United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/072
June 1989
SEPA
Superfund
Record of Decision
Kimberton, PA
-------
50272-101
REPORT DOCUMENTATION I 1.. REPORT NO.
PAGE EPA/ROD/R03-89/072
I ~
3. Recipient' a Acceulon No.
4. Tille and Subtitle
SUPERFUND RECORD OF DECISION
Kirnberton, PA
Second Remedial Action - Final
7. Aulhor(a)
5. Report Dale
June 30, 1989
II,
8. Perfonning Organization Rep'- No.
9. Perfonning Org8lnlzatlon Name and Addre..
10. Projec:tlTaaiuwork Unit No.
11. Contract(C) or Grant(G) No.
(C)
1~ ~ Organlz8tlon Name and ~
U.S. Environmental Protection
.
401 M Street, S.W.
Washington, D.C. -20460
(G)
13. Type of Report & Period Covered
Agency
800/000
14.
15. Supplementary Noles
1&. Abend (Umlt: 2DO _rda)
The Kirnberton site. is in Chester County,Pennsylvpnia, near the Philadelphia
metropolitan area. The site encompasses ~n industrial production plant currently owned
by Monsey Products Company, Inc., and adjacent properti~s within the neighboring
Village of Kimberton. Water quality testing since 1981 has revealed numerous area
domestic and commerical potable well water supplies contaminated with VOCs. A portion
- this contamination originated from the onsite industrial production plant, which
sposed of wastes in several lagoons during the 1950s. An EPA investigation in the
spring of 1982 revealed the presence of organics, including TCE and DCE, in local
ground water, surface water, and soil. In mid 1982, fifty seven, 55-gallon drums from
an abandoned onsite septic system were excavated, removed, and disposed of offsite. In
1984 a remedial action program was initiated t.o excavate, . remove, and dispose of
approximately 2,050 yd3 of soil from three former lagoon areas that were highly
contaminated with VOCs. These lagoons are in proximity to numerous private water
supply wells and less than 1 mile from French Creek, which is used for public
recreation and fishing. VOCs are believed to ultimately discharge to surface waters to
the north and east in the Village of Kimberton via the groundwater. In 1985, 67
residential and commercial wells were sampled and found to contain various"
(See Attached Sheet)
,
17. Document Analyais L Deac:riptors
Record of Decision - Kimberton, PA
Second Remedial Action - Final
Contaminated Media: gw, sw
Key Contaminants: VOCS (TCE)
b. Idendlier8lOpen-Ended Tenne
.
c. COSA 11 FieIdIGroup
'. vailabilty sc.tement
19. Sect8ity Clus (This Report)
None
21. No. of Pages
108
2D. Sect8ity CIa.. (This Page)
NnnA
22. Price
(See ANSI-Z39.18)
See Ins/nJc/Jona on Re-
2n (4-77
(Formerty NTIS-35)
Department of Commerce'
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EPA/ROD/R03-89/072
Kimberton, PA
Second Remedial Action - Final
16.
Abstract (Continued)
concentrations of TCE, DCE, and vinyl chloride. As a result of these findings, the
former and current owners of the plant agreed to provide 23 residential and commercial
locations with an alternate source of drinking and contact water as an interim solution
under the first operable unit. This second operable unit addresses the contaminated
plume and the source of contaminatio~. The primary contaminants of concern affecting
the ground water and surface water are VOCs including TCE and DCE.
The selected remedial action for this site includes the continued provision of
alternate water supplies through GAC treatment system and/or potable water supply
storage tanks; pumping and treatment of ground water using an air stripping system with
onsite discharge to an adjacent stream; long-term ground water monitoring; collection
and treatment of surface water at the local ground water discharge point using an air
stripping system; and institutional controls to restrict ground water use. The.
estimated present worth cost of this remedial action is $2,630,000, which includes
annual O&M costs of $175,000.
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IB:IARATI~ FOR '!BE RBX>RD OF IB:ISI~
SITE NAME AND ~OO
Kimberton Superfund Site .
Village of Kint>erton, Chester County, Pennsylvania
Staterrent of Purpose
This decision document presents the final selected remedial action for the
Kimberton Superfund Site (Site) developed in accordance with the Canprehensive
Environmental Response, Canpensation and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986 (CERCIA), 42 u.s.c.
Section 9601 et ~., and to the extent practicable, the National Contingency
Plan (NCP), 40 C.F.R. Part 300..
Staterrent of Basis
This decision is based upon and documented - in the contents of the
Administrative Record. The attached index identifies the items wh:.ch oanprise
the Administrative Record. The Ccmnonwealth of Pennsylvania has reviewed,
ciatmented and concurred 00 this Record of Decision.
Description of the Selected RenEdy
The remedial al ternati ve presented in this document is the second operable
. unit of a permanent remedy for the Kimberton Site. The first operable unit
provided a reliable interim solution for the prevention of health risks to area.
residents associated with exposure to contaminated groundwater. The alternative
selected for the first operable unit required continued ronitoring and treatment
of contaminated wells on an individual basis until a permanent water line can be
established in the community. Treatment consists of filtration utilizing granular
activated carbon adsorption. Potentially threatened wells continue to be rconitored
and will be provided treatment if appropriate. The contaminant plume and source
or sources of contamination are the subject of this second operable unit. Pumping
of the groundwater and treatment of both ground and surface water by airstripping
will be the final remedies for ~e effective remediation of this Site. -
Assessnent of the Site
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this Record of Decision,
may present an inminent and substantial endangerment to public health, welfare
or the environment.
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Declaration
The selected remedy is protective of human health and environment, attains
Federal and State requirements t;hat are applicable or relevant and appropriate,
and is oost-effective as set forth in Section l2l(d) of CER::IA, 42 V.S.C.
Section 962l(d). This remedy satisfies the statutory preferences as set forth
in Section l2l(b) of CERCIA, 42 V.S.C. Section 962l(b), for remedies that employ
treatInent that reduce toxicity, mbili ty or vol\.Dne as a principal element.
As a result of soil. sampling oonducted during a preliminary site assessment
three fonner lagoons were identified within the site with elevated concentra-
tionsof volatile organic canpounds (VOC). The lagoon areas were excavated..
in 1984. Analytical results of post-excavation soil samples indicate that
lagoon excavation activities successfully reIIDved potential source materials
for ground water oontamination fran Lagoons 6, 7, and 9. Data obtained
during and after the excavation indicate a minimum of 95 percent reduction
in total VOC ooncentrations. Finally, it is determined that this remedy
utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable.
This remedy will be reevaluated during the oourse of this remediation to
ensure an effective and timely canpletion of this remedial action.
b(3ofrY?
Date
0---0 2~
Edwin B.Erickson
Regional Administrator
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SECTION
III.
VI.
VII.
" VIII.
XI.
XII.
- XII I.
i
i
Table of Contents
for
Decision Sunrnary
PAGE
-
I.
INI'R)OOC'I'ION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
II.
SITE NAME, LOCATION AND DESCRIPl'ION................
SITE
H~SIORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
"N.
mro~~ HISIORY................................
v.
SITE. OIARACl'E'RIsrrcs... . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A. GEX)r.a;Y~EDr.a;y."............."... ~ . . . . . . . . .
B. EXI'EN'l' OF c::x:>N'rNtmATION. .........................
C. ~~Y OF SITE RISKS...........................
COMMUNITY RELATIONS HISIORY........................
REMEDIAL ALTERNATIVE OBJECTIVES....................
DESCRlPl'ION OF REMEDIAL ALTERNAXIVES...............
IX.
DESCRIPl'ION OF .ARMs...............................
X.
m1PARATIVE ANALYSIS OF ALTERNAXIVES...............
ooarn,~ION OF SIGNIFICANT CHANGES...............
SELECTED REMEDIAL ALTERNAXIVE. . . . . . . . . . . . . . . ." . . . . . .
A. ~TION CRITER!A.............................
B. DETERMINATION OF PREFERRED REl1EDIAL
~IVE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
C. 5'l'ATDtENT OF FINDINGS REGARDING WETLANDS
NID FIOODPIA.INS.................................
STATUTORY ~1mATIONS..........................
APPENDIX A. - SUMMARY OF ANALYTICAL IlA.TA
APPENDIX B. - RESPONSIVlliESS SUMHARY
APPENDIX C. - AI:MTIUSTRATIVE REOORD INDEX
APPENDIX D. - STATE LEITER OF CONCURRENCE
1
1
2
3
3
3
6
18
20
20
20
24
26
35
35
35
36
38
38
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1.
Intrrrlt rT. ion
'n1e Village of Kimberton is located in the northeastern p:>rtion of Olester
COlmty, Permsylvania near the Philadelp-lia Iretrop:>litan area (Figure 1). NLm1erc
Ck:mestic aIXl I..;ullu.ercial potable well water supplies have been sampled by the
Chester county Health Department (CQID) and analyzed by Pennsylvania Depa.rt.ne1t
of EnviIOIlliental Resources (PJIDER) since January 1982. High levels of chlorinated
hydrocartxm chanical contamination have been detected in many of the sanpled
wells. A portion of this contamination has originated fran the property currently
owned by the MIDsey Products Carpany, Inc. (M:msey) v.Jhich contained several
buried lagoons that were operated by the CIBA-GEIGY COrp:>ration (CIBA-GEIGY)
during the 1950' s. 'D1e Kimberton SUperfund Site (Site) was evaluated through
the Federal Hazard Ranking System (HRS) and subse:;uently placed on the National
Priori ties List (NFL), a list of hazardous waste sites targeted for action under
the SUperfund program, in 1982. : .
'D1ree of the lagoons have been excavated, and .contaminated soilS were
raroved to an off-site. '!he lagoons are ii1 close proximity to numerous private
water supply wells and less than one mile fran French Creek, which is used for
p.Jblic recreation and fishing. C~-GEIGY sampled 67 residential and conmercial
establishments in August, 1985 ~ and found various concentrations of trichloroethy-.
lene (TeE), 1,2-dichloroethylene (OCE) and vinyl chloride (VC) in some wells.
'Ihese canp:>unds, are all considered hazardous substances for p..trp)ses of the
CCJrprehensive Enviromental Resp:mse, COO1penSation and Li9bi li ty Act, as amended
(CERC!A) . C~~GY and M:>nsey signed a Consent order and Agreanent w::'th FADER
to provide certain residential and cCl111ercial locations with an: alternative
source of drinking and contact water in December 1986. In addition, CI~-GEIGY
and M:msey continue to m:mitor theSe and other designated locations periodiCally
according to prescribed sampling and analytical procedures outlined under the
terms of this COnsent order. 'DUs is a Potentially Resp:msible Party (PRP)
funded, Statelead enforcene1t site. .
II.
Si te Location and DescriPtion
'Ihe Site (Figure 2) eI1CCI11paSSes roth. the MJnsey property and adjacent
properties wi thin the surrounding town of Kilnberton and the area-wide groundwater
contamination. 'Ihe MJnsey property is located wi thin the northeast section of
Chester county, on the U. S. G. S. Phoenixvi lIe 7.5 minute quadrangle at approxi-
mately 750 34' 30" longitude 400 07' 3" latitude. 'Ihe Site is geographically
located within the eastern p:>rtion of a triangle formed by Route 113 (to the
SOuth), Coldstream Road (to the east) and Hares Hill Road" (to the north and
west) . 'It1e tOlNh of Kimberton is located near the crossroads of Hares Hi 11 Road
and Old Ki1nberton Road, less than 0.2 mi les fran the MJ~ey property.
Local P'1YSiograpw is characterized by rolling countryside gerierally
ccrnprised of small hills and valleys. Sit.e area surface water drains toward
French Creek, which generally flows from west to east approximately 0.75 miles
to the north of the Site. The ultimate regional drainage basin, of which French
Creek is a tributary, is the SChuylkill River located approximately 3.5 miles to
the northeast.
The Site is underlain by graphitic gneiss to the southwest and clastic
sediJrentary rocks (shales, sandstones, and si 1 tstones) to the northeast.
-------
y
r? r
FIGURE I
SITE LOCATION
MONSEY/CIBA-GEIGY
KIMBERTON.PA.
SOURCE: USGS MALVCHH AMD
PHOOUXVILLf ^A, QUADS
GROUNOWATER
TECHNOLOGY
Figure 1
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ERM Group.
Figure 2
Area of Investigation
Monsey C1BA-GE1GY
Kimberton, Pennsylvania
i. •
\
Kimbtnan Farm
Seh
J-
/
- -
"•"•'? ~~ T^L" V .N
•*«e« ;<-
•Jk>
cS
'Kimberton
'H*
\.;^
' • * f
,. '*»,«>•/
iff.
»
-------
Local hydrogeology primarily consists of a water table aquifer discharging
into local surface streams at topographic lows through a system of springs and
seeps. As would be expected, ground water movement through deeper, bedrock
zones appears to occur primarily through secondary porosity (fractures and
bedding plane partings).
III. Site History
The property known as the Kimberton site appears as parcel #194 on the
Chester County Tax map shown in Figure 3. The property is currently owned by
Monsey Products Company/ Inc. and was purchased by Monsey in 1968 from Firmenich
Incorporated.
• The chain of title search indicates that three companies have held title
to the property presently known as the Kimberton site:
- Ciba Products Corporation
- Firmenich Incorporated
- Monsey Products Company/ Inc.
Corporate research on these three companies indicates that they are all
involved in industrial production. Ciba Products Corporation (now CIBA-GEIGY
Corporation) produces Pharmaceuticals/ contact lenses/ herbicides and fungicides,
and seeds. Firmenich Incorporated is involved in the production of chemicals
and synthetic perfumes and Monsey Products Company/ Inc. produces asphalt, coal
tar roofing, driveway sealer and automotive undercoatings.
During the period of Site ownership by a predecessor of CIBA-GEIGY (Ciba
Products Company) from 1947 to 1959, a series of eight lagoons were operated on
the Site. These lagoons/ which received various residues from the manufacturing
operations at that time/ were ultimately abandoned and closed. Several of these
lagoons were subsequently backfilled or otherwise regraded.
Volatile organic compounds were first detected in the groundwater at
Kimberton during routine water quality testing of a private well on the Monsey
property by CCHD in August 1981. Subsequent testing of 24 additional local
wells by PADER from January through March of 1982 detected levels of a number of
volatile organic compounds in twelve of the wells sampled.
In response to the groundwater contamination in the Kimberton, EPA conducted
a field investigation of local groundwater, surface water, and soil contamination
in the Spring of 1982. This investigation revealed the presence of organic
chemicals, including trichloroethylene (TCE) and trans2-dichloroethylene (DCE),
in local groundwater, surface water, and soils sampled from the site. As a
result of the field investigation team's (FIT) report of July 23, 1982, the Site
was placed on the NPL by the EPA.
-------
c
a ~>
*. v%
o X -
S >vu t7 • QiawioiMMr T<
if mm 21 i 23 fwu 28 • OT
IGT) InMMd MMs \Ht 1
(Swt <9«S)
9» LJQCNO
Figure 3
-------
3
Investigations oond_ucted by CIBA~EIGY and Monsey since the initial
detection of organic catipounds in water and soil samples have indicated a
gradual release of volatile organic compounds through the subsurface to
the local water table. These compounds gradually migrate with the local
. groundwater gradient and discharge to surface waters to the north and
east in the Village of Kimberton. Volatile organic compounds have been
detected in a number of private wells in an apparent downgradient direction
from the current Monsey property. Limited, low level surface water
contamination has also been detected in local receptor streams.
IV.
Enforcement History
Past. dlspOSal practices , involving hazardous substances, which occurred
between 1947 to 1959, have. resulted in groundwater and soil contamination at
.this site. In September 1986 PADER, which is the lead agency for enforcement
for this Site, sent to CIBA~IGY and Monsey letters informing these companies
that they were Potential Responsible Parties (PP.Ps) and liable for the contamina-
tion at this Site. In addition, these letters sought their participation in the
Remedial Investigation and Feasibility Studies (RI/FS) process. Both companies
agreed to conduct a RI/FS at this Site, to provide an alternate source of
drinking and contact water to those residential and comnercia1 locations whose
water supply was contaminated. b:,~ the Site, and to continue to rronitor specified
locations for the identified contaminants. These provisions were formally
dqcumented in two Consent Order and Agreements with PADER in 1986 and 1987.
V.
Site Characteristics
A. Geoloqy /Hydrogeology
1.
Site Geology
. There are tWo predaninant geologic formations in Kirnberton:
a graphitic gneiss which is a rretarrorphic rock of Precambrian age described as a
mediLun-grained gneiss and schist characterized by the presence of graphite; the
other, the StC)Ckton Formation, a sedimentary unit of Triassic age and consisting
locally of gray and red siltstones, red shales, fine to medium gray and reddish
gray sandstones and arkosic sandstones (Figure 4). The shales and siltstones
are sometimes thinly interbedded with tmPure carbonate rock. The contact zone
between the graphitic gneiss and the Stockton Formation lies to the no~theast of
Coldstrearn PDad and in an approximate WNW to ESE orientation. It is, for the
rrost part, ill-defined and has been mapped using drilling logs of the monitoring
wells installed by Groundwater Technology Inc., (GTI) (a contractor employed by
CIBA-GEIGY). As determined through drilling of the rronitoring wells, the graphitic
gneiss has undergone significant rrechanica1 and chemical breakdown (weathering).
The weathering has worked progressively downward from the surface,
creating an upper unconsolidated weathered zone of deCOlT1I;X>sed rock and soil
which grades vertically into a crumbly, gravel-like material where pieces of
. sand"';to boulder-size rocks remain in place in a clayey matrix.. The weathered
zone was found to be between 50 feet and 75 feet in thickness, except in one area
where it was only 30 feet thick. Groundwater is located alrrost exclusively
within the weathered ~rtlon of the graphitic gneiss (locally on the Monsey
-------
~
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.f)
Q
o
t>
~C\
~
!
?
\
-(
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Figu.re .4
Generalized Site Geology
Monsey/CIBA-GEIGY
Kimberton, Pennsylvania
<:>
c
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c:::s
~ =u
a Go
"... D
C)oD
(J
(j
a
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.500.
1000
~thololia. 'T08 8Onitorinl ve1l
inuallation. , '-%1 , ,. U- 35:
- - -
-- -
Scate in Feet
LEGEND
. -....
-. .... ,_. -- ~....
. -- .. ....... ......--
.-. - . - . ., I8ftIA.8 tI8A.8 C -'- -,
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,. Consi.c. locally ol Ira, ,
ced 8i.ltat.".. , nd .bale; ,.. "'n.1 r. ~
Une co ....1- Iraiaed In, ~ .;, .~ ..~ ~ .;;
. reddish-Ica, .and.con.. ,
arkosic land.cone.. Shale'
.iltlcoae. ara .08ec1888 thinly
incarb8d~ed v1ch 18pYca
carbonace rock. .
, .
'0
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,-
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" D_inanc1, qu8l'u , letellpel'
v1th "ary1n, 88O"ftU ot ..He.
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-------
4
property) .
