United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/075
June 1989
Superfund
Record of Decision
Whitmoyer Laboratories, PA
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50272.~01
.R~FORT DOCUMENTATION 1'. REPORTNO. 12-
! l PAGE EPA/ROD/R03-89/075
H\ title 8IId 8uDft8
j SUPERFUND RECORD OF DECISION
Whitmoyer Laboratories, PA
irst Remedial Action
. Author(.1
3. RecipI8nt'. AcC8881an No.
5. Report D.te
06/30/89
I.
I. Pwrfonnlng Org.nlzatlon AepI. No.
. 8.. PwrfonnIng Org8lnlza1lon""" 8IId AddrM8
10. ProjecllT..klWorit Unit No.
11. Contrect(C) or Gr.nt(G) No.
(C)
(a)
J 12. ~ 0rpnIutI0n NMI8 8IId Ad*M8
! a.s. Environmental Protection
401 M Street, S.W.
i Washington, D.C. 20460
13. Type 01 Report .. PeJiod Covered
Agency
800/000
14.
, 15. Suppl8n8ntuy No..
.
! 11. Ab8tr8Ct (Umlt: 200 _Ide)
; The 22-acre Whitmoyer Laboratories site is located in Jackson Township, Lebanon
!county, Pennsylvania. Land use surrounding the site is predominantly agricultural;
I however, there is some residential, commercial, and industrial development within 1.5
!mileS of the site. This includes a manufacturing plant to the south; a pharmaceutical
factory to the east; a large, active limestone quarry to the west; and an elementary
I~~hool to the northwest of the site. Portions of the site are within neighboring
I8lpehocken Creek's 100-year floodplain. The creek, which is bordered by small, open
~tlands areas, is being proposed for inclusion in Pennsylvania's scenic river system,
with a "priority 1A status." Priority 1A status would designate the stream as being in
most urgent need of protection. In 1957 site owners began producing organic arsenicals
at the site. In 1964 widespread ground water contamination was discovered onsite
leading to the placement of concentrated wastes in a concrete vault and the initiation
of ground water pumping and treatment. Sludges from the ground water treatment were
i later consolidated in lagoons. In 1987 an EPA investigation revealed that
: approximately 69,000 gallons of concentrated liquids had been abandoned onsite in 18
] tanks and 14 piping units. The wastes include 5,000 gallons of water-immiscible
,
: liquids, 25,000 gallon~ of water-miscible liquids with a high arsenic content, and
! (See Attached Sheet) .
i t7; D_t An8Iy8l. .. o.8Criptore
j Record of Decision - Whitmoyer Laboratories, PA
j ~irst Remedial Action
Contaminated Media: concentrated liquids in tanks
Key Contaminants: VOCs (PCE), metals (arsenic)
and piping units
It. Id8ntlfler8lOpen.End8d T-
I c; COSATI ReldlGroup
. 11. Av8ll8Ol11y St8t8lll8t1t
18. Security CI... (Thl. Report)
None
20. Security CI... (Thl. Pege)
Non/=>
21. No. 01 P.ge.
4A
22. Plica
(S8e:AHSI-Z38. tl)
SH 1n8lTUf:tlone on R.-
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(Formerly NTIS-3S)
o.pal1ment 01 Commerce
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E?A/ROO/R03-89/075
wiitmoyer Laboratories, PA
First Remedial Action
~.
Abstract (Continued)
~,OOO gallons of water-miscible liquids with a low arsenic content. All the tanks and
piping units are within 400 feet of Tulpehocken Creek; 27 of the 32 tanks and piping are
within 150 feet. Because the site slopes toward the creek, any release from a tank or
piping failure is likely to contaminate the creek. Flooding of the creek could cause
failure of these tanks, resulting in catastrophic release of contaminants to the creek.
Additionally, contaminants released from the tanks and piping units could migrate to
ground water and or the drinking water supply lines serving the site. Because the
concentrated liquids pose significant health and environmental threats, their removal is
addressed in this first operable unit. Subsequent operable units will identify potential
soil, ground water, and surface water/sediment contamination and additional remedial
actions that may be necessary. The primary contaminants of concern in the concentrated
liquids are VOCs including PCE, and metals including arsenic.
The selected interim remedial action for this site includes consolidating, transporting
offsite, and then treating, using thermal treatment or biodegradation, or recycling
approximately 69,000 gallons of concentrated liquid wastes at a permitted RCRA facility,
followed by disposing of treated water in offsite surface water and disposing of solid
residues in an offsite landfilli decontaminating 32 tanks and approximately 2,000 feet of
piping to meet RCRA Subtitle C closure standards and disposing of the tanks and piping
onsitei and treating and disposing of the cleaning agent residues offsite at
RCRA-permitted facilities. The estimated capital cost of this interim remedial action is
$475,000, with no O&M costs.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Whitmoyer Laboratories Site, Jackson Township, Lebanon County,
Pennsylvania.
Concentrated Liquids Operable Unit.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the concentrated liquids operable unit at the Whitmoyer
Laboratories Site, Lebanon County, Pennsylvania. The remedial
action was developed in accordance with the statutory
requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and is consistent with the National Contingency Plan (NCP) 40 ,
CFR Part 300. This decision is based on the administrative
record file for this site (index attached). The attached index
identifies the items which comprise the administrative record
upon which the selection of the remedial action is based.
The Commonwealth of Pennsylvania concurs with this remedial
action. A copy of the concurrence letter is attached.
DESCRIPTION OF THE SET.E^TCT REMEDY
This operable unit is the first of several for the site. This
first operable unit addresses hazardous concentrated liquids
(that are present in tanks and vessels), outdated liquid
products, and other miscellaneous liquid chemicals (hereafter
referred to as "concentrated liquids") which have been abandoned
at the site. Actual or threatened releases of hazardous
substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment..
The selected remedy involves consolidating the waste liquids into
approximately three general categories, transporting the wastes
off-site for treatment, and eventually disposing of the treated
liquids into an off-site surface-water body and disposing of
solid residuals in an off-site landfill. Organic compounds
present in the liquids will be destroyed, either directly or
indirectly, through thermal treatment or biodegradation; or be
recycled. The tanks and vessels (and associated piping) will
then be cleaned, using, as appropriate, steam, emulsifiers,
water, etc. , to remove the bulk contamination from these items
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2
and meet Resource Conservation Recovery Act (RCRA) closure
regulations. The decontaminated tanks and vessels would then be
left on-site for future reuse, scrap, or disposal. No demOlition
of the tanks and vessels is included under this alternative. The
cleaning agents would be treated and disposed off-site. Under
the selected remedy, specific treatment technology(ies) are not
identified at this point so as not to limit potential viable
technologies for the remedial action.
The remedy does not address threats posed by groundwater, surface
water/sediment, soils, and other contaminant sources at the site.
Subsequent records of decision for these items will be prepared
fOllowing completion of the Remedial Investigation (RI) and
Feasibility Study (FS).
The major components of the selected remedy include:
*
Interim tank inspection.
*
Compatibility testing and consolidation of approximately i
69,000 gallons of concentrated liquid wastes into
approximately three categories.
*
Transportation of these wastes off-site for treatment.
*
Treatment of the wastes at a permitted facility.
Disposal/discharge of solid and liquid treatment
residuals.
*
*
Decontamination of 32 tanks and vessels and about
2,000 linear feet of piping.
*
COllection, off-site transportation, treatment and
disposal of about 8,000 gallons of decontamination fluids.
Inspection of tanks and piping for compliance with design
specifications.
The selec~e4; remedy is one of the first phases of the long-term
remediation. of this site and will be consistent with the final
remedy.
*
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3
DECLARATION STATEMENT
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mObility, or voltme as a principal element and utilizes
permanent sOlutions and alternative treatment (or resource
recovery) teChnologies to the maximum extent practicable.
Because this remedy for the concentrated liquids operable unit
will not result in hazardous substances remaining on-site above
health-based levels, the five-year facility review will not apply
to this action.
Date
~E~
Edwin B. Erickson
Regional Administrator
Region III
C/3o (fi
.
... ,'"
. .
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4
ROD
DECISION SUMMARY
SITE NAME. LOCATION. AND DESCRIPTION
The Whitmoyer Laboratories Site is located on approximately 22
acres in Jackson TownShip, Lebanon County, PennsYlvania, about
1 mile southwest of the Borough of Myerstown (see Figures 1 and
2). The site lies between the Union Canal of Tulpehocken Creek
and the Conrail (Reading) Railroad. Fairfield Avenue forms the
site's eastern boundary, while Creamery Street adjoins the site
to the west.
A food storage warehouse is active in Building 18 on site. Land
surrounding the site is predominantly farmland, with scattered
farmhouses. A Sterling Drug factory is located 2,000 feet east
of the site, while PJ Valves, a manufacturing plant, is located
about 1,500 feet to the south. A large active limestone quarry,
locally referred to as the Calcite Quarry, is located
approximately 1.5 miles west of the site.
TOPOGRAPHY. SURFACE WATER. AND DRAINAGE
Topographic relief on the site is moderate, varying in elevation
from 493 feet in the southwest corner to 449 feet in the
northeast corner. The entire site drains to Tulpehocken Creek,
with drainage being roughly perpendicular to the creek axis.
Portions of the site are within the 100-year flood plain of
Tulpehocken Creek.
The Union Canal branches from Tulpehocken Creek just west of the
site and rejoins the creek near the site's eastern boundary.
Myerstown is the first downstream community, at a distance of
approximately 3/4 mile. Tulpehocken Creek is a tributary to and
joins the SchuYlkill River near Reading, Pennsylvania. The
Schuylkill River flows into the Delaware River, which eventually
empties into the Atlantic Ocean. Tulpehocken Creek (and the
SChuylkill River) serve as drinking water supplies and irrigation
sources downstream of the site.
The headwaters of the section of Tulpehocken Creek which passes
by the site originate approximately 3 miles to the northwest.
