UnltSv ?•- *
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0'
. TECHNICAL REPORT DATA
(Please ,ead Instructions on the ,evene before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R03-85/017
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1985
Harvey-Knott, DE 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 13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
U.S. Environmental Protection Agency 14. SPONSORING AGENCY CODE
401 M Street, s.w.
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
.16. ABSTRACT
The Harvey-Knott Drum Site is located in New Castle County, Delaware, approximately
one-half role east of the Maryland-Delaware border. The Harvey and Knotts Trucking,
Inc., operated an open dump and burning ground on the site between 1963 and 1969. The
facility accepted sanitary, municipal, and industrial wastes believed to be sludges,
paint pigments, and solvents. Wastes were emptied onto the ground, into excavated
trenches, or left in drums (some of which were buried). Some of these wastes were
either burned as a means of reducing waste volume, or allowed to seep into the soil.
Contamination of soil, surface \olater, and ground water has occurred as a result of dis-
posal of these industrial wastes.
The selected remedial action for this site includes: cleaning the onsite drainage
pond by collecting and treating surface water; removal and offsite disposal of con-
taminated sediments, sludges, and bulk wastes to a qualifying RCRA facility; removal
and offsite disposal of all crushed or intact surface drums, debris, wastepiles, and
sludges to a qualifying RCRA facility; installation of ground water extraction and
treatment facilities to collect and remove contaminants in the shallow ground water;
applying treated ground water to flush contaminants from onsite surface and subsurface
soils; and preparation of the site surface for installing the flushing pipe network
which entails (a) grading the entire application area, (b) covering with a 24-inch
(see separate sheet)
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFJERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Harvey-Knott., DE
Contaminated Media: gw, soil, sw, wetlands
Key contaminants: heavy metals, organics,
PCB s , inorganics
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Repo,,) 21. NO. OF PAGES
None c;o
20. SECURITY CLASS (This page) 22. PRiCe
None
EPA Fo'm 2220-1 (R.O'. 4-77)
PREVIOUS EOITION 15 OBSOL.ETE
II~
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INSTRUCTIONS
,.
REPORT NUMBER
Insert the [PA report number as it appeus on the cover of the public;ation.
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by each report redpient,
..
TITLE AND SUBTITLE .
Title should indicate dearly and briefly the subject ~overa~e "f the report. and be disl'laYL'd pruminently, S..t slItttitiL', ifu~L'LI. 11\ ~malier
type or otherwise subordinate it to main title. When a report is prep:ued in more than une volume, rL'p"at tl~ primary titlL'. a~ld v,.I:une
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REPORT DATE
Each report shan cury a date indicating at least month' and year. Indkale the !>asis un whidl it was sdecled (,."t., Jill" oliSSlIC'. elllll' oj'
Ilpprolltl/, dtlte 01 preptlTtltion, etr.).
5.
8.
PERFORMING ORGANIZATION CODE
Leave blank,
7. AUTHOR(S)
. Give name(s) in -<>nventional order (John R. Doc, J. Robt'" DOf.., I'tf'.j. Lisl authur's aflilialiun if il ,litTers frum th"'l>crfurminj: ..rj:ani.
zation,
8.
PERFORMING ORGANIZATION REPORT NUM8ER
Insert if performing organizalion wishes 10 assi", this number.
9.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, street, city, slate, and ZIP code. List no more th;an two h:vels of an urganizaliunal hireilrdlY.
10. PROGRAM ELEMENT NUMBER
Use the program element number under which the report was prepared. Subordinate numlx'rs ilia)' t>c indud..d in p-JrL'nlhL''''s.
11. CONTRACT/GRANT NUMBER
Insert conUact or grant number under which report was prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include lIP code,
13, TYPE OF REPORT AND PERIOD COVERED
Indicate interim final, etc., and if applicable, dates covered.
1.. SPONSORING AGkNCY CODE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such as:
To be published in, Supersedes, Supplements, dc.
18. ABSTRACT
Include a brief (200 words or less) factual summary of the most sij!nilkant informatiun L'untain.'" III III.. "'II4.rI. II tilL' '''1'''11 \'I'lIlallls a
significant bibliography or literature survey, mention il here.
Prepared in cooperation wilh. Translall.... ..I.. l'II:"'"I"j al """"'h'lIn' ..I'.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Seleci from the Thesaurus of I:ngineerinj! and Scientilk Terms the pruper auth..ri/ed It:llns I"alldentify the major
concept of the research and are sufficiently specitic and precise 10 be used as index entrics for l.:illalut:1n~.
(b) IDENTIFIERS AND OPEN.ENDED TERMS - Use idenlifiers for project nam.., code nilmcs, e4uipmcnt dc'it=naturs. ell.:. Use "I>CII-
ended terms written in descriplor form for those subjects for which no dcsc:riplor c",ists.
(c) COSATI HELD GROUP - Held and group assignments are to be taken from the 1965 ('051\1'1 Suhie!:t ('"tL,#,"Y Usi. Sincc Ihe ma.
jority of documents are multidisciplinary in nalure, the Prim;ary Held/Group assignmclIlIs' will bc ,pnilk diw11'linc, arca III' human
endeavor, or type of physical object. The application/s) will be cross.referc",:ed with scwndary I il'ld/(;ruuI> assll!'nll1cnls thai will "ulI..~
the primary posling/s).
18. DISTRIBUTION STATEMENT
Denote releasabiiit)' 10 the public or limitation for reasons other Ihan securily for example "Kcleaw t:llhIllIlCcl.- (';Ic allY a~ailalllhl)' I"
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DO NOT submit classified reports to the National Te!:hnicallnformation scrvke.
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Insert the price set by the National fechnicallnformation Scrvi!:c or the Goyernment Printing om!:c. if known.
E PI. FOf'm 2220-1 (R.... 4-77) (Re"e,.e)
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SUPERFUND RECORD OF DECISION
Harvey-Knott, DE
Abstract - continued
layer of clean soil, and (c) establishing permanent vegetation as a precaution
against direct contact. Total capital cost for the selected remedial alternative
is estimated to be ~3,572,OOOwith annual O&M costs approximately $776,000 for years
1-5, $90,000 for years 6-10 and $44,000 for years 11-30. Decisions on the extent
of aquifer restoration, cleanup actions in offsite streams and wetlands, and
final site closure will be deferred pending (a) additional soil investigation
during design, (b) analyses on the effectiveness of the chosen alternative and
(c) the impacts of the site on the adjacent wetlands.
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RECORD OF DECISION.
REMEDIAL ALTERNATIVE SELECTION
Site:
Harvey and Kno:~ Drum Site
New Cas:le County. Delaware
Data Reviewed:
The underlying technical information. unless otherwise specified. used
for analysis of cost-effectiveness and feasibility of remedial alternatives
is included in the following documents and project correspondence. I
have been briefed by my staff of their conten~s. and ~hey for~ the principal
basis for my decision of the appropriate extent of remedial action.
- Remedial Investigation/Feasibility Study Report (Draft). Harvey
and Knott Drum Site. New Castle County, Delaware. Volumes I, II.
III and IV. (NUS Corp.. Augus~ 1985)
- Work Plan. Initial Remedial Measure/Remedial Investigation/Feasibility
Study of Alternatives. Harvey and Knott Drum Site. New Castle County.
Delaware (NUS Corp.. August 1983).
- Remedial Action Master Plan. Harvey Knott Site. Kirkwood. Delaware
(Roy F. Weston. Inc.. February 1. 1983)
- Summary of Remedial Alternative Selection
- Recommendations by the Delaware Depar~ment of National Resources
and Environmental Control.
- Staff summaries and recommendations.
Description of the Selected Remedy
Specifically. this alternativ~ includes the following elements:
o Cleaning ~he onsite drainage pond by collecting and ~reating surface
water (est. 200.000 gallons). After the pond is dewatered. removal
and disposal of contaminated sediments. sludges. and bulk wastes
to a qualifying facility permitted under the Resource Conservation
and Recovery Act (RCRA) 40 C.F.R. Part 264. Subpart N.
o Removal and disposal of all crushed or intact surface drums.
debris. wastepiles. and sludges to a qualifying RCRA facility.
o Installation of ground water extraction and treatment facilities
to collect and remove contaminants in the shallow ground water.
Treated ground water will then be applied to flush contaminants
from onsite surface and subsurface soils. I~ is estimated ~hat
this extraction/treatment/flushing program will operate for five
years ~o restore the aquifer to drinking water quality or. final
EPA approved alternate concentration limits.
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o Preparation of the site
network will entail (a)
covering with a 24 inch
permanent vegetation as
surface for installing the flushing. p~pe
grading the entire applic~t:on area, (b)
layer of clean soil, and (c) establish~ng
a precaution against direct contact.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40
C.F.R. Part 300), I have determined that the remedial action described
above together with proper operation and maintenance constitute remedies
which mitigate and minimizes threats to and adequately protects public
health, welfare and the environment. The remedial action provides for
the removal and offslte disposal of surface wastes as a source control
remedy and the installation of ground water extraction/treatment/reappli-
cation facilities as management of migration controls. Seiection of target
and final endpoint levels of residual ground water and soil contam~nants
will be established in such a way so as to minimize the extent of the
shallow aquifer requiring long-term institutional controls while at the
same time, providing a technically feasible and cost-effective remedy.
The levels will take into account the site specific and regional
characteristics and will be protective of the public health, welfare and
the environment.
I have deferred a decision on final site closure requirements until
the post ground water extraction/treatment/reapplication soil grid sampling
program is evaluated.
I am a1so deferring selection of remedial response measures, if any,
for the adjacent wetlands and surface waters. Further assessment of the
impact of the site on th~se sensitive areas and evaluation of alternatives
to provide adequate protection will be performed.
. .
The selected remedy includes the operation and maintenance of the
ground water extraction/treatment/reapplication facili~ies to reduce or
. eliminate the potential exposure to ground water contamination. These
activities will be considered part of the approved action and eligible
for Trust Fund monies until such time that I made the decision regarding
the endpoint level of treatment for s01ls and ground water. At the time
when the levels are achieved I will a1so decide on the future status and
funding of O&M.
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for use at
other sites. In addition, the offsite transport and disposal of contaminated
material from the site is more cost-effective than other remedial actions
and is necessary to protect public health, welfare, or the environment.
Date
r ;0,/&'5-
" .
j . cc. /lL...:
J M. Seif
~ional Administrator
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SUMMARY OF REXEDIAL ALTERNATIVE SELECTION
HARVEY AND ~~OTT DRUM SITE
NEW CASTLE COUNTY, DELAWARE
Site Location and Description
The Harvey and Knott Drum Site is located in New Castle County,
Delaware, approximately one-half mile east of the ~aryland-Delaware bo~der
(figure 1). The community of Kirkwood is located approximately 5 miles
southeast of the site and the community of Glasgow lies approximately 3
miles northeast. The site is in a remote, rural area, previously used
for farming. Light residential development to the north of the site
consists of approximately 100 residences. The closest habitations are
several rural and trailer homes along Old County Road (Route 395) and
the Shelly Farms develop~ent (figure 2). .
