Environmental l*rotaction
Agency
Emergency and
Remedial Response
August 1984
Superfund
Record of Decision:
Wade Site, PA
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R03-84/009
2.
I. RECIPIENT'S ACCESSION NO. • f
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION:
Wade Site (ABM), PA
5. REPORT DATE
08/30/84
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Wade site is a three acre parcel of land on the banks of the Delaware
River. It is located nine miles south of Philadelphia in Chester, Pennsylvania. From
approximately 1950 until the early 1970's the site was the location of a rubber re-
cycling facility which shredded tires and other post-consumer rubber products. During
the early 1970's the site was converted to an illegal industrial waste storage and
disposal facility. Drums of waste were emptied either directly onto the ground or
trenches, severely contaminating soil and the ground water. Approximately 150,000
gallons of waste chemicals remain on-site.
The recommended alternative selected for this site consists of: removal,
decontamination and disposal of on-site tires and tankers, removal of on-site waste
piles; demolishing buildings, leveling the site, and filling and grading the property
up to 12 inches over the existing grade to cover any protruding subsurface structures
which have not been removed; removal down to the depth at which the first acceptably
contaminated sample was found (based on a contamination cutoff level recommended by the
RI/FS contractor); and covering the site with top-soil and seeding the cap to
minimize erosion.
Key Words: Compliance with Environmental Laws, Negotiations, Capping,
Excavation, Ground Water, Cost Recovery, Potential Responsible
Parties
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Group
Record of Decision:
Wade Site (ABM), PA
Contaminated media: gw, soil, air
Key contaminants: over 100 organics, metal
and inorganics
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report/
None
21. NO. OF PAGES
30
20. SECURITY CLASS (This page)
None
22. PRICE
EPA Form 2220-1 (R««. 4-77) PREVIOUS EDITION is OBSOLETE
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EPA Form 2220-1 (Rev. 4-77) (R.v.rt.)
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ENFORCEMENT DECISION DOCUMENT
REMEDIAL ALTERNATIVE SELECTION
Site: Wade
Chester, Pennsylvania
Documen.ts Reviewed
I am basing my decision on the following documents
describing the analysis of the cost and effectiveness of
remedial alternatives for the Wade Site:
- Focused Feasibility Study, Wade Site, Chester,
Pennsylvania, Metcalf & Eddy, Inc., April 1984.
- Draft Report, Result of Soil Analysis and Cost
Estimates for selected Remedial Activities regarding
the Wade Hazardous Waste Site in Chester, PA,
Roy F. Weston, November 1983.
- Summary of Remedial Alternatives Selection
- Public Comments and Recommendations
- Responsiveness Summary
Description of Selected Remedy
- remove and dispose of tires and tankers
- remove on-site waste piles
- demolish buildings
- test contents, remove contents, and close two underground
storage tanks
The building on this site will be demolished and the
remaining slabs will be left on site for future use. All
demolition rubble will remain on the property and used for
fill material.
- level debris, fill and grade property
- remove and dispose of contaminated soil
The purpose of this activity is to remove from the property
any contaminated material and any material that will.hinder
subsequent efforts to fill and grade the site.
- cover with topsoil and seed cap
- operation and maintenance of site
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Declarations
Consistent with the Comprehensive Environmental Response
Compensation and Liability Act of 1980 (CERCLA) and the
National Contingency Plan (40 CFR Part 300), I have deter-
mined the removal, decontamination and disposal of tankers,
tires and debris; destruction of buildings, leveling, filling
and grading the site; and covering with a seeded topsoil cap
at the Wade site is the least costly alternative of all the
remedial options reviewed that provides for current and future
protection of public health, welfare and the environment.
The State of Pennsylvania has been consulted and agrees with
the approved remedy, in addition, the action will require
future operation and maintenance activities to ensure the
continued effectiveness of the remedy. Settlements have
been reached between EPA and the responsible parties based
on the selected remedy.
I have also determined that the action being taken which
includes the off-site transport of contaminated materials to a
RCRA approved lined facility is the least costly alternative
when compared to the other remedial options reviewed, and is
necessary to protect public health, welfare, or the environment,
/ Date
M. Thomas
Assistant Administrator
Office of Solid Waste and
Emergency Response
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a tSf^J » UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AV-EMERGENCY RESPONSE
3 I98A
MEMORANDUM
SUBJECT: Enforcement Decision Document Approval for the
Remedial Action at the Wade Site, Chester, Pennsylvania
FROM: Gene A. Lucero, Director O$tl^ n>
Office of Waste Programs Enforcement
TO: Lee M. Thomas
Assistant Administrator
This Office has reviewed the Enforcement Decision Document
and the Focused Feasibility Study for the Wade Site. I recommend
that you approve the recommended alternative which will provide
for future protection of public health, welfare, and the
environment.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL 30 1984 SOLID WASTE AND EMERGENCY RESPONSE
OUL
MEMORANDUM
SUBJECT: Enforcement Decision Memorandum for Approval of
Remedial Action at the Wade S|te,/Chester, Pennsylvania
FROM: Russel H. Wyer, Director
Hazardous Site Control Di^Tsiofe (WH-548E)
TO: Gene A. Lucero, Director
Office of Waste Programs Enforcement (WH-527)
The Enforcement Decision Memorandum and the Focused Feasibility
Study for the Wade Site has been reviewed by my staff.
