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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/R03-91/109
ROD Date:  12/31/1990
Operable Unit(s):  03
 
Media:  SOIL SEDIMENT DEBRIS GROUND WATER
 
Contaminant:  VOCS, BENZENE, TCE, PCE, OTHER ORGANICS, PAHS, METALS, ARSENIC
 
Abstract:  THE 22-ACRE WHITMOYER LABORATORIES SITE IS AN INACTIVE LABORATORY FACILITY IN JACKSON TOWNSHIP, LEBANON COUNTY, PENNSYLVANIA. LAND USE IN THE AREA IS PREDOMINANTLY AGRICULTURAL WITH ADJACENT WETLANDS AREAS. IN ADDITION, PART OF THE SITE LIES WITHIN THE 100-YEAR FLOODPLAIN OF THE TOLPEHOCKEN CREEK-UNION CANAL. AN ESTIMATED 20 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 OWNERS, ROHM & HAAS, BEGAN STORING CONCENTRATED WASTES IN A CONCRETE VAULT, AND UNTIL 1971 CONDUCTED ONSITE GROUND WATER PUMPING AND TREATMENT AND OCEAN DUMPING OF WASTES. IN 1977, SLUDGE FROM GROUND WATER TREATMENT WAS PLACED IN 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 BEGAN PROVIDING BOTTLED WATER TO RESIDENTS WITH GROUND WATER CONTAMINATED BY SITE ACTIVITIES. A PUBLIC WATER SUPPLY LINE EXTENSION IS CURRENTLY BEING DESIGNED AND WILL BE CONSTRUCTED AS PART OF A REMOVAL ACTION. WHEN THE SITE WAS ABANDONED IN 1987, VERY LITTLE OF THE RCRA CLOSURE PLAN HAD BEEN IMPLEMENTED. FROM 1988 TO 1990, EPA REMOVED APPROXIMATELY 800 ABANDONED DRUMS AND LABORATORY WASTES OFFSITE. A 1989 RECORD OF DECISION (ROD) PROVIDED FOR REMEDIATION OF HAZARDOUS CONCENTRATED LIQUIDS, INCLUDING LABORATORY WASTES, ABANDONED AT THE SITE AS OPERABLE UNIT 1 (OU1). A DECEMBER 1990 ROD PROVIDED A REMEDY FOR VAULT AND LAGOON WASTES, MISCELLANEOUS PRODUCTS AND FEEDSTOCKS, TANKS, PROCESS VESSELS, AND OTHER ONSITE STRUCTURES AS OU2. THIS ROD ADDRESSES CONTAMINATED ONSITE SOIL, SEDIMENT, AND GROUND WATER AS OU3. THE PRIMARY CONTAMINANTS OF CONCERN AFFECTING THE SOIL, SEDIMENT, DEBRIS, AND GROUND WATER ARE VOCS INCLUDING BENZENE, TCE, AND PCE; OTHER ORGANICS INCLUDING PAHS; AND METALS INCLUDING ARSENIC.

