UNITED STATUS
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
Expert Management Inc. (EMI)
River Road
Tamaqua, PA 18252
Formerly:
ICI Explosives USA. inc. (EIJSA)
LPA ID NO. PAD 071203046
And
ICI Americas, Inc. (ICI A)
LPA ID NO. PAD 000797928
Draft Statement of Basis
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I, Introduction,
The United States Environmental Protection Agenev ("EPA") is issuing this Statement of
Basis ("SB") to solicit public comment 011 FPA's determination that the properties formerly
known as 1C1 Americas. Inc. Facility (ICIA) and the IC1 Explosives USA. Inc. Facility (EUSA).
which were located on River Road in Tamaqua within Walker Township. West Peim Township
and Hast Brunswick Township in Schuylkill Count}'. Pennsylvania, have attained Corrective
Action Complete with Controls. The Facilities are subject to the requirement of performing
correctiv e action activities because they are subject to the provisions of the Solid Waste Disposal
Act. as amended by the Resource Conservation and Recover)' Act of 1976 ("RCRA"). and the
1 lazardous and Solid Waste Amendments of 19X4 {"I iSWA"). 42 \ I.S.C. 6901 - 6992.
Section 3013 of RCRA. 42 U.S.C. ^ 6934. requires facilities such as ICIA and EUSA to
investigate and clean up releases of hazardous wastes or hazardous constituents that have
occurred at their facility. I his Statement of Basis explains I'PA's preliminary determination that
ICIA and FUSA have fully investigated and properly cleaned up the f acilities, with continuing
groundwater monitoring at the ICIA facility under PADEP oversight.
A. EPA's Decision
In order to expedite imestigation. clean-up and potential resale of the property. IIUSA
was divided into several parcels: Corona. Wakefield. Project Riverdaie and an unnamed clean
parcel that had not been impacted by industrial activity. In addition, the ICIA facility is
commonly referred to as the Project Wood lawn Parcel.
Each of the four parcels, where historic industrial activ ity has taken place, has been
investigated and remediated (or is being remediated) to meet Pennsylvania's Non-Residential
Statewide Health Standards, site-specific risk-derived standards or Maximum Contaminant
Levels (MCLs) for soils, groundwater and surface water.
EPA's Final Decision includes institutional and engineering controls. FUSA and ICIA
must prov ide a restrictive deed notice for groundwater use and land use for all parcels. The
restrictive deed notice is to ensure that the land is to be used for only non-residential purposes,
and the groundwater is to be used only for non-potable and non-agricultural purposes. In
addition. EMi must continue to implement the groundwater monitoring program agreed to by
EPA. PADEP and EMI. This program is detailed in a September 17. 2003 letter from PADEP to
EMI. This program will he implemented by PADEP through a Consent Order which will he
issued subsequent to EPA's Final Decision.
As the Facilities operated under RCRA Interim Status until they shut down. EMI has
continuing RCRA clean-up obligations under both EPA and PADEP. PADEP's Consent Order
will address EMI's environmental obligations, including the on-going groundwater monitoring
program. Upon issuance of this Final Decision. EMI's RCRA Corrective Action obligations
with EPA will be completed.
Draft Suitcmem of Basis
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'I his proposal to designate the Facilities as Corrective Action Complete with Controls is
consistent with current EPA guidance entitled ""Final Guidance on Completion of Corrective
Action at RC'RA Facilities (February 25. 2003)."
B. Act 2 at EUSA - Corona and Wakefield
In April 2004. EPA Region III and the Commonwealth ol"Pennsylvania Department of
Environmental Protection ("PADEP") entered into a One Cleanup Program Memorandum of
Agreement ("MOA" or "Agreement") to. among other things, facilitate PADEP's
implementation of Pennsylvania's Voluntary Cleanup Program ("VCP") under the authority of
Act 2 and to promote the One Cleanup Program initialise by working together in a coordinated
manner to avoid duplication of effort at properties subject to RCRA and to ensure the
remediation of such properties in a timely fashion. The Agreement describes the circumstances
in which EPA will use Final Reports .submitted pursuant to the VCP of Act 2 to issue final
decisions regarding corrective action completions at certain facilities.
At two parcels on the EUSA Facility (Corona and Wakefield). PADEP has approved the
Final Reports submitted pursuant to Act 2. An Act 2 Release ofEiability has been provided to
I-USA for areas which ha\e been remediated, EPA. PADEP. and EUSA have worked together
throughout this process to ensure that the corrective actions performed bv El 'SA under the VCP
of Act 2. and the Final Reports submitted to PADEP documenting its actions, would provide the
information necessary for EPA to issue a final decision regarding corrective action completion at
the parcels.
EPA has reviewed the reports submitted to PADEP on behalf of EUSA pursuant to Act 2.
the PADEP letters of approval, the results of soil and groundwater sampling activities, historical
investigations and reports of remedial activities conducted at the parcels. As a result of this
review. EPA has determined that EUSA has met its RCRA Corrective Action obligations at the
two parcels, and that these parcels can be designated ""Corrective Action Complete with
Controls."
PADEP's approval of EUSA's Final Reports, include that EUSA provide a restrictive
deed notice for groundwater use and land use. The restrictive deed notice is to ensure that the
groundwater and the land are to he used only for non-residential purposes.
II. Facility Background
A, Ownership
The Tamaqua plant was originally built in 1906 by the Potts Powder Company to produce
dynamite and blasting powders. Atlas Powder ("Alias") was formed in 1912 as a result of an
antitrust suit by the United States against E. I. du Pont de Nemours Powder Company that forced
the breakup ol'du Pont's explosive business into three companies: DuPont. Hercules Powder and
Atlas. Alias bought the Potts Powder Company in I9i2 and expanded the Tamaqua plant to
Draft Statement of Basis
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make all grades of dynamite and detonators. The Tamaqua facility is sometimes called the
Reynolds facility.
In 191 X. Adas established the Reynolds Experimental Laboratory ("RXL") at Tamaqua.
This laboratory was established to develop explosive ingredients and firing devices.
Alias Powder changed its name to Atlas Chemical Industries Inc. in 1961. In 1971. Atlas
was merged into Imperial Chemical Industries and became ICI America. However, due to
antitrust objections to the merger raised by the United States. ICI America sold part of the
Tamaqua facility in 1973. approximately 2620 acres, consisting of the dynamite, nitroglycerin,
and blasting supplies businesses, to Tyler Industries, which formed a "new" Atlas Powder
Company. The remaining assets at Tamaqua. approximate!) 103 acres, comprised a portion of
the Aerospace Components Division, a subsidiary of Imperial Chemical Industries, and did
business as ICI America (the name change to ICI Americas occurred in 1977) or ICIA herein.
