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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:  Amendment
ROD ID:  EPA/541/R-99/160
ROD Date:  09/30/1999
Operable Unit(s):  03
 
Media:  Sediment, Soil
 
Contaminant:  Base Neutral Acids, PAH, VOC
 
Abstract:  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; piperazine, 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.

EPA issued two Explanations of Significant Differences (ESD) on December 28, 1994 (ESD 1) and November 7, 1995 (ESD 2). 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, and 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.

In December 1990, the ROD for OU3 was issued. It addressed contaminated soils and adjacent sediments, nonhazardous buildings, and groundwater. The ROD Amendment for OU3 was issued in September 1999.

This Amendment modifies the cleanup by eliminating the excavation of moderately contaminated unsaturated off-site soils and instead, requires they be covered with two feet of clean soil and re-vegetated. The underlying soils will be remediated in-place via the groundwater pump and treat system in the same manner as the on-site moderately contaminated soils and the off-site saturated soils. All moderately contaminated soils are located within the capture zone of the groundwater extraction and treatment system. For purposes of this document only: 1) "on-site) refers to the 22 acres of property encircled with a chain-link fence which is bounded by the Union canal to the north, the railroad tracks to the south, Fairlane Avenue to the east and Creamery Road to the west; and 2) "Off-site" refers to the nearby parcels of property which also contain contamination from the Site.
 
Remedy:  The remedy for this Amendment addresses the saturated soils, moderately contaminated unsaturated soils, and organically saturated soils of operable unit (OU) 3. The remedy includes excavation and off-site treatment and disposal of heavily contaminated unsaturated soils and organically contaminated unsaturated soils; excavation of offsite moderately contaminated unsaturated soils and consolidation on-site; and construction of a clean, two-foot soil cover over moderately contaminated soils.

As with the Record of Decision (ROD) for OU3, heavily contaminated unsaturated soils will be excavated and transported off-site for treatment (as necessary) and disposal. The treatment methods and criteria will be determined by the specific permit requirements of the selected disposal facility and shall meet all Resource Conservation and Recovery Act (RCRA) requirements. Fixation will be the primary methods of treatment used on the affected arsenic-contaminated soils, although treatment for removal of organic contaminants is anticipated for
some of these soils. Similarly, organically contaminated unsaturated soils will be excavated for off-site treatment (as necessary) and disposal.

The excavation of contaminated soils will require temporary diversion of the Union Canal into the Tulpehocken Creek. The temporary diversion (up to two years) is not expected to permanently impact the Union Canal and Lock nor the Tulpehocken Creek. The heavily and organically contaminated soils are located primarily on the site, with several areas immediately adjacent to the Union Canal. One off-site excavation area is located opposite the northeast corner of the site (former Production Area), adjacent to Fairlane Avenue and the Tulpehocken Creek.
Excavation of this area may be limited by its proximity to the Creek and Fairlane Avenue bridge crossing. All off-site excavation areas shall be immediately backfilled and restored to their original grade commensurate with the surrounding areas. The excavation of heavily contaminated soils and organically contaminated soils will begin during the autumn of 1999 and continue for approximately eight months.

Off-site moderately contaminated unsaturated soils would be excavated to the water table and brought back on-site. The excavation areas would be backfilled with lightly contaminated or clean soil, covered with two feet of clean soil, and restored. Once on-site, moderately contaminated soils would be placed in former excavation areas (locations of the former lagoons or areas of heavily or organically contaminated unsaturated soils), regraded, and covered with two feet of clean soil.

As described in the ROD for OU3, lightly contaminated soils on- and off-site would be covered with two feet of clean soil and revegetated. The soil cover will be monitored and maintained to protect against subsidence, erosion, and other factors, which may threaten its integrity, and will be restored as necessary on a periodic basis. Deed restrictions will continue to be required for on- and off-site areas where contaminated soils remain.

The ROD for OU3 requires the excavation of sediments that exceed the excavation criteria for moderately contaminated soils if they are adjacent to soil remediation areas. Sediment samples shall be collected from the Union Canal following its temporary diversion to supplement existing sediment data to determine the extent, if any, of contaminated sediments which require excavation.

During the design of the remedy, an evaluation will be performed to determine whether oxidizing agents or other chemicals could be used to increase the dissolution of arsenic from the soils into the groundwater. An operations and maintenance (O&M) plan shall also be developed during the design phase, and will include details for monitoring soils, sediments, surface water and groundwater to evaluate the effectiveness of the remedy. Discussions are currently being held between the Environmental Protections Agency, the state, the current site owner, and local officials to determine if the beneficial reuse of a portion of the site can be incorporated into the long-term plans for maintaining the site.
 
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