PB94-963919
                                  EPA/ROD/R03-94/182
                                  October 1994  ccpy 2
EPA  Superfund
       Record of Decision:
        Stanley Kessler Superfund Site,
        King of Prussia, PA,
       -9/29/94

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                        RECORD OF DECISION
                  STANLEY KESSLER SUPERFDND SITE
                            DECLARATION
 SITE NAME AND  LOCATION

 Stanley Kessler  Superfund  Site
 Upper Merion Township, Montgomery County, Pennsylvania


 STATEMENT OF BASIS AND PURPOSE

 This decision  document presents the final selected remedial
 action for the Stanley Kessler Superfund Site  ("the Site").  The
 remedial action  was selected in accordance with the Comprehensive
 Environmental  Response, Compensation, and Liability Act of 1980
 ("CERCLA"), as amended by  the Superfund Amendments and
 Reauthorization  Act of 1986 ("SARA") and the National Oil and
 Hazardous Substances Pollution Contingency Plan ("NCP").  This
 decision is based on the Administrative Record for this Site.

 The Commonwealth of Pennsylvania has concurred on this remedy.


 ASSESSMENT OF  THE SITE

 Pursuant to duly delegated authority, I hereby determine
 pursuant to Section 106 of CERCLA, 42 U.S.C. §9606, that actual
 or threatened  releases of  hazardous substances from this Site,
 if not addressed by implementing the response action selected
 in this Record of Decision ("ROD"), may present an imminent and
 substantial endangerment to the public health, welfare, or the
 environment.
DESCRIPTION OF THE SELECTED REMEDY

The selected remedy for the Site will restore contaminated ground
water to its beneficial use by cleaning up the ground water to
background levels as established by EPA or to the appropriate
Maximum Contaminant Levels ("MCLs") or non-zero Maximum
Contaminant Level Goals ("MCLGs") established under the Federal
Safe Drinking Water Act ("SDWA") whichever is more stringent.
The selected remedy as described below is the only planned action
for the Site.

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 The selected remedy  includes the following major components:

 •     Ground  water  extraction to remove contaminated ground water
      from  beneath  the Site and to prevent contaminants from
      migrating  further

 •     Installation, operation, and maintenance of granular
      activated  carbon units to treat ground water to the
      required levels

 •     Periodic sampling of ground water and treated water to
      ensure  that treatment components are effective and ground
      water remediation is progressing towards the required
      cleanup levels

 •     Deed  Restrictions to prohibit the installation of new
      wells in areas of contamination which do not meet applicable
      or relevant and appropriate requirements ("ARARs").  These
      restrictions  can be withdrawn when ARARs are achieved.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment and is cost-effective.  EPA believes that the
selected remedy will comply with all Federal and State
requirements that are legally applicable or relevant and
appropriate to the remedial action.  The selected remedy
utilizes a permanent solution to the maximum extent practicable
and satisfies the statutory preference for a remedy that employs
treatment that reduces toxicity, mobility, or volume.
Implementation of the selected remedy will not involve extensive
construction, excavation, or other remedial action measures that
would pose any appreciable short-term risks to the public or to
the workers during construction or implementation.

Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review by EPA will be
conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
      H.^bstmayer                       Date
 iegional Administrator
Region III

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                           EPA REGION 3
                           SEPTEMBER, 1994
     RECORD OF DECISION
     STANLEY KESSLER SITE
KING OF PRUSSIA,  PENNSYLVANIA

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                        RECORD OF DECISION

                 STANLEY KESSLER SUPERFUND  SITE

                        TABLE OF CONTENTS




I.        SITE NAME, LOCATION AND DESCRIPTION	1

II.       SITE HISTORY AND ENFORCEMENT ACTIVITIES	1

III.      HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 3

IV.       SCOPE AND ROLE OF THE ACTION	4

V.        SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
          CONTAMINATION 	 5

VI.       SUMMARY OF SITE RISKS	10

VII.      DESCRIPTION OF ALTERNATIVES	14

VIII.     SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . .  . 19

IX.       THE SELECTED REMEDY	24

X.        STATUTORY DETERMINATIONS	29

          APPENDIX A     FIGURES

          APPENDIX B     TABLES

          APPENDIX C     RESPONSIVENESS SUMMARY

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                        RECORD OF DECISION
                     STANLEY KESSLER SDPERFDND

                         DECISION SUMMARY

 I.    SITE NAME,  LOCATION,  AND DESCRIPTION

      The  Stanley Kessler Site (the  "Site")  is  located at  103
 Queens  Drive, King  of Prussia, Upper Merion Township,  Montgomery
 County, Pennsylvania.   The Stanley  Kessler  Company  operates a
 business  at the  Site on a  3.21 acre parcel  within an  industri-
 lized area of King  of Prussia.  The property contains an
 approximate 14,760  square  foot one  story  masonry building where
 wire  is degreased and respooled.   (Figure 1, Site Location Map)

      Local physiography is characterized  by low rolling hills and
 ridges  of the Chester Valley,  a subdivision of the  Piedmont
 uplands,  which generally trend in an east-west direction.  The
 Chester Valley contains tightly folded carbonate rocks of
 Cambrian  and Ordovician age.   Sinkholes are commonly  associated
 with  the  weathering characteristics of the  limestone  and  dolomite
 bedrock and have been reported present in the vicinity of the
 Site.