THE SELECTED REMEDIAL ACTION FOR THIS SITE INCLUDES EXCAVATING AND FIXATION OF APPROXIMATELY 61,000 CUBIC YARDS OF SOIL/SEDIMENT WITH CONTAMINANT CONCENTRATIONS ABOVE THE "PRINCIPAL THREAT" ACTION LEVELS USING AN IRON-BASED OR OTHER FIXATION PROCESS, FOLLOWED BY OFFSITE DISPOSAL; USING BIOLOGICAL TREATMENT FOR APPROXIMATELY 5,600 CUBIC YARDS OF SOIL/SEDIMENT WITH ORGANIC CONCENTRATIONS ABOVE THE "PRINCIPAL THREAT" ORGANIC CHEMICAL ACTION LEVELS FOR THE HEAVILY CONTAMINATED SOIL EITHER PRIOR TO OR FOLLOWING FIXATION, FOLLOWED BY OFFSITE DISPOSAL; EXCAVATING AND CONSOLIDATING ONSITE IN THE VADOSE ZONE APPROXIMATELY 39,000 CUBIC YARDS OF SOIL/SEDIMENT HAVING CONTAMINANT CONCENTRATIONS BELOW THE "PRINCIPAL THREAT" ACTION LEVELS BUT ABOVE GROUND WATER-BASED UNSATURATED SOIL CLEAN-UP TARGETS, FOLLOWED BY CAPPING WITH LOW-PERMEABILITY MATERIALS; PLACING ONSITE IN THE VADOSE ZONE APPROXIMATELY 16,000 CUBIC YARDS OF SOIL/SEDIMENT WITH CONCENTRATIONS BELOW THE GROUND WATER-BASED UNSATURATED SOIL ACTION LEVELS; SOIL CAPPING ANY REMAINING CONTAMINATED SURFACE SOIL THAT CONTAINS ARSENIC CONCENTRATIONS GREATER THAN 21 MG/KG AND OTHER DISTURBED AREAS, AS NEEDED; BACKFILLING, GRADING, AND REVEGETATING THE EXCAVATED AREAS; DEMOLISHING ONSITE STRUCTURES, FOLLOWED BY SALVAGING NON-HAZARDOUS DEBRIS AND OFFSITE DISPOSAL OF UNSALVAGED DEBRIS; ONSITE PUMPING AND TREATMENT OF CONTAMINATED GROUND WATER USING PHYSICAL, CHEMICAL, AND POSSIBLY BIOLOGICAL TREATMENT, FOLLOWED BY EITHER ONSITE DISCHARGE TO SURFACE WATER, REINJECTION INTO THE AQUIFER, OR BOTH METHODS; DISPOSING OF ANY TREATMENT RESIDUALS OFFSITE; CONDUCTING LONG-TERM GROUND WATER MONITORING; AND IMPLEMENTING INSTITUTIONAL CONTROLS INCLUDING DEED RESTRICTIONS FOR THE REMAINING CONTAMINATED AREAS. ADDITIONALLY, THIS ROD PROVIDES A CONTINGENCY FOR GROUND WATER IF IT BECOMES TECHNICALLY IMPRACTICABLE TO ACHIEVE CLEAN-UP GOALS. THE CONTINGENT REMEDY INCLUDES PUMPING FROM THE PERIMETER AREA ONLY TO PREVENT MIGRATION OF THE CONTAMINANT PLUME. THE ESTIMATED PRESENT WORTH COST FOR THIS REMEDIAL ACTION IS $77,300,000, WHICH INCLUDES ANNUAL O&M COSTS OF $2,397,600 OR $2,477,600 (DEPENDING ON THE GROUND WATER DISCHARGE OPTION CHOSEN).

PERFORMANCE STANDARDS OR GOALS; SOIL ACTION LEVELS FOR SATURATED AND UNSATURATED SOIL AND "PRINCIPAL THREAT" ACTION LEVELS WERE DEVELOPED BASED ON THE THREAT DUE TO INHALATION/INGESTION AND TO GROUND WATER USING MCLS, RCRA TOXICITY CHARACTERISTIC LEVELS (TCLP), AND HEALTH-BASED CRITERIA. THE TARGET CLEAN-UP GOAL FOR SURFACE SOIL IS ARSENIC 21 MG/KG. THE ACTION LEVELS FOR UNSATURATED SOIL INCLUDE BENZENE 0.009 MG/KG, PCE 0.051 MG/KG, TCE 0.017 MG/KG, AND ARSENIC 450 MG/KG. THIS WILL REDUCE THE EXCESS CANCER RISK LEVEL ASSOCIATED WITH INHALATION/INGESTION EXPOSURE TO (10-6). THE ACTION LEVELS FOR SATURATED SOIL INCLUDE BENZENE 0.002 MG/KG, PCE 0.012 MG/KG, TCE 0.004 MG/KG, AND ARSENIC 210 UG/KG BASED ON PROTECTION OF GROUND WATER. PRINCIPAL THREAT ACTION LEVELS INCLUDE BENZENE 10 MG/KG, PCE 14 MG/KG, TCE 10 MG/KG, AND ARSENIC 1,000 MG/KG. GROUND WATER CLEAN-UP GOALS ARE BASED ON FEDERAL MCLS, PROPOSED MCLS, AND A (10-6) EXCESS CANCER RISK LEVEL AND REFERENCE DOSE EQUAL TO 1 FOR NONCARCINOGENS. CHEMICAL-SPECIFIC GROUND WATER CLEAN-UP GOALS INCLUDE BENZENE 0.005 MG/L (MCL), PCE 0.005 MG/L (PMCL), TCE 0.005 MG/L (MCL), AND ARSENIC 0.05 MG/L. A STATE ARAR TO REMEDIATE GROUND WATER TO BACKGROUND LEVELS WILL BE WAIVED BECAUSE OF TECHNICAL IMPRACTICABILITY. IF THE CONTINGENT REMEDY IS EMPLOYED, AN ARAR TO COMPLY WITH SDWA MCLS WILL ALSO BE WAIVED BECAUSE OF TECHNICAL IMPRACTICABILITY.
 
