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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
FINAL DECISION AND RESPONSE TO COMMENTS
C&D Technologies, Inc.
82 East Main Street
Lcola, PA
PAD056771405
PURPOSE
The United States Environmental Proteetion Agency (EPA) is issuing this Final Decision
and Response to Comments (FDRTC or Final Decision) selecting the Final Remedy for the C&D
Technologies, Inc. facility located in I-cola. Pennsylvania (hereinafter referred to as the Facility
or Site). The Final Decision is issued pursuant to 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. Sections 6901, el seq.
On August 29, 2019. EPA issued a Statement of Basis (SB) in which it described the
information gathered during environmental investigations at the Facility and proposed a Final
Remedy for the Facility. The SB is hereby incorporated into this Final Decision by reference and
made a part hereof as Attachment A.
This FDRTC selects the remedy that EPA evaluated under the SB. Consistent with the
public participation provisions under RCRA. EPA solicited public comment on its proposed
Final Remedy. On August 29, 2019. notice of the SB was published on the EPA website:
I https://www.epa.aov/publicnotices/notiees-search I and in the LNP newspaper. The thirty (30)
day comment period ended on September 28, 2019.
Since EPA did not receive any comments on the SB, the remedy proposed in the SB is
the Final Remedy selected by EPA for the Facility.
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FINAL RI.MF.DY
I-PA's Final Remed_\ lor the i'aci 1 it\ is ihal there are 110 unaddressed releases and
therefore no further investigation or cleanup is required.
DECLARATION
Based on the Administrative Record compiled for the corrective action at the C&D
I echnoloyies. Inc. facility. I have determined that the remedy selected in this Final Decision
Response to Comments, v\ hich incorporates the August 2C). 2010 Statement of Basis, is
protectee of human health and the environment.
John
Land. Chemicals, and Redev elopment Division
IS I'.PA. Region 111
Attachment A: Statement of Basis (August 2019)
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ATTACHMENT A
STATEMENT OF BASIS
C&D Technologies, I tic,
I cohi, l'A
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! "\TII-D SI AITS
i \VIRO\\ir\T.\I. PRC) i! CllOX AlihXtA
RKilUX Ii!
SIAII"M!-:M of basis
C&D Technologies, Inc.
N2 I-as l Main Street
I,cola, PA ! 754(1
P \!)
Prepared b\
RCRA Correcli\e Action Braaeh 2
Land, Chemicals. and Redex elonmeni L>i\ ision
*\ui!u?i 20 H
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Table of'Contents
Sec'son 1: Inirtxtiuniotu...
Section 3; 1 aciltii Background
v-etiois J: Siiinsiiar\ of Kmimntnenial 11 Mm
Section 4: Knviromncntai Indicator;. ...............
Section 5; Public Participant*!?
Attachment A: Index in Admiiskmime Record
Figure I: Map of Facility
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Section i: Introduction
I lie t niied Slates l.mironmental Protection Agencv i! PA> has prepared ihis Statement
ol Basis (SB) to solicit public comment on its proposed reinedv tor the CA:D 1 cchnoloiiies, Inc.
lacilit) located at K2 I as| Main Street I.cola. Pcnns) l\ ania {here i nailer re I erred to as the facilitv
or Site). IPA's review of available information indicates that there arc no tmaJdressed releases
oi' hazardous waste or hazardous constituents from the Pucililv. Based on that assessment,
H'.Vs proposed decision is that no further imestimation or cleanup is required. 1 I'A has
determined that its proposed decision is protective of human health and the em iron men t and that
no lurther corrective action or land use controls are necessan at this time, "I his SB highlights
key information relied upon h\ I I'A is making its proposed decision.
I he facilitv is subject to PPA's Correcti\e .Action Program under the Solid Waste
Disposal Act, as amended b\ the Resource Conservation and Recover) Act (RCRA) of 1M76,
and the Hazardous and Solid Waste Amendments (11SWA) of 10X4. 42 C.S.C. 6W1 el seq.
I Corrective Action Program). I he Corrective Action Program is designed to ensure that certain
facilities subject to RCRA ha\e investigated and cleaned up am releases of hazardous waste and
hazardous constituents that have occurred at their property. I he Commonwealth of
Pennsylvania (Commonwealth) is not authorized for the Corrective Action Program under
Section 3006 of RCRA. 1 here fore, I-PA retains primarv authoritv in the Commonwealth for the
Corrective Action Program.
Id'A is providing a thirtv (30) day public comment period on this SB. I .PA tnav modifv
its proposed rcmed) based on comments received during this period. HPA will announce its
selection ol a Imal rcmed) lor the facility in a final I )ccision and Response to Comments {final
Decision) after the public comment period has ended.
