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Whitmoyer Laboratories

Jackson Township, Pennsylvania

EPA Proposes Change for Soils Cleanup

EPA is proposing to change the cleanup plan for soils at the Whitmoyer Laboratories Superfund Site (the site). EPA proposes to take organically-contaminated soils off site for treatment and place a two-foot cover of clean soil on the site instead of an impermeable cap. This soil cover would allow rainwater and melted snow to seep through the soils, carrying any remaining arsenic into the groundwater where it will be captured by the groundwater extraction wells. This captured water is pumped to the on-site treatment plant, where it gets cleaned. Because this process would remove contamination from the soils that are in the water table (saturated soils), EPA proposes to leave these saturated soils in place.

Originally, EPA decided to excavate the saturated soils down to the bedrock, treat soils contaminated with organic chemicals on site, and cover the site with an impermeable cap.

If EPA's proposal is adopted, the cleanup of the entire site, excluding groundwater, could be completed in two years. EPA will hold a meeting and public comment period on this proposal.

Public Meeting

on EPA's Proposed Change
July 13, 1999 at 7:30 p.m.
Jackson Township Municipal Building
Conference Room
60 North Ramona Road
Myerstown, PA

From our readers...

Q: What is organic contamination?

A: Organic compounds are composed of naturally- occurring substances such as carbon, hydrogen, nitrogen, and oxygen. Organics can be animal- or plant-produced or synthetic. Organics at this site include: benzene, tricloroethene (TCE), pyrene, and aniline. More information about site contaminants can be found in the public files listed on page six.


Groundwater Zones & Soils

Groundwater is fresh water from rain or melting ice or snow that soaks into the soil and is stored in the tiny spaces between rocks and particles of soil. Groundwater is found in two zones. The unsaturated zone is immediately below the land surface. It contains water and air in the open spaces, or pores. The saturated zone is a zone where all pores and rock fractures are filled with water. The top of the saturated zone is called the water table. Underneath this zone is bedrock, a solid rock surface. The saturated and unsaturated areas are the location of soils mentioned in this proposal.

Soil Contamination Levels

Throughout this document, you will see references to soil- contamination levels. These levels were established in the 1990 ROD, and are based upon how much arsenic is present in the soil. Although there are other soil contaminants present, there is a large quantity of arsenic. If we address the arsenic, we will also reduce other contaminants to safe levels in the process.

The arsenic in the soil requires treatment. The soil exceeds the leachability test, which measures how much contamination seeps out of the soil and into the water within a specific timeframe.
The arsenic level is greater than 450 particles in a million soil particles. However, this soil passes the leachability test and does not require treatment.
The arsenic level is between 21 to 450 particles in a million soil particles. This soil does not require treatment.

What Else Changes?

The rest of the soils cleanup plan would remain the same. EPA would still require the following:

EPA's Original Plan

EPA's decision on how to address soil contamination is outlined in the December 31, 1990, Record of Decision (ROD) for Operable Unit Three (OU-3). A ROD is a legal document that formally states EPA's chosen cleanup plan for a site. Operable units are clusters of site work. This ROD for OU-3 included these approaches: excavating groundwater-saturated soils, treating soils contaminated with organic contaminants on site, and constructing an impermeable cap.

Why Do Something Different?

Whitmoyer Proposed Plan June 1999 Page 2EPA is proposing this change to the ROD because additional information about the soils was discovered during engineering and planning work for the cleanup (Remedial Design). The Remedial Design is an engineering phase that generates additional information used to develop technical drawings and specifications for the cleanup work.

Site Studies Revealed More Information...

Specific information acquired during the Remedial Design included:

...and More Concerns

This study raised several serious concerns, including:

30-Day Public Comment Period

You can let EPA know what you think about the proposal during the 30-day public comment period beginning June 30, 1999 and ending July 29, 1999. During that time you can mail your comments to EPA at the address on page six. No decisions or changes will be made until after the comment period ends. Once the comment period closes, EPA addresses issues raised during the comment period. EPA will present its proposal at a public meeting on July 13, 1999. All community members are invited to attend and participate.

EPA's New Proposal

EPA, in consultation with the Pennsylvania Department of Environmental Protection and the Whitmoyer Laboratory Private Study Group, has developed an alternative approach (Alternative Remedy) which includes:


Under EPA's new proposal, soil excavation work will require the temporary diversion of the Union Canal into the Tulpehocken Creek. This temporary diversion is not expected to permanently impact the Union Canal & Lock or the Tulpehocken Creek. The heavily-contaminated and organically-contaminated soils are located primarily on the site, with several areas immediately adjacent to the Union Canal. All of the off-site excavation areas would be immediately backfilled and restored to their original grade.

