SDMS DocID 2214252
Superfund Program ^
prop«ed p„„
Price Battery Superfund Site ^pro^0
Operable Units 1 & 2
Hamburg, Pennsylvania July 2015
INTRODUCTION
I
The United States Environmental Protection Agency (EPA) is issuing this Proposed Remedial Action
Plan (Proposed Plan) to present EPA's Preferred Alternative for addressing soils, ground water and
sediment at the Price Battery Superfund Site (Site). EPA is the lead agency for the Site, and the
Pennsylvania Department of Environmental Protection (PADEP) is the support agency. This Proposed
Plan summarizes information from the remedial investigation and feasibility studies (RI/FS) conducted
for the Price Battery Site. The remedial investigation (RI) and feasibility study (FS) for the Facility
Portion of the Price Battery Site were completed in February 2011 and September 2013, respectively.
The Final Comprehensive RI Report for the Residential Portion of the Site was subsequently completed
in February 2014. EPA had previously issued an Interim Record of Decision (ROD) for the Residential
Portion of the Site on September 30,2009.
The Price Battery Superfund Site is located in the Borough of Hamburg, Berks County, Pennsylvania.
The Site was finalized on the National Priorities List (NPL) on April 27,2005. The National Superfund
Database Identification Number is PAN0Q0305679. The Price Battery Superfund Site includes the
former Price Battery manufacturing facility (Facility), adjacent residential areas, and other areas within
and near Hamburg, Pennsylvania that were contaminated with antimony, arsenic, and lead. The
geographic coordinates of the approximate center of the Site are 40.550 degrees north latitude and 75.98
degrees west longitude.
The Site has been organized by EPA into three separate Operable Units (OUs):
• Operable Unit One (OU-1): Residential Portion
• Operable Unit Two (OU-2): Facility Portion (Exide-owned properties)
• Operable Unit Three (OU-3): Site-Wide Ecological Assessment
In this Proposed Plan, EPA is proposing a final remedy for OU-1, Residential Portion. The remedial
actions identified in the interim remedy for OU-1, selected in the September 30,2009 Interim ROD were
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completed in 2013; therefore, EPA is now proposing No Further Action as the final remedy for OU-1.
This Proposed Plan also describes the final remedial alternative EPA prefers for addressing the Facility
Portion (i.e., Exide-owned properties) of OU-2 at the Site to address contaminated soils, sediment, and
ground water on and/or beneath these properties. The Preferred Alternatives for OU-2 described in this
Proposed Plan are consistent with removal actions and remedial actions already undertaken at the Price
Battery Site. OU-3 is not addressed in this Proposed Plan and will be the subject of a separate Proposed
Plan and ROD.
This Proposed Plan is being issued as part of EPA's public participation requirements under Section 117
of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended
(CERCLA), 42 U.S.C. § 9617, commonly known as Superfund, and Section 300.430(f)(2) of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR §300.430 (f)(2).
The public's comments will be considered and discussed in the Responsiveness Summary of the Record
of Decision, which will document EPA's Selected Remedy for OU-1 and OU-2 of the Price Battery Site.
This Proposed Plan summarizes information that can be found in greater detail in the RI/FS reports. The
RI/FS reports and other documents are contained in the Administrative Record for the Site. EPA
encourages the public to review these documents in order to gain a more comprehensive understanding
of the Site, and the Superfund activities that have been conducted to date at the Site. The Administrative
Record for the Site can be accessed at www.epa. eov/arweb: search "PA", search "Price Battery", search
"Remedial-01" and "Remedial-02" (which are all drop down menus).
The Administrative Record may also be viewed at the following locations:
U.S. EPA-Region III Docket Room Hamburg Public Library
Mr. Paul Van Reed 35 North Third Street
1650 Arch Street Hamburg, PA 19562
Philadelphia, PA 19103 (610)562-2843
(215) 814-3157
EPA's proposed remedial decision for OU-1, Residential Area soils is No Further Action. The remedial
actions selected in the September 2009 Interim ROD have been completed. EPA completed cleanup of
the Residential Portion of the Price Battery Site in October 2013. As the comprehensive RI for OU-1
progressed, EPA identified additional residential properties for cleanup, and EPA incoiporated these
properties into the residential remedial action that was ongoing pursuant to the September 2009 Interim
ROD for OU-1. EPA has completed the residential cleanup at all eligible properties whose owners
provided access. There are no known additional residential properties (for which owners provided
access) requiring cleanup. The September 2009 Interim ROD also provided for institutional controls
and ongoing public education regarding lead exposure risks. Therefore, because no additional cleanup
measures are necessary, EPA's preferred remedial decision for OU-1 is No Further Action, and to
establish the OU-1 interim remedy as the final remedy for the Price Battery Site OU-1, Residential
Portion.
The Preferred Alternative for OU-2, Facility Portion (i.e., Exide-owned properties of the Site) soils, is
Alternative S-4A. The Preferred Alternative is to excavate Principle Threat Waste (PTW) lead-
contaminated soils and soils exceeding the Remedial Action Level (RAL) cleanup levels for lead
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calculated specifically for the Exide-owned properties of the Price Battery Site. Contaminated soil
would be excavated to required cleanup levels, stabilized (on-site or off-site), and disposed of in an
approved off-site disposal facility. The resulting excavations would be backfilled with reclaimed
concrete and/or imported clean soils and graded for potential future commercial/industrial
redevelopment of the properties. The Preferred Alternative for sediment is SD-3. Contaminated
sediment in Kaercher Creek, on the Exide-owned properties, would be removed and the current gabion
mattress liner system reinforced to further stabilize the gabion mattress liner system. Underground pipes
currently containing contaminated sediment beneath the Facility would be cleaned out and grouted
closed to prevent any additional contamination from entering Kaercher Creek.
No Action is being proposed for ground water because isolated ground water contamination has been
determined not to be attributable to Site activities. Additional ground water monitoring wells would be
installed, and the monitoring well network on the Facility property would continue to be monitored to
insure there are no changes to the existing ground water conditions. Institutional controls would also be
implemented on the Exide-owned properties of the Site to prohibit residential use of the Site and set
forth any additional requirements for future redevelopment of the properties. The estimated cost of the
Preferred Remedy is $ 3,222,823
This Proposed Plan identifies EPA's preferred remedial decision for OU-1 and alternatives forOU-2,
and no final decision has been made. EPA may modify the preference; select other response actions, or
develop other alternatives based on comments received during this period. EPA, in consultation with
PADEP, will announce the selection of remedies for OU-1 and OU-2 at this Site in a Record of
Decision. EPA is issuing this Proposed Plan as part of its public participation responsibilities under
Section 300.430(f)(2) of the NCP. This Proposed Plan fulfills the public notification requirements of
CERCLA Sections 113(k)(2)(B), 117(a), and 121(f)(1)(G), 42 U.S.C. §§ 9613(k)(2)(B), 9617(a), and
9621(f)(1)(G).
Comments may be submitted to EPA in writing or emailed to:
John Banks (3HS22) Larry Johnson (3HS52)
Remedial Project Manager Community Involvement Coordinator
US EPA Region III US EPA Region III
1650 Arch Street 1650 Arch Street
Philadelphia, PA 19103 Philadelphia, PA 19103
banks.iohn-d@epa.gov i ohnson.larrv-c@epa. gov
SITE BACKGROUND
Physical Characteristics and Land Use
The Price Battery Superfund Site is located approximately 20 miles north of the City of Reading, in the
central to southern portion of the Borough of Hamburg, Berks County, Pennsylvania (Figure 1). The
Borough of Hamburg is located at the foot of the Blue Mountains, along the Schuylkill River, just south
of Schuylkill County. The Price Battery Superfund Site includes the former Price Battery
manufacturing facility, adjacent residential areas, and other areas within and near Hamburg,
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Pennsylvania that were contaminated with antimony, arsenic, and lead. The Site is within a mixed
commercial/industrial/residential area which is approximately 1.2 square miles in size. The
commercial/industrial land makes up the minority of the area. The Price Battery facility is zoned
industrial, and the residential properties are located north, northwest, northeast, east, southeast, and
south of the former Facility. Based on the 2010 U.S. Census data (County of Berks 2013) the total
population of Berks County is 411,442 people and consists of 164,827 households. The total population
of the Borough of Hamburg is 4,289 people and consists of 2,019 households. The land use in the
immediate area outside of the Price Battery Site is mostly residential or agricultural. Commercial
properties make up the minority of the adjacent property area.
The former Price Battery facility is located at 246 and 251 Grand Street in the Borough of Hamburg.
Kaercher Creek flows through the Borough of Hamburg and through the former Price Battery facility
before joining the Schuylkill River located to the southwest of Hamburg. The former Price Battery
facility, including all Exide-owned properties, covers approximately nine acres of land in the Borough.
The Exide-owned properties (Facility Portion) include the following: Warehouse Parcel, Broom Works
Parcel, Main Parcel, and Parking Lot (Figure 2).
History of Activities that Led to Contamination
Price Battery Corporation (Price Battery) was founded in 1918 and has occupied at least a portion of its
current location since its inception. The Price Battery facility is currently not in operation. The Facility
formerly consisted of three large manufacturing buildings (east building, west building, and the oxide
department), including a secondary lead smelter [Main Parcel]; a one-quarter-acre lot located between
Peach Alley and Third Street [Parking Lot]; a one-acre plot of land located between Walnut and Pine
Streets [Broom Works Parcel] ; and a large warehouse and parking lot located on a parcel to the west of
Second Street [Warehouse Parcel]. The secondary lead smelter ceased operation in 1971. The majority
of the buildings, except the warehouse building, were demolished in 2007 and 2008. Since the
demolition of the buildings on the Main Parcel, the Main Parcel is currently covered with the former
building floors and foundations, concrete, and bituminous pavement. A chain link fence encompasses
the entire boundary of the Main Parcel. All four parcels are shown in Figure 2.
The former east building contained a battery storage room, a warehouse room, a loading dock, north and
central dry formation rooms, a plate drying room, a plate storage room, a lead oxide pasting area, a
battery assembly area, a grid-casting room, and a laboratory. Interior walls had been degraded by acid
corrosion and damaged by heavy equipment in several areas. Several 55-gallon drums, sumps, and
trenches containing various materials were formerly located in this building. The former west building
consisted of a warehouse room, a loading dock, a wet formation area, a finishing room, and an
enveloping room. Drums were formerly located in the enveloping area and the wet formation area.
Trenches were located in the wet formation area and the finishing room.
The Warehouse Parcel is situated on an approximate 3.12-acre parcel of land west of Second Street and
consists of a 30,000-square-foot steel-frame warehouse constructed in the early 1980's and a parking lot
which still remain on the property. The warehouse is the only building on the Exide-owned properties.
The parking lot area, which lies south of the warehouse, is covered primarily with asphalt and partially
by gravel. Historical maps indicate that portions of this area were once the boat basin of the Hamburg
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section of the Schuylkill Navigation Canal. Aside from the storage of products and materials for the
manufacturing operations, which occurred on the Main Parcel, no other activities are known to have
been performed at the Warehouse Parcel. The warehouse was used for document and equipment
storage, and a nearby business had been granted permission to utilize the paved areas in front of the
building for temporary staging of equipment.
From the 1940s to approximately February 1956, Price Battery owned and operated the lead battery
recycling and manufacturing facility located at 246 and 251 Grand Street in Hamburg, Pennsylvania. As
part of the battery recycling process, Price Battery also owned and operated a secondary lead smelter at
the Facility. The Facility recycled lead-acid batteries and also produced approximately 15,000 new
batteries per year. New batteries from the Price Battery facility were delivered to customers, and junk
batteries were brought back to the Price Battery facility for recycling. Employees at the Price Battery
facility split open the used batteries at the smelter at the Facility and reused the lead plates from the junk
batteries in the smelter. Price Battery reused only the lead plates from the batteries. The rest of the
battery was considered to be waste and was stored in a dump truck. The waste consisted of asphalt, hard
rubber, and plastic casing that may have been contaminated with lead. The bottom of the junk battery
casings normally contained a lead residue that had settled to the bottom of the battery casing during the
battery's lifetime. This residue resulted from the lead oxide and acid that had been placed in the battery
as it was being manufactured. When the dump truck was full of waste battery casings, Price Battery
employees drove the truck to various locations in and around Hamburg to dump the waste battery
casings. Waste battery casings were also made available for people to pick up from the Facility for use
as fill.
Noxious odors and acid fumes were reportedly emitted from the Price Battery facility. In 1941, a
citizens' group contacted the Borough of Hamburg with concerns about the Facility's operations. The
group's legal counsel indicated that smoke stacks on the Facility emitted lead-contaminated ash
produced during the melting of old batteries.
From the 1940s until approximately 1961, Price Battery contracted with Blue Mountain Coal
Company (Blue Mountain) to compact battery casing waste after it was dumped in and around Hamburg
and t© remove slag from the Price Battery facility. The slag was left over from the lead smelting
operations at the Facility. Blue Mountain dumped the slag at the locations in Hamburg where Price
Battery had dumped the battery casings. Beginning in the early 1960s, Price Battery entered into an
agreement with Brown's Battery (Brown's) to send junk batteries that were returned from Price Battery's
customers to the Brown's breaking facility located in Shoemakersville, Pennsylvania. Brown's broke
open the junk batteries and removed the lead plates for return to the smelter at the Price Battery facility,
where the lead plates were reused.
In 1956, General Battery Corporation (General Battery) acquired the Facility from Price Battery.
General Battery continued Price Battery's battery-making operations at the Facility, making the same
products and using the same equipment until 1971, when General Battery closed its smelter operation. In
1987, General Battery merged into Exide Technologies Inc. (Exide). Exide has been held as a corporate
successor-in-interest to General Battery Corporation. Exide ceased manufacturing at the Site in 1995.
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Enforcement History
EPA has identified Exide as a potentially responsible party (PRP) at this Site. Exide filed for bankruptcy
in 2002, and EPA filed a proof of claim in that bankruptcy for several sites, including the Price Battery
Site. Given the nature of the bankruptcy proceeding, EPA did not seek to have Exide conduct the
cleanup on residential properties addressed by the 2009 Interim ROD (i.e., properties that are not owned
by Exide). However, Exide and EPA executed an Administrative Order on Consent (AOG) on May 30,
2007, under Section 104 of CERCLA, for Exide to perform a RI/FS (RI/FS AOC) of all Exide-owned
properties. Exide filed for bankmptcy again in 2013, and EPA has filed a subsequent claim against
Exide to, among other things, ensure Exide completes its cleanup obligation at the Exide-owned
properties.
History of Previous Environmental Investigations
Exide Removal Actions
EPA conducted removal assessment activities at the Price Battery facility from July through October
2002. The assessment included multi-media sampling, test pit excavations, monitoring well installation,
and x-ray fluorescence (XRF) analysis. Based on EPA sampling results, the Price Battery facility was
found to be heavily contaminated with lead, arsenic, and antimony. On June 23,2003, pursuant to
Section 106 of CERCLA, EPA entered into an AOC with Exide to perform a removal action (Removal
AOC) at the Price Battery facility including restricting access to the Price Battery facility and mitigating
the threat due to the presence of hazardous substances, among other things. Under the Removal AOC,
Exide capped soils on the Broom Works Parcel, paved previously unpaved areas on the Warehouse
Parcel, capped sediments in Kaercher Creek on the Main Parcel, and removed waste materials from the
Facility including from within any sumps or trenches. A more detailed description is provided below:
Broom Works Parcel Capping: Pursuant to the Removal AOC, Exide was required to mitigate the threat
of direct exposure to lead contamination greater than 1,000 parts per million (ppm) within any fenced
area. Since surface soils on the Broom Works Parcel contained total lead concentrations as high as
120,000 ppm, the Broom Works Parcel soils were capped, and the parcel was fenced. The cap consisted
of a non-woven geotextile installed over a smoothly graded and compacted soil subgrade and covered by
8 inches of crushed stone.
Kaercher Creek Sediment Capping: Exide capped sediments in Kaercher Creek within the property
boundary of the Main Parcel. Total lead concentrations detected in the sediments ranged from 4,867
ppm to 24,090 ppm. The cap consisted of approximately 6,500 square feet of 6-inch thick gabion
mattresses grouted in place to ensure stability.
Main Parcel Building Cleanout: This process included the pumping and removal of liquid and solid
residual waste materials from the Facility sumps, pits, and trenches. After removal of the residual waste
materials, the sumps, pits, and trenches were cleaned until their surfaces were visually absent of waste,
dirt, or sediment. The areas were subsequently backfilled with stone and capped with 4 to 6 inches of
concrete. Liquid and solid wastes were transported off-site for disposal.
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Institutional Controls: A Declaration of Use and Deed Restriction (Deed Restriction) was placed on all
of the Exide-owned parcels in 2004 as required by the November 12, 2002 Removal Action
Memorandum and the Removal AOC. Among other things, the Deed Restriction prohibited use. of the
Exide properties for residential, recreational, schools, day care facilities, or other uses which could
potentially expose children to contamination.
Building Decontamination and Demolition: Although not a specific requirement of the Removal AOC,
Exide had the existing buildings on the Main Parcel decontaminated and demolished to grade in the
summer and fall of 2007. The decontamination and demolition activities consisted of steam
cleaning/pressure washing all remaining equipment and structural components to remove visual
contamination pursuant to the requirements of the Resource Conservation and Recovery Act (RCRA)
"Debris Rule" codified at 40 CFR §268.45. Following decontamination, the buildings were demolished,
and the demolition debris was segregated for off-site disposal or recycling, as appropriate. The
remaining floor slabs and paved surfaces of the Main Parcel were swept and pressure washed.
