hebelka
site determined that the cleanup level for the site should be 560 ppm.
All soil with levels of lead contamination over 560 ppm will be addressed
under this action. This cleanup level corresponds to EPA's general policy
of cleanup level of 500 ppm for lead-contaminated soil.
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EPA's Preferred Alternative
After careful consideration of the proposed cleanup solutions, I?A*s
preferred alternative for addressing the contaminated soils is alternative
4: Excavation, Fixation, and Off-site Disposal of Contaminated Soils ana
Recycling the Battery Casings. Alternative 4 would permanently reduce
the mobility and toxicity of the contaminated soils at the site to levels
which meet public health and environmental standards, while not creating
any hazardous by-products or residues which would have to be disposed of.
At this tine, EPA believes that the treatment technology exists to carry
out the preferred alternative.
EPA will attempt to recycle the battery casings and reclaim the
usable material of the casings and their contents. Should EPA subsequently
find that recycling is impractical, EPA will, at such time dispose of the
battery casings in a RCRA landfill.
EPA's Remaining Alternatives
EPA also considered the following alternatives:
1. No Action - eliminated from consideration because the lead
contamination in the soil needs cleanup.
2. Capping - eliminated from consideration because the lead
contamination would be left on site.
3. Excavation and Offsite RCRA Landfilling - eliminated from
consideration because the soil would be left untreated.
4. Excavation, Acid Leaching, and Dispos'ai - -i^iainated from
consideration because this technology is unproven.
Community Input
On February 23, L989 EPA placed an ad in the Morning Call newspaper
announcing the alternatives for cleanup of the Hebelka Superfund Site.
Residents are asked to send their written comments to:
Nanci Sinclair (3PAOO) or Fran Burns (3HW21)
U.S. EPA Region III U.S. EPA Region III
841 Chestnut Street 841 Chestnut Street
Philadelphia, PA 19107 Philadelphia, PA 19107
Consnts arc being accepted froa February 23 - March 26, 1989.
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Pott OfflM fax 2093
Hanftburg. PomuylvMite 17120
March 31, 1989
Secretary for
Environmental Protection (717) 787-5028
Stephen R, Wassersug, Director
Hazardous waste Management Division
' EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re i Letter of Concurrence
Hebelka Auto Salvager Weisenburg Twp., Lahigh Co.
Aacord of Decision (ROD)
Dear Mr. Wassersugt
The Record of Decision for the initial operable unit
which addresses the source of the contamination by remediation of
the on-site contaminated soils and battery eatings at the Bebelka
Auto Salvage has been reviewed by the Department.
The major components of the selected remedy includet
* Recycling of battery casings. If recycling of the
battery casings proves impractical, the battery
casings will be disposed at a permitted Resource
Conservation and Recovery Act (RCRA) landfill.
* Excavation of lead contaminated soil,
fixation of the soil, utilising a cement or line
based fixation process and depositing the fixed
material in a landfill that the state has
permitted to accept this material.
I hereby concur with the KPA's proposed remedy with the
following conditions!
* The7 Department will be given the opportunity to concur
with decisions related to subsequent operable units and
the future Remedial Investigation and Feasibility Study
to identify the extent of, and future potential for,
site related contamination and remaining sources of
that contamination, and evaluate appropriate remedial
alternatives to assure compliance with DBR cleanup
ARARs and design specific ARARs.
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Stephen R. Wassersug, Director -2- March 31, 1989
* B?A will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the Remedial
Action, to assure compliance with DKR cleanup
ARARs and design specific ARARs.
* The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state law.
* This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section 104(c)(3).
Thank you for the opportunity to concur with this EPA
Record of Decision. If you have any questions regarding this
matter please do not hesitate to contact me.
Sine
X. McClellan
Deputy Secretary
Environmental Protection
AR30!132
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