United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-90/094
September 1990
&EPA Superfund
Record of Decision:
Brown's Battery Breaking, PA
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-90/094
3. Reclpient'e Accaaaion No.
4. THe and SubtfDe
SUPERFUND RECORD OF DECISION
Brown's Battery Breaking, PA
First Remedial Action - Final
S. Report Dilt
09/28/90
7. Autfior(t)
B. Performing Organization Rapt No.
». Performing Organization Name and Addrcaa
10. Project/Taak/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
12. Sponsoring Organization Nam* and Addrtaa
U.S. Environmental Protection Agency
• 401 M Street, S.W.
Washington, D.C. 20460
13. Typ» of Report A Period Covtrad
800/000
15. Supplementary Motaa
18. Abefract (Limit: 200 worda)
The 14-acre Brown's Battery Breaking site is an inactive lead-acid battery processing
facility in Tilden Township, Berks County, Pennsylvania. The area surrounding the site
is primarily agricultural with scattered rural residences. The site is bordered by
Conrail tracks, Mill Creek, and the Schuylkill River. The site lies within the 100-year
floodplain of the Schuylkill River. From 1961 to 1971, the facility recovered
lead-bearing materials from automobiles and truck batteries by breaking the battery
casings, draining the acid, and recovering the lead alloy grids, plates, and plugs.
During this time, the crushed casings were used as a substitute for road gravel or
disposed of onsite. The State conducted onsite and offsite investigations during the
1980s that identified lead concentrations in excess of acceptable limits in residents,
livestock, soil, and surface waters. A 1983 EPA investigation revealed extensive lead
contamination in onsite soil and sediment located in the Schuylkill River. As a result
of the investigation, EPA initiated an Immediate Removal Request to relocate three
families and to excavate and consolidate 13,000 cubic yards of contaminated soil and
battery casings into an onsite containment area, that was covered with a low
permeability cap. A second removal, initiated in 1990, consisted of temporarily
(See Attached Page)
17. Document Analyale a. Daacriptora
Record of Decision - Brown's Battery Breaking, PA
First Remedial Action - Final
Contaminated Media: soil, sediment
Key Contaminants: metals (lead)
b. ktonlifiera/Open-Endcd Tarma
c. COSATI Reid/Group
16. AvallaMlty Statement
It. Security daaa (Thia Report)
None
20. Security Claaa (Thia Page)
None
21. No. of Pagea
87
22. Price
(Se«ANSl-Z39.t8)
SM Initructioni on
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R03-90/094
Brown's Battery Breaking, PA
First Remedial Action - Final
Abstract (Continued)
relocating all onsite residents. The cleanup strategy for the site consists of three
operable units: site access; remediation of onsite soil and battery casings; and ground
water remediation. This Record of Decision addresses site access; subsequent actions
will address soil and ground water remediation. The primary contaminant of concern
affecting the soil and sediment is lead.
The selected remedial action for this site includes permanently relocating all onsite
residents and businesses to compatible offsite locations; decontaminating personal
belongings, as appropriate; and implementing site access restrictions including fencing
and institutional controls including deed restrictions. The present worth cost for this
remedial action is $342,900. There are no O&M costs associated with this remedial
action.
PERFORMANCE STANDARDS OR GOALS: There are no chemical- specific ARARs for this operable
unit. The initial remedy will eliminate human contact with the soil and sediment. Site
use and access restrictions will reduce the potential for transport of contaminants
offsite.
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DECLARATION FOR TEE RECORD OF DECISION
SITE NAME AND LOCATION
Brown's Battery Breaking Site
Tilden Township, Pennsylvania
Operable Unit I - Site Access
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Brown's Battery Breaking Site, located in Tilden Township,
Berks County, Pennsylvania. The remedial action was developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the Administrative Record for this site.
The Commonwealth of Pennsylvania concurs with the selected
remedy.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant
to Section 106 of CERCLA, 42 U.S.C. § 9606 that actual or
threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in
this Record of Decision (ROD), may present an imminent and
substantial endangerment to the public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for Operable Unit I, Permanent Relocation,
will eliminate human contact with contaminated soil, contaminated
ground water, and lead-bearing dust particles. The overall site
cleanup strategy consists of two additional Operable Units:
Operable Unit II which will address contaminated soils and
battery casings, and Operable Unit III which will address the
contaminated ground water. Remedial action under Operable Unit I
is consistent with the future remedial activities.
The major components of the selected remedy include:
o Permanent relocation of all onsite residences and the
onsite business
o Decontamination of personal belongings as appropriate
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o Construction of a six-foot fence topped with barbed wire
around the perimeter of the site
o Deed restrictions to prevent future residential and
industrial use of the site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable given
the limited scope of this action. However, because treatment of
the principal threats of the site was not within the limited
scope of this action, this remedy does not satisfy the statutory
preference for treatment as a principal element. The Operable
Unit II Feasibility Study is evaluating several permanent
solutions and alternative treatment technologies for their
applicability to remediate contaminated soil and battery casings.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
SEP 2 8 1990
Edwin B. Erickson Date
Regional Administrator
Region III
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THE DECISION SUMMARY
Sit* History and Enforcement Activities
Site Description
The Brown's Battery Breaking Site is located in Tilden Township,
Berks County, Pennsylvania at latitude 40° 31' 15" N and
longitude 76° 00' 06" W. The site is approximately 14 acres in
size and is located approximately two miles northwest of
Shoemakersville, Pennsylvania (Figure 1). The projected 1990
population of Shoemakersville is 1,410 people.
The site is bordered by Conrail tracks to the northwest, Fisher
Dam Road to the northeast, the Schuylkill River to the southeast,
and Mill Creek to the southwest (Figure 2).
The land use in Berks County is agriculturally oriented with
scattered rural residences on a wide variety of lot sizes. The
largest concentration of farmland in the county is in the
vicinity of the site. Pockets of commercial development exist in
Shoemakersville to meet the needs of the rural community. The
county's industrial land use tends to be concentrated in the
urban areas and along major roadways and rail lines.
Tilden Township is in the foothills of Blue Mountain, which
includes the Hawk Mountain Sanctuary and Pinnacle Peak
Conservation area to the east of the site. The Schuylkill River
is designated a state scenic river and in Tilden Township it is
used for recreation, including swimming, small boat launching and
summer riverfront cottages.
Conservation groups in the region include the Schuylkill River
Greenways Association and the Berks County Conservancy. Both
groups seek conservation easements along the Schuylkill River and
the railroad that follows its banks. The Berks County
Conservancy owns a 35-acre easement just north of the site.
Site area topography is relatively flat with the exception of two
manmade features. The Conrail railroad berm rises 9 feet above
the site and the containment area is elevated 6 to 8 feet above
the surface. Approximately 50% of the site is located in the 10-
year floodplain. The entire site, except for the central portion
of the containment area, is within the 100-year floodplain.
Currently four residences and one business are located on the
site: a one story brick home, two mobile homes, a log cabin
structure, and an automobile and truck service shop (Figure 2).
The log cabin residence was constructed prior to 1860 and has
potential historic significance.
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CONTOUR INTERVAL: 3D FEET
SOURCE: U.3.Q.8., 1«7t, AUBURN. PA. 7.5 MINUTE SERIES
QUADRANGLE AND U.S.Q.S.. 1077. HAMBURG, PA.
74 MINUTE SERIES QUADRANGLE.
FIGURE 1
BROWN'S BATTERY BREAKING
SITE LOCATION MAP
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xtNCE AND TCCHNOLOCf CORP.
PHILADELPHIA. PENNSYLVANIA
BROWN'S BATTERY BREAKING SITE
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Site History
From 1961 to 1965 the lead recovery process at the Brown's
Battery Breaking Site involved placing batteries on their sides
upon a conveyer belt that carried them to a hydraulic guillotine.
The guillotine sliced the top from each battery casing, allowing
access to the lead alloy grids. In the early years of operation,
the open-top batteries were manually inverted and the sulfuric
acid was poured directly onto the ground, along with the battery
grids. The empty battery casings were deposited on the ground
surface to the west side of the breaking building and in several
pits located along Mill Creek and the railroad tracks. Battery
grids were loaded onto a trailer for transport and resale.
From 1965 to 1971, the battery casings were rinsed with water
prior to disposal to remove any residual lead oxides remaining in
the casings. The rinse water was collected in steel tanks
together with the insoluble lead oxide. At the end of each
working day the insoluble lead oxide was recovered and shovelled
into the trailer containing the battery grids. The rinse water
was then poured directly onto the ground. The casings were
crushed after rinsing and the smaller battery casing pieces were
sometimes used as a substitute for road and driveway gravel
around the site and for several local properties, including farms
and at least one housing development.
During the ten years of facility operations, battery casings were
deposited over much of the site. The total number of batteries
processed on the site is unknown. Operations at the Brown's
Battery Breaking Site ceased in 1971, following the sudden death
of the owner/operator. In 1978 the site was purchased by the
current owner of the site. The parcel of land in the northeast
portion of the site surrounding the log cabin is owned by a
separate individual.
In March 1980, the Pennsylvania Department of Environmental
Resources (DER) was requested to examine the cattle and water
supplies at a dairy farm near the site in Shoemakersville,
Pennsylvania. Tests on the cattle and farm-pond water indicated
elevated lead levels. Further investigation revealed the use of
broken battery casings as the driveway materials at the farm.
The farmer identified a nearby property on Fisher Dam Road,
formerly owned by Robert Brown, as the supplier of the battery
casings.
In June 1983, the Pennsylvania Department of Health (DOH) tested
the blood of the four young children residing on the site. The
blood tests for all four children revealed lead concentrations in
excess of the 30 micrograms per deciliter (ug/dl) health action
limit. The health action limit was established by the Centers
for Disease Control (CDC). DOH subsequently instructed parents
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on proper cleaning procedures and limiting the children's
activities in contaminated areas.
A Preliminary Assessment and Site Investigation (PA/SI) was
conducted by EPA in 1983. The PA/SI established extensive lead
contamination in onsite soils and in sediments located in the
Schuylkill River.
Based on the PA/SI results, the EPA ON-Scene Coordinator (OSC)
determined that a detailed Extent of Contamination (EOC) survey
was required. The EPA Environmental Response Team (ERT) was
tasked to design a multimedia survey that would address the areas
of concern identified during the PA/SI. The survey had the
following objectives:
o Determine the areal and vertical extent of contamination,
including battery casings, soils, and sediments;
o Determine the total quantity of waste materials present
and identify deposits of potentially recoverable lead; and
o Determine the potential for surface water, ground water,
and air to transport lead from the site.
The field sampling program for the EOC survey was conducted
November 1-3, 1983 by ERT. Samples were collected from soil,
air, vegetables grown in two onsite gardens, two drinking-water
wells, Schuylkill River and Mill Creek surface waters and
sediments, ponded water on the site, and battery casing piles.
Figure 3 illustrates the ERT sampling locations and associated
lead concentrations. In addition, battery casing depths were
recorded along an established sampling grid, and sampling points
were surveyed. A rapid turnaround Feasibility Study (FS) report
was completed during this same time period. The purpose of the
report was to evaluate methods of hazard mitigation.
The FS conducted evaluated seven hazard mitigation alternatives:
1. Disposing of the wastes offsite;
2. Constructing a secure landfill onsite;
3. Capping the wastes onsite;
4. Incinerating the wastes onsite;
5. Soil washing of waste for offsite use or disposal;
6. Stabilizing waste onsite; or
7. Limited waste removal from the site.
The study was completed in December 1983, and concluded that
capping addressed the immediate threat to the public health by
preventing direct contact with lead bearing soils and dust by
people living or working on the site.
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APmOMIMIE WMPIC STATION^
EXTENT OF COMTAMMATON 8URVEV
{_) MTTEIWCASMM FOUND AT SITE
/\ SEOMCNI/EUnFMX WMTER SMO>UNa SITE
W » SURFACE WMTENOONCOfflMnONS
S-
SCALE: NONE
Sown: MiiiMail t«n
ta rn*ntwm
JUMIW4
WA NO. 914)1-31B4
FIGURE 3
PREVIOUSLY IDENTIFIED
AREAS OF CONTAMINATION
AND SAMPLING LOCATIONS
BROWN'S BATTERY BREAKING SITE
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A CERCLA Immediate Removal Request was forwarded from EPA Region
III to EPA Headquarters on October 6, 1983. Approval was granted
on October 20, 1983, and the three families residing on the site
were relocated on October 31, 1983. Excavation of the
contaminated soils and battery casings began on January 9, 1984
and continued until June 13, 1984. Soils and battery casings were
placed in the southwest section of the site and covered with a
low-permeability soil cap. This area is referred to as the
"containment area."
The amount of excavated battery casings and soil materials moved
into the containment area during the removal action was reported
as approximately 13,000 cubic yards. Nearly 20,000 cubic yards
of clean fill was used to regrade the excavated areas, primarily
on the northeast, the southeast, the area between the railroad
tracks and containment area, and central portions of the
property. The containment area was capped with over 6,000 cubic
yards of low-permeability soil. The resulting containment area
measured 600 feet by 230 feet and was 6 to 8 feet high. The
total cost of the removal and containment was approximately 1.4
million dollars. The removal action was formally completed on
July 11, 1984.
Inclusion on the National Priorities List
The Brown's Battery Breaking Site was proposed for inclusion on
the Superfund National Priorities List (NPL) in October 1984.
The site was formally placed on the NPL in June 1986.
Current Activities
As a result of the Remedial Investigation/Feasibility Study
(RI/FS) sampling activities conducted between June 1989 and March
1990, a second removal action was determined to be necessary.
This decision was based on a toxicological review of surface soil
sampling results which found elevated lead concentrations on the
property of current residents and in areas immediately adjacent
to their homes. A detailed discussion of the location and
analytical results of the samples is included below in the
"Summary of Site Characteristics".
The second removal action was initiated in June 1990 and is
currently in progress. This action provides for temporary
relocation of all onsite residents to suitable offsite locations.
Seven adults and two children currently reside onsite in the four
residences. This action does not address the onsite automobile
and truck service shop which employs four adults, two of which
reside in onsite residences.
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History of CERCLA Enforcement Activities
Between October 24 and 26, 1983, General Battery Corporation
(GBC) and the site owner were verbally notified of EPA's intent
to conduct removal activities at the site and to determine
whether responsible parties would voluntarily perform such
activities. A follow-up letter on November 17, 1983 to both
parties indicated that, since neither the site owner nor GBC had
notified EPA of their willingness to undertake the removal
activities, EPA would proceed with such activities.
On June 30, 1987 GBC entered into an Administrative Order On
Consent to perform the RI/FS for the Brown's Battery Breaking
Site. However, on August 4, 1988 GBC formally notified EPA that
GBC was "unwilling to proceed with the performance of the RI/FS,
as modified by the EPA." On August 25, 1988 the Regional
Administrator notified GBC that EPA would take over the RI/FS and
release GBC from all obligations under the June 30, 1987 Consent
Order, except for the obligation to pay any stipulated penalties
and accrued oversight costs.
In March of 1985, the United States brought a civil action,
pursuant to Section 104 and 107 of CERCLA, 42 U.S.C. § § 9604 and
9607, against GBC and the site owner. In the action, the United
States sought its past costs for the 1983-84 removal action and
for all subsequent costs associated with the response work at the
site.
On June 1, 1990 the United States District Court for the Eastern
District of Pennsylvania granted the United States' motion for
partial summary judgment by finding GBC and the current site
owner liable for those past and future costs not inconsistent
with the NCP. In addition, the Court granted the United States
sixty days to answer GBC's counterclaims.
On July 27, 1990 EPA issued a Unilateral Order pursuant to
Section 106(a) of CERCLA, 42 U.S.C § 9606(a), to GBC and the site
owner, to perform additional removal work at the site. The order
required GBC and the site owner to either temporarily relocate
those onsite residents desiring such relocation or excavate
contaminated surface soils and relocate affected residents during
the excavation. The order provided the respondents with three
business days from receipt of the order to indicate whether they
intended to comply with the terms of the order.
Highlights of Community Participation
The onsite residents and workers have been kept well informed of
the site conditions throughout the remedial field activities.
Frequent informal meetings were held with individuals outside of
their residence or at the onsite business. Residents and workers
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were also informed of the overall clean-up strategy and were
frequently updated via phone calls with the status of EPA's major
actions.
A meeting was held on July 24, 1990 in the Tilden Township
Municipal Building to discuss the rights and benefits of the
residents associated with the temporary relocation action. The
meeting was attended by all adult site residents and
representatives from EPA Region III, EPA Headquarters (HQ), and
the United States Army Corps of Engineers (USAGE).
All public participation requirements of Sections 113(k)(2)(B)
(i-v) and 117 of CERCLA were met in the remedy selection process.
A one quarter page newspaper advertisement was published in the
Reading Times on August 17, 1990. It specified the availability
of the Proposed Remedial Action Plan (PRAP), public comment
period, and the location of the Administrative Record. All
onsite residents and known Potentially Responsible Parties were
mailed a copy of the PRAP at the beginning of the public comment
period.
The public comment period on the PRAP began on August 17, 1990
and ended on September 15, 1990. A public meeting to discuss the
PRAP was held on September 4, 1990 at the Tilden Township
Municipal Building. Approximately 40 people attended, including
former and current site residents, the current site owner,
supervisors from Hamburg Borough as well as staff from EPA Region
III, USAGE, and DER.