Imperial Chemical Industries PLC Group repurchased the explosives business from Tyler
in 1990 and established it as a wholly owned subsidiary. ICI Lxplosives USA. Inc. or LUSA
herein. In 2001. ICI Explosives USA Inc. changed its name to K-One Holdings and transferred
its assets, including the Tamaqua property, into a newly created subsidiary known as Lxpert
Management. Inc. (EMI). In 2003. ICIA was also consolidated under EMI. The total plant
property for Tamaqua was about 2.741 acres.
The ICIA and LI ¦ SA operations at Tamaqua ceased between 1996 and 1998. In order to
expedite investigation, clean-up and potential resale of the properly. LUSA was divided into four
parcels: Corona. Wakefield. Project Riverdale and an unnamed clean parcel that had not been
impacted by industrial activity. The ICIA proper!} is known as Project Wood I awn throughout
the document submissions. All of the property has been sold or transferred to other parties as
follows:
- In October 1 997. the nitroglycerin operations at LUSA. the "Corona" area comprising
about 662 acres, were sold to Copperhead Chemical (or "CCCI").
- Approximately 1490 acres of land that had nev er been affected by plant operations w ere
transferred to the Pennsylvania State Game Commission on December 1, 1998 (formerIv
LUSA).
- An additional 227 acres, the "Wakefield" area (formerly LUSA). was sold to
Copperhead Chemical on January 4. 1999.
- On December 17. 2004 EM! sold 103 remaining acres, designated as the "Project
Wood) awn" area of the property (formerly ICIA). and 259 acres designated as the
"Project Riverdale" area of the properly (formerly LUSA) to Bella Terra Farms LLC. an
adjacent property holder; this sale terminated LMLs land holdings in Pennsylvania.
Attachment A provides a map of current property ow nership.
Draft Statement of Basis
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B. Operation
EUSA and ICIA are located approximately live miles southwest of the Borough of
Tamaqua in Schuylkill County. Pennsylvania. The properties are primarily undeveloped and
mostly wooded with se\eral dirt or paved road. Surrounding properties are mostly rural.
Throughout their lives, the Facilities have been used for explosives fabrication as well as
loading, assembling, packaging and testing of the materials. The plants produced bombs,
torpedoes, starter cartridges, blasting caps, fuses and primers for private industry as well as
military applications. They also produced vasodilator drugs {nitroglycerin} for the medical
community. There was also an on-site wastewater treatment system that included evaporation
and treatment of explosive residues, the use of catch tanks, an oil recovery system and
neutralization. The Tamaqua plants also disposed of explosive wastes and waste solvents,
including bomb plant waste on-site. Explosive wastes were containerized and taken to the
several burning areas for disposal.
The plants shut down operations between 1996 and 1998. Most plant operations and
buildings on the Sites have been demolished and removed: the exception being the operations on
the Corona and Wakefield parcels that were sold to CCCL
A number of units that managed solid and hazardous wastes were identified in the RCRA
Facility Assessment (RFA) for each facility. These Solid Waste Management Units (SWMUs)
are listed in Attachment B, as well as their ultimate disposition.
HI Summary of the Environmental Investigation
The objectives of the Remedial Investigation activities were to evaluate environmental
conditions at the Facilities, to demonstrate attainment of Remediation Standards, to support a
petition for a Release of Liability from PADEP for Corona and Wakefield parcels, to receive a
Final Decision from EPA. and to achieve site closure. To achieve these objectives. ICIA and
EUSA completed a series of soil, groundw ater, and surface w ater investigations which included
sampling of monitoring wells, surface w ater sampling and sampling of soils in order to
demonstrate attainment of State Health Standards, MCEs. site specific standards and pathw ay
elimination for all media. As it was often not possible to determine whether the contamination
originated Irorn a RCRA-regulated unit or a pre-RCRA unit, and therefore whether PADEP or
EPA had primacy, the environmental investigation proceeded as a joint effort, with both agencies
approv ing the work. This work has been documented in numerous reports submitted to EPA and
PADEP and is found in EPA's Administrative Record.
Draft Suite muni of I3;tsis
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I\ Investigation Results
A. Soil Contamination
The site-wide remedial investigations began in the 1980's with assessment of the
SWMUs and other areas that may have been impacted by industrial activities.
Risk assessments were used for the Corona and Wake lie Id parcels to address the lead,
arsenic and mercury found in the soil, groundwater and surface water. Most samples that
exceeded Non-Residential Statewide Health Standards were still at relatively low concentrations.
The risk assessment for Wakefield showed that none of the Constituents of interest were at a
level of concern for non-residential uses of the properly. In addition, a site specific standard for
lead of 9600 mg/kg was approved by PADI'P for surface soils at the Corona parcel.
Most of the areas in Project Riverdale and Project Wood lawn were found not to exceed
the Non-Residenliai Statewide Health Standards for soils. The areas of the parcels found to
exceed Standards, and therefore requiring additional investigation, were primarily the burning
and disposal areas. These arc listed below:
1C1A -- Project Wood 1 au.ii
Open Burn Pit - AAP />* 16
Pit 1 - AOO
Match Comb Pile/Pit 2 - AAP ?•' 15/AOC
Bermed Test Exploding Area - AAP AOC A
Temporary Staging Areas A, B mid C - AOCs
f.mpt> Drum Storage Area - AAP *725
lit 'SA - Project Riverdale
Waste Pile - AOC'
Slurry Pits - USA f/29
Burning Ba\s- USA £28
Temporary Burning Grounds Staging Area- AOC
Cap Reject Pit - USA H3 i
Historic Pill Area -AOC
In 1999. 1CIA completed removal and disposal of all waste materials from Project
Woodlawn and excavation of soil hot spots which were identified by appearance of the surface
soils or historical data. At the same time. HUSA removed the slurry pits and most of the burning
areas on Project Riverdale. This overall removal effort culminated in 25.000 tons of soils being
taken off-site during the summer of 1999. The Open Burn Pit (ICIA) and the Burning Bays
(iThSA) required additional excavation for residual lead contamination.
