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Record of Decision System (RODS)

WHITMOYER LABORATORIES

Abstract

Site Name:  WHITMOYER LABORATORIES
Address:  19 N RAILROAD ST 
City & State:  JACKSON TOWNSHIP  PA  17067
County:  LEBANON
 
EPA ID:  PAD003005014
EPA Region:  03
 
NPL Status:  Currently on the Final NPL
 
ROD Type:  Record of Decision
ROD ID:  EPA/ROD/R03-89/075
ROD Date:  06/30/1989
Operable Unit(s):  01
 
Media:  CONCENTRATED LIQUIDS IN TANKS AND PIPING UNITS
 
Contaminant:  VOCS, PCE, METALS, ARSENIC
 
Abstract:  THE 22-ACRE WHITMOYER LABORATORIES SITE IS LOCATED IN JACKSON TOWNSHIP, LEBANON COUNTY, PENNSYLVANIA. LAND USE SURROUNDING THE SITE IS PREDOMINANTLY AGRICULTURAL; HOWEVER, THERE IS SOME RESIDENTIAL, COMMERCIAL, AND INDUSTRIAL DEVELOPMENT WITHIN 1.5 MILES OF THE SITE. THIS INCLUDES A MANUFACTURING PLANT TO THE SOUTH; A PHARMACEUTICAL FACTORY TO THE EAST; A LARGE, ACTIVE LIMESTONE QUARRY TO THE WEST; AND AN ELEMENTARY SCHOOL TO THE NORTHWEST OF THE SITE. PORTIONS OF THE SITE ARE WITHIN NEIGHBORING TULPEHOCKEN CREEK'S 100-YEAR FLOODPLAIN. THE CREEK, WHICH IS BORDERED BY SMALL, OPEN WETLANDS AREAS, IS BEING PROPOSED FOR INCLUSION IN PENNSYLVANIA'S SCENIC RIVER SYSTEM, WITH A "PRIORITY 1A STATUS." PRIORITY 1A STATUS WOULD DESIGNATE THE STREAM AS BEING IN MOST URGENT NEED OF PROTECTION. IN 1957 SITE OWNERS BEGAN PRODUCING ORGANIC ARSENICALS AT THE SITE. IN 1964 WIDESPREAD GROUND WATER CONTAMINATION WAS DISCOVERED ONSITE LEADING TO THE PLACEMENT OF CONCENTRATED WASTES IN A CONCRETE VAULT AND THE INITIATION OF GROUND WATER PUMPING AND TREATMENT. SLUDGES FROM THE GROUND WATER TREATMENT WERE LATER CONSOLIDATED IN LAGOONS. IN 1987 AN EPA INVESTIGATION REVEALED THAT APPROXIMATELY 69,000 GALLONS OF CONCENTRATED LIQUIDS HAD BEEN ABANDONED ONSITE IN 18 TANKS AND 14 PIPING UNITS. THE WASTES INCLUDE 5,000 GALLONS OF WATER-IMMISCIBLE LIQUIDS, 25,000 GALLONS OF WATER-MISCIBLE LIQUIDS WITH A HIGH ARSENIC CONTENT, AND 39,000 GALLONS OF WATER-MISCIBLE LIQUIDS WITH A LOW ARSENIC CONTENT. ALL THE TANKS AND PIPING UNITS ARE WITHIN 400 FEET OF TULPEHOCKEN CREEK; 27 OF THE 32 TANKS AND PIPING ARE WITHIN 150 FEET. BECAUSE THE SITE SLOPES TOWARD THE CREEK, ANY RELEASE FROM A TANK OR PIPING FAILURE IS LIKELY TO CONTAMINATE THE CREEK. FLOODING OF THE CREEK COULD CAUSE FAILURE OF THESE TANKS, RESULTING IN CATASTROPHIC RELEASE OF CONTAMINANTS TO THE CREEK. ADDITIONALLY, CONTAMINANTS RELEASED FROM THE TANKS AND PIPING UNITS COULD MIGRATE TO GROUND WATER AND OR THE DRINKING WATER SUPPLY LINES SERVING THE SITE. BECAUSE THE CONCENTRATED LIQUIDS POSE SIGNIFICANT HEALTH AND ENVIRONMENTAL THREATS, THEIR REMOVAL IS ADDRESSED IN THIS FIRST OPERABLE UNIT. SUBSEQUENT OPERABLE UNITS WILL IDENTIFY POTENTIAL SOIL, GROUND WATER, AND SURFACE WATER/SEDIMENT CONTAMINATION AND ADDITIONAL REMEDIAL ACTIONS THAT MAY BE NECESSARY. THE PRIMARY CONTAMINANTS OF CONCERN IN THE CONCENTRATED LIQUIDS ARE VOCS INCLUDING PCE, AND METALS INCLUDING ARSENIC.