EPA Removal Actions
A separate EPA removal action began on May 12,2003, to address residential properties contaminated
with lead in the vicinity of the former Price Battery facility. From May 2003 through October 2004, this
removal action entailed the excavation of residential soils contaminated with lead above 400 ppm from
residential yards and the decontamination of residential interiors. An action level for lead dust on floors
of 40 micrograms per square foot (jig/ft2) was used for interior decontamination consistent with EPA
regulations for lead-based paint abatement. In the absence of a site-specific cleanup level for lead-in-
soil at the commencement of the removal actions, EPA conservatively used the 400 ppm screening level
for lead-in-soil at residential properties as the cleanup level in order to start work as quickly as possible
until a residential site-specific lead-in-soil cleanup level was determined for the Price Battery Site,
Residential Portion.
During the course of EPA's 2004 removal activities, EPA collected additional information in order to
develop a risk assessment and calculate a residential site-specific cleanup level for lead-in-soil that
would be protective of children who might be exposed to lead contamination in the soils. This site-
specific risk assessment ultimately established a residential cleanup level for lead-in-soil of 572 ppm.
Beginning in April 2005, the removal action entailed the excavation of lead-contaminated soils above
572 ppm for lead to "clean" soil (lead soil levels below 572 ppm), unless physical barriers such as tree
roots, foundations, etc., prohibited excavation of soils to "clean". In such cases where all lead-
contaminated soil above 572 ppm could not be removed, a visual barrier (i.e., orange construction
fencing) was placed to indicate the remaining soils potentially contained lead above 572 ppm. The
removal action was completed on September 30, 2010, and thereafter, EPA utilized its remedial
authority, pursuant to the 2009 Interim ROD for OU-1, for the remediation of the remaining residential
properties.
Remedial Response
EPA divided the Price Battery Superfund Site into three operable units (OUs). OU-1 addresses lead-
contaminated-residential soils and interiors within and near the Borough of Hamburg; OU-2 addresses
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the Facility Portions of the Price Battery Site (i.e., the Exide owned properties); and OU-3 is a site-wide
ecological assessment. These OUs and actions taken are further discussed below.
Operable Unit One (OU-1) — Residential Portion
Beginning in 2005, and concurrent with the ongoing residential removal actions described above, EPA
also initiated a RI/FS for OU-1 to determine the full nature and extent of residential contamination at the
Site, to characterize the risks to human health and the environment, and to evaluate alternatives to clean
up the residential contamination. The initial findings of the RI/FS are presented in an Interim Remedial
Investigation Report for OU-1 (February 2009) and Interim Feasibility Study Report (May 2009) and are
documented in an Interim ROD for OU-1, dated September 30,2009.
The selected remedy in the Interim ROD entailed residential exterior soil excavation and specialized
interior cleaning to remove lead-contaminated soils and dust at impacted residential properties,
consistent with the ongoing EPA removal action at the time. The Interim ROD authorized work to be
performed under remedial authority, instead of removal authority, and enabled EPA to continue to
address immediate Site risks while additional work was performed to determine the full nature and
extent of residential contamination at the Site. The cleanup of residential properties was completed by
EPA in October 2013. The Final Comprehensive RI Report detailing the full nature and extent of the
residential contamination and documenting EPA's sampling and cleanup efforts was finalized in
February 2014. Cleanup at all known contaminated residential properties, whose owners provided
access to EPA for cleanup, has been completed. EPA demobilized from the Site in October 2013 after
the completion of the residential cleanup.
Operable Unit Two (OU-2) - Facility Portion
OU-2 addresses all Exide-owned properties within the Borough of Hamburg, including ground water
below the properties, which includes the Main Parcel (Facility property), Warehouse Parcel, Broom
Works Parcel, and Parking Area. On May 30,2007, EPA entered into an RI/FS AOC with Exide to
perform the OU-2 RI/FS. Exide made the determination to demolish the buildings on the Main Parcel.
Pursuant to the AOC, Exide was to initiate the RI/FS after demolition activities were completed. Exide
began demolition activities in June 2007 and completed demolition and debris disposal in early 2008.
Exide began the RI/FS fieldwork pursuant to the May 30,2007 RI/FS AOC in September 2008. The RI
was completed in February 2011, followed by the FS in September 2013.
Operable Unit Three (OU-3) - Ecological Assessment
OU-3 addresses potential ecological risks associated with former operation of the Price Battery facility
with the focus being the investigation of Mill Creek, Kaercher Creek, and the Schuylkill River. The
OU-3 RI is currently being performed by EPA and will be the subject of a separate Proposed Plan and
ROD when completed.
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SITE CHARACTERISTICS
Operable Unit One (OU-1) - Residential Portion
The primary objectives of the OU-1 RI were to determine the extent of residential lead contamination
due to lead battery manufacturing and smelting activities at the former Price Battery facility.
Subsequent to the completion of the interim RI/FS in 2009, the aerial extent of the Residential Portion of
the Site was expanded and additional residential sampling was conducted to define the full extent of
residential contamination. It became clear during the interim RI/FS that contamination extended beyond
the original estimated boundaries of the Site. The interim approach was used to convert the ongoing
cleanup from removal authority to remedial authority as quickly as possible while additional sampling
continued to further define the boundaries. Ultimately, the full aerial extent of contamination from
deposition of lead dust from the former Price Battery facility encompassed an approximate 1.2-square
mile area comprised of the following locations (Figure 3):
• A large area east of the Schuylkill River, bounded by Girard Avenue, Mulberry Alley, and Port
Clinton Avenue to the north; Front Street, PA Route 61, and the Schuylkill River to the west;
Hawk Ridge Drive to the south; and Kaercher Creek Park and some properties east of the
Hamburg Borough in Windsor Township to the west;
• A small eastern area, along Windsor Castle Road; and
• An area west of the Schuylkill River primarily along West State Street and Diamond Drive in
Tilden Township.
EPA believes these areas represent the full extent of aerial lead deposition from the Price Battery facility
operations. Because EPA suspected that the source of lead contamination in the outer fringes of this
area may not be attributable to deposition of air-borne particulates from the former smelter (based on
previous air modeling conducted during the Interim RI), alternate source contributions to the lead
contamination in these fringe areas were investigated in two additional studies. These studies included a
lead-based paint (LBP) assessment of residential homes and a lead speciation study performed by EPA's
National Enforcement Investigation Center (NEIC). The results of the LBP assessment and the NEIC
lead speciation study are included in the Administrative Record for the Site.
The general conclusion of these studies was that properties in the northernmost and westernmost fringe
areas of the OU-1 portion of the Site were impacted, at least partially, by air-borne deposition of lead
particulates. NEIC determined that potentially between 16 percent and 33 percent of the lead in the
northernmost properties was likely from the battery smelter emissions. EPA determined that, although
this contribution was small, as a conservative approach, these properties would nonetheless be eligible
for remedial action. However, based on these results, EPA did not expand its investigation any further
beyond these, properties. EPA believes the lateral extent of lead in surface soil primarily due to smelter
operations has been determined.
In total 6,467 surface soil samples were collected from 1,145 properties, 449 subsurface soil samples
were collected from 160 properties, and 4,934 dust samples were collected from 500 houses during the
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OU-1 RI. EPA has completed significant cleanup of lead-contaminated soil and interior dust at
residential properties within the Borough of Hamburg and adjacent areas utilizing both removal and
remedial cleanup authorities. As of September 12,2013, EPA had conducted cleanups at 555 residential
property exteriors. This is 92 percent of all known contaminated residential properties where lead
concentrations were above the lead preliminary remediation goal (PRG) of 572 ppm in residential soil.
Similarly, EPA had conducted removal and remedial actions that cleaned the interiors at 402 residential
properties. This is 81 percent of the homes identified as having lead-contaminated indoor dust above the
hazard level of 40 jag/ft2 for lead dust on floors. The remaining properties with lead contamination were
not made accessible to EPA. No additional properties are scheduled for cleanup. EPA completed the
remedial action for OU-1 in October 2013.
Operable Unit Two (OU-2) - Facility Portion
Exide conducted the OU-2 RI/FS for the Exide-owned portions of the Price Battery Superfund Site. The
OU-2 RI was conducted in two phases (Phase I and Phase II) aiid consisted of multimedia sampling
intending soils, sediments, and ground water. A Baseline Human Health Risk Assessment (BHHRA)
and a Screening Level Ecological Risk Assessment (SLERA) were also completed as part of the OU-2
RI/FS. A summary of the findings of these investigations is provided below.
OU-2 Geology and Site Soils
The bedrock in the area of the Price Battery Site consists of the Ordivician Hamburg Sequence
formation, which consists predominately of gray, greenish-gray, purple, and maroon shale, siltstone, and
greywacke. The shallow soils beneath the majority of the Main Parcel and all of the Broom Works
Parcel and Parking Lot are "made land" consisting of soils derived from miscellaneous shales and
sandstone materials. The western edge of the Main Parcel and the Warehouse Parcel is underlain by the
Philo Silt, which is associated with the floodplairi deposits of the Schuylkill River. Previous Site
investigations have identified additional types of fill containing cinders and ash believed to be derived
from coal-fired furnaces and steam engines, cinders and stone fill placed by the railroad as ballast within
the railroad right-of-way, and zones of fill containing varying amounts of battery casings and slag.
Soil samples from on-site soil borings were collected on each of the four Exide-owned properties and
analyzed for lead, arsenic, and antimony with a subset of the soil samples also analyzed for the full
target analyte list (TAL) metals, volatile organic compounds (VOCs), semivolatile organic compounds
(SVOCs), total petroleum hydrocarbons (TPH), and polychlorinated biphenyls (PCBs). In general, soil
borings were completed to a depth of 12 feet below ground surface (bgs) or 4 feet below the native
soil/fill interface, whichever was deeper; and samples were collected from various depths within that
range. Table 1 summarizes the occurrence of the most commonly detected contaminants in the fill
during the OU-2 RI.
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Table 1: Soil Contaminant Detections
Parcel
Samples/Detections
Low (ppm)
High (ppm)
Mean (ppm)
Antimony
Main
109/106
0.18
14,300
335.5
Arsenic
Main
109/109
1.9
4.530
53.1
Lead
Main
109/109
9.8
125,000
7,435
PAHs**
Main
8/12
0.09
189.4
16.2
Antimony
Warehouse
30/30
0.13
447
88.3
Arsenic
Warehouse
30/30
2.6
68
14.5
Lead
Warehouse
30/30
26.5
32,000
6,892
PAHs**
Warehouse
5/5
0.78
9.50
5.25
Antimony
Broom Works
23/23
0.7
119
15.0
Arsenic
Broom Works
23/23
1.2
26.4
11.4
Lead
Broom Works
23/23
14.1
2,280
524.8
PAHs**
Broom Works
3/3
2.29
10.9
6.00
Antimony
Parking Lot
13/13
0.95
10.2
2.90
Arsenic
Parking Lot
13/13
3.6
80.2
25.5
Lead
Parking Lot
13/13
11.9
1,210
258.6
PAHs**
Parking Lot
3/3
0.64
21.1
11.8
PAHs = Polycyclic Aromatic Hydrocarbons
** Sum of individual PAH concentrations detected
Consistent with previous investigations, soil borings encountered a layer of fill material immediately
beneath the pavement of the floor slabs of the Main Parcel. The thickness of the fill material
encountered on the Main Parcel during the OU-2 RI varied from 1.5 to 7.5 feet. Native soils
encountered beneath the fill were comprised of a gray to brown silt with varying amounts of clay and/or
sand and, generally, did not exhibit impacts from historic Site operations, although some specific
impacts were noted.
In general, analytical results for shallow fill that post-dates commencement of manufacturing operations
at the Price Battery facility shows elevated concentrations of lead, arsenic, and occasionally antimony.
The occurrence of lead, antimony, and arsenic at the high concentrations observed at the Site is linked to
the soil fill materials (often containing slag and/or battery casings), surficial deposits believed to be the
result of fugitive dust, and/or the management of lead-bearing wastes on the ground surface.
Shallow fill that predates manufacturing operations is generally lacking in inorganic constituents above
the residential soil screening levels but did contain elevated concentrations of polycyclic aromatic
hydrocarbons (PAHs). PAHs are a broad range of organic compounds resulting from the incomplete
combustion of fossil fuels, including coal. The PAHs occur in fill material comprised of cinders and ash
believed to be utilized for construction of the railroad bed and minor filling, and do not appear to be
related to past battery manufacturing operations. Coal ash and cinders are fairly ubiquitous in the area
and also were found in multiple residential yards during the OU-1 residential cleanup. PAHs were
found in 100% of the fill samples analyzed for PAHs on the Broom Works Parcel (a former railroad
right-of-way north of the Main Parcel) and the Parking Lot Parcel (a residential parcel east of the Main
Parcel). Neither the Broom Works Parcel nor Parking Lot Parcel were ever subject to site
manufacturing operations. On the Main Parcel, there is no correlation between elevated lead
concentrations in soil and elevated PAH concentrations in soil.
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VOC results identified elevated levels of benzene, toluene, ethylbenzene, and xylene (BTEX
compounds) in the southeast corner of the Main Parcel. These soils occur in the vicinity of a former
gasoline underground storage tank (UST) and will be addressed outside the context of the CERCLA
remedial action contemplated in this Proposed Plan. Closure of the UST and remediation of the BTEX-
contaminated soils will be conducted under PADEP authority and requirements.
OU-2 Sediment
Sediment samples from the stream bed of Kaercher Creek were collected from depositional locations
based on field observations and analyzed for lead, arsenic, and antimony. During the OU-2 Phase I RI,
sediment samples were collected from five locations on the Main Parcel and three locations upstream of
the Main Parcel. Four additional upstream sediment samples were subsequently collected from
sediment depositional areas in the general vicinity of the Apple Alley Bridge during the OU-2 Phase II
RI (Figure 4). Sediment sampling results are provided in Table 2 below.
Table 2: Kaercher Creek Sediment Sampling Results
Residential
Cleanup Level*
EPA Freshwater
Sediment Screening
Level
KC-SED-1
On-site
KC-SED-2
On-site
KC-SED-3
On-site
KC-SED-4
On-site
Antimony
31
2
10.5
6.3
4.6
10
Arsenic
15
9.8
3.4
10.6
8.3
5.1
Lead
572
35.8
850
1150
851
1540
Residential
Cleanup Level*
EPA Freshwater
Sediment Screening
Level
KC-SED-5
On-site
KC-SED-6
Upstream
KC-SED-7
Upstream
KC-SED-8
Upstream
Antimony
31
2
5.2
3.6
2.7
1.2
Arsenic
15
9.8
6.5
39.1
7.2
4.1
Lead
572
35.8
1770
401
243
131
Residential
EPA Freshwater
Sediment Screening
Level
Apple Alley (Upstream)
Cleanup Level*
1
ID
2
3
4
Antimony
31
2
5.8
1.2
2.7
0.87
2
Arsenic
15
9.8
7.5
5.7
6.7
4.9
4
Lead
572
35.8
545
226
330
175
230
All results in ppm
*OU-l site-specific soil cleanup levels.
On-site - sediment samples collected within Main Parcel
KC-SED - Kaercher Creek Sediment Sampling Location
Sediment sampling results were compared to the OU-1 residential site-specific soil cleanup levels for
potential human health impacts and to the EPA Region III Biological Technical Assistance Group
(BTAG) freshwater sediment screening levels for potential ecological impacts. The Kaercher Creek
sediment sampling identified concentrations of lead and antimony in the Creek sediment on the Main
Parcel above the gabion mattress liner system installed during the removal action which were found to
be typically higher than metals concentrations in sediments upstream. Lead results from sediment
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samples collected from upstream of the Main Parcel revealed lead levels below the OU-1 residential
site-specific soil lead cleanup level of 572 ppm in all upstream samples. Lead results in Kaercher Creek
sediment samples collected within the Main Parcel were above the established OU-1 site-specific
residential cleanup value of 572 ppm with a maximum result of 1,770 ppm of lead. All of the Kaercher
Creek sediment samples (upstream and on the Main Parcel) exceeded the freshwater sediment screening
level for lead of 35.8 ppm. No Kaercher Creek sediment samples exceeded the OU-1 residential site-
specific soil cleanup level for antimony of 31 ppm for residential soil; however, 9 of 12 sediment
samples exceeded the antimony freshwater sediment screening level of 2.0 ppm. One sediment sample
upstream exceeded both the residential site-specific soil cleanup level and freshwater sediment screening
level for arsenic with a concentration of 39.1 ppm. One sediment sample within the Main Parcel
exceeded the freshwater sediment screening level for arsenic with a concentration of 10.6 ppm. All
other sediment samples were below both the residential site-specific soil cleanup level and freshwater
sediment screening level for arsenic. Kaercher Creek sediment samples collected by EPA in 2002, prior
to capping of the Kaercher Creek sediments with the gabion mattress liner system under the 2003 AOC,
showed lead levels ranging from 4,867 ppm to 24,090 ppm.
In addition, an investigation within the covered area of Kaercher Creek (the portion of Kaercher Creek
underlaying the Facility foundation) within the Main Parcel was performed to evaluate the sidewalls of
the Creek for pipes and penetrations (other openings). A total of 12 pipes were identified as part of this
investigation, and the sediment in a representative number of those pipes was sampled (Figure 5).
