IIUSS3

Superfund ProgramProposed PlanOccidental Chemical CorporationMontgomery County, Pennsylvania April 1993

ERA ANNOUNCES PROPOSED PLAN

The U.S. Environmental Protection Agency ('ERA') is issuing this '"'Daitelitb rememberProposed Remedial Action Plan ('Proposed Plan1) to present its li^i i I; k ;Preferred Remedial Alternative for cleaning up contamination at the ' ^ 'Aijrif'ab Ma 19Occidental Chemical Corporation Site ('Site') located approximately 3 1993; T 'miles southeast of the Borough of Pottstown, in Montgomery County, Pubite comment iPennsylvania. This Proposed Plan summarizes information obtained period on alternatives' *from a recently completed Remedial Investigation and Feasibility Study in Prooosed Plan("RI/FS"), and the technologies EPA is considering for the cleanup of the ''j ::.; t ?iOccidental Chemical Corporation Site. The EPA has prepared this I"'rMaV-4 1993 :':';'-"''-• ••''•''•.Proposed Plan to solicit public comment on its preferred alternative and ^ Pu ic rrleetino at;the other alternatives for remediation of the contaminants present on the ^pottstt^wn SeniorSite. EPA will jelect a final remedy for the Site only after the public ? center;comment period has ended and any comments received during the ill at; 0 Pp - *^ !comment period have been reviewed and considered. The final remedy ;i%& ^will be outlined in a Record of Decision ("ROD") for the Site. Based on i ; ; i ?§ :GE: i i ; ,new information and/or comments received, the remedy selected in the mmmmmm*i^mmmm*^mmROD may be different from the preferred alternative described in thisProposed Plan.

The Proposed Plan is being issued as part of EPA's public participation requirements under Section117 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, asamended ("CERCLA"). The public's comments will be considered and presented with discussionincorporated in the Responsiveness Summary contained in the ROD for the Site. This Proposed Plan

summarizes information that can be found in greaterHHHHHH HM MMmi H MHIIII IIHnB IHI detail in the RI/FS report and other documents

contained in the Administrative Record file for the Site.EPA encourages the public to review these documents

SCOPEANOSUMMARYOF srrEliais>|i|pi

"*s;:SUMMARY OF REDii'Aii^PREFERRED 'COMPARATIVE ANAl S1S i. H*, kCOMMUNITY.ROLE.....,.........™..;

SITE BACK IipiiiA |;;lsip|| l!lK|ill in order to gain a more comprehensive understandingof the Site and the Superfund activities that have beenconducted there. The locations of the AdministrativeRecord file for the Site and the address to sendcomments on this Plan are given at the back of theProposed Plan. The Proposed Plan also contains aglossary of terms that may be

SR308I5I

unfamiliar to the general public. The terms in operate the landfill. In 1977, FTR applied for abold print in the text are more fully defined in permit to expand the landfill. As part of thethe glossary in the back of the Proposed Plan. permit, PADER required FTR to install a

leachate control system. FTR established aII. SITE BACKGROUND groundwater recovery system consisting of

nine onsite process water wells which wereThe Occidental Chemical Corporation (OCC) continuously pumped. (See Figure 3) In thisSite is 1/2 mile southeast of the Borough of system the groundwater in the bedrock isPottstown, Pennsylvania The Schuylkill River pumped to the surface and is re-used duringsurrounds the site on three sides forming the processing. This leachate control system, stillwestern, southern, and eastern boundaries. working today, controls the groundwater flow(See Figure 1). The Site consists of towards the center of the site which acts toapproximately 250 acres and is an active contain the contaminant plumes. (See Figurepolyvinyl chloride manufacturing plant. OCC 4) In 1985, the landfill was closed and cappedowns the plant and also about 60 acres in accordance with a Closure Plan approvedlocated to the northeast of the active plant. by PADER.This adjacent property is vacant and has notbeen used in conjunction with plant operationsin the past. In addition to the closed landfill, a 7 acre active

residual waste landfill is present at the Site.A. Site Ownership This landfill is currently operated by OCC *' -

under a permit issued by PADER in 1977Prior to the second World War this Site was (Permit No. 300001). The landfill is permittedowned by Jacobs Aircraft Engine Company and operated as a residual solid waste(JAEC), which manufactured aircraft engines. disposal facility. It is not permitted as aThe Defense Plant Corporation (DPC) 'residual* solid waste landfill under PADER'spurchased the Site from JAEC in 1942, new residual waste regulations. It has aalthough JAEC continued to operate and drainage swale which parallels the base of themanufacture aircraft engines for DPC until late landfill and carries all surface water to a1944. In 1945, DPC leased the Site to sediment settling basin. The active landfill andFirestone Tire and Rubber (FTR), which sediment settling basin are unlined.subsequently purchased the Site in 1950. FTRmanufactured tires and polyvinyl chloride Four inactive unlined earthen lagoons are also(PVC) resins at the site. In 1980, FTR sold the present on the Site. These lagoons were usedSite to Hooker Chemicals and Plastics for the storage of PVC sludge until 1974 whenCorporation, which later became the PADER ordered the closure of these lagoons.Occidental Chemical Corporation (OCC). OCC No further disposal of material in the earthencontinues to manufacture PVC resins at the lagoons has taken place since 1974. TwoSite today. lined lagoons were then constructed to handle

the waste.

