UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
GAF MATERIALS CORPORATION
QUAKERTOWN, PENNSYLVANIA
EPA ID # PAD096847835
Prepared by
Office of Pennsylvania Remediation
Land and Chemicals Division
August 2013
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Table of Contents
Section 1: Introduction 1
Section 2: Facility Background 2
Section 3: Summary of Environmental History 3
Section 4: Environmental Indicators 4
Section 5: Public Participation 5
Index to Administrative Record 6
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Section 1: Introduction
The United States Environmental Protection Agency (EPA) has prepared this Statement of Basis
(SB) to solicit public comment on its proposed decision for the GAF Materials Corporation
facility located at 60 Pacific Drive, Quakertown, Pennsylvania 18951 (Facility). EPA's
review of available information indicates that there are no unaddressed releases of
hazardous waste or hazardous constituents from the Facility. Based on that assessment,
EPA's proposed decision is that no further investigation or cleanup is required. EPA has
determined that its proposed decision is protective of human health and the environment
and that no further corrective action or land use controls are necessary at this time. This
SB highlights key information relied upon by EPA in making its proposed decision.
The Facility is subject to EPA's Corrective Action Program under the Solid Waste Disposal Act,
as amended by the Resource Conservation and Recovery Act (RCRA) of 1976, and the
Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. §§ 6901 et seq.
(Corrective Action Program). The Corrective Action Program is designed to ensure that certain
facilities subject to RCRA have investigated and cleaned up any releases of hazardous waste and
hazardous constituents that have occurred at their property. The Commonwealth of Pennsylvania
(Commonwealth) is not authorized for the Corrective Action Program under Section 3006 of
RCRA. Therefore, EPA retains primary authority in the Commonwealth for the Corrective
Action Program.
The Administrative Record (AR) for the Facility contains all documents, including data and
quality assurance information, on which EPA's proposed decision is based. See Section 5, Public
Participation, for information on how you may review the AR.
Statement of Basis
GAF Materials Corporation
August 2013
Page 1
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Section 2: Facility Background
The GAF Materials Corporation facility is an approximately 25-acre parcel located
approximately 13 miles southeast of Allentown in the northern section of Quakertown,
Pennsylvania.
The site is bound to the east by a rail line, to the south and west by Pacific Drive, and to
the north by light industrial development. The vicinity of the site is a combination of
light industry and recreational and residential property. A location map and a Facility layout
are attached as Figures 1 and 2, respectively.
The Facility was established on December 15, 1979 by Georgia-Pacific Corporation.
Georgia-Pacific had purchased the Facility in two separate parcels from the American
Funding Corporation. The first 20-acre parcel was purchased in 1978 and the adjoining
5-acre parcel in August 1979. Prior to Georgia-Pacific development, the site was
believed to be a farm. Georgia-Pacific operated the Facility until March 1994 when Atlas
Roofing Corporation purchased Georgia-Pacific's roofing business. The Building
Materials Corporation of America, doing business as GAF Materials Corporation,
purchased the Facility in May 2004. In 2008, GAF Materials Corporation ceased
operations at the Facility, which remains dormant in the hopes of potential future reuse.
Throughout the changes in ownership, the Facility manufactured asphalt shingle roofing,
roll roofing, and felt underlayment for roofing applications.
Statement of Basis
GAF Materials Corporation
August 2013
Page 2
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Section 3: Summary of Environmental History
A 1991 Preliminary Assessment identified five Solid Waste Management Units
(SWMUs) at the Facility. A 2004 Environmental Indicator (EI) Inspection Report
provided updated information on these SWMUs and included additional areas of concern
(AOCs) due to subsequent releases and remedial activities at the Facility. The table
below describes these SWMUs/AOCs as well as their post-investigation status.
Complete details, including sampling data, can be found in the individual reports which
are listed in the Index section of this SB and located in the AR. Sampling included soil
and groundwater and covered the SWMUs/AOCs impacted by releases at the Facility.
Target screening levels were determined to be EPA Region 3's residential Regional
Screening Levels (RSLs) for Volatile Organic Compounds (VOCs) in soil and EPA's
Maximum Contaminant Level (MCL) national primary drinking water standards for
VOCs in groundwater.
