UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

FINAL DECISION AND RESPONSE TO COMMENTS

HONEYWELL INTERNATIONAL, INC.
POTTSVILLE, PENNSYLVANIA
EPA ID NO. PAD069JV6185


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I-	FINAL DECISION - Compliance with Groundwater Use Restrictions

The United States Environmental Protection Agency (EPA) has determined that the
implementation of the institutional controls that require compliance with groundwater
use restrictions will be the Final Remedy for the Honeywell International, Inc. facility
located at 98 Westwood Road, Pottsville, Pennsylvania 17901 (Facility). This
determination is based on EPA's findings as detailed in the Statement of Basis (SB).
The SB is hereby incorporated into this Final Decision by reference and made a part
hereof as Exhibit A.

II-	PUBLIC COMMENT PERIOD

On August 29,2014, EPA issued the SB which summarized the information gathered
during environmental investigations at the Facility and described EPA's proposed
remedy. Consistent with public participation provisions under the Resource
Conservation and Recovery Act (RCRA), EPA requested comments from the public on
the proposed remedy as described in the SB. The commencement of a thirty (30)-day
public comment period was announced in the Citizens Voice newspaper on August 29,
2014 and on the EPA Region III website. The public comment period ended on
September 29,2014.

Ill. RESPONSE K). COM Ml-NTS

EPA received no comments on the SB. Consequently, the final remedy is unchanged
from the proposal.

EPA is issuing this Final Decision under the authority of the Solid Waste Disposal Act, as
amended by RCRA, and the Hazardous and Solid Waste Amendments of 1984,42 U.S.C.
Sections 6901 to 6992k.

V. DECLARATION

Based on the Administrative Record compiled for the Corrective Action at the Honeywell
International, Inc. facility, EPA has determined that the Final Remedy selected in this
Final Decision and Response to Comments is protective of human health and the
environment.

IV.

John A. Amisiead. Director
Land and Chemicals Division
U.S EPA Region III

Date

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Exhibit A


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UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

REGION III

STATEMENT OF BASIS

HONEYWELL INTERNATIONAL, INC.
POTTSVILLE, PENNSYLVANIA

PAD069776185


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I. Introduction

The United States Environmental Protection Agency (EPA) has prepared this
Statement of Basis (SB) to solicit public comment on its proposed remedy for the
Honeywell International. Inc. facility located at 98 Westwood Road, Pottsville, PA 17901
(Facility). EPA's proposed remedy consists of the implementation and maintenance of
groundwater use restrictions. This SB highlights key information relied upon by EPA in
developing its proposed remedy.

The Facility is subject to EPA's Corrective Action Program under the Solid Waste
Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA) of
1976, and the Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. §§
6901 et seq. (Corrective Action Program). The Corrective Action Program is designed to
ensure that certain facilities subject to RCRA have investigated and cleaned up any
releases of hazardous waste and hazardous constituents that have occurred at their
property. The Commonwealth of Pennsylvania is not authorized for the Corrective Action
Program under Section 3006 of RCRA. Therefore, EPA retains primary authority in the
Commonwealth for the Corrective Action Program.

The Administrative Record (AR) for the Facility contains all documents, including
data and quality assurance information, on which EPA's proposed decision is based. See
Section IX, Public Participation, for information on how you may review the AR.

II. Facility Background

The Facility property consists of approximately 27 acres. Land use adjacent to the
Honeywell property is residential to the north, commercial to the south, undeveloped
wooded areas to the east, and Westwood Road to the west. A Facility location map and a
Facility layout are attached to this SB as Figures 1 and 2, respectively.

Honeywell manufactures fluoropolymer film for the pharmaceutical industry and
nylon film for the food industry. Operations started at the Facility in 1961, as Allied
Chemical Corporation, following the purchase of the property in 1958. Operations have
been continuous i'rom then to present. On June 4, 1999. Allied Signal Inc. and Honeywell
Inc. merged and on December 1, 1999. the Facility became Honeywell International, Inc.

