NUSWASTE MANAGEMENT SERVICES OROUP

i ONE DEVON SQUARE, sum aaa . July 13 , 1990; 70« WEST LANCASTER AVENUE MTTC -Q/an f\^AO }| WAYNE. PENNSYLVANIA 19067 ' «UO*y y\J \J4*kO x /I (8101071-0900 No Response Requiredi • ' / . . " - ' ' '1 Hs. Deborah DewsburyI U.S. Environmental Protection Agency| Region III - .| 841 Chestnut Street; Philadelphia, PA 19107

SUBJECT: REM III PROGRAM - EPA CONTRACT NO. 68-01-7250WHITMOYER LABORATORIES SITELEBANON COUNTY, PENNSYLVANIAADMINISTRATIVE RECORD DOCUMENTS - OPERABLE UNIT TWO

Dear Ms. Dewsbury;s

As per the request of Mr. Dappolone of your office, please findenclosed the documents which were cited in the Whitmoyer Laborato-ries Site Remedial Investigation and Feasibility Study reportswhich are not generally available. These documents are beingforwarded for inclusion in the Administrative Record for the site,and should be placed in the record prior to completion of theRecord of Decision for Operable Unit Two. I am not sure if Mr.Fred McMillan of your office is aware of these documents1 exis-tence. As they may contain enforcement sensitive information,please make him aware of their availability.

If you have any questions or comments regarding these documents,please contact me at (215) 971-0900.

. -Very truly yours,\

tf•v »%-o 1 •fohn Jf I're nowski, PESite Manager

JJT

Attachments

cc: T Dappolone - EPA Region III (w/o attachments)G Latulippe - NUS (w/o attachments)D Brayack - NUS (w/o attachments)

File: W.A* No. 200-3LC9 (1S17/563)

•oflR30379l

C. ff. tihitaoytrreal 4. EiMlbergr

; , Clena Tro*t, _ , lf 1965.

\- _X . . • • : - • •

, .. . ' - Hr. tosi Xatxl •' -• ' • ' • \ i ' ' " ' ' ' ' '

• ' • • •' ',.'.. . ** *• *• Clauser ' ' , "

tfucc Solutions Other Than Ax ealc learlag Which Are Obtained Ac The tfhi&aoyer flaat

la addition to tbt artvmie btarla? «&rte cohieivM vblch «• will cruck c» tb« OCAJOeh* VhieaoyM* plat prodocM tti« feUovl&g

« Thlt «re« kt* »«n report by H. Sufftucn.

** toilAt vmttas frca tt *v»r»£« ef fifteen Wn each day vhicfa dl»cb«rrrf to •Mpcie tank wst of the ;trts«. tha g«ra;r« also 1« u»d so vuh an crtr«f» «f >c«ocrueka *ach 4ay. All cba azaga drain* dlschargt co a aoap ac eha hjrdraulie lift

la ua cd out to

Coctrol labgr«toTy*"» All t&a analytical vtitu flov Co a c*«»jw:ol vaat ofbullrftajt. Water ajpirator* ara tutd to tupply Taonja aod they alao aiiebar&a totha eaaspool. About 1.000 alloaa «f aolatloa a 4ay la 4Uchar*ad. .

I luildla* 'S A— Shower facilities era used by abovt sixty eot?loye«s each day. This| solution discharges to tha sto«* severs which discharge to the creek. Toilet facilitiesI ( ,- ia the eaae locker rooa, flow to a ssptlc tant which orcrflovs to s cesspool.; , V x - . . . • • , - . . .

5B— A small wash bowl aside of the second floor office connects to the :

5 C-* About tea caplayeea uaa a urlaal and waah bovl which discharge* toa cesapool «aat of ttw a«co*d floor office,

r 3 A— OUT two voaea eaployaea UM the toilet and wash bowl la thla araa.These facilltiaa dlacharsa to a ae tlc teak *oid« of tha canal.

5utlditi*> 1 A-« Xaad vtvhlata aad alao .Trocaa* v»Jte aol&cion obtained la the•esuiactvra of FIT-EM, ClfSATUTt (coal tar dip), liaiaeata, olataaata* etc., are

to a nap. Thla raap Is periodically pttaped out to the lacooas*

2 A end B— About 1,500 iallcnj of aolutioa a aonth la obtained from thedacx-waah aad ra&etiiratioa ef an if on exchange snlt ualac cauatUt and ourlaelc acliiProceaa washlaps obtained in the Batmfactcre of piperaziae, MOte»> etc* aolatioaa

N : •• - - •- •

(Coatlaued)

March 1, 1965 .. . - ' : . . . . • . . '

Mr. Too lezzi

Mr. a. L. Clauser ' .

Haste Solution* Other Than Arsenic Bearing Which Are Obtained At The tfhitmoyer Plant

are also obtained in very snail volqm. these washings are being druontd fordisposal in tho lagoons while the BM. exchange solution vill be dischargeddirectly to the ground away from the lagoons.

Coal Shed— About 200 gallons per day of low boiling pi per a tine aotaft type eoepotmdsare. obtained for about four days each week. This solution It dumped into oneof the lagoona. *,£* ~~p~t*i.. A v-*-£ w'-~*- e~f -*s-e* ?&. ,

" • ' * A • ™*»w». 'Boiler blov dovn and water •oftner solution fron rock silt «nd Nalco t« dliekmrgedfrom the coal ihed to the <-re«k.

X. 1. Clauser

SLC:« ' ' • ' ' '

^ fr /

(J

SR303793

DATE STAMP

. " . '•'•' MEMO '

WHITMOYER LABORATORIES, INC.MYERSTOWN, PENNA, U. S. A.

PO»» April 16, 1971 .

To Wr. F. Dengler — -- ,

From Mr. J* M. Kauffman

CC.

W. P. AfflbroglH. 'M. HuffmanR. R. LashWaste Material Fil

Subject: - ANALYSIS OF FERRIC SULFATE STUDY FROM LAGOON

A sample identified only as "Ferric Sulfate" dated March 26, 1971which was taken from a Lagoon on the Whitmoyer property has beenfound to have the following analysis:

Sample« as is , ; '. , • • _ ,

Total Arsenic* X 2.2 ' . .Inorganic Arsenic, X 1,4Organically Bound

• Arsenic, X (.by difference) 0,8

Calcium, X 3.6 ,Loss on Prying, X 53.9Iron, X 10.7pH 3,0

Dried Solid . •

Total Arsenic, X 4*6Calcium* X 6.7Iron, X 19.8''

Filtrate ''':'- '

Total Arsenic. X 0.0024 . . , , , -

Assuming that all of the arsenic is tied up with the iron as the insolublearsenate Fe3 (AsO K, that the remainder of the iron Is present as thesulfate Fe (SO )., chat the calcium Is present as CaSU^ the following computationscould be postulated which yields coincidentallv, or otherwise, 100X account-ability: '

Fe2 (S04) 3 20.8XFe3(As04) 2 13.1*CaSOA 12.2XWater 53.9%

100.0

JMK/mh

o' »OH« «nd HAAS COMPANY

John K. Kauf fman

- i

* \

DATE STAMP

* WHITMOYER LASOKAiwww, WNW.MYERSTOWN, PENNA, U. S. A.

Dot. October 5, 1972

To Mr* T. lezzl

From >**• p* A. Dengler

W. P, Ambrogi -'. .IT. M.;:Huffman,>;- |

• . '." ' V- -.(:,•- .

Subject: SUB-SURFACE ARSENIC MATERIAL BALANCE ., : •

i . • • ' " : " • • ' • • . " . . . • ' " • . • 'Pounds of Arsenic Acid Purchased Pounds of Waste

Year ' ___At 75% a ______.____ Arsenic Discarded

1957 169,000 66,8901958 283,000 112,0111959 480,000 189,984I960 1,055,000 417,5691961 ' 1,851,900 733,0221962 2,736,000 1,.082,9091963 2,819,200 1,115,8391964 - 3,431,000 . 1,357,9901965 3,015,100 * None1966-lst qtr. 933,900 ' None

Purchased from Abbott*s 288,46157364,675

Consumed Arsenic in Finished Products ———————— 1,234,000(Theoretical. Yield)

T7130,675

11.' (DDAA)

Approximately 2000 drums filled and put into storage. .With arecovery of 87,480 arsenic.

III. Sold as Kem-Gro pure and 50% - 7,986 arsenic.

IV. Calcium salts placed in concrete holding bin.•

Calcium Salts - 15.2% As (wet)735,876 pounds of arsenic

V. Removed by watex treatment

434,467 pounds of arsenic. .

SUBSIDIARY Qf ROHM and HAAS COMPANY

fl«303795

SUB-SURFACE ARSENIC MATERIAL BALANCE ,.w- ^, . . . . . . - -, -^ BB fc — . • - . *^L _ ( i*v

Page 2 " ' . ' .';"•"• v XJ- .-,•* j.

Passed Downstream (Estimated by yearly waste storageaccumulations).

Year _p/p.m ', Pounds of Arsenic

1957 '' " 2.0 43,8001958 -. . . 4.0 " 87,6001959 6.0 . ' 131,4001960 14.0 306,600 <1961 15.0 328,5001962 20.0 438,0001963 ,25.0 547,50019,64 3.0*0 657,000 '1965' 1.0 21,9001966 (First Quarter) 0.5 • . 2,4621966 through 1972b , , _________

2,564,762i • _ ' ' • ' _Summary of Material .

A - -.- Total Purchases —————— ••• ————————— 5,364,675\ - ' ' • ' •B - - Consumed in Whitmoyer Products - — ; —— 1,234,000

C - - Total Arsenic in Waste—— —— .- ————— 4,130,675"

. D - - Drummed as DDAA '-; ——— .--——-* —————— P. 87,480

: '-'• :: * . ' 4,043,195 ' ,

E - - Sold as Kem-Gro -—----—— —————— 7,986. ' - ; ••- .. . ... ,- 4,035,209

F - - Placed in .Holding Bin (Estimated) —— 735,876, ; - 3,299,333.

