UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
LORD CORPORATION
CAMBRIDGE SPRINGS, PENNSYLVANIA 16403
EPA ID NO. PAD051129757
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TABLE OF CONTENTS
Section Page
I. Introduction 1
II. Facility Background I
III Summary of the Environmental Investigations and Activities 2
IV. Investigation Results 4
V. Property Deed Restriction 8
VI Environmental Indicators 9
VII. Financial Assurance 9
VIII. Evaluation of Criteria 9
IX. Public Participation 11
LIST OF ATTACHMENTS
Attachment 1 Site Location Map
Attachment 2 Layout of Lord Corporation, Cambridge Springs Plant, PA
TABLE
Table 1
Historical Groundwater Elevation Data 2003 -2006
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1
I. Introduction
The United States Environmental Protection Agency ("EPA") is issuing this Statement of
Basis ("SB") to solicit public comment on EPA's determination that Lord Corporation,
Cambridge Springs Mechanical Plant ("Lord" or "Site" or "Facility") located at 124 Grant Street,
Cambridge Springs, Crawford County, Pennsylvania 16403-0246 has attained Corrective Action
Complete with Controls. The Facility is subject to the requirement of performing corrective action
activities because it is subject to the provisions of Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act of 1976 ("RCRA") and the Hazardous and Solid Waste
Amendment of 1984 ("HSWA"), 42 U.S.C. §§ 6901 - 6992. This law requires facilities such as
Lord to investigate and clean up releases of hazardous wastes or hazardous constituents that have
occurred at their facility. This SB explains EPA's preliminary determination that Lord has fully
investigated and properly cleaned up the Facility pursuant to the authority of the Commonwealth
of Pennsylvania's Land Recycling and Environmental Remediation Standards Act ("Act 2"). The
Pennsylvania Department of Environmental Protection (PADEP) approved Lord's Final Report in
May 2003.
PADEP's approval of Lord's post remedial plan activities required Lord to prohibit the use
of groundwater for potable purposes through a deed restriction and to include a deed notice of
contamination at the site. EPA's proposal to designate the Facility as "Corrective Action
Complete with Controls" is consistent with PADEP earlier approval and current EPA guidance
entitled "Final Guidance on Completion of Corrective Action at RCRA Facilities (February 25,
2003)."
II. Facility Background
The Lord Mechanical facility is located in the northwest sector of Cambridge Springs, a
small town .of around 2,000 people in Crawford County. The facility is located on approximately
16.6 acres just west of Grant Street and south of French Creek. The site contains a 149,000 square
foot manufacturing building. To the north lays the Cambridge Springs Wastewater Treatment
Plant and French Creek (within 200 feet). The area to the east of the plant is light industrial and
residential. To the west lays Jackson Run (a tributary located within 100 feet of the site) and
undeveloped land. This site lies within the French Creek flood plain. Attachment 1 shows the site
location. Attachment 2 presents the layout of the Facility.
Most of the property is covered with building or impermeable surfaces such as asphalt or
macadam parking lots and driveways. The property is enclosed with a chain-link fence with
limited access. A water storage tower and pump house for fire protection are located on the
northwest corner of the facility property.
The Lord Corporation acquired the Cambridge Springs property from White Industries,
Inc. in 1966. While the nature of facility operation prior to 1966 is unknown, White Industries
operated a small manufacturing facility here. Since 1966, Lord Corporation has performed rubber
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to metal bonding operations on the property. These operations expanded considerably during the
1970's when Lord constructed a large addition to the original structure. Lord began machining
metal components here in 1974 This facility was known as the Lord Kinematics facility until
1983 when it was redesignated as the Lord Mechanical Products facility.
The Lord Mechanical Products facility manufacturers elastomer-to-metal-bonded (rubber
to metal) products. The metals include steel, stainless steel, aluminum, and brass. The elastomers
include natural rubber, styrene butadiene elastomer, chlorobutyl elastomer, neoprone, nitrile
elastomer, epichlorohydrine elastomer, ethylene propylene diene turpolymers, and polyvinyl
chlorides. None of the elastomers are manufactured at the facility. Metals are prepared for
bonding by machining, degreasing, grit blasting, chemical treatment, and adhesive application.