The Harvey and Knotts Trucking, Inc., operated an open dump and
burning ground between 1963 and 1969 at the site. The facility accepted
sanitary, municipal, and industrial wastes believed to be sludges, paint
pigments, and solvents. Wastes were emptied onto the ground surface,
into excavated trenches, or left in drums (some of which were buried).
Some of the wastes were then either burned as a means of reducing waste
volume or allowed to seep into the soil. A security fence installed as
part of an EPA emergency action presently surrounds the areas (2.2 acres)
of greatest visible surface contamination.
There are two major water supplying aquifers in the area of the site
above bedrock (which is about 350 feet below the ground surface). The
shallow ground water occurs under water-table conditions and is referred
to as the Upper Hydrologic Zone (URZ). It is flowing to the southwest,
south, and southeast of the site, toward surface waters and wetland areas.
Most of the domestic drinking water wells in the area are installed in
the UHZ. Wells used for agriculture such as dairy farming or crop irrigation
also use the UHZ.
The second major source of ground water in the site area is the
Lower Hydrologic Zone (LHZ) which is under confined conditions. The UHZ
and the LHZ are separated by an aquitard referred to as the Potomac clay.
The LHZ is the major public and industrial water supply in New Castle
County (figure 3). Both the UHZ and LHZ are Class II aquifers as classified
under the Ground Water Protection Strategy.
Soils in the area consist of predominantly sandy materials underlain
by silts, clays, sands, and some gravels. They are well drained with
moderate to rapid permeabilities. The soils form a relatively flat land
surface that slopes toward the south which is also the general direction
of the shallow ground water. Ground water is generally encountered at
about five to ten feet below the ground surface.
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BASE MAP IS A PORTION CF THE U.S.G.s. EU
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. «' "~., o.\.~-( ~'. , ..-:....,...~,'h. -.:.' r-------~ .'.' ... ,'" ""'''' J.,....~~,' :'M APfR)~TE PfQIER'TY ...
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, ~~,. '.. ~/\:"(~RLY ~), '- ",' - - -' EDNAJ,ICHOTTS " "",A-"'< \ .(~,r:"" .... .
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LEGEND
0 ""tAL IIITINT t1' Wl\.L
~IUI. WCI.I.S ..ocATlO IN
ClIICI.&O AMAS AM ItVP-
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BASE MAP FROM DENVER AND MARTlN, U.S.G.s. <:PEN FIL£ REPORT 81-916,
FIGURE 3
LOCATION OF POTOMAC FORMATION WELLS
HARVEY AND KNOTT DRUM SITE, KIRKWOOD, DE
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-2-
The s~te area ~s drained by two unnamed tributar~es which border the
site on the east and west and flow south into Long Creek. Extensive
wetland areas surround the southwest, south, and southeast sides of the
site which have probably resulted from beavers building dams within the last
fifteen year along the tributaries and Long Creek.
Site History
The site was discovered by the State of Maryland Waste Management
Administration during an aerial overflight on January 14, 1981. Subsequent
to the overflight, the State of Maryland conducted a ground search and
determined that the site actually was located within the State of Delaware
and notified the Delaware Department of Natural Resources and Environmental
Control (DNREC). This onsite invest~gation by the State of Maryland.had
ident~fied numerous drums and wastes which had been disposed in an
uncontrolled manner at the site.
DNREC requested EPA assistance and both agencies conducted a pre-
liminary assessment in December 1981 to determine the immediate effect
of the site conditions on the public health and environment. Test results
indicated contamination in the soils and ground water by heavy metals
and organic chemicals including PCBs. To prevent direct contact with
exposed hazardous wastes at the site and to minimize the spread of conta-
mination via surface water runoff and ground water transport offsite,
EPA instituted Immediate Removal measures during June through August of
1982. These emergency measures included the installation of a security
fence around the areas of greatest visible surface contamination, over-
packing and staging 43 leaking drums and performing an extent of contam~-
nation survey. In addition, seventeen monitoring wells were installed
by the DNREC and EPA to identify the nature and extent of contaminated
shallow ground water.
. Based on the analytical results received from the preliminary assess-
ment/site investigation, the Hazard Ranking System score at this site ~as
30.77. The site was then proposed for placement on the National Priorities
List, and authorization to proceed with a Remedial Investigation/Feasibility
Study was approved in April 1983. .
Site conditions (Figure 4) as encountered prior to the Remedial
Investigation can be characterized as follows:
An area of approximately 2.5 acres had been fenced to prevent access
to drums and an open pond.
Stockpiles of empty to full drums in various states of deterioration,
were located within the fenced area.
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!~ ..,::''''',''' ~ ," ---.' .,,-;-;,,;,. . """":.--';-' ~-:';'f" '"~o,''' -: ::"~. ... ~c. toenAIIIIlATED WASTE I'Ili .. .1.--'\,\
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- --~~,,- .-:/'" '\~;'.' ':. .J~k0t;~:',." i.~/", ,/ i"',.. '~r~,.DRI8I.N«J ~~WA\"E "Ti
~""~.~::~~'I"1\",~..:_.:. '~,:',:"".~,'.":'(fP! l~~,(\i 'J ',~~~) '. ,~~. '~'-:.' .,'.','~' ;.1.: :' ;,. ,//.'.',/./" l
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:';!::;-{";: . ;," . ., ~ -'''~' (.. .,' - ..:., -.., ~ J/! ' "~l~~T~ ~TER~~.: I .:: /-,-"',.', ~-) ,!......o.,
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;~' " ' ',!,<,~ .:.. oc-ttD AREA >--.::-:--,........ " ;," 1/'." ., .. \ I
lIt' ..t'.: . J '. CIOLI8IMOI8 011 ~AL--1'IT1 '.' .",' ,'j I' .' "', ...
:i~) . .1 l~~K) "':' .. -i;.-./:~~:" i "--. / ,.'.'\ ,: }d'l ; I " . /0,\ \ \;
. , ~ I J I. ' , '--::,,;-/~. ' " I' /..., .' h~/ ./ .",/ ~ \ \ \: r"\
FIG URE 4
EXISTING CONDITIONS
HARVEY AND KNOTT DRUM SITE I KIRKWOOD. DE
LEGEND
.... [.~TlNO WELLS
100 0
P"'"""""IIII!~
SCALE IN FE fT
100
.
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-3-
Stockpiles of landfill-type wastes (lumber, steel, garbage, and unknown
waste) were generally located in the center of the fenced area.
A small waste pile had been developed in the eastern side within the
fenced area.
A pond within the fenced limit contained various types of landfill waste
in addition to drums.
An area north to northeast of the fenced area showed evidence of localized
stressed vegetation and land surface disposal of liquids and/or sludges.
An area west of the fenced area, which receives surface runoff from
. the fenced area, showed evidence of stressed vegetation. However,
this area is also poorly drained, a factor which could cause this
condition.
An area south-southwest of the fenced area had been excavated for soil
borrow or for use as a supplementary disposal area.
The natural topography of the land on and offsite indicates .that drainag~
of surface runoff is poor and results in ponded water and swamps, both
seasonal and perennial. Furthermore, beavers have created additional
ponded water areas west and south of the site increasing wetlands
conditions.
Contamination of soil, surface water, and ground water had occurred
as a result of disposal of industrial wastes. The exposure to dermal
contact had been temporarily mitigated by the installation of a fence.
Since there were a number of residents using the shallow ground water
upgradient of the site, the potential for contamination existed if the
ground water flow was modified by increased pumping of upgradient wells.
The wetland environmental habitat downgradient of the site also could be
affected by (a) migration and discharge of shallow contaminated ground
water and (b) surface runoff from the site.
In an effort to minimize immediate and obvious hazards to the public
and the environment, an Initial Remedial Measure (IRM) was conducted by
EPA within the fenced area during March through June of 1984. The IRM work
plan consisted of characterizing the wastes within the fenced limits,
consolidating wastes where appropriate, and transporting the wastes to an
EPA-approved disposal facility. During the execution of the work it
became obvious that the number of drums, waste stockpiles, and quantity
of industrial type wastes (paint pigments, sludges, and solvents) was
greater than anticipated. As a result, the amount of materials to be
.removed had to be reevaluated. The increased quantity affected the
characterization of all onsite wastes and the scope of work had to be
revised to remove only the most hazardous materials.
-------
-4-
Based on analytical results (a composite sample of the overpacked
drums showed 1.3 percent Aroc10r 1254), the existing 43 overpacked drums
were repackaged, removed, and disposed of at the CECOS International,
Inc., facility in Ohio. Testing also indicated one waste stockpile
in the eastern area of the fenceline contained at least 750 ppm of Aroclor
1254. A soil berm and surface drainage ditch were constructed around
this PCB-conta~inated wastepile to: (1) collect and direct surface runoff
from the PCB-laden stockpile into the pond within the fenced limits, and
(2) to prevent further runoff to the north and east areas outside the
fence. .
Approximately 500 drums that were identified as being empty were
characterized, crushed, and staged within the fenced area. Another 290
drums that were partially to entirely full are staged in another area
within the fenced area. The central zone of the fenced area still has
numerous drums that have not been staged and characterized to determine
whether they contain any hazardous wastes.
Current Site Status
Results of geophysical surveys did not identify the presence of
buried ferromagnetic materials outside of the fenced area. Interpretations
of the electromagnetic survey (plume identification or presence of clay)
were used to locate monitoring wells and understand. the subsurface
conditions. A buried gravel deposit was identified outside of the southeast
side of the fenced area.
Due to the presence of extensive amounts of surface metal within
the fenceline, the use of geophysical techniques was precluded in this
area. In an effort to determine the presence of buried drums and the
extent of contamination within and immediately outside of the fenced
area, test pit excavation programs were performed. Crushed and intact
drums were found in the west-central part of the fenced area at depths
of four to seven feet.
Surface and subsurface soil sampling locations are shown on figure 5.
A number of Hazardous Substances List (HSL) organic compounds and inorganic
elements were detected. Organic compounds include: volatile organics
(halogenated aliphatics, monocyclic aromatics, and ketones); semi-volatile
organics (phthalate esters, phenols, and amines); pesticides; and PCBs.
Trace elements include all those on the HSL.
As indicated on Table 1, volatile contamination (numbers 1 through
5) was prevalent in high concentrations particularly in subsurface samples.
The most highly contaminated soils were found in test pits l2(at a depth of
7 ft.), TP-17(8 ft.) and TP-18(4 ft.) on the southern periphery of the fenced
area and a150 TP 20(3 and 6 ft.) just outside the western fence limit.
