SDMS DocID 2101297

INTERIM RECORD OF DECISION PRICE BATTERY SUPERFUND SITE

OPERABLE UNIT ONE, RESIDENTIAL SOILS

DECLARATION

SITE NAME AND LOCATION

Price Battery Superfund Site Operable Unit 1, Residential Soils Borough of Hamburg, Berks County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

The attached Interim Record of Decision ("ROD") presents the selected interim remedial action for Operable Unit One ("OU-1") at the Price Battery Site ("Site") located in the Borough of Hamburg, Berks County, Pennsylvania. The interim remedial action was selected in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. §§ 9601 - 9675, as amended ("CERCLA"), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. Part 300. The Interim ROD explains the factual and legal basis for selecting the interim remedial action for OU-1 at this Site. The information supporting the Interim ROD is contained in the Administrative Record for this Site.

The Commonwealth of Pennsylvania concurs with the selected interim remedy set forth in this Interim ROD. /

ASSESSMENT OF THE SITE

Pursuant to duly delegated authority, I hereby determine, pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual or threatened releases of hazardous substances from OU-1 of this Site, if not addressed by implementing the interim response action selected in the Interim ROD, may present an imminent and substantial endangerment to public health or welfare or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The selected interim remedial action for OU-1 will be the first remedial action at the Site. Historic deposition of lead-contaminated particulate from the former Price Battery secondary lead smelter smokestack has contaminated residential properties with lead, arsenic, and antimony in a significant portion of the Borough of Hamburg. The correlation between lead and arsenic or lead and antimony is sufficiently strong that any remediation which addresses lead contamination in soil and dust should also address unacceptable concentrations of arsenic and antimony in soil. A removal action addressing contaminated residential properties has been ongoing since 2003.

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The selected remedy in this Interim ROD entails residential exterior soil excavation and specialized interior cleaning to remove lead-contaminated soils and dust, consistent with the ongoing removal actions. This Interim ROD allows future response work to be performed under remedial authority, instead of removal authority, and will enable EPA to continue to address immediate site risks while additional wprk is performed to determine the full nature and extent of the contamination at the Site. A final remedy selection process will proceed after the full nature and extent of the contamination is determined, and a Final ROD for OU-1 will be issued.

The selected interim remedial action includes the following major components:

• Excavation, backfilling, and revegetation of lead-contaminated soils in residential or residential-type properties exceeding 572 parts per million ("ppm") lead ^

• Disposal of excavated soils in an approved off-site permitted disposal facility based on Toxicity Characteristic Leaching Procedure ("TCLP") analysis

• Specialized interior cleaning of residential properties exceeding interior dust level of 40 micrograms/squaxe foot ("|ig/ft ") for floors

• Temporary relocation of residents during specialized interior cleaning

• Public education in the form of community meetings, pamphlets, brochures, etc., informing property owners, renters, and the community of the hazards associated with lead exposure, including lead-based paint, and preventative measures to reduce exposure

• Insfitutional controls ("ICs") limiting access for future development, improvement, and use of unremediated properties or properties where residual risk may remain after cleanup. ICs will include activity and use restrictions enacted through proprietary (e.g., easements, covenants) and/or governmental (e.g. zoning requirements or Registry) controls to prevent use of the property that will pose an unacceptable risk to receptors \ (i.e., for residential use). The exact type of IC implemented will be determined by EPA in consultation with PADEP and local government agencies.

STATUTORY DETERMINATION

The selected interim remedial action is protective of human health and the environment; complies with all Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action; is cost-effective, and ufilizes permanent solutions and alternative treatrrient (or toxicity, mobility, or volume of hazardous substances, pollutants, or contaminants as a principal element through treatment).

The interim remedial action may result in hazardous substances, pollutants, or contaminants remaining on-Site above levels that allow unlimited use and unrestricted access for those

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residential properties which decline participation in the cleanup or where cleanup performance standards cannot be achieved. Therefore, an assessment of the Site will be conducted no less often than every five years after inifiafion of the interim remedial action in accordance with Secfion 121(c) of CERCLA, 42 U.S.C. § 9621(c), to ensure that the remedy is, and will be, protective of human health and the environment.

yatHryn A. Hodgkiss,\cting Di/ector Date > Hazardous Site Cleanup Division Region III

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PRICE BATTERY SUPERFUND SITE

OPERABLE UNIT 1 RESIDENTIAL SOILS

HAMBURG, PENNSYLVANIA

INTERIM RECORD OF DECISION

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PRICE BATTERY SUPERFUND SITE OPERABLE UNIT 1, RESIDENTIAL SOILS HAMBURG, PENNSYLVANIA

INTERIM RECORD of DECISION

TABLE OF CONTENTS

I. SITE NAME, LOCATION, AND DESCRIPTION.... .1

H. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1

i n . HIGHLIGHTS OF COMMUNITY PARTICIPATION .5

IV. SCOPE AND ROLE OF THE OPERABLE UNIT 6

V. SITE CHARACTERISTICS ........7

A. Geographical, Topographical and Hydrogeological Features .........7 B. Remedial Investigation Activities and Extent of Contamination .9 C. Conceptual Site Model 14

VI. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 15

VIL SUMMARY OF SITE RISKS .......15 A. Human Health Risk Assessment Summary ...15 B. Summary of Ecological Risk Assessment 18

VIH. REMEDIAL ACTION OBJECTIVES ........18

IX. SUMMARY OF REMEDIAL ACTION ALTERNATIVES 20

X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. 'iS

XL PRINCIPAL THREAT WASTES 35

XIL SELECTED REMEDY 35

XIIL STATUTORY DETERMINATIONS 44

RESPONSIVENESS SUMMARY..., 60

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FIGURES

Figure 1 Site Location 47

Figure 2 Removal Assessment and Remedial Investigation Areas 48

Figure 3 Predicted High Probability Area 49

Figure 4 Percentage of Properties Exceeding 572 PPM 50

Figure 5 Site Conceptual Model ..51

TABLES

Table 1 Action Specific ARARs 52

Table 2 Location Specific ARARs 54

Table 3 Chemical Specific ARARs. 55

Table4 Selected Remedy Costs.....; 57

HI

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ACRONYMS AND ABBREVIATIONS

AERMIC American Meteorological Socety/Environmental Protection Agency Regulatory Model

Improvement Committee

AOC Administrative Order on Consent

ARAR Applicable or Relevant and Appropriate Requirement

ATSDR Agency for Toxic Substances and Disease Registry

BkC Berks-Weikert complex

CDC Centers for Disease Control

XERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CERCLIS CERCLA Information System

CFR Codeof Federal Regulations

cm centimeter

EPA Environmental Protection Agency

ERT Emergency Response Team

g/cm^ grams/cubic centimeter

HEPA High Efficiency Particulate Air

HHRA Human Health Risk Assessment

HI Hazard Index

HUD Department of Housing and Urban Development.

HVAC Heating Ventilation and Air Conditioning •

IC Institutional Control

lEUBK Integrated Exposure Uptake Biokinetic Model

Lv Linden Loam

MSL Mean Sea Level

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ACRONYMS AND ABBREVIATIONS (CONT)

NCP National Contingency Plan

NPL National Priorities List

OSWER Office of Solid Waste and Emergency Response

OU Operable Unit

PADEP Pennsylvania Department of Environmental Protection

PADOH Pennsylvania Department of Health

PbB Blood Lead

PRG Preliminary Remediation Goal

ppm part per million

PRP Potentially Responsible Party

RCRA Resource Conservation and Recovey Act

RI/FS ^Remedial Investigation and Feasibility Study

ROD Record of Decision

TAL Target Analyte List

TEC To-be-Considered

TCLP Toxicity Characteristic Leaching Procedure

TSP Trisodium Phosphate

Hg/dl micrograms/deciliter

Hg/ft̂ micrograms/square foot

UkB Urban-land Berks complex

USDA United States Department of Agriculture

XRF X-Ray Fluorescence

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INTERIM RECORD OF DECISION PRICE BATTERY SUPERFUND SITE

OPERABLE UNIT 1 RESIDENTIAL SOILS

DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

The Price Battery Superfund Site ("Site") is located approximately 20 miles north of the City of Reading, in the Borough of Hamburg, Berks County, Pennsylvania (Figure !)• The Price Battery Superfiind Site, as currently defined, includes the former Price Battery manufacturing facility, adjacent residential areas and other areas in Hamburg,.Permsylvania that were contaminated with antimony, arsenic, and lead. Between 1940 and 1971, operations at the facility included a secondary lead smelter, smokestack and an oxide plant. During operations, battery casings were broken open and the lead plates inside the batteries were removed for smelting. The lead-contaminated battery wastes and casings were sometimes used as fill material throughout the Borough of Hamburg and surrounding vicinity. The lead smelter produced emissions that contaminated residential properties downwind of the facility with antimony, arsenic, and lead. In 1971, smelting operations ceased, and the smelter and smokestack were dismantled. However, battery production continued unfil the mid-1990s.

For the purposes of this Interim Record of Decision ("ROD"), the current area of the Price Battery Site is defined as the area bordered to the north by Franklin Street, to the west by Front Street and PA Route 61, to the south by Hawk Ridge Drive, and to the east by St. John's Cemetery and Hillside Court properties (Figure 2). These are approximate boundaries and should not be considered absolute. The geographic coordinates of the approximate center of the Site are 40.550 degrees north latitude and 75.98 degrees west longitude (Figure 2).

The United States Enviroiunental Protection Agency ("EPA") is the lead agency and has idenfified the Site as CERCLIS ID# PAN000305679. The Pennsylvania Department of Environmental Protection ("PADEP") is the support agency. The cleanup of residential properties at the Price Battery Site is being funded from the Superfund Trust under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended ("CERCLA").

IL SITE HISTORY AND ENFORCEMENT ACTIVITIES

Price Battery Corporation was foimded in 1918 and occupied at least a portion of its current location at 246 and 251 Grand Street in Hamburg, Pennsylvania, since its inception. The Price Battery facility is approximately 9 acres in size and is currently not in operation. The facility formerly consisted of three large manufacturing buildings (east building, west building, and the oxide department) [Main Parcel], a quarter acre lot located between Peach Alley and Third Street

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[Parking Lot], a one-acre plot of land located between Walnut and Pine Streets [Broom Works Parcel], and a large warehouse and parking lot located on a parcel to the west of Second Street [Warehouse Parcel]. The majority of these buildings, except the warehouse building, were demoHshed in 2007 and 2008.

The former east building contained a battery storage room, a warehouse room, a loading dock, north and central dry formation rooms, a plate drying room, a plate storage room, a lead oxide pasting area, a battery assembly area, a grid-casting room and a laboratory. Interior walls had been degraded by acid corrosion and damaged by heavy equipment in several areas. Several 55-gallon drums, sumps and trenches contaiiiing various materials were formerly located in this building. The former west building consisted of a warehouse room, a loading dock, a wet formaUon area, a finishing room, and an enveloping room. Drums were formerly located in the enveloping area and the wet formaition area. Trenches were located in the wet formation area and the finishing room.

A large warehouse and a parking lot area still remain on the parcel of land west of Second Street. The parking lot area, which lies south of the warehouse, is covered primarily with asphalt and partially by gravel. Historical maps indicate that portions of this area were once the boat basin of the Hamburg section of the Schuylkill Navigation Canal. The warehouse is approximately 200 by 300 feet in area.

From the 1940s to approximately February 1966, Price Battery owned and operated the lead battery recycling and manufacturing facility located at 251 Grand Street in Hamburg, Pennsylvania. As part of the battery recycling process, a secondary lead smelter operated at the facility. The facility recycled lead-acid batteries and also produced approximately 15,000 ' batteries per year. New batteries from the Price Battery facility were delivered to customers and junk batteries were brought back to the Price Battery facility for recycling. Employees at the Price Battery .facility split open the used batteries at a smelter at the facility and reused the lead plates from the junk batteries in the smelter. Price Battery reused only the lead plates from the batteries. The rest of the battery was waste and was stored in a dump truck. The waste consisted of asphalt, hard rubber, and plastic casing that may have been contaminated with lead. The bottom of the junk battery casings normally contained a lead residue that had settled to the bottom of the battery casing during the battery's lifefime. This residue resulted from the lead oxide and acid that had been placed in the battery as it was being manufactured. When the dump truck was full of waste battery casing. Price Battery employees drove the truck to various locations in and around Hamburg to dump the waste casings. Battery casings were also made available for people to pick up from the facility for use as fill.

Noxious odors and acid fumes were reportedly emitted from the Price Battery facility. In 1941, a citizens' group contacted the Borough of Hamburg with concerns about the facility's operations. The group's legal counsel indicated that smoke stacks on the facility emitted lead-contaminated ash produced during the melting of old batteries.

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From the 1940s until approximately 1961, Price Battery contracted with Blue Mountain Coal Company ("Blue Mountain") to compact battery casing waste after it was dumped in and around Hamburg and to remove slag from the Price Battery facility. The slag was left over from the lead smeUing operations at the facility. Blue Mountain dumped the slag at the locations in Hamburg where Price Battery had dumped the battery casings. Beginning in the early 1960s, Price Battery entered into an agreement with Brown's Battery ("Brown's") to send junk batteries that were returned from Price Battery's customers to the Brown's breaking facility, located in Shoemakersville, Pennsylvania. Brown's broke open the junk batteries and removed the lead plates for return to the smelter at the Price Battery facility where the lead plates were relised.

In 1966, General Battery Corporation C'General Battery") acquired the facility from Price Battery. General Battery continued Price Battery's bitery-making operations at the facility making the same products and using the same equipment until 1971, when General Battery closed its smelter operation. In 1987, Exide Technologies Inc. ("Exide") acquired General Battery. Exide ceased manufacturing at the Site in 1995.

Exide is the current owner of the former Price Battery facility, and EPA has identified Exide as a potenfially responsible party ("PRP") at this Site. Exide has filed for bankruptcy, and EPA has filed a proof of claim in that bankruptcy for several sites including the Price Battery Site. Given the nature of the bankruptcy proceeding, EPA will not seek to have Exide conduct the Remedial Action on those properties addressed by this Interim ROD (i.e. properties that are not owned by Exide). The status of EPA's claim against Exide for this Site is currently the subject of ongoing settlement negotiations. However, Exide and EPA have negotiated an administrative order on consent ("AOC") to perform a remedial investigation/feasibility study ("RI/FS") of all Exide-owned properties. All structures previously located on the four Exide-owned properties (warehouse parcel, broomworks parcel, main parcel, and parking lot) have been demolished, except for the blue warehouse.

The Site was finalized on the National Priorities List ("NPL") on April 27, 2005.

Summary of EPA Removal Actions

> An EPA removal action was initiated on May 12, 2003, to address residential properties in the vicinity of the former Price Battery facility contaminated with lead. Residents were notified of the program and were provided the information necessary for them to initiatie discussions with the EPA regarding their potential eligibility for cleanup. The E P A provided the residents with a cleanup questionnaire requesting information on ownership of the residence and the ages of children at the residence. EPA contractors then collected samples from exterior soils and interior dust for analysis. The results of the soil/dust analysis and the ages of the children at the residence factored into the EPA's determination of the eligibility for cleanup.

From May 2003 through October 2004, this removal action entailed the excavafion of soils contaminated with lead above 400 parts per million ("ppm") from residential yards and the decontamination of residential interiors. An action level for lead dust on floors of 40 micrograms

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per square foot ("|jg/ft^) was used for interior decontamination consistent with EPA regulafions for lead-based paint abatement. In the absence of a site-specific cleanup level for lead in soil at the commencement of the removal actions, EPA conservatively used the 400 ppm screening level for lead in soil at residential properties as the cleanup level unfil a site-specific lead in soil cleanup level was determined for the Price Battery Site. As part of those actions, EPA removed contaminated soils to a depth of 6 - 12 inches, placed a visual barrier (i.e., orange construcfion fencing) at the bottom of the excavation to indicate that remaining soils were potentially above 400 ppm, and backfilled with clean soil. Those actions eliminated the immediate risk to residents exposed to contamination at or near the surface but did not necessarily fully address the extent of contamination in the residential yards. During the course of 2004, EPA collected additional information in order to develop a risk assessment and calculate a site-specific cleanup level for lead in soil that would be protecfive of children who might be exposed to lead contamination in the soils. This site-specific risk assessment ulfimately established a cleanup level for lead in soil of 572 ppni. Beginning in April 2005 to the. present, the removal acfion has entailed the excavafion of lead contaminated soils above 572 ppm for lead to "clean" soil (lead soil levels below 572 ppm), unless physical barriers such as tree roots, foundations, etc., prohibited excavation of soils to "clean". In such cases where all lead contaminated soil above 572 ppm could not be removed, a visual barrier (i.e., orange construcfion fencing) was placed to indicate that remaining soils were potentially above 572 ppm. The removal action is ongoing.

The following table shows the total number of houses cleaned arid sampled since the begirming of the removal action. Because of cold temperatures during the winter months, exterior cleanup activities are temporarily halted in the winter of each year and resumed in the spring, although interior cleanup activities may condnue during the winter.

