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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/R03-91/108
ROD Date:  12/17/1990
Operable Unit(s):  02
 
Media:  DEBRIS SLUDGE
 
Contaminant:  VOCS, BENZENE, PCE, TOLUENE, XYLENES, OTHER ORGANICS, PHENOLS, METALS, ARSENIC, LEAD
 
Abstract:  THE 22-ACRE WHITMOYER LABORATORIES SITE IS AN ABANDONED ANIMAL PHARMACEUTICAL MANUFACTURING FACILITY IN JACKSON TOWNSHIP, LEBANON COUNTY, PENNSYLVANIA. LAND USE IN THE AREA IS PREDOMINANTLY AGRICULTURAL, AND THERE ARE WETLANDS AREAS ADJACENT TO THE SITE. PART OF THE SITE LIES WITHIN THE 100-YEAR FLOODPLAIN OF THE TULPEHOCKEN CREEK-UNION CANAL, AND AN ESTIMATED 40 RESIDENCES IN THE VICINITY OF THE SITE USE THE UNDERLYING AQUIFER AS THEIR DRINKING WATER SUPPLY. FROM 1957 TO 1964, WHITMOYER LABORATORIES, INC., PRODUCED ORGANIC ARSENICALS ONSITE. IN 1964, THE NEW SITE OWNERS, BEGAN STORING CONCENTRATED WASTES IN AN ONSITE CONCRETE VAULT AND, UNTIL 1971, CONDUCTED ONSITE PUMPING AND TREATMENT OF GROUND WATER AND OCEAN DUMPING OF WASTES. IN 1977, SLUDGE FROM GROUND WATER TREATMENT WAS PLACED IN ONSITE LAGOONS IN THE EASTERN AREA OF THE SITE. BETWEEN 1978 AND 1982, THE SITE CHANGED OWNERSHIP TWICE, AND THEN IN 1985, A RCRA SITE CLOSURE PLAN WAS FILED. IN 1986, EPA PROVIDED BOTTLED WATER TO RESIDENCES WITH CONTAMINATED GROUND WATER. ONSITE CONTAMINATION OF SOIL AND GROUND WATER HAS RESULTED FROM A COMBINATION OF POOR HOUSEKEEPING, POOR DISPOSAL PRACTICES, AND IMPROPER STORAGE OF HAZARDOUS MATERIALS. IN 1986, ARSENIC CONTAMINATION WAS DETECTED IN NEARBY RESIDENTIAL WELLS BY EPA. WHEN THE SITE WAS ABANDONED IN 1987, VERY LITTLE OF THE RCRA CLOSURE PLAN HAD BEEN IMPLEMENTED. FROM 1988 TO 1990, EPA REMOVED THE ABANDONED DRUMS AND LABORATORY WASTES FROM THE SITE. A 1989 RECORD OF DECISION (ROD) PROVIDED FOR OFFSITE REMOVAL OF CONCENTRATED LIQUIDS IN ABANDONED TANKS AND PROCESS VESSELS AS THE FIRST OPERABLE UNIT (OU1). THIS ROD ADDRESSES OU2, WHICH INCLUDES REMEDIATION OF CHEMICAL VAULT AND LAGOON WASTES, OUT-DATED PRODUCTS, MISCELLANEOUS CHEMICALS AND FEEDSTOCKS, AND CONTAMINATED SITE STRUCTURES. A ROD FOR OU3 WILL ADDRESSES REMEDIATION OF CONTAMINATED ONSITE SOIL AND GROUND WATER. THE PRIMARY CONTAMINANTS OF CONCERN AFFECTING THE DEBRIS AND SLUDGE ARE VOCS INCLUDING BENZENE, PCE, TOLUENE, AND XYLENES; OTHER ORGANICS INCLUDING PHENOLS; AND METALS INCLUDING ARSENIC AND LEAD.