Surface soils generally exhibited 100 to 1,000 times less than the volatile
contamination found in subsurface soils. This could be attributed to
-------
_301
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FIGURE 5
SOIL SAMPLING LOCATIONS
HARVEY AND KNOTT DRUM SITE. KIRKWOOD. DE
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-------
TABLE 1
CONTAMINANTS OF CONCERN
ItARVEY AND KNOTr DRUM SUE
No. of Observations/ Concentration Pertinent
Contaminant Media Total No. 0' Samples Ranne Inclusion Rationale
1. Benzene Surface Soils 1/40 6 ug/kg Proven carcinogen, high
CAS No. 74-43-2 Groundwater 9/72 5 - 1,130 ug/I groundwater concentration
2. Ethylbenzene Subsurface Soils 6/23 10 - 1,200,000 ug/kg Prevalent in media. high
CAS No. 100-41-4 Groundwater 15/72 5 - 8.530 ugll concentration in groundwater
Sediment 4/7 8 - 990 ug/kg
3. Methylene Chloride Surface Solis 4/40 36 - 134 ug/kg Prevalent throughout media in
CAS No. 75-09-2 Subsurface Soils 14/23 13 - 5,200,000 ug/kg high concentrations, highlV
Groundwater 24/72 4 - 81.300 ugll mobile.
Surface Water 5/7 5 - 398 ug/I
Sediment 7/7 9 - 47.000 ug/kg
4. Toluene Surface Soils 10/40 1 - 727 ug/kg Prevalent in media, high
CAS No. 108-88-3 Subsurface Soils 8/23 6 - 2,400,000 ug/kg concentration In groumJwater,
Groundwater 16/72 8 - 211,746 ug/I chronic toxicity
Sediment 3/7 6 - 830 ug/kg
5. XVlenes (Total) Surface Soils 3/40 26 - 180 ug/kg Prevalent in media. high
CAS No. 1330-20-7 Subsurface Soils 9/23 27 - 1,600.000 ug/kg concentration in groundwater
Groundwater 20/72 7 - 36,593 ugll
Sediment 4/7 29 - 1,530 ug/kg
6. 01 s(2 - ethvlhexvl)phthala t e Subsurface Solis 5/23 396 - 7,300 ug/kg Carcinogenic potential. present
CAS 'No. 117-81-7 Groundwater ,8/72 10 - .286 ugll In groundwater
7. PCO-1260 Surface Soils 3/40 93 - 237 ug/kg Carcinogenic potential,
CAS No. 11096-82-5 Subsurface Solis 6/23 49 - 330 ug/kg bioaccumulation potential
Sediment 2/9 1.600 - 41,000 ug/kg
-------
TABLE 1
CONTAMINANTS OF CONCERN
UARVEY ANO KNOTT ORUM SITE
PAGE TWO
No. of Observations/ Concentration Pertinent
Contaminant Media Total No. of Samples Range Inclusion Rationale
8. Cadmium. Surface Soils 34/40 0.08 - 291 mg/kg Prevalent throughout media
CAS No. 7440-43-9 Subsurface Soils 20/23 0.03 - 25 mg/kg present In residential wells
Groundwater 5/56 1 - 6 ug/I
Residential Wells 3/6 1 - 3 uglt
Surface Water 1/9 4 ug/I
Sediment 8/9 0.22 - 3 mg/kg
9. Chromium. Surface Soils 40/40 3 - 181 mg/kg Found in groundwater in excess
CAS No. 7440-47-3 Subsurface Soils 10/23 9 - 66 mg/kg 0' primary drinking water
Groundwater 4/56 10 - 420 uglt standards. prevalent throughout
Surface Water 2/9 10 ug/I media
Sediment 8/9 3 - 29 mg/kg
10. lead. Sur'ace Soils 40/40 3 - 20.200 mg/kg Found in groundwater in excess
CAS No. 7439-92':"1 Subsurface Soils 23/23 3 - 6.000 mg/kg of primary drinking water
Groundwater 8/56 5 - 111 ug/I standards
Residential Wells 3/6 5 - 7 uglt
Surface Water 4/9 6 - 162 ugll
Sediment 8/9 10 - 128 mg/kg
. Concentrations reported for groundwater are from post-1983 sampling only.
-------
-5-
(a) the volatilization of surface (0-24 inches) contamination, (b) downward
migration from infiltration of precipitation since volatiles are relatively
water soluble, and (c) decomposition by biological activity.
Semi-volatile organics detected in subsurface soils reflect the
contamination exhibited by volatiles. Samples obtained from test pits
12, 17, and 20 contained high concentrations (10-100 ppm) of base/neutral
extractab1es. Although these compounds are not as mobile in the environment
as the volatiles their appearance at high concentrations in subsurface
soils may be attributable to increased solubility caused by volatile
contamination or to direct deposition.
PCBs identified in surface and subsurface soil samples include the
following:
Concentration Range (ppb)
Chemical
Surface Soil
Subsurface Sol1
PCB 1254
PCB 1260
ND - 3169
ND - 237
ND - 540
ND - 330
ND - Not detected
Areas contaminated with PCBs are:
Surface soil to the northeast of the fenced area.
Subsurface soil in the central portion of the fenced area.
Surface soil directly west of the fenced area.
Surface soil in the 10w1ying area directly south of the site.
PCBs are relatively immobile in the environment because of their
limited water solubility and their tendency to adsorb to at sample locations
soils. Thus, it is likely that these contaminants were deposited where
they were detected, except in the area to the west of the fenced area.
PCBs were probably adsorbed to 80il particles and transported by surface
water runoff from other areas of the site. The ability of PCBs to adsorb
to soil particles makes them susceptible to transport because of erosion
or airborne migration. The area to the west of the site is a drainage
area that collected surface water runoff from the fenced area during
site operation. It appears that the presence of PCBs in this location
resulted from erosion of contaminated soils.
Most areas of the site contain trace elements above
background levels. While trace element contamination is
scattered about the site, the concentrations encountered
are very high. These areas include:
literature
apparently
in some areas
Surface soil to the northeast of the site
Subsurface soil in TP-1 through TP-8
Surface soil near TP-7
Subsurface 50i1 in TP-25
-------
-6-
The most contaminated area is the vicinity of test pits 1 through
8. Contaminants in this area probably resulted from the deposition
of wastes containing trace elements. The presence of trace elements ~n
the northeastern and southern areas is also indicative of concentrated
disposal. The presence of trace elements outside of the fence area on
the west side is probably due to erosion and surface runoff of contaminated
soils, similar to the transport of PCBs in this area. .
Chromatographic screening results identified HSL organic and inorganic
substances in both surface water and sediment samples obtained from
locations (figure 6) within site boundaries and in surface water bodies
near the site. Sediment samples contained all of the volatile compounds
frequently identified at high concentrations in other site media (see
Table 1) which indicates that chemical contaminants are migrating from
the site. It is believed that occurrence of volatile compounds in the
sediment samples (101 through 106) could be attributed to the discharge
of shallow contaminated ground water to the surface water bodies. Transport
of eroded contaminated site soils is unlikely due to the distance from
the' site to the sample locations. Also, overland contaminated surface
runoff is a possibility, but due to the volatilization process enroute
to the surface water bodies, it is unlikely that this was the major mode
of transport.
Surface water contamination from volatile compounds was minimal (only
detected at location 101 and 102 at less than 0.4 ppm). Evaporation of
volatiles from surface waters is expected to occur quite rapidly.
Semi-volatile contamination was detected in sediment samples 1, 2,
3, 4, 106, and 5. The presence of these compounds in sediment samples is
probably attributable to (a) erosion of contaminated site soil since the
travel distances are not great (with the exception of location 5) and (b) con-
taminated ground water discharge through sediments to surface water bodies.
The absence of semi-volatile compounds in surface water samples
obtained at the same locations is indicative of the partitioning of the
chemicals between the water and sediment compartments and is reflective
of their generally low water solubility and high soil adsorption potential.
PCBs were detected in sediment samples at location ff2 (41ppm), location
#3(1.6 ppm). and location 05(0.08 ppm). It should be noted that a
duplicate sample at location 05 did not detect PCBs. The presence of PCBs
at locations 2 and 3 is probably due to erosion of contaminated soil from
the site. there were no detectable PCBs in surface water samples.
Trace elements. which were detected in surface waters, are of concern
because of their known toxic effects upon aquatic organisms. Lead (162
ppb) was the only element to significantly surpass the Proposed Water
Quality Criteria level 2/7/84 (acute toxicity - 40 ppb based on calculated
water hardness). This sample was taken from the pond within the fenceline.
It should be noted that an upstream sample taken from Long Creek during
preliminary investigations contained 130 ppb of lead. The onsite pond
also contained the highest sediment sample concentrations for lead (98
ppm). cadmium (3.2 ppm), arsenic (9.5 ppm), and chromium (29 ppm).
-------
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LEGEND
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-...C WATP I UDIMOn' SAWUHQ LOCAT'Of
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SURFACE WATER AND SEDI MENT SAMPLING LOCATION
HARVEY AND KNOTT DRUM SITE. KIRKWOOD. DE
o SSO IJ/)O
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SCALE IN FEET
-------
-7-
Geologic and Hydrogeologic Summaries
The purpose of the subsurface investigation/well installation program
was to determine the nature and extent of contamination that had migrated
through ground water movement. Previous investigations of the site
hydrogeology (Shaly 1982) concluded that the shallow ground water under
the site is flowing away from the residential area of Shelly Farms which
is located northeast and north of the site. The shallow ground water
flow is to the southwest, south, and southeast of the site, toward surface
waters and wetland areas. Previous investigations also determined that the
shallow ground water in the vicinity of the site is contaminated by organic
compounds.
The location of site monitoring wells is shown on figure 7 while the
A-Al geologic cross section is diagramed on Figure 8.
The uppermost formation occurring at the site 1s the Columbia
Formation consisting of very dense, fine to coarse, grained sands, fine
to coarse grained gravels, silty sand and gravels, and occasional cobbles.
Deposits that occur at the site range in thickness from 19 to 46 feet.
Ground water seepage velocities range from SSO feet/year southwest of the
site to 2,300 feet/year southeast of the site.
Beneath the Columbia Formation lies the Upper Potomac Formation.
These deposits are very dense, fine to coarse grained sands, uniform
medium sands, silty sands, and very stiff, variegated sandy clays, and
silty clays. Thickness of the Upper Potomac Formation increases to about
60 feet south of the sit~ from almost non-existent north of the site.
The ground water seepage velocity in the Upper Potomac deposits is
estimated at 240 feet/year.
Based on the correlation of subsurfac~ geology and hydraulic connection
of the Columbia and Upper Potomac Formations, these deposits are considered
to be one hydrologic zone (the Upper Hydrologic Zone). The UHZ is under
water table conditions over most of the site area. Discharge from the
UHZ supports base flow to the unnamed tributaries east and west of the
site and Long Creek.
Precipitation is the source of recharge to the UHZ and affects its
capacity to support base flow to streams in the study area. The average
annual precipitation of over 44 inches is more than adequate to replenish
the UHZ which requires about 14 inches per year for recharge.
Beneath the UHZ lies the Potomac clay and Lower Hydrologic Zone.
The Potomac clay is a major confining layer (aquitard) between the UHZ
and LHZ. It is comprised of very stiff, variegated, silty clay or clay
with discontinuous lenses of very fine to medium sand, silty sand and
sandy clay. The average thickness of the Potomac clay is approximately
ISO feet. Ground water flowing through the Potomac clay has a downward
vertical gradient. The average vertical velocity is on1y 1.3xlO-2 ft/year.