Moderately-contaminated unsaturated soils located off site would be excavated to the water table and brought onto the site. As in the 1990 ROD, the excavation areas would be backfilled with lightly- contaminated or clean soil, covered with two feet of clean soil, and restored. Once on site, moderately- contaminated soils would be re-graded and covered with two feet of clean soil. As originally planned in the 1990 ROD for OU-3, the soil cover would be re- vegetated, monitored and maintained in order to protect against subsidence, erosion, and other factors which may threaten its integrity (or stability). This cap will be restored as necessary on a periodic basis. Deed restrictions will continue to be required for all areas where contaminated soil remains.


The approach to sediment contamination would remain the same. The OU-3 ROD calls for excavating sediments adjacent to soil cleanup areas when the levels of sediment contamination meet or exceed the excavation criteria for moderately- contaminated soils. Sediment samples will be collected from the canal bed after the Union Canal is temporarily diverted. This sampling information will supplement existing sediment data and will be used to determine the extent, if any, of contaminated sediments requiring excavation.

Evaluation of Alternatives

There are two alternatives:

1. Excavate heavily-contaminated and moderately- contaminated soils to the top of bedrock; treat and dispose heavily-contaminated soils off site; consolidate moderately-contaminated soils under an impermeable cap; and biologically treat soils contaminated with organic contaminants. This is the course of action described in the 1990 ROD.

2. Excavate soils to the top of the water table, removing only unsaturated soils; consolidate moderately-contaminated soils on site under a two- foot cover of clean soil; treat heavily-contaminated soils, as necessary, and dispose of them at an off-site facility; and treat soils contaminated with organic contaminants at an off-site facility. This is the new proposal.

OU Three (Soils and Sediments)(1)
Comparison of Original Plan and EPA's New Proposal

Contaminant Type / Location

Original Plan

New Proposal

Heavily-contaminated soils (Unsaturated, on-site and off-site) Unsaturated soils are found above the groundwater.

Excavation, on-site treatment and off-site disposal.

Remains the same(2).

Heavily-contaminated soils (Saturated, on-site and off-site) Saturated soils are found below the groundwater level, or, top of the water table.

Same as above.

Treatment via the ground water pump-and-treat system, two- foot clean soil cover, deed restrictions.

Moderately-contaminated soils (Unsaturated, on-site)

Excavation, consolidation on- site in vadose zone3 under an impermeable cover, backfill of excavated areas, deed restrictions.

Treatment via the ground water pump-and-treat system, two- foot clean soil cover, deed restrictions.

Moderately-contaminated soils (Unsaturated, off-site)

Same as above.

Excavation, consolidation on- site under a two-foot soil cover, treatment via the ground water pump-and-treat system, backfill of excavated areas, deed restrictions.

Moderately-contaminated soils (Saturated, on-site and off-site)

Same as above.

Treatment via the ground water pump-and-treat system, two- foot clean soils cover, deed restrictions.

Lightly-contaminated soils (on-site and off-site)

Cover with two feet of clean soil, deed restrictions.

Remains the same.

Sediments (on-site and off-site)

Cleanup where soils adjacent to creek or canal require cleanup, according to methods and criteria of moderately- and heavily- contaminated soils.

Remains the same.

Organically-contaminated Soils (Saturated, on-site and off-site)

On-site bioremediation followed by treatment of arsenic- contaminated soils according to criteria and methods above.

Treatment via the ground water pump-and-treat system, two- foot clean soil cover, deed restrictions.

Organically-contaminated Soils (Unsaturated, on-site and off-site)

Same as above.

Excavation, off-site treatment (as necessary), and disposal.


1 Site cleanup work is grouped into smaller, more manageable units, known as Operable Units (OUs). As part of a change in approach for the lagoons (OU's Three and Five), the areas once known as the "excavated lagoons", were included in the remedy for soils. This change moved work on the "excavated lagoons" area from OU Five (lagoons) to OU Three (soils and sediments). EPA cleanup decisions are formally outlined in a legal document called a Record of Decision or ROD. This change to the ROD, described above, is documented in the Explanation of Significant Difference (ESD) dated November 16, 1998. ESDs detail changes in EPA's cleanup approach and how they vary from the plan originally detailed in an existing ROD.

2 As part of the November 16, 1998 ESD, the remedy for heavily-contaminated soils was changed to allow soil treatment to happen off-site, rather than on-site. As this change has been accepted by US EPA, it is not addressed by this new proposal.