Year

2002 2003 2004 2005 2006 2007 2008 2009 TOTAL

Exteriors Sampled

166 153 37 38 260 182 17 1 854

Properties Exceeding 400 ppm 121 109 27 35 157 113 16 1 579

Properties Exceeding 572 ppm 116 102 25 33 123 76 14 1 490

Interiors Sampled

0 104 13 53 50 118 42 ON

380

Interiors Exceeding 40ng/ft^ 0 100 13 53 49 117 40 0 372

Exteriors Cleaned

0 43 46 46 44 ,89 89 0 357

Interiors Cleaned

0 20 43 37 22 55 52 9 238

ppm = part per million (lead soil level) Hg/ft̂ = microgram per square foot (interior lead dust level for floors)

As of 3/16/09

As of March 16, 2009, 854 houses were sampled during the eight year period covering the removal action. This sampling continues to show the presence of high levels of lead in soils and household dust. A total of 357 properties were cleaned on the exterior and 238 properties were cleaned on the interior. Based on information currently available in EPA's residential database, the total number of residences remaining that are eligible for cleanup because they exceed the

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exterior and/or interior action level are approximately 133 exteriors and 134 interiors. There are an additional 157 properties, that never responded to EPA mailings requesting exterior sampling access; therefore, the eligibility of these 157 properties is currently unknown. Also, there are 89 residences where a removal acfion was conducted in 2003 and 2004 which may need addifional exterior work. During the initial two years of the removal action, yard excavation was conducted to eliminate the direct contact risk with lead contaminated soils; however, these excavations may not have necessarily eliminated all residual risk since contaminated soils may have been left in-place under a 6-12 inch protective topsoil cover. EPA will attempt to gain access to these properties during the remedial action to resample and/or re-excavate the yards so that property restrictions will not need to be placed on these properties. EPA will also continue to atternpt to gain access to conduct exterior sampling at those residences which never responded to EPA mailings.

i n . HIGHLIGHTS OF COMMUNITY PARTICIPATION ^

EPA has been performing outreach to the citizens of Hamburg, Hamburg Borough Council, health officials, the media, non-profit groiips, and others since becoming involved at the Site in 2002 in an effort to convey informafion about the hazards of lead exposure and particularly how lead affects the health of children. EPA has participated in niunerous formal and informal meetings to explain EPA's role and commitment in Hamburg, convey information about the Superfund process, and provide general information about the Site and lead contamination, including lead paint hazards. EPA has participated in local events such as Hamburg Community Days and Safety Day by setting up booths or information stands regarding lead hazards. EPA has also participated with the Pennsylvania Department of Health ("PADOH") in annual child blood lead screenings in Hamburg and discussions with local pediatrician offices regarding lead contaminafion within the Borough. EPA also responds to inquiries on a daily basis regarding the Site and individual homeowners' sampling results and personally meets with every resident or tenant who has been scheduled for a residential cleanup. EPA also maintains full-time community relations support on-site.

On June 10, 2009, pursuant to secfion 113(k)(2)(B) of CERCLA, 42 U.S.C. §113(k)(2)(B), EPA released for public comment the Proposed Remedial Action Plan ("Proposed Plan") setting forth EPA's preferred remedial alteriiafives for the Site. The Proposed Plan was based on documents contained in the Administrative Record File. EPA made these documents available to the public in the EPA Administrative Record Room in EPA Region Ill's office located at 1650 Arch Street in Philadelphia, Pennsylvania, and at the local information repository at the Hamburg Public Library located at 35 North Third Street in Hamburg, Pennsylvania. A notice of availability of these documents was published in the Reading Eagle and Hamburg Item on June 10,2009. EPA opened a 30-day public comment period on June 10, 2009 to receive comments on EPA's preferred alternatives and the other alternatives identified in the Proposed Plan. Corrunents received during this public comment period, as well as EPA's response to such comments, are summarized in the Responsiveness Summary section of this Interim ROD. EPA and PADEP also held a public meeting on June 18, 2009 at the Hamburg Area High School, Large Group

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Information Room located at 701 Windsor Road in Hamburg. A detailed discussion of the recent community activities is presented in Section X under the subheading Community Acceptance.

More detailed documentation on the information contained in this Interim ROD may be found in the Administrative Record which contains the Interim Remedial Invesfigation, Interim Feasibility Study, and other information used by EPA in the decision making process. EPA encourages the public to review the Administrative Record in order to gain a more comprehensive understanding of the Site and the activities that have been and will be conducted there. The Administrative Record can be viewed at the Hamburg Public Library located at 35 North Third Street in Hamburg, Pennsylvania and is also available at the EPA Region III Office located at 1650 Arch Street in Philadelphia, Pennsylvania. To review the Administrafive Record at EPA's Philadelphia office, contact Ms. Anna Butch, Administrative Record Coordinator, at (215) 814-3157. The Administrative Record can also be accessed on the web at www.epa.gov/arweb. Copies of this Interim ROD are available for public review in these information repositories.

EPA will continue to work with the community in an effort to provide enhanced communicafion and education on lead prevention through outreach, public availability sessions, attendance at local gatherings, and mailings.

IV. SCOPE AND ROLE OF OPERABLE UNIT

EPA's inifiaf response actions for lead-contaminated residential properties at the Price Battery Site commenced in 2003 under CERCLA removal authority. As the soil and interior residential cleanup under CERCLA removal authority was ongoing, planning for continued response under CERCLA remedial authority was proceeding. EPA organized the remedial response into two operable units:

• Operable Unit 1: Price Battery Residential Portion

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• Operable Unit 2: Price Battery;Facility Portion (i.e.^ Exide-Owned Properties)

Operable Unit 1 ("OU-1") addresses lead contaminated residential soils and interiors within the Borough of Hamburg. Beginning in 2005, EPA initiated a RI/FS for OU-1 to determine the nature and extent of contamination at the Site, to characterize the risks to human health and the environment, and to evaluate altemafives to clean up the contamination at the Site. The findings of the RI/FS are presented in the Interim Remedial Investigation Report for OU-1 and the Interim Feasibility Study Report. OU-1 is the subject of this Interim ROD.

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Operable Unit 2 ("OU-2") addresses all Exide-owned properties within the Borough of Hamburg, including groundwater below the properties, which includes the Main Parcel (facility property). Warehouse Parcel, Broom Works Parcel, and Parking Lot. On May 30, 2007, EPA entered into an AOC with Exide to perform the OU-2 RI/FS. Exide made the determination to demolish the buildings on the former Price Battery facility. Pursuant to the AOC, Exide was to initiate the

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RI/FS after demolifion activities were completed. Exide began demolition acfivifies in June 2007 and completed demolition and debris disposal in early 2008. Exide began the RI/FS fieldwork pursuant to the May 30, 2007 AOC in September 2008. OU-2 will be the subject of a subsequent Proposed Plan and ROD.

This Interim ROD allows future response work to be performed under remedial authority and describes an interim approach EPA has selected for addressing residential properties that have been contaminated with lead by the former Price Battery facility, consistent with the ongoing removal action. The Price Battery facility no longer exists; however, historic deposition of lead-contaminated particulates from the former secondary lead smelter smokestack has contaminated a significant portion of the Borough of Hamburg. Residential properties that are contaminated with lead resulting from historic industrial emissions are the only types of properties that will be addressed by this cleanup. Residential properties are defined as any area with high accessibility to sensitive populations (children under six years of age and pregnant and nursing women), and includes properties containing single and multiple family dwellings, apartment complexes, vacant lots in residenfial areas, schools, child care facilifies, community centers, parks, greenways, and any other areas where children may be exposed to site-related contaminated media. Residential yards contaminated solely from other sources, such as lead-based paint, cannot be addressed under CERCLA authority and will not be addressed under this cleanup action.

The interim remedy described in this Interim ROD addresses all Site-related residential contaminated soils and interior dust in target area properties for OU-1 as currently known. The long-term nature of the Site response provides an opportunity to select an interim remedy to address the highest priority properties while addifional evaluation is performed to support a final remedy once the extent of the residential lead contamination is known. The remedy described in this Interim ROD will be consistent with the final remedial acfion selected for the Site.

A subsequent Proposed Plan and Final ROD will be issued when EPA has determined the full natiu-e and extent of the contaminafion. This Interim ROD does not include a remedial alternative for OU-2, Exide-owned properties, which will be studied further prior to EPA proposing remedial alternatives and selecting a preferred alternative to clean up the Exide-owned properties. In addition, pending an evaluation of the RI/FS for OU-2, EPA may consider a third Operable Unit to further study groundwater, surface water, and sediment in areas outsidcithe scope of OU-2.

V. SITE CHARACTERISTICS

A. Geographical, Topographical, and Hydrogeological Features

The Borough of Hamburg, Berks County, Pennsylvania, is located at the foot of the Blue Mountains, along the Schuylkill River, just south of Schuylkill County. The Price Battery Site is located in the central to southern portion of the Borough. Kaercher Creek flows through the

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Borough of Hamburg and through the former Price Battery facility before joining the Schuylkill River located to the southwest of Hamburg.

The Borough of Hamburg and Tilden Township are situated on a low-lying secfion of land bordering the Schuylkill River. Elevations range from approximately 350 feet above mean sea level ("MSL") near the Schuylkill River to almost 550 feet above MSL on the ridges found to the north and east of the town center.

Surficial drainage across the Borough of Hamburg is primarily east to west and siu-ficial drainage across Tilden Township is primarily west to east. Mill Creek to the north and Kaercher Creek to the south act as intermediate collecfion points for surface water, collecting run off from approximately 50% of the land area south of Interstate 78, before they discharge into the Schuylkill River. The remaining surficial runoff flows directly into the Schuylkill River. The Schuylkill River then carries the water to the southeast and away from the Borough of Hamburg and Tilden Township.

The site is located in the Great Valley Secfion ("Great Valley") of the Ridge and Valley Province. The Great Valley is approximately 20 miles wide and extends in length from the midpoint of the eastern border of the state, to the midpoint of the southern border of the state. To the north, the Great Valley is bordered by the Blue Moimtain Section. The south edge of the Great Valley abuts both the Reading Prong Section of the New England Province and the Gettysburg-Newark Lowland Section.

Within the Hamburg portion of the Great Valley, the underlying geological feature consists of Hudson River Shale and Utica Slate. This slate bed, in combination with the Trenton, Chazy, and Calciferous limestone beds, makes up the predominant geological features of the Great Valley. These two formations are excessively crimpled by side pressure, and the whole valley is a labyrinth (underground) of sharp, small anticlinal and synclinal folds, all pressed over to the north and collapsed, so that the dips exposed along the Schuylkill River from Reading up to the Port Clinton gap (17 miles in straight line) are all steep to the south; whereas the limestone as a whole passes down northward under the slate, and the slate as a formation dips northward under the Medina sandstone of the Blue Mountain.

Based oh US Department of Agricuhure ("USDA") studies, there are approximately 10 soil classifications within the area of the Price Battery operable units. These classifications can be reduced to three main groups: 61% of the material can be classified into the Berks-Weikert complex ("BkC"), 29% as Urban-land Berks complex ("UkB") and 10% as Linden loam ("Lv").

In general, all three soil types share a common depth to restrictive features with lithic bedrock typically encountered prior to 100 inches. All three soil types also have a moderately high to high ability to transmit water, with a moderately high to high hydraulic conductivity (0.2 to 6.0 inches per hour). Detailed soil maps and descripfions are provided in the Interim Remedial Invesfigation Report.

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Contamination found at the Price Battery Site to date has been surficial and there has been little investigation of groundwater beyond surficial perched water within the confines of the facility (OU-2) itself Groundwater will be sampled on the facility property by Exide as part of the OU-2 RI. Limited groundwater sampling has been done outside of the OU-1 area and no groundwater contamination has been found to date. No investigation of the hydrology or distribution of the hydrostratigraphic units of interest within OU-1 has been conducted for this reason. If the remedial investigation for OU-2 ultimately reveals that groundwater beneath the former Price Battery facility is contaminated, EPA will consider a separate operable unit for groundwater outside the facility boundaries.

B. Remedial Investigation Activities and Extent of Contamination

1. Air Dispersion Modeling

EPA conducted a removal site assessment of the residential area downwind of the former Price Battery facility between September 10, 2001 and November 12, 2002. EPA targeted this area for characterization of lead concentrations in soil, based on an air dispersion model of contaminants emitting from the facility provided by the EPA Emergency Response Team C'ERT"). The dispersion model was based on the assiuned height of the former smokestack, predominant prevailing wind direction and velocity, and local topography. Lead analytical results from this initial soil sampling indicated that fiarther sampling of the residential area would be necessary.

Based on results of preliminary sampling in 2001 and 2002, soil samples were collected from residential properties (where access was provided) within the area identified by ERT as likely to have the highest lead deposition. In March 2003, EPA began a removal acfion at affected properties that included soil removal, interior carpet and dust sampling and analysis, and interior remediation, as appropriate. These removal actions have been ongoing through 2009.

In the fall of 2005, EPA initiated an Interim RI/FS for OU-1 (Residenfial Portion) to determine the exact nature and extent of the lead contamination potentially affecting residences surrounding the former Price Battery facility. As part of the Interim RI, a subsequent, more detailed, air dispersion model was prepared that indicated that lead deposition may have impacted a significant area within the Borough of Hamburg. The air dispersion model was prepared using AERMOD; which is the preferred air dispersion model for the American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee ("AERMIC"). AERMOD is capable of using detailed source information, building information, hourly meteorological data, and terrain data to predict concentrations and deposition fluxes conservatively at multiple locations (receptors) for a given time period. AERMOD was run to predict dry, wet, and combined particulate deposition; to account for mass depletion due to dry and wet scavenging processes; and to account for aerodynamic influences from the facility's structures. An annual averaging period was selected to produce total annual deposition output.

The air dispersion model was finalized in June 2006 and looked solely at lead deposition to provide an initial view of how the lead smelter may have deposited lead contamination. The

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modeling performed accounted only for initial deposition and accumulafion of lead emissions from process stacks and vents at the facility. It did not account for meteorological and other mechanical processes that may have acted over the intervening years to re-entrain and redistribute these lead emissions. A mixing depth of 1 inch and a soil density of 2.65 grams per cubic centimeter ("g/cm'') were used as model input assumptions. The model assisted in determining where to focus the interim remedial investigations around the Price Battery facility.

The 2006 air dispersion model was not designed to account for meteorological and other mechanical processes which could re-entrain and redistribute lead emissions. Also, the model assumed a specific mixing depth and soil density. If different mixing depths and/or soil densities had been assumed, the model may have included more or less depositional area. Therefore, there is some degree of uncertainty in the air dispersion model; however, the assumptions used provide a representative model of air dispersion from the facility process stacks and vents.

2. EPA Particulate Transport Evaluation

In November 2008, a particulate transport evaluation was prepared using the average air model dispersion concentrations generated in June 2006, coupled with topography. The boundary line depicted on the map found in Figure 3 indicates that the enclosed area has a high probability of having lead soil concentrations above 572 ppm resulting from both deposition and migration. Analytical results were compared to the air dispersion model boundary line to confirm delineation. In a few instances, the predicted particulate transport evaluation boundary matches the edges of the air dispersion model domain, as there is no deposition up gradient to wash down. Areas of the particulate transport evaluation that require further clarification include the following:

• Eastern side: the high probability area is significantly smaller than the air dispersion model, due to high relief changes that likely would resuh in migration of deposits to the lower lying areas, toward downtown Hamburg.

• South along the west bank of the river: there is a 'finger' of low lying land down gradient from a ridge that lies within the air deposition area. The air deposition in that area is not predicted to be particularly high, but the steepness of the elevation change and the small depression at the base of that ridge create an oblong bowl that could accumulate higher levels of deposits due to the compressed area.

The particulate transport evaluarion was based on the average 30-year air dispersion model contours; which have a certain degree of uncertainty, as noted previously. The particulate transport evaluafion used the middle of each hillside to start upgradient washdown areas; which, possibly leads to a more conservative high probability lead area. This evaluation looked at the drainage area as open space and did not account for urban drainage patterns such as storm water controls. This evaluation also did not consider high volume precipitation events that produce temporary streams in flatter open areas or flood events which would result in pockets of pool

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sedimentation. Therefore, there is some degree of uncertainty in the particulate transport evaluation; however, the assumptions used were conservafive and should provide a representafive high probability area for lead concentrafions above 572 ppm.

3. Soil Investigation >̂

Beginning in 2002, siuface soil samples were collected during the removal assessment from properties located within the original area of concern to determine the extent of contamination and to identify properties eligible for removal action. This initial area was defined approximately as the residential area that is bordered to the north'by Pine Street, to the east by Primrose Alley and South Sixth Street, to the south by Maple Street, and to the west by South Second Street, Peach Alley, and South Third Street. The area of concern was later extended to include the area north of Pine Street to State Street (Figure 2). Samples were analyzed by x-ray fluorescence ("XRF") with 10% sent to a laboratory for confirmation to determine lead concentrations,in surface soil at properties located close to the Price Battery facility. The samples were analyzed for lead. Soil samples with lead concentrations above 400 ppm were considered to be exceedances prior to May 26, 2005. On May 26, 2005, as documented in a Removal Action Memorandum, the cleanup level for lead in soil was increased to 572 ppm.

Based on the results of the air dispersion modeling conducted in 2006, EPA suspected that the contaminafion extended beyond the original area in which removal assessments were ongoing. EPA decided to initiate an Interim RI and continue investigations beyond the removal assessment area to determine the extent of contamination. Remedial soil invesfigafion acfivities began in October 2006 resulting in the OU-1 target area for this Interim ROD being expanded to the area bordered to the north by Franklin Street, to the west by Front Street and PA Route 61, to the south by Hawk Ridge Drive, and to the east by St. John's Cemetery and Hillside Court properties (Figure 2).