Elastomer preparation consists of milling, extruding, strip forming, and dicing. The blending
process is accomplished by press curing the uncured elastomer and adhesive to the metal.
Finishing processes consist of deflashing, coating, painting, and packaging. Typically, the
adhesives used contain high percentages of methyl isobutyl ketone, xylene, methyl ethyl ketone,
and tetrachloroethylene before use.
Geology beneath the Facility consists mainly of silt and clay fill and disturbed deposits to
approximately 3 feet below land surface (ft bis). These deposits overlie interbededded clay, silt,
silty sand and silt and gravel to 7 to 9 ft bis. This heterogeneous layering of permeable and less
permeable materials extends below the water table in some areas of the Facility, including within
the source area adjacent to the main manufacturing building. The finer grained deposits are
underlain by sand and gravel which is uniformly distributed beneath the investigation area to
depths of 12 to 17 ft bis at which depth the surface of a very stiff, plastic gray clay was
encountered. The dense clay unit is laterally continuous beneath the Facility. The surface
topography of the clay units varies from 15 to 18.5 ft bis. Based on a Pennsylvania Department of
Transportation (PADOT) boring installed adjacent to the site as part of the Grant Street Bridge
project, this clay unit is 44 feet thick, and overlays a layer of sandstone on top of siltstone.
Groundwater was determined to be present in the unconsolidated silt, sand and gravel
deposits which overlie the clay unit. Depth to groundwater ranged from approximately 7 ft bis at
the south Facility fence line to approximately 11 to 12 ft bis along the north fence line. Analysis
of groundwater elevation data indicated a groundwater flow direction north-northeast toward
French Creek.
III. Summary of the Environmental Investigations and Activities
In 1994, EPA completed a RCRA Facility Assessment/Environmental Priorities Initiative
(RFA/EPI) and subsequent RFA/EPI Report. Lord initiated an Initial Characterization
Investigation (completed July 30,1997 through August 2, 1997) to evaluate Solid Waste
Management Units (SWMUs) and Areas of Concern (AOCs) identified by EPA.
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The results of the Initial Characterization Investigation indicated that no significant
impacts to environmental media were present at the SWMUs and AOCs. However,
tetrachloroethene (PCE) was detected in groundwater along the north boundary fence. Based on
this finding, Lord initiated remedial investigation efforts in the area north of the manufacturing
building, which has been defined as an Act 2 "Site." Lord Corporation believed that the PCE
contamination was likely attributable to small spills and leaks that occurred around the PCE
unloading area. No specific sources or events had been identified.
In August 1998, Lord submitted Notice of Intent to Remediate (NIR) to PADEP, notified
Borough of Cambridge Springs and posted a notice in the Erie Times.
In November 1998, Lord submitted a Site Remedial Investigation/Risk Assessment
(RI/RA) to PADEP. The RI/RA identified a shallow band of contaminated groundwater
originating along the northern facility boundary. This groundwater discharges to French Creek and
consists of volatile organic compounds.
In February 1999, PADEP approved the overall Site Remedial Investigation/Risk
Assessment. PADEP required Lord to monitor the plume since conclusions regarding the amount
of contamination reaching French Creek were based on plume dimensions and rate of movement.
PADEP also requested that Lord amend the property deed to both restrict groundwater use and to
include a notice of contamination at the facility.
In December 2000, Lord submitted to EPA a technical study on Remedial Technology
Screening. In this report, Lord concluded that active remediation was not necessary since existing
concentration of Volatile Organic Compounds did not pose a risk to human health or French
Creek. Lord proposed that institutional controls be implemented and enforced so that potential
risks posed by the facility were managed.
Property deed restrictions were drafted for the Facility in 2001 and submitted to the Erie
County Recorder of Deeds office. The deed changes were officially recorded on March 12,2001.
In March 2002, Lord submitted to PADEP an Act 2 Final Report which concluded that the
levels of chlorinated volatile organic compounds (CVOCs) at the Facility meet site specific
standards under Act 2 and requested relief from liability. The Final Report specifically concluded
that the levels of CVOCs in the groundwater discharging from the Facility to French Creek,
comprised of a diffuse plume and seeps, met applicable human health criteria limits under Act 2.