The creek is formed by springs and runoff from Blue Mountain.
GEOLOGY
The Whitmoyer Laboratories Site is located within the Lebanon
Valley, part of the Great Valley portion of the Valley and Ridge
physiographic province. The valley is a topographic expression
of the underlying, relatively easily eroded carbonate bedrock
Units. The site is underlain by carbonate bedrock of the
Ontelaunee formation, the youngest member of the Ordovician Age
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FIGURE I
LOCATION MAP
WHITMQYER LABORATORIES SITE. MYERSTOWN. PA
AIUS
COFFORATOfM
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SOUMCC' GtMEBAt LAYOUT OMAWMC. MiEPANCONtSS, PREVENTION ft CONTINGENCY PLAN. DEC 22, 1982.
GENERAL ARRANGEMENT
WHITMQYER LABORATORIES SITE. MYERSTQWN. PA
O 2OO 4OO
SCALE IN FEET
FIGURE 2
MUS
CQRPQRATlOfM
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Beekmantown group. A thin mantle of clayey residual soil
overlies bedrock in the site vicinity. Depths to bedrock in the
site vicinity range from 0-18 feet, based on available boring
logs. The depth to bedrock is greatest in the vicinity of
Tulpehocken Creek and the Union Canal.
Soils in the area are primarily residual soils derived from
weathering of the bedrock surface, with some alluvium adjacent to
Tulpehocken Creek. Based on available boring logs for the area,
the soils consist predominantly of silt and clay. A thin veneer
of organic-rich topsoil overlies the residual soils throughout
much of the area.
HYDRQGEQLOGY
The carbonate bedrock units underlying the Lebanon Valley form
the major aquifer in the area. The various formations present,
although differing somewhat in water-yielding capacity, are
considered to form a single, large, heterogeneous, unconfined
aquifer. The porosity of the carbonate aquifer is almost \
entirely secondary, with fractures enlarged through solution-
channel ing, forming the primary groundwater storage zones and
migration pathways.
Groundwater flow directions in the area generally follow
topography, then follow stream flow direction in valley bottoms.
In the site area, groundwater flows to the northeast towards
Tulpehocken Creek and the Union Canal, then generally follows the
course of the stream to the east-northeast.
Groundwater in the bedrock aquifer is used for potable and
industrial water supplies. Approximately 40 residences in the
site vicinity have potable water supply wells tapping the
aquifer. Twenty of these residences have been placed on bottled
water by EPA due to contamination of their water supply from past
site activities. Large industrial users of groundwater include
Sterling Drug, Inc., Quaker Alloy Casting Co., and P.J. Valves,
Inc.
The Myerstown Water Authority provides potable water to the
residents of Myerstown. One of their reserve wells (#8) taps the
bedrock aquifer underlying the site. This well is utilized
during periods of high demand. To date, contamination from the
site has not been detected in this well.
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CLIMATOLOGY
The Whitmoyer Laboratories site is located within the
southeastern Piedmont climatological division of Pennsylvania.
Second Mountain, which rises 1,500 feet along the north border;
and South Mountain, which rises 1,000 feet along the southern
border, form the Lebanon Valley, in which the site is located.
The Lebanon Valley has a humid continental climate.
The average annual precipitation at the site is 42.3 inches; this
precipitation is mostly evenly distributed throughout the year,
with slightly less precipitation occurring in the winter. The
average annual snowfall is 27 inches. Evaporation at the site is
36.3 inches; thus, net precipitation is 6 inches.
In the summer, high temperatures are generally in the mid-80s and
the lows near 60°F. During the winter the highs average in the
upper 30s and the lows in the 20s. The prevailing wind is from
the northwest in winter and from the west-southwest in summer.
\
POPULATION ANp ENVIRONMENTAL RESOURCES
Lebanon County, according to the 1980 census, has a population of
109,829, and is classified by the Commonwealth of Pennsylvania as
a "fifth class" county. The population of Myerstown in 1984
was 3,270. Populations of 1,296 and 4,683 reside within one and
three miles of the site, respectively.
Portions of Tulpehocken Creek contain very small, open water
wetlands areas consisting of small pockets along the riverine
system of the creek and Union Canal.
The area has some habitat value, with opossum, raccoon, numerous
fish, a water snake, and various songbirds observed during a
1986 EPA site visit.
Tulpehocken Creek has been proposed for inclusion on the
Commonwealth of Pennsylvania's scenic river system, with a
"priority 1A status." This designation is for streams which
"have the most urgent need for protection and immediate need for
additional study,0 according to a Pennsylvania Department of
Environmental Resources (PADER) official. This designation is
currently in the public hearing process.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
A brief chronology of site history and enforcement activities
follows.
1900 Circa
1934
1957
1964
1971
1977
1978
1982
1984
1985
1986
1987
1988
1989 April -
June
An oil pipeline was constructed across the site.
Whitmoyer Laboratories, Inc. (WLI) formed.
WLI begins production of organic arsenicals at the
site.
ROHM & HAAS buys WLI. Widespread contamination
discovered. Concentrated wastes placed in a
concrete vault. Groundwater pump-and-treat
program initiated. Ocean dumping of wastes
begins.
Groundwater pump-and-treat and ocean dumping
program terminated.
Sludges from groundwater treatment consolidated in
eastern lagoons.
Beecham Laboratories acquires WLI.
Stafford Laboratories, Inc. purchases WLI.
Stafford Laboratories, Inc. files for bankruptcy".
Whitmoyer Laboratories Site proposed for the
National Priorities List (NPL).
WLI files a RCRA Closure Plan with PADER, and
switches its RCRA status from a Treatment,
Storage, or Disposal facility to a generator
facility.
Whitmoyer Laboratories Site finalized on the NPL.
Stafford Laboratories, Inc. abandons facility,
with very little, if any, of the RCRA Closure Plan
implemented. EPA initiates RI/FS.
EPA initiates an emergency response to remove
abandoned drums from the site. This work
continues into summer of 1989.
EPA sends Special Notice letters to ROHM & HAAS
Company, Beecham labs, Mr. C.W. Whitmoyer,
Stafford Laboratories, Meyerwhit Land Corporation
and the Buckeye Pipeline company for the
concentrated liquids operable unit. ROHM & HAAS,
Beecham, and Meyerwhit Land corporation have
declined the opportunity to perform the Remedial
Design and Remedial Action (RO/RA).
The 60-day moratorium initiated by the Special
Notice Letters ends on June 24, 1989. If a good
faith offer to perform the RD/RA is not received
by this date, EPA will begin the RD/RA for the
concentrated liquids operable unit with funds from
the Hazardous Substances Superfund.
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10
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Concentrated Liquids Assessment and Proposed Plan for the
Whitmoyer Laboratories Site concentrated liquids operable unit
were released to the public in April 1989. These two documents
were made available to the public in the administrative record
file and information repository maintained at the EPA Region III
Docket Room and the Myerstown Public Library, respectively. The
notice of availability of these documents was published in the
Lebanon pailv News on April 17, 1989. A public comment period was
held from April 17, 1989 through May 17, 1989. Although EPA
provided the opportunity for a public meeting in the affected
area, no citizens requested EPA to hold a public meeting, and one
was not held. A response to the comments received during the
public comment period is included in the Responsiveness Summary,
which is part of this Record of Decision.
SCOPE AND ROLE OF OPERABLE UNIT
As with many Superfund sites, the problems at the Whitmoyer \
Laboratories Site are complex. As a result, EPA is dividing the
site into operable units. The exact number of operable units has
not been determined at this time. The concentrated liquids
represent the first operable unit for the site. The concentrated
liquids were identified by EPA as the site's first operable unit
because of the significant, actual, and potential threats these
liquids pose to human health and the environment. The primary
response objective is to reduce or eliminate these threats by the
selected remedial action.
This action will be consistent with any future response action
taken at the site. An RI/FS is currently under way to investigate
potential soil, groundwater, and surface water/sediment
contamination, as well as other contaminant sources. The results
of the RI/FS will be used to identify additional remediation
activities which may be necessary.
SITE CHARACTERISTICS
During the RI, 18 tanks and 14 piping units (process vessels with
associated piping) were found to contain concentrated liquids
including hazardous substances. These tanks and units were
sampled by EPA during the weeks of August 15, 1988 and November
28, 1988. Sample locations are shown on Figure 3.
In October, 1988, EPA's REM III contractor conducted an inventory
of miscellaneous liquids (unsold products, process chemicals, and
wastes) abandoned at the site. Since the majority of these
liquids are clearly labeled, no sampling of miscellaneous liquids
was conducted.
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11
Based on eXisting information and analytical reSults, nearly all
of the concentrated tank, piping, and miscellaneous liquids can be
categorized into three groups for remediation purposes:
water-immiscible liquids, water-miscible liquids with high arsenic
content, and water-miscible liquids with low arsenic content.
seventy-two gallons of ~iscellaneous liquids are currently
unclassifiable. It is expected that these wastes will fall into
one of these three categories when additional information on these
wastes is collected during the remedial design phase.
Table 1 presents the classification of these concentrated liquids
addressed by this document. Altogether, there are approximately
69,000 gallons of concentrated liquids. Of this amount, 39,000
gallons (57 percent) are classified as water-miscible liquids with
low arsenic content; 25,000 gallons (36 percent) are classified as
water-miscible liquids with high arsenic content; and
5,000 gallons (7 percent) are classified as water-immiscible
liquids.
S~Y OF SITE RISKS
Proper maintenance and controls are needed at the site to prevent
releases of the concentrated liquids which may present an imminent
and substantial endangerment to public health and the environment.
The greatest risks to human health from the facility are
associated with direct contact with the concentrated liquids by
unauthorized personnel on-site (e.g., trespassers, vandals, etc.).