THE SELECTED INTERIM REMEDIAL ACTION FOR THIS SITE INCLUDES CONSOLIDATING, TRANSPORTING OFFSITE, AND THEN TREATING, USING THERMAL TREATMENT OR BIODEGRADATION, OR RECYCLING APPROXIMATELY 69,000 GALLONS OF CONCENTRATED LIQUID WASTES AT A PERMITTED RCRA FACILITY, FOLLOWED BY DISPOSING OF TREATED WATER IN OFFSITE SURFACE WATER AND DISPOSING OF SOLID RESIDUES IN AN OFFSITE LANDFILL; DECONTAMINATING 32 TANKS AND APPROXIMATELY 2,000 FEET OF PIPING TO MEET RCRA SUBTITLE C CLOSURE STANDARDS AND DISPOSING OF THE TANKS AND PIPING ONSITE; AND TREATING AND DISPOSING OF THE CLEANING AGENT RESIDUES OFFSITE AT RCRA-PERMITTED FACILITIES. THE ESTIMATED CAPITAL COST OF THIS INTERIM REMEDIAL ACTION IS $475,000, WITH NO O&M COSTS.
 
Remedy:  THIS OPERABLE UNIT IS THE FIRST OF SEVERAL FOR THE SITE. THIS FIRST OPERABLE UNIT ADDRESSES HAZARDOUS CONCENTRATED LIQUIDS (THAT ARE PRESENT IN TANKS AND VESSELS), OUTDATED LIQUID PRODUCTS, AND OTHER MISCELLANEOUS LIQUID CHEMICALS (HEREAFTER REFERRED TO AS "CONCENTRATED LIQUIDS") WHICH HAVE BEEN ABANDONED AT THE SITE. ACTUAL OR THREATENED RELEASES OF HAZARDOUS SUBSTANCES FROM THIS SITE, IF NOT ADDRESSED BY IMPLEMENTING THE RESPONSE ACTION SELECTED IN THIS ROD, MAY PRESENT AN IMMINENT AND SUBSTANTIAL ENDANGERMENT TO PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT.

THE SELECTED REMEDY INVOLVES CONSOLIDATING THE WASTE LIQUIDS INTO APPROXIMATELY THREE GENERAL CATEGORIES, TRANSPORTING THE WASTES OFF-SITE FOR TREATMENT, AND EVENTUALLY DISPOSING OF THE TREATED LIQUIDS INTO AN OFF-SITE SURFACE-WATER BODY AND DISPOSING OF SOLID RESIDUALS IN AN OFF-SITE LANDFILL. ORGANIC COMPOUNDS PRESENT IN THE LIQUIDS WILL BE DESTROYED, EITHER DIRECTLY OR INDIRECTLY, THROUGH THERMAL TREATMENT OR BIODEGRADATION; OR BE RECYCLED. THE TANKS AND VESSELS (AND ASSOCIATED PIPING) WILL THEN BE CLEANED, USING, AS APPROPRIATE, STEAM, EMULSIFIERS, WATER, ETC., TO REMOVE THE BULK CONTAMINATION FROM THESE ITEMS AND MEET RESOURCE CONSERVATION RECOVERY ACT (RCRA) CLOSURE REGULATIONS. THE DECONTAMINATED TANKS AND VESSELS WOULD THEN BE LEFT ON-SITE FOR FUTURE REUSE, SCRAP, OR DISPOSAL. NO DEMOLITION OF THE TANKS AND VESSELS IS INCLUDED UNDER THIS ALTERNATIVE. THE CLEANING AGENTS WOULD BE TREATED AND DISPOSED OFF-SITE. UNDER THE SELECTED REMEDY, SPECIFIC TREATMENT TECHNOLOGY(IES) ARE NOT IDENTIFIED AT THIS POINT SO AS NOT TO LIMIT POTENTIAL VIABLE TECHNOLOGIES FOR THE REMEDIAL ACTION.

THE REMEDY DOES NOT ADDRESS THREATS POSED BY GROUNDWATER, SURFACE WATER/SEDIMENT, SOILS, AND OTHER CONTAMINANT SOURCES AT THE SITE. SUBSEQUENT RECORDS OF DECISION FOR THESE ITEMS WILL BE PREPARED FOLLOWING COMPLETION OF THE REMEDIAL INVESTIGATION (RI) AND FEASIBILITY STUDY (FS).

THE MAJOR COMPONENTS OF THE SELECTED REMEDY INCLUDE;
* INTERIM TANK INSPECTION.
* COMPATIBILITY TESTING AND CONSOLIDATION OF APPROXIMATELY 69,000 GALLONS OF CONCENTRATED LIQUID WASTES INTO APPROXIMATELY THREE CATEGORIES.
* TRANSPORTATION OF THESE WASTES OFF-SITE FOR TREATMENT.
* TREATMENT OF THE WASTES AT A PERMITTED FACILITY.
* DISPOSAL/DISCHARGE OF SOLID AND LIQUID TREATMENT RESIDUALS.
* DECONTAMINATION OF 32 TANKS AND VESSELS AND ABOUT 2,000 LINEAR FEET OF PIPING.
* COLLECTION, OFF-SITE TRANSPORTATION, TREATMENT AND DISPOSAL OF ABOUT 8,000 GALLONS OF DECONTAMINATION FLUIDS.
* INSPECTION OF TANKS AND PIPING FOR COMPLIANCE WITH DESIGN SPECIFICATIONS.

THE SELECTED REMEDY IS ONE OF THE FIRST PHASES OF THE LONG-TERM REMEDIATION OF THIS SITE AND WILL BE CONSISTENT WITH THE FINAL REMEDY.
 
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