SDMS DocID 2196104

ADV^CED /XeoServices TM

Engineering/or the Environment. Planningfbr People.

1055 Andrew Drive, Suite A West Chester, PA 19380-4293

tel 610.840.9100 fax 610.840.9199 www.advancedgeoservices.com

November 4,2013 2002-978-12

John Banks, Remedial Project Manager USEPA Region III 1650 Arch Street Philadelphia, PA 19103

RE: Revised Feasibility Study Report Exide-Owned Properties Price Battery Superfund Site Hamburg, Pennsylvania

Dear John:

Advanced GeoServices, on behalf of Exide Technologies, submits one (1) original and three (3) copies of the Revised Feasibility Study Report for the Exide-Owned properties at the Price Battery Superfund Site in Hamburg, Pennsylvania. The May 17,2013 Revised Feasibility Study Report was revised to address the United States Environmental Protection Agency's (USEPA) comment letter dated September 18,2013. For your convenience, the comment by the USEPA, the USEPA contractor, and the Pennsylvania Department of Environmental Protection (shown in bold) is followed by our response.

RPM COMMENTS

Comment: 1.

Response:

Comment: 2.

General Comment: The document should undergo a thorough editorial review. Numerous typos remain in the document.

A general review has been conducted and revisions to correct typographical and reference errors have been made.

Page 4-9; Section 4.2.3.1; first bullet: This bullet states that the existing concrete/asphalt cover over RAL soils is maintained as a cap. However, under Alternative S-2, on page 4-7, it states that the existing pavement and floor would be less than the 2 ft thickness recommended by PADEP (PA Code 288.234); therefore the action specific ARAR for capping would not be met unless provisions for demonstrating the acceptability of utilizing alternative cover systems are implemented. This same caveat should be used in Section 4.2.3.1 and anywhere else where capping is part of the alternative.

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Response:

Comment:

Response:

Comment: 3.

Sections 4.2.1.2 and 4.2.3.2 have been revised to indicate that the cover provided by the remaining pavement and floor would be less than the 2 ft thickness recommended by PADEP (PA Code 288.234) and the action-specific ARAR would not be met unless provisions for demonstrating the acceptability of utilizing alternate cover systems are implemented.

Reference to the non-residential standards is made in several other places.

This comment is unclear, and we request clarification on the revisions EPA is requesting.

Page 4-10, Section 4.2.3.1; 1st & 2nd bullets: The first bullet states that if below the PADEP non-residential statewide health standards the crushed material will be approved for reuse during backfilling and restoration activities. However, on page 4-12, it states that if concrete does not meet the 50 mg/kg for lead assumed in the BHHRA, the RAL must be recalculated utilizing the actual lead concentration to assure project PRGs are attained. These two statements seem contradictory. The RAL should be recalculated anytime the 50 mg/kg standard cannot be met.

Response: Section 4.2.3.1 has been revised to provide clarification. If the crushed material meets PADEP non-residential statewide health standards, the material will be reused during backfill and restoration. If the lead concentration in the reused crushed material is greater than 50 mg/kg, the RAL will be recalculated.

The BHHRA assumed clean imported soils will have a maximum lead concentration of 50 mg/kg lead and 15 mg/kg arsenic. This may be difficult to achieve.

Response: Based on our experience with fill sources in Pennsylvania, a maximum level of 50 mg/kg lead and 15 mg/kg arsenic in imported soil is achievable.

Comment: 4. Page 4-12; first bullet: This bullet states that confirmatory sampling will be conducted at the bottom of the excavation to determine that PTW is removed. In addition, confirmatory sidewall samples should also be taken to ensure that the lateral extent of contamination has also been removed. This should include excavation for PTW soils and

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RAL soils under the alternatives where RAL soils will also be excavated.

Response: Page 4-12,1st bullet has been revised to indicate that sidewall sampling will be conducted, except along the property line.

TOXICOLOGIST COMMENTS

Comment: 1. Section 2.2.4.3.3: A remediation goal for dibenz(a,h)anthracene in ground water should be provided in this section of the report.

Response: Section 2.2.4.3.3 has been revised to provide the groundwater remediation goal for dibenzo(a,h)anthracene of 0.029 pg/L (PADEP Act 2 Statewide Health Standard for Residential in a Used Aquifer with TDS less than or equal to 2,500).