-------
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FIGURE 7
MONITORING WELL LOCATIONS
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FIGURE 8
GEOLOGIC CROSS-SECTION A-AI
HARVEY AND KNOTT DRUM SITE, KIRKWOOD. DE
50
o
10
.
~-
WI.tlCAL SCAU 'linn
-------
-8-
The Lower Potomac deposits and the weathered bedrock comprise the LHZ.
Deposits in the LHZ consists of intarbeddad fine to medium sands, lignitic
silty sand, and stiff s11ty clay. The lower deposits average about 70
.feetin thickness. A velocity of 130 feet/year was calculated for the
LHZ. Based on geologic data in the LHZ, the direction of ground
water flow in the LHZ was expected to be toward the southeast in the
downdip direction of the Potomac Formation. Monitoring well readings
indicate that the LHZ is actually flowing in a northeast direction. This
suggests that the LHZ is under some influence, perhaps from public water
supply production wells in the vicinity of the site.
At this time there are three known well fields in the LHZ in the
area of the site. As indicated on figure 3, these fields and their
distances from the site are: Artesian Eastern State - 1.5 miles; Artesian
Brennan Farm Wells - 2 miles; and City of Chesapeake Municipal Wells.-
4 miles. The Eastern State well field (500 gpm) probably has more
influence than the Chesapeake wells (118 gpm) due to distance from site
and higher pumping rates. The Brennan Farm wells are not in production
~t this time due to the presence of excess iron in the ground water.
Ground Water Contamination
The majority of the monitoring wells installed at the site are
screened in the UHZ. The available data indicates that contamination
of ground water in the UHZ has occurred and the available data indicate~
that the LHZ may also be threatened. Monitoring well 1010 is screened
in a sand lens in the Potomac clay between the UHZ and LHZ (figure 8).
Monocyclic aro~atic contamination was present in this well during the
August 1984 sampling round but not during the August 1985 sampling round.
Geologic Investigations reveal that the Potomac clay layer below the
site is not continuous and that there is a potential for contaminant
migration to the LHZ. This potential is considered to be low based on
(a) none of the three deep wells' (107D, 1080, and l09D) in the LHZ were
contaminated, and (b) the slow ground water velocity (1.3 x 10-2 ft/yr)
and thickness of the confining layer (150 ft). It should be noted that
there is no existing downgradient well in the LHZ since the general flow
direction was found to be toward the northeast. Each Remedial Alternative
will include installation and monitoring of thedowngradient flow to
evaluate whether contaminated ground water has traveled through the
Potomac clay. If contamination is detected remedial actions will be
investigated and implemented for deep aquifer contamination.
Chemical contaminants identified in shallow ground water correlate
with contamination observed in surface and subsurface soils. Toluene,
ethylbenzene, total xylenes, and methylene chloride were detected in shallow
ground water samples at high concentrations. Coupled with chemical
results from test pit samples, contaminants identified in UHZ monitoring
wells indicate the existence of at least one major contaminant plume
(figure 9). This plume has migrated from the site in the southerly
direction of the shallow ground water flow.
-------
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FIGURE 9 300
.
VOLATILE CONTAMINANTS IN UPPER HYDROLOGIC ZONE- SHALLOW WELLS (1984 RESULTS)
HARVEY AND KNOTT DRUM SITE. KIRKWOOD. DE
.....
..,ISl.
.. )..
1.'11
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300
I
SCALE IN FEET
-------
-9-
Figure 10 indicates that contamination has also migrated in an
east/southeasterly direction toward the gravel channel and hlgher relative
ground water seepage velocity of 2300 ft/ye3r.
Contrary to expectations, methylene chloride was found in monitoring
wells 104SA, 8, 1, and 5 which are north and west of the fenced area.
Due to the flatness of the topography surface runoff and shallow ground water
may be initially migrating in a radial pattern particularly after periods
of heavy precipitation. It should be noted .that monitoring wells 8 and
5 were found to be clean during the August 1985 sampling round.
Semi-volatiles followed the trend set by the volatiles in ground
water, that is, they reflect the existence of a southerly contaminated
ground water plume. The highest concentration of semi-volatiles were
present in samples obtained from monitoring wells 6 and 9.
PCBs were not identified in ground water at the slte. This is best
explained by the low water solubility and high soil adsorption potential
of these compounds.
The occurrence of pesticides found in monitoring wells land lOlSC is
not considered to be site related for two reasons: these compounds were not
identified in other media at the site, and these compounds are generally
very insoluble in w~ter unless they have been formulated for agricultural
application. The adjacent areas around the site have been or are currently
being used for agricultural purposes. .
Inorganic contamination in ground water was not demonstrated to be
widespread with the exception of chromium in monitoring well 11 (420 ppb)
and lead in monitoring well 101D (111 ppb). The substantial amounts of
inorganics in site soils constitute a source for trace metal contamination
in the shallow ground water. Ground water contamination with lead and
chromium is indicative of leaching of inorganics from the soil compartment
since these locations are near the fenced area. .
Available results from the LHZ reveal no inorganic contamination in
this aquifer.
. None of the organic HSL compounds identified at the site were detected
in upgradient residential wells. Lead and cadcium were identified in one
well during a 1983 sampling episode at concentrations of 7.1 ppb and 3.3
ppb respectively. These are below the National Interim Primary Drinking
Water Standard (NIPDWS) limits of 50-ppb lead and lO-ppb cadmium. A sub-
sequent resampling of this well in 1984 did not identify these contaminants
above the detection levels.
Endangerment Assessment
Preliminary and' Remedial Investigations at the site have.revealed
extensive contamination resulting from past waste disposal practices.
Surface and subsurface soils and sediments are contaminated with organic
compounds, PCBs, and inorganic trace elements. Shallow ground water 3nd
surface waters are contaminated with organic and inorganics substances.
-------
~ - - .
'~., -
\ I \:
--
\
\
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'-...... /-~
.~9' ',' /' . "--
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'. ".....
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'-1 \ \
~~.
FIGURE 10
VOLATILE CONTAMINANTS IN UPPER HYDROLOGIC ZONE DEEPER WELLS
HARVEY AND KNOTT DRUM SIT~. KIRKWOOD. DE
300
.
LEGEND
- CCIIP. IOItQ111118 WRLS AS 0# 0ZII4/85
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."UII(
fTlfYL ...lOf
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TOTAL aYLfJlt:S
COIIfIOUIIOS U..OfTfCTfO A80Vf "UHOO
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'WI'O""""~ 00UfT(7 ~1'I..I.IoC
!II!I1' AU. IMUIfI IN "./1.
o
300
.
SCALE IN FEE T
-------
-10-
Routes of contaminant transport paths for potential exposure of
human and environmental receptors in the vicinity of the site are:
Transport via the movement of shallow contaminated ground water
under the site. Contaminants may move with shallow ground water
and discharge to the nearby surface water and to the wetland
areas located in the vicinity of the site.
Contaminated sediment transport due to erosion and surface water
runoff of contaminated surface soils.
Evaporation of volatile organics to ambient air, if favorable
meteorological conditions and soil disturbances (during remedial
action) enhance emissions to a significant degree.
Physical transport of site contaminants by surface water during
high flow conditions.
Potential human and environmental receptors at this site include:
Users of ground wat-er as a potable water supply. Potential receptors
in the Upper Hydrologic Zone surround the site at varying distances
from it. For receptors presently located upgradient of the site,
there is a potential for exposure to site contaminants only if
ground water movement is altered (i.e., by pumping). For those
receptors in the UHZ located downgradient from the site, the wells
are separated from the contaminated plume by the many wetland
areas to the southwest, south, and southeast of the site. The
effectiveness of the wetland areas in attenuating contaminants
is not known; in addition, the percentage of the shallow ground
water passing beneath the wetlands is also unknown.
If the Lowe~ Hydrologic Zone (lower Potomac Aquifer), which is
classified as a production zone, were to become contaminated,
the potential number of receptors would increase dramatically.
At this time, there is no actual exposure to receptors via ingestion
of contaminated ground water.
.
Persons using
w~tland areas
exposure) and
fish).
Long Creek, the beaver pond, and all other surrounding
for recreational purposes, i.e., swimming (dermal
fishing (dermal exposure and ingestion of contaminated
Environmental receptors, including aquatic biota in affected
surface waters, onsite terrestrial fauna using aquatic animals as
food sources, and terrestrial vegetation.
Property owners, third party intruders, and remediation personnel
who traverse the site and come in direct contact with contaminated
wastes, 'surface soils, or surface waters.
-------
-11-
It should be noted that the available data do not indicate any
documented past or present human exposure. The following health and
environmental risks associated with this site are based on comparisons
with relevant environmental exposure criteria, and the conclusions are
derived from the contaminant patterns, opportunities for exposure, and
the toxicity of the contaminants.
The majority of the potential receptors using ground water for
drinking,purposes in the locally contaminated Upper Hydrologic
Zone (URZ) are upgradient of the site. Therefore they are not
considered to be exposed to the site contaminants unless the
ground water gradient changes dramatically. The URZ water users
to the southwest, south, and southeast are hydraulically downgradient
from the contaminated ground water plume in the vicinity of the
site. The potential for future contamination of these residential
wells is related to the degree of contaminant migratIon beyond
the site wetland areas. The downgradient ground water discharge
rates have not been quantified because of site data base limitations.
Monitoring wells have not been placed beyond and downgradient of
the wetlands. Contaminant migration is potentially moving beyond
the wetlands toward downgradient receptors.
The many production wells located in the Lower Hydrologic Zone
have not been affected by the contaminated ground water in the UHZ,
however, the potential for downward migration between the URZ and
LHZ exists. The contamination detected in the sand lens in the
clay-silt matrix separating the URZ and LAZ (MW-IOID) is an
indication that the plume is migrating vertically through
this aquitard.
Much of the shallow ground water discharges to the numerous
surface water bodies and wetlands to the southeast, south, and
southwest of the site. Therefore, the potential for toxic effects
to aquatic organisms is expected.
Inhalation of volatilized contaminants and of contaminated
inhalable particulates from the site is not considered to pose a
potential health hazard at this time. However, should a major
soil disturbance and/or contaminant migration occur, the potential
for this exposure will increase.
.
Dermal exposure to site contaminants is a concern. Even though
the'areas of highest surface soil contamination are contained
within a fence, contamination to the northeast and west of the
fenced area and in the surrounding wetland areas is easily accessible.
The potential for toxic effects to terrestrial organisms (vegetation,
soil/organisms, mammals, etc.) is expected to be high onsite due to
levels of contamination found in the soils.
