Record of Decision System (RODS)
BROWN'S BATTERY BREAKING
|Site Name:||BROWN'S BATTERY BREAKING|
|Address:||446 FISHER DAM RD|
|City & State:||HAMBURG PA 19526|
|NPL Status:||Currently on the Final NPL|
|Abstract:||ABANDONED BATTERY PROCESSING/RECYCLING SITE CONTAMINATED WITH LEAD.|
Post-excavation confirmation samples shall be collected from the bottom and sidewalls from all soil excavation areas. Appendix G of the Consent Decree requires the excavation of the upper twelve inches of soil in all areas identified by the Federal Trustees that contain unacceptable lead levels. EPA coordinated with the Federal Trustees, Pennsylvania Department of Environmental Protection (PADEP) and the General Battery Corporation (GBC), the responsible party conducting the cleanup, throughout the remedial design process and has determined that the soil excavation can be limited to less than twelve inches provided confirmation sampling demonstrates the remaining soil
lead concentration is less than 200 mg/kg.
Excavated soil with lead concentrations less than 1000 mg/kg may be used as backfill in the excavation areas required by the Operable Unit (OU)-2 Record of Decision (ROD) since the soil cleanup level for lead in this area is 1000 mg/kg. One foot of clean fill and/or topsoil must be placed above any site soils used as backfill to eliminate the direct contact threat should any soils inadvertently exceed the acceptable level of 1000 mg/kg of lead in soil.
Individual piles of marginally contaminated soil must be tested prior to onsite stabilization to determine if treatment is required to meet applicable Resource Conservation and Recovery Act (RCRA), as amended Land Disposal Restrictions and any additional requirements of the receiving landfill. Piles meeting these criteria may be disposed without treatment. All soils with lead concentrations exceeding 1000 mg/kg must be disposed at the selected off-site landfill.
The sequencing of excavation areas shall be determined by the Finals Remedial Design and the Remedial Action Work Plan. The sequencing of excavation activities shall be developed to minimize the amount of time any particular excavation area left open. This approach will reduce the potential for contaminant release due to flood events. It is not necessary to excavate the Containment Area first as described in the OU-2 ROD.
It is not anticipated that a significant volume of lead post and plates will be encountered because the sale of such material was a source of income for the previous owner of the site. If the combination of lead posts and/or plates exceed five per cubic foot, then they shall be separated and disposed of in accordance with the OU-2 ROD. If lead posts and plates are only sporadically observed, then they are required to be separated from the soil and debris in which the posts and plates were found and shall be treated and disposed with the impacted material.
A ¾ acre parcel of property containing a log house is located within the site boundaries on the northeastern portion of the site adjacent to Schuylkill River. There is no information indicating that battery breaking-related operations were conducted on this property and the contamination appears to be primarily superficial. Soils on this site parcel shall be remediated to a lead concentration of 200 mg/kg as a result of excavation soils required by Appendix G of the Consent Decree. The depth of excavation shall range from 0.5 feet to 3.0 feet covering approximately 95% of the property. The excavation will remove soils with lead levels exceeding the EPA residential screening criterion and the
PADEP residential cleanup standard; therefore, this property shall not require deed restrictions following remediation and may once again be used for residential purposes. Post-excavation sampling will be performed to confirm that the property is remediated to the lead concentration of 200 mg/kg. Post-excavation sampling on this parcel shall also include two test pits, which shall extend through the soil to the top of the bedrock.
The construction of the six-foot fenced topped with barbed wire shall be limited to the site boundaries along Fisher Dam Road to the north and the base of the railroad embankment to the west.
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