The Facility is currently known as Honeywell Specialty Film Plant (Honeywell).
Honeywell's current operation employs 210 workers and consists of two biaxial oriented
nylon film extrusion lines, six fluoropolymer, one cast nylon/Aclar line, and two silos with
a 200,000 pounds capacity each for nylon chip resin storage.

On October 9, 1980, the EPA assigned identification number PAD069776185 to
the Facility. The Part A permit application was first filed on November 13, 1980 and
revised on September 27, 1983. On September 30,1985, the Part B permit was issued for
the construction and operation of a hazardous waste storage facility. On April 28,1986,
the Facility submitted an application to amend the hazardous waste permit to add an
additional storage area for hazardous waste. On June 23, 1987, PADEP authorized a

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permit modification for the construction and operation of the additional hazardous waste
storage unit. The Facility's hazardous waste storage areas were clean closed and certified
on September 8, 1995.

In 2003, Honeywell responded to an acetone release under Pennsylvania
Department of Environmental Protection (PADEP) authority. On January 6,2006,

PADEP approved the Remedial Investigation/Final Report for acetone that was
remediated to the Act 2 Statewide Health Standards (SHSs) and Site Specific
Standards (SSSs) at the Facility.

III. Summary of Environmental Investigations

The Facility had used acetone stored in an aboveground storage tank (AST)
located southeast of Building 1 and west of Shed 1. Between November 10 and 15,2003,
approximately 764 gallons of acetone were released into the subsurface from the
underground transfer line leading from the AST to the process building (Building 1). The
release was caused by a 1/8 inch hole in a pipe.

In response, the Facility removed the AST contents. On November 17,2003, the
acetone pipeline from the comer of Building 1 to the location where it crossed the French
drain (approximately 30 feet) was removed. The asphalt, subbase gravel and underlying
soil to the north and west of the spill site were also removed.

In December 2003, the Facility began site characterization activities to assess the
degree and extent of acetone impact to soil and groundwater. Soil and groundwater
samples were collected as part of phased site characterization activities between December
2003 and April 2005.

The Act 2 SSS for acetone is 1,000 mg/kg for non-residential properties. EPA
recognizes that this standard is protective of both human health and groundwater in non-
residential scenarios. Thus, EPA agrees that the appropriate remedial goal was to address
soil that exceeded the 1,000 mg/kg standard.

Excavation of the impacted soil was completed in stages. The excavation was
concentrated in the area near the southeast corner of Building 1, where the acetone
releases occurred, and extended along the former location of the acetone pipeline for
approximately 35 feet. Soil was also excavated around and below the former location of
the French drain pipe to the location of the manhole. The excavation area was backfilled
with a combination of granular fill and general soil fill and repaved with approximately 6
inches of asphalt.

Impacted soil with acetone concentrations exceeding 1,000 mg/kg was removed
throughout the Facility property with one exception - the area below the footer of
Building 1. At this location, an acetone concentration of 19,000 mg/kg was reported.
Additional soil was not removed from below the footer due to the concern that this would
cause structural damage to the building.

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Honeywell performed a risk evaluation that used a risk-based standard that
requires action if the acetone in soil below the footer measures higher that 21, 291 nig/kg.
Since the highest concentration found in the area was 19,000 mg/kg, no further action is
necessary, given current and anticipated land use.

A total of 824,300 pounds of acetone contaminated soil was sent for off-site for
disposal. Four roll-off boxes containing 118,860 lbs. of contaminated soil were shipped
off-site for incineration.

Honeywell also investigated groundwater impact at the Facility. On March 8 and
9, 2004, four monitoring wells were installed at the Facility. Monitoring well MW-1 is an
upgradient well, MW-2 is located next to the excavation area, and MW-3 and MW-4 arc at
the downgradient Facility boundary In November 2004, two piezometers, PZ-1 and PZ-
2, were installed in the vicinity of the former excavation. Groundwater flow direction is to
the south/southwest. Groundwater samples were collected from each of the monitoring
wells on March 10, 2004, September 8, 2004, December 5, 2004, and January 6, 2005.
Groundwater samples were collected from each piezometer on December 5, 2004 and
January 6, 2005. Groundwater samples were collected from MW-1 and PZ-1 and PZ-2 on
February 25, 2005. On April 12, 2005, additional groundwater samples were collected
from 9 test borings GP-1 through GP-6, GP-9, GP-10, and GP-PZ2, PZ-1, PZ-2 and
MW-2.