Residents and the site owner were mailed a copy of the PRAP
meeting transcript on September 21, 1990. Comments on the PRAP
were received from two sources. One resident wrote he was "not
moving" and GBC submitted several comments and questions.
Media interest has been primarily local. However, on
September 24, 1990 WFMZ-TV Channel 69 (Independent) in Allentown
called EPA for information about the site after being contacted
by one of the onsite residents.
SCOPE AMD ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
The overall site clean-up strategy consists of three Operable
Units: 1) site access; 2) remediation of onsite soils and
battery casings; and 3) remediation of ground water. This Record
of Decision addresses Operable Unit I, Site Access.
The RI/FS currently in progress has documented extensive
contamination of onsite soils. It documents the release of
contamination into adjacent surface water and sediments and into
the ground water of the upper aquifer. Contamination to the
ground water appears to be limited and has not significantly
-------
affected the two onsite residential wells. The full extent of
ground water contamination will be determined during a second
RI/FS scheduled to begin in late 1990/early 1991.
The Operable Unit I remedial action must be consistent with
future remedial activities. Based on the location, volume and
level of contamination determined during the ongoing RI/FS, it is
anticipated that extensive soil excavations will occur in areas
immediately adjacent to the residences and the business.
Extensive excavation activities will require significant site
access restrictions during the Operable Unit II remedial
activities.
SUMMARY OF SITE CHARACTERISTICS
In this section, results of the sampling and chemical analyses
from the Operable Unit II RI are given, and the nature and extent
of contamination in each medium sampled are discussed. Media
sampled include soil, ground water, surface water, and sediments.
Air was not sampled during the RI, but the potential for
contaminant migration via the air pathway was evaluated using the
Industrial Source Complex (ISC) model. Data generated by the
Contract Laboratory Program (CLP) was validated according to EPA
Region III protocols. All CLP data reviewed in the following
sections represents validated results.
Soil is by far the most contaminated medium onsite. Lead is the
most abundant, widespread, and concentrated contaminant present.
Low concentrations of other metals and Target Compound List (TCL)
organic contaminants were also sporadically detected in soils and
other media, but these contaminants are relatively minor and do
not pose significant environmental hazards. Therefore, the
following discussion on the nature and extent of site
contamination focuses on the occurrence of lead.
Site soils and associated lead-bearing wastes (battery
components) are the primary sources of lead occurring in all
other environmental media. Another source of lead in site soils
was battery acid drained onto the soils in the vicinity of the
breaking building. Relatively high lead concentrations were
detected in this area, but due to the presence of abundant
battery casings in subsurface soils, the relative contribution of
battery acid is undetermined.
Most of the crushed battery casings and associated lead-
contaminated soils were consolidated in the containment area and
capped during the initial removal action. However, some
contaminated soils were left in place and covered by backfill
materials after battery casing/soil removal. Vertical
distribution of lead in the soil column is not consistent
10
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throughout the site and does not always display a simple pattern
of high surficial concentrations that decrease with depth, in
some areas, surficial soils are relatively clean whereas
underlying soils are contaminated.
Areal Extent of Surficial Lead Contamination Outside of the
Containment Area
Surficial soil lead contamination in excess of 500 parts per
million (ppm) is widespread throughout the site. The level of
500 ppm was chosen as a guide during the RI based on EPA's
"Interim Guidance on Establishing Soil Lead Cleanup Levels at
Superfund Sites". The final cleanup level will be determined
during Operable Unit II. Lead concentrations of up to 60,000 ppm
were detected near the surface, but concentrations were generally
below a few thousand ppm. Figure 4 presents the approximate
horizontal extent of lead contamination on the site.
RI data indicate that virtually the entire gravel driveway area
including the site entrance, the area on either side of the
service shop, and the large area between the service shop and
containment area are contaminated with lead. Contamination
observed between the auto shop and containment area extends into
the yard of the mobile home residence located on the Schuylkill
River, especially on the southwest side of the residence. Most
samples had lead concentrations between 1,000 ppm and 3,500 ppm,
with less than 10 percent of the samples below 500 ppm, and
approximately 20 percent of the samples above 3,500 ppm.
Other notable areas with elevated lead trends include the
backyard area northwest of the mobile home residence located
along the Conrail tracks, the grassy area just north of the
entrance driveway, and the wooded area between the containment
area and the Schuylkill River.
In March 1990, ERT analyzed 121 surface soil samples and
subsurface samples from 23 locations within this wooded area,
using field analytical equipment. Approximately 33 percent of
surface samples had lead concentrations between 1,000 and 10,000
ppm, and eight percent had lead concentrations greater than
10,000 ppm. Due to the proximity of the Schuylkill River to this
area, erosion and transport of contaminated soils to the river is
a major concern.
The distribution of lead in soils in the wooded area correlate
well with small piles of battery casings and soil observed
throughout the area. The occurrence of battery casings was
concentrated in a narrow band approximately two feet high along
the northwestern edge of the wooded area. Numerous small piles
of battery casings were also observed in the southwest half of
11
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•AMD OM MS Mn 1£AO CU/IM* tlVCL
N{.HCC AND TECHNOlOCr CORP.
BRONN'S BATTERY BREAKING SITE
WPHOXINAIt
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the wooded area, accounting for the high concentrations of lead
observed in that area.
In general, areas throughout the site where battery casings were
observed at the surface had high soil lead concentrations. These
areas include the area near the northeast corner of the
containment area, the area surrounding the breaking building
foundation, and the wooded area.
Vertical Extent of Lead Contamination Outside the Containment
Area
The vertical extent of lead contamination in site soils was
evaluated through the drilling and sampling of 32 soil borings
and monitoring well boreholes (28 borings, 4 wells). In
addition, 33 shallow borings were installed and sampled using
hand augers by ERT and EPA Region III personnel. Most hand
borings were installed in areas that were inaccessible to the
drilling rig (i.e. residential areas, wooded areas).
Table 1 gives the depth to the 500 ppm lead concentration for all
locations where soil boring samples were obtained. Soil boring
locations used to determine the vertical extent of contamination
are shown on Figure 5.
Borings taken in the wooded area were installed primarily in
areas where small piles of battery casings were visible on the
ground surface. Sample results indicate that subsurface soils
were largely uncontaminated except for discreet "hot spots"
located within or near the small piles of battery casings and
soil. Subsurface soil lead concentrations in these "hot spots"
range up to 28,000 ppm, with three of nine samples analyzed in
the laboratory having lead concentrations of 10,000 ppm or
greater.
Surface lead contamination above 500 ppm is present throughout
most of the site, and is generally confined to the upper three
feet of soil. Exceptions include the strip of land between the
containment area and Conrail tracks, where lead concentrations
above 500 ppm were detected to depths of six feet and the
containment area where battery casing burial was reportedly
observed at depths of up to 10 feet below the pre-containment
area land surface.
In some areas, surficial soils had relatively low concentrations
of lead, and shallow subsurface soils had concentrations of lead
greater than 10,000 ppm. In these areas, layers of battery
casings were observed at depths ranging from one to three feet.
Areas in the vicinity of the battery breaking building and the
area just south of the brick residence are the most significant
examples of this observation.
13
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TABLE 1
DEPTH TO 500 PPM LEAD CONCENTRATION
(Depth in Feet)
Borehole #
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
MW-8
MW-9
MW-10
MW-11
XRF Data
6.
1.
3.
0
0.
0
0
0
0.
1.
5.
3.
1.
0.
0
0.
5.
1.
2.
>0
0.
0 -
4 -
4 -
3 -
-
8 -
3 -
0 -
1 -
5
8 -
9 -
0 -
0 -
5 -
.5
8 -
6
4
4
0
0
2
2
7
3
2
2
5
2
3
.5
.5
.6
.4
.4
.5
.6
.0
.2
.0
.5
.5
.0
.0
Laboratory Data Midpoint
(CLP ICP and ERT AA)
6.
<4
3.
2.
0.
NR
<0
<2
0.
1.
<3
3.
1.
0.
<2
0.
<3
1.
2.
0 -
.8
4 -
7 -
3 -
.4
.5
8 -
3 -
.5
1 -
5
8 -
.0
9 -
.5
0 -
5 -
6
4
4
0
2
2
3
2
2
2
3
.5
.6
.0
.4
.5
.6
.2
.0
.5
.0
.0
NR
4
.5
NR
0
1.
1.
NI
2.
0
>6
2.
0
4.
0
0.
5 -
0 -
5 -
.5
5 -
2
2
3
.0
.5
.0
0.
<3
<2
1.
1.
NI
2.
<2
8 -
.5
.5
5 -
0 -
5 -
.5
4
2
2
3
*2.5 -
3
.0
2.
5 -
3
.5
.8
.5
.0
3.2
.0
NR
0 -
8
4
.5
4.
0
0.
0 -
8
4
.5
6.25
2.4
4.0
3.35
0.35
NR
0.2
1.25
1.65
1.95
1.75
3.15
1.5
1.4
1.0
1.7
1.75
1.5
2.75
NR
2.65
1.75
1.25
2.15
1.75
NI
2.75
1.25
>6.5
2.75
NR
4.25
0
0.8
Maximum
6.
4.
4.
4.
0.
NR
0.
2.
2.
2.
3.
3.
1.
2.
2.
2.
3.
2.
3.
5
8
6
0
4
4
5
5
6
5
2
5
0
0
a
5^
0
0
NR
4.
3.
2.
2.
2.
5
5
5
8
5
NI
3.
2.
0
5
>6.5
3.0
NR
4.
0
0.
,5
,8
NR =• Not Run by Laboratory
NI - Not Installed
* = Deeper samples not run by laboratory, depth to 500 ppm determined by
using XRF data.
14
-------
TABLE 1
DEPTH TO 500 PPM LEAD CONCENTRATION
(Depth in Feet)
Borehole #
E-l
E-32
E-33
E-34
E-36
E-39
E-40
E-41
E-42
E-45
E-46
E-288
E-290
E-298
E-301
E-302
E-303
E-304
E-305
E-307
E-308
E-311
E-312
E-313
E-314
E-315
E-316
E-317
E-318
E-319
E-321
E-322
E-323
XRF Data
0
0.0-0.5
0
0.0-0.5
0.5-1.0
1.5-3.0
0
0.0-0.5
0.0-0.5
0
0.5-1.0
0.0-1.0
0.0-1.0
0.0-1.0
0.0-1.0
1.0-2.0
0.0-1.0
1.0-2.0
0.0-1.0
1.0-2.0
1.0-2.0
0
1.0-2.0
0.0-1.0
1.0-2.0
0
0.0-1.0
0
2.0-3.0
1.0-2.0
1.0-2.0
2.0-3.0
1.0-2.0
Laboratory Data
(CLP ICP and ERT AA)
NR
0.0-0.5
NR
0.0-0.5
>0.5
>1.5
NR
0.0-0.5
<0.5
0
NR
NR
NR
NR
NR
NR
<2.0
<2.0
NR
NR
NR
0
>1.0
NR
<2.0
<2.0
NR
NR
>2.0
<2.0
NR
>2.0
NR
Midpoint
0
0.25
0
0.25
0.75
2.25
0
0.25
0.25
0
0.75
0.5
0.5
0.5
0.5
1.5
1.0
1.5
0.5
1.5
1.5
0
1.5
0.5
1.5
1.0
0.5
0
2.5
1.5
1.5
2.5
1.5
Maximum
0
0.5
0
0.5
1.0
3.0
0
0.5
0.5
0
1.0
1.0
1.0
1.0
1.0
2.0
1.0
2.0
1.0
2.0
2.0
0
2.0
1.0
2.0
0
1.0
0
3.0
2.0
2.0
3.0
2.0
NR = Not Run by Laboratory
E designates samples collected by th« ERT/REAC team.
* = Deeper samples not run by laboratory, depth to 500 ppm determined by
using XRF data.
15
-------
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-------
Using the level of 500 ppm, the volume of soil and battery
casings outside the containment area requiring excavation is
estimated to be 20,500 cubic yards. This volume will change
based on the final cleanup level determined during Operable Unit
II.
Volume of Contaminated Soil/Battery Casings within the
Containment Area
Two test pits were excavated within the containment area to
obtain samples for the two treatability studies. The excavations
indicate that the material in the containment area is
approximately 70 percent crushed battery casings (visual
estimate). The total volume of waste materials in the
containment area is estimated at 39,500 cubic yards. This
estimate is based on cross-sections and as-built drawings
prepared during the initial removal action, assuming that all
materials placed in the containment area were contaminated.
Domestic Well Sampling and Analysis
The two domestic wells onsite (log residence well [GW6] and brick
residence well [GW7]) were each sampled twice during the RI for
Target Analyte List (TAL) parameters. The log residence well was
sampled a third time for lead analysis only. Both wells were
sampled once for TCL parameters. The log residence well is a
hand-dug well completed in the shallow unconsolidated alluvial
deposits. It is reportedly 13 feet deep. The brick residence
well is a drilled well, and is reportedly 140 feet deep. It is
completed in the fractured bedrock aquifer, and the depth of the
well intake is unknown. No well records are available for either
well.
The pH of the log residence well (5.7, 6.0) is slightly depressed
compared to that of the background well (MW-8, 6.7) indicating a
possible influence from the pouring of battery acid on site
soils. Depressed pH generally increases the likelihood of metal
solubilization and the migration of metals in ground water. The
pH of the brick residence well was measured at 6.0 and 6.6 on
separate occasions. There is no site background well installed
in the bedrock for comparison.
Only unfiltered samples were collected from the domestic wells.
Metals analyses of the domestic wells are therefore indicative of
the total metal content of the samples, including metals
contained in suspended sediments and colloids. Water samples
from both wells were clear and apparently free of sediment.
Lead was detected at an estimated concentration of 4 parts per
billion (ppb) in the second of the three samples obtained from
17
-------
the log residence well. The well was subsequently resampled,
with no lead detected.
The log residence well was inaccessible for sampling, so samples
were obtained from the kitchen faucet. The well was purged prior
to sampling by allowing the water to run 15 to 30 minutes, at
which time the temperature, specific conductance, and pH of the
water had stabilized. At this time, insufficient data exist to
determine whether the lead is a result of site ground water
contamination or the result of leaching from household plumbing.
The brick residence well was sampled on two occasions. Lead was
not detected in either of the samples.
Monitoring Well Sampling and Analysis
Existing monitoring wells (MW-3, MW-4, and MW-5) (Figure 5) and
new monitoring wells installed during the RI (MW-8, MW-9, MW-10
and MW-11) (Figure 5) were sampled during Phase II of the RI for
TAL inorganics analysis. MW-9 was also sampled for TCL organics
analysis. The only organic compound detected was
bis(2-ethylhexyl)phthalate, at a concentration of 15 ppb.
All monitoring wells were completed in the shallow unconsolidated
alluvial deposits. Both filtered and unfiltered samples were
obtained. Unfiltered sample analyses are indicative of total
metals concentrations, including metals contained in suspended
sediments. Of the two types of analyses (dissolved metals and
total metals), dissolved metals results are more indicative of
ground water quality and the availability of metals for ground
water transport.
Several metals were detected in elevated concentrations in
filtered ground water monitoring well samples. These include
lead, aluminum, iron, cobalt, manganese, nickel and zinc.
Apparently, some of the elevated dissolved metals concentrations
are the result of reduced ground water pH. Ground water pH is
depressed onsite, probably as a result of battery acid being
poured on the surface soils. In general, metals become more
soluble as the pH of ground water decreases. Ground water pH
values for monitoring veils range from 4.0 (MW-10) to 6.7 (MW-8,
background).
Well MW-10 was the only well with detectable concentrations of
dissolved lead (estimated 14.3 ppb) and had the lowest pH of all
wells onsite (4.0). MW-10 is located downgradient of the battery
breaking building, where battery acid generated by battery
breaking operations was reportedly poured onto the ground.
MW-10 also had very high concentrations of dissolved aluminum
(3,670 ppb, highest of all wells). The occurrence of dissolved
18
-------
aluminum appears to be related to ground water pH. Total
aluminum concentrations ranging from 4,720 ppb to 140,000 ppb
were detected in all unfiltered monitoring well samples but
dissolved aluminum was detected only in the three wells with
lowest pH values (MW10 - pH 4.0, MW11 - pH 4.7, and MW3 - pH
4.8) .
Surface water analytical results indicate that contaminated
ground water may be discharging to surface water. Three
dissolved metals, iron, manganese, and zinc were detected in
surface water samples taken immediately adjacent to the site.
These metals were detected in concentrations above background
surface water concentrations, and were generally not detected in
samples taken downstream of the site with the exception of
manganese. This pattern of occurrence indicates possible
discharge of metal-contaminated ground water from the site to the
adjacent surface water bodies. Dissolved metal concentrations
appear to be quickly attenuated upon discharge to surface water.
Attenuation mechanisms include dilution in the water column,
sorption to sediments, and precipitation of soluble species.
Surface Water Sample Results - Schuylkill River
Seven locations in the Schuylkill River were sampled during
Phases I and II of the RI. Filtered and unfiltered samples were
taken at each location. The resulting lead concentration for
each surface water sampling location is given in Figure 6.
