Superfund Record of Decision: Brown's Battery Breaking, PA - Second Remedial Action


United States        Office of
Environmental Protection   Emergency and
Agency           Remedial Response
                                          EPA/ROD/R03-92/150
                                          July 1992
                                          PB93-963918
v°/EPA   Superfund
          Record of Decision:
          Brown's Battery Breaking, PA

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NOTICE.
The appendices listed In 1M index that are not found in this document have been remowed at 1he'request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supplemental material is. how8wr, contain8d In the administrative record
for this site.
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50272.'01
rEPORT DOCUMENTATION 11. REPORT NO. 2. 3. Reclplent'a Ac:c:e88ion No.
PAGE EPA/ROD/R03-92/150
4. TIt. and Subt1t18 S. Report Data
SUPERFUND RECORD OF DECISION 07/02/92
Brown's Battery Breaking, PA
Second Remedial Action - Final 6.
7, Author(a) 8. Performing Organization RapL No.
'0 Performing Orgalnlzatlon Nama and Add- 10. Projec:t/Taak/Work Unit No.
11. Contrac:t(C) or Grant(G) No.
(C)
(G)
12. Sponaorlng Organization Name and Add.... 13. Type of Report & Period Coverad
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SUppiemontary Notaa
PB93-963918
16. Abatrac:I (UmIt: 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 and Mill Creek. The entire site lies within the lOa-year floodplain of
the Schuylkill River. From 1961 to 1971, the facility recovered lead-bearing materials
from automobile and truck batteries by breaking the battery casings, draining the acid,
and recovering the lead alloy, grids, plates, and plugs. During this time, battery
acid and rinse water from recovery activities were dumped onto the soil, and crushed
casings were disposed of onsite or used as a substitute for road gravel. During the
1980's, state onsite and offsite investigations identified lead concentrations in
excess of acceptable limits in residents' blood levels, livestock, soil, and surface
waters. A 1983 EPA investigation also revealed extensive lead contamination in onsite
soil and sediment located in the Schuylkill River. As a result of the investigations,
EPA initiated a removal action that relocated three families, and excavated and
consolidated 13,000 cubic yards of contaminated soil and battery casings into an on site
(See Attached Page)
17. Doc:umont Analyalt .. Daac:rlplora
Record of Decision - Brown's Battery Breaking, PA
Second Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: metals (lead, nickel) I other inorganics (sulfate)
b. Identifi8ra/Opan-Ended Tarme
~ c:. COSAlI FieldlGroup
8. Availability Statement 19. Security Cia.. (This Report) 21. No. 01 Page.
None 74
20. Security Cia.. (Thia Page) 22. Price
None
212 (4-71)
(See ANSI-Z3'.18)
See Inatruclionll on R.v.rse
(Fonnerty HT1S-35)
Dapenmont of Commerce

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EPA/ROD/R03-92/150
Brown's Battery Breaking, PA
Second Remedial Action - Final
Abstract (Continued)
containment area, which was capped with a low permeability cap. In 1990, a second
removal temporarily relocated all onsite residents and implemented institutional
controls. A 1990 ROD addressed implementation of deed restrictions and relocation of
affected residents. This ROD addresses the remediation of onsite soil, battery casings,
and ground water as a final action at the site. The primary contaminants of concern
affecting the soil, debris, and ground water are metals, including lead and nickel; and
other inorganics, including sulfate.
The selected remedial action for this site includes excavating and treating 67,000 cubic
yards of soil and battery casings offsite using an innovative thermal treatment
technology, followed by offsite disposal; constructing two vertical limestone barriers in
the shallow aquifer to neutralize lead levels; pumping and treatment of contaminated
ground water in the bedrock aquifer using pH adjustment, precipitation, and ion exchange,
with onsite discharge; transporting sludge generated during the treatment process offsite
for disposal at a POTWi monitoring ground wateri and implementing institutional
controls, including deed restrictions to limit site usei providing for a contingent
remedy, which allows for stabilization/solidification of the soil and casings, followed
by offsite disposal of the stabilized mass, if the selected innovative alternative cannot
be implemented. The estimated present worth cost for this remedial action is
$12,316,000. No O&M costs were specified in this ROD.
PERFORMANCE STANDARDS:
Clean-up levels for lead-contaminated soil are based on present EPA policy. An ARAR
waiver has been issued on the basis that EPA will achieve an Equivalent Standard of
Performance in the protection of human health and the environment. The recommended
action level for residential areas is between 500 and 1,000 mg/kg, but no criterion for
industrial areas has been established. EPA, therefore, has determined 1,000 mg/kg as the
clean-up level for the lead-contaminated soil. Ground water clean-up goals for the
shallow bedrock aquifer are based on CWA WQC and state standards. Chemical-specific
clean-up goals for this site are background levels except for manganese, which must be
cleaned to 50 mg/l (state). Other ground water goals include beryllium 0.19 ug/l (WQC)i
cadmium 0.88 ug/l (WQC); lead <3 ug/l (WQC)i manganese 50 ug/l (state)i nickel 2.9 ug/l
(WQC)i and sulfate 27 ug/l (WQC).

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RBCORD O~ DBCIBIO.
BRon' 8 BA'1"1'BRY BRBUIBG 8ITB
DBCLARATIOB
SITE NAME AND LOCATION
Brown's Battery Breaking site
Tilden Township, Pennsylvania
Operable unit II - Remediation of site Soils and Ground Water
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Brown's Battery Breaking site ("the 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 has not concurred in this
remedy.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant
to section 106 of CERCLA, 42 U.S.C. S 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 overall cleanup strategy for the Site consists of two
Operable units: Operable Unit I, presently being implemented,
which addressed restriction of site access and relocation of the
site residents and the onsite business, and this second Operable
unit which will address the contaminated soils and ground water.
Specifically, the selected remedy for Operable Unit II,
Remediation of Site Soils and Ground Water, will remove
contamination from onsite soils so that the site can be used in
an industrial manner, and will restore the ground water to its
beneficial use by cleaning both the shallow and deep aquifers to
background levels. A contingent soil remedy, to be implemented
if the selected soil remedy is not implementable, also has been
chosen and will accomplish the same remedial goals. This
Operable unit II is the final action of two Operable Units for
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the site.
The major components of the selected remedy include:
.
Offsite treatment of soil and battery casings using an
innovative thermal treatment technology. EPA also has
selected a contingent soil alternative of onsite
sOlidification/ stabilization of the soils and casings
and offsite disposal should the innovative technology
not prove implementable;

Construction of a vertical limestone barrier in the
shallow aquifer; and
.
.
Pumping of the bedrock aquifer with onsite treatment
and disposal.
STATUTORY DETERMINATIONS
Both the selected remedy and the contingent remedy are protective
of human health and the environment and are cost effective. EPA
believes that both remedies will comply with all Federal and
State requirements that are legally applicable or relevant and
appropriate to the remedial action with the sole exception of the
Commonwealth of Pennsylvania's requirements for closure of
hazardous waste disposal sites. Therefore, in accordance with 40
CFR 5300.430(e) (9)(B), I hereby waive the provisions of 25 PA
Code 5265.300-310 on the basis that EPA will achieve an
Equivalent Standard of Performance in the protection of human
health and the environment by the implementation of either the
selected remedy or the continqent remedy. Both remedies utilize
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable and
satisfy the statutory preference for treatment as a principal
element.
Because this remedy will result in hazardous substances remaininq
onsite above health-based levels, a review by EPA 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.
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7 ~/?Z-

Date
~R30/902

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I.
II.
III.
IV.
V.
VI.
VII.
VIII.
RECORD OF DECISION
BROWN'S BATTERY BREAKING SUPERFUND SITE
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION
1
SITE HISTORY AND ENFORCEMENT ACTIVITIES
4
SCOPE AND ROLE OF THIS PINAL OPERABLE UNIT II
WITHIN SITE STRATEGY
8
SUMMARY OF SITE CHARACTERISTICS
9
CONTAMINANT FATE AND TRANSPORT
14
SUMMARY OP SITE RISKS
21
SUMMARY OF REMEDIAL ALTERNATIVES
29
COMPARATIVE ANALYSIS OP ALTERNATIVES
50
x
IX. SELECTED REMEDY
72
61
RESPONSIVENESS SUMMARY
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TUB DECISION SUMMARY
I. SITB NAMB, LOCATION, AND DESCRIPTION
The. Brown's Battery Breaking site (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 1990 population of
Shoemakersville was 1,410 people.

The site is bordered by Reading, Blue Mountain and Northern
Railroad 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
site is in the vicinity of the largest concentration of farmland
in the county. 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 are seeking 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 railroad berm rises 9 feet above the site
and there is an area elevated 6 to a feet above the surface in
the southwest corner of the site known as the "containment area".
Approximately 50% of the Site is located in the 10-year
floodplain. The entire Site, except for the central portion of
the containment area, lies within the 100-year floodplain.
Currently, a one-story brick home, a mobile home, a log cabin
residence, and an automobile and truck service shop are located
on the site (Figure 2). Although the log cabin residence was
constructed prior to 1860, EPA believes it has little or no
historic significance because of modifications made to it by past
and present owners.
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                                                          so•   o   so-  too
                                                            GRAPHIC SCALE
.CHCC AND KCHNOLOCT CORP.
                                                   BROWN'S BATTERY BREAKING SITE

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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. BACKGROUND -
From 1961 to 1971, Mr. Robert Brown conducted a battery
recycling/lead recovery process at the Site. Batteries were
brought to a building ("the breaking building"), they were placed
on their sides upon a conveyer belt and carried 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 Mr. Brown's operation, the open-top batteries were
manually inverted and the sulfuric acid was poured directly onto
the ground outside the breaking building, 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. The
foundation of the breaking building still exists onsite.
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 outside the breaking
building. 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.
otherwise, the battery casing pieces remained 'onsite.

During the ten years of facility operations from i961 to 1971,
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 Mr. Brown, and ownership of the property
passed to his wife, Barbara Brown. Currently, most of the
northern portion of the site is owned by Mrs. Susan and Mr. Terry
Shaner, Sr., and most of the southern portion is owned by Mr.
Terry Shaner, Jr. Mr. Richard Strausser owns the parcel of land
in the northeast portion of the site consisting of the log cabin
and approximately three quarters of an acre of surrounding
property. (Figure 2). The Reading, Blue Mountain, and Northern
Railroad owns a strip of land, which includes the railroad
tracks, along the entire northwest side of the site.
In March 1980, the Pennsylvania Department of Environmental
Resources (DER) was requested by the farm owner 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
4
AR301907

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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. This property later became
known as the Brown's Battery Breaking Superfund Site.
In June 1983, the Pennsylvania Department of Health (DOH) tested
the blood of the four young children who, at the time, resided on
the site. The blood tests for all four children revealed lead
concentrations in excess of the 30 micrograms per deciliter
(~g/dl) health action limit established by the Centers for
Disease Control (CDC). DOH subsequently instructed parents on
proper cleaning procedures and limiting the children's activities
in contaminated areas. .
A preliminary Assessment (PA) was conducted by EPA in 1983.
Based on the PA 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. 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 transport of lead from the
site by surface water, ground water, and air.
ERT conducted the field sampling program for the EOC survey
between November 1-3, 1983. Samples were collected from soil,
air, vegetables grown in two onsite gardens, two onsite drinking-
water wells, Schuylkill River and Mill Creek surface waters and
sediments, ponded water on the Site, and battery casing piles on
the site. 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 EOC survey report 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.
5
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A Site Investigation (SI) was completed in 1984. The SI
established extensive lead contamination in onsite soils and in
sediments located in the Schuylkill River.
B. FIRST REMOVAL ACTION
A CERCLA Immediate Removal Request was forwarded from EPA Region
III to EPA Headquarters on October 6, 1983, for temporary
relocation of the onsite residents, performance of studies to
select a removal cleanup option, provision of site security,
decontamination of residences and related tasks. Approval was
received on October 20, 1983, and the three families residing on
the site were relocated on October 31, 1983, for the duration of
the onsite construction activities. Based on the results of the
above studies, 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 quantity of excavated battery casings and soil materials
moved into the containment area during the removal action was
reported by the OSC to be 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
completed on July 11, 1984, and the three relocated families
returned to their residences. '
C. 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 placed on the NPL in June, 1986 (51 FR 21054).
D. SECOND REMOVAL ACTION
As a result of the Remedial Investigation/Feasibility Study
(RI/FS) sampling activities conducted by EPA between June, 1989
and March, 1990, a second removal action was determined by EPA to
be necessary at the Site. 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. At that time,
seven adults and two children lived onsite in the four
residences.
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The second removal action was initiated in June 1990 and
provided, once-again, for temporary relocation of all onsite
residents to suitable offsite locations. This action did not
address the onsite business activities. One family was relocated
under this second removal.
E. RECORD OF DECISION FOR OPERABLE UNIT ONE
On September 28, 1990, the EPA signed a Record of Decision
authorizing the permanent relocation of all the residents and the
automobile and truck service shop, the construction of a fence
around the site, and the placement of deed restrictions on the
property. Implementation of this ROD is presently underway.
F. HISTORY OF CERCLA ENFORCEMENT ACTIVITIES
Between October 24 and 26, 1983, General Battery corporation
(GBC) and the site owner were verbally notified by EPA of EPA's
intent to conduct removal activities at the site and were offered
the opportunity to perform such activities. A follow-up letter
by EPA on November 17, 1983, to both parties stated that, since
neither the Site owner nor GBC had notified EPA of their
willingness to undertake the removal activities, EPA would begin
such activities. On March 2, 1983, EPA issued a unilateral.
administrative to GBC, pursuant to Section 106 of CERCLA, to
undertake the removal activities. That order was withdrawn on
March 30, 1984.
On June 30, 1987, GBC entered into an Administrative Order On
Consent to perform the RIfFS for the Brown's Battery Breaking
site. However, EPA later determined that performance of studies
in addition to those specified in the Order, including additional
air and stream sampling as well as installation and sampling of
additional monitoring wells, was necessary in order to complete
the RIfFS. GBC, on August 4, 1988, formally notified EPA that
GBC was "unwilling to proceed with the performance of the RIfFS,
as modified by the EPA". On August 25, 1988, the Regional
Administrator notified GBC that EPA would take over the RIfFS 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 Sections 104 and 107 of CERCLA, 42 U.S.C. S59604 and
9607, against GBC and Terry Shaner, 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. This litigation is still ongoing.

On July 27, 1990, EPA issued a Unilateral Order pursuant to
Section 106(a) of CERCLA, 42 U.S.C S9606(a), to GBC and the
7
AR30J910

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present site owner, to perform additional removal work at the
Site. The order required GBC and the site owner either to
temporarily relocate those onsite residents desiring such
relocation or excavate contaminated surface soils and relocate
affected residents during the excavation. The respondents have
not complied with this order.