The conclusion was based on the fate and transport analysis and surface water dilution
calculations performed by Lord pursuant to 1997 Act 2 Technical Guidance Manual, which was in
effect at the time of the submission of the Final Report.
In June 2002, PADEP disapproved the Final Report on the basis that its calculation of the
in-stream concentration of PCE from the diffuse groundwater discharge at the Facility using the
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newly-adopted PENTOXSD model showed that human health criteria limits under Act 2 would be
exceeded.
In July 2002, Lord filed an appeal of PADEP's June 2002 disapproval.
In November 2002, Lord submitted to PADEP a Draft Phytoremediation Work Plan
proposing additional remediation measures on the Facility designed to minimize the potential
impact of CVOCs in the groundwater at the Facility. The Work Plan was proposed to settle the
appeal filed by Lord of the decision by the PADEP to deny Lord's Act 2 Final Report of 2002
submitted under Act 2.
In April 2003, Lord submitted to PADEP a Final Phytoremediation Work Plan. The Work
Plan outlined the design criteria considered to construct the phyto-barrier that would intercept
groundwater flowing into French Creek.
In May 2003, Lord Corporation and PADEP entered into a Consent Order and Agreement
with respect to Act 2 activities associated with the Facility.
By letter dated May 14,2003, PADEP withdrew its June 2002 disapproval of the Lord
Final Report dated March 26, 2002 ("Final Report"). In the May letter, PADEP approved the Final
Report submitted on behalf of Lord pursuant to Act 2 and indicated the Facility attained a site
specific standard. In addition, PADEP required a deed notice.
In February 2007, Lord submitted PADEP a Summary Report for 2006 Activities in
accordance with the 2003 Final Phytoremediation Work Plan. Lord indicated that the 2006
Summary Report would be the final report submitted to PADEP. Collection of groundwater
elevation data had been discontinued and there was no projected monitoring or reporting in 2007
or thereafter. The phytoremediation barrier would continue to be maintained with periodic
trimmings and tree replacement as necessary.
IV. Investigation Results
From July 1997 to October 2006, Lord conducted investigative and remedial actions to
fulfil the site characterization requirements of Act 2.
Initial Characterization Investigation
Evaluation of soil analytical data collected during the SWMU and AOC Characterization
investigation indicated that all detected constituents in soil in the vicinity of the SWMUs and
AOCs were present at concentrations below their respective Act 2 screening levels. Analytical
results of groundwater from a temporary piezometer TPZ-3 indicated that concentration of one
compound, tetrachloroethene (PCE) was detected at a concentration slightly greater than the Act
2 Used-Aquifer MSC (medium-specific concentration) but below the Non-Used Aquifer MSC.
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Groundwater results from TPZ-4 indicated that the concentration of one compound, PCE, was
detected at a concentration greater than the Used-Aquifer MSC and the Non-Used Aquifer. TPZ-4
was located along the north boundary fence. This area was subsequently designated a "Site" under
Act 2. PCE usage at the Facility was discontinued in 1995. The investigation also revealed that no
exceedances of Act 2 Statewide Health MSCs were identified at any of the SWMUs and AOCs.
Remedial Investigation
The "Site" Remedial Investigation, completed from October 1997 to October 2006,
included activities such as soil borings, installation of monitor wells, multiple rounds of
groundwater sampling and aquifer testing. The investigation work also consisted of Addendum 1
and 2 investigations, an assessment of fate and transport and a site-specific risk characterization,
"Site" follow-up activities from 1999 to 2000 and phytoremediation activities during 2003 to
2006.
Addendum 1 investigation confirmed the presence of Volatile Organic Compounds
(VOCs), primary PCE, in soil and groundwater north of the main building at the "Site." Detected
concentrations ofPCE in soil ranged from 0.002 milligrams per kilogram (mg/kg) to 0.6 mg/kg.