Soil sampling of residential properties during the Interim RI was performed in accordance with the "Superfund Lead-Contaminated Residential Sites Handbook". This policy document, and previous drafts, establishes an approach to the characterization and remediation of lead-contaminated residential soils under CERCLA response authority. The actions described in this Interim ROD are consistent with the approach established in this policy document. Based on property size, 3 or 5 point composite samples were collected in different areas of the property closest to the residence. Composite areas were normally taken from front, side, and back yards and samples were collected away from a building drip line (if possible) to reduce the probability of lead-based paint chips entering a sample. For larger properties (greater than 5,000 square feet) three composite samples Were collected. For smaller properties (less than 5,000 square feet) two composite samples were collected.

The surface soil samples were analyzed for antimony, aluminum, arsenic and lead. Lead, antimony and arsenic are all site-related; aluminum is known to cause interferences in lead analysis and was included for analysis to evaluate data if such interferences were encountered. Ten percent of all samples also receiyed full Target Analyte List ("TAL") analysis. Surface soil

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samples collected from residenfial properties which exceed the site-specific cleanup level of 572 ppm qualified for exterior remediation and further interior dust sampling.

Subsurface soil sampling was also conducted to determine if lead contaminafion was present at depth in yards where surface soil lead contamination was low and the yard was bordered by adjacent properties which had high lead levels. Subsurface soil samples were collected from ten percent of the properties sampled during the RI which had lead concentrations below the cleanup level of 572 ppm. The subsurface soil sampling performed was biased to properties located mostly north of State Street between those properties that displayed lead concentrafions below the 572 ppm lead cleanup level, and properties that had elevated arsenic concentrafions (above the 15 ppm arsenic cleanup level) but had low lead values. The samples were analyzed for antimony, aluminum, arsenic, and lead. Ten percent of all samples were sent for analysis for full TAL analysis. The goal of the subsurface sampling was to determine the probability that additional properties could potentially qualify for cleanup because lead contaminafion was present below the immediate surface of the yard because of the potenfial of clean fill being placed in the yard thereby influencing the surface sample results. The results indicate that there is the potential in a smaller subset of properties that lead contamination does lay below the immediate surface of the yard.

In general, the sampling revealed that concentrations of lead in soil are greatest near the former location of the former Price Battery facility. Concentrations of lead, in general, decrease with increasing distance from the former facility. Exterior residential yard lead concentrations ranged from 1.1 to 173,978 ppm with a mean concentrafion of 1,511 ppm. Although soil samples were collected outside the drip-line of the homes, it appears that some residential soil samples may have been impacted by the presence of exterior lead^based paint given the extremely high concentrations in some yard samples. However, since these homes are located within the area predicted to have a high probability of having lead soil concentrations above 572 ppm resulting from both deposition and migrafion, EPA believes these properties have also been impacted, in part, from airborne deposition above EPA's cleanup level. Figure 4 depicts the percentage of residential properties impacted by historic lead emissions at the Site. More detailed information regarding the lead concentrafions found at individual properties may be found in the Final Interim Remedial Invesfigation Report for OU-1.

These boundaries idenfify the focus area for the invesfigafion of the Site, but do not define the extent of the Site. Theextent of the Site will ulfimately be determined once all residenfial properties of potential concern have been characterized and documented in a Final ROD for the Price Battery Site. Every residential property (assuming access is provided) is tested individually and sampling results determine if the property is included as part of the Site.

4. Dust Investigation

Dust samples were collected from properties which had exterior surface soil lead concentrations of 400 ppm (prior to May 26, 2005) or 572 mg/kg (after May 26, 2005) or higher. The objective of the interior dust sampling was to determine whether lead concentrations present in interior

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residenfial dust samples were above the EPA lead hazard level of 40 |ig/ft̂ for floors (including carpeted floors). In general, dust samples were collected from as many rooms as possible or accessible including living rooms, dining rooms, kitchens, bedrooms, attics, and basements. Particular emphasis was placed on collecting dust samples from high traffic areas and children's play areas. ^

Surface wipe samples were taken on smooth floorings including hardwood, linoleum, and tile from a 10 x 10 cenfimeter ("cm") area. Surface vacuum samples were collected from wall-to-wall carpets and area rugs. Vacuum samples were collected using a high-efficiency particulate air ("HEPA") vacuum over a 1-square-meter area. Each sample was collected in a pre-weighed dedicated vacuum collection bag. The vacuum sample was collected by running the vacuum over the area horizontally, vertically and then horizontally once more. Once the sample was collected, the dedicated collection bag Was removed from the vacuum. The sample was then placed in a dedicated plastic bag, labeled and sealed. The vacuum parts that were in direct contact with dust during the sampling were decontaminated between sampling locations.

Interior lead concentrations ranged from 0.1 to 680,979 |ig/ft^ with a mean concentration of 2,193 |ag/ft̂ . Approximately 64% of all interior samples collected in homes within the original removal target area exceeded the EPA lead hazard level of 40 fig/ft̂ ; and approximately 79% of interior samples exceeded the lead hazard level for floors in homes sampled in the Interim RI area. It appears that some interior residential samples may have been impacted by the presence of interior lead-based paint based on some of the extremely high concentrations detected. However, again, since these homes are located within the area predicted to have a high probability of having lead soil concentrations above 572 ppm resulting from both deposition and migration, EPA believes the interior of these properties have also been impacted from tracking in lead contamination from the exterior soils. More detailed information regarding the interior lead concentrations found at individual properties may be foimd in the Final Interim Remedial Invesfigafion Report for OU-1. v

5. Surface Water and Sediment Sampling

Surface water and sediment have not been investigated to date as part of the OU-1 Interim RI, because these media are beyond the scope of the current Interim RI, the focus of which is residential soils and indoor dust. EPA will evaluate surface water and sediment in the future, as appropriate, pending the results of the OU-2 remedial investigation being conducted by Exide at the former Price Battery facility property.

6. Groundwater Sampling

Contamination found at the Price Battery Site OU-1 has been surficial and there has been fittle investigation of groundwater beyond surficial perched water within the confines of the facility (OU-2) property itself. Limited groundwater sampling has been performed within the OU-1 area and the immediate vicinity, and no groundwater contamination has been found to date. No , investigation of the hydrology or distribution of the hydrostratigraphic units of interest within

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OU-1 has been conducted, because the fociis of OU-1 has been lead deposifion from the former Price Battery facility to residential areas. Groundwater investigations are being conducted on the facility property as part of the OU-2 investigation. If these investigations reveal that groundwater has been impacted at the facility property and contaminafion may extend beyond the facility boundary, EPA will assess groundwater under a subsequent operable unit.

7. Biota

No investigafions have been performed to date in regards to biota associated with the OU-1 properties. Ecological risks have not been evaluated at this time. The primary purpose of this Interim ROD for OU-1 is to address human health risks associated with exposure to residenfial soils and interior dust contaminated with lead as quickly as possible. Ecological risks will be further evaluated in the Final ROD for OU-1 or in a ROD for a subsequent OU for the Price Battery Site.

C. Conceptual Site Models

A Conceptual Site Model was developed to identify which human exposure pathways were complete or could be potentially complete in the fiature. Residents within the boundaries of the Site could be exposed to contaminants via several pathways as illustrated in Figure 5. Exposure to antimony, arsenic, and lead in soil and indoor dust could occur via incidental ingestion, dermal contact, and inhalation. Incidental ingestion and inhalation of fiigitive dust are addressed for lead, arsenic, and antimony. Dermal contact is not evaluated for lead, therefore, dermal absorption of lead was not considered. Dermal contact is unlikely to be significant for anfimony and arsenic, but they are nevertheless addressed in a risk analysis.

Additional exposure pathways are assumed to be incomplete or insignificant for the risk analysis. Exposure to site-related contamination could occur through ingesfion of produce grown in contaminated soil, and, in theory, through ingestion of groundwater contaminated via leaching of site-related contaminants from soil. Comparafively, exposure to site-related contamination via ingestion of homegrown produce is likely low relafive to soil concentrations.

Consumption of groundwater at the Site is theoretically possible, but it is unlikely to occur because residents in Hamburg are connected to municipal water. More over, surface contamination resulfing from aerial deposition is unlikely to present a significant threat to groundwater. No investigation of the hydrology or distribution of the hydrostratigraphic units of interest within OU-1 has been condiicted, because the focus of OU-1 has been lead deposition from the former Price Battery facility to residenfial areas. Groundwater investigafions are being conducted on the facility property as part of the,OU-2 invesfigafion. If these investigafions reveal that groundwater has been impacted at the facility property and contamination may extend beyond the facility boundary, EPA will assess groundwater under a subsequent operable unit.

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VI. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES

The Price Battery OU-1 Site is located in the central to southern portion of the Borough. The Site is located in a mixed commercial/industrial/residential area approximately three-quarter square miles in size in the vicinity of the former Price Battery facility. The commercial/industrial land makes up the minority of the target area. The Price Battery facility is zoned industrial; and the residential properties that make up the OU-1 target area are located north, northwest, northeast, east, southeast, and south of the facility. Based on the 2000 U.S. Census data (U.S. Census Bureau 2000), the total population of Berks County is 336,523 people and consists of 141,570 households. The total population of the Borough of Hamburg is 4,114 people and consists of 1,824 households. ,

The land use in the immediate area outside of the OU-1 target area is mostly residential or agricultural. Commercial properties make up the minority of the adjacent property area.

The continued residential use of property can reasonably be assumed for the majority of properties that comprise the site through local zoning control. It is also reasonable to assume that, at some point in the future, interest may arise in converting some of the residential properties to non-residential use. Future non-residential use of remediated properties will remain protective of human health since the Remedial Action will provide for unrestricted future use.

V ' ' • •

Also located within the general area of the affected properties are numerous non-residential

properties. Non-residential properties (i.e., commercial properties) will not be addressed by the action in this Interim ROD.

VIL SUMMARY OF SITE RISKS

A. Human Health Risk Assessment Summary

The initial Human Health Risk Assessment ("HHRA") was completed for the Price Battery Site in October 2005 in an effort to determine the risks and establish a site-specific soil cleanup level for lead in soils to support the removal action. At the time the HHRA was completed, the Price Battery site boundaries, in general, included approximately 25 city blocks in the Borough of Hamburg (i.e., the Original Removal Assessment Area depicted in Figure 2). This original area was primarily located southeast of the Price Battery facility in the expected downwind direction and was approximately defined as the area bordered to the north by Pine Street, to the east by the Hamburg Borough boimdary line with Windsor Township, to the South by Maple Street, and to the west by Second Street. Although the Site boundaries have significantly increased during the remedial investigation activities, EPA believes the conclusions of the HHRA are more or less similar for the expanded area.

Data available for analysis in the HHRA included: 1) residential soil samples analyzed for antimony, arsenic, and lead; 2) residenfial indoor dust samples analyzed for lead; 3) residential tap water samples and municipal water supply samples analyzed for lead; and 4) matched data

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sets from blood lead, soil lead, and indoor dust lead concentrafions. At that fime, blood samples from 62 residents, including adults and children older than 84 months, had been analyzed and were available for the risk assessment. These blood lead concentration data, after eliminating results for adults and children older than 84 months, were used for comparison with blood lead predictions from the Integrated Exposure Uptake Biokinetic ("lEUBK") model. ResuUs from a total of 23 children and 20 homes were available for comparison.

In general, EPA recommends a target cancer risk range or a target non cancer hazard index ("HI") value (i.e., a cancer risk in the range of 1 x 10'* to 1 x 10"̂ or non cancer HI of 1) as threshold values for potential human health impacts. In addition, protection of young children for health effects of lead exposure is considered achieved if the odds of a typical or hypothetical child (or group of similarly exposed children) with blood lead levels of 10 micrograms of lead per deciliter of blood ("|ag/dl") or greater is no more than 5 percent. The results of these risk calculations are compared to these target values to aid in determining whether additional cleanup actions are necessary at a site.

More information regarding risk and the toxicolpgical profiles for lead, arsenic, and antimony • may be obtained at ATSDR's ToxFAQ's website at www.atsdr.cdc.gov/toxfaq.html.

1. Cancer Risks • \

Cancer exposure for the Price Battery Site is associated with residential exposure to arsenic in soil and indoor dust. Risks are estimated for residents that spend the first 30 years of their lives within the target area, including exposures as both a child and as an adult. Total cancer risks for residents at the Price Battery Site range from 3x10"* to 3x10^, with the highest values exceeding the upper limit of the EPA risk range of 1x10'* to 1x10^. The highest potential cancer risks are associated with properties along the western edge of the target area, primarily west of Third Street near the former Price Battery facility. Most of the estimated cancer risks from exposure to arsenic are below 1x10^. Only three of the 336 residences sampled in the original area had an estimated cancer risk that exceeded 1x10^. The average estimated arsenic concentration in soil at those residences ranged from 111 ppm to 230 ppm. These residences have already been remediated. For most of the area, arsenic risks fall in the range between 1x10"* and 1x10'^, the lower half of the EPA risk range, including essentially all of the target area east of Third Street. At low risk levels, naturally occurring (background) arsenic begins to dominate risk estimates. A reasonable estimate for background arsenic concentration is 10 ppm; at which, cancer risk is estimated to be about 4 x 10"*. This level of risk is characteristic of much of the Site, including the area east of Fifth Street, as well as many jof the houses south of Windsor Street, between Fourth and Fifth Streets. In this area, arsenic related risks appear to be no greater than elsewhere in Pennsylvania.

I •

2. Non Cancer Hazard Indices

Non cancer His for the Price Battery Site are associated with residential exposure to antimony

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and arsenic in soil and indoor dust. Total His for young children at the Price Battery Site range from 0.09 to 40. In a similar pattern to cancer risks, the highest potenfial His are associated with properties along the western edge of the target area, primarily west of Third Street. Forty-four of the 336 residences, or about 13 percent, have an esfimated HI that exceeds 1.0, indicating the potential for non cancer health effects to occitf. At many of these locations, the HI exceeds 1.0 due to the estimated level of antimony in soil. Antimony and arsenic concentrations were measured at 12 of the 44 houses with an HI above 1.0. Concentrafions at the remaining houses with an HI above I were esfimated from lead concentrations in soil, using a regression analysis.

3. Blood Lead Levels

EPA's risk assessment for lead is unique. Lead does not lend itself to traditional risk assessment methods since there are not scientifically agreed upon toxicity values for lead. Due to the inability to use traditional risk assessment methods, lead is regulated based on blood lead ("PbB") concentration. EPA and the Centers for Disease Control and Prevention ("CDC") have determined that childhood PbB concentrations at or above 10 |ig/dl present risks to children's health. Generally, EPA will attempt to limit exposure to soil lead levels such that a typical (or hypothetical) child or group of similarly exposed children would have an estimated risk of no more than 5 percent exceeding the 10 |ag/dl PbB level after cleanup.

PbB concentration can be correlated with both exposure and adverse health effects. Existing evidence indicates that adverse health effects occur even at very low exposures to lead (e.g., subtle neurological effects in children have been observed at low doses). To predict PbB concentration and the probability of a child's PbB concentration exceeding 10 ug/dl based on a given exposure scenario from muUiple sources, a model can be applied which considers lead exposure and toxicokinetics (the absorption, distribution, metabolism, and excretion of lead in the body) in a child to calculate an exposure level that satisfies the risk reduction goal. The lEUBK Model for Lead in Children is used to predict the risk of elevated PbB levels in children (under the age of seven) that are exposed to environmental lead from many sources and. to establish cleanup levels for lead. An overview of the lEUBK model for lead in children may be found at http://epa.gov/superfund/lead/products/factsht5 .pdf

Residential PbB levels were calculated using site-specific and default exposure assiunptions as inputs to the lEUBK model. For this assessment, estimates for PbB concentrations were calculated on a house-by-house basis using house-by-house average soil and dust lead levels, as well as site-specific or default inputs for lead exposure concentrafions for air, water, and diet. The lEUBK model was run for four age groups: 18 months, 36 months, 72 months, and random ages between 6 and 84 months to illustrate the impact of different age assumptions on the lEUBK model output. -

In general, the model predicted that the area east of Fourth Street between Windsor and Maple Streets was found to meet the acceptable criteria. However, even in this area which is farthest

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from the former smelter, the model predicts that some properties have soil and dust levels that might cause blood lead levels to exceed acceptable levels.

In portions of the original removal target area (see Figure 2) where cancer risks and non-cancer hazards from arsenic and antimony are present, the model also predicted that lead exposures are extremely high. This area essentially covers all of the target area north of Windsor Street. This relatively large area where lead exposures exceed acceptable levels suggests that any remediation or mitigation based on addressing lead contamination in soil and dust should also address unacceptable concentrations of arsenic and antimony in soil.

The model predicted relatively low PbB levels in the original target area to the south and east which suggested that the original target area might encompass all of the area contaminated with lead requiring cleanup. Since predicted PbB concentrations at the farthest northern extent of the Site are still very high, elevated PbB concentrations could conceivably be found outside of the original target area for this risk assessment. Therefore, the risk assessment concluded that it is conceivable that the northern boundary of the original target area could expand.

B. Summary of Ecological Risk Assessment

Ecological risks have not been evaluated at this time. The primary purpose of the Interim ROD for OU-1 is to address human health risks associated with exposure to residential soils and interior dust contaminated with lead as quickly as possible. Ecological risks will be further evaluated in the Final ROD for OU-1 or in a ROD for a subsequent OU for the Price Battery Site.