Sampling identified sediment in two pipes with antimony and lead concentrations an order of magnitude
or more greater than the concentrations observed upstream. The results of sediment sampling in several
pipes (identified as Pipes 1, 2, 3, and 12) revealed lead concentrations exceeding the residential site-
specific human health lead cleanup level of 572 ppm. The highest lead result (26,300 ppm) was
recorded in a 12-inch-diameter corrugated metal pipe (Pipe 3). All seven of the pipe sediment samples
collected exceeded freshwater sediment screening levels for lead. The highest arsenic result (94.4 ppm)
and the highest antimony result (85.2 ppm) were in Pipe 2. Five of the seven samples exceeded the
freshwater sediment screening level for antimony of 2.0 ppm, and two of the seven samples exceeded
the freshwater sediment screening level for arsenic of 9.8 ppm.
Although the amount of Creek bed sediment data is very limited and no evaluations have been
conducted related to stream sedimentology, the information suggests that sediment in the 12-inch
diameter corrugated metal pipe identified as "Pipe 3" may, in particular, be a source of contaminated
sediment containing elevated levels of lead and antimony that discharges to the Creek. Ultimately the
bedload from upstream sediment and the contributions from the pipes may be contributing to elevated
metals concentrations observed in sediment which re-accumulated within the gabion mattress liner
system on the Main Parcel. However, the gabion mattress liner system itself appears to be in good
condition and functioning as a cap for the impacted sediment beneath the gabion mattress liner system
addressed during the 2003 removal action. If the gabion mattress liner system were to be damaged or
otherwise breached, the underlying sediment could become exposed to the erosive forces of the Creek
and be transported downstream.
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Table 3: Pipe Sediment Sampling Results
Parameter
EPA Region III
Soil Screening Levels
EPA
Region III
Freshwater
Sediment
Screening
Level
Pipe#
Industrial
Residential*
Soil
1
2
3
4
6
11
12
Antimony
470
31
2
9.9
85.2
53.4
3.8
0.48
2.0
4.4
Arsenic
480
15
9.8
3.8
94.4
10.2
5.7
3.9
7.4
4.6
Lead
800
572
35.8
670
6130
26300
542
116
350
647
All results in ppm
*OU-l site-specific cleanup levels.
OU-2 Ground Water
Ground water was sampled from seven overburden and four bedrock monitoring wells on the Exide-
owned properties during the OU-2 RI. Depth to ground water ranged from approximately 4 to 8 feet bgs
for the overburden wells. The potentiometric ground water surface is 1 to 2.5 feet below the Kaercher
Creek stream bed (Figure 6). Therefore, ground water is not discharging into Kaercher Creek. Ground
water flow in both the overburden and the shallow bedrock is generally west-southwest towards the
Schuylkill River which is consistent with regional ground water flow. In addition, a downward gradient
was documented between the overburden and bedrock wells ranging from approximately 2.2 feet along
the east side of the Main Parcel to less than 0.1 feet in the southwest corner of the Warehouse Parcel.
Lead exceeded the EPA Region III risk-based screening level of 15 micrograms per liter (jj.g/1) for lead
in tap water (there currently is no maximum contaminant level (MCL) promulgated pursuant to the Safe
Drinking Water Act, and codified at 40 CFR Part 141, for lead) in one unfiltered sample from bedrock
well 3 (BW-3) at a concentration of 57.3 jj.g/1. The associated filtered sample, however, was non-detect
for lead (<3.0 jj.g/1). Unfiltered samples measure the total concentration of metals in ground water
whereas filtered samples measure the dissolved metals in ground water. Samples for metals analysis are
often filtered to remove suspended particulate matter in the water sample. Lead has a strong affinity
towards soil particles, and in general, the smaller the soil particle, the greater the affinity. Once
adsorbed to a soil particle, lead is not easily released. The variability between the filtered and unfiltered
lead result for BW-3 is likely a reflection of turbidity (i.e., suspended particulate matter) in the well
resulting from well development difficulties. Arsenic and antimony analytical results did not exceed
their respective MCL in any ground water sample collected during the OU-2 RI, although the arsenic
results in monitoring well 7 (MW-7) were above the tap water EPA risk-based screening level.
Several PAHs were detected in the ground water sample from MW-2 above their corresponding MCLs
and/or risk-based screening levels for tap water during the second round of ground water sampling
although they were below detection limits during the first round. PAH impacts in MW-2 were not
observed in MW-3 situated approximately 90 feet downgradient, suggesting that the PAH ground water
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contamination is very isolated in nature. MW-2 is located in the former railroad right-of-way which
extends south from the Broom Works Parcel through the Main Parcel. As discussed earlier, PAHs
appear to be related to "historic" fill containing cinders and ash that predate Facility operations. The
PAHs are believed to be associated with the construction of the railroad tracks in the mid to late 1880s
and localized filling using cinders and ash from coal fired heaters, and therefore, not site-related.
A few VOCs were detected during the OU-2 ground water sampling events, although they were
typically below the reporting limits with the only noteworthy exceptions being BTEX compounds in
nested well pair MW-6 and BW-6, which are an overburden well and bedrock well, respectively.
Benzene was detected in overburden well MW-6 at 67 jj.g/1; although in bedrock well BW-6, benzene
was only detected at 6.0 jo.g/1. The BTEX compounds are associated with an UST in the southeastern
corner of the Main Parcel, and the ground water impacted by BTEX compounds appears to be limited in
extent to the southeastern corner of the Main Parcel. Exide represents that the UST was a gasoline
storage tank; therefore, closure of the UST is deferred to PADEP authority.
The depth of ground water beneath the Site occurs below the bottom of the fill except at the west end of
the Warehouse Parcel and possibly in a portion of the Main Parcel. Therefore, ground water interaction
with the contaminated fill is limited. Furthermore, based on the ground water sample results, it can be
inferred that, even after the many decades the fill material has been in place, very limited ground water
impact has occurred. The contaminants which may be present in the fill are not prone to dissolution and
transport by ground water in contact with the fill material or surface water infiltrating from the surface
through the fill material to ground water.
The potential drinking water aquifer in the vicinity of the Site is the Ordovician sandstone and siltstone
bedrock. The overburden in the vicinity of the Site, and regionally, consists of inter-fingering, low
permeability silts, clays and sand lenses. Under EPA's ground water classification guidelines, ground
water at the Site would be classified as a Class II aquifer. A Class II aquifer is defined as a current
and/or potential source of drinking water and water having other beneficial uses. Ground water in the
overburden unit above bedrock, however, is not used for supplying drinking water, because bedrock
ground water is used as the drinking water source in that area.
The former Facility and the surrounding community are serviced by a public water supply for potable
water, although industrial and manufacturing operations along Route 61 south and west of the Facility
were purported to have private water supply wells. Public water is provided by the Borough of
Hamburg from municipal supply wells located outside of the Borough in Windsor Township. The
Borough of Hamburg requires that users within 150 feet of a public supply waterline connect to public
water. A detailed well search performed as part of the OU-2 RI identified 11 industrial withdraw wells,
3 unused wells, and 1 overburden ground water monitoring well within 0.5 miles of the intersection of
Grand Street and Second Street. The search also identified one domestic well 0.46 miles away situated
on the north side of State Street on the west side of the Schuylkill River (Tilden Township). All of the
wells identified (except the overburden well) have casings that extend through the overburden unit into
bedrock; and the wells extend to depths typically between 200 feet to 500 feet bgs. Water production
occurs within distinct bedrock zones.
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In addition to the OU-2 ground water sampling, a limited amount of sampling of private residential
wells was conducted by EPA during the OU-1 RI in areas within the lead depositional areas but where
public water is not available (i.e., Tilden Township). The ground water results did not indicate that Site-
related metals are impacting residential ground water quality in OU-1 (outside the Exide-owned
properties). Concentrations of Site-related metals in the residential ground water samples were all below
MCLs.
SCOPE AND ROLE OF RESPONSE ACTION
IDENTIFIED IN THIS PROPOSED PLAN
This Proposed Plan describes EPA's preferred remedial decision for OU-1 (Residential Portion) and
preferred remedial alternatives for OU-2 (Facility Portion) at the Price Battery Superfund Site, which
have been contaminated primarily with lead, arsenic, and antimony by the former Price Battery facility.
On September 30,2009, an Interim ROD was issued for OU-1 for the cleanup of residential exteriors
and interiors consistent with previous removal actions. The 2009 Interim ROD converted the ongoing
residential cleanup at the time from removal authority to remedial authority. As a Comprehensive OU-1
RI continued to delineate the full nature and extent of the residential contamination, newly identified
residential properties were included in the ongoing remedial action. EPA completed the cleanup of the
last residential property, whose owner provided access to EPA for cleanup, in September 2013, and EPA
subsequently demobilized from the Site in October 2013. Human health risks at these residential
properties were addressed pursuant to the Interim ROD. Therefore, because all known contamination
exceeding clean up criteria at contaminated residential properties (whose owners provided access) has
been addressed, EPA's preferred remedial decision for OU-1 is No Further Action.
This Proposed Plan also describes the proposed alternative for OU-2 to address soil and sediment
contamination on the Exide-owned parcels of the Price Battery Site. In addition, EPA has initiated a
Remedial Investigation designated as OU-3 to further study surface water, sediment, and ecological risk
in areas outside the scope of OU-1 and OU-2. A final remedy for OU-3 will be the subject of a
subsequent Proposed Plan and ROD.
SUMMARY OF SITE RISKS
What is Risk and How is it Calculated?
A Superfund human health risk assessment estimates the "baseline risk." The baseline risk is the
estimate of the likelihood of health problems occurring if no cleanup action were taken at a site. To
estimate a baseline risk, EPA undertakes a four-step process:
Step 1: Analyze Contamination
Step 2: Estimate Exposure
Step 3: Assess Potential Health Dangers
Step 4: Characterize Site Risk
In Step 1, EPA looks at the concentration of contaminants found at a site as well as past scientific
studies on the effects these contaminants have had on people (or animals, when human studies are
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unavailable). Comparisons between site-specific concentrations and concentrations reported in past
studies help EPA to determine which contaminants are most likely to pose the greatest threat to human
health.
In Step 2, EPA considers the different ways that people might be exposed to the contaminants identified
in Step 1, the contaminant concentrations that people might be exposed to, and the potential frequency
and duration of exposure. Using this information, EPA calculates a reasonable maximum exposure
scenario which portrays the highest level of human exposure that could reasonably be expected to occur.
In Step 3, EPA uses the information from Step 2 combined with information on the toxicity of each
chemical to assess potential health risks. EPA considers two types of risk: cancer risk and non-cancer
risk. The likelihood of any kind of cancer case resulting from a Superfund site is generally expressed as
an upper bound probability, for example a "1 in 10,000 chance (1E-04)." In other words, for every
10,000 people that could be exposed, one extra cancer case may occur as a result of exposure to site
contaminants. An extra cancer case means that one more person could get cancer than would normally
be expected from all other causes. For non-cancer human health effects, EPA calculates a "hazard index
(HI)." The key concept here is that a "threshold level" (measured usually as a hazard index of less than
1) exists below which non-cancer health effects are no longer predicted.
In Step 4, EPA determines whether site risks are great enough to potentially cause health problems for
people at or near the site. The results of the three previous steps are combined, evaluated, and
summarized. EPA adds up the potential risks from the individual contaminants and exposure pathways
and calculates a total site risk.
Calculating Risks from Exposure to Lead
The risk assessment for lead is unique. Lead does not lend itself to traditional risk assessment methods
described above because there are no scientifically agreed upon toxicity values for lead. Due to the
inability to use traditional risk assessment methods, lead is regulated based on blood lead levels (BLL).
EPA's health protection goal is to limit exposure to soil lead levels to ensure that a typical (or
hypothetical) child, or group of similarly exposed children, would have an estimated risk of no more
than a 5% probability of exceeding a BLL of 10 micrograms per deciliter (p.g/dl). The Centers for
Disease Control (CDC) recommends that the goal of all lead poisoning prevention activities should be to
reduce children's BLLs below 10 (J.g/dl. Blood lead concentration can be correlated with both exposure
and adverse health effects. Existing evidence indicates that adverse health effects occur even at very
low exposures to lead (e.g., subtle neurological effects in children have been observed at low doses). To
predict blood lead concentration and the probability of a child's blood lead concentration exceeding 10
(ag/dl based on a given exposure scenario from multiple sources, a model can be applied which considers
lead exposure and toxicokinetics (the absorption, distribution, metabolism, and excretion of lead in the
body) in a child to calculate an exposure level that satisfies the risk reduction goal. The Integrated
Exposure Uptake Biokinetic (IEUBK) Model for Lead in Children is used to predict the risk of elevated
BLLs in children and to establish cleanup levels for lead.
The IEUBK Model was used for developing the site-specific lead-in-soil cleanup level of 572 ppm for
the Price Battery OU-1 residential cleanup. However, because the future use of the various parcels
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comprising the Exide-owned properties of the Price Battery Site OU-2 is expected to remain
commercial/industrial, and not residential, EPA's Adult Blood Lead Model (ALM) was used for
assessing risks from lead exposures at OU-2. BLLs in adolescents and adults are assessed using the
ALM. EPA's target for an adult female is to protect a developing fetus to ensure that the fetus has no
more than a 5% probability of having a BLL above 10 (ig/dl. This goal is based on protecting the fetus
of a pregnant site worker.
Borough of Hamburg Redevelopment Planning
Existing zoning of the Exide-owned properties is Business Development (BD) which allows for a
variety of commercial and industrial uses; new residential uses are specifically prohibited by the 2004
Deed Restriction implemented pursuant to the Removal AOC. The properties surrounding the Exide-
owned properties are similarly zoned, with the exception of the Peach Alley frontage, which is zoned
Borough and Village Center (VC). According to the Borough's Redevelopment Area Plan, no zoning
text changes are proposed; however, some zoning map amendments are suggested to implement the
goals of the plan. The proposed map amendments would include a rezoning of the Main Parcel to VC
Borough and Village Center.
Although no specific plans or proposals have been put forth, permitted uses within the VC District
would include a variety of commercial, residential, and institutional uses, as well as the creation of a
recreational trail through the area. At the request of the Borough of Hamburg, the potential for a
recreational trail crossing the Main Parcel, Broom Works Parcel, and Parking Lot Parcel was considered
in the development of alternatives for OU-2. However, during recent discussions with Borough officials
regarding the recreational trail, Borough officials indicated that the proposed location of the recreational
trail has changed, and it is currently envisioned to follow Front Street and not cross the Exide-owned
parcels, as originally contemplated. Deed restrictions already in-place for the Exide-owned properties
are intended to preclude residential development on those properties, and therefore, the preferred
alternatives for OU-2 focus on non-residential exposure scenarios which is consistent with the VC
District zoning.
Summary of Site-Related Risks for OU-2
The current and likely future use of the Exide-owned properties is commercial/industrial. Currently the
majority of the parcels are paved, covered with buildings, or covered with a stone cap that limits access
to soils. These parcels currently have deed restrictions against disturbing the existing cover or using the
properties for residential or recreational use or for day cares or schools. However, risks from exposure
to contaminated soil for a hypothetical future resident were assessed by comparison of detected
concentrations to the EPA residential site-specific cleanup levels for lead (572 ppm), arsenic (15 ppm),
and antimony (31 ppm) in soils developed during the Price Battery OU-1 residential cleanup. The
results of this screening analysis show that residential risks from soil exposures under baseline
conditions at the Exide-owned parcels would be unacceptable.
In addition, risks from exposure to contaminated sediment were also evaluated. In the absence of
establishing a screening level for recreational exposure to lead, arsenic, and antimony in sediment,
sediment contaminant concentrations were screened against the residential soil site-specific cleanup
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numbers developed during OU-1. Using residential soil cleanup numbers as a screening criteria for
recreational sediment exposure is a very conservative approach and overestimates the potential
recreational use exposure risk to sediment. The results of this sediment screening analysis show that
risks from sediment exposures under baseline conditions at the Exide-owned parcels would also be
unacceptable.
Future exposures to soil may occur if the parcels are redeveloped or the asphalt/stone cap is removed for
utility maintenance. Therefore, a detailed exposure assessment was performed for various
commercial/industrial scenarios that included specific users and exposure conditions for each of the
Exide-owned parcels. The results of a "hot spot" (i.e., areas of high contamination relative to other
areas of the Site) analysis showed that soil lead concentrations on the Main Parcel are generally higher
in the northeast quadrant of the Main Parcel, both in surface soils and subsurface soils. The Main Parcel
was divided into two areas for the purposes of evaluation: Main Parcel A and Main Parcel B (Figure 7).
Main Parcel B occupies the northeast quadrant of the Main Parcel, and Main Parcel A occupies the
remainder of the Main Parcel. These two areas were each evaluated as a separate exposure area,
although the division was based on differences in lead concentrations rather than expectations of
exposure patterns. The other three parcels evaluated included the Warehouse, Broom Works, and
Parking Lot.
Four receptors were evaluated based on exposure assumptions on each parcel as follows:
• Current Utility Worker (exposed to soil depths 0-5 feet)
• Hypothetical Future Office Worker 1 (exposed to soil depths 0 - 1.25 feet)
• Hypothetical Future Office Worker 2 (exposed to soil depths 0-10 feet)
• Future Construction Worker (exposed to soil depths 0-17 feet, including dermal exposure to
ground water)
• Hypothetical Residential Exposure to Ground Water as a Drinking Water Source
Dermal contact with overburden ground water could occur by Construction Workers during construction
activities. In addition, although the Site is not currently and will not likely be used for residential use
(the former Facility and surrounding community are served by a public water supply), overburden and
bedrock ground water risks were evaluated for a future hypothetical residential exposure scenario.
There is no widespread ground water contaminant plume at the Site. The residential exposure scenario
assumed that a hypothetical residential well could be placed anywhere on-site, and that a resident would
be exposed to the concentrations from only that well. Thus, ground water risks were evaluated for
individual wells, rather than averaging across all wells within an exposure area. Individual wells were
selected from each exposure area that represented the greatest potential risk.