During; this large-scale investigation/excavation several historic contaminated areas were
discovered. At Project Woodlawn. ICIA discovered a previously unknown waste management
unit, which was denoted Pit 1. It contained inert wastes and solvent contamination. Using
historical aerial photos. ICi subsequently dug test pits throughout the Project Woodlawn Area,
Pit 2 was encountered beneath Match Comb Pile and contained inert waste and other inorganic
debris. In addition, organic-contaminated soils were encountered at the Bermed Test exploding
Area. These new ly discovered areas were excavated and residual soils removed.
During the decommissioning of the Temporary Burning Bays on Project Riverdale.
IT :SA discovered that a Historic Fill Area nearby had significant concentrations of lead. Two
rounds of excavation have taken place to a depth of tw o feet below original grade. A report was
submitted on Januar\ 13. 2006. proposing that the lead contamination that remained was not of
Draft Statement of Basis
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concern. Based on predicted blood lead levels for three scenarios, PADHP agreed that no further
action was needed for the Historic [;ill Area on April 27. 2006.
Post excavation sampling for the units listed above were submitted to Mi1 A and PADHP.
Based on the comparison to the available Non-Residential Statewide I iealth Standards for soil
and approved risk assessments. HP A has determined that residual chemicals in soil do not pose a
threat to human health under an industrial land use scenario. The surface soil results attained
cither the Statewide I Iealth Standards or the site-specific standard for direct contact. Residual
subsurface contamination remains, however it is below the Statewide 1 Iealth Standards for direct
contact, i his subsurface residual is covered by at least 5 feet of soil, and therefore there is no
complete exposure pathway.
B. Groundwater Contamination
The groundwater investigation showed two distinct areas of contamination exceeding the
media clean-up goals: nitrate levels at (he slurry pits at KliSA; and VOC contamination at the
burning and disposal areas near the Open Burn Pit at 1CIA. The groundwater clean-up goals at
this site are MCI.s. which are health-based drinking water standards. 1 here are private wells in
the area used for potable purposes. Although none of the private wells are downgradient of the
plume. MCLs were agreed to be an appropriate remediation goal.
Groundwater - HI ISA
A characterization of groundwater quality at Project Riverdalc w as completed during the
facility-wide investigation. Nitrate in the groundwater near the Project Riverdalc slurn pits.
SWMU ft 29. was found to be the on!\ constituent above its MCL of 10 mg/l. Waste and
surrounding soils were removed from the unit in 1994.
Quarterly groundwater monitoring occurred between 1992 and 2001. Data from 1999
through 2001 showed the effect of the waste removal on groundwater quality. Results showed a
drop in nitrate levels from 68 mg'l at the end of 1 999 to I 3 mg'l one year later. HUSA applied
for an Alternate Concentration Limit (AO.) for nitrate in groundwater at the slurry pits, citing
the following:
1) The groundwater near this unit is not used for potable purposes and would not be in
the future due to its location and the use restriction placed in the deed.
2) I'he Kittle Schuylkill River is the only receptor of the groundwater. There is no
impact to the River, as shown by monitoring data upriver and downriver of the slurry pits
(1 mg/l vs. 1.1 mg/l).
3) Groundwater levels of nitrate have been consistently decreasing since the waste was
removed.
Draft SuiScmenl ofB;isis
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PADLP. with HP A agreement, approved a nitrate ACL of 130 mg/1 on October 22, 2001.
Groundwater monitoring at Project Riverdale was discontinued at that time. There is no
complete exposure pathway.
Groundwater - 1C1A
IC'IA had been pumping and treating the groundwater in the vicinity of the Project
Woodlawn burning and disposal areas: Open Burn Pit. Match Comb Pile. Bermed Test
Exploding Area, Pit I and Pit 2 since 1996. under a Groundwater Abatement Plan, which was
part of the 1986 PADER Consent Order and Agreement. These units were unlined areas where
hazardous wastes were either burned or managed in a waste pile. Investigations had shown
elevated levels of volatile organic constituents (VOCs) in the groundwater, primarily,
triehloroethene (TC'E). 1,1,1-trichloroelhane (1.1 J-TCA). and eis-1.2-diehloroethene (1.2-DCH).
In 1999. PADLP approved a trial shut-off of the pumping system in order to determine if
1) the system was effective in containing the plume in fractured bedrock. 2) natural
biodegradation of the organic contaminants w as occurring, and 3) monitored natural attenuation
was a viable remedial option. During the shut-off. an upgraded monitoring plan provided
monthly data on the groundwater quality for one year.
During the site-wide investigations, additional historic disposal areas were found. Eight
additional wells were added to the monitoring network to assess the impacts of all the disposal
units on groundwater. Two springs in the area and the Little Schuylkill River were also were
sampled to determine if the contamination was affecting surface water on the site. All disposal
areas and other areas of contamination were excavated and their wastes removed during a large-
scale removal effort in the summer of 1999.
A final report on the temporary shut-off was submitted in January 2001 and w as
evaluated b\ EPA and PADLP. This data showed that 1) the now shut-down pump-and-treat
system had likely not been containing the entire groundwater plume: 2) the plume size and
concentration diminished during the shut-down, most likely attributable to the removal of the
w aste materials from the disposal areas; and 3) there is evidence of natural biodegradation of
contaminants occurring. The data also showed that groundwater in the disposal areas is in
bedrock and Hows northwest, toward the Little Schuylkill River. The surface water investigation
showed no impacts to the springs or the River. The pump-and-treat system was subsequently
removed.
Subsequently. PADLP approved a red need-frequency monitoring program for 2001 and
2002. following this, the 1 aciiity submitted a proposal for future Monitored Natural Attenuation
based on the findings of the 2001/2002 monitoring program. This Monitored Natural
Attenuation plan has been approved b\ PADEP. and agreed to b\ EPA in a September 17. 2003
letter. Three on-site wells and one off-site well will be monitored on an annual basis. Every five
years, an additional six wells will be sampled for a more detailed view of the plume dynamics.
Currently, monitoring shows continuing reduction in contaminant concentrations.
Natural attenuation of the chlorinated compounds in the form of "reductive dechlorination" is the
Dniti Suuement of Uasis 8
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presumed means by which VOC concentrations arc decreasing. This is a process where
microbes utilize the chlorinated compounds as a food source, '['his in turn alters the VOC
structure and creates breakdown products. Review of the breakdown compounds such as 1.2-
DCK indicate the natural attenuation process is well established. In the location of the source
area, the breakdown product 1.2-DCL levels are substantially higher than the original source
material ot'TCFi.