THE SELECTED REMEDIAL ACTION FOR THIS SITE INCLUDES EXCAVATING AND INCINERATING ONSITE APPROXIMATELY 3000 CUBIC YARDS OF HIGH ORGANIC CONTENT VAULT WASTES, AND APPROXIMATELY 101 CUBIC YARDS OF MISCELLANEOUS PRODUCTS AND FEEDSTOCKS, FOLLOWED BY CEMENT/POZZOLAN-BASED FIXATION, AND DISPOSING OF THE RESIDUAL ASH OFFSITE; TREATING APPROXIMATELY 1,500 CUBIC YARDS OF LOW ORGANIC CONTENT VAULT WASTES USING FIXATION OR A SIMILAR FIXATION PROCESS, FOLLOWED BY OFFSITE DISPOSAL; EXCAVATING AND INCINERATING ONSITE APPROXIMATELY 20 BURIED DRUMS AND 50 CUBIC YARDS OF TANK AND PROCESS VESSEL RESIDUALS, FOLLOWED BY TREATING ANY RESIDUAL ASH USING FIXATION, AND OFFSITE DISPOSAL OF RESIDUALS; EXCAVATING APPROXIMATELY 24,000 CUBIC YARDS OF ARSENIC-CONTAMINATED LAGOON WASTES WITH LEVELS ABOVE 10,000 MG/KG, FOLLOWED BY FIXATION OF THE HAZARDOUS LAGOONS WASTES; AND DISPOSING OF RESIDUALS ALONG WITH NONHAZARDOUS WASTES AND OTHER PRODUCTS AND FEEDSTOCKS OFFSITE; DEMOLISHING BUILDINGS, ASSOCIATED TANKS, VESSELS, PROCESSING EQUIPMENT, AND DEBRIS; INCINERATING ONSITE ANY COMBUSTIBLE DEBRIS EXHIBITING THE RCRA ARSENIC TOXICITY CHARACTERISTIC, FOLLOWED BY OFFSITE DISPOSAL; COATING AND SEALING NONCOMBUSTIBLE PERMEABLE DEMOLITION DEBRIS PRIOR TO OFFSITE DISPOSAL; SURFACE CLEANING OF NONCOMBUSTIBLE IMPERMEABLE DEMOLITION DEBRIS, WHICH EXHIBIT THE RCRA ARSENIC TOXICITY CHARACTERISTIC AND CONTAMINATED ONSITE STRUCTURES BEFORE OFFSITE DISPOSAL; AND OFFSITE DISPOSAL OR RECYCLING OF UNTREATED UNSALVAGED DEMOLITION DEBRIS. THE ESTIMATED PRESENT WORTH COST FOR THIS REMEDIAL ACTION IS $45,800,000. THERE ARE NO O&M COSTS ASSOCIATED WITH THIS REMEDIAL ACTION DUE TO SELECTION OF OFFSITE DISPOSAL FOR RESIDUALS.

PERFORMANCE STANDARDS OR GOALS; CHEMICAL-SPECIFIC DEBRIS AND SURFACE WATER CLEANUP GOALS WERE NOT PROVIDED, BUT CLEANUP WILL BE BASED ON RCRA, CAA, CWA, AND STATE STANDARDS.
 
Remedy:  THIS OPERABLE UNIT (OU) IS THE SECOND OF THREE OPERABLE UNITS FOR THE SITE. THE REMEDIAL ACTION FOR THE FIRST OPERABLE UNIT (OU ONE) AT THIS SITE INVOLVED REMEDIATION OF HAZARDOUS CONCENTRATED LIQUIDS WHICH WERE ABANDONED AT THE SITE. THE REMEDIAL ACTION FOR THE SECOND OPERABLE UNIT (OU TWO) ADDRESSES CONCENTRATED WASTES ABANDONED IN A CONCRETE VAULT; CONCENTRATED WASTES ABANDONED IN TWO GROUPS OF LAGOONS; OUTDATED PRODUCTS AND MISCELLANEOUS CHEMICALS ABANDONED IN THE BUILDINGS; AND THE BUILDINGS AND RELATED STRUCTURES (TANKS, PROCESS VESSELS, ETC.) LOCATED ON THE SITE. THESE MATERIALS POSE SOME OF THE PRINCIPAL THREATS AT THE SITE. THE THIRD OPERABLE UNIT, (OU THREE) WILL ADDRESS SOIL AND GROUNDWATER CONTAMINATION AT THE SITE AND POSSIBLE REMEDIATION THEREOF. THE US ENVIRONMENTAL PROTECTION AGENCY (EPA) HAS SELECTED THE FOLLOWING REMEDIAL ACTION FOR OU TWO. THIS REMEDIAL ACTION ADDRESSES THE HAZARDS POSED IN OU TWO BY TREATING THE MOST CONTAMINATED MATERIALS, AND DISPOSING OF TREATMENT RESIDUALS AND THE MATERIALS CONTAMINATED AT LOW LEVELS OFFSITE, SUCH THAT THE MATERIALS WILL NOT REQUIRE ANY LONG-TERM ONSITE MANAGEMENT.

