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Record of Decision System (RODS)



Address:  6TH & MINOR STREETS 
City & State:  EMMAUS BOROUGH  PA  18049
County:  LEHIGH
EPA ID:  PAD981033285
EPA Region:  03
NPL Status:  Currently on the Final NPL
ROD Type:  Record of Decision
ROD ID:  EPA/541/R-99/086
ROD Date:  09/30/1999
Operable Unit(s):  01
Media:  Groundwater, Other, Sediment, Soil, Surface Water
Contaminant:  Base Neutral Acids, Inorganics, Metals, PAH, PCBs, Pesticides, VOC
Abstract:  The Rodale Manufacturing Site encompasses approximately a 1.2 acre parcel of real property. The site is located at the intersection of Sixth and Minor Streets, in the Borough of Emmaus, Lehigh County, Pennsylvania.

Currently, the only structure on the property is a ground-water treatment system (GWTS) building and recovery well protective enclosures. Prior to 1993, the property included a three-story building that occupied most of the property which served as a manufacturing, warehouse, and office facility. An exterior, open-space courtyard area was expanded in 1989 as a result of demolition of the southern wing of Building D. Three disposal wells were located in the open area, along with several other wells and cisterns.

Prior to the 1930s, the property was occupied by the D.G. Dery Silk Corporation and later by Amalgamated Silk Corporation. Rodale Press, a publishing and printing business, occupied portions of the building for several years beginning in 1953. From the late 1930s until 1975, the property was operated by Rodale Manufacturing, which manufactured wiring devices and electrical connectors. In 1975, the property was sold to Bell Electric, a wholly-owned subsidiary of Square D Company. Bell Electric manufactured similar electrical components.

Past disposal practices were first identified by Square D in March, 1981, when a capped borehole was discovered during the installation of new equipment. Long-time employees of Rodale Manufacturing indicated that two other wells were also used for disposal purposes, and four additional features were found.

In 1984, in coordination with the State, Square D commenced pumping contaminated groundwater from one of the disposal wells. The volatile organic compunds (VOCs) contamination in the ground water was treated by an air-stripping tower. This air stripper was operated until 1989. In January 1989, a Site inspection was conducted at the Site on behalf of the USEPA. In October 1991, the site was listed on the National Priorities List (NPL). An Administrative Order on Consent (AOC) to conduct a Remedial Investigation and Feasibility Study (RI/FS) was executed between the USEPA and Square D and became effective in September 1992.

As required by the RI/FS AOC, a Well Survey Investigation was conducted by Square D. Based on the findings of the Investigation, a separate AOC for a Removal Response Action for a site groundwater treatment system (GWTS) was executed between the USEPA and Square D, effective September 1994. The purpose of the GWTS was to recover and treat contaminated ground water to limit further migration of contamination. The construction of the GWTS was completed in August 1996. Remedial investigation activities were conducted concurrently with the construction of the GWTS. A Record of Decision was signed in September 1999.
Remedy:  This alternative includes hydraulic containment of the dissolved phase of the volatile organic compound (VOCs) plume at and in the immediate vicinity of the probable Probable dense non-aqueous phase liquid (DNAPL) zone by extraction and treatment and the issuance of the Technical Impracticability (TI) waiver for the groundwater and subsurface soils Applicable or Relevant and Appropriate Requirements (ARARS) in the Probable DNAPL Zone. This alternative would involve:

1. Extracting ground water from a series of extraction wells, treating the extracted ground water using conventional treatment processes and discharging the treated ground water to surface water. The Groundwater Treatment System (GWTS) is currently operating on-site since it was constructed as part of the removal response action. The GWTS was designed and installed to extract ground water from four monitoring wells. One of the wells proved marginally effective and ground water extraction from that well was eliminated. Because of the discontinued use of one of the wells and the highly fractured and heterogenous nature of the bedrock, the current ground water extraction system may not be providing complete hydraulic containment of the highest levels of the dissolved phase VOC plume. Therefore, further investigation needs to be conducted to determine the number of additional wells that may need to be installed to contain contamination from the Probable DNAPL Zone.

2. Decontamination of ground water through Monitored Natural Attenuation (MNA) outside the ground water extraction system capture zone until the cleanup standards are met. Natural attenuation will remediate the ground water dissolved plume beyond the GWTS capture zone to cleanup standards. Results of the monitoring will be used to determine if natural attenuation is decreasing the concentrations of the contaminants at an acceptable rate, while providing sufficient protection to human health and the environment. The evaluation of the monitoring will be conducted during the 5-year review of the remedy conducted by EPA. If it is demonstrated that natural attenuation can not remediate this portion of the plume, the GWTS will be expanded to remediate it.

3. The TI Waiver of the ARARs for TCE in groundwater and TCE and PCE in the subsurface soils in the Probable DNAPL Zone as set forth in the ROD.

4. Institutional controls, in the form of land use restrictions in the Property boundaries to prevent or reduce exposure to contaminated soils, and ground water use restrictions throughout the entire Site to prevent or reduce exposure to contaminated ground water.

Estimated Capital Cost: Not documented
Estimated Annual O&M Cost: Not documented
Estimated Present Worth Cost: $4,240,000
Text:  View full-text ROD [ 1.15M ]
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