Weathering wi thin the Stockton Formation was far less severe wi th
the weathered layer generally ranging in thickness fran 5 feet to 15 feet
{Figure 5)." .
2.
Hydrogeolocw
The hydrogeology of the Kimberton area, is typical of the Chester
Coonty region as a whole. ' Water levels fluctuate in response to seasonal
precipitation and evapotranspirational trends. The water table closely mtmics
topography, with the dominant recharge areas lying in the higher elevations and
discharge zones consist of springs and streams at low elevations.
Within the area of concern, water table conditions exist within
two contras~ing (lithogically derived) water-bearing units: The metarrorphic
graphitic gneiss (encanpassing the Monsey property) and the Stockton Formation
(o:mpri~ing the downtown Kimberton area and surrounding properties). As discussed
previously, the graphitic gneiss is highly weathered to a median depth of 50
feet to 75 feet. The unconsolidated upper part of the graphitic gneiss generally
has rrcderate to low permeability, but contains a considerable arrount of water in
storage. Below the unconsolidated zo~e the rock is generally solidi however,
sane minerals are heavily weathered, particularly along fractures'. Permeability
and storage capacity of the solid fractured rock generally decrease with depth
as the degree of weathering decreases. The highest permeability probably occurs
. where the unconsolidated and solid rock merge. In this transitional area, openings
in rock are fonned or enlarged by the weathering process. Storage capacity,
however, is low because the rock has limited pores i ty .
Groundwater IYDvement through the gneiss tends to migrate in
response to elevational changes in the water table (Figure 6). The subsurface
zone of primary IYDvement is noted within the highly weathered and fractured
upper portion of the gneiss. Deeper water-bearing zones are reported to occur
at fracture traces (dominantly vertical to subvertical in profile), and generally
receive recharge via vertical infiltration from the overlying horizons. Local
well yields within the graphitic gneiss range fran 4 - 25 gallons per minute
(gpn) in wells which draw water fran the weathered zone, with over 200 gpn
reported in several of the deeper wells (existing Monsey wells * 1-4) which may
penetrate deeper fractures within the bedrock gneiss. Groundwater IYDvement
locally within the graphitic gneiss and suspect fracture zones are regionally
interpreted in a north-north easterly direction fran the Monsey property and
downtown Kimberton area, toward French Creek.
-------
LOCATION OF GEOLOGIC PROFILES
A-8, C-D, A'-D
Figure 5
-------
SOUTH'SOUTHWEST
C
ceouxjic
SCCTKDN C-0
NORTH-NORTHEAST
0
IM
rut
NOMMMIM. KALI
M wat» tiVIL Ik taMl W Mff IMt
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Stachlan
> un«l*t* locally •'
• llt*lon*« end red
fin* to
nom* I«*IMM» mv
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c»rbofi«l« rack.
ton** af pr*r«r«ntl«l >>t*th«rlnq.
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-------
NORTH-NORTHWEST
NORTH-NORTHEAST
M
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NMHMNMl. KALI
GEOLOGIC PflOJFUE
SECTION A'-D
»f
• •o<»l«n«».
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and slllslan** «r«
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M «»rc«
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vf*ncii tcAtt is
TMtl HOBIIOMlAi
-------
NORTH-NORTHWEST
SOUTH- SOUTHEAST
B
MONMV mooucrs
•JILPKH
1*0
mi
NQMfOMI*!. »C*Lf
SlorM«n
Con»t§t» laccllf
•on trait* IM* m
MMU MMNMM
MMn* MMmn
GEOLOGIC PROFIlf
SECTION A-B
. Shclci *»d •ilt*l*«M>
• r* ••••(!••• Ikinlir lnt«rk«M«4 itllli
r*ck.
MTC.«t*TICAL
*»hlblt«
!*«••• *f »r«f«r«n»l»l •••tfc«r in?.
•fforfM
MAT*M» n«t
IWMrWMMUItCM
I* fivt
tM. SC«lf
CUCMNMtWATCn
TECHNCMOCV
-------
WATER lABLE ELEVATION (in fttfcfcovt sec l«v«|)
30 JULY 1986 .
-------
5
The stOckton Formation generally consists of interbedded sandstones,
siltstones, and shales. The interbedding and fracturing has caused extremely
anisotropic and heterogel"ieous hydraulic characteristics associated with this
formation. Groundwater is largely transmitted along bedding planes, fractures
and joints. Water withdrawal rates ooted for wells locally penetrating the
Stockton Formation have yielded .between 2 and 20 gpn, depending upon the nature,
location, and depth of wells.
. .. a..,- Groundwater
Groundwater elevations of m:mitoring wells both on and off the
site were measured fran the top of secure casings using electrical water level
detectors (Figure 7). Field surveys were performed to determine accurately the
horizontal coordinates and vertical elevations (tied into U.S.G.S. bench mark
datum located in downtown Kimberton) of well casings. Respective field data
transposed onto prepared base maps provided a basis for the following
interpretative correlations relative to groundwater rtDvement within the Monsey
property and adjacent Kimberton area:
- The ")Ccurance of groundwater is under water table condi tions
at depths ranging fran approximately 2 ieet to 50 feet below land surface.
- Water table elevations mimicking a subdued version of
surface topography: increased groundwater elevations correlating to areas of
high topographic elevations such as ridges and knolls: red~ced groundwater
elevations occurring dominantly in topographically low. areas characterized by
, streams, creeks, and springs. .
- I.ocal groundwater recharge to the Monsey property and adjacent
Kimberton area occurs fran both vertical infiltration onto related surface areas.
and directionally fran adjacent topographic high areas: dominantly from the
south of route 113, fran the oorth of Hares Hill Road, and fran the east of
downtown Kirnberton (up topographic gradient from the easterly direction of the
. llJ1ru:tI11ed creek/marsh area). .
- Ground water discharge 'locally occurs through surface springs,
seeps, and creeks to small streams located wi thin local topographic lows. One
such discharge area is located adjacent to the northwest boundary of r>1onsey's
property as an unnamed creek flowing to the northeast through the center of
Kimberton (Stream "A": Figure 8). Another such discharge area exists to the
northeast of the Monsey property as a minor unnamed creek flowing to the northwest
and eventually converging with Stream "A" (Stream "B": Figure 8). A third local
groundwater discharge occurs to the southeast of the Monsey property, again as an
unnamed minor creek in this case flowing generally southeast from the site area
, (Stream "e": Figure 8).
- Ground water gradient and ground water flow are directionally
controlled in response to elevational changes in the water table. Under natural,
non-pumping conditions, the predominant ground water gradient from the r10nsey
property ranges directionally from the northwest clockwise through the southeast,
-------
Th«E*H Group.
Well Locations
Figure 7
-------
The ERH Group.
Site Area Stream Flow and Spring Locations
E«lm*«d Flow
0.1-OJ (cf«)
7 Estimated Flow R«t*
(eft)
/y^r^OSfnmons
X ZZ
On Sainn UOCTBoai (1
laeadom (1«tS)
Flov Direction -
Figurt 8
-------
6
toward the above noted grO\In1water discharge zones.
- Physiochemical paramaters measured fran area nonitoring
wells as baseline water: -quality characteristics (Pi, 'Im, and chloride) appear
to fall wi thin backgroum ranges. -
b.
surface Water
'!he local surface waters can be divided into three U11I1aIred
streams (Figure 8) emanating within and/or flowing through the central Kil'nberton
area. For clarity, the streams have been designated as follows:
- - Stream A: A small, pennanent stream (the prim:lry stream in
the center of Kimberton) flowiI'lggenerally south to north, adjacent to the north-
western 1:x:>ur1Cary of the M:msey property. '!his stream is primarily'spring fed west
of the Site fran sources at and upstream of the gneiss/clastic contact zone.
Estimated average stream flow in this area ranges seasonally fran 0.5 to 4 cubic
feet per second (cfs). - A significant increase in stream volume occurs up:m its
confluence with the outfall fran Gotwals Ponds. Estimated flow downstream of
this confluence ranges fran 8 to 12 ~~s.
- Stream B: An ~ent minor intermittent stream which
appears to originate fran a spring near the location of the Kil'nberton town dump
as of 1950. 'Ibe terrnirnJs of this stream is not visible on aerial photogratilS
but it is believed to becane confluent with Stream A. Estimated flow down the
headwaters is 0.1 -to 0.5 cfs. DJwnstream flow has not been observed but is not
anticipated to be significant.
- Stream C: A tributary of French Creek which flows south of
the intersection of Route 113 and Cold Stream Road. '!his stream derives a major
volume of its flow fran topogr~Cally high areas to the south of the study
area. Stream flow appears to be - intermittant upstream of Cold Stream Road.
However, a significant increase in stream flow results from a major spring located
roughly 300 feet downstream fran Cold Stream Road with flows estimated at 0.5 to 2
cfs.
B.
EXtent of ~tion
1.
Drum RE!roval
In mid 1982 CI:BA.~GY and M:msey supervised the excavation and
raroval of 57, 55-gallon drums fran an abandoned, on-site septic systan formerly
used to serve the plant's wastewater storage needs. 'IDese drums contained of f ~
specification asphaltic materials which had been used as partial backfill for
the collapsed septic pit sometime earlier. 'IDe drum reroval program, conducted
in conjunction with PADER, consisted of reroval of all drums fran the pit area,
procurement of samples fran five representative drums for analysis, procurement
of p:>st-excavation soil samples for analysis, and appraisal of p:>ssible casual
relationship between the buried drums and the groundwater contamination.-
-------
7
'D1e dnm1 excavation, rerDval, and disposal program was
successfully catpleted in l'bvanber, 1982. SOil sarrples at a level beneath the
excavation floor incticat~ no extensive migration of organic CanpJunds fran the
area. '
'D1e preliminary hydrogeologic assessment conducted by CIBl\-GEIGY
and Mmsey recarmended a nore definitive off-site investigation of the groundwater
S\1ITOlJnling the site. '!his is currently being catpleted.
2.
Laaoon Excavation
As a result of soil sampling conducted during preliminary site
assessment activities, three areas were identified within the ~ey property
with relatively high levels of organic cCJ1iX)UI1d contamination. Study of
available historic aerial photogr~ confirnai that the three areas were fonner
treatment lagoons. 'Ihese three areas, identified by GrI as Lagoons 6, 7, and 9,
were characterized by materials of similar chanical canp:>si tion and P1ysical '
appearance.
~ review of this infonnation and at the request of FADER, a
program was urnertaken by the ~-GEIGY and MmSey to excavate, rem:>ve, and
diS{:Ose of soils fran the three fonner lagoon areas as part of a site remedial
action program.
'n1e excavation program was finalized during August and early
Septenber 1984. Actual site excavation was initiated on 5eptenber 17 and
catpleted on 5eptenber 25. Site backfilling and restoration were carpleted on
October 8.
~ Canpletion of the excavation program on 5eptanber 25, 1984, a
total of 143 truckloadS of contaminated soil had been excavated from the site
representing approximately 2,050 cubic yards of material. All excavated
materials were confirnai as received at the licensed TSD faci li ty operated by
CEX:nS International, Inc., in Niagara Falls, New York.
Excavation limits were determined in the field by visual assessment and
through photoionizer neasur-ernents procured along the base and sides of each
excavation. ~ canpletion of the excavation program, representative soil
sarrples were obtained fran pit floors and walls in the presence of FADER or EPA,
and sample splits were provided to FADER for analysis. SUbsequent to this
process, marker horizons were placed in each excavation and backfilling was
initiated. 'Site backfilling and restoration were initiated on septanber 26,
1984, and canpleted on CCtober 8, 1984, with the application of vegetative cover
material.
'!he canbination of visual 'assessment, low-level recorded photoionizer
readings, and analytical results of p:>st-excavation soil sarrples all indicate that
the lagoon excavation rariedial action program was successful in rem:>ving p:>tential
source materials of ground water contamination fran the Site. Data obtained
during and subsequent to the excavation program in:licate a minim.Im of 95 percent
reduction in ,tOtal volatile organic canp:>und concentration in these fonner
-------
8
lagoons .
To rrcre oanpletely.define the representative concentrations of the chemical
oanpounds wi thin each of the former lagoon areas, a program of discrete soil
sampling was implemented fran January 11-19, 1988. Soil samples were collected
fran former Lagoons 1, 2, 3, 4, -8, and Area 5 in accordance with the Work Plan
for Canpletion of the Remedial Investigation and Feasibility Study: Kimberton,
Pennsylvania (RI Work Plan) (July 1987). IDeations of the former lagoons and
sample points are depicted in Figure 9. .
o
Conclusions fran the Lagoon Investigation
The average accumulation of silty clay overburden,
observed beneath the former lagoon areas, was approximately
8 feet in thickness. In light of the fact that no
distinct lithologic differentiation was observed between
lagoon fill material and the indigenous overburden, it is
assumed that the former lagoons were filled by regrading
adjacent soils. . In all cases, d~rectly beneath the
silty clay horizon a distinct graphitic gneiss saprolite
was encountered.. .
o
Former LagoOn 1 was comprised of approximately 5 to 7
feet of silty clay overlying the weathered graphitic
gneiss. With the exception of the 8 to 10 foot sample
interval of boring C (10.0 ppm), no significantly
elevated field CNA readings were observed.
Former Lagoon 2 contained approximately 7 to 8 feet
of overburden. . D..1e to the detection of elevated Organic
Vapor Analyzer OVA readings in soil boring B (50 ppm),
this boring was advanced approximately 3 to 4 feet below the
lagoon/saprolite interface, at which point field OVA readings
had decreased to 9 ppm.
o
o
Former Lagoon 3 was characterized by the greatest
accumulation of silty clay overburden, averaging 11
feet in thickness. No elevated field CNA readings were
observed during the soil roring program. It is
presently believed that a semi-continuous layer of dark
. gray brittle material exist at a depth of approximately
6 feet, proximal to borings C and E.
o
Former Lagoon 4 derrcnstrated 6 to 8 feet of overburden,
characterized by Wle absence of elevated field OVA
readings. A semi-continuous ananalous layer (1/4 inch
thick dark gray brittle layer) was encountered at a
depth of approximately 6 feet below roring locations E
and D. .
-------
Figure 9
Supplemental Soil Sample Locations
Monsey/CIBA-GEIGY
Kimberton, Pennsylvania
Latsratcry /
i I Sampling Areas
U-J
-------
9
o
Area 5 dem:mstrated the presence of a distinct top soil horizon
and a 7 to 8 foot thick silty clay unit overlying the graphitic
gneiss saprolite. Ari ancrnalous occurrence of a 3/4-inch thick
gray /blue brittle layer was observed near the surface. in boring
B. No elevated field (NA readings were observed. during the soil
boring program.
o
Former Lagoon 8, unlike the other lagoon areas, has not
been completely regraded and is, therefore characterized
by a distinct depression with the ground surface. Approx-
imately 5 to 7 feet of overburden was encountered above
the saprolite horizon in this area. With the exception of
the four to six foot sample interval of boring C (7.2 ppm)
no elevated (}lA readings were observed during the sampling
program. A 3-inch thick "beige paste" layer was observed
consistently at a depth of three to four inches below grade
in borings A, B, and E.
o
Wi th the exception of former Lagoons 1 and 2, only trace
concentrations of a limited number of Target Canpounds
List (Tel..) volatiles were detected in lagoon soil samples.
o
Lagoon 2 was characterized by the presence of four
volatile oompounds: trichloroethene, chlorobenzene,
ethylbenzene and xylenes at concentrations of 410 ug/kg,
(microgram/Kilogram.) 96 ug/kg, 11 ug/kg, and 25 ug/kg,
respectively.
o
Former Lagoon 1 deroonstrated the presence of
trichloroethene at a concentration of 70 ug/kg and
chlorobenzene at 9 ug/kg.
o
With the exception of Area 5, six TeL semivol~tile
canpounds were recorded in various combinations at trace
to low concentrations in the former lagoon areas.
o
Area 5 was characterized by the presence of eight .TCL
semivolatile oompounds ranging in estimated
concentrations fran a low 290 ug/kg (2-nethylphenol) to
a high of. 5700 ug/kg (phenol).
3.
Groundwater Contamination
The highest concentrati()~s of volatile organic comp.::ments (VOC) rocmi toring
wells were found in those adjacent to, and directly down hydraulic gradient fran
the site of the former lagoons. Although wells #5, #14, and #21 are reasonably
close to wells having high VOC concentrations (wells #7, #16 and #13,
respectively) they remain uncontaminated because of their upwater table
gradient positions within the hydraulic regime. VOC I S were in detected in
shallow ground water west of the lagoon areas (at well #28) but based on water
table gradient maps and chemical analysis of samples fran wells #34 and #35, in
addition to the Fitzsimnon well (no \DC detected in all three wells), ground
water in this are appears to be discharging to Stream A, northeast of the
Fitzsimnons property (Figure 12 and Tables I and 2).
-------
I
. TABLE 1
DETERMINA TlON . OF VOC COIIC£MTRA TlONS
WITHIN VARIOUS AQUIFER ZONES AND IN SPRING A-10
:u
fD
<
~.
(Q
fD
Po
Average Concenlraiion (PPb)"
Zone" T richloroelhene 1-1 ,2 - Oichloroelhene Vinvl Chloride 1,1-0ichloroelhene Total VOCs (000'
1 2 254 6,117 183 5
> 3,ooQ ppb VOCs 7 6,300 4,215.. 278 39
9 6,313 1,050 - -
MaximJm 6,313 6117 278 39 12 747
.2 10 1,232 1,102 - - .
2,000 - 3,000 ppb VOCs 29 2,100 700 - -
MaximJm 2.100 1 102 - - . 3202
3 1 250 540 690 -
1,000 - 2,000 ~ VOCs 11 747 937 164 25
13 594 637 - 10
16 1,045 964 315 21
32 433 530 - 7
MaximJm 1 045 964 690 25 2724
4 President's 48 1,Q53 - -
Trace - 1,000 ppb VOCs 3 197 603 - -
4 96 62 49 -
5 - - - -
" 6 13 - -
-
8 27 6 - -
12 563 1,050 - 7
17 608 323 - 13
23 16 21 - -
25 - 3 - -
28 397 147 - -
30 4 4 - -
MaximJm 608 1 053 49 13 1 723
Spring A-10 - 800 790 - 9
MaximJm 800 790' 0 9 1,599
VI
.......
....
o
.......
co
\D
"Based on all samples analvzed Irom 5/85 hencetor1h. ,
"Zones were eSlablished based upon Ihe approximale lolal VOC isoconcenlralion conloulS develo~ 'rom Ihe moSI recen! moniloring well dala
(June 1986 & March, June, AuguSI1988). .
-------
10
TABLE 2
. '.
Canparison of Analytical
Data fram June 23-26, 1986
and June 21-27, 1988
Sampling Periods for
Selected Wells.
well #
Total VOC (~b)
June 23 - 26, 1986
Total VOC (~b)
June 21 - 27, 1988
5
8
11
13
14
16
18
19
21
23
7
9
1730
1222
ND
606
ND
ND
ND
70
ND
ND
2180
1210
ND
1343
ND
ND*
ND .
