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Record of Decision System (RODS)



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:  Amendment
ROD ID:  EPA/541/R-98/147
ROD Date:  05/12/1998
Operable Unit(s):  02
Media:  Soil
Contaminant:  Metals
Abstract:  Please note that the text in this document summarizes the Record of Decision for the purposes of facilitating searching and retrieving key text on the ROD. It is not the officially approved abstract drafted by the EPA Regional offices. Once EPA Headquarters receives the official abstract, this text will be replaced.

The Whitmoyer Laboratories site is the location of a former veterinary feed additives and pharmaceuticals manufacturing facility. Production began at the site in 1934 and in the mid-1950's, the facility began using arsenic in the production of feed additives. Other products produced included a coal-tar dip, used to treat skin disorders; peperazine, a worming agent; and sulfa drugs, used to inhibit bacterial growth. In addition to arsenic, a number of products manufactured by the facility contained aniline, an organic chemical derived from benzene.
The original site owner, C.W. Whitmoyer, Sr., sold the facility to the Rohm and Haas Company in 1964. In 1978, Rohm and Haas sold the company to Beecham Inc., who in turn sold the facility to Stafford Laboratories, Inc. in 1982. Stafford Laboratories, Inc. filed Chapter 11 bankruptcy in mid-1984 and continued operations at the site until January 1987.

The Environmental Protection Agency (EPA) began assessing site conditions in 1984. However when the facility closed in 1987, the Resource Conservation and Recovery Act (RCRA) Closure Plan had only been partially implemented. The site was listed on the National Priorities List (NPL) in 1986; and EPA conducted numerous sampling activities both on- and off-site throughout 1987. In 1988, EPA removed approximately 400 drums from the site, while it conducted a Remedial Investigation/Feasibility Study (RI/FS) using the Fund money. A Record of Decision (ROD) for Operable Unit 1 (OU1) was issued in June 1989, for the consolidation, removal and treatment of concentrated liquids and decontamination of 32 tanks and vessels. A ROD for OU2 was issued in December 1990 and addressed the concentrated wastes in the concrete vault, wastes abandoned in two groups of lagoons, products and miscellaneous materials abandoned in buildings, and the buildings and related structures. A ROD for OU3 was issued in December 1990, which addressed contaminated soils and adjacent sediments, non-hazardous buildings, and groundwater.

EPA issued two Explanations of Significant Differences (ESD) on December 28, 1994 and November 7, 1995, respectively. ESD 1 modified the remedy to allow certain materials to be sent off-site for incineration including, laboratory bottles, wooden debris from the vault, transformers (with and without detectable polychlorinated biphenyls [PCBs]), crushed drums with adhering tar-like material, unexpected solid and liquid wastes from the vault, miscellaneous materials from on-site buildings, wooden tanks and process vessels, combustible demolition debris exhibiting the RCRA arsenic toxicity characteristic). ESD 2 selected off-site treatment and disposal of additional wastes originally determined to be treated on-site. ESD 2 documented: the incineration of the aniline still-bottom tars and carbon/tar wastes excavated from the vault at off-site facilities, the stabilization of the calcium arsenate sludge, incinerate wastes of elevated levels of organic compounds, and the stabilization of wastes with a limited amount of organic compounds. A ROD Amendment was issued in May 1998 for OU2.
Remedy:  This Record of Decision (ROD) Amendment changes the original selected remedy of on-site incineration to stabilization and disposal of treated soils in a Resource Conservation and Recovery Act (RCRA) Subtitle C landfill. The change to the selected remedy is based on new information collected during the Remedial Design (RD) phase of the original remedy, such as bench-scale treatability testing and full-scale testing results.

Bench-scale stabilization treatability tests were conducted in 1995 to identify a formulation that could feasibly and consistently achieve the 5 mg/L arsenic Land Disposal Restriction (LDR) treatment standard for D004 (arsenic characteristic) wastes.

Full-scale stabilization demonstration tests were conducted in November 1996 to confirm that: off-site stabilization can be implemented at full-scale, adequate reduction in leachable arsenic (i.e., toxicity characteristic leaching procedure arsenic) can be achieved, and vault soils will be accepted at one or more off-site disposal facilities in accordance with the facility's Waste Analysis Plan and RCRA permit requirements.

Based on the results of the bench-scale and full-scale tests, it has been demonstrated that stabilization of the soils can comply with the applicable LDR treatment standard for arsenic through the use of treatability variance. Characterization of vault soils, bench-scale treatability testing, and full-scale demonstration tests indicated that off-site chemical stabilization followed by disposal in a Subtitle C landfill is an appropriate alternative to the on-site incineration remedy selected for vault soils in the ROD for operable unit 2 (OU2).

Estimated Capital Costs: Not Documented
Estimated Present Worth Cost: $685,000
Estimated Annual O&M Costs: Not Documented
Text:  View full-text ROD [ 25K ]
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