Only one sample at 8 - 10 ft bis (0.6 mg/kg) exceeded Act 2 Statewide Health MSCs screening
criteria for PCE 0.43 mg/kg. Concentration ofPCE in the "Site" groundwater ranged from 0.027
milligrams per liter (mg/L) to 45 mg/L. Concentrations ofPCE were higher than Act 2 MSCs of
0.005 mg/L,
Addendum 2 investigation confirmed the presence ofPCE above the Act 2 MSCs. It (a)
provided additional information such as hydraulic data and migration on the presence of VOCs in
groundwater, (b) determined no separate phase PCE was observable in "Site" monitor wells, and
(c) showed that active remediation through pumping would not be effective in achieving Act 2
Statewide Health MSCs for groundwater based on the results of the Source Reduction Pilot Test.
Using the highest detected concentration ofPCE in groundwater at the Facility fence line,
the fate and transport calculations predicted the concentration ofPCE in groundwater discharging
to French Creek to be 7.68 mg/L. (The calculation included the following assumptions: 1. uniform
PCE concentration throughout the saturated aquifer; 2. 100 foot wide, high PCE concentration -
8.0 mg/L, center plume for diffuse discharge calculations; 3. 100 foot wide plume fringes for
diffuse discharge calculations; and 4.1,200 square feet total cross-sectional diffuse groundwater
flow area to French Creek.) The in-stream surface water concentrations were determined based on
Act 2 Guidance using dilution calculation to be 0.00037 mg/L which was below the Pennsylvania
Title 25 Chapter 16 Water Quality Criteria for Toxic Substances permissible water quality
concentration of 0.0007 mg/L for PCE under human health criteria.
Lord sampled two seeps discovered on the bank of French Creek during an inspection in
June, 1998. Seep samples were submitted for laboratory analysis of VOCs using EPA Method
8260. Data indicated that the concentration of total VOCs in Seep 1 was 0.486 mg/L (consisting
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ofPCE and its degradation products) and total VOCs in Seep 2 was 8.2 mg/L (all PCE). These
data correlated closely to the diffuse concentration predicted by the fate and transport analysis of
approximately 7.68 mg/L. Additionally, the concentration of 8 2 mg/L ofPCE was applied to the
surface water dilution calculations and resulted in a total cumulative concentration of 0.000396
mg/L in French Creek. This value was below the indicated 0.0007 mg/L criteria.
Using exiting groundwater data and the results of a focused investigation conducted in
1997, the dimensions of the saturated zone associated with the VOC groundwater plume entering
French Creek was conservatively determined to be 6 feet thick and 300 feet wide.
Facility Risk Assessment
The Facility risk assessment identified three potential human receptors: (1) a future
construction worker (excavation); (2) facility workers (indoor air vapors exposure); and (3) an
adolescent trespasser (groundwater seep exposure). Terrestrial and aquatic biota in French Creek
were identified as potential receptors for Ecological Assessment. From a human health
perspective, the evaluation of non-carcinogenic effects resulted in no Hazard Index thresholds
greater than 1 for any of the potential receptors. Further, the evaluation of carcinogenic effects
resulted in no Excess Lifetime Cancer Risks (ELCR) exceeding the Act 2 target ELCR of 1 x 10-5
for any receptor.
The qualitative ecological assessment indicated that the "Site" should not pose a risk to
either terrestrial or aquatic life or in the vicinity of the "Site." This was based on (1) no evidence
was found of the occurrence of species of concern in the French Creek area around Lord's
Cambridge Springs facility according to a review of Pennsylvania Natural Diversity Inventory and
(2) a qualitative ecological site reconnaissance survey confirmed that no significant adverse
impact on the wetlands were evident.
"Site " Follow-up Activities
Lord performed the below follow-up activities during 1999 to 2001 as a result of receipt of
PADEP approval letter ofFebruary 1999 (see Section lit above).
Addendum 3 of the "Site" Remedial Investigation was to verify the VOC plume cross-
sectional area, field investigation activities included depth to water measurements from existing
monitoring points in the vicinity of the "Site" and a direct-push investigation along French Creek.