Remedy:  THIS OPERABLE UNIT (OU) IS THE THIRD OF THREE OPERABLE UNITS FOR THE SITE. THIS ACTION (OU THREE) ADDRESSES CONTAMINATED SOILS AND ADJACENT SEDIMENTS, AND GROUNDWATER PRESENT AT THE SITE. THESE MEDIA POSE SOME OF THE PRINCIPAL THREATS AT THE SITE. THE US ENVIRONMENTAL PROTECTION AGENCY (EPA) HAS SELECTED, AND THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES STAFF HAVE VERBALLY CONCURRED ON THE SELECTION OF THE FOLLOWING REMEDIAL ACTION FOR THE THIRD OPERABLE UNIT (OU THREE) OF THE WHITMOYER LABORATORIES SITE. THIS ACTION ADDRESSES THE MATERIALS MAKING UP THE THIRD OPERABLE UNIT BY EXTRACTING AND TREATING CONTAMINATED GROUNDWATER TO THE EXTENT DESCRIBED HEREIN AND THE MOST CONTAMINATED SOILS/SEDIMENTS; CONSOLIDATING AND CAPPING LESS CONTAMINATED SOILS/SEDIMENTS; DISPOSING THE SOLID TREATMENT RESIDUALS OFFSITE, SUCH THAT THE MATERIALS WILL NOT REQUIRE ANY LONG-TERM ONSITE MANAGEMENT; AND DISCHARGING TREATED GROUNDWATER TO EITHER TULPEHOCKEN CREEK OR THE AQUIFER BENEATH THE SITE.

THE MAJOR COMPONENTS OF THE SELECTED REMEDIAL ACTION ARE AS FOLLOWS;
* EXCAVATION OF ALL MODERATELY CONTAMINATED SOILS/SEDIMENTS FROM OFFSITE AND SATURATED ONSITE LOCATIONS, AND ALL HEAVILY CONTAMINATED ONSITE AND/OR OFFSITE SOILS (ESTIMATED VOLUME = 116,000 CUBIC YARDS (CY)).
* DEMOLITION OF BUILDINGS 4, 9, 11, AND 14.
* BACKFILLING OF THE EXCAVATED AREAS WITH CLEAN FILL OR LIGHTLY CONTAMINATED SOIL.
* ONSITE FIXATION OF THE APPROXIMATELY 61,000 CY OF HEAVILY CONTAMINATED SOILS/SEDIMENTS USING AN IRON-BASED OR OTHER SIMILAR FIXATION PROCESS THAT PROVIDES EQUIVALENT PROTECTION.
* BIOLOGICAL TREATMENT OF THE APPROXIMATELY 5,600 CY OF SOILS WITH ORGANIC CHEMICAL CONCENTRATIONS ABOVE THE HEAVILY CONTAMINATED SOIL ACTION LEVELS EITHER PRIOR TO OR FOLLOWING THE FIXATION STEP.
* CONSOLIDATION OF THE MODERATELY CONTAMINATED SOILS/SEDIMENTS ON SITE ABOVE THE GROUNDWATER TABLE.
* CAPPING OF THE APPROXIMATELY 39,000 CY OF MODERATELY CONTAMINATED SOILS/SEDIMENTS HAVING CONTAMINANT CONCENTRATIONS ABOVE GROUNDWATER-BASED UNSATURATED SOIL CLEANUP TARGETS WITH LOW-PERMEABILITY MATERIALS.
* SOIL CAPPING OF ALL SOILS/SEDIMENTS REMAINING ON THE SURFACE FOLLOWING THE EXCAVATION AND CONSOLIDATION STEPS THAT ARE NOT CAPPED WITH LOW-PERMEABILITY MATERIALS AND CONTAIN GREATER THAN 21 MG/KG ARSENIC; AND OTHER DISTURBED AREAS AS NEEDED.
* FOLLOWING THE SOILS/SEDIMENTS REMEDIATION, PLACEMENT OF DEED RESTRICTIONS ON AREAS WITH REMAINING CONTAMINATION.
* AGGRESSIVE EXTRACTION OF ALL GROUNDWATER FROM THE AQUIFER BENEATH THE SITE WITH CONCENTRATIONS ABOVE HEALTH-BASED LEVELS (E.G., 50 UG/L ARSENIC) UNTIL THE MAXIMUM GROUNDWATER CONTAMINANT CONCENTRATIONS ARE ALL LESS THAN HEALTH-BASED LEVELS.
 
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