. 40
ND -Non Detectable
*
Sample Collected March 28-31, 1988
Conclusions Fram The Groundwater Investigation (Figures 10 through 13)
o
The Kimberton Site is characterized by the occurrence of
t~ distinct geological units, the Stockton Formation and
the Graphitic Gneiss, which have different hydrological
properties.
o
Groundwater occurs under water table conditions at depths
ranging fran 2 feet to 50 feet below grade. Water table
elevations generally mimic local topographic expression
but at lesser gradients.
o
Local groundwater recharge occurs dominantly as
directional recharge from adjacent topographic high
areas and also via surface infiltration of precipitation
onto related areas.
o
Groundwater discharge occurs via surface springs, creeks
and streams in low topographic areas. The dominant
local ground water discharge zone is manifested by the
creek to the north of the Honsey property (designated
Stream B). Stream B lies to the east of the Monsey
property and converges with the above noted zone slightly
to the north of Kimberton. .
-------
Figure 10
Water Table Gradient
(7-30-86)
. Monsey CIBA-GEIGY
Kimberton, Pennsylvania
Source: Groundwtt*r Technology
225 0 223 4SQ
SCALE IN FEET
-------
Figure "
Total Volatile Concentrations (ppb)
June 1986 & March, June, August 1988
Monsey CJBA-GEIGY
Kimberton, Pa.
o V/0
-------
Figure 12
Total Volatile Concentrations (ppb)
June 1986 & March, June, August 1988
Monsey/CIBA-GEJGY
Kimberton, Pa.
I •»• If «f
•»••• a M u «r
If
•* — "**—****•** *~'* *
Sourca: Groundwat«r Tachnology. Inc.
Zone 2
Zone 3
Zone 4
(See Table 4-1 for explanation of zones)
N
500 1000
M
. . •
Scale in Feet
272150601
Ornmky/OM:
EJK1/89
D.
1/89
Revised 5/10/89
-------
13
GAG System Locations
Monsey/CIBA-GElGY
Kimfaerton, Pennsylvania
-------
11
o
Grourx1 wter gradient and flOW' within the Site area are
directianally controlled by elevational changes in
pressure head. - t1rner natural, IlOJ1-p.nnping conditions,
the direction of ground water flOW' is oriented toward
the northeast, north and northwest toward the above
mted local gr01.IrXi water discharge zones.
1m upJard hydraulic gradient has been determined in
discharge areas to the north of the Site along Stream A.
A downward hydraulic gradient has been detennined in the
recharge area to the east of the site.
o
o
Transmissivity and storage coefficient values of the.
grapri tic gneiss in the former lagoon area were
detennined to be on the order of 17,000 gJ.Xi/ft and .01,
respectively.
Hydraulic properties of the grapri tic gneiss are highly
directional. Increased hydraulic carmmication in the.
north to northeast direction is attributed to fracturing
and preferential weathering in that direction.
o
o
'!he highest interstitial ground water velocity has been
detennined to be 1905 ftjyear to the north-northeast in
the grapri tic gneiss. '!he lowest groundwater velocity
was calculated to be 113 ft/year in the Stockton Fonnation.
o
Laboratory analyses of ground water 'samples secured from
all Site m:mitoring wells indicate that 17 different VCX:s
were detected ch.1ring the m:mitoring period and appear below:
'lbluene
Chlorobenzene
Vinyl Chloride
Chloroethane
Methylene Chloride
l,l-Dichloreothene
l,i-Dichloroethane
Trans-l,2-Dichlorethene
O1lorofonn
1,2-Dichloretl1ane
l,l,l-Trichloroethane
carron Tetrachloride
1,2-Dichlorpropane
Trans-l ,3-DichloroproPene
Trichloroethene
Tetrachloroethene
Acrolein
o
Of these, Trichlorethene and Trans-I, 2-Dichloroethene
collectively accounted for 90% to 100% of the total VtX' s
present, if any, in a given sample.
-------
12
o
Vinyl O1loride was fourxl to be present at six m:mitoring
wells (1,2 ,4 ,7 ,11, and 16). 1 , lDichloretl1.ene ,
l,2-Dichloroet:bane and .l,l,l-Trichloroethane were.
repeatedly rep,rted within m:mitoring wells at less than
awroximately 50 ~ conc:entrations levels. .'
o
Migration of volatile organic canponents is catt.rolled
to a high degree by local grOlD'Xlwater gradient which
produces a rorth, northwesterly, and rort:heasterly flow
(and contaminant transp:>rt) toward t1NO local di~.
areas which converge to the north of KiJIt»ertori. . ']be
primary direction of vex: ITDVanent also coin:ides with
the direction of increased aquifer permeability and
;'. interstitial ground water velocity. .
o
N:> deep ITDVanent of vex:'s along bedding planes in the
Stockton Fonnation was detected to the rorth or east of
the Site.
o
'!he upward vertical hydraulic gradient in the Stockton
Fonnation in the discharge area to the rorth of the
known vex: plume wi 12 deter the downward ITDVE!Ie1t of
vex:' s. As previously concluded, vex: I1DvateIlt has been
determined to. be- in the direction of decreased hydraulic
head.
o
Deep vex: migration in the grapri tic gneiss to the
ro~t of the Site, ac.ross the ground water divide,
has not been detected and should rot occur under ronnal
hydraulic conditions.
o
vex: ' s occur at intermediate depths in a vertical mixing
zone wi thin fractured. bedrock gneiss in the central
plume area.
o
vex: ' s present in shallow ground water to the west of the
Site in a lateral down gradient direction are believed
to discharge to Stream A.
'!he extent of the vex: contamination in shallOW' ground
water has been defined to the north, south, and
southwest of the fomer lagoon area. To the north of
the Site, ~ing at the Kimberton Country House has
o
-------
13
o
altered the configuration of the contaminant plume but
the extent of the \OC contamination has been def ined by
Granular -Activated Carbon (GAC) system and nonitoring
well sampling oorth and west of the Kimberton Country
House. Catmercial and/or resi.dential pumping to the
southeast of the Site. near the intersection of Route 113
and Coldstream Road has also altered the extent of the
VOC contaminant plume. However, VOC concentrations .
rreasured in comnercial and residential wells decreased
away fran the Site in this area to a minirm.Jm of
approximately 20 ppb total VOC at Phillips spring
(locations 22). The occurrence of VOC at this spring
may be a residual effect of past largescale water
withdrawal by Roberts Meat Packing.
No VOC levels were detected in deep noni toring wells
located northwest, north and east of existing VOC plume.
o
No hydrogeologic data collected suggests the
preferential VOC IrDvernent;. against hydraulic gradient or
potentially along the Graphitic Q1eiss/Stockton
Formation contact zone.
o
Site hydrogeologic data indicates that the water bearing
zones of the Graphitic Gneiss and Stockton Formation
represent a single aquifer system with varying water
transmitting capacities. Specific areas of ground water
.recharge and discharge have been shown to exist through
the acquisition of data fran several deep and shallow
tronitoring well pairs. Hydrologic data indicates that
ground water gradient and flow fran the former lagoon
areas is oriented toward the northwest, north and northeast
toward the identified local ground water discharge zones
that converge just north of Kimberton Road. Groundwater
transmission in the Stockton Formation has been determined to
occur Cbrninantly along bedding planes and along bedding strike
in response to hydraulic gradient. Regional geologic mapping
evidenCe indicates that both the beds of the Stockton
Formation and the geologic contact strike approximately NW-SE
and dip tOwards the NE. Deep and shallow m:mitoring wells
(i31A and #19 c:xxnpleted to depths of 200 feet and 59 feet,
respectively) placed in strategic down dip locations within
the Stockton Formation (i.e., placed at locations to IIDnitor
potential down dip vertical migration) report no detection of
VOC's, indicating a lack of doWn dip vertical migration in
the Stockton Formation associated with the Stockton/Graphitic
Gneiss contact.
-------
Figure 0 '14 0
Streams Investigation Sampling Locations
for Laboratory Analysis
Monsey/CIBA-GEIGY, Ki~berton, Pennsylvania
~ ~A-10 ~o -
- ~/. low. C ooif
Frencll CINk
o 0
Stre.mA ~
o o~&oI
o It.,
~'.
~"'.
o "'.9,
0:
.
.,
:I
,
.
~
0<;)
<::>
,
~
-
Q =
Q ~
00 "
~ <)
o .~
a
=
~ =u
Q a 0
C
C:)otJ
q
c
t::J
o
...
N
8-5 .&
LEGEND
Permanent Stream
..- Interminent Str..",
. Spring Sam~8 ".
00
. S4dim8nt Sample
. Stream Sample
-
,""
c.
r ~o r' '" . 0
\; .~ ~} .~. .:~ ;.,.J
I
T1w
~i
cnIe
-------
14
b. Residential and Private Wells
In August 1985, a program of residential and private well sampling
in the central Kimberton area was initiated by Groundwater Technology Inc.
Results of" this initial sampling program indicated the presence of volatile
organic compounds, primarily trichloroethylene (TCE), dichloroethylene (DCE),
and vinyl chloride (VC), within the water supply of a number of local residences
and commercial establishments. As a result of this sampling program, alternative
water supplies were provided to a total of 25 locations within the Borough of
Kimberton. Currently 23 locations receive alternative water supplies (Figure
13).
The collection of data through the ongoing sampling program has and
continues to provide useful information on groundwater plume definition and
migration pattern.
Three unnamed streams designated A, B, and C flow through
the central Kimberton area.
Stream C generally flows fran west to east, with its
source being a small spring house located within a farm
pasture approximately two miles southwest of sample
location C-5.
The major contributing source to Stream C is the Phillip's
Spring (sample location C-3).
Stream B is an intermittent stream which originates from
the discharge of a subsurface concrete pipe. The source
of the stream is presently unknown, but the orientation
of the pipe indicates that the source area would be
located east to southeast of sample point B-4.
Downstream of sample point B-l, Stream B discharges into
Stream A.
Stream A, which is the primary stream in the center of
Kioberton, flows generally from south to north and
originates proximal to Fitzsimmons Pond and coalesces
with French Creek approximately 3,000 feet north of the
Monsey Property.
Sediment sample analytical results obtained from Stream A
indicate low concentrations of volatile organic compounds
trichloroethene and trans-1,2 dichloroethene, at sample
locations A-4, A-6, and A-8.
-------
15
- Several positively and tentatively identified semivolatile
compounds were ob~rved in sediment sample A-a downst,ream
from the Monsey Property. These compounds have been
attributed to a documented release of asphalitic material
from the t10nsey Property.
- Several semivolatile comp::>unds were observed in the
background sediment sample (A-17).
- Sample point A-IO, which is a primary contributory
source to the baseline flow of Stream A, derronstrated the
presence of trans-I, 2-dichloroethene (790 ug/1),
trichloroethene (800 ug/l), and 1, l-dichloroethene. (9 ug/l).
- Sampling points downstream from spring A-lO (A-9, A-7, A-
S, A-3, A-2, and A-I) indicate decreasing concentrations
of trans-l,2-dichloroetheneand trichloroethene.
- Both quantitative Gas ChronDtography/Mass Spectrography
(GC/l.f3) and semi-quantitative (GC) analysis of Stream B
samples, B-3 and B-4, denonstrated the absence of volatile.
organic.. compounds.
- Stream B samples, B-1, B-2, and B-3, were only analyzed
by the portable Gas Chranatograph (GC). . B1 dem::>nstrated
the presence of trans (cis) -1, 2-dichloroethene ,
l,l-dichloroethene, and trichloroethene, and B-2 denonstrated
the prese~ce of trans(cis)-1,2,-dichloroethene and trichloroethene
while sample B-3 derronstrated the absence of \OCs.
- Five surface water samples were collected along Stream C
and analyzed by both GC/MS and GC methodology. Samples C-
4 and C-5 were characterized by the absence of \OCs
whereas sample C-3, which is a major contributory source
for Stream C, denonstrated the presence of" trichloroethene
(17 ug/l).
- Sample points C-2 and C-4, located downstream from C-3,
indicated decreasing trichloroethene concentrations.
- Stream C samples, obtained upstream from location C-3,.
were characterized by the absence of \OCs. Sample C-3,
which represents the major contributory source for
Stream C, denonstrated the presence of trichloroethene
(17 ug/1).
-------
16
'111e CXI1pJlJl1ds that have been detected in surface water are:
Volatiles. -
l,l-Dichlorethene
Trans-l ,2-Dichloroethene
Trichloroethene
,
i
I
Water Solubility is an important factor affecting a constituent's release
and subsequent migration and fate .in the surface water envitonment. Highly..
soluble contaririnants are easily and quickly distributed wi thin the hydrologic
cycle. 'Itlese contaminants tend to have relatively low bioconcentration factors
in aquatic life and relatively low adsorption coefficients for soils and sediments.
All the detected CCll1l;Ounds in Kiroberton surface waters have high solubilities in
water. .
Henry's Law Constant indicates the relative tendency of a constituent to
volatilize fran aqueous solution to the at:rIDs];i1ere based on the canpet.ition
between its vap:>r pressure and water SOlubility. Constituents with high values
of the Henry's Law ':onstant will tend to volatilize to the atncsphere faster
tl1an constituents with low values and, therefore, will predaninantly occur in
low concentrations in surface waters. 'Itle detected canpJunds in surface waters
of the Kiroberton area have high Henry's Law constants.
5.
Wetland. Assessrrent
a.
Assessment of Potential Imcact
The areas where vegetative stress may be apparent, (Figure 15) such as
stream' banks and ground water discharge J;X)ints, were examined during the quali ta-
ti ve inventory. Typical indicators of vegetative stress. that were looked for
included denuded areas, sttmted growth, chlorosis (yellowing), excessive dead
wood (trees and shrubs), and canopy density (overstory).
A total of seven surface soil samples (0-3 inches) were collected from
representative vegetative assa11blages within Wetland Area A (Figure 16).
-------
Figure 15
Wetland Boundary Locations
Monsey/CIBA-GEIGY
Kimberton, .Pennsylvania
<:>
~
~
Q ~
1
a °
Q " 0
o ~
o .
c::=
'J 0 U
(J
Q ~
c
~aQ
~
<:>
()
o
Wetland Area A
{J
C!:;
.
.........
-. -.Co
Co
.
.... ~
.. .
-..i~
LEGEND
~
.
()
..
N
"1 to
.......... Wetland Boundaries
Permanent Stram
-. ..-Int8nnftt8nt Str8Im
- ? -1nf8rr8d LocatIon of,... ."" r. ~ {3 ~
Sub8urf8c8 Condu~ 0... :J r.. .. I ff1
o 500.
. --
~ - -
SsL~ OJ' P.
1000
I
-------
Figure
Zetland Soil Sample Locations
(15 April 1988)
Monsey/CIBA-GElGY
Kimberton, Pennsylvania
°.,'%
o / ,7
SS-2W SS^3W SS-4W
/iL
• Sol Swipto Location
-------
17
No areas of vegetative stress were observed along Streams A, B, C or
adjacent to any ground water discharge points. OVA readings of zero were
observed during the collection of each soil sample. Acetone was detected
in all samples including the travel blank. Sample SS~i contained an estimated
value of 14 ppb of methylene chloride. Acetone and methylene chloride are
camonly used chemical in the laboratory and therefore suggest laboratory
contamination. .
b. Water Quality Criteria for the Protection of Aquatic Life
on ~tarch 28 and 29, 1988, 19 surface water samples were collected and
analyzed for priority pollutant \OCs fran Streams A, B, and C. Sample locations
are presented in Figure 14. Results' of the analYSes are presented in -Table 3. .'
. Sample locations upstream of the Monsey facility on Stream A (A-16 and A-IS) did
not reveal the . presence of volatile organic conlJ;x>unds. Springs adjacent to the
Monsey facilfty and sampling points downstream indicated the presence of trans-If
2dichloroetheneand trichloroethene. Sampling point A-lO, a major contributory
source to the baseline flow of Stream A, contains the highest levels of trans-I,
2dichloroethene (790 ug/l) and t+ichloroethene (800 ug/l). A-lO was the only
station to contain l,l-dichloroethene at a concentration of 9 ug/l. .
Samples taken sequentially farther downstream from A-lO indicate a
progressive decrea$e in concentration of trans-l,2-dichloroethene and
trichloroethene as a result of dilution.
1Wo sampling points (B-3.and B-4) along Stream B did not indicate the
presence of volatile organic compounds. Five sampling points along Stream C
show the upper two stations (C-S and C-4) devoid of volatile organic compounds
while the oownstream stations (C-3, C-2 and C-l) contain trichloroethene at
concentrations of 17 ug/l, 9 ug/l and 7 ug/l, respectively. Sampling point C-3
(Phillips Spring) is a primary contributory source of Stream C as indicated fran
the chemical results. The detection of trans-I, 2-dichloroethene and
trichloroethene in Stream A and trichloroethene in Stream C indicates that the
highest concentration of both pollutants occurs in conjunction wi th springs.
This observation is similar to the observation made by GI'I in April 1982 fran
spring samples draining into Stream A, which indicated that the \OCs may be
entel:'ing th~ streams primarily fran ground water discharge points.
-------
! I ' TABLE 3 I
..
.. KIM8ERTON. PA
I I SURFACEWATER ANAL YT1CAL. RESULTS
j I L.ANCASTER LABORATORY
I SAMPLED 3/28-3/29 1988
MPLE , " .Dichloroethene (ua/l) trans-' .2-Di~hloroethene (ua/L) TriChloroethene (uqiL)
;
-, , 9 8
2 , , I 9
.3 22 20
. .5 31 25
,-7 71 59
~-9 280 270
~'-1 0 -9 790 800
~-11 27
- 12 180 14
~. 1 4 120 . 8
~-, 5 ~
~-'6
3-3
8.4
:: -1 7
;'2 9
"'..3 1 7 .
.-4
,;'5
Blank soaces indicate the comoound was not detected.
-------
18
Data available for dich10roethene (OCE) and trich10roethene (TCE) indicate
that the level of acute' toxicity for freshwater aquatic life occurs at a
concentration of 11,600 and 45,000 ug/l, respectively (USEPA 1986). The LC50
values for two freshwater invet1:ebrates (Daphnia magna and Daphnia pulex) when
exposed to tri~h10roethene are 64,000 ug/l and 45,000 ug/1, respectively.
Nei ther Daphnid showed chronic effects when exp:>sed to 10,000 ug/l of
trichloroethene. Acute toxicity tests performed on fathead minnows (Pirnephales
promelas) to 'ICE in flow-through and static test systems yeilded I.C50' s of
40,700ug/l and 66,800 ug/1, respectively. A loss of equilibrium was observed
in fathead minnows exposed to 21,900 ug/1 of TeE. The 96-hour LCSO for bluegills
(Lepomis macrochirus) was obtained at a 'ICE concentration of 44,700 ug/l. The
calculated bioconcentration factor for blueg ills (L. macrochirus) was 17.
According to the EPA Quality Cri teria for ~vater, 1980, the occurrence of chronic
toxicity in aquatic organisms caused by TeE is questionable, since the half-life
of 'ICE in tissues is less than one day (USEPA 1980). .