Information on the Corrective Action program as well as a fact sheet for the fact lit} can
be found b\ navigating https; www.epa.gov hvvcorreeliveuctionsites contact-infonnaiioji-
correctivc-action-hazardous-wasie-clean-ups-delaw are.
1 he Administrative Record (AR) for the facility contains all documents, including data
and quality assurance information, on which PPA's proposed rented) is based. See Section 5,
Public Participation, below, for information on how vou may review the AR.
Section 2; Facility Background
1 he facility property consists of approximate!) 17.4 acres and is located in an
agricultural residential light industrial area. A map of the facility is attached as figure I.
'I he facility was used for the manufacture and storage of lead-acid batteries for the
telecommunications industry between 1(>72 and 2012. fhe Site consists of two pieces of land.
Statement of Basis
CA: I > feelinologics. Inc. tl eola, P \)
PAD 05 67"? |4()5
August 2019
Page I
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Section 2: i nei!h\ Background {eonlinueii)
I ract I (north! and 1 raci 2 (south), and includes two buildings. Building A and Building B.
Building A is located in I ruct I. and operations in this building included batten manufacturing-
Building B is located in Tract 2. and it was a warehouse used tor the storage and distribution of
new batteries,
I he propert} is currently owned by Purl Container Corporation (Dart), who purchased
the propert) from t'&I) on April 5, 2U13. At present, there are no ongoing batten operations at
the Site,
Section 3: Summitry of Lnvironniental llistur\
Site Wastes
The primar} ha/ardous constituent at the Site was lead from the manufacturing processes.
1.cad-tainted wastewater primutih consisted of washdown of equipment, product and floors.
1 his wastewater was treated on-site in a wastewater treatment svstem and then discharged to the
public sewer. C )ther. untreated wastewater collected from the past mixing process was stored and
subsequently transported off-site for treatment.
Additional lead-containing waste at the Site were dross, which is a b\-product of the
melting process, dust containing lead, and lead scrap, bead-containing waste was collected,
stored, and transported off-site to a smelter.
Solvents at the Site from laboratory processes and spent epo\\ wa>tc was stored outside
in 55-gallon drums. Spent cooling oil and Imlraulie oils were also stored in 55-galIon drums.
Releases and Remedial Actions
Historical releases of regulated substances ha\ e occurred at unions times between 1l>82
and I VMS, 1 he releases are described below, as well as the immediate remedial acti\ hies
performed,
ts)82 - Wastewater treatment sy stem released approximate!} CilKltl gallons of non-hazardous
wastewater into the soil when a storage tank developed a leak. The tank was removed and 75cu
yd soil was excavated. Monitoring wells MW'-l. MW-2, and MW-3 were installed following
this release to monitor groundwater.
1982 ¦ A pipe connector ruptured. rcleaMiig 1 SIM) gallons of w astewater consisting of boiler
blow down and waste oils. Approximately t).37cu yd of soils were removed and monitoring well
MW-4 was installed to monitor groundwater.
Statement of Basis
C&l) I eclmologies. Inc tl cola. I* \ >
PAD 05677 1 105
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See I in n 3: Siimmnn of Kn\ironinen fai Mistorv (eontinucd)
H>.X4 Approximate!) 300-500 gallons ofwastew,tier was released from a ruptured h\-pass
valve 1 he released eiiteivd (he 1 ;ici 1 iIs 's \l'l )l S-permitted discharge dileh, I alcr. in NXo.
another 50-100 gallons were released to the discharge ditch when a hose connector ruptured- At
thai lime, some of the wastewater was recovered and 1 lie area was (lushed with deioni/ed water,
I^NK in two (2) e\ems. lead oxide powder was released when being transferred to a storage
silo. Approximate!) two (2) pounds total of lead was emitted in total. Remedial cleanup
included vacuuming the impacted roof and pavement. cleaning nearbv equipment, and wet-lloor
.scrubbing on paved areas.
I4KN- A wastewater release outside of Building A was found to have elevated levels of lead in
soil but not in groundwater. Cleanup inv olvcd removal of 71 tons of soil.
Site Inv esti^ations/Dccum missioning
Tank (..'insures
1W4 and 21)02 Closure was completed for a 1000-gal|on gasoline underground storage tank
{removed) and a 6000-galIon former wastewater underground storage tank (closed in place). No
ev idence of teaks or releases were found at these closures.
Soils
2(112 and 2013 - During Site decommissioning, a 2012 soils investigation was conducted to
evaluate potential presence ol lead in soils within Building A and between Buildings A and B.
I his included areas lor deliveries, equipment handling, storm sewer drainage, above ground
tanks and underground tanks. A total of 129 samples from ft I soil boring locations as well as 11
other sampling locations, including sediments from the stormwater sewer line, were collected.