On April 1, 1991, issued a Unilateral Order to the present Site
owners to, among other things, provide EPA access to the site for
performance of certain studies and the relocation of site
residents, and to refrain from leasing or permitting anyone to
live on the Site once residents were relocated. EPA is assessing
the respondents' compliance with this Order.
G. HIGHLIGHTS OF COMMUNITY PARTICIPATION
All public participation requirements of Sections 113(k) (2) (B) (i-v)
and 117 of CERCLA have been met in this remedy selection process.
A one-quarter page newspaper advertisement was published in the
Readina Times/Readina Eaale. Reading, Pennsylvania, on January 8,
1992. It specified the availability of the Proposed Remedial
Action Plan (PRAP), the duration of the public comment period,
and the location of the Administrative Record.
The public comment period on the PRAP began on January 8, 1992,
and ended on March 9, 1992, having been extended an extra 30 days
based on a timely request from the public. A public meeting to
discuss the PRAP was held on January 21, 1992, at the Hamburg
Borough Hall. Approximately 300 people attended, including
former and current site residents, the current Site owner,
supervisors from Hamburg Borough, staff from EPA Region III and
DER as well as several hundred employees of General Battery
Corporation. .
Based on public comments received during that comment period, EPA
issued a revised PRAP. EPA published a new one-quarter page
newspaper advertisement in the Readina Times/Reading Eaale on
April 14, 1992, announcing the revised PRAP and new 30-day
comment period ending May 15, 1992. This announcement also
offered the opportunity for a public meeting if .the public
desired one. No public meeting was requested and none was held.
III. SCOPK AND ROLE OP OPERABLE UNIT TWO WITHIN SITE STRATEGY
The overall Site cleanup strategy consists of two Operable Units:
Operable Unit One which requires the restriction of site access
and relocation of onsite residents; and Operable Unit Two which
requires the remediation of onsite soils, battery casings and
ground water. This Record of Decision addresses Operable Unit
Two, remediation of soils, casings and ground water.
8
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The RI/FS documented extensive lead contamination of onsite
soils. It also documented the release of contamination into
adjacent surface water and sediments and into the ground water of
the shallow andlbedrock aquifers. Direct contact with the
contaminated soils and potential ingestion of contaminated ground
water pose the principal risks at this Site. A full description
of the results of the investigation appears in the "Summary of
site Characteristics" section, immediately below.
IV. SUMMARY OF SITE CHARACTERISTICS
A. BACKGROUND
The field work for the Remedial Investigation/Feasibility study
(RI/FS) was performed in four phases. The activities and dates
for each phase are as follows:
o
Phase I was conducted in June, 1989, and consisted of
soil sample collection, surface water and sediment
sample collection, and ground water sample collection
from two potable wells on the Site.

Phase II occurred during the fall and winter of 1989.
Phase II included the collection of additional soil
samples, the installation and sampling of four
overburden monitoring wells, and the sampling of three
existing overburden monitoring wells. Additional Phase
II soil samples and treatability study samples were
collected during March, ~990.
o
o
Phase III was undertaken in the spring of 1991. Four
overburden monitoring wells were installed. Ground
water samples were collected from all but one of the
existing wells. In addition, samples of settled dust,
paint, and surface soils were collected.
o
Phase IV was conducted in July and August of 1991 and
consisted of the installation and sampling of three
bedrock wells.
Air was not extensively sampled during the RI, but the potential
for contaminant migration via the air pathway was evaluated using
the Industrial Source Complex (rSC) model.

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 risk to public health or the environment nor
require any remedial action. Therefore, the following discussion
9
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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
battery 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
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.
B. SOILS
The results of Site sample analyses indicate that soils are the
most heavily impacted environmental medium at the Site and lead
is the contaminant of concern. Although organic compounds
including PAHs, phthalate esters, chlorinated pesticides, and
PCBs were also detected, they were not widespread at the site and
were present only in extremely low concentrations which present
no threat to human health or the environment.
Soils data indicate widespread lead contamination in surficial
soils. Most areas of the Site had lead in surficial soils
exceeding the cleanup goal of 1000 ppm. The most highly
contaminated soils were concentrated in the general area between
the containment area and the service shop, in the area just
southwest of the mobile home residence adjacent to the schuylkill
River, and in the wooded area between the containment area and
Schuylkill River.
EPA sampling data show that concentrations of lead in soil range
from background to 60,000 ppm. still higher concentrations, up
to 170,000 ppm, were indicated by the ERT Atomic Adsorption (AA)
lead analysis. However surficial concentrations were generally
below a few thousand ppm.
The occurrence of lead concentrations greater than a few thousand
ppm in the shallow subsurface was sporadic. In general, these
occurrences correlated well with the occurrence of battery casing
fragments.
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C. SHALLOW AQUIFER
Aluminum, ironr-and manganese were among those contaminants
detected in elevated concentrations in filtered ground water
samples collected from site monitoring wells during Phases II and
III. In addition, low concentrations of lead, zinc, and copper
were detected in one out of three unfiltered ground water samples
collected from the log residence domestic well during Phase II.
The results of Phase II and III sampling indicate that similar
concentrations of calcium, magnesium, and sodium were present in
the log residence well during both phases. No other metals were
detected in unfiltered ground water samples collected from this
well during either phase.
Low concentrations of methylene chloride, acetone toluene, and
methoxychlor were detected in ground water collected during Phase
III; however, these compounds were not detected substantially
above the level reported in laboratory or field blanks, or the
concentration was below the detection limit and is not accurate
or precise. In addition, ground water samples collected during
Phase II efforts did not contain any volatiles, semi-volatiles,
or pesticides/PCBs.
Several dissolved metals were detected in overburden monitoring
well samples in concentrations above background levels during
Phase II and Phase III. These metals include lead, aluminum,
cobalt, iron, manganese, nickel and zinc. While lead and zinc
are components of battery wastes, the other metals are apparently
naturally occurring. The presence of elevated concentrations of
dissolved metals from both waste sources and naturally-occurring
sources is the result of battery acid dumping which has reduced
the ground water pH and allowed for the dissolution of these
metals.
Ground water samples from all overburden monitoring wells had pH
levels below the background range of pH 6.7-6.6. With one
exception, the overburden wells with the lowest pH levels also
contained the highest concentrations of dissolved metals. Three
of these wells are located near and downgradient of the battery
breaking building. Past battery acid disposal is interpreted to
be responsible for the low pH readings in this area of the site.
The fourth well is located at the end of the containment
area near Mill Creek. It is possible that the low pH in this
well is due to the residual sulfuric acid in the lead-
contaminated battery casings and soil aggregated in the
containment area. It should be noted, however, that this well
did not contain detectable amounts of lead (total or dissolved
fraction) during either sampling phase. The dissolved metals
present in elevated concentrations in these five overburden wells
were aluminum, lead, cobalt, manganese, nickel and zinc.
11
AR30191lt

-------
Dissolved lead was detected in three monitoring wells sampled
during Phase III in concentrations between 13 ppb and 55 ppb.
Cobalt was detected in four Phase II monitoring wells in
concentrations ranging from 74.3 ppb to 177 ppb (dissolved
metals), but in only one well during Phase III (225 ppb total
metals).
Dissolved manganese was detected in all site monitoring wells at
levels exceeding background concentrations during Phase III. The
highest concentration was 30,600 ppb and the lowest 1900 ppb.
Like cobalt, the dissolved nickel concentrations decreased from
Phase II to Phase III. During Phase III nickel was found in
roughly equal concentrations ranging from 31.7 to 65.4 ppb.

The dissolved zinc concentrations in the filtered samples
obtained ranged from 229-240 ppb in Phase III. Like nickel, the
dissolved zinc concentrations were detected during Phase III at
lower concentrations than in Phase II.
The decreasing concentrations of these dissolved metals,
including manganese, from Phase II to Phase III is probably a
seasonal effect. Samples collected during Phase III generally
had higher pH than Phase II samples. The Phase II sampling event
(November, 1989) was preceded by a dry season, whereas during
Phase III (April, 1991), the ground water obtained more recharge.
As a result, higher concentrations of hydrogen ions (lower pH)
and dissolved metals were observed during Phase II when less
precipitation and, therefore, less dilution occurred.
Sulfate concentrations, sulfide concentrations and alkalinity
were measured exclusively during Phase III in all "monitoring
wells except one which did not contain sufficient volume of water
for collection of samples for ion analysis. Sulfate results
indicate that the highest sulfate concentrations are associated
with low pH values. This clearly indicates the extent of
overburden aquifer contamination by sulfuric acid (consisting of
sulfate and hydrogen ions) on the site.

Alkalinity values ranged from non-detected to 101 mg/L in
overburden wells.
D. BEDROCK AQUIFER
The concentrations of most metals in the bedrock aquifer are
considerably higher than in the overburden aquifer, reflecting
dissolution of large quantities of solids. Dissolved cadmium is
high in the well nearest the battery breaking building (58 ppb
and 26 ppb during EPA sampling on August 2, 1991 and August 14,
1991, respectively). Farther downgradient, the dissolved
concentration decreased by approximately 30%. The dissolved
cadmium in the bedrock aquifer is probably the result of
12
aR301915

-------
dissolution by--battery acid. No cadmium was detected upgradient
of the battery breaking building.
Sulfate occurrence in the bedrock aquifer is a direct result of
acid dumping during the battery breaking operations. Sulfate
concentration ranges from 27 ppm to 4910 ppm.
Dissolved lead concentrations vary consistently with cadmium and
sulfate concentrations in three bedrock wells. The lead
concentration ranges between Non-Detectable and 14.6 ppb.

The high concentrations of all dissolved metals such as
o beryllium, manganese and nickel vary similarly among bedrock
wells with high concentrations near the battery breaking building
and low background concentrations near the upgradient well. This
trend is consistent with both major aquifer constituents and
trace aquifer constituents. The primary cause for this trend is
the sulfuric acid near the battery breaking building.
The concentrations of dissolved metals in the bedrock aquifer are
generally much higher than those in the overburden aquifer. This
is likely because precipitation has percolated into the
overburden aquifer and replaced the water with high
concentrations of dissolved metals. Meanwhile, the high metal
concentrations in the bedrock aquifer remain largely undiluted.

Low concentrations of dissolved and suspended metals including
lead, zinc, iron, and manganese were detected °in surface water
samples obtained from Mill Creek and the Schuylk 0.1 River 0
adjacent to the Site. Suspended metals are probe oJly contributed
by runoff and dissolved metals by ground water d~3charge from the
Site. Analysis of downstream water samples did not reveal
elevated concentrations of dissolved or suspended metals.
Therefore, the low concentrations of metals in surface water must
attenuate quickly by methods such as dilution, .sorption, and
coprecipitation.
Sediment samples obtained from the schuylkill River upstream of
the Site contained lead concentrations up to 259 ppm that are
considered above background levels. Sediment samples obtained
from the Schuylkill River directly adjacent to the Site contained
concentrations of lead greater than background levels, and in
some cases greater than upstream sediment lead concentrations.
Sediment samples obtained from the schuylkill River downstream of
the site did not contain concentrations of lead greater than
upstream samples. .
E. AIR
Onsite soils contaminated with lead have the potential to be
suspended and transported by wind erosion and vehicular traffic
13
l\R301916

-------
as particulate emissions or dust. This contaminated dust can
then be ingestea or inhaled by persons on or near the Site.

Particulate emissions were evaluated using the ISC Model and
through limited ambient air sampling for lead. The modeled
results for ambient particulate emission impact were multiplied
by the mean lead concentration in the driveway material to arrive
at ambient lead impact concentrations.
The maximum particulate emissions and lead impact occurred ata
location approximately 35 meters north-northeast of the log cabin
residence onsite. The estimated quarterly average lead impact
concentration at this location is 0.0041~g/m3. This
. concentration is 0.3 percent of the National Ambient Air Quality
Standard ("NAAQS") for lead of 0.15 mg/m3, time weighted average
(TWA). No ambient samples exceeded the NAAQS for lead.
Due to the lack of standard methods for sample collection and
analysis of settled dust samples, the lead values were evaluated
qualitatively rather than quantitatively. While no federal or
Pennsylvania standards currently exist for regulating lead in
household settled dust, the States of Maryland and Massachusetts
have established standards ranging from 200 ~g/ft to 800 ~g/ft.
Samples collected in the brick residence did not exceed these
lead standards. The lead results for the brick residence ranged
from 6.21 ~g/ft to 56.88 ~g/ft.

F. VOLUME OF CONTAMINATED SOIL OUTSIDE THE CONTAINMENT AREA
Using the cleanup level of 1000 ppm,as .discussed in Section VI
below, the volume of soil and battery casings outside the
containment area requiring excavation is estimated to be 27,500
cubic yards.
G. 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. Based on a
visual estimate, the excavations indicate that the material in
the containment area is approximately 70 percent crushed battery
casings. 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, and the assumption that all materials
placed in the containment area were contaminated.
v. CONTAMINANT FATE AND TRANSPORT
Lead is the most widespread and concentrated contaminant present
on the Site and was identified as the contaminant of greatest
14.
aR30i9'

-------
health concern on the site based on the baseline risk assessment.
Current information about the Brown's Battery Breaking site
indicates that three migration pathways are significant: air,
ground water, and surface water. Data collected during the RI
indicate that offsite migration occurs to the surface water and
ground water pathways. Current data on the bedrock ground water
pathway is limited due to the limited scope of the hydrogeologic
investigation. An expanded hydrogeologic evaluation of the
bedrock ground water will need to be performed during the design
of the Remedial Action.
A. CONTAMINANT PERSISTENCE
Lead is not usually mobile in 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.
B. 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
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 railroad line.
15
AR301918

-------
RI sample res~s 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.

The vertical distribution of lead at concentrations greater than
1000 ppm was generally limited to the upper four feet of the soil
column. Significant exceptions to this generalization include
the containment area (where lead-bearing wastes were observed at
depths up to ten feet during the first Removal Action), an area
near the brick house, and the narrow strip of land between the
containment area and the railroad tracks (Figure 3).
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.
Ground Water:
Pathway
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.
Evaluation of the air pathway was accomplished through the use of
the ISC model. 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.,

Ground water results indicate that several metals have become
solubilized and mobilized in site ground water due to onsite
battery acid dumping which has depressed ground water pH.
Solubility of metals generally increases as pH decreases. The
depressed pH in the shallow ground water has mobilized metals
including lead and zinc, both of which are battery waste
components. In addition, it has mobilized iron, manganese,
nickel, aluminum, and cobalt which occur naturally onsite (Figure
4). Evaluation of site hydrogeology indicates that ground water
16
~R301919

-------
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pH AND OTHER CONTAMINATION
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PHILADELPHIA, PENNSYLVANIA
roojtcr no.
20210
PHASE
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BROWN'S BATTERY BREAKING SITE
OVLRBUROEN fOUIFICR flSSUHED «RC« OF CONCERN
FIGURE
4
-------
contaminated ~soluble metals is in hydraulic communication with
the bedrock aquifer. In addition, ground water will discharge to
adjacent surface water bodies to some extent.