      The  Schuylkill River,  which flows to the east  and south
 through this portion of the valley  is located, at its closest
 point,  approximately two (2)  miles  to the east of the site and is
 the principal regional drainage feature.  A portion of an unnamed
 tributary of the Schuylkill River flows adjacent to portions of
 the Site.

      The  current source of drinking water for the businesses and
 homes in  the Site vicinity is the Upper Merion Reservoir  ("UMR"),
 which lies approximately 3500  feet  north  of the Site.  Hazardous
 substances released to the ground water at  and from the Site flow
 towards the UMR.

 II.   SITE HISTORY  AND ENFORCEMENT  ACTIVITY

      Materials are  stored  on  a level paved  area south  of  the
 building  onsite.  This paved  area is enclosed by an eight-foot
 high  chain-link  fence.  The Stanley Kessler and Company,  Inc.
 ("Kessler") conducts operations at  the Site which consist of
 degreasing and repackaging welding  wire.  There are no
 manufacturing operations at the facility.   Since approximately
 1963, solvents have  been used  for degreasing at the Site; prior
 to 1963,  acids and  bases were used  for cleaning metals.   During
 the period when  acids  were used, splashed acid, or  drag-out, from
 the acid-dip degreasers was washed  down a series of floor drains
 inside the building to an  onsite acid waste neutralization
 system.   This neutralization  system consisted of two tanks which
have historically been referred to  as the septic tank  ("Tank 1")
 and cesspool ("Tank  2").   Tank 1 consisted  of a concrete vessel,

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 containing crushed limestone to neutralize  the  acid, with a
 baffled overflow to Tank  2. Tank 2 was a  cinder block vessel
 which had no structural bottom and was open to  native soils.
 Tank 2 was the  most northerly of the two  tanks  that constituted
 the  waste neutralization  system.

      In April 1979,  trichloroethene  ("TCE"),  1,2,3-
 trichloropropane,  tetrachloroethene  ("PCE")  and other volatile
 organic compounds ("VOCs") were detected  in the Upper Merion
 Reservoir ("UMR").   The UMR was formerly  a  dolomite quarry, known
 as the Bridgeport Quarry, and has served  as a public water supply
 source operated by the Philadelphia Suburban Water Company since
 1969.   The reported presence of VOCs in the UMR prompted an area-
 wide investigation by FADER and the USEPA to identify potential
 sources of ground water contamination.

      In July, 1979 the Pennsylvania Department  of Environemntal
 Resources ("PADER")  and USEPA personnel sampled Tank 2, the
 "cesspool",  at  the site.  While onsite, approximately 30 drums,
 stored in an asphalt paved area adjacent  to the east side of the
 building,  were  observed by USEPA and PADER.   More than 20 drums
 reportedly contained water that was contaminated with trace
 amounts of solvents; some of the drums reportedly contained spent
 solvent,  and some were empty.

      In correspondence dated September 7, 1979,  Kessler was
 notified by the PADER that the company was  in violation of the
 Pennsylvania Clean Streams Law because TCE  and  other organic
 compounds had been detected in the cesspool water sample
 collected by USEPA/PADER.  At that time,  Kessler was directed by
 PADER  to install monitoring wells to define the extent of ground
 water  contamination, develop a recovery plan, eliminate all
 sources of ground water pollution, and prepare  a Pollution
 Incident Prevention  Plan for the facility.   Five monitoring wells
 were installed  and sampled.  The analyses results indicated the
 presence of  several  organic contaminants  in the ground water.

     In 1981 the septic tank and cesspool were  excavated.
 Grossly discolored,  blue-green soils with a strong chemical odor
 were encountered beneath both the septic  tank and cesspool.  As
 the  excavation  progressed, soil samples were  collected by EPA.
 Organic analyses of  these soils showed that many volatile organic
 contaminants were present.  The strongest concentration of
 contaminants was determined to be under the cesspool, where the
 soil contained  1,700 parts per million ("ppm")  of 1,1,1-
 trichloroethane ("TCA"), 910 ppm of TCE,  460  ppm of toluene, and
 52 ppm of  PCE.   The  depth of the excavation was  about 15 feet.
 In all,  approximately 60 tons of soil were  removed and
 transported  offsite  for disposal.  The excavated area was filled
with rocks and  soil.  Three vent pipes were installed,
penetrating  to  a depth of about 12 feet.