E - - Removed by Water Treatment ————— '— 434,467

, 2,864,866

II. •« Passed .Downstream -- —— • — —— -- — • —— 2,564,762

I. - Remaining — — : ——————— " ———————— 300;104' ' ' . ' • ' ' ,

• •a Today's Arsenic Acid is purchased at 84 to 85% arsenic.

b Passed downstream 1966 through 1972 'approximately two pounds per dayexcept during direct well discharging. Direct well discharging istigured in Section (E) Water Treatment.

'

Frantz A. DenglefFAD/rjw . Safety Director .

30379

DATE STAMP

MEMO

WHITMOYER LABORATORIES, INC.MYERSTOWN. PENNA.. U. S. A.

Dot* December 30, 1975 -.

To -Mr* F. A. Dengler

From Mr. L. J. Croesus

CCi

•

J. Gallagher

*Subject: STORMWATER DISCHARGES TO CREEK

Attached is a preliminary listing of values since the.October 9th incident, which was reported as 4 Ib. of arsenicentering the Creek. The December 3 result suggests theremay have been some"additional arsenic deposited on the roofsince October.

The Bldg. 17 tank, to the best of this writer's knowledge,has not been.sampled by production personnel at any time.The tank is also not being drained to any point. .The* tankneeds to be normally empty in the event of a purge even ifit means sending rainwater directly to the creek most of thetime.

The Bldg. 16 result suggests we have additional problems.

-&JVCLloyd JviCroesus

LJC:lcb ., , .* . . *r

Attachments

SUBSIDIARY OF lOHM'r* HAAS COMPANY AR3Q3797

PLANT ROOF DRAINS RUN-OFF

'Date Location Timo Tot. Ars. (mg/1.) pH

10-9 nidg. #7 Spouting 1335 16,840. 4,5(Pipe #9a)*

' 10-10 „ Bldg. #7 Spouting 0830- (composite)i,719. 6.8(Pipe 19a)* 1349

> i • , . • . . . . . . ; • -10-26 Bldg..17 Tank - 238,

10-31 Bldg. #7 Tank . 88.

11-12 Bldg. #6 (Pice #12)* 1410 35.2 7.31• > ' . - ' * .

11-12 Bldg. #7 (Spouting) 1359 ' 39.4 7.23(Tank) , 1359 7.1 7.11

1 ] 11-14 Bldg. #7 Tank . , 0 9 3 0 , . . 0,93 7-2^- ^ ' ' • • ' . ' * ' . • . * • - ' . ' • . • ' " ' ' ' . .

12-3 Bldg. #7 Tank ,. '. °853 19-4 7.05' "'".**/• ' " • • '.-•'•'

A *•* * ..

*See Attached Sheets

- ' .

DATE STAMP

Date

To

From

WHITMOYER LABORATORIES, INC. MYERSTOWN, PENNA., U. S. A.

February 11, 1976

Mr. F, A. Dengler

Mr, L. J. Croesus. .' O

Subject: WHITMOYER PLANT GROUNDWATER MEASUREMENTS - 1975

The following divides the plant into 4 areas and attempts tosummarize all work done during 1975 in relation to groundwater.

I. Lagoon Area:

A new drawing of the plant site was made in June by alocal registered surveyor, Gary T. Matthew, see Fig. .1.Elevations of the lagoon walls have been added to thedrawing and monitorir? holes labelled with referenceelevations, see Fig. II. Attached also, (Fig. Ill), isthe drawing made in 1973 which contains lagoon dimensions.Additional dimensions can be taken directly from Fig.II using the scale 1 inch * 50 feet. Fig. IV containsall the measurements which were taken to show the relation-ship of varying water levels at different locations.Water analyses from these same locations are compiled onFigs. ' V. through VII. Because of the recent problemswith the Western Berks Water Authority*, Fig. VIII isincluded to note iodide concentrations in plant ground-water. A single soil sample was also taken on 5-27-75 fromthe floor of lagoon 17 by Mr. Dengler. The clay underthe ferric arsenate layer was found to contain 3.1%total arsenic. Considerable problems were encounteredwith Well II involving electrical shorts in the pump andthe physical d-tangement of the plumbing.

II. Bldgs. 13 and 111 Area - Cellar Sump Pumps

The attached Fig. IX. summarizes ail available recentdata on these waters. Waters are presently pumped fromBldg. Ill into Bldg, 13 and from there into Well 14with a valved by-pass to send the flow, in part orentirely to lagoon 16 during flood conditions. Flowsgoing into Well 14 have i been mete red, (comp. values on Fig.IX) 8 '

November 1975 60,466 gal. (does not include 1st 12 days of mo.)December 1975 88,511 gal.January 1976 66,663 gal. (does not include last 6 days of mo.)

SUSStDIARY OF IOHM *nd HAAS COMPANY

AR303799

WHITMOYER PLANT GROUNDWATER MEASUREMENTS - 1975

III. Serial »001 Cooling Water Discharge to Creek Area

The standpipe immediately next to the concrete mixingchamber for Serial f001 was'sampled 7-8-75:

pH. » 10.9Tot. Ars. « 8.90 mg./l.

An oily residue was noted along the creek bank 15 yardsEast of Serial 1001 the following day and analyzed:

pH - 7.15Tot. Ars. - 19.0 mg./l.

Several days later, a pipe end was located near the aboveresidue, protruding from the bank. The pipe had a*terminal valve lacking a handle. This valvewas opened on 7-17 long enough to take a sample of theslurry which was leaking from it. An analysis of theslurry follows:

» 6.77- 3.43

Total Ars. of Solids » 12.60%Total Iron of Solids - 31.35% • *• . .Total Ars. of Liquid »400.0 ppm

A re-sampling of the standpipe on 7-19 indicated:

pH « 8.95,Tot. Ars. - 9,14 mg./l.

Per Mr. Dengler's orders, the valve was removed, the, pipe plugged with hydraulic cement and buried.

IV. Sewer Sample Station Area

The few samples from this area varied greatly, but werefor the most part in the neighborhood of several hundredmg./l. This is evident from Fig. VI, Well 17 analyses.For the above reason, we particularly can not afford anyinfiltration into the sewer system in this area, althoughwe know it occurs in M*H. 12. Ground water levels weremeasured and described in the attached Memo of 3-14-75.

LloydfJf Croesus

LJC:lcb

Attachments .flR303800

-J U

Wb.. < * ..-iS Ijj a S- -S'| OL . S. .CO <^f * «as 4. ^W UJ *n >i>* o

___ r"*. W 3H ^^ 3 U

& f~} " i 5* 5 \ _^ -J < b.— /""""s ' */PS ( Jr. * —X ..

og <• « I -g3 I ,° 2 S—I u. Q ps

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AR30380I

' '• - -'.vt is.- ': •*!• • •••'i"&*H /.. • m ' /->,:•';•.''... •.••Sv!lfe.''*»'J ••/'''"«.'.L*.A1.•Xi'st...'1!

: • i - : . < « w . - > M t s , •;- • W;-> ^

DELAWARE CONTAINER CO., INC

REF *: 6146, Report Requested: 9/22/37, Completed: 10/8/87Generator: Whitmoyer Laboratories* Inc. '.Street Address: 99 S. Fairlane AvenueCity, State: Myerstown, PA 17067EPA ID »: PAD 003005014Manifest * (if applicable): N/A .Generator's common name for waste: Com Flush tl8 (Comp. #3)

Analytical Parameter Results

- Physical State 9 70* F , Solid- Phases . One- Color Yellow »1- Specific Weight* 1.37 $/cc- pH * 70°F , 3.80- Silver, Ag. Leach'able, mg/1 <.01- Aluminum, Al, Leachable, mg/1 0.4-; Arsenic, As, Leachable, mg/1- 6;2 *- Barium, Ba, Laachable, mg/1 <10- Cadmium, Cd, Leachable, mg/1 .02 .- Chromium, Cr, Leachable, mg/1 .04- Copper, Cu, Leachable, mg/1 .10 .- Mercury, Hg, Leachable, mg/1 .04- Iron, Fe, Leachable, mg/1 .84- Manganese, Mn, Leachable, mg/1 .15-'Nickel, Ni, Leachable, mg/1 .09- Lead, Pb, Leachabla, mg/1 <0.1- Selenium, Se Leachable, mg/1 .01- Zinc, Zn, Leachable, mg/1 .25

Respectfully submitted,

DELAWARE CONTAINER CO., INC.

. Chuck StefanoskyLaboratory Manager

code: CusARF •

Ke«t Uth Avt. £ Valley 3d., Co««miU, ?i 19320 A R 3 0 3 flW

n^r™™™^-—— ---"••' ————— '-1 —— """"

*

DATE STAMP

MfMO ' ,

•' ' • VVMITMOyilR UHORATORO. INC -MYTO1OWN, PINNA, I/ 5.. A.

ftaio February 16, 1976 .