Contaminants of Concern
EPA considers lead, arsenic and antimony as the primary site-related contaminants of concern (COCs)
that will be addressed for the Price Battery Site.
The BHHRA for OU-2 of the Price Battery Site identified manganese, PAHs, and BTEX compounds as
contributing to the potential risks from the exposure to soils and ground water at the Site. However,
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manganese concentrations in ground water are comparable to background concentrations and likely not
site-related. The PAHs appear to be related to coal ash and cinders in the fill material which pre-dates
battery manufacturing operations at the Site and are therefore not site-related. The BTEX compounds
are associated with a gasoline UST. Exide represents that the UST was a gasoline storage tank;
therefore, closure of the UST will be addressed by the responsible party pursuant to PADEP's UST
regulatory authority. Although manganese, PAHs, and BTEX compounds proceeded through the risk
assessment process, they are not considered site-related COCs, and EPA will not be proposing any
further action to address these contaminants.
Estimated Cancer and Non-Cancer Risks
The estimated cancer and non-cancer risks are discussed below by exposure area for the non-lead
contaminants. Cancer and non-cancer risks are summarized in Table 4. Table 4 presents the total risk
for each receptor. The total risk is the sum of all the risk pathways (i.e., ingestion, inhalation, and
dermal contact with contaminants). Detailed risk calculation tables for each receptor and each
individual pathway are presented in Appendix D of the OU-2 Baseline Human Health Risk Assessment
Report (BHHRA). Specifically, Appendix D Table 6 of the BHHRA provides a detailed risk summary
and includes the percent contribution of each exposure pathway to the total risk, as well as the
contaminant contributing the majority of the risk of each pathway.
Calculated total risks include, where applicable, risks associated with exposure to manganese, PAHs,
and BTEX which are not considered site-related contaminants and not COCs; therefore, risk values
presented in Table 4 are overestimated.
Cancer Risks
In order to evaluate carcinogenic risk, EPA has identified an acceptable risk range of 1 in 10,000 (1E-
04) to 1 in 1,000,000 (1E-06), which represents the increased risk of cancer from exposure to site-related
contaminants. Cancer risks posed to all Worker receptors were determined to be less than or equal to
2E-05 in the Broom Works Parcel, Parking Lot, and Warehouse Parcel (Table 4). In Main Parcel A,
cancer risks posed were found to be at or below 1E-05 for both Office Workers and the Utility Worker.
Cancer risk for the Construction Worker in Main Parcel A was determined to be 1E-04; the majority of
the risk was found to be from dermal contact with overburden ground water, where most of the risk is
posed by exposure to dibenzo(a,h)anthracene (non-site-related contaminant). In Main Parcel B, cancer
risk was determined to be 1E-05 for the Utility Worker and Construction Worker, and 1E-04 for Office
Worker 2. Cancer risk for Office Worker 1 was determined to be 4E-04; about 80% of the risk is from
the soil ingestion pathway, and all of the cancer risk is posed by exposure to arsenic.
For the hypothetical resident exposed to ground water on the Exide-owned properties, cancer risk
exceeded EPA's acceptable risk range for exposure to overburden ground water in MW-2 (8E-02); the
majority of the risks posed are from ingestion of and dermal contact with dibenzo(a,h)anthracene in
overburden ground water. Dibenzo(a,h)anthracene is a PAH likely from the coal ash and cinders
deposited at the Site and not site-related since it appears that the coal ash and cinders were used as fill
material prior to the commencement of battery manufacturing operations. Cancer risks were 1E-04 for
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overburden monitoring wells MW-6 and MW-7; the majority of the cancer risks posed are from the
ingestion of benzene (non-site-related contaminant) and arsenic, respectively.
Non-Cancer Risks
Non-cancer risks were found to be less than or equal to the target HI of 1 for all receptors in the Broom
Works Parcel and Parking Lot (Table 4). Non-cancer risks were below 1 for the Utility Worker in all
exposure areas. In the Warehouse Parcel, non-cancer risks were less than 1 for all receptors except the
Construction Worker (HI of 2). In Main Parcels A and B, the total HI for both Office Workers ranged
from 3 to 11, and the His for the Construction Worker were 25 and 18, respectively. For the Office
Worker and Construction Worker, nearly all the risk posed was found to be from the soil ingestion
pathway, and the major risk contributor is antimony.
For the hypothetical resident exposed to on-site ground water, non-cancer risks were below 1 in
monitoring wells BW-6 and MW-2. Non-cancer risks were greater than 1 for exposure to ground water
from bedrock monitoring wells BW-3 and BW-7, and overburden monitoring wells MW-1, MW-6, and
MW-7. Non-cancer risks for the hypothetical resident exposed to ground water from these wells ranged
from 2 to 18 for the child and 1.5 to 8 for the adult. The majority of the risks posed from exposure to
ground water in overburden well MW-6 are from the ingestion of benzene and inhalation of xylenes
(non-site-related contaminants) while showering. For the other wells, the majority of the risks posed
were found to be from the ingestion of manganese (non-site-related contaminant).
Manganese accounts for 75 to 99% of the non-cancer risks to residents hypothetically exposed to ground
water from wells MW-1, MW-7, BW-3, and BW-7. However, manganese concentrations in ground
water are comparable to background concentrations. Manganese concentrations exceed their respective
background concentration only in overburden well MW-7 and bedrock well BW-7, in the southwest
corner of the Warehouse Parcel. Therefore, the manganese risks from the other wells are likely due to
naturally occurring background concentrations. If manganese were eliminated from the risk assessment,
the HI for the child resident would be 1 or below for these wells. Without manganese, overburden
monitoring well MW-6 is the only well with ground water posing unacceptable non-cancer risk for the
resident, with benzene via ingestion and xylenes via inhalation during showering accounting for the
majority of the risk. The benzene and xylenes are associated with a gasoline UST and not -site-related
COCs. Exide represents that the UST was a gasoline storage tank; therefore, closure of the UST will be
addressed by the responsible party pursuant to PADEP's UST regulatory authority.
Table 4: Summary of Cancer and Non-Cancer Risks
Exposure Area
Receptor
Total Excess Lifetime
Cancer Risk'1'
Total Hazard Index'1'
Broom Works
Office Worker 1
4E-06
0.2
Office Worker 2
5E-06
0.1
Utility Worker
5E-07
0.01
Construction Worker
4E-07
0.8
Main Parcel A
Office Worker 1
5E-06
5
Office Worker 2
1E-05
4
Utility Worker
2E-06
0.3
Construction Worker
1E-04
25
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Exposure Area
Receptor
Total Excess Lifetime
Cancer Risk'1'
Total Hazard Index'"
Main Parcel B
Office Worker 1
4E-04
11
Office Worker 2
1E-04
3
Utility Worker
1E-05
0.3
Construction Worker
1E-05
18
Parking Lot
Office Worker 1
2E-05
0.2
Office Worker 2
1E-05
0.1
Utility Worker
2E-06
0.01
Construction Worker
1E-06
1
Warehouse
Office Worker 1
5E-06
0.3
Office Worker 2
4E-06
0.2
Utility Worker
6E-07
0.02
Construction Worker
6E-07
2
Resident*2'
MP Well BW-3
NA
3
MP Well BW-6
1E-05
0.2
MP Well MW-1
6E-05
7
MP Well MW-2
8E-02
0.0009
MP Well MW-6
1E-04
2
MP Well BW-7
5E-06
9
MP Well MW-7
1E-04
18
MP-A Hot Spot
Construction Worker
3E-08
0.04
Office Worker 2
3E-07
0.00009
(1) Calculated total risks include, where applicable, risks associated with exposure to manganese, PAHs, and BTEX which are not
considered site-related contaminants and not COCs; therefore, risk values presented in this table are overestimated.
(2) The Hazard Index reflects non-cancer risks to a child resident exposed to ground water on the Exide-owned properties. Results for the
Adult Resident are in the BHHRA.
NA = Not applicable because there were no carcinogenic COCs in this well
Bolded values indicate exceedance of EPA risk ranges.
Lead Risks in Soil
Risks associated with lead exposure were also evaluated and are presented as a probability that predicted
BLLs would exceed target ranges (Table 5). Unacceptable risks posed by lead contaminated soil were
found to exceed the target probability of 5% for Office Worker 1, Office Worker 2, and the Construction
Worker in Main Parcel A, Main Parcel B, and the Warehouse Parcel. Lead risks did not exceed the
target probability for any receptor in the Broom Works or Parking Lot parcels. Lead risks for the
Current Utility Worker did not exceed the target probability of 5% in any of the five exposure areas.
Table 5: Summary of Soil Lead Risks
Exposure Area
Office Worker 1
Office Worker 2
Utility Worker
Construction
(0-1.25 ft)
(0-10 ft)
(0-5.25 ft)
Worker
(0-17 ft)
Main Parcel A
58%
18%
0.05%
64%
Main Parcel B
97%
78%
2%
98%
Warehouse
60%
14%
0.06%
59%
Broom Works
0.2%
0.06%
0.003%
0.7%
Parking Lot
0.02%
0.01%
0.003%
0.05%
Note: Lead risk given as the predicted probability offetal blood lead >10 ug/dl
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Ecological Risks
An ecological exposure evaluation was conducted of the Exide-owned properties to determine if any
ecological habitat existed, and a Screening Ecological Risk Assessment (SLERA) was completed for
sediment sampling results for the Main Parcel portion of Kaercher Creek.
Results for soil and sediment were screened against their respective EPA Region III BTAG Screening
Levels (for soil and freshwater sediment benchmarks for sediment) to determine the nature and extent of
potential environmental contamination at the Main Parcel. Based on these results, and for the purpose of
the SLERA, lead, arsenic, and antimony were selected as contaminants of potential ecological concern
(COPECs) in soil and sediment at the Exide-owned properties that make up part of the Site.
The results of the ecological exposure evaluation of the terrestrial portions of the Exide-owned
properties supported the conclusion that the barrier created by the pavement, concrete, structures and
crushed stone and geotextile cap covering the parcels prevented a complete exposure pathway between
ecological receptors and OU-2 Site soils. Therefore, no complete ecological pathways for soils exist on
the property and the soil pathway was not further evaluated.
The ecological exposure evaluation of the Kaercher Creek portions of the Main Parcel identified
ecological habitat containing limited amounts of vegetative cover and potential foraging areas. Sediment
deposits along and within Kaercher Creek resulted in metals contaminant levels for lead, arsenic, and
antimony above the EPA Region III BTAG Freshwater Sediment Screening levels. Outside the covered
portion of the Creek (where exposure to receptors would be expected to be highest), sediment deposits
were largely limited to the Creek edges and along the walls of the channel. Sediment depths ranged
from less than an inch to approximately 12 inches along the channel wall, where terrestrial vegetation
was observed. This sediment is entirely isolated from the original Creek channel sediments which are
now covered by the gabion mattress liner system installed as part of the 2003 removal action.
The sediment surface area outside the covered portion of the Creek is approximately 2,300 ft2, most of
which is covered by vegetation. Only a small area of approximately 900 ft2 is available as aquatic
substrate in this area. Small mussels, larval fish and crayfish have been observed in this area. Although
no other aquatic animals were observed, the possibility exists that small transient fish, invertebrates,
reptiles, and amphibians may occasionally be present. However, given its size, highly modified benthic
structure (gabion mattress liner system) and limited resources (shallow water depth, absence of
cover/habitat, lack of consistent food/prey), it is unlikely that significant resident populations of these
animals are present. Higher order animals that may also transiently inhabit this area include small
mammals and birds. Mammals may include rodents, raccoons, fox, and squirrels. Birds may include
passerines, piscivorous birds (e.g., heron), and an occasional raptor. As noted for other possible
inhabitants in this area, habitat and other resources are too limiting to accommodate resident
populations, and all would be expected to be transient.
In order to evaluate the sediments that have accumulated in the Creek since installation of the gabion
mattress liner system, sampling was conducted on the Main Parcel and upstream portions of Kaercher
Creek. The possible source of the sediments deposited since the capping of the Creek bottom include
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bed load from areas upstream of the Main Parcel, sediment laden stormwater discharged to the Creek by
the municipal storm sewers, and sediment contributed by pipes discharging at the Exide owned
properties that border the Creek. Since the levels of metals contamination found on the Main Parcel
portion of Kaercher Creek are higher than those found in sediment samples immediately above the point
at which flow enters the Main Parcel, sources other than sediment transport from upstream may be
responsible. The pipe sediment sampling results, especially sediment in Pipe 3, suggest those sediments
as possible source materials to the Main Parcel portion of Kaercher Creek. Potential downstream
migration and deposition of these contaminated sediments is possible.
To determine which contaminants (i.e., lead, arsenic, and antimony) posed a risk, a Hazard Quotient
(HQ) was calculated, where HQ = sediment concentration/EPA Region III freshwater sediment
screening levels. If the HQ is greater than or equal to 1, contaminant concentrations are considered
sufficiently high that they could produce adverse ecological effects and are, therefore, retained as
ecological contaminants of concern (COCs). Based on sediment sampling results previously discussed,
concentrations of arsenic (1/5 samples), lead (5/5 samples), and antimony (5/5 samples) sampled on
Main Parcel Creek sediments did exceed freshwater sediment screening levels.
Risks were estimated by comparing single-points of exposure (i.e., sediment concentrations) with media
specific (i.e., sediment) benchmarks. Screening level results indicate that potential ecological risks exist
for sediment-based aquatic life, and to a lesser extent, direct and indirect exposure by higher trophic-
level organisms. Although HQs are not a risk measure in terms of likelihood or probability of adverse
effects, they do provide a benchmark for assessing potential risk.
The results of the ecological risk characterization are summarized in Table 6. The highest measured
sediment contaminant concentrations were used and resulted in HQs of 49.4, 1.08, and 5.25 for lead,
arsenic, and antimony, respectively. The highest levels are typically used to help ensure that potential
threats to the environment are not missed and that the levels of risk are not underestimated. On that
basis, lead represented the highest risk to organisms. Since arsenic was observed only slightly above an
HQ of 1, in only one sample, it is relatively insignificant as an ecological COC and not expected to have
a significant potential for risk or effect among exposed ecological receptors. Antimony was detected in
all five Main Parcel samples with HQ results ranging from 2.3 to 5.5. Antimony has a very diverse level
and manifestation of effect among biota, but at the low levels observed, is not expected to pose a
significant adverse effect to ecological receptors.
Table 6: Kaercher Creek Sediment Ecological Risk Characterization
Main Parcel Portion
EPA Freshwater
KC-SED-1
KC-SED-2
KC-SED-3
KC-SED-4
Sediment
On-site
On-site
On-site
On-site
Screening Level
Parameter
Result
HQ
Result
HQ
Result
HQ
Result
HQ
Antimony
2
10.5
5.25
6.3
3.15
4.6
2.3
10
5
Arsenic
9.8
3.4
0.35
10.6
1.08
8.3
0.85
5.1
0.52
Lead
35.8
850
23.74
1150
32.12
851
23.77
1540
43.02
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EPA Freshwater
Sediment
Screening Level
KC-SED-5
On-site
KC-SED-6
Off-site
KC-SED-7
Off-site
KC-SED-8
Off-site
Parameter
Result
HQ
Result
HQ
Result
HQ
Result
HQ
Antimony
2
5.2
2.6
3.6
1.8
2.7
1.35
1.2
0.6
Arsenic
9.8
6.5
0.66
39.1
3.99
7.2
0.73
4.1
0.42
Lead
35.8
1770
49.44
401
11.2
243
6.79
131
3.66
All results in ppm
On-site - sediment samples collected within Main Parcel
Off-site - sediment samples collected outside the Main Parcel
KC-SED - Kaercher Creek Sediment Sampling Location
In summary, ecological COCs include lead, arsenic, and antimony. EPA believes that the potential for
direct and indirect sediment-based ecological effects is present, but the limited habitat and likely future
remediation of contaminant sources precluded the need to further quantify ecological risk. EPA believes
that sediment contained in pipes beneath the Main Parcel could contribute contaminated sediment to the
Kaercher Creek bed load in areas downstream from the Main Parcel; therefore, remediation of the
sediment in the pipes and within the gabion mattress liner system is necessary.
A comprehensive ecological assessment has also been initiated by EPA for Kaercher Creek (other than
on Exide-owned properties), Mill Creek, and the Schuylkill River to further quantify risks to ecological
habitat in areas of the Site outside the Exide-owned properties of the Price Battery Site. This ecological
assessment once completed will be part of a subsequent OU-3 decision. A final remedy for OU-3 will
be the subject of a future Proposed Plan and ROD.
Basis for Action
The BHHRA and ecological risk characterization assessment found that the former Price Battery facility
manufacturing operations contaminated soil and sediments with lead, arsenic, and antimony above levels
that are protective of human health and the environment and are summarized below.
Soils
For soils on the Exide-owned portions of the Price Battery Site OU-2, EPA has determined there is a
basis for action for the following reasons:
• Lead results were above the established OU-1 site-specific residential cleanup value of 572 ppm;
therefore, residential risks from soil exposures under baseline conditions at the Exide-owned
parcels would be unacceptable.
• Unacceptable risks posed by lead contaminated soil were found to exceed the target probability
of 5% for Office Worker 1, Office Worker 2, and the Construction Worker in Main Parcel A,
Main Parcel B, and the Warehouse Parcel.
• Unacceptable cancer risks posed primarily by arsenic contaminated soil were found to exceed the
acceptable cancer risk range for Office Worker 1 and Office Worker 2 in Main Parcel B.