Site Use and Regulatory Compiance The two active lined lagoons currently holdpolyvinyl chloride (PVC) sludge which is

Past manufacturing operations at the Site have recycled into the manufacturing process andled to the release of hazardous substances resold as low grade PVC product Theinto the environment. The Site consists of the lagoons are lined with a synthetic liner tofollowing: (See Figure 2) prevent migration of chemicals into the

subsurface.

A 17 acre solid waste landfill was operatedfrom about 1942 through 1985. In 1973, In addition to the above disposal areas,Pennsylvania Department of Environmental trichfcxoethylene (TCE) was used in theResources (PADER) granted a permit to FTR to manufacturing process from the late 1940's

AR308I52

BCMl ""* raw, .OCCIDENTAL

..• \,#x- \ -

--• *

until 1987. TCE was brought to the Site in On September 25, 1990, EPA expanded itsrailroad tank cars and was unloaded via lists of hazardous waste to include somepumping to a holding tank. The holding tank organic compounds. This list included VCM.was located above ground and situated in a Therefore, due to the change in wastebermed retention basin where TCE was stored classification from non-hazardous tobefore its use in the PVC manufacturing hazardous, the active lined lagoons becameprocess. Over the years the TCE transfer subject to stricter regulatory requirements.process from tank car to holding tank resulted Therefore, these lagoons must either bein releases of TCE into the soils. upgraded or closed. OCC has submitted a

plan to close the lagoons. The plan isFrom 1979 through 1983 Firestone and OCC currently under review and must be approvedsampled and analyzed process water wells to by U.S. EPA and PADER.determine if TCE had migrated from theunloading area through the overburden soils III. SCOPE AND ROLE OF RESPONSE ACTIONand into the groundwater via fractures in theunderlying bedrock. Analytical results revealed The Proposed Remedial Action described inthe presence of TCE in these wells at this Proposed Plan will address the threatsconcentrations which exceeded the maximum posed by the release of hazardous substanceslevel allowed (5 ppb TCE) by the Safe Drinking at the Site. The principal threat posed by theWater Act. The highest concentrations were Site is the groundwater contamination whichdetected in the TCE handling area of the site resulted from the former TCE handlingwhere concentrations ranged from 10 to 295 operation. The concentrations of chemicals ofppb. In early 1984, approximately 898 tons of the five contaminant plumes exceed the levelssoil contaminated with TCE were removed in allowed by the Safe Drinking Water Act Inthe TCE handling area This reduced the addition, EPA plans to remediate the inactivemovement of TCE from the soil to the earthen lagoons. EPA will issue one ROD atgroundwater. the Site that will address the groundwater

contamination and the inactive earthen lagoons.In 198S, The United States EnvironmentalProtection Agency, Region III investigated theSite to characterize existing Site conditions. The active lined lagoons are being addressedQroundwater and sediment samples were by RCRA Interim Status and the 7 acre activecollected and analyzed. The Site was residual solid waste landfill is currentlyevaluated by EPA in 1988 using the Hazard operating in accordance with a permit issuedRanking System, and the OCC Site was placed by PADER. These two areas will not beon the National Priorities List (NPL) addressed by this action.of Superfund Sites. EPA's evaluation identifiedthe primary concern at the Site as the presenceof several volatile organic compounds (VOCs-) IV. SUMMARY OF SfTE RISKSin the groundwater. The EPA investigationidentified TCE, trans-1,2-dichloroethene (1,2- The Risk Assessment ('RA') performed duringDCE), and vinyl chloride monomer (VCM) as the RI/FS identified contamination of theprimary chemicals of concern. In December groundwater in the bedrock aquifer on the Site1989, OCC signed an Administrative Order on as posing an unacceptable level of risk.Consent ("Consent Order*) with EPA (Docket Although there is no current risk associatedNo. III-89-20-DC). Under the terms of the with the use of groundwater at the Site, theConsent Order, OCC conducted a site-wide risk calculation was determined assuming theRemedial Investigation / Feasibility Study plume was allowed to migrate offsite resulting(RI/FS) for the Site. The RI/FS was conducted in a residential exposure.between 1990 and 1993 and has recently beencompleted and submitted to EPA for review The RA studies both carcinogenic and norl-and approval. carcinogenic, current and future risk, at the

Site based on the levels of contaminants found

AR3G8157

during the Remedial Investigation and a prevented migration of contaminants from thereasonable maximum exposure. Risks were site, therefore groundwater does not currentlycalculated based on a combination of pose a risk to residents downgradient of theinhalation, ingestion, and dermal absorption of site or to the Schuylkill River. However, thegroundwater and soils from the area Table 1 concentrations of the five principal chemicalscontains a summary of the Risk Scenarios found in the groundwater during the Rl exceedevaluated for the Site. the allowable levels under the Safe Drinking

Water ActThe National Contingency Plan fNCP)establishes a range of acceptable levels of In addition, under a worst case scenario wherecarcinogenic risk for SUPERFUND sites at a future onsite resident would utilize thisbetween one in 10,000 and one in 1 million groundwater for a potable water supply, its useadditional cancer cases if cleanup action is not would represent an unacceptable future cancertaken at a site. Expressed as a scientific risk (6.1 x KT3) and would represent annotation, this translates to an acceptable risk unacceptable noncancer health effect risk (HIrange of between 1x10"* and 1x10"* over a = 33 for children and HI » 14 for adults). Thedefined period of exposure to contaminants at Risk Assessment utilized the maximum and thea site. 95% upper confidence limit of the contaminant