The maximum OCE and 'ICE concentrations found in spring A-lO 790 ug/l and
800 ug/l , respectively are. well below those listed in to the ~vai1able literature
on the acute and chronic effects of OCE and 1':E. ThE: observed levels of OCE and
TCE do not appear to be of concern to the indigenous aquatic camlUl1i ty . This
appearance is further substantiated by the inherent low bioaccumu1ation factors
of 5.6, 1.6 and 10.6 for l,l-dichloroethene, trans-l,2-dichloroethene and
trichloroethene, respectively.
c. CONCLUSIOOS OF 'mE ~ ASSESSMENT
The Endangerment Assessment (FA) for the Kimberton Site has examined .the
existing data, identified compounds of concern, evaluated potential exp:>sure
pathways, and approximated potential risks to human and other environmental.
receptors. The FA report evaluates both present risk under existing conditions
and the hypothetical risk should existing conditions change. The hypothetical
risk calculated in the FA report is representative of the worst case.
assumptions (Table 4).
The hypothetically exposed population includes all residences in which well
water quality has been affected. The potentially exposed population has been
provided wi th individual point-of-use carbon treatment systems. Therefore,
there is currently no exposure to public through ingestion of contaminated ground
water, detmal contact while bathing or through inhalation of \OC while bathing.
If the current water treatment system is maintained, there will be no risk to
the potentia11y-exposed population. If current conditions change (i.e., no
carbon treatment system or no alternate source of drinking water), then thef:e
would be a risk to the potentially exp:>sed population.
-------
T Ib'. 4
Summa" of the Allkl It the Klmberton Sit.
~
CESCRPTr.N
LIFETIME WEIGHTED
CARCINOGENIC RISK.
CAAQNOGENIC RISK
Actual (carbon systeml)
. ground w8t8r only
. all palhwaYI .'
.-
approximat.y 0
2 e.08
Hypothetical
. dermal cantacr and inhalation at stream I
. ground water u.. .
and S88p8lsprin91 (child 6-12)
. dermal contact with stream I8dImenII
(child 8-12)
}
,
c-02
-'7
~
CESCRPTOI
um,we WEIGHTED
~
HAZARD INDEX ..
NONCARCINOGENIC HAZARD
Actual (carbon sy'taml)
. ground w8t8r only
- all palhwaY'
approximat.y 0
8.36E-08
Hypothetical
. ground wa18r u..
- d8nnaI contacI with '8d1m8nta (child 8-12)
- inhUnlon of YOCI in stream (child 6-12)
- Inh8don of YOCI in 188P8I",
(child "'2)
'.17E.OO
o ...
1.21 E-08
2.35E-08
Bold val...1 indic81l - .. """ot8lld It8k II 0UIIid8 N US EPA', r~1d8d ranges.
Carcinogenic ~I:I ~~ guIdeInee - '.ooe~ ID 1.ooE-07 (US EPA)
Hazard index - 1888 - - (US EPA)
. Indicator. at8 trtchIoiI~".1.14cNar(Mf..".. and vinyt chloride (b8nza(a)pyr8ft8. benzO
-------
19
The conclusions that can be inferred from the results of the Endangerment
Assessment are as follows:
-
Actual
- risks from compounds detected in ground water is approximated to be
zero (carbon trea~nt systmes in place),
- carcinogenic risks and hazard indices for surface water exposure
(Le, Qer:mal contact with and inhalation of \OCS in surface water
and der:mal contact with PAHs in stream sediments) to children are
within US EPA's req:mnended guidelines, and .
- 00 drinking water levels are E:xceeded at the point of use (after.
carbon trea~nt); .
Hypothetical
- ooncarcinogenic hazard indices fran trans-l,2,OCE exposure in
untreated ground water exceed one,
- <;=arcinogenic risk fran tri
-------
20
VI. Cc:mmmity Relations History
The main community' Concerns for the affected residents and businesses
revolve around the issue of:
1.
2.
3.
Groundwater contamination on and off-site,
Quality of alternate water supplies, and
Desire of affected residents to remain on private wells.
VII. Rerredial Alternative Objectives
. Based upon the information presented in the Remedial Investigation and Risk
Assessment, the following remedial action objectives have been develoPed:
1.
Hydraulic groundwater control should be established to contain
the identified Site contaminants and to reduce the concentration
and mass of these contaminants present in groundwa.t4ar.
2.
A local spring (Spring A-IO) should be remediated to improve the
water quality of. a local stream designated as n An (see Figure 16).
. .
A five alternatives were specifically develoPed to address the ground and
surface water contamination at the Site. These alternatives were identified and
evaluated according to the previous described criteria required by CERCIA.
Appropriate general response actions for remediation of ground water and
surface water at the Kimberton Site have been identified in Table S. These
general response actions are described in the following paragraphs.
VIII.
Description of Remedial Alternatives
A. Identification of Potential Remedial Technology Types and Processes
Technology types and associated processes that are potentially appropriate
for the Kimberton Site have been identified. Each of these technologies will be
described and screened according to the following criteria:
Effectiveness: Each remedial technology must be evaluated according .
to its effectiveness in protecting human health and the environment.
Treatment techoologies are evaluated on their effectiveness in rerroving
specific constituents fran the contaminated media.
site-
- Ability to Meet Remedial Objectives: Remedial technologies will be
evaluated based upon their ability to reduce the concentrations and mass
of VOCs in the aquifer and/or their ability to mitigate the extent of
VOCs entering the surface water.
-------
(\)
t ,)
'"
'""-c
e,;','
".
..~
TABLE 5
IDENTIFICATION OF APPROPRIATE GENERAL RESPONSE' ACTIONS
".
ConIamnated Media
General Re . Action Ground Water Surface Water
No Action X
,
.
Coniinued Provision 08 Alemate X
~ Water &.will
Hydr8l1c Conlrol X
Cotedlon X
On-Slte Treatment X X
'
Off-Site Treatment X X
:
In Situ Treatmenl X I
"
..
-------
21
- TechnolOClV Feasibilitv: 'D1is evaluation includes consideration of the
ability to construct, successfully operate, and maintain each systen.
- Potentiallv Administrative Requirements: '!he administrative feasibility
evaluation considers such factors as penni tting and roni toring
requirements .
B. selection of Technoloc:1'ies for Groundwater
. A sunma.ry of the criteria evaluations for ground water remediation
technologies is presented in Table 8. 'll1e results of this selection process
are described below. '.
Continued Provision of Alternate Water SUDclies: Retained
because it is protective Of plblic health and the environ-
ment .
EXtraction wells: Retained for extraction of ground water
for treatment.
In Situ Bioreclamation: Eliminated because sit~related
contaminants are difficult to degrade ~ in situ treat-
ment would be less reliable and controllable than on-site
treat:ne1t.
Air Strippinq: Retained because it is a proven technology
for rem:>val of si t~related constituents fran water.
GN:, Msorption: Eliminated because this technology
exhibits limited effectiveness in rem:>ving vinYl chloride
fran water.
Chanical OXidation: Retained because it is a proven
technology for reroval of si t~related constituents fran
water.
Bioloaical Treatment: Eliminated because it would not be
practical for rem:>val of low concentrations of constituents
fran water at the Kirnberton Site.
Treatment bv a rorw: Retained because it would be an
effective technology for rem:>val of sit~related constituents
fran water in canbination with higher strength municipal
wastewater.
-------
22
In sunmary, the groundwater remediation technologies that shall be
retained for inclusion ift the developroont of alternatives include the following:
Continued Provision of Alternate Water Supplies,
Extraction Wells,
Air Stripping,
Chemical Oxidation, and
Treatment by a FOTW
C.
Selection of Technologies for Surface Water
A summary of the criteria evaluations for surface water remediation
,technologies is presented in Table 7. The resu'lts of this selection process
are described below:
No Action: Retained because it is protective of public
health and applicable or relevant and appropriate requirements
(ARARs) for surface water are not exceeded.
. Collection Sump:
treatment.
Retained for collection of Spring A-IO for
Air Stripping: Retained because it is a proven technology
for reltDval of site-related constituents from water.
GAC Adsorption: Eliminated because this technology exhibits
limited effectiveness in reltDving vinyl chloride (a break-
down product of spring-related constituents) from water.
ChernicalOxidation: Retained because it is a proven
technology. for rem:>val of site-related constituents from
water.
Biological Treatment: Eliminated because it would not
be practical for rert¥)val of low concentrations of
constituents from water from the Kimberton Site.
Treatment by PO'lW: Retained because it would be an
effective technology for reltDval of site-related
constituents fran water in ccmbination with higher
strength municipal wastewater.
-------
TABLE 6
SELECTION OF REPRESENTATIVE REMEDIAL TECHNOLOGIES FOR GROUND WATER
Technology
REMEDIAL TECHNOLOGIES
IXHWnUvu rlVWHHI vl MHBflwiV
Potable Water Supplies
ExtactionWels
(nSituBtorodamatian
TREATMENT TECHNOLOGIES
Air Stripping
GAC Adsorption
Treatment by POTW
•' O
Ab%toMset
Efecftveness RemedalObiectves
mass ol VOCs would to
reduced.
Suited we! tor al
coniammana) or concern.
-Poorly suited tor vinyl
cNoride removal.
Suited wal tor al
conlaminank ol concern.
-Concentrations of conlaminanls
are too tow tor technology
to be practical.
-Suited wel for ground
wain vumuiiivu wisi rHgner
skenglh municipal wastewater.
Technical
FeasMly
-bnptemenlable.
-bnptemantable.
-Extremely dMcuft to
oonskud. operate.
andmaimah.
lnfl«Mn nimtllrt
-impiBmenUMe.
-ImptemerOable
-Dependent on
ground water
extaction rate.
Admirisraira
Requiremento
-Ground Water Monitoring
-PotebtoWellnstola»on
Resections
-Properly Easements
Commission Permit
•Chester County Healti
Depanmerrt DrVng Permit
-Property Easements
-Dataware River Basin
Commission Permit
-Chester County Heahh
UUpMVTMNU UfWHO rWnlH
-NPDES Permit
-Air Discharge Permit
•NPDES PWivw
-NPDES Permit
•NPDES PWniH
-POTW approval
•Ouarterly monitoring
Con**-!*,
Retain
Retain
Eliminate
Retain
Eaminate
Retain
Eliminate
Retain
-------
TABLE 7
SELECTION OF REPRESENTATIVE REMEDIAL TECHNOLOGIES FOR SPRING A-10
Technology
REMEDIAL TECHNOLOGIES
Mo Action
TREATMENT TECHNOLOGES
Air Skipping
GAC Adsorption
Chemical OntrtaHon
Biological Treatment
Treatment by POTW
AbftytoMeet
Effectiveness RemedM Obtectives
-Protective of pubic -No reduction of VOCe
heath, but not protective entering surf ace water.
«j — -« *
or envponrneni.
-Protective of pubec -Reduction of VOCe
contamnanis 01 concern.
-Poorly suited for vinyl
chloride removal.
contaminants of concern.
-Concentrations of contaminants
are too low for technology to
-Suited we! for surface water
wMMfieu wiin IHIUIM*
Potential
Technical AdmMstrative
FearibsW Requirements
-Imptomsntable. -None
-Implementable. -Property Easements
-bnplementable. -NPDES Permk
-Ak Discharge Permit
-Implementable. -NPDES Permit
-hnplemsntable. -NPDES Pern*
-tmplemsntable. -NPDES Permk
•Implementable. -POTW Approval
Conclusion
RelaJn
Retain
Retain
Eliminate
Retato
Eliminate
Retain
-------
23
. .
In summary, the surface water remediation technologies that will be
retained for inclusion in the development of alternatives include the
following:
No Action,
Collection Sump,
Air Stripping,
Chemical Oxidation, and
Treatment by a roIW.
Evaluation of Technologies for Remediation of Spring A-IO and the Groundwater
Alternatives for remediation of Spring A-IO and contaminated groundwater
have been developed as shown in Table 8, and are listed below:
1.
2.
No Action,
.'
Continued Provision of Al;:ernate ~Jater Supplies,
3.
Continued Provision of Alternate Water Supplies and
Collection and Treatment of Spring A-IO,
Continued Provision of Alternate ~'later Supplies, Collection
and treatment of Spring A-IO, and On-Site Source Control and
Ground Water Remediation, and
4.
5.
Continued Provision of Alternate Water Supplies, Collection
and Treatment of Spring A-IO, On-Site Source Control and
Ground Water Remediation, and Off-Site Ground Water
Remediation.
Alternatives I and 2 offer no remediation of the surface water or ground
water at the Kimberton Site. Alternative 3 includes surface water remediation
only, while alternatives 4 and 5 ~ire the remediation of surface and ground
water.. .
Alternative 4 ~ires the on-site extraction of the frost contaminated
ground water located in the center of the \QC pl~. In addition, ground water
would be extracted fran wells located at the down gradient boundary of the site
to prevent further off-site migration of \t)Cs.
. Alternative 5 would require on-site and off-site extraction of ground water
from extraction wells located in both the graphitic gneiss and Stockton Formation.
This would provide an extensive ground water recovery program addressing all
areas of the contaminant pl~. Optimum ground water extraction rates for these
two al ternati ves shall be approximated through the use of a nurrerical
canputer m::x!el.
Alternatives 3, 4, and 5 require treatrrent of the surface water and/or
ground water. The following treatrrent technologies were evaluated for each
-------
. TABLE 8
DEVELOPMENT OF ALTERNATIVES FOR GROUND/SURFACE WATER REMEDIATION
ConUnutd Provtoton of On-Sto Some* Off-Si* Ground Cotodbnof
Afcwnafiv* Al«nutf« Water Supplies Control and Remediation Water Remediation Spring A-10 Treatment Technology
2
3
X
X
A. Air Strapping
B. Chemical Oxidation
C. TrMtiiMnt by a POTW
A. Air Strapping
B.ChwnteaJ Oxidation
C. Treatment by a POTW
A. Ak Stripping
B.Chwnfcal Oxidation
C.Tr«atm«ilbyaPOTW
r»
-------
--~-----
-
----~--- - .
24
of these alternatives:
A.
B.
C.
Air Stripping" -
Chemical Oxidation, and
Treatment by a R:YIW.
IX.
A. APplicable or Relevant and Appropriate Requirements
. Section 121 of CERCIA requires that remedial actions achieve a level
:of cleanup of hazardous substances that 1) protects human heal th and the
-environment and 2) meets "legally applicable" standards pranulgated by USEPA or
-a state for any hazardous substances or pollutants remaining on the Site. In
"addition, the remedial action must meet cleanup criteria and requirements that
are "relevant and appropriate under the circumstances of the release or
" threatened release of such hazardous substances or pollutant or contaminant"
(CERCIA, Section 121). The legally appliccible standards and relevant and
appropriate criteria at a CERCIA site are collectively referred to as "ARARs."
The water quality standards of PADER may be legally applicable for the
. portion of the. French Creek Basin encompassing the Kimberton area (25 Pa. Code
93.7); There are no PADERwater canpounds at the Site. HO'Never, 25 Pa. Code.
Section 93.6 oontains a general standard that surface waters may not contain.
substances fran waste discharge that are in such concentrations or arrounts as to
be harmful to aquatic or other life or to be "inimical" to designated water
uses. In order to. determine whether this standard is potentially a limiting
factor at the site, the ground water discharges to Stream A must be compared to
USEPA 's Ambient Water)Jali ty Criteria (~). The AWOC are not exceeded by the
concentrations or COI'I1p:>unds in the surface water, as is shown in Table 9.
Maximum Contaminant Levels (r-I::Ls) have been promulgated by USEPA under the
Safe Drinking Water Act (40 CPR Sections 141.1-141. 62). MCLs are legally. .
applicable to public water supplies serving twenty-five (25) or rrore persons. .
HCLs have been established ~or 'OCE and related organics (40 CPR 141.61 (a) ) .
These C>CLs for indicator compounds and other compounds detected at the site are
reported in Table 10." . .
Currently, the public water supply. in Kimberton is not affected by the CERCIA
releases, and therefore, r-I::Ls are not legally applicable. However, CwfCLs may be
relevant and appropriate for Class IIA aquifers even where no public water supply
is affected. A Class IIA aquifer is a current or potential source of drinking
water (USEPA) Ground Water Protection Strategy (1984) and GJidelines for Ground
Water Classification under the USEPA Ground Water Strategy (1986». The
regional aquifer underlying the site is classified as a Class IIAaquifer.
USEPA's Interim Guidance states that MCLs are generally relevant and
appropriate for Class IIA aquifers and are fully protective of human health
(USEPA Interim Guidance on Canpliance with Other Applicable or Relevant and
Appropriate Requirements, 52 Fed. Reg. 32496, 32499 (August 27, 1987».
Notwi thstanding the general policy that r-I::Ls are appropriate for Class IIA
aquifers, USEPA' s Guidance provides that C1CLs may not be relevant and
appropriate where it is technically infeasible to achieve MCLs. In those
-------
TABLE 9
RELEVANT AND APPROPRIATE REQUIREMENTS FOR SURFACE WATER
(all concentrations are in mg/L, ppm)
Comoound
1,1-Dichloroethene
1,2-Dichloroethene
Trichloroethene
Surface Water
Concentrations
Maximum Average
0.009 0.00283
0.79 0.0783
0.8 0.0633
US EPA
AWQC*
Acute Chronic
11.6
11.6
45 21.9
US EPA Ambient Water Quality Criteria 1986
"::r::o
-------
TABLE 10
RELEVANT AND APPROPRIATE REQUIREMENTS FOR GROUND WATER
(•II concentrations are In ug/L, unless otherwise specified)
Compound
Vinyl Chloride
1.1-Dichbroethene
1.1-Dichloroelhane
trans- 1 ,2-Dlchloroelhene
1.1.1-Trichloroelhana
1 ,3-Dlchloropropene
Trfchbroethene
Acrolein
Toluene
Chlorobenzene
Chbroelhane
Melhylena Chloride
Chbrotorm
1.2-Dlcnbroelhane
Carbon Telrachtorlde
1 .2 Dtehbropropbn*
Telrachbroelhane
Ground Water
Concentralbn
Maximum
690
50
60
7,600
ISO
11
11.000
110
30
4
30
40
60
20
8
8
10
Acceptable
Drinking Water
Level
2 (a)
7 (a)
4.200 - 42.000*
3.500"
20 (a)
87(6)
5 (a)
540(6)
10,800"
30.000"
N/A
5"
100 (a)
5 (a)
5 (a)
0.56 (2)
0.7"
US EPA
Health Advisory
(bng-lerm adult)
0.015 (2)
0.24 (2)
3.500 (3)
N/A
3.500 (3)
125.000 (3)
22,000 (2)
N/A
2.8 (2)
N/A
10.800 (4)
30.000 (3)
N/A
5(2)
N/A
2,600 (3)
0.95 (2)
250 (3)
0.3 (2)
0.50 (2)
6.8C (3)
0.7 (2)
Acceptable
Intake
Chronic (1)
(ug/kg/day)
NA
9
120
10(5)
540
N/A
NA
N/A
300
.27
N/A
60
10
NA
NA
N/A
NA
Acceptable
Intake
Subchronlc (1)
(ug/kg/day)
NA
N/A
1.200
270
N/A
N/A
NA
N/A
430
270
N/A
N/A
N/A
NA
NA
N/A
NA
(a) - USEPAMCL(finaQ
NA • Natappfcabb
N/A - touMdar* data to develop criteria
Bated on Acceptable Intake Chronic andfor Acceptable Intake Subchronlc x 70 kg x 1 (2L)
Heath Advisory
(1) Acceptable Daly Intake US EPA 1986
(2) •' Health Advisory-reference concentration for potential carcinogens based on 10E-06 cancer risk. US EPA 1986
(3) < US EPA Heath Advisory for bog term exposures for 70 kg adult
(4) : US EPA HeaNh Advisory for lifetime exposures for 70 kg adult
(5) -Calculated from Health Advisory
(6) iU3 EPA Ambient Water Quality Criteria, adjusted for drinking water only (1E-06 cancer risk)
C,"
-------
25
instanCes, "the cost-effective remedy may be to provide an alternative drinking
water 5Ul=P1y rather than restoring the contaminated aquifer." .