3 Vadose Zone: The zone below land surface and above the water table. This area's moisture content is less than saturation, so all spaces between soil and rock are not filled with water.

Both remedies reduce the risks associated with coming into direct contact with contaminated surface soils. The 1990 ROD protects the groundwater by excavating saturated soils to the top of bedrock and reducing contaminant movement from the unsaturated soils to the groundwater by constructing an impermeable cap. The new proposal relies on the natural movement of groundwater, rainwater, and other precipitation through the soils in order to leach the arsenic and other contaminants from the soils to the groundwater.

The top of the water table has significantly lowered as a result of continual groundwater pumping that began in April 1998. As a result, almost all of the heavily-contaminated soils are located above the current water table. The proposed changes should enhance and hasten the overall removal of arsenic from the soils. We would evaluate technologies to see if there are methods that can increase the movement of arsenic from the soils into the groundwater, thus speeding the cleanup of soils and groundwater.

Under both alternatives, the most highly- contaminated soils would be treated and disposed of at a secure, off-site facility.

Long-Term Effects

Under both alternatives, long-term risks are associated with arsenic in the soils, since metals cannot be destroyed. The original plan calls for an impermeable cap. This cap would reduce the amount of arsenic reaching the groundwater in the short-term, but would not reduce the mass of arsenic at the site over time since most of the arsenic would remain under the cap. Further, clean soils used as backfill in the saturated zone would become contaminated by contact with the groundwater. Future site use would be limited due to the significant increase in elevation at the site and the need to maintain the impermeable cap.

The new proposal would be more effective in the long-term. The soil cover would allow precipitation to seep through the soils, allowing arsenic to move to the groundwater. There, it would be captured by the groundwater pump-and-treat system, and then be removed from the site. Because saturated soils would not be excavated, clean material would not become contaminated by groundwater after backfilling. Future use of the site would be more flexible because of the lower elevation and the increased options with a soil cover (compared to the impermeable cap).

Time Schedule

We estimate that the original plan can be carried out within a five-year period. This is the time needed for effective biological treatment of soils contaminated with organic chemicals, and also for the extensive excavation and backfilling. The new proposal can be carried out in approximately two years. The time needed to restore the groundwater is not expected to significantly differ with either the original plan or the new proposal.


EPA estimated the original plan would cost $27.2 million (1990). However, actual costs to implement the plan could approach $35 million when adjusted for inflation as well as the increased volume and depth of moderately-contaminated saturated soil. We anticipate that the new proposal would result in a cost-savings between $15 million to $20 million.

Proposal Support

The Pennsylvania Department of Environmental Protection assisted with developing the new proposal and supports this alternative approach. Recent discussions with the current owner and local officials indicate that it is very likely that a majority of the site would be converted into a recreation area. Many of the proposed changes were discussed during previous public meetings and were favorably received by the majority of citizens present.

This summary is not a legal or technical document. The new proposal to change the way soils are addressed is formally described in a legal document called a 'Draft Amendment to the Record of Decision for Operable Unit Three'. A copy of this draft legal document is available in public information files kept at the following locations. These files contain copies of the RODs for Operable Units One, Two, and Three, plus documents that EPA used in making its cleanup decisions. The files are also called the "Administrative Record", and are available here:

Myerstown Community Library
199 North College Street
Myerstown, PA 17067
(717) 866-2800
M, W, Th. - 12 to 8
Tu, F - 12 to 6
Sat. - 9:30 to 12

U.S. Environmental Protection Agency Region III
Administrative Record Room, 6th Floor
1650 Arch Street
Philadelphia, PA 19103
Please contact Anna Butch for an appointment.
(215) 814-3157
Weekdays - 8:30 a.m. to 4:30 p.m. 

EPA Contact

If you have any questions or want to be added to EPA's mailing list for this site, please contact: (800) 553-2509 or (215) 814-5528 Lisa Brown, Community Involvement Coordinator

Additonal Comment Period Information

A public meeting to discuss the proposed Amendment will be held on July 13, 1999, at 7:30 p.m. in the Conference Room at the Jackson Township Municipal Building. A stenographer will be at the meeting so that you can make your comments orally, if you'd prefer. A public notice announcing the start of the comment period will be published in the Lebanon Daily News. The 30-day public comment period runs from June 30, 1999 to July 29, 1999. Comments should be postmarked by July 29 and sent to: Christopher J. Corbett, RPM (3HS22) U.S. EPA, Region III 1650 Arch Street Philadelphia, PA 19103

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