concentrations found in all bedrock wells at theIn addition to carcinogenic risk, chemical Site.contaminants that are ingested, inhaled ordermally absorbed may present a non-carcinogenic risks to different organs of the Earthen Lagoonshuman body. Those non-carcinogenic risks ortoxic effect are expressed as a Hazard Index Each lagoon is generally composed of three('HI"). A HI exceeding one is considered layers; a white, wet material, a gray to blackunacceptable non-carcinogenic risk. wet material, and a coal fines layer. The white

and gray materials are products of the PVCRemedial Investigation Results manufacturing process and will be referred to

in this document as PVC material. The totalGroundwater volume of material in the four lagoons is

approximately 38,000 cubic yards. SoilSampling conducted during the Rl confirmed sampling conducted during the Rl detected thethe presence of groundwater contamination presence of volatile and semi-volatile organicbeneath the Site. VOCs including TCE, trans- compounds in the material contained in the1,2-DCE, VCM, styrene, and ethylbenzene are four inactive earthen lagoons. The chemicalsthe principal chemicals present in the bedrock present are associated with the process ofgroundwater. The Rl indicates that there are making PVC. However, the sampling of thefive individual contaminant plumes present lagoon material has revealed that it is not abeneath the site. The RI/FS estimates that the hazardous waste as defined by RCRA. The Rllargest plume is the TCE plume which has a also revealed that there is a layer of coal finevolume of 258 million cubic feet. The VCM material at the bottom of Lagoons 2, 3, and 4.plume is 22 million cubic feet, trans-1,2-DCE It appears that the coal fine material hasplume is 20 million cubic feet, styrene plume is served as a collection/adsorption layer for the13 million cubic feet and the ethylbenzene chemicals present in the lagoon material andplume is 38 million cubic feet Figure 5 the soil beneath the coal fine layer has notdepicts the aerial extent of the TCE been affected. In the area of Lagoon 1 wherecontaminant plume which is the largest of the there is not a coal fine layer present, thefive plumes. chemicals have been found in the soils directly

beneath the lagoons. The chemicals have notThe groundwater beneath the Site is currently migrated to the deeper soils. Based onbeing pumped for use as process water at the sampling in the Rl, the underlying soils andsite. Pumping of the groundwater has coal fines layer have been classified as non-

AR3G8I58

§W O

I >

g

I» yr a- a- ^

0-*

AO

1

i i

S.u u C

1 ! ill] III! ii

I 3 £ £ £ 55s .S a a a a a

ft Ot 0&

, f > tiH Hi i i fil !ii pi! i

§t—x•n

<n op <M c s i r ^ v f ^ "- T2 2 ^ 2 ^ 2 2 2 2 2'x'x'x ^ « x x x 2 x x x

"" "" <s o bT^ "^ X X Xoo o> • 5 ^5

LEGEND

Reconnaissance Borehole Location

MDL/MCL (0.005 mg/l) FlQUre 5

Concentration Contour (mg/l) Occidental Cheml

4001

TCEIsoconcentratiorContour Plot

hazardous. Alternative 1B - Groundwater Cotection UsingProduction Wete and Treatment by Air

The earthen lagoons are located in the 100- Strippingyear floodplain of the Schuylkill River.

Estimated Capital Costs: $000A RA was performed on the soils at the Estimated Annual O&M Costs: $8,380earthen lagoons. Onsite worker exposure and Estimated Present-Worth Costs: $ 69,000future residential exposure were both Estimated Implementation Time: 100 Yearsevaluated. The RA found that future residentialuse of the earthen lagoon would represent an This alternative allows the present pumpingunacceptable noncancer health effect risk for scenario to continue without alteration. Itchildren (HI = 1.1). The RA utilized the would contain giroundwater by using themaximum and the 95% upper confidence limit existing collection and treatment system, whichof the contaminant concentrations found in soil is in place at the plant to provide processsamples from the earthen lagoons at the Site. water from the existing production wells. The

groundwater is treated in the existing airstripper (with no VOC controls) to reduce vinylchloride monomer.

V. SUMMARY OF REMEDIAL ALTERNATIVESAlternative 2A - (3roundwater Collection Using

The Feasibility Study ('PS") contains all the Recovery Wete and Treatment by Air Stripping.remedial alternatives considered for the (with Vapor Phase Carbon Adsorption) Before.cleanup of the groundwater and Earthen the ProcessLagoons at the OCC Site. Table 2 presents alist of the OCC Alternatives for the bedrock Estimated Capital Costs: $1,400,000aquifer that were analyzed in detail in the FS. Estimated Annual O&M Costs: $ 340,000Table 3 presents a list of the OCC Alternatives Estimated Present-Worth Costs: $ 7,100,000for the earthen lagoons that were analyzed in Estimated Implementation Time: 100 Yearsdetail in the FS.

This groundwater pumping and treatmentalternative is designed to optimize well

GROUNDWATER ALTERNATIVES locations and recovery rates. It preventsmigration of the five contaminant plumes and

Alternative 1A - No Action/Institutional Controls removes the contaminants from the saturatedzone. Groundwater would be extracted by

Estimated Capital Costs: $0 controlled pumping to prevent mixing of theEstimated Annual O&M Costs: $0 plumes. The groundwater would be extractedEstimated Present-Worth Costs: $ 600 at a pumping rate of approximately 410 gallonsEstimated Implementation Time: Immediate per minute and treated above ground by Air

Stripping. Air stripping would remove theThe NCP requires that EPA consider a 'No volatile organics (TCE, trans-1,2,DCE, VCM,Action* alternative for every site to establish a styrene, ethylberizene) from the groundwaterbaseline for comparison to alternatives and the vapor-phase carbon adsorption unitthat do require action. Under this alternative, would remove the volatiles from the air stream.plant production wells would be shut down The treated groundwater would be used in theand no groundwater would be collected and PVC production process. Following thetreated. Deed/Land Use Restrictions would be production process, the groundwaterplaced on the property to prevent use of undergoes additional treatment beforegroundwater. This alternative would require discharge either to the Pottstown PotableOCC to collect its process water from the Treatment Works (POTW) or the SchuylkillSchuylkill River which would allow the River.contaminated groundwater to migrate offsite.