A series of 11 geoprobe soils borings, designated GP-1 through GP-11, were performed in a line
parallel to and less than 50 feet south of the southern bank of French Creek. The highest VOC
concentrations detected were identified between points GP-4 and GP-9 and ranged from 0.627
mg/L (GP-4) to 9.275 mg/L (GP-5). These values dropped dramatically moving out towards
either end of the sampling transect. Total VOC concentrations consisted mostly ofPCE, with
relatively minor concentrations of trichloroethene, trans-1,2-dichloroethene, cis-1,2-
dichloroethene, and 1,1,1 -trichloroethane. Vinyl chloride was not detected in groundwater
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collected during the direct-push investigation. Based upon Addendum 3 investigations, the
dimensions of the saturated plume associated with the VOC groundwater plume entering French
Creek were re-confirmed at 6 feet high by 300 feet wide (See Section Remedial Investigation
above).
Fate and transport analysis and surface water dilution calculations were completed for all
VOCs found in groundwater at the "Site." Average site-specific VOC concentrations for the
diffuse plume discharging to French Creek were calculated using detected concentrations from
Addendum 3 direct-push investigation and quarterly sampling events when necessary. Based on
the proximity of this focused investigation to the creek, and the uniform distribution of VOC
concentrations across the plume front, the data adequately represented groundwater which entered
French Creek.
The stream concentrations predicted using mass loading calculations were compared with
Pennsylvania Title 25 Chapter 16 Water Quality Criteria for Toxic Substances (1997) for each
average VOC concentration from the 1999 field investigation and monitoring data. Calculated in-
stream concentrations for all detected VOCs in groundwater which may discharge to French Creek
were below the human health criteria standards.
Lord conducted a review of threatened and endangered species surveys and a qualitative
ecological site reconnaissance survey. Lord concluded that no evidence was found of the
occurrence of species of concern in the French Creek area around the Facility and no significant
adverse impacts on the wetlands were evident.
Lord conducted a review of available screening benchmarks for assessing potential
ecological risks due to selected VOCs in aquatic systems. The selected VOCs included PCE,
1,1,1 -trichloroethane, trichloroethene, cis-1,2-dichloroethene, trans-1,2-dichloroethene, and vinyl
chloride. The review focused on the potential for direct toxicity to fish and invertebrates. Surface
water screening benchmarks and sediment considerations that were applicable to the "Site" were
identified and compared to chemical concentrations that had been measured or predicted in
environmental media at the "Site." These comparisons showed that the discharge of VOCs in
groundwater to surface water at the "Site" was not anticipated to pose a risk to the environment.
The levels of VOCs in groundwater and seeps at the "Site" were similar to or lower than all
applicable surface water benchmarks with the exception of measured concentrations ofPCE in
groundwater. However the anticipated dilution and volatilization of PCE upon contact of the
groundwater and surface water would effectively reduce the contact concentration ofPCE in
surface water to a modeled and surface water dilution calculated concentration below surface
water quality screening benchmarks.
Lord obtained a report prepared by EnvironScience of Ohio dated July 12,2000 entitled
Threatened & Endangered Fish Survey Final Report, French Creek, Crawford County,
Pennsylvania, Grand Avenue Bridge. The report indicated that the viability of fish communities in
the portions of French Creek that were adjacent to, and downstream of, the Facility were as good
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as, or better than, the viability of communities in portions of the creek that were upstream of the
Facility. Lord suggested that groundwater and surface water from the Facility pose no current or
future risk to French Creek's fish or aquatic invertebrate communities.
Lord conducted one year of quarterly groundwater sampling analysis in 1999 and two
years of semi-annual groundwater sampling and analysis in 2000 and 2001.
Lord prepared and submitted annual status reports in 1999,2000 and 2001.
Lord concluded that based on data collected during the three years (1999,2000 and 2001)
of site monitoring, concentrations ofVOCs did not pose a risk to human health or the surrounding
ecological environment.
Phytoremediation
Phytoremediation is the use of plants and plant processes to reduce groundwater flow and
mass loading to French Creek. It captures groundwater and soil pore-space water by using trees
with deep root systems that take up large quantities of water. The water uptake of certain plants
can be significant enough to suppress the water table, and in some instances, create zones of
captured contaminated groundwater.