Comment: 2. Section 2.2.5.2: The first bullet indicates that clean-up goals for sediment will be Concentrations equal to or greater than 35.8 mg/kg lead, 9.79 mg/kg arsenic, and 3 mg/kg antimony, or the site-specific value defined during EPA's Risk Assessment for Kaercher Creek, whichever is greater." Shouldn't the word "greater" in this sentence be replaced by "lower?"

Response: The original language is correct, and language in Section 2.2.5.2 has been clarified.

Comment: 3. Section 2.2.5.3: Restoring ground water to beneficial use should be listed as a remedial action goal. The first bullet should be revised, as follows: "Establish Institutional Controls to prevent the use of Site ground water for drinking water until remediation goals are met."

Response: The language in the bullet has been revised. A remedial action goal has been added to maintain or restore and maintain, as appropriate, beneficial uses established under applicable laws, where such uses are affected by on-site conditions.

(Note: A Comment 4 was not provided in the letter.)

Comment: 5. Section 2.3.2: EPA is still a bit uncomfortable with the method used by Exide to establish Remedial Action Levels (RALs) for soil. EPA suggests requiring the recalculation of exposure point concentrations

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Response:

(EPCs) after soil excavation is performed. Data points for the EPC calculations should include confirmatory samples collected subsequent to excavation, as well as historical sampling data (minus RAL exceedances).

Section 2.3.2 has been revised as requested to indicate that EPCs will be recalculated after soil excavation and that confirmatory soil sample and historical sampling data (except data that exceeds RALs) will be used in the calculation.

Comment: 6. Section 2.3.4: In addition to ensuring that "overburden ground water not being utilized as a potable source and that impacts do not extend beyond the Site boundaries," the Response Actions for PAHs at MW-2 might also include active treatment (in-situ chemical oxidation). The last sentence of this section should be revised to reflect this.

Response: Section 2.3.4 has been revised to indicate active treatment might be a component of Response Actions.

Comment: 7.

Response:

Section 2.4.2.2: The first paragraph indicates that ground water monitoring would be conducted to "ensure impacts to ground water observed during the Phase II ground water sampling are not worsening or expanding." More than not "worsening or expanding," a reduction in ground water contaminant concentrations is the ideal goal, which is verified through monitoring. This should be acknowledged in the report.

Section 2.4.2.2 has been revised to indicate the ideal goal of improving groundwater conditions.

Comment: 8.

Response:

Comment:

Section 3.2: The last paragraph discusses importing clean soil with a "maximum lead concentration of 50 mg/kg" as a component of Alternative S-4B. Will analytical data be provided to confirm that lead in the fill material does not exceed 50 mg/kg?

Section 3.2 has been revised to indicate that analytical will be conducted on imported clean soil and documentation will be provided.

Section 4.2.1.1: In the discussion of potential risks for each of the parcels, if the Hazard Index (HI) exceeds 1, the risk drivers should be identified.

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Response: Section 4.2.1.1 has been revised to provide the risk drivers when the Hazard Index exceeds 1.

For the Warehouse Parcel, there is no mention of non-cancer risks for Office Worker 1 and Office Worker 2. Was the HI for each of these receptors less than 1? If so, that should be stated in the report. If not, the respective His should be provided, along with the associated risk drivers.

Response: Section 4.2.1.1 has been revised to indicate that the Hazard Index is less than 1 for the Office Worker 1 and Office Worker 2 at the Warehouse Parcel.

HYDROGEOLOGIST COMMENTS

Comment: 1. The WP and Response to Comments addressed EPA's comments from the draft document. EPA will need to approve the locations of the new wells, the drilling specs and sampling protocols.

Response: No response required.

BTAG COMMENTS

Comment: 1. The revised document includes appropriate revisions that address the BTAG concern that contaminated sediments have a high potential for migration from the site causing unacceptable risk to downstream aquatic biota.

Response: No response required.

PADEP COMMENTS

Comment:

Response:

Comment:

Response:

Regarding AG's response to our comment 1 - their response is acceptable.

No response required.

Regarding AG's response to our comment 2 - their response is acceptable.

No response required.

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Comment: 3.

Response:

Response:

Comment: 4.

Response:

Comment: 5.

Response:

Comment: 6.

Response:

Response:

Regarding AG's response to our comment 3 (relating to Section 2.1.5 [now 2.2.4.1.5], Capping Requirements) - AG's response to the first part of comment 3 is acceptable.

No response required.

AG's response to the second part of the comment is acceptable in the cover letter, however, in the text of the feasibility report, AG references the incorrect Residual Waste Regulatory citations and therefore does not fully address our comment (in the revised Feasibility Study Report, AG references §288.422 and 288.432, whereas our comments applied to §288.423, 288.523 and 288.623 which relate to the leachability of the waste proposed to be placed and what type of liner system is therefore required.) We therefore recommend that AG revise the relevant paragraph in the report.