Trt " Mr. Tom Tezzl „'

from Mr, Fruntz A. Dangler*- '

.'•/""'

Of. D. C. Cl*Mr. H. M. Huf

Subject: WHITMOYER GROUND WATER CONTAMINATION, . • ' •" * •

Lloyd Croesus was assigned to the Lagoon Project which •.":'',]••consisted of measuring static ground water in and around the lagoon •' *'area at various measuring points. Figure IV Includes these •..','•:.'measurements. The purpose of the project (Phase I) was to determine :.,'•*;'If at any point, the static level of the ground water became , . -."elevated to a point that It reached into the floor.of the lagoons* ' •Observation Holes (OH on Figure No. IV) were dug to measure andobserve rain water and ground water adjacent to the lagoons. Theseholes could be considered the most important part of the project. . .They are also plotted on Figure No. 2 O.H. 12-SW had to be filled- '•in shortly after it Was dug because the walls continued to collapse.O.H. 7-S due to its loa£ion picked up run-off water from the warehousespouting which Is located to .the south of the hole* Therefore,water in the hole was in excess of O.H. 5-S and O.H. 5-E. Therate of perculatlon from O.H. 5-S and O.H.5-E as scene by the eyewas at a much greater rate than the ground water in neighboring .measuring points, ftius indicating there was free space for thewater to move out and on a downward flow. Actually, after aconsiderable amount of precipitation, the O.H.'s were dry beforesome of the Lagoon Holes (LH). Another problem which enteredInto the picture and continues to present a problem is that of thesump pump located in the Truck Garage. This pump dischargesground water flowing into the pit for the truck lift., To compoundthis situation, wash water from the truck wash-bay discharges intothe 'pit. The pit, is about ten feet below the floor surface. Thesump pump discharges Into Lagoon No*. 6. It has been discharging intothis lagoon since the garage was built in 1965. Additional surfacewater was added to the lagoons when we had to divert the sump pumpsfrom Bldg. 03 and 11 into the lagoons. This became ' necessary whenthe entire aquefor'"became saturated, and Well No. 4 started tooverflow. To summarize, hare1 appears to be enough perculation effectin the lagoon area even though extra amounts of water is added,thatis in addition to normal precipitation. Looking back to June 22,1972, when the Agnes Hurricane struck, the surface waters on the lagoon rperculated within ««~ days. How long it took the Water to filteroff the floor of th« lagoon is unknown. This, of course, is the criticalpoint, but normal or perhaps I should say, near normal conditionsreturned about 30 days after Agnes. If conditions equal to Agneswere to strike today, I think it is very unlikely that O.H. 5-=would Indicate that the aquefor reaches the floor of the lagc.i,.

We do see a need for a Interceptor trough to be trenched aroundthe entire lagoon area. The trough could serve two purposes. _ .,One being to prevent surface water from flowing onto the surface of , • .the lagoons, and second, the trough could act as a monitoring point > .•for water in an around the lagoon area* * ,•;'•; J

. ' A fe^flQfcflffSUBSIDMtY O* ROHM »r

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303806VIBMo •<•-••-

K. WATER RECEIVING TANKS Arsenic in Water

- ' . . / 'Pate ' Location Cone. As PPM \ j

j-3-76 Bldg. No, 7 Roof Drain Tank 5.88

1-27-76 Bldg. No, 7 Roof Drain Tank (pH 6.83) 3.68

2-17-76 Bldg, No. 7 Roof Drain Tank (pH 7.63) 5.65

3-10-76 Bldg. No. 7 Roof Drain Tank (pH 7.00) 2.85

6-30-76 Bldg. No. 7 Roof Drain tank (pH 6.8 ) 2.10 R.S.T.

7-6-76 Bldg. No. 7 Roof Drain Tank (pH 7.2 ) 8.10 R.S.T.

,7-9-76 Bldg. No. 7 Roof Drain Tank (pH 7.1 ) 2.90 R.S.T.

7.12-76 Bldg. No. 7 Roof Drain Tank (pH 6.8 ) 1.20 R.S.T.

7-19-76 Bldg. No. 7 Roof Drain Tank (pH 7.72) 14.20 R.S.T.

7-30-76 Bldg. No. 7 Roof Drain Tank (pH ) ' 1.0 R.S.T.

•9-21-76 Bldg. No. 7 Roof Drain Tank (pH ) 31.10 R.S.T.(Pumped into Dept. 8101) - ..

8-27-76 Bldg. No. 7 Roof Drain Spouting (pH 6.45) 12.64

9-10-76 Bldg. No, 7 Roof Drain Tank (pH 7.58) 5.0

9-13-76 Bldg. No. 7 Roof Drain Tank (pH 6.8) 11.1 R.S.T.

9-14-76 Bldg. Nof 7 Roof Drain Tank. (pH 5.4) 554

9-14-76 Bldg. No. 7 Roof Drain Spouting (pH 4.5) 1.28

9-16-76 Bldg. No. 7 Roof Drain Tank (pH 6.8) 40*5

9-16-76 Bldg. No. 7 Roof Drain Tank (pH 6.3) 15.9

9-17-76 Bldg. No. 7 Roof Drain Tank (pH 6,4) 35.1- '9-21-76 Bldg. No. 7 Roof Drain Tank (pH 6.6) 86.8

9-27-76 Bldg. No. 7 Roof Drain Tank (pH 6.9) 13.6

9-28-76 Bldg. No. 7 Roof Drain Tank (pH 6.8) 29.0

10-1-76 Bldg. No. 7 Roof Drain Tank (pH 7.4) 15.4 ^

10-4-76 Bldg. No. 7 Roof Drain Tank (pH 7.3) 2.rp -

10-8-76 Bid*. No. 7 Roof Drain Tank (pH ) 5.48>

,10-11-76 Bldg. No. 7 Roof Drain Tank (pH 7.5) 1.38

fl §.3.935fl .d Screen Test

Page 2; ' K« ' ' • '. ' '•• ' •' , • '• •

, WATER RECEIVING TAKKS Arsenic in Water

' . • ' . • : • . - • • . . - . \ ' . : . ' • , . ' . • , ' . . • . , • ..." ,-Date Location Cone, as PPM

10-14-76 Bldg. No. 7 Roof Drain Tank (pH 7.12) 18.4

10-25-76 Bldg. No. 7 Roof Drain Tank (pH ) 3.44

10-26-76 t Bldg. No. 7 Roof Drain Tank (pH 7,3) 1.04

11-1-76 Bldg. No. 7 Roof Drain Tank (pH 7.3) 1.278

11-29-76 Bldg. No. 7 Roof Drain Tank (pH 7.1) 2.78. ' , ; ' , " . .

12-7-76 Bldg. No. 7 Roof Drain Tank (pH 7.4) , Arsenic not run

3-4-77 Bldg. No. 7 Roof Drain Tank (pH 7.25) Conductance-78,8 umhos

3-14-77 Bldg. No. 7 Roof Drain Tank (pH 7.1) Conductance-79 umhos

3-16-77 Bldg. No. 7 Roof Drain Tank (pH 5.8) . Inorg. Ars.-65.0 mg./l.

3-18-77 Bldg. No. 7 Roof Drain Tank (pH 6,7) Rap. Ars. Scr. - 7.36 nig./l.

3-28-77 Bidg. No* 7 Roof Drain Tank (pH 6.85) Rap. Ars. Scr.-28,2 mg./l.I j (0820 hrs) , , •- 3-28-77 Bldg. No. 7 Roof Drain Tank (pH 7.2) Conductance - 227 umhos

(1230 hrs)4-4-77 Bldg. No. 7 Roof Drain Tank (pH 6.9) , Conductance « 267.3 unhos

4fl4-77 Bldg. No.7 Roof Drain Tank (pH 5.6) Rap. Are. Scr. - 430 mg./l.

4-25-77 Bldg. No. 7 Roof Drain Tank (pH 7.0) Rap. Ara, Scr. - 24.6 mg./l.

4-26-77 Bldg. No. 7 Roof Drain Tank (pH 7.1) Conductance - 519 umhos

4-29-77 Bldg. No. 7 Roof Drain Tank (pH 7.2) Conductance - 223 umhos

5-3-77 Bldg. No, 7 Roof Drain Tank (pH 6,8) Rap. Ars. Scr*- 80.8 mg./l.

5-9-77 Bldg. Na. 7 Roof Drain Tank (pH 7,1) Rap. Ars. Scr. - 32.0 mg./l.

5-18-77 Bldg. No. 7 Roof Drain Tank (pH 7.45X Rap. Ars. Scr. - 52.8 mg./l.

5-20-77 Bldg. No. 7 Roof Drain Tank (pH 7.1) Rap. Ars. Scr. - 22.4 og./l.

AR303808

WATER RECEIVING TANKS Arsenic in Water

pat% Location Cone. As PPM

*H303809

,

( j :V * .'

DATE STAMP

MEMO

WHITMOYER -LABORATORIES, INC.MYERSTOWN, PENNA., U. S. A.

Oof* February 24, 1970i' ' • • • • •

To Mr. T. lezzi

From Kr. F- A< Tjengler

-'v,'- ... .

CC: ' • " " ; " a.

. Mr. W. P. ArabrogiDr. J. B. GrahamMr. W. P. HigginsMr. F. Wv Robinson. -> t •y"/ >' Lx?^ /, ' r

Subject: MONTHLY OPERATIONS AND MONITORING REPORT - WASTE PERMIT'NO. 6681004 - JANUARY. . ' i . . " ' . ' . , ' V - . ' ' • ' " , •

Attached is the monthly report on the well discharge program. . .

On January 20th a small amount of suds was noted on the head waters (at thepoint of our well discharge) of the fire pond. Immediate action was taken tolocate the source of the suds. After sampling all the wells, only well fourhad any indication of suds. This well was turned off in order not to jeopard-ize the aquatic life. An investigation was conducted in and around the area of '••well four. It was learned that a transfer line to an aniline tank broke, causingabout eight hundred gallons of aniline water to get into the dike area sourth ofbuilding number six. Upon further investigation it was revealed that a mechanicaljoint in the dike's concrete wall had separated. Probably due to the extensivefreeze we had this month. The dike was •r.ptled of,its contents and the line re-paired. Temporary steps were taken to seal the Joint where the leak was. How-ever, warm weather must set in before a permanent seal can be made. Samplessubmitted to the lab from well number four showed the presence of minute quantityof aniline. It was decided not to discharge from well number four until further

' tests have been made. Control tests were conducted on gold fish using 10 - 20 &30% solutions from well four. A control test from C.W.W.E. was also used. Theeight fish (two in each test) were fed on a regular diet. All fish displayed nor-mal health habits during their test from 1-26-70 to 2-2-70. The test was dis-continued on 2-3-70. Well number four was turned on for one hour for two daysat which time stream conditions were strictly observed. After no adverse conditionswere noted the well was turned on for continuous operation. '

Aniline is organic and only trace amounts were detected, therefore, the continuous.operation of well four would not be harmful. Since the stream is loaded withmicroorganisms the aniline (In small quantities) would be biodegradeable. It isthe opinion of this writer, that the few dead fish observed in the fire pond werepinched beneath the ice and the stream bank. When we flushed out the pond theice caved in traping a few fish. When the water level was raised it released thedead fish. Twelve dead fish of three different species were counted..