There exists a potential risk of
wetland areas which would result
environmentally sensitive areas.
contaminant migration toward the
in possible degradation of these
-------
-12-
Alternatives Evaluation
The major objectives for remedial action to be taken at the Harvey
ahd Knott Drum site are to mitigate or eliminate environmental contamination
and migration at the source area. This would involve preventing and/or
reducing: (a) direct contact with contaminated surface soil. water. sediments
and bulk waste products (b) further migration of existing contaminated
shallow ground water. (c) existing concentrations of contaminants in the
UHZ. (d) future contamination of the UHZ. and (e) existing contamination
and further degradation of surface waters. The requirements of CERCLA
Section 104. EPA's mandate to protect the public health and welfare and
the environment. determine the goals and level of response for the site.
In an effort to determine remedial alternatives for the subject
site. feasible technologies were identified for consideration in general
response actions. Available technologies were then screened to eliminate
all but the most definitive and implementable alternatives. This
screening included: technical (site conditions or waste characteristics). .
environmental and public health. institutional. performance and cost criteria.
Certain response actions and technologies were not associated with
any specific remedial objective or feasible technology for the site.
These technologies and response actions and the rationale for not including
them are listed on Table 2. Further detail of this initial screening is
included in Section 9 of the Feasibility Study.
Those technologies that have passed the technology screening process
were used to form remedial alternatives. These components were then combined
to form various remedial alternatives (Table 3). These alternative are listed
in the Alternatives Matrix with associated costs. Remedial alternatives
were developed using best engineering judgement to select a technology
or group of technologies that best addresses the problems existing at
the site to protect public health, welfare and the environment. In an effort to
provide a degree of flexibility in the final selection of a remedial
action. alternatives covering a range of remedial action categories have
been developed. These categories are described below:
A.
No action:
No-action alternatives could include monitoring activities.
B. Alternatives that meet the CERCLA goals of preventing or minimizing
present or future migration of hazardous substances and protecting human
health and the environment. but which do not attain all of the applicable
or relevant standards. (This category may include an alternative that
closely approaches but does not meet. the level of protection provided by
the applicable or relevant standards.)
-------
-13-
C. Alternatives that meet CERCLA goals and attain all applicable or
~elevant Federal public health and environmental standards, guidance, and
advisories.
D. Alternatives that exceed all applicable or relevant Federal
public health and environmental standards, guidance, and advisories.
E. Alternatives specifying offsite storage, destruction, treatment,
or secure disposal of hazardous substances at a facilitiy approved under
the Resource Conservation and Recovery Act (RCRA). Such a facility must
also be in compliance with all other applicable Environmental Protec~ion
Agency (EPA) standards.
The evaluation criteria selected were: technical feasibility, public
health, environmental, institutional evaluation, and cost effectiveness.
Particular emphasis was placed on:
- Technical Feasibility
o Performance
o Implementability
o Reliability
- Public Health Evaluation
o Reduction of Health Impacts
- Environmental Evaluation
o Reduction of environmental impacts
o Protection of Natural Resources
Institutional Evaluation
o Legal requirements, institutional requirements
o Community Impacts
- Cost Effectiveness
o Capital Costs
o Operation and Maintenance
o Present Worth Values
o Sensitivity Analyses
Costs
-------
-14-
Description of Remedial Alternatives
A.
No Action Alternatives
. Alternative No.1 - No Action with Monitoring
This remediation activity will not improve site conditions, nor will
it reduce the migration of site contaminants. Contaminants were identified
in the shallow ground water (most notably toluene, xylene, and ethyl benzene).
It is expected that ground water discharge to surrounding wetland areas
could introduce contaminants into these locations. Regulatory control of
the use of ground water in the vicinity of the site is recommended.
Soils in the vicinity of the site are highly contaminated. ~oils
inside the fenced area aI'e not readily available for direct human contact;
however, wildlife species are not currently prohibited from contact with
this area. Extensive soil contamination has been detected outside the
fenced area as well. These areas are available to human and wildlife
receptors because the location of the site is close to a residential area
and there is no additional fence to prohibit property access on foot.
Alternative 1 includes a long-term monitoring program to provide
information on the extent of contaminant migration as a function of time.
The results of the monitoring program could confirm (1) decreases in the
extent or concentration of contaminants as a result of natural processes;
(2) increases in the extent of concentrations of contaminants, in which
case other remedial al~ernatives could be reconsidered; or (3) no change
in the extent of concentration of contaminants, indicating that conditions
have stabilized at the site.
The long-term monitoring program will consist of the following
activities:
installing nine new monitoring wells (one in the LHZ, and eight in
the UHZ)
.
sampling nine new and ten existing monitoring wells (see
FS report p 10-8)
. .sampling nine surface water locations (see FS report p 10-8).
- COMMON TO ALL ALTERNATIVES -
The remedial components for onsite pond cleanup, surface cleanup and
offsite drum disposal, and post closure monitoring are essential site
cleanup activities and have been included in all of the alternatives except
for the No Action with monitoring.
-------
General Response Action
Containment
Diversion
Complete Removal
Onsite Treatment
In-Situ Treatment
TADtE 2
ELIMINATED GENERAL RESPONSE ACTIONS AND
ASSOCIATED REMEDIAL TECIINOlOGIES
IIARVEY AND KNOTT DRUM SITE
Eliminated Remedial Technologies
Groundwater containment barrier walls
and well point systems
Gas barriers
Terraces and benches
Chutes and downpipes
levees
Seepage basins
Sewers and water pipes
Solidification
Incineration
Permeable treatment beds
Bioreclamation
Neutralization
Landfarming
Comments
Site characteristics do not support this technology
(lack of a continuous impermeable formation).
Installation and operation costs of this technology
do not provide sufficient technical benefit.
Data does not support the need for this technology.
Surface water runon not affecting site significantly.
Surface water runon can be controlled by other means.
flood plains not applicable to site.
Site characteristics do not support this technology.
Not applicable to this site.
Random cO-disposal of various industrial waste
mixtures cannot be treated with any effectiveness by
this technology.
Waste characteristics do not support this technology.
Random co-disposal of various industrial waste
mixtures cannot be treated with any effectiveness by
these technologies. Site characteristics. i.e. shallow
groundwater table. also preclude the use of these
technologies.
-------
1 \OLE "3
IU-M[UIAI A :-IIUN AI,TERNAliVES
IIARVEY I\N » KNon DRUM SHE
Component Technologies Developed Remodlal Action Alternatives
1 2t 20 . 2C 3A 3D 3C ...!.. i
No Actlnn with Monllorlng X
rosl-Closuro MOllllorlno )( )( )( X X X )( X
Soil Salllplill!1 G.,d )( )( )( )( X X )( X
Suil Ca.) )( )(
Su.face Prcl)aralion X X X X X
Magllotometer Survey )( )( )( X )( X X X
Multimedia (;ap )( X
. Sur'al:o Water Drainage/Sedimentation X )( )( X )( )( X X
Groulldwator Pumplng/Trealment (Includes )( X X X X
Pond Water)
rondWato. Pumping X X X X )( )( X X
I'orul Watc. I'rotreatmonl X )( X
Suit nushillg/Effluont Discharge X )( X X )(
Pond/Sur'ace Cleanu.. and Drum Removal X X X X X X X X
rarllal Removal/Dackfill X X X X
Complote ncmoval/Oackfill X X )(
0115110 I.and'ill X
UlIslle I.alldlill (Colltalner/nefuse) X X X X X X X X
(Jllslle Lalldfill (Complete Removal) X X
(ir lII.hlg/navegAt at Inn )( )( )( )( )( )( X )(
----
)( 1 m:hllutouv Included In alternative
. m:hnnlnuv not '",:Iudod In alternative
Nute: I ho Suil Sam'llinu Grid will be performed twice for Altenl111ves 3A, 38, 3C, 4 and 5.
-------
.,-
Remedial Action
Alternative
1. No Action with
~fonitoring
REMEDIAL ACTION ALTERNA'flVI<:S EVALUATION SUMMARY
Costs ($l,OOOs)
Capital
2A. Onsite Pond 1,738
Cleanup, Offsite
Drum/Debris
Wastepile Disposal,
Contaminated Soil
Excavation and
Onsite Soil Cap
or
28. Onsite MultI-
media Cap
2,196
2C.Onsite Pond 19,004
Cleanup, Offsite
Drum/Debris
Wastepile Disposal,
Complete
Contaminated SoiL
Removal and
Off si te
Landflll1ng
53
Present Worth
729
2,482
3,140
19,721
Public Health
Considerations
Potential for chronic
and/or carcinogenic
health effects If
shallow GW in site
area were to be
inKested at present
levels. Does not
address ~urface con-
tamination outside
of fenced area
(direct contact).
Consolidation of soli
contamination and
residual cappIng
reduces onsite surface
exposure. Does not
address exi6ti~g and
future contamination
of the shallow
aquifer.
Removal of unsaturated
contaminated soil wilL
eliminate direct con-
tact exposure and
future contamination
from this source.
Environmental
Considerations
Potential bio-
accumulation of
contaminants from
surface soils (Pb,
Cd, PCBs) Impacts
to wetlands needs
further investiga-
tion and assess-
ment.
Does not address
existing contamin-
ation in saturated
soils and shallo,,",
aquifer. Eventual
dischar~e to wet-
land areal> and
potentiaL impact~
to downgradient
we 11s.
SAME AS 2A, 28
Technical
Considerations
Other
Installation of This alternatLve
new HWs. Moni- does not comply
toring of both new with RCRA GW cor-
and existing HWs rective action
will provide his- requLrements.
toric data on the Monitoring Pro-
status of the GW gram wiLL be Im-
plume. plemented for all
alternatives.
Remaining contam-
inants in satur-
ated s01l will not
be removed/treated
or contained. GW
diversion barrier
not technically
feasible.
Estimated excav-
ated soil volume
is 48,200 cu. yds.
Source removal is
effectIve and
rellable.
SAME AS I
SAMI-: AS 1
-------
Costs ($1,0008)
Remedial Action
Alternative
Present Worth
Capital
3A. Onsite Pond
Cleanup, Off6ite
Drum/Dt!bris
Wastepile Disposal
Contaminated
Groundwater
Extraction,
Treatment and
reapplication
and
3,572
6,825
38 Soil Cap 4,363 7,486
or
3C Multimedia Cap 5,020 7,680
or
4 OffsHe Disposal 21,635 17,042
or
5 Onsite Landfill 6 , 328 8,468
-2-
Public Health
Considerations
Will prevent direct
contact with highly
contaminated materials.
GW extraction should
reduce extent of
shallow aquifer plume
removing pathway of
. potential ingestion of
contaminated GW.
Environmental
Considerations
Should address all
identified remed-
ial objectives.
Technical
Considerations
Close observation
of rate of extrac-
tion and reappli-
cation of treated
GW is paramount to
prevent dewatering
of wetland areas.
Other
The RA shall make
a decision
whether to cap
residual soil
contaminatLon
based on the
results of a
second soll grLd
sampling program.
(3A ONLY)
NarE:
All alternatives with the exception of No. 1 include a contIngency to excavate, transport and dispose in an
nffaite HWMF of an additional 500 drums. This' estimate is for buried drums within the fenced area.