Some of the liquids, including raw arsenic acid (TA0006) and
several miscellaneous product liquids, are corrosive. Most of the
water-immiscible liquids present in tanks and piping contain
suspected volatile toxic organics, and, as a result, their
associated vapors are toxic. Some of the water-immiscible liquid
is predominantly aniline. Concentrated aniline is acutely toxic
to humans. Aniline penetrates the skin rapidly and induces
methemoglobinemia in those persons sufficiently exposed. Death
can result from a significant exposure. Nearly all of the tanks
and piping contain significant levels of arsenic. One-third of
the tanks and piping contain very high arsenic concentrations
(average 3 percent arsenic). Accidental ingestion of arsenic can
cause sickness or death. Arsenic is also a known human
carcinogen. Accidental ingestion of any of the concentrated
liquids addressed here will likely result in toxic effects.
A threat to human health and the environment is also posed by
tank/piping failure. Tanks and piping (vessels) can fail
'primarily under three scenarios. Tanks, vessels, and their
attendant piping and valves can fail due to freezing weather.
date, the tanks do not appear to be significantly affected by
freezing weather. However, continued lack of maintenance,
To
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Cl,n,a
I_heible
W.t... -.i ac ible'
liquid ..ith High
AniMAie ConLont
TABLE'
CLASSIFICATION OF CONCENTRATED LIQUIDS
WHITMOYER LABORATORIES SITE
S..ple C..Uona
'...... 1,900
'&8181 200
'I'&OOOJ 150
.1000. 300
.10005 300
.10001 400
.10001 60
.10010 150
.'0011 350
PIOOU 500 t os t )
MheeUAAeoua 690
t'O'IAL 5,000.
,.AOOOI },100
,.A0002 5,200
,.A0003 2,800
,.A0006 30
,.A0008 ),600
PIOOOI 600
PI0002 !a00
PIOOO) 500
PI0006 1,000
PI0001 950
PI0012,D 1,100
'10013 500
MiaceUaAeOU$ UO
TO!'AL 25,000.
8Iotllli
r002 ...atll, .lisu.od E' TOMie fo.. Aa. MOlitl, aniline.
r002 ...ate, .aau.ed E' TOMie fo.. Aa, H9, and po~~ibl, Se.
MOIiiU, .niline.
r002 ....ate, aaauaed E' !'oxic fo.. As. MO$tlr PC~.
r002 ...ate, assu.od E' !'oxie fo.. A$. Mostlr PeE.
r002 ...at., ..a.u.ed I' !'o.ie fo.. Aa. MO$Ll, Pe~.
r002 ...ste, ..su..d I' "oxie fo.. As. Moat 1, 'C~.
r002 ..aate, Aliauaed I' !'oxie to.. Ali. MoaLl, aniline.
A..u..d E. "oxie fo.. Ali. Moatl, c..e$,lie ..cid. RCMA FOOt
..a.te 1...a a"M AMARa.
r002 ..aate, a..au.ed E' "oMie fo.. As. Moatl, aniline.
r002 ..aate, aaau.ed E' "o.ie fo.. Ali. MOlitl, .niline.
MoaUy oil.
Av...ago B,.U Contltnt '" 9,900 .,.U/lbi AveulCJe Cl content"" 211';
Eati...ted Aa content'" }5-l00 .g/kg ...senic.
r002
rOOl
..002
'010
Ug.
r002 ....ate, Sludge. Ignit.ble. but "ill not cO.OU$t. ~p Toxic
to.. As, Cd, Se, and Ug.
r002 ..aate, E' "oxie for As, Cd, and Se.
P002 ..aate. EP "o.ic tor As, Cd, ..nd pOliliibl, Se.
F002 ...ate, EP Toxic for Aa, Cd, .nd Se.
r002 ....te, E' Toxic for AIi, Cd. and Se.
r002 ..aste, E' Toxic for Aa, Cd, ..nd Se.
r002 ....te, Ef "oxie tor A5, Cd, and Se.
r002 ...ate, E' Toxic tor AIi, and poaliibl, Cd dnd Se.
Araenlc .cid ..alite in 5S-~.I. dru.li. Aliliu.ed ~p "oxic tor A~.
..a.te,
..aste,
..a.te,
...ate,
EP "oxic tor Aa, Cd, and poliaibl, Se.
E' Toxic for Aa, and poa5ibl, Cd and Se.
EP "oxic for AIi, Cd, and Se.
Corroliive. ~, Toxic to.. Aa, Cd. Se. .nd pOliliibl,
Average araltnic content'" 30,000 .~/k~ AIi..
algnifie.nt o..goilnie content.
MdY conl..in d
i
I
-------
TABLE )
CLASSIFICATION OP CONCENTRATED LIQUIDS
WHITMOVER LABORATORIES SITE
PAGE TWO
Class
Water-aiscibl*
Liquid with L*V
Arsenic Content
Unclassif iable
Sample
TA0009
TA0010
TA0011
TA0012.D
TA0013
TA0014
TA0015.D
TA0016
TA0017
TAOOlt
Miscellaneous
TOTAL
TOTAL
Gal Ions
5.000
500
600
4.400
12.000
7.200
2.100
1.500
1.800
2,500
1.600
39.000*
70
Motes
As suited KP Tonic toi As.
Probably piperazine solution, lit organic carbon.
1
Assumed KP Tonic for As.
Contains 1.51 Zinc. pH-4. Includes 600 gals, of sludtje.
Assumed EP Tovic for As. Includes 1.400 gals, of sludge.
Assumed CP Tonic for As.
Assumed EP Tonic for As.
Assumed CP Tonic for As.
Assumed EP Tonic for As.
Half of category is Tesan Teat Dip. Some miscellaneous wastes
are corrosive.
Average Arsenic Content = 10 Bg/kg As.
Average TOC Content - 2.51, Average COD Content - 8.9«
Average BOO Content - 5.11
These wastes should be classi f iabln in one of the thiee othei
categories once moitt information is obtained.
Total Estimated Volume - Concentrated Liquids = 69,000 gallons.
* All data rounded to two significant digits or the nearest 10-gallon increment tor
quantities.
-------
TA 011
TA0010
"-
\ PARKING AREA
"
~ A~\S \ \ \
o ~ 00 200 \! . .
,....-,-- /:'
- SC;LE IN ~EET L. - --~
- - -. -. --- ---.. .~_. - '-.......-
PIOO ~
.45;
1
I
I SLOG'
PI 0010
SOU~!' NUS FIELD INVESTIGATION,19SS.
NOT TO SCALE
FIGURE 3
TANK. VESSEL. AND PIPING LOCATION CBiN.roIf"""'Il . ~
WHITMOYER LABORATORIES SITE. MYERSTOWN. PA LD ~ - ~
-------
15
coupled with an extended period of freezing weather, as occurs
periodically, could result in the rupture of many of the
unwinterized tanks and piping. They can also fail due to
deterioration over time from stress, fatigue, or the effects of
the concentrated liquids. Structural integrity testing of the
tanks and vessels was outside the scope of the RI and was not
conducted. The potential for tank/piping failure from acts of
vandalism is also present.
There is the possibility of direct contact with the ~oncentrated
liquids during tank failure. The potential effects of direct
contact are discussed above.
All of the tanks and piping are within 400 feet of Tulpehocken
Creek; 27 of the 32 tanks and piping (and attached vessels) are
within 150 feet. The site slopes toward the creek. Thus, any
releases from tank/vessel failure are likely to reach and
contaminate Tulpehocken Creek. All but two of the tanks are
diked. This diking could prevent a significant portion of the
tank contents from contaminating the environment during a tank \
failure. However, without maintenance of the diking integrity and
periodic removal of accumulated precipitation, the dikes will be
ineffective at containing leaks. Releases from the tanks and
vessels could also cause migration of contaminants to groundwater
and/or the sewer line serving the site; such migration could
additionally contaminate this potable water supply and/or cause an
upset at the sewage plant.
Many of the concentrated liquids have low flash points and/or are
combustible. A fire could cause the release of hazardous
substances to the atmosphere. A tank/piping explosion would cause
the release of hazardous substances to the environment. The West
Myerstown Elementary SchoOl, a potential receptor, is located
approximately 1,800 feet northwest of the tanks and piping.
The MaD of Flood-Prone Areas. published by the United States
Geologic Survey, and the Flood Insurance Rate Map, published by
the Federal Emergency Management Agency, both show the tanks
associated with samples TAOOOI-TA0008 to be in the 100-year
flood plain (elevation 559 above MSL, see Figure 3). Severe
flooding could cause the failure of these tanks, with catastrophic
release of contaminants to the creek waters.
DESCRIPTION OF ALTERNATIVES
USing information collected by EPA's REM III contractor and the
findings of past and present investigations and data analysis, EPA
developed five alternatives for an early action Record of Decision
for the concentrated liquids operable unit at the Whitmoyer
Laboratories Site. EPA's approach to this early action ROD has
been to evaluate a limited number of alternatives. The wastes to
be remediated are liquid wastes only and this leads toward
-------
16
treatment of the waste rather than containment. Also treatment of
liquid wastes is generally required to meet the Land Disposal
Regulations (LDR) treatment standards. The five alternatives are
No Action; Off-site Disposal (without treatment); Off-site
Treatment and Disposal; On-site Treatment and Disposal; and On-
site Containment.
Three of these alternatives were eliminated from further
consideration based on critical flaws. Off-site Disposal (without
treatment) was eliminated since the wastes, as liquids, are not
readily landfillable; disposal without treatment of the F-wastes,
P-waste, and "California List" wastes is generally prohibited
under the 40 CFR 268 Land Ban requirements, and the wastes contain
levels of priority pollutants and conventional parameters that are
significantly higher than typical concentration standards required
for direct discharge to surface waters. On-site Treatment and
Disposal was eliminated, since the relatively low volume of wastes
present, coupled with relatively high mobilization, engineering,
and capital costs, would result in very high treatment costs. .