According to the Phytoremediation Work Plan of April 2003 (see Section III above),
considering (1) the parameters developed and measured during the Act 2 investigation, the
groundwater flow rate to the French Creek was approximately 31,000 gals/day and (2) the
pumping rate of200 gallons per day per tree, it was estimated the 135 hybrid poplars trees phyto-
barrier would be able to remove approximately 28,000 gallons per day. The phyto-barrier could
therefore bring about an approximately 90 percent reduction in the groundwater flow during the
growing season after trees had matured. Lord completed the phyto-barrier (phytoremediation
barrier) construction in May 2003 and implemented water level monitoring from 2003 to 2006.
Water level measurements were collected from piezometers at the site on a quarterly basis. Table
1 provides historic water level data May 2003 to October 2006. The water elevation data provided
indication that the system had the ability to reduce water table at the "Site." Based on the work
plan, collection of groundwater elevation was discontinued and there would be no projected
monitoring and reporting. The phyto-barrier will continue to be maintained with periodic
trimmings and tree replacement as necessary.
V. Property Deed Restriction
Amending the Facility property deed to include a notice of contamination and to restrict
groundwater use was initiated in 1999. Deed changes were completed in 2001 and submitted to
the Erie County Recorder of Deeds office. The deed changes were officially recorded on March
12,2001.
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VI. Environmental Indicators
EPA has established two environmental indicators that are designated to measure the
human health and groundwater impacts of RCRA facilities. These two indicators use
environmental data and apply a decision matrix to determine that human health impacts are "under
control" and that groundwater contamination is "under control". Lord met these indicators at the
Facility in September 28, 2000. EPA believes that these environmental indicators provide
additional evidence that the action proposed has been effective and will protect human health and
the groundwater at the Facility in the long-term.
VII. 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 actions to remediate soil, groundwater contamination at this time and given
that the costs of implementing institutional controls at the Facility will be de minimis, EPA is
proposing that no financial assurance be required.
VIII. Evaluation of Criteria
This section provides a description of the criteria EPA uses to evaluate proposed final
remedies under the Corrective Action Program. The criteria are applied in two phases. In the first
phase, EPA evaluates three remedy 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
EPA's evaluation of the threshold criteria follows:
1. Protect human health and the environment
Lord obtained an Act 2 Release of Liability from PADEP for the Site. The level of
CVOCs in surface and subsurface soil, groundwater and surface water at the Facility did not
present a risk to human health or the environment based on information obtained during the
Remedial Investigations performed by Lord. The Remedial Investigations contained a risk
characterization and ecological assessment. (See Section IV. Initial Characterization
Investigation, Remedial Investigation and Facility Risk Assessment above for screening levels.)
The only possible exposure route to contaminated groundwater or soil at the Facility is to
workers taking environmental samples or to workers excavating soil in the vicinity of the Site.
However, Lord is in compliance with applicable regulations governing worker safety and has
developed Health and Safety Plans which provide for appropriate worker training and explains the
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circumstances under which it is necessary for workers to wear protective clothing if exposure to
contaminated soil and groundwater is expected.
2. Achieve media cleanup objectives
PADEP approved the Final Report submitted on behalf of Lord pursuant to Act 2 and
indicated the Facility attained a site specific standard for groundwater as developed for the site
using Act 2 guidance. (See Section IV. Remedial Investigation and "Site " Follow-up Activities for
screening levels.)
Evaluation of soil analytical data collected during the SWMU and AOC
Characterization investigation indicated that all detected constituents in soil in the vicinity of the
SWMUs and AOCs are present at concentrations below their respective Act 2 screening levels.
The investigation also revealed that no exceedances of Act 2 Statewide Health MSCs were
identified at any of the SWMUs and AOCs.
3. Control the source(s)
Lord uses the former perchloroethylene storage tank for holding recycled water. This
tank was cleaned and converted to its current use at some time after the degreasing units were
taken out of service in1995. Lord implemented a phytoremediation barrier to reduce groundwater
flow to French Creek. It captures groundwater and soil pore-space water by using trees with deep
root systems that take up large quantities of water. The water uptake of certain plants can be
significant enough to suppress the water table, and in some instances, create zones of captured
contaminated groundwater. To further limit the potential for a complete exposure pathway, Lord
has filed a deed notice which provides notice that the use of the site property is limited to non-
residential use.