A reference to 25 PA Code 288.423,288.523 and 288.623 have already been provided in Section 2.2.4.1.5,3rd paragraph in addition to 288.422 and 288.432. No revisions are required.

Regarding AG's response to our comment 4 - their response is acceptable.

No response required.

Comments 5-7 were HSCA comments, therefore we defer to HSCA.

No response required.

Regarding AG's response to our comment 8 (relating to Table 2-1): a. AG's response to our bullet 1 is acceptable.

No response required.

b. AG's response to our bullet 2 - their response is acceptable.

No response required.

c. AG's response to our bullet 3 - is partially acceptable. The Table now includes a reference to the PA Residual Waste Regulations, Chemical Analysis of Waste as being Applicable. However, comments indicate they are not triggered for

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Response:

Response:

Comment:

Response:

Comment: 8.

materials that are managed within an AOC and are applicable to off-site disposal only.

This is not accurate, as the waste analysis is needed to determine teachability of waste and therefore what Residual Waste LF capping standards to apply. Characterization of waste, under the Residual Waste Regulations is also applicable for on-site deposition (consolidation) of waste in an AOC as the Residual Waste regulations are independent of the Hazardous Waste regulations and the AOC policy and should therefore be applicable.

Exide would plan to classify any hazards reflected by the site materials in designing the cap so that the appropriate capping standards of the Residual Waste rules are considered. That classification process is not expected to include any added testing beyond the work already conducted in the RI/FS. Since the materials are to be managed within an AOC, no new wastes are being created which might require additional testing in connection with the intended management. Table 2-1 has been revised to indicate that 25 PA Code 287.54 and 271.611 are applicable to consider capping standards for on-site disposal.

d. AG's response to our bullet 4 - acceptable.

No response required.

AG's response to our comment relating to Table 2-3 is acceptable.

No response required.

Page 2-14 Section 2.2.4.3.3: Groundwater: First Paragraph: The statement "The point of Compliance is established as the property boundary..." should read "The point of Compliance is established at the property boundary..."

Response: Section 2.2.4.3.3 has been revised as requested.

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CDM COMMENTS

CDM Smith's Specific Comment 14:

Section 3.3 Development of Alternatives - Groundwater, p. 3-3 (of September 30, 2011 FS Report). The description of Alternative GW-2 indicates that impact to groundwater is limited and that any soil removal activities, if selected, would result in the removal of soils with the greatest potential to impact groundwater. However, the RALs are based on achieving human health exposure point concentrations, not preventing soil to groundwater migration, meaning a significant volume of contaminated soil could remain at concentrations that impact groundwater. Considering the exposure of groundwater to contaminated fill and the downward gradient of groundwater flow, the development of an extraction/treatment/discharge or in situ treatment alternative may need to be considered for groundwater.

Exide's Response (p. 17 of 30 of Revised FS dated May 17, 2013) to CDM Smith's Specific Comment 14:

We stand by our statement that removal of soils with the highest contaminant concentrations will reduce the potential for site soils to impact groundwater. Given the limited impact to groundwater observed in shallow groundwater samples from current conditions, the potential for future impacts is expected to be even less. We have added an active groundwater treatment system in the form of In Situ Chemical Oxidation (ISCO) to address the SVOC impacts observed in MW-2 in one of the two rounds of groundwater sampling completed during the RI.

New Comment to Exide's Response to CDM Smith's Specific Comment 14: Exide's response does not fully address the concern raised in the original comment. The impact to groundwater issue may be more complicated than that assumed by the FS authors. Especially if in situ chemical oxidation (ISCO) is used as a remedy to address semi-volatile organic compounds (SVOCs), the following adverse impacts are plausible: • Lead, when oxidized, could result in lead oxide (PbO), which has a

significant aqueous solubility (50 miligrams per liter (mg/1) in alpha form; and 106 mg/1 in beta form). Thus, residual lead levels in soil that may otherwise be presumed acceptable after the removal/excavation of soils with the "highest contaminant concentrations" may have impact to groundwater if subjected to ISCO.

• Hexavalent chromium (Cr+6) in groundwater samples has been found to be less than 5 micrograms per liter (pg/l) at the site. However, given that Total Cr in soil ranges from 1 to 100 milligrams per

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kilogram (mg/kg), the oxidation of trivalent chromium (assuming all Cr is in the form of Cr+3) to Cr+6 as a result of ISCO is a distinct possibility, which in turn would increase the prospect of Cr*6 mobilization and thus impact to groundwater.