Ground water in the bedrock aquifer contains very high levels of
sulfate and dissolved solids (manganese, calcium and magnesium)
immediately downgradient of the battery breaking building. There
is also an elevated concentration of cadmium in these wells. The
pH in the wells downgradient of the battery breaking building was
also lowered to levels between 4 and 5. The sulfate, dissolved
solids and cadmium all appear to be the result of the battery
breaking operation because levels upgradient were very low or
undetected and representative of background (Figure 5). Surface
water sampling and analysis detected low concentrations of
suspended and dissolved lead, zinc, and manganese adjacent to the
site. Downstream surface water samples did not contain elevated
metals concentrations. Therefore, EPA has concluded that metals
in solution are quickly attenuated by dilution, sorption
to sediments, and/or precipitation.
Sediment samples generally did not exhibit elevated metals
concentrations except for those samples obtained directly
adjacent to the Site, which contained up to 367 ppm lead. The
Schuylkill River channel in the site area is apparently not an
area of sediment deposition. Metals accumulating in sediments
are probably periodically scoured by flooding, then diluted and
re-deposited downstream.
C. POPULATION AND ENVIRONMENTAL AREAS POTENTIALLY AFFECTED
Prior to 1990, four residences and an active automobile and truck
service shop existed onsite. A total of seven adults and two
children resided in the four residences. Two of the residents
were employed at the auto shop. Two additional adults reside
offsite but are employed at the shop. A second removal action
was initiated on June 29, 1990, the purpose of which was to
provide temporary relocation to the residents to protect them
from direct exposure to onsite contamination. The occupants of
one residence agreed to be moved under this action. Two
residents and their mobile home trailer as well as the residents
of the log cabin have been relocated under the ROD for Operable
Unit I. Further relocation activities are planned for the near
future. 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 in
ground water, the RI 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
19
aR301922
-------
BEDROCK AREA OF CONCERN
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PHILADELPHIA. PENNSYLVANIA
POOJCCT ND.
20210
THnse
215
BROWN'S BflTTERY BREflKING SITE
BEDROCK AQUIFER ASSUMED
ARES OF CONCERN
FIGURE
5
-------
primary drinking source for several cities located downriver of
the site. Several downstream industries also utilize the river
as a water resource.
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, there 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.
VI. SUMMARY OF SITE RISKS
During the RIfFS, an assessment was made to estimate the health
and environmental impacts from exposure to the contaminated soil,
battery wastes, and ground water as a drinking water source at
the Brown's Battery Breaking site. This assessment is commonly
referred to as a baseline risk assessment. This assessment
focused on the health effects that could result from the
following exposure pathways:
o
Ingestion of contaminated soil and settled house dust
by a resident child and adult.

Ingestion of contaminated fish caught in the Schuylkill
River by a resident child or adult.
o
o
Ingestion of contaminated water by a resident child
swimming in the Schuylkill River.

Ingestion of contaminated drinking water by a
resident child or adult.
o
o
Inhalation of contaminated respirable dust by a
resident child or adult.
The baseline risk assessment focused on lead, manganese, nickel,
beryllium and cadmium as contaminants of concern. These metals
are relatively insoluble and are not mobile in the environment
under normal conditions. These metals tend to adhere strongly to
soil particles and remain near the area of deposition. They do
not readily migrate in ground water under natural conditions;
however, the dumping of battery acid onsite has lowered the
ground water pH thus increasing the solubility of several metals
and the likelihood that they will migrate in groundwater.
21.
AR3UI924
-------
A. TOXICITY ASSESSMENT
1. Lead
Exposure to lead via inhalation and ingestion can cause potential
carcinogenic and noncarcinogenic adverse health effects. The
fo~lowing sections present toxicological information and toxicity
values for the carcinogenic and noncarcinogenic effects of lead.
Carcinoqenic Effects. The Carcinogen Assessment Group (CAG) of
the u.s. 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 the
basis of sufficient animal evidence, with inadequate human
evidence.
Noncarcinoqenic Effects. The noncarcinogenic toxicologic effects
of lead are well documented. Lead affects the following human
systems or organs:
.

.
Hematopoietic system
Nervous system
Kidneys
Gastrointestinal system
Bone marrow cells
Reproductive system
Endocrine system
Heart
Immune system
.
.
.
.
.
.

.
The consensus on the blood lead (Pb-B) level of children which is
considered toxic has changed in recent years. In 1975, the u.S.
CDC defined the toxic level in children's blood as 40 ~g/dl. .
This value was reduced in 1985 by CDC to 25 ~g/dl. In 1986, the
World Health organization (WHO) recommended 20 ~g/dl as the upper
acceptable toxic limit for children. In the same year, EPA's
Clean Air scientific Advisory Committee indicated that levels of
10 to 15 ~g/dL can be associated with adverse health effects in
children. In October, 1991, the u.s. CDC recommended an
intervention level of 10 ~g/dl.

Consequently, a Pb-B level of 10 ~g/dL was used as the Pb-B limit
for children, below which children should not be considered at
risk from exposure to lead, according to currently available
data.
For adults, particularly white males of 40 to 59 years old,
studies have indicated that increases in blood pressure are
associated with Pb-B levels ranging from possibly as low as 7
~g/dL to ~ 30 - 40 ~g/dL. As a result, a Pb-B level limit of 10
~g/dL was used for adults, below which adults should not be
considered at risk from exposure to lead.
22
~R301925
-------
2. Manganese

Manganese (Mn) is an essential element for humans (i.e., required
for proper functioning of the human body), and is also used in
making steel alloys, dry-cell batteries, electrical cores,
ceramics, matches, glass, dyes, in fertilizers, welding rods, as
oxidizing agents and as animal food additives. Inhalation
exposure to high concentrations of manganese dioxide can result
in lung inflammation, whereas chronic inhalation exposure results
in damage to the central nervous system similar to Parkinson's
disease, as well as cirrhosis of the liver. The estimated safe
daily intakes Mn for lifetime exposure is an oral dosage of
IxlO"1 mg/kg/day (RfD), and an inhaled dosage of l.lxlO"4
mg/kg/day (RfC).

3. Nickel

Nickel (Ni) is an important element used for electroplating
coatings for turbine blades, helicopter rotors, extrusion dies
coinage, ceramics, storage vessels, batteries, and electronic
circuits as well as in the production of steel and many other
alloys. The major source of human exposure is in the workplace
by inhalation of dust and fumes and skin contact, but it can also
affect the general populations by ingestion of contaminated food
stuffs and drinking water, usually in the form of soluble salts.
It has been known for over 40 years that inhalation of nickel is
associated with the development of lung, nasal and respiratory
cancer. However, an evaluation of the carcinogenicity of soluble
salts of nickel, which are possible contaminants of soil, water,
and food, has not been performed.

Noncarcinogenic effects of nickel exposure include nausea, fever,
lung inflammation and respiratory failure following acute
incidences, as well as contact dermatitis (skin rashes). There
is also evidence that chronic ingestion of nickel containing
foods increases the risk of developing skin rashes. Studies
performed in animals to estimate the long-term effects of nickel
exposure showed a decrease in body and organ weights of rats (may
be indicative of disease), as well as a decrease in their
appetite. The estimated safe oral dosage (RfO) for lifetime
exposure to Ni is 2xlO~2 mg/kg/day.

4. Beryllium

Beryllium (Be) is a highly toxic heavy metal (also occurring as
Beryllium salts) resulting from coal combustion and other
industrial processes. The principal routes of human exposure are
inhalation, ingestion of Be salts and skin contact.
Transportation of this metal through human tissue is accomplished
via the bloodstream. Be is classified as a probable human
carcinogen (Class B2), producing major adverse health effects to
the lung and skeletal system. Human epidemiological studies

flR3GI926
-------
indicate a possible relationship between inhalation of beryllium
and the incidellce of lung cancer in exposed workers. Animal
studies have demonstrated the induction of tumors by a variety of
beryllium compounds. An increase in lung cancer was observed in
rats following both chronic oral and inhaled dosages of Be, with
inhalation being the more dangerous route of exposure (i.e.,
producing a higher incidence of cancer at lower concentrations).
Bone cancer has been induced in rabbits and mice following.
chronic intravenous injection of various Be salts.
The toxicity of Be is also evident by the noncarcinogenic health
effects that exposure can produce. Skin contact may result in a
delayed allergic reaction, which is characterized by large skin
lesions that may not heal. Inhalation of beryllium causes
. inflammation of the entire respiratory tract and berylliosis
(chronic lung disease). The estimated safe oral dosage (RfD) for
lifetime exposure to Be is 5x10-4 mg/kg/day.

5. Cadmium
Cadmium (Cd) is a noncorrosive metal used in a wide variety of
industrial processes such as electroplating and galvanizing. It
is also used as a color pigment for paints and plastics, and as
cathode material for nickel-cadmium batteries. Cadmium is a by--
product of zinc and lead mining, which are significant sources of
environmental pollution. Cd is an airborne workplace
contaminant, but exposure is of greater concern to the general
population. It is found in food stuffs such as grains, meat,
fish and fruit, in contaminated air, water, and soil, as well as
in cigarette smoke. Humans are exposed to cadmium via inhalation
and ingestion, at which time the metal can be transported through
the bloodstream to vital organs. Cd is designated as probable
human carcinogen (Class B1), based on a higher incidence of lung
cancer in cadmium smelter workers, and increased incidence of
prostrate cancer in battery workers. Several animal studies
support this data. Chronic inhalation exposure of rats to
cadmium produce lung tumors in Wi star rats, and tumors at various
sites (including mammary tumors in females) in Fischer rats.
Acute exposure to high concentrations of Cd by ingestion causes
nausea, vomiting, and abdominal pain; inhalation of fumes causes
inflammation and edema (i.e., liquid accumulation) in the lungs.
Progressive accumulation of Cd in soft tissues, particularly the
kidney, poses a serious human health risk. A higher incidence of
kidney damage reported for certain regions of Japan has been
linked to a high intake of dietary cadmium. Chronic exposure in
humans may also result in irreversible lung damage in the form of
chronic bronchitis and emphysema. The estimated safe daily oral
intake of Cd (RfD) which does not pose an appreciable risk to
human health over a lifetime is 5X10-4 mg/kg/day. -
24
AR30192.7
-------
B. RISK ASSESSMENT
EPA's sampling of Site soils found that the average concentration
of lead in surface soil samples was 6,720 milligrams per kilogram
(mgfkg). The average settled lead dust concentration found in
the brick house onsite was 9,203 mgfkg. The average lead
concentration in the overburden and bedrock aquifers, both of
which are drinking water sources was 0.00636 milligrams per liter
(mgfl). In addition, EPA has recently identified a blood lead
concentration of 10 micrograms per deciliter (~gfdl) as a level
of concern for both children and adults. Using this average and
current biological impact models, the EPA has estimated that
99.8% of the children residing onsite will have blood-lead above
10 ~g/dl, with an average level of 46.96 ~g/dl. The average
blood-lead levels of adults residing onsite and adults working
onsite are calculated to be 36.0 ~gfdl and 13.9 ~gfdl,
respectively.

The shallow aquifer appears to be contaminated by lead, nickel,
beryllium, cadmium, cobalt, copper, aluminum, manganese, zinc,
iron, sulphate and acid. While elevated lead concentrations are
found only in the area adjacent to the battery breaking building,
depressed pH and elevated metals occur in the shallow aquifer
under most of the Site. The lower pH is likely caused by direct
dumping of sulfuric acid to the ground near the battery breaking
building and possibly by the leaching of residual acid from
battery casings that were deposited throughout the site. Higher
concentrations of other dissolved metals (aluminum, iron,
manganese and zinc) in the shallow aquifer appear to be
associated with the low pH.
The bedrock aquifer near the battery breaking building is
contaminated by elevated levels of cadmium, beryllium, manganese.
nickel, lead and high levels of sulfate. The bedrock ground
water also has a pH below 5, which has caused concentrations
above background of dissolved aluminum, calcium, chromium cobalt
copper, iron, magnesium, silver, and zinc. Many of these metals
may originate from leaching soils and aquifer solids by sulfuric
acid dumped near the battery breaking building. The source of
cadmium, however, may be attributed to the batteries broken and
dumped on site.
Potential risk was quantified for resident children and adults
for ingestion and inhalation exposure to manganese, nickel,
beryllium, and cadmium by integrating quantified exposure pathway
intake values and contaminant toxicity values. Carcinogenic risk
through drinking water was calculated only for beryllium due to
unavailable toxicity values for other contaminants. The
calculated carcinogenic risks for the resident child and adult
are 6X10-6 (6 additional cancer cases per million children
exposed) and 4X10-4 (4 additional cancer cases per 10,000 adults
exposed), respectively. A Hazard Index (HI) value above 1.0
25
AR301928
-------
indicates that-the potential exists for adverse noncarcinogenic
health effects. The calculated HI for the resident child and
adult as a result of ingestion of the manganese contaminated
onsite ground water is 10, indicating a high potential for
adverse effects.
Based on the conclusions of this Risk Assessment, 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.
The cleanup levels for ground water are the lower of Maximum
Contaminant Levels (MCLs) or background water quality levels.
For this Site, background water quality becomes the cleanup level
for all contaminants except Manganese, which must be cleaned to
the Commonwealth of pennsylvania MCL of 50 ppb. Background
levels for the shallow alluvial aquifer and the bedrock aquifer
are preliminary and will be further refined during remedial
design (see Tables 1 and 2). EPA is adopting a cleanup level for
lead in soils of 1000 mg/kg. Under this cleanup level, the
future use of the site will be restricted to industrial use only.
Present EPA policy is to use a range of 500 - 1000 mg/kg in
residential areas to protect the health of young children. There
is, however, no established criterion for a soil lead level to
protect adult residents or adults who work, but do not live, on a
site contaminated with lead. Calculations by EPA have shown that
adult workers exposed to a soil lead concentration of between
682 mg/kg and 4082 mg/kg will result in a blood lead level of
10 ~g/dl. EPA has, therefore, determined that 1000 mg/kg, the
upper bound of the "residential" range, is also a reasonable
cleanup level to protect the health of adult workers.
C. 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 in solution
short distances from the site.
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 may 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.
26.
~R301929
-------
Table 1
Applicable Cleanup Levels - Shallow Alluvial Aquifer
(Based on background dissolved concentrations unless otherwise noted)
CONTAMINANT
Aluminum
Cadmium
Lead
Manganese
pH
Silver
Sulfate
. Total Dis.
Zinc
Iron
Copper
CLEANUP LEVEL
Solids
32.6 J.lg/l
ND
<3 J.lg/l
50 J.lg/l
6.5-8.5
<10 J.lg/l
54.5 mg/l
140 mg/l
<20 J.lg/l
200 J.lg/l
<25 J.lg/l
BACKGROUND
32.6 J.lg/l
ND
<3.0 J.lg/l
25-183 J.lg/l
6.6-7.3
<10.0 J.lg/l
54.5 mg/l
140.0 mg/l
<20.0 J.lg/l
200.0 J.lg/l
<25.0 J.lg/l
OBSERVED
CONCENTRATION*
4,600 J.lg/l
ND
323 J.lg/l
30,600 J.lg/l
3.9-6.3
ND
1180 mg/l
1,400 mg/l
240 J.lg/l
110,000 J.lg/l
ND
Table 2
Applicable Cleanup Levels - Bedrock Aquifer
(Based on background dissolved concentrations unless otherwise noted)
CONTAMINANT
Aluminum
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Silver
Sodium
Zinc
Sulfate
CLEANUP LEVEL
50-200 J.lg/l
0.19 J.lg/l
0.88 J.lg/l
29 mg/l
-2.3 J.lg/l
~4.1 J.lg/l
25 J.lg/l
120 J.lg/l
<3 J.lg/l
8.4 mg/l
50 J.lg/l**
-2.9 J.lg/l
1.59 mg/l
2.9 IJg/l
10.8 mq/l
76 IJg/l
27 J.lg/l
*
**
Maximum level found
Based on State MCL
BACKGROUND
-85 J.lg/l
-0.19 J.lg/l
-0.88 J.lg/l
29 mg/l
-2.3 J.lg/l
-4.1 J.lg/l
25 J.lg/l
120 J.lg/l
<3 J.lg/l
8.4 mg/l
696 J.lg/l
-2.9 J.lg/l
1. 59 mg/l
2.9 J.lg/l
10.8 mg/l
76 J.lg/l
27 J.lg/l
27
OBSERVED
CONCENTRATION*
55,400 J.lg/l
30 IJg/l
58 J.lg/l
445 mg/l
. 31,4 J.lg/l
2070 IJg/l
180 J.lg/l
76,000 J.lg/l
14.5 J.lg/l
746 mg/l
263,000 J.lg/l
1,440 IJg/l
11. 3 mg/l
55 J.lg/l
36 mg/l
3600 J.lg/l
4910 J.lg/l
~R301930
-------
1. 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 fly larva) 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. These locations
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
these locations 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."
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
contaminated plants. Many plant species absorb 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
Commonwealth 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
28
aR301931
-------
collected from the schuylkill River adjacent to and immediately
downstream of ~e site. Results indicate no significant toxic
effects from the sediments.
A. SOILS AND CASINGS
VII. SUHMARY OP REMEDIAL ALTERNATIVES
In order to select the most appropriate remedy for the Site,
various alternatives are developed so that a variety of distinct,
viable options can be analyzed. The costs for each alternative
are based on the "Restricted site use" cleanup level which is
1000 mg/kg total lead in soil. The alternatives evaluated for
the soils and battery casings include the following:
Alternative 81:
Alternative S2:
Alternative 83:
Alternative 84:
Alternative 8S:
No Action.
Onsite Stabilization/Solidification of
Soil and Casings, Offsite Disposal of
the Treated Mass at a Permitted
Landfill.
Offsite Treatment/Disposal of Soil and
Casings at a RCRA Hazardous Waste
Landfill.
Onsite Stabilization/Solidification of
Soil Only, with Offsite Disposal of the
Treated Mass at a Permitted Landfill;
Thermal Treatment/Energy Recovery/Lead
Recovery of Casings.
Offsite Thermal Treatment of Soil and
Casings.
It should be noted that all costs, timeframes and volumes
discussed below are estimates. All alternatives, except the No
Action alternative, require excavation of only those contaminated
materials (soils and casings) above the 1000 mg/kg cleanup level.
Alternatives S2, S3, S4, and S5 will, therefore, include deed
restrictions limiting the Site to industrial use only.