I Concur
I Do Not Concur
I Concur with Comment
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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
AU6 11984
OFFICE OF
ENFORCEMENT AND
COMPLIANCE MONITORING
MEMORANDUM
SUBJECT: Enforcement Decision Memorandum for Approval of
Remedial Action at the Wade Site, Chester, Pennsylvania
FROM: Frederick F. Stiehl f
Acting Associate Enforcement Counsel
for Waste (LE-134S)
TO: Gene A. Lucero, Director
Office of Waste Programs Enforcement (WH-527)
The Enforcement Decision Memorandum and the Focused
Feasibility Study for the Wade site has been reviewed by my
staff.
I Concur
I Do Not Concur
1 Concur with Comment
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Summary of Remedial Alternative Selection
Wade Site
Chester, Pennsylvania
Site Location, Description and History
The Wade site is a three acre parcel located on the
banks of the Delaware River, just nine miles south of the
City of Philadelphia, in Chester, Pennsylvania. The site is
located in the industrial portion of Chester and is two
blocks from the residential portion of the City. The site
is bounded by the Commodore Barry Bridge, the Delaware
River, a railroad right-of-way, and property owned by the
Philadelphia Electric Company. From approximately 1950
until the early 1970's, the site was the location
of the Eastern Rubber Recycling Company, a firm which
shredded tires and other post-consumer rubber products.
This use was abandoned during the 1970's and the site was
converted to an illegal industrial waste storage and disposal
facility. Drums of wastes were emptied either directly onto
the ground or into trenches, thus severely contaminating soil
at several locations, as well as jeopardizing the ground water
beneath the site. In February 1978, a fire broke out which
was so severe that the Commodore Barry Bridge was closed for
6 hours and 45 firemen required examination at the local
hospital. As a result of the fire, one of the site buildings
was completely destroyed and two others were seriously damaged.
Large piles of debris containing exploded drums, building
materials, tires, and shredded rubber (from the rubber re-
cycling operations), and chemically-contaminated earth littered
the property. Approximately 150,000 gallons of waste chemicals
remained after the fire; most of the material was contained
in 2,500 55-gallon drums located inside the fire damaged
buildings, although a large portion was stored in 5 bulk
tankers in the front lot.
In 1980 and 1981, contractors were engaged by the
Pennsylvania Department of Environmental Resources (DER) and
the U.S. EPA to remove and dispose of the drums (and their
contents) contained in the buildings, to remove and dispose
of the contents of the tankers, and to perform an investigation
of the site's soil, ground water, and air quality. WESTON
personnel served as the DER Site Representative for the
day-to-day monitoring of Contractor activities.
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Subsequent to the above on-site activities, CECOS was
engaged by the DER in the summer of 1983 to investigate and
characterize the remaining hazardous and non-hazardous elements
of the site, such as debris piles and contaminated soil.
The following activities composed the scope-of-work for CECOS:
1. "pick through" the debris and rubble to isolate
all drums;
2. analyze the contents of drums containing chemicals;
3. repackage leaking drums in secure containers;
4. stage drums containing chemicals in accordance with
their contents;
5. crush all empty drums;
6. analyze soil and debris for contamination;
7. determine locations and quantities of contaminated
soil and debris; and
8. determine quantities and compositions of drummed
chemicals.
In addition to the above, CECOS staged the debris into
separate piles (for tires and shredded rubber, wood, scrap
metal, and potentially contaminated soil) and transported
and disposed of all drums containing chemicals found during
the site characterization.
Since the number of drums containing chemicals was not
known until the characterization was complete, removal and
disposal of such drums were not included in the scope-of-work,
as described in the DER's request for proposals for this site
characterization. It turned out that there were 750 drums
containing chemicals. It was decided from a cost and safety
standpoint that these drums should be removed and disposed
under this contract rather than placing them in secure storage
on the site for disposal under a later contract. The
Contractor, therefore, was directed, under an explicit
contract option for "out-of-lump sum" work, to perform the
disposal activities. Empty drums were not disposed of.
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CECOS was on the site from August 1 to September 10,
1983. 'During that time approximately 5,000 cubic yards
of debris were picked through and staged in separate piles,
approximately 750 drums containing chemicals were characterized;
wastes were repackaged in secure containers when necessary;
combined in compatible groups when possible; 630 drums were
disposed; and 320 soil samples were obtained and analyzed.
The DER monitored work acceptability and efficiency
through persons formally named (in the CECOS Contract) as
Cleanup Director and Site Representative. The Cleanup
Director had ultimate responsibility for the site and for
monitoring the Contractor's performance. The Site Representa-
tive was an employee of WESTON who was on-site full-time
and represented the Cleanup Director in his absence and was
authorized to make specific decisions on behalf of the DER.
All cleanup actions taken to date at the site by the DER
were done with the concurrence of EPA. The Agency was intimately
involved, both technically and legally, in the development
and implementation phases of the cleanup. All proposed
actions were reviewed to assure that they complied with
Federal environmental regulations which existed at the time.