Since the source area {MW08C) continues to show Tt'G and 1.2-DCK levels considerablv
above their MCLs of 5 ug/1 and 70 ug/l. respective!). the groundwater in this area is expected to
take significant time to achieve clean-up goals. The TCK concentration has fluctuated over the
years as site operations and later excavations were performed. In 1990. the TCL level was 2700
ug/l. It decreased to 361 ug/l alter excavation activities in 1999. and graduallv increased as the
excavations were filled in and the site returned to steady-state conditions. Currently. TCL
concentration is 940 ug/l in the source area. Continued monitoring is expected to show a gradual
decrease in concentration over the long-term.
During this same period. 1.2-DCI: concentrations show that biodegradation is taking
place at the source area. As it is not an original source contaminant, and is found as a breakdown
product, its increasingly high lev els indicate that natural dechlorination is occurring. After
excavation activities in 1999. 1.2-DCE concentration was 1260 ug/l at the source area. By 2006.
the concentration had increased to 2300 ug/l. Continued monitoring is expected to show
fluctuation in the concentration as the dechlorination process continues, with an eventual
decrease.
The TCI- concentration at the downgradient edge of the plume (MW20) has reduced from
82.1 ug/i in 1999 to 16 ug/l in 2006 and the 1.2-DCL concentration has decreased from 260 ug/l
to 120 ug/l in the same period of time, future monitoring is expected to show continued
decrease in concentration of both constituents.
For 1.1.1-TCA, the MCL of 200 ug/l has been achieved throughout the plume. In 1990.
the concentration was 600 ug/i in the source area. By 1999. it had decreased to 210 ug/l in this
area and since 2000. it has been below MCLs throughout the plume: the highest readme has been
138 ug/L.
Including the use of land use controls, an access agreement, an ACL and continued
monitoring, the H SA and ICIA Sites have attained compliance with RCRA Corrective Action
requirements for groundwater.
C. Surface Water
The Little Schuylkill River. Brushy Run. Stump Run and two on-site springs have been
monitored as part of the site-wide environmental investigation to evaluate whether groundwater
plumes were adversely impacting surface water qualitv. Data collected from the surface water
indicate no evidence of adverse impacts when compared to Pennsylvania's Water Qualitv
Criteria, when upstream and downstream data are compared, or through the Wakefield risk
Draft Statement of Basis
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assessment. The surface waters do not show any impact from potential groundwater discharges
to the surface water on the site. 1 here are no complete exposure pathways.
D. Off-site Groundwater
ICtA
Off-site contamination is occurring in two distinct areas. The properly to the north of
ICIA's Project Woodlawn disposal area has a small corner impacted by the 1CIA burning area
plume previously described in Section IV.B. Groundwater Contamination, above. In 1999, two
wells (MW24 and MW25) were placed on the property to tieilne the lateral extent ofthe plume.
There was an existing monitoring well from 199{) on this property that was used as a background
well. MW24 is being sampled on an annual basis, as part ofthe on-site monitoring program and
MW25 will be sampled even five years. Mistorieally. MW24 has shown levels of TCK slightly
above the MCL of 5 ug/i, in 1999. just after the excavation of source materials on-site, the TCK
level was 18 ug/1. In 2006. the concentration had decreased to 5.8 ug/1. MW25 has historicallv
shown concentrations near it's 2000 reading of 10 ug/1. Future monitoring is expected to show
decreasing concentrations in MW24 and MW25. This properh is zoned agricultural and the
owner does not use the groundwater, KMI current!) has an access agreement with the owners to
continue sampling and will maintain this agreement as long as groundwater monitoring is
required.
The area to the southeast of IC'IA is known as the C'lamtovvn Area. The proper! v
bordering IC1A. southeast ofthe Project Woodlawn disposal area has an on-site potable well
showing intermittent small detections of'ICE. but none above MCLs. IC'IA had placed a triple
carbon filtration system on the well, however the owners bypassed the svstem and (liters were
subsequently removed. A second well was used for potable purposes at a trailer on the proper!}'.
A triple carbon ilitration system was also placed on this well and bottled water provided for
drinking. The TCK level at this well reached 9.6 ug'l at a sampling port before the (liters, but
TCK was not detectable at the tap: there was no exposure to contaminants. Another was a pond
well which was to be used for lire lighting purposes but was never needed. Although the TCIi
level reached 30 ug/1. there was no exposure from groundwater at this well as it was not used for
any other purpose. Both of these w ells w ere closed using IZPA's well closing protocol in 2004.
There is no exposure to the residents from groundwater contamination. Although this property
appears side-gradient to the 1C1A disposal area, the Site is underlain fractured bedrock and
groundwater may have a secondary directional component.
Well MW19 is located in the far upgradient corner of the Project Woodlaw n parcel. The
data from this well shows groundwater quality of any groundwater How component toward the
Clamtown Area. MW19 has show n some hits of TCP. above MCLs, the highest being 41 ugl.
Currently, the TCK level is 3.2 ug/1. below the MCL. MW19 is part oflhe annual monitoring
well network, and acts as a sentry well for any groundwater flow ing toward Clamtown Area.
Based on the characteristics ofthe groundwater ilovv. the annual monitoring program and
data showing no potable wells are contaminated, future off-site exposure pathways are also
expected to be incomplete.
Draft Statement of Basis 10
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E. Ecological Screening
Chemical constituents detected on site in soil and groundwater are not considered to be at
le\els of ecological concern. An October 1999 Maeroinvertebrate Survey and Assessment lor
Brushy Run and the Little Schuylkill River was submitted by ICIA and E USA. It presents data
showing that that site activities have not affected the River and the Creek. Exposure pathways
are incomplete.
F. Final Reports
PADLP approved the final Reports submitted on behalf of iiUSA for the Corona and Wakefield
Parcels in September 1998 and January 2002. and, pursuant to Act 2. grunted EUSA a Release of
Liability for each parcel.
V. Control Activities
A, Soil
Complete exposure pathways to site soils do not exist at the Facility because the
contamination levels of the soil are below the Pennsylvania Non-Residential Statewide Health
Standards for direct contact, a site-specific risk-derived level, or are addressed through an
approved risk assessment. In addition, any residual subsurface contamination has been covered
by at least 3 feet of clean soil, further ensuring an incomplete pathway.
As an institutional control. ICI developed a set of land use restrictions for both IC1A and
EUSA properties. Only non-residential use of the properly is permitted, and disturbance of
subsurface must follow proper soils handling and disposal practices. I his Declaration of
Covenants and Restrictions has been agreed to by the new property owners for both the 1CSA and
i I SA Sites, and has been propcrh recorded in the deeds.