This alternative offers the same degree of protection as off-sit~
treatment but at a much higher cost. On-site containment was
eliminated from further consideration, since this alternative
offers only a temporary solution and would not be effective in the
long term. Based on this analysis, EPA retained two alternatives
for further consideration. The two alternatives are:
*
*
No Action
Off-site Treatment and Disposal
ALTERNATIVE 1 - NO ACTION
Alternative 1 consists of no action for the concentrated liquid
wastes. This alternative is considered as a baseline for
comparison with other alternatives. The no-action alternative
would not involve any actions other than those currently provided
at the site. These include existing diking of all of the tanks
(except the two tankers), site fencing, and a security guard
service.
Under the no-action alternative, existing chemicals would be
allowed to remain on- site. This alternative would not minimize
or eliminate any possible catastrophic threat to human health and
the environment that currently exists. In addition, this
alternative would not provide a p~rmanent SOlution, nor would it
comply with other statutory or regulatory requirements (in
particular, RCRA storage, disposal, and closure requirements).
-------
17
ALTERNATIVE 2 - OFF-SITE TREATMENT AND DISPOSAL
Alternative 2 consists of consolidating the waste liquids into
three general categories, transporting the wastes off-site for
treatment, and eventually disposing of the treated water in an
off-site surface water and disposing of solid residuals in an off-
site landfill. The organic compounds would be destroyed, either
directly or indirectly, through thermal treatment or
biodegradation, or recycled. The tanks and vessels (and
associated piping) would then be cleaned, using, as appropriate,
steam, emulsifiers, water, etc., to remove the bulk contamination
from these items and meet RCRA Subtitle C closure standards. The
decontaminated tanks, vessels, and piping would then be left on
site for future reuse, scrap, or disposal. No demolition of the
tanks and vessels would be included under this alternative. The
cleaning agent residuals would likewise be treated and disposed
off site. The off-site treatment facilities must be RCRA
permitted facilities and be in compliance with their permit.
The three major categories of concentrated liquids are --
*
*
Water-Immiscible
Water-Miscible High Arsenic
Water-Miscible Low Arsenic
*
The consolidation activities under this alternative are not
planned to occur until actual on-site remedial action occurs. The
waste categories presented here are preliminary, to al~ow for
optimization under remedial design. In particular, discrete tank,
piping or miscellaneous wastes may be moved to other categories in
order to facilitate treatment. Also, additional categories may be
developed or categories eliminated, based on optimization during
remedial design.
The potential tasks under this alternative are summarized as
follows:
.
,
*
Interim tank inspection.
*
Compatibility testing and consolidation of approximately
69,000 gallons of concentrated liquid wastes into
approximately three categories.
*
Transportation of these wastes Off-site, in accordance with
RCRA, US Department of Traqsportation (DOT), and State
regulations.
Treatment of the wastes at permitted facility(ies) (as yet
unidentified), in accordance with RCRA and State
regulations.
-------
18
*
Disposal/discharge of sOlid and liquid treatment residuals,
in accordance with RCRA, Clean Water Act and State
regulations.
*
Decontamination of 32 tanks (and piping vessels) and about
2,000 linear feet of piping, in accordance with RCRA closure
standards and design specifications.
*
COllection, transportation, treatment, and disposal of about
8,000 gallons of decontamination fluids, in accordance with
RCRA, DOT, and State regulations.
*
Inspection of tanks and piping for compliance with design
specifications.
Potential treatment technologies for the three categories of
concentrated liquids are presented in Table 2. This table is
developed based on applicable EPA guidance, coupled with a review
of the vOlumes, matrices, and contaminants present in the
concentrated liquids.
This alternative involves the treatment and disposal of RCRA
hazardous listed and characteristic wastes off-site. Some of
these wastes are 'classified as RCRA F-wastes, P-wastes (40 C.F.R.
261.31 and .32) and/or "California List" wastes (RCRA Section
3004(d)(Z». EPA has promulgated land disposal restrictions (LDR)
for these wastes; thus the land disposal restrictions are
applicable requirements for these wastes. The off-site treatment
facilities must be able to achieve the LDR treatment standards for
these wastes.
Under this alternative, specific treatment technologies are not
identified at this point so as not to limit potential viable
technologies under remedial action. Final selection of
technologies will be made based on vendor responses to
performance specifications. Criteria to be used in this selection
include:
*
*
*
*
*
*
Compliance of vendors with their permits (RCRA, NPDES, and
pretreatment standards).
Compliance with CERCLA and ARARs.
Permanence.
Ultimate fate of contaminants.
Reduction in volume, mObility, and toxicity.
Costs.
For purposes of costing this alternative, the fOllowing treatment
~eChnOlogies were selected:
*
Water-Immiscible: Incineration, fOllowed by NPDES POTW or
surface water discharge of waters and RCRA hazardous waste
disposal of inorganic residues.
-------
TAHLK 2-
API'MCAHILITV Of THKATMKNT TtCIIWGUHHtS
LABOHATUHI ES SITE
Technology
• tiocetl Option*
• Vitilf lectio*
riltt«l l«n
• Ceibon Mtaiption
• ••»•(•• OkMtti*
• All Stopping
• Qaidel io*
• Maiitfftl i»*l ion
• Pine Apil«l Ion
Organic*
Oignnlc*
Qiff.**lc*/Mtnl*
Ealld*/Ml*l»
N«l*l«/aig*nice
Oignnic*
Vul«til« oig4»c»
Itolal*
OffCKic*
Oig*nic*
H«lci
Mad* i*l*
Low
Mot «|H»''c«bl«
Hot »pplic*bl«
Hot appllcoblo
fat. Applicable
tot. *ppllc«bl«
Lou
Hot *p|>l ic^bl*
Hot •pplic«l>li>
Lou
ton
iMftlkCibio
fotvot i*l
illt«f (•!••»•
High liquid cuntvnt
High liquid content
S««i*ol«t il«
Ocyaiiiet
High concviit <«t ion
Tonic ily
Yuekcily
M*l
":;;.
Applicability
I.UH/H4id*i«ta
lutw
Lou
High
• igt>
Pat. «ppl iC4bl«
•at «pplicebl*
Pat. eppliccble
Maiteot*
H>gli
Lou
• i !•!
A!:::tc"
Potent i*l
lulerluf encek
Hii|l> w*t«i content
High n«tci content
Ulgh wtflef cont*ibt
Se»ivoli tcebi lily
tax /Made i«l«
I.UW
I.OU
High
Ul-jli
fot . *ppllc«b It-
Hut epplic^ble
Pot. epplic«ble
Muilel«le
Utgb
;r •:;:,. «-.,.
HiHcibl*
AikMnitf %
1
1 nitre f •(•meet
Hiylt w*lm conlVAi
Hi*jh w*t «i conlunt
UvMiivuldl * Ic
To* icily
-------
20
* Water-Miscible High Arsenic: Physical/chemical treatment,
followed by National Pollution Discharge Elimination System
(NPDES) Publicly Owned Treatment Works (POTW) or surface
water discharge of waters and RCRA hazardous waste disposal
of inorganic residues.
* Water-Miscible Low Arsenic: Physical/chemical treatment,
followed by NPDES POTW or surface-water discharge of water
and hazardous or nonhazardous disposal of inorganic
residues.
At the completion of this remedial alternative, human health and
environmental risks posed by the liquids will either be
substantially reduced or eliminated. The estimated capital cost
of this alternative is approximately $475,000. There are no
annual operation and maintenance (O&M) costs. The estimated time
to implement this alternative and to meet the cleanup goals is 18
months or less.
SUMMARY Of THE COMPARATIVE ANALYSIS Of ALTERNATIVES
OVERALL PROTECTION Of HUMAN HEALTH and the ENVIRONMENT
Alternative 1 - No Action would not protect human health and the
environment. The risks presently posed by the liquids are
discussed above. Risks associated with direct human contact are
somewhat reduced due to the presence of a security guard service;
however, accidental contact with the waste is still conceivable.
Since some of the wastes are ignitable and have high BTU values,
there is a risk of fire occurring at the site. Because seven
tanks lie within the flood plain, there is a risk of release
during flooding.
If no action is taken, it is likely that one or more of the tanks
will eventually leak or fail. At the same time, the containment
dikes will eventually fill with rain water, since there is net
precipitation at the site. With the dikes full of rain water,
they will not offer secondary containment protection. Also some
tanks have no secondary containment structures. Therefore, the
no-action alternative would not protect the environment from leaks
and potential catastrophic failure of the tanks. Environmental
media likely to be affected by leaks and catastrophic failure
include soils, groundwater, and surface water (Tulpehocken Creek).
Alternative 2 - Off-site Treatment and Disposal of the wastes
would involve removing the wastes from the site and thereby
minimizing long-term risks at the site associated with these
wastes. This alternative would eliminate the direct contact
threat posed by the wastes and would remove the threat to human
health and the environment from the stored liquids. The wastes
would then be treated to destroy or recycle the organic
contaminants, using the technologies identified in the Description
of Alternatives. The metal contaminants would be treated using
-------
21
described in_the Description of Alternatives, and then disposed in
an appropriate landfill designed to protect human health and the
envirorunent.
Alternative 2 would also include interim periodic inspection of
the tanks prior to remediation. These inspections could provide
some additional protection by identifying leaks and potentially
identifying other means of failure.
COMPLIANCE WITH ARARs
Alternative 1 - No Action wOuld not comply with the ARARs
presented 'in Appendix A.
Alternative 2 - Off-site Treatment and Disposal would comply with
each of the ARARs presented in Appendix A. Since some of the
concentrated liquids are RCRA-listed wastes and/or "California
List" wastes, the "land ban" regulations of 40 C.F.R. Part 268 are
applicable to these wastes, and must be complied with by the off-
site treatment facility. Alternative 2 would also meet each of
the response objectives.
~
Alternative 1 - No Action has a zero cost associated with it.
Items such as site maintenance, security service, and 5-year site
review are all assumed to be covered under other operable units at
the site.