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      The USEPA finalized the  listing of the Site on the CERCLA
National Priorities  List ("NPL")  in December 1982  (47 Fed. Reg.
58484)  (December 30,  1982).

      In 1984,  Kessler installed an onsite ground water air
stripping treatment  system in response to a federal court order
issued  in March 1984.    To create its ground water extraction and
treatment system,  Kessler converted an existing monitoring well
located near the site of the  excavated septic tank into a
recovery well,  RW-1.   In June 1984 the recovery well began
pumping ground water at  the rate  of 5 gallons per minute ("gpm").
The pumped-out ground water was treated in an air stripper.
Treated water  was  then re-introduced to the subsurface through a
discharge point,  or  "infiltration gallery", located where the
septic  tank and cesspool had  been, in order to flush contaminants
from  the soil.   Subsurface water  levels could be monitored
through the three  vent  pipes.  Ground water and the treatment
system  were monitored monthly for TCE and PCE only.  In 1984
samples collected  from RW-1 at a  depth of 90 - 100 feet below
ground  revealed concentrations up to 16,000 parts per billion
("ppb") of TCE.  The ground water treatment and soil flushing
program was discontinued in September 1990 in order to conduct
the remedial investigation.   The  sampling conducted during the
remedial investigation (1992) detected 600 ppb of TCE at RW-1 and
130 ppb TCE in monitoring well, HW-6.  The data generated during
this  ground water  withdrawal  and  soil flushing program indicate
that  pumping the ground  water reduced the contaminant
concentrations  in  the  ground  water.  Despite the ground water
remediation that was  conducted from 1984 to 1990, contaminant
concentrations  at  RW-1 and at monitoring wells downgradient of
the former septic  tank and cesspool area, are still significantly
higher  than drinking water quality standards and represent a
threat  to the  Class  IIA  aquifer,  which is affected by releases
from  this Site.

On July 5, 1994, EPA  sent notice  of the impending remedial
design/remedial action ("RD/RA")  negotiations to the Department
of Interior ("DOI") and  the National Oceanic and Atmospheric
Administration.  EPA  sent a notice of the Proposed Remedial
Action  Plan to  the Delaware River Basin Commission on August 5,
1994.
III.   HIGHLIGHTS OF COMMUNITY PARTICIPATION

     The RI/FS report and the Proposed Plan for the Site were
released to the public on June 20, 1994, in accordance with
Sections 113 (k) (2) (B), H7(a), and 121(f)(l)(G) of CERCLA, 42
U.S.C.  §§9613(k)(2)(B), 9617(a), and 9621(f)(1)(G).  These and
other related documents were made available in the Administrative
Record located at the U.S. EPA  Region III Office, 841 Chestnut
Building, Philadelphia, Pennsylvania, 19107; and at the Site

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 Repository,  Upper Merion Township Library,  175 West Valley Forge
 Road,  King of Prussia,  Pennsylvania,  19406.

     A public meeting was held  on June  30,  1994  to discuss the
 results of the RI/FS  and the preferred  alternative as  presented
 in  the Proposed Plan  for the Site.  Notice  of the Proposed Plan
 and public meeting was  published in the Montgomery County
 Neighbors  Section of  The Philadelphia Inquirer on June 16th and
 June 23rd.   Due to a  request for an extension, the comment period
 was extended to 60 days, closing on August  18, 1994.   EPA
 notified the public of  the 30-day extension to the public  comment
 period by  placing a display advertisement in The Philadelphia
 Inquirer on June 30,  1994.

     In accordance with 40 C.F.R. § 300.430 (f) (3)(F),  all
 comments which were received by EPA prior to the end of the
 comment period,  including those expressed verbally at  the  public
 meeting were considered and are addressed in the Responsiveness
 Summary which is part of this ROD.


 IV.    SCOPE AND ROLE  OF THE RESPONSE ACTION WITH SITE  STRATEGY

     The National Contingency Plan ("NCP")  (40 C.F.R.  § 300.430
 (a)(l)(i))  states that  the general goal of  the remedy  selection
 process is  to select  remedies that: are 1)  protective  of human
 health and  the environment; 2)  maintain protection over time; and
 3) minimize  untreated waste.  In addition,  Section 121 of  CERCLA,
 42 U.S.C. §  9621,  includes general goals for remedial  actions at
 all  Superfund sites.  The goals include: achieving a degree of  ,
 cleanup which assures protection of human health and the
 environment  (Section  121(d)(l)); selecting  cost  effective
 remedies (Sections 121(a)  and 121 (b)(l));  preference  for
 selecting remedial actions in which treatment that permanently
 and  significantly reduces the volume, toxicity,  or mobility of
 contaminants is  a principal element (Section 121(b));  and
 requiring that the selected remedy complies with or attains the
 level  of any applicable or relevant and appropriate requirements
 ("ARARs") of federal  or State environmental laws (Section
 121 (d) (2) (A)).   The remedy selected in this ROD  is pumping and
 treating of  the  contaminated ground water emanating from the
 Site.   This  ROD  is the  only planned response action for the Site.

