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Record of Decision System (RODS)



EPA ID:  PAD980229298
EPA Region:  03
NPL Status:  Currently on the Final NPL
ROD Type:  Record of Decision
ROD ID:  EPA/ROD/R03-93/166
ROD Date:  06/30/1993
Operable Unit(s):  01
Media:  Soil, Sediment, GW
Contaminant:  VOCs
Abstract:  The 250-acre Occidental Chemical Firestone site is an active polyvinyl chloride (PVC) manufacturing facility located one-half mile southeast of the Borough of Pottstown, Montgomery County, Pennsylvania. Land use in the area is mixed agricultural, residential, and commercial, with some natural habitat and wetlands. The site is surrounded by the Schuylkill River on its western, southern, and eastern sides and is bordered by wooded and agricultural land to the northwest and northeast, respectively. In addition, the eastern portion of the site is located within the 100-year floodplain of the Schuylkill River. Several nearby communities usethe Schuylkill River as a source of drinking water; however, the nearest public intake is located approximately 3.5 miles downgradient ofthe site. The site consists of a closed 17-acre solid waste landfill, a 7- acre active industrial waste landfill, four inactive unlined earthen lagoons, two active lined lagoons, and a TCE Handling Area. The 17-acre solid waste landfill was operated from 1942 until its closure in 1985. The State issued two permits to Firestone allowing continued operation of this landfill. The second permit, which was issued in 1977, required continuous pumping of the onsite production wells to act as a leachate collection system for the landfill. This requirement is still in operation today and causes bedrock ground water to flow toward the center of the site; thereby, containing the contaminant plumes at the site and preventing offsite releases to the adjacent river or ground water. The 7-acre active industrial landfill is operating under a State permit issued in 1977. The four inactive, unlined earthen lagoons were used for storage of PVC sludge until 1974, when the State ordered Firestone to stop using the lagoons. Although these lagoons have received no waste since 1974, the PVC contents were left in place. The two active lined lagoons currently hold PVC sludge. The PVC sludge was not a listed hazardous substance until September 25, 1990; however, because of this change in regulations, Occidental Chemical Corporation (OCC) is in the process of closing the lined lagoons. TCE was used in the manufacturing process from the late 1940s until 1987. The chemical was transported to the site in railroad tank cars and was unloaded via pumping to an above-ground holding tank, located in a bermed retention basin (the TCE Handling Area). Spills occurred in this area during the transfer of TCE from the tank cars to the holding tank. PVC manufacturing began at the site in the late 1940s when Firestone Tire and Rubber leased the site. Firestonepurchased the site in 1950 and continued to manufacture tires and PVC resins until 1980, when the site was purchased by the OCC, which currently manufactures PVC at this site. Previous manufacturing activities conducted at this site have resulted in the release of hazardous substances to the environment, and EPA studies cited the presence of several VOCs in the ground water as the primary concern at this site. As a result, OCC conducted the remedial investigation from 1990 to 1993 to characterize the nature and extent of contamination at the site, which indicated that exposure to contaminated ground water, from the bedrock aquifer, and to the contaminated soil and sediment, from the earthen lagoons, presented unacceptable health risks to potential future residents living onsite. This ROD addresses a final remedy for the bedrock ground water contamination and inactive earthen lagoons. A future ROD will address the Sedimentation Pond and the drainage swale associated with the active industrial landfill. The primary contaminants of concern affecting the soil, sediment, and ground water are VOCs, including benzene, PCE, TCE, toluene, and xylenes. SELECTED REMEDIAL ACTION: The selected remedial action for this site includes constructing an access road to the earthen lagoons; excavating the lagoon contents (PVC material, coal fine layers, and contaminated soil); onsite drying and bagging of the PVC material for recycling; implementing air pollution controls; sampling and analyzing the coal fines layer and recycling residues to determine appropriate transportation and offsite disposal requirements; sampling and analyzing the underlying soil to ensure removal of all lagoon contents; backfilling the excavation to the original grade and revegetating the area; sampling the Sedimentation Pond and drainage swale to define the extent of cleanup required for contaminated sediment; mitigating any affected wetlands; sampling the floodplain south of the landfill and the drainage swale to determine whether contaminants migrated during flood events; collecting ground water using recovery wells, with onsite treatment using air stripping and vapor phase carbon adsorption; discharging the treated water either offsite to a POTW or to the Schuylkill River; monitoring the ground water periodically; and implementing institutional controls, including deed restrictions. The estimated present worth cost for this remedial action is $11,119,000, which includes an annual O&M cost of $403,000 for years 0-3, and $340,000 for each of the following estimated 97 years until completion of the ground water remediation. PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for the excavation of the earthen lagoons are not provided; however excavation willbe based on reducing contaminant levels to background levels. Chemical- specific goals for ground water are also based on the State's requirement for reducing contaminant levels to background concentrations, and include vinyl chloride 0.18 ug/l; ethylbenzene 0.06 ug/l; styrene 0.04 ug/l; TCE 0.12 ug/l and trans-1,2-dichloroethene 0.06 ug/l;. If EPA and the State determine that it is not technically practicable to achieve these levels, the cleanup levels will be based on SDWA MCLs, and include ethylbenzene 700 ug/l; styrene 100 ug/l; TCE 5 ug/l; trans-1,2-DCE 100 ug/l; and vinyl chloride 2 ug/l;. INSTITUTIONAL CONTROLS: Deed restrictions shall be implemented to limit site use to industrial only and to prevent the use of onsite ground water as a drinking water source.
Remedy:  The Occidental Chemical Corporation Site includes an active manufacturing facility approximately 250 acres in size. The remedial action selected for the Site is a final remedy which will address ground water contamination in the bedrock aquifer and contamination at the earthen lagoons.

The selected remedial action includes the following components:
* Extraction and treatment of contaminated ground water combined with air stripping and carbon vapor adsorption throughout the entire plume of contamination and
* Long-term ground water monitoring throughout the entire plume
* Excavation of PVC material, coal fines layer and contaminated soil at the earthen lagoons
* Onsite Drying of PVC material and landfilling of the coal fines layer at the earthen lagoons
* Restoration of the earthen lagoon area to original grade.
* Additional sampling of sediment pond and drainage swale
Text:  View full-text ROD [ 100K ]
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