- .
Other potential ARARs are 1) Drinking Water Health Mvisory Levels
developed by the USEPA Office of Drinking Water (1987), and 2) values derived
from the SUperfund Public Health Evaluation Manual (EPA 54011-861060, October
1986) for noncarcinogens and carcinogens. 'Ihese ARARs are also presented in
Table 11.
Description of ARARs
Federal.
safe Drinking Water Act - M:Ls
Clean Water Act
- Ambient Water Quality Criteria
Clean Air Act, Part D
National Ambient Air Quality Standards
State.
Pennsylvania Clean - Ambient Water Quality Standards .
Streams Law - section 402 . .
Pennsylvania Rules and
Regulations
Title 25 Chapter 93
Pennsylvania SCenic Rivers Act
French Creek State Park SCenic Rivers Act
Pennsylvania Air Resource Regulations
Pennsylvania Air Toxic Guidelines
Addi tional Reauiretents for Protectiveness
'nle selected site remedy is consistent with the following:
Federal EXecutive Order 11988,
Floodplain Managanent 40 C.F.R.
Part 6, ApperXJ; x A.
- Action to avoid.adverse
effects, minimize potential
harm, restore and preserve
natural beneficial value.
Federal EXecutive Order 11990,
Protection Of Wetlands, 40 C.F.R.
Part 6. Appendix A.
- Action to minimize
destruction, loss, or
degradation of wetlands.
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26
Additional Requirements for Protectiveness (Cont.)
Federal Clean Water Act .
- Differential Groundwater
Policy Class IIA aquifer.
Pennsylvania Scenic Rivers Act.
French Creek State Park Scenic
River Act
Pennsylvania Air Resource Regulations
Pennsylvania Air Toxic Guidelines
New Jersey Coastal Plain
Sole Source Aquifer
- Action to min~ize aquifer
~pacts
x.
DETAILED ANALYSIS OF RETAINED REMEDIAL ALTERNATIVES
AND COMPARATIVE ANALYSIS
This section includes a detailed evaluation of each of the alternatives that
were retained after the preliminary screening process in the Feasibility Study.
The alternatives were screened on the basis of effectiveness, irnplementability
and cost. Alternative 1, No Action, was el~inated fran further consideration
because it would not provide for continuation of point of use granular activated
carbon systems provided in acco:r:-dance with an Administrative Consent Order (ACe).
with the Pennsylvania ~p~nt of Environmental Resources (PADER) and would
not address the contaminated groundwater. Al ternati ve 5, which includes groundwater
pumping off site in t. .a Stockton Formation, was elultinated from further consideration
because: .
1.
It would not provide a significant increase in \OC rem:>val fran
groundwater compared to Al ternati ve 4. . .
It could adversely affect the water quality of uncontaminated
off-site wells in the Town of Ktmberton. .
2.
3.
It would be technically oifficult to construct due to the extensive
piping and electrical networks required, which would extend under
roads, over .hilly terrain and through residential areas.
4.
It would be disruptive to roads and private property during
construction and subsequent operation and maintenance requirements.
5.
It could adversely affect the water level off-site wells in the town of
Kimberton.
Treatment technologies identified as potentially appropriate for the
contaminants present in ground and surface water include: (a) air stripping, (b)
chemical oxidation, (c) GAC adsorption, (d) on-site biological treatment, and
(e) treatment by a Publicly owned Treatment VDrks (POIW). GAC adsorption was
eliminated by the screening process because it is relatively. ineffective for
reIrOval of vinyl chloride. Biological treatment on site was eliminated by the
screening process because it is not practical for treatment of low
concentrations of contaminants in ground and surface water at the Ktmberton
-------
TABLE. ll
DETAILED ANALYSIS ofr ALTERNATIVES
Criteria
Alternative 2
Alternative 3
Alternative 4
SHORT-TERM EFFECTIVENESS:
Protection of community
during remedial actons
Protection of wo/Ken
during remedial activities
Environmental impacts
Time until response
objectives are achieved
Safely Imptementod without special
Af A£d| |tJAJ)A
Not applicable.
No impact on environment.
ARARs in Ihe ground water and
significant reduction in VOCs discharged
to surface water would not be achieved
(or a long period of time.
Safely implemented wittoul special
precautions.
Worker protection during construction
would toduda TYVEK paper suits and
gloves.
No impact on environment
Significant reduction of the amount of
VOCs discharged into Stream A would be
accomplished irnmedistoly. However.
ARARs in Mw ground water would not be
achieved for a long period of time.
Safely implemented without special
precautions.
»
Worker protection during construction
would include TYVEK paper suits and
gloves. Respiratory protection during
wel drilling could be required based upon
air monitoring results.
Ground water table would be lowered, and
couM polentisMy affect water supply welte
Significant reduction of tie amount of
VOCs discharged into Stream A would be
accornplishednunedialely. VOC
concentrations and mass in ground water
would be reduced more quickly. However.
ARARs in tie ground water would not
be achieved for a long period of time.
LONG-TERM EFFECTIVENESS AND PERMANENCE:
Magnitude of residual risk
"'0
i >
Negligible risk at Stream A. Nonexistent
nek mtfttviakvl urish nrmmd water Mane
Negligible risk at Steam A. Nonexistent
risk associated witi ground water usage
Negligible risk at Stream A. Nonexisienl
risk associated with ground water usage
because of atiemale water supplies.
-------
TABLE
DET
(CON!
TERNATIVES
Criteria
Alternative 2
Alternative 3
Alternative 4
LONG-TERM EFFECTIVENESS (CONTINUED):
Adequacy ol control*
Raliabiiy ol controls
Long-term management would
Long-larm monitoring ol tie ground
water would be required.
Carelut monitoring ol alternate water
supplies would en*ure the protection ol
public health.
Air (hipping ia expected to
meet performance requiremenu lor me
nalaminants present Long-term
..Management would include:
1) servicing alternate water supplies and
2) operation and maintenance ol
heatmanl system.
Long-term monitoring ol ma ground
water would be required.
Technical componento are not expected to
require replacement during implementation
of remedial program. CaraM monitoring ol
alternate water tuppto* would ensure
ma protection ol pubic twain.
Air shipping is expected to meet
performance requirements lor the
contaminants preterit. Long-term
management would include:
1) servicing alternate water supplies and
2) operation and maintenance ol
beatnenl system.
Long-term monitoring ol tfte ground water
would be required.
Technical components are not expected to
require replacement during implementation
ot remedial program. CareM monitoring ol
alternate water supplies would ensure
ma protection ol public health.
REDUCTION OF TOXJCITY. MOBILITY. OR VOLUME:
Treatment DTOOM* and
remedy
Amount ol hazardous malarial
destroyed or treated
Not applicable.
There would be no destruction or
heaiment ol hazardous malarial in the
aquifer and entering Stream A except by
natural degradation and lu*hing.
Air •kipping it a damorairated technology
Nut i* wal suited tor removing ma
contaminant* ol concern.
VOC* discharged via Spring A-IO at a
current rate of Ill/day would be coloctod
and treated. ThM rate would decrease win
lima. Natural degradation and lushing
wouU gradually reduce VOC level* in me
aquifer.
Air skipping i* a demonstrated technology
mat is wal suited for removing me
contaminants ol concern.
Approximately 1 fin/day ol VOCs would
be Initially exkacted bom me aquiier and
heated Also. VOCs discharged at a
rale ol If/day via Spring A- 10 would be
collected and heated. The remaining
VOCs would eventually be naturally
degraded and lushed horn the aquiier.
.1
• I
-------
11 (CONTIMtfED)
DETAILED AMXLV8M Of ALTERNATIVES
Criteria Alternative 2
^•••^^•^•^^^••^^^••••^^•MMV^MI^^H^^^^^BAqBBBBBMtelfBtel'HMPaiBVl^aV'VMMVM^^^M^^MaVlia^VMtfl^^H^^H^^^HM^^V^^^^^^
REDUCTION OF TOXICITY. MOMJTV. OR VOLUME (CONTINUED):
Reduction in toxicily.
mobity. or volume
lm»verstt>iUtyol*M treatment
Typo and quantity ol treatment
residual
There would be no immediate reduction
ol hazardous mclwult in tw aojuMer and
StrMun A by Ms fMMdMl imtfiodL
Hon»»>f.n»iurald»y«dallnn«nd
•nd •jshing would gradudy reduce VOC«
in tfw aojulkr and Mlwina SkMm A.
Not applicable.
Not applicable.
Aternaiive3
There would be an imnwdiato reduction
tromSprinflA-fO. There would be no
immediate reduction ol hazardous
macariab in Ate aquifer. However, natural
ftegredaion and Hmhing would o/aduaiy
decrease concentraeont ol VOCa in MM
•Ajilflf
^•^OTV^I
Air stripping permanent/ remove* VOCt
liwignilcanl amounto ol VOCe could be
preMM in i>e teaUd eMuert.
Altefnative 4
There would be an immediate reduceon ol
haTaWifaiM maLviiy* fantannn Otrftnm A
Irom Spring A-10 Ateo, terocouldbaa
significant reduction ol VOCs in the aquiler
by Imptenienlafton ol Ms remedial action
The remaining VOCs would gradually be
degraded and lluthed Irom the aquiler.
Air stripping pemumenlly removes VOCs
torn water.
Infiigruticanl amounn ol VOCs could be
present in the tested efluenl.
IMPLEMENTABUJTY- TECHNICAL FEASIBILITY: •
Abiily 10 consrucl technology
ReUbtty of technology
Not applicable.
ftlnl •nrtiir^frifai
NoiappecaoN.
ol up to 1.000 bet of pipeftne acroM rolling
•main and under road*.
Air stripping is expecttd to oonsfelenily
meet discharge req^Jirernenki. Technical
dUHcuMes am not foreseen.
ConstrucSon would induds tie installation
ol apprOMmalely 4.000 feel ol pipeline
across roling terrain and under roads.
Also. 10 wels would have to be
insisted through 100 feel of saturated
thickness.
Air skipping is expected to consistontV
nweldttcnarge requirements. Technical
dittculues are not foreseen.
-------
TABLE 11 (CONTINUED)
DETA&EP ANALYSIS OF ALTERNATIVES
Criteria
Atonufe.2
Alternative 3
Alternative 4
IMPLEMENTABIUTY - TECHNICAL FEASI6UTY (CONTINUED):
Ease ^undertaking additional
Monitoring oonsidaraaona
ansdpatart
A continuing ground water monitoring
changaa In ma VOC plume, mua alowing
ma protection ol the aNactad residences.
Because ol ma mttelafen ol serial
the public would be exposed to
any risk dua to ma tolun of a
monitoring program.
No fuium ramedial actions would ba
anticipated.
A continuing ground water monitoring
program would sufficienty daina any
changaa in ma VOC plume, nut alowing
ma protection of ma aHacted rasldancas.
Because ol ma inslalalion ol serial
IVlfatf t4 !•• r-*flwi ilnikl ll U HfJibflhr !*««"•
ma pubic would ba exposed to
any risk dua to ma haure of a
monitoring program. An ak stopper afluanl
monitoring program would ba required
r
No Mure remedial actions would be*
anticipated.
A continuing ground water monitoring
oroofMi woukl AiiNkJfiiiltv linfeiMt onv
changes In ma VOC plume, thus allowing
ma protection ol ma aMected residences.
Because ol na installaJion of serial
poinl-ol-use carbon uniu. it to unlikely mat
ma public would be exposed to
any risk dua to ma failure ol a
monitoring program. An air skipper effluent
monitoring program would ba required.
IMPLEMENTABIUTY - ADMINISTRATIVE FEASIBILITY.
Cocfdinatton with other
aganctoa
•Ground water monitoring
-MM inslalalion resmcaans
•Ground water monitoring
-WMtaslalalkmresB-fcaans
-NPOESparmil
-Ground water monitoring
-MfeM inslalalion restrictions
-Properly easements
-NPOESparmil
-Chaster County HeaMh Department
wal drilling permit
-Delaware Rver Basin Commission ground
water extraction permit
IMPLEMENTAfltLTIY- AVAILABILITY OF SERVICES AND MATERIALS:
Avaajtofcyoltvatnant.
storage capacity, anddspoaa)
Not applicable.
NoKwNcabla.
Not applicable.
'0
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TABLE II (CONTINUiO)
DETAILED ANALYSIS OF ALTERNATIVES
Criteria Ak*malive2
Akernalive3
Alternative 4
IMPLEMENTABILITY - AVAILABILITY OF SERVICES AND MATERIALS (CONTINUED)
AvaJUbiMyol necessary Not applicable.
^nuirui^Ml AfiH ftf^w^ialMli
Avatfabiiiyolprospecsve Not applicable.
lechnotoflles
Equipmem required is reectly available.
Minimal Anarakir frakiim MmiM tM rMMiirAri
welNteniorwtrated. Several vendors
supply each type of eqMipment required tor
airMfppinfl.
i^
Equipment required is readily available!
Minimal operator raining would be required
Air skipping equipment it available and
wel-demonsfraied Several vendors
supply each type ol equipment required tor
air stripping.
COST:
Probable construction CM! —
Annual OAM coal (not —
inducing quarterly ground
water monitoring or
maintenanaa of aftemate
water supples)
PiM«iliMMtiMa(lyato —
COMPLIANCE WITH ARARS:
ChMnicd tfMdic ARAHi tor turbos water •» mat
not U mat tor • long period ol time.
$162.000
993.000
$1.21 MWon
ARAHs far surtaoa water are met.
However. ARARs tor pound water woutd
not to met tor a ton0 period ol time.
$666.000
$176.000
92.63 Million
ARARs tor surface water are met.
However. ARARs tor ground water would
not be met tor a tong period ol time.
( t
» I
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TABLE II (CONTINUED)
DETAILED ANALYSIS OF ALTERNATIVES
1 •
«
< 1
Criteria
Alternative 2
Alternative 3
Alternative 4
COMPLIANCE WITH ARARS (CONTINUED):
Acton specific
Locaton specific
Appropriate waivers
Notappfcabte
Not applicable.
-ARARs in ••ground water are expected
to gradually be attained trough natural
lusting and VOC degradation.
- The public is presensy not at risk.
Future risk is not expected
Ful compliance wift 40 CFR Part 262
(standards tor generators) and
40 CFR Parts 264 and 26S (standards tor
owners and operators ol haiardntu waste
Emissions tan air sfetoping in toll
compliance wall Pennsylvania air
toxics guidelines.
Not applicable.
- ARARs in tie ground water are expected
to gradual? be attained through natural
lushing and VOC degradation.
-The public is prweniVnolal risk.
Future risk is not expected
Ful compliance with 40 CFR Part 2621
(standards tor generators) and
40 CFR Parts 264 and 265 (standards tor
owners and operators ol hazardous waste
Emissions torn air slipping in toll
compliance wit) Pennsylvania air
AAKifw niiMnlirtaa
Not applicable.
Not applicable
•»•
OVERALL PROTECTION OF HUMAN HEALTH AND ENVIRONMENT:
MeeVxfctoewninete.
reduce, or control risks
Matftods to protect (he
environment
•Alternative water suppiei
None.
AhnmalhM HMlnr — — "-—
-Cokecton ol Spring A-IO
-Alternative water supplies
-Cofecton ol Spring A-IO
-Extraction ol ground water
STATE ACCEPTANCE:
_• * M 1
V ^ W
COMMUNITY ACCEPTANCE:
»
Tobaaddn
fisad totrnMrvi aonncv nMaw
I • I
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27
Site. ChanicaUoxidation and treatment by a POTW were eliminated because
neither processes cost effective.
Each of the alternatives received a detailed evaluation based
upon the following criteria:
Short-term effectiveness,
Long-term effectiveness and permanence,
Reduction of toxicity, mobility, or volume,
Implementability,
Cost
Compliance with all applicable or relevant and appropriate federal
or state requirements (ARARs)
Overall protection of human health and the environment,
State acceptance, and
Community acceptance.
These criteria combine the specific CERdA requirements that must be
satisfied in a Record of Decision (RCD) with emphasis on evaluating long-term
effectiveness and related considerations.
A. Description of Alternatives
Alternative 1 - Mb Action
All alternatives considered must be judged against a "No Action"
alternative as required by CERCXA to provide a worst case for comparison with
other alternatives. This alternative involves taking no actions at the Site to
remediate the contamination. In addition, this alternative would not provide
for continuation of point of use granular activated carbon systems provided by CIBA-
GEIGY and Monsey in accordance with an Administrative Consent Order with FADER.
The no action alternative would not comply with the ARARs for a CERdA
cleanup.
Alternative 2 - Continued Provision of Alternate Water Supplies; Monitoring;
Institutional Controls.
Alternative 2 provides for the continued provision of alternate water
supplies through Granular Activated Carbon treatment system and/or potable water
supply storage tanks. "Die ground water monitoring program would also continue
to allow for periodic reassessment of the extent of contamination and the
concentrations of hazardous substances contained in the ground water. In
addition, administrative controls will be instituted to prevent the installation
of new groumwater extraction wells for use within the area affected by
groundwater contamination.
The contaminates in the groundwater would gradually meet the Maximum
Contaminant Levels (MXs) through natural flushing and volatile organic
compounds (VDCs) degradation. The MZLs are promulgated pursuant to the Safe
-------
28
Drinking Water Act (SDWA). These requirements are legally applicable to public
water-supplies serving twenty-five (25) or more persons or entailing 15 or more
service connections. There are no public water supplies in Kimberton affected
by Site releases, and therefore, MCLs are not legally applicable.
The aquifer beneath the Kimberton Community is classified as a Class IIA
aquifer under the Clean Water Act. This classification indicates that it is
utilized as a current or potential source of drinking water. The MCLs for
indicator compounds and other compounds detected at the Site (Table 10) have
been determined to be relevant and appropriate.