1. Alternative 81 - No Action. The NCP requires that the "no
action" alternative be evaluated at every site to establish a
baseline for comparison. Long-term environmental monitoring of
nearby surface water and sediments (Mill Creek and Schuylkill
River) and ambient air for heavy metals of concern would be
conducted for 30 years. Monitoring would be performed quarterly
for the first ten years, semiannually for the second ten years
and annually for the last ten years. Under this alternative,
contamination would remain onsite, and health risks to residents
and workers would be high.
29
AR301932
-------
capi~l Cost: $0
Lonq-term Monitorinq
First 10 years:
Second 10 years:
Third 10 years:
Present Worth: $296,350
Time to Implement: 30 years
(30 years)
$32,000
$16,800
$ 8,820
There are no ARARs associated with a no action alternative.
2. Alternative S2 - Onsite stabilization/solidification of 80il
and casinqs, Offsite Disposal of stabilized Mass in a Permitted
Landfill. Under this alternative, the entire volume of
contaminated materials (soils and casings) present on the Site
would be sOlidified/stabilized onsite and removed offsite to a
landfill permitted to accept this type of waste. Through the
process of sOlidification/stabilization, lead is physically
entrapped within the matrix of the solidification/stabilization
agent and its mobility is reduced. Any lead posts or plates will
be separated from the casings prior to treatment and shipped
offsite for disposal, as hazardous waste, to a RCRA permitted
facility.
Capital Cost: $28,360,000
Annual Cost: None
Present Worth: $28,360,000
Time to Implement: 18 to 24
Months
compliance with ARARs

30.
nR301933
-------
during construction activities, 40 CFR §50.6 and 40 CFR §52.21(j)
and 25 PA Code §§131.2 and 131.3.

Determinations about the effectiveness of soil remediation at the
site will be based on EPA 230/02-89-042, Methods for Evaluating
Cleanup Standards. Vol. It Soils and Solid Media.

This alternative will comply with regulations for generation of
hazardous wastes (49 CFR Parts 171 - 173 and 25 PA Code Chapter
262, Subchapters A and C).

Plans for Site restoration will comply with recommendations
outlined in the Pennsylvania Scenic Rivers Act and Schuylkill
River Scenic River Act (32 P.S. §§820.21, et sea.. and
821.31 - 38).

Onsite treatment, storage, and disposal will comply with RCRA
regulations and standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities, in accordance
with 25 PA Code Chapter 264, Subchapters A-E, Subchapter I
(containers), and Subchapter J (tanks), and 40 CFR §§264.601 -
264.603 (miscellaneous units).

This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR §268.50).

This alternative will not comply with State regulations for
closure of hazardous waste sites (25 PA Code §265.300 - 310), but
these closure regulations will be waived based on achieving an
Equivalent Standard of Performance by the removal of the
contaminated soils and remediation of the ground water to
background levels.
31
-------
3. Alternat~e 83 - Offsite Treatment/Disposal of 80il and
Casings at a RCRA Hazardous Waste Facility. This alternative
consists of the excavation of the entire volume of contaminated
so~ls and battery casings present on the site and transportation
(as a hazardous waste) to a RCRA facility for treatment and
disposal.
capital Cost: $49,000,000
Annual Costs: None
Present Worth: $49,000,000
Time to Implement: 18 to 24

Compliance with ARARs
Months
This alternative will comply with the applicable portions of the
PADER Ground Water Quality Protection strategy which prohibit
continued ground water quality degradation, as the entire waste
volume will be removed from the site. This alternative also will
comply with the requirement for treatment before disposal to meet
Land Disposal Regulations (40 CFR Part 268). Solidified wastes
are required to meet the Toxicity Characteristic Leaching
Potential (TCLP) standards for lead in leachate (5.0 mg/L) in
order to be disposed of in a properly permitted landfill.
Treatability studies indicate that solidified wastes easily pass
the Extraction Potential Toxicity test (E P Tox), which, though
not the proper procedure, produces results very similar to the
TCLP test with regard to metals. Therefore, EPA has determined
that the treated wastes will meet TCLP standards and will be able
to be disposed of in compliance with the above regulations.
Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally approved
State Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, 5552.2020 - 52.2023 and in 25 PA Code
55123.1 and 123.2, and will cause no violation of National
Ambient Air Quality standards due to fugitive dust generated
during construction activities, 40 CFR 550.6 and 40 CFR S52.21(j)
and 25 PA Code S5131.2 and 131.3.
Determinations about the effectiveness of soil remediation at the
site will be based on EPA 230/02-89-042, Methods for Evaluatina
CleanuD Standards. Vol. I: Soils and Solid Media.

Remedial action activities will comply with regulations governing
flood prevention for treatment and storage facilities located
within a 100-year floodplain (40 CFR Part 6, Appendix A,
Executive Order 11988, 25 PA Code S269.22(b) and 25 PA Code
Chapter 265.470(2».
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).
32
AR30/935
-------
Offsite and onsite treatment, storage, and disposal will comply
with RCRA requrations and standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers) and Subchapter J (tanks).
Plans for site restoration will comply with recommendations
outlined in the Pennsylvania Scenic Rivers Act and Schuylkill
River Scenic River Act (32 P.S. SS820.21, et sea., and
821.31 - 38).
The action will comply with the requirements of the National
Historic Preservation Act (Chapters 106 and 110(f) and 36 CFR
Part 800) and Archeological and Historic Preservation Act (16 USC
S469a-1) by reviewing historical records and conducting a Site
historical significance survey. If the results of these efforts
indicate the site has historic significance, additional
archaeological work will be conducted to preserve any historical
artifacts prior to commencement of the remedial action.
This alternative will comply with CERCLA S121(d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund Site waste at a facility which is not in compliance
with S3004 and S3005 of RCRA and all applicable State
requirements.
This alternative will not comply with State regulations for
closure of hazardous waste sites (25 PA Code S265.300 - 310), but
these closure regulations will be waived based on achieving an
Equivalent standard of Performance by the removal of the
contaminated soils and remediation of the ground water to
background levels.

4. Alternative S4 - onsite stabilization/Solidification of Soil
only, Offsite Disposal of Stabilized Hass in a Permitted
Landfill; Incineration of casings with Subsequent Enerqy
Recovery/Lead Recovery. Under this alternative, the same
treatment process as described in Alternative S2 would be used
for the contaminated soil; however, the casings would be
separated and transported to a secondary lead smelter. An
estimated 13,000 Btu's per pound can be recovered from the
casings, and approximately 96% of the lead remaining in the
casings can be recovered. The estimated volume of casings is
21,120 cubic yards. The smelting facility is subject to a RCRA
permit for the treatment, storage and disposal of hazardous
wastes and a Clean Air permit regulating air emissions. All
current and future land disposal requirements for disposal of
slag, baghouse dust, and air scrubber sludges apply.
capital Cost: $24,631,000
AnDual Cost: none
Present worth: $24,631,000
Time to Implement: 36 to 42
Months
33
AR301936
-------
Compliance with ARARs

This alternative will comply with the applicable portions of the
PADER Ground Water Quality Protection strategy which prohibit
continued ground water quality degradation, as the entire waste
volume will be removed from the site. This alternative also will
comply with the requirement for treatment before disposal to meet
Land Disposal Regulations (40 CFR Part 268). Solidified wastes
are required to meet the Toxicity Characteristic Leaching
Potential (TCLP) standards for lead in leachate (5.0 mg/L) in
order to be disposed of in a properly permitted landfill.
Treatability studies indicate that solidified wastes easily pass
the Extraction Potential Toxicity test (E P Tox), which, though
not the proper procedure, produces results very similar to the
. TCLP test with regard to metals. Therefore, the EPA has
determined that the treated wastes will meet TCLP standards and
will be able to be disposed of in compliance with the above
regulations. This alternative also will comply with the
preference for recycling of hazardous wastes stipulated by the
NCP. The incineration of battery casings would be performed at a
facility permitted under 25 PA Code Chapter 265, Subchapter R,
and 25 PA Code Chapter 270, in accordance with 25 PA Code Chapter
264, Subchapter 0, regarding incineration, and in accordance with
the applicable provisions of 40 CFR Part 266, subpart H,
regarding the handling and processing of hazardous wastes in
boilers and industrial furnaces. A long-term storage facility
will need to be used to contain the contaminated battery casings
pending processing. Casings will require storage for a period of
approximately 3.5 years. The storage facility must be a RCRA-
permitted treatment, storage or disposal (TSD) facility.
Fugitive dust emissions generated at the site and at the
secondary lead smelter during remedial activities will comply
with fugitive dust regulations in the Federally approved State
Implementation Plan for the Commonwealth of Pennsylvania, 40 CFR
Part 52, Subpart NN, SS52.2020 - 52.2023 and in 25 PA Code
SS123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR S50.6 and 40 CFR S52.21(j)
and 25 PA Code SS131.2 and 131.3. In addition, the secondary
lead smelting operation will comply with all applicable air
emission requirements in accordance with 25 PA Code Chapter 123
and 25 PA Code Chapter 127, Subchapters C and D. Should
modification to the secondary lead smelter become necessary to
handle incineration of the battery casings, the applicable
provisions of 25 PA Code Chapter 127, Subchapters A and a, would
also apply.
Determinations about the effectiveness of soil remediation at the
site will be based on EPA 230/02-89-042, Methods for Evaluatinq
CleanuD Standards. Vol. I: Soils and Solid Media.
34
AR30/937
-------
Remedial actio!Lactivities will comply with regulations governing
flood prevention for treatment and storage facilities located
within a 100 year floodplain (40 CFR Part 6, Appendix A,
Executive Order 11988, 25 PA Code 5269.22(b), and 25 PA Code
Chapter 265.470(2».
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).
Plans for site restoration will comply with recommendations
outlined in the Pennsylvania Scenic Rivers Act and Schuylkill
River Scenic River Act (No. 32 P.S. Chapters 820.21 and
821.31 - 38).
The action will comply with the requirements of the National
Historic Preservation Act (Chapters 106 and 110(f) and 36 CFR
Part 800) and Archeological and Historic Preservation Act (16 USC
5469a-1) by reviewing historical records and conducting a site
historical significance survey. If the results of these efforts
indicate the Site has historic significance, additional
archaeological work will be conducted to preserve any historical
artifacts prior to commencement of the remedial action.

Offsite or onsite treatment, storage, and disposal will comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers), and Subchapter J (tanks), and 40 CFR
55264.601 - 264.603 (miscellaneous units).
This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR 5268.50).

This alternative will comply with CERCLA S121{d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund Site waste at a facility not in compliance with 53004
and 53005 of RCRA and all applicable State requirements.
This alternative will not comply with State regulations for
closure of hazardous waste sites (25 PA Code S265.300 - 310), but
these closure regulations will be waived based on aChieving an
Equivalent Standard of Performance by the removal of the
contaminated soils and remediation of the ground water to
background levels.

5. Alternative S5 - Offsite Thermal Treatment of soils and
Casings/Lead Recovery. Under this alternative, which was
proposed by Exide/General Battery Corporation (Exide) during the
comment period following the publication of EPA's Proposed Plan
for this Site on January 8, 1992, Exide proposes to design and
install a fuming/gasification furnace as part of its secondary
35
A.R30J938
-------
lead smelting operations in Reading, Pennsylvania. Support
facilities (including a RCRA permitted storage facility for soil
and battery cases, material sizing equipment, and material
handling equipment) will be installed as part of this
alternative. The furnace will be tied into the existing
secondary lead smelting process at the facility as a source of
lead and energy.

During the operation of the fuming/gasification furnace,
contaminants in the soil and battery casings will be purged from
the materials as a metal fume and the battery casings gasified.
The produced gas which is generated will be ducted to the two
existing reverberatory furnaces at Exide's Reading, PA, facility
to be used as fuel. If necessary, this fuel will be supplemented
by the natural gas which is currently used. Fumed or vaporized
metal in the gas stream will be subsequently recovered in the two
existing reverberatory furnaces and existing control systems
equipment. Recovered lead will be returned to the existing
reverberatory furnaces for subsequent reclamation. Purged soil
will be generated as a solid material. .
The ash volume generated from the furnace is expected to be
approximately 10% of the original battery case feed volume plus
the total volume of the soil feed. It is anticipated that the
resulting ash will contain extremely low levels of metals.
$11,000,000
unknown
unknown
24 months for removal of waste from
Site
6 years for completion of soil
cleanup

These costs and timeframes are preliminary estimates from Exide
who has an expressed interest in developing this technology.
capital Cost:
Annual Cost:
Present worth:
Time to Implement:
Compliance with ARARs

This alternative will comply with the applicable portions of the
PADER Ground Water Quality Protection Strategy which prohibit
continued ground water quality degradation, as the entire waste
volume will be removed from the Site. This alternative also will
comply with the requirement for treatment before disposal to meet
Land Disposal Regulations (40 CFR Part 268) as the soils and
casings will be thermally treated. The treated wastes must meet
TCLP standards for lead in leachate (5.0 mg/L) in order to be
disposed of in a properly permitted landfill. The thermal
treatment would be performed at a facility permitted under 25 PA
Code Chapter 265, Subchapter R, and 25 PA Code Chapter 270, and
in accordance with the applicable provisions of 40 CFR Part 266,
36..
aR301939
-------
Subpart H, reg~ding the handling and processing of hazardous
wastes in boilers and industrial furnaces.
Fugitive dust emissions generated at the site and at Exide's
smelter during remedial activities will comply with fugitive dust
regulations in the Federally approved state Implementation Plan
for the Commonwealth of Pennsylvania, 40 CFR Part 52, Subpart NN,
SS52.2020 - 52.2023 and in 25 PA Code SS123.1 and 123.2, and will
cause no violation of National Ambient Air Quality Standards due
to fugitive dust generated during construction activities, 40 CFR
S50.6 and 40 CFR S52.21(j) and 25 PA Code SS131.2 and 131.3. In
addition, Exide's secondary lead smelting operation will comply
with all applicable air emission requirements in accordance with
25 PA Code SS123.11 - 13 (particulate matter emissions), 25 PA
Code SS123.21 - 22 (Sulfur compound emissions), 25 PA Code
S123.25 (monitoring requirements) and 25 PA Code Chapter 127,
Subchapter D (Prevention of Significant Deterioration of Air
Quality requirements related to Exide's Sulfur Dioxide
emissions). Should modification to the secondary lead smelter
become necessary to handle thermal treatment of the battery
casings, the applicable provisions of 25 PA Code Chapter 127,
Subchapters A and B, would also apply.