     This ROD requires  remediation of the ground water aquifer
 which  has been contaminated by  releases of hazardous substances
 at and from  the  Site.   EPA has  classified the affected aquifer at
 the  Stanley  Kessler Site as a Class IIA aquifer,  a current source
 of drinking  water, in accordance with the EPA document
 "Guidelines  for  Ground  Water Classification" (Final Draft,
 December 1986).   The  concentrations of contaminants in the ground
water  at the Site are above Maximum Contaminant  Levels ("MCLs")
which  are enforceable,  health-based drinking water standards

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 established under  the  Safe Drinking Water Act  ("SDWA"),  42  U.S.C.
 §§  300f  to 300J-26.  MCLs are enforceable standards  set  for
 public water  supply  systems and are ARARs for  the ground water at
 the Site which  is  a  current source of drinking water.  EPA  ground
 water policy, as described in the document entitled  "Guidance on
 Remedial Actions for Contaminated Groundwater  at Superfund
 Sites,"  require active restoration of ground water that  is  a
 current  or potential source of drinking water  through pumping and
 treatment.

     The objectives  of the selected response action  are  to  1)
 restore  contaminated ground water to background concentrations,
 2)  prevent current or  future exposure to contaminated ground
 water, and 3) protect  uncontaminated ground water for current and
 future use.   Pumping and treating ground water is the most
 expeditious way to reduce the contaminant levels that have  been
 detected and  inhibit further migration of the  contaminant plume.


 V.   SUMMARY OF  SITE  CHARACTERISTICS AND EXTENT OF CONTAMINATION

 A.   SITE CHARACTERISTICS

 1.    Geology

     Local physiography is characterized by low rolling  hills and
 ridges of the Chester  Valley, a subdivision of the Piedmont
 Uplands  Section of the Piedmont Physiographic  Province,  which
 generally trends in  an east-west direction.  The Chester Valley
 contains tightly folded carbonate rocks of Cambrian  and
 Ordovician age.  Sinkholes are commonly associated with  the
 weathering characteristics of the limestone and dolomite bedrock
 and have been reported present in the vicinity of the Site.

     Geology of the  Piedmont Upland Section in the study area is
 characterized by Precambrian to early Paleozoic crystalline
metamorphic rocks  (including schists and gneisses of the
Wissahickon Formation)  and sedimentary rocks (Cambro-Ordovician
 carbonates)  which have undergone partial low-grade metamorphism.
The Cambro-Ordovician  carbonate sequence dominates the geology
and hydrogeology at, and in the immediate vicinity of, the  Site.
This sequence of carbonate rocks consists of three distinct
geologic formations which are,  from oldest to youngest,  the
Ledger (dolomite),  Elbrook (limestone),  and Conestoga
 (limestone).   The bedding strike of this carbonate sequence is
reported as N80E in the vicinity of the Site with bedding dip at
50-55 degrees to the south-southeast.

     The Site is underlain by the Conestoga Formation which
consists of blue to gray,  granular,  thin-bedded,  micaceous
limestone,  a middle dark graphitic member and basal beds that are
conglomeratic containing pebbles and masses of marble in a

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 limestone matrix.   Underlying the  Conestoga Formation and mapped
 as  subcropping  to  the  north of the Site  is the Elbrook Formation.
 The Elbrook  Formation  is  described as a  thinly-bedded, light to
 light blue limestone.  There are some beds of finely laminated,
 fine-grained marble as well.  The  Ledger Formation underlies the
 Elbrook  Formation  and  is  mapped as subcropping immediately north
 of  the Elbrook  Formation.  The Ledger Formation mainly consists
 of  a light gray to white  dolomite  that is often massive.  A
 reservoir used  as  a major source of supply of drinking water for
 the Philadelphia Suburban Water Company  known as the Upper Merion
 Reservoir (aka  Bridgeport Quarry)  is located approximately 3500
 feet north of the  Site and within  the Ledger Dolomite (see Figure
 1).