The estimated costs associated with Alternative 2--0ff-site
Treatment and Disposal--total about $475,000, inCluding $50,000
for remedial design and construction management. Since the
actions associated with this alternative would require less than
1 year to remediate, there are no long-term operation and
maintenance costs. Included in the capital cost under disposal
are secondary costs for the vendors, including solid residue
disposal in a hazardous waste landfill and treated water
discharge. Engineering costs, which include consolidation
compatibility testing, specification preparation, bid review,
construction monitoring, and compliance inspection, are also a
part ,of the cost estimate.
LONG-TERM EFFECTIVENESS and PERMANENCE
'Alternative 1 - No Action would not be effective in the long term.
With time, the integrity of tanks, vessels, and piping will
deteriorate. ' Deterioration mechanisms include corrosion,
weathering, freezing, and metal fatigue. Additionally, with time,
the secondary containment systems will likely deteriorate. ' Two of
the tanks at the site (TA-0009 and 0012) contain about 10,000
g~llons of waste and have no secondary containment. An additional
concern is, that tanks TA0001-0008 are in the 100-year flood plain
and are subject to catastrophic washout. The possibility of a
fire at the s'i te is also increased over the long term.
-------
22
With the hazardous materials removed from the Site, and the tanks,
vessels, and piping decontaminated, Alternative 2--0ff,-site
Treatment and Disposal would be effective in the long term.
Destruction or recycling of the organic contaminants would
eliminate future risks associated with them. Metals residuals may
require additional remedial measures fOllowing treatment prior to
disposal. If necessary these metals may be treated prior to
disposal to reduce mObility and will be placed into an off-site
disposal facility for proper long-term management. These items
would be covered under the off-site treatment vendor's operation.
This alternative offers a high degree of permanence and is
consistent with future remedial efforts for the remaining operable
units at the site.
REDUCTION OF TOXICITY. MOBILITY. OR VOL~
Alternative 1 - No Action would not result in the reduction of the
toxicity of the existing wastes. MObility and volume may increase
with time as a result of leaks or tank failure. This failure
would reSult in contamination of other media at the site,
including groundwater, soils, and potentially surface water
(Tulpehocken Creek).
Alternative 2 - ~his alternative satisfies the statutory
preference for reduction in toxicity, mObility, and volume of
hazardous Substances. Off-site Treatment and Disposal would
result in a significant reduction in toxicity of the organics--by
destruction; reduction in volume of contaminated materials by
separation of water from the contaminants; and mObility of the
residual metals by concentrating, deterring, and placing them in a
properly managed landfill. The metals may also be stabilized by
the vendor prior to landfilling.
SHORT-TERM EFFECTIVENESS
In the short term, Alternative 1 - No Action may be moderately
effective. However, the potential for accidental human contact
and catastrophic tank failure remain major risks. Additionally,
it should be noted that currently at least one tank (TA0002/0008)
has been obsGrved to be leaking; this leak is currently Controlled
'by a secondary containment structure. The no-action alternative
can be in effect almost immediately fOllowing completion of the
Record Of Decision.
Alternative 2 - Off-site Treatment and Disposal would likewise
have some short-term risks. There are risks associated with tank
failure during the period from the present time until completion
of 'off-site transport. However, these risks will be decreased by
periodic inspection. The risk of accidental human contact and
-------
23
catastrophic tank failure cannot be eliminated, however. The off-
site treatment and disposal alternative also carries some
additional short-term risk associated with transporting the
contaminated wastes off-site. These risks are primarily
associated with potential transport truck accidents. Risk
reduction techniques, including personal protection equipment,
monitoring, emergency spill response measures, etc., will be
incorporated into the remedial design to minimize these risks.
All of the tasks under this alternative can be implemented within
2 to 18 months, with actual on-site activities requiring about
1 month or less. The interim inspection task under this
alternative can be implemented immediately.
IMPLEMENTABILITY
Alternative 1 - No Action is readily implemented, since no permits
or action-related activities are involved.
Alternative 2 - Off-site Treatment and Disposal would involve a i
remedial design phase to develop action plans and specifications
and selection of a contractor to perform the remedial work. Since
about one-half to all of the waste is RCRA hazardous, manifesting
would be required for transportation and off-site disposal of the
wastes. The availability of vendors capable of performing the
treatment and disposal work is somewhat limited, although there
are several vendors available for each of the three categories of
waste.
At the completion of tank, vessel, and piping decontamination,
these items would be inspected to ensure compliance with
decontamination requirements.
STATE ACCEPTANCE
The Commonwealth of Pennsylvania, Department of Environmental
Resources (PADER) has reviewed the information available for the
site. Alternative 1 - No Action is not acceptable to PADER.
PADER concurs with the selection of Alternative 2--0ff-site
Treatment and Disposal as the remedy for the concentrated liquids
operable unit. See attached concurrence letter.
COMMUNITY ACCEPTANCE
The Proposed Plan for the concentrated liquids operable unit was
. issued in April 1989. A public comment period on EPA's plans was
provided from April 17, 1989 until May 17, 1989. Community
sUpport for the proposed action is high (see the attached
Responsiveness Summary).
-------
24
tXPLANATION OF SIGNIFIC~ CHANGES
The Proposed Plan for the Whitmoyer Laboratories Site concentrated
liquids operable unit was released for comment in April 1989. The
Proposed Plan identified Alternative 2--0ff-site Treatment and
Disposal as the preferred alternative. EPA reviewed all of the
comments submitted during the pUblic comment period. Upon review
of these comments, it was determined that no significant changes
to the remedy, as it was originally identified in the Proposed
Plan, were necessary.
THE SELECTED REMEDY
Based upon consideration of information available for the
Whitmoyer Laboratories Site Concentrated Liquids Operable Unit,
which are set forth in the Administrative Record, an evaluation of
the risks currently posed by the site, the requirements of CERCLA,
the detailed evaluation of alternatives, and community input, both
EPA and the Commonwealth of PennsYlvania have selected Alternative
2 (Off-site Treatment and Disposal) as the remedy to be
implemented for the operable unit. This alternative will i
significantly reduce or eliminate the actual and potential threats
to human health and the environment posed by the liquids, is
consistent with EPA's strategy for remediation of the site and
meets the criteria specified in CERCLA Section l2l(b)(l).
Approximately 69,000 gallons of concentrated liquids will be
treated in this operable unit. A summary of the concentrated
liquids is provided in Table 3. (More information permitting
classification of the 70 gallons of currently unclassifiable
liquids will be collected during the remedial design.) These
liquids will be consolidated and transported off-site for
treatment/disposal. RCRA hazardous wastes that are restricted
from land disposal (40 CFR 268) must be treated to the appropriate
treatment standards by the off-site treatment facility prior to
disposal. Organic compounds will be destroyed or recycled.
Residual metals in the concentrated liquids may be treated prior
to disposal to reduce mobility-and will be placed into an off-site'
disposal facility for proper long-term management. The tanks,
vessels and associated piping will be cleaned using appropriate
decontamination fluids, and left on-site for future reuse, scrap,
or disposal. The cleaning agents will also be treated and
disposed off-site.
RESPONSE OBJECTIVES
The response objectives for this operable unit are to --
~
Reduce or eliminate potential exposure pathways by which
contaminants may reach potential receptors.
Protect the environment from potential leaks and/or
catastrophic tank failure.
~
~
Be cost-effective.
-------
TABLE 3
CLASSIFICATION OP CONCENTRATED LIQUIDS
WHITMOYER LABORATORIES SITE
Class
Isusiscible
Water -alscibU
liquid with High
arsenic Coat«at
Matar-aiscible
Liquid with Leu
arsenic Coataat
line lass ifiabla
Gallons
5,000*
25,000*
IS .000*
70
Motes
average BTU Content • 9,900 BTU/lb; average Cl content * 2M|
Estimated As content » 75-100 stg/kg arsenic.
average arsenic content • 30,000 ag/kg as.* Hay contain a
significant organic content.
average arsenic Content » 11 a^g/kg as.
average TOC Content * 2.51, average COD Content * 1.9%
average BOO Content -5.11
These wastes should be classifiable in one of the three other.
categories once smre information is obtained.
Total Estimated Volune - Concentrated Liquids = 69,000 gallons.
* All data rounded to two significant digits or the nearest 10-gallon increment
for SMll quantities.
-------
26
*
Be in"compliance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act
(SARA) .
*
Be conducted in accordance with the National Contingency
Plan (NCP Section 300.68).
..
Be in compliance with applicable or relevant and appropriate
requirements (ARARs).
*
Provide permanent sOlutions to contamination problems to the
maximum extent practicable.
*
Be effective over both the short - and long-term.
*
Be acceptable to State authorities and the local community.
Leave the facility in a state conducive to remediation of
other areas of the site.
..
STATUTORY DETERMI~TIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental requirements
established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that permanently
and significantly reduce the volume, toxicity or mobility of
hazardous wastes. The fOllowing sections discuss how the selected
remedy for this site meets these statutory requirements.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through off-site liquids treatment to destroy or recycle organic
contaminants and to collect metal contaminants for disposal in an
appropriate landfill. The selected remedy eliminates a direct
contact threat and allows other areas of the site which may pose
potential health threats to be remediated. Tanks, vessels, and
associated piping will be cleaned, with cleaning agents also being
treated and disposed off-site. Prior to remediation, tanks and
vessels will be periodically inspected.
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27
Destruction -~or recycling) of organic compounds will eliminate the
threats posed by these chemicals. Since metals cannot be
destroyed, there will be some long-term risks; however, these
metals may be treated prior to disposal to reduce mobility and
will be placed into an off-site landfill for proper long-term
management. Any short-term risks from implementation of the
selected remedy will be mitigated by incorporating into the design
personal protection equipment, monitoring, and emergency spill
procedures.
ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS
The selected remedy of off-site treatment and disposal will attain
all applicable or relevant and appropriate requirements. The
ARARs are specified in Appendix A.