VIII. REMEDIAL ACTION OBJECTIVES

Remedial action objectives are medium specific goals developed to protect human health and the environment. The remedial action objectives specify Site-related contaminants of concern, exposure routes, and acceptable contaminant levels for each exposure route. Protectiveness may be achieved by reducing exposiu'e as well as by reducing actual contaminant levels.

The following Remedial Action Objectives have been developed for the Price Battery Site:

Soil

1) Prevent ingestion, inhalation, or direct contact with surface soil or subsurface soil that contains concentrations of lead in excess of preliminary remediation goals ("PRGs"); and

2) Permanently and/or significantly reduce the toxicity, mobility or volume of characteristic hazardous waste.

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Interior House Dust

1) Prevent ingestion, inhalation, or direct contact with interior house dust that contains concentrations above the EPA lead hazard levels for floors.

Determination of Preliminary Soil Clean Up Goals ("PRGs")

EPA generally selects a residential soil cleanup level for lead which is within the range of 400 ppm to 1200 ppm. The lEUBK modeling results for the Price Battery Site recommend a soil lead concentration of 572 ppm (or 600 ppm average) to ensure that a child has less than a 5 percent probability of having a blood lead level exceeding 10 |ag/dl. In addition, EPA has established a site-specific action level of 15 ppm for arsenic and 31 ppm for anfimony. The correlafion between lead and arsenic or lead and antimony is sufficiently strong that any remediation which addresses lead contamination in soil and dust should also address unacceptable concentrations of arsenic and antimony in soil. Therefore, EPA will only use the lead in soil action level of 572 ppm (or 600 ppm average) as its basis for determining if the cleanup goals have been achieved.

EPA believes that the combination of site response actions recommended in the alternatives in this document will be protective of human health. Additionally, at the completion of the comprehensive remedial action for the Site, the EPA will sponsor a site-wide exposure study to determine if a child or a group of similarly exposed children within the Site boundaries still has a greater than 5 percent probability of exceeding a blood-lead level of 10 |ag/dl, and, if so, EPA will make a determination whether additional actions are required.

EPA is aware that lead in the environment at the Price Battery Site may originate from many sources. In addition to the identified soil exposure pathway, other important sources of lead exposure are interior and exterior lead-based paint, lead-contaminated interior dust from lead-based paint, and to a lesser extent, tap water. Generally, interior and exterior lead-based paint, interior dust contaminated solely from lead-based paint, and tap water cannot be remediated by the EPA in the course of residential lead cleanups. CERCLA and the National Contingency Plan ("NCP") limit Superfund authority to address interior lead-based paint. For example, CERCLA Section 104(a)(3)(B) limits EPA's ability to respond to releases within residenfial structures as follows-Section 104(a)(3): , /

"Limitations on Response. The President (EPA) shall not provide for removal or remedial action under this section in response to a release or threat of release...from products which are part of the structure of, and result in exposure within, residential buildings or business or community structures..."

The above-cited section of CERCLA generally limits EPA's authority to respond to lead-based paint inside a structure or house. However, EPA has authority to conduct response actions addressing soils contaminated by a release of lead-contaminated paint chips from the exterior of homes to prevent recontamination of soils that have been remediated, and EPA has the authority

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to respond to airborne lead from the former Price Battery smelter and/or lead-contaminated soils that enter a structure or house and cause lead contamination. -

The EPA Office of Solid Waste and Emergency ResJDonse ("OSWER") policy recommends against using money from the Superfund Trust Fund to address interior lead-based paint exposures, and recommends that actions to address or abate interior lead-based paint risks be addressed by others such as the U.S. Department of Housing and Urban Development ("HUD"), local governments, health authorities, potenfially responsible parties ("PRPs"), private organizations, or individual homeowners. OSWER policy also recommends against using Superfund Trust money to remove interior dust solely contaminated from lead-based paint or to replace lead plumbing within residential dwellings, and recommends that the EPA Regions seek partners to address these other lead exposure risks.

EPA acknowledges the importance of addressing these other exposures in realizing an overall solution to the lead problems at residential Superfund Sites. EPA is prepared to partner with other organizations such as the Agency for Toxic Substances and Disease Registry C'ATSDR"), HUD, state environmental departments, state and local health departments, private organizations, PRPs, and individual residents and to participate in a comprehensive lead risk reduction strategy that addresses lead risks comprehensively. EPA can provide assessments of these other lead hazards to homeowners as part of our investigation activities and can provide funds to support health educafion efforts to reduce the risk of lead exposure in general. It should be understood that OSWER policy directs that EPA should not increase the risk based soil cleanup levels as a result of the action taken to address these other sources of exposure.

IX. SUMMARY OF REMEDIAL ACTION ALTERNATIVES

CERCLA requires that any remedy selected to address contamination at a hazardous waste site must be protective of public health and welfare and the environment, cost-effective, in compliance with regulatory and statutory provisions that are applicable or relevant and appropriate requirements ("ARARs"), and consistent with the NCP to the extent practicable.

MajorARARS

EPA has identified the following substantive federal and state requirements as being ARARs or otherwise being worthy of consideration during the evaluation of the remedial alternatives in this Interim ROD. .

The disposal of excavated soil from site remediation activifies will be determined by whether or not it passes the Toxicity Characteristic Leaching Procedure ("TCLP") for lead and arsenic. If excavated soils pass the TCLP, then the soil may be disposed of in a permitted nonhazardous Resource Conservation and Recovery Act ("RCRA") waste storage, treatment, or disposal facility. If excavated soils do not pass the TCLP, they will be disposed of at a RCRA Subtitle C hazardous waste landfill.

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The Commonwealth of Pennsylvania has promulgated standards for lead, antimony, and arsenic for soil cleanup under Permsylvania Act 2, Title 25 PA Code 250 Appendix A Table 4; however, at the Price Battery Superfund Site, a site-specific cleanup standard was determined through the EPA baseline risk assessment, which is consistent with State law and regulations. ^

In addition to ARARs, EPA may implement other federal or state policies, guidelines, or proposed rules capable of reducing the risks posed by a site. Such To-Be-Considered ("TBC") standards, while not legally binding (since they have not been promulgated), may be used in conjunction with ARARs as part of the risk assessment conducted for each CERCLA site to set protective cleanup levels and goals. EPA has considered the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing ("HUD Guidelines") as a TBC for the Price Battery Site. The HUD Guidelines address lead hazards posed by paint, dust, and soil in the residential envirorunent. The HUD Guidelines were issued pursuant to Section 1017 of the Residential Lead-Based Paint Hazard Reduction Act of 1992, which established standards for lead hazard evaluations, residential dust lead cleanup levels, dust and soil sampling requirements, and dust clearance standards for lead-based paint abatement projects. Although not directly comparable to the Price Battery Site cleanup, certain portions of the HUD Guidelines have been considered with respect to establishing the criteria to be used in evaluation and cleanup and clearance sampling conducted as part of a remedial action. For instance, the 40 |ag/ft̂ clearance standard for floors will be used by EPA to determine if interior residential cleanups have been effective. (Note the HUD Guidelines specify a 100 ^g/ft^ clearance standard for floors which has been superseded by the 40 ^g/ft^ clearance standard).

Additional ARARs concerning minimization of any effects of remediation on historic properties, or landmarks; consideration of flood plain hazards and flood plain management; avoiding adverse impact to wetlands; remedial action worker safety; clean backfill requirements; and best practices to prevent fugitive dust emissions during any remedial activity, were all identified during the evaluation of remedial alternatives. A more detailed description of all the ARARs can be found in Tables 1 to 3.

Estimate of Properties Requiring Remediation

Certain assumptions were made by EPA with respect to the number of remaining properties, not already addressed by the ongoing removal action that will eventually grant access for remediation of the yards and interiors. For purposes of discussion, these properties can be divided into classes based on their current participation in the ongoing removal action. The classes can be defined as:

Exterior

• Class El - Remaining properties (>572 ppm lead) that provided exterior cleanup access (69 properties)

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Class E2 - Remaining properties (>572 ppm lead) that have denied/not responded to cleanup access (74 properties) Class E3 - Properties (>572 ppm lead) that were excavated in 2003/2004 and may require further cleanup (89 properties) Class E4 - Properties that never provided exterior sampling access to have exterior soils assessed for lead contamination (157 properties)

Interior

) Class 11 - Remaining properties (>40 ^g/ft^ lead) that provided interior cleanup access (40 properties) Class 12 - Remaining properties (>40 |ag/ft̂ lead) that have denied/not responded to cleanup access (77 properties) Class 13 - Properties with unknown interioi;,lead concentrations because exterior sampling access was never granted to determine eligibility requirements (274

properties)

Experience during the removal action has shown that not all residents will participate in the sampling and cleanup of their properties. Iii addition. While some residents may not participate at all, other residents will participate to varying degrees with respect to exterior and interior sampling access and exterior and interior cleanup. The following tables illustrate the number of properties requiring cleanup under various scenarios:

EXTERIORS (As of 3/16/09) Exterior Class Combination

Class El Only If 100% of Class El, E2, E3, and E4 If Class El and 75% of Class E2, E3, &!E4 If Class El and 50% of Class E2, E3, & E4 If Class El and 25% of Class E2, E3, & E4

Remaining Potential Exterior Properties to Clean

69 389 309 229 149

INTERIORS Interior Class Combination

Class 11 Only If 100% of Class 11,12, and 13 If Class 11 and 75% of Class 12, & 13 If Class 11 and 50% of Class 12, & 13 If Class 11 and 25% of Class 12, & 13 i

(As of 3/16/09) Remaining Potential Interior Properties to Clean

40 391 303 216 128

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The Class El and II properties have definifively provided access to have a cleanup conducted and therefore are known quantities. However, the extent of participation for the other classes of properties at this time is unknown. Past experience during the removal action indicates that residents who have denied participation or did not respond to EPA mailings infrequently reconsider participation unless the property is sold and a new owner decides to participate. Therefore, for the purposes of this interim remedy, EPA has conservatively assumed that 25 percent of these remaining residents may reconsider their participation. Under this assumption the total remaining potential properties requiring exterior and interior cleanup are 149 and 128 residences, respectively. The remedial alternatives developed for the Interim Feasibility Study used this basis for estimating costs.

Remedial Alternatives

During development of the Interim Feasibility Study, EPA developed four remedial action alternatives for the soil cleanup and three alternatives for the interior dust cleanup. The following is a summary of the alternatives that were evaluated for in the Interim Feasibility Study:

Exterior Remediation

Soil Alternatives

Alternative S1 - No Action

The NCP requires that EPA include a "No Action" Alternative in its remedy selection decision making process. Under the No Action Alternative, no cleanup measures will be put in place. The purpose of the No Action Alternative is to provide a baseline to compare the other clean up alternatives. The No Action Alternative will not meet any of the cleanup objectives described earlier in this Interim ROD. Furthermore, the No Action Alternative will not provide the controls necessary to protect people and the environment from the Site-related lead, arsenic, and antimony soil contamination. There are no costs to implement, operate, and maintain this Alternative. However, because existing contaminated soils will remain in place, EPA will conduct five-year reviews as required by Section 121 (c) of CERCLA.

Alternative S2 - Institufional Controls

Under this Alternative, institutional controls ("ICs") at the Site will be employed to protect human health. The ICs will be used in limiting access to and future development, improvement, and use of affected properties. Specifically, ICs willinclude activity and use restrictions enacted through proprietary (e.g., easements, covenants) and^or governmental (e.g. zoning requirements) controls to prevent use of the property that will pose an unacceptable risk to receptors (i.e., for residenfial use). Informational device ICs (warning signs, advisories, additional public education) also will be employed to limit access to the contaminated soils. However, because

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existing contaminated soils will remain in place, EPA will conduct five-year reviews as required by Section 121(c) of CERCLA

Alternative S3 - Excavafion of Soils to 1 -Foot Depth with Consolidation for TranspOrtafion to and Disposal in RCRA Subtitle C or D Landfill or Approved RCRA Recycling Facility

Soil Excavation

Under this Alternative, contaminated soils will be excavated to a depth of 1 foot and transported from each residence/parcel to a central area for consolidation and staging, then shipped off-site to an appropriate RCRA landfill or other permitted disposal facility. If soils remaining below 1 foot are still above the soil PRG of 572 ppm (or 600 ppm average), high visibility horizontal fencing will be placed prior to backfilling to indicate the presence of soils remaining with elevated lead levels. Approximately 5,400 cubic yards of contaminated soils will require excavation and disposal from approximately 149 properties. The number of properties estimated requiring remedial action may increase as sampling of affected properties continues at the Site and/or homeowners reconsider participation in the cleanup.

Restoration

After removal of all contaminated soils to a 1 foot depth and placement of high visibility horizontal fencing, the excavations will be backfilled with clean soils that comply with Pennsylvania Clean Fill requirements and new sod will be added as vegetation. ICs such as deed restrictions, municipal ordinances, and information devices will be used, if necessary, to fiarther reduce the potential for exposure. Five-year reviews as required by Secfion 121 (c) of CERCLA will be conducted for those properties where contaminated soil may have been left in place.

Air Monitoring

Air monitoring will be conducted during excavation activities. Water will be used to minimize fugitive dust emissions during soil excavation, transport, and handling. All stockpiles of material awaiting disposal will be covered with tarps or plastic sheeting to minimize fugitive dust emissions and control precipitation run on/run off

Alternative S4 - Excavation to Clean Soil Depth and Consolidation for Transportation to and Disposal in RCRA Subtitle C or D Landfill or Approved RCRA Recycling Facility

Soil Excavation

Altemafive S4 is similar to Alternative S3 in that contaminated soils will be excavated and transported from each residence/parcel to a central area for consolidation and staging, then shipped off-site to an appropriate RCRA landfill or other permitted disposal facility. Alternative S4 differs from Alternative S3 in that the depth of the excavation will continue beyond one foot

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until "clean" soil is reached. "Clean" is defined as having lead concentrafions below the PRG of 572 ppm (or 600 ppm average). Historically, the average depth of excavation to get to clean soil has been from 6 inches to 18 inches. For the purposes of estimafing the cost of this alternative, however, an average excavation depth of 12 inches was assumed for all affected properties. Using this assumption, approximately 5,400 cubic yards of contaminated soils will require excavafion and disposal from approximately 149 properties. The number of properties estimated requiring remedial action may increase as sampling of affected properties continues at the Site and/or homeowners reconsider participation in the cleanup.

Soil Sampling

Prior to excavation, the depth of excavation will be pre-delineated by composite sampling of soils at six, twelve, and, if necessary, eighteen inch depth intervals using a XRF analyzer. Excavation will progress in six inch increments until the targeted depth is achieved at which time confirmation sampling will be conducted. Confirmation saniples will also be analyzed through XRF analyses (in-situ or ex-situ) and ten percent of the samples will be shipped to a fixed laboratory for analysis.

However, under this alternative it may not be possible to excavate soils in all areas to "clean" because of obstructions (i.e., tree and shrub roots, old outhouse foundations, old buried septic or cesspools) or excavations abutting house foimdatipns. In such cases, where attainment of the lead in soil action level cannot be achieved in all areas of the yard, attainment of the cleanup level will be deemed to have been achieved if the arithmetic average of the post-excavafion sampling and clean backfill soils results in a yard-average lead concentration of 600 ppm or below. As an additional precaution, high visibility horizontal fencing will be placed in these specific sections of the yard to serve as a visual indicator for the resident that lead contaminated soils may be present. Despite best efforts, if the 60b ppm lead in soil yard-wide average cannot be met, those areas of the yard which are causing the yard to exceed the 600 ppm lead in soil average will be covered with high visibility horizontal fencing and ICs will be implemented to prevent future exposure. Five-year reviews as required by Section 121(c) of CERCLA will be conducted for those properties where contaminated soil may have been left in place.

Restoration

After removal of all contaminated soils (placement of high visibility horizontal fencing where needed), the excavations will be backfilled with clean soils that comply with Pennsylvania Clean Fill requirements and nevv sod will be added as vegetation.

Air Monitoring

Air monitoring will be conducted during excavation activities. Water will be used to minimize fugitive dust emissions during soil excavation, transport, and handling. All stockpiles of material

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awaiting disposal will be covered with tarps or plastic sheeting to minimize fugitive dust emissions and control precipitation run on/run off

Interior Remediation

Dust Alternatives

Alternative Dl - No Action

The NCP requires that EPA include a "No Action" Alternative in its remedy selection decision making process. Under the No Action Alternative, no cleanup measures will be put in place. The purpose of the No Action Alternative is to provide a baseline to compare to the other clean up alternatives., The No Action alternative will not meet any of the cleanup objectives described earlier in this Interim ROD. Furthermore, the No Action Alternative will not provide the controls necessary to protect people and the environment from the Site-related lead dust contamination. There are no costs to implement, operate, and maintain this Alternative. However, because existing interior dust contamination will remain in place, EPA will conduct five-year reviews as required by Section 121(c) of CERCLA.

Altemafive D2 - Institutional Controls

For this Alternative, ICs at the Site will be employed to protect human health. The ICs are used in limiting access to contaminated house dust on interior surfaces. Specifically, ICs will include public education in the form of community meetings, pamphlets, brochures, etc. informing property owners and renters of the hazards associated with interior house dust contamination and effective methods for cleaning. However, because existing interior dust contamination will remain in place, EPA will conduct five-year reviews as required by Section 121(c) of CERCLA.