• . . " ' . * ' Frantz A. Dengler

FAD/sfw ;

or *OMM «*d HAAS COMPANY flR3038IO

MEMORANDUMftOMM AND HAAS COMPANY , ,

To Mr. L. 0. Johnson

Prom 0. G. darksD«n Auaust 1 1 , 1976

COLICS TO CAM* ** .M WMJ

Or, L. E. Westkaemper FileMr, T. F. DeckerMr. F. A. Oengler 'Mr. J. 'GallagherMr. H. M. Huffman y*~\Hr. 0. J. King , j

Subject Evaporation of Paulsboro Waste

Uhitmoyer has modified Its waste concentration equipment to Increase capacityso that they can concentrate the Paulsboro waste and dispose of the solidsat Chem-Trol. They have added additional employees to extend the hours ofoperation of the equipment. .The process is now In the startup phase. Duringthis startup, a tube failed in the heat exchanger and this was being repairedduring my visit of August 6.

The changes to the system involved Installation of a carbate heat exchangertn. a fashion to permit Injection of the super heated waste Into the vapor •space of the two kettles allowing it to flash rather than boil from thesurface of the liquid in the kettle. This design Is to prevent the possi-bility of material purging through the vents onto the roof as happened earlierthis year, resulting In a spill to the creek. Foam or high level detectorshave also, been Installed In both kettles. High level or foam wi l l shut ofthe feed and sound an alarm. .

. As an additional precaution to prevent a spill, Uhitmoyer plans to directthese vents to a common kettle which will then vent to the atmosphere. Thiskettle will collect a purge should the other precaution which has taken fall/The kettle will be steam heated to keep condensation to a minimum. Anything; Jwhich collects In this kettle w i l l be recycled to the evaporator. Presently,^'the roof onto which a purge would fall drains Into a tank so that the purgecan be caught and returned to the system. .

The pH of the waste Is adjusted before It Is fed to tie up the aniline asa salt and prevent its loss as a vapor to the atmosphere. Samples of thevapor must be analyzed and dispersion results calculated under the routineevaporation rate expected. Mist eliminators are In the vapor lines fromboth kettles to prevent droplets of the process fluid from being entrained.

Uhitmoyer recognizes the possibility that a leak Into the steam side ofthe kettle or the heat exchanger w i l l contaminate the steam condensate witharsenic. The steam condensate Is recycled to the boiler from which thereis a blowdown to the sanitary sewer. In order to keep arsenic from enteringthe sanitary sewer via this route, the condensate Is tested hourly for chlo-rides which are of higher concentration than arsenic In the process fluid.The process will be shut down if the chloride exceeds 180 ppm. Uhitmoyerplans to combine all steam condensate from the arsenic department for testing

* "' before it Is returned to the boiler.

It was suggested that a routine procedure for checking the effectivenessof high level detectors should be set up, and Mr. Gallagher jndtcated thiscan be done.

As soon as the equipment is through the startup stage, Uhitmoyer will beginconcentration of the Paulsboro waste.

DGC:aern 0. G. Clarke

SHOECTICS m laa Bifcpitf ~> *».'''i ^ Y ; • ; -,./• ' • . '

:. lezzi, Bristol Plant SnrfronisentalControl. ManagerRohm and Kaas Delaware Valley,

, A .serious ground and surface water pollution problem was discovered in .the '

Vicinity of rerstown, Pennsylvania,', shortly after tihitmoyer Laboratories was

acquired as a wholly-owned subsidiary of Rohm and Eaas Company in 1964.. The

problem was the result of past practices of fryy3HTig and disposal of wastes

from the production of arsenical products. The subsidiary, with the aid of

the parent, company, undertook extensive measures to protect water from further

contamination and bring the pollution problem under control and solve it.

The Ifyerstown Plant of Uhitmoyer is located In l rerstown, Lebanon County,

Pennsylvania. It is situated along and in the head water reach area of the

Tulpehocken Creek, which is a tributary of the Schuylkill River*

i j At the time of discovery of the pollution problem, the plant employed aboutV—•/ ' ' • ". , • • • • . _' . •

90 people and manufactured a diversified line of pharmaceuticals and nutritional

products for poultry, livestock and feed industry. These products included

sulfur compounds, vitamins, feed additives and supplements based on arsenical

• . chemicals, ' . • . ,.' . . ' ' . 7

Vaste waters were treated with excess lime and was handled as a slurry for

disposal on the ground within an earthen diked area. The resulting arsenic

: wastes were primarily organically-bound arsenical compounds and calcic arsenate

and calcium arsenite.

The treatment and disposal practice was not effective. r Pollution of ground

ind surface waters resulted from the wastes from seven years of production of -

arsenical compounds. Hie amount of arsenic in the wastes produced during that

time was estimated at 4 minion pounds measured as total arsenic -

U°9 flR3038!2

polluticn,.problem vas •uncovered. by Rohm end Haas Company shortly

r Vhitmcyer vas acquired. Emergency remedial" measures vere taken to stop

October, 1964. vere 53 end 56 cf s respectively. Average arrml flov is around

200 cf s and the wrlwi flood flov vas mftasured at 9840 cf s on December 7, 1953.»*•The general, direction of the stream course follovs the east-northeast strike

of the carbonate rock formations underlying the area* Hie stream bottom

material vas generally of ailtation material, vhich is typical for drainage

from r carbcnata area* . '

Qxe geological formations underlying the area In the vicinity of the

Vhi'teoyer Plant are carbonate rocks of limestone' and dolomite, vhich dip to

the south about 30° from the horizontal. . . *\ \ O •

farther contamination and recover the contamination that elated. Extensive

studies, including ground vater end surface vater surveys, vere made and an

extensive monitoring program vas implemented.

The natter vas brought to the attention of the Division of Sanitary

Engineering of the Pennsylvania Department of Health (Note: vater quality

rypageaent is now under the Department of Environmental Resources). Full, ,

disclosure of the problem vas made knovn and a comprehensive clean-up and ,, . • *

control program vas also presented for review and approval. .After extensive

corroborating surveys and announcements to interested governmental agencies

and municipal vatar suppliers, the Department of Health made the pollution.

problem 3movn to the public through the nevs media.

Eia 'drainage area of the Tulpehocken Creek _ is 211 square miles and the

streaat. length is 33*5 miles vith an average bed. .slope of 0.0015. Average end

flcvs at the confluence vith the Schuyliill River during September-

AR3038I3

The plant is situated on the crystalline dolemitic Ontelaunee formation

£25 feet north of the contact "with the cherts limestone and dclocitic Spier' • ' • ' • ' ' 'formation boarding on the south and 1450 feet south of the high calcium

Ifcne stone tarriHe formation boarding to the north. , '• * . ' • • . . .

The water bearing properties of the Epler formation to the south is a

poorly permeable aquifer and that of the Ontelaunee f orsation, In general, is ,. • , • . •considered a highly permeable aquifer. Xhe properties of the Jtenville and • .

Kyerstovn formation further north is unknovn, but since they are high in' • ' . ' • \limestone content, relatively' large solution channels should exist and if

* * ' • . **penetrated by a veil, vater yields, cculd.be high. The Eershey formation 'still

further to the north is considered a poorly permeable aquifer* Thus, the peer. • / ' • " .' '••• •'-'•• \

vater bearing properties of the Eershey and Epler 'formations serve as containing

barriers for the ground water In the formations between. The vater bearing

strip thus- formed is variable in width but approximates one mile, Studies macs

r shoved that this strip was pinched cut approximately 6 miles douLstreen

at Vorelsdorf and that subsurface waters In toe strip would eventually core to

the surface at or before this pinch out. The municipal vater supplies, both

surface and veil water, for Kyerstcvn are located on the tight shaly and silt?' • ' • * ' . '

lies stone Eershey formation and out and above the reach of any contamination

from the pollution problem. - ; <

Thert 'are a amber of tear and thrust faults in the area which influence .

ttovement of subsurface vaters; 1 'tear fault is located 3500 feet to the east .

of the plant. Qte fault has an 800 foot horizontal displacement and, is 2-1/3 .

miles long trending, southeast to northeast to 'cut across the formations sectioned*• ' i • * •' '. ,

and to end in the Eershey formation. A 1500 foot long east-west thrust fault. '" ' ' .-" l - . • v

thrusting to the south, exists 1.5 miles e&st-northeast of the plant; and another

flR3038IU

CONFIDENTIAL-thrust- fault, eadsts 0.9 miles eas* of this fault vhich thrusts north and

south to encompass an oral shaped area having a peripheral length of 1.6• ' ' .miles, i number, of spring? are located in this area. .

2ie area has a gently rolling topography resulting from erosion' by the

Tulpehocken Creek and its tributaries. The trough or valley forsad'by this

erosion is located on the softer Cntelaunee, ianrilla and Eershey formations.

Eia valley vails to the north slope toward from the 450 foot elevation of the

creek at the pi pjt. site for a distance of about 0.6 miles to reach the 500 foot

elevation and to the south it is steeper, reaching this elevation vithin about.»

0 . 3 niles. ; . ' • • . ' ' • - .