Compliance with RCRA Corrective Action requirements for soils has been attained with
the use of land use controls, risk assessments and site-specific clean-up levels.
B, Groundwater
Both engineering and institutional controls are ensuring an incomplete exposure pathway.
EMI is continuing to monitor the on-sile and off-site groundwater contamination to confirm that
the plume does not grow or move, and that the natural biodegradation activities further reduce
the toxicity of the contaminants. EMI will perform the groundwater monitoring activities in
accordance with PADEP's September 17. 2003 letter. Three on-site wells and one off-site well
will be monitored on an annual basis. Every five years, an additional six wells will be sampled
for a more detailed view of the plume dynamics.
ICI developed a set of groundwater use restrictions for both ICI A and LUSA properties.
Only non-potable and non-agricultural use of the groundwater is permitted. This Declaration of
Draft Statement of Uasis 11
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Covenants and Restrictions has been agreed to by the new proper!)' owners for both the iCIA and
EL'SA Sites, and has been properly recorded in Schuylkill County.
Including the use of land use controls, an access agreement, an ACL and continued
monitoring, the ELS A and ICiA Sites have atlaincd compliance with RCRA Corrective Action
requirements for groundwater.
VI. Action by EMI
To confirm that groundwater quality is improving. I-.Ml will continue to monitor
groundwater at the ICIA facility on an annual basis. KM1 will perform the groundwater
monitoring activities in accordance with PADEP's September 17. 2003 letter. The groundwater
sampling program will continue until MCLs are achieved. HMI mas1 submit a report to PADEP
to request termination of groundwater sampling, once sufficient data has been collected to show
that the remediation goals have been met.
EMI has already properly recorded the land use and groundwater use restrictions at the
time the parcels were sold or transferred to the new owners.
VII. Evaluation of Criteria
This section provides a description of the criteria EPA uses to evaluate proposed final
remedies under the Corrective Action Program. I he 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. LP A then evaluates seven balancing criteria
to determine which proposed remedy alternative provides the best relative combination of
attributes.
A. Threshold Criteria
1. Protection of! luman I lealth and the Environment
Numerous surface water sampling e\ents have not indicated any ev idence to suggest that
1 ittle Schuylkill River. Brush) Run or the two on-site springs have been negatively impacted
from groundwater discharges to the creek.
An evaluation of potential impacts to human and ecological receptors from the Sites
conditions was completed in accordance with all applicable and appropriate PADEP and EPA
rules and regulations.
The only possible exposure route to contaminated groundwater or soil at the Eacilities is
to workers taking environmental samples or to workers excavating soil at the facility. Therefore,
the deed notice restricts states that the subsurface soils throughout ihe Property should not be
disturbed or excavated unless proper materials handling and soil disposal practices are followed.
Draft Statement of Basis 12
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2. Achieve Media Cleanup Standards
Site investigations completed by 1C1A and HUSA demonstrate that lewis of metals such
as lead, antimony and mercury in soil are either below the Pennsylvania Non-Residential
Statewide Health Standards or site-specific risk-derived standards.
1 listoric groundwater data indicates that concentrations of" 1.1.1 -TCA at IC1A have
steadily declined and now the clean-up standard has been achieved throughout the plume.
Data also shows that concentrations of VOCs. such as TCI: and 1-2. DO: in groundwater
at 1C1A have steadily declined at the edges of the plume, although concentrations at the source
area have remained consistently high. HMI will continue to monitor the groundwater conditions
at the Site to ensure that groundwater quality continues to improve.
3, Control the Release(s)
Sampling results support the determination of lack of impacts to surface water from each
Sue s groundwater.
The facilities have filed a Declaration of Covenants and Restrictions with the deed to
each parcel of the Properties which provide notice that groundwater use of the properly is limited
to non-potable and non-agricultural purposes.
HPA. PADHP and HMI ha\e agreed on a continuing monitoring program for the Project
Woodlaun parcel groundwater which requires scheduled monitoring of specified wells. This
agreement was detailed in I'ADHP's September 1 7. 2003 letter, and addresses on-site and off-site
contamination. The monitoring program will he incorporated into a Consent Order issued bv
PADHP subsequent to HPA's final Decision for 1C1A and l:L'SA.
li. Balancing Criteria
Because the proposed reined) consists of measures which have already been either
completed or implemented, and because HPA is satisfied that the proposed remedy is protective
of human health and the environment. HPA is not choosing among alternative remedies.
'I"herefore, an evaluation of the balancing criteria is unnecessary. Nonetheless. HPA presents the
seven criteria below to illustrate the suitability of the proposed remedy:
1. Lonu-'l erm Reliability and Hffectiveness
flic facilities" investigations and remediation activities have addressed soil and
groundwater contamination at the Sites. PADHP will oversee the groundwater monitoring
activities and evaluate the continued effectiveness of ICIA's groundwater monitoring program.
HPA also considers the restrictions of on-site groundwater use and land use of the
property to non-residential purposes as long-term components of the control activities. Deed
notices have been llled with all property transfers and sales, providing for specified limited use
of the property.
Drafl Statement of Basis 13
-------
2. Reduction of Toxicity. Mobility, or Volume of Wastes
Unacceptable or complete exposure pathways do not exist at this facility. 1 his has
eliminated the potential for direct contact exposure and reduced the mobility of the contaminants
as well.
3. Short-Term Effectiveness
The short-term effectiveness of a remedy is related to the risks posed to the community
and workers involved in the design, construction and implementation of the remedy. The short-
term risks posed by the proposed remedy for the facility are minimal, as Site activities have
already been completed for the remed}1. Contamination is below established Statewide Health or
risk based standards and monitoring is expected to continue.
In addition, continued monitoring provides information regarding environmental
conditions and provides a basis for EMI to respond to changes in the future, if necessary.
4. Iroplementability
Implementability includes the technical and administrative feasibility of constructing and
operating the proposed remedy. The proposed remedy for the facilities is both technically and
administratively feasible. EMI has continuing RCRA obligations to both EPA and PADEP to
clean-up groundwater. The groundwater monitoring technology and protocol for 1(1 A are
already in place and have been agreed to PADEP. EPA and EMI. Further, a Consent Order
between PADEP and EMI. to be issued subsequent to EPA's Final Decision, will be the
instrument through which the continued groundwater monitoring system will be implemented.