&R308I6I

TABLE 2 - SUMMARY OF REMEDIAL ALTERNATIVES FOR THE GROUNOWATER AT OCCIDENTALCHEMICAL CORPORATION SITE

Alternative 1A - No Action/Institutional ControlsEstimated Capital Costs: $000Estimated Annual O&M Costs: $000Estimated Present-Worth Costs: $ 600Estimated Implementation Time: immediate

Alternative 1B - Groundwater Collection Using Production Wells and Treatment by Air StrippingEstimated Capital Costs: $000Estimated Annual O&M Costs: $000Estimated Present-Worth Costs: $ 69,000Estimated Implementation Time: 100 Years

Alternative 2A - Groundwater Collection Using Recovery Wells and Treatment by Air Stripping After theProcessEstimated Capital Costs: $ 1,400,000Estimated Annual O&M Costs: $ 340,000Estimated Present-Worth Costs: $7,100,000Estimated Implementation Time: 100 Years

Alternative 28 - Groundwater Collection Using Recovery Wells and Treatment by Air Stripping Beforethe ProcessEstimated Capital Costs: $ 1,600,000Estimated Annual O&M Costs: $ 430,000Estimated Present-Worth Costs: $ 8,700,000Estimated Implementation Time: 100 Years

Alternative 3A - Groundwater Collection Using Recovery Wells and Treatment by Steam StrippingBefore the ProcessEstimated Capital Costs: $ 1,400,000Estimated Annual O&M Costs: $ 560,000Estimated Present-Worth Costs: $ 11,000,000Estimated Implementation Time: 100 Years

Alternative 38 - Groundwater Collection Using Recovery Wells and Treatment by Steam Stripping Afterthe ProcessEstimated Capital Costs: $ 1,800,000Estimated Annual O&M Costs: $ 720,000Estimated Present-Worth Costs: $ 14,000,000Estimated Implementation Time: 100 Years

TABLES- SUMMARY OF REMEDIAL ALTERNATIVES FOR THE EARTHEN LAGOONS AT THEOCCIDENTAL CHEMICAL STTE

Alternative 1 - No Action with Deed/Land Use Restriction

Estimated Capital Costs: $600Estimated Annual O & M Costs: $000Estimated Present Worth Costs: $000Estimated Implementation Time: Immediate

Alternative 2 - Onsite Drying of PVC Layers and Landfilling of Coal Fine Layer

Estimated Capital Costs: $3,847,000Estimated Annual O & M Costs: $63.000Estimated Present Worth Costs: $4,019,000Estimated Implementation Time: 3 Years

Alternative 3 - Offsite Drying of PVC Layers and Landfilling of Coal Fino Layer

Estimated Capital Costs: $5,900,000Estimated Annual O & M Costs: $8,640Estimated Present Worth Costs: $5,915,000Estimated Implementation Time: 2 Years

Alternative 4 - Landfilling of the Lagoon Materials

Estimated Capital Costs: $5,389,832Estimated Annual O & M Costs: $2,880Estimated Present Worth Costs: $5,394,000Estimated Implementation Time: 2 Years

AR308I63

AAlternative 2B - Groundwater Collection Using treatment before discharge either to the WRecovery Wefls and Treatment bv Air Strfooing Pottstown POTW or the Schuylkill River.(with Vapor-Phase Carbon Adsorption) Afterthe Process Alternative 3B - Groundwater Collection Using

Recovery Wete and Treatment bv SteamEstimated Capital Costs: $ 1,600,000 Stripping After the ProcessEstimated Annual O&M Costs: $ 430,000Estimated Present-Worth Costs: $ 8,700,000 Estimated Capital Costs: $ 1,800,000Estimated Implementation Time: 100 Years Estimated Annual O&M Costs: $ 715,000

Estimated Present-Worth Costs: $ 13,470,000This alternative is identical to that described in Estimated Implementation Time: 100 YearsAlternative 2A with the exception that thegroundwater would be pumped at a rate of This alternative is identical to that described inapproximately 620 gallons per minute (gpm) to Alternative 3A with the exception that thean Air Stripper located after the PVC groundwater would be pumped at a rate ofProduction Process. Once the volatile approximately 620 gpm to the Steam Stripperorganics are removed by the air stripper, the which is located after the PVC Productiongroundwater undergoes additional treatment Process. Steam Stripping would remove thebefore discharge either to the Pottstown POTW volatile organics from the groundwater. Theor the Schuylkill River. volatile organics that are removed during

steam stripping would enter a condenserwhich would require offsite disposal. Once the *

Alternative 3A - Groundwater Collection Using volatile organics are removed, the groundwaterRecovery Wete and Treatment bv Steam would undergo additional treatment beforeStripping Before the Process discharge either to the Pottstown POTW or the

Schuylkill River.Estimated Capital Costs: $ 1,400,000Estimated Annual O&M Costs: $ 560,000Estimated Present-Worth Costs: $ 11,000,000Estimated Implementation Time: 100 Years EARTHEN LAGOON ALTERNATIVES