COST-EFFECTIVENESS
EPA and the Commonwealth of Pennsylvania believe the selected
remedy is cost-effective in mitigating the risks posed by the
concentrated liquids in a reasonable period of time (less than 18
months). Because organic chemicals present in the liquids willibe
destroyed (or recycled) and metals will be disposed in an
appropriate landfill, selection of the off-site treatment and
disposal remedy affords a high degree of long-term effectiveness
and permanence.
The capital cost Of the concentrated liquids remedy is estimated
to be $475,000, including $50,000 for remedial design and
construction management, with no annual O&M costs. While these
costs are significantly greater than for the no-action
alternative, the selected remedy is protective of public health
and the environment and complies with all ARARSi the no-action
alternative does not achieve these criteria. Therefore, EPA and
the Commonwealth of Pennsylvania believe that the selected remedy
is cost effective.
UTILIZATION OF PE~ SOLUTIONS AND ALTERNATIVE TREATMENT (OR
RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM EXTENT PRACTICABLE.
The concentrated liquids found at the site represent a principal
threat to human health and the environment. By treating all of
the concentrated liquids and decontamination fluids at an off-site
treatment facility, the selected remedy uses treatment
technologies to the maximum extent practicable.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating all of the concentrated liquids and decontamination
!~uids at an off-site treatment facility, the. selected remedy
'addresses the principal threats posed by the concentrated liquids
through the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment as a
principal element is satisfied.
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27
Destruction (or recycling) of organic compounds will eliminate the
threats posed by these chemicals. Since metals cannot be
destroyed, there will be some long-term risks; however, these
metals may be treated prior to disposal to reduce mobility and
will be placed into an off-site landfill for proper long-term
management. Any short-term risks from implementation of the
selected remedy will be mitigated by incorporating into the design
personal protection equipment, monitoring, and emergency spill
procedures.
ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS
The selected remedy of off-site treatment and disposal will attain
all applicable or relevant and appropriate requirements. The
ARARs are specified in Appendix A.
COST-EFFECTIVENESS
EPA and the Commonwealth of PennsYlvania believe the selected
remedy is cost-effective in mitigating the risks posed by the
concentrated liquids in a reasonable period of time (less than l~
months). Because organic chemicals present in the liquids will be
destroyed (or recycled) and metals will be disposed in an
appropriate landfill, selection of the off-site treatment and
disposal remedy affords a high degree of long-term effectiveness
and permanence. .
The capital cost of the concentrated liquids remedy is estimated
to be $475,000, including $50,000 for remedial design and
construction management, with no annual O&M costs. While these
costs are significantly greater than for the no-action
alternative, the selected remedy is protective of public health
and the environment and complies with all ARARs; the no-action
alternative does not achieve these criteria. Therefore, EPA and
the Commonwealth of Pennsylvania believe that the selected remedy
is cost-effective. .
UTILIZATION OF PERMM'ENT SOLUTIONS AND ~=T~~~= ~R
RESOURCE RECOVERY TECHNOLOGIES) TO THE C LE.
The concentrated liquids found at the site represent a principal
threat to human health and the environment. By treating all of
the concentrated liquids and decontamination fluids at an off-site
treatment facility, the selected remedy uses permanent treatment
technologies to the maximum extent practicable.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating all of the concentrated liquids and decontamination
fluids at an off-site treatment facility, the selected remedy -
addresses the principal threats posed by the concentrated liquids
through the use of treatment technologies. Therefore, the
statutory preference for remedies that employ treatment as a
principal element is satisfied.
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28
TABLE 3
Estimated Costs of Selected Remedy
Site Work
(Mobilization/Demobilization,
Liquid removal, Tank decon,
Safety monitoring)
Off-Site Transportation of Liquids
$199,462
15,200
Off-Site Treatment of Liquids
and Decon water
123,000
Contingency (20%)
67.533
405,195
Design
50,000
Interim Inspection Monitoring
(10 months)
20.000
Total Project Costs
$475,195
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29
APPENDIX A
APPLICABLE OR RELE~ AND APPROPRIATE REQUIREMENTS CARARS)
-------
30
Action
ARARS
1. Consolidation of
69,000 gallons of con-
centrated hazardous
wastes into tanks and
containers, off-site
transport, treatment &
disposal of toxic waste.
Alt. 1
No Action
N/A a)
2. Transport of concentra-
ted wastes in tanks and
containers.
b)
c)
N/A a)
b)
Alt. 2 - Off-site treatment
and disposal
Any air emission generated
during the remedial action
must not exceed National
Ambient Air Quality Standards
established under the Clean
Air Act, Section 109, and 40
C.F.R. Parts 50 and 51.
Federal Flood Plain Executive
Order 11988 provides for con-
sideration of flood plains
during remedial actions.
Liquids located in the 100
year flood plain will be con-
solidated in an area outside
the flood plain.
\
Any new on-site tanks and con-
tainers must be constructed,
operated, and closed in
accordance with 40 C.F.R. Part
264, Subparts I and J,
respectively and 25 PA Code
Chapter 75.264 Subparts (q)
and (r).
Transport of hazardous waste
for treatment and disposal
must satisfy Pennsylvania
Solid Waste Disposal Regula-
tion, 25 PA. Code Chapters 262
and 263 (40 C.F.R. Parts 262
and 263).
Transport of hazardous materi-
als for treatment and disposal
must satisfy Department of
Transportation regulations set
forth in 49 C.F.R. Part 107,
171.1-171.500. The DOT regu-
lations govern the transport
of hazardous waste materials,
including packaging, shipping,
equipment and placarding.
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31
Action
Alt. 1
No Action
Alt. 2 - Off-site
and disposal
Treatment
3. Consolidation of 69,000
gallons of concentrated
hazardous wastes into
tanks and container.
4. Decontamination of 32
tanks and 2,000 linear
feet of piping on site.
N/A Regulations of the Occupation-
al Safety & Health Administra-
tion ("OSHA"), 29 C.F.R. Parts
1904, 1919 and 1926, provide
occupational safety and health
requirements applicable to
workers engaged in on-site
hazardous waste field
activities.
N/A a) The handling and closure of
the existing RCRA-regulated
tanks and piping must satisfy
40 C.F.R. Part 264, Subparts I
("Use and Management of
Containers") and J ("Tank \
Systems"), respectively and
25 PA Code 75.264.
b) Closure of the units must also
satisfy 40 C.F.R. Part 264,
Subpart G ("Closure and Post-
Closure" ) and 25 PA Code
Chapter 75.264(o).
5. Off-site disposal of
69,000 gallons of
concentrated hazardous
wastes off-site.
N/A a) Any hazardous waste delivered
off-site must be delivered to
a treatment/storage/disposal
("TSD") facility which has
qualified for Interim status
or has obtained a RCRA permit.
Such treatment, storage, or
disposal must be performed in
accordance with 40 C.F.R. Part
265,. or the analogous State
regulations, or the TSD's
permit, as may be appropriate.
b) Section 121(d)(3) of CERCLA
mandates that hazardous wastes
disposed off-site be disposed
of at a facility that is oper-
ating in compliance with
interim status requirements or
a permit and if the wastes are
to be land-disposed, the re-
ceiving facility must not be
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32
Action
Al t . 1
No Action
Alt. 2 - Off-site Treatment
and disDosal
releasing any hazardous wastes
or constituents into ground-
water, surface water or SOil
and any releases from other
units at the facility must be
controlled by RCRA. corrective
action.
6. Off-Site disposal of
8,000 gallons of water
used, used to decontamin-
ate on-site tanks and
piping.
N/A
c) Any off-site disposal must
comply with the EPA Off-Site
Disposal POlicy, OSWER Direc-
tive No. 9834.11 (11/13/87).
~ (See 5 above)
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WHITMOYER LABORATORIES SITE
LEBANON COUNTY, PENNSYLVANIA
FINAL
RESPONSIVENESS SUMMARY
JUNE 23, 1989
This Responsiveness Summary is intended to document public
concerns and comments expressed during the public comment
period. The summary is also intended to document the EPA's
responses to the comments and concerns that were received.
Information is organized as follows:
1.0
2.0
3.0
Overview
Summary of Comments and Responses
Remaining Concerns
Attachment:
List of Community Relations Activities
Conducted at the Whitmoyer Laboratories Site
1.0
OVERVIEW
The public comment period for the Whitmoyer Laboratories Site
began on April 17, 1989, and extended until May 17, 1989. In a
public announcement that appeared in the Lebanon County Daily
News on April 17, 1989, EPA summarized the Agency's Proposed Plan
for disposing of concentrated liquids from the site and offered
the local community an opportunity to request a public meeting to
discuss the plan. The announcement also informed community
members that copies of the Proposed Plan and the Concentrated
Liquids Assessment, upon which the plan was based, were available
locally at the Myerstown Public Library in Myerstown,
Pennsylvania. No public meeting requests were received.
Consequently, no meeting was held.
2.0
SU*ARY OF COMMENTS AND RESPONSES
During the comment period, only one comment was received
regarding the Proposed Plan to dispose concentrated liquids. The
comment was presented in a letter from a local official
associated with the Lebanon County Emergency Planning Agency, and
it was dated April 25, 1989.
" COMMENT:
This official stated that he needed specific
information from EPA in order to enhance the original
site emergency contingency plan and provide for a
-------
WHITMOYER LABORATORIES SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
I .
SITE IDENTIFICATION
1)
u.S. EPA Identification and Preliminary Assessment,
12/23/83. P. 100001-100004.
2)
u.S. EPA Site Inspection Report, 4/11/84. P. 100005-
100011.
*
Administrative Record file available 6/16/89.
Note: Company or organizational affiliation is identified in
the index only when it appears in the file.
1
-------
5)
6)
7)
II.
1)
REMEDIAL ENFORCEMENT PLANNING
Letter to Mr. Jon F. Horwath, Buckeye Pipe Line Company,
from Mr. Thomas C. Voltaggio, U.S. EPA, re: 104(e)
information request, 4/14/89. P. 200001 - 200005.