A separate report has been prepared by WESTON titled,
"Cost Estimates for Selected Remedial Activities in Response
to Hazardous Conditions present at the Wade Property in
Chester, Pennsylvania." The analytical results of the soil
sampling program performed by CECOS are presented in that
report since they provide the basis for the cost estimates of
removing contaminated soil.
A focused feasibility study (FFS) and Endangerment
Assessment for the Wade site were tasked to Metcalf & Eddy,
Inc., by EPA in February 1984. The FFS considers the endanger-
ment and recommends the most cost-effective remedial alternative.
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Current Site Status
A* plan of the site is presented in Figure 1. The
grid markings shown on the figure were used for locating
the soil sampling points. As can be seen from the figure,
the site contains seven structures, four rubber storage
tanks, seven tankers, a pump pit, and eleven piles of debris.
The structures vary in structural integrity from
moderate to poor, all having been damaged by the fire in
1978. Although not indicated by the figure, the concrete
pad underlying grids 22 and 23 was the floor of a two-story
stone and brick building which was completely demolished
in the fire. There is heavy machinery bolted to this pad
and also in place in the building encompassed by grids
24, 25, and 26. In general, the buildings on the site
pose a physical hazard, due to lack of structural integrity,
to persons entering them or walking near them.
The tankers are empty with the possible exception of
rainwater. Five of the seven tankers were used to contain
solid and semisolid chemicals which were removed and
disposed during the DER's cleanup operation in 1980.
Like the buildings on the site, the structural integrity
of the tankers ranges from moderate to poor and it is
assumed that none of them is able to be towed over the
road supported by its own undercarriage.
The pump pit is a concrete rectangular structure
greater than 15 feet deep and currently back filled with
soil. It is not believed that the pit is connected to the
river though it historically contained a pump used to obtain
process water for the rubber company's operations.
The piles of debris located at several parts of the
site were formed as a result of the site characterization
and contain separate categories of waste, such as: tires
and shredded rubber, potentially contaminated soil, scrap
metaT, scrap wood, and crushed empty drums. All of these
separate materials were formerly found mixed together in
scattered piles across the site prior to the site character-
ization.
The site itself is level and essentially barren of
vegetation due to excavation and grading performed during
the site characterization. Vegetation was present, however,
prior to those activities and it is expected to return.
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Over one hundred different organic and inorganic
compounds and metals have been identified on the Wade
property during the course of investigations at the site.
While the majority have been identified in surface soils
many have been detected in both air and ground water
samples taken from the site.
Sampling by R.F. Weston indicated that contamination
of soils on the site is widespread. Weston divided the
site into approximately 60 grids and sampled for total
volatile organic compounds (VOC) and total baseneutral
and acid extractable (BNA) fractions of priority pollutants
at four points within each grid. Their results showed
contamination by VOC, BNAs, or both of the top 12 inches
of soil in nearly every grid. In general, BNA fraction
was present in higher concentration than the VOC fraction.
Despite the numerous investigations that have taken
place on the site, the data do not easily permit generali-
zation of the areal extent of contamination by any one
compound.
Many of the compounds found on site have been
associated with a variety of health effects in humans,
laboratory animals, or both, when inhaled or ingested in
sufficient quantities. At least six organic compounds or
classes of compounds are suspect human carcinogens;
benzene, chlorinated benzenes, chloroform, tetrachloroe-
thylene, trichloroethylene, and bis(ethylhexyl phthalate).
Certain metals found at the site - hexvalent chromium and
arsenic - are also suspect human carcinogens. Lead is also
present in the soils and ground water.
The principal conclusions to be drawn from the site
investigation and endangerment assessment are:
1. Based on the monitoring results, concentrations of
volatile organic compounds on the Wade site do not
present acute exposure hazards to persons on or off
site. Although low by acute standards, concentra-
tions of benzene found did present slighty elevated
lifetime risks of cancer to persons directly on site.
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2. Inhalation/ingestion of contaminated soil is
potentially the most serious route of exposure for
persons entering or playing on the site. Under the
assumptions used in the FS, lifetime risks of cancer
(10~4) from inhaling/ingesting small amounts of
contaminated soil on the site were higher than risks
from other routes of exposure. Sampling results
indicate that the concentrations of benzene found on
the site are associated with risks of cancer that
are 5-10 times higher than those considered as
negligible. This finding applies only to persons
with chronic exposures to soil on the site (i.e.,
children playing on the site over long periods of
time) . No evidence of potential acute health effects
were found, a finding consistent with results of a
study by the Center for Disease Control.
3. Persons entering the site may be exposed to toxic
chemicals both in the air and in contaminated soil
and are therefore the most susceptible population at
risk from contaminants on the Wade Site.
4. Underground tanks and tunnels, structurally damaged
buildings, and piles of flammable debris present
immediate safety hazards to persons entering or
playing on the site.
5. Drinking water and fish are not likely to be
significant routes of exposure to chemicals from
the Wade site. Ground water beneath the site is
not used as a source of drinking water and
concentrations of chemicals in the Delaware
resulting from contaminated ground water discharge
to the Delaware are estimated to be negligible.