Determinations about the effectiveness of soil remediation at the
site will be based on EPA 230/02-89-042, Methods for Evaluating
CleanuD Standards. Vol. I: Soils and Solid Media.
Remedial action activities will comply with regulations governing
flood prevention for treatment and storage facilities located
within a 100 year floodplain (40 CFR Part 6, Appendix A,
Executive Order 11988, 25 PA Code S269.22(b), and 25 PA Code
Chapter 265.470(2».
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).
Plans for Site restoration will comply with recommendations
outlined in the Pennsylvania Scenic Rivers Act and Schuylkill
River Scenic River Act (32 P.S. SS820.21, et sea., and
821.31 - 38).
The action will comply with the requirements of the National
Historic Preservation Act (Chapters 106 and 110(f) and 36 CFR
Part 800) and Archeological and Historic Preservation Act (16 USC
S469a-1) by reviewing historical records and conducting a Site
historical significance survey. If the results of these efforts
indicate the Site has historic significance, additional
archaeological work will be conducted to preserve any historical
artifacts prior to commencement of the remedial action.
37
AR301940
-------
This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR S268.50).
Onsite and offsite treatment, storage, and disposal will comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers) and Subchapter J (tanks), and 40 CFR
S~264.601 - 264.603 (miscellaneous units).

This alternative will comply with CERCLA S121(d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund Site waste at a facility not in compliance with S3004
and S3005 of RCRA and all applicable State requirements.
This alternative will not comply with State regulations for
closure of hazardous waste sites (25 PA Code S265.300 - 310), but
these closure regulations will be waived based on aChieving an
Equivalent Standard of Performance by the removal of the
contaminated soils and remediation of the ground water to
background levels.
B.
Shallow Alluvial Aauifer
The alternatives evaluated for cleanup of the shallow alluvial
aquifer include the following:

Alternative A1 - No Action
Alternative A2 - Vertical Limestone Barrier
Alternative A3 - Soil Mixing
Alternative A4 - Subsurface Drain/Offsite Treatment
Alternative AS - Subsurface Drain/onsite Treatment and
Discharge
1. Alternative Al - No Action. This alternative 'includes
monitoring of approximately six shallow monitoring wells for
thirty years. Monitoring would be performed quarterly for the
first ten years, semiannually for the second ten years, and
annually for the last ten years. Ground water samples would be
analyzed for lead, pH, specific conductance, and sulfate. Long-
term reduction of contaminant concentration may occur over a
period of approximately 15 to 30 years through discharge into the
Schuylkill River and Mill Creek. Eventually all contaminants
would be retained by soils and to a lesser extent, discharged to
the adjacent surface water and deposited in river sediments.
38,
AR301941
-------
capital cost:
Long=term Monitoring
First 10 Years:
Second 10 Years:
Third 10 Years:
Present Worth:
Time to Implement:
$17,640
(30 yrs):
$18,208/yr
$9,560/yr
$5,020/yr
$171,000
30 years
2. Alternative A2 - Vertical Limestone Barrier. This alternative
includes the construction of two vertical limestone barriers to
neutralize the low pH and immobilize lead (see Figure 6). The
barriers, which would be connected together, would be placed
upgradient (perpendicular to Schuylkill River) and downgradient
(adjacent to the Schuylkill River and Mill Creek) of the
contamination, and consist of permeable crushed limestone placed
in a three-foot trench from grade to bedrock. Contaminated water
passing through these barriers would rise in pH to about 8,
effectively immobilizing the dissolved metals. Together, both
barriers would neutralize acidic soils and water and effectively
immobilize the dissolved metal contamination on the Site.
Sulfate contamination would also be reduced by this
alternative. In addition, two ground water recharge ponds would be
constructed and maintained. One would be upgradient of the
contamination and the other would be located between the vertical
limestone barriers. These ponds would recharge the shallow
alluvial aquifer, increasing the velocity of the contaminated
ground water through the vertical limestone barrier. Water in
the pond can be maintained at a constant head by pumping either
from the Schuylkill River or the discharge from the bedrock
aquifer treatment system. Because this is a passive treatment
system it is estimated that long-term monitoring will be required
for a period of at least 6 years to assure the ground water is
effectively treated.
Capital Cost:
Annual Cost (6 yrs):
Present Worth:
Tim. to Implement:

Compliance with ARARs
$612,500
$18,208/yr
$704,000
3 to 6 years
Contamination in the ground water will be reduced to background
levels as required by 25 PA Code 55264.90 - 264.100, specifically
25 PA Code SS264.97(i) and 264.100(a) (9).
Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
State Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, 5552.2020 - 52.2023 and in 25 PA Code
55123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR 550.6 and 40 CFR 552.21(j)
39
~R30/942
-------
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-------
and 25 PA Code-sS131.2 and 131.3.This alternative will comply
with 25 PA Code Chapter 264, Subchapter F, regarding ground water
monitoring.
This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6) (f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, Section 2.20.4).

3. Alternative A3 - soil Hixinq. This alternative involves in-
situ chemical stabilization of lead and neutralization of pH by
mixing the contaminated soils and subsurface materials with lime
from ground surface to bedrock above and below the ground water
table. The system utilizes a crane mounted mixing head with
large, approximately 8 foot diameter, augers. This alternative
immobilizes the lead and increases the pH immediately which
eliminates the need for long-term monitoring. This is a proven
technology with readily available materials and equipment. See
Figure 7 for the area estimates for soil mixing.
10) and
capacity,
the
capital Cost:
Lonq-term Honitorinq
(one sampling event in
Present Worth:
Time to Implement:
5 years):
$8,667,600

$4,448
$8,690,000
0.5.to 1 year
compliance with ARARs

Contamination in the ground water will be reduced to background
levels as required by 25 PA Code S5264.90 - 264.100, specifically
25 PA Code 5S264.97(i) and 264.100(a) (9).
Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
State Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, S552.2020 - 52.2023 and in 25 PA Code
55123.1 and 123.2, and will cause no violation of National
Ambient Air Quality standards due to fugitive dust generated
during construction activities, 40 CFR S50.6 and 40 CFR S52.21(j)
and 25 PA Code SS131.2 and 131.3.
This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding ground water monitoring.

This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
41
~R301944
-------
SOIL MIXING AREA
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-tHCE AND ICCHNOLOCr CORP.
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-------
construction of water extraction wells (No. (6)(f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes(No.
9; Water Code "of the Basin, Section 2.50.2), non-interference
with domestic or other existing wells (No. 10) and non-impact on
ground water levels, ground water storage capacity, or low flows
of perennial streams (No. 4; Water Code of the Basin, Section
2.20.4).4.

Alternative A4 - Subsurface Drain/Offsite Treatment. Under this
alternative, ground water would be collected by subsurface drains
installed 12 to 15 feet below the surface through the entire
length of the lead and pH contamination. A drain and trench
system would extend 900 feet (see Figure 8). Water would be
pumped from the drain into a holding tank and then transported
offsite to a Public Owned Treatment Works (POTW). This
alternative would remediate the contaminated ground water at the
Site; however, the estimated time to implement this alternative
is 2 to 8 years.

Capital Cost: $339,000
Annual Cost: $362,400/yr
Present Worth (8 year duration): $2,547,000
Time to implement: 2 to 8 years

Compliance with ARARs

Contamination in the ground water will be reduced to background
levels as required by 25 PA Code §§264.90 - 264.100, specifically
25 PA Code §§264.97(i) and 264.100(a)(9).

Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
State Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, §§52.2020 - 52.2023 and in 25 PA Code
§§123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR §50.6 and 40 CFR §52.21(j)
and 25 PA Code §§131.2 and 131.3.

This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).

Onsite and offsite treatment, storage, and disposal will comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers), and Subchapter J (tanks), and 40 CFR
§§264.601 - 264.603 (miscellaneous units).

This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding ground water monitoring.

43
-------
This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6) (f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells {No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, Section 2.20.4)

This alternative will comply with waste water pretreatment
regulations (40 CFR Part 403).
10) and
capacity,
the
This alternative will comply with CERCLA S121{d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund site waste at a facility not in compliance with S3004
and S3005 of RCRA and all applicable State requirements.

This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR S268.50).
5. Alternative AS - Subsurface Drain/onsite Treatment. Under
this alternative, ground water would be collected by subsurface
drains as described in Alternative 4. The water would then be
pumped to a wastewater treatment system constructed onsite for
treatment of bedrock ground water (see Figure 8). The effluent
from the treatment system would be discharged to the Schuylkill
River. The sludge would be hauled to a POTW and meet
pretreatment standards of the specific POTW selected. This
alternative is contingent on the implementation of a bedrock
aquifer treatment system. If a treatment system is not built for
the bedrock aquifer, then a treatment plant would be needed under
this alternative. Listed below are two costs; the first cost
assumes a bedrock aquifer treatment system exists, and the second
cost assumes a wastewater treatment plant (WWTP) must be funded
under this alternative.
WWTP
Exists
Capital Cost: $339,000
ADDual Cost: $57,900/yr
Present Worth (8 year duration):
Time to Implement: 2 to 8 years
$647,900
WWTP
Needed
capital Cost: $413,600
Annual Cost: $227,500/yr
Present Worth (8 year duration):
Time to Implement: 2 to 8 years
$1,655,000
44
aR301947
-------
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compliance with ARARs
contamination in the ground water will be reduced to background
levels as required by 25 PA Code SS264.90 - 264.100, specifically
25 PA Code SS264.97{i) and 264.100{a) (9).
Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
state Implementation Plan for the Commonwealth of Pennsylvania,40
CFR Part 52, Subpart NN, SS52.2020 - 52.2023 and in 25 PA Code
SS123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR S50.6 and 40 CFR S52.21(j)
and 25 PA Code SS131.2 and 131.3.
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).
Onsite and offsite treatment, storage, and disposal will comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers), and Subchapter J (tanks), and 40 CFR
SS264.601 - 264.603 (miscellaneous units).
This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding ground water monitoring.

This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area o Regulations regarding
construction of water extraction wells (No. (6) (fO); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, Section 2.20.4)
10) and
capacity,
the
This alternative will comply with waste water pretreatment
regulations (40 CFR Part 403).

This alternative will comply with CERCLA S121(d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund site waste at a facility not in compliance with S3004
and S3005 of RCRA and all applicable state requirements.
Any surface water discharge will comply with substantive
requirements of the Clean Water Act NPDES discharge regulations
(40 CFR SS122.41 - 122.50), the Pennsylvania NPDES regulations
(25 PA Code S92.31), the Pennsylvania Wastewater Treatment
Regulations (25 PA Code SS95.1 - 95.3), and the Pennsylvania
Water Quality standards (25 PA Code SS93.1 - 93.9).

46
AR30f949
-------
This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR S26S.S0).
C. Bedrock Aauifer
The depth of contamination in the bedrock aquifer is currently
unknown. It has been found at depths of 40 feet and assumed to
be no deeper than 100 feet. The alternatives evaluated for
cleanup of the bedrock aquifer are listed as follows:

Alternative B1 - No Action with Long-term Monitoring
Alternative B2 - Pump and Offsite Treatment
Alternative B3 - Pump and Onsite Treatment and Disposal
Alternative B1 - No Action. This alternative involves long-term
sampling and analysis from six bedrock wells to monitor the fate
and transport of the contamination for 30 years. Bedrock water
samples will be collected semiannually for sulfate, beryllium,
cadmium, calcium, manganese, magnesium, zinc, lead and pH.
capital Cost:
Annual Cost:
Present Worth
Time to Implement:
$71,300
$9,400/yr
(30 year duration):
30 years
$171,000
There are no ARARs for a no action alternative.
Alternative B2 - Pump and Offsite Treatment. Under this
alternative the bedrock ground water would be pumped and
transported to a POTW. Ten to twenty wells would be installed
upgradient, downgradient and within the area of bedrock
contamination to trace the extent and direction of contaminant
movement. These wells will be converted to pumping wells for the
remedial action. The estimated yield with this well system is
10,000 gallons per day for a well system 40 feet deep. A 25,000
gallon storage tank would be erected onsite for storage of pumped
groundwater. This alternative is sensitive to local POTW
availability and capacity, and sensitive to the depth of
contamination which is currently unknown. Listed below are costs
for 40-foot wells and for 100-foot wells. A contingency factor
of 40% has been added in each alternative because information on
the bedrock aquifer is limited.
20 Wells
- 40 Foot Depth
capital Cost: $994,147
ADDual Cost: $4,700/yr
Present Worth: $1,019,000
Time to Implement: 1 year
47 .
AR301950
-------
20 Wells
- 100 Foot Depth
Cap~al Cost: $4,187,260
Annual Cost: $4,700/yr
Present Worth: $4,212,000
Time to Implement: 1 year

Compliance with ARARs
Contamination in the ground water will be reduced to background
levels as required by 25 PA Code SS264.90 - 264.100, specifically
25 PA Code SS264.97(i) and 264.100(a)(9). The exception to this
is manganese, which will be reduced to the level specified by the
Commonwealth of Pennsylvania's MCL, 25 PA Code S109.202, which is
lower than the calculated background concentration.

Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
state Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, SS52.2020 - 52.2023 and in 25 PA Code
SS123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR S50.6 and 40 CFR S52.21(j)
and 25 PA Code SS131.2 and 131.3.
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).

This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding ground water monitoring.
Onsite activities will comply with RCRA regulations and standards
for owners and operators of hazardous waste treatment, storage,
and disposal facilities, in accordance with 25 PA Code Chapter
264, Subchapters A-E, Subchapter I (containers) and Subchapter J
(tanks), and 40 CFR SS264.601 - 264.603 (miscellaneous units).
This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6)(f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, Section 2,20.4).

This alternative will comply with waste water pretreatment
regulations (40 CFR Part 403).
10) and
capacity,
the
This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR S268.50).
4&
AR301951
-------
This alternati~ will comply with CERCLA S121(d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund Site waste at a facility not in compliance with S3004
and S3005 of RCRA and all applicable State requirements.