-------
-15-
Site action will be initiated with onsite pond cleanup. The ponded
water (estimated at 200,000 gallons) will be drained and treated to a level
acceptable for discharge to a Publicly Owned Treatment Works (POTW). After
dewatering, drums, sludges, automobile scraps, and bulk wastes from the
pond bottom (approximately 5 tons) will be removed. These wastes will be
disposed offslte in a RCRA Hazardous Wastes Management Facility (HWMF).
The second remedial component common to all
cleanup of all crushed and intact drums, debris,
sludges. It is estimated that approximately 117
material require removal. This material will be
disposed offsite in a RCRA HWMF.
alternatives is a surface
metal, waste piles and
cubic yards of waste
removed from the site and
Once the site is cleared of all surface debris and metal, a magnetometer
study will be performed to determine whether additional drums are buried
onsite. This study may indicate that additional excavation and drum "removal
is required. The cost of removing and disposing these drums is not included
within the scope of the cost estimate for each of the alternatives.
The third common remedial component is that upon construction of the
recommended remedial alternative, ground water and surface water post-
closure monitoring program will be implemented. The scope of this program
has been described previously in the No Action with Monitoring alternative.
B.
Alternatives that meet the objectives of CERCLA
2A, 2B, 2C
Remedial Action Alternatives 2A, 2B, and 2C were developed to meet the
CERCLA objective of protecting public health, welfare, and the environment
by reducing present or future threats from hazardous substances. The
intent of these alternatives is to reduce the migration of contaminants by
providing surface cleanup actions consisting of onsite pond cleanup, pond
water treatment, drum and bulk waste removal followed by offsite disposal,
and contaminated soil excavation. Excavated materials will either be
disposed onsite and capped or hauled offsite to a permitted Hazardous Waste
~nagement Facility.
These remedial action alternatives are a combination of several remedial
components and have common elements except for (a) the volume of excavated material
and (b) its final disposed. Alternatives 2A and 2B include partial removal
and onsite capping actions, whereas Alternative 2C is a complete removal/offsite
disposal response.
Based upon results of previous site investigations, the areas of
greatest surface and subsurface soil contamination are delineated on figure
11. Alternatives 2A and 2B include excavating soils in areas Nos. 1, 2, and
4, placing these soils into area Nos. 3, and capping onsite. Alternative 2C
proposes to excavate areas 1, 2, 3, and 4 and dispose offsite in a RCRA
Hazardous Wastes Management Facility.
-------
- FIGURE II
REMEDIAL ACTION ALTERNATIVES 2A.2B.62C
HARVEY AND KNOTT DRUM SITE. KIRKWOOD. DE
.
300
.
o
300
.
SCAlE IN FEET
-------
. ,
-16-
The depth of excavation will be limited to the elevation of the water
table which is approximately five feet from the surface. A supplemental
soil grid sampling program is proposed to be conducted during design. This
program will determine the lateral extent of s011 contamination and repr~sen-
tative background soil characteristics. For alternatives 2A and 2B the
grid sampling will determine the selected excavation volume and limits of
the cap. For alternative 2C, it will determine the volume of excavation
for complete removal (areas 1 through 4) and offsite disposal in an HWMF.
The only difference between alternative 2A and 2B is the inclusion of
a 30 mil synthetic membrane and geotextile filter below the proposed 2A
compacted soil cap. This would classify 2B as a multimedia cap.
After excavation and capping (2A, 2B) or offsite disposal (2C) is
accomplished, excavated areas will be backfilled and graded to the approximate
original contour. These disturbed areas will then be covered with topsoil
and revegetated.
Upon completion of construction of one of these alternatives, the post-
closure ground water and surface water monitoring program described under
the No-action with monitoring alternative will be i~plemented.
C. (D) Alternatives that attain (Exceed) All Applicable Standards
3A, 3B, (3C)
Remedial Action Alternatives JA, 3B, and 3C (figure 12) were developed
to address the onsite bulk wastes, contaminated surface water, and contaminated
soils (as described with alts. 2A, 2B, and 2C) as well as extraction/treatment/and
reapplication of shallow contaminated ground water. Alternatives 3A and 38
are considered to attain all applicable standards while 3C is intended to
exceed applicable standards.
The ground water extraction/treatment/reapplication systems are the
same for Alterantives 3A to 3C. The alternatives differ with respect to
remediation of residual contaminated soils. Final site closure for each
alternative is contingent on the effectiveness of the reapplication (flushing)
of treated ground water in reducing ground water and soil contaminants
below respective target contamination levels.
Target soil and Alternate Concentration Levels
ground water contamination will be established
design phase. Final levels will be determined
information is gained through operation of the
(ACLs) for
during the
as additional
systems.
-------
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e,lOO-
FIGURE 12
REMEDIAL ACTION ALTERNATIVES 3A. 38. 8 3C
HARVEY AND KNOTT DRUM SITE. KIRKWOOD. DE
I
I.£G£NO
IIIiiI AREA Of _AY _TION rOIl ~ F\.U$-
(,:,(j)-",J AREA Of lIMO... COIITAMlNATtO $OIL
~ 1'llEA1'II£II1' fLAII1' AREA
PWT"'"'
: --- ; APfIIOIIIMAT[ LIMIT 01 Wt1'LANDI ($U$ONALI
............
- - .-vJSlDII LJII( or $l'lllllllLDI -.ICA1'1GI AREA
- CCLI.lC:1'I0II PIPING fRCII EXTIIIIICTICII W£LU
- ....11 _llIlILfR DlSTRIIUTlOII Llllf
- LATfRAL ~R HUDSITYP. 01 $U8AllfASI
fl . PROI'OSfO (X"""1'I01I WtLL
. fXlSTlliO lIOII1'0111110 WfLL
& RflifOLAL IIIVfSTIGATlOII WfLL
~
AlTERNAnV£)A. NOCAPISPR~ED AREAS 1.2,).AND.
WILL BE FLUSHED B V SPRA Y IRRIGA liON
(nt,S ,n I AND WILL BE LEfT IN PLACE AND
MONI10RED.
ALTEIINA nVE )1.. )C '
AREAS I.l,). AND. WILL BE flUSHED
BY SPRAY IRRIGATION (... S ,n I
AND THEN AREAS 1,2, AND. WILL BE
EXCAVATfDAND PlACED IN AREA)
fOR CAPPING ALTfRNATIVE )BISA
SOIL CAP AND ALTERNATIVE IC IS A
MULTIMEDIA CAP,
200 0
r------
$CAL£ . rUT
200
.
-------
-17-
, The contaminant removal efficiency of the water flushing operation is
expected to reduce the levels of existing contaminants in surface and
subsurface soils thereby lowering the residual risk of contaminants leaching
into the shallow ground water. It is estimated that the contaminated ground
water extraction/treatment/reapplication systems will operate for at least
five years. Once these sytems are no longer in operation, Alternative 3A
requires no further action (except for post-closure monitoring)., Alternative
38 would install a compacted soil cap at the end of the extraction/treatment
reapplication operation due to possible residual soil contaminant' levels
above levels. Alternative 3C differs from 38 only by the design of the
cap - 3C involves the installation of a multimedia cap and is intended
to exceed RCRA requirements.
Prior to the installation of the extraction/treatment/reapplication
systems the soil grid sampling program, similar to which is described in
Category 8, will be conducted to determine the actual limits of the reapplica-
tion (flushing) areas.
After the soil flushing has been completed, a second soil sampling
program will be performed to assess residual contaminant levels in the
soil. As stated previously, alternative 3A does not anticipate any further
remedial action. Alternatives 38 and 3C propose to install a cap due to
their expectation of higher than final l~vels of contamination remaining
in the so11.
Upon completion of construction of the selected cap for alternatives
38 and 3C, the post-closure monitoring program initiated at the outset of
these alternatives wil~ continue as part of the operation and maintenance
program. The caps will be effective as long as they are not disturbed.
Post-closure inspection and maintenance will be required to ensure the
integrity of the selected final cover.
. Another alternative that meets all applicable standards is alternative S.
This alternative is similar to alternatives 38 and 3C with the difference
being the method of remediating remaining soil contamination after the
flushing program has been completed. 80th 38 and 3C proposed to cap residual
contaminated soil areas. Alternative 5 proposes to excavate remaining'
contaminated soil areas (based on the second soil grid sampling program)
and place these in an onsite hazardous waste landfill designed in accordance
with RCRA standards. The total estimated volume to be placed in the onsite
landfill'is 48,200 cubic yards.
Upon completion of ,construction of the onsite landfill the full post~
closure monitoring program will be continued until final ground water
levels have been attained, whereby only post closure monitoring for the
landfill will be required.
-------
-18-
E.
Alternatives that Specify Offsite Disposal
Alternative 4 is also similar to 38, 3C, and 5 with the difference 1n
final remediation of the remaining post 90il flushing contaminated areas
being excavated and disposed in an offsite RCRA HWMF. This alternative
would also be classified under Category C.
Upon completion of the excavation and offsite disposal of contaminated
soil areas, the post-closure, monitoring program will continue until final
contaminated ground water levels are attained.
Recommended Alternative
Section 300.68(j) of the Nationaf Contingency Plan (NCP) [47 FRo31180;
July 16, 1983) states that the appropriate extent of remedy shall be
determined by the lead agency's selection of a remedial alternative which
the agency determines is cost-effective (i.e., the lowest cost alternative
that is technically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare, and the environment. In selecting a remedial alternative, EPA
considers all environmental laws that are applicable and relevant. Based
on the evaluation of the cost-effectiveness of each of the proposed alterna-
tives, the comments received from the public and information from the
Delaware Department of Natural Resources and Environmental Control (DNREC),
we recommend Alternative No. 3A be implemented at the Harvey and Knott
Superfund Site. This selected alternative will address all onsite surface
and subsurface contamination problems identified in the Remedial Investigation.
Decisions on the extent of aquifer restoration, cleanup actions in offsite
streams and wetlands, and final site closure will be deferred pending (a)
additional soil investigation during design (b) analyses on the effectiveness
of the chosen alternative and (c) the impacts of the site on the wetlands
adjacent to the site.
The removal and offsite disposal to a RCRA HWMF of all crushed and
intact surface drums, debris, contaminated sediments, and sludges, and the
cleanup of the onsite drainage pond will:
1) eliminate and prevent further migration from these sources of
contamination;
2) allow additional investigation for the presence of buried drums;
these. sources of contamination will also be eliminated if encountered.
3) prepare the site for the installation of the contaminated ground
water extraction/treatment/reapplication facilities.
-------
-19-
The excraction/creatment/reapplication facilities will serve a dual
purpose. They will reduce the contaminated plume found in the UHZ and at
~he same time flush contaminants from the surface and subsurface soil
compartments. These soils do not have the capacity to adsorb and si~nifi-
cantly attenuate site contaminants as evidenced by the concentrations found
in the shallow ground water. Flushing contaminated soil areas with treated
water should expedite the release of contaminants from the soils.