Altemafive D3 - Specialized Cleaning

Under Altemafive D3, homes located on properties undergoing soil remediation will undergo specialized cleaning to address lead contamination associated with interior house dust. Residents will be temporarily relocated prior to cleaning the house. Approximately 128 properties, not already addressed by the removal action, may be eligible for interior house dust remediation. The number of properties esfimated to be eligible for an interior cleanup may increase as sampling of affected properties continues at the Site and/or homeowners reconsider participation in the cleanup. This Alternative will include the following steps:

• Packing: Residents will be required to pack their personal belongings prior to the specialized cleaning being conducted. Packing materials will be provided by EPA. Residents will also be required to place EPA custody seals on all the boxes. All boxes will remain in the house, unless unique situations warrant removal of the boxes from the home to facilitate the specialized cleaning. -

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• Relocation: Residents will be temporarily relocated for approximately one week while the specialized cleaning is conducted. Residents will also be provided per diem for the length of the temporary relocafion. Individual residents' needs will be taken into account for every temporary relocation. EPA will also reimburse residents for boarding pets if necessary. Residents will only be temporarily relocated for inferior remediation. Residents will not be relocated for remediafion of the exterior soils solely unless Unique circumstances with the residence warrant relocation for the exterior cleanup.

• Security: EPA will provide security during non-work hours for protection of the house and its belongings.

• Isolation of Clean Rooms: Poly-sheeting will be used to isolate "clean" rooms or rooms that underwent cleanup from contaminated rooms to rninimize the chance that contamination is spread to clean rooms.

• Carpet and Padding Removal: Carpet dust samples will be collected by HEPA vacuuming and the dust collected in the vacuum bag analyzed for lead. Carpet samples with dust lead levels above 40 |ag/ft̂ will be removed. Contaminated carpet will be removed immediately after sealing off clean rooms with poly-sheeting by cutting carpet into pieces small enough to fit into drum liners. Bagging and sealing will be completed in the contaminated room to minimize the chance of spreading contamination. Residents will be reimbursed for the replacement value of the carpet and pad removed based upon an appraisal of the quality and grade of the carpet and pad. The resident is responsible for the purchase and installafion of new carpets.

• Insulation: In order, to effectively implement the specialized cleaning, in certain instances, exposed insulation may also be removed. Insulation traps large amounts of dust. Residents will be reimbursed for the replacement value of the insulation based on the square footage and R-value of the insulation rerhoved. The resident is responsible for the purchase and installafion of the new insulation.

• Disposal of Carpet/Padding and Insulation: Any carpet and padding or insulation removed will be disposed of by EPA in a permitted off-site RCRA Subtitle D disposal facility based on TCLP testing, as necessary.

• HEPA Vacuuming: Hard surfaces (i.e., ceilings, walls, and floors), including flooring previously covered by carpeting, will be HEPA vacuumed.

• Specialized Cleaning

• For rooms with floors with lead dust concentrations above 40 |ig/ft^, ceilings, walls, and floor surfaces (i.e., wood floors, linoleum, concrete floors, etc.) will be cleaned with

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AR100912

trisodium phosphate ("TSP"). If the floor is unfinished wood or concrete, an encapsulant (such as LeadLock '̂* ,̂ or equivalent) will be applied after cleaning followed by two coats of a clear coat compound to protect the encapsulant from foot traffic.

For rooms with floors with lead dust concentrations below 40 |ig/ft^, ceilings, walls, and floor surfaces will be cleaned with a common household cleaning agent. TSP will not be used. For rooms with carpeted flbc carpeted floors will be shampooed. used. For rooms with carpeted floors with lead dust concentrations below 40 fag/ft , the

• HEPA Vacuuming: A second HEPA vacuuming of floor surfaces will be conducted after the specialized cleaning.

• Confirmation Sampling: Confirmatory lead dust wipe sampling will be conducted to ensure lead dust concentrations are below 40 |ig/ft . Samples will be collected from representative hard floor surfaces to confirm the effectiveness of the specialized cleaning.

If warranted, the steps in the cleaning process may be modified to improve the efficiency of the overall process based on the outcome of tesfing conducted during the cleanup or if unique conditions exist in the house which require the cleaning process,to be modified.

X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

Criteria Used To Compare Cleanup Alternatives

The remedial altematives summarized in this Interini Record of Decision have been evaluated against the nine decision criteria set forth in the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP") (see 40 C.F.R. §300.430(e)(9)). These nine criteria are organized into three categories which include: threshold criteria, primary balancing criteria, and modifying criteria. Threshold criteria must be satisfied in order for an alternative to be eligible for selection. Primary balancing criteria are used to weigh major trade-offs between altematives. Modifying criteria are formally taken into account after public comment has been received. The criteria are set forth below:

Threshold Criteria

1. Overall Protectiveness of Human Health and the Environment addresses whether a remedy provides adequate protection of human health and the environment from unacceptable risks posed by hazardous substances or pollutants or contaminants and describes how risks are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

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AR100913

2. Compliance with Applicable or Relevant and Appropriate Requirements ("ARARs") addresses whether a remedy will meet all of the applicable, or relevant and appropriate requirements of Federal and State environmental statutes and regulations and/or whether there are grounds for invoking a waiver.

Primary Balancing Criteria:

3. Long-Term Effectiveness refers to the ability of a remedy to maintain reliable protection of human health and the environment over time once cleanup goals are achieved.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment addresses the degree to which treatment will be used to reduce the toxicity, mobility, or volume of the contaminants causing site risks.

5. Short-Term Effectiveness addresses the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the constmction and implementation period until cleanup goals are achieved. '

6. Implementability addresses the technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement a particular option.

7. Cost includes estimated capital and operation and maintenance costs. Costs are evaluated on a present worth basis.

Modifying Criteria;

8. State Acceptance indicates whether the State concurs with, opposes, or has no comment on the remedy. , ,

9. Community Acceptance considers whether the community agrees with the remedy.

The above criteria are used to evaluate the advantages and disadvantages of each alternative in order to select an appropriate remedy. The following is a brief summary evaluating and comparing each alternative against the nine criteria.

1. Overall Protection of Human Health and the Environment

Soil Altemafives:

Altemative SI, the No Action Altemafive, does not provide adequate protection of human health and the environment. The No Action Altemafive was developed as a baseline for comparison against the other altematives. The No Action Altemative does not eliminate or control the

29

AR100914

current and future risks to residents from exposure to contaminated soils. The No Action Altemative will not be discussed further in the nine criteria analysis, because it does not satisfy the threshold criterion of providing overall protection to human health and the environment. Altemative S2, Institufional Controls, provides a minimal degree of protection of human health and the environment by monitoring to identify areas of concern and instituting controls to attempt to prevent exposure.

Soil Altematives S3 and S4 both address to varying degrees the concem of reducing residenfial exposure to soil above the risk-based cleanup level and of reducing residential soil lead concentrafions as a source for contaminated house dust. Altemative S3 will remove the direct contact threat from contaminated soils but potentially leave in-place contaminated soils below one foot. ICs may still be required at a significant number of properties to prevent exposure to potential contamination below one foot. Altemative S4 will completely remove the -̂ contaminated soils to the extent practicable. ICs may sfill be required under Altemative S4 if the 600 ppm lead in soil yard-wide average cannot be met; however, the likelihood that this will occur is very small. In either case, post reniediation sampling and observation will determine if remedial goals have been met. The long-term risks associated with residual contaminant concentrations are addressed by Altematives S3 and S4. Altemative S4, however, will provide a higher degree of long-term protection since all of the contaminated soils, to the extent pracficable, will be removed. The short-term exposure risks of both Altematives S3 and S4 will substantially be the same during the excavation of contaminated soils. Altematives S3 and S4 will both require approximately one week to complete per residence.

Dust Altematives:

Altemafive Dl, the No Acfion Altemative, does not provide adequate protection of human health and the environment. The No Acfion Altemative was developed as a baseline for comparison against the other altematives. The No Action Altemative does not eliminate or control the current and future risks to residents from contaminated interior dust. The No Acfion Altemafive will not be discussed fiirther in the nine criteria analysis, because it does not satisfy the threshold criterion of providing overall protection to human health and the environment. Altemative D2, Institutional Controls, provides a minimal degree of protection of human health and the environment by monitoring to identify residences of concem and education to attempt to prevent exposure.

Altemative D3 eliminates exposure pathways and reduces the level of risk by remediating the indoor dust. Permanence of the solution will result from removing the dust only after or concurrent with,the remediation of the exterior soils of the residence. The short-term exposure risk will be negligible if the remediation workers are properly trained and use the correct cleaning equipment and procedures. Altemative D3 is expected to require approximately one week per residence to complete.

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2. Compliance with ARARs

Any cleanup altemative selected by EPA must comply with all applicable or relevant and appropriate federal and state environmental requirements or provide the basis iipon which such requirement(s) can be waived. Applicable requirements are those environmental standards, requirements, criteria, or limitations promulgated under federal or state law that are legally applicable to the Remedial Action to be implemented at the Site. Relevant and appropriate requirements, while not being directly applicable^ address problems or situations sufficiently similar to those encountered at the Site that their use is well-suited to the particular circumstance.

EPA will also consult to-be-considered material ("TBCs"). TBCs are non-promulgated advisories or guidance issued by Federal or State governments that are not legally binding and do not have the status of potential ARARs. However, EPA will consider TBCs along with ARARs, and EPA may use the TBCs in determining the necessary level of cleanup for protecfion of health iand the environment.

Soil Altematives:

Altemative SI, the No Action Altemative, and Altemative S2, Institutional Controls, do not meet ARARs. Pennsylvania Act 2 Standards, Title 25 PA Code § 250.407(c) establish a point of compliance for soil. For attainment Of site-specific soil standards in residenfial areas, the point of compliance for ingestion and inhalation exposure is up to 15 feet below the existing surface unless bedrock or physical stmctures are encoimtered which prevent safe continued remediation. Under Altemative S4 for soils it appears that, for the predominance of properties, the standard

will be achieved. For the properties where contamination remains at depth, a minimum of two feet of clean fill will provide pathway elimination using an engineering control. An institutional control in the form of a use restriction will then be used to maintain the pathway elimination. Altemative 3 will not meet the standard as 1 foot of soil will be inadequate for pathway eliminafion. PADEP maintains that the Waste Management regulations for a minimum two foot soil cover for closing waste in place are the.standard for pathway elimination. A waiver to Title 25 PA Code § 250.407(c) will be required to implement Altemative S3. Altemafives S3 and S4 will meet all other ARARs.

Dust Altematives:

Altemative Dl, the No Action Altemative, and Altemative D2, Insfitufional Controls, do not meet ARARs. Altemative D3 will comply with ARARs.

3. Long-Term Effectiveness and Permanence

Soil Altematives: Long-term effectiveness of the remedial altematives is the greatest for Altemative'S4 With its complete removal, to the extent practicable, of soils above the 572 ppm (or 600 ppm average)

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cleanup level. Altemative S3 will also remove soils which are above the cleanup level; however, only the top one foot of contaminated soils will be removed under Altemative S3. Contaminated soils may potentially be left in-place below one foot. Institutional Controls may be required at a significant number of properties under Altemative 3 to ensure the soils below one foot are not disturbed. Therefore, Altemative 3 offers somewhat less long-term'protectiveness and permanence than Altemafive S4, because all the contaminated soils will not be removed and reliance on institutional controls for soils below one foot will be necessary,

Altemafive S4 will result in the least amount of residual risk because all soil, to the extent pracficable, idenfified as being above the cleanup level will be removed to ensure that future exposure to residents does not occur. Altemafive S3 does not reduce residual risk to the same degree as Altemative S4, because contaminated soils may be left in-place below one foot. Long-term protectiveness will be dependent on the ability to enforce and maintain ICs.

Dust Altematives:

Altemative D3 will effectively remediate the contaminated house dust which was tracked in from residential exteriors. Based on effective source control of the residential yard source and public education on additional possible lead risks associated with lead based paint, this altemative will be effective for the long-term.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment

Soil Altematives:

Under Altemafive S4, all soil above the cleanup level, to the extent practicable, will be removed and replaced with clean fill. Under Altemative S3, only the top one foot of contaminated soil will be removed and replaced with clean fill. Both Altematives S3 and S4 will result in the reduction of toxicity, mobility, or volume of lead contamination through excavation and disposal of contaminated soil at an approved off-site disposal facility; however, Altemative S4 will achieve the highest reduction in toxicity, mobility, or voliune because all the contaminated soil, to the extent practicable, will be removed.

Dust Altematives: i

Altemative D3 will reduce the toxicity, mobility, or volume of contaminated residential house dust by the removal or immobilization of lead contaminated dust through specialized cleaning.

11

5. Short-Term Effectiveness

Soil Altematives:

Altematives S3 and S4 are similar in that they both require excavation of contaminated soils to

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varying extents. Exposure to fugitive dust generated by the remedial activities is the common short-term risk. Localized releases of potentially contaminated dust during remediation will be minimized by standard dust control techniques (i.e., water suppression). Protection will be enhanced by dust monitoring diuing constmction activities. For Altematives S3 and S4, constmction contractors will need protection against dermal and respiratory exposiu-e to dust while working in contaminated areas. Protective clothing and respirators or dust masks may be required to help control this risk.

If appropriate dust control measures are implemented properly, all of the action altematives will have similar short-term effectiveness. Altematives S3 and S4 are both estimated to take approximately one week to complete per property.

Neither Altemative S3 nor S4 is expected to substantially adversely affect the community during remediation. Each altemative will also include prioritizing residential yards of sensitive subpopulations in order to remediate the highest risks early in the remedy and enhance short-term effectiveness.

Dust Altematives:

Altemative D3 will achieve short term effectiveness. Indoor dust monitoring will be conducted during the speciaHzed cleaning process. In addition, construction contractors will need protection against dermal and respiratory exposure to dust while working in contaminated homes. Protective clothing and respirators or dust masks may be required to help control this risk, particularly during carpet removal and HEPA vacuuming. Potential cross contamination of clean areas of the home will be minimized through the use of poly-sheeting dust barriers to isolate clean rooms from contaminated rooms during the specialized cleaning.

6. Implementability

Soil Altematives:

The activities proposed as part of Altematives S3 and S4 are well-developed, non-complex technologies. Neither Altemative. S3 nor S4 is difficult in terms of constmctability. There are not great differences between the methods in completing the proposed remedial activities. Altematives S3 and S4 involve the removal of varipus depths of soil and vegetative cover then placement and maintenance of replacement soil and revegetation. All of the activities are technically feasible and none require complicated technical expertise. Each has similar levels of effort.

Altematives S3 and S4 may require predesign sampling to establish if remediation is necessary and to determine the extent of remediation. Additional sampling to confirm the effecfiveness of the remedy will have to be performed for Altematives S3 and S4.

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Post-remediation sampling and observafion will show whether the remedial objectives have been accomplished for Altematives S3 and S4. Implementafion of ICs for Altemative S3 and potenfially S4, if necessary, may be the most difficult portion of the altematives to reliably achieve. Implementation of ICs may affect the long-term effecfiveness of Altemative S3, in particular, because contaminated soil may be left in-place under this Altemative and it is expected that a significant number of homes may require ICs under Altemative S3 compared to Altemafive S4.

Dust Altematives:

Altemative D3, specialized cleaning, will follow well-established protocols and will be easily implementable. However, Altemative D3 will require the temporary relocation of residents for approximately one week while the specialized cleaning is undertaken. Based on past experience from ongoing removal acfions at the Site, the temporary relocafion process is well established and is easily implementable. Under Altemafive D2, ICs will be used in limiting access to contaminated house dust on interior surfaces. Specifically, ICs will include pubUc educafion in the form of community meetings, pamphlets, brochures, etc. informing property owners and renters of the hazards associated with interior house dust contamination and effective methods for cleaning. While public education and dispensing of pamphlets may be easily implementable, verifying residents' adherence to these procedures will be extremely difficult, if not impossible.

7. Cost

The costs for Altematives S3, S4, and D3, as previously discussed, are based on the assumption that 25 percent of the properties that denied access or never responded to EPA mailings seeking access (sampling and/or cleanup) may reconsider (this includes 25 percent of those properties that were originally completed during the first two years of the removal action where re-excavation may be necessary to achieve remedial cleanup standards).

Soil Altemafives

Altemative SI Altemative S2 Altemative S3 Altemative S4

Capital Costs $0 $243,750 $11,370,971 $11,215,643

J

Present Worth Cost $0 $2,019,286 $11,415,359 $11,260,031

Dust Altematives '

Altemative Dl Altemative D2 Altemative D3

Capital Costs $0 $97,500 $8,639,149

Present Worth Costs $0

. $257,656 $8,639,149

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8. State/Support Agency Acceptance

The Commonwealth of Pennsylvania supports the selection of the combination of Soil Altemative S4 and Dust Altemative D3 and has concurred on this ROD.

9. Community Acceptance

A thirty-day public comment period on EPA's Proposed Plan for the Price Battery Site began on June 10, 2009. An advertisement announcing the issuance of the Proposed Plan and a public meeting to discuss the Proposed Plan was placed in the Reading Eagle and Hamburg Item. The public meefing was held on June 18, 2009 at the Hambiu-g High School located at 700 Windsor Street in Hamburg. The meeting was attended by approximately 25 members of the community.

The community appears to support EPA's findings and preferred altemative. No one objected to EPA's preferred altemative, nor did anyone recommend an altemative approach. EPA did not receive any written comments during the public comment period. As expected, however, EPA received several letters, emails, and phone inquiries from residents that have reconsidered their participation in the cleanup.