2)
Letter to Mr. Harold Bogatz, Myerwhit Land Corporation,
from Mr. Thomas C. Voltaggio, U.S. EPA, re: 104(e)
information r~quest, 4/14/89. P. 200006-200010. A
certified mail receipt is attached.
3)
Letter to Beecham Laboratories, from Mr. Thomas C.
Voltaggio, U.S. EPA, re: Whitmoyer Laboratories Superfund
NPL Site, 4/14/89. P. 200011-200016. A certified mail
receipt is attached.
4)
Letter to Mr. Frank A. Lucero, Stafford Laboratories,
from Mr. Thomas C. Voltaggio, U.S. EPA, re: 104(e)
information request, 4/14/89. P. 200017-200020.
A certified mail receipt is attached.
Letter to Ms. Ellen Friedell, Rohm , Haas Company, trom
Mr. Thomas C. Voltaggio, U.5. EPA, re: 104(e)
information request, 4/14/89. P. 200021-200025. A
certified mail receipt is attached.
Letter to Hr. C.W. Whitmoyer from Mr. Thomas
Voltagqio, U.5. EPA, re: 104(e) information
4/14/89. P. 200026-200030. A certified mail
attached.
C.
request,
receipt is
Letter to Mr. Thomas C. Voltaqqio, U.S. EPA, from Mr.
Harold Boqatz, Meyerwhit Land Corporation, re: Meyerwhit
Land Corporation's response to the 104(e) letter dated
April 14, 1989. P. 200031-200031.
2
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III. REMEDIAL RESPONSE- PLANNING
1) Fact Sheet: Arsanilic Acid Startup Fact Sheet, 5/10/77.
P. 300001-300005.
2) Memorandum to Mr. R.L. Widerkehr from Mr. Harold M.
Huffman, Whitmoyer Laboratories, Inc. re: Arsenical
Waste Disposal, 7/21/80. P. 300006-300021. An Arsenical
Waste Disposal report is attached.
3) Memorandum to those listed from Mr. Lloyd J. Croesus,
Whitmoyer Laboratories, re: EPA Notification of
Hazardous Waste Activity, 8/11/80. P. 300022-300023.
4) Letter to Mr. Donald Wanamaker, Lion Technology, from
Mr. Lloyd J. Croesus, Whitmoyer Laboratories, Inc., re:
Fiberglass Tank - RCRA Consultation, 8/27/81. P.
300024-300024.
5) Letter to Mr. Lawrence P. Gemmell, GEM-CHEM Co., from Mr.
Lloyd J. Croesus, Whitmoyer Laboratories, re: v
Transmittal of an aniline water stream data sheet,
9/28/82. P. 300025-300030. The aniline water stream
data sheet is attached.
o) Material Safety Data Sheet for Emulsified Cresylic Acid
solution, prepared by Whitmoyer Laboratories, Inc.,
12/21/82. P. 300031-300032.
7) Memorandum to Mr. W.H. Skinner from Mr. L.J. Croesus,
Whitmoyer Laboratories, Inc., re: Expense Projection for
November and December 1983, 11/10/83. P. 300033-
300033.
8) Memorandum to those listed from Mr. Lloyd Croesus,
Whitmoyer Laboratories, Inc., re: Arsenical Wastewater
Shipment to Haste Conversion Company on November 10,
1983, 11/11/83. P. 300034-300034.
9) Memorandum to those listed from Mr. Lloyd Croesus,
Whitmoyer Laboratories, Inc., re: Update on Arsenical
Wastewater Shipment to Waste Conversion Company on
November 10, 1983, 11/15/83. P. 300035-300036.
-------
10) Report: Analytical Laboratory Request and Report for
Waste from 8108 Tanker at 12 noon on 11/1/83, prepared by
Whitmoyer Laboratories, Inc., 11/22/83.P~7~~300037-
_ 300037.
11) Memorandum to Regional File from Mr. Timothy Alexander,
Harrisburg Regional Office, re: Transmitting information
in regard to the level of arsenic found in the lagoons,
12/29/83. P. 300038-300039.
12) Letter to Mr. Krishnan Ramamurthy, Pennsylvania
Department of Environmental Resources, from Mr. Lloyd
Croesus, Whitmoyer Laboratories, Inc., re: Transmittal
of proposed material balance, 1/18/84. P. 300040-300044.
13) Report: Analytical Laboratory Request and Report Form
for Study" and Liquid from T-R for Sample Numbers 2024Q01
and 2024002 prepared by Whitmoyer Laboratories, Inc.,
2/84. PT~3~00045-300045.
14) Memorandum to Mr. F.A. Lucero from Mr. A.C. Smith, re: \
Phenol Residue Inventory, 10/10/84. P. 300046-300046.
15) Letter to Mr. Tim Alexander, Pennsylvania Department of
Environmental Resources, from Mr. Arnold Smith, Whitmoyer
Laboratories, Inc., re: Transmittal of the final
revision of the Revised Closure Plan, 5/17/85. P.
300047-300082. The plan is attached.
16) Letter to Mr. Stephen R. Wassersug, U.S. EPA, from Mr.
Arnold C. Smith, Whitmoyer Laboratories, Inc., re:
Transmittal of a topographic map and a site map and
a list of Whitmoyer SWMU's 9/23/85. P. 300083-
3000089. A Certification Statement, a
topographic map and a site map are attached,
17) Memorandum to Mr. F.A. Lucero from Mr. A.C. Smith,
Whitmoyer Laboratories, Inc., re: Six Month Plan for the
removal of Accumulated Hazardous Waste, 10/31/85. P.
300090-300090.
13) Telecon Note to Mr. Dave Fantasia, Waste Conversion from
Mr. D. Brayacfc, NUS Corporation, re: P waste and F waste
at facility, 3/9/86. P. 300091-300091.
-------
19) Site Visit Note to Mr. Trepanowski, NUS Corporation, re:
visited Mr. Kirst to observe the tanks and the plant,
1/12/88. P. 300092-300092.
20) Telecon Note to Mr. Arnold C. Smith and Mr. John
Trepanowski, NUS Corporation, re: P waste and F waste at
facility, 3/21/88. P. 300093-300093.
21) Telecon Note to Kathy Marino, Rollins, from Mr. John
Trepanowski, NUS Corporation, re: Haste
Incineration,5/23/88. P. 300094-300094.
22) Telecon Note to Mr. Bruce Marte, SCA, from Mr. John
Trepanowski, NUS.Corporation, re: SCA's requirement for
a waste profile, 5/23/88. P. 300095-300095.
23) Telecon Note to Mr. Mike Camfield, CECOS Landfill, from
Mr. John Trepanowski, NUS Corporation, re: EP Toxicity
values and corrosivity of a waste for acceptance,
5/23/88. P. 300096-300096.
24) Telecon Note to Mr. Jim Callahan, Chemical Waste
Management, from Mr. John Trepanowski, NUS Corporation,
re: Model City, 5/23/88. P. 300097-3000097.
25) Report: Final Work Plan, Whitmoyer Laboratories Site,
Jackson Township, Lebanon County, Pennsylvania, prepared
by EBASCO Services, Inc., 6/10/8" 8. P. 300098-300387.
26) Report: Final Field Operations Plan, Whitmoyer
Laboratories Site, Jackson Township, Lebanon County,
Pennsylvania, prepared by EBASCO Services, Inc., 6/10/88.
P. 300388-300732.
27) Letter to Mr. John Trepanowski, NUS Corporation, from Mr.
Kirk A. Stemple, Chemical Waste Management, Inc., re:
Transmittal of Waste Profile Sheets, 6/20/88. P. 300733-
300742. Waste Profile sheets for Arsanilic, Carbarsone
and Aniline are attached.
28) Site Visit Note, re: Tanks on site, 7/19/88. P. 300743-
300744.
29) Site Visit Note, re: Tanks on site and their contents,
9/27/88. P. 300745-3007451
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34)
35)
36)
37)
38)
/
30)
Telecon Note
Corporation,
Inventory of
storaqe, and
300746.
between Mr. John Trepanowski, NUS
and Mr. Jeff Pike, O.S. EPA Reqion III, re:
the Whitmoyer product inventory, aniline
a memo on subject, 9/28/88. P. 300746-
31)
Telecon Note between Mr. John Trepanowski, NUS
Corporation, and Mr. Ken Sirmarco, Delaware Container
Company, re: Delaware Container Company analyses on
wastes at Whitmoyer, 10/13/88. P. 300747-300747.
32)
Report: Preliminary Health Assessment or Whitmoyer
~aboratories, JacksonJ:0wnship, Lebanon County
PennsYl~a, prepared by Office o~th Assessment,
Aqency for Toxic Substances and Disease Reqistry (ATSDR),
11/17/88. P. 300748-300751.
33)
Telecon Note between Mr. John Trepanowski, NOS
Corporation, and Mr. Walter Mock, Betz Entec, re:
in Buildinq 9 at site, 2/3/89. P. 300752-300757.
\
Drums
Telecon Note between Mr. David Brayack, NUS Corporation,
and Mr. Rich Fuller, Rollins, re: Incineration of
liquid, 2/8/89. P. 300758-300758.
Telecon Note between Mr. John Trepanowski, NOS
Corporation and Mr. Pat McManus and Mr. Jeff Pike, U.5.
EPA, re: Tank wastes and characteristic wastes, 3/1/89.
P. 300759-300760.
Telecon Note between Mr. John Trepanowski, NOS
Corporation, and Mr. Pat McManus and Mr. Jeff Pike, U.S.
EPA, re: Liquid in Tank 7, 3/1/89. P. 300761-300763.
Telecon Note between Mr. John Trepanowski, NOS
Corporation and Mr. Pat McManus, U.S. EPA, re: Soil
and qroundwater wastes, 3/10/89. P. 300764-300764.
Telecon Note between Mr. D. Brayack, NOS Corporation, and
Mr. Kevin Zarovick, Chemical Waste, re: Incineration and
treatment of wastes, 3/13/89. P. 300765-300765.