EPA. PADEP and EMI agreed upon the well network and monitoring schedule and this was
documented in a September 17. 2003 letter from PADEP to EMI.
5- Cost
IC'IA and EUSA have already expended the capital costs involved in performing the
investigations and remedial activities necessary to meet non-residential standards for soils for
both Facilities and in implementing the proposed control activities at the ICIA Site. PADEP
requires a bond for the site, inclusive of the continued groundwater monitoring. EMI has
acquired a bond in the PADEP-approved amount of S325.O0O for 25 years of monitoring (2003-
2028).
6. Community Acceptance
EPA will provide public notice and an opportunity for comment to any interested parties
before this proposed decision becomes final.
Draft Statement of Basis
14
-------
7. State Acceptance
EPA's proposed determination that the 1CIA and El'SA Facilities are Corrective Action
Complete with Controls is based upon the activities performed by ICIA and IZUSA pursuant to
the requirements of RCRA and Corrective Action. ICIA and HUSA have met (or are meeting)
final cleanup goals, have assessed the entire facilities, and have addressed all releases, including
all SWMUs and AOC's. identified by PADHP and HPA.
PADHP has worked in concert with EPA throughout the investigation, remediation and
monitoring of the Sites. All data and reports have been submitted to and evaluated by both HPA
and PAPFP. Two parcels on the HUSA properly have entered into Pennsylvania's Act 2
Program. A 662-acre parcel. "Corona", received a Release of Liability on Septemberl). 1 Wo.
and a 227-aere parcel. "Wakefield", was issued a Release of Liability on January 3. 2002.
Subsequent to EPA's Final Decision. PADHP plans to issue a Consent Order which will
address the site environmental conditions and continued groundwater monitoring at ICIA Project
Wood lawn.
VIII, Environmental Indicators
FPA 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 thai groundwater contamination is '"under control". 1CTA and HUSA met the
human health indicator at their respective Facilities on October 05. 2001. EUSA met the
groundwater indicator on June 10. 2003. and ICIA met it on October 04, 2005. HPA believes
that these environmental indicators provide additional evidence that the actions completed and
proposed for iCA and HUSA have been effective and will protect human health and the
groundwater at the Facilities in the long-term.
IX. Public Participation
EPA is requesting comments from the public on ils determination that the Facilities are
Corrective Action Complete with Controls. On . HPA placed an announcement in the
local newspaper. . 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 Facilities. 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 HPA in writing to the address listed below, and anyone submitting comments
will receive a copy of the llnal decision and a eop\ of the response to comments.
A public meeting w ill be held upon request. Requests for a public meeting should be
made to Ms. Hiiula Matyskiela of the EPA Regional Office at the address listed below or at 215-
814-3420.
Draft Statement of Bnsis
15
-------
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: I.indn Matyskiela
Phone: 21 5-814-34205 fax: 215-814-3113
r>mai!:malyskieln.linda Y/ epa.gov
Following the thirty (30) day public comment period. PPA will prepare a final Decision
and Response to Comments in which it will identify the selected remedy for the Facilities. 1 he
Response to Comments w ill 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 remedies for
the facilities as proposed by I:PA in this Statement of Basis. F:PA will seek additional public
comments on any proposed revised remedy.
*
Draft Statement of Basis
16
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ATTACHMENT A
Facility Map
with
Property Boundaries
Drafl Statement ol" Basis
17
-------
Draft Statement of Basis
18
-------
ATTACHMENT B
SWMU List
for
ICIA and EUSA
Draft Statement of Basis
19
-------
Areas Identified in the respective RFA's of 1CI Americas inc. arid ICI Explosives USA, Inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
UNIT NAME
UNIT DESCRIPTION
DISPOSITION
STATUS
PAD071203046
Former IC! Explosives USA Inc.
USA-SWMU #1
Process Catch Tank #293, 2500 gallon
rectangular stainless steel tank with
containment basin. Used to evaporate liquids
accumulated from floor drains of dry houses
(removed), and rinsate of LMNR process. K044
/ K066 generation point.
Treated @ SWMU #28. ________
Process Catch tank #212, 375 gallon 3'
diameter x 5' deep. Used to evaporate liquids
accumulated from floor drains of the former
cap line. K044 / K066 (?) generation point.
Treated @ SWMU #28.
Eliminated with demolition
of structure (1999).
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #2
Eliminated with demolition
of the Cap Line (1992).
Flashed interior, and
recycled metal tank.
So:is addressed as
part of the site
Corrective Action
Program.
USA-SWMU #3
Process Catch Tank, baffled 4' x 3' x 5'
stainless steel, accumulated K044 / K046 (?)
from nitromannite production process for
treatment @ SWMU #28.
Shutdown in 1997,
demolished in 1998 with
building. Flashed interior,
and recycled metal basin.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #4
Acetone Recovery System, generated F003, Shutdown in 1997,
acetone still bottoms from nitromannite , demolished in 1998 with
production process. building. Flashed interior,
• and recycled metal basin.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #5
Nitromannite Neutralization Sump, 5,000 gallon . Shutdown in 1996,
brick lined basin used to neutralize acidic I demolished in 1997; all
nitration rinse waters. : debris shipped off-site to
permitted facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #6
Nitromannite Equalization Sump, 10,000 gallon
concrete basin used to regulate flow of liquid
from SWMU#5 to site NPDES permitted
treatment plant.
Shutdown in 1996,
demolished in 1997; all
debris shipped off-site to
permitted facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #7
Shelldraw Grit Chamber, 20' long by 2' wide by
1' deep trough used to screen grit from blasting
cap shell washing operation, lead into
SWMUfS.
Shutdown in 1992,
removed as part of
building demolition in
1993. All debris shipped
off site to permitted
facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #8
Shelldraw Oil Separator Basin, 3200 gallon
baffled oil 1 water separator. Generated oil for
reclamation. Tied into SWMU #11.
Shutdown in 1992,
removed as part of
building demolition in
1993. All debris shipped
off site to permitted
facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #9
Shelldraw Reaction Tank, 100 gallon tank with
mixer.
Shutdown in 1992,
removed as part of
building demolition in
1993. All debris shipped
off site to permitted
facility.
Soils addressed as
part of the site
Corrective Action
Program.
Draft Statement of Basis
20
-------
Areas Identified in the respective RFA's of ICI Americas Inc. and ICI Explosives USA, inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
! UNIT NAME
UNIT DESCRIPTION
DISPOSITION
STATUS
, PAD071203046
Former ICI Explosives USA Inc.