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• Unacceptable noncancer risks posed by antimony and arsenic were found to exceed an HI of 1
for Office Worker 1, Office Worker 2, and the Construction Worker in Main Parcel A and Main
Parcel B.
Sediment
For sediment in Kaercher Creek within the Main Parcel of the Exide-owned portions of the Price Battery
Site OU-2, EPA has determined there is a basis for action for the following reasons:
• Lead results were above the established OU-1 site-specific residential cleanup value of 572 ppm
with a maximum result of 1,770 ppm of lead.
• Lead, arsenic, and antimony exceed EPA freshwater sediment screening levels for ecological
receptors
• Unacceptable ecological risks posed primarily by lead and arsenic were found to exceed an HQ
of 1 for ecological receptors
• Accumulated contaminated sediment in Kaercher Creek and pipes may be transported to
downstream ecological receptors.
Ground Water
For ground water on the Exide-owned portions of the Price Battery Site OU-2, EPA has determined
there is no basis for action for the following reasons:
• PAH contamination in overburden monitoring well MW-2 appears to be isolated in nature and
related to fill material containing coal ash and cinders used as railroad ballast which pre-dates
operation of the Price Battery facility and is therefore not site-related. Monitoring well MW-2 is
located in the former railroad right of way.
• BTEX compounds detected in overburden well MW-6 and bedrock well BW-6 appear to be
isolated in nature and attributable to a gasoline UST in the southeastern corner of the Main
Parcel. Exide represents that the UST was a gasoline storage tank; therefore, closure of the UST
will be addressed by the responsible party pursuant to PADEP's UST regulatory authority.
• Elevated detections of lead in bedrock monitoring well BW-3 is believed to be the result of
turbidity within the well resulting from well development difficulties and not representative of
ground water quality.
• Arsenic was detected above its risk-based screening level in only one well (MW-7) but was
below its corresponding MCL.
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REMEDIAL ACTION CLEANUP OBJECTIVES
To protect the human health and the environment from potential current and future health risks, remedial
action objectives (RAO) have been developed to address contaminated soil and sediment and for
monitoring of ground water at the Price Battery Site OU-2.
The RAOs developed for Price Battery OU-2 are presented in Table 7 below:
Table 7: Price Battery OU-2 Remedial Action Objectives
MEDIUM
OBJECTIVE
Soil:
Prevent direct human exposure to soils above the preliminary remediation goals
(PRGs) for lead and risk-based concentrations (RBCs) for antimony and
arsenic.
Prevent potential future impact to stream sediment and surface water by soil
erosion from the Facility.
Protect ecological receptors from exposure to contaminated soils above
ecologically protective values.
Ground Water:
Monitor ground water to insure that the isolated ground water contaminant
concentrations do not change.
Sediment:
Minimize the potential for exposure of human receptors to sediment containing
COCs in excess of the residential soil screening levels.
Eliminate existing on-site accumulations of contaminated sediment in Kaercher
Creek and pipes, which sediments could be transported to downstream
ecological receptors.
Prevent on-site exposure of ecological receptors to sediment containing COCs
above EPA freshwater sediment screening benchmarks.
Determination of Risk-Based Concentration for Lead
A risk-based concentration (RBC) is the average concentration in an exposure area that will result in an
acceptable risk to a particular receptor (for lead, this term is referred to as the preliminary remediation
goal (PRG), but the term RBC will be used for consistency). Lead-in-soil RBCs are risk-based target
cleanup levels that must be met on average throughout the exposure area. It is acceptable to leave
concentrations that exceed the cleanup level (RBC) for lead-in-soil, as long as the post-remediation
average concentration in an exposure area does not exceed the RBC for lead-in-soil. The soil lead RBC
calculated for the Office Worker is 2,240 ppm and 941 ppm for the Construction Worker.
The Remedial Action Level (RAL) is the concentration above which soil must be addressed so that the
post-remediation average concentration meets the specified target cleanup level (i.e., meets the RBC).
The RAL is a cleanup level (i.e., a remedial trigger concentration) that ensures the post-cleanup average
concentration within an exposure area achieves the target cleanup level with a specified level of
confidence.
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The RBCs and corresponding RALs for lead calculated for the exposure scenarios with potentially
unacceptable risk are presented in Table 8. To be conservative, the lowest lead RAL (8,669 ppm) will
be applied as the target remedial level for all parcels and all soil depths, except to the extent that
contaminated soil cannot be removed because of field conditions (i.e., physical constraints, maintaining
safe excavation slopes, etc.).
Table 8: Soil Lead RBCs and RALs
Receptor
Soil Depth
RBC (ppm)
RAL (ppm)
Main Parcel A
Main Parcel B
Warehouse
Office Worker 1
0-1.25 ft
2,240
27,615
12,285
8,669
Office Worker 2
0-10 ft
2,240
35,000
25,300
28,500
Construction Worker
0-17 ft
941
35,000
8,748
9,313
Determination of Risk-Based Concentrations for Arsenic and Antimony
The OU-2 BHHRA includes calculations of arsenic and antimony RBCs in soil for each of the exposure
scenarios evaluated. The lowest calculated RBCs were 100 ppm for arsenic (Office Worker) and 46
ppm for antimony (Construction Worker). Elevated levels of antimony and arsenic were generally
correlated with elevated levels of lead, and the BHHRA concluded that performing a remedial action to
meet the RALs for lead in soil will result in average concentrations of antimony and arsenic below the
RBCs identified above.
No unacceptable risk from lead, arsenic, or antimony was identified for the exposure scenarios evaluated
in the BHHRA on the Broom Works Parcel or the Parking Lot.
Principal Threat Wastes in Soils
For the purposes of Price Battery OU-2 only, principal threat wastes (PTW) are defined as those
materials containing antimony, arsenic or lead at concentrations two orders of magnitude (i.e., 100
times) higher than the RBCs calculated in the OU-2 BHHRA. Although the BHHRA calculated RBCs
for a number of exposure scenarios, for simplicity, the lowest calculated RBCs were used to calculate
PTW levels. PTWs are defined as those soils with concentrations of one or more constituents above the
concentrations in Table 9.
Table 9: Principle Threat Waste Levels
RBC (ppm)
PTW (ppm)
Antimony
46
4,600
Arsenic
100
10,000
Lead
941
94,100
Relative to these concentrations, PTWs have been identified to exist only on Main Parcels A and B. No
PTWs have been identified on the Warehouse, Broom Works, or Parking Lot Parcels.
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Contaminants of Concern in Sediment
The COCs in sediment are antimony, arsenic and lead. Sediment contained in the pipes and penetrations
(openings in the Kaercher Creek concrete channel wall), and sediment within and on top of the gabion
mattresses, must be removed, sealed, or otherwise mitigated to prevent the potential for contaminated
sediment transport to downstream ecological receptors and prevent on-site exposure of ecological
receptors to sediment containing COCs above levels of concern. Based on a determination in the
ST,ERA that the Main Parcel portions of Kaercher Creek have limited ecological value, remedial action
will focus on eliminating contaminated sediment accumulations in the Main Parcel portions of Kaercher
Creek and in pipes with the potential to become eroded and transported to downstream ecological
receptors. Although Kaercher Creek within the Main Parcel has limited ecological value, this action
will also prevent exposure of ecological receptors within the Main Parcel portion of Kaercher Creek to
sediment containing COCs above EPA freshwater sediment screening levels. Therefore, the following
ecological freshwater sediment screening levels (Table 10) have been identified as the cleanup levels for
sediment for the Main Parcel portions of Kaercher Creek and sediment contained in the pipes:
Table 10: Sediment Cleanup Levels
Human Health*
Ecological
Lead
572
35.8 (TEC)
Arsenic
15
9.79 (TEC)
Antimony
31
3.0 (UET)
All results in ppm
~Site specific residential levels developed by EPA for OU-1
TEC = NO A A Threshold Effect Concentrations
UET = Upper Effects Threshold
Because the freshwater sediment screening levels are lower than the site-specific residential cleanup
levels developed during OU-1, EPA will use the more stringent of the two as cleanup levels for
protection of human health and ecological receptors'
SUMMARY OF REMEDIAL ALTERNATIVES
The Superfund law (CERCLA) requires that any remedy selected to address contamination at a
hazardous waste site must be protective of human health and the environment, cost-effective, in
compliance with regulatory and statutory provisions that are applicable or relevant and appropriate
requirements (ARARs), and consistent with the NCP to the extent practicable.
1 Site-specific ecological sediment cleanup values were not calculated for Kaercher Creek. EPA believes that the potential
for direct and indirect sediment based ecological effects is present, but the limited habitat and likely future remediation of
contaminant sources by addressing sediment found in the open pipes discharging to Kaercher Creek precluded the need to
further quantify ecological risk and the results of the SLERA sufficed. Therefore, the use of the sediment screening
ecological values as sediment cleanup levels is reasonable given the limited extent of remediation necessary of Kaercher
Creek within the Main Parcel.
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Summary of Major ARARS
Operable Unit One
ARARs for OU-1 were identified in the September 30, 2009 Interim ROD for the Residential Portion of
the Price Battery Site. No additional ARARs for OU-1 have since been identified. The remedial action
at OU-1 is complete, and all ARARs identified in the OU-1 Interim ROD were met during the remedial
action.
Operable Unit Two
EPA has identified the following substantive federal and state requirements as applicable or relevant and
appropriate requirements (ARARs) or otherwise worthy of consideration during the evaluation of the
remedial alternatives in this Proposed Plan.
Off-site disposal of excavated soil from site remediation activities will be determined by whether or not
the soil passes the Toxicity Characteristic Leaching Procedure (TCLP) for lead and arsenic. If
excavated soils pass the TCLP, then the soil may be disposed of in a permitted nonhazardous Resource
Conservation and Recovery Act (RCRA) waste storage, treatment, or disposal facility. If excavated
soils do not pass the TCLP, the soils may be stabilized on-site until confirmed to pass TCLP and then
disposed of in a permitted nonhazardous waste storage, treatment, or disposal facility. Otherwise,
excavated soils that do not pass the TCLP will be disposed of at a permitted RCRA Subtitle C hazardous
waste storage, treatment, or disposal facility for stabilization and/or disposal.
The Commonwealth of Pennsylvania has promulgated standards for lead, antimony, and arsenic for soil
cleanup under Pennsylvania Act 2, Title 25 PA Code 250; however, for the Price Battery Superfund Site
OU-2, a risk-based site-specific cleanup standard was determined through the Superfund risk
assessment, which is also consistent with Pennsylvania Act 2, Title 25 PA Code 250.
In addition to ARARs, EPA may implement other federal or state policies, guidelines, or proposed rules
capable of reducing the risks posed by a site. Such To-Be-Considered (TBC) standards, while not
legally binding (because they have not been promulgated), may be used in conjunction with ARARs as
part of the risk assessment conducted for each CERCLA site to set protective cleanup levels and goals.
EPA considered the Area of Contamination Policy and its applicability to the remediation of the Exide-
owned properties of the Price Battery Superfund Site, specifically the Warehouse Parcel and the Main
Parcel. The Area of Contamination Policy allows RCRA hazardous waste to be managed within an
Area of Contamination without triggering the RCRA Land Ban Restrictions (which require further
treatment of such waste) if the waste is solely managed for consolidation on-site. The Area of
Contamination policy was first articulated in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). See 53 FR 51444 for detailed discussion in proposed NCP preamble; 55 FR
8758-8760, March 8, 1990 for final NCP preamble discussion. See also, most recent EPA guidance,
March 13,1996 EPA memo, "Use of the Area of Contamination Concept During RCRA Cleanups." See
also, "Management of Remediation Waste under RCRA," EPA530-F-98-026 (October 1998).
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In the case of the Warehouse Parcel and the Main Parcel, EPA has determined that, consistent with the
Area of Contamination Policy, although these parcels are separated by a public right-of-way, the parcels
may be considered as one Area of Contamination for the purposes of consolidating excavated soil from
one parcel to another. This decision is based, in part, on the discovery of some lead contamination
above background values for the area in subsurface soils below the paved public right-of-way.
Additional ARARs concerning minimization of any effects of remediation on historic properties, or
landmarks; consideration of flood plain hazards and flood plain management; avoiding adverse impact
to wetlands; clean backfill requirements; and best practices to prevent fugitive dust emissions during any
remedial activity were all identified during the evaluation of remedial alternatives. A more detailed
description of these ARARs can be found in the ARARs Appendix to this Proposed Plan.
Remedial Alternatives for OU-2
Remedial alternatives for Price Battery OU-2 are presented below. The alternatives are numbered to
correspond with alternatives presented in the 2013 Final FS for the Exide-owned portions of the Price
Battery Site.
Common Components to all Alternatives
The Declaration of Use and Deed Restriction (Deed Restriction) placed on all of the Exide-owned
parcels in 2004 as required by the November 12,2002 Removal Action Memorandum and Removal
AOC is incorporated as a common component in all the proposed alternatives discussed below. Among
other things, the Deed Restriction prohibited use of the Exide properties for residential, recreational,
schools, day care facilities, or other uses which could potentially expose children to contamination.
Additional institutional controls ("ICs") will be required limiting access for future development,
improvement, and use of the Exide-owned properties where residual risk may remain after cleanup. ICs
will include activity and use restrictions enacted through proprietary (e.g., easements, covenants) and/or
governmental (e.g., zoning requirements) controls to prevent use of the property that will pose an
unacceptable risk to receptors. The exact type of IC implemented will be determined by EPA in
consultation with PADEP and local government agencies. The restrictions in the current Declaration of
Use and Deed Restriction will be incorporated into any new institutional controls.
In addition, Five Year Reviews are an element common to all the remedial alternatives. Five Year
Reviews are required on all Superfund sites when there is waste left in place. In the case of this Site,
lead-contaminated soils and sediments will be left in place for all the alternatives above levels that allow
for unlimited exposure and unrestricted use of the Exide-owned properties.
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SOIL ALTERNATIVES
Alternative S-l: No Action
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $0
Estimated Present Worth Cost: $0
Estimated Construction Timeframe: N/A
Estimated Time to Achieve RAOs: N/A
The NCP requires that EPA include a "No Action" Alternative in its remedy selection decision making
process. Under the No Action Alternative, no cleanup measures would be implemented. The purpose of
the No Action Alternative is to provide a baseline to compare the other clean up alternatives. The No
Action Alternative would not meet any of the cleanup objectives described earlier in this Proposed Plan.
Furthermore, the No Action Alternative would not provide the controls necessary to protect human
health and the environment from the Site-related lead, arsenic, and antimony soil contamination other
than the current deed restriction on the property which prohibits residential use. There are no costs to
implement, operate, and maintain this Alternative. However, because existing contaminated soils would
remain in place, EPA will conduct Five-Year Reviews as required by Section 121(c) of CERCLA.
Alternative S-2: Institutional Controls
Estimated Capital Cost: $20,900
Estimated Annual O&M Cost: $5,400
Estimated Present Worth Cost: $87,909
Estimated Construction Timeframe: 1 Week
Estimated Time to Achieve RAOs: NA
Alternative S-2 would control risks primarily through limitation of access to areas of contamination.
Debris remaining from past Site operations would be removed. The perimeter fence around the Main
Parcel would remain for security and general safety purposes, at least until the property is sold or
redeveloped. Institutional controls (ICSs) would provide notice that contamination is known to exist
and that uncontrolled intrusive activities are limited or restricted. Future excavation for redevelopment
or utility work would be limited to depths and locations where contamination has been shown not to
present unacceptable risks or done only within carefully developed procedures approved by EPA in
consultation with PADEP. No residential use of the properties would be permitted. ICs would include
activity and use restrictions enacted through proprietary (e.g., easements, covenants) and/or
governmental (e.g., zoning requirements) controls to prevent use of the property that would pose an
unacceptable risk to receptors. The exact type of IC implemented would be determined by EPA in
consultation with PADEP and local government agencies. The restrictions in the current Declaration of
Use and Deed Restriction would be incorporated into any new institutional controls.
Activities would include semi-annual inspections of overall site conditions to confirm no disturbance is
occurring, evaluating the integrity of the site cover system (including the existing gabion mattress liner
system), and ensuring that the institutional controls remain protective. EPA would conduct Five-Year
Reviews as required by Section 121(c) of CERCLA.
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Alternative S-3: Excavation, Stabilization, and Off-Site Disposal of Soils Defined as Principal
Threat Waste; Capping Remaining Soils In-Place; Institutional Controls
Estimated Capital Cost: $1,109,994
Estimated Annual O&M Cost: $4,050
Estimated Present Worth Cost: $1,160,251
Estimated Construction Timeframe: 22 Weeks
Estimated Time to Achieve RAOs: 22 Weeks
Alternative S-3 improves the Site for potential re-use and/or redevelopment while minimizing the
amount of excavation and soils management. Under this alternative, PTW soils would be excavated,
stabilized, and disposed off-site at an approved disposal facility. Stabilization of excavated PTW soils
could occur either on-site or off-site, as necessary, to meet disposal requirements. Any soils exceeding
the RAL which overlay the PTW soils would be removed and managed consistent with the PTW soils.
Other RAL soils not overlying the PTW soils would not be excavated and remain in-place.
Approximately 1,540 cubic yards (cy) and 1,310 cy of soil would be excavated from Main Parcel A and
Main Parcel B, respectively. Soils would be excavated to depths ranging from approximately 2 feet to 6
feet below ground surface. No excavation would occur on the Warehouse Parcel because there are no
identified PTW soils on this parcel.