     There have been several investigations in which measurements
 of  linear structural features from quarry walls and rock outcrops
 in  the Site  vicinity were collected and  analyzed to identify the
 average  trend and  dip  of  joint sets.  The reported strike and dip
 of  the joints measured in the Site vicinity are N16-30E with a
 dip of 70-90 degrees NW,  N60W with a dip of 35-40 degrees NE, and
 N84W with a  dip of 55  degrees SW.

     A fracture trace  analysis was performed through stereoscopic
 inspection of aerial photographs by the  United States Geological
 Survey (USGS) in 1982.  Many lineaments  and fracture traces were
 mapped in the vicinity of the Upper Merion Reservoir.  The trend
 of  the mapped lineaments  and fractures correspond to the reported
 measured trend  of  the  joints in the study area.  These
 interpreted  lineaments are well developed and extend across the
 different contacts of  the three carbonate formations at angles to
 the  reported bedding trend.

     The Site geology, based on monitoring well data, consists of
 saprolite and underlying  limestone bedrock.  Saprolite is the
 chemically weathered product of bedrock  and ranges in thickness
 from 30  to 70 feet.  The  saprolite consists of brown, orange-
 brown, and olive green sandy silts, clayey silts, and silty clays
with phyllite and  limestone fragments.  A larger amount of
phyllite and limestone fragments are encountered with depth.
 Competent bedrock  is described as  blue-gray and brown, thickly
bedded limestone which is consistent with the description of the
 Conestoga Limestone  Formation.

Hydrogeology

     The aquifer underlying the Site is  a carbonate aquifer and
regionally encompasses the Ledger,  Elbrook, and Conestoga
Formations.   As is the case for all carbonate aquifers,  ground
water flows  through  secondary porosity features such as joints,
fractures,  and bedding planes which are enlarged through
solutioning.   Consequently, ground water flow will be influenced
by the structural  orientation and  interconnectivity of fractures

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 and joints.   During a USGS study of  the Valley Creek Basin  in
 Chester Valley,  five active quarries were  inspected which
 revealed that most of the solution openings  were horizontally
 enhanced vertical fractures whose width was  less than one foot.

      This carbonate aquifer has  been described as anisotropic
 with a principal axis of highest transmissivity trending east-
 northeast.   A pump test at the Henderson Road  NPL site, which is
 located approximately 1000 feet  north of the Stanley Kessler
 site,  demonstrated the trend of  the  principal  axis of
 transmissivity at about N60E.  Water level data also indicate an
 elongate cone of depression surrounding the  UMR in an east-
 northeast direction.   The pump test  at the Stanley Kessler Site
 also revealed an elliptical cone of  depression oriented in an
 east-northeast direction.   However,  although ground water flows
 more readily along this axis of  higher transmissivity under
 natural conditions,  the extreme  amount of withdrawal of water
 from the UMR in  conjunction with the existence of almost north-
 south and northwest-southeast trending joints  and fractures,
 causes ground water to migrate toward the UMR  to the north.

      Aquifer properties were determined from an aquifer test
 performed during the Remedial Investigation.   The estimated
 average transmissivity was calculated as 13000 gpd/ft.  Given
 that the aquifer test occurred within the top  100 feet of the
 saturated aquifer,  the hydraulic conductivity  was evaluated as
 130  gpd/ft or 6.13  E-3 cm/sec.   The  hydraulic  gradient was based
 on water elevation data collected during the RI and was
 calculated to be 0.05 ft/ft to the north-northwest.  The
 effective porosity most likely ranges from 0.01 to 0.05.
 Therefore, the estimated average linear velocity would range from
 17 ft/day to 87  ft/day.

      Due to  the  large amount of  withdrawal (approximately seven
 million gallons  per day ("mgd")  from the Upper Merion Reservoir
 3500  feet north  of  the Site), the water table  has been lowered
 significantly and a  large  cone of depression has been identified
 based  on ground  water elevation  data.   This  cone of depression
 extends beneath  the  Stanley Kessler  Site and strongly influences
 the  direction of ground water flow.  (See Figure 2)


 B. Nature And Extent  Of Contamination

     Environmental media were analyzed for volatile organic
 compounds, semi-volatile organic  compounds,  pesticides/PCBs and
metals  as summarized  in Table 1.   Soil,  surface water and
 sediment  sampling locations are depicted in  Figure 3.   Ground
water  sampling locations are depicted in Figure 4. Additionally,
 select  soil  samples were analyzed for Total  Organic Carbon
 ("TOC"),  grain size distribution,  permeability,  in situ soil
moisture, and density;  surface water samples were analyzed in

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                                                                8

 situ for Ph,  temperature,  Eh, dissolved oxygen, and specific
 conductivity; and sediment samples were analyzed for grain size
 distribution  and TOC.  Various water quality parameters were also
 measured in situ which included pH, temperatures, Eh, dissolved
 oxygen  and specific conductivity.