This groundwater pumping and treatment Alternative 1 - No Action/Institutional Controlsalternative is similar to Alternative 2A with theexception that the volatile organics would be Estimated Capital Costs: $0removed using Steam Stripping. As described Estimated Annual O&M Costs: $0in Alternative 2A, this option also optimizes well Estimated Present-Worth Costs: $ 600locations and recovery rates. It prevents Estimated Implementation Time: Immediatemigration of the five contaminant plumes andremoves the contaminants from the saturated The NCP requires that EPA consider a 'Nozone. Groundwater would be extracted by Action* alternative for every site to establish acontrolled pumping to prevent mixing of the baseline for comparison to alternativesindividual contaminant plumes. The that do require action. Under this alternativegroundwater would be extracted at a pumping the lagoons would be left in place and deedrate of approximately 410 gallons per minute restrictions would be placed on the area toand treated above ground by Steam Stripping. prevent use of the soils.Steam Stripping would remove the volatileorganics from the groundwater. The volatile Alternative 2 - Onsite Diving of PVC Layers andorganics that are removed during steam Landfillina of the Coal Fines Layerstripping would enter a condenser and wouldrequire offsite disposal. The Steam Stripper Estimated Capital Costs: $3,847,000would be located before the PVC production Estimated Annual O&M Costs: $63,000process. Following the production process, Estimated Present Worth Costs: $4,019,000the groundwater undergoes additional Estimated Implementation Time: 3 Years

This alternative provides for onsite drying of of concern.the white and gray PVC layers of the earthenlagoons and landfilling of the coal fines layer. VI. EVALUATION OF ALTERNATIVESThis alternative requires that a road beconstructed to the lagoons. The layers will be EPA's preferred alternative for the bedrockdried in an onsite dryer and the vapors from aquier at the OCC Site is Alternative 2A.the dryer will be treated to reduce VOC Groundwater CoBection using Recovery Weftsemissions prior to discharge. The PVC layers and Treatment by Air Stripping fwfth Vaoor-of reclaimed material will be marketed as Phase Carbon Adsorption) Before the Processreclaimed product, the coal fines layer and anycontaminated soil will be transported offsite to Alternative 2A is the preferred alternative foran appropriate disposal facility. the treatment of the contaminated groundwater

since it meets the threshold criteria, andAlternative 3 - Offsite Drying of PVC Layers and provides the best balance of effectiveness,Landfilling of Coal Fines Layer permanence, implementability, reduction of

toxicity, mobility and volume of contaminantsEstimated Capital Costs: $5,900,000 through treatment EPA may, in consultationEstimated Annual O & M Costs: $8,640 with the Commonwealth of Pennsylvania, laterEstimated Present Worth Costs: $5,915,000 modify the preferred alternative or selectEstimated Implementation Time: 2 Years another remedial action presented in this

Proposed Plan and RI/FS if new information "o'r *This alternative provides for offsite drying of public comments warrant such action. Thethe white and gray PVC layers and the public, therefore, is encouraged to review andlandfilling of the coal fines layer. The comment on all alternatives identified in thisalternative requires building an access road to Proposed Plan. The RI/FS should bethe lagoons, excavating each of the layers of consulted for more information on thesematerial, transporting the PVC layers to an alternatives.offsite dryer, where it is dried, bagged,packaged and transported back to OCC formarketing as reclaimed product. The coal EPA's preferred alternative for the Earthenfines layer and any contaminated soil will be Lagoons is Alternative 2transported to an appropriate offsite disposalfacility. Alternative 2 is the preferred alternative for the

treatment of the Earthen Lagoons since itAlternative 4 - Landfilling of the Lagoon meets the threshold criteria, and provides theMaterials best balance of effectiveness, permanence,

implementability, reduction of toxicity, mobilityEstimated Capital Costs: $5,389,832 and volume of contaminants throughEstimated Annual O & M Costs: $2,880 treatment Based on new information or publicEstimated Present Worth Costs: $5,394,000 comments, EPA, in consultation with theEstimated Implementation Time: 2 Years Commonwealth of Pennsylvania, may later

modify the preferred alternative or selectThis alternative provides for landfilling of all another remedial action presented in thismaterial in the earthen lagoons. This Proposed Plan and RI/FS. The public,alternative requires that an access road be therefore, is encouraged to review andbuilt to the earthen lagoons area and that all comment on all alternatives identified in thisof the material is excavated from the lagoons Proposed Plan. The RI/FS should beand is transported offsite for disposal at a consulted for more information on theselandfill. alternatives.

Each of the excavation alternatives includes a Actual or threatened releases of hazardouspost-excavation sampling program to substances from the OCC Site, if notdocument complete removal of the chemicals addressed by the preferred alternative or one

AR308I65

8

of the active measures considered, may • Short term effectiveness:present a current or potential threat to public The time until protection is achieved andhearth, welfare, or the environment. the short term risk or impact to the community,

onsite workers and the environment that mayIn selecting EPA's preferred alternative EPA be posed during the construction andevaluated each proposed remedy against the implementation of the alternative.nine criteria specified in the NationalContingency Plan. The alternative must first • Implementabilitv:satisfy the threshold criteria Next the primary The technical and administrative feasibilitybalancing criteria are used to weigh the of a remedy, including the availability oftradeoffs or advantages and disadvantages of materials and services needed to implementthe alternatives. Finally after public comment that remedy.has been obtained the modifying criteria areconsidered. Below is a summary of the ninecriteria used to evaluate the remedial • Cost:alternatives.

Includes estimated capital, operation andThreshold Criteria maintenance, and net present worth costs.