6. Contamination on the Wade site is not expected to
have a serious impact on the environment either
through volatilization of chemicals to the air or
release of contaminants via ground water to the
Delaware River. Both releases have been estimated
to be extremely low.
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Enforcement
In December of 1978/ EPA asked the Regions to list
candidates for RCRA §7003 actions. The Pennsylvania
DER, which had unsuccessfully ordered Wade and ABM to
clean up the site in 1977, recommended the Wade Site.
Waste leaking, spilled, or otherwise disposed from
drums, tanks or other containers deemed to provide an
imminent and substantial endangerment to health and the
environment by the EPA. On April 20, 1979, the EPA
commenced a civil action against Wade and ABM.
The Court ordered them to clean up the site.
The complaint was amended in March of 1980 to join
Ellis Barnhouse and Frank Tyson, former presidents of
ABM. When it became apparent that the current
defendants were insolvent, a year long investigation of
ABM's generator customers took place. After 32
generators settled for 1.6 million dollars, EPA sued the
remaining 6 generators in the original clean-up action in
December of 1981. In September of 1982 the Court
dismissed the injunctive relief claims against the
generators and EPA then commenced a CERCLA §107 cost
recovery action which is the current basis for the action
against the generators. In May of 1984, the remaining
generators agreed to settle with EPA and the State.
Settlement agreements are being negotiated.
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Initial Remedial Alternative Screening
Several alternatives were evaluated by Mitre, NEK,
Weston, EPA and DER. Based on an initial screening, the
following alternatives were rejected:
1. Volatilization of volatile contaminants by
excavating the soil and spreading it in thin
layers and turning periodically to expose it to
the atmosphere or placing the soil in windrows.
This technique was rejected on the basis of low
efficiency due to the small size of the site, no
off-site location available, no removal of BN/A
contaminants, the requirement of air monitoring,
unpredictable weather conditions, and the
possible requirement of mechanical aeration.
2. Land farming and composting, for aerobic
degradation of organic contaminants. This
alternative was rejected because of the possible
requirement for commercially-developed mutant
bacteria, the low concentrations of organic
material present in the soil, required treatability
studies and pilot testing, specialized equipment,
long processing times, continuous monitoring and
because the technique had not been proven for
decontamination of soil.
3. Creation of a secure cell on-site, by means of an
impermeable cover, continuous monitoring of ground
water and possibly impermeable side walls or liner
to prevent migration of contaminants away from the
property boundaries. This alternative was rejected
because the contaminated soil would remain in an
urban area, the cell would have to be perpetually
monitoried, the hydrological properties of the site
are not suitable for a secure cell, the property
would have to be restricted from other use and State
and Federal permits may be required.
4. Total removal and off-site disposal of soil at a
licensed, secured landfill and backfilling the site
with imported soil. This alternative was rejected
because site investigation shows the soil contamination
is localized in discrete areas and because of the high
cost of this solution.
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Remedial Alternative Screening
In order to perform a detailed evaluation, it was
necessary to develop a list of remedial alternatives which
would include a No Action Remedial Alternative. Metcalf &
Eddy developed 12 alternatives for the Wade site, based on
Weston's six soil removal options. (See Table 2 for soil
removal options.)
Alternatives:
1. No Action
2. Remove, decon & dispose of tires & tankers, remove
on-site waste piles; demolish buildings, level site,
fill and grade property.
3. Remove, decon & dispose of tires & tankers, remove
on-site waste pile; demolish buildings, level site,
fill and grade property, cover with asphalt cap.
4. Remove, decon & dispose of tires & tankers, remove
on-site waste piles; demolish buildings, level site,
fill and grade property, cover with topsoil and
seeded cap.
5. Remove, decon & dispose of tires & tankers, remove
on-site waste piles; demolish buildings, level site,
fill and grade property, soil removal option 1A,
cover with asphalt cap.
6. Remove, decon & dispose of tires & tankers, remove
on-site waste piles; demolish buildings, level site,
fill and grade property, soil removal option 1A,
cover with topsoil and seeded cap.
7. Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site, fill and grade property, soil
removal option 1C, cover with asphalt cap.
8. Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site, fill and grade property, soil
removal option 1C, cover with topsoil and seeded
cap.
9* Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site, fill and grade property, soil
removal option 2A, cover with asphalt cap.
10. Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site/ fill and grade property, soil
removal option 2A, cover with topsoil and seeded
cap.
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11. Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site, fill and grade property, soil
removal option 2C, cover with asphalt cap.
12. Remove, decon & dispose of tires & tankers,
remove on-site waste piles; demolish buildings,
level site, fill and grade property, soil
removal option 2C, cover with topsoil and seeded
cap.
Screening Considerations:
A. Ground water
The hydrological evaluation determined that
the Delaware River is the outflow point for ground
water from the Wade site. The results of the evaluation
indicate that, based on all organic contaminants detected
in ground water at the site, continued input of contami-
nated ground water to the Delaware River under the no-action
alternative would not have a measurable adverse impact on
water quality or biota, if contaminated soil was removed from
the site. The concentrations of individual organics after
mixing of ground water with both the estimated full flow
and half flow of the Delaware River are all well below all
applicable Ambient Water Quality Criteria and U.S. EPA
Health Advisories for ingestion of toxic and carcinogenic
compounds in water (Table 1). Therefore, due to the negli-
gible impact of ground water on the off-site environment and
public health, groundwater interception and withdrawal
remedial actions were eliminated from further consideration.