Thus, if a treatability study is undertaken to evaluate ISCO as a remedy for SVOCs, the impact of lead and chromium mobilization should be thoroughly investigated.

Response: Initiation of any active groundwater remediation alternative to address SVOCs when SVOCs have only been detected in one out of two sampling events in only one well is probably premature. The commenter is correct that there are inherent uncertainties regarding all effects an injected agent might have when applied in a field setting. Care must be taken to avoid making groundwater conditions worse. Section 3.3 has been revised to indicate that if a treatability study is undertaken to evaluate ISCO as a remedy for SVOCs, then the impact of lead and chromium mobilization by the oxidation process will be evaluated. Such a treatability study would be carefully crafted to test predicted adverse effects that such reagents might have. However, unanticipated and undesired effects are always possible.

CDM Smith's Specific Comment 15:

Section 4.2.2.1 Description of Alternative S-2, first bullet (Components), second sentence, p. 4-6. The second sentence indicates the future excavations will be restricted to areas where soil contaminant concentrations are below the RALs. According to the FS, RALs, which are significantly higher than the PRGs and RBCs, were developed to achieve PRGs and RBCs for the overall exposure unit (e.g. main parcel). However, because potential exposure via digging is location specific, it would appear that the contaminant level cutoff would need to be the PRG or RBC, would it not? If so, the area to be restricted via ICs may need to be re-considered.

Exide's Response (p. 18 of 30 of Revised FS dated May 17, 2013) to CDM Smith's Specific Comment 15:

The BHHRA included evaluation of post-remediation acute risks for a construction worker with one-day exposure to the maximum concentrations remaining after lead remediation. Non-cancer risks were below the target HI of 1 for all COCs with exception of antimony. The HI for antimony were 5,2, and 4 for Main Parcel A, Main Parcel B and Warehouse Parcels, respectively. However, the antimony risk is overestimated due to the use of the chronic RfD since an acute RfD was not available. Thus, it is very unlikely that a construction worker would experience any adverse effects from a one day exposure to antimony in soil in any of the exposure area.

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New Comment to Exide's Response to CDM Smith's Specific Comment 15: Exide's response does not fully address the stated concern. In the response, the FS authors are deferring to the findings of the Baseline Human Health Risk Assessment (BHHRA) for a 1-day worker exposure. However, this approach does not address the potential exposure to workers if the construction/excavation work was longer in duration.

Response: While short-term (e.g. 1 day) exposures may occur at a location of maximum concentration, longer-term exposures are assessed by averaging over a larger exposure area that is expected to be contacted during the duration of a longer-term project. These exposure areas were defined after a hot-spot analysis which separated out part of the Main Parcel where concentrations were highest and evaluated the hot-spot separately (but using the same methodology as the other areas). None of the other parcels had distinct hot spots. The hot-spot analysis ensures that averaging is not done over too large an area such that the high concentrations are inappropriately averaged out. The assumption of construction worker exposure (100 days per year) and utility worker exposure (10 days per year) in the designated hot spot area provides a reasonable worst case scenario for exposures to higher concentrations of COCs for periods longer than the one day assumption for acute exposure. The lead RALs were calculated separately for each parcel (exposure area) for Office Worker, Construction Worker and Utility Worker scenarios, and the lowest value was chosen, therefore the RAL would be protective of all scenarios (including in the hot spot area). The average and maximum concentration of non-lead COCs were evaluated after the lead RAL was applied. The "post-remediation" averages for arsenic and antimony met the RBCs, and the maximum concentrations were used in the acute exposure evaluation, where risk was also found to be acceptable.

CDM Smith's Specific Comment 23:

Section 4.4.4.2 Compliance with ARARs, last sentence, p. 4-39. What is the basis for the statement that Alternative GW-2 may eventually meet the ARARs as they relate to SVOCs at MW-2?

Exide's Response (p. 4-35 of Revised FS dated May 17, 2013) to CDM Smith's Specific Comment 23:

Compliance with ARARs - There are no action-specific or location-specific ARARs for groundwater Alternative GW-2. The chemical-specific ARARs discussed in Section 2.2.4.3.3 would not be met initially, and may eventually be met as they relate to SVOCs at MW-2 as a result of source removal and natural attenuation as documented by groundwater monitoring.