Lead was not identified in any filtered surface water samples
collected in the Schuylkill River during Phases I or II. In
addition, no detectable lead was reported in the unfiltered
samples collected during Phase I. However, low concentrations of
lead were identified in five unfiltered sample stations collected
during Phase II. Approximate locations and corresponding lead
concentrations are summarized below in Table 2.
The lead values for stations 3SR and 5SR were roughly three to
four times greater than the background lead concentration.
Stations 2SR and 4SR contained slightly lower lead concentrations
than station 1SR, the background station. These three values
were below the Contract Required Detection Limit (CRDL) of 5.0
ug/L and above the instrument detection limit of 1.0 ug/L. All
five values were qualified (J) during data validation. The
qualifier indicates lead is present, however, the actual
numerical values provided is estimated.
19
-------
K)
o
7SR
5
• • SURFACE WATER SAMPLE LOCATIONS
SR • SCHUYUOU. RIVER
MC • MH CREEK
17.3- LEAD CONCENTRATION (my/Kg)
J • ANALYTE PRESENT
(Reported value may not b»
CONTOUR INTERVAL: 1 FOOT
Scale Norw
Soutc«: Modilhid horn land turttrf partmnwd
to» En»»oom»nU) RMponM TMm, Joo« 19B4.
NOTE: 1.0 moll (•Owr
•moonridrndnoi
1.0 mo/I
WA NO. 91-01-3L84
FIGURE 6
APPROXIMATE SURFACE WATER
SAMPLING SITES WITH ASSOCIATED
LEAD CONCENTRATIONS IN ppm
BROWN'S BATTERY BREAKING SITE
-------
TABLE 2
SCHUYLKILL RIVER SURFACE WATER
Station Approximate Lead Concentrations
(Unfiltered) Location micrograms/liter (ug/L)
1SR Background: 100' upriver 4J
of Fisher Dam Bridge
2SR At boat ramp 3.9J
3SR 900' downriver of
Fisher Dam Bridge 17.3J
4SR 1,400' downriver of
Fisher Dam Bridge 3.0J
5SR North of Small Island 12.7J
Because lead was only found in unfiltered samples, it is believed
that the lead measured in these samples was adhering to particles
suspended within the water column. Unfiltered surface water
samples collected directly adjacent to the river bank contained
measurable lead. However, lead was not detected in samples 6SR
and 7SR which were collected downstream in the bulk flow of the
river. The presence of lead adjacent to the site could be the
result of recent erosion or resuspension of lead-bearing
sediments. Lead was detected in all sediment locations in the
Schuylkill River.
Surface Water Sample Results - Mill Creek
Five surface water locations were sampled in Mill Creek during
Phase I and II sampling activities. Filtered and unfiltered
samples were obtained from each location. Figure 6 illustrates
the resulting lead concentrations at each sample location.
A detectable concentration of lead was identified in only one
surface water sample analyzed during the entire sampling effort
in Mill Creek. Sample SMC (unfiltered), collected at the
confluence with the Schuylkill River during Phase II, revealed a
lead concentration of 18 J ug/L.
Due to the fact that this sample was unfiltered, it is believed
that the lead contained in this sample is adsorbed to particulate
21
-------
matter suspended in the water column. The sediment sample
collected at approximately the same location contained 11 ppm
lead in a silty clay sediment sample. Lead contaminated soils
are present in the soil sampling stations located directly
upgradient of 8MC. The embankment is steep and poorly covered
with obvious signs of erosion. Sample location 12MC is the
background sample for Mill Creek surface water. No lead was
present above detection limits in the background sample during
Phases I and II of testing.
Sediment Sample Results - Schuylkill River
Nine sediment sampling stations were sampled during Phase I and
two additional upgradient stations were sampled during Phase II.
All eleven samples were sampled for the full suite of 23 metals
in the TAL. Figure 7 contains the resulting lead concentrations
at each sample location.
Lead was detected in all eleven sediment sample locations in the
Schuylkill River. Samples collected upgradient of the site
contained variable amounts of lead: BG1SR (259 ppm), BG2SR (63.2
ppm), and 1SR (126 J ppm). The concentrations of lead in
upgradient sediment samples in the Schuylkill River are
significantly elevated. Upgradient samples in Mill Creek range
from 8.4 ppm to 20.1 J ppm.
Stations 2SR and 4SR contained higher sediment lead
concentrations than all three of the upgradient samples.
Stations 5SR and 7SR contained higher lead concentrations than
upgradient samples BG2SR and 1SR.
The most highly contaminated sediment sample, 4SR (367 ppm), is
located adjacent to the wooded area in the southwest portion of
the site. Poorly vegetated steep banks and a swift current in
the river provide evidence of significant erosion. Elongated
piles of soil and battery casings approximately two feet in
height are common throughout this area. Surface soils exhibit
some of the highest levels of contamination found onsite outside
of the containment area.
Sediment sample 2SR is located in a depositional area of fine
grained sediments near the boat ramp. The construction of the
boat ramp provides a cross-sectional view of the soil profile.
Numerous battery casings are visible in the subsurface soil
exposed along the sidewalls of the boat ramp. Battery casings
were also found in the sediments at this location. The lead
content of this sample (281 ppm) was higher than all upgradient
samples.
22
-------
N>
Bt«K¥lMiil*JJi;-'.-i»«i.-iiir.---.--r,-J**1*
-96R'
46.9 J
8R
MC
4.3
ScafeNon*
Source: Mod««d Horn Itnd «urv«y pwtonMd
kx EnvHonriMnUI R«ponM TMm. Jun» 1054.
8EOMENT SAMPLE LOCATIONS
8CHUVLMUWVER
MU. CREEK
LEAD CONCENTRATION (n^I/Ko)
OUPUCATE SAMPLE «l«/K4)
ANALVTE PRESENT
(ftaportMl vriu* nwy not b«
CONTOUR INTERVAL: 1 FOOT
BO • BACKGROUND SAMPLES. PHASE I
WANO.91-01-3L84
FIGURE 7
APPROXIMATE SEDIMENT SAMPLE
LOCATIONS WITH ASSOCIATED
LEAD CONCENTRATIONS IN ppm
BROWN'S BATTERY BREAKING SITE
-------
The strong current of the river attenuates the additional lead to
this system within a few hundred feet downriver from the site.
Sample locations 5SR (198 ppm lead) and 7SR (131 ppm lead) are
located between two islands located immediately downriver of the
site (Figure 7). Sample 8SR and (60.1 J ppm lead) and 9SR (45.6
J ppm lead) are located approximately 120 feet and 350 feet
respectively, downriver of the islands.
Bioassessment Testing on Schuylkill River Sediments
A whole sediment chronic bioassay test was performed based on the
recommendation of the Region III EPA Bioassessment Group.
Chironomus tentans (midge) was used for chronic sediment bioassay
emergence studies conducted on the Schuylkill River sediment
samples. Samples were collected from four locations on the river
during Phase II sampling. Figure 8 illustrates the four stations
chosen for this purpose (BAl-located near station 6SR-Sed, BA2 -
located on the southwest end of the larger island, BA3 - located
10 feet upstream of station 2SR-Sed, and BA4 - located downriver
of station 3SR-Sed). These stations were chosen because of their
fine-grained sediment texture and because of their location in
depositional zones near the site. In addition, Phase I sediment
sampling results indicated that the above areas represented a
typical range of sediment lead concentrations.
The results of the tests, according to the toxicological
evaluation, were as follows:
"No significant difference in emergence of midges could
be detected between control and test sediments.
Control emergence totalled 76 percent. Although sample
BA4 had low emergence (61 percent), relative to the
controls, there was high enough variability in the
response to this sample to preclude significance...
The fact that BA3 showed higher emergence than the
controls indicates that this sample may contain better
growth conditions than the control in terms of particle
size or organic matter."
Sediment Sample Results - Mill Creek
Seven sediment locations were sampled for TAL metals in Mill
Creek during Phase I sampling activities. Lead was detected in
all sediment samples collected in Mill Creek. However,
background sediment samples (15MC and 16MC) contained equal or
greater concentrations of lead than the downstream sediment
samples. The highest concentration identified was 20.9 ppm and
the lowest sediment concentration was 8.4 ppm.
24
-------
vet
• MOASSESSMEMTSAMPtf LOCATIONS
SCALE: NONE
SOURCE: MODIFIED FROM LAND SURVEY PERFORMED FOR
ENVIRONMENTAL RESPONSE TEAM. JUNE 1864.
CONTOUR INTERVAL: 1 FOOT
WA NO. 91-01-3L84
FIGURE 8
APPROXIMATE BIOASSESSMENT
SAMPLE LOCATIONS
BROWN'S BATTERY BREAKING SITE
-------
Air
The Ambient Air Quality Impact Assessment is based on information
provided by the RI/FS Work Plan (8/25/89), the ERT/REAC final
report (1/6/90), local climatological data for Allentown, PA
(1977-1988), seasonal and annual "STAR" meteorological data for
Harrisburg, PA (1977-1988), and personal interviews with
residents and workers at the site. Ambient air concentrations of
lead in and around the Brown's Battery Site result from the
physical entrainment of lead bearing particulate matter. Two
modes of physical entrainment of the particulate matter were
identified:
o Wind erosion
o Vehicular traffic on unpaved roads
The industrial Source Complex Long Term (ISCLT) model was
selected as the most appropriate dispersion model to evaluate the
potential particulate matter and lead emission from the site.
The ISCLT model is used to estimate seasonal and annual ambient
air concentrations of pollutants. The National Ambient Air
Quality Standard (NAAQS) for lead is 1.5 ug/m3.
Dispersion modeling was performed for each season of the year
based on constant particulate matter emissions for each season.
The results are broken down into three main categories: maximum
impacts onsite; maximum impacts at the onsite residences; and
maximum impacts offsite. The results include total particulate
matter impacts and total lead concentrations. The modeled
ambient particulate matter impact results were multiplied by the
mean lead concentration in the driveway material to arrive at the
modeled ambient lead impact concentrations.
The maximum particulate matter and lead impact occurred at a
location approximately 35 meters north-northeast of the log cabin
residence. The estimated quarterly average lead impact
concentration at this location is 0.0041 ug/m3 or approximately
0.3 percent of the National Ambient Air Quality standard (NAAQS).
The modeled maximum offsite particulate matter and lead impact
was estimated to be 1.044 and 0.0018 ug/m3, respectively. This
impact occurred on the Schuylkill River south of the parking area
near the log cabin residence. The quarterly lead concentration
represents 0.1 percent of the NAAQS for lead. Modeled lead
concentrations decreased rapidly beyond the site boundary.
In summary, the model predicts that low concentrations of lead-
bearing particulate matter can become airborne through wind
erosion and disturbances caused by vehicular traffic. The model
further predicts that virtually no lead-bearing particulate will
migrate beyond the site boundary.
26
-------
CONTAMINANT FATE AND TRANSPORT
The contaminant of greatest concern on the Brown's Battery
Breaking Site is lead. Lead is the most widespread and
concentrated contaminant present on the site and was identified
as the contaminant of greatest health concern on the site based
on a numeric ranking and baseline risk assessment.
Current information about the Brown's Battery Breaking Site
indicates three migration pathways are significant: the air
pathway; ground water pathway; and surface water pathway. Data
collected during the RI indicate that offsite migration occurs to
the surface water and ground water pathways. Current data on the
ground water pathway is limited to the shallow unconfined aquifer
due to the limited scope of the hydrogeologic investigation. An
expanded hydrogeologic evaluation will be performed during
Operable Unit III.
Contaminant Persistence
Lead is not usually mobile in normal ground water or surface
water because solubilized lead, leached from ores or other
sources, is adsorbed by ferric hydroxide or tends to combine with
carbonate or sulfate ions to form nearly insoluble compounds.
The equilibrium solubility of lead compounds in water is low.
Therefore, filtered ground water or surface waters within
environmental ranges of pH would not normally contain detectable
amounts of lead.
In addition to the formation of salts or hydroxides, lead is
preferentially adsorbed to organic acids, particularly humic and
fulvic acids. Humic and fulvic acids are the decay products of
organic matter containing cellulose. These organic acids are
resistent to further decay and possess high cation exchange
capacities. Organic acids are present in soils, sediments and to
some extent, are suspended in surface waters.
Sorption is the primary mechanism for reducing soluble lead in
natural waters, soils and sediments. Therefore the mobility of
lead in the environment is restricted to co-transport on organic
or inorganic materials or transport as insoluble lead particles.
Lead may also be present as colloidal particles that are capable
of passing a 0.45 micron filter.
Contaminant Deposition and Migration Pathways
The battery breaking activities performed on the site over a ten
year period contributed lead sulfates, lead oxides, particles of
lead alloy, and substantial amounts of sulfuric acid to the site.
These activities were centrally located on the site at the
27
-------
battery breaking building. In addition to the deposition of acid
on the ground surface, contaminated broken battery casings were
spread over much of the surface of the site. Casings were used
as a base material for the driveway extending from Fisher Dam
Road to the service shop, and were placed in several pits as deep
as 10 feet below the surface of the ground in areas near Mill
Creek and along the Conrail railroad line.
RI sample results establish the presence of lead on the site, in
site soils, sediments, unfiltered surface water samples in Mill
Creek and the Schuylkill River, and in both filtered and
unfiltered ground water samples.
Currently, soil lead contamination greater than 500 ppm is
generally limited to the upper three feet of site soils,
excluding the containment area and the small area between the
containment area and the railroad. In this small strip of land
west of the containment area, lead concentrations of greater than
500 ppm were identified at a depth of six feet during the RI.
The containment area was documented during the Extent of
Contamination Survey in 1983 as containing pits filled with
battery casings at a depth of up to 10 feet.
Migration pathways established as a result of the current
understanding of the nature and extent of contamination found on
the site are as follows:
Air Pathway: Wind or vehicular traffic resuspension and
transport of soils into surface waters
adjacent to the site and around the surface
of the site. Includes both wet and dry
fallout.
Vertical and horizontal migration of lead-
bearing particles in soil pores, along root
channels, and by resolubilization.
Movement of ground water into surface waters
or into potable wells onsite.
Surface Water Surface movement of soil via runoff
Pathway caused by precipitation (rainfall, snowmelt)
into the Schuylkill River and Mill Creek.
Sediment movement in the Schuylkill River and
Mill Creek.
Ground Water
Pathway
28
-------
Air Migration Pathway
The air migration pathway consists of the resuspension and
transport of contaminants adhering to soils in the driveway and
exposed surface soils onsite due to wind erosion and vehicular
traffic (automobile and truck traffic). Following entrainment in
air, likely routes of transport include redeposition onto the
site and deposition into the Schuylkill River or Mill Creek.
Airborne lead transport would probably increase during excavation
activities and similar disturbances to the existing soil cover.
Ground Water Migration Pathway
Limited ground water contamination from lead in filtered samples
was detected during the RI. The source of lead detected in the
filtered monitoring well 10 sample is probably from the
resolubilization of lead from soil caused by the low pH found in
the well (4.0) or the contribution of lead-bearing particles less
than 0.45 microns (urn) in size. The source of the lead detected
in one of three samples from an onsite residential well may be
the result of onsite contamination or may be the result of lead
leaching from plumbing fixtures.
Data is not available to characterize the potential for shallow
ground water migration into deeper aquifers. Therefore no
conclusions can be drawn on this aspect of ground water
migration.
Base flow of ground water contributes to the surface water flow
at least part of the year as evidenced through both physical and
chemical parameters. Sample results also indicate that the
dissolved metals believed to originate from the base flow are
rapidly attenuated in the downriver surface water samples.
Surface Water Migration Pathway
Water runoff from storm events can cause erosion and transport of
contaminated surface soils into the Schuylkill River and Mill
Creek. Surface soil erosion is especially prevalent in areas
with poor surface cover, such as the boat ramp or dirt driveway
areas onsite.
Wet or dry fallout from airborne contamination contributes small
amounts of lead, as predicted through the ISCLT air model, to the
surface water adjacent to the site.
The materials forming the bottom of the Schuylkill River
immediately upstream of, adjacent to and downstream of the site
consist primarily of coarse sand, gravel and cobble-sized
particles. This suggests that the river has a sufficient
sediment transport capacity to selectively move smaller particles
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(fine sands, silts and clays) leaving behind the larger particles
in a process known as "armoring". Sediment transport is a
continuous process, but it is greatly accelerated during high
flow events. As a result, particulate lead or contaminated soil
entering the Schuylkill River is eventually transported
downstream.
The Rl sediment lead results indicate the site is contributing
lead to the Schuylkill River adjacent to the site. Lead
concentrations attenuate to upstream lead concentrations a few
hundred feet downstream of the site (directly below the islands).
Lead is present in unfiltered surface water samples in both Mill
Creek and the Schuylkill River. Mill Creek surface water lead
concentrations are generally low along the entire length of the
site. Schuylkill River surface waters exhibit lead
concentrations elevated above upgradient sample concentrations
for selected samples along the site. As with sediments,
unfiltered surface water lead concentrations attenuated to
upgradient levels downriver of the site.
It is believed that a combination of factors is effecting the
reduction in lead values found in surface water and sediment
downstream of the site. These factors include dilution,
sorption, oxidation, precipitation and sediment transport of
lead.