For all environmental investigations, groundwater concentrations were screened
against federal drinking water standards known as Maximum Contaminant Levels (MCLs)
promulgated pursuant to Section 42 U.S.C. §§ 300f et seq. of the Safe Drinking Water Act
and codified at 40 CFR Part 141, or EPA Region III Risk-Based Concentration (RBCs) for
tap water (designated as Screening Levels for tap water (SLs)) for chemicals for which
there are no applicable MCLs. EPA has not promulgated an MCL for acetone, therefore
EPA screening level of 14,000 ug/1 was used to evaluate groundwater data.

Acetone was found in the source area at levels ranging from 5,400 parts per
millions (ppm) to as high as 15,000 ppm. Within 50 feet of the source, acetone levels had
decreased to 29 ppm. At the Facility boundary wells, MW-3 and MW-4, 200 feet away,
acetone was not detected. Given the volume of soil removal, EPA expects groundwater
concentrations of acetone will continue to decline due to natural attenuation. Acetone is
highly volatile and easily degrade in the environment. In addition, Honeywell completed
fate and transport modeling in accordance with the Act 2 Technical Guidance Manual.
The results of the modeling confirm that the acetone levels in groundwater associated with
the release location do not exceed the EPA RSL of 14,000 ug/1 or the PADEP used-aquifer
MSG of 10,000 ug/1 at the downgradient Facility property boundary. EPA is, therefore,
proposing groundwater use restrictions as the sole remedial measure for groundwater.

EPA evaluated the indoor air exposure pathway for acetone vapor that could
migrate from groundwater to the surface. The acetone concentrations in groundwater
underneath the Facility were found to be below EPA's target groundwater screening level

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for vapor intrusion of 23,000,000 ug/1. Thus, the indoor air pathway does not currently
require any action.

IV.	Corrective Action Objectives

EPA's Corrective Action Objectives for the Facility are the following:

1.	Soils

EPA's Corrective Action Objective for soils is to attain EPA's residential soil
Screening Level of 61,000 mg/kg.

2.	Groundwater

EPA's Corrective Action Objective for Facility groundwater is to meet EPA
Screening Level for tap water which is 14,000 ug/1 for acetone. Until such time as the
Screening Level is met throughout the Facility, exposures will be controlled by requiring
groundwater use restrictions at the Facility.

3.	Subsurface Vapor Intrusion

EPA corrective action objective for indoor air at the Facility is the attainment of
EPA's target groundwater Screening Level for vapor intrusion. EPA has determined that
attainment of EPA's target groundwater screening level for vapor intrusion is protective of
human health and the environment for individual contaminants at the Facility.

V.	Proposed Remedy
1. Soils

EPA has made a Corrective Action Complete without Controls determination for
Facility soils because based on the available information, there are currently no
unacceptable risks to human health and the environment from Facility soils for the present
and anticipated use of Facility property and therefore, EPA proposes that no land use
restrictions are required at the Facility.

EPA's proposed remedy for groundwater at the Facility is monitored natural
attenuation in concert with the implementation and maintenance of groundwater use
restrictions for as long as acetone concentrations in the groundwater measure above
14,000 ug/1.

Under the groundwater restrictions to be put in place at the Facility,
groundwater shall not be used for any purpose other than to conduct the operation,
maintenance, and monitoring activities required by PADEP and/or EPA, unless it

2,

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is demonstrated to EPA, that such use will not pose a threat to human health or the
environment or adversely affect or interfere with the selected remedy and EPA provides
prior written approval for such use.