Alternative 3 - Continued provision of Alternate Water Supplies; Monitoring;
Institutional Controls; Collection and Treatment of Spring A°
K).
This alternative is the same as alternative No. 2 plus the collection of
Spring A-10 and the treatment of the water by air stripping.
Water quantity standards promulgated by PADER for the portion of the
French Creek basin encompassing the Kimberton area (25 Pa. Code 93.7).
There are no PADER water quality standards for TCE or any of the indicator
compounds at the site. However/ 25 Pa. Code Section 93.6 contains a general
standard that surface waters may not contain substances from waste discharge
that are in such concentrations or amounts as to be harmful to aquatic or other
life or to be "inimical" to designated water uses. In order to determine
whether this standard is potentially a limiting factor at the site, the ground
water discharges to Tributary. "A" must be compared to US EPA's Ambient Water
Quality Criteria that are shown in Table 9.
The AWQC criteria do not have the legal effect of water quality standards;
they are advisory and are subject to adjustment to reflect site-specific
factors. AWQC values for the indicator compounds and other compounds detected
at the site are reported in Table 9.
The site is in a non-attainment zone for ozone, therefore, the emissions
from the air stripping will comply with Pennsylvania air toxics guidelines. A
National Pollution Discharge Elimination System (NPDES) permit may be required
for the surface water discharge from the air stripper.
Alternative 4 - Continued provision of Alternate Water Supplies/ Collection
and Treatment of Spring A-10 and On-Site Source Control and
Groundwater Remediation
This alternative is the same as alternative No. 3 plus the collection and
treatment on-site through groundwater pumping and air-stripping. The treated
water from the air stripper will be discharged into Stream A. The extraction
wells will pump a total of 100 gallons per minute (gpm) initially, with a
capacity to pump a total of 200 gpm.
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29
A permit fipn the Delaware River Basin Commission will be required to
extract the grouflHwater. A drilling permit will also be required from the
Chester County Health Department.
VDC concentrations and mass in the groundwater would be reduced. MCLs
would be achieved over a long'period of time. Air stripping and natural
degradation and flushing of the acquifer will reduce VDC significantly.
Potential relevant and appropriate requirements include: Maximum
Contaminant Levels (MCLs), Maximum Contaminant Level Goals (MGLGs), Drinking
Water Health Advisory Levels developed by the office of Drinking Water (1987),
values derived from the Superfund Public-Health Evaluation Manual (EPA 54011-
861060, October 1986) for noncarcinogens and carcinogens, and Ambient Water
Quality Criteria (AWQC) for protection of Human and Aquatic Life.
; B. Detailed Evaluation of Alternatives
Short-Term Effectiveness
The evaluation of the short-term effectiveness of each remedial action
includes consideration of 1) the protection of the community during the remedial
action(s), 2) the protection of the workers during the construction phase of the
remedial action(s), 3) the environmental impacts of the remedial action(s), and
4) the length of time required to achieve the remedial response objectives.
Protection of the Community
None of the alternatives would generate short-term risk to the public health.,
Alternatives 3 and 4 involve treating ground and/or surface water by air stripping?
however, the emissions generated have been determined to be within safe limits.
Protection of the Workers
Alternatives 3 and 4 require construction of a surface water collection
system and/or a ground water extraction system. Workers constructing the surface
water collection system (Alternatives 3 and 4) would require protection against
dermal contact with surface water (e.g., tyvek coveralls and gloves). Workers
drilling the extraction wells (Alternative 4) would not only require protection
against dermal contact, but could require respiratory protection. This
determination would be made in the field based upon air monitoring measurements.
Environmental Impacts
Construction activities for implementation of Alternatives 2 and 3 are
absent or minimal, and thus would not generate adverse environmental impacts.
However, implementation of Alternative 4 would include ground water extraction,
which could adversely affect the ground water supply available to residents in
the area.
Time Until Response Objectives are Achieved
Alternatives 3 and 4 would require the collection and treatment of Spring
A-10. This would provide an immediate improvement in water quality in Stream A.
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30
Alternative 2, however, would. not provide any iroprovarentin water quality
in Stream A.
t .
A1ternative4 is the only alternative that would provide ground water
remediation. Ground water WOUld be extracted and treated, thereby containing
VCCs from migrating off site. It is presently anticipated that ground water
extraction and treatment could be required for approximately 30 years.
Refinement of this estimate would be p;:>ssible. subsequent to initiation of the
remedial program.
Lonq-Tenn Effectiveness and Permanence
'n1e evaluation of the long-term effectiveness and permanence of each remedial
action includes consideration of 1) the magnitude of residual risks after
inplanentation, 2) the adequacy of controls; and 3) the reliability of controls.
Macmi tude of Resic'tI1.11 Risks after ImDlanentation
At present, use of gro\.Il1Ci water at the Kimberton Site p;:>ses no risk to
p,lblic health because tt~ affected residences have been provided with alternate
water supplies. 'n1ese residences ~d continue to use alternate water SUWlies
until vex:: concentrations in the grourn water meet ARMs or until they are
hooked up to pJblic water line. Also, there is currently no significant risk
associated with deI1tBl contact with or inhalation of catpJtIIX1s detected in surface
water. 'l11erefore, residual risks renaining after inplanentation of any of the
alternatives Wuld be 'negligible.
~1.1MT of controls
Air stripping, as required by Alternatives 3 arxl 4, is expected to ~
perfonnance requirements for the contamir.ants present, provided that proper
maintenance procedUres are followed. Ialg-tenn management for any of the
. alternatives would include servicing of the alternative water supplies until
ARMs are attained or public water is introduce:l to the catm.mi ty . Long-term
mmitoring of the grourn water ~d be require:l until the ground water
contaminant levels .meet ARMs.
Reliability of controls
For each alternative to be effective, careful mmitoring of the alternate
water supplies is require:l until ARMs are met in the aquifer or until plblic
water service is made available to the ccmrami.ty. Alternatives 3 am 4 require
operation am maintenance of a water treatlrent systen. Operational c~nents
are not expecte:l to require replacement during inplateltation of these
alternatives.
Redl1rtion of Toxicity. I"bbility. or Volume ,
. 'n1e evaluation of the reduction in toxicity, robility, or volume of the
'contaminants for each ranedial action includes consideration of 1) the treatment
process and rE!1l3dy, 2) the anD\IDt of hazardous material destroyed or treated, 3)
the extent of reduction in toxicity, robility, or volume, 4) the irreversibility
of the treatment, and 5) the type am quantity of treatment residual.
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31
Treatne1t Process and RemedY
f .
~
Air stripping, as required by Alternatives 3 and 4, is a daronstrated
. technology that is well-suited for raroving the contaminants of concern.
Arrount of Hazardous Material DestroYed or Treated
'!he aITDUnt of hazardous materials destroyed or treated varies according to
the alternative. Alternative 2 would not prcm:>te the reduction of VOCs in the
ground water and entering Stream 1\ except by natural degradation and flushing of
the va:s' in the aquifer. Alternatives 3 and 4 include the collection and
treat:nent. of water fran Spring 1\-10. '1!le vo:s are currently discharged from
Spring 1\-10 at a rate of approximately 1 p:>und/day; this rate would decrease
with time as the ~s in the aquifer decrease with time. Like Alternative 2,
Alternative 3 would not prC!1Ote the reduction of vcx:s in the ground water except
by natural degradation and flushing. However, Alternative 4 would initiq,lly
provide the extractiQn of approximately 15 ~unCs/day of \U:s. '!his mass rem:>val
rate would decrease with time. '!he ranainder of low-level vo:s in the plume
would eventually be degraded anj flushed naturally.
RedlJCt.ion in Toxicity, t-bbility. or Volume
Alternative 2 W'CUld provide no :imnediate reduction in contaminant toxicity"
ItDbility', or volume in the grOtIl'Xlwater or surface water. However, natural
degradation and flushing would gradually reduce the mass of vcx:s in the aquifel
and entering Stream 1\. Alternatives 3 and 4 would provide an :imnediate reduction
of contaminants entering Stream 1\ from Spring 1\-10. Alternative 4 is the only
alternative that includes grouhd water extraction. '!his action should ~tentially
result in a significant reduction of vcx:s in the aquifer by the extraction and
treat:nent. of ground water. 'Ihe remaining VCCs would also be naturally degraded
and flushed from the aquifer over a period of time. .
Irreversibility of Treatment
Air stripping, as required by Alternatives 3 and 4, pennanently rem:>ves
va:s from ground anj surface water.
TvPe am CUanti~y of Treatne1t Resinl1i'11
For alternatives requiring treatment, Alternatives 3 and 4,
insignificant ancunts of vcx:s could be present in the treated
effluent.
Technicallv Fp~~ibilitv of Irri'lanentation
11le evaluation of the technical feasibility Of inplanenting each remedial
action includes consideration of 1) the ability to construct the equipnent
" j.ncorporating the technology, 2) the reliability of the tecnoology, 3) the ease
of undertaking additional ranedial action, if necessary, anj 4) m:mitoring
requiranents .
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32
Ability to Construct Technology
Alternatives 3 and 4 would involve construction of a collection system for
Spring A-10, including up to 1,000 feet of pipeline across rolling terrain and
under roads. Alternative 4 would require the installation of another 3,000 feet
of pipeline and ten wells for extraction and treatment of ground water. These
wells would have to be installed through 100 feet of saturated soil. These
construction activities may be difficult, but are technically feasible.
Reliability of Technology
Air stripping, as required by Alternatives 3 and 4, is expected to
consistently meet discharge requirements. This technology is a proven treatment
method for removing organic contaminants from a liquid waste stream or
contaminated water supply. Technical difficulties are not foreseen.
Ease of Undertaking Additional Remedial Action
No future remedial actions are anticipated for any of the alternatives.
Monitoring Requirements
A continuing ground water monitoring program should sufficiently define any
changes in the TOC plume, thus allowing the protection of the affected
residences for each of the alternatives. Because of the installation of serial
point of use carbon units, it is unlikely that the public would be exposed to
unacceptable risk due to the failure of a carbon unit monitoring program. An
air stripper effluent monitoring program must be implemented for Alternative 3
and 4.
Administrative Feasibility of Implementation
All of the remedial alternatives would require the continuation of ground
water monitoring and placement of restrictions on the installation of new wells.
In addition, Alternatives 3 and 4 would require an NPDES permit for surface water
discharge. Alternatives 3 and 4 would require property easements for
installation of pipelines, wells, and/or a surface water (Spring A-10)
collection device. Alternative 4 requires the extraction range of 144,000 to
288,000 gpd of groundwater, thus requiring a permit from the Delaware River
Basin Commission. This alternative may require a drilling permit from
the Chester County Health Department.
Availability of Services and Materials
The evaluation of the availability of services and materials for
implementing each remedial action includes consideration of 1) the availability
of treatment, storage capacity, and disposal services, 2) the availability of
necessary equipment and specialists, and 3) the availability of prospective
technologies.
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33
Availabili'~ of Treatment. Storaqe CaDaci tv. and Disoosal services
- -
None of the alternatives require off-site treatment, storage, or disposal
services. .. .
Availability of Necessary Equi;ment and .Scecialists
'll1.e equiprent required for implanentation of Alternatives 3 and 4 would be
readily available. Minimal operator training would be required for operation
and maintenance of an air stripper systan.
Availability of PrQSDeCtive Tecl1nolooies
Air stripping systems, as required for Alternatives 3 and 4, are available
and well~trated. Several vendors supply each type of equiptSlt required
for air stripping.
~
'll1.e evaluation of the cost for implementing each remedial action. includes
consideration of 1) the probable construction cost, 2) the annual operation and
maintenance cost, and 3) the present \oJOrth analysis. A S1..n'IIt1arY of the cost
analysis follows.
Probable construction COSt
'll1.e probable construction costs for each of the alternatives are as follOWS~
Alternative 2: $ - 0
Alternative 3: . $ 162,000, and
Alternative 4: $ 656,000
Ar1l111::11 Operation and ~intenance COSt
'll1.e annual operation am maintenance costs for implanentation of each of
the alternatives are as follows:
Alternative 2:
Alternative 3:
Alternative 4:
$ 0
$ 93,000, and
$ 175,000
'n1.ese operation and maintenance costs do not include the tmiversal
requirement for ground water mnitoring and maintenance of alternative water
SUWlies.
Present ~rth Analysis
'D1e present \oJOrth analyses for each of the alternatives, based up::m an
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34
annual_discount~te of 8%, are:
Alternative 2:
Al ternati ve 3:
Alternative 4:
$ 0
$ 1.21 million, and
$ 2.63 million
Canpliance with ARARs
The evaluation of the compliance with ARARs for each remedial action
includes consideration of 1) chemical-specific ARARs, 2) action-specific ARARs,
. and 3) location-specific ARARs. Also, if ARARs cannot be attained by the
- remSdial action, appropriate waivers justifying this deficiency must be cited.
Chemical-Specific ARARs
ARARs for surface water are met by all of the alternatives.
for groundwater will be attained after as period of time.
However'- ARARs
Action-Specific ARARs
. There are no action-specific ARARs for Alternative 2. Alternatives 3 and
4 must be in full compliance with the applicable provisions of 25 Pa. Code'
SeCtion 75.262, (Generators of Hazardous Waste) and 75.264 (Standards for Uwners
and q;,erators of Hazardous Waste Treatment, Storage, and Disposal Facilities).
Also, emissions fran air stripping would be in full compliance with Pennsylvania
air toxics regulations (Alternatives 3 and 4). .
Location-Specific ARARs
There are no location-specific ARARs applicable to any of the remedial
alternatives. . .
Appropriate Waivers
Waivers could be required for Alternatives 2 and 3 to justify the .
. . implementation of remedial actions that do not directly praoote the overall
attainment of ARARs in the ground water. Appropriate waivers for the Kimberton
. Site include:
- ARARs relating to the ground water are expected to be eventually
met through natural flushing and VOC degradation, and
- The public is presently not at risk; future risk is not
. expected.
Overall Protection of Human Health and the Envirornrent
" The evaluation of the overall protection of human health and the
environment includes consideration of I) the methods to eliminate, reduce, or
control risk, and 2) the method to protect the environment.
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35
Met.hodsto Eliminate. Reduce or Control Risks
- 1~ .
Each of the:alternatives include the continUed provision of alternate water
supplies to protect the public health from contact with contaminated grmmd .
water. There is presently no significant risk (i. e., well below EPA guidelines)
associated with surface water.
Methode; to Protect Environment
Alternative 2 does not offer protection to the envirornnent. Alternatives 3
and 4 protect the surface water by collection and treatment of Spring A-IO. In
.addition, Alternative 4 requires the extraction of ground water, which WOUld
hasten the rec1uction of va: concentration and nass in the aquifer.
State Accectance
Evaluation of this criterion is required fOllowing agency review.
. Ccmmmi tv AcceDt.ance
. Evaluation of this criterion is required fOllowing public COUI..ent.
SUnmarv of DP-t-;d led AnaJ,vsis of Alternatives
A sumnary of the detailed analysis of alternatives is presented in
Table 12.
XI.
n:x:tnnE!ntation of Sicmificant ClanaE~..c;
N:> significant changes to the preferred alternative presented in the
prop:>sed plan have occurred... .
XII.
selected RaIe:li.al Alternative
A.
Evaluation Criteria
section 121 of SMA and the current version of the National
Contingency Plan (N:]?) (50~. Reg. 47912, ~r 20, 1985) establish a
variety of requirE!1BltS pertaining to ranedial actions under CERcrA. The
fOllowing nine criteria were used in the evaluation of the renedial action
alternatives at Kimbertan:
- Overall protection of human health and the enviro11rrent refers to
whether or not a ranedy provides adequate protection and describes how risks
p:>sed throUQh each pathway are el:im:inated, reduced or controlled through
treatIre1t, engineering controls, or institutional controls.
.. - Cancliance with ARARs addresses whether or. not a ranedy wi 11 Ireet
.all of the applicable or relevant and appropriate requirE!1BltS of other Federal
and State enviralJu~ltal statutes or provides grourn for invoking a waiver.
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36
-.
- ~erm effectiveness and permanence refers to the ability of a
remedy-to furnisn-reliable protection of human health and the environment
after cleanup goals have been met.
- Reduction of toxicity, mobility or volume is the anticipated
performance of the treatment technologies a remedy may employ.
. - Short-term effecti veness address~ the period of time needed to
achieve protection, and any adverse impacts on human health and the environment
that may be posed durirg the construction and implementation period until
cleanup goal are achieved.
- ~lementabilit~ is the technical and administrative feasibility of
a remedy, inc udirg the avallability of materials and services needed to
implement a particular q>tion.
- Cost includes estimated capital and q>eration arid maintenance costs
and net presentworth costs.
" State Acceptance indicates whether, based on its review of RI/FS and
Proposed Plan, the State concurs with, opposes, or has no carment on the preferred
alternative at the present time. .
- Corrmunity Acceptance will be assessed in the Record of Decision
following a review of the public.ccmnents received on the Administrative Record
and Proposed Plan. .
B.
Determination of Preferred Remedial Alternative
. The preferred alternative is Alternative 4. Alternative 4 (collection
of Spring A-lO and extraction and treatment of ground water on site), as rore
fully described below, is reccmnended as the most technically feasible, practical,
and effective remedial action for the Ktmberton Site:
1.
The extraction wells pumpirg a total of 100 gpm initially, with a
capacity to pump a total of 200 gpo, should be installed for on- .
site hydraulic control and groond water remediation. '!be
extracted groond water should be treated in an air stripping system
am then discharged to an adjacent surface water stream (Stream
A). .
The current goal of the groundwater remediation is to achieve
natural background conditions. This goal will be periodically
reassessed durirg remediation system and aquifer performance
to determine if such goals are feasible.
2.
The principal local ground water discharge point to Stream A
(Sprirg A-lO) should be collected and treated by air strippirY) to
ircprove surface water quality.
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37
•
3. The GAC point of use treatment systems and potable water supply
storage tanks will be maintained until a public water supply is
installed.
4. Administrative controls to prevent the installation of new ground
water extraction wells for use within the area affected by ground
water contamination should be implemented.
5. Long-term ground water monitoring in conjunction with remedial
activities should be instituted to further assess contaminant
plume configuration and dynamics. During this time period the
performance of the Stockton Formation will be further evaluated to
assess the validity of the assumptions groundwater model assumptioas
which involve the remediation of the Stockton formation. If- this
evaluation indicates that further groundwater remediation in the
Stockton formation is a viable alternative/ then such a program
may be implemented for that area.
Implementation of these recommended remedial activities will meet the
objectives of CERCLA to protect human health and the environment, to be cost
effective, and to utilize treatment technologies to the maximum extent
practical.
The preferred alternative provides complete protection, in the short-term,
to groundwater users by treatment of the water at the individual wells. Long-
term effectiveness will be obtained by implementing the pumping and treatment
of the groundwater. The Responsible Parties identified at this Site will continue
to maintain carbon filters and water via below grade tanks which provide both
drinking and contact water and, which upon chemical analysis achieves the current
guidelines of background.