Population and Environmental Areas Potentially Affected
Four residences and an active automobile and truck service shop
exist onsite. A total of seven adults and two children reside in
the four residences. Two of the residents are employed at the
onsite business. A second removal action was initiated on
June 29, 1990 and is currently in progress. The purpose of this
action is to provide temporary relocation to the residents to
protect them from direct exposure to onsite contamination. Two
additional adults reside offsite but are employed at the
automobile and truck service shop. Access to the site is
currently unrestricted thereby allowing an undetermined number of
people direct exposure to onsite contamination via the various
pathways described above.
In addition to the direct exposure to the high levels of
contamination present in onsite soils and to a lesser extent
ground water, the ongoing RI has documented the release of
contamination into the surface water and sediments of the
Schuylkill River. The Schuylkill River borders the entire
southern property line of the site and is classified as a
recreational river. The river is a primary drinking source for
several cities located downriver of the site. Several downstream
industries also utilize the river as a water resource.
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Mill Creek is located along the western bank of the site property
and flows directly into the Schuylkill River at the southwestern
corner of the property. It is stocked with trout at a location
approximately one mile above the site. DER officials estimate
that trout could migrate into the area of Mill Creek adjacent to
the site. In addition to the stocked trout, their are numerous
indigenous species of aquatic wildlife in both Mill Creek and the
Schuylkill River. Typical terrestrial woodland wildlife inhabit
the site year round and various migratory birds may feed or nest
at the site for relatively short periods of time.
SUMMARY OF SITE RISKS
Selection of Contaminants of Concern
Lead was selected as the site contaminant contributing most
significantly to human risk. Selection was accomplished through
the following process:
o Identification of site sample data by media (soil, ground
water, sediment, surface water) which are considered
positive results;
o Comparison of positive site sample data results with
background data by media; and
o Use of a concentration - toxicity screen to select
contaminants of concern which were positively detected
above background values.
Because lead is poorly absorbed dermally, the exposure pathways
via dermal absorption are considered incomplete pathways and will
not be considered for risk evaluation. Vegetables are no longer
grown onsite by residents in site soils, but are grown onsite in
above ground containers with non-contaminated soils. The
possibility exists that these vegetables may become contaminated
with lead dust which has settled from suspended airborne
particulates.
Residents were informed of the potential risks associated with
growing any vegetables onsite. It is assumed that all vegetables
grown onsite were thoroughly washed by residents prior to
consumption. Consequently, exposure to lead via this pathway is
considered minimal.
Because Mill Creek ia shallow and muddy, it is considered
unsuitable for swimming. It is expected that an individual would
prefer to swim in the Schuylkill River.
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Thus, the following exposure pathways are considered complete:
o Ingestion of contaminated soil by a child or adult;
o Ingestion of contaminated fish caught in the Schuylkill
River by a child or adult;
o Ingestion of contaminated water by a child or adult
swimming in the Schuylkill River;
o Ingestion of contaminated drinking water by a child or
adult; and
o Inhalation of contaminated respirable dust by a child or
adult.
Of the potential child and adult human receptors which have been
identified in the above complete pathways, the following maximum
exposed individuals (MEIs) have been identified:
o A child up to 6 years old who lives and recreates on site;
o An adult who lives and recreates on site; and
o An adult who works onsite and lives off site.
Toxicity Assessment
Exposure to lead via inhalation and ingestion can cause potential
carcinogenic and noncarcinogenic adverse health effects. EPA has
quantitatively evaluated toxicity data and characterized the
relationship between the dose of lead administered or received in
animal or human studies and the incidence of adverse health
effects in the exposed population. The following discussion
presents toxicological information and toxicity values for the
carcinogenic and noncarcinogenic effects of lead.
Carcinogenic Effects
The Carcinogen Assessment Group (CAG) of the EPA has recently
assigned a weight-of-evidence classification of B2 to lead,
indicating that lead is a probable human carcinogen. The B2
classification was assigned on a basis of sufficient animal
evidence, with inadequate human evidence.
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Noncarcinogenic Effects
The noncarcinogenic toxicologic effects of lead are well
documented. Lead affects the following human systems or organs:
o Hematopoietic (blood production) system
o Nervous system
o Kidney
o Gastrointestinal system
o Bone marrow cells
o Reproductive system
o Endocrine system
o Heart
o Immune system
Table 3 lists noncarcinogenic effects for each system or organ
affected.
Noncarcinogenic effects in exposed children are demonstrated
generally at lower lead blood levels than for exposed adults.
Research has shown a progressive decline in the lowest exposure
levels for children at which noncarcinogenic effects can be
detected. Table 4 summarizes the documented noncarcinogenic
effects of lead for children as determined by the Agency for
Toxic Substances and Disease Registry.
The consensus on the lead blood level of children which is
considered toxic has changed in recent years. In 1975, the U.S.
Communicable Disease Center (CDC), now known as the Centers for
Disease Control, defined the toxic level in children's blood as
40 micrograms/deciliter (ug/dl). This value was reduced in 1985
by CDC to 25 ug/dl. In 1986, the World Health Organization
recommended 20 ug/dl as the upper acceptable toxic limit. In the
same year, EPA's Clean Air Scientific Advisory Committee
indicated that levels of 10 to 15 ug/dl can be associated with
adverse health effects.
The EPA Reference Dose (RfD) Work Group discussed the relevance
of developing a verified oral and inhalation RfD at two meetings
in 1985. The RfD Work Group considered it inappropriate to
develop RfDs for lead and concluded that children's
neurobehavioral development may be affected at lead blood levels
without a threshold.
The soil lead at this facility is the primary cause for health
concerns. Levels are so high that adverse health impacts on both
children and adults constitute a constant threat even when health
checks and tests to assess such possibilities yield negative
results. The standard procedure for the assessment of such
impacts is one that measures the level of lead in blood. While
we are aware that much of the impacted lead that enters the human
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TABLE 3
NONCARCINOGENIC EFFECTS OF LEAD
System or Organ
Effect
Hematopoietic System
Nervous System
Kidney
Gastrointestinal System
Bone Marrow Cells
Reproductive System
Endocrine System
Heart
Immune System
Anemia, stippled cells
Encephalopathy (a brain
disease causing convulsions,
delirium, hallucination and
cerebral edema), peripheral
neuropathy (causing weakness,
palsy, and wrist drop), otic
atrophy (causing auditory
defects and vertigo)
Loss of kidney function,
azotemia, kidney failure,
aminoaciduria
Abdominal discomfort or pain,
colic, constipation and/or
diarrhea, loss of appetite,
metallic taste, nausea and
vomiting, loss of weight
Chromosome changes
Offspring show decreased
reproductive fitness, re-
tardation of embryonic growth,
retardation of fetal
deve1opment, impa ired
postnatal development
Change in adrenal steroid
excretion, depression of
aldosterone secretion rate,
depressed thyroid function
Degeneration of heart muscle
in children
Greater susceptibility to
infectious disease
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TABLE 4
DOCUMENTED NONCARCINOGENIC EFFECTS FOR CHILDREN
Neurologic
Effects
Heme
Synthesis
Effects
Other
Effects
Lowest Level
Lead Blood
(ug/dl)
Effects Seen
Deficits in
neuro-
behavioral
development
(Bayley &
McCarthy
Scales)
electrophys-
iological
changes
Inhibition
of blood
forming
enzyme (ALA-
D)
Reduced
gestational
age and
weight at
birth;
reduced size
up to age 7-
8 years
10-15
(Prenatal
and
postnatal)
Elevated
precursors
to hemo-
globin
formation
Impaired
vitamin D
metabolism
15 - 20
Lower IQ,
slower
reaction
time
<25
Slowed nerve
conduction
velocity
30
Reduced
hemoglobin
40
Peripheral
neuropathies
Frank anemia
70
Encepha-
lopathy
Colic, other
GI effects,
kidney
effects
80 - 100
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physiology is from soil lead that is incidentally ingested, this
soil contaminant is also, to a relatively minor extent, inhaled
and possibly absorbed through the skin. Standard daily direct
contact values are employed in this regard.
It is also important to consider that lead is a multimedia
contaminant and everyone consumes a significant amount of this
element in a normal diet and trivial amounts from uncontaminated
dusts and soils. Calculations designed to predict blood level
impacts can become complex and are in a constant status of being
upgraded as more information becomes available from the
scientific literature.
Fortunately, the EPA Lead Uptake/Biokinetic Model is now
available as a software package to assist us in this problem.
This is an excellent program that has the ability to predict
blood lead level impacts in children from contaminant lead
exposures. It provides default values for all exposure routes
such as air, water, food, dusts and soils when they are not
available for the facility under study and allows for the
prediction of blood level impacts from known contaminant levels
from any source. It also provides a venue for the calculation of
acceptable soil levels for the protection of exposed children.
Blood lead levels are employed as a criterion in this process.
Acceptable contaminant levels are established as those that
elicit blood lead levels that are less than 10 ug/dl in at least
95 percent of those exposed to the contamination under review.
This criterion is used in both the biokinetic model and when
calculations are carried out in the traditional manner as are
required in assessing exposures and calculating acceptable
contaminant levels for adults. EPA has recently established this
criterion in an interim status because of adverse impacts that
have been reported from concentrations that exceed this level.
In the case of children, measurable neurophysical retardation has
been reliably reported in children with blood lead concentrations
that exceed 10 ug/dl and in adults increases in blood pressure
have been detected in middle aged individuals with blood lead
levels that exceed this criterion.
The arithmetic mean of the soil lead concentrations at the site
(9247 ppm) was employed in the biokinetic model as the soil
exposure input. This resulted in the prediction that all (100%)
of the exposed children are likely be impacted with blood lead
levels that exceed the 10 ug/dl criterion. This does not
conflict with test data that may indicate that some children, at
a given time, may have lower levels, but indicates that the
threat exists and is real.
Calculations were undertaken in order to assess the impact on
adult workers and on adult residents at this facility. Typical
food, air, water, and background dust inputs were added to
standard soil uptake assumptions in these efforts. Along with
other standard assumptions, soil lead concentrations were
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calculated to have a blood lead impact that was equivalent to 4.0
ug/dl for each 1000 mg/kg of this element in the soil. There is
support for the use of this factor in the scientific literature.
Blood lead impact concentrations were assumed to be distributed
at a geometric standard deviation (GSD) of 1.70 which was the GSD
of the blood lead in the Baltimore lead abatement study. All
calculations were double checked by a computerized uptake
statistical model which yielded essentially the same results. It
was calculated that an average of 76 percent of the residents and
60 percent of the onsite workers would be impacted with excessive
blood lead concentrations from the conditions that exist at this
facility.
Residential Blood Lead Sampling Results
Currently, two children reside on the site. The two children
moved into an onsite residence in June 1988. DOH monitored the
blood lead level of both children in November, 1989. The
resulting blood lead level for each child was 5 ug/dl.
Both children and all but one of the adult residents had their
blood lead level tested in August 1990. The children's blood
lead levels were at 4 and 5 ug/dl. Blood lead levels of the
adult residents ranged from 2-34 ug/dl. Three of the six
adults tested had blood lead levels equal to or greater than the
10 ug/dl criterion.
Environmental Assessment
Lead is the most voluminous, widespread, and concentrated
contaminant found onsite, and is therefore the most likely
contaminant to affect onsite receptors. Small amounts of other
metals, including manganese, zinc, and iron may affect nearby
aquatic organisms due to migration of these metals short
distances from the site in solution.
RI sampling data indicate that contaminants have only migrated a
few tens of feet from the site generally in relatively low
concentrations. Potential receptors are largely limited to
organisms living onsite and in the Schuylkill River and Mill
Creek immediately adjacent to the site. Exceptions are predatory
animals that nay live nearby and feed on prey animals living
onsite. No endangered species or critical habitats have been
found to be associated with the site or in the immediate area
surrounding the site.
The most highly impacted organisms are probably burrowing animals
living in contaminated soils onsite. Ingestion of contaminated
soils can provide significant exposure to burrowing animals,
including small rodents and lower forms such as worms and
insects. Small herbivores may also be impacted by ingestion of
37
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contaminated plants. Many plant species take up lead, and lead-
bearing dust can also contaminate plants.
Predators feeding on burrowing animals can potentially be
exposed, however, lead is not generally biomagnified.
Bioconcentration factors tend to decrease as trophic levels
increase.
The Schuylkill River is designated as a scenic river by the State
of Pennsylvania. It is considered appropriate for contact and
non-contact recreation. RI data suggests water quality in the
river downstream of the site is not significantly impacted by
contaminants from the site.
Aquatic organisms living in the Schuylkill River and Mill Creek
adjacent to the site may potentially be affected by contaminants
from the site. Lead is expected to exist in the solid phase
under conditions present in site surface waters, adsorbing to
sediments. Bioassays were performed on four sediment samples
collected from the Schuylkill River adjacent to and just
downstream of the site. Results indicate no significant toxic
effects from the sediments.
SECOND REMOVAL ACTION
As a result of RI sampling activities conducted between June 1989
and March 1990, a second removal action was determined to be
necessary. This decision was based on a toxicological review of
surface soil sampling results that indicated elevated lead levels
on the properties of current residents and in areas immediately
adjacent to their homes.
The second removal action was initiated in June 1990 and is
currently in progress. This action is intended to temporarily
relocate all onsite residents to protect them from direct
exposure to onsite contamination.
A meeting was held on July 24, 1990 in the Tilden Township
Municipal Building to discuss the rights and benefits of the
residents affected by the temporary relocation removal action.
The meeting was attended by all adult site residents and
representatives from EPA Region III, EPA Headquarters (HQ), and
the United States Army Corps of Engineers (USAGE). During the
meeting the residents were informed of the existing site
conditions and EPA's evaluation which recommends immediate
relocation of all site residents. Residents were also informed
of EPA's current and planned remedial investigations and future
potential actions: Operable Unit I - site access; Operable Unit
II - remediation of onsite soils and battery casings; and
Operable Unit III - remediation of ground water.
The residents were informed that EPA was prepared to immediately
relocate all residents to a temporary location such as a motel or
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similar establishment until suitable rental properties could be
located and procured. They were also informed of all benefits
that would be provided. All residents expressed interest in
relocating from their current locations. However, none of the
residents agreed to immediate relocation to a motel or similar
establishment.
Following the conclusion of the meeting, the residents from each
household met individually with the OSC and representatives from
EPA HQ and USAGE to discuss their individual benefits under the
current removal action. The benefits for each residence vary
slightly since: one household owns both their dwelling and land;
a second household owns their dwelling, a mobile home, but rents
the property on which it is located; a third household rents both
their dwelling and land; and a fourth household rents their
dwelling, the building in which the onsite business is located,
and the property associated with both. The current site owner
was not present at the meeting nor were any other potentially
responsible parties.
DESCRIPTION OF REMEDIAL ALTERNATIVES
In order to select the most appropriate remedial action, various
alternatives have been developed so that a variety of distinct,
viable options can be analyzed prior to selecting a remedial
action. The alternatives evaluated for Operable Unit I are:
Alternative 1: No Action;
Alternative 2: Limited Site Access; and
Alternative 3: Permanent Relocation.
Alternative 1: No Action
The purpose of the no action alternative is to establish a
baseline for comparison with the other alternatives. Under this
alternative, the business and any residents who refused temporary
relocation during the removal action would remain onsite and no
actions would be taken to limit site access or reduce exposure to
onsite contamination.
* Capital Cost: None
* Total Operation and Maintenance (O&M) Costs: None
* Present Worth (PW): None
* Months to Implement: None
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Alternative 2: Limited Site Access
The limited site access alternative consists of placing a six
foot fence topped with barbed wire around the perimeter of the
site to restrict access. Signs will be posted to indicate the
area is a hazardous waste site. Deed restrictions will be placed
on the site properties to prohibit new people from moving onsite
to new or existing residences until a determination is made
regarding future site usage of the properties.
The automobile and truck service shop will continue to operate
and the employees and any current residents who refuse temporary
relocation during the removal action would be permitted access to
the site.
Limited environmental sampling will be performed to monitor the
contamination in the ground water and private wells. Periodic
blood lead screening will be available to all onsite employees
and remaining residents.
* Capital Costs: $21,600
* Total O&M Costs: 21,400
* PW: $53,800
* Months to Implement: two to three
Alternative 3: Permanent Relocation
The permanent relocation alternative consists of permanently
relocating all onsite residents and the business to replacement
properties comparable to their present location. After the
relocation is completed, the residents and business would not be
permitted to return to the site.
All appropriate personal belongings for both the business and the
residences will be decontaminated prior to delivery at their
final location.
This alternative restricts site access by placing a six foot
fence topped with barbed wire around the perimeter of the site.
Signs will be posted to indicate that the area is a hazardous
waste site. Deed restrictions will be placed on the property to
prohibit residential and industrial use of the site until a
determination is made regarding future site usage.
Section 101(24) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) states that a remedial
action includes the cost of such permanent relocation of
residents and businesses. Section 104(j) provides the authority
to acquire property to conduct a remedial action.
All relocation activities will be conducted in accordance with
the Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970, as amended, 42 U.S.C. § 4601 et sea. These
40
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policies and provisions are contained in the Federal Register of
March 2, 1989 and 49 CFR Part 24.