      Figure 5,  the Conceptual Site Model, shows the mechanisms of
 contaminant release and potential transport mechanisms.  The
 primary source of Site contamination was the disposal of waste
 solvents at the Site that  were released into the ground water.
 As a result of the releases ground water has been contaminated
 significantly above Maximum Contaminant Levels.

 l. Soils

      A  total  of ninety-three soil gas samples were collected in
 the  areas of  the septic tank and cesspool and the former drum
 storage areas during the soil gas survey.  TCE was the most
 frequently identified volatile chemical found in the soil gas
 samples.  TCE  was detected  in nearly all the soil gas samples from
 the  septic tank and cesspool area, and was also detected in the
 former  drum storage areas.  PCE and 1,1,1-TCA were identified to
 a lesser extent and vinyl  chloride was randomly detected in 6 of
 93 samples.

      A  total  of eleven soil borings were installed during the
 subsurface soil investigation.  Samples were collected on three
 foot intervals  until no VOCs were detected using the portable gas
 chromatograph ("GC") in the two former drum storage areas (six
 borings total,  three from  each area) and on five foot intervals
 to bedrock in the waste neutralization area (five borings total).
 Site surface  soil analytical data generally indicates nondectable
 concentrations,  concentrations slightly above detection levels,
 and  concentrations similar to the background sample for SVOCs,
 pesticides/PCBs,  and inorganic metals.  The highest concentration
 of site related volatiles  (30 ppb TCE and 16 ppb 1,1,1-TCA)  were
 detected in the southwest  former drum storage area.  These
 samples were  collected below an asphalt cover at a depth of 3-5
 feet.   Acetone  was detected in three soil boring samples above
 the  PADER cleanup standard of 30 ppb at 5-7 feet (64 ppb), 13-15
 feet (89  ppb) and at 15-19  feet (60 ppb)  in soil boring 131 in
 the  east former drum storage area.  Tables 2 through 5 summarize
 the  results of  the soil investigation.   Tables 6 and 7 are a
 comparison of the reported  concentrations of the inorganics
 detected in the surface soil and subsurface soil samples with
 background values for the  inorganics in soil.   Beryllium was
 detected above  the PADER cleanup guidance of 1 ppm in the
 following three soil samples SB-202-1112 at 3.1 ppm, SB-203-1113
 at 3.7  ppm and  at SB-204-1114 at 3.4 ppm at depths ranging from
 34-54 feet in the former waste neutralization area.  EPA does not
 believe the acetone or beryllium represent a threat to ground
water because acetone was not detected in the monitoring well

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which  is downgradient of this soil boring location.  Beryllium
was not detected  in the filtered ground water samples which were
collected  in the  former waste neutralization area.

2. Surface Water  and Sediment

     A total of five surface water samples and four sediment
samples were collected in the intermittent stream and one of its
tributaries.  The low levels of semivolatiles, pesticides/PCBs,
and metals that were detected were similar to background
concentrations.   Tables 8 through 12 summarize the results of the
surface sampling  and Tables 13 through 16 summarize the results
of the sediment sampling.

3. Ground  Water

     TCE and 1,1,1-TCA were detected in all ground water samples
at concentrations from 8.4 ppb at MW-3 to 600 ppb at RW-1 for
TCE, and 1.4 ppb  at MW-3 to 340 ppb at RW-1 for 1,1,1-TCA.  The
highest TCE hit was at the 149'-160' below ground interval at RW-
1, and for 1,1,1-TCA at the 126'-138' interval at RW-1.  Toluene
was detected in only RW-1 during the depth discrete sampling
ranging in concentration from .5 ppb to 46 ppb. The highest hit
for toluene was detected at the 126'-138' interval.  Tables 17,
18, and 19 summarize the results for volatile organics, total
metals and dissolved metals.  Table 20 summarizes the results of
the depth  discrete sampling of RW-1.  At least five of the Site-
related contaminants detected in the Class IIA aquifer exceed
MCLs.  The contaminants and their respective MCLs are summarized
in the table below.

     Concentrations of total metals in unfiltered ground water
samples have at times exceeded MCLs, and Drinking Water
Equivalent Levels for silver, barium, beryllium, cadmium, sodium,
lead, and antimony.  The dissolved metals concentrations were
below these standards.   Filtered samples represent dissolved
metals concentration and are often more representative of mobile
contamination.   Monitoring wells sometimes produce turbid water
(water containing solids).   The turbidity can be due to
disruption of the adjacent geologic formations during well
purging.   When particles containing metal species are suspended
into the ground water and are not removed,  they dissolve when the
sample is preserved to a pH<2.   Only the filtered ground water
sampling results were used in the Risk Assessment.