A copy of the transcript of the public meefing is included in the Administrative Record. EPA's written responses to questions/comments posed during the public meeting are provided in the Responsiveness Summary of this Interim ROD.

XI. PRINCIPAL THREAT WASTES

Principal threat wastes are source materials containing the lead contamination that require remediation based on toxicity, mobility, and the potential to create unacceptable human health or ecological risks. The principal threat wastes at the Site consist of lead-contaminated residential soils. The NCP (Section 300.430(a)(l)(iii)(A)) establishes a preference for treatment to be used to address principal threat wastes when practicable. Treatment will not be employed for the interim remedy described in this Interim ROD due to the vmcertainty of treatment technologies that can be applied to lead-contaminated soils at the Site. Stabilization/solidification has traditionally been used in other applications to stabilize lead-containing materials prior to disposal. This technology has not been applied to residenfial properties intended for uru-estricted future use. By comparison, non-treatment technologies (excavation and replacement of removed materials, revegetafing) are traditionally applied to residential cleanup actions and are well demonstrated arid effective for eliminating site risks present at the Site. '

XII. SELECTED REMEDY

Following consideration of the requirements of CERCLA, a detailed analysis of the altematives using the nine criteria set forth in the NCP, and careful review of public comments, EPA has

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selected a combination of Soil Altemative S4 and Dust Altemative D3 for implementafion at the Price Battery Site.

Summary of the Rationale for the Selected Remedy

EPA is selecting a combination of Altemative S4 and Altemative D3, as developed in the Price Battery Interim Feasibility Study. Altemative S4 and Altemative D3 provide for continued response to excavate and replace lead contaminated soils above the PRG at the Site and perform interior decontamination while additional work is performed to further evaluate the complete extent of the Site contamination. The selected remedy is consistent with the scope of the response action currently being performed by EPA at the Site under removal response authority. The selected remedy includes health education and public outreach programs to further enhance the protectiveness of other response measures.

Risks posed by existing levels of lead contamination at the Site warrant immediate response. The selected remedy enables EPA to continue response measures in a timely manner at properties that pose the greatest risks to human health. These highest risk properties include any property exceeding 572 ppm where a child under six years old or a pregnant woman resides, any high child-impact area exceeding 572 ppm, and any other residential or residential-type property exceeding 572 ppm. High child-impact areas include properties where a high incidence of lead-exposure to children could occur. These high child-impact areas include schools, churches, parks, vacant lots, and other areas that could potentially attract young children. Accelerated response to these high priority properties can occur under the selected remedy.

The characterization of risks performed to date at the Site clearly supports the need to take action at these high priority properties. Due to the large number of these high priority properties at the Site, several years may be required to implement this interim remedy. This response period provides an opportunity to further evaluate the full nature and extent of the contamination. Response to lower priority properties (i.e., properties where children or pregnant women do not reside) will not be delayed or postponed under this interim approach. Additional information and data will be collected during the interim remedy and will be considered in the final remedy selection process. Final remedy selection for the Site will occur during implementation of the interim responsie. This schedule enables the final remedy for the remaining properties to proceed without intermpfion upon completion of the interim remedy.

In addition, the Selected Altemative will meet all ARARs and provide a long-term and permanent solution. The Selected Altemative offers short-term effectiveness, provided appropriate controls and plans are in-place.

Description of the Selected Remedy and Performance Standards

The Selected Remedy represents an interim action that willenable EPA to continue to address immediate site risks while additional work is performed to determine the full extent of the

36

AR100921

contamination at the Site. This interim approach requires EPA to propose a final remedy and seek public comment for any additional contaminated residential properties which lie outside the OU-1 target area as currently defined and not addressed by this Interim ROD. The selected , remedy developed in this Interim ROD was developed as Altematives S4 and D3 in the Price Battery Interim Feasibility Study and includes the following elements:

Altemafive S4 - Excavation to Clean Soil Depth and Consolidation for Transportation to and Disposal in RCRA Subtitle C or D Landfill or Approved RCRA Recycling Facility

For each residential yard, the exact nature of the remediation will have to be considered on a case-by-case basis. In general, the following areas may be eligible to be remediated in each yard:

• Sod/lavm areas • Alleys (if unpaved) to the extension of the lot lines • Planters, beds, and other landscaped areas • Garden areas • Unpaved driveways ^ • Garages with dirt floors

In short, remediation will occur in any area within and adjacent to the residential yard where residents could potentially come in contact with soils above the cleanup levels.

The components of the preferred altemative will include:

1.) Soil Excavation and Sampling: Soils containing lead concentrafions greater than 572 ppm will be excayated and removed. Prior to excavation, the depth of excavation will be

^ pre-delineated by composite sampling of soils at six, twelve, and, if necessary, eighteen inch depth intervals using an XRF. Excavation will progress in six inch increments until the targeted depth is achieved at which time confirmation samples will be analyzed through XRF analysis (in-situ or ex-situ) with ten percent of the samples shipped to a fixed laboratory for analysis. At a minimum, composite samples will be collected from each discrete portion of the yard (i.e., front, back, and side yards), respectively. Additional sampling points may be required based on site-specific conditions. However, under this altemative it may not be possible to excavate soils in all areas to "clean" because of obstmctions (i.e., tree and shmb roots, old outhouse foundations, old buried septic or cesspools) or excavations abutting house foundations. In such cases, where attainment of the 572 ppm level caimot be achieved in all areas of the yard, attainment will be deemed to have been achieved if the arithmetic average of the post-excavation sampling and clean backfill soils results in a yard-average lead concentration of 600 ppm or below. As an additional precaution, high visibility horizontal fencing will be placed in these specific sections of the yard to serve as a visual indicator for the resident that lead contaminated soils may be present. Despite best efforts, if the 600 ppm lead in soil yard-wide average cannot be met, those areas of the yard which are causing the yard to exceed

,37

AR100922

the 600 ppm lead in soil average will be covered with high visibility horizontal fencing and ICs implemented to prevent future exposure.

Excavation of contaminated yards will progress in six inch increments until sampling confirms that the remedial goals have been achieved. This will be completed using appropriately sized constmction equipment, such as small excavators, skid steers, and dump tmcks. Some manual excavation and finishing is also anficipated. Dust suppression measures will be used during remedial activifies. Based on past experience from ongoing removal activities, excavation depths generally range from six inches to eighteen inches in individual yards with a few yards going to two feet or more. Generally, excavations depths are greatest along Third Street and become shallower with each subsequent street moving east to topographically higher locations. Excavation depths may also vary within the same yard.

2.) Restoration: Clean backfill and/or topsoil will be placed to return the land to original grade and condition to the maximum extent practicable. Surface revegetation will be in the form of sod (or seed, if appropriate). Sod care instmctions will be provided to the homeowner. Watering and maintenance of the sod will be the responsibility of the homeowner. Any landscaping removed will be replaced in-kind or the residents will be reimbursed for replacement of landscaping of similar kind. Landscaped beds or gardens will be restored with topsoil and/or mulch or landscape stone. Driveways will be restored with gravel.

3.) Disposal of Excavated Soil: Excavated soil and vegetation will be stockpiled and tested for disposal. Excavated soils will be tested for the TCLP criteria for lead to determine whether the soils can be disposed of at a non-hazardous waste landfill.

4.) Air Monitoring and Dust Control: Appropriate air monitoring will be conducted to identify the possible occurrence of contaminant migration during remedial activities. Dust suppression measures will be used during remedial activities. Any evidence of contaminant migration during remedial activities either through air monitoring or visual observation will result in immediate implementation of additional dust suppression measures or a shutdown of constmction activities.

5.) Public Education/Institutional Controls: Public educafion will take the form of community meetings, pamphlets, brochures, etc. informing property owners and renters of the hazards associated with lead exposure and preventative methods to reduce exposure.

6.) Institutional Controls: Institufional controls at the Site will be employed to protect human health. The ICs will be used in limiting access to and future development, improvement, and use of unremediated properties or properties where residual risk may remain after the cleanup. Specifically, ICs will include activity and use restrictions

38

AR100923

enacted through proprietary (e.g., easements, covenants) and/or governmental (e.g. zoning requirements or register) controls to prevent use of the property that will pose an unacceptable risk to receptors (i.e., for residenfial use). The exact type of IC implemented will be determined by EPA in consultation with PADEP and local government agencies. ^

Altemative D3 - Specialized Cleaning '

Properties that have exterior lead contamination above the cleanup level of 572 ppm related to former Price Battery operations and interior lead dust levels on floors above the cleanup level of 40 |ig/ft^ will be eligible for interior cleaning. If warranted, the steps in the cleaning process may be modified to improve the efficiency of the overall process based on the outcome of testing conducted during the cleanup or if imique condifions exist in the house which require the cleaning process to be modified.

This altemative includes a combination of actions:

1.) Source Control: The residential yard soil source will initially be remediated before or concurrent with the indoor dust remediation at a specific residence. Source control will be accomplished via removal of soils above the cleanup level of 572 ppm, backfilling with clean soils, and revegetation. Interior remediation will not be conducted prior to or in lieu of exterior cleanup. •

, ) . •

2.) Specialized Cleaning:

• Packing: Residents will be required to pack their personal belongings prior to the specialized cleaning being conducted. Packing materials will be provided by EPA. Residents will also be required to place EPA custody seals on all the boxes. All boxes will remain in the house, unless imique situations warrant removal of the boxes from the home to facilitate the specialized cleaning.

• Relocation: Residents will be temporarily relocated for approximately one week while the specialized cleaning is conducted. Residents will also be providedper diem for the length of the temporary relocafion. Individual residents' needs will be taken into account for every temporary relocafion. EPA will also reimburse residents for boarding pets if necessary. Residents will only be temporarily relocated for interior remediation. Residents will not be relocated for remediafion of the exterior soils only unless unique circumstances with the residence warrant relocation for the exterior cleanup.

• Security: EPA will provide security during non-work hours for protection of the house and its belongings.

39

AR100924

• Isolation of Clean Roomis and Soft Furnishings: Poly-sheeting will be used to isolate "clean" or rooms that underwent cleanup from contaminated rooms to minimize the chance that contamination is spread to clean rooms. Poly-sheeting will also be used to protect soft fumishings.

II . .

II • ' •

Carpet and Padding Removal: Carpet dust samples will be collected by HEPA vacuuming and the dust collected in the vacuum bag analyzed for lead. Carpet with dust lead levels above 40 fig/ft̂ will be removed. Contaminated carpet will be removed immediately after sealing off clean rooms with poly-sheeting by cutting carpet into pieces small enough to fit into drum liners. Bagging and sealing will be completed in the contaminated room to minimize the chance of spreading contaminafion. jResidents will be reimbursed for the replacement value of the carpet and pad removed based upon EPA's appraisal of the quality and grade of the carpet and pad. The resident is responsible for the purchase and installafion of new carpets.

Insulation: In order to effectively implement the specialized cleaning, in certain instances, exposed insulation in attic and basement ceilings may also be removed. Insulation trapsj large amounts of dust. Residents will be reimbursed for the replacement value of the-insulation based on the square footage and R-value of the insulation removed. The resident is responsible for the purchase and installation of the new insulation.

Disposal of Carpet/Padding and Insulation: Any carpet and padding or insulation removed will be disposed of by EPA in a permitted off-site RCRA Subtitle D disposal facility.

HEPA Vacuuming: Hard siu-faces including walls, ceilings, and floors (including flooring previously covered by carpeting) will be HEPA vacuumed. For soft fumishings, only HEPA vacuuming will be performed. Upholstered items will be vacuumed at a rate of one square yard per minute in two steps in opposing directions. !

Specialized Cleaning: The specialized cleaning will include cleaning of floors, walls, ceilings, and other household fumiture, cabinets, and closets consistent with past and ongoing removal actions at the Site. The specialized cleaning will include attics and basements. Specialized cleaning will not include heating, ventilation, and air conditioning ("HVAC") interior duct work.

1. Rooms with Floors Above 40 fig/ft^: For rooms with floors with . i | - y

lead dust concentrations above 40 |ig/ft , hard floor surfaces (i.e., wood floors, linoleum, concrete floors, etc.) and other room surfaces and fumiture will be cleaned with TSP. If the floor is unfinished

40

AR100925

wood or concrete, an encapsulant (such as LeadLock , or equivalent) will be applied after cleaning followed by two coats of a clear coat compound to protect the encapsulant from foot traffic. Basements with dirt floors will be covered with geotextile fabric and gravel. Accessible basement crawl spaces will be covered with geotextile

*> fabric and gravel or geotextile fabric alone.

2. Rooms with Floors Below 40 jig/ft^: For rooms with floors with lead dust concentrafions below 40 |ag/ft̂ , hard floor surfaces will be cleaned with a household cleaning agent. TSP will not be used. For rooms with carpeted floors with lead dust concentrations below 40 ^g/ft^, the carpeted floors will be shampooed.

• HEPA Vacuuming: A second HEPA vacuuming of floor surfaces and soft fumishings will be conducted after the specialized cleaning.

3.) Clearance Testing: Confirmatory lead dust wipe sampling will be conducted to ensure that lead dust concentrations are below 40 |ig/ft^. Clearance testing will be performed after the specialized cleaning to confirm the success of the remedial action. The clearance testing will be performed by a contractor independent of the contractor performing the specialized cleaning. Samples will be collected from representative hard floor surfaces to confirm the effectiveness of the specialized cleaning. Tesfing of floors will be consistent with the procedures used for clearance testing for lead-based paint abatement projects, although interior lead-based paint abatement will not be conducted. Only floors will require clearance testing. Window sills and troughs will not be tested. Sampling will occur at least one hour after complefion of the specialized •cleanup.

4.) Public Education; The public education program will consist of pamphlets, brochures, general media exposure, and information about the remedial action requirements, as well as overall lead risks including risks from lead-based paint. The primary purpose will be to keep the public informed about soil or lead dust contamination and to communicate good maintenance practices.

5.) Institutional Controls: Institutional controls will be implemented limiting access to fiiture development, improvement, and use of unremediated properties or properties where residual risk may remain after cleanup. ICs will include activity and use restricfions enacted through proprietary (e.g., easements, covenants) and/or governmental (e.g. local ordinances, zoning requirements, or Registry) controls to prevent use of the property that will pose an unacceptable risk to receptors (i.e., for residential use). A Registry of Homes will be provided to the Borough of Hamburg idenfifying which properties are unremediated or have been remediated. This Registry will supplement existing Permsylvania real estate transfer disclosure requirements and

41

AR100926

to ensure that potential buyers are aware of potential contamination. The exact type of IC implemented will be determined by EPA in consultation with PADEP and local government agencies.

In summary, the preferred altemative is believed to provide the best balance of trade-offs among all the altematives evaluated with respect to the nine criteria above. Based on the information available at this time, EPA believes the preferred altemative will protect human health and the environment, will comply with ARARs and be cost effective.

Eligibility for Remedial Action

The following describes procedures to be followed to determine the eligibility of a property for remediation. It is expected that these procedures will be similar regardless of the final remedy selected by EPA. Residences within the OU-1 target area foimd to contain exterior soil with lead levels at or above the site-specific risk-based standard of 572 ppm (or 600 ppm average) will be eligible for remediation, the extent of which will be based on residence specific conditions determined through the sampling. Residential properties eligible for sampling include: properties containing single and multiple family dwellings, apartment complexes, vacant lots in residential areas, schools, child care facilities, community centers, parks, greenways, and any other areas where children may be exposed to site-related contaminated media.

Property owners within the OU-1 target area will be solicited to participate in sampling to determine eligibility for remedial action. Requests for participation will be made through EPA mailings to individual property owners. EPA may also make appeals for participation through local media outlets, as well as personal door-to-door visits, whenever possible. EPA will solicit participation for a limited time, the duration of which will be determined by EPA in consultation with PADEP. After this solicitation period ends, responsibility for any future remedial actions taken to address lead contamination at a residence will be the individual property owner's responsibility.

Sequence of Sampling

Sampling for eligibility will be conducted in the following general manner, If a property owner located within the Site boundary requests sampling of his/her property, initially, exterior sampling will be performed. A composite sample will be collected from each property. The number of sampling points and their locations which make up the composite sample will be determined by EPA in consultation with PADEP. At a minimum the composite of each residence sampled will be a representative sample from the front and back yards, and, if appropriate, side yards and play areas. Sampling will begin on exterior soils because EPA's risk-based standard is based on contamination from exterior soils being tracked into the residences.

Residences found to contain exterior soil with lead levels at or above the site-specific risk based trigger of 572 ppm (or 600 ppm average) will be eligible for remediation, the extent of which

42

AR100927

will be based on residence specific conditions determined through sampling. There will be no age of resident or income eligibility requirements. Sampling results will be provided to each resident. Those residents who qualify will then have the choice to participate in the remedial action, or not. If eligibility sampling finds that a property is eligible for remedial acfion and the property owner(s) choose not to participate in the remedial action, some type of institutional control will need to be implemented to insure that future buyers of the property are aware of the sampling results.

Those residences which qualify for an exterior soils cleanup will also be eligible for interior dust sampling. The resident will have the option to have interior sampling performed. Residences found to contain interior wipe and/or dust samples with lead levels above the 40 |ig/ft^ clearance criteria will be eligible for interior remediation. Any interior cleanup will be conducted either concurrent with the exterior clezmup or after the exterior cleanup is completed. Interior samples will be collected utilizing wipes on hard floor surfaces or HEPA vacuuming on carpeted floors. Dust samples from HEPA vacuuming of carpeted surfaces will be collected in a vacuum bag, and the dust collected in the vacuum bag analyzed for lead.