3. Alternative B3 - Pump, Onsite Treatment and Disposal. In this
alternative, a treatment facility will be constructed onsite and
connected to the recovery well system described in Alternative
B2. The ground water will be treated by precipitation and ion
exchange for pH, cadmium, sulfate, iron, manganese, calcium and
other metals and dissolved solids. The effluent would be used to
recharge the shallow alluvial aquifer as described in Alternative
A2, or discharged to the Schuylkill River or a combination of
both. The effluent quality is expected to meet ambient water
quality criteria for discharge to the Schuylkill River or
recharge ponds. Sludge will be removed by tank truck and
transported to a POTW. Because of the uncertainties associated
with the bedrock flow and contaminant characteristics, a 40%
contingency factor has been added to the final cost. As in
Alternative B2, costs are given for a 40-foot well system and for
a 100-foot system because the depth of contamination is presently
unknown.
20 Wells -
40 Foot Depth
capital Cost: $303,250
Annual Cost: $4,700
Present Worth (6 year duration): $328,000
Time to Implement: 1 year
20 Wells
- 100 Foot Depth
capital cost: $586,800
Annual Cost: $4,700
Present Worth (6 year duration): $612,000
Time to Implement: 1 year

compliance with ARARs
contamination in the ground water will be reduced to background
levels as required by 25 PA Code SS264.90 - 264.100, specifically
25 PA Code 5S264.97(i) and 264.100(a)(9). The exception to this
is manganese, which will be reduced to the level specified by the
State MCL, 2S PA Code 5109.202, which is lower than the
calculated background concentration.

Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
state Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, SSS2.2020 - 52.2023 and in 25 PA Code
SS123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
49
AR30J952
-------
during construction activities, 40 CFR S50.6 and 40 CFR S52.21{j)
and 25 PA Code-sS131.2 and 131.3.
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).

Onsite treatment will comply with RCRA regulations and standards
for owners and operators of hazardous waste treatment, storage,
and disposal facilities, in accordance with 25 PA Code Chapter
264, Subchapters A-E, Subchapter I (containers), and Subchapter J
(tanks), and 40 CFR SS264.601 - 264.603 (miscellaneous units).
This alternative will comply with 25 PA Code Chapter 264,
. Subchapter F, regarding ground water monitoring.
This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6) (f); Water Code of
the Basin, section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, section 2.20.4)
10) and
capacity,
the
This alternative will comply with waste water pretreatment
regulations (40 CFR Part 403).
This Alternative will comply with the requirements for storage of
wastes restricted from land disposal (40 CFR S268.50). This
alternative will comply with CERCLA S121(d) (3) and with EPA OSWER
Directive #9834.11, both of which prohibit the disposal of
Superfund site waste at a facility not in compliance with S3004
and S3005 of RCRA and all applicable State requirements.

Any surface water discharge will comply with the substantive
requirements of the Clean Water Act NPDES discharge regulations
(40 CFR SS122.41-122.50) , the Pennsylvania NPDES regulations (25
PA Code S92.31), the Pennsylvania Wastewater Treatment
Regulations (25 PA Code SS95.1 - 95.3), and the Pennsylvania
Water Quality standards (25 PA Code SS93.1 - 93.9).
VXXI. COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Overall Protection of Human Health and the Environment.
1. Soils
Alternatives S2, S3, S4 and S5 all provide adequate protection of
human health and the environment since the lead-contaminated
materials are processed, either onsite or offsite, and securely
50
AR301953
-------
landfilled or treated, thereby eliminating all exposure pathways.
The no action alternative (Alternative Sl) provides no additional
protection of human health and the environment since no
mitigation of the current soil exposures is effected.
2. Shallow Ground Water
Alternatives A2, A3, A4 and AS provide adequate protection of
human health. Alternatives A2, A4, and AS provide for protection
of human health and the environment by immobilizing or removing
the contaminants over time. Alternative A3 immediately protects
human health and the environment by immobilizing the contaminants
in the soil matrix. Alternative A1 fails to provide adequate
protection of human health or the environment.
3. Bedrock Ground Water
Alternatives B2 and B3 provide adequate protection of human
health and the environment because both alternatives completely
remove the contamination from the bedrock aquifer. Alternative
B1 fails to provide adequate protection of human health or the
environment.
B. Compliance with ARARs.
1. Soils
Alternatives S2, S3, S4, and S5 will eliminate- continued ground
water quality degradation because the entire waste volume will be
removed from the site (PADER Ground water Quality'Protection
strategy). Alternative Sl is not in compliance with this waste
disposal requirement. Ground water degradation would continue to
occur if Alternative Sl were implemented.

Alternatives S2, S3, S4 and S5 are also in compliance with the
regulatory requirement for treatment before disposal to meet LDRs
(40 CFR Part 268) and with requirements for storage of waste
restricted from Land Disposal (40 CFR S268.50). Solidified
wastes in Alternatives S2, S3, and S4 as well as the ash in
Alternatives S4 and S5 are required to meet TCLP standards for
lead in leachate (5.0 mg/L) in order to be classified as non-
hazardous and allow disposal in a pennsylvania landfill that is
permitted to accept residual (non-hazardous industrial) wastes.
RCRA landfills also require compliance with leachate testing.
Therefore, the hazardous wastes sent to the RCRA facility
according to Alternative S3 will be treated to achieve the 5 mg/L
TCLP standard for lead as determined through TCLP testing.
Treatability studies indicate that solidified wastes easily pass
the EP Tox test, which is very similar to the TCLP test with
regard to metals. Therefore, EPA has determined that the
stabilized/solidified wastes will meet TCLP standards. The soil
remediation in Alternatives S2, S3, S4, and S5 can be evaluated
51-
AR301954
-------
in accordance~ith EPA 230/02-89-042, Methods for Evaluating
CleanuD Standards. Vol. I: Soils and Solid Media. Alternative
S1 does not provide any treatment of the hazardous materials
present on the 5ite to mitigate contaminant migration.
All requirements for smelting and thermal treatment in
Alternatives S4 and 55 will be met in accordance with applicable
RCRA permits and requirements (40 CFR Part 266, 5ubpart H, 25 PA
Code Chapter 265, Subchapter R, 25 PA Code Chapter 270). In
addition, incineration in Alternative 54 will meet the
requirements of 25 PA Code Chapter 264, Subchapter O.

Alternatives S2, 53, S4 and S5 comply with ARARs related to site
fugitive dust controls during excavation and treatment and, for
Alternatives S4 and S5, air emissions controls for incineration
and thermal treatment equipment. (25 PA Code Chapters 121 - 142)
that govern air emissions from remedial actions). These
alternatives also comply with regulations governing flood
prevention for treatment and storage facilities located within a
100 year floodplain (40 CFR Part 6, Appendix A, Executive Order
11988, 25 PA Code S269.22(b), and 25 PA Code Chapter 265.470(2»
through flood control measures and environmental monitoring. In
Alternative 51, no wastes are excavated and no extensive airborne
releases were predicted by the ISC model.
Alternatives 52, 53, S4, and S5 must comply with hazardous waste
generation ARARs, and Alternatives S3, S4, and S5 must comply
with transportation ARARs (i.e., metallic posts and plates,
untreated wastes) according to 49 CFR Parts 171 - 173 and 25 PA
Code Chapter 262, Subchapters A and C, and Chapte~ 263.

Alternatives 53, S4, and S5 that employ onsite and offsite .
treatment, storage, and disposal of wastes will comply with RCRA
regulations and standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities, in accordance
with 25 PA Code Chapter 264, 5ubchapters A-E, Subchapter I
(containers), and Subchapter J (tanks), and 40 CFR SS264.601 -
264.603 (miscellaneous units). Alternative 52 will comply with
onsite treatment and storage requirements.
Plans for Site restoration for all four alternatives that include
excavation will comply with recommendations outlined in the
Pennsylvania 5cenic Rivers Act and 5chuylkill River 5cenic River
Act (No. 32 P.S. SS820.21, et sea., and 821.31 - 38).

Alternatives 53 and 54 will comply with CERCLA S121(d) (3) and
with EPA 05WER Directive #9834.11, both of which prohibit the
disposal of 5uperfund site waste at a facility not in compliance
with S3004 and S3005 of RCRA and all applicable State
requirements.
52
AR30/955
-------
Alternatives SJL, S3, S4 and S5 will not comply with State ARARs
for closure of hazardous waste sites, but will achieve an
Equivalent Standard of Performance by removing the contaminated
soils and remediating the ground water to background levels.

2. Shallow Ground Water

Alternative Al does not comply with State or Federal MCLs or
Pennsylvania regulations requiring cleanup to background levels.
Alternatives A2, A4, and A5 do not immediately comply with the
ARARs but require a number of years to achieve compliance.
Alternative A3 would immediately comply with the ARARs for acid
and dissolved metals.

In addition, Alternatives A4 and A5 would require storage and
treatment facilities to be constructed within earthen berms or
dikes to comply with the location specific floodplain ARAR.
Alternative A5 would have to comply with the substantive
requirements of an NDPES permit for surface water discharges, and
Alternatives A4 and AS would have to comply with land disposal
restrictions and wastewater pretreatment requirements for wastes
shipped to a POTW.

Alternatives A4 and AS, which include onsite and offsite
treatment, storage, and disposal of wastes, will comply with RCRA
regulations and standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities, in accordance
with 25 PA Code Chapter 264, Subchapters A-E, Subchapter I
(containers) and Subchapter J (tanks), and 40 CFR §§264.601 -
264.603 (miscellaneous units).

Alternative A4 and AS will comply with regulations for generation
and transportation of hazardous wastes (49 CFR Parts 171 - 173
and 25 PA Code Chapter 262, Subchapters A and C, and Chapter
263) .

Alternatives A4 and AS will comply with CERCLA §121(d)(3) and
with EPA OSWER Directive #9834.11, both of which prohibit the
disposal of Superfund Site waste at a facility not in compliance
with §3004 and §3005 of RCRA and all applicable State
requirements.

Alternatives A2, A3, A4 and AS will comply with Pennsylvania Air
Pollution Control Regulations (25 PA Code Chapters 121 - 142)
that govern fugitive dust emissions during remedial actions.

Alternatives A2, A3, A4 and A5 will comply with the Delaware
River Basin Commission Ground Water Protected Area Regulations
regarding construction of water extraction wells (No. (6)(f);
Water Code of the Basin, Section 2.50.2), metering of surface
water intakes (Mo. 9; Water Code of the Basin, Section 2.50.2),
non-interference with domestic or other existing wells (No. 10)

5R30I956
-------
and non-impact-on ground water levels, ground water storage
capacity, or low flows of perennial streams (No.4; Water Code of
the Basin, Section 2.20.4).

Alternatives A2, A3, A4, and A5 will comply with ground water
monitoring requirements (25 PA Code Chapter 264, Subchapter F).
3. Bedrock Ground Water
Alternative Al does not comply with State or Federal MCLs or
Pennsylvania regulations requiring cleanup to background levels.
Alternatives B2 and B3 would not immediately comply with the
ARARs but require approximately a year to achieve compliance.
Alternatives B2 and B3 comply with the chemical specific ARARs.
Alternative B2 will comply with the Clean Water Act as there will
be no discharge to the Schuylkill River, while Alternative B3
must comply with substantive NPDES requirements for discharges to
the Schuylkill River. Alternatives B2 and B3 would have to
comply with land disposal restrictions and wastewater
pretreatment requirements for wastes shipped to a POTW.

Alternatives B2 and B3, which include onsite and offsite
treatment, storage, and disposal of wastes, will comply with RCRA
regulations and standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities, in accordance
with 25 PA Code Chapter 264, Subchapters A-E, Subchapter I
(containers) and Subchapter J (tanks), and 40 CFR SS264.601 -
264.603 (miscellaneous units).
Alternatives B2 and B3 will comply with Pennsylvania Air
Pollution Control Regulations (25 PA Code Chapters 121 - 142)
that govern fugitive dust emissions during remedial actions.
Alternatives B2 and B3 will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6)(f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, Section 2.20.4).

Alternatives B2 and B3 will comply with regulations for
generation and transportation of hazardous wastes (49 CFR Parts
171 - 173 and 25 PA Code Chapter 262, Subchapters A and C, and
Chapter 263).
10) and
capacity,
the
Alternatives B2 and B3 will comply with CERCLA S121(d) (3) and
with EPA OSWER Directive #9834.11, both of which prohibit the
disposal of Superfund site waste at a facility not in compliance
54
AR301957
-------
with S3004 and-S3005 of RCRA and all applicable state
requirements.

Alternatives B2 and B3 will comply with ground water monitoring
requirements (25 PA Code Chapter 264, Subchapter F).
c. Long-term Effectiveness and Permanence.
1. Soils
Each of the alternatives, with the exception of Alternative Sl,
would meet the criteria of long-term effectiveness and
permanence. Alternatives S2, S3, S4, and S5 result in the lead
contaminated soil and battery casings being removed from the site
resulting in a greatly reduced threat to the environment and an
acceptable level of residual site risks for onsite workers, but
not residents. Since residential use will no longer be
permitted, Alternatives S2, S3, S4 and S5 are all judged to be
effective in the long-term.

Information collected through the stabilization/solidification
treatability studies that were conducted for the RI/FS indicates
the technology can permanently immobilize wastes. However, there
are additional process and performance specifications that are
not addressed in bench-scale studies. For example, the
effectiveness of soil and casing separation needs to be
determined for a large-scale operation as the separation in the
treatability study was accomplished by hand sorting. In
addition, Alternative S2 requires removal of the lead alloy from
the battery casings prior to stabilization/solidification. The
efficiency of this lead separation also needs to be determined.
Alternative S5, which specifies thermal treatment, is judged to
be more permanent than Alternatives S2, S3, or S4 as the
contamination would be removed from the soils and the casings
incinerated.
2. Shallow Ground Water
Alternatives A2, A3, A4, and AS would result in minimal residual
risk after the achievement of remedial objectives and are,
therefore, judged to be effective in the long-term. Alternative
A1 does not utilize remedial technologies and, therefore, has no
long-term effectiveness other than that obtained by access
restrictions. Alternatives A2, A3, A4, and A5 would all
permanently remove the contamination from the shallow ground
water.
3. Bedrock Ground Water
Alternatives B2 and B3 would both meet the criteria of long-term
effectiveness and permanence since in both alternatives the
contamination will be removed from the aquifer. Alternative B1
55
~R301958
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has limited long-term effectiveness because the plume is not
expected to attenuate rapidly.

D. Reduction of Toxicity, Mobility or Volume Through Treatment.
1. Soils
The principal risk of exposure to lead contaminated soils
addressed by each of the alternatives, with the exception of
Alternative S1, is addressed in this analysis. stabi1ization/
solidification fixes the waste in a solid matrix thereby greatly
reducing leachability. The resulting reduction in mobility of
lead contamination for Alternative S2, Alternative S3 and the
. soil portion of Alternative S4 is judged to be nearly 100
percent. In Alternative 55, the toxicity and mobility of the
contaminants are greatly reduced as the lead is removed from the
soil matrix and reused in the smelting process.
The resme1ting of metallic lead posts and plates in Alternative
52 and Alternative 54 and the processing of the battery casings
for energy recovery in Alternative 54 result in a reduction of
the total volume of contaminated wastes. The volume reduction of
Alternative 54 is estimated at 25%. This reduction includes the
14% increase expected as a result of the onsite stabi1ization/
solidification of site soils. The reduction in volume of
contaminated wastes resulting from recycling metal plates and
posts in Alternative S2 is unknown because the volume of metallic
plates and posts present in the containment area is not known.
The reduction in volume of contaminated wastes resulting from
Alternative S5 should be greater than that of Alternative 54 as
there will be no stabi1ization/ solidification taking place.