* Capital Cost: $342,900
* Total O&M Costs: None
* PW: $342,900
* Months to Implement: Two to six
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section summarizes the relative performance of the
alternatives by highlighting the key differences among the
alternatives in relation to the nine evaluation criteria. A
glossary of the evaluation criteria is given below.
Glossary of Evaluation Criteria
Overall protection of human health and the environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced or controlled through treatment, engineering controls, or
institutional controls.
Compliance with ARARs addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements of
federal and state environmental statutes and/or provide grounds
for invoking a waiver.
Long-term effectiveness and permanence refers to the magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once
cleanup goals have been met.
Reduction of mobility, toxicity. or volume through treatment is
the anticipated performance of the treatment technologies that
may be employed in a remedy.
Short-term effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment during
the construction and implementation period.
Implementabilitv is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
Cost includes capital and operation and maintenance costs.
State acceptance indicates whether the state concurs with,
opposes, or has no comment on the preferred alternative.
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policies and provisions are contained in the Federal Register of
March 2, 1989 and 49 CFR Part 24.
* Capital Cost: $342,900
* Total O&M Costs: None
* PW: $342,900
* Months to Implement: Two to six
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section summarizes the relative performance of the
alternatives by highlighting the key differences among the
alternatives in relation to the nine evaluation criteria. A
glossary of the evaluation criteria is given below.
Glossary of Evaluation Criteria
Overall protection of human health and the environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced or controlled through treatment, engineering controls, or
institutional controls.
Compliance with ARARs addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements of
federal and state environmental statutes and/or provide grounds
for invoking a waiver.
Long-term effectiveness and permanence refers to the magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once
cleanup goals have been met.
Reduction of mobility, toxicity. or volume through treatment is
the anticipated performance of the treatment technologies that
may be employed in a remedy.
Short-tern effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment during
the construction and implementation period.
Implementability is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
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Community acceptance has been and will be assessed throughout all
site activities and is documented in the Responsiveness Summary
of this Record of Decision.
Overall Protection of Human Health and the Environment
The combination of the actions presented in the Permanent
Relocation alternative will provide good overall protection of
human health. The health of all onsite residents and workers is
protected since they will be relocated to off site locations and
their personal belongings will be decontaminated. Site access
will be totally restricted and residential and industrial use
will be prohibited protecting the health of off site individuals.
This alternative will also prevent future activities such as
onsite construction, vehicle traffic, and general soil
disturbances from accelerating the release of contamination to
the environment.
The Limited Site Access alternative protects the health of
individuals not living or working on the site by limiting access
and prohibiting additional residents from moving onsite.
Although access will still be permitted to customers of the
onsite business, the site will be posted as a hazardous waste
site, informing them of the risks associated with the area. This
alternative does not protect the health of the workers nor the
health of any residents who do not accept the temporary
relocation offered by the current removal action. However, it
does provide a means to monitor their exposure. The Limited Site
Access alternative does not provide any protection to the
environment.
The No Action alternative does not provide any protection to
human health since all workers and any remaining residents will
continue to be exposed to the contaminants onsite. Since site
access remains unlimited, additional individuals may unknowingly
become exposed to onsite contamination. Future onsite activity
may accelerate the release of contaminants to the environment.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
There are no chemical specific or location specific ARARs for
this Operable Unit. Action specific ARARs identified for this
Operable Unit include Federal relocation requirements.
CERCLA Section 104(j) provides the authority to acquire property
that is needed to conduct a remedial action. Section 101(24)
states that the term "remedial action" includes permanent
relocation of residents and businesses when it is determined that
relocation is more cost-effective and environmentally preferable
than other alternatives.
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All relocation activities will be conducted in accordance with
the Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970, as amended, 42 U.S.C. § 4601 et seq. These
policies and provisions are contained in the Federal Register of
March 2, 1989 and 49 CFR Part 24.
Long-term Effectiveness and Permanence
The Site Access Operable Unit is intended to provide short-term
protection until the site cleanup activities occur. None of the
alternatives provide a permanent solution. However, the
Permanent Relocation alternative eliminates the continued
exposure of the onsite employees and any residents that do not
accept temporary relocation. Restricting site access will
eliminate exposure of additional individuals and will limit the
potential for migration of contaminants off site.
Reduction of Toxicity, Mobility or Volume of Contaminants Through
Treatment
These alternatives do not reduce the toxicity, mobility, or
volume through treatment. This criteria will be addressed in
Operable Units II and III.
Short-term Effectiveness
The Permanent Relocation alternative provides good short-term
effectiveness in reducing risks to human health and preventing
the transport of contaminants off site. This alternative will
not create any adverse impacts on human health or the environment
during implementation. Appropriate monitoring and health and
safety measures will be adhered to during the decontamination of
personal property and installation of the fence.
The Limited Site Access and No Action alternatives provide no
short-term effectiveness to onsite employees or remaining onsite
residents. The Limited Site Access alternative provides good
short-term effectiveness to individuals not living or working
onsite by restricting site access.
Implementability
All three alternatives are technically and administratively
implementable. All materials and services needed to implement
each of the alternatives is readily available.
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Cost
There are no costs associated with the No Action alternative.
The Limited Site Access alternative will cost approximately
$53,800 and the Permanent Relocation alternative will cost
approximately $342,900.
State Acceptance
DER supports the decision that permanent relocation is the
preferred alternative for this OU.
DER recognizes that issues concerning cleanup standards will be
addressed in the contaminated soil and battery waste operable
unit. The permanent relocation of the onsite residents and
workers should not control the degree to which the site should be
cleaned nor should it dictate any future use of the site.
Pennsylvania has not agreed to take title to the property under
Section 104(j) of CERCLA, 42 U.S.C. Section 9604(j), nor does DER
believe that deed restrictions are appropriate where access
agreements can be obtained from the property owners. In such
agreements, the property owners should provide assurances that
they will not inhabit the site during the remedial action, and
should they transfer the title to a third party during the
remedial action, they will provide notice to the third party of
the remedial action in progress at the site.
Community Acceptance
A meeting was held on July 24, 1990 with onsite residents to
discuss their rights and benefits during the temporary relocation
removal action. All residents in attendance expressed interest
in relocating from their current locations. However, none of the
residents agreed to immediate relocation to a motel or similar
establishment.
A public meeting to discuss the Proposed Remedial Action Plan was
held on September 4, 1990 in the Tilden Township Municipal
Building. Overall, those in attendance were highly critical of
the past efforts taken by EPA at the site.
As a result of the concerns expressed by the citizens during the
meeting, the Remedial Project Manager (RPM) and Community
Relations Coordinator met with the onsite residents on September
5, 1990 to discuss their concerns and their personal opinion of
the alternatives, specifically the proposed alternative for
permanent relocation. Personal discussions were conducted at
each residence and at the onsite business. A total of six out
of the seven adult residents were present for the various
discussions which were held "around the kitchen table" of each
residence.
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All residents have been informed of the current health risks
associated with living onsite and their close proximity to
elevated lead levels. Residents have also been informed of the
strong potential for EPA to restrict site access during the
construction activities anticipated during Operable Unit II.
All residents except for one household have agreed they would
consider permanently relocating from the site, but their final
decision would be based on a number of factors, the most
important being the location of their future residence and the
financial burden associated with living at this location. All
residents expressed concern about future financial difficulties
since their current rental payments range from $100 - $150 per
month at their present location. The resident who owns his
current residence expressed concerns about future mortgage
payments and the potential for increased property taxes at a
different location.
The residents who own their mobile home expressed concerns
regarding their financial limitations and the acreage
requirements associated with permanently relocating their mobile
home. They had previously lived in a trailer park and have
openly discussed their dissatisfaction and their intentions to
not live in a trailer park again.
The residents who occupy the rented mobile home expressed
concerns regarding the health effects of remaining onsite,
especially since they plan on having children in the near future.
They also expressed their intentions to purchase an off site
residence, but are presently unable with their current savings.
The operator of the onsite business expressed concerns regarding
locating a similar building in the immediate area to accommodate
truck repairs.
THE SELECTED REMEDY
The selected remedy is the Permanent Relocation alternative. The
combination of the actions presented in this alternative provide
good protection of human health by relocating all onsite
residents and workers to comparable off site locations, site
access to the general public will be restricted by the
construction of a six-foot fence topped with barbed wire that
will surround the entire site. Deed restrictions will prohibit
residential and industrial use of the site until a determination
is made regarding future site usage. Restricting onsite human
activities will decrease future releases of contamination to the
environment.
The selected remedy is consistent with future remedial
activities. Extensive excavation of widespread highly
contaminated soil and battery casings will occur during the
45
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Operable Unit II remedial action. A significant amount of this
material is located directly adjacent to the homes and the
business. It is anticipated that the residents and workers would
have to be relocated during the Operable Unit II remedial action.
The Permanent Relocation alternative meets all ARARs and provides
the best balance of tradeoffs among the alternatives with respect
to the balancing criteria. The selected remedy provides good
short-term effectiveness by eliminating the risk to onsite
residents and workers by relocating them permanently to off site
locations.
This remedy is the most costly of the alternatives. However, it
is the most cost-effective in relation to the reduction in risk.
All materials and services needed to implement the remedy are
readily available. The Permanent Relocation alternative is
acceptable to both the state and the community.
The selected remedy does not employ any treatment or resource
recovery technologies. However, the FS for Operable Unit II is
evaluating several such technologies for their applicability to
remediate contaminated soils and battery casings.
THE STATUTORY DETERMINATIONS
The permanent relocation of the onsite residents and workers in
conjunction with the restricted site access and deed restrictions
will eliminate the current human health risks. No unacceptable
short-term risks or cross-media impacts will be caused by the
implementation of the remedy.
All relocation activities will be conducted in accordance with
the Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970, as amended, 42 U.S.C. § 4601 et seq. These
policies and provisions are contained in the Federal Register of
March 2, 1989 and 49 CFR Part 24. The Permanent Relocation
alternative complies with all ARARs.
The selected remedy provides overall effectiveness proportionate
to its costs, in that it represents a reasonable value for the
money to be spent. Although the other alternatives are initially
less costly, they do not fully protect human health nor do they
offer any protection to the environment. Future relocation of
the residents and workers may occur during Operable Unit II,
thereby increasing the current cost-effectiveness of this
alternative while providing immediate protection to human health
upon implementation.
The most critical criteria in the selection decision was the
overall protection of human health and the environment and short-
term effectiveness. Lead levels are so high that adverse health
impacts on both children and adults constitute a constant threat.
All onsite residents and workers are directly exposed to the
46
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widespread contamination that is located within their yards and
potentially transported into the homes and business located
within the site boundary. As a result, the Permanent Relocation
alternative is the only viable remedy available.
In general, community acceptance is extremely critical when
selecting a remedy such as permanent relocation. EPA is aware of
the significant potential impacts caused by selecting this
alternative. However, due to the immediate health concerns posed
by this site, the only logical alternative consistent with future
remedial activities is to provide permanent relocation for all
individuals affected.
Numerous discussions have been held with the individuals living
and working on the site to explain the current health risks posed
by the contamination as well as the future plans to remediate the
site during Operable Units II and III. All individuals are
concerned about the health risks associated with the site, but
are equally concerned about the various hardships, financial and
otherwise, that may result from a permanent relocation. It is
vital that EPA provide clear, concise, and constant communication
with the affected individuals throughout the entire
implementation of this Operable Unit.
Because treatment of the principal threats of the site was not
within the limited scope of this action, this remedy does not
satisfy the statutory preference for treatment as a principal
element.
47
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Bureau of Waste Management
Harrisburg Regional Office
One Ararat Boulevard
Harrlsburg, Pennsylvania 17110
717-657-4586
September 26, 1990
Mr. Edwin B. Erickson
Regional Administrator
US EPA, Region III
841 (Jtestnut Building
Philadelphia, Pennsylvania 19107
Re: Record of Decision (ROD) Concurrence
Brown's Battery Breaking Site
Site Access - Operable Unit I (OU I)
Tilden Township, Berks County
Dear tor. Erickson:
The Record of Decision for the initial Operable Unit (OU I) will address
permanent relocation of all on-site residents and the business. This will pro-
vide site access before remedial action can be initiated on the site.
The major components of the selected remedy include:
The pe
t relocation of the business and the residents
currently residing on the site in order to eliminate human contact
with lead contaminated soil, voter, ead dust particles to replace-
ment properties comparable to their present location.
* The residents and the business would not be pnrmttrart to return to
the site.
* Site access would be restricted by a six-foot fence topped with
barbed wire and signs would be posted to indicate that the area is
a hazardous waste site*
* Deed restrictions would be placed on the property to prohibit
residential and industrial use until a determination i§ made
regarding nature site usage.
I hereby oonoir with the EPA selected/proposed remedy with the following
conditions end stipulations:
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£3'd
Mr. Edwin B. Brick***
September 26, 1990
2
The Department will be provided the opportunity to concur with
decisions related to subsequent operable units (OU) , review and
comment on all studies performed at the site, evaluate appropriate
alternatives and participate in any negotiations with responsible
parties Co assure compliance with DER. cleanup ARARs.
Ihe Departanent will be given the opportunity to concur with deci-
sions related to the design of the Reoedial Action, to assure
coopliance with MR cleacup ARARs and design specific ARARs.
the Department's posture is that its design standards are ARARs
pursuant to SARA Section 121, and we will reserve our right to
enforce those design standards.
Ihe Department will reserve our right and responsibility to take
independent enforcement actions pursuant to state law.
* Pennsylvania has not agreed to take title to die ucuperty .
Section 1040) of ORCLA, 42 U.S.C. Section 9604
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BROWN'S BATTERY BREAKING - TILDEN TOWNSHIP, PENNSYLVANIA
RESPONSIVENESS SUMMARY
A. OVERVIEW
This Responsiveness Summary documents concerns and comments
expressed by residents of the community of the Brown's Battery
Breaking Site during the public comment period held by the EPA
regarding a Proposed Remedial Action Plan for site access (the
first of three anticipated Operable Units). This summary also
documents EPA's responses to the comments and concerns expressed
by members of the community. The Responsiveness Summary is
organized in the following manner:
1.0 Overview of the Public Meeting and Proposed Plan
2.0 Background of Community Involvement
3.0 Summary of Major Questions and Comments Received During the
Comment period
Attachment: Proposed Remedial Action Plan, Brown's Battery
Breaking Site, Tilden Township, Pennsylvania
1.0 OVERVIEW OF PUBLIC MEETING AND PROPOSED REMEDIAL ACTION PLAN
The public comment period for this Proposed Remedial Action Plan
began on August 17, 1990 and ended on September 15, 1990. EPA
held a meeting with the residents of the site July 24, 1990 in
the Tilden Township Municipal Building to discuss the rights and
benefits associated with the temporary relocation action
authorized in June, 1990. The meeting was attended by all of the
adult residents and representatives from EPA Region III, EPA
Headquarters (HQ) and the United States Army Corps of Engineers
(USAGE).
All public participation requirements of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA)
Sections 113(k)(2)(B)(i-v) and 117 as amended by the Superfund
Amendments and Reauthorization Act (SARA) were met in the remedy
selection process.
A one quarter page display advertisement was published August 17,
1990 in th« Reading Times. It specified the availability of the
Proposed Remedial Action Plan, the public comment period and the
location of the administrative record.
A public meeting to discuss the Proposed Plan was held on
September 4, 1990 at the Tilden Township Municipal Building,
Hamburg, Pennsylvania, following the regular meeting of the
Tilden Township Board of Supervisors.
Approximately 40 people attended, including former residents.
All but one of the adults currently living onsite came to the
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meeting.
Representatives from the Tilden Township Board of Supervisors
remained after their session. Staff representatives from EPA's
Region III, the Pennsylvania Department of Environmental
Resources (DER) and the United States Army Corps of Engineers
(USAGE) were present to answer questions. Also present were
members of Concerned Citizens of Western Berks County, a group
which is actively involved in remedial activities at the Berks
Landfill Site.
The public meeting began soon after 8:00pm with presentations by
EPA officials and was followed by a question and answer session.
The meeting ended at approximately 9:45pm. Following the
meeting, staff members from EPA and USACE remained to answer
additional questions.
The Community Relations Coordinator (CRC) began the meeting by
welcoming the audience, introducing the other EPA, DER and USACE
staff, and giving a brief overview of the public's role in the
Superfund remedial process. She explained that the meeting was
to consider the various alternatives for the next phase of the
cleanup. Members of the community were encouraged to voice their
opinions at the meeting and/or submit their comments in writing
as part of the official record. Copies of the Proposed Plan were
made available to all attendees to assist them in considering the
various alternatives.
The Remedial Project Manager (RPM) provided a brief history of
the site, which was active from 1961 to 1971. He explained that
there had been a removal action conducted between October, 1983
and July, 1984. This action moved much of the visible battery
casings and contaminated soil to a restricted containment area
which was later covered with a low permeability cap and fenced.
Three alternative proposals, including No Action, were presented.
Alternative 3 (Permanent Relocation) was identified as EPA's
preferred alternative because EPA views this as the best way to
eliminate the threat of high level lead contamination to the
public, primarily residents and workers onsite. Concerns about
the soil and groundwater contamination will be addressed in the
second and third operable units. The three alternatives were:
1) No Action - The Superfund program requires that the "no
action" alternative be evaluated at every site as a
baseline for comparison with other possibilities.