• Overall protection of human health and Modifying Criteriathe environment:

• State Acceptance:Whether the remedy provides adequate

protection and how risks posed through each Whether the State concurs with, opposes,pathway are eliminated, reduced or controlled or has no comment on the Preferred Remedialthrough treatment, engineering controls, or Alternative.institutional controls.

• Community Acceptance:• Compliance with ARARs:

Whether the public agrees with theWhether or not a remedy will meet all Preferred Remedial Alternative (this will be

applicable or relevant and appropriate assessed in the Record of Decision following arequirements (ARARs) of Federal and State review of the public comments received on theenvironmental statutes and/or whether there Administrative Record and the Proposed Plan).are grounds for invoking a waiver. Whether ornot the remedy complies with advisories,criteria and/or guidance that may be relevant. COMPARATIVE ANALYSIS OF

ALTERNATIVES - GROUNDWATER

Primary Balancing Criteria Overal Protection: Since Alternative 1A (NoAction) would neither eliminate nor reduce to

• Long-Term effectiveness and acceptable levels the threats to human healthpermanence: or the environment presented by contamination

The ability of the remedy to afford long at the Site, it is unacceptable and therefore, itterm, effective and permanent protection to will not be discussed in the remainder of thishuman health and the environment along with analysis.the degree of certainty that the alternative willprove successful. Alternative 18 - (Production Wells & Treatment

by Air Stripping with Carbon Adsorption) does• Reduction of toxicitv. mobility or volume: adequately protect human health and theThe extent to which the alternative will environment by collecting groundwater and

reduce the toxicity, mobility, or volume of the treating volatile organics. It preventscontaminants causing the site risks. groundwater impact on surface water. It does

AR3Q8I66

not optimize collection of chemicals from the Compliance with ARARs: Levels of volatilebedrock aquifer because the pumping system organics in the groundwater are in excess ofwas designed to provide process water, not Safe Drinking Water Act Maximum Contaminantremediate the groundwater. It also does not Levels (MCLs). The goal of the groundwaterminimize the discharge of volatile organics to remedy for the Site is to restore the quality ofthe air because the air stripper is designed to groundwater to comply with Pennsylvaniaoperate without VOC controls. ARARs of background quality. Production Well

Pump and Treat Alternative 1B does not satisfyAlternative 2A (Recovery Wells & Treatment by the goal of restoration. Alternatives 2A throughAir Stripping (with Carbon Absorption) Before 38 have the potential to meet PennsylvaniaProcess) - adequately protects human health ARARs.and the environment by collecting groundwaterand treating it to background concentrations Long Term Effectiveness and Permanence:and eliminates air discharges of VOCs. It Alternatives 2A through 3B would likely reduceprotects the environment because it minimizes risk to acceptable levels under the future usewaste streams to be disposed during scenario. Alternatives 2A through 3B areremediation and prevents contaminated effective in the long-term because of thegroundwater from migrating offsite. conservative design of the treatment system,

which can handle fluctuations ofAlternative 2B (Recovery Wells with Air Stripper concentrations of chemicals in groundwaterAfter Process) - adequately protects human and dynamic discharge regulations.health and the environment by collecting Groundwater monitoring is to be conducted togroundwater and treating volatile organics to document the progress of remediation. At thebackground concentrations and eliminates air end of remediation, concentrations ofdischarges of VOCs. It protects the chemicals remaining in the groundwater areenvironment because it minimizes waste expected to be minimal.streams to be disposed during remediationand prevents contaminated groundwater from Reduction of Tenacity, Mobility, or Volumemigrating offsite. through Treatment: Alternative 1B reduces

the concentrations of VOCs in groundwater byAlternative 3A (Recovery Wells with Steam removal through collection and treatment by airStripper Before Process) - adequately protects stripping. Once the VOCs are removed fromhuman health and the environment by the groundwater by the Air Stripper they arecollecting groundwater and treating volatile released to the air without controls. Alternativeorganics to background concentrations and 1B controls the mobility of the chemicals in theeliminates air discharges of VOCs. It protects bedrock aquifer, preventing lateral offsitethe environment because it minimizes waste migration. However, the existing deepstreams to be disposed during remediation production well pumping is a mechanismand prevents contaminated groundwater from which has promoted vertical migration of themigrating offsite.. chemicals.

Alternative 3B (Recovery Wells with Steam Alternatives 2A and 2B also reduce the VOCsStripper After Process) • adequately protects in the groundwater at the OCC Site. However,human health and the environment by Alternatives 2A and 2B provide an efficientcollecting groundwater and treating volatile remediation program that does not causeorganics to background concentrations and cross-migration of the individual chemicaleliminates air discharges of VOCs. It protects plumes or vertical migration of the plumes.the environment because it minimizes waste Once the groundwater is processed throughstreams to be disposed during remediation the air stripper, the VOCs are removed andand prevents contaminated groundwater from sent to a vapor-phase carbon unit formigrating offsite. absorption of volatile organics. The volatile

organics adsorb onto the carbon bed. Anonsite carbon regeneration system employs

AR3Q8I67

10

activated carbon to remove the volatile protective than Alternative 4 because recyclingorganics. of the majority of the lagoon materials occurs