The excavations would be backfilled with reclaimed concrete and soils segregated during excavation of
the PTW soils (and proven to be below the PADEP non-residential statewide health standards) and/or
imported clean fill material. Backfilling would be performed to levels at or near existing grades except
as coordinated with site redevelopment activities. Imported clean soil must have maximum
concentrations of no more than 50 ppm and 15 ppm for lead and arsenic, respectively. All other
chemical parameters for the imported soil would meet Pennsylvania Clean Fill criteria. The existing
concrete/asphalt cover over RAL soils would be maintained as a cap, or buildings and pavement
associated with future redevelopment, if they occur, function as a cap. Any future redevelopment, if
known, would be incorporated into the cap design. If the scope of future redevelopment is not known,
the cap would be designed to the extent possible to accommodate a variety of potential redevelopment
options. The IC requirements of Alternative S-2 are included in this Alternative. Because existing
contaminated soils will remain in place, EPA would conduct Five-Year Reviews as required by Section
121(c) of CERCLA.
Alternative S-4A: Excavation, Stabilization, and Off-Site Disposal of Soils defined as Principal
Threat Waste and Soils Exceeding the Remedial Action Level; Institutional
Controls
Estimated Capital Cost: $2,731,416
Estimated Annual O&M Cost: $3,713
Estimated Present Worth Cost: $2,777,484
Estimated Construction Timeframe: 54 Weeks
Estimated Time to Achieve RAOs: 54 Weeks
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Alternative S-4A also would improve the Site for potential re-use and/or redevelopment. Alternative S-
4A goes beyond Alternative S-3 in that all PTW and RAL soils would be excavated, stabilized, and
disposed off-site at an approved disposal facility. Soils below the site-wide RAL would remain in-place.
Stabilization of excavated PTW and RAL soils could occur either on-site or at an off-site disposal
facility, as necessary, to meet disposal requirements. Approximately 1,820 cy, 2,470 cy, and 3,900 cy of
soil would be excavated from Main Parcel A, Main Parcel B, and the Warehouse Parcel, respectively.
Concrete pavement, floor slabs, and foundations overlying the RAL and PTW soils will be segregated,
cleaned to remove residual contamination (based on visual observations) pursuant to the requirements of
RCRA, crushed, and stockpiled. Crushed material will be analyzed for inorganic constituents and the
results compared against the PADEP Statewide Health Standards for non-residential soils (direct
contact) prior to reuse as backfill. Imported clean soil shall have maximum concentrations of no more
than 50 ppm lead and 15 ppm arsenic. All other chemical parameters for the imported soil would meet
Pennsylvania Criteria for Management of Fill. Backfilling would be performed to levels at or near
existing grades except as coordinated with site redevelopment activities. Any crushed material used for
backfilling will be overlain by imported clean fill. Institutional controls would be imposed that protect
or control future redevelopment/land use at the Site and would require control of soils generated during
future construction activities as such soils (i.e., soils above the RBC but less than the RAL) could
represent a risk if not properly managed. Residential redevelopment would be prohibited. The IC
requirements of Alternative S-2 are included in this Alternative. Because existing contaminated soils
would remain in place, EPA would conduct Five-Year Reviews as required by Section 121(c) of
CERCLA.
Alternative S-4B: Excavation, Stabilization and Off-Site Disposal of Soils defined as Principal
Threat Waste; Excavation and On-Site Consolidation of Soils Exceeding the
Remedial Action Level; Institutional Controls
Estimated Capital Cost: $1,691,585
Estimated Annual O&M Cost: $13,500
Estimated Present Worth Cost: $1,859,107
Estimated Construction Timeframe: 56 Weeks
Estimated Time to Achieve RAOs: 56 Weeks
Alternative S-4B also would improve the Site for potential re-use and/or redevelopment. This alternative
is similar to Alternative S-4A in that all PTW soils and RAL soils would be excavated. Excavated PTW
soils would be stabilized and disposed off-site. However, RAL soils would not be disposed off-site, but
rather they would be consolidated into a single capped area on-site. Soils below the RAL would remain
in-place. The excavated RAL soils would be placed in a designated consolidation area on one of the
Exide-owned properties without stabilization. All four Exide-owned parcels are considered one Area of
Contamination. Consolidation within the Area of Contamination would not represent hazardous waste
generation, and would not trigger RCRA Land Disposal Restrictions or minimum technology
requirements. RCRA Corrective Action Management Unit (CAMU) requirements would not be
triggered because the RAL soils would not be stabilized. The specific location for the consolidation area
could be adapted to fit future land development concepts, but would most likely result in a consolidation
area in the northeast corner of the Main Parcel. The consolidation area would be created by excavating
an area and depth to accommodate the volume of RALs soil and the cap. A 24-inch thick cap
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(consisting of soil and/or pavement) would be placed across the consolidation area. The edges of the
cap would be flush with surrounding grades and grading would be designed to avoid sharp changes in
grade, slopes greater than a ratio of 3 horizontal to 1 vertical and finished grades greater than 5+/- feet
above surrounding grades. The depth of the consolidation area would be limited by ground water. In
addition, other soils (i.e., soils with concentrations below the Site-wide RAL) excavated during creation
of the consolidation area could be utilized for backfill of the excavation areas and for capping. The IC
requirements of Alternative S-2 are included in this Alternative. EPA would conduct Five-Year
Reviews as required by Section 121(c) of CERCLA.
SEDIMENT ALTERNATIVES
Alternative SD-1: No Action
Estimated Capital Cost: 0
Estimated Annual O&M Cost: 0
Estimated present Worth Cost: 0
Estimated Construction Timeframe: NA
Estimated Time to Achieve RAOs: NA
The No Action Alternative is required by CERCLA as the basis for comparison with other alternatives.
This alternative involves no action to reduce the risks posed by sediments at the Site. None of the
contaminated sediments would be addressed. Utilizing the No Action Alternative, the contaminated
sediment above and below the gabion mattresses and within piping that discharges into Kaercher Creek
at the Site would remain in-place, and the current deed restrictions would remain in-place. EPA would
conduct Five-Year Reviews as required by Section 121(c) of CERCLA.
Alternative SD-2: Institutional Controls
Estimated Capital Cost: $20,900
Estimated Annual O&M Cost: $5,400
Estimated present Worth Cost: $87,909
Estimated Construction Timeframe: 1 Week
Estimated Time to Achieve RAOs: NA
Alternative SD-2 is a limited construction alternative that would control human health risks primarily
through limitation of access to areas of contamination. The perimeter fence around the Main Parcel
would remain for security and general safety purposes, at least until the property is sold or redeveloped.
The gabion mattress liner system in the Creek would be included in this alternative, ensuring that the
integrity of the stream liner system is documented and maintained. The gabion mattress stream liner
system is approximately 6,500 square feet (ft2) and includes an estimated 100 cy of impacted stream
sediment within the gabions. Sediment in the underground pipes would remain under this alternative.
Periodic maintenance and inspection of the Site are included in the cost estimate for this alternative.
Activities include semi-annual inspections of overall Site conditions, including soil and sediment areas
to confirm no disturbance is occurring and to evaluate the integrity of the Site cover system (including
the gabion mattress liner system). Institutional controls would be implemented to provide notice that
contamination is known to exist and prohibit removal of the existing gabion mattress or excavation of
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soils within or along the Creek. EPA would conduct Five-Year Reviews as required by Section 121(c)
of CERCLA.
Alternative SD-3: Sediment Removal and Stream Liner; Institutional Controls
Estimated Capital Cost: $265,605
Estimated Annual O&M Cost: $2,700
Estimated Present Worth Cost: $299,109
Estimated Construction Timeframe: 14 Weeks
Estimated Time to Achieve RAOs: 14 Weeks
Alternative SD-3 is specific to addressing sediment in Kaercher Creek on the Main Parcel, including
contributions from the Site drainage pipes. The former building floors enclosing (across the top of) the
Creek and the loose sediment contained within or on the gabion mattresses would be removed. The
accumulated sediment in the mattresses would be removed to the extent practicable using a vacuum
truck. The gabion mattress would be filled with grout or concrete to encapsulate any remaining
sediment that cannot be removed from within the gabion mattresses and bolster the structural stream
liner system. Existing walls of the channel or portions thereof may need to be reconstructed to ensure
long-term stability. Existing pipes that open into the Creek and the sediment contained within them
would be cleaned, removed, and/or sealed. Any accumulated sediment that is removed would be
disposed off-site, placed in the on-site consolidation area, or used as backfill in on-site soil excavation
areas. The gabion mattresses would then be grouted to ensure long term stability and permanence. The
estimated volume of sediment to be removed would be approximately 100 cy and 10 cy from the gabion
mattresses and pipes, respectively. Institutional controls would be implemented to prohibit removal of
the existing gabion mattress or excavation of soils within or along the creek. EPA would conduct Five-
Year Reviews as required by Section 121(c) of CERCLA.
Alternative SD-4: Stream Realignment
Estimated Capital Cost: $817,742
Estimated Annual O&M Cost: $6,075
Estimated Present Worth Cost: $893,126
Estimated Construction Timeframe: 61 Weeks
Estimated Time to Achieve RAOs: 61 Weeks
Alternative SD-4 was originally developed to complement and enhance the recreational trail envisioned
by the Borough of Hamburg crossing the Main Parcel portion of the Price Battery Site. However, since
the development of Alternative SD-4 in the FS, recent discussions with Hamburg Borough officials
regarding the recreational trail indicated that the proposed location of the recreational trail has changed
and is currently envisioned to follow Front Street and not cross the Exide-owned parcels as originally
contemplated. Nonetheless, Alternative SD-4 remains a viable Alternative to address sediment
contamination in Kaercher Creek within the Main Parcel.
Under Alternative SD-4, Kaercher Creek on the Exide parcels would be relocated and reconstructed
along the original alignment for the trail envisioned by the Borough of Hamburg within the Main Parcel.
The Creek would have been integrated with the trail by creating a natural stream bank approaching the
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Creek from the proposed trail. The area available for redevelopment would be maximized by creating a
retaining wall along the west and northwest side of the Creek. A 75 +/- foot wide buffer would be
created along Peach Alley for the walking trail, and the Creek would be relocated along the west side of
proposed buffer. The cross-sectional area for the new channel would be increased to increase flow
capacity. Pipes 2 and 3 and the accumulated sediment within these pipes would be removed. Efforts
would be made to naturalize the new stream bed and vegetate the stream banks to enhance ecological
habitat and improve surface water quality. The original channel alignment would be backfilled with
structural fill, abandoning the existing gabion mattress and contaminated sediments in-place. The
existing concrete walls would be demolished and recycled for use as backfill, or the walls would be
abandoned in-place. The approximate volume of sediment abandoned-in-place (primarily beneath the
gabion mattress) would be 350 cy with lead concentrations ranging from 4,867 ppm to 24,090 ppm with
an average of 14,787 ppm. The volume of gabion mattress to be abandoned-in-place would be
approximately 100 cy. Because contaminated sediment would be abandoned in place, EPA would
conduct Five-Year Reviews as required by Section 121(c) of CERCLA.
GROUND WATER PREFERRED DECISION
EPA's preferred decision for ground water is No Action. Ground water contamination observed at the
Price Battery Site is either not site-related, or it is related to petroleum contamination that will be
deferred to PADEP under its authorities for appropriate action. PAH contamination in overburden
monitoring well MW-2 appears to be isolated in nature and related to fill material containing coal ash
and cinders used as railroad ballast which pre-dates operation of the Price Battery facility and is not site-
related. Monitoring well MW-2 is located in the former railroad right of way. BTEX compounds
detected in overburden well MW-6 and bedrock well BW-6 appear to be isolated in nature and
associated with a gasoline UST in the southeastern corner of the Main Parcel. Exide represents that the
UST was a gasoline storage tank; therefore, closure of the UST will be addressed by the responsible
party pursuant to PADEP's UST regulatory authority. Elevated detections of lead in bedrock monitoring
well BW-3 is the result of turbidity within the well resulting from well development difficulties and not
representative of ground water quality. Arsenic was detected above its risk-based screening level in
only one well (MW-7) but was below its corresponding MCL.
However, ground water monitoring would be conducted to ensure that contaminant concentrations
remain stable at the Site and would serve as an early indicator should ground water contaminant
concentrations change following implementation of the remedial action. At a minimum, approximately
two additional ground water monitoring wells would be installed for monitoring (after soil remediation,
if selected). Monitoring well BW-3 would also be redeveloped or replaced to address turbidity issues
within that well. Quarterly ground water sampling would be conducted. Monitoring data would be
reviewed annually for statistical trends beginning after 2 years (eight quarters). The need for continued
ground water monitoring would be re-evaluated at 5-year intervals concurrent with Five-Year Reviews
as required by Section 121(c) of CERCLA.
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EVALUATION OF ALTERNATIVES
Criteria Used To Compare Cleanup Alternatives
The remedial alternatives summarized in this Proposed Plan have been evaluated against the nine
decision criteria set forth in the NCP, 40 C.F.R. § 300.430(e)(9). These nine criteria are organized into
three categories: threshold criteria, primary balancing criteria, and modifying criteria. Threshold
criteria must be satisfied in order for an alternative to be eligible for selection. Primary balancing
criteria are used to weigh major trade-offs among alternatives. Modifying criteria are formally taken
into account after public comments have been received.
The criteria and the evaluation of each alternative against such criteria are set forth below:
Threshold Criteria
Overall Protectiveness of Human Health and the Environment assesses whether an alternative
eliminates, reduces, or controls threats to public health and the environment through treatment,
engineering controls, or institutional controls.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) evaluates whether
the alternative meets all of the applicable or relevant and appropriate requirements of environmental
statutes and regulations.
Primary Balancing Criteria
Lone-Term Effectiveness and Permanence considers the ability of an alternative to maintain protection
of human health and the environment over time once cleanup goals are achieved.
Reduction of Toxicity. Mobility, or Volume of Contaminants Throueh Treatment evaluates the degree
to which treatment will be used to reduce the toxicity, mobility, or volume of contaminants causing site
risks.
Short-Term Effectiveness considers the length of time needed to implement an alternative and the risks
the alternative poses to workers, residents, and the environment during construction and implementation.
Implementabilitv considers the technical and administrative feasibility of implementing the remedy,
including factors such as the relative availability of materials and services.
Cost includes estimated capital and annual operations and maintenance costs, as well as present worth
cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost
estimates are expected to be accurate within a range of +50 to -30 percent.
Modifying Criteria
State/Support Aeencv Acceptance considers whether the state agrees with EPA's Preferred Alternative.
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Community Acceptance considers whether the local community agrees with EPA's Preferred
Alternative. This criterion is assessed in the Record of Decision following a review of public comments
received on the Proposed Plan.
Evaluation of Alternatives
The above nine criteria are used to evaluate the cleanup alternatives in order to select a remedy. This
section of the Proposed Plan profiles the relative performance of each alternative against the nine
criteria, noting how each alternative compares to the other options.
1. Overall Protection of Human Health and the Environment
Soil Alternatives
The No Action Alternative does not provide adequate protection of human health and the environment,
because it does not eliminate or control the current and future risks from exposure to contaminated soils.
The No Action Alternative will not be discussed further in the nine criteria analysis because it does not
satisfy the threshold criterion of providing overall protection to human health and the environment.
Alternative S2, Institutional Controls, provides some protection of human health and the environment
through monitoring of areas of concern and instituting controls to prevent exposure. Alternative S-2
relies on institutional controls rather than physical means of addressing contamination and does not
address PTWs. Therefore, Alternative S-2 does not achieve the degree of protectiveness afforded by the
other alternatives evaluated.
Alternative S-4A, Excavation and Off-Site Disposal, provides protection at the Site through the removal
of all soils with lead concentrations in excess of the site-wide RAL, including PTW soils. This provides
the most permanent means of risk reduction among the soil alternatives evaluated and produces a site
that can be redeveloped without posing an unacceptable risk to construction workers or future users or
requiring overly restrictive controls for material handling. Alternative S-3, Excavation and Off-Site
Disposal of PTW, is not as protective as Alternative S-4A because it leaves materials on the Warehouse
Parcel and Main Parcels A and B that can represent an unacceptable risk to future construction workers
and would require special procedures to protect human health during redevelopment. Alternative S-4B
consolidates varying amounts of RAL soils in an on-site consolidation unit under an engineered cap to
provide protection by preventing future exposure instead of being sent for off-site disposal. Although
Alternative S-4B is protective, it does not achieve the same protectiveness as Alternative S-4A.
Sediment Alternatives
The No Action Alternative does not provide adequate protection of human health and the environment,
because it does not eliminate or control the current and future risks from contaminated sediment on the
Main Parcel or potential transport of contaminated sediment downstream. The No Action Alternative
will not be discussed further in the nine criteria analysis because it does not satisfy the threshold
criterion of providing overall protection to human health and the environment. Alternative SD-2
provides minimal protection to human health and the environment by relying on institutional controls to
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prevent exposure and disturbance of the current gabion mattress system. However, because SD-2 does
not include removal of sediments from the gabion mattresses and pipes, there is the potential for
continuing contamination of downstream sediments. Contaminated sediment could potentially be
released during storm events thereby potentially affecting downstream ecological habitat. Both
Alternatives SD-3 and SD-4 are protective of human health and the environment, because contaminated
sediment would be removed or the Creek channel relocated, thereby decreasing the potential for
contaminated sediment release downstream. Alternative SD-4 provides nominally more protection than
Alternative SD-3 because the stream channel would be relocated, whereas contaminated sediment would
remain capped in-place under the current gabion mattress system liner of Alternative SD-3, even though
contaminated sediment would be removed from within the gabion mattresses. Alternative SD-4 would
provide this nominal additional protection at a higher cost and would be more difficult to implement.