B. Balancing Criteria
Because of control activities have already been implemented and are operating and
because EPA is satisfied that the control activities are protective of human health and the
environment, EPA is not choosing among alternative of remedies/corrective action activities.
Therefore, an evaluation of other alternatives is not necessary. Nonetheless, EPA presents the
seven criteria below to illustrate the suitability of the control activities:
1. Long-Term Reliability and Effectiveness
The Facility's Act 2 investigations and remediation activities have addressed soil and
groundwater contamination at the Site. EPA also considers the restrictions on groundwater use
and the restrictions on the use of property to non-residential use as long term components of
control activities. Lord has filed a deed notice to the Facility which provides notice that
development of on-site groundwater for drinking and other domestic uses is prohibited and the
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Facility property is limited to non-residential use.
2. Reduction of Toxicity. Mobility, or Volume of Wastes
Direct contact exposure pathways do not exist due to the presence of asphalt paved
surface. This has eliminated the potential for the direct contact exposure and reduced the mobility
of the contaminants as well. In addition, Lord implements a phytoremediation barrier to reduce
groundwater flow and mass loading to French Creek.
3. Short-Term Effectiveness
Continued implementation of the phytoremediation barrier at the Facility is effective in
short term since it is an activity that is currently ongoing and its continuation can be accomplished
easily.
4. Implementabilitv
The deed notice is both technically and administratively feasible. Deed notice has been
filed in the Office of the Recorder of Deeds for Erie County.
5. Cost
Lord has already expended the capital costs involved in performing the investigations
and remedial activities necessary to obtain a Release of Liability pursuant to PADEP's Act 2
program.
6. Community Acceptance
The local community of Cambridge Springs, Pennsylvania, was given the opportunity
to evaluate all of the Facility's proposed remedial plans from the earliest stages of the
investigations through conclusion of the cleanup and it has accepted Lord's corrective action and
control activities. EPA will provide public notice and an opportunity for comment to any
interested parties before this proposed decision becomes final.
7. State Acceptance
All of Lord's Remedial Investigation Workplans for the Facility were evaluated and
approved by PADEP. PADEP issued letter approving Lord's Act 2 Final Report and granting Lord
an Act 2 Release of Liability on May 14,2003. EPA's proposed determination that the Lord
Facility is Corrective Action Complete with Controls is based upon the activities performed by
Lord pursuant to PADEP's Act 2.
IX. Public Participation
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EPA is requesting comments from the public on its determination that the Facility is
Corrective Action Complete with Controls. On January 30, 2008, EPA placed an announcement
in the local newspaper, The Meadville Tribune, to notify the public of the availability of this
Statement of Basis, its supporting Administrative Record, and the public's opportunity to request a
public meeting on EPA's proposed corrective action for the Facility. The public comment period
will last thirty (30) calendar days from the date that this matter is publicly noticed in a local paper.
Comments should be sent to EPA in writing to the address listed below, and all cementers will
receive a copy of the final decision and a copy of the response to comments.
A public meeting will be held upon request. Requests for a public meeting should be
made to Mr. Hon Lee of the EPA Regional Office at the address listed below or at 215-814-3419.
The Administrative Record contains all information considered by EPA when making this
determination. The Administrative Record is available for review during business hours at the
following location:
U.S. Environmental Protection Agency Region III (3WC22)
1650 Arch Street
Philadelphia, PA 19103
Contact: Hon Lee
Phone: 215-814-3419
Fax:215-814-3113
E-mail: lee.hon@,epa. gov
Following the thirty (30) day public comment period, EPA will prepare a Final Decision
and Response to Comments in which it will identify the selected remedy for the Facility. The
Response to Comments will address all significant written comments and any significant oral
comments generated at a public meeting, if such a meeting is held. The Final Decision and
Response to Comments will be made available to the public. If, on the basis of such comments or
other relevant information, significant changes are proposed to be made to the remedy for the
Facility as proposed by EPA in this Statement of Basis, EPA will seek additional public
comments on any proposed revised remedy.