under these alternatives.Alternatives 3A and 3B also reduce the VOCsin the groundwater at the OCC Site. Compliance with ARARS: Alternatives 1, 2, 3,Alternatives 3A and 38 provide an efficient and 4 comply with applicable or both relevantremediation program that does not causa and appropriate Federal and Statecross-migration of the individual chemical environmental regulations.plumes. Once the groundwater is processedthrough the steam stripper and the VOCs are Long Term Effectiveness and Permanence:removed from the groundwater, the steam and Alternatives 2, 3, and 4 provide long termorganic vapors enter a condenser which effectiveness and permanence. Alternatives 2requires offsrte disposal. and 3 provide more long term effectiveness

and permanence than Alternative 4 becauseShort Term Effectiveness: The risk associated they minimize the amount of material that iswith the current groundwater use scenario was landfilled.not calculated during the FS since there is nomigration of the contamination or current use Reduction of Toxicity, Mobility or Volumeof the contaminated groundwater. Drinking trough Treatment: Alternatives 2 and 3 reducewater wells in the area are not affected by the mobility and volume by recycling the majoritygroundwater contamination from the OCC Site. of lagoon materials. Alternative 4 reduces' - - •Remedial construction workers would be mobility of the lagoon materials by placementexposed to volatile emissions during any well into a secure landfill; Alternative 4 does notand pipe installation activities associated with reduce volume.OCC Alternatives 2A through 3B.

Short Term Effectiveness: Alternative 4ImptementatHfity: Alternative 1B is already in provides more short term effectiveness thanplace and containing the contaminant plumes. Alternatives 2 and 3 because it is proposed toAlternatives 2A through 38 are proven take less time than either alternative.technologies that have been specified in Alternatives 3 and 4 require less time fornumerous CERCLA RODs. design and installation of remediation

equipment than Alternative 2. Worker healthCosts: Of the Alternatives containing remedial and safety will be protected under allaction, OCC Alternative 1B - Existing alternatives by use of engineering controlsGroundwater Collection and Treatment System, and, if necessary, personal protectivewould have the lowest capital and present equipmentworth costs. Alternative 2A - GroundwaterCollection Using Recovery Wells and ImptementabiCty: Each of the alternatives isTreatment by Air Stripping Before the Process, implementable. Alternative 2 is anticipated tothe preferred alternative, has the lowest net be more complicated to implement becausepresent worth and complies with the ARARs. equipment is to be designed, installed, and

started-up. Alternatives 3 and 4 requireCOMPARATIVE ANALYSIS FOR EARTHEN material loading, transport offsrte, andLAGOONS backfilling activities. Disposal and reclamation

activities occur offsrte with Alternatives 3 and 4.Overall Protection: Alternative 1 - No Actionwould not eliminate or reduce the threats to Costs: The lowest cost is associated withhuman health and the environment presented Alternative 2, followed by Alternative 4.by the contamination at the earthen lagoons. Alternative 3 is the most costly.It is not protective of human health and theenvironment and therefore, will not bediscussed in the remainder of this analysis.Alternative 2 and 3 may be considered more

SR308I68

11VII. COMMUNfTY ROLE IN SELECTION questions and requests for information can bePROCESS sent to:

This Proposed Plan is being distributed tosolicit public comment regarding the proposed Linda Dietz (3HW24)remedial alternatives for cleaning up the Site. Remedial Project ManagerEPA relies on public input so that the remedy U.S. Environmental Protection Agencyselected for each Superfund site meets the Region IIIneeds and concerns of the local community. 841 Chestnut BuildingTo assure that the community's concerns are Philadelphia, PA 19107being addressed, a public comment period (215) 597-6906lasting thirty (30) days will follow this publicnotice and a public meeting will be held in thecommunity. It is important to note that Arrangements have been made for a publicalthough EPA has proposed a Preferred meeting to be hold on May 4,1993 at 7:00Alternative, the final remedy selection for the p.m. at the Pottstown Senior Citizens Center, inSite has not been made. All comments Pottstown, PA. Questions regarding the publicreceived will be considered and addressed by meeting should be directed to:EPA before a final remedy selection is made.

Detailed information on the material discussed Mr. Merv Harris, 3EA21herein may be found in the Administrative Community Relation CoordinatorRecord for the Site, which contains the U.S. Environmental Protection AgencyRemedial Investigation, Risk Assessment, and Region IIIFeasibility Study Reports and other information 841 Chestnut Buildingused by EPA in the decision-making process. Philadelphia, PA 19107EPA encourages the public to review the (215) 597-2129Administrative Record in order to gain a morecomprehensive understanding of the Site andSuperfund activities that have been conducted Following the conclusion of the thirty (30) daythere. Copies of the Administrative Record are public comment period on this proposed plan,available for review at the following Information a Responsiveness Summary will be prepared.Repositories: , The Responsiveness Summary will summarize

' and respond to citizens' comments on EPA's"' Preferred Remedial Alternative. EPA will then

Pottstown Public Library prepare a formal decision document, the500 High Street Record of Decision (ROD), that summarizes thePottstown, PA 19464 decision process; and the remedy selected forAnn: Kathy Arnold, Director the Site. This ROD will include the(215) 970-6551 Responsiveness Summary. Copies of the ROD

will be made available for public review in theU.S. EPA information repositories. Once the formalRegion III decision document is approved, EPA will invite841 Chestnut Building, 9th Floor the parties responsible for contamination at thePhiladelphia, PA 19107 Site to participate in the implementation ofAttn: Anna Butch (3HW01) remedial design and remedial action for the(215) 597-3037 Site.

Public Comment Period

The public comment period will run from April20,1993, to May 19,1993. Written comments,

AR308I69

12

GLOSSARY CJFR - The Code of Federal Regulations. Forexample, the citation 40 CFR 260 means Title40 of the Code of Federal Regulations, Part260.