2. Compliance with ARARs
Any cleanup alternative selected by EPA must comply with all applicable or relevant and appropriate
federal and state environmental requirements or provide the basis upon which such requirement(s) can
be waived. Applicable requirements are those environmental standards, requirements, criteria, or
limitations promulgated under federal or state law that are legally applicable to the remedial action to be
implemented at the Site. Relevant and appropriate requirements, while not being directly applicable,
address problems or situations sufficiently similar to those encountered at the site that their application
is well-suited to the particular circumstance.
EPA will also consider to-be-considered material (TBCs) along with ARARs. TBCs are non-
promulgated advisories or guidance issued by federal or state governments that are not legally binding
and do not have the status of potential ARARs. However, EPA may use the TBCs in determining the
necessary level of cleanup for protection of human health and the environment.
A complete listing of ARARs and TBCs for the preferred alternatives for OU-2 of the Price Battery Site
is presented in the ARARs Appendix to this Proposed Plan.
Soil Alternatives
Alternative S2, Institutional Controls, does not meet chemical-specific ARARs, because contaminated
PTW soils and RAL soils will remain in-place without further treatment. In addition, the cover provided
by the existing pavement floor would be less than the two foot thickness called for by PADEP
requirements (25 PA Code 288.234); therefore, the action-specific ARAR for capping would not be met
unless provisions for demonstrating the acceptability of utilizing alternative cover systems are
implemented. Alternatives S-3, S-4A and S-4B would meet action-specific ARARs related to erosion
and sediment control, contact water discharge, Land Disposal Restrictions, off-site waste handling and
on-site waste handling. Alternatives S-4A and S-4B would meet chemical-specific ARARs related to
soil and air. Alternative S-3 meets chemical-specific ARARs related to air, but does not meet chemical-
specific ARARs related to soil if RAL soils are allowed to remain on-site without a permanent cover.
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Sediment Alternatives
Alternatives SD-1 and SD-2 do not meet chemical-specific ARARs (i.e., EPA freshwater sediment
screening levels) for freshwater sediment as the risk associated with the potential release of
contaminated sediments downstream would not be addressed. Alternative SD-3 would meet the
freshwater sediment chemical-specific ARAR since sediment on the gabion mattress liner system and
within the pipes beneath the Main Parcel would be addressed. Alternatives SD-3 and SD-4 would meet
the action-specific ARAR for work in waterways and location-specific ARARs of the Clean Water Act
by bypassing flow during the work and implementing sediment controls. Alternative SD-3 would
fiirther meet Clean Water Act requirements by incorporating measures to collect and treat pore water
from within the sediment/gabion matrix. Alternative SD-4 would meet the freshwater sediment
chemical-specific ARAR since sediment within the pipes beneath the Main Parcel would be removed,
and sediment within the gabion mattress liner system would be abandoned in-place.
3. Long-Term Effectiveness and Permanence
Soil Alternatives
Alternative S-2 by itself is not considered to provide long-term effectiveness and permanence. The most
significant potential sources of contamination would remain even though institutional controls would be
implemented to require special management of impacted soils during intrusive activities. Alternative S-
4A provides the highest degree of long term protectiveness because all RAL and PTW soils would be
excavated and disposed off-site. Alternatives S-3 and S-4B also provide long-term protectiveness but
not to the same degree as Alternative S-4A since RAL soils would remain on-site under a cap or within
a capped on-site consolidation unit. Although Alternatives S-3, S4A, and S-4B all could be susceptible
to future disturbance, properly implemented institutional controls and routine monitoring/inspections
would mitigate potential problems. Long-term protectiveness would be dependent on the ability to
enforce and maintain ICs; however, any ICs necessary for Alternative S-4A would be less burdensome
than the ICs for the other soil alternatives because Alternative S-4A would leave the least contamination
in-place of all the soil alternatives.
Sediment Alternatives
Alternative SD-2 would not provide long-term effectiveness and permanence since the most significant
potential sources of contamination would remain. Although institutional controls could provide some
measure of protection against disturbance of contaminated sediment in the pipes and Kaercher Creek,
contaminated sediment transport downstream could remain a possibility during storm events.
Alternative SD-3 would achieve long-term protectiveness through removal of contaminated sediment,
stabilizing the gabion mattress system, and addressing contaminated sediment in the underground pipes.
Although SD-3 could be susceptible to future disturbance, properly implemented institutional controls
and routine monitoring/inspections would mitigate potential problems. Alternative SD-4 would also
provide long-term protectiveness and is most conducive with the permanent, long-term use of the Site.
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4. Reduction of Toxicity, Mobility, or Volume Through Treatment
Soil Alternatives
Alternative S-2 does not provide any reduction in toxicity, mobility or volume through treatment since it
relies solely on institutional controls. Alternatives S-3, S-4A and S-4B provide for varying amounts of
reduction in toxicity, mobility or volume through treatment (i.e., stabilization) and off-site disposal of
PTW soils. However, Alternatives S-3 and S-4B both allow RAL soils to remain on Site untreated
either under the existing cover or an engineered cap. Alternative S-4A provides for the greatest
reduction in toxicity, mobility, or volume through treatment (i.e., stabilization) by excavating all RAL
soils, in addition to the PTW soils, and treating these soils (pending TCLP results) via stabilization,
either on-site or off-site, prior to disposal of these soils in an approved off-site disposal facility.
Sediment Alternatives
Alternative SD-2 would not reduce the toxicity, mobility, or volume of contaminants in Kaercher Creek
since it relies solely on institutional controls. Alternatives SD-3 and SD-4 would reduce the toxicity,
mobility, and volume of contamination in the Creek through the removal of contaminated sediment or
relocation of the Creek but not through treatment of the contamination. However, Alternative SD-3
could reduce the toxicity and mobility of contaminants in sediment removed from the gabion mattresses
and pipes through treatment if the sediment would require stabilization prior to off-site disposal based
on TCLP results. Alternative SD-4 would not reduce the mobility, toxicity or volume of contaminated
sediment through treatment because the current channel, including the contaminated sediments within
the gabion mattresses, would be abandoned-in-place underneath a cap. However, Alternative SD-4
could reduce the toxicity and mobility of contaminants in sediment removed from the pipes through
treatment, if the sediment would require stabilization prior to off-site disposal based on TCLP results.
5. Short-Term Effectiveness
Soil Alternatives
Alternative S-2 would not have significant short-term effectiveness issues. Little or no field activities
would be necessary to implement Alternative S-2, and the implementation of institutional controls
would not take long. Alternatives S-3, S-4A, and S-4B would all pose short-term impacts related to
construction activities, but impacts to workers and the community can readily be controlled. During soil
excavation, consolidation, stabilization (if conducted on-site), and handling activities, there is the
potential for the spreading of contaminants as airborne dust. The construction specifications would
include specific measures to control dust, and, when properly implemented, exposures would be
significantly reduced to workers and the local community. Dust suppression measures including water
sprays or manufactured dust-suppression products would be used. Air monitoring would be conducted
during activities with the potential for dust generation. Additionally, the potential remains for off-site
migration of Site materials via sediment erosion during construction. Specific erosion and sediment
control measures such as silt fences, silt socks, or hay bales would be taken to mitigate this possibility.
Erosion and sediment control measures would be selected during preparation of the construction
specifications. Impacts on traffic on the local roads by vehicular traffic between the Site and the
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highway would be limited to delivery of construction materials and equipment, contractor personnel and
truck traffic being sent off-site for disposal, and hauling clean soil fill and cap materials back to the Site.
Alternative S-4A and S-4B would have greater short-term impacts than Alternative S-3 because of the
amount of material to be handled and transported. The number of trucks for off-site disposal of
contaminated soil could be approximately 200 to 300 trucks over one to two months with an equal
amount for import of clean soil for Alternatives S-3 and S-4B and as much as 500 to 800 trucks over a
two to four month period for Alternative S-4A. The RAOs for soil would be met at the completion of
construction.
Sediment Alternatives
Alternative SD-1 is essentially implemented, and since there would be no construction, there would not
be any short-term impact on the community, workers, or the environment. Similarly, Alternative SD-2
would not have significant short-term effectiveness issues. For Alternative SD-3, during removal and
handling of sediment, there could be the potential for the spreading of contaminants in suspended
sediment washing downstream, dust (for dry sediment accumulated in pipes), or tracking by workers and
equipment. These short-term impacts could be adequately controlled through appropriate erosion and
sediment control measures. There will be some truck traffic associated with the removal of sediment,
but it would not be expected to be significant and can be controlled with the implementation of
appropriate traffic safety measures. The short-term impacts due to construction would likely be similar
to Alternative SD-3 for Alternative SD-4, but impacts to workers and the community can be readily
controlled similar to Alternative SD-3. The RAOs for sediment would be met at the completion of the
construction activities.
6. Implementability
Soil Alternatives
Alternative S-2 is essentially already implemented at the Site. Institutional controls are currently in
place; however, they would need to be re-evaluated and modified to account for possible future
redevelopment of the properties. Alternatives S-3, S-4A, and S-4B are readily implementable with
proper planning and design. The excavation and management of soils and construction of the cap are
common environmental construction activities and will not require the use of specialized equipment,
techniques, or labor resources. Implementation of a capping solution would optimally be coordinated
with a specific redevelopment plan to determine site grading requirements. Administrative
implementability is not a concern for on-site construction and post-construction
administrative/institutional controls, because Exide owns all of the properties to be remediated.
Sediment Alternatives
All of the sediment alternatives are implementable. Alternative SD-2 is essentially already implemented
at the Site. However, the current institutional controls would need to be re-evaluated and/or modified to
provide the greatest degree of protection. Alternative SD-3 is most readily implementable with proper
planning and design. Alternative SD-4, Creek Realignment, would be the most difficult to implement,
but can provide the greatest overall benefit relative to optimizing the contiguous usable areas of the
43
AR307405
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Main Parcel and integrating community plans. However, SD-4 would be more difficult to implement
than Alternative SD-3 and would provide only marginally more long-term protectiveness than SD-3 at a
higher cost.
7. Cost
Soil and Sediment Alternatives
Alternative S-4A has the highest cost due to volume of soil being removed and sent off-site for disposal.
Alternative S-l and S-2 involve minimal construction, and therefore their costs are much lower.
Alternative SD-4 is more expensive than Alternative SD-3 by approximately $600,000 and would be
more difficult to implement than Alternative SD-3 with little additional risk reduction benefit. The only
costs associated with the No Further Action alternative for ground water are the annual monitoring costs
and costs associated with the installation of approximately two additional monitoring wells. The cost of
the Alternatives is provided in Table 11 below.
Table 11: Remedial Alternative Costs
Capital Costs
Annual O&M Costs
Present Worth Costs*
SOIL
Alternative S-l
$0
$0
$0
Alternative S-2
$20,900
$5,400
$87,909
Alternative S-3
$1,109,994
$4,050
$1,160,251
Alternative S-4A
$2,731,416
$3,713
$2,777,484
Alternative S-4B
$1,691,585
$13,500
$1,859,107
SEDIMENT
Alternative SD-1
$0
$0
Alternative SD-2
$20,900
$5,400
$87,909
Alternative SD-3
$265,605
$2,700
$299,109
Alternative SD-4
$817,742
$6,075
$893,126
GROUND WATER
No Action w/Monitoring
$6,380
$11,270
$146,230
~Discount rate of 7% was used in calculation of Present Worth Costs
8. State/Support Agency Acceptance
The Commonwealth of Pennsylvania's acceptance of the Preferred Alternatives will be evaluated after
the public comment period and will be described in the Record of Decision.
9. Community Acceptance
Community acceptance of the Preferred Alternatives will be evaluated after the public comment period
ends and will be described in the Record of Decision.
44
AR307406
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SUMMARY OF THE PROPOSED REMEDIAL DECISION FOR OU-1 AND OU-2
Operable Unit One - Residential Portion
EPA's preferred remedial decision is No Further Action for addressing interior and exterior residential
contamination. On September 29, 2009, EPA issued an Interim ROD selecting interior decontamination
and exterior yard remediation of residential properties while a more comprehensive RI/FS continued to
define the full extent of the residential contamination. However, as this comprehensive RI progressed
and additional properties were identified, these properties were incorporated into the ongoing remedial
action. EPA cleaned up these additional residential properties, and no further action is necessary. The
interim remedy selected in the 2009 Interim ROD may be considered the final remedy for OU-1. The
risks associated with exposure to interior lead-contaminated dust and exterior soils has been addressed,
and all ARARs associated with the remedy have been met. EPA will continue public education and
outreach as specified in the 2009 Interim ROD. EPA has provided the Borough of Hamburg with a
Registry which documents the cleanup status of individual properties. Because some residential
property owners declined participation in the cleanup, EPA will perform Five Year Reviews of the OU-1
remedy to ensure continued protection to human health and the environment.
Operable Unit Two - Facility Portion
EPA has selected as its Preferred Alternative a combination of Soil Alternative S-4A and Sediment
Alternative SD-3. In addition, EPA has proposed No Action with Monitoring for ground water.
Total Combined Present Worth Cost: $3,222,823
Soil: Alternative S-4A
The components of the preferred alternative are:
1. Excavate soils from the Main Parcel and the Warehouse Parcel that exceed the lowest calculated
RAL (8,669 ppm) for lead in soil, including PTW soils, except to the extent that contaminated
soil cannot be removed because of field conditions (i.e., physical constraints, maintaining safe
excavation slopes, encountering ground water, etc.).
2. Concrete pavement, floor slabs, and foundations overlying the RAL and PTW soils will be
segregated, cleaned to remove residual contamination (based on visual observations) pursuant to
the requirements of RCRA, crushed, and stockpiled. Crushed material will be analyzed for
inorganic constituents and the results compared against the PADEP Statewide Health Standards
for non-residential soils (direct contact) prior to reuse as backfill.
3. Stabilize excavated soils on-site and transport to an off-site permitted facility or transport soils as
hazardous waste for stabilization at an off-site permitted facility prior to disposal. Conduct TCLP
testing of excavated soils and/or stabilized soils as necessary for proper disposal or to determine
effectiveness of stabilization.
45
AR307407
-------
4. Perform post-excavation confirmation sampling of excavation floor and sidewalls to ensure RAL
levels have been achieved. Recalculate the exposure point concentration (EPC) utilizing
confirmation sample results collected after excavation.
5. Backfill resulting excavations with reclaimed crushed concrete and clean fill material to levels at
or near existing grades except as coordinated with site redevelopment activities. Any crushed
material used for backfilling will be overlain by imported clean fill. Reclaimed crushed concrete
must meet backfill concentrations identified in the BHHRA for lead (<50 ppm), arsenic (< 100
ppm), and antimony (< 46 ppm). If reclaimed concrete exceeds 50 ppm lead (but is below the
PADEP Statewide Health Standards for non-residential soils for direct contact of 1,000 ppm
lead), the RAL must be recalculated utilizing the actual concentration for the proportion of
backfilling completed using recycled concrete and additional soil remediation performed as
appropriate to achieve the desired RBC. Clean soil must meet Pennsylvania Criteria for
Management of Fill, or the backfill concentrations identified in the BHHRA, whichever is lower.
6. Stabilize Site surfaces using concrete, asphalt, buildings, and landscaping in a manner consistent
with plans for Site redevelopment and suitable for preventing erosion of soils above residential
remediation standards and as specified by erosion and sediment control requirements.
7. Implement institutional controls (ICs) to ensure the remedy provides an adequate measure of
protection in light of current and anticipated future use. Such additional institutional controls
would include notification to future property owners that contaminated soils remain in-place and
that special handling of these soils would be required if these soils are disturbed during
redevelopment construction activities. No residential use of the properties will be permitted. ICs
will include activity and use restrictions enacted through proprietary (e.g., easements, covenants)
and/or governmental (e.g., zoning requirements) controls to prevent use of the property that will
pose an unacceptable risk to receptors. The exact type of IC implemented will be determined by
EPA in consultation with PADEP and local government agencies. The restrictions in the current
Declaration of Use and Deed Restriction will be incorporated into any new institutional controls.
Sediment: Alternative SD-3
1. Remove accumulated sediment from the gabion mattress, to the extent possible, using a vacuum
truck or equivalent. Remove sediment from underground pipes and penetrations including, but
not limited to, Pipes 1,2, and 3. Grout any underground pipes, as necessary, to further prevent
contaminated sediment within any pipes from entering Kaercher Creek.
2. Dispose of accumulated sediment off-site or use as backfill in on-site soil excavation areas if
coordinated with soil remediation and sediment meets the same requirements for other soils
under Alternative S-4A, above.
3. Grout gabion mattress to insure long-term stability of the Creek bed.
4. Perform annual inspections to confirm that the gabion mattress and channel walls remain stable
and remove accumulated trash and debris to maintain the hydraulic capacity of the channel.
46
AR307408
-------
5. Implement institutional controls to prohibit removal of the gabion mattress or excavation of soils
within or along the creek in conjunction with the IC requirements of Alternative S-4A.
Ground Water: No Action with Monitoring
No active cleanup measures would be taken for ground water at the Site.
1. Install new monitoring wells to the current monitoring well network after soil remediation is
implemented. Redevelop or replace monitoring well BW-3 to address turbidity problems within
the monitoring well.
2. Conduct quarterly ground water sampling. After eight consecutive quarters of monitoring,
conduct a statistical evaluation to determine contaminant concentration trends and continue
statistical analysis annually. Reevaluate need for continued monitoring at five year intervals.
In summary, the Preferred Alternative is believed to provide the best balance of trade-offs among all the
alternatives evaluated with respect to the nine criteria above. Based on the information available at this
time, EPA believes the Preferred Alternative would protect human health and the environment, would
comply with ARARs, would be cost effective, and would utilize permanent solutions and alternative
treatment technologies to the extent practicable. The Preferred Alternative would also meet the statutory
preference for the selection of a remedy that includes treatment as a principal element.