B. Soil Excavation/Removal Remedial Alternatives
Six remedial alternative soil excavation/removal
options (1A, IB, 1C, 2A, 2B and 2C) were developed by
Roy F. Weston based on either of two threshold levels of
organic contaminants for defining whether the soil is
contaminated (See Table 2.) One threshold level on which
three of the alternatives (1A, IB, 1C,) were based was 100
mg/kg for both the volatile and base neutral/acid (BN/A)
fractions. The second, on which the remaining three (2A,2B,
2C) alternatives were based, was 100 mg/kg for the volatile
fraction and 500 mg/kg for the BN/A fraction. Metcalf &
Eddy reviewed the confirmed contaminated soil excavation
quantities and potentially contaminated soil quantities for
Options 1A, 1C, 2A and 2C, determined by R.F. Weston. A
conservative approach was taken due to possible synergistic
effects.
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. Ole«ilora»ra»aii«
. Olc*laro»ra»m«
. Olc«larapra»«n«
, OlehlirafrapOT*
, Olckloro*rao*n«
. Olchlora»ra»an*
. Oldilaraprapw*
, Ole»oro»rap«ii>
Dla»t»U>M*t»
flraundwtcr
CaicOTtrctlen
(«q/L»
IW.OOO
t.OOO
f.wn
3,100
<2.0
21
2.200
M
27.000
146
144
n
w
30
21
6TO
<2.0
3.400
•W
III
M
•.MO
m
M
T4
30
24
7.0W
1,780
4W
237
2»
W
33
1*
9.000
StctlM GMemtratlaii In 6* !••»•• M.ni
M»>ir •!*»• •Ulna-rull Flo> (w|/l)
B4A
B6A
•W
B4A
M.M
• 1A
B2
M
B4A
e»
BM
B4
§1
BIA
M
82
M.M
MA
BM
B»
B2
B3A
BM
B4
M
88
B2
B3A
B4A
B9
B«A
BM
87
B8A
M
B3A
O.I3«2
0.0093
0.0078
0.00)2
0.000002052
0.000022
0.0073
0.0000377*
0.078
O.OOOI4M
0.0001483
0.0000)9
0.000032
0.000432
0.000022
0.0007
0.000002062
O.OOMO?
0.00088
0.000173
0.0000337
0.0067
0.00079087
0.00009
0.0000764
0.0000304
0.000023
0.0073
0.00184
0.0004642
0.00074
0.000236
0.000037
0.0000361
0.0000196
0.0032
CWMiitraHiM In D»l«w» H.OI tatUnt Niter QMlIt* O-lt*rl«
•1*
0.000004
0.007
0.00173
0.00074
0.0001
0.0134 113.000 m>n. lMMt*»
0.00036
0.0002
0.00019 . •
O.OOdD62
0.00003
0.00003 10.200 m>n. (MMt*)) 430 ««A drailc
0.0149
0.00)7
0.0003
0.0003
0.000113
0.00007
0.00004
0.01
-------
TAflLt 1 fOnMlMM). OCUMMC m«tM OMTMIIMTKM ASSCS9CNT
Cnewfctloi Station CoMCMtratlai In tolawr* M» Omantrctloi In 0*U«r« R.lll A*t«*t *tv Owllty
rju — 1< C«u/lt -inbT- *«tv •(»tfi<|-Fi>l« Ft«nt ««q/U •<*••• C.NIWI .1/2 Flow («N/LI Criteria for Saltwtar Acwtfe Ufa
ftkyl BMWM
ftkyl Bw»aMa
Ctfcytatl«r
CtkyUtlW
iMtroayl Alekakol
••oprtwyl AldMAel
Ixwrotyl Alekekol
lM*r<»rl BMIBII*
lM*ro*yl Bwtwt*
NithyUldMfiel
Nttkyldi* ChlerM*
N»tkyl«w CMorM*
N»t*iy (•»*» 1 totow
Mtfcyl llatetylk*tawi
Mvtfcyl Itotetyll^ai*
MBtbyl iMtaityltetow
••tttyl liotntyltotow
MBthyl ItotMtylkcton*
•bttiyl Itotefyltotoi*
Mtky 1 Mthwry 1 at*
n-ffopflstcholiol
TcfTMll I OTMtfcyl MM
T«tr»chl«ro»t1iyl«i»»
TatrikytfrofirM
TctrMiydrotvM
TvtrakvdrelwMi
T«tr«h««re«vM
TatrchydrofwOT
T«tr*liydro«V4n
T»tr (hydro* «•••
T*tr«hytfrotir»
TeliMii*
TolDMW
Trwt-1.2 DIcMoroBtfcylOT*
Tratcl.2 OleHlvactftylM*
Tr«n«-l,2 Ole*le»-o»ttiylw>«
TM
14
•.0
4.0
17.000
900
400
100
1)
1.200
11.400
114
T.100
05.000
1.770
400
80
42
S.O
1.100
200
21
12
26.000
2.300
1.400
MO
200
190
170
170
12.400
<*.o
MO
M
•.0
B4A
BO
BU
B2
MA
B3A
B2
MA
B3A
B3A
MA
B5A
MA
MA
B9A
BBA
B34
M
B5
MA
B2
BOA
B9
B3A
B9A
B8
BIA
B9
B7
B6A
B6A
MA
B6.6A
B8A
BO
B2
0.00733
0.00001444