Several surface and subsurface samples contained lead at concentrations above the direct contact
anil soil to groundwater Act 2 Statewide 1 lealth Standards (SI ISs). pailicularlv in the stormwatei
drainage ditch. An additional soil investigation in 20!3 focusing on this impacted stormwater
drainage ditch area. As a number of areas along the ditch were found to have elevated lead
levels, soil was removed along the entire length and width of the drainage ditch, as well as the
sediment from a collection sump near the railroad tracks.
Between ll)K2 and 2013, approximately 593 tons of material was removed and
transported otl-siie for treatment. Post-excavation sampling confirmed soils did not show lead
levels above residential and non-residential SI IS at the Site.
(ininndwatcr
In March 2013, live (5) on-site monitoring wells were installed, and groundwater samples
were collected and analv/ed lor volatile organic compounds, semivolatiie organic compounds,
and metals. 1 he onlv parameter to be detected at a concentration above the residential used-
aquifer SI IS in Site groundwater was dissolved lead (7.5 ug l in \1\\ -5>. The Pcnnsv Iv ania Vet 2
Statecnenl of Bask
I ttl) 1 eehnologiev Inc. (I cola. PA )
PAP (15 67? I 1(15
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Section 3: Summary of Yaw iron men t;il 11 islot \ (continued)
residential uscd-ai|uilet Si IS lor lead In 5 lit; 1. 1 PA's drinking water standard for lead is 1 5 tm i,
W cli M\\ is located in the southwestern portion of 1 ract 1. near the stonnwater drainage ditch
and areas ol previous!) e\ca\ated lead-impacted soil. Sod containing lead at concentrations
above its residential soil SI IS was excav ated from the drainage ditch during prc\ ions remedial
;tcti\itics conducted at the Site (see abo\c). Dissolved lead was not detected ahove the
residential used-aquifer SI IS in am other groundwater location.
In Jul\ 201.> and februur) 2014. groundwater was collected from on-site monitoring
wells to lurther charaeteri/e and delineate dissolved lead detected previously in groundwater.
During these monitoring events. lead was no! defected in groundwater above the residential used-
aijiiiler SI IS at am location, including MW-5.
As there was one sample in early 2013 that showed a slight!) elevated level of dissolved
lead at MW-5. the Faeilitv performed a Human Health Risk Assessment (II! IRA) to evaluate
potential risks associated with dissolved lead in groundwater at the Site. I he site-specific
III IRA was conducted to provide quantitative anahsis ol current and future tin-site and tiff-site
land use scenarios based on the nature ol the dissolved lead detected in the groundwater,
potential exposure pathways to human receptors, and the degree to which these exposures mav
pose adveise effects.
I he Site and hvdraulicalh downgradient properties have been commercially developed
and. although future use of (he Site for residential purposes is highlv unlikely, the III IRA
conservatively evaluated potential on-site and off-site residential exposure to dissolved lead in
groundwater, I he i II IRA shows that there is no unacceptable risk to lead in groundwater tor
residential or non-residential land-use scenarios for the Site.
A report on the Site investigations and remedial work was submitted April 2014.
PAPhP pro\ ided Act 2 approval on Julv 00. 2014. No land-use or ground water-use controls
were required h\ PADPP,
Section 4: Yawiromnentiil Indicators
HI'A sets national goals to measure progress toward meeting the nation's major
env ironmental goals. lor ( orrecthe Action. I ,PA evaluates two key env ironmcntal indicators
for each taeilitv: (1! current human exposures under control and {2) migration of contaminated
groundwater under control. I-PA has determined that the facility met both the migration of
contaminated groundwater under control indicator and the current human exposures under
control indicator on January OS, 2IHI1.
Statement of Basis
( tk!> I cchnologies. Inc (I cola. PA >
PAD 05 h7T 1405
Sugust 2n|0
Page 4
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i !\nitOi'(u A • In A'\ ! i li e.
PAD (II 015 41)45
l-miranmenml Priorities Iniiiaii\e, Preliminary Assessment ol*Ultra Corporation CM)
Batteries Division; XL'S, tinted September 13, I*>89
Lnvironmemal Assessment Inspection Report: lor C&D Tetiinologies. Inc. Leola, PA; USAC1:.
dated April 5, 1999
Remedial Invesiiyation/Risk Assessment/Final Report for C&D Technologies. Inci URS» dated
••V-ris 2014
Statement of" Basis
C&D Technologies. Inc. (Leola, lJA)
PAD 05 6?7 1405
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Figure 1
Statement of Basis
C&D Technologies. Inc. (Leola. PA)
PAD 05 677 1405
August 2019
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