The Preferred Alternative can change in response to public comment or new information.
COMMUNITY ROLE IN REMEDY SELECTION PROCESS
This Proposed Plan is being distributed to solicit public comment on the appropriate cleanup action for
the Site. EPA relies on public input to ensure that the remedy selected for each Superfund Site considers
the needs and concerns of the local community. EPA is providing a 30-day public comment period
beginning on July 15,2015, and ending on August 14,2015, to encourage public participation in the
selection process. All written comments must be postmarked by August 14,2015 and sent to:
John Banks (3HS22) Larry Johnson (3HS52)
Remedial Project Manager Community Involvement Coordinator
US EPA Region III US EPA Region III
1650 Arch Street 1650 Arch Street
Philadelphia, PA 19103 Philadelphia, PA 19103
banks. iohn-d@,epa. gov iohnson.larrv-c@epa.gov
EPA will conduct a Public Meeting on July 30, 2015 at 6:30 p.m. at the Hamburg Borough Municipal
Building at 61 North Third Street in Hamburg, Pennsylvania, to present the Proposed Plan and
supporting information, answer questions, and accept both oral and written comments from the public.
47
AR307409
-------
The Administrative Record file containing background documents regarding the Site, as well as copies
of the Remedial Investigation and Feasibility Study Reports are available to the public at the following
locations:
Hamburg Public Library
35 North Third Street
Hamburg, PA 19526
(610) 562-2843
and
U.S. Environmental Protection Agency, Region III
Administrative Record Room, 6th Floor
1650 Arch Street
Philadelphia, PA 19103
Please contact Paul Van Reed at (215) 814-3157 for an appointment.
Weekdays - 8:30 a.m. to 4:30 p.m.
The Administrative Record file can also be accessed on the web at www.epa.gov/arweb
EPA will summarize and respond to comments received at the public meeting and written comments
post-marked by August 14, 2015 in the Responsiveness Summary in the Record of Decision, which will
document EPA's selected remedy for the Site. To obtain additional information relating to this Proposed
Plan, please contact one of the following EPA representatives:
John Banks, RPM (3HS22)
Remedial Project Manager
U.S. EPA, Region III
1650 Arch Street
Philadelphia, PA 19103
Phone: (215) 814-3214
banks.iohn-d@epa.gov
Larry Johnson (3HS52)
Community Involvement Coordinator
U.S. EPA, Region III
1650 Arch Street
Philadelphia, PA 19103
Phone: (215) 814-3239
iohnson.laiTv-c@epa.gov
48
AR307410
-------
FIGURES
49
AR307411
-------
FIGURE 1; PRICE BATTERY SITE LOCATION
50
AR307412
-------
FIGURE 2: PRICE BATTERY OU-2
EXIDE-OWNED PROPERTIES
51
AR307413
-------
Legend ,j_ .
+ -m»«vt»«7 ti*-r 11 ibaMty Area
| [ P>»qn»-'' ftcr CvilV'tv f\vt .vo Opt-' Z*mc O^n-'-j
* rtrsntt't SnxiKosUvK
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' f f ATitlV & I - 1K ,
fl " •Sr*J *
„¦ |»^\t x V-'*v*
M.I- : 1
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" „ V S * " 10 t> 1 i> t" 1 * V " ' K* " Q 0
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Ix1, f * >; , r.v i At. , t' 1 . > >» I L- 1
Price Battery Swpertund Site Ff|un»2-3
Berks U)ur.ty, Homburq. PA ft-1 .t«v Met' PmtoiiWt> Le.ia ak»i
Bases er Partru at."17'impart EvattisiOfi
FIGURE 3: PRICE BATTERY OU-1 BOUNDARY AREA
PREDICTED HIGH PROBABILITY DEPOSiTIONAL AREA
52
AR307414
-------
FIGURE 4; KAERCHER CREEK SEDIMENT SAMPLING LOCATIONS
53
AR307415
-------
- u'vr ~' f'i
A*ivr
ms - j"< " •-* it. vn*t
I t niKM ' Xf
t - *£,~*• * ..M*
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t
u.<
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It
~t
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.: p;
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-•* tr
c ^ '.
N»-
FIGURE 5: APPROXIMATE LOCATION OF PIPES WITHIN ENCLOSED AREA OF KAERCHER CREEK
54
AR307416
-------
FIGURE 6; OVERBURDEN GROUND WATER POTENTIOMETRIC MAP
55
AR307417
-------
it
»
i
1 1
I I
I 1
1 I
_ . . _X. \
m
0mmmt
a
»«y a<>* rv*r.-«
k t *« s"*~** V i '»>* ^
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FIGURE
1
FIGURE 7: EXPOSURE AREAS
56
AR307418
-------
ARARS
57
AR307419
-------
Table 1
Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard,
Requirement,
Criterion, Or
Limitation
Citation Or Reference
Description
Status
Comments
FEDERAL*
Manifesting and
Recordkeeping
Requirements
25 PA Code §§ 262a. 10
(incorporating by reference 40
CFR Part 262, but limited to
Subparts A - C, 262a. 11, 262a. 12,
262a.21, and 262a.34)
Standards for recordkeeping of
the management actions for
hazardous wastes.
Applicable
Applicable if remedial activities
include the off-site transport of
hazardous waste. Does not apply to
transport of material within an AOC.
Hazardous Waste
Management
25 PA Code §§261 a. 1
(incorporating by reference 40
CFR Part 261, but limited to
Subparts A - E, 261 a.2-8, 262a.32,
and 262a.39)
Waste characterization
Applicable
Applicable for characterizing
contaminated soil or sediment
determined to be sent off-site for
disposal.
Land Disposal
Restrictions
25 PA Code §
268a. 1 (incorporating by reference
40 CFR Part 268, Subparts A- E)
Restricts disposal of hazardous
waste that could trigger land
disposal regulations
Applicable
Not triggered for materials that are
managed within an Area of
Contamination. Applicable to off-site
disposal only.
Storage
Requirements
Preparedness and
Prevention
25 PA Code § 264a. 1
(incorporating by reference 40
CFR Part 264, but limited to
substantive parts of Subparts B -
G and I - M)
Standards for the storage of
hazardous wastes.
Requirements for spill response
planning and control
Relevant and
Appropriate
Includes requirements if remedial
activities include the storage of
hazardous waste greater than 90
days.
Materials on-site are not regulated as
hazardous waste when consolidated
in same Area of Contamination
Off-Site Transport
of Hazardous
Waste
EPA OSWER Directive 9834.11
Establishes technical guidelines
for the off-site transport of
hazardous wastes.
TBC
TBC if remedial activities include the
off-site transport and management of
hazardous waste.
National
Ambient Air
Quality Standards
40 CFR § 50.6
Requirements for fugitive dust
and particulate matter, lead in
air, and carbon monoxide.
Applicable
NAAQS for particulates and lead
may be applicable to earth-moving
activities as well as to treatment
processes that may include mixing or
other processes that result in
potential releases of particulates.
Standards for
Owners and
Operators of TSD
25 PA Code § 264a Subpart N
Requirement for landfills,
including design and operating
requirements, monitoring and
inspection, response actions,
surveying, closure and post-
closure care.
TBC
Materials on-site are not regulated as
hazardous waste when consolidated
in same Area of Contamination
•Pennsylvania has an authorized hazardous waste program; therefore the Pennsylvania hazardous waste regulations
are identified here as the applicable Federal hazardous waste standards.
58
AR307420
-------
Table 1 (Continued)
Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard,
Requirement,
Criterion, Or
Limitation
Citation Or
Reference
Description
Status
Comments
PENNSYLVANIA
Hazardous Waste:
PA Hazardous
Waste Landfill
25 PA Code
264a. 1 (incorporating
by reference 40
CFR Part 264
Subpart N)
Requirements that cap systems
for hazardous waste landfills have
a lower permeability than their
bottom liner
TBC
Materials on-site are not regulated as hazardous
waste when consolidated in same Area of
Contamination
Soil:
Administration of
Land Recycling
Program (Act 2)
25 PA Code
§ 250.407(c)
Subpart D Site-
Specific Standard
For attainment of site-specific soil
standards in residential areas, the
point of compliance for ingestion
and inhalation exposure is up to
15 feet below the existing surface
unless bedrock or physical
structures are encountered which
prevent safe continued
remediation.
Applicable
Applicable to soil remediation activities.
PA Residual Waste
and Municipal
Waste Regulations,
Chemical Analysis
of Waste
25 PA Code
§§287.54, 271.611
Chemical Analysis Requirements
Applicable
Applicable to consider capping standards for on-
site disposal. Applicable to off-site disposal.
Administration of
Land Recycling
Program (Act 2)
25 PA Code
§ 250.308
Standards for protection of ground
water using default soil to ground
water standards or site-specific
soil to ground water modeling.
Applicable
Applicable to soil remediation and capping
requirements.
Residual Waste:
Final Cover and
Grading
25 PA Code
§ 288.234, 288.423,
288.523 and
288.623
Standards for cap design for on-
site consolidation area
Relevant
and
Appropriate
Siting and other design requirements for on-site
consolidation area. Requirements regarding the
type of waste that may be disposed in the
consolidation area."
General Provisions
25 PA Code § 287
General provisions for residual
waste management
Relevant
and
Appropriate
Residual waste provisions are not applicable
when consolidating contaminated materials within
an Area of Contamination
Storage and
Transportation
25 PA Code § 299
Subpart A
Storage and transportation of
residual waste
Relevant
and
Appropriate
Not applicable when consolidating materials within
an Area of Contamination
59
AR307421
-------
Table 1 (Continued)
Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard,
Requirement,
Criterion, Or
Limitation
Citation Or
Reference
Description
Status
Comments
PENNSYLVANIA (CON'T)
Other
Pennsylvania's
Land Recycling
Program Technical
Guidance Manual
253-0300-100
Establishes recommendations and
guidance for attainment of site
specific standards in soil at
voluntary state cleanup Sites for
land reuse.
TBC
TBC for remedial activities involving soil.
Department of
Environmental
Protection Bureau
of Land Recycling
and Waste
Management:
Management of Fill
258-2182-773
Establishes clean fill requirements.
TBC
TBC for soils used as clean fill at excavated areas at
the site.
Fugitive Dust
Control
25 PA Code
§§123.1-123.2
Requires that the remedial action
take all reasonable actions to
prevent particulate matter from
becoming airborne.
Applicable
Applicable to earth-moving activities as well as to
treatment processes that may include mixing or
other processes that result in potential releases of
particulates.
Air Pollution Control
25 PA Code
Chapters 121.1
-.3,127,139
(excluding
Subchapter I)
Requires prevention of air
emissions at remedial sites and that
ambient air quality will be
maintained in areas where air
quality is better than applicable air
quality standards and improved in
areas where air quality is worse
than applicable air quality
standards.
Applicable
Applicable to earth-moving activities as well as to
treatment processes that may include mixing or
other processes that result in potential releases of
particulates.
Erosion and
Sedimentation
Control
35 PS §691.1
et. seq. Chapter
102, 25 PA
Code §§ 102.4,
102.11, and
102.22
Regulates erosion and
sedimentation control measures.
Applicable
Applicable to grading and excavation activities
conducted as part of site remediation. Implemented
by Berks County.
Storm Water
Management Act of
1978, as
amended
32 P S. §
680.13
Provides storm water runoff control
requirements during construction
activities.
Applicable
Applicable to grading and excavation activities
conducted as part of site remediation.
Dam Safety and
Waterway
Management
25 PA Code
105,
Subchapters A-
K
Applies to work performed within,
along, and across waterways.
Channel changes and dredging
Applicable
Chapter 105 implementation delegated to BCCD.
60
AR307422
-------
Table 2
Location-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard,
Requirement,
Criterion, Or
Limitation
Citation Or
Reference
Description
Status
Comments
FEDERAL
National Historic
Preservation Act
16 U.S.C. §
470; et. Seq.;
36 CFR Part
800
Minimizes impact of actions
on historic properties and
landmarks.
Applicable
Applicable to actions at historic properties or
landmarks, or properties at the site that
contain historical and archeological data.
Archeological
Resources
Protection Act
16 U.S.C.
469a-1
Provides protection from
actions that may cause
irreparable harm, loss, or
destruction of artifacts
Clean Water Act
(Dredge and Fill
Requirements)
33 U.S.C. §§
1251-1376;
40 CFR Parts
230
Provides protection to waters
in and around the site.
Relevant
and
Appropriate
Relevant and appropriate to actions involving
capping, berm construction and/or onsite
disposal of contaminated soil that may impact
local water bodies.
PENNSYLVANIA
Clean Streams
Law
35 P.S. §
619.1; 25 PA
Code §§
93.4, 93.7,
93.8 (b)(c),
93.9, 25 PA
Code
Chapter 16
and Chapter
105
Subchapters
A-K
Provides protection to waters
in and around the site.
Relevant
and
Appropriate
Requires that any remedial actions taken at
the site not contribute to pollution of state
waters.
PA Floodplain
Management Act
32 P.S.
679.101-60;
25 PA Code
§106.31
Standards for construction in
100 year floodplain, wetlands
and regulated waters.
Relevant
and
Appropriate
Applicable to remediation in Kaercher Creek
and realignment of the Creek.
61
AR307423
-------
Table 3
Chemical-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard,
Requirement,
Criterion, Or
Limitation
Citation Or
Reference
Description
Status
Comments
FEDERAL
Soil:
EPA Soil Screening
Guidance
EPA/540/R-
96/018 July 1996
Provides methodology for
calculating risk-based,
site-specific soil screening
levels.
TBC
Used to standardize and accelerate
site cleanup.
Hazardous Waste:
Identification and
Listing of Hazardous
Waste
25 PA Code §§
261a.2-261a.39
(incorporating by
reference 40
CFR §§ 261.2-
261.35)
Defines those solid
wastes which are subject
to regulations as
hazardous wastes.
Applicable
Applicable to determining whether
wastes are considered hazardous
under RCRA for off-site disposal.
Ground Water:
Federal MCLs
40 CFR §§
141.23 -.24,
141.51, 141.61,
141.62
National drinking water
standards
Relevant
and
Appropriat
e
Applicable through the PADEP Act 2
requirements
Guidelines for Ground
Water Classification
under the EPA Ground
Water Protection
Strategy
EPA/813R88001
June 1988
Provides site-specific
ground water
classification guidelines,
procedures, and data
requirements
TBC
Applicable when classification has not
been determined by Pennsylvania
Other:
EPA Region III Risk-
Based Concentration
Table
www.epa.gov/re
g3hwmd/risk/hu
man/rb-
concentration_ta
ble/Generic_Tabl
es/
Establishes chemical
screening guidelines for
use during risk
assessment.
TBC
May be useful in development of
cleanup goals.
National Ambient
Air Quality
Standards
40 CFR §§ 50.6,
50.12
Provides acceptable
ambient air quality levels
for particulate matter and
lead.
Applicable
Applicable to earth-moving activities as
well as to treatment processes that
may include mixing or other processes
that result in potential releases of
particulates or lead.
Risk Assessment
Guidance for
Superfund, Volume 1,
Part A
EPA/540/1-
89/002
Defines Preliminary
Remediation Goals and
Remedial Action Levels
for soil
TBC
Applicable when evaluating the
adequacy of soil remediation activities.
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AR307424
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Table 3 (Continued)
Chemical-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania
Standard, Requirement,
Criterion, Or Limitation
Citation Or
Reference
Description
Status
Comments
FEDERAL
Revised Interim Soil
Lead Guidance for
CERCLA Sites and
RCRA Corrective Action
Facilities
OSWER Directive
9355.4-12
August 1994
Establishes a
streamlined approach for
determining protective
levels of lead in soil at
CERCLA sites and
RCRA facilities
TBC
Recommends screening levels for lead
in soils for residential land use of 400
ppm; describes how to develop PRGs
for residential land use; and describes
a plan for soil lead cleanup at sites that
have multiple sources of lead.
Clarification to the 1994
Revised Interim Soil
Lead Guidance for
CERCLA Sites and
RCRA Corrective Action
Facilities
OSWER Directive
99200.4-27P
August 1998
EPA/540/F-
98/030
PB98-963244
Clarifies the Revised
Interim Soil Lead
Guidance for CERCLA
Sites and RCRA
Corrective Action
Facilities
TBC
Clarifies OSWER policy on using the
IEUBK model and blood lead studies;
determines geographic area to use in
evaluating human exposure to lead
contamination; addresses multimedia
lead contamination; and determines
appropriate response actions at lead
sites.
PENNSYLVANIA
Soil and Ground Water
Remediation Levels
25 PA Code 250,
Subpart 250.401
Protocol for developing
site remediation
standards
Applicable
Allows the use of site-specific
standards
Water Quality Standards
25 PA Code 93
Defines water quality
criteria, anti-degradation
requirements, and
designated water uses
for surface water
Applicable
Implementation of the Clean Streams
Law by PA. Applicable if on-site
treatment and discharge of surface
water occurs.
Water Quality Criteria
25 PA Code §§
16.11-16.52,
16.101-16.102,
Appendix A
Guidelines for
development of water
quality criteria for
surface water
Applicable
Implementation of the Clean Streams
Law by PA. Applicable if on-site
treatment and discharge of surface
water occurs.
Pennsylvania Guidance
Manual for Ground Water
Monitoring
December 2001
www.deD.state.us
Guidance for ground
water monitoring
TBC
Establishes guidelines for ground
water monitoring
Air Resources - Variance
and Alternate Standards
25 PA Code §
141.1
Criteria for
implementation of
alternate standards
related to ambient air
quality
Applicable
Applicable if imposed by PADEP
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