3.	Subsurface Vapor Intrusion

EPA has made a Corrective Action Complete without Controls determination for
subsurface vapor intrusion at the Facility. The acetone concentrations in the Facility's
groundwater measure below EPA's target groundwater screening level of 23,000,000 ug/1
for vapor intrusion. (See Administrative Record, Table 1, for further information and
comparison).

4.	Implementation

EPA proposes to implement the groundwater restrictions through an enforceable
environmental covenant that conforms to the format and requirements set out in the
Pennsylvania Uniform Environmental Covenant Act, 27 Pa.C.S. §§ 6501-6517 (UECA).
The completed and approved environmental covenant will be will be filed and recorded.
The environmental covenant will bind Honeywell and all future owners of the Facility to
the restrictions set out in it. The environmental covenant will be drafted and recorder by
Honeywell.

VI. Evaluation of EPA's Proposed Remedy

This section provides a description of the criteria EPA used to evaluate the
proposed remedy consistent with EPA guidance. The criteria are applied in two phases.
In the first phase, EPA evaluates three decision threshold criteria as general goals. In the
second phase, for those remedies which meet the threshold criteria, EPA then evaluates
seven balancing criteria to determine which proposed remedy alternative provides the best
relative combination of attributes.

A. Threshold Criteria

1. Protect Human Health and the Environment

Based on the results of the October 18, 2005 Remedial Investigation/Final Report, EPA
has determined that after Honeywell's excavation and disposal activities, the sources of
groundwater contamination, have been greatly reduced. While contaminant remains in the
groundwater beneath the facility, the contaminant is contained and does not migrate
beyond the Facility's property. Since the contaminant remains in the groundwater at
concentrations above the Act 2 non-residential used aquifer MSC for acetone and EPA
RSL, EPA's proposed final remedy requires the implementation and maintenance of
groundwater use restrictions to ensure that groundwater beneath the Facility is not used for
any purpose.

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2.

Achieve Media Cleanup Objectives

The Facility has achieved the EPA's residential SLs for soils and subsurface vapor
intrusion. The groundwater beneath the Facility plume appears to be stable (not
migrating); although acetone concentrations are above MCLs, they are either stable or
declining over time through attenuation. In addition, groundwater monitoring will
continue until groundwater clean-up standards are met through attenuation. Until drinking
water standards are met, the proposed remedy requires groundwater use restrictions to
minimize the potential for human exposure to contamination and protect the integrity of
the remedy.

3. Remediating the Source of Releases

In all proposed remedies, EPA seeks to eliminate or reduce further releases
of hazardous wastes or hazardous constituents that may pose a threat to human health
and the environment. As shown in the October 18,2005 Remedial Investigation Report,
the Facility met this objective by removing the AST and several hundred tons of
contaminated soil. There are no remaining large, discrete sources of acetone which would
be released to the environment. Therefore, EPA has determined that this criterion has
been met.

B. Balancing/Evaluation Criteria

1.	Long-Term Effectiveness

The proposed groundwater use restrictions will maintain protection of human
health and the environment over time by controlling exposure to the hazardous
constituents remaining in groundwater. EPA anticipates that the groundwater use
restrictions may be implemented through an environmental covenant to be recorded with
the deed for the Facility property and which will be enforceable against future owners.

2.	Reduction of Toxicity, Mobility, or Volume of the Hazardous

Constituents

The reduction of toxicity, mobility and volume of hazardous constituents at
the Facility has already been by tank removal and soil excavation.

3.	Short-Term Effectiveness

EPA's proposed remedy does not involve any activities, such as construction or
excavation that would pose short-term risks workers, residents, and the environment. In
addition, EPA anticipates that the groundwater use restrictions will be folly implemented
shortly after the issuance of the Final Decision and Response to Comments (FDRTC).

4.	Implementability

EPA's proposed remedy is readily implementable.

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5. Cost

The major portion of remedial work has been completed. The cost of
implementing the proposed remedy is estimated to be less than $1,000.00. EPA is not
proposing financial assurance for this remedy.