EPA, in consultation with PADER, has made a preliminary determination
that the preferred alternative provides the best overall compliance with
respect to the nine criteria. The preferred alternative is anticipated to meet
the following statutory requirements to:
- Protect human health and the environment
- Meet ARARs
- Be cost-effective
- Utilize permanent solutions and alternative treatment
(or resource recovery) technologies to the maximum
extent practicable.
In summary, at this time the preferred alternative is believed to provide
the best overall compliance among the alternatives with respect to the criteria
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38
used to evaluate remedies. Based on the information available at this time,
therefore, EPA and PADER believe the preferred alternative would be protective,
would meet ARARs, would be cost-effective, and would utilize permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This alternative meets
the goal of protecting human health and the environment and restoring the
contaminated groundwater to a clean and uncontaminated condition.
Schedule
Remedial Design and Construction for the final remedy is anticipated to
commence in Spring 1990.
C. Statement of Findings Regarding Wetlands and Floodplains
This decision provides a remedial alternative for treatment of
contaminated groundwater, defined as the final remedial action for this site.
However, the Design Report will consider the impact of contamination on
wetlands floodplains and surface water.
XIII. The Statutory Determinations
A. Protection of Human Health and the Environment
The selected remedy will reduce and control the amount of ground-
water contamination, which will ensure adequate protection of human health and
the environment. No unacceptable short and long-term risks will be caused by
implementation of the remedy.
Based on a review of volatile organic chemical analytical data from
collected groundwater samples from affected off-site wells, and in view of the
vinyl chloride concentrations in the untreated groundwater, the use of granular
activated carbon filters has proven to be successful in reducing the
concentrations of the contaminants of concern, (i.e. TCE, DCE, VC) to non-
detectable levels.
B. Attainment of ARARs
The selected remedy will attain the applicable or relevant and
appropriate requirements and are as follows:
Federal
Safe Drinking Water Act - MCLs
Clean Water Act - Ambient Water Quality Criteria
Clean Air Act, Part D
National Ambient Air Quality
Standards
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39
State'...
Pennsylvania Clean
Streams Law - Section 402
- Ambient Water Quality Standards
Pennsylvania Rules and.
Regulations .
Title 2S.01apter 93
Pennsylvania Scenic Rivers Act
FreI1ch Creek State Park SCenic Rivers Act
Pennsylvania Air Resource Regulations
Pennsylvania Air Toxic Guidelines
~i tiOnal Reauirenents for Protectiveness
'!he selected site ranedy is consistent with the fOllowing:
Federal EKecuti ve Order 11988,
Floodplain Management 40 C.F.R.
Part 6, ~ A.
- Action to avoid adverse
effects, minimize potential
harm, restore and preserve
natural beneficial value.
Federal EKecuti ve Crder 11990,
Protection of Wetlands, 40 C.F .R.
Part 6, Appendix A.
- Action to minimize
destruction, loss, or
degradation of wetlands.
- Differential Groundwater
Policy Class IIA aquifer.
Federal Clean Water Act
Pennsylvania SCenic Rivers Act
FreI1ch Creek State Park SCenic
River 1tct .
Pennsylvania Air Resource Regulations
. Pennsylvania Air Toxic Guidelines.
New Jersey COastal Plain
Sole SOUrce 1IqW.fer
- Action to minimize aquifer
. iltpacts
C. COst-effectiveness
'!he selected ranedy is cost effective with respect. '.me PRPs are
operating the current systans described in the selected renedial al ternati ve in
cCllpliance with the FADER Consent Order and ~eement.
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40
D.
The selected remedy is the most appropriate solution for this operable
unit and represents the maxtmum extent to which permanent solutions and
treatment can be practicably utilized.
E.
Preference for treatment as a principal element
The preference is satisfied since treatment is the principal element
of the chosen alternative.
I
I
i
I
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10) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittai of. the
rosult<5 of. GAC system sanoUng, 2/2/89. P. 30153L-301532. The sampling results
are attached. -^
11) Letter to Mr. Eugene W. Pine. Pennsylvania Department of. Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of. the
Grounclwater Technology Inc's. (GTI) report of sampling and analysis results por
the third quarter of. 1988, 2/2/89. P. 301533-301644. A memorandum regarding
groundwater guality laboratory analytical data and a report entitled "Data
Validation, CIBA-GEIGY, Kimberton, Pennsylvania" are attached.
12) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
results of GAC system sampling, 2/22/89. P. 301645-301648. The sampling results
are attached.
13} Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
crom Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re? Kimberton RI/FS
quarterly sampling well no. 33, 2/28/89. P". 301649-301649.
14) Report: Feasibility Study Report, preoared by Environmental Resources Management,
Inc., 3/89. P. 3016«50-302077.
15) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
quarterly sampling event conducted in Kimberton dated February 21 and 22, 1989,
and the results of GAC system sampling/ 3/24/89. P. 302078-302109. The
quarterly sampling avent and the results of GAC system sampling are attached.
16) Letter to Mr. Eugene V7. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
Groundwater Technology Inc.'s report of sampling and analysis results for the
first quarter of 1989, 4/10/89. P. 302110-302116. A memorandum regarding
groundwater quality laboratory analytical data is attached.
17) Letter to Mr. Eugene VI. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
results of GAC system samoling of the Kimherton Country House collected on
March 22 and 23. 1989, 4/17/89. P. 302117-302120. The sampling results are attached.
18) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
February 1989 quarterly sampling QA/QC data review oackage, 4/28/89.
P. 302121-302152.
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K_IMB ERTON _I I_S ITF
ArMINl'STPATIVF RECORD FILE * .**
INDEX OF DOCUMENTS
REMEDIAL RESPONSE BANNING
— -—__«_.-_-— — — *"^BV '— • ~"
I) Letter to Mr. Fhjoene w. Pine. Pennsylvania Department of Environmental Resources,
fron Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of. December
1988 (^uart-^rly samoling QA/QC data review package, 3/2/38. P. 300001-300034.
A report entitled "AnalyticarCuality Assurance Review, CIBA-GEIGY - Kimberton,
Pennsylvania, December 1988 Quarterly Residential and Carbon System ACO Monitoring
and Rebeddinn Samples" is attached.
2) Record of Decision, 9/30/88. P. 300035-300116.
3) Reoort: Remedial Investigation Report, Kimberton, Pennsylvania, Volumes I-II,
orepared by Environmental Resources Management, Inc. and Groundwater Technology,
Inc., 10/14/88. P. 300117-301484. References are listed on P. 300283.
4) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
GAC system sampling, 10/31/88. P. 301485-301488. The sampling results are attached.
5) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
. from Mr. J. Stewart Johnson, CIHA-GEIGY Corporation, re: Transmittal of the
GAC system sampling, 11/16/88. P. 301489-301490. The sampling results are att,' 3.
6) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
analytical results obtained from the December 1988 quarterly sampling of the
GAC systems, 1/5/89. P. 301491-301519. The analytical results are attached.
7) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
GAC system sampling, 1/9/89. P. 301520-301522. The sampling results are attached.,
8) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GEIGY Corporation, re: Transmittal of the
analvtical results obtained from the December 1988 quarterly sampling of the
GAC systems at the Weaver Residence, 1/12/89. P. 301523-301525. The analytical
results are attached*
9) Letter to Mr. Eugene W. Pine, Pennsylvania Department of Environmental Resources,
from Mr. J. Stewart Johnson, CIBA-GFIGY Corporation, re: Transmittal of the
analytical results obtained after rebedding of carbon treatment systems at the
Effgen, Pifer and Ludwick locations, 1/23/89. P. 301526-301530. The analytical
results are attached.
* Administrative Record File available 5/15/89.
** For further documentation on this site, please refer to the Kimberton Site
Administrative Record.
Note: Company or organizational affiliation is identified in the index only when
it appears in the file.
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. -
APPENDIX C.
- -~.
ADMINISTRATIVE RECORD INDEX
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- 9 -
GLOSSARY OF TERMS
Administrative Record (AR) - A legal document that contains information on
Superfund site. The AR serves as the basis for the selection of a Superfund
response action, and this record is available to the public.
ARARs - Applicable or relevant and appropriate Federal, State or
other promulgated public health and environmental requirement.
CERCLA - Comprehensive Environmental Response, Compensation, and Liability
Act established a Trust Fund for the purposes of cleanup at hazardous waste
sites identified on the National Priority List.
Feasibility Study (FS) - The purpose of this study is to identify and screen
cleanup alternatives for remedial action, and to analyze in detail the technology
and costs involved with the various alternatives.
National Contingency Plan (NCP) - Contains the regulations that govern the
Superfund program*
National Priorities List (NPL) - EPA's list of the nation's top priority
hazardous waste sites that are eligible to receive federal money for response
under superfund.
Remedial Design - An engineering phase that follows the Record of Oscisicm
when technical drawings and specifications are developed for the subsequent
remedial action at a site on the National Priorities List (NPL).
Remedial Investigation (RI) - The purpose of this study is to gather th@
data necessary to determine the type and extent of contamination at a Superfund
site.
Superfund - The common name used for the Comprehensive Environmental
Response, Compensation, and Liability Act, also referred as the Trust fund. The
Superfund program was established to help pay for cleanup of hazardous waste
sites and to take legal action to force those responsible for the sites to clean
them up.
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4. .The GAC point-of-use treatment systems and potable water supply storage
tanks should be maintained until a public water supply is installed.
5. Administrative controls to prevent the installation of new groundwater
extraction wells for potable use within the area affected by groundwatei
contamination should be implemented.
6. Long-term groundwater monitoring in conjunction with remedial
activities should be instituted to further assess contaminant plums
configuration and dynamics.
Implementation of these recommended remedial activities will meet the
objectives of CERCLA to protect human health and the environment, to be cost
effective/ and to utilize treatment technologies to the maximum extent possible.
PADER, in consultation with EPA, has made a preliminary determination that
the preferred alternative provides the best balance with respect to the nin©
criteria. In addition, both surface and groundwater remediation is consistent
with the policy of the Pennsylvania Clean Streams Law which provides
for the remediation and restoration of polluted streams and groundwater
to a clean and unpolluted condition.
SUMMARIZING THE STMinQRY FINDINGS
In summary, at this time the preferred alternative is believed to provide
the best balance of trade-offs among alternatives with respect to the criteria
used to evaluate remedies. Based on the information available at this time,
therefore, PADER and EPA believe the preferred alternative would be protect
human health and the environment, would attain ARARs, would be cost-effective,
and would utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
The proposed remedial activities focus on the known Site contamination.
These activities will eliminate the risk the Site currently presents to human
health and the environment. If unknown conditions or information
available and actions are warranted to protect human health and the environment
or to prevent abate, or minimize an actual or threatened release of hazardous
substances on at or from the Site, previous activities performed at the Site
shall not be doemod to limit the power and authority of EPA and the
Commonwealth of Pennsylvania.
FblJBMing the conclusion of the 30-day public comment period on this
proposed remedy, a Responsiveness Summary will be prepared. Changes to the
preferred alternative, or a change from the preferred alternative to another
alternative may be made if public conosnts or additional data indicate that
modifications to the preferred alternative or a different remedy would better
achieve the cleanup goals for the Site. The Responsiveness Sunnary will sunmarize
citizen's contents on the proposed remedy and PADER and EPA*s responses to these
comments. Thereafter, PADER and EPA will prepare a formal decision document that
summarizes the decision process and the selected remedy* This document will
include the Responsiveness Summary. Copies will be made available, for public
review, in the information repository listed previously.
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- 7 -
with the Pennsylvania Department of Environmental Resources (PADER). Alternate
5, which includes groundwater pumping off site in the Stockton Formation, ms
eliminated fron further consideration because:
1. It would not provide a significant increase in VOC removal frcra
groundwater compared to Alternative 4.
2. It could adversely affect the water quality of uncontaminated
off-site wells in the Town of Kimberton.
3. It would be technically difficult to construct due to the extensive
piping and electrical networks required, which would extend under
roads/ over hilly terrain and through residential areas.
4. It would be disruptive to roads and private property during -
construction and subsequent operation and maintenance requirements c
5. It could adversely affect the water level of off-site wells in the town
of Kimberton.
Treatment technologies identified as potentially appropriate for the
contaminants present in ground and surface water include* (a) air stripping,
(b) chemical oxidation/ (c) GAC adsorption/ (d) co-site biological treatme
(e) treatment by a Publicly Owned Treatment Works (POIW). GAC adsorption wa«.
eliminated by the screening process because it is relatively ineffective for
removal of vinyl chloride. Biological treatment on site was eliminated by the
screening process because it is not practical for treatment of low concentrations
of contaminants in ground and surf ace water at the Kimberton Site. Chemical
oxidation and treatment by a PDTW were eliminated because neither process is cost
effective. -
PRELDONMOr EBTBMPanCH OP PBEFHggD IOCDIAL ALTBMMTVE
tioos for naniiHuT Actions
Alternative 4 (collection and treatment of a local spring and extraction arid
treatment of groundwater on site)/ as more fully described below/ is reconnended
as the most technically feasible/ practical/ and effective remedial action for
the Kimberton Site* The alternative also includes the continued provision of
Alternative Hater Supplies.
1. 3M> extraction wells pumping a total of 100 gpa, initially/ with a
capacity to punp a total of 200 gpja should be instated for co-site
hydraulic control and groundwater remediation. The extracted groundwatei
should be treated in an air stripping system with appropriate emission
controls and then discharged to an adjacent surface water system.
2. The principal local groundwater discharge point to Stream A (Spring A-l
should be collected and treated by air stripping to improve surface
water quality. •
3. A public water supply should be installed when feasible to provide a
long terra water supply system for the area to replace currently used
point-of-use water treatment systems and water storage tanks.
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- 5 -
/ Five alternatives were specifically developed to address the ground and
/ surface water contamination at the Site. These alternatives were identified and
/ evaluated according to the previous described criteria required by CERCLA.
( -r Devgldaent and Screening of Remedial Action Alternatives
The following remedial action alternatives were developed/ each providing a
different degree of remediation:
1. Mo Action: No provision of alternate water supplies and monitoring
a certain locations.
Estimated Construction Cost: 0
Estimated Operation and Maintenance Cost: 0
Estimated Implementation Timeframe: Not Applicable.
•
2. Continued Provision of Alternate Mater Supplies (point of use
GAC systems and water storage tanks) currently in place including
monitoring.
Estimated Construction Cost: 0
Estimated Operation and Maintenance Cost: $250,000/year
Estimated Implementation Tims-frame: Indefinite.
3. Continued provision of Alternate Water Supplies,~Collection
and Treatment of Spring A-10: Same as alternative No. 2 plus the
collection of Spring A and.the treatment of the water by air-
stripping with appropriate emission controls.
i
Estimated Construction Cost> $162^000
Estimated Operation and Maintenance Cost: $93,000/year
Estimated Implementation Timeframe: 30 years
4. Continued Provision of Alternate Water Supplies, Collection
and Treatment of Spring A-10, and Cn-Site Source Control and
Groundwater Remediation: Same as alternative No. 3 plus the
collection and treatment on-site through groundwater pumping
and air-stripping with appropriate emission controls.
Estimated Construction Cost: $656,000
Estimated Operation and Maintenance Cost: $175,000/year
Batinmtarl Implementation Timeframe: 30 years
5. Continued Provision of Alternate Miter Supplies, Collection
and Treatment of Spring A-10, and Cn-Site Source Control and
Groundwater Remediation, and Off-Site Groundwater Remediation:
Same aa alternative No. 4 plus off-site collection and
treatment of groundwater.
Estimated Construction Cost: $944,000
Estimated Operation and Maintenance Cost: $194,000/year
Estimated Implementation Timeframe: 30 years
The alternatives were screened on the basis of effectiveness, implenentability,
and cost. Alternative 1, No Action, was eliminated from further consideration
because it would not provide for continuation of point of use granular activated
carbon systems provided in accordance with an Administrative Consent Order (AGO)
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- 5 -
There is currently no public exposure to site contaminants through gr^-
use/ because the potentially exposed population has been provided with
individual point-of-use carbon filtration treatment systems. If the current
water treatment systems are maintained/ there should be no future risk to the
potentially fXposed population.
If installation of point-of-use systems and alternate water supplies had not
been implemented/ there would be a risk to the potentially exposed populations
This hypothetical exposure scenario (i.e., use of untreated groundwater) would
introduce a carcinogenic risk of 1 x 10~2 due to the presence of vinyl chloride
and trichloroethene. This risk exceeds USEPA's recommended guidlines in groundwa-
of 1 x 10~4 to 1 x 10~7 at CERCIA sites. Known contaminants in the grounds ter
at the Kimberton Site do not currently pose risk to public health, however the
objectives of groundwater remediation are to contain the contaminants on-sifee and
to remove these contaminants from the groundwater to be protective for future
use.
Human contact with or inhalation of compounds in sediments, streams, ssaps, a
springs represents an actual exposure scenario. However, the carcinogenic risks
and hazard indices for this exposure (i.e., dermal contact with and inhalation of
contaminants in surface water and dermal contact with PAHs in stream sediments)
are within IE EPA's
ded guidelines for CERCLA sites.
Comparison of aquatic life criteria with the actual concentrations in th~
stream and stream sediments shows that the aquatic life criteria are exceed&i '
for TCE and OCE in Stream A at Spring A-10. The objectives of surface water
remediation is to treat the water discharge at Spring A-10 thereby improving the
water quality of Stream A.
The soil and air evaluated under the current RI are not considered exposure
media for this assessment because site access is limited, the site is well vegetate
and surficial soils are not contaminated. The results of the soils investigation
conducted as part of the RI show that there are no significant concentrations of
contaminants present within the former lagoons. Therefore the former lagoons are
no longer acting as significant continuing sources for groundwater contamination
and no remedial action is required with respect to the former lagoons.
As.'
Based upon the information presented in the Remedial Investigation and Risk
sment, the following remedial action objectives have been developed:
dwater control should be established to contain
V
Hydraulic gr
the identified Site contaminants and to .reduce the concentration and
mas* of these contaminants present in groundwater.
A local spring (Spring A-10) should be remediated to improve
the water quality of a local stream designated as "A" (see Figure 1).
-------
- 4 -
- Short-term effectiveness: the period of time needed to achieve protection.
and any adverse impacts on human health and the environment that may be
posed during the construction and implementation period until cleanup
goals/ are achieved.
- Impleraentability: the technical and administrative feasibility of a remedy
including the availability of materials and services needed to implement a
particular option. .
" Coat: includes estimated capital/ operation and maintenance, and net preser
worth costs.
• State Acceptance; indicates whether/ based on its review of RI/PS and
Proposed Plan/ the State concurs on/ opposes, or has no cement on the
preferred alternative at the present tine*
• Community Acceptance: will be assessed in the Record of Decision following
a review of the public comments received on the Administrative Record and
the Proposed Plan.