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Attachment 1
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I//47
. ' • V-8M
I SITE LOCATION Hi
Course FRENQfJ
/Cambridge Springs^
-¦ ENNSYLVANIA
1 HILOMETEB
quadrangle location
CAMBRIDGE SPRINGS, PA.. QUAD
SITE LOCATION MAP
LORD INDUSTRIAL PRODUCTS DIVISION
SCALE I: 24000
2
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Attachment 2
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AREA 1
AREA 4
EHSKE3SE
LORD MECHANICAL
PRODUCTS
AREA7
AREA3
40 80 120 160 200FT
LEGEND
FENCE
WATER
AREA 1 - WEST END DRUM STORAGE AREA
AREA 2 - EXTERIOR OF OIL/WATER
SEPARATOR BUILDING
AREA 3 - COMPRESSOR BL0WDOWN AREA
AREA A - PERIMETER OF THE METHYLENE
CHLORIDE TANK PAD
AREA 5 - FORMER LOCATION OF THE
SOLVENT OVERSPILL TANKS
AREA 6 - FORMER LOCATION OF THE FUEL
OIL STORAGE TANK
AREA 7 - FORMER LOCATION OF THE
IRON-PHOSPHATE CLEANING LINE
OVERSPILL TANKS
SWMUs - SOUD WASTE MANAGEMENT UNITS
AOCs - AREAS OF POTENTIAL CONCERN
SWMU» AND AOCi LOCATION MAP,
INITIAL CHARACTERIZATION INVESTIGATION
LORD MECHANICAL PRODUCTS DIVISION,
CAMBRIDGE SPRINGS, PENNSYLVANIA
DATE
14JUUB8
PROJECT MANAGER
D. B/UJCER
DRAHN6 NAME
BASE211
ARCADIS GERAGHTY&MILLER 1 R
mm
R. surrn
LEAD DESKN PROF.
CHECKED
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PROJECT NUMBER
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LEGEND
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FACILITY PLAN,
LORD MECHANICAL PRODUCTS DIVISION
CAMBRIDGE SPRINGS, PENNSYLVANIA
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Table 1
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ARCADIS
Table I, Historical Groundwater Elevation Data, Lord Corporation, Cambridge Springs, Pennsylvania.
5/28/03
4/23/04
6/25/04
8/27/04
10/28/04
4mm
6/22/05
msm
19*24/05
40M6
6/2606
8/28/06
10/30/06
PZ-1
1129.45
1130.10
1129.34
1129.11
1129.47
1129.89
1129121
1128.92
1129.01
1129.78
1129.09
1129.15
1133.38
PZ-2
1130.00
1130.54
1129.97
1129.70
1130.00
1130.51
1129.86
1129.62
1129.66
1131.19
1129.74
1129.70
1133.59
P2-3
1129.30
1130.90
1129.22
1128.97
1129.28
NMn»
1129.08
1128.76
1128.84
1129.43
1128.94
1128.87
Nlll»
P2-4
1129.88
1130.45
1129.88
1129.60
1129.%
MM"'
1129.79
1129.48
1129.52
1130.09
1129.62
1129.59
1133.53
PZ-5
1129.22
1129.82
1129.18
1128.94
112922
1129.63
1129.01
1128.69
1128.78
1129.35
1128.87
1128.76
1133.20
PZ-6
1129.37
1129.91
1129.49
1129.21
1129.43
1130.55
1129.33
1129.10
1129.16
1129.61
1129.24
1129.27
1132.13
MW-2D
1130.64
1131.21
1130.56
1130.32
1130.68
1131.10
1130.45
1130.26
1129.23
1130.83
1130.35
1130.32
1133.72
Note:
Elevation data collected from 5/28/03 was baseline data collected at the time the trees were planted.
NM(1): Elevation data could not be collected due to ongoing City of Cambridge Springs storm sewer work
Elevation data could not be collected die to well being submerged under water.
G.\PUBUC\LORD\Cauibrid^.* Sprmg> 2006\Tabkr 2 - Historical GW clcv.xis
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