0.00000879
'0.000004
0.017)3
0.00093
0.000413
0.000103
0.0000134
0.00124
0.012
0.00012
0.0079
0.0877
0.00131
0.000413
0.000062
0.00004332
O.000003I
0.00113)
0.00071
0.000007062
0.0000124
0.07682
0.007372
0.0014
O.OOOM94
0.0078
0.000196
0.00017)3
0.00017)3
0.013
0.000007062
0.000 3O94
0.0000309
0.0000062
0.01508
0.00003
0.000016
O.OOOON
0.0)3
0.0010
0.0006
0.00021
0.00003
0.0075
0.0733
0.0007
0.0138
0.1753
0.00762
0.0008
0.000174
0.000087
0.0000062
0.0073
0.0004
0.000043 10.200 «a/l Aartvi 450 X/V eftrailc
0.000025
0.054
0.0047
0.0078
0.00062
1 0.000)7
0.00004
0.00033
0.00033
0.076 t.100 mn. (•af«)«3.000 w/l Idrmlel.
0.000004
0.00062 224.000 «nA l«atHI
0.00062
0.0000124
-------
TABU I <0»tlm»4>. KUMMC MIVCM OMrMIIMTION ASSCS9CNT
CwcMtratlai Statloi OMMiitratloii In 0»l«w« •."' Concentration In 0»l«wr* •.."' A*l**t Mtar QMllty
Oi^ninl («f/U Nuater altar Bluing-full Flow <«g/l» cttar Bluing .1/2 Flo* iMg/LI CHtarl* »•
%I«W
%|BM
%l*n*
%!•*•
%I«M
21.400
425
77
72
49
10
5. MO
24
17
14.700
• I*
6)
60
M
54
42
M
M
It
II
<2.0
4.0
B4A
BM
BB
B4
B)
BM
BM
B4
B)
BM
BM
B)
B4
BM
BM
BM
BM
B2
B5
Bl
B2A
BM
0.022)
0.0004M
0.0000794
0.000074
0.0000)09
0.0000 10)
0.0099
0.000029
0.0000010)
0.0192
0.0006)9
O.OOOO69
0.000062
0.0000)776
0.0000997
0.0000*1)2
0.0000402
0.0000)7
0.00002
0.00001 1)
0.000002062
0.000002062
0.0449 M.200 «(A (MHt«»
0.0009
0.00016
0.00019
0.0001
0.00002
0.0109 2.000 «|/l <*Mt*>
0.00009
0.0000)9
0.0)
0.001)
0.0001)
0.000124
0.0001
0.0001
O.OOOOM
o.ooooa
0.000074
0.00004
0.00002)
0.000004
0.000004
-------
Table 2
Soil Excavation/Removal Remedial Alternatives
1. Remove contaminated soils exceeding organic contaminant
concentration of either 100 mg/kg volatile organics or
100 mg/kg base, neutral/acid organics.
A. Excavate to Last Contaminated Depth1
B. Excavate to intermediate Depth?
C. Excavate to Uncontaminated
2. Remove soils exceeding an organic contaminant concentration
of either 100 mg/kg volatile organics or 500 mg/kg base,
neutral/acid organics.
A. Excavate to Last Contaminated Depthl
B. Excavate to intermediate Depth?
C. Excavate to Uncontaminated Depth3
I/ Soil removed down to depth at which last contaminated
soil was found.
2/ Soil removed down to depth at which last contaminated sample
was found if threshold level exceeded by 20 percent or less;
one foot deeper than last contaminated depth if threshold
level exceeded by 21 to 100 percent; and down to depth at
which first Uncontaminated sample was found if threshold
level exceeded by greater than 100 percent.
3/ Soil removed down to depth at which first Uncontaminated
sample was found.
-------
-16-
There are currently no standards for exposure to total
volatile organic (VOC) or base neutral/acid extractable (BNA)
fractions in soil. The toxicity of the contaminated soil
depends in part on the individual compounds present and in
part on any additive or synergistic effects that the
compounds may exert together. Since no compelling toxico-
logical evidence supports a threshold of 100 rag/kg of total
VOCs or BNAs versus 50 mg/kg or 150 mg/kg, it is unlikely
that any meaningful distinction can be made between excavat-
ing to "clean" depth or to one foot below the last contami-
nated sample on the basis of public health impact.