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                                                               10
Summary of Organic Groundwater Sampling Results
at the Stanley Kessler Site
Chemical
yf^yiimnn
Concentration
Observed
(PPb)
SDWA
MCL
(PPb)
Monitoring
Well
Observed*
VOLATILE ORGANIC COMPOUNDS
Benzene
Chlorobenzene
Chloroform
Cis-1,2-
Dichloroethylene
Dichloromethane
1 , 2-Dichloroethane
1 , 1-Dichloroethene
Tetrachloroethene
1,1,2, -Tr ichloroethane
1,1, 1-Tr ichloroethane
Trichloroethene
Toluene
7.3
2.1
<0.5
4.6
<0.5
1.4
37
7.3
0.8
340
600
46
5.0
100
100
70
5.0
5.0
7.0
5.0
5.0
200
5.0
1000
MW-5A
MW-5A
MW-8
RW-1
MW-6
RW-1
RW-1
RW-1
RW-1
RW-1
RW-1
RW-1
*Indicates where the highest contaminant concentrations were
detected.

VI.  SUMMARY OF SITE RISKS

     An assessment of the potential risks posed to human health
and the environment was completed in accordance with the NCP [40
C.F.R. 300.430(d)].  This section of the ROD discusses the
results of the human health and ecological baseline risk
assessment.  The results of the baseline risk assessments provide
justification for performing the remedial action and assist in
determining what exposure pathways need to be remediated.

A. ENVIRONMENTAL RISKS

EPA has classified the affected aquifer at the Stanley Kessler
Site as a Class IIA aquifer, a current source of drinking water,
in accordance with the EPA document "Guidelines for Ground Water
Classification" (Final Draft, December 1986).  The concentrations

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                                                                11

 of  contaminants in  the ground water at the Site are above Maximum
 Contaminant levels  ("MCLs") which are enforceable, health-based
 drinking water standards established under the Safe Drinking
 Water Act  ("SDWA"),  42 U.S.C.   §§ 300f to 300J-26.  MCLs are
 enforceable standards set  for public water supply systems and  are
 relevant and appropriate for the ground water at the Site which
 is  a  current source of drinking water.  EPA ground water policy,
 as  described in the document entitled "Guidance on Remedial
 Actions for Contaminated Groundwater at Superfund Sites," require
 active restoration  of ground water that is a current or potential
 source of  drinking  water through pumping and treatment.  The
 affected aquifer is a current source of drinking water which has
 been  contaminated above acceptable drinking water standards.
 Therefore  the environment  has been adversely affected due to
 releases from the Site.

      No known threatened or endangered plant or animal species
 have  been  identified in the immediate vicinity of the Site.
 Based on the industrial use of  the Site and surrounding area,  the
 presence of an extensive terrestrial community is unlikely.
 Terrestrial organisms that could inhabit the Site are birds and
 small wildlife.   Most of the facility property is paved; and the
 unpaved areas are primarily covered with grass or vegetation.

      The potential  for areas immediately surrounding the Site  to
 support a  large wildlife population or a diverse community of
 terrestrial and aquatic life is low.  The land use is mainly
 industrial,  and there is substantial vehicular traffic on roads
 in  the area.   In addition, the  surrounding area is an urban,
 well-populated area.

 B.  HUMAN  HEALTH RISK EVALUATION

      The potential human health risks posed by a Superfund Site
 if  no remedial action is taken are calculated in a baseline risk
 assessment.   In general, a site poses a potential human health
 risk  if 1)  the contaminants at the site may cause cancer or some
 other health  effect  at existing levels,  2) there is a route or
 pathway through which a receptor may be exposed,  e.g., ingestion
 of  contaminated soil, and 3)  there is a receptor which can be
 exposed, e.g.,  a child ingesting soil.   In a baseline human
health risk assessment,  the contaminants are evaluated, the
exposure routes  are  characterized and the receptors are
 identified.

     As described in detail below,  the consumption of ground
water at the  Site would result in unacceptable risk to human
health.  Currently,  there are no wells providing ground water  at
the Site,  but  the aquifer is a natural resource which could be
used  in the future.   Additionally,  the contaminated ground water
from the Site  flows to the UMR.

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                                                                12

 Exposure Assessment

     The exposure assessment identified potential  exposure
 pathways.  Five exposure scenarios were examined under current
 and future use assumptions.  Exposure of receptors to chemicals
 in potentially impacted media  (surface soil, ground water, and
 air) were examined under Reasonable Maximum Exposure  ("RME")
 assumptions.

     Current surface land use  in the vicinity of the Site is
 zoned limited industrial/light manufacturing.  Industrial
 facilities are located directly to the northeast,  southwest, and
 west of the Site.  The nearest residential dwelling is
 approximately 1500 feet northeast of the Site and  the nearest
 school is 0.5 miles south of the Site.  Residential developments
 are located within one mile of the Site and include Henderson
 Park, Gulph Mills Village, Kingswood Apartment, and Hughes Park.