USA-SWMU #10
Shelldraw Flotation Tank, gallonage unknown, j Shutdown in 1992,
approximately 5' diameter by T deep. removed as part of
i building demolition in
! 1993. AM debris shipped
off site to permitted
: facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #11
Shelldraw Sludge Holding and Thickening Shutdown in 1992,
Tank, approximately 900 gallons. removed as part of
; building demolition in
: 1993. All debris shipped
5 off site to permitted
facility.
Soils addressed as
part of the site
Corrective Action
Program,
USA-SWMU #13
Wastewater Equalization Tank: inside building
992
Shutdown 1998
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #14
Neutralization Basin No.1: In Denization
Facility
Never managed or
released hazardous
waste.
Soils in area were
addressed as part of
the site Act 2
Program.
USA-SWMU #15 Neutralization Basin No.2: in Denization
Facility
Never managed or
released hazardous
waste.
Soils in area were
addressed as part of
the site Act 2
Program.
USA-SWMU #16
Sanitary Treatment Plant
Shutdown 1998 . Soils in area were
addressed as part of
the site Act 2
Program.
USA-SWMU #17
Drummed Hazardous Waste Storage Facility
Clean-closed under Soils in area were
PADEP addressed as part of
the site Act 2
; Program.
USA-SWMU #18
Emulsion Plant Wastewater Filter
Dismantled 1988 ' Soils addressed as
• part of the site
j Corrective Action
i Program,
USA-SWMU #19
Sodium Sulfonate Treatment Tank
Dismantled 1988 ; Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #20
Former Emulsion Wastewater Evaporat on
Holding Tank No.1 : 2500 gallon
Dismantled 1982
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #21
Former Emulsion Wastewater Evaporation
Holding Tank No.2 : 2500 gallon
Dismantled 1982
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #22
ARDL Pilot Plant Wastewater Holding Tank
No.1
Dismantled 1993
Soils addressed as
part of the site
Corrective Action
Program.
Draft Statement of Basis
21
-------
Areas Identified in the respective RFA's of IC1 Americas Inc. and ICI Explosives USA, Inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
UNIT NAME I UNIT DESCRIPTION DISPOSITION
STATUS
PAD071203046 j Former ICI Explosives USA Inc.
USA-SWMU #23
AROL Pilot Plant Wastewater Holding Tank
No.2
Dismantled 1993
' Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #24
Former ARDL Centrifuge System
Shutdown prior to 1960 Soils addressed as
part of the site
: Corrective Action
Program.
USA-SWMU #25
ARDL Wastewater Tank Trailer
Shutdown 1993
Soils addressed as
part of the site
Corrective Action
Program.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #26
Packaging Lab Wastewater Holding Tank
Shutdown unknown
USA-SWMU #27
Packaging Lab Wastewater Holding Truck
Shutdown prior to 1991 Soils addressed as
! part of the site
| Corrective Action
i Program.
USA-SWMU #28
Burning Grounds; RCRA regulated facility used
to thermally treat explosives and potentially
reactive materials. Consists of an area
approximately 600' in length by 150' wide, made
up of seven bays constructed of soil on three
sides each, with an approximate height of 5'.
Discontinued usage
(1999), excavated and
shipped 25,000 tons
of impacted soils off site
to TSDF.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #29
Slurry Pits; three 8' -10' wide pits,
approximately 7" - 8' deep by approximately 50'
- 60' in length. Pits contain emulsion residue.
Discontinued usage in the
1970's.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #30
Match Head Burning Area; 16' Song x 3" deep x
6" wide trough located south of building 669.
Matches with mononitroresorcinoi were burned
with oil.
Abated by excavation
prior to 1989 installation of
flood control berm.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #31
Cap Reject Pit, 4" x4' x 10' building with
approximately 4' of sand in floor where off spec
caps were initiated.
Demolished (1991), wastes
in soils were shipped to a
permitted facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #32
Empty Drum Storage Area
Removed between 1982 I Soils addressed as
and 1990. | part of the site
I Corrective Action
Program.
USA-SWMU #33
Drums of Oily Grit near Shelldraw.
Abated (1991) Drums Soils addressed as
shipped off-site to part of the site
permitted facility. Corrective Action
Program.
USA-SWMU #34
Drums of Reclaim Oil near Shelldraw. Abated
(1991)
Drums shipped off-site
to permitted facility.
Soils addressed as
part of the site
Corrective Action
Program,
Draft Statement of Basis
22
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Areas Identified In the respective RFA's of ICE Americas Inc. and IC1 Explosives USA, Inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
UNIT NAME
UNIT DESCRIPTION
DISPOSITION
STATUS
PAD071203046
Former ICI Explosives USA Inc.
USA-SWMU #35
Cap Reject Pit Waste Area- Abated (1991)
Surficial contamination
shipped off-site to a
permitted facility.
Soils addressed as
part of the site
Corrective Action
Program.
USA-SWMU #36
Recyclable Scrap Pile Area
Scrap salvaged (1991)
Soils addressed as
part of the site
Corrective Action
Program.
AOC
Historic Fill Area
Excavated and shipped off I Soils addressed as
site to a permitted part of the site
disposal facility s Corrective Action
. Program.
AOC
Temporary Burning Grounds Staging Area
Excavated and shipped off
site to a permitted
disposal facility
Soils addressed as
part of the site
Corrective Action
Program.
AOC
Waste Pile
Excavated and shipped off
site to a permitted
disposal facility
Soils addressed as
part of the site
Corrective Action
Program.
*SWMlJs #12, #37, #38, #39 listed in the RFA were later determined by EPA to be process tanks, not SWMUs.
~~Through agreement with PADEP, all ICI Explosives SWMUs retained the "USA-" designation throughout the
ownership changes.
Draft Statement of Basis
23
-------
Areas Identified in the respective RFA's of ICI Americas Inc. and IC1 Explosives USA, Inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
UNIT NAME
UNIT DESCRIPTION
DISPOSITION
STATUS
PAD000797928
Former ICI Americas Inc.
AAP-SWMU #1
Building 799, Reactives Accumulation Buckets
containing carbonated water for wet collection of
reactives containing wipes. Contents taken to
SWMU #6 for separation of solids from liquids.
Liquids taken to SWMU#8 or #9 for evaporation.
Solids taken to SWMU#18 for thermal destruction.