An exterior risk-based goal of 572 ppm (or 600 ppm average) lead in soil and 40 |ig/ft^ clearance criteria for lead dust on interior floors will be applied on a residence by residence basis. Because the correlation between lead and arsenic and lead and anfimony is sufficiently strong, all of the altematives are designed such that implemenfing the lead-based remedy will also meet the arsenic and antimony goals idenfified in the Preliminary Remediafion Goals ("PRG") Report.

Summary of the Estimated Remedy Costs

In order to more accurately estimate potential costs of the Preferred Altemative, EPA has assumed that only 25 percent of those homes that have not already responded affirmatively to having a cleanup conducted will reconsider. Under this assumption, EPA estimates that an additional 149 exteriors and 128 interiors will ultimately provide access to have the cleanup conducted.

If Altematives S4 and D3 are implemented concurrently, certain cost benefits will be realized such that the combined costs of both Altematives will be less than the sum of the Altematives individually. The estimated combined cost of implementing Soil Altemative S4 and Dust Altemative D3 is $ 15,956,500. A detailed cost estimate is provided in Table 4.

Expected Outcome of the Selected Remedy •

The selected remedy will reduce, to acceptable levels, risks to human health and the environment from the Price Battery Site by excavating and removing all soils, to the extent practicable, and interior decontamination of residences that exceed the Performance Standards described above. A very limited amount of contaminated soil may have to remain in cases where.complete excavation is not possible.

43

AR100928

The selected remedy will provide accelerated response to contaminated Site properties and will significantly improve human health protection in the community. The selected remedial action will take several years to implement due to the number of remaining properties left to be addressed. This interim strategy allows for further assessment of the complete extent of the contaminafion to be performed while properties posing the highest human health risks are remediated through the well-demonstrated approach of excavation and soil replacement. A final remedy selecfion process will proceed after the full nature and extent of the contaminafion is determined.

Concurrent with the selected remedy, EPA will work with other interested parties to design and implement a comprehensive program to better characterize risks associated with all potenfial sources of lead at the Site.

Because the full extent of the lead contaminafion at the Price Battery Site has not yet been defined, this selected remedy carmot be considered a final action for the Site. Public involvement will continue during implementation of the interim remedy to assess new information that is developed to support selection of a final remedial acfion for the Site. Prior to the selection of a final remedy, the EPA will release a Proposed Plan idenfifying the Agency's preferred altemative to remediate site contaminants not addressed during this interim action. Following public review and comment of the Agency's Proposed Plan for Final Remedial Action, EPA will issue a Final ROD for the Site.

XIIL STATUTORY DETERMINATIONS

Section 121 of CERCLA requires that the selected remedy be protective of human health and the environment, comply with ARARs, be cost effective, and use permanent solutions and altemative treatment technologies or resource recovery technologies to the maximum extent practicable. Addifionally, CERCLA includes a preference for remedies that use treatment to significantly and permanently reduce the volume, toxicity, or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedy for the Site meets these statutory requirements.

Protection of Human Health and the Environment J • • • .

The selected remedy will provide protection of human health and the environment by achieving the Remedial Action Objectives through conventional engineering measures and interior decontamination procedures. Risks associated with lead contaminated soils and dust at the Site are caused by the potential for direct contact with contaminated soils and dust. The selected remedy eliminates this direct exposure pathway through excavation and replacement of lead contaminated soils and interior decontamination of residential properties. Contaminated soils will be removed from remediated areas, permanently eliminating this idenfified source of exposure. Likewise, interior decontamination procedures will significantly reduce exposures to

44 .

AR100929

lead-contaminated dust within the residences. The implementation of the selected remedy will not pose unacceptable short-term risks or cross-media impacts.

Compliance with Applicable or Relevant and Appropriate Requirements

The,selected remedy will comply with all Federal and State requirements, standards, criteria, and limitafions that are applicable or relevant and appropriate, as required by section 121(c) of CERCLA, 42 U.S.C. § 9621(c). Such requirements, standards, criteria and limitations are identified in Tables 1-3.

Cost Effectiveness

The NCP at 40 C.F.R. § 300.430(f)(l)(ii)(D), requires EPA to evaluate cost-effecfiveness by comparing all the altematives meeting the threshold criteria—protection of human health and the environment and compliance with ARARs—against long-̂ term effectiveness and permanence; reduction of toxicity, mobility or volume through treatment; and short-term effectiveness (collectively referred to as overall effectiveness). The NCP further states that overall effectiveness is then compared to cost to insure that the remedy is cost effective.

EPA concludes, following an evaluation of these criteria, that the selected remedy is cost-effective in providing overall protection in proportion to costs and meets all other requirements of CERCLA. The estimated present value of the selected remedial action is $15,956,500.

Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable

The selected remedy utilizes a well demonstrated approach to remediation of contaminated soils that will provide a permanent remedy for remediated soils. Removal and replacement of contaminated soils permanently removes site contaminants as a potential source of exposure. No treatment technologies were identified that could be considered reliable at this time. The selected remedy best satisfies the statutory mandates for permanence and treatment.

EPA has concluded that the selected remedy is protective, compliant with ARARs, cost-effective, and provides the best balance of trade-offs for utilizing permanent solutions and altemative treatment technologies to the extent practicable for the Site.

Preferencefor Treatment as a Principal Element

The selected remedy does not ufilize treatment to address the principal threats posed by the Site. No treatment technologies were identified that have demonstrated the ability to reliably provide short- and long-term effectiveness and permanence. ''

45

AR100930

Reduction of Mobility, Toxicity, and Volume r • • •

The selected remedy will reduce the mobility of contaminants of concem at the Site through removal and appropriate disposal of the lead-contaminated soils. The volume and toxicity of principal threat materials will not be reduced. The appropriate disposal of these materials will effectively control the potential for future exposure.

Five Year Review Requirements j ') • •

Secfion 121(c) of CERCLA and Secfion 3do.430(f)(4)(ii) of the NCP require review of the remedy if the remedy results in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure. Any such review must be conducted no less often than every five years after initiation of the remedial acfion.

ii •

At remediated properties, the selected remedy does not result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure. Therefore, for these properties, five-year reviews will not be necessary. However, in those cases where it is not possible to achieve the soil cleanup levels or a resident has voluntarily determined not to participate in the cleanup, hazardous substances will remain in place and five year reviews at such properties will be conducted, as necessary.

Documentation of Significant Changes

The Proposed Plan for the Price Battery Site was released for public comment on June 10, 2009. The Proposed Plan identified as EPA's preferred altematives for soil and interior dust the altematives selected in this Interim ROD. The remedy selected in this Interim ROD involves no significant changes to the preferred altemative identified in the Proposed Plan.

46

AR100931

FIGURE 1 SITE LOCATION

^̂ m:̂ ^m :̂ •""'y^»w^:; |:.|^K Hamburg, Pennsylvania

roPOt f^OtMBOrrt 3«ta lor AioOlS

47

AR100932

FIGURE 2 REMOVAL ASSESSMENT AND REMEDIAL INVESTIGATION AREA

: ' r ; - ' ^ 7 -Legend

C Z J ] Oflffwl R«™«l A.««™nl An .

l " " 1 E ip indKj Renxwil A iMunwn) Are*

^ ^ ^ inlirlm R v n a d i l kiwitigation A m

1 ^ ^Ong t * i aR«nwdMl l nv« i t l g i t l a tAn i

• Fonmr SmoftnlKk

(•;• •"" ] Fonmr Priet Battwy Pltnt

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"Mn

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3 ; . . . - .. ^C. % :--rT-. :i~M..i>---

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• V !

V -:Y V. .> ;K -

,.sp .r

1, OOO^' 2,000,.' - ' - -

• ^ y > " • • ' • •

48

AR100933

FIGURE 3 PREDICTED HIGH PROBABILITY AREA

\yrmvOEEaFftiVnce BaneiyOSWXDwroniingauiT»ce_ilowm»d o:yi9raiD9itt»7i A

Legend • Former Smokestack

Former Price Battery Plant and Other Exide-Owned Properties

^ ^ ^ Interim RI Boundary Extent

• • • Undefined Interim RI Boundary Extent

Predicted High Probability Area

Surface Water Bodies

Note: Predicted High Probability Area for lead concentrations above 572 mglkg determined through the use of drainage patterns, soil sample data and topographic features.

49

AR100934

FIGURE 4 PERCENTAGE OF PROPERTIES EXCEEDING 572 PPM

f^rS^a5!^!^S^S£ t _J b::; Legend

gSTART Qoi/ir] hvastigaiDn AriM

START Roi#id lAirHati iganonAns

RAf. Pnirr t 1 IrvAVigAltm Am*

RAC R iu id 2 irvaiiieriicnAraa

1 ^ i i | ) f uimar pnc* banw> Mart mO 0r>«r Enoa-Ovriiad Proparti*-

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- J ; — i f ; . i !•

50

AR100935

FIGURE 5 SITE CONCEPTUAL MODEL

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la's l i t

ff^ 2 L

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Current and Future Offsits Residents (Young Children)°

Current and Future Offsite Residents (Adults)'

Current and Future Offsite Commercial Industrial Workers

• a 3

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TJ C, n> o 3 <n

51

AR100936

Table 1 Action-Specific ARARs/TBCs Price Battery OU-1 Site Hamburg, Pennsylvania

Standard, Requirement, Criterion, Or Limitation Citation Or Reference Description Status Comments

FEDERAL

RCRA IVIanifesting and Recordkeeping Requirements

RCRA Storage Requirements

Off-Site Transport of Hazardous Waste

Other: National Ambient Air Quality Standards

HUD Guidelines for the Evaluation and Control of , Lead-Based Paint Hazards in Housing

PENNSYLVANIA

Hazardous Waste: PA Hazardous Waste Regulations

40 CFR §§262.10-262.44

40 CFR § 264; 40 CFR 265, Subpart 1

EPA OSWER Directive 9834.11

40 CFR § 50.6

www.hud.gov/offices/lbp/ hudguidelines

25 PA Code §§ 260a-266a, 266b, and 268a-270a

Develops guidelines for recordkeeping of the management actions for hazardous wastes.

Develops standards for the storage of hazardous wastes.

Establishes technical guidelines for the off-site transport of hazardous wastes.

Requires that the remedial action include fugitive dust control measures.

Establishes standards for lead hazard evaluations, residential dust lead clean up levels, dust and soil sampling requirements, and dust clearance standards.

Establishes guidelines for hazardous waste management.

Applicable

Relevant and Appropriate

TBC

Applicable

TBC

Applicable

Applicable if remedial activities include the off-site transport of hazardous waste.

Includes requirements if remedial activities include the storage of hazardous waste greater than 90 days.

TBC if remedial activities include the off-site transport and management of hazardous waste.

Applicable to earth-moving activities as well as to treatment processes that may include mixing or other processes that result in potential releases of particulates.

While EPA does not have authority under Superfund to address lead-based paint, remedial action at the site may provide for an evaluation of the impact of lead-based paint in some circumstances. The cited standards would be helpful in determining the effectiveness of the cleanup and in establishing the criteria to be used in evaluation, cleanup and clearance sampling conducted as part of a remedial action.

Applicable to hazardous soils excavated from the site.

52 AR100937

Table 1 (Continued) Action-Specific ARARs/TBCs Price Battery OU-1 Site Hamburg, Pennsylvania

PENNSYLVANIA (Continued)

Soil: 25 PA Code Chapter 250: Administration of Land Recycling Program (Act 2)

Other: Pennsylvania's Land Recycling Program Technical Guidance Manual Department of Environmental Protection Bureau of Land Recycling and Waste Management: Management of Fill

Fugitive Dust Control

Air Pollution Control

Erosion and Sedimentation Control

Storm Water Management Act of 1978, as amended

25 PA Code § 250.407(c) Subpart D Site-Specific Standard

253-0300-100

258-2182-773

25 PA Code §§123.1-123.2

25 PA Code Chapters 121, 127, 139

35 PS § 691.1 et. seq. Chapter 102, 25 PA Code §§ 102.1-102.5, 102.11-102.13,, 102.21-102.24

32 P.S.§ 680.13

For attainment of site-specific soil standards in residential areas, the point of compliance for ingestion and inhalation exposure is up to 15 feet below the existing surface unless bedrock or physical structures are encountered which prevent safe continued remediation.

Establishes recommendations and guidance for attainment of site specific standards in soil at voluntary state cleanup Sites for land reuse.

Establishes clean fill requirements.

Requires that the remedial action take all reasonable actions to prevent particulate matter from becoming airborne.

Requires prevention of air emissions at remedial sites and that ambient air quality will be maintained in areas where air quality is better than applicable air quality standards and improved in areas where air quality is worse than applicable air quality standards.

Regulates erosion and sedimentation control measures.

Provides storm water runoff control requirements during construction activities.

1 ' • • .

Applicable

TBC

TBC

Applicable

Applicable

Applicable

Applicable

Applicable to residential cleanup activities.

TBC for remedial activities involving soil.

1

TBC for soils used as clean fill at excavated areas at the site.

Applicable to earth-moving activities as well as to treatment processes that may include mixing or other processes that result in potential releases of particulates.

Applicable to earth-moving activities as well as to treatment processes that may include mixing or other processes that result in potential releases of particulates.

Applicable to grading and excavation activities conducted as part of site remediation.

Applicable to grading and excavation activities conducted as part of site remediation.

53 AR100938

Table 2 Location-Specific ARARs/TBCs Price Battery OU-1 Site Hamburg, Pennsylvania

Standard, Requirement, Cr i ter ion, Or L imi ta t ion

Citat ion Or Reference Descr ipt ion Status Comments

FEDERAL

National Historic Preservation Act

Archeological Resources Protection Act

Endangered Species Act of 1973

Clean Water Act (Dredge and Fill Requirements)

16 U.S.C. § 470; et Seq.; 40 CFR § 6.301 (b); 36 CFR Part 800

16 U.S.C. 469; 40 CFR 6.301 (c)

16. U.S.C. § 1531-1543; 50 CFR Parts 17. 401; 40 CFR § 6.302 (h)

33 U.S.C. §§ 1251-1376; 40 CFR §§230, 231

Minimizes impact of actions on historic properties and landmarks.

Provides protection from actions that may cause irreparable harm, loss, or destruction of artifacts

Provides protection of critical habitat upon which endangered or threatened species depend.

Provides protection to waters in and around the site.

Applicable

Applicable

Relevant and Appropriate

Applicable to actions at historic properties or landmarks, or properties at the site that contain historical and archeological data.

Applicable to actions that impact critical habitat of endangered or threatened species. Requires a determination of presence of endangered or threatened species.

Relevant and appropriate to actions involving capping, berm construction and/or onsite disposal of contaminated soil that may impact local water bodies.

PENNSYLVANIA

Clean Streams Law 35P.S. §619.1;25 PA Code §§ 93.4, 93.7, 93.8 (a), 93.9, 25 PA Code Chapter 16

Provides protection to waters in and around the site.

Relevant and Appropriate

Requires that any remedial actions taken at the site not contribute to pollution of state waters.

54 AR100939

Table 3 Chemical-Specific AFlARs/TBCs Price Battery OU-1 Site Hamburg, Pennsylvania

Standard, Requirement, Criterion, Or Limitation Citation Or Reference Description Status Comments

( FEDERAL

Soil: EPA Soil Screening Guidance

Hazardous Waste: Resource Conservation and Recovery Act (RCRA) Part 261 - Identification and Listing of Hazardous Waste

Other: EPA Region III Risk-based Concentration Table

National Ambient AirQuality Standards

HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing

EPA/540/R-96/018

40 CFR §§261.24-261.3

NA

"1

40 CFR §§50.6, 50.12

www.hud.gov/offices/lbp/ hudguidelines

Provides methodology for calculating risk-based, site-specific soil screening levels.

Defines those solid wastes which are subject to regulations as hazardous wastes, and lists specific chemical and industry-source wastes.

Establishes chemical screening guidelines for use during risk assessment.

Provides acceptable ambient air quality levels for particulate mattei' and lead.

Establishes standards for lead hazard evaluations, residential dust lead clean up levels, dust and soil sampling requirements, and dust clearance standards.

TBC

Applicable

TBC

Applicable

TBC

Used to standardize and accelerate site cleanup.

Applicable to determining whether wastes are considered hazardous under RCRA.

May be useful in development of cleanup goals.

Applicable to earth-moving activities as well as to treatment processes that may include mixing or other processes that result in potential releases of particulates or lead.

While EPA does not have authority under Superfund to address lead-based paint, remedial action at the site may provide for an evaluation of the impact of lead-based paint in some circumstances. The cited ' standards would be helpful in determining the effectiveness of the cleanup and in establishing the criteria to be used in evaluation, cleanup and clearance sampling conducted as part of a remedial action.

55-AR100940

Table 3 (Continued) Chemical-Specific ARARs/TBCs Price Battery OU-1 Site Hamburg, Pennsylvania

Standard, Requirement, Cr i ter ion, Or L imi tat ion

Citation Or Reference Description Status Comments

FEDERAL

Other: Superfund Lead-Contaminated Residential Sites Handbook

Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities

Clarification to the 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities

OSWER Directive 9285.7-50

August 2003

OSWER Directive 9355.4-12 August 1994

OSWER Directive 99200.4-27P August 1998 EPA/540/F-98/030 PB98-963244

Provides guidance on assessing and remediating residential properties contaminated with lead.