2) Limited Site Access - The site would be fenced with
barbed wire, signs would be posted and deed
restrictions would be placed in effect. The business
would continue to operate and employees as well as any
residents refusing relocation during the removal action
would retain access rights to the site.
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3) Permanent Relocation - This would involve the
relocation of residents and the business to replacement
properties comparable to their present locations.
After the relocation, the site would be restricted by
fencing, signs and deed restrictions. No one would be
allowed to return to the site until a determination is
made regarding future site usage.
During the question and answer period that followed, the RPM
responded to concerns about the first removal action, the current
removal action, health and safety concerns arising from the lead
on site as well as features of the proposed relocation package.
The On Scene Coordinator (OSC) for the current Removal action
answered questions about his authorization for the removal and
temporary relocation first discussed with residents at the July
24, 1990 meeting.
The CRC closed the meeting by urging the attendees to respond to
the proposal during the comment period so their remarks would
become part of the official Record of Decision.
2.0 SUMMARY OF COMMUNITY INVOLVEMENT
PRIOR COMMUNITY RELATIONS ACTIVITIES
In March, 1980, the Pennsylvania Department of Environmental
Resources (DER) was asked to examine the cattle and water
supplies of a farm near the site. This was the first official
action in regard to the site, bringing it to wider public
attention. When the farm owner identified the Brown's site as
the source of battery casings with which the nearby road was
paved, further investigation was pursued at the site.
Parents whose children had been tested by the Pennsylvania
Department of Health (DOH) for lead in their blood and found to
be above the action limit in effect at the time (1983), were
instructed about proper cleaning procedures and limiting the
children's activities in the contaminated area.
The two children who currently live on site had their blood level
tested in November, 1989 and August, 1990. Their parents have
been informed that their levels are below the current action
level.
Six of the seven onsite residential adults had their blood lead
levels tested in August, 1990. Three of the six adults tested
had blood lead levels equal to or greater than the current
acceptable level of 10 micrograms per deciliter.
During the 1983-1984 removal action, residents were temporarily
relocated to nearby motels.
During the conduct of the Remedial Investigation and Feasibility
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Study and the offering of the Proposed Plan, the onsite residents
and workers have been kept well informed through a variety of
means:
o Onsite interviews
o Community Relations Plan Development
o Proposed Plan Development
o Public notices regarding:
public meetings
availability of Proposed Plan
o Public Meetings
o Media interviews
o Public Comment Period
o Official Meeting Transcript
o Responsiveness Summary
3.0 SUMMARY OF MAJOR QUESTIONS AMD COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA*8 RESPONSES
During the comment period, one resident and one of the
potentially responsible parties (PRP) submitted written comments
to the Region III EPA office through the Community Relations
Coordinator. The resident who wrote to EPA said his family would
not move "because of public response and low blood levels".
Region III staff acknowledged his remarks in writing. Region
III received calls from the Reading Eagle and from elected and
appointed officials in the area near the site. Also, Channel 69,
an independent station in Allentown, called for background
information after being contacted by one of the onsite residents.
There was one congressional query from Congressman O'Pake, which
was answered by the EPA Region III Administrator.
Because of the level of public concern expressed during the
comment period, representative questions are grouped below by
topical areas of concern:
Lead Contamination;
Q. How can EPA say that there ia * current danger to
residents onsit* if the blood lead levels of most
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adults and both children are below action levels?
A. The soil lead at this site is the main source of
concern. Levels are so high that adverse health
impacts on both children and adults constitute a
threat, even when health checks and tests to assess
such possibilities yield negative results. The
standard procedure for the assessment of such impacts
is one the measures the level of lead in the blood.
While we are aware that much of the impacted lead that
enters the human physiology is that which is
incidentally ingested, this soil contaminant is also,
to a relatively minor extent, inhaled and possibly
absorbed through the skin.
Q. What vill EPA do about debris and open drum* that are
on the vite?
A. The drums will be sealed immediately (this action was
completed 9-5-90 after EPA was advised by a resident
that drums containing contaminated garments from
cleanup workers were open and exposed to the air).
Q. Why have there been so many delays? I* it because
there isn't enough money?
A. EPA is fully funded for this site cleanup. Delays have
taken place as we have tried to get the most accurate
reading of conditions on site so that our strategy is
sure to protect public health and the environment.
Also, one of the responsible parties had begun some of
the remedial work on the RI/FS and later pulled out,
which meant EPA had to begin some of the work again.
Q. will there be other opportunities for public
involvement with the cleanup of this aite?
A. Yes. Each Operable Unit (Site Access, Soil
Remediation and Groundwater Remediation) will have
periods during which we will solicit public comments
and hold public meetings.
Q. What if people don*t want to move or don't like the
relocation package they're offered? Can they be forced
out?
A. EPA has contracted with the United States Army Corps of
Engineers through EPA's Headquarters Real Estate staff
to find comparable buildings for the residents and the
business. These specialists will continue working
with affected parties to make sure they conduct a
thorough search of possibilities in the area. At this
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time, EPA has no plans to conduct a forced removal of
residents from the site. Nevertheless, EPA has the
authority to institute a forced relocation.
Comments submitted by General Battery Corporation to EPA:
l. The environmental problem, if any, exists at the site
was caused by the EPA itself as a results of EPA
activities during 1983-1984. The proposed plan does
not address the EPA's prior misconduct or its own
liability in connection with the site.
There is no evidence to support these allegations. EPA
did not cause the contamination originally found at the
site. These comments are speculative and irrelevant to
the proposed remedial action plan.
2. There is no imminent and substantial endangerment at
the site, and therefore, the proposed plan is
unnecessary and wasteful. If such a condition does
exist, the EPA has continued to act as though the site
presented no problem, quite contrary to imminent and
substantial endangerment.
Pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606,
the EPA Region III Regional Administrator has
determined that actual or threatened releases from this
site may present an imminent and substantial
endangerment to the public health, welfare, or the
environment.
3. The proposed plan does not state how the soil became
contaminated with lead subsequent to EPA's initial
removal in 1983-4, when the EPA certified that it
successfully abated the alleged imminent hasard at that
time posed by lead soil contamination.
The proposed plan addresses conditions that are
documented in the Administrative Record for the site.
The first EPA removal action met its goals according to
applicable requirements.
4. The proposed plan does not state that it is consistent
with the National Contingency Plan (NCP) and, indeed,
it is inconsistent with the HCP.
The Declaration of the Record of Decision states the
remedial action plan was developed in accordance with
CERCLA, as amended by SARA, and, to the extent
applicable, the NCP.
5. The proposed plan fails to state the EPA has ordered an
administrative order pursuant to section 106 of CERCLA
(Order), which addresses the same subject matter of the
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proposed plan. Nor does the proposed plan state how
the recommended remedial alternative is consistent with
BFA's first removal action, its second removal action/
the Order or permanent remedial action.
This comment is incorporated in the Enforcement
Activities portion of the Record of Decision.
6. The proposed plan fails to identify the Applicable or
Relevant and Appropriate Requirements (ARAR's) that are
applicable to this site.
This comment is incorporated in the Record of Decision.
7. By way of further response, OBC incorporated by
reference a number of documents. Among those was OBC*s
Memorandum of Lav in Opposition to the United states*
Motion for Partial Summary Judgment, etc., in United
States v. General Battery Corporation* et al. v.
DiMeniehi. E.S.D.C.. E.D. Pa. Mo. 85-1372.
Since GBC submitted the above-referenced Memorandum,
the court found GBC liable to the United States as a
matter of law on June 1, 1990. The court's opinion is
incorporated herein by reference.
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SUPERFUND PROGRAM PROPOSED PLAN
Brown's Battery Breaking Site
Tilden Township, Berks County, Pennsylvania
August 1990
EPA ANNOUNCES PROPOSED PLAN
DATES TO REMEMBER:
August 17. 1990 - Seoteabtr IS. 1990;
period on the Proposed Plan.
Public comment
September 4. 1990; Public meeting at Tilden Township
Municipal Building.
CONTACTS:
USERA:
Christopher Corbett
(3HW22)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6906
DER:
Ron Klinikowski
State Office Building
625 Cherry Street
Reading, PA 19602
(215) 378-4175
I. INTRODUCTION
The Proposed Plan identifies the preferred alternative for site access at the
Brown's Battery Breaking Site. In addition, the plan includes summaries of other
alternatives considered for the site, and the rationale for identification of
the preferred alternative. This document is issued by the U.S. Environmental
Protection Agency (EPA), the lead agency for site activities. The Pennsylvania
Department of Environmental Resources (OER), is the support agency for this
response action. EPA, in consultation with the OER, will select a final
alternative for this action at the site only after the public comment period has
ended and the information submitted by the public during this time has been
reviewed and considered.
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BROWN'S BATTERY BREAMNQ SITE
k a\ ^C»"x*«>,'Sw //•/.
SOUAC& U.S.O.S., IfTt. AUfUMN. PA. 7.5 MINUTE SCMICS
.. 1977. MAM8UAO. ^A.
7 S MINUTE SEMES QUADRANGLE.
FIGURE 1
BROWN'S BATTERY BREAKING
SITE LOCATION MAP
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EPA is issuing this Proposed Plan as part of its public participatiH
requirements under Section 117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980. This document summarizes
information that can be found in greater detail in documents contained in the
administrative record file for this site. EPA and the DER urge the public to
review these other documents in order to gain a more comprehensive understanding
of the site and Superfund activities that have been conducted there.
The administrative record file, which contains the information upon which the
selection of the response action will be based, is available at the Hamburg
Borough Library, 35 N. Third Street, Hamburg, Pennsylvania. The library is open
on Monday, Tuesday, and Thursday from 1:30 PM to 8:30 PM and Wednesday and Friday
from 10:00 AM to 5:00 PM. For further information regarding the review and
copying of the administrative record file call the library at (215) 562-2843.
EPA, in consultation with the OER, may modify the preferred alternative or select
another alternative presented in this plan based on public comments or new
information. Therefore, the public is encouraged to review and comment on all
of the alternatives identified.
II. SITE BACKGROUND
The Brown's Battery Breaking Site is an inactive lead-acid battery processing
facility located in Tilden Township, Berks County, Pennsylvania (Figure 1). The
facility recovered lead-bearing materials from automobile and truck batteries
from 1961 to 1971. The operation involved breaking the vulcanized rubber battery*
casings, draining acid from the batteries, and recovering the lead-alloy grids,
plates and plugs.
From 1961 to 1965, the lead-recovery process used at the site consisted of
placing batteries on their sides on a conveyer belt that carried them to a
hydraulic guillotine. The guillotine sliced the top from each battery casing,
allowing access to the lead alloy grids. In the early years of operation, the
open-top batteries were manually inverted and the sulfuric acid was poured
directly onto the ground, along with the battery grids. The empty battery
casings were deposited on the ground surface in several areas of the site.
Battery grids were loaded onto a dump trailer for transport and resale.
From 1965 to 1971, the battery casings were rinsed with water prior to disposal
to remove any residual lead remaining on the casings. The rinse water was
collected in steel tanks together with the lead. At the end of each working day
the lead was recovered and shoveled into the dump trailer containing the battery
grids. The rinsewater was then dumped directly on the ground. Casings were
crushed after rinsing. The smaller battery casing pieces were often used as a
substitute for road gravel both onsite and off site.
The Brown's Battery Breaking Site has been investigated by several state and
federal agencies, including the Pennsylvania Department of Health (DOH), DER,
and EPA. DER initiated an investigation of lead contamination at a dairy farm
located near the site in the spring of 1980. The dairy farm had become
contaminated through the use of crushed battery casings as road cover. The
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Brown's Battery Breaking Site was identified as the source of the battery
casings. Subsequent testing conducted by OER and DOH at the Brown's Battery
Breaking Site provided sufficient evidence to indicate that a serious health
threat existed on the site. EPA studied the site in the fall of 1983 and
conducted a Removal Action during the winter of 1983 and spring of 1984. This
Removal Action consisted of excavation and consolidation of battery casings and
contaminated soils and onsite containment of the wastes beneath a low
permeability cap located in the southwest quadrant of the site. This area is
referred to as the "containment area". The site was placed on the EPA Superfund
National Priorities List (NPL) in June 1986.
EPA is in the process of completing a Remedial Investigation/Feasibility Study
(RI/FS) for the site which began in 1989. The purposes of the RI/FS are to
characterize the extent of contamination at the site, quantify risks to human
health and the environment, and evaluate potential remedial alternatives. Site
characterization included sampling and analysis of surface and subsurface soil,
groundwater, surface water, and sediment. A baseline risk assessment was
conducted as part of the investigation and includes quantification of risks to
both human health and the environment. An evaluation of remedial alternatives
is presented in the Feasibility Study portion of the report.
Major findings of the RI/FS are as follows:
• Onsite surface soils and shallow subsurface soils are contaminated
with varying levels of lead;
• Soil contamination is the result of onsite deposition of battery
wastes, including crushed rubber battery casings, battery acid, and
metallic lead grids, posts, and plugs; these materials remain onsite
and must be addressed along with contaminated soils;
• Lead is being transported from the site to the adjacent Schuylkill
River; and
• Dissolved lead is present in groundwater onsite.
III. SCOPE AND ROLE OF REMEDIAL ACTION
Because of the degree of lead contamination and the complexity of associated
environmental problems at the Brown's Battery Breaking Site, EPA has divided the
remedial response work into three manageable components called "operable units
(OU)". These are as follows:
• Site access OU.
• Contaminated soil and battery waste OU.
• Contaminated groundwater OU.
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The contaminated soil and battery waste OU will be discussed in the forthcoming
RI/FS Report. For reasons explained in the RI/FS Report, the contaminated
groundwater OU has not been fully characterized and will be addressed in the near
future. Therefore, the remedial alternatives discussed in this Proposed Plan
apply only to site access.
The site access OU is intended to address the potential public health threat to
residents and workers from contaminated soil and battery wastes and lead
contaminated groundwater, surface water, and air. The objective of this OU is
to prevent exposure of contaminants to the site residents and workers.
IV. SUMMARY OF SITE RISKS
During the RI/FS, an analysis was conducted to estimate the health and
environmental problems that could result from exposure to the contaminated soil
and battery wastes at the Brown's Battery Breaking Site. This analysis is
commonly referred to as a baseline risk assessment. In conducting this
assessment, the focus was on the health effects that could result from direct,
inadvertent ingestion of contaminated soil, inhalation of contaminated dust, and
ingest ion of contaminated drinking water. The analysis focused on the major
contaminant of concern, lead. Lead is a relatively insoluble metal, and is not
highly mobile in the environment under normal conditions. Lead tends to adhere
strongly to soil particles and remain near the area of deposition. Lead does
not readily migrate in groundwater under natural conditions; however, dumping
of battery acid onsite has lowered groundwater pH, increasing the solubility of
lead and the likelihood that lead will migrate in groundwater. Lead is known4
to cause cancer in laboratory animals, and is classified as a probable human
cancer-causing agent. In addition, elevated blood-lead levels in children are
known to cause adverse effects on the following human systems and organs:
Hematopoietic (blood production) system
Nervous system
Kidney
Gastrointestinal system
Bone marrow cells
Reproductive system
Endocrine system
Heart
Immune System
EPA's sampling of site soils found that the average concentration of lead in
surficial soil samples was 9,247 milligrams per kilogram (mg/kg). In addition,
EPA has recently identified a blood-lead concentration of 10 micrograms per
deciliter (ug/dl) as a level of concern for both children and adults. Using this
average and the latest scientific methods available, the EPA has estimated the
following blood-level impacts above the 10 ug/dl criterion:
• Children residing onsite 100 percent above 10 ug/dl
• Adults residing onsite 76 percent above 10 ug/dl
• Adults working onsite 60 percent above 10 ug/dl
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Because of these potential impacts, EPA has determined that removing the
residents and workers from the site is necessary to eliminate an imminent and
substantial endangerment to public health.
V. SUMMARY OF CURRENT ACTIONS
As a result of the Remedial Investigation conducted between June 1989 and March
1990, a second Removal Action was determined to be necessary. This decision was
based on a toxicological review of surface soil sampling results that indicated
elevated lead levels on the properties of current residents and in areas
immediately adjacent to their homes.
The second Removal Action was initiated in June 1990 and is currently in
progress. This action is intended to temporarily relocate all onsite residents
to protect them from direct exposure to onsite contamination.
Four residences and an active auto body shop exist onsite. One resident is a
homeowner and the other three are tenants. A total of seven adults and two
children reside in the four residences. Two of the residents are employed at
the auto body shop. Two additional adults are employed at the auto body shop
but reside off site. Access to the site is currently unrestricted thereby
allowing an undetermined number of people direct exposure to onsite
contamination.
A meeting was held on July 24, 1990 in the Tilden Township Municipal Building
to discuss the rights and benefits of the residents affected by the temporary
relocation. All adult site residents attended the meeting and were informed of
the existing site conditions and EPA's recommendation of immediate temporary
relocation. Neither the site owner nor any other potentially responsible parties
were present. The residents were informed that EPA was prepared to immediately
relocate all residents to a temporary location such as a motel or similar
establishment until arrangements could be made for suitable rental properties.
None of the residents agreed to immediate relocation to a motel. EPA will
continue to work with the onsite residents to provide appropriate temporary
relocation arrangements.