Eliminated with demolition
of building (1997). Buckets
were burned at SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #2
Building 917, Reactives Accumulation Buckets
containing carbonated water for wet collection of
reactives containing wipes. Contents taken to
SWMU #6 for separation of solids from liquids.
Liquids taken to SWMU#8 or #9 for evaporation.
Solids taken to SWMU#18 for thermal destruction.
Eliminated with demolition
of building (1996). Buckets
were burned at SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #3
Building 886, Reactives Accumulation Buckets
containing carbonated water for wet collection of
reactives containing wipes. Contents taken to
SWMU #6 for separation of solids from liquids.
Liquids taken to SWMU#7 for evaporation. Solids
taken to SWMU #18 for thermal destruction.
Eliminated by removal, as
part of a building
remodeling (1995).
Building demolished.
(1998). Buckets were
burned at SWMU # 18.
Soils in area were
addressed as part of
the site Act 2
Program.
AAP-SWMU #4
Building 992, Reactives Accumulation Buckets
containing carbonated water for wet collection of
reactives containing wipes. Contents taken to
SWMU #7 for separation of solids from liquids.
Liquids taken to SWMU#8 or #9 for evaporation.
Solids taken to SWMU #18 for thermal
destruction.
Eliminated with demolition
of building (1997). Buckets
were burned at SWMU#18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #5
Building 915, Reactives Accumulation Bucket
containing carbonated water for wet collection of
reactives containing wipes. Contents taken to
SWMU #7 for separation of solids from liquids.
Liquids taken to SWMU#12 or #14 for
evaporation. Solids taken to SWMU #18 for
thermal destruction.
Eliminated with demolition
of building (1997). Buckets
were burned at SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #6
Building 926 Reactives Screening Shed,
separated liquid from solid wastes. Liquids taken
to evaporator, solids taken to thermal treatment.
Eliminated with demolition
of building (1997). All
containers were burned at
SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #7
Building 886 Reactives Screening Shed,
separated liquid from solid wastes. Liquids taken
to evaporator, solids taken to thermal treatment.
Eliminated by removal as
part of a building
remodeling (1995),
Building demolished
(1999). Contents were
burned at SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU#8
Process Catch Tank #796
Eliminated with demolition
of building (1997). All
containers were burned at
SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
Draft Statement of Basis 24
-------
Areas Identified in the respective RFA's of ICI Americas Inc. and 1CI Explosives USA, Inc.
now known as Expert Management Inc. Tamaqua, Pennsylvania
UNIT NAME
PAD000797928
UNIT DESCRIPTION
DISPOSITION
STATUS
Former ICI Americas Inc.
AAP-SWMU #9
Process Catch Tank #787
Eliminated with demolition
of building (1997). All
containers were burned at
SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #10
Process Catch Tank #886, Vacuum Line System
Eliminated by removal as
part of a building
remodeling (1995).
Building demolished
(1999). Buckets were
burned at SWMU # 18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #11
Process Catch Tank #886
Eliminated by removal as
part of a building
remodeling (1995).
Building demolished
(1999), Buckets were
burned at SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU#12
Process Catch Tank #915A
Eliminated with demolition
of building (1997), All
containers were burned at
SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #13
Process Catch Tank #915B,
Eliminated with demolition
of building (1997). All
containers were burned at
SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #14
Process Catch Tank #922 j Eliminated with demolition
of building (1997). All
i containers were burned at
[ SWMU #18,
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #15
Former Match Comb Pile - Pit 2, an AOC was
found under this SWMU during site investigation
Excavated and shipped off
site to a permitted
disposal facility (1987).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #16
Open Burn Pit
Discontinued usage (1987)
wastes shipped 5,000 tons
of impacted soils off site
with waste from other
SWMU's in this area to a
permitted disposal facility
(1999).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #17
Detonator Burning Building i Eliminated with demolition
) of building (1997). All
: contents were burned at
: SWMU #18.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #18
Thermal Treatment WOK
Eliminated with demolition
of building (1998). All
contents were burned
prior to demolition,
inspected by PADEP, and
disposed of offsite at a
permitted facility.
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #19 I Former Thermal Treatment Facility Container
i Holding Area
I
| Soils addressed as
! part of the site
: Corrective Action
Draft Statement of Basis
25
-------
J i ¦ Program.
Areas Identified in the respective RFA's of ICI Americas inc. and ICI Explosives USA, Inc.
now known as Expert Management inc. Tamaqua, Pennsylvania
UNIT NAME
UNIT DESCRIPTION
DISPOSITION | STATUS
PAD000797928
Former ICI Americas Inc.
AAP-SWMU #20
Former Building 928, Waste Ash Drum Holding
Area
Soils addressed as
part of the site
Corrective Action
Program
AAP-SWMU #21
Magazines
Eliminated with demolition ; Soils addressed as
of building (1997). All i part of the site
containers were burned at Corrective Action
SWMU #18. Program.
AAP-SWMU #22
Building 2005, Waste Solvent Accumulation Cans
Eliminated with demolition , Soils addressed as
of building (1996). : part of the site
' Corrective Action
i Program.
AAP-SWMU #23
Building 2005 Waste Solvent Accumulation Shed
Eliminated with demolition
of building (1996).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #24
Former Temporary Storage Area
Eliminated with demolition
of building (1996).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #25
Former Empty Drum Storage Area - Pit 1, an AOC
was found adjacent to this SWMU during site
investigation
Eliminated by being sent
to a drum recycler / scrap
manager (1992).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-SWMU #26
Waste Oil Accumulation
Area Eliminated with
demolition of building
(1996).
Soils addressed as
part of the site
Corrective Action
Program.
AAP-AOC - A
Bermed Test Exploding Area - also know as
Product Device Testing Area
Ceased operations in the
1960's,
Soils addressed as
part of the site
Corrective Action
Program.
AAP-AOC-B
Test Exploding Barricade Area
Temporary testing
operation in 1989 only.
Soils addressed as
part of the site
Corrective Action
Program.
AOC
Pit 1
Excavated and shipped off
site to a permitted
disposal facility
Soils addressed as
part of the site
Corrective Action
Program.
AOC
Pit 2
Excavated and shipped off
site to a permitted
disposal facility
Soils addressed as
part of the site
Corrective Action
Program.
AOCs
Temporary Staging Areas A, B, and C
Soils addressed as
part of the site
Corrective Action
Program.
* "Through agreement with PADEP, all ICI Americas SWMUs retained the "USA-" designation throughout the
ownership changes.
Draft Statement of Basis
26
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