Administrative Record - EPA's official Fractures - Cracks found in the bedrock whichcompilation of documents, data, reports, and can provide a pathway for migration ofother information that is considered important contaminants.to the status of, and decisions made, relativeto a Superfund site. The record is placed in Groundwater • Water found beneath the earth'sthe information repositories to allow public surface that fills pores between soil, sand, andaccess to the material. gravel particles to the point of saturation.

Groundwater often flows more slowly thanAquifer - An underground geologic formation, surface water. When it occurs in sufficientor group of formations, containing useable quantity, groundwater can be used as a wateramounts of groundwater that can supply wells supply.and springs.

Hazard Index - The sum of more than oneARARs - Applicable, Relevant and Appropriate hazard quotient for multiple substances and/orRequirements: multiple exposure pathways.

Applicable requirements are those cleanup Hazard Quotient - The ratio of a singlestandards, standards of control, and other substance exposure level over a specified timesubstantive environmental protection period to a reference dose for that substancerequirements, criteria, or limitations derived from a similar exposure period.promulgated under Federal or State law thatspecifically address a hazardous substance, Information Repository - A location wherepollutant, contaminant, remedial action, documents and data related to the Superfundlocation, or other circumstance at a CERCLA project are placed by ERA to allow the publicsite. access to the material.

Relevant and Appropriate requirements are Leachate -The contaminated liquid resultingthose same standards mentioned above that from water percolating through a landfill orwhile not 'applicable' at the CERCLA site, other waste disposal facility.address problems or situations sufficientlysimilar to those encountered at the site that National Contingency Plan (NCP) - The Federaltheir use is well suited to the particular site. regulation at 40 CFR, Part 300 that guides the

determination and manner in which sites willBedrock - A general term for rock, usually be cleaned up under the Superfund program.solid, that underlies soil or otherunconsolidated material. National Priorities List fNPL) - EPA's list of the

nation's top priority hazardous waste sites thatCapping - Construction of a protective cover are eligible to receive federal money forover areas containing wastes or contamination. response action under Superfund.Caps prevent surface exposure of the wastesand reduce or eliminate infiltration of rain water O&M - Operation and Maintenanceor other precipitation into the waste. Thisminimizes the movement of contaminants from Order of magnitude - a range of valuethe site through ground water, surface water, extending from some value to ten times thator leachate. value.

Carcinogen - A cancer-causing agent. Organic Compounds - Chemicals containingcarbon. Many hundreds of thousands are

flR308!70

13

known. At the OCC site the chemicals present Report. This portion of the Rl evaluates theare organics. (i.e. TCE, VCM, styrene, 1-2- carcinogenic and non-carcinogenic riskstrans-DCE, ethylbenzene). Some organic presented by the contaminants at the site.compounds can cause cancer. Risk is calculated both for current uses and

potential future uses of the property by aOverburden- The loose soil, silt, sand or other defined population, i.e., on and offsiteunconsolidated material overlying bedrock. residents, trespassers, etc.

Plume - The three dimensional area of Saturated Zone - A subsurface area below thecontamination in a particular media, such as water table, in which ail pores and cracks aregroundwater. A plume can expand due to filled with groundwater under pressure equal togroundwater movement or greater than that of the atmosphere.

Potwinyl Chloride- A plastic that is fairly inert Scientific Notation - In dealing with particularlyand manufactured at OCC. large or small numbers, scientists and

engineers have developed a 'short hand*pob - Parts per Billion. Five parts per billion is means of expressing numerical values. Fora fractional representation of 5 parts in 1 billion example, 1,000,000 can be written as 1 x 10sparts. For solids, ppb is a fraction based on and 1/1,000,000 can be written as 1 x 10"*.weight, for example 5 pounds of a contaminantin a billion pounds (500,000 tons) of soil. For SUPERFUND (Comprehensive Environmental..liquids ppb is based on volume, for example 5 Response Compensation and Liability Act - Atablespoons of a contaminant in a billion federal law passed in 1980 and modified intablespoons (3,906,250 gallons) of water. 1986 by the Superfund Amendments and

Reauthorization Act codified at 42 U.S.C. §§ppm - Parts per Million. Five ppm is a 9601 et. seq.. The Act created a Trust Fund,fractional representation of 5 parts in 1 million. known as Superfund, which is available to EPA

to investigate and clean up abandoned orRCRA (Resource Conservation and Recovery uncontrolled hazardous waste sites.Act) - A statute at 42 U.S.C. §§ 6901 et. seq.under which EPA regulates the management of Trichtoroetnyteno - A common solvent used forhazardous waste. degreasing. Abbreviated TCE*.

Record of Decision (ROD) - A legal decision Unsaturated zone - The area above the waterdocument that describes the remedial actions table where the soil pores are not fullyselected for a Superfund site, why certain saturated, although some water may beremedial actions were chosen as opposed to presentothers, how much they will cost, and how thepublic responded and how the public's VotaBe Organic Compounds (VOCs) -comments about the Proposed Plan were Chemical compounds containing carbon thatincorporated into the final decision. readily volatilize or evaporate when exposed to

the air. These compounds can be used asRemedial Investigation and Feasjbffity Study solvents by industry.(RI/FS) - A report composed of two scientificstudies, the Rl and the FS. The Rl is the studyto determine the nature and extent ofcontaminants present at a Site and theproblems caused by their release. The FS isconducted to develop and evaluate options forthe cleanup of a Site.

Risk Assessment (RA) - The RA is an essentialcomponent of the Remedial Investigation

&R308I7I