6
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40)
41 )
42)
43)
39)
Letter to Mr. Jeffrey Pike, U.S. EPA, from Ms. Noreen
Chamberlain, Pennsylvania Department of Environmental
Resources, re: Confirmation of receipt of Whitmoyer
Laboratories, Inc. Draft Proposed Plan, 3/22/89. P.
300766-300766.
Report: Pro osed Plan Su erfund Concentrated Li uids
Remedial Action, (no author cited), 4 17/89, P. 300837-
!OOl4 5 .
Material Safety Data Sheet for Piperazine 65, prepared by
Dow Chemical U.S.A., (undated). P. 300846-300846.
Chern-Clear Inc., Sample Form for Sample No. 1644
(undated). P. 300847-300849.
7
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IV. REMOVAL DOCUMENTS
1) Letter to Mr. Jack L. Downie, U.S. EPA, from Mr. David P.
Karamer re: Laboratory and Industrial Chemicals/Hazardous
waste in the buildings and storage tanks at site,
8/25/88. P. 400001-400002.
2) Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
James M. Seif, U.S. EPA, re: Justification for
Additional Funding Request of CERCLA Removal Funds and
Change of Scope of Work, 9/21/88. P. 400003-400009. A
memorandum regarding the ceiling increase and a Change of
Scope of Work is attached.
3) Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
Stanley L. Laskowski, U.S. EPA, re: Request for an
Exemption to the One-Year Statutory Limit and Change of
Scope of Work, 12/16/88. P. 400010-400016. The request
for an approval of exemption to the One-Year Statutory
Limit and Change of Scope of Work is attached.
4) Letter to Mr. Thomas C. Voltaggio, U.S. EPA, from Ms.
Ellen S. Friedell, Rohm and Haas Company, re: Removal of
Concentrated Liquid, 4/27/89. P. 400017-400017.
5) Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr.
James M. Seif, U.S. EPA, re: Justification for Approval
of a Removal Action, (undated). P. 400018-400024. A
CERCLA Funding Request Form is attached.
8
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1) Geological Survey Map of Flood Prone Areas/ 1973, 500001-
500001.
2) Geological Survey Map of Flood Prone Areas, 1973, 500002-
500002.
3) Map Index and panels 5, 11, 12, 13, 14, Flood Insurance
Rate Map (FIRM) of Township of Jackson, Pennsylvania,
Lebanon County, (undated). P. 500003-500008.
4) Photograph of Leaking arsenic wastewater tank 1/5/Town on
12/22/82 Preparedness, Prevention and Contingency Plan
Map, (undated). P. 500009-500009.
5) Photograph of Methanol and Cellosolve Tanks, (undated).
P. 500010-500010.
6) Photograph of Tank T-3 mark PCE Aniline (Tank 10 on the
12/22/82 Preparedness, Prevention, and Contingency Plan
Map) and Tank marked PCE (Tank 9 on the 12/22/Map),
(undated). P. 500011-500011.
7) Photograph of Tank T-10 Arsenical Wastewater (Tank 4 on
the 12/22/82 Preparedness, Prevention, and Contingency
Plan Map), (undated). P. 500012-500012.
8) Photograph of Tanker Truck (marked 725) showing lack of
secondary containment, (undated) . P. 500013-500013.
9) Photograph of Tanker Truck (marked 410) taken to show
lack of secondary containment and proximity to
Tulpehocken Creek,(undated). P. 500014-500014.
10) Photograph of unmarked tanker (Tanker 19 and 20 on the
12/22/82 Preparedness, Prevention, and Contingency Plan
Map), (undated). P. 500015-500015.
11) Report: Site Analysis, Whitmoyer Laboratories Myerstown,
Pennsylvania, •
500016-500038.
Pennsylvania, prepared by U.S. EPA,(undated).P7
[pi
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12)
Report: Final Community Relations Plan Concerning
Remed'al Plannin .Activit at Selected Uncontrolled
Hazardous Substance Disposa Sites (no author cited),
(undated). P. 500039-500063.
10
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SITE SPECIFIC GUIDANCE DOCUMENTS
1) Report: Rexolin Chemicals AB Description and
classification of Chemical Piperazine 65 (technical
grade), prepared by Rexolin Chemicals, 2/1/79.
2) Report: U.S. SPA Site Analysis: Whitmover Laboratories,
Myerstown, Pennsylvania, prepared by The Bionetics
Corporation,8/84.
3) Report: Aniline - A Proposal for Testing Needs to Fill
the Data Gap Present in the Literature, prepared by Dr.
Raymond S.H. Yang, 12/18/85.
4) Report: Toxicological Profile for Arsenic (Draft for
Public Comment), prepared by The Agency for Toxic
Substances and Disease Registry, U.S. EPA, 11/87.
5) Fact Sheets: LARO, 10 FEC-80, PIPERAZINE-34, HYDROL
Concentrate, PANTEK II, prepared by Whitmoyer
Laboratories Inc., (undated). \
6) Fact Sheets: TESAN, 10FEC-20, 1QFEC-80, PANTEK-II, Clean
Hatch, Piperazine-34, Piperazine Dihydrochloride,
Arsanilic Acid-100, Ethylenediamine Dihydriodide (EDDI),
Whitsyn-S, Tzad, San-O-FEC-5; prepared by Whitmoyer
Laboratories, Kent, and Hess & Clark, Inc., (undated).
11
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GENERAL GUIDANCE DOCL'MENTS *
1) "Interim" Priorities List," Federal Register, dated 10/23/01-
2) "Expanded Eligibility List," Federal Register, dated 7/32/82.
3) "Proposal of First National Priority List," Federal Register, dated L2/3C/92.
4) Community Relations in Superfund: A Handbook (interim version), dated 9/33.
5) "Proposal of Update 1," Federal Register, dated 9/8/83.
6) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled "Transmittal
at Superfund Removal Procedures - Revision 2," dated 8/20/84.
7) EPA Groundwater Protection Strategy, dated 9/84.
8) "Proposal of Update 2," Federal Register, dated 10/15/84.
\
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activities •£.
Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 3," Federal Register, dated 4/10/85.
11) Guidance on Remedial Investigations under CEBCLA, dated 6/85.
12) Guidance on Feasibility Studies under CEPCLA, dated 6/85.
13) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments' for CEBCLA Actions, dated 3/6/85.
14) Groundwater Contamination and Protection, prepared by Mr. Donald V.
Feliciano, dated 8/28/85.
15) Memorandum to U.S. EPA from Mr. Gene Lucero re: Community relations
at Superfund Enforcement sites, dated 8/28/85.
16) "Proposal <* Update 4," Federal Register, dated 9/13/85.
17) "Promulgstion of Sites from Updates 1-4,* Federal Register, dated 6/10/86.
18) Superfund Public Health Evaluation Manual, dated 10/86.
f
19) CEPCLA Compliance with Other Laws Manual, dated 5/S8.
for Conducting Remedial Investigations and Feasibility Studies
:LA - Inter:.- ;:r.al. ;recarec =y cr.e U.S. £PA Office of Energy arc
2C) Guidance for __
under CESCLA -Inter :r ::-al, jrecarec =y cr.e U.S. £?A Office of Energy and
P-erediai Resocr.se,
* Located in EPA Region III -::.:«.
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public safety services response in
unplanned incident OCcurred during
"action. The information requested
following:
the event an
the remedial
included the
o
The name and number of an EPA contact person who
will be able to provide pertinent information in
the event of a release.
o
The work schedule, as well as the shipping
schedule and travel routes for all vehicles
transporting hazardous wastes from the site
through Lebanon County.
o
Contingency plan coordination among EPA,
EMA (Emergency Management Agency), local
safety units, Pennsylvania Department of
Environmental Resources (PACER), and the
Fish Commission.
state
County
public
o
Information regarding the type of protective
equipment needed by public safety personnel who
would be called on to respond to an emergency.
Status reports regarding cleanup activities.
o
Information, in the event of a release, regarding
level of concern and area or radius of contaminent
plume migration.
EPA RESPONSE: The name, address, and phone number of the EPA
Remedial Project Manager (RPM) for the Proposed
Concentrated Liquids Remedial Action was provided
in a letter, dated June 1, 1989. In addition, the
RPM stated that the requested information
regarding schedules, travel routes, and protective
equipment will be defined during the remedial
design and will, subsequently, be provided to the
appropriate officials, as it is developed. The
RPM also said that EPA will coordinate contingency
planning with the necessary emergency response
units and establish an acceptable project status
reporting format for use during the remedial
action.
3.0
o
REMAINING CONCERNS
There do not appear to be any significant remaining concerns
regarding the proposed remedial action. Both state and local
officials seem to be in agreement with EPA's preferred
alternative.
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ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE . . ..' . '., .
WHITMOYER LABORATORIES SITE, LEBANON COUNTY, PENNSYLVANIA
.--.." ''''.'
. .
o
EPA established a local Information Repository at the
Myerstown Public Library.
EPA provided the name of a Community Relations Coordinator who
could be contacted by the public, as needed, and who would be
knowledgeable about site-related activities.
o
o
EPA participated in a meeting called by local citizens.
Agency representatives presented general Superfund information
and discussed the status of the WLI sitee
o
EPA conducted numerous Public Meetings. Meetings were held
during Fall 1987 and in February and July 1988.
o
EPA representatives visited local residents' homes, in January
1988, to discuss well-sampling data and the proposed municipal
waterline extension.
o
EPA met with township officials and water authority
representatives, on March 8 and 20, 1989, to discuss
the extension of the public water supply system to
residences affected or threatened by the site.
o
EPA prepared a Community Relations Plan, a Proposed Plan,
Press Releases, and a Responsiveness Summary for the site and
made copies available at the local Information. Repository.
o
EPA provided a 30-day Public Comment Period, following the
release of the Proposed Plan for the Concentrated Liquids
Remedial Action.
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