Establishes a streamlined approach for determiriing protective levels of lead in soil at CERCLA sites and RCRA facilities

Clarifies the Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities

TBC

TBC

TBC

Used in evaluating lead contamination in residential soils

Recommends screening levels for lead in soils for residential land use of 400 ppm; describes how to develop PRGs for residential land use; and describes a plan for soil lead cleanup at sites that have multiple sources of lead.

Clarifies OSWER policy on using the lEUBK model and blood lead studies; determines geographic area to use in evaluating human exposure to lead contamination; addresses multimedia lead contamination; and determines appropriate response actions at lead sites.

56 AR100941

TABLE 4 SELECTED REMEDY COSTS'

Alternative S4 and D3 - Excavation to Clean Soil Depth, Consolidation for PRESENT WORTH COST , Transportation to and Disposal in RCRA Subtitle C or D Landfill

J And Specialized Cleaning Discount Rate: 7% ,

Site Name: Price Battery Site Location; Hamburg, PA

ITEM DESCRIPTION

MOBILIZATION/DEMOBILIZATION Transport Equipment & Staff Lodging and per diem for 9 people

' INTERIOR PREPARATION Packing Supplies (boxes and strapping tape) Temporary relocation of residents for 1 week (at standard CONUS lodging and per diem Carpet Replacement Allowance

, RENTAL EQUIPMENT Rent cargo trailer Rent mini excavator, crawler mounted Rent skid steer Rent walk behind compactor Rent dump truck Rent water truck Rent offroad forklift Rent excavator (used 3 times a year to load out soil) Rent flatbed truck Rent pickup trucks ($600 each * 3 trucks) Rent porta Johns ($672 each * 4 porta Johns)

TRAILER Rent trailer Electric Phone Cable ADT Security

PERSONNEL Response manager ($55.62*55 hours/week) Field accountant ($35.02*40 hours/week+$52.53*15 hours/week) Foreman ($46.09*40 hours/week+$69.14*15 hours/week) Laborers ($41.31*40 hours/week+$61.97*15 hours/week*3 people and $31.31 *40 hours/week+$46.95*15 hours/week*4 people) Equipment operators ($62.00*55 hours/week*2 people) Truck driver ($41.00*55 hours/week) Oversight and samplers ($55.62*55 hours/week*2 people) Security MATERIALS

Screened backfill (6 inches) Unscreened backfill (6 inches)

UNITS

month month

property household

property

month month month month month month , month each

month month month

month month month month' month

week

week

week

week week week

week week

E.c.y E.C.Y

QUANTITY

36 36

128 128

128

30 36 36 36 36 36 36

9 36 36 36

36 36 36 36 36

149

149

128

149 149 149

149 149

2,980 2,980

UNIT PRICE DOLLARS

$1,121 $38,740

$124 $1,001

$3,745

$600 $1,400 $1,600 $320

$1,908 $2,968 $1,700 $1,800 $600

$1,800 $2,688

$1,100.00 $300.00 $800.00 $100.00 $45.00

$3,059.10

$2,188.75

$2,880.70

$15,572.45 $6,820.00 $2,255.00

$6,118.20 $854.00

$16.43 $8.16

TOTAL COST DOLLARS

$40,373 $1,394,640

$15,808 $128,128

$479,360 i

$18,000 $50,400 $57,600 $11,520 $68,688

$106,848 $61,200 $16,200 $21,600 $64,800 $96,768

$39,600 $10,800 $28,800 $3,600 $1,620

$455,806

$326,124

$368,730

$2,320,295 $1,016,180

$335,995

$911,612 $127,246

$48,961 $24,317

57 AR100942

TABLE 4 SELECTED REMEDY COSTS' Altemative S4 and D3 - Excavation to Clean Soil Depth, Consolidation for PRESENT WORTH COST

Transportation to and Disposal in RCRA Subtitle C or D Landfill And Specialized Cleaning Discount Rate: 7%

Site Name: Price Battery Site Location: Hamburg, PA

ITEM DESCRIPTION

landscape stone, 3/4 inch Pocono Double ground bark mulch High visibility Snow fence Sod Sod watering

OFFSITE LANDFILLING Disposal at Subtitle D Landfill

SAMPLING XRF machine rental TCLP analysis

SPECIALIZED CLEANING MATERIALS HEPA bags Lead lock and Clearcoat Unfinished floors Rags Cleaning Solutions Mops Poly Drum liner bags for waste carpet

1,

POST-CLEANING Carpet disposal (roll off) - $1,000*5 times a year Confirmation Wipe Sampling

EROSION CONTROL Synthetic erosion control, place and remove hay bales

DEED RESTRICTIONS Legal Research, Coordination with government officials

HEALTH AND SAFETY EQUIPMENT PDR 1000 rental (exterior) PDR 1000 rental (interior) Miscellaneous PPE (interior) Miscellaneous PPE (exterior)

UNITS

C.Y. C.Y. S.F. S.F.

property

ton

month year

property property property property property property property

year property

month

LS

month month month month

QUANTITY

89 134

8,046 160,920

149

6,556

36 3

128 128 128 128 128 128 128

2.5 128

36

1

36 30 30 36

UNIT PRICE DOLLARS

$60.42 $33.39 $0.12 $0.33

$22.00

$50

$4,500 $250

$25.50 $1,000 $250 $50 $20 $64 $38

$5,000 $155

.

$100

$90,000

$570 $570 .

$3,870 $3,870

TOTAL COST DOLLARS

$5,402 $4,478

$966 ' $53,104

$3,278

$327,800

$162,000 $749

$3,264 $128,000

$32,000 $6,400 $2,560 $8,192 $4,864

•

$12,500 $19,840

$3,600

$90,000

, $20,520 $17,100

$116,100 $139,320

Subtotal - Capital Cost $9,813,654

58 AR100943

TABLE 4 SELECTED REMEDY C O S T S ' Alternative S4 and D3 ~ Excavation to Clean Soil Depth, Consolidation for

Transportation to and Disposal in RCRA Subtitle C or D Landfill And Specialized Cleaning

Site Name: Price Battery . • / Site Location: Hamburg, PA

ITEM DESCRIPTION UNITS QUANTITY

Contractor Fee (10% of Capital Cost)

Legal Fees, Licenses & Permits (5% of Capital Cost)

Engineering & Administrative (15% of Capital Cost)

Subtotal

Contingency (25% of Subtotal)

TOTAL CONSTRUCTION COST

PRESENT WORTH O&M COST

TOTAL PRESENT WORTH COST

PRESENT WORTH COST

Discount Rate: 7%

UNIT PRICE DOLLARS

TOTAL COST DOLLARS

$981,365

$490,683

$1,472,048

$12,757,750

$3,189,437

$15,947,187

$9,313

• $15,956,500

' Assumptions used to calciilate costs may be found in the Final Interim Feasibility Study Report for OU-1, dated May 27, 2009.

59 AR100944

/

RESPONSIVENESS SUMMARY PRICE BATTERY SUPERFUND SITE

OPERABLE UNIT 1 RESIDENTIAL SOILS

BOROUGH OF HAMBURG, PENNSYLVANIA

OVERVIEW

On June 10, 2009, EPA announced the opening of the pubHc comment period and published its Preferred Altemative for the Price Battery Superfund Site ("Site"), Operable Unit 1 ("OU-1"), Residential Soils, located in the Borough of Hamburg, Berks County, Pennsylvania. EPA established a 30-day public comment period to accept comments on its Preferred Altemative.

EPA held a public meeting on June 18,2009, at 7:00 pm at the Hamburg High School, Large Group Information Room, in Hamburg, Pennsylvania. The purpose of the meeting was to discuss the Interim Remedial Investigation ("RI"), Interim Feasibility Study C'FS"), and Human Health Risk Assessment ("HHRA") prepared for the Site and to discuss EPA's Preferred Altemative for QUI. The public meeting was attended by EPA, the Pennsylvania Department of Environmental Protection ("PADEP"), Pennsylvania Department of Health ("PADOH"), the Agency for Toxic Substances and Disease Registry ("ATSDR"), EPA consultants, and local residents. This Responsiveness Summary documents public comments on the Proposed Plan expressed during the public comment period and provides EPA responses to those comments.

No written comments regarding EPA's Preferred Altemative were received during the comment period. However, as anticipated, EPA received several letters, emails, phone inquiries, and walk-ins, from residents that have reconsidered their participation in the EPA cleanup and have opted to have their properties tested and/or remediated. These individuals, however, did not submit comments on the Preferred Altemative. Therefore, this Responsiveness Summary only addresses questions and comments raised during the public meeting.

Comments From the Public Meeting held on June 18,2009

These comments were collated from the Certified Transcript of the Public Meeting for the Price Battery Superfund Site by Sargent's Court Reporting Services, Inc.

1. Comment: Is there any possibility that there is contamination and pollution in the air we breathe that hasn't been tested for?

Response: In the beginning of the residential removal actions which began in 2003, air sampling was conducted to evaluate the potential for lead-contaminated dust from yard excavation activities to migrate off the property. This air sampling inclucjed high volume air sampling in downwind areas from the excavation activities, as well as air monitoring at the residential property line, and personal air sampling on the contractors performing the work. The results of the air sampling did not indicate levels of lead in the air of any potential concem. As a result, the high volume air sampling and personal protective

60 AR100945

sampling was discontinued; however, air monitoring at the residential property line continues to ensure the protectiveness of the cleanup activities. In addition, EPA strives to have zero visible dust emissions from the excavation activities during the removal of contaminated soil. EPA's contractor uses water suppression as a means for controlling dust if visible emissions are evident.

2. Comment: The dates provided for the operational history and ownership of the Price Battery Site are not correict. If the dates are incorrect, how do we know if the remainder of the factual information provided regarding the lead contamination is correct?

Response: The commenter is partially correct. EPA maintains that the operational dates of the Price battery facility are correct, including operation of the secondary lead smelter from approximately 1940- 1971. However, the dates of transfer of ownership between Price Battery, General Battery, and Exide were misstaited during the public meeting.

Nonetheless, irrespective of the property transfer and ownership dates, battery production did occur at the plant from the 1940's to approximately 1995, and a secondary lead smelter did operate at the former facility from 1940-1971. The battery recycling and smelter operations resulted in the deposition of airbome lead particulate in residential yards and other areas within the Borough of Hamburg and the surrounding vicinity, including the disposal of battery chips and casings at various locations in and around the Borough of Hamburg.

3. Comment: Will the Registry of homes EPA is proposing providing to the Borough of Hamburg affect the sale of our homes and will it place a homeowner in jeopardy if we do not participate?

Response: EPA does not believe that the Registry itself will negatively impact residential property owners who do not participate in the sampling and cleanup efforts. Homeowners are required under Pennsylvania real estate law to make disclosures about contamination on their properties in certain circumstances. Furthermore, real estate brokers, buyers, and mortgage lenders are becoming increasingly aware of the locations of contaminated areas and Superfimd sites in general. Attracting buyers and securing mortgages may be difficult for unremediated properties. The Registry will provide an additional control to ensure that unsuspecting buyers are aware of possible lead contamination of a property. It will also allow those who do participate to demonstrate to a potential buyer that their property has been cleaned.

4i Comment: If you had the soil tested and the inside of the house tested and you declined the first time, can you come back and say you want it done?

Response: Yes. EPA's encourages all residents to participate in the cleanup and will also include residents who ultimately reconsider participating in the cleanup. EPA will also make an effort to provide all non-responding residents a second opportunity to participate in the cleanup. However, if a resident continues to decline participation or

61 AR100946

continues to be nonresponsive, once EPA's residential clearlup effort is completed in Hamburg, responsibility for cleanup of the property will fall on the homeowner.

5. Comment: Do soil lead levels fluctuate a lot? If a home was previously sampled on the interior, will EPA come back and take another sample or will they use the same sample results?

Response: Soil lead levels will not tend to fluctuate to an appreciable extent unless the soils are physically disturbed by erosion, tilling, or filling and grading activities. However, interior dust levels will tend to fluctuate over time based on a number of factors including how much lead continues to be tracked into the home by foot traffic or pets and how often the floors are vacuumed, wet mopped, or shampooed. Depending oh the amount of time that has elapsed from when the original interior samples were taken, EPA may consider resampling the interior. Resampling of residential interiors will be done on a case-by-case basis.

6. Comment: The area rugs EPA sampled were brand new. How did they get contaminated?

Response: Lead dust within the home from the Price Battery Site is a result of lead being tracked into the home from the exterior soils. Even though a carpet may'be brand new, foot traffic from the yard on the carpet may deposit lead contamination onto the carpet. Carpets tend to act as dust reservoirs and trap and hold the lead contaminated dust.

7. Comment: Why is it that one yard has lead and the one next door doesn't? How do you come up with that?

Response: Lead contamination may not be consistent from one neighboring property to the next, and such a pattern of contamination is not unexpected. There can be considerable variability in lead concentrations in surface soils. Modification of soil in residential yards resulting from filling, grading, tilling, or other activities can either cover or dilute surface lead contamination

8. Comment: A commenter noted the activities occurring at the former Exide facility. What will be done with the property? Are you planning on tearing all the concrete up?

Response: Exide is currently conducting a RI/FS at the facility property and other Exide-owned properties. The RI/FS will determine the extent of the contamination at the property and evaluate options for cleaning up the contamination. Until the RI/FS is complete and a separate Proposed Plan and ROD issued for the facility property, it is too early to tell what the cleanup option for the property ultimately will entail. There is a high degree of interest in reuse of the property, and any cleanup option selected would take into consideration fiiture use of the property.

62 AR100947

9. Comment: My home was already tested and I have been awaiting a cleanup. If the area of concem continues to expand, where does my home then fall with respect to a cleanup?

Response: EPA has prioritized the cleanup of residential properties based on two criteria. Homes with resident children under six years of age and pregnant women receive highest priority for cleanup.,. The remaining homes are prioritized based on highest-lowest lead contamination in the yards. There are instances, however, where the exteriors of lower priority homes are cleaned up if they border a higher priority home undergoing a cleanup. Although this approach may result in longer wait times for homes with lower lead contamination levels in the yards, EPA believed it was the fairest approach. EPA plans to continue this method of prioritizing homes for cleanup.

10. Comment: Is the "safe" blood lead level for a child going to be lowered?

Response: Evidence indicates that blood lead levels below 10 |Ag/dl could cause adverse health effects in children. EPA is contemplating lowering the standard for acceptable lead levels in blood from 10 )ag/dl to a range of 5-10 jig/dl. Studies indicate there are adverse health effects to children with blood lead levels in this range. Although no final decisions have been made with respect to lowering the acceptable blood lead levels at this

• time, there is the probability that they may be lowered in the future.

EPA encourages parents with small children to have their child's blood lead level tested. For the past several years, the Pennsylvania Department of Health ("PADOH") has annually sponsored blood lead testing for children less than 5 years of age. EPA encourages parents to take advantage of this blood lead testing when it is offered.

11. Comment: If a home was tested and found to contain elevated levels of lead and the home was subsequently remodeled; what are the chances that the home still is contaminated? *

Response: EPA cannot definitively answer this question. Homeowners are often under the misconception that remodeling, including the removal of carpets and/or other flooring surfaces, will remove the lead contamination. However, this may not necessarily always be the case, especially if appropriate dust control techniques and cleaning methods are not employed. Such techniques include sealing off" rooms with polysheeting to ensure lead dust is not transferred to adjacent rooms, HEPA vacuuming, and wet washing with TSP detergent during and after the remodeling is complete. Furthermore, if your yard contains elevated levels of lead from former operations of the Price Battery facility, and your yard has not been cleaned up, lead contamination will be tracked back into the home possibly recontaminating new carpets and floors above acceptable levels. The only way to be sure if your home is "clean" even after remodeling is to have the home retested for lead contamination.

63 AR100948

12. Comment: A commenter noted that their child had elevated blood lead and the commenter stated that the child is now having behavioral problems. What do I do for him? Where do I go?

Response: PADOH recommends children with elevated blood lead levels be followed by their primary care provider. The Childhood Lead Poisoning Prevention Program provides the following services in conjunction with your family doctor for children with elevated blood lead levels: referral for diagnostic services and medical treatment; investigation of lead hazards in the homes of lead-poisoned children; technical assistance to property owners and local health officials regarding the remediation of lead-based paint hazards; and education regarding lead poisoning. You may contact the PA Lead Information Line ("LIL") at 1-800-440-LEAD (5323) for more information.

In addition, the Pennsylvania Department of Health's Special Kids Network is available to assist families to address barriers and challenges families experience when trying to get needed services for their children with special health care needs. Family Health Nursing Services Consultants work with families and communities to help build better and more coordinated services for children and youth with special needs. Parents can contact Pennsylvania's Health and Human Services Call Center to be connected to a Consultant toll-free at 1-877-986-4550, TTY 1-877-986-5432.

13. Comment: A commenter noted they thought funds were running out for the cleanup and asked if additional funds were granted for additional cleanup.

Response: EPA has secured funding to continue residential cleanups under removal authority through October 2009. Once the ROD is issued, the Price Battery cleanup will be eligible to receive remedial action fiinding. EPA expects that fiinding will be available beginning in 2010 to continue residential cleanup activities.

14. Comment: Will the transcript of the public meeting be made available?

Response: The transcript will be made available to the public as part of the ^ Administrative Record for the Price Battery Site. The transcript and Administrative Record will be available for risview at the information repository located at the Hamburg Public Library and EPA Region III office in Philadelphia. The Administrative Record and transcript will also be available online at www.epa.gov/arweb.

64 AR100949