In several grids, the concentration composites indicated
contaminant levels greatly exceeding the set threshold
levels, yet analysis of the quadrants' analytical data
indicates the opposite. In other grids, this relationship
was reversed. These results suggest that the sampling
method may not be an accurate indicator of the extent of
contamination of the whole grid. While this lack of corre-
lation is a general problem with all the soil removal
options, it suggests that making distinctions between soils
that are 20%, 21-100% or greater than 100% over the threshold
is not valid over an entire quadrant. On the basis of the
toxicological issues and the sampling discrepancies, Metcalf
& Eddy concluded that soil removal options IB and 2B are
unjustified and should be excluded.
C. Remove Debris
Removal and disposal of on-site, crushed drums and
contaminated soil pile(s) were included in the Removal of
Debris remedial item. These had been included under the
contaminated soil removal activity, however, it is more
appropriate to consider them as part of removing site debris.
A 50 percent swell factor was used for estimating the volume
of crushed drums after loading into trucks for subsequent
hauling to a final disposal site. A 15 percent swell factor
was used for estimating the loading volume of soil from above-
ground soil piles or excavated from the site for subsequent
hauling to a final disposal site.
D. Demolish Building
Several items were added to the Demolish Buildings
remedial activity. These included the following:
- Rough grading and site leveling up to 12 inches
over existing grade in order to cover any pro-
truding subsurface structures which have not been
removed.
- On-site sump sampling and analysis and waste
removal.
-------
-17-
- Underground fuel oil tank/contents removal.
- 'Underground waste chemical/solvent tank
contents removal.
- Closure of underground tunnel, filling in of
building basements and vehicle weighing station
pit. The tunnels and pit are potential reservoirs
for off-site contamination.
These items were added to the Demolish Buildings
remedial activity because it would be appropriate to under-
take these items during the building demolition activity.
Off-site, handling quantities of building demolition debris
were calculated for the following scenarios: remove all
debris from site for each soil excavation option under
consideration (1A, 1C, 2A, 2C). These quantities are used
in the subsequent cost analysis of remedial alternatives.
The site remains a safety hazard to persons entering or
playing on the site and in abandoned buildings. Despite
locked gates to the site, persons from the surrounding
neighborhood are known to gain access to the site.
Initial remedial activities on the site have not removed
all safety hazards from the site. Two partially full under-
ground tanks, an underground 4-foot x 4-foot tunnel beneath the
main building, and structurally damaged buildings present
serious physical hazards to persons gaining access to the site.
The identity of compounds in the remaining underground tanks
have not been established as of this writing but nevertheless
the tanks themselves are at least partly accessible from the
ground. Both the tanks and the tunnel may contain oxygen
deficient or toxic atmospheres that increase the likelihood
of accidents. The major fire at the Wade site in 1978 damaged the
structural integrity of several buildings on-site, increasing the
likelihood of unexpected collapse. Finally, remaining piles of
debris (wood and tires) are potential fire hazards.
E. Site Capping
The results of the Endangerment Assessment for the No
Action remedial alternative, as previously discussed, in-
dicated minimal risks as a result of on-site ground water
contamination. On this basis, ground water interception,
withdrawal and treatment remedial alternatives were elimi-
nated from further consideration and detailed evaluation.
The site capping options range from relatively impermeable
clay capping to asphalt capping to relatively permeable
topsoil/seeding capping. Clay capping is the most effective
of these capping options at preventing infiltration of
precipitation into the unsaturated soil zone (contaminated
soil) and subsequent movement into the ground water.
-------
-18-
Precipitation has and does infiltrate the unsaturated
zone on-site and recharges the ground water, but its effect
on ground water does not pose significant risks as previously
discussed. Therefore, it is not necessary to prevent
infiltration by installing a relatively impermeable clay cap
or asphalt cap on the site.
-------
-19-
Cost Analysis
Table 3 presents the site implementation costs for
all the 12 remedial alternatives based on Metcalf & Eddy's
cost estimates for site Debris Removal, Building Demolition,
Site Capping and Contaminated Soil removal.
Post Closure, Long Term Monitoring Plan
Once remedial activities have been completed on the
Wade site, it is required that the site be further monitored
for a period of 30 years to determine the effectiveness of
the remedial activities.
The plan includes the following tasks:
1. Site Inspection:
The site inspection will include a visual
inspection of surface conditions and the monitoring
we 11 s.
2. Installation of Upgradient Monitoring Wells:
Two upgradient monitoring well clusters will
be installed in off-site locations in order to
monitor the water quality of the ground water
before it flows under this site.
3. Water Sampling:
The purpose of this sampling is to determine
ground water quality before ground water enters the
site and ground water quality as it leaves the site.
4. Laboratory Analysis:
Both water and soil samples will be analyzed for
priority pollutants, cyanide and TOX based upon
contaminants identified in previous site sampling.
After five years of sample collections, the sampling
protocol will be re-evaluated to determine if certain
pollutants can be targeted such that there can be a
reduction in the cost of laboratory analysis without
any reduction in monitoring effectiveness.
-------
TABLE 3 REMEDIAL ALTERNATIVE COST ANALYSIS
Remedial
Alterna-
tive
No.
1.
2.
• 3.
J».
5.
6.
7.
8.
9-
10.
11.
12.