As a precaution to direct contact with contaminated surface soils,
alternative 3A proposes to grade the entire reapplication area, backfill
and cover with a 24 inch layer of clean soil, and establish permanent
vegetation. At the time the extraction/treatment/reapplication facilities
are terminated, soils at the site will be sampled to determine whether an
impermeable cap will be required. It is intended that soil flushing will
reduce soil contaminants until residual levels pose no further threats to
the shallow ground water which would and alleviate the necesssity to cap
Che site.
Results from both the ground water monitoring and soil grid sampling
programs will then be evaluated to determine the level of residual contami-
nants and assess whether further remedial action i~ required. This could
entail further operation of the extraction/treatment/reapplication systems
and/or the installation of a more impermeable cap to attain a final site
closure.
Operation and Maintenance
Periodic inspection and maintenance will be required during operation
of the extraction/treatment/reapplication program to assure that it is
properly functioning. Operation of the individual equipment units is
expected to be relatively simple, however, the operator should have experience
with a municipal well fi~ld or contaminated ground water pumping system or
have demonstrated experience in a ground water related field. This is
necessary to ensure that the adjacent wetlands are not dewatered by excessive
pumping and insufficient reapplication rates. It is recommended that
piezometers be placed at the nearest wetland boundaries to monitor the
impact of the selected remedial actions on the wetlands and adjust pumping
rates for seasonal fluctuations.
Maintenance of the soil cover will be required to ensure that an
adequate vegetative cover is maintained to prevent erosion. The soil cover
will be an effective direct contact barrier as long as it is not disturbed.
The ground water and surface water monitoring programs will commence
after installation of the extraction/treatment/reapplication systems.
Periodic analyses will evaluate the remedy's effectiveness in reducing the
extent of contaminated ground water. Once target (ACL) cleanup levels are
attained or after the ground water extraction/treatment/reapplication systems
are terminated a second soil grid sampling program will be performed.
All operation and maintenance requirements will be the responsibility
of the State of Delaware after completion of the extraction/treatment/reapplica-
tion program which is estimated to operate for five years.
-------
-20-
Consistency With Other Environmental Laws
EPA is currently proposing regulation requiring the agency to select a
remedial Superfund remedy which "..... attains or exceeds applicable or
relevant Federal public health or environmental standards." See proposed
40'C.F.R. ~300.68(f).
Environmental laws which may be applicable or relevant to remedial
activity are:
- National Environmental Policy Act (~EPA)
Clean Air Act (CAA)
- Clean Water Act (CWA)
- Safe Drinking Water Act (SDWA)
- Resource Conservation and Recovery Act (RCRA)
- Toxic Substances Control Act (TSCA)
- Delaware Hazardous Waste Regulations and Water Quality Standards
Compliance with all applicable substantive requirements of the CWA and CAA
as well as Delaware Hazardous Waste Regulations and Water Quality Standards
will be incorporated into the design of the recommended remedial alternative.
Any potential emission of volatile gasses into the atmosphere which may
occur during the construction of the remedial action or operation of the
treatment systems is expected to pose a very low hazard to site personnel
and a lower hazard to receptors in the vicinity of the site. All State
permits for the extraction and discharge of treated ground and surface
waters will be complied with as necessary.
This alternative meets the NEPA functional equivalency exception
because the necessary and appropriate investigation and analysis of
environmental factors as they specifically relate to the Harvey and Knott
Drum site and the recommended alternative were considered and evaluated in.
the Remedial Investigation and Feasibility Study. A meaningful opportunity
for public comment on environmental issues was provided before the final
selection of the remedial alternative was made.
A Wetlands Functional Assessment was conducted by the U.S. Army Corps of
Engineers and supports the implementation of the recommended alternative.
Specifically, site area No.1 as depicted on Figure 12, was designated as a
wetland which had been impacted by the site. The cleanup of soil and ground
water contamination with successful restoration of native vegetation in
this area precludes the need for additional wetlands compensation. On a
broader evaluation, the wetlands surrounding the site proper are much more
extensive than site area No.1. It was therefore recommended that measures.
be taken to ensure that it is not degraded. . The recommended alternative
will prevent the further migration of contamination from the site. A
subsequent environmental assessment of the extensive wetlands and surface
waters adjacent to the site will be performed to determine the impact the
site has already had on these areas. Remediation decisions for the wetlands
will be addressed as separate operable unit.
-------
-21-
There is not at this time, any indication of the consumption of
contaminated ground water which exceeds the National Interim Primary Drinking
Water Standards (NIPDWS) in the site vicinity. All MaKimum Contaminant
Levels (MCLs) and Health-based exposure levels (10-6 cancer risk) will
be used when establishing initial target levels for ground water remediation.
Decisions regarding RCRA final closure of the site and the level of
ground water quality to be achieved are deferred. In order to be consistent
with 40 C.F.R. 264 Subpart F of the regulations, ground water corrective
action is required until the concentration of hazardous constituents at the
point of compliance for a site achieves one of the following:
- MCLs for particular substances,
- an ACt which would provide adequate
health and the environment,
- background levels
.
protection of public
EPA is not prepared at this time to determine the appropriate level of
ground water corrective action at this site. Operation of the eKtraction/
treatment/reapplication facilities will operate for an estimated five years
and should substantially reduce the amount of contaminants in the ground
water in the vicinity of the fenced area and reduce the plume which has
migrated in the southerly direction. Using 1) existing site characteristic
data, 2) monitoring well analyses, 3) further wetland assessment and 4)
additional information collected during the operation of the extraction/
treatment/reapplication program, EPA will make a determination as to the
final level of contaminants which would adequately protect human health and
the environment. Under CERCLA, the ground water correction systems would
continue to operate until the final established level is achieved unless
that level proved technically infeasible or would not be cost-effective.
Where RCRA final closure regulations are applicable, they would require
that all hazardous wastes at a site be removed, treated onsite, or capped
in such a way as to minimize the migration of contaminants from the site.
It is the intent of the recommended alternative to flush contaminants from
the soil compartment. While these reapplication areas would not be capped
immediately in accordance with RCRA, the backfill, clean soil, and revegetation
should adequately address direct human exposure during the flushing program.
In conjunction with the establishment of a ground water treatment
level, EPA would evaluate the level of contaminants which could be left in
the soil without the necessity of a cap at the site.
-------
-22-
Evaluation of Alternatives Not Selected
The No-Action with Monitoring alternative was not selected since it
would not control the sources and migration of contamination at the site.
Contaminated surface water. soils. and sediments will continue to pose a
direct contact threat to human health and the environment. Contaminated
peripheral monitoring wells south of the fenced area have documented the
migratory behavior of contaminants found within the fenced area. Further
leaching of contaminants from these sources as well as contaminated sub-
surface 90ils will continue to expand the existing contaminated plume in
the shallow ground water. If the direction of the shallow ground water
changes or if contamination of the lower Hydrologic Zone occurs. ingestion
of contaminated ground water could occur.
Alternatives 2A and 2B involve consolidating contaminated sotls and
covering with compacted soil and multimedia caps respectively. Both of
these alternatives reduce direct contact exposure in the vicinity of the
site and decrease the amount of precipitation which would percolate through
contaminated soils. Due ,to the high water table and geologic constraints
of installing upgradient ground water barriers. leaching of contamination
from saturated soils will continue to affect the shallow aquifer. The
contamination persisting in the unsaturated soils will remain vulnerable
to interaction with the changing water table. Thus. these two alternatives
would not address the existing contamination in the shallow aquifer. The
potential risk for ingestion of contaminated ground water would still remain
for receptors in the si~e area. The discharge of contaminants to the
wetlands would also cause degradation to these sensitive areas.
Alternative 2C would be more effective ~han 2A and 2B in'reducing
further leaching of contaminants in the soil by removing a greater quantity
of the source (excavating 5 to 6 feet of unsaturated soils) and disposing
in an offsite HWMF. However. all three of these alternatives do not address
the residual contamination in saturated soils (below the water table level)
and the contamination which has already migrated in the shallow aquifer.
This contamination will continue to migrate with the natural ground water
flow and could eventually discharge to wetlands and streams in the vicinity
of the site or to other areas in the UHZ and potentially. the LHZ.
Alternatives 3B. 3C. 4 and 5 were developed to address the situation of
residual soil contamination after the operation of the ground water extraction/
treatment/reapplication program is terminated. For the purposes of selecting
a cost-effective alternative. these alternatives were more expensive to con-
struct and implement while achieving the same or greater level of protection
of human health and the environment when compared to alternative 3A. Unless
the post ground water flushing soil grid sampling program demonstrates
levels of soil contamination above final ac~epted limits. these alternatives
are considered to be less cost effective based on the expectation of the
extraction/treatment/reapplication facilities cleaning the s011s below
final accepted limits.
I
.
-------
HARVEY AND KNOTT
Responsiveness Summary
A public meeting was held on September 12, 1985 to discuss the Remedial
Investigation and Feasibility Study for the Harvey and Knott Drum Site.
The
meeting was attended by 10 local residents.
The EPA and Delaware preferred
alternative was outlined in a one page fact sh~et and the audience was invited
to comment on it.
A summary of the public's comments is attached.
Two written
statements were received.
One letter written by an individual expressed concern
over her health and the quality of her water source.
The second letter requests
EPA to pursue legal actions against the owner and operator of the site.
A fact sheet covering all the alternatives under consideration was mailed
to all 120 nearby residents prior to the meeting.
There has been low community interest 1n the RI/FS study of the site.
The first RI meeting drew 10-15 local residents.
-------
I .
A SUMMARY OF .
CITIZEN AND INTERESTED-PARTY COMMENTS AND CONCERNS
AND OF U.S. ENVIRONMENTAL PROTECTION AGENCY RESPONSES
HARVEY AND KNOTT DRUM SITE
KIRKWOOD, NEW CASTLE CCUNTY, DELAWARE
SEPTE~iBER 1985
Monitoring and Artesian Wells
Issue:
Response:
Issue:
Response:
Issue:
Response:
Are there monitoring wells on the site?
Yes, both deep and shallow monitoring wells are located in clusters
around the site. There are at least 17 monitoring wells on site.
(A slide was presented to show monitoring well locations.)
Vells in the Shelly Farms. area and in the area north and northwest
of the site on State Route 40 have been going dry. .Could the
artesian wells be responsible?
Because of the existence of the Potomac clay, it is unlikely that
the deep wells are affecting the shallow wells. There is a great
deal of water in the shallow aquifer, and the annual precipitation
in the area is sufficient to replenish the supply. Shallow wells
at the site are not going dry. However, the wells that are going
dry are located in an area that is not involved in our study. It
would be a good idea to find out more about conditions in that area"
from the appropriate local authorities.
A Delaware Department of Natural Resources and Environmental
Control (DNREC) spokesman stated that this has been a dry year and
that wells across the entire state have been going dry.
How deep are the artesian wells?
They are about 230 feet deep.
Soil Contamination
Issue:
Is the soil contaminated?
Response:
Issue:
Response:
There are volatile contaminants in the surface and subsurface soils
now. The recommended remedial action alternative will flush these
contaminants from the soil.