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New Comment to Exide's Response to CDM Smith's Specific Comment 23: The response on page 4-35 of the Revised FS is vague. In the statement, "The chemical-specific ARARs discussed in Section 2.2.4.3.3 would not be met initially, and may eventually be met as they relate to SVOCs at MW-2 as a result of source removal and natural attenuation as documented by groundwater monitoring", what does "eventually" mean here? Is there a projected timeframe for the natural attenuation process to lead to the ARAR compliance with respect to SVOCs? This bullet (on pg. 4-35) should be rephrased.

Response: Section 4.3.2.2 has been revised to delete 'eventually'. Additional language has been added to explain that SVOCs were identified in only 1 of 2 sampling events that the consistent presence of SVOCs should be determined through additional groundwater monitoring, and that natural attenuation may already be occurring.

CDM Smith's Specific Comment 25:

Table 2-3 Chemical-Specific ARARs. Standards and criteria related to groundwater and protection of the watershed should be added to the table [(National Primary Drinking Water Standards Maximum Contaminant Levels (MCLs), Maximum Contaminant Level Goals (MCLGs), Guidelines for Groundwater Classification Under the EPA Groundwater Protection Strategy, Guidance Manual for Groundwater Monitoring (PA), Pennsylvania Water Quality Criteria].

Exide's Response (Table 2-3 of Revised FS dated May 17, 2013) to CDM Smith's Specific Comment 25:

Table 2-3 has been revised to include standards related to groundwater.

New Comment to Exide's Response to CDM Smith's Specific Comment 25: Table 2-3 has been updated to include the National Primary Drinking Water Standards (MCLs), Maximum Contaminant Level Goals (MCLGs), Pennsylvania Water Quality Standards and the Pennsylvania Water Quality Criteria. However, Table 2-3 has not been updated to include the Guidelines for Groundwater Classification Under the EPA Groundwater Protection Strategy (EPA/813R88001) and the Pennsylvania Guidance Manual for Groundwater Monitoring. No explanation has been provided for the exclusion of these two standards/requirements.

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Response: Table 2-3 has been revised to include tbe Guidelines for Groundwater Classification Under the EPA Groundwater Protection Strategy (EPA/813R88001) and the Pennsylvania Guidance Manual for Groundwater Monitoring.

CDM Smith's Specific Comment 26:

Table 3-1 Soil Remedial Technologies and Options. The purpose of this table is unclear. If it is meant to serve as a summary of the screening of remedial technologies and process options for effectiveness, implementability and cost, it is more appropriately placed in Section 2 and should be revised to eliminate references to the specific soil alternative IDs. (S-l, S-2, etc). In addition, a reference to the presumptive remedy guidance for metals in soil should be included if the assembled technologies were limited to those identified as presumptive remedies in the guidance. On the other hand, if the table is meant to serve as a summary of the assembled alternatives for effectiveness, implementability and cost, it is appropriately placed; however, the first two columns should be replaced with a simple list of alternatives' ID and title. Additionally, the sediment alternatives should be broken out into a separate table.

Exide's Response (Table 3-1 and Table 3-3 of Revised FS dated May 17, 2013) to CDM Smith's Specific Comment 26:

Exide has responded to this comment by making the requested changes to Table 3-1, as well as broken out the remedial alternatives for sediment in a separate table, Table 3-3.

New Comment to Exide's Response to CDM Smith's Specific Comment 26: On the revised Table 3-1, under column 2 "Description", for Option S-3, there appears to be a typographical error. The word "off-site" does not make sense in the phrase "Place off-site deed restrictions to limit/control disturbance of RAL soils".

Response: Table 3-1 has been revised to delete 'off-site' as requested.

EDITORIAL COMMENT

Comment: A thorough proofing of the document is warranted before finalization. For example, section and subsection headings in the Table of Contents do not match the respective headings in the document in a few instances. In addition, table numbering (at the top of each table) should be verified and corrected as needed, especially across all Table 1-Xs. Example: Table 6 on

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page 254 of 374 (of the pdf version of the FS Report dated May 17, 2013) should be Table 1-6.

Response: A general review has been conducted and revisions to correct typographical and reference errors have been made.

This addresses the comments contained in the USEPA comment letter dated September 18,2013. We look forward to your approval to proceed.

Sincerely,

ADVANCED GEOSERVICES CORP.

Jennifer W. DiJoseph, P.E. Associate Project Consultant

Paul G. Stratman, P.E., P.G. Senior Project Consultant

PGS:vm

Enclosures

cc: M. Love

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