VI. SUMMARY OF REMEDIAL ALTERNATIVES
In order to select the most appropriate remedial action, various alternatives
are developed so that a variety of distinct, viable options can be analyzed.
The alternatives evaluated for the site access OU are presented below:
Alternative 1: No action.
Alternative 2: Limited site access.
Alternative 3: Permanent relocation.
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Alternative 1: NO ACTION
The Superfund program requires that the "no action" alternative be evaluated at
every site to establish a baseline for comparison. Under this alternative, the
business and any resident who refused temporary relocation during the removal
action would remain onsite and no actions would be taken to limit access to the
site or reduce exposure to onsite contaminants.
• Capital Cost: None
• Total Operation and Maintenance (O&M) Costs: None
• Present Worth (PW): None
• Months to Implement: None
Alternative 2: LIMITED SITE ACCESS
The limited site access alternative would consist of placing a 6 foot fence
topped with barbed wire around the perimeter of the site to restrict access.
Signs would be posted to indicate that the area is a hazardous waste site. Deed
restrictions would be placed on the site properties to prohibit new people from
moving onsite to new or existing residences until a determination is made
regarding future usage of the properties.
The auto body shop would continue to operate and the employees and any current
residents who refuse temporary relocation during the removal action would be
permitted access to the site.
Limited environmental sampling would be performed to monitor the contamination
in the groundwater and private wells. Periodic blood-lead screening would be
available to the auto body shop employees and remaining residents in order to
monitor their blood lead levels.
• Capital Cost: $21,600
• Total O&M Costs: $21,400
• PW: $53,800
• Months to Implement: 2 to 3
Alternative 3: PERMANENT RELOCATION
The permanent relocation alternative would involve the relocation of residents
and the business to replacement properties comparable to their present locations.
After the relocation is completed, the residents and business would not be
permitted to return to the site. Site access would be restricted by a 6 foot
fence topped with barbed wire. Signs would be posted to indicate that the area
is a hazardous waste site. Deed restictions would be placed on the property to
prohibit residential and industrial use until a determination is made regarding
future site usage. Section 101(24) of CERCLA states that a remedial action
includes the costs of such permanent relocation of residents and businesses.
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Section 104(j) provides the authority to acquire property to conduct a remedial
action. All relocation activities will be performed in accordance with the
"Uniform Relocation Assistance and Real Property Acquisition Policies Act of
1970", and the "Uniform Relocation Act Amendments of 1987".
• Capital Cost: $342,900
• Total O&M Costs: None
• PW: $342,900
• Months to Implement: 2 to 6
VII. EVALUATION OF ALTERNATIVES
The preferred alternative for relocation at the Brown's Battery Breaking Site
is Alternative 3 - Permanent Relocation. Based on current information, this
alternative appears to provide the best balance among the nine criteria that EPA
uses to evaluate alternatives. This section profiles the performance of the
preferred alternative against the nine criteria, noting how it compares to the
other alternatives under consideration. A glossary of the evaluation criteria
is given below.
GLOSSARY OF EVALUATION CRITERIA
Overall protection of human health and environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional control.
Compliance with ARARs addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of federal and state
environmental statues and/or provide grounds for invoking a waiver.
Long-term effectiveness and permanence refers to the magnitude of residual risk
and the ability of a remedy to maintain reliable protection of human health and
the environment over time once cleanup goals have been met.
Reduction of toxicitv. mobility, or volume through treatment is the anticipated
performance of the treatment technologies that may be employed in a remedy.
Short-term effectiveness refers to the speed with which the remedy achieves
protection, as well as the remedy's potential to create adverse impacts on human
health and environment during the construction and implementation period.
Implementabilitv is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement the
chosen solution.
Cost includes capital and operation and maintenance costs.
State acceptance indicates whether the state concurs with, opposes, or has no
comment on the preferred alternative.
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Community acceptance has been and will be assessed throughout all site activities
and will be documented in the Record of Decision following a review of the public
comments received on the Proposed Plan.
ANALYSIS
Overall protection; The no action alternative does not provide any protection
to human health or the environment since all remaining residents and onsite
workers will continue to be exposed to the contaminants onsite.
The limited site access alternative protects the health of individuals not living
or working on the site by limiting access and prohibiting additional residents
from moving onsite. Although access will still be permitted to auto body shop
customers, the site will be posted as a hazardous waste site, informing them of
the risks associated with the area. This alternative does not protect the health
of the shop employees or residents remaining onsite, but it does provide a means
of monitoring their exposure. The limited site access alternative does not
provide any protection to the environment.
The permanent relocation alternative provides good overall protection of human
health. The health of remaining residents and shop employees is protected since
they will be permanently relocated after the Record of Decision is signed. Site
access will be restricted and residential and industrial use will be prohibited
protecting the health of off site individuals. This alternative will protect
the environment to a small extent by eliminating human activity on the site which
can transport contamination off site.
Compliance with ARARs; The ARARs that are applicable to the site access OU are
those that deal with relocation and exposure and protection of human health.
ARARs that deal with maximum contaminant levels, site activities, etc. will be
addressed during the other OUs.
The no action and limited site access alternatives are not in compliance with
ARARs since the residents and auto body shop employees would still be exposed
to site contaminants.
The permanent relocation alternative is in compliance with ARARs by eliminating
exposure to shop employees, residents, and off site individuals. CERCLA Section
104(j) provides the authority to acquire property that is needed to conduct a
remedial action. Section 101(24) of CERCLA states that the term "remedial
action" includes permanent relocation of residents and businesses when it is
determined that relocation is more cost-effective and environmentally preferable
than other alternatives. All relocation activities will be performed in
accordance with the "Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970" and the "Uniform Relocation Act Amendments of 1987".
8
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Long-term effectiveness and permanence; The site access OU is intended to
provide short-term protection until the cleanup takes place. None of the
alternatives provide a permanent solution. However, permanent relocation will
eliminate continued exposure to the auto body shop employees and remaining
residents from contaminants at the site. Fencing and deed restrictions will
limit the potential for exposure to other people and the transport of
contamination off site.
Since the relocation OU does not provide long-term effectiveness or a permanent
solution for the environment, this criteria will be evaluated during the analysis
of contaminated soil, battery waste, and groundwater alternatives.
Reduction of toxicitv. mobility, or volume of contaminants through treatment;
No reduction of toxicity, mobility, or volume of contaminants by treatment will
occur during the site access OU. This criteria will be evaluated during the
analysis of the other two OUs.
Short-term effectiveness; The no action and limited site access alternatives
provide no short-term effectiveness since shop employees and remaining residents
are exposed to site contamination. The permanent relocation alternative provides
good short-term effectiveness in reducing risks to human health and preventing
the transport of contaminants off site.
Implementabilitv; All of the site access alternatives are technically and
administratively implementable.
Cost; There are no costs associated with the no action alternative. The limited
action alternative will cost approximately $53,800 and the permanent relocation
alternative will cost approximately $342,900.
State acceptance; The Pennsylvania Department of Environmental Resources (DER)
supports the decision that permanent relocation is the preferred alternative for
this OU.
DER recognizes that issues concerning cleanup standards will be addressed in
the contaminated soil and battery waste operable unit. The permanent relocation
of the onsite residents and workers should not control the degree to which the
site should be cleaned nor should it dictate any future use of the site.
Pennsylvania has not agreed to take title to the property under Section 104(j)
of CERCLA, 42 U.S.C. Section 9604(j), nor does DER believe that deed restrictions
are appropriate where access agreements can be obtained from the property owners.
In such access agreements, the property owners should provide assurances that
they will not inhabit the site during the remedial action, and should they
transfer the title to a third party during the remedial action, they will provide
notice to the third party of the remedial action in progress at the site.
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Community acceptance; The no action alternative may not be acceptable to the
community since the shop employees and residents remaining on the site will be
exposed to a health threat.
The limited site access alternative may be acceptable to the community since
the shop employees and the residents who choose to remain onsite will be
monitored for exposure to lead.
The permanent relocation alternative is acceptable to the community if suitable
replacement properties can be procured. These opinions are based on recent
comments and conversations with site residents.
Community acceptance will be updated throughout this process, evaluated after
the public comment period, and described in the Record of Decision.
VIII. SUMMARY OF THE PREFERRED ALTERNATIVE
The permanent relocation alternative provides good protection of human health
and limited protection of the environment. The relocation and site restrictions
will eliminate human contact with contaminated soil, contaminated groundwater,
and lead-bearing dust particles. Restricting site use and access will reduce
the potential for transport of contaminants off site.
The preferred alternative provides overall effectiveness proportionate to its
costs. Temporary relocation for any remaining onsite residents would be required
during the extensive excavation activities anticipated during the contaminated
soil and battery waste Operable Unit. Permanent relocation will eliminate the
potential cost to temporarily relocate the remaining onsite residents for
approximately eighteen to twenty-four months.
The permanent relocation alternative is in compliance with all ARARs specific
to the site access OU. This alternative is effective in meeting the goals of
this OU, is technically and administratively implementable, and is acceptable
to both the state and community.
IX. THE COMMUNITY'S ROUE IN THE REMEDY SELECTION PROCESS
EPA solicits Input from the community on the cleanup methods proposed for each
Superfund response action. EPA has set a public comment period from August 17.
1990 to September 15. 1990 to encourage public participation in the selection
process. The comment period includes a public meeting at which EPA will present
highlights of the on-going RI/FS Report and Proposed Plan, answer questions, and
accept both oral and written comments.
A public meeting is scheduled for 8:00 PM September 4. 1990 and will be held at
Tilden Township Municipal Building.
10
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Comments will be summarized and responses provided in the Responsiveness Summary
section of the Record of Decision (ROD). The ROD is the document that presents
EPA's final selection for the site remedy. To send written comments or obtain
further information, contact:
Leanne Nurse
Community Relations Coordinator
U.S. Environmental Protection Agency
841 Chestnut Street (3EA-21)
Philadelphia, PA 19107
(215) 597-6920
11
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BROWN'S BATTERY BREAKING SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
I. SITE IDENTIFICATION
1) Report: Site Analysis, Brown's Battecy Breaking
Site/ Berks County, Pennsylvania/ prepared by The
Bionetics Corporation, 2/84. P. 100001-100016.
* Administrative Record File available 8/2/89, updated
8/17/90.
Note: Company and organizational affiliation is identified
in the index only when it appears in the file.
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II. REMEDIAL ENFORCEMENT PLANNING
1) Memorandum of Purchase Option, between Mr. Robert T.
Brown and Mrs. Barbara A. Brown, and Price Battery
Corporation, prepared by Berks Title Insurance
Company, 10/1/62. P. 200001-200001.
2) Letter to Mr. Holland E. Shade, General Battery
Corporation, from Mr. John Watts Barrett, Barrett
and Monaghan, re: Request for a release from a land
purchase option, 11/11/77. P. 200002-200005. An
executed release from the purchase option and a
notary's statement are attached.
3) Letter to Mr. John Watts Barrett, Barret [sic] and
Monaghan, from Mr. R.E. Shade, General Battery
Corporation, re: Transmittal of the executed
release from the purchase option, 11/22/77. p.
200006-200006.
4) Letter to Mr. Rolland E. Shade, General Battery
Corporation, from Mr. John Watts Barrett, Barrett
and Monaghan, re: Release from the purchase option,
12/20/77. P. 200007-200007.
5) Summary of October 25, 1983 Meeting between U.S. EPA
and General Battery Corporation, prepared by Mr.
Richard L. Zambito, U.S. EPA, 10/25/83. P. 200008-
200008.
6) Letter to Mr. Thomas Massey, U.S. EPA, from Mr. J.A.
Bitler, General Battery Corporation, re:
Transmittal of names of medical experts with
experience in treatment of high lead exposure
children, 10/27/83. P. 200009-200010. A list of
the names and addresses of the physicians is
attached.
7) Memorandum to Mr. J. Bitler, General Battery
Corporation, from Mr. J. Leed, General Battery
Corporation, re: Recyclability of lead-containing
rubber battery cases and soil, 10/28/83. P. 200011-
2000011.
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8) Memorandum to Record from Mr. J. Leed, General
Battery Corporation, re: Transmittal of a copy of
an article from the October 28, 1983 issue of
Environment Reporter regarding U.S. EPA procedures
at hazardous waste sites, 11/7/83. P. 200012-
200012.
9) Letter to Mr. John Bitler, General Battery
Corporation, from Mr. Robert J. Mitkus, U.S. EPA,
re: EPA activities at the Brown's Battery Breaking
Site in lieu of voluntary action by potentially
responsible parties, 11/9/83. P. 200013-200014.
10) Letter to Mr. John Bitler, General Battery
Corporation, from Mr. Robert J. Mitkus, U.S. EPA,
re: EPA activities at the Brown's Battery Breaking
Site in lieu of voluntary action by potentially
responsible parties, with a list of concurrences,
11/9/83. P. 200015-200017. A memoraridum regarding
the recyclability of lead-containing rubber battery
cases and soil is attached.
11) Letter to Mr. William F. Price from Mr. J.A. Bitler,
General Battery Corporation, re: Transmittal of a
copy of EPA notification regarding cleanup action at
the Brown's Battery Breaking site, 11/14/83. P.
200018-200018.
12) Letter to Mr. and Mrs. Terry L. Shaner Sr. from Mr.
J.A. Bitler, General Battery Corporation, re:
Transmittal of a copy of EPA notification regarding
clean-up action at the Brown's Battery Breaking
Site, 11/15/83. P. 200019-200019.
13) Memorandum to Mr. C. Petzold from Mr. J.A. Bitler
re: Request for information on options for
consuming the rubber cases from the site landfill,
12/13/83. P. 200020-200020.
14) Memorandum to Mr. J. Bitler, General Battery
Corporation, from Mr. D. Ferrante, General Battery
Corporation, re: Relocation of families from the
Brown Battery Breaking Site, 12/15/83. P. 200021-
200021.
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15) Memorandum to Mr. John Bitler, General Battery
Corporation, from Mr. John Hardy, General Battery
Corporation, re: Research of the whereabouts of
Barbara B. Brown, and other relatives of Robert T.
Brown, Sr., 12/15/83. P. 200022-200024. A copy of
a page from a telephone directory is attached.
16) Letter to Mrs. Barbara B. Brown from Mr. John A.
Bitler, General Battery Corporation, re:
Transmittal of a copy of EPA notification regarding
clean-up action at the Brown's Battery Breaking
Site, 12/16/83. P. 200025-200025.
17) Letter to Mr. John A. Bitler, General Battery
Corporation, from Mr. Paul T. Essig, re:
Whereabouts of Barbara Brown, 12/20/83. P. 200026-
200026.
18) Letter to Mr. John Bitler, General Bafetery
Corporation, from Mr. Robert J. Mitkus, U.S. EPA,
re: 104 (e) information request, 1/10/84. P.
200027-200028.
19) Memorandum to Mr. J.A. Bitler, General Battery
Corporation, from Mr. C.G. Petzold, General Battery
Corporation, re: Transmittal of requested documents
concerning Brown Battery Company, 1/19/84. P.
200029-200029.
20) Summary of January 27, 1984 Meeting Between U.S. EPA
and General Battery Corporation, prepared by Mr.
Richard L. Zambito, U.S. EPA, 1/27/84. P. 200030-
200030.
21) Memorandum to Mr. C. Petzold, General Battery
Corporation, from Mr. J.A. Bitler, General Battery
Corporation, re: Request for information regarding
Brown Battery Breaking Company, 1/30/84. P. 200031-
200031.
22) Summary of February 9, 1984 Meeting between U.S. EPA
and General Battery Corporation (GBC), prepared by
Mr. Richard Zambito, U.S. EPA, 2/9/84. P. 200032-
200032.
23) Letter to Mr. Kermit Rader, U.S. EPA, from Mr. Denis
[sic] V. Brenan, Morgan, Lewis & Bockius, re:
Transmittal of a list of materials requested,
2/17/84. P. 200033-200033.
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24) Letter to Mr. Kermit Rader, U.S. EPA, from Mr. Denis
[sic] V. Brenan, Morgan, Lewis & Bockius, re:
Address of William F. Price, principal and chief
executive officer of Price Battery Corporation,
3/1/84. P. 200034-200034.
25) Order In The Matter Of General Battery Corporation,
3/2/84. P. 200035-200049.
26) Letter to Mr. Kermit Rader, U.S. EPA, from Mr. J.A.
Bitler, General Battery Corporation, re: Response
to the EPA's 104 (e) information request, 3/8/84. P.
200050-200051.
27) Letter to Mr. Richard Zambito, U.S. EPA, from Mr.
Gary R. Galida, Pennsylvania Department of
Environmental Resources, re: Legal classification
of cleanup activities under CERCLA, 3X21/84. P.
200052-200052.
28) Letter to Mr. John Bitler, General Battery
Corporation, from Mr. Stephen R. Wassersug, U.S.
EPA, re: Request for reimbursement for response
actions performed by EPA under CERCLA, 9/19/84. P.
200053-200055. A receipt for certified mail is
attached.
29) Letter to Mr. John Bitler, General Battery
Corporation, from Mr. Stephen R. Wassersug, U.S.
EPA, re: Potential liability for costs of
additional work to be performed at the Brown's
Battery Breaking Site, 4/25/86. P. 200056-200059.
A receipt for certified mail is attached.