Precipitation} vhich averages about 44 inches per year, is the source of

all ground vater in tha area. Recharge occurs to the carbonate rocks as the

precipitation infiltrates downward through the soil and* enters solution r'-a~"»' a

end openings in the beddirg planes. Joints and fractures as it flcvs over the '

surface of the rodcp strata. Ground vater levels respond sore rapidly is tie —-

yalley than en the valley ridges* Vhile there are some artesian veils in the

area, the" carbonate rocks are cne complex, aonhomogeneous aquifer and the vat«r

level in most veils is at or lover than the,vater table./ . ' ' *

Eie soil cantel averages 5 to 7 feet deep, in general, in the area. Since

the configuration of the vater table generally conforms to the topography,

ground vater movement flovs from the valley vails toward the valley trough*» . . 'and parallel to the eastward flowing creek. - Hovever, there vas also an

\ • ' 'vtstvard mcTemant in the vicinity of the plant. This .vas caused by a

'of the vater table by extensive and ccntisuous pinning operations to keep dry

tha 150 + foot deep Calcita Quarry located 1J* miles vest of the plant. 2a'amount of pulping of about 3-5COO gpm accounted for over 75 percent of tha flev-

going by tha plant, da vastward movement of ground vater .-

eastward movement resulted la a ground vater ridge in'the vicinity of tha plist.

. . AR3038I5

- — *".'* I l/rl f i..-5-

i Eais ridge shifted scmevhat depending upon paying operations, precipitation

I ) and the amount of .water movement from the valley walls. He major vector-'-cfi ^-^ . • 'A • ,- • . • . •f grpund water movement from the plant area was eastward, however, the unnatural\. , • • ' '• •'• ' ' ' ' ' ' • :, -I ' ground water ridge served to slow the rate of this movement.

I ' , The ground water as well as the surface water is of the calcium bicarbonate

I type and hard* Water softeners are In common use and fecal contamination of '

: wells in carbonate rock area is not unexpected and chlorinators or bottled

• water is used in some homes* .

| , Surveys were run on ground water and streams to determine the extent of

I contamination from the Whitsoyer plant as -veil as for base line informaticn to

assess the effects of our efforts to abate and solve the pollution problem. tie

• Tulpehocken Creek was sampled at various points along its length and the

•;" Schuyl dll Hiver was sampled above and'below the confluence at Keadizig, Grcurd

; v J -water samples were obtained by sampling >springs, quarries, ponds .and veils cf

residences and industrial establishments, including industrial discharges* -i

sampling points were along-the-general- course of-the Tulpehocken Creek. -7'-*;

was also done on the north and south Valley walls in the Myerstovn jrea. ?i"7<i'rg

in the Plant area included the' stream, bottom material from the north and scuth1 ,• ' ' t* ' -.banks of the stream as well as above'and below the plant. •

. 'The, initial survey confirmed our original cursory checks 'and visual• ' • ' ' " ' ' " • • • • ' , ' • " • ' ' ' • • < ' ; >

_ . observations and studies of the available hydrological and geological infsrzaUcz.. . .

' . ' . '

Figure I'is a reproduction of the original survey'map in reduced forn.' . . ' . , • •j. summary of the surveys follows: - " '. •, ' , ' . ; •.

. 1. The liquids icrolved in the disposal operations at the Uhitzoyer Flan?

reached both the grcund and surface waters.

2. The bulk of these--liquids, reached the Tulpehocken Creek . * "I J ' ' •• • • -" '•.'-'.-•:. • • . . ':'- mantel and the rock strata. The amount of total arsenic in -ue uuu.... v».j' • . - ' - •

estimated at 660 to UCO pounds per day. This movement was in a ncr htrly azd

easterly direction with an entry, greater on the s c t 4 ' : > A ^ cr-!*'> "Ja =

i ~ ?'???&',?fr:. I-U M•*}«-: t. 4 1 ;S» ... ;• k. * ? <V••-. ;.-;^^>- . >. •Z -i *i il •• £ * X*S -V '» i> •' ? ** r T*r * v "*ar .**" s. * *^ •« I. •»

» s

-4 r r >,— r— .j-i AJ"; y / .& f jn - S ;cH= -= v. •L.i. * ^'_ T' % ^ . X" I CR r rV-H^S cr» XJ.\

«• S(5! ^ r'lsSS / • &j : ±t-r>^g cxss-rrW-i.-. ?I tfGSZrrH?' iF«:>'>rx i t- - H S cr» xj. \ \ *v/3i£ 4,' i rI r 5^3 _ Xv1 .. - V-• V

S?52Cmi iA..:, ' Lg T: S .- /

* . -w ? ^ ^ *'«i5 »>* ^S^

u^ / • __--—:———'-' sHauaai?

-7- CONFIDEN i iAL--on the north tank. The waters in- the rock formations in the vicinity of

\ i the plfint vere under hydrostatic head producing springs of high arsenic*""~ . ' ' • ' , . . •

content - I960 ppm in one case -at or slightly above the surface of the

• - stream vater on'both the north and south side of the stream.

3. The liquid vas pert of the recharge to the rock strata belov;

possible the use of company-cvned abandoned veils as recovery veils vith

high yields of arsenic* Water from one well had an arsenic content of 11,100 p?r..

, 4. Movement of ground vater did occw in all directions from the plant site.

Westward movement of arsenic vas eventually established for a distance of" , , • * . '1.84 miles, southward movement occurred for a distance of 1500 feet; north-

vard movement for a distance of 1600 feet and eastward movement for a

distance of A.5 miles. , " ' ;, " ' '• '

5« Movement vas across the rock formations as veil as parallel to the bedding

> i • planes of these formations. .Also, movement vas across the tear fault to\*~>S ' " .• ' . , ' . • ;..; . . • ' -

the east which also served to distribute movement north and south along

the vertical contact faces of the fault. . V

6.. .Arsenic bearing waters did reach solution, channels in the rock formation.

the springs in the area of the thrust fault 0.9 miles east of the plant

contained 3*2 ppm total arsenic in the springs in the western section of

area and much lessor amounts In the eastward and northward sections.

7* Over 30 veils vere found to contain arsenic at various levels ranging frcn

about 0.01 ppm to 299 ppm;. the latter being a residence 840 feet vest-

southwest of the plant.

; 8. The area of the subsurface contamination approadffiateil-J- miles vide ty 6 '

'miles vide. < • . *"' '' • ..' • . . "<: L, 9. irsenic vas found along the entire course of the Tulpehocken Creek east cf

'*• _ . ' - |Jr , _ j - ** ~

\~ the plant and in the SchuyZkill River beloj the confluence

content diminished going dovnstream because of municipal industrial, '

1 ::;.-. flR3038!8

. ' •". '- - - ,, «l ,»«-«ll II >...._..«._ I ,„,., ,,lm , IL ,., ,,,|,I,,,,,

-*-=;•. U UMMiJhiM i !AL- ,'•tributary and ground water inputs. The content was 45 ppm immediately "

below the plant and downstream; 18*4 ppm at one mile, 8.7 ppm at 3.5

miles, 4.2 ppm at 6.8 miles, 1.54 ppm at 21.5 miles, 0.35 ppm in the ./""""**" ' ' J '•

Schuylkill River below the confluence and 0.09 ppm in the Schuylkill -x

above the confluence with the Delaware Estuary at Philadelphia.

10. The Tulpehocken Creek does serve to some extent as a source of recharge

to the ground water in some Incidences of use during dry weather.

Concern of the officials of the Health Department over this and extensive

corroborating survey data was mutual and cooperation was excellent. State

and Company officials worked around the clock to locate additional contaminated

wells. Official notices of contamination were issued by the Health Department

and alternate supplies of approved water were provided by the Company to those

with affected wells. An effective surveillance program was instituted which• , • - \included the monitoring of outlying private and industrial veil supplies and

surface streams and public water supplies. '

The presence of arsenic at levels above 0.05 ppm, was detected in 30 wells i 1

The drinking water1 standards then of the U.S. Public Health Service for

inorganic arsenic was 0.05 ppa allowable, and the World Health Organization

standard was 0.2 ppm. While organically bound arsenic and inorganic.arsenate

are relatively non-toxic compared to inorganic arsenite, all forms of arsenic

under the circumstances were considered as one for policy purposes and

operational decisions.

A core approach was used in attacking the problem. The clean-up work at

the plant crystallized into a three-pronged program Involving (1) the removal

and cleanup of the arsenical waste disposal sites to eliminate further

contribution to the contamination problem, (2) recovery and treatment of con-

taminated groundwater, and (3) the safe and orderly startup of arsenical

production on a no discharge basis in order to minimize the dislocation of' . ' - • ." •• . • < , / V -

the economy of the area. The program was operated on, an emergency.ha*,iv - * -. * \^ J

AH3033I9

.CO'NMUtiN NAL-Removal end clean-up vork v&s done aroxaad, the clock* Caere vere two

1 rinclpal areas of contamination to te removed. One vas the arsenic-bearing

Sludge from the treatment of vastes end the other vas the outside storage area

for a relatively insoluble vaste by-product vhich vas being held for later

recovery of arsenical material.

• , The sludge pile vas demobilised vith a coating of bentonite clay to ward

off rainfall, and surface runoffs vere directed around the pile until'' a vater-

tight reinforced-concrete vault vas constructed to receive the material for' •. • • . . , ' •

permanent storage.'"-The vault, measuring S31 z 123! x 12* high, vas completed

. vithin a 'month and a half. The yault vas coated inside and out vith a select" ' ' ' : • ' .

, vaterpropfing material and support columns vere provided for later installation• * • . x .' ' • • ' • • . • ' - - .of a sloping roof. In addition, the bottom vas covered vith a layer of sand -

for drainage to vertical stainless steel drav tubes for removing excess liquids• • • • - • . • ' ' . - - . ' .