6.	Community Acceptance

EPA will evaluate Community acceptance of the proposed remedy during the
public comment period and will be described in the FDRTC.

7.	State/Support Agency Acceptance

PADEP has overseen cleanup activities to date. EPA is proposing that PADEP's
actions to date are protective. EPA will evaluate the Commonwealth's acceptance based
on comments received from PADEP during the public comment period and will be
described in the FDRTC.

VII.	Environmental Indicators

EPA sets national goals to measure progress toward meeting the nation's major
environmental goals. For Corrective Action, EPA evaluates two key environmental
indicators for each facility: (1) current human exposures under control and (2) migration
of contaminated groundwater under control. The EPA has determined that the Facility
met these indicators on March 14, 2012.

VIII.	Financial Assurance

EPA has evaluated whether financial assurance for corrective action is necessary to
implement EPA's proposed remedy at the Facility. Given that EPA's proposed remedy
does not require any further engineering action to remediate soil, groundwater or indoor
air contamination at this time and given that the costs of implementing groundwater use
restrictions are estimated to be less than $1,000.00, EPA is proposing that no financial
assurance be required.

IX.	Public Participation

Before EPA makes a final decision on its proposal for the Facility, the public may
participate in the remedy selection process by reviewing this SB and documents contained
in the Administrative Record (AR) for the Facility. The AR contains all information
considered by EPA in reaching this proposed remedy. It is available for public review
during normal business hours at:

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U.S. EPA Region III
1650 Arch Street

Philadelphia, PA 19103
Contact: Ms. Tran Trail
Phone: (215) 814-2079
Fax: (215)814-3113

Email: tran.tran@epa.gov

Interested parties are encouraged to review the AR and comment on EPA's
proposed remedy. The public comment period will last thirty (30) calendar days from the
date that notice is published in a local newspaper. You may submit comments by mail,
fax, or e-mail to Ms. Tran Tran. EPA will hold a public meeting to discuss this proposed
remedy upon request. Requests for a public meeting should be made to Ms. Tran Tran. -

EPA will respond to all relevant comments received during the comment period.
If EPA determines that new information warrant a modification to the proposed remedy,
EPA will modify the proposed remedy or select other alternatives based on such new
information and/or public comments. EPA will announce its final remedy and explain the
rationale for any changes in a document entitled the FDRTC. All persons who comment
on this proposed remedy will receive a copy of the FDRTC. Others may obtain a copy by
contacting Ms. Tran Tran at the address listed above.

John A. Arm stead, Director
Land and Chemicals Division

US EPA, Region III

Attachments:

1.	Attachment 1 - Figure 1 - Facility Location Map

2.	Attachment 2 - Figure 2 - Site Layout

3.	Attachment 3 - Index to Administrative Record

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Attachment 1
Figure 1 - Facility Location Map


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Attachment 2
Figure 2 - Facility Layout Map


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SOURCE:
google.com

SCALE: Approx.1 "=150' DATE:JUNE 2009
S.O. NO.: 115410	FILE: 11 5410_HONEY_02

DSN/DWN:JPK/RRR	CHK: JPK

aker

MICHAEL BAKER JR., INC.
MOON TOWNSHIP, PENNSYLVANIA

FIGURE 2
FACILITY LAYOUT MAP
HONEYWELL INTERNATIONAL, INC
98 WESTWQOD ROAD

POTTSVILLE. PENNSYLVANIA


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Attachment 3
Index to Administrative Record


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INDEX TO ADMINISTRATIVE RECORD

1.	Final Environmental Indicator Inspection Report for Honeywell International, Inc.
Prepared by Baker, November 2009.

2.	Remedial Investigation Report, Honeywell Pottsville Plant prepared by MACTEC
Engineering and Consulting, Inc., October 18, 2005.

3.	Deed Restriction.

4.	Table 1, Act 2 Standards and EPA's Region 3's Risk Based Concentrations comparison

5.	PADEP Approval of Act 2 Final Report, January 6, 2006.

6.	PADEP Clean Closed Determination, September 22,1995.


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