Will you be removing the contaminants or just dispersing them?
Water treatment will probably consist of an initial air stripping
facility to remove volatile organics from the water, and there will
most likely be a carbon adsorption unit for polishing.
1
-------
Issue:
Response:
How long will it take to flush the contaminants from the soil?
That .....ill depend on how many aquifer volumes can be flushed through
the system. Water flows very' Quickly in this area; We will keep
water flushing through the system to~ard extraction ','ie11s, and we
will treat the water and monitor water Quality. After a point. the
percentage of volatiles in the water Vii" cease to reduce
significantly, and at that time, we will have to decide if it is
worthwhile to continue flushing water through the system.
Procedural Issues
Issue:
Response:
Issue:
Response:
Water Qual fty
Issue:
Response:
Is there any chance the State government will reject the EPA's
remedial recommendations?
The EPA has put a lot of time into deciding on the remedial action
alternative that ;s being recommended for this site and the State
has already written a memo approving the EPA recommendations. No
problems are anticipated.
Will the EPA take action against Harvey and Knott Trucking, Inc.?
Part of the Superfund law requires that the Federal Government
attempt to identify all potentially responsible parties (PRPs) and
then find some kind of remedy with the help of the PRPs. PRPs
i ncl ude site owners, waste transporters, chemi ca 1 manufacturers,
and disposers--everyone identified with a site. From that
standpoint, since they were owners and were operating as
transporters. they would be identified as responsible parties.
Enforcement efforts, however. are the responsibility of the -
attorneys.
Four years ago, the State sampled residential water supplies. What
was found?
The State did not find the water to be contaminated. The latest
residential water samples indicate no organics above detection
limits and no inorg~nic contamination exceeding the pr1~ary
drinking water standards. As the earlier slide presentation
illustrated, the groundwater contamination seems to be heading in a
southerly or southeasterly direction.
2
-------
Comments by the Potentially Responsible Parties (PRPs)
PRPs submitted written comments on three separate occasions:
1. June 19, 1985 - General Motors had retained Fred C. Hart Associates. Inc.
to review remedial investigation data. Hart prepared a "Preliminary
Endangerment Assessment and Remedial Alternatives" document.. GH requested
that the final draft RI/FS report take into account Hart's suggestions
regarding (a) the endangerment assessment to the extent possible and
(b) the remedial action alternatives developed by Hart.
EPA and its contractors, NUS Corporation. reviewed the Hart document.
which was timely and pertinent. and to the extent possible incorporated
the endangerment assessment into the Public Health and Environmental Concerns
section of the RI/FS. Hart's alternatives were also similar to the
remedial response alternatives developed by NUS with the exception of
upgradient ground water diversion. Due to the lack of a continuous
imperable fo~tion and constructability difficulties (high water. table
levels and depth to the Potomac clay - 75 feet) this response action was
eliminated during the initial screening of alternatives.
2. September 4, 1985 - General Motors submitted comments and observations
based on the draft. August 1985 Remedial Investigation and Feasibility
Study Report (NUS Corporation).
Comment #1 The report is generally adequate and comprehensive. however.
the report (section 8.2) also identifies additional investigations that
should be conducted prior to. or concurrent with, the selected remedial
action alternative.
Answer: With the exception of the Environmental Assessment of adjacent
wetlands and surface waters and Lower Hydrologic Zone investigation. EPA
considers the remaining investigative work (p 8-12 of RI/FS) to be .
preliminary design or performance determination activities related to the
recommended alternative. The Environmental Assessment of the wetlands/
surface waters has been separated as an operable unit while the LHZ
investigation is necessary to further evaluate the impacts the site may
have had on this confined aquifer. Thus, EPA believed it has taken GM's
comment into account.
Comment #2 The report e.g., page 8-11) appears to recommend the application
of drinking water quality criteria as the criteria for ground water
remedial action. Since the remedial action design is not a design for
the construction of a drinking water supply plant, it would be more
appropriate to apply a criterion based on the level of contamination
abatement necessary to meet the remedial action objectives and criteria.
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Answer: Target and alternate concentration levels will be established
for soil and ground water respectively to reduce or eliminate potential
exposures to contamination. These levels will be investigated as a
preliminary design task. GM's input will be taken into account during
the development of these levels.
Comment #3 The background data for elements and compounds of concern
were obtained in the Remedial Investigation. Therefore, the report should
include comparisons and discussions of data representing background with
those representing contaminated soils and ground water.
Answer: None of the organic Hazardous Substances List compounds identified
in shallow ground water wells at the site were detected in upgradient
residential wells. Also, the last sampling (1984) for inorganics did not
identify these contaminants above detection levels in residential wells.
The surface soil sampling performed during tre RIfFS identified areas of
contamination and provided estimates for the purpose of developing and
evaluating remedial response alternatives. An inittal soil grid sampling
program will better define the horizontal extent of soil contamination and
background soil characteristics. This will be performed as a preliminary
design task.
Comment #4 The general conclusions derived from the Remedial Investigation
in pages ES-3 and 4, as well as page 6-63, of the report are supported by
the data in the report. Relative to ground water, the most crucial
migration pathway of concern, it is important to highlight the conclusions
that "transport of dissolved organic and inorganic site contaminants to
residential wells screened in the UHZ (upper hydrologic zone) is not considered
likely at present" and "The absence of chemicals in samples obtained from
wells 1070, 1080, an~ 1090 indicates that the LHZ (lower hydrologic zone)
is uncontaminated." Further, as stated in the conclusion to Chapter 6,
the LHZ "does not appear to be threatened by site contamination."
Answer: Although there does not exist any present documented evidence of
consumption of contaminated groundwater, EPA must minimize and mitigate
the threat of ingestion of contaminated ground water. This has been
addressed in the endangerment assessment of the Summary of Remedial
Alternative Selection.
Comment #5 We have evaluated the remedial_action alternatives in the
report. Based on the information in the report, we recommend EPA to
select a modified alternative 3B consisting of an Operable Unit (see the
February 12, 1985, EPA proposed 40 CFR 300.68(d» and certain applicable
investigation and monitoring. Implementation of the Operable Unit will
be consistent with the final remedy if additional action such as Ground
Water Extraction, Treatment, and Land Application via Spray Irrigation
are determined to be necessary for broadening the Operable Unit into the
final remedial measure.
Answer: EPA feels that this phased approach is consistent with the
recommended alternative, 3A, as described in the Summary of Remedial
Alternative Selection. It should be emphasized that target and alternate
concentration levels established for soils and ground water must be
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consistent with other environmental laws. Ground water and surface water
monitoring will be performed as described in the Summary of Remedial
Alternative Selection.
3. September 25, 1985 - At the request of Chrysler Corporation, O'Brien
and Gere Engineers, Inc., submitted technical comments after reviewing
the draft, August 1985, RI/FS.
It should be noted that the original comment period for the
Harvey and Knott Feasibility Study lasted from August 26, 1985, to
September 20, 1985. At the request of Chrysler Corporation, the comment
period was extended by EPA to September 27, 1985.
II Comment A - Until it 1s established that potential receptors have been
or are likely to be significantly affected by ground water contamination,
and until a link is then shown between the source and potential human
exposure, the RI/FS is significantly flawed; it provides no basis for
evaluating whether remedial action related to ground water is required,
or i£ so, what type of remedial action is appropriate.
Answer: Potential receptors (users of both the Upper and Lower Hydrologic
Zones) have been identified as described in Section 7 of the RI/FS. The
link between the source of contamination and the receptor is the pathway
or route of transport. ,This pathway is the shallow aquifer (UHZ) which
is already contaminated. The plume(s) of contamination must be monitored
and managed to prevent or mitigate its migration into a current source of
drinking water.
Comment B - Although the RI/FS indicates that some upper level aquifers
have been contaminated, it has failed to analyze the nature and extend (SIC)
of any ground water contaminant plume(s).
Answer: EPA disagrees with this comment and refers to Figure 6-8, 6-9,
6-11, 6-12 and 6-16 of the RIfFS. These figures identify the nature of
ground water contamination. Although many of the peripheral wells are
contaminated which would indicate the plume is more widespread than
presently documented, ~he information in the RI/FS report was sufficient
to establish remedial objectives and develop and evaluate remedial
alternatives.
~:.
Comment C - Type of Wastes -~he RI/FS report's sole purpose to
define the generator or original source of contaminants identified in the
field. It is the RIfFS reports responsibility to characterize the type
of waste to assess the existing and potential threats to public health,
welfare and the environment.
Comment D - Soil Contamination - The extent of
been determined or evaluated in the RIfFS. As
associated with potential soil removal actions
the need be evaluated.
soil contamination has no't
a result, remedial costs
cannot be estimted nor can
Answer:
See previous answer to Comment 3.
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Comment E - Additional Data Required
Answer:
See previous answer to Comment 1.
III
Risk Assessment
. A. EPA believes it performed an adequate risk assessment which is
"referenced in Section 7 of the RI/FS report. EPA disagrees with the
comment that the exposure likelihood from ground water contamination is
virtually nil. The potential exists and the EPA is concerned that
(1) the shallow aquifer contamination will spread and (2) the deeper
aquifer may become contaminated.
In reaching a decision on the appropriate CERCLA response action, "
EPA considers other environmental laws and regulations for guidance and
will attempt to comply with these statutes. In this instance, it is
clear that there is sufficient information to assess RCRA Part 26~
regulations. These regulations call for a corrective action program when
hazardous substances have migrated beyond the waste management boundaries
and final site closure actions in waste disposal areas.
The RI/FS has established that the direction of ground water flows
and how the wetlands are hydraulically influenced by the shallow aquifer.
It is imperative that any current or future degradation or environmental
impact to these. sensitive areas be prevented. Also, further wetlands
assessment will be performed to address contaminants which may have
already impacted these areas and evaluate remedies to prevent additional
threats.
B. As far as only doing a primary surface cleanup at the site. the PRPs
comment does not take into accoun~ existing ground water contamination
and the potential impacts if my have on drinking water supplies and
adjacent wetlands/surface waters.
IV. Remedial Alternatives
A.
Lack of Data or Analysis.
See previous comment #1 and answer.
B.
Technology Issues.
This can be performed during preliminary design.
C. Treatment Level.
of the ROD.
The reader is referred to the Declaration section
V.
Miscellaneous Deficiencies in Draft RI/FS
A. Cost Estimates. EPA believes it has selected the least cost alternative
which meets all remedial objectives. Increases in volumes of 5011,
numbers of buried drums, etc., will be similarly reflected 1n all acceptable
alternatives 3A, 3B, 3C, 4 and 5. Based on available data, EPA believes
its cost estimates are accurate.
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B.
Laboratory Procedures
2. There were other contaminants which did not show up in their respect
laboratory blanks. These contaminants were used for assessing environme
impacts at the site. All data was subjected to stringent validating
procedures.
~
HazardouS 'We.
(of or roof ion, ~ ~
Us. EpA Reg~q'
pf\i{odelp ~
1. Standard QA/QC procedures were followed and EPA will mak~ this
information available for review.
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