"*br treatment-and stabilizing the slump characteristics of the deposited materials." ' • ' ;./ j • • "

Bae sludge pile vas transferred to the vault vithin 15 days including one to

tvo feet of earth under the pile , dovn to bedrock. -

- the outside recoverable material vas covered vith canvas and polyethylene

sheeting and the material vas repackaged into steel drums and transferred to an' . -' iV ' 'approved .dry storage area. Ihe underlying earth vas alsp skis&ed end deposited

. t i .

in the vault. An estimated p million founds vas recovered during the clean-up

operation. Eov irrirh of the balance of 1 million pounds remained in the subsurface... • .• .- • - ' /.: (.. , ./

vas unbaovn because .o*f the previous outflovs. However, ve deemed It prudent

to assume that 500,000 pounds remained and we operated accordingly., ' ' ' : . ; .

Concurrent vith the clean-up program; a treatment process vas perfected by

the Research Division of Hohm and S&as Company to remove arsenic frcm water in zhe

fcrm of an insoluble precipitate. The process involved the dosinp vith ferric

e at a ratio of about 2 parts of iron to 1 part of arsenic

pE to 6 to 7 vith lime. The process vas highly efficient, reducing the content• ' . . - " . ' ' ' ' tOC . •• . • ! - • . . ' • '

in thousands cf prm to around 1 ppm. AR303820

, ' . . - • ' -10-

To start off the subsurface arsenic recovery system, abandoned ccni

vails vere reactivated and Vaters were treated in chemical reaction kettles

of the arsenical department which was shut down until permanent treatment •

facilities vere constructed* the latter facilities, involving alternating

batch raring' tanks, vera completed in about a three-week period. Thereafter,

all of the recovered waters vere handled by this system on a continuous feed

•and treatment basis.' _ ' ' _ • • ' • •

.Ine plant is supplied water from.the Myerstova Water Authority, which

has its source in the unaffected aha1.* formation as icentioned before. On' " *. • • • ."' ' . . . • • - . •March 1, production was resumed after, the production facilities had been

revamped end self contained for operation' on a no-discharge, no land disposal

basis; in accordance with conditions of a pezait. In addition, plans were

cade and the tie-in of the plant's sanitary1 and non-arsenic bearing vastes

to the new >iyerstovn Sewage Authority Treatment Plant was completed in 1966. / "

She clean-up and recovery programs effected an almost imcediate reduction x-

of arsenic in the surface waters and in the wells near the plant site. The

pollution problem vas brought under control within two--months. For exanple,

the arsenic content in the stream immediately east of the plant, which originally , .

measured 40 to 60 ppm, had been reduced to 1 to 5 ppm within a month and a half

period. Comparable reductions followed on downstream and a similar magnitude of

reduction was accomplished in a well adjacent to company property. Bowever,

much arsenical materials remained in the subsurface, and the operation of the ;

recovery wells was continued on a 24 hour, seven day week basis since start-up

in 1964. Weekly yields which peaked at 11,000 pounds per week fall, rapidly

but leveled off sorsuhit at 4500 to 5CCO pounds per veek by .April, 196?. '

AH30382I

iin auger and core boring study was made in the vicinity of the plant

for purpose of deteraining the direction and extent of movement of arsenic';.-' • :• ' • .- ', -• . '' ' • • , '.'- '

as veil as for monitoring and base Use purposes, Ve ™»*» 4.6 auger holes •

in the soil mantel down to bedrock and sijc core borings aade 30 to 50 feet

in the bedrock. Numerous soil and water saaples were analyzed and data• • ' * • . ' .

vas plotted. The results confirmed the general conclusions which were dravn

'from, the original survey work discussed previously. Eie arsenic 'content in

the 'soil was at or near the contact with'the bedrock. From this, and the

other data, we concluded that the arsenic was 'deep in the soil »T"1 bedrock. i • - - . . - ' • . . . ' * , . '•

and that the recovery of arsenic would be a long-term operation. Figure U

shows the locations of the auger and core holes marked JL and C numbers'/• • , • . . ' ' \

respectively. The figure also shows .the location of the initial recovery' .. ' • .>

veils No. 1, 2, 3 and 4~ ' . , " . >i • . ^

' The wells were supplemented in June, 1965 with three additional new wells

No. 5> 6 and 7, as shown -on the figure., ' , •

The arsenic recovery well system was operated essentially as a liquid

mining process. The recovered arsenic bearing water was treated and returned

to the area of the original disposal/contamination zone where the stable-** '- , ' ' : . '

iron-arsenic precipitate settled -and was filtered from the water as it perceiv

to the subsurf ace to move additional arsenic to the wells which were operated

draw-down capacity. Figure HI is a simplified flow diagram of

the process. ' f . . ; •, '

The arsenic yields continued to fall off gradually from the Ipril, 1965

yields of 4500 to 5000 pounds per week to 2000 to 3000 pounds per week in

March, 1966. .However, outflow 05 arsenic persisted, but at greatly reduced

rates.' . ' * • ; . ' • ' " . : . . • - . • . . - ' . " . . >

flH303822

AH303823

\2f-> vPv T * ,\v. -v K

The recycling r. ng operation by its very nature' at the core could not

create an overall- 'ccne of depression in the area to prevent the eastward J — '• " • ' - • ' ' •' - •" )•covenant of the ground vater. Dr. ' J. Graham, Consulting Ground Water : . \_/

Geologist of Ilggette, 2rashears & GrahaarHev lork, vas engaged to study

tha problem for recccosndations. He vas given coopleta access to the area

and all of the voliTlnnus records end reports. .

.tor. Graham recbimended the installation of a system of outlying veils•

on a perimeter encircling both the plant and tha source of contamination

beyond the reach of tha easting veils. Ike veils vere to be located and7

constructed in such a vay as to develop a series of overlapping cones of

depression in the vatar table which vould fora a trough to intercept and

contain the migrating arsenic-bearing vater. The recovered vater vould ha?«

to be discharged avay from the plant area in order to lover the general vatar

table and develop tha trough. ' - .

£ha recoacendationa vera presented and discussed with ,the Division cf •

Sanitary-Engineering and a joint decision vas reached to proceed vith the

veil driTLng progrsa. Because the yield of both vater and arsenic could net%

be calculated, the decision concerning the disposal vas held in abeyance

pending tha o'utccca of tha drilling" program. '

In all, 23 vails vera drilled. Arsenic content, yields and areas cf( .

influence ver» checked during tha drilling. Of tha veils, seven had suffici*rt

capacity for use as production veils; one replaced an eadsting veil for =cr* .

effective drav dovn reach; 10 veils vera used for observation and five vere

abandoned because they vera dry or of insufficient capacity. Tha veils vere

cased vith 6-inch pipe, set firaly into tha top of tha -bedrock and an uucasad1 • • • • ,

hole of 5-7/8 inch diameter drilled into the bedrock strata. The. depths cf' • * . . " ' , - ^-~~^

tha production veils ranged from 60 to 158 feat and tha capaci ', ,

from 10 gpa to 80 gpm for a total of 234 SP** Eie arsenic content ranged

AR303825

-15-

}from 33 pra to 440 ppa. Operation. of the veils was left in abeyrnce until

/ . • , " .I ;iaal disposition of the yields could be decided. Eie location of the veils'\~<S r • ' , • • , • • . . • .

• • .

i s also shovn o n Figure I I . . ' • " . ' ' '

Operation of the 'existing veils vaa continued throughout vith exception1 .. f '

of No. 5, vhich vas replaced vith the nev veil Mo, 51. Eie fall off of yields

continued and reached 500 to 700 pounds per week by jpril, 1963. The amount

removed by then totalled 360,000 pounds, dis represented a pollution potential1 ' ' . '.. . ' i • 'equivalent to the dilution capacity to 0.05 ppa of over 10 years of water from

' • • ' ' . " * *the entire Tulpehocken Creek vatershed. ' . . • .

Company supply of vater vas 'discontinued gradually vhere outlytag veils

reached levels consistently below 0,05 ppa of arsenic. By the forepart of 196£,' • • • . '^ '

15 of the original 30 remained on supply 'and upst of these vere kept so as a

precautionary ceasure. the levels in the creek ifiaediately below .the plant

i ysnged within 0.2 ppa to 0.3 ppa as compared to 40 to 60 ppa in 1964. Seven

dies downstream it ranged from 0.05 FP1 to 0*15 Ppi as conpared to 4 to 5 P=

ia. 196.' . • ' " • .' ' ''-•'_' - ' • ' ' '

The ongoing comprehensive ' cool torlng program vas expanded to include

routine monitoring of the stream bottom' material at six points along the creek* * ' _ - • • , . -

and numerous studies vere made both 'separately and in cooperation vith various '

government agencies. The results vere favorable over a vide range of the suc^tct

matters studied.. ' ' ,

Permits, vith appropriate conditions for discharge of recovered vater f res,

the veils to the cree& vere received from the Department of Health and the •

Delaware Hiver Basin Commission, de veils were equipped and piped into,. a

header system for controlled discharge! ;*nd operation vas begun November 1, 196B.• , i . - .

The phase-in of the discharge operation ves done on a gradual bas ~•

AR303826

^ '

The volume of the 14 veils operating at capacity peaked at 174. gpa

and then gradually declined to about 125 gpm as ''draw-down conditions vere f\

reached and the vater table stabilised at lover than previous levels. The

original 7 veils averaged about 75 gpm. The rate of arsenic removal peaked

around. 850 pounds per veek before trending downward to about 500 pounds-per

veek as compared with 350 pounds per veek prior to the start-up of the nev

veils; .•> - . • - i

In 1970, a program of overstresslng vas studied* This involved pending

of clean vater over certain areas to create infiltration galleries to facilitate

the movement of arsenic to the recovery system* The program vas abandoned

vhen no discernible improvement vas made in the arsenic removal rate.