REMEDIAL INVESriGMTCH AND RISK ASSESSMENT PIMDDC8
The Remedial Investigation (RI) Reports prepared for the Kimbertcn Site
indicate that past manufacturing and wast* saiiegement operations hare affected
local 1 ground; and surface water* in the ana* Trichlorosthene, 1/1-dlchlorcethene/
and trans-1 /2-dicfaIoroetnene an present in ground and surface waters. In addition
vinyl chloride is present in groundwater in several isolated locations. All of
these compounds are known as volatile organic ««ujMimls (WGs).
groundwater is the primary drinking water source in the Kiaberton
cccnunity. Those locations impacted by the presence of Site-related organic
ouapuunds have been equipped with Granular Activated Carbon (GAC) treatment syst
and/or potable water supply storage tanks. These operational systsss have) been
denonstrated to be effective in providing potable water which meets current drinking
water standards. This remediation was the subject of a Record of Decision dated
September 29, 1988 and constitutes Operable Unit 1 of the remedial action for the Si
The Administrative Record for this sits demonstrates that there is no current
risk to human health associated with groundwater treatment systems or alternate
water supplies which have been provided to the affected locations. Environmental
regulations provide that/ where practical, contaminated water supply aquifers
should be lemsiUiteil.
The Administrative Record also documents that the currant risk to human
health associated with dermel contact with or inhalation of oceyuunJs detected in
surface water are below n»A guidelines. Bowever/ nmmiH il action is iai.i.mmni>V il
to treat the discharge* of Site-related volatile organic compounds from a local
spring due to exoedsnoa of Ambient Water Quality Criteria which could impact
aquatic life.
-------
- 3 -
HOLE IN THE SELECTION PROCESS
This proposed plan is being distributed to solicit public comment regarding
the-proposed pTan and the other alternatives to clean up the contamination at
this Site. Detailed information on all of the material discussed here may be
found in the documents contained in the Administrative Record (AR) for the Site,
including the RI/FS Report.for the Site. Copies of these documents are available
for review at the following information repository location:
Cast Pikeland Ibwnship Municipal Building
Rapps Oam Road
Kimberton, PA 19442
The public comment period will run from May 16, 1989, to June 14, 1989c
Written comments, questions and requests for information can be sent to:
Gene Pine, Project Manager
Bureau of Waste Management
PA Dept. of Environmental
Resources
Fulton Building, 7th Floor
3rd and Locust Streets
Harrisburg, PA 17120
717-783-781S
Frank Roller
Ccnraunity Relations Coordinator
Bureau of Waste Management
PA Dept. of Environmental
Resources
Fulton Building, 7th Floor
3rd and Locust Streets
Harrisburg, PA 17129
717-783-7816
EVMJOAnOM CRITERIA
*
With PACER oversight, CIBA-GEIGY and Monsey commenced remedial activities
at the Site in 1984. A Remedial Investigation/Feasibility Study (RI/FS) per-
formed under a 1987 Consent Order and Agreement with PACER, was completed
in April 1989. In addition, the Consent Order and Agreement provides
for the provision of alternate water supplies and monitoring of certain
locations. The RI/FS identified remedial action alternatives- that would address
the contamination of the Site. These alternatives were then evaluated against
the following nine criteria*
- Overall protection of human health and the environment: whether the remedy
provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering
or institutional controls.
with ARARa: whether or not a- remedy
meet all of the appli=
cable- or relevant and appropriate requirements (ARARs) of other Federal
and State, environmental statutes and/or provides grounds for invoking a
waiver. Whether or not the remedy complies with advisories, criteria and
guidance that EPA and PACER have agreed to follow.
- Long-term effectiveness and pei
n the ability of the remedy to main-
tain reliable protection of human health and the environment over time
once cleanup goals have been met.
Reduction of toxicitv, mobility or volume* the anticipated performance of
the treatment technologies the remedy may employ.
-------
- 2 -
and Liability Act (CERCLA) CTRA-TPTV-V
Agreement wi£h PADERto provide ^eS,?Y ** *»»y signed a Consent
with an alternative sourS ot drSKS" ,3sidentiai and cornercial io
FIGURE 1
-------
Kijaberton Superfund Site Proposed Remedial Action Plan
Presented by Pennsylvania Department of Environmental Resources
and the United States Environmental Protection Agency
- This proposed remedial action plan has been prepared by the Pennsylvania
Department of Environmental Resources (PADER) and the United States Environ-
mental Protection Agency (EPA). The proposed plan presents clean up alter-
natives that PADER and EPA have considered for the Kimberton Superfund Site
(Site) in the Village of Kimberton, Chester County, Pennsylvania. These alter°
natives were identified and described in the Remedial Investigation reports and
a Feasibility Study (RI/PS Report) which were prepared to evaluate: 1) the
extent of the contamination problem at the site, 2) the potential risks to th<§
public health and the environment and 3) the steps to be taken to correct the
problem. The proposed plan discusses the second of two operable units for
this site. The first operable unit provided for treatment of contaminated
groundwater by filtration utilizing granular activated carbon adsorption and &
monitoring program at certain locations. The second operable unit focuses
on the elimination and control of the contamination source.
Section 117 (a) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), 42 U.S.C. Section 9617(a), requires
publication of a notice and a brief analysis of a Proposed Plan for any remedial
action at a Site. The proposed plan begins with a brief history of the Kimberton
Site, followed by a summary of each of the remedial alternatives PADER and E£&
have considered for dealing with the groundwater contamination at this site,
and includes PADER and EPA's rationale for recommending and, in some cases
eliminating, any one of these remedial alternatives. In addition, this proposed
plan identifies the preliminary decision on a preferred alternative and explains
the rationale for the preference. PADER and EPA are seeking public comment on
all of the remedial alternatives currently under consideration. .At the conclusion
of this proposed plan, a glossary of 'terms that may be unfamiliar
to the general public is provided.
SITE DESCRijri'iON AND
The Village of Kimberton is located in the northeastern portion of
Chester County, Pennsylvania near the Philadelphia metropolitan area.
Numerous domestic and commercial potable well water supplies have been sampled
by the Chester County Health Department and analyzed by PADER since January
1982. High levels of chlorinated hydrocarbon chemical contamination have been
detected in many of the sampled wells. The source of this contamination has
been identified as the property currently owned by the Monsey Products Corporation
(Monsey) which contains several buried lagoons that were operated by the CIBA-GEIGY
Corporation (CIBA-GEIGY) during the 1950 's (see Figure 1).
Three of the lagoons were excavated in 1984 and the contaminated
soils were removed off-site. The lagoons are in cloex* proximity to numerous
private water supply wells and are less than one mile from French Creek, which is
used for public recreation and fishing. CIBA-GEIGY sampled 67 residential and
commercial establishments in August 1985 and found various concentrations
of trichloroethene (TCE), trans-l,2-dichloroethene (1,2 DCE), 1,1-dichloroethene
(1,1 DCE) and vinyl chloride (VC). These contaminants are all considered
hazardous substances under the Comprehensive Environmental Response, Compensation
-------
I. Introduction
The Kimberton site occupies approximately one acre and
is Located in the northeastern portion of Chester County in
the Village of Kimberton. Domestic and commercial well water
samples haWe detected high levels of chlorinated hydrocarbon
chemical contamination. A source of this contamination has
been identified as the property currently owned by the Monsey
Corporation which contained several buried lagoons that were
operated by CIBA-GEIGY Corporation during the 1950's. An
investigation of the site and further sampling studies have
revealed the presence of assorted volatile organic compounds.
The Kimberton site was added to the Superfund National Prior-
ities List (NPL) in 1982.
II. Summary of Community Relations Activities
A number of public meetings were conducted during 1981-82
by the Pennsylvania Department of Environmental Resources and
EPA to discuss the results of preliminary water sampling and
the possible cleanup actions that may be taken. In cooperation
with PADER, CIBA-GEIGY and Monsey Products, Inc. conducted
additional public meetings and provided briefings to local
officials to inform them of the site investigation results. In
1985, both companies established interim water supplies for 23
families and also provided carbon adsorption systems. In
August of 1988, PADER and EPA notified area residents that the
Proposed Remedial Action Plan for Operable Unit I was available
for review/comment by placing an advertisement in the August 26,
1988 edition of the Chester County Daily Local News. In additione
the proposed plan was mailed to all citizens in the area whose
names were on the site mailing list. A public meeting to discuss
the Proposed Remedial Action Plan was also offered to area
residents. However, requests for such a meeting were never
received.
Operable Unit II proposed remedial alternative focused on
groundwater remediation at the Kimberton Site. In May of 1989,
PADER and EPA notified area residents that the Proposed Remedial
Action Plan was available for review/comment by placing an
advertisement in the May 21, 1989 edition of the Reading Eagle
times. A public meeting to discuss the Proposed Remedial Action .
Plan was also offered to area residents. However, requests for
such a meeting were never received.
III. Written Comments
Neither PADER nor EPA received written nor verbal comments
on either Proposed Remedial Action Plan for the Kimberton
Superfund Site.
-------
RESPONSIVENESS SLMMARY FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE KIMBERTCN SUPERFUND SITE
EAST PIKELAND TCWSHIP, CHESTER COUNTY
PENNSYLVANIA
Table of Contents
I. Introduction
II. Summary of Conrounity Relations Activities
III. Written Garments
Attachment I. Proposed Remedial Action Plan
for the Kimberton Superfund Site
-------
APPENDIX A
ANNALYTICAL DATA
-------
!.Ac.orw I \'aIM} lAI;( 0\12 \/n l..tEI !.AC,UO'U IIU IJMLJ lAIilM r, 4 \/(1 IILIII
IMSS ((UVH.fHJ ~ 'UJlVAUHf IMSS (UJIVAI EM lNOMJ IMSS H' IVAI tNl lAIn:Ju
SAMPlE LOCAflON tNXU.I I 1f'QUNDS. UOXJo4a CfOUNOS. &AaXWJ IfOUNOS, AnamiIIoll8l.,., 1NU:.N4 Cf'OUHOSt Anonwluua ...,.,
.. ..
2 8 , . 2a
'J 8 268 "8 308 .....
I J
018
70 o.ln .10 1.111 II " 0.0'. J J ..
..
a J j
"'1 .28 I
. J .18 S
I 8 RI II OJ8
. '.OIJI .. 0.41 a 1 ... aSen .
.. 0 i
II 0.041 ita r
.112 en_J !
..22!..c-i
. c....-4. ~c: ,:~
- ~ : .
:-t' -r-
Ia 0 ...
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= 'C! ,. I
. :aen~1
::GI .
- 0 ..
It 8 48 8 ~:J ~.
:..,a
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t2 1 ~
1
41 8 ,.1 130 I 3008 70 8 '9
110 I." 1100 '.Il .... 1.44 IJO 1 180.8 61 8
140J J4 J a:
170 J 40 J !
t8J
220 8 250 8
N) N)
,
',. ".1111.'.:
(''Y' ......uuII.. ......, bald taec- .18 ........ - ........ . . ......., .....
. WOf ".v.. ...... .. . ..... -.nil"'" ,
J ."...'* ..,"" .. . ......... .....
,~ Hoe .....,.8d ... . .. ......
1"-:':="""" C8IIpIUIId 8... filii clal8daci
~ i .
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,..
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.,
:100
:150
tG
tG
tG.
N)
APPROVED FOn
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QUALITY ASSUnAr~CE
fllvtl R fJ!:;g" k~- '1- J
t' 1.'
1-: " : ' r'. ~ r I.
~.~ c;- . ~ ~I
-------
RESPOOSIVENESS StJt.II1AAy FOR '!HE
PIDPaSED REMEDIAL ACTIOO PLAN
AT 'mE KIMBE:RIOO SUPERFUND SITE
,"
,CHESTER CXXJN1'Y, PENNSYLVANIA
JUNE 20, 1989
.-'
-------
APPENDIX B
RESPONSIVENESS SUMMARY
.
. -.
-------
TraHIC A8ccrt - 7191 7192 7193 719. 7197 7203
;Jle Identificano" travel blank A..' A.6 A.a A.17 ~UiDment RinSol
~ uQ/l(a UQ/l(a ~I(...!t Y~/l(a ua/l(Q ua/L
- volatil. compound.
,ne 10 B 3 B 6 B 18 B 8 B 21 B
. I:ano". 1 B :
'lor08tl'l8"'. 1 2 3 J 2;
dichloro.th.". (total) 6 J 3 J 3S
en. 2 J
.atil. TIC. ~ NO ~ ~ NO
-------
TABLE 5..
KIMBERTON. PA
SURFACE WATER ANAl YTleAl ResuLTS
~ I..ASORATORY
i SAMPLED 3/28-3/29 1988
.
MPLE 1 .1 -Dichloroethene Ju~lI.J tranS-1.2-0ichloroethene LUj3/1J TriChloroethene. (UQ/lJ.
I I
- 1 I 9 8
2 1 1 I 9
3 22 20
-5 31. 25
\ - 7 71 59
:'-9 280 270
~ -10 9 790 800
~ .11 27
.4, - 1 2 180 14
~ .14 120 . 8
~-'5 ..
~ -16
9-3
8-4
:.1 7
>2 9
: - 3 17
.-4
.;'5
81ank SDaces indicat8 the net W8I not deteCted.
A~PROVED FOR
RELEASe BY
QUALITY ASSURANCE
;~~~~;~ ;~;r-
[II, ".r
-------
6/4/86
SAMPLE
S1 « A-11
52* no equivalent
sample point
S3 . A-7 ...
S4 » A-3
S6 - A-2_ _.
S7 « A-1
P1 • C-2
S5 - A-9
1 2/6/S5
SAMPLE
S1 • A- 11
S2 • no eouivatont
sampto point
S-3 - A-7
S-4 . A-3
t
^CWSOrOtTECIED
•
TABLE 5*
CI8AGEIGY
KIM8ERTON. PA
SURFACE WATER ANALYTICAL RESULTS
trans- I.t2-Dicnloroethen* lug/I)
20
180
NO
.
20
BMDL
BMDL
.
BMDL
360
tran»-1,2-0ichloroethene (ug/l)
16
•
110
25
21
•
BMDL-BELOW MEAN DETECTION LIMIT
LANCASTER LABORATORY!
•
Triehloroeth«n« fua/D
BMDL
•
150
ND
10
BMOL
BMDL
30
320
Trtchloro«then« (ugyi)
3
1 10
25
25
1,1-Dicnloroethene (ua/i)
ND
i*
ND
ND
ND
ND
ND
ND
BMDL
1,1-Dichloroethene (uo/n
ND
1
ND
ND
,
-------
TABLE .2
SAMPLES SPUT WITH NUS
SUPPLSMENrAL LAGOON SAMPUNG
KIMBERTON. PA
SAMPLE INTERVAL DEPTH (FEET)
30lL BORING tAGOC::N 1 ~2 tAGOC::N 3 ~4 LAGOCN 8 AREA S
-
A 2~'6--- 2.6 6-10 0-4
6-8 6-10 12-16 4-8
16-20
B 6-10 6-10 6-12 0-4
1 0-14 1 0-12 12-16 , 4-10
C 2-6 4-8 4-6 4-8 0-4
6-10 8-12 8-12 4-8
0 2-6 4-8 4-8 0-4
8-10 12-16 4-10
E 0-4 0-4 0-4 0-4
4-8 4-8 6-10 4-12
8-10 12-16
r ,.. ,..: " ~ t)
\:;".-J ~ .J ...,
. n..
. --t ..
- :_-=-:{f:. 1.'1/
": --'I " I
-------
/
....l--. l8guOft .. L..- 82 a...-" hunonU L8e- N l~N L8QOGA " . ~oon ., AleA :., hII... . I Rin.. 12 (quI'''.''' 1iIn..
i Ano.......u. t ... Ano"..tou. la... A.............. t '." J ,.
'01.111. IIC. fa .. N) ,. N) ,. ~ N) N) N)
i,'hlDl",,- 1'0".' II .... I
....,.1.108 IIC. I ,
>! ....-.. III' U... 110. ,... 12.. UIO .0... 7850 . 1800 II In 11
-' ....iII... lIr4tocMloa. ..... .... ." 110. "'0 '1820 40 110 7
'01.111......... 110'
"... .''''08 ,ph'lI ,ltPhellol1 I"
~"." "'11,..,,,, 1III...tbltp".oI . ....
2'_'1108" "_lh.I"h08.1'~'D'_',,, I
rea'" 7
'........... ... U
1~'OC''''8C'dl8''I'oI 'I 2.
'~"II8c... ,.01 II
~... .
,"8I'8IIec.c8an8
~krc:loIIeo- ..- 110
1"=-""'" Uoo 10
[.~..... .800
iiI'''''''II,IIIeIl'''', 110
I "'...... .......,... h- 110
!:''i'' ............ h- 110
~........ .
t~.oIl/'" .
... ,
'~.... "'* ,
,
~.
[.... .,... ............ .... lie ........... ............
" .....,.... .. .. .. ......
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APPROVED r:OB
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/n~~ =:
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-"'. J..
'GI c-
~ ~ I II : J ~
~.! I ..;;..
:: J C
31
r
II
-------
tAra..., I \I\: u...~ AIIfA 5 VOIIIUCl
IMSS E<..vAl. EM tNr.Q\ll IMSS [UfVAI. fNf
SA""', lOCA noN ...... CfOUNOSt Anomalou. u,. AREA. .fOUNDSt. RINSE I RINSE J E......-... RInM
..18..11 c."p.""" M
meII.,1Me cNulldi 0.:1,
..... aal 8' J ,
1'.dlchlo.oell\'l18 10111
c:hIe.oI...
..kNo'MlIIene 1 '.0021 J J I J
.'_111 I.'. .nlanon. ~
dl 1.,.dIc:IIIoI..... ==
.
--- U J 0.1 J ~
.8IIadllDf ..
.
........ 8. I. 0.. J 01 J J J S
cHlNabont- 0.. J
""1I8nl1/ll .
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. Ie 0.1 J iXD ....
. ~.
...1....... c_;-.. '" :I ..
.5!~-
-------
APPrnDIX D
STATE I.Er1'ER OF OONCtJRRENCE
-------
"Pranu^ti0n of sites
-—--"-anaum to Tcaei~ t, *~"
-------
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
Deputy Secretary for
Environmental Protection
June 29, 1989
717-787-5028
Mr. Edwin B. Erickson
Regional Administrator
USEPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
Kimberton Superfund Site, draft Record Of Decision (ROD)"
I
Dear Mr. Erickson:
The draft Record of Decision (as received June 23,
1989) for the Kimberton Superfund site, groundwater operable
unit, has been reviewed by the Department. It is my
understanding that this Record of Decision will be submitted
to you for your approval.
The proposed remedy for the groundwater operable unit
would consist of pumping the contaminated groundwater, treating
by air stripping, and discharging the water to a small stream.
An on-going assessment of the pump and treat remedy would allow
for modifications to the pump and treat project.
I hereby concur with the EPA's proposed remedy, with
the following conditions:
* EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DER design specific
ARARs.
* The Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
* The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state and federal law.
-------
-* Thfm-concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section 104(c)(3).
Thank you for 'the opportunity to concur with this EPA
draft Record Of Decision. If you have any questions regarding
this matter please do not hesitate to contact me.
Sincerely,
irk Jf7 MCClellan
Deputy Secretary
------- |