Site
Debris
Removal
($)
o :
529,029
529,029
529,029
529,029
529,029
529,029
529,029
529,029
529,029
529,029
529,029
Demolish
Bldgs
(1)
0
268, 715
268,745
268,745
252,750
252,750
243,156
243,156
260,871
260,871 '
256,439
255,439
Site
Capping
(I)
0
0
331,930
75,620
331,930
75,620
331,930
75,620
331,930
75,620
331, 930
75, (>20
Soil
Excava-
tion
($)
0
0
0
0
1,191,250
1,191,250
1,979,755
1,979,755
714,530
714,530
1,012,512
1,012,512
Total
Implemen-
tation
Cost
($)
0
797,774
1,129,704
873,394
2,304,959
2,048,649
3,083,870
2,827,560
1,836,360
1,580,050
2,129,910
1,873,600
-------
•21-
5. Replacement of Monitoring Wells:
The present three downgradient well clusters
were originally constructed with galvanized pipe and
it is anticipated that the wells will need to be
replaced in 10 years. The two upgradBent wells will
be constructed with stainless steel pipe and it is
anticipated that the wells will need to be replaced
in 15 years. Monitoring well deterioration may
result from corrosion of the pipe or screen,
accumulation of silt in the well, or plugging of the
screens.
6. Well Maintenance and Rehabilitation:
A program of/well maintenance and rehabilitation
will be implemented every five years to insure that
the monitoring wells will provide representative
samples and that the surface integrity of the well
has not been compromised.
7. Topsoil Maintenance;
A program of topsoil maintenance will be implemented
every two years to insure that the topsoil cap completely
covers the site. Periodically it may be necessary to fill
in erosion channels, to add topsoil to areas where the
vegetation has become sparse.
8. Mowing of Grass:
Once the topsoil cap has been constructed and it has
been seeded and sodded it will be necessary to mow the
new grass during the growing season. The task would be
performed on a yearly basis probably during the summer
months and will become a integral part of the site
maintenance.
Commun i ty Re1at ion s
public meetings were held in October 1982, July 1983,
and September 1983 to discuss the remedial work performed
by CECOS and the studies conducted by Roy F. Weston. various
types of media (e.g., newspaper ads, fact sheets, radio) were
utilized to notify the public of these meetings. Representa-
tives of U.S. EPA, State, local governments and the community
were all well represented. Copies of reports and data were
provided, with a 20 day comment period.
A public meeting to discuss the Wade site feasibility
study was held at Chester City Hall on Wednesday, June 13, 1984.
The meeting, was conducted by the PA DER and EPA. public officials
and citizens were very interested in the future use of the site as
well as the timeframe for completion of the cleanup. There were no
written comments received.
-------
-22-
Recommended Alternative
Seption 300.68(j) of the National Contingency Plan
(NCP) [47 FR 31180, July 16, 1982] states that the appropriate
extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency
determines is cost-effective (i.e., the lowest cost
alternative that is technologically feasible and reliable) and
which effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare, and
the environment. Based on our evaluation of the cost-
effectiveness of each of the 12 proposed alternatives, the
comments received from the public, information from the
Endangerment Assessment, and information from DER and
Weston, we recommend that alternative 10 be implemented.
This alternative includes: the removal, decontamination,
and disposal of tankers, tires and debris; destruction of
buildings; soil removal; leveling, filling, and grading
the site, and covering with a seeded topsoil cap.
The recommended alternative is the least cost alternative
that is technically feasible and reliable, that meets the
requirements of the NCP and provides for future protection
of public health, welfare, and the environment. It also complies
with RCRA by calling for offsite disposal of contaminated
soil at a RCRA approved lined facility, and the level of cleanup
was determined in a manner consistent with the RCRA methodology.
In comparison with the other alternatives, alternative 10 has
the following:
1. Fewer monitoring requirements as a result of
the topsoil cap;
2. Requires less time to implement of all the soil
excavation options (lowest quantity of contaminated
soil requiring excavation);
3. Easiest to install of the soil options due to the
smaller soil excavation quantities;
4. Uses relatively proven technology, i.e., contaminant
source removal with proper disposal;
5. More durability with a topsoil cap than asphalt due
to a longer period of time that the level of effective-
ness can be maintained;
6. More effective than the no action remedial alternative
and non source removal alternatives;
7. If no action was chosen, we would still have the
problem of a release occurring which would ultimately
end in a ground water investigation;
-------
-23-
8. The exposure rate of most concern for the Wade
Site from the standpoint of public health is
- inhalation/ingestion of contaminated surface
soils. Further removal of soil beneath the
5 foot level (Alternative 12) would have no
impact on this route of exposure, and;
9. Removal of contaminated soil down to 5 feet
allows for protection of human health and
environment in the future.
The estimated costs for the recommended action are:
Remedial Action Estimated Cost
Site Debris Removal $ 529/029
Demolish Buildings $ 260/871
Site Capping $ 75/620
Soil Excavation $ 714/530
Total Implementation Cost = $1/580/050
Operation & Maintenance $ 320/000
Total = $1,900,050
Project Schedule
- Approve Record of Decision July 1984
- Award Contract September 1984
- Start Construction September 1984
------- |