Operation of the' arsenic recovery/discharge -system vas continued through-

out in accordance vith the conditions of the peiaits until March 16, 1971, vhen

operations vere terminated*

Ine declining yield curve which started at 11,000 pounds per veek had ; "**

reached an asyaptotic rate of 40 to 60 pounds per veek. A total in excess of

425,000 pounds of arsenic vas recovered from the veils during the approximate' • '

6J- years of pumping. " . . ' ,• , ' • v,

•Eie arsenic, level in all the operating wells had teen reduced drasticall/. _

The' concentration in one veil, for example,,had been reduced from over 10,CCO ppz.

to 10 to 30 ppm* . Tte level of arsenic in the creek right below the plant reached

. the 6.02 to 0.03 ppm level vithin a ccnth of the termination of. pumping as

compared to 40 to 60 ppm level in 1964. Tie level of arsenic on dovn the stream

vas belcv O.C5 ppa. Of the 30 outlying veils, originally on company-supplied

vater, only six remain on the list and four of these are at satisfactory

sustaining levels sufficient for removal from the, list. The othr*. . .-f.. , „relatively close to tan plant site.

flft303827

• " CONFIDENTIAL-*

Eie Corps-of Engineers contracted the U.S. Geological Survey to evaluate , ,. . - • • - ' • • t . . • >•I /the situation in the J yerstovn area. Complete cooperation vas given to Mr. i\

Charles Wood, Eydrologist, lading access to all past records and providing' •

auger boring vork performed under his supervision. The two »•-<" conclusions

reached from his evaluations vere: 1) the present condition presents no "threat

. to vater quality dovcstreaa and 2) further pumping vill not produce any measurable

"benefits and therefore is unnecessary. - X-' :

periodic, evaluations of the massive monitoring data accumulated since

the shutdown of ithe ground vater .pumping operations confirms that the outflow

of residual arsenical materials in "the vicinity of the Vhitaoyer Plant site

vas on a continuing asymptotic endslowly declining rate, furthermore, .there "

is no. conflicting evidence in the data sets to indicate that'this trend vill* . -• • •' . • ' •

.change. The three sets of data involved in these analyses are the stream': ' ** ' • '- '

monitoring data, the outlying private veil'monitoring data and the; monitoring

of the nov idle veils in the vicinity and on the "Whitmoyer Plant site.

The success of the arsenical recovery and environmental rehabilitation

vork in the vicinity of Myerstovn is an excellent example of a cooperative . -

effort on the part of responsible government and industry in working together

in solving, a serious problem. The government agencies involved in the regulatory

decisions and cooperative studies made during the program vere the 'Pennsylvania -. , ' . , " • • . * " -Department of Environmental Resources, Delaware River Basin Commission, U.S.*i • • * , . ,Environmental Protection Agency, Corps of Engineers, U.S..Geological Survey and

the U.S. Public Health Services. -

'

'

1 . . .

• . . __ _

DATE STAMP

.' • - J ».!_.'. w

WHITMOYER LABORATORIES, INC.MYERSTOWN, PENNA.. u. s. A.

Dot* March 16, 1979

To Those Listed

From L. J. Croesus •-'"

cc•wD< Jj

H. M. HuffmanR. T. KirstT. E. I«ongR. S. Rosera/-^\- : o*

Subject: ARSENICAL STORAGE VAULT

One of the drawings in my files indicates the following:

Length « 124 ft. ;

Width - 83 ft. .

Top of Side Wall to Bottom - 12 Feet

I have not been able to. locate a diagram for. the vault itself.

If anyone has such, a diagram or has information contrary to the above,

please let me know.' ' -

". •Lloyd J. Croesus

LJCrlcb

.' •

. _ '

i . - ' • '

U • - . ' ; - • .DATE STAMP

,- MLMO 80-271i • • ' • . ' . •'..' '• WHfTMOYER LABORATORIES, INC.

, MYERSTOWN. PENNA., U. S. A.

Doit August 20, 1980

To R. S. Rosera - ,1 . • • - • • •From 'G. ,P. Hoover

CL-^/ac.cc. ,., •A. R. Bott

Arsenic File

Subject: ' LEACHATE STUDY - FINAL REPORT.

A leachate study was performed on a sample of arsenical saltsi • - , ' • ' " , . " ' • "

and a composite charcoal sample., The study was performed in com-

pliance with the ASTM "Water.Shake Extraction Procedure" you provided.

Table V, attached, contains details pertinent to our performance of

this procedure. -x - . •

Tables I and II, .contain all data collected on the salt, charcoal,

-and leachates of each. '•'•''

Table III contains a breakdown of cost per analysis performed and

shows the total cost to be $2,408.00.

Method references, where applicable, are included in Table IV.

I hope this infonaation- ill satisfy your needs.

Gr aory P. Hoover

GPH;lcb

Attachment

AR3038300' *OMM .«d HAAS

TABLE_i 8-20-80080-271

COMPOSITE CHARCOAL* LEACHATE TEST

Analysis Composite Charcoal*(W55864) • Charcoal Leachate

tfat'tr (Loss on Drying) 5,375 mg/Kgm 96.4 %

Solids 994,625 mg/Kgm** - • 36,530 ng/l'. >

pH . 3.5 (.50* Solution) 3.4

Chemical Oxygen Demand 1,333,000 mg/Kgm - 56,700 ng/l.(COD)

Total Organic Carbon (TOC) N/A 4,022 mg/Kgm

Grease & Oil 1QO ng/Kgn . 0.95 mg/1.

Total Volatile Solids 611,500 mg/Kgm ' 18.600 mg/1.

Total Dissolved Solids N/A \ 13,300 mg/1.

Specific Conductance N/A ll,571aimho

Anmonia Nitrogen ' 1,302 mg/Kgn • . 162 mg/1.

Phenols "- 40 mg/Kgm . 11.8 mg/1.

Cyanide 0.185 mg/Kgm <0.005 mg/Kg• ' ' - ' - -

Total Arsenic 229,000Smg/Kgn , 9,180 mg/1.

Perchlorethylene (PCE) 1.600 mg/Kgm <0.5 mg/1.* ~*r

Aniline 22,000 mg/Kgn 4,780 mg/1.« • * _ - . • •Specific Gravity 6 25°C/15.56°C 'N/A 1.020

Cadmium < 8 mg/Kgn <0.5 mg/Kgn

Copper - . • . 24 mg/Kgm 0.25 mg/Kgm

Chromiun 2.&mg/Ksqi < 0.02 mg/Kgm

Uad 0,6 mg/Kgn . < 0.02 mg/Kgn.-' , . ' ' '

Mercury < 4 ng/Kgn <0,2 mg/Kgm

Molybdenun 6.4 mg/Kgn < 0.05 mg/Kgrt

Nickel ' 9 mg/Kgn <0.05 mg/Kgn*"**** • - . - ' '

Selenium • . 0.76 mg/Kgm '• . * n8/ 8*

Silver - <4 mg/Kgn ^ ~.~-1 , ' 1 '

*Equal quantities of north press charcoal (Lab No. W55853) and south presscharcoal (Lab No. V55852) were composited for leachate study.

**Deterained by difference between Loss on Drying and 100X.flft30383l

. • , - . - . - . - • .*Determined by difference between Loss on Drying and 100%,N / A - N o t Applicable . . • > . . • •

, • : : '.---- "IMWLil , 8-20-so ' .'• 080-271' ^ ARSENICAL SALT UEACHATE TEST

Analysis Arsenical Salt -. (W55863) Salt Leachate (V55S621

Water (Loss on Drying) 4 ,670 mg/Kgm , 80.6%• • , . • • ' ' • - - - • i • ,

Solids - 995,330 ttg/Kgm* . [ 216.000 «g/l.

pH . '2.6 (50% Solution) 3.0

Chemical Oxygen Demand 54,220 mg/Kgm 7.000 mc/1(COD) , ' . b

Total Organic Carbon (TOC) >/A 1,192 mg/Kgt

Grease & Oil _ 50 mg/Kgm 1.8'mg/Kgs

Total Volatile Solids 466, 000 ng/Kgm • 106,220 ag/1.

Total Dissolved Solids N/A ; , , 66,360'mg/l.

Specific Conductance "N/A 1,620,000 Who* • * ' . . ' , ' • , .

Ammonia Nitrogen ' 52,770 mg/Kgm 11,082 mg/1.

Phenols * . • 6 mg/Kgm 1.2 mg/1.

Cyanide l 0'°°5 mg/Kgm < 0.005 mg/Kgtt' , , • - - , . ; , '

Total Arsenic 150,000 mg/Kgm '. 20,030 Bg/1.• ' ' m

Perchlorethylene (PCE) < 1.0 mg/Kgm 0.5 mg/1.i , " • • .

Aniline " ."WO mg/Kgm 175 Bg/l.

Specific Gravity € 25°C/15.56°C \»/A . 1.113' ' * . - * . , - . '. " ,

Cadmium < 25 mg/Kgm ' . ,' ' V 2 mg/Kg=

Copper ' - • - , . 2 . 5 mg/Kgm • 1 mg/Kgn

Chromium . 1.5 mg/Kgm . ' . < 0.1 mg/Kgc

Lead 1-.2 mg/Kgm - 0,2 mg/Kgn

Mercury < 12 mg/Kgm < 1 mg/Kg=

Molybdenum < 2;5 ng/Kgm <0.2 mg/Ks::

Ni *i , <2.5»g/Kgm <0.2mg/Kg=

Selefiituft* , * <0.10og/Kgm <0.005 mg/Kg=

Silver < 1.2 Bg/Kgm , ,. ng/Kga

«R303832

.TABU: in 8-20-80£80-271

COST OF ANALYSIS ' .