THE MAJOR COMPONENTS OF THE SELECTED REMEDIAL ACTION ARE AS FOLLOWS;
* EXCAVATION OF THE ARSENIC AND ORGANICALLY-CONTAMINATED CONCRETE VAULT-CONTENTS (4,500 CUBIC YARDS), THE APPROXIMATELY 20 BURIED DRUMS LOCATED EAST OF THE VAULT, AND AN ESTIMATED 50 CUBIC YARD OF RESIDUALS POTENTIALLY PRESENT IN THE TANKS AND PROCESS VESSELS NOT ADDRESSED UNDER OU ONE.
* EXCAVATION OF THE APPROXIMATELY 24,000 CUBIC YARD OF MATERIALS PRESENT IN THE LAGOONS HAVING AN ARSENIC CONTENT GREATER THAN 10,000 MG/KG (LAGOON WASTES).
* REMOVAL OF THE APPROXIMATELY 101 CUBIC YARD OF MISCELLANEOUS PRODUCTS/FEEDSTOCKS FROM THE BUILDINGS.
* SURFACE CLEANING OF CONTAMINATED SITE STRUCTURES.
* REMEDIATION OF DANGEROUS CONDITIONS EXISTING IN BUILDINGS OUTSIDE OF THE BUILDING 1-7 COMPLEX.
* DEMOLITION OF THE BUILDING 1-7 COMPLEX AND ALL TANKS, VESSELS, PIPING, PROCESS EQUIPMENT, AND OUTDOOR TANK CONCRETE DIKES.
* ONSITE INCINERATION OF THE FOLLOWING; APPROXIMATELY 3,000 CUBIC YARD OF HIGH ORGANIC CONTENT WASTES PRESENT IN THE VAULT; THE CONTENTS OF THE APPROXIMATELY 20 BURIED DRUMS; THE ESTIMATED 50 CUBIC YARD OF RESIDUALS POTENTIALLY PRESENT IN THE TANKS AND PROCESS VESSELS NOT BEING ADDRESSED UNDER OU ONE; AND THE MISCELLANEOUS PRODUCTS/FEEDSTOCKS AND COMBUSTIBLE DEMOLITION DEBRIS EXHIBITING THE RCRA ARSENIC TOXICITY CHARACTERISTIC. THE REMEDY SELECTED BY EPA IS INCINERATION THAT MEETS ALL RCRA, NAAQS, AND NESHAPS REQUIREMENTS AND THAT IS DEMONSTRATED TO BE SAFE DURING THE REMEDIAL DESIGN PHASE OF ROD IMPLEMENTATION.
* FIXATION OF THE INCINERATION RESIDUALS AND THE APPROXIMATELY 1,500 CUBIC YARD OF LOW ORGANIC CONTENT WASTES PRESENT IN THE VAULT USING A CEMENT/POZZOLAN-BASED OR OTHER SIMILAR FIXATION PROCESS THAT PROVIDES EQUIVALENT PROTECTION.
* FIXATION OF THE LAGOON WASTES EXHIBITING THE RCRA ARSENIC TOXICITY CHARACTERISTIC USING AN IRON-BASED OR OTHER SIMILAR FIXATION PROCESS THAT PROVIDES EQUIVALENT PROTECTION.
* COATING AND SEALING THE NONCOMBUSTIBLE, PERMEABLE DEMOLITION DEBRIS EXHIBITING THE RCRA ARSENIC TOXICITY CHARACTERISTIC.
* SURFACE CLEANING THE NONCOMBUSTIBLE, IMPERMEABLE DEMOLITION DEBRIS EXHIBITING THE RCRA ARSENIC TOXICITY CHARACTERISTIC.
* SALVAGING NONHAZARDOUS DEMOLITION DEBRIS, AS FEASIBLE.
* DISPOSAL OF THE FOLLOWING IN ACCORDANCE WITH ALL APPLICABLE REGULATIONS; THE TREATED WASTES; THE UNTREATED (NONHAZARDOUS) LAGOON WASTES; THE UNTREATED (NONHAZARDOUS) MISCELLANEOUS PRODUCTS/FEEDSTOCKS; AND THE UNTREATED (NONHAZARDOUS) DEMOLITION DEBRIS THAT IS NOT SALVAGED IN OFFSITE LANDFILL(S).
 
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