. For Alternative S2 there will be an increase in the volume of the
contaminated waste due to the addition of a stabi1ization/
solidification agent. Treatment residuals result from each of
the alternatives, except Alternative 51. These residuals consist
of any contaminated debris that cannot be crushed or
decontaminated for Alternative S2 and Alternative S4 and the
scrubber sludge, baghouse dust and slag generated as a result of
burning casings in Alternative S4 and the thermal treatment in
Alternative S5. Since the baghouse dust and scrubber sludges are
resme1ted at the Reading facility, the risks from these residuals
are judged to be equally low. Each of the treatment processes is
irreversible since the lead is either bonded within a matrix or
recycled.
Alternative S1, no action, does nothing to reduce the toxicity,
mobility or volume of the lead-contaminated materials at the
Brown's Battery Site.
56.
~R301959
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2. Shallow Gro\lnd Water
Alternatives A2, A3, A4, and A5 remove or precipitate the
contaminant out of the ground water thereby reducing the
toxicity, mobility, and volume of the contaminant in groundwater.
Alternative A1 will have a minimal impact on this criteria
because it relies solely on natural attenuation.
3. Bedrock Ground Water
Alternatives B2 and B3 remove the contamination from the aquifer
down to background levels thereby greatly reducing the toxicity,
mobility and volume of the contaminants in the ground water.
Alternative B1 will have a minimal impact on the toxicity,
mobility and volume of the contamination because natural
attenuation occurs slowly.
E. Short-term Effectiveness.
1. Soils
Short-term effectiveness considerations for the four alternatives
including excavation of hazardous wastes are similar. Dust
inhalation and release of lead-contaminated materials are judged
to be the potentially serious risks from these alternatives.
Wetting of the soil during processing or excavation should
alleviate problems from dust inhalation by workers or release to
the environment. Worker safety can also be addressed by the use
of respiratory protection. Untreated soils and battery casings
will be transported for Alternatives S3 and S5 and untreated
casings will be transported in Alternative S4. These materials
will be transported in trucks which are lined and covered and the
wastes will be manifested according to Pennsylvania hazardous
waste regulations and federal Department of Transportation
requirements.
All alternatives, except Alternative Sl, involve excavation of
large portions of the Site, as well as temporary stockpiling of
wastes onsite. Potential threats to the environment resulting
from these actions include erosion of lead-contaminated soils and
transport to Mill Creek and the Schuylkill River. In addition,
since the Site is located on the floodplain of the schuylkill
River, flooding could cause a large-scale release of
contaminants. These hazards are judged to be roughly the same
for all alternatives except Alternative Sl. Hazards can be
mitigated through proper engineering controls.

If implemented, Alternative S2 and Alternative S4 would require
the construction of processing areas on the Brown's Battery site.
Temporary environmental impacts would consist of the construction
of concrete pads for processing areas, decontamination stations,
and the installation of electrical utilities for the processing
57.
AR301960
-------
equipment. These structures should be easily removed at the end
of the remedial actions. All of the onsite activities can be
completed wit~ 1 to 2 years of start-up, a relatively short
period of time, which is a common advantage of each of the
alternatives. Alternatives S4 and S5 also require the long-term
storage of contaminated battery casings, however, this will be
conducted offsite.
Alternative Sl, the no action alternative, has no short-term
effectiveness as the site will remain contaminated and therefore
continue to pose a risk to the public and to the environment.
2. Shallow Ground Water
Alternative A3 poses the greatest risk to workers from machinery
and dust. Alternative A2, A4, and AS pose equal risk to workers
from machinery but less of a risk than Alternative A3.
Alternative A1 would have the least risk involved for workers.
All the Alternatives would pose limited risk to the community
although more vehicular traffic would be expected for Alternative
A4 because of daily offsite wastewater disposal.

Alternative A3 would achieve remedial action objectives
immediately after completion of construction. Alternative A2,
A4, and AS would require a number of years to achieve remedial
action objectives. It cannot be determined if Alternative A1
would ever achieve remedial action objectives.
The optimum time to implement Alternatives A2, A3, A4 or AS is
during soil remediation. These ground water alternatives should
be installed after the contaminated soil is scraped off the upper
few feet, but before clean backfill is compacted in place. This
will minimize cost and avoid disturbance of the clean backfill
once it is in place. With the exception of Alternative A1, each
of the Alternatives involves excavation from grade to bedrock.
As grade is lowered, the excavation is reduced. Moreover, there
would be no concern for management and disposal of hazardous
waste soils as these soils would be removed by the soil
remediation. Alternatives A2 and A3 are earthwork intensive in
situ technologies which are more conducive to being constructed
during soil remediation than Alternatives A4 and AS.
Alternatives A4 and AS are less earthwork intensive and could
occur after soil remediation with less impact on cost.
3. Bedrock Ground Water
Risks to the community and workers onsite are minimal for all
three alternatives, although Alternatives B2 and B3 will have
increased safety risks during construction related to drilling
more wells and erecting equipment onsite. The duration of
treatment and monitoring are the same for both Alternatives B2
58
AR301961
-------
and B3, approximately one year for pumping, and 5 years for
monitoring.
In Alternative 1, natural attenuation will be very slow and the
fate of pollutants is unknown. Therefore, the aquifer will remain
contaminated for an indefinite period of time.
F. Implementability
1. Soils
Implementability considerations for waste excavation and
transportation varies only slightly among Alternatives S2, S3,
S4, and S5. The required metal separation for Alternatives S2
and S4 and the soil and casing separation required for
Alternative S4 pose minor additional implementability
considerations. All Alternatives except Alternative Sl require
hazardous waste transportation permits from the Commonwealth of
Pennsylvania, the u.S. Department of Transportation and other
states through which the waste may have to pass on its way to
disposal. These permits should be readily obtainable. Several
licensed hazardous waste transporters are available to transport
the volume of wastes generated from these Alternatives.
Availability of services is currently good for conducting
Alternatives S2 and S3 and potentially poor for conducting
Alternatives S4 and S5. The implementability of Alternative S4
is dependent upon the availability of one vendor to perform the
resource recovery and waste recycling. Battery casings are
currently being burned at this facility, but at low feed rates
(-5 percent). In addition, there is significant question
regarding the availability of storage capacity at this facility
for the additional volume of battery casings expected from this
Site.
The implementabilty of soil Alternative S5 is dependant upon
several factors, both technical and administrative. The
alternative combines two technologies which have been proven
technically feasible in other industrial applications, but have
never been used together in these circumstances. Pilot studies
will be needed to demonstrate that these technologies can work
together in this innovative fashion to clean the soils and gasify
the battery casings while not interfering with the secondary
smelting operations. Implementation of this alternative will
require obtaining a RCRA permit as well as State and local
permits for the long-term waste storage facility as well Federal,
State and local permits for the new furnace. If these, or any
other necessary permits cannot be obtained, or if the facility is
in violation of RCRA regulations, this alternative cannot be
implemented.
59
~R301962
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Alternative 51 can be readily implemented since environmental
monitoring can be subcontracted from a large pool of available
contractors.
2. Shallow Ground Water
Alternative A1 is the easiest to implement of all the
alternatives. Little equipment and maintenance are required.
Alternative A2 is more easily implemented than Alternatives A3,
A4, or AS and requires no maintenance. Alternative A3 requires a
large mechanized operation to achieve its objectives, but would
not require operation and maintenance. Alternatives A4 and AS
would both require the operation and maintenance of systems for
several years. Alternative A4 requires a POTW for treatment and
disposal of the extracted ground water. POTWs are available but
have, in the past, refused to accept wastewaters from CERCLA
sites. All of these alternatives are relatively easy to
implement.
3. Bedrock Ground Water
Alternative B1 is more easily constructed than both Alternatives
B2 and B3, because fewer wells will be installed and less
equipment erected. Alternative B2 is more easily constructed
than Alternative B3 because less equipment is needed and
operation and maintenance is less intensive.
Alternatives B2 and B3 have equally reliable technologies, and
additional treatment would be relatively easy because the wells
will be in place. Both alternatives have available offsite POTWs
for disposal and treatment of residual waste. However,
Alternative B2 relies solely on offsite POTWs for'disposal, while
Alternative B3 treats the ground water onsite and relies on
offsite POTWs for disposal of residual waste only. Because the
total volume to be treated is indefinite at this time,
Alternative B3 is favored over Alternative B2 because available
POTW capacity is finite. Technology considerations are not
applicable to Alternative B1.

G. Cost
The estimated present worth costs are as follows:
1. Soils
Alternative 1 - $296,000
Alternative 2 - $28,360,000
Alternative 3 - $49,000,000
Alternative 4 - $24,631,000
Alternative 5 - $11,000,000*
60
aR301963
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2. Shallow Ground Water
Alternative 1
Alternative 2 -
Alternative 3
Alternative 4
Alternative 5
$171,000
$704,000
$8,690,000
$2,547,000
$1,655,000
3. Bedrock Ground water
Alternative 1
Alternative 2
Alternative 3
$171,000
$1,019,000 (40 feet)
$328,000
$4,212,000 (100 feet)
$612,000
. * Exide/GBC cost estimate - not verified by EPA
community Acceptance
The January 8, 1992, Proposed Plan and January 21, 1992, public
meeting produced a small number of comments from the general
public and a large volume of comments from Exide/GBC, the
principal PRP, and its employees. Responses to these comments
appear in the Responsiveness Summary section of this report.

The April 15, 1992, Revised Proposed Plan, which announced an
opportunity for a public meeting, produced neither a request from
the public for such a meeting, nor any comments on the Proposed
Plan from the general public or the PRPs.
state Acceptance
The Commonwealth of pennsylvania has not concurred on this ROD.
IX. SELECTED REMEDY
A. After careful consideration of the proposed remedial
alternatives and evaluation against the nine criteria listed
above, EPA has chosen a combination of alternatives as the
Selected Remedy.

In the judgement of EPA, the following alternatives represent the
best balance among the evaluation criteria and satisfy the
statutory requirements of protectiveness, compliance with ARARs,
cost effectiveness, and utilization of permanent solutions to the
maximum extent practicable:
61
'.
AR301964
-------
1.
Soils and Casinas
The selected alternative for soil remediation at the Brown's
Battery Site is-Alternative S5, Offsite Thermal Treatment of
Soils and Casings. Specifically, EPA has determined that
Alternative S5:
.
Provides for maximum reduction in waste volume via
thermal treatment of the casings, as opposed to
Alternatives S2, S3, and S4 which would increase the
volume of the waste due to the nature of the
sOlidification/ stabilization process.
.
Provides for maximum reduction in toxicity and mobility
both at the Site, by excavation and removal of
contaminated soils and casings, and at the ultimate
location of the soil disposal, since the contaminants
are removed from the soil medium, not merely stabilized
within it. This also results in maximum protection of
the offsite environment because the slight potential
risk of the treated materials in Alternatives S2, S3
artd S4 causing some future environmental harm at the
disposal site is eliminated.
.
Provides for maximum reuse/recycling of the metals
after their removal from the soil matrix.
.
Is the least costly of the soil alternatives.
EPA acknowledges that this alternative constitutes innovative
technology for which no treatability or pilot studies have yet
been completed. EPA believes, however, that the proposed
combination of technologies which, individually, have been used
in other industrial applications, has a reasonable expectation of
being successful.

If, however, this innovative alternative cannot be implemented,
EPA's preferred contingent alternative is S2, Stabilization/
Solidification of Soil and Casings, Offsite Disposal of the
Stabilized Mass in a Permitted Landfill. Specifically, EPA has
determined that, among Alternatives Sl, S2, S3 and S4,
Alternative 82:
.
Provides for maximum reduction in toxicity and mobility
of the contaminated soils and casings.

Can be implemented easily using available vendors.
.
.
Is much less costly than other Alternatives considered
to be as easily implementable.
62
AR301965
-------
Does not require large volumes of hazardous waste to be
transported over public roads.

EPA has determined that all of the following must take place in
order for the selected Alternative, S5, to be considered
technically and administratively feasible:
.
a. Exide/GBC must commit to implementing the primary
alternative, S5.
b. Exide must submit a detailed expeditious schedule for the
implementation of Alternative S5 which is acceptable to
EPA. This schedule shall include, at a minimum, the
major milestones to be accomplished during the remedial
action that EPA will review when determining if the
Alternative S5 continues to be implementable.

c. pilot studies performed by Exide must demonstrate the
technical feasibility of the process.
d. After any necessary pilot and treatability studies are
completed, Alternative S5 must continue to
provide the best balance among the nine criteria
originally used to evaluate the alternatives.

e. Exide must obtain all legally required permits for the
storage facility and for the construction and operation
of the new furnace or other equipment related to
Alternative S5.
2. Shallow Alluvial Aauifer

The selected alternative for the shallow alluvial aquifer is
Alternative A2, Vertical Limestone Barrier. It is the least
costly alternative other than Alternative A1, No Action.
Alternative A2 is a passive treatment system which requires
minimal operation and maintenance and immediately protects
surrounding receptors. This alternative treats all shallow
alluvial aquifer contamination and meets all Federal and
Pennsylvania ARARs.
3. Deep Bedrock Aauifer

The selected alternative for the bedrock aquifer is Alternative
B3, Pumping and Onsite Treatment and Disposal with discharge to
the recharge ponds described in Alternative A2 and/or the
Schuylkill River. It is the least costly alternative, other than
Alternative B1, No Action. Alternative B3 is a proven technology
which is easily implementable. This alternative treats all the
bedrock contamination and meets all Federal and Pennsylvania
ARARs.
63
AR301966
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B. PERFORMANCE STANDARDS
1. Soils and C~ings

Under Alternative S5, the entire volume of contaminated materials
(soils and casings) present on the site above 1000 mg/kg lead
shall be excavated, removed offsite and treated by a thermal
process to drive off the lead and other inorganics. Under the
contingent Alternative, S2, the entire volume of contaminated
materials (soils and casings) present on the site above 1000
mg/kg lead shall be excavated, treated by a solidification/
stabilization process and removed offsite to a landfill permitted
to accept this type of waste.
Under either Alternative S5 or contingent Alternative
treated waste must meet the LDR treatment standard (5
leachable lead) before its ultimate disposal, as well
following:

The initial excavation phase will involve the excavation of the
containment area (see Figure 2). Berms of sufficient height to
protect against the 100-year flood will be constructed along the
sides of the containment area to the railroad track embankment.
These berms and the walls of the containment area will serve as
protection against flooding. After excavation, the area will be
backfilled with imported soil and the berms removed although the
containment area mound will not be reconstructed.
S2, the
ppm for
as the
Soil excavation will continue until all soils over the cleanup
goal of 1000 mg/kg lead have been removed. Methods for
determining that cleanup goals have been reached will be
finalized during the design by EPA and but will be based on EPA
230/02-89-042, Methods for Evaluatina CleanuD Standards. Vol I.
All vehicles transporting hazardous waste from the site will be
washed down before leaving the Site to minimize the spread of
contamination to presently non-contaminated areas away from the
site.
All local roads damaged by the increased truck traffic due to the
remedial action will be repaired following the conclusion of the
onsite soil excavation.
2. Shallow Aquifer

Alternative A2 will remediate the ground water by increasing the
pH in the shallow aquifer to between 6.0 and 8.0 and will achieve
the background levels (Table 1) for the contaminants in the
shallow ground water, which is a relevant and appropriate
requirement under the PA Hazardous Waste Management Regulations.
The Pennsylvania ARAR for hazardous substances in ground water is
that all ground water must be remediated to "background" quality
as specified by 25 PA Code SS264.90 - 264.100, specifically 25 PA
Code SS264.97(i) and (j) and S264.100(a) (9). The Commonwealth of
64
~R301967
-------
Pennsylvania also maintains that the requirement to remediate to
background is also found in other legal authorities.

