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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-00/534
ROD Date:  08/24/2000
Operable Unit(s):  03
 
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.

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.

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:  Excavation and fixation of soil/sediment with contaminant concentrations above principal threat action levels using an iron-based or other fixation process, followed by offsite disposal; biological treatment of soil/sediment with organic concentrations above principal threat organic chemical action levels either before or after fixation, followed by offsite disposal; excavation and consolidation onsite of soil/sediment having contaminant concentrations below principal threat action levels but above ground water-based unsaturated soil clean-up targets, followed by capping; onsite placement of soil/sediment with concentrations below ground water-based unsaturated soil action levels; soil capping
any surface soil with arsenic concentrations above 21 mg/kg; backfilling, grading, and revegetating excavated areas; demolition of 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; disposal of treatment residuals offsite; ground water monitoring; contingency remedy; institutional controls; O&M.
 
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