SWMU/AOC
Description
Current status
Former Drum Storage
Area
Previously stored heat transfer oil. motor oil.
transmission fluid, and grease drums
No evidence of spills or
releases observed or
reported
Waste Oil Tanks (two
275-gallon; one 600-
gallon)
Collect waste oil from condensing of vapors
during shingle manufacturing; 100-gallon
spill in 1983 resulted in removal of 150 yd3
of contaminated soil and implementation of
preventive measures
No further action required
after cleanup of 1983 spill;
no evidence of further spills
or releases observed or
reported
Hydrocarbon Collection
System
Collects fumes from top of asphal t tanks for
treatment through carbon bed
No evidence of spills or
releases observed or
reported
Safety-Kleen Units (one
25-gallon; one 10-
gallon)
Parts washers used in the maintenance shop
and lift truck shop; 2003 PADEP inspection
noted that non-hazardous solvents are used in
these units
No evidence of spills or
releases observed or
reported
Solvent Distillation
Unit
Small unit used in laboratory to test shingle
quality
No evidence of spills or
releases observed or
reported
Former 14,000-gallon
Fuel Oil Tank
Piping from this AST failed; tank and piping
were disposed of off-site in 1993; two
investigations resulted in removal of 4800
tons of contaminated soil; some total
petroleum hydrocarbons (TPH) remain in
limited areas of subsurface where excavation
not possible due to underground utilities
Low levels of TPH
remaining after 1993
remediation have likely been
attenuated to non-detectable
levels as a result of natural
degradation processes
Statement of Basis
GAF Materials Corporation
August 2013
Page 3
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Asphalt Tanks (four
40,000-gallon; one
10,000-gallon)
Store asphalt product; one tank sprayed
product over an approximately 16,900 fit2
area in 2003; asphalt solidified on contact
with ground; 66 tons of asphalt and impacted
surface soil excavated and disposed off-site
No further action required;
no evidence of further spills
or releases observed or
reported
Industrial Wastewater
and Stormwater
Discharges
Permit for process water discharge to
Quakertown Wastewater Plant: NPDES
general permit for stormwater discharges
No evidence of non-
compliance with permit
requirements
Air Emission Sources
Several heaters, vents, and stacks that
exhaust to outdoor air; many of these sources
had contributed to odor problems in the past
As of 2001, all air emissions
are regulated under Title V
Permit
Facility Groundwater
One release to perched groundwater occurred
as a result of leaking piping from former
14,000-gallon fuel oil AST; low levels of
TPH and xylenes were detected in grab
samples within excavation in 1993
Low levels of TPH and
xylenes have likely been
attenuated to non-detectable
levels as a result of natural
degradation processes
In summary, concentrations of hazardous constituents identified in the soil are within
EPA's Regional Screening Level risk range for residential use, and concentrations of
hazardous constituents identified in groundwater are all below EPA's Maximum
Contaminant Level national primary drinking water standards. Therefore, there are no
unacceptable risks to human health or the environment from hazardous constituents at
this Facility.
Section 4: Environmental Indicators
EPA sets national goals to measure progress toward meeting the nation's major
environmental goals. For Corrective Action, EPA evaluates two key environmental
indicators for each facility: (1) current human exposures under control and (2) migration
of contaminated groundwater under control. The EPA has determined that the Facility
met these indicators on June 4, 2013.
Statement of Basis
GAF Materials Corporation
August 2013
Page 4
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Section 5: Public Participation
Before EPA makes a final decision on its proposal for the Facility, the public may
participate in the decision selection process by reviewing this SB and documents
contained in the Administrative Record (AR) for the Facility. The AR contains all
information considered by EPA in reaching this proposed decision. It is available for
public review during normal business hours at:
U.S. EPA Region III
1650 Arch Street
Philadelphia, PA 19103
Contact: Griff Miller
Phone: (215) 814-3407
Fax: (215) 814-3113
Email: miller.griff@epa.gov
Interested parties are encouraged to review the AR and comment on EPA's proposed
decision. The public comment period will last thirty (30) calendar days from the date that
notice is published in a local newspaper. You may submit comments by mail, fax, or e-
mail to Mr. Miller. EPA will hold a public meeting to discuss this proposed decision
upon request. Requests for a public meeting should be made to Mr. Miller.
EPA will respond to all relevant comments received during the comment period. If EPA
determines that new information warrants a modification to the proposed decision, EPA
will modify the proposed decision or select other alternatives based on such new
information and/or public comments. EPA will announce its final decision and explain
the rationale for any changes in a document entitled the Final Decision and Response to
Comments (FDRTC). All persons who comment on this proposed decision will receive a
copy of the FDRTC. Others may obtain a copy by contacting Mr. Miller at the address
listed above.
Date: 8/26/13 /Wayne S. Navlor/ for
John A. Armstead, Director
Land and Chemicals Division
US EPA, Region III
Statement of Basis
GAF Materials Corporation
August 2013
Page 5
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Index to Administrative Record
Environmental Priorities Initiative, Preliminary Assessment of Georgia-Pacific
Corporation, NUS Corporation, June 1991.
Limited Subsurface Investigation of Georgia-Pacific Corporation, Waste Concepts,
August 1993.
Memos from Durham Environmental and Remediation Service to PADEP Regarding
Asphalt Spill, March 14 and 20, 2003.
Final Environmental Indicator Inspection Report for Atlas Roofing Corporation, 60 Pacific Drive,
Quakertown, PA 18951, prepared by Tetra Tech FW, August 2004.
Statement of Basis
GAF Materials Corporation
August 2013
Page 6
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