The limestone barriers, which would be connected together, would
be placed upgradient (perpendicular to Schuylkill River) and
downgradient (adjacent to the Schuylkill River and Mill Creek) of
the contamination, and consist of permeable crushed limestone
placed in a three-foot trench from grade to bedrock.
In order to remediate the shallow aquifer, two trenches shall be
excavated down to bedrock. One trench shall be placed upgradient
of the contaminated area, and run perpendicular to Schuylkill
River. The other trench shall be placed downgradient of the
contaminated area, perpendicular to the ground water flow
direction and adjacent to the Schuylkill River and Mill Creek.
These trenches shall connect with each other, enclosing the
contaminated ground water on three sides (see Figure 4). The
trenches shall be backfilled up to the high water table with
crushed limestone of an average particle diameter of 0.08 inches.
Excavated soils shall be backfilled or sent offsite for treatment
depending on whether they are above or below the selected cleanup
level.
To decrease the time for all aquifer water to be treated by the
limestone barrier, two infiltration ponds shall be constructed
onsite. One shall be upgradient of the contamination and the
other shall be located between the vertical limestone barriers.
These ponds shall recharge the shallow alluvial aquifer,
increasing the velocity of the contaminated ground water through
the vertical limestone barrier. The recharged ponds shall be
maintained at a constant, piezometric head by pumping water from
the Schuylkill River and/or discharge from a bedrock aquifer
treatment system.
Monitoring wells shall be installed in the area of contamination
and sampled on a quarterly basis for at least 6 years. The
number and location of these wells shall be specified by EPA
during the design of the limestone barrier. If, at any time,
sampling confirms that background levels have been attained
throughout the shallow aquifer and remain at the required levels
for twelve consecutive quarters, monitoring may be suspended.
3. Bedrock Aquifer
A treatment facility shall be constructed onsite and connected to
the recovery well system described below. The ground water shall
be treated for cadmium, sulfate, iron, manganese, calcium and
other dissolved solid ions, and then discharged to the Schuylkill
River. During design, wells shall be installed near the battery
breaking building and monitoring well MW-13. Ten to twenty wells
shall be installed in the suspected area of bedrock ground water
contamination, that is, in the area where concentrations of
contaminants in the ground water is suspected to be greater than
the "background" limits specified in Table 2. These wells shall
be used to determine the areal and vertical extent of
65
t\R30J968
-------
contamination, and to determine aquifer parameters needed for
flow rate and volume calculations. These wells shall be
converted to pumping wells for the remedial action.
The Selected Remedy shall achieve the background levels (Table 2)
for the contaminants in the bedrock ground water, which is a
relevant and appropriate requirement under the PA Hazardous Waste
Management Regulations. with the sole exception of manganese,
the pennsylvania ARAR for hazardous substances in ground water at
this site is that all ground water must be remediated to .
"background" quality as specified by 25 PA Code SS264.90 -
264.100, specifically 25 PA Code SS264.97(i) and (j) and
S264.100(a) (9). The Commonwealth of Pennsylvania also maintains
that the requirement to remediate to background is also found in
other legal authorities.' For manganese, the Pennsylvania ARAR is
the State MCL (50#g/L) specified by 25 PA Code S109.202, which,
in this instance, is lower than the calculated background
concentration.
In order to remediate the bedrock ground water, the extraction/
treatment system implemented under this Selected Remedy shall
operate until ground water monitoring shows that the
concentrations of contaminants of concern have been reduced to
the levels specified in Table 2. To this end, monitoring wells
shall be installed in the area of contamination and sampled on a
quarterly basis for at least 10 years. The number and location
of these wells will be specified in the design of the extraction
system. If sampling confirms that cleanup levels have been
attained throughout the downgradient area and remain at the
required levels for twelve consecutive quarters, operation of the
extraction system can be suspended. If, subsequent to the
extraction system shutdown, quarterly monitoring shows the ground
water concentrations of any contaminant of concern to be above
the levels specified in Table 2, the extraction system shall be
. immediately restarted and continued until the levels in Table 2
have once more been attained for twelve consecutive quarters.
All extracted ground water will be treated to levels which will
allow for discharge into a nearby surface water body in
compliance with the requirements of State and Federal NPDES
regulations.
4. Ground Water
If implementation of the Selected Remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will not be possible to meet the remediation standards and it is
thus technically impracticable to achieve and maintain background
concentrations throughout either the shallow or bedrock aquifer
(or for manganese in the bedrock aquifer, achieve and maintain
the State MCL), then EPA, in consultation with the Commonwealth
of Pennsylvania, may amend the ROD or issue an Explanation of
Significant Differences to inform the pUblic of alternative
ground water standards which may include, but not be limited to,
any of the following:
66
aR301969
-------
a)
engineering controls such as physical barriers, or
long-term gradient control provided by low level
pumping, as containment measures;
b)
chemical-specific ARARs will be waived for the cleanup
of those portions of the aquifer based on the technical
impracticability of achieving further contaminant
reduction;
c)
institutional controls will be provided/maintained to
restrict access to those portions of the aquifer which
remain above remediation goals;
d)
e)
continued monitoring of specified wells; and

periodic reevaluation of remedial technologies for
ground water restoration.
The decision to invoke any or all of these measures may be made
by EPA in consultation with PADER during a periodic review of the
remedial action which occurs at least every five years, in
accordance with section 121(c) of CERCLA, 42 U.S.C. S9621(c).

C. DEED RESTRICTIONS
Restrictions shall be placed on the deeds to the properties that
comprise the site which shall limit the site to "industrial use"
only.
xx. STATUTORY DETERHXHATXONS
Protection of Human Health and the Environment
Both the selected remedial action and the contingent alternative
protect human health and the environment by treating highly
contaminated soils and ground water. Under the selected remedy,
soils that are above the cleanup level will be excavated, removed
offsite and treated by a thermal process that will cause the lead
and other inorganic materials to leave the soils as a fume or
vapor and gasify the casings. Under the contingent alternative,
the same soils would be treated by a stabilization/solidification
process that will render them non-hazardous. In either case, the
treated soils will be disposed of in accordance with Federal and
State regulations. Shallow ground water will be treated in situ
as it flows through a limestone gravel barrier. The limestone
will raise the pH of the shallow aquifer, precipitating out the
lead and rendering it immobile. The deep (bedrock) ground water
will -a extracted, treated to remove the lead and other
inorg~nics, and discharged either to local streams or to the
onsite retaining ponds.
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,
ComDliance ~ith ADDlicable or Relevant and ADDroDriate
Reauirements'
These standards are considered applicable to this action:

This action will comply with the requirements for treatment
before disposal to meet Land Disposal Regulations and for storage
of wastes banned from land disposal (40 CFR Part 268).
Fugitive dust emissions generated during remedial activities will
comply with fugitive dust regulations in the Federally-approved
state Implementation Plan for the Commonwealth of Pennsylvania,
40 CFR Part 52, Subpart NN, 5552.2020 - 52.2023 and in 25 PA Code
55123.1 and 123.2, and will cause no violation of National
Ambient Air Quality Standards due to fugitive dust generated
during construction activities, 40 CFR 550.6 and 40 CFR 552.21(j)
and 25 PA Code 55131.2 and 131.3. In addition, the secondary
lead smelting operation will comply with all applicable air
emission requirements in accordance with 25 PA Code 55123.11 - 13
(particulate matter emissions), 25 PA Code 55123.21 - 22 (Sulfur
compound emissions), 25 PA Code 5123.25 (monitoring requirements)
and 25 PA Code Chapter 127, Subchapter D (Prevention of
Significant Deterioration of Air Quality requirements related to
Exide's Sulfur Dioxide emissions). Should modification to the
secondary lead smelter become necessary to handle thermal
treatment of the battery casings, the applicable provisions of 25
PA Code Chapter 127, Subchapters A and B, would also apply.

Offsite treatment, storage, and disposal will comply with RCRA
regulations and standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities, in accordance
with 25 PA Code Chapter 264, Subchapters A-E, Subchapter I
(containers), and Subchapter J (tanks).
This alternative will comply with regulations for generation and
transportation of hazardous wastes (49 CFR Parts 171 - 173 and 25
PA Code Chapter 262, Subchapters A and C, and Chapter 263).

Remedial action activities will comply with regulations governing
flood prevention for treatment and storage facilities located
within a 100 year floodplain (25 PA Code S269.22(b) and 25 PA
Code 5265.470(2».
Any surface water discharge will comply with the substantive
requirements of the Clean Water Act NPDES discharge regulations
(40 CFR 55122.41 - 122.50), the Pennsylvania NPDES regulations
(25 PA Code S92.31), the Pennsylvania Wastewater Treatment
Regulations (25 PA Code 5595.1 - 95.3), and the Pennsylvania
Water Quality Standards (25 PA Code 5593.1 - 93.9).

The action will comply with the requirements of the National
Historic Preservation Act (Chapters 106 and 110(f) and 36 CFR
Part 800) and Archeological and Historic Preservation Act (16 USC
469a-1) by reviewing historical records and conducting a Site
historical significance survey. If the results of these efforts
68
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indicate the Site has historic significance, additiona~
archaeological work will be conducted to preserve any bistorical
artifacts prio~to commencement of the remedial action.
The offsite thermal treatment will be performed in accordance
with the applicable provisions of 40 CFR part 266, Subpart H,
regarding the handling and processing of hazardous wastes in
boilers and industrial furnaces. The offsite thermal treatment
will be performed at a facility permitted under 25 PA Code
Chapter 265, subchapter R, and 25 PA Code Chapter 270.

This alternative will comply with CERCLA 5121(d) (3) which
prohibits the disposal of Superfund Site waste at a facility not
in compliance with 53004 and 53005 of RCRA and all applicable
State requirements.
This alternative will comply with waste water pretreatment
regulations (40 CFR Part 403).
This alternative will not comply with state regulations for
closure of hazardous waste sites (25 PA Code 5265.300 - 310), but
these closure regulations will be waived based on achieving an
Equivalent Standard of Performance by the removal of the
contaminated soils and remediation of the ground water to
background levels.

This alternative will comply with the Delaware River Basin
Commission Ground Water Protected Area Regulations regarding
construction of water extraction wells (No. (6) (f); Water Code of
the Basin, Section 2.50.2), metering of surface water intakes
(No.9; Water Code of the Basin, Section 2.50.2), non-
interference with domestic or other existing wells (No.
non-impact on ground water levels, ground water storage
or low flows of perennial streams (No.4; Water Code of
Basin, section 2.20.4).
10) and
capacity,
the
These standards are considered relevant and appropriate to this
action:
Onsite treatment will comply with RCRA regulations and standards
for owners and operators of hazardous waste treatment, storage,
and disposal facilities, in accordance with 25 PA Code Chapter
264, subchapters A-E, Subchapter I (containers), and Subchapter J
(tanks).
This alternative will comply with 25 PA Code Chapter 264,
Subchapter F, regarding ground water monitoring.

contamination in the ground water will be reduced to background
levels as required by 25 PA Code SS264.90 - 264.100, specifically
25 PA Code SS264.97(i) and 264.100(a) (9). The exception to this
is manganese, which will be reduced to the level specified by 25
PA Code 5109.202 which is lower than the calculated background
concentration. If implementation of the Selected Remedy
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demonstra~1S, in corroboration with hydrogeological and chemical
evidence, that it will not be possible to meet the remediation
goals and it tsthus technically impracticable to achieve and
maintain background concentrations throughout either the shallow
or bedrock aquifer (or for manganese in the bedrock aquifer, to
achieve and maintain the state MCL) then EPA, in consultation
with the Commonwealth of Pennsylvania, may amend the ROD or issue
an Explanation of Significant Differences to inform the public of
alternative ground water goals.
The following are to be considered during this action:
This alternative will comply with EPA OSWER Directive #9834.11
which prohibits the disposal of Superfund Site waste at a
facility not in compliance with S3004 and S3005 of RCRA and all
applicable State requirements.
Determinations about the effectiveness of soil remediation at the
site will be based on EPA 230/02-89-042, Methods for Evaluatinq
CleanuD Standards. Vol. I: Soils and Solid Media.

continued ground water quality degradation will be prevented as
called for in the PADER Ground water Quality Protection strategy,
December 1989.
Plans for site restoration will comply with recommendations
outlined in the Pennsylvania Scenic Rivers Act and schuylkill
River Scenic River Act (No. 32 P.S. SS820.21, et sea., and
821.31 - 38).

Onsite and offsite treatment will comply with RCRA regulations
for owners and operators of treatment, storage, and disposal
facilities, in accordance with 40 CFR SS264.601 - 264.603
(miscellaneous units).
This alternative will comply with 40 CFR Part 6, Appendix A, and
Executive Order 11988 regarding actions to avoid adverse impacts
on floodplains.
Cost Effectiveness

Cost effectiveness is determined by comparing the costs of the
alternatives beinq considered with their overall effectiveness to
determine whether costs are proportional to the effectiveness
achieved. The estimated present worth cost of the Selected
Remedy is $12,316,000. This Remedy is judged to afford overall
effectiveness proportional to its cost such that the remedy
represents good value for the money. When the relationship
between cost and overall effectiveness of the Selected Remedy is
compared to the cost and overall effectiveness of the of other
combinations of the Alternatives that were considered, the
Selected Remedy is jUdqed the more cost effective. The estimated
cost of the contingent alternative is $28,360,000. Should
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implementation of the soil component of the Selected R~edY prove
to be infeasible, the relationship between cost and overall
effectiveness~ the contingent alternative, along with the
selected ground water alternatives is judged the more cost
effective in comparison to the cost. and overall effectiveness of
the other combinations of the Alternatives.
Utilization of Permanent Solutions and Alternative Treatment
Technoloaies to The Maximum Extent Practicable
EPA has determined that the Selected Remedy represents the
maximum extent to which permanent solutions and alternative
treatment technologies can be utilized while providing the best
balance among the other evaluation criteria. Should
implementation of the soil component of the Selected Remedy prove
to be infeasible, EPA has determined that, among the remaining
alternatives, the contingent soil alternative along with the
selected ground water alternatives represent the maximum extent
to which permanent solutions and alternative treatment
technologies can be utilized while providing the best balance
among the other evaluation criteria. In addition, the thermal
treatment process and the vertical limestone barrier are
considered to be innovative methods for treating soils and ground
water contaminated with lead and other inorganics.
Preference for Treatment as a Principal Element
The Selected Remedy satisfies the statutory preference for
remedies that employ treatment as a principal element to
permanently reduce the volume, toxicity, or mobility of hazardous
substances. By excavating contaminated soils and removing-the
contamination and by extracting groundwater from the aquifer and
removing contamination from it before it is discharged back into
the environment, the Selected Remedy addresses the primary risk
posed by the Site through treatment. The contingent alternative
would also reduce the toxicity and mobility of the contamination
and address the primary risk through treatment as the
contaminated soils and casings would be solidified/stabilized and
disposed of in a permitted facility offsite.
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