30) Letter to Ms. Carol E. Stokes, U.S. EPA, from Mr.
John A. Bitler, General Battery Corporation, re:
Clarification of conditions stated in earlier
correspondence, 5/8/86. P. 200060-200061.
31) Letter to Ms. Carol E. Stokes, U.S. EPA, from Mr.
John A. Bitler, General Battery Corporation, re:
Request for additional information prior to General
Battery Corporation's participation in the proposed
Remedial Investigation/Feasibility Study (RI/FS),
5/14/86. P. 200062-200063.
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32) Letter to Ms. Carol Stokes, U.S. EPA, from Ms.
Kristine A. Crosswhite, Miles & Stockbridge, re:
Confirmation of extension for the Julian C. Cohen
Salvage Corporation to indicate its intent to
participate in the Remedial Investigation/
Feasibility Study, 5/14/86. P. 200064-200064.
33) Letter to Mr. John A. Bitler, General Battery
Corporation, from Ms. Carol Stokes, U.S. EPA, re:
General Battery Corporation's participation in the
Remedial Investigation/Feasibility Study and
development of a Statement of Work (SOW), 5/23/86.
P. 200065-200067. A receipt for certified mail is
attached.
34) Letter to Ms. Carol Stokes, U.S. EPA, from Mr. Denis
V. Brenan, Morgan, Lewis & Bockius, re:
Confirmation of an extention [sic] granted to
General Battery Corporation relative fco the
performance of a Remedial Investigation/ Feasibility
Study, 6/26/86. P. 200068-200068.
35) Memorandum to Ms. Carol Stokes, U.S. EPA, from Ms.
Libby Rhoads, U.S. EPA, re: Wetland areas which may
be impacted by the Brown's Battery Breaking Site,
6/30/86. P. 200069-200069.
36) Letter to Ms. Carol Stokes, U.S. EPA, from Mr. John
A. Bitler, General Battery Corporation, re: General
Battery Corporation's intention to participate in
the Remedial Investigation/Feasibility Study,
7/25/86. P. 200070-200070.
37) Routing and Transmittal Slip to Mr. Kermit Rader,
from Carol [sic], re: Brown's Battery Draft Order,
8/20/86. P. 200071-200073. A letter regarding the
necessity of a Consent Order and a Statement of Work
and a receipt for certified mail are attached.
38) Letter to Ms. Carol Stokes-Cawley, U.S. EPA, from
Mr. Frank A. Labor III, Morgan, Lewis & Bockius, re:
Amendment of timetable regarding General Battery
Corporation's participation in the Remedial
Investigation/Feasibility Study, 8/27/86. P.
200074-200075.
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39) Report of Conversation to Mr. Jeff Lead [sic],
General Battery Corporation, from Ms. Carol Stokes-
Cawley, re: Well specifications, 9/22/86. P.
200076-200076.
40) Memorandum to Browns Battery Site File, from Ms.
Carol Stokes-Cawley, U.S. EPA, re: Details
concerning the Statement of Work for the Remedial
Investigation/Feasibility Study, 11/26/86. P.
200077-200078.
41) Letter to Ms. Carol Stokes, U.S. EPA, from Mr. Denis
[sic] V. Brenan, Morgan, Lewis & Bockius, re:
Transmittal of a Scope of Work, 12/1/86. P. 200079-
200079.
42) Letter to Ms. Carol Stokes-Cawley, U.S. EPA, from
Mr. John A. Bitler, General Battery Corporation, re:
Transmittal of the revised Statement of Work,
12/24/86. P. 200080-200080.
43) Letter to Mr. John A. Bitler, General Battery
Corporation, from Mr. Jack Kelly, U.S. EPA, re:
Proposed revisions to the Statement of Work,
1/27/87. P. 200081-200081.
44) Letter of Transmittal to Mr. John Bitler, General
Battery Corporation, from Mr. W.G. Christopher,
Engineering-Science, re: Transmittal of the revised
Statement of Work, 3/6/87. P. 200082-200082.
45) Letter to Mr. Jack Kelly, U.S. EPA, from Mr. John A.
Bitler, General Battery Corporation, re:
Transmittal of a revised Project Schedule, 3/12/87.
P. 200083-200086. A graphical Project Schedule, a
marked-up copy of a graphical Project Schedule and a
written summary of the Project Schedule are
attached.
46) Administrative Order On Consent In The Matter Of
Brown's Battery Breaking Company Site, 6/30/87. P.
200087-200140.
47) Letter to Mr. Jack Kelley [sic], U.S. EPA, from Mr.
Jeffrey A. Leed, General Battery Corporation, re:
Transmittal of the Work Plan for the Remedial
Investigation/Feasibility Study, 8/11/87. P.
200141-200141.
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48) Letter of Transmittal to Mr. J. Kelly, U.S. EPA,
from Mr. J.P. McAuliffe, Engineering-Science, re:
Transmittal of the Brown's Battery Breaking Site
Work Plan and Quality Assurance Project Plan,
8/21/87. P. 200142-200142.
49) Letter to Mr. Jack Kelley [sic], U.S. EPA, from Mr.
Jeffrey A. Leed, General Battery Corporation, re:
Submittal of the Health and Safety Plan for
approval, 10/1/87. P. 200143-200143.
50) Letter to Mr. Jeffrey Leed, Exide Corporation, from
Mr. Jack Kelly, U.S. EPA, re: Resolution of
Remedial Investigation/Feasibility Study Work Plan
issues, 3/25/88. P. 200144-200145.
51) Letter to Mr. Jack Kelly, U.S. EPA, from Mr. Frank
A. Labor III, Morgan, Lewis & Bockius, re: General
Battery/Exide Corporation's response to EPA
modifications of the proposed Work Plan, 5/6/88. P.
200146-200148.
52) Letter to Mr. Frank Labor, Morgan, Lewis & Bockius,
from Mr. Jack Kelly, U.S. EPA, re: Proposed
modifications to the Work Plan, 7/1/88. P. 200149-
200157. A list of additional work to be required as
Phase II of the Remedial Investigation and a list of
necessary revisions to the proposed Work Plan are
attached.
53) Letter to Mr. Jack Kelly, U.S. EPA, from Mr. Frank
A. Labor III, Morgan, Lewis & Bockius, re:
Acknowledgement of receipt of correspondence
regarding General Battery Corporation, 7/8/88. P.
200158-200158.
54) Letter to Mr. Jack Kelly, U.S. EPA, from Mr. Frank
A. Labor III, Morgan, Lewis & Bockius, re: General
Battery Corporation's refusal to perform the
Remedial Investigation/Feasibility Study, 8/4/88.
P. 200159-200160.
55) Letter to Mr. Frank Labor III, Morgan, Lewis i
Bockius, from Mr. James M. Seif, U.S. EPA, re: EPA
commencement of Remedial Investigation/Feasibility
Study activities at the Brown's Battery Site,
8/25/88. P. 200161-200163. Two certified mail
receipts are attached.
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56) Memorandum to Mr. J.W. Horton, General Battery
Corporation, from Mr. J.A. Bitler, General Battery
Corporation, re: Transmittal of photographs of the
Brown Battery Breaking facility, (undated). P.
200164-200164.
57) Letter to Mr. Robert T. Brown, Brown's Battery
Breaking Company, from Mr. S. Dershwin, Price
Battery Corporation, re: Renewal of a contract for
breaking batteries, (undated). P. 200165-200165.
58) List of parties sent Remedial Investigation/
Feasibility Study (RI/FS) notice letters, (undated)
P. 200166-200168. A list of parties from which
responses were received is attached.
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III. REMEDIAL RESPONSE PLANNING
1) Report: Feasibility Study for Brown's Battery
Breaking Site, prepared by IT Enviroscience,
12/16/83.FT 300001-300064.
2) Report: Extent of Contamination Survey for the
Brown's Battery Breakage Site, prepared by U.S. EPA,
12/83.P. 300065-300128.
3) Report: Brown's Battery Breaking Site, Remedial
Action Master Plan and Remedial Investigation/
Feasibility Study Work Plan, Final Draft, prepared
by Ecology and Environment, Inc., 1/86. P. 300129-
300230.
4) Letter to Ms. Linda Boornazian, U.S. EPA, from Mr.
Harry P. Butler, CDM Federal Programs.Corporation,
re: Transmittal of Health and Safety Plan for the
site reconnaissance visit at the Brown's Battery
Breaking Site, 3/3/87. P. 300231-300255. The
Health and Safety Plan is attached.
5) Letter to Mr. Frank A. Labor III, Morgan, Lewis and
Bockius, from Mr. Kermit Rader, U.S. EPA, re:
Transmittal of the revised draft of the Consent
Order, with comments, 3/19/87. P. 300256-300276.
The order is attached.
6) Letter to Mr. Kermit Rader, U.S. EPA, from Mr. Frank
A. Labor III, Morgan, Lewis 4 Bockius, re:
Transmittal of the Brown's Breaking Site
Administrative Order On Consent, 6/15/87. P.
300277-300277.
7) Letter to Mr. Jeffrey Leed, General Battery
Corporation, from Mr. Jack Kelly, U.S.'EPA, re:
Transmittal of EPA's comments on the RI/FS Work
Plan, 11/10/87. P. 300278-300279.
8) Memorandum to Mr. Jack Kelly, U.S. EPA, from Mr. H.
Ronald Preston, U.S. EPA, re: Review and
recommendations of the Remedial Investigation Work
Plan, 12/2/87. P. 300280-300379. The following are
attached:
a) a draft of the review memorandum;
b) a memorandum regarding deficiencies in the
Project Plan;
c) a Quality Assurance Project Plan Review;
10
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d) a letter regarding the analysis of metals
in soil samples;
e) a letter regarding the transmittal of a
summary report of a discussion of Remedial
Investigation/Feasibility Study issues;
f) a letter regarding the transmittal of a
revised summary of a meeting;
g) a report entitled "Revised Summary of
January 7, 1988 Meeting to Discuss EPA
Comments on the RI/FS Work Plan for
Brown's Battery Site";
h) a work plan review of the Remedial
Investigation/Feasibility Study;
i) a letter regarding EPA's response to the
Remedial Investigation/Feasibility Study
Work Plan;
j) a letter regarding General Battery
Corporation's unwillingness ,to perform the
Remedial Investigation/Feasibility Study;
k) a letter regarding EPA's intention to
perform the Remedial Investigation/
Feasibility Study;
1) a handwritten memorandum regarding
communications with Terry Shaner.
9) Boring Logs # 1, 2, and 3 for Brown's Battery
Breaking Site, prepared by the New England Pollution
Control, Co., Inc, 3/22/89. P. 300380-300386. A
topographic and geologic survey for wells # 1, 2,
and 3 and a site plan of the respective wells are
attached.
10) Report: Quality Assurance Project Plan, prepared by
Black & Veatch Inc., 5/15/89. P. 300387-300790.
11) Technical Support Documents, prepared by the U.S.
EPA, undated. P. 300791-300894. The following are
attached:
a) a calculation sheet for lead concentration
in air at site;
b) a calculation sheet for lead concentration
in leafy vegetables from site gardens;
c) a report entitled "Feasibility Study for
Brown's Battery Breaking Site";
d) a memorandum regarding lead results on
samples at the Terry Shaner site;
e) a letter regarding potential financial
responsibility for EPA activities at the
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Brown's Battery Breaking site;
f) a Notice of Violation to Terry and Susan
Shaner;
g) a letter regarding Price Battery
Corporation's response to an information
request;
h) a letter regarding the extension of a
deadline and confirmation of the
guardianship of William F. Price;
i) a Letter of Guardianship;
j) a letter regarding procedures between the
Price Battery Corporation and Brown's
Battery Breaking Company;
k) a Deed between Barbara A. Brown, and Terry
L. Shaner and Susan A. Shaner;
1) a Deed between Terry L. Shaner and Susan
A. Shaner, and Terry L. Shaner Jr.;
m) a letter regarding the blood, lead levels
of four children;
n) a Fund Authorization Request> Immediate
Removal Request for the Brown's Battery
Breaking site.
12. Report: Draft Sampling Analysis Plan, Brown's
Battery Breaking Site, prepared for the U.S. EPA,
5/15/89. P. 300895-300954.
13. Report: Draft Addendum to Field Sampling Plan,
prepared by B & V Waste Science and Technology
Corp., 9/12/89. P. 300955-300972.
14. Report: Draft RI/FS Plan, (undated). P. 300973-
301505.
15. Memorandum to Mr. Chris Corbett, U.S. EPA, from Mr.
Richard Brunker, U.S. EPA, re: Calculated hazards
from exposed soil. P. 301506-301507.
16. Superfund Program Proposed Plan, Brown's Battery
Site, 8/90. P. 301568-301519.
17. Letter to Mr. Christopher Corbett, U.S. EPA, from
Mr. Joseph Gormley, B & V Waste Science and
Technology Corp., re: Transmittal of a calculation
for lead concentration at the Brown's Battery Site,
8/1/90. P. 301520-301525.
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18. Report: Your Rights and Benefits as a Displaced
Program, prepared by the U.S. Department of
Transportation, (undated). P. 301526-301551.
19. General Guidance: Federal Register, Uniform
Relocation Assistance and Real Property Acquisition
for Federal and Federally Assisted Programs,
(undated). P. 301552-301591.
20. Letter to Mr. Christopher Corbett, U.S. EPA, from
Mr. Joseph Gormley, B & V Waste Science and
Technology, Corp., re: Submittal of cost
calculations for permanent relocation alternatives,
8/15/90. P. 301592-301594.
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IV. REMOVAL
1) Report: Federal On-Scene Coordinator's Report,
Brown's Battery Breaking Site, Tilden Township,
Berks County/ Pennsylvania, CERCLA Immediate Removal
Action. Volume I, 10/20/83-7/11/84. P. 400001-
400217.
2) Report: Federal On-Scene Coordinator's Report,
Browns Battery Breaking Site, Tilden Township,
Berks County, Pennsylvania, CERCLA Immediate Removal
Action, Volume II, 10/20/83-7/11/84.P. 400218-
400609.
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1) Sampling Location Map, 11/83. P. 500001-500001.
2) Waste Thickness Contour Map, 11/83. P. 500002-
500002.
3) Contour Map with Areas of Contamination, 1/16/84.
P. 500003-500003.
4) Letter to Honorable William Ruckelshaus, U.S. EPA,
from Mr. John Heinz, U.S. Senate, re: Safe Drinking
Water Act,2/29/84. P. 500004-500007. A letter
regarding complaints about the cleanup of the
Brown's Battery site and a congressional
correspondence control slip are attached.
5) Letter to Honorable John Heinz, U.S. Senate, from
Mr. Thomas P. Eichler, U.S. EPA, re: '.Procedures of
the EPA Superfund Emergency Removal Program and how
they pertain to the Brown's Battery site, 3/7/84.
P. 500008-500010.
6) Letter to Honorable Gus Yatron, House of
Representatives, from Mr. Thomas P. Eichler, U.S.
EPA, re: Procedures of the EPA Superfund Emergency
Removal Program and how they pertain to Brown's
Battery Site, 3/7/84. P. 500011-500027. The
following are attached:
a) a copy of the- aforementioned letter;
b) a letter regarding complaints about the
cleanup of the Brown's Battery site;
c) two congressional correspondence control
slips;
d) a letter regarding transmittal of
correspondence;
e) five photocopied newspaper articles.
7) Land Survey Map, 5/84. P. 500028-500028.
8) Letter to the Congressional Relations Director, U.S.
EPA, from Mr. John Heinz, U.S. Senate, re:
Transmittal of correspondence complaining about the
EPA's actions, 10/17/84. P. 500029-500033. A
handwritten letter regarding the battery recycling
business is attached.
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9) A Congressional Correspondence Control Slip from
Honorable John Heinz, U.S. Senator, 11/7/84. P.
500034-500038. Two copies of a letter regarding the
status of the Brown's Battery site cleanup and the
EPA view of its impact are attached.
10) Aerial Photographs of the Brown's Battery Breaking
Site, 7/24/85. P. 500039-500041. A site layout map
is attached.
11) Report: Community Relations Plan, prepared by NUS
Corporation, 9/26/86. P. 500042-500058.
12) Two Photography Volumes of Brown's Battery Breaking
Site, (undated). P. 500059-500325. The following
are included:
a) 1,019 color photographs;
b) 39 pages of 35mm negative film strips;
c) 1 slide.
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GENERAL GUIDAfCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.'
2) "Proposal of Update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites/ dated 8/28/85.
4) Groundvater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero ret Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/8S.
6) Guidance on Remedial Investigations under CERCLA, dated 6/85.
I
7) Guidance on feasibility Studies under CERCLA, dated 6/85.
8) "Proposal of Uodate 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGrav entitled "Cownunity Relations Activite*
at Supertax! Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2,* Federal Register, dated 10/15/84
11) EPA Gjrourxfrater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Hectaan, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
13) "Proposal of Update 1,' Federal Register, dated 9/8/83.
14) Community Relations in Superfundt A Handbook (interim version), dated
978T
15) "PrcooMl of Pint National Priority List," Federal Register, dated
12/30/82.
16) "Expanded Eligibility List," Federal Register, dated 7/23/82.
17) "Interia Priorities List," Federal Register, dated 40/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System; A user's Manual
(undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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