Analysis , Total Cost . Where Analyzed•

if8"* 1 $ 80.00 v WhitmoyerSolids ; ) , ,

pH .16.00 Whitmoyer

Chemical Oxygen Demand 220.00 Whitmoyer

Total Organic Carbon 64.00 Raltech

Oil & Grease •• 158.00 • Whitmoyer

Total Dissolved Solids } m^t •Total Volatile Solids 5 104'°° Whitmoyer

Specific Conductance 10.00 Whitmoyer

Ammonia Nitrogen 182.00 Whitmoyer .

Phenol > 250.00 • Whitmoyer• - ' • ' " • ' ' ' 'Cyanide . ,. -288.00 Raltech

ARsenic 32.00 Whitmoyer

Cadmium, Copper, Lead, Mercury, ''rMolybdenum, Nickelt Silver A , 600.00 Lehigh Testing

, »Selenium - ' 200*00 Raltech

Aniline - ' 84.00 Whitmoyer

PCE _ 120.00 Whitmoyer

$2,408.00

8-20-80TABLE IV ; #60-271

METHODS OF ANALYSIS

i< ^-^ 1. Water: Solid Samples - loss on drying @ 103,- 105°C for 4 hours :• Liquid Samples -determined by mathematical difference between'• • . . 100% -and the solids remaining after drying.

' 2. Solids: -' Solid Samples - determined by mathematical difference between100%. and the .loss on drying,: Liquid Samples - Whitmoyer .TestMethod 518 (Reft Standard Methods for the Examination of Waterand Wastewater, 14th Edition, 1975, Sec. 208A, pp. 91,92).

3* pH: Whitmoyer Test Method 661. pK performed on a 50% solution .for• solid samples. !

4. Chemical Oxygen Whitmoyer Test Method 527 (Ref: Standard Methods for the Exacina-Demandi ' tion of Water and Wastewater, 14th Edition, 1975, Sec. 508,

pp. 550 - 554). Mpdified to accept solid samples.

5. Total Organic Performed by Raltech Scientific Services (Ref: Standard MethodsCarbon: ' ' for the Examination of Water and Wastewater, 14th Edition,

.".' 1975, Sec. 505, pp. 532 - 534), . ,

6. Grease & Oil: ' Whitmoyer Test Method 762 (Ref: Standard Methods for the• Examination of Water and Wastewater, 14th'Edition, 1975,

. - Sec. 502A, pp. 515-516). Modified to accept solid samples.

7. Total Volatile Whitmoyer Test Method 521 (Ref: Standard Methods for the Examina-Solids: tion of Water and Wastewater, 14th Edition, 1975, Sec. 208E,

p. 95). Modified to accept solid samples.' • ' " TV- ' • ' • ' • , ., •

8. Total Dissolved Whitmoyer Test Method 519 (Ref: Standard Methods for the Examina-Solids: tion of Water* and Wastewater, 14th Edition, 1975, Sec. 208C,

pp. 93,94). •"••-i

9. Specific ', Whitmoyer Test'Method 731 (Ref; Standard Methods for the Examina-Conductance: tion of Water and Wastewater, 14th Edition, 1975, Sec. 205,

pp. 71 - 75*.* . '

10. Ammonia Nitrogen: Whitmoyer Test Method 776 (Ref: Rohm and Haas Test Method 777).Modified to Accept solid samples.'

\\t Phenols: Whitmoyer Test Method 763 (Ref: Standard Methods for the Examina-tion of Water and Wastewater, 14th Edition, 1975, Sec. 510 A & B,pp. 576 - 580). Modified to accept solid samples.

12. Cyanide: Performed by Raltech Scientific Services (Ref: Methods for Cheoica, ,Analysis of Water and Wastes, 1979, Storet No. 00720, Method 335.2

** n* ' • 335.3, U.S. EPA, Cincinnati, Ohio),

13. Total Arsenic: . Whitmoyer Test Method 5 (Ref: Adapted froi ' . andRiemon, W., Anal. Chem. Vol. 22, No. 82, (1950), pp. luoo-7.

' \ " ' • • - . • , . ' " • - ' . ' . ' "14. Perchlorethylene: s Whitmoyer Teat Method 945 — Modified to accept solid samples.

" flR30383t»

, 8-20-30- TABLE IV (CONT'D) 080-271

. - . - ' • METHODS O F ANALYSIS

15. Anilinet Whitmoyer Test Method 568 - Modified tb accept solid samples. -.

16. Specific Gravity: Whitmoyer^Test Method 4 * . .

17. Cadmium,. Copper, Performed by Lehigh Testing — spectrographicaliy.Chromiua, Lead,Mercury, Molybdenum,Nickel, Silver:

18. Selenium: . Performed by Raltech Scientific Services (Ref: Official Methods ofAnalysis, 1980, 13th Edition, fcethod 3.097-3.101, AOAC - J.K.Watkinson, Anal. Chem., Vol. 38, No. 1, Jan. 1966).

AR30383S

T\RTIT v 8-20-80..1MJJLV ... 080-271,

LEACHATE DATA ' ' r

Lab No. References

North Press Charcoal - W55853South Press Charcoal - W55852Composite Charcoal - W55864Arsenical Salts - W55863Charcoal Leachate - W55861Arsenical Salt Leachate - V5S862

Test Weights

Charcoal W5.5861 .

3.65 Ib, W55853 > - - .,3.65 Ib. W55852 3

. 13.248 liters Deionized Water*

Agitation Time - 48 hours - 5 gallon container

Arsenical Salts W55862 '

7.3 Ib. W5586313.248 liters Deionized Water,

Agitation Tine - 48 hours -,5 gallon container

Reference JCZ 92/21, 22

AR303836

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" 1A Aniline itill bottom Tars

Starting materials: Tot. Ars, = 13.2?a — ,.'792 gnu\ Aniline = 15.8 — .9 6 cm.

TTAA = 34.5* -- Z.070 em,DDAA * 5.8* — '.348 ga. -

* . . - • • 4aqueous extraction4'

Moth, Liq. , - . Solids:Tot, Ars. = 0,259gn./100al, ".-..4662gn, Tot, Ags.=l6.0^--.364grInorg. Ars, = 0.24gm./100ml. "*,432gm. :' TTAA = 67.0/0— I.SOSga.

Aniline = 0.51* — ,9282gip, . DDAA = 3-5* «DDAA = <l$o /TIAA = trace , •

1, assay v;;i-.ts. in red. *''. .>r •-2. Soln. contains: 0,5% NaOH; *J*12* NK,; 2.0* Acetone

30cl, of soln. per

•i'

MONITORING DATA SHEET TOR ARSENICAL STORAGE VAULT

Distribution Date^UG 2 ? 103?>

R.J.D.

Canal 3 Extreme West End of Property -0.0/0_____ mg./l.* Total Arsenic on

a.3

8

o25

PIPE *4- _2__• 9 ' " to Water Level. /^ mg/1 Total Arsenic on-fa*

PIPE 03 - g * y " to Water Level. tWl Total Arsenic

' :HOLE DRILLED BY KOHL BROSJ - ' /V ' ^> " to Water Level- ://

I - ' - - . . . ' 1 i : ' : ! ' • ; / • ' - ' i• , "j V/^ mg/1 Total Arsenic on l"/i-gt— \ J

, . • • - • .. • • v-X-EhO * ' / ' ' • • • ' • * ' / ' < /PIPE tf2 - ' ft . • b " to Water Level. O«fe../b Total Arsenic on J-|.?

PIPE $! . @ « 5 ' " to Water Level. *o /£ Total Arsenic on

CANAL fi CULVERT • Q»Q& . mg./l. Total. Arsenic on

1 CANAL @ THE OVERFLOW OF MOVABLE GATE - O.OOt* ng./l. Total At

CREEK Q FAIRLANE AVE. BRIDGE « Q»jQ/y, Tng./l. Total Arsenic on fc/l-d

As of 2-12-82, Wells # 3 & U no longer drain into the ised: JI.J-D- 2-5-82

BUCKEYE PIPE LINE COMPANY

July 18, 1989

Mr. Jeffrey A. PikeWilted States Environmental

Protection AgencyKegion III ,841 Chestnut BuildingPhiladelphia, PA 19107 \

Dear Mr. Pike; • ^ -i .

, ' This letter is written in response to your letter received on July 10,1989, regarding the .Remedial Investigation (RI) report for the Wufrnoyerlaboratories site in Myerstown, Pennsylvania.

First, Buckeye Pipe Line Company, L. P. (Buckeye), has never owned'or usedthe production buildings nor has Buckeye ever owned \ the land on which theproduction buildings are situated. '

Second, a small segment of Buckeye's pipeline which passes through theMiitmoyer site has only been used to transport light refined petroleumproducts (i.e., gasoline, No. 2 fuel oil, diesel fuel and kerosene). Thepercentage of the total volume of each of these products varies with demandand scheduling. No other products including aniline were ever transmitted bythe pipeline.

Third, the pipeline has always followed the same right-of-way through theWhitmoyer facility. ;

If you should have any further questions, please feel free to contact the1 writer at the letterhead address. •

Very truly yours.

F. Horwath ,Supervisor, Environmental Compliance

?0 Box 368 Emmaus. Pennsy.vania 18049-0368. (215) 820-8300

COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL RESOURCES

Post Office Box 2357Harrisburg, Pennsylvania 17120

March 15, 1990

Bureau of Topographic and Geologic Survey(717) 787-5828

Mr. Roger ClarkNUS CorporationPark West 2Cliff Mine Road .Pittsburgh, Pennsylvania 15275

Subject: Sinkhole map, Meyerstown area, Lebanon County

Dear Mr. Clark:Enclosed is a copy of a portion of the Richland

minute map. The map shows the location of karst features in thearea you are interested in. The data is from my field map andmay reflect additional features when compared to the open-filereport. . ' . . , -

If there are any questions, please contact me.

- incerely, r

William E. KochanovGeologistEnvironmental Division

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