     Future use of the Site is assumed to be residential, which
 includes domestic use of onsite ground water, for  risk assessment
 purposes.  Ground water beneath the Site is classified as a Class
 IIA aquifer, a current source of drinking water.

     The Site and surrounding areas fall within the Philadelphia
 Suburban Water Company ("PSWCo") franchise area which supplies
 potable water to its customers.  According to the  Montgomery
 County Planning Commission water supply distribution mains for
 Montgomery County indicate that all surrounding properties are
 serviced by PSWCo or another water company.  However, use of an
 exposure scenario based on future residential use  is consistent
 with EPA Risk Assessment Guidance which requires consideration of
 hypothetical residential use.  Moreover, EPA requires that ground
 water which is suitable for use as a water supply  be protected
 and restored to its beneficial use.

     Potential exposure pathways considered for the purpose of
 evaluating Site risks included: ingestion, dermal  contact and
 vapor inhalation of contaminated ground water; inhalation of
 volatiles and particulates in air; and ingestion and dermal
 contact with surface soil.  The potential exposure pathways for
 current and future land use scenarios are presented in Tables 21
 and 22,  respectively.

     The next step in the exposure assessment process involved
 the quantification of the magnitude, frequency, and duration of
 exposure for the populations and exposure routes selected for
 evaluation.   The contaminant intake equations and  intake
parameters were derived from standard literature equations and
data from EPA guidance documents.  Average Daily Doses ("ADD")
and Lifetime Average Daily Doses ("LADD")  were estimated for the
contaminants in the baseline risk assessment.

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                                                                13

 Toxicitv Assessment:

      The Reference Dose ("RFD")  for a substance represents the
 level of intake which is unlikely to result in adverse non-
 carcinogenic health effects in individuals exposed for a chronic
 period of time.   For carcinogens,  the slope factor is used to
 estimate an upper-bound probability of an individual developing
 cancer as a result of exposure to a particular level of a
 potential carcinogen.

 Risk Characterization

      The baseline risk assessment in the  RI/FS quantified the
 potential carcinogenic and  non-carcinogenic risks  to human health
 posed by contaminants in several  exposure media.   The
 carcinogenic and non-carcinogenic risks were determined for soil,
 air  and ground water.

      Carcinogenic risk is presented as the incremental
 probability of an individual contracting  some form of cancer over
 a  lifetime as the result of exposure to the carcinogen.   For
 known or suspected carcinogens, acceptable exposure levels are
 generally concentration levels that represent an excess upper
 bound lifetime cancer risk  to  an  individual of between l.OxlO'4,
 and  l.OxlO'6 using information  on  the relationship  between dose
 and  response.  Risk standards  for non-carcinogenic compounds are
 established at acceptable levels  and criteria considered
 protective of human populations from the  possible  adverse effects
 from exposure.   The ratio of the  ADD to the RfD values,  defined
 as the Hazard Quotient,  provides  an indication of  the potential
 for  systemic toxicity  to occur.   To assess the overall potential
 for  non-carcinogenic effects posed by multiple chemicals,  a
 Hazard Index ("HI")  is derived by  adding  the individual hazard
 quotients  for each chemical of concern.   This approach assumes
 additivity of critical effects of  multiple chemicals.   EPA
 Considers  any HI  exceeding  one to  be an unacceptable risk to
 human  health.  The current  risks and future risks  for each of  the
 exposed populations are summarized in  Tables 23 and 24.


 Current Use Scenario

     The excess lifetime cancer risk for  onsite workers  currently
 exposed is  1.8 x  10*6.   The  noncarcinogenic hazard  index is
 0.006.  The  exposure pathways  assume dermal  contact with soil,
 ingestion  of  soil  and  inhalation of  volatiles  in indoor  air.

     For the  trespassing scenario, the most  sensitive receptor
would  be a  child.   The  excess  lifetime  cancer  risk for a child
 Site trespasser is  1.1  x 10"5.  The HI is  0.02.  The exposure
pathways assume soil and sediment  ingestion,  dermal contact with
 soil and sediment,  and  domestic use  of ground water.

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                                                                14

 Future Use Scenario

      The excess lifetime cancer risk  for a  future  onsite
 construction worker is 2.6  x  10"7.   The HI  is 0.02.  The exposure
 pathways assume dermal contact  with soil, ingestion  of  soil and
 inhalation of fugitive dust.

 The  excess lifetime cancer  risks for  an onsite adult resident  is
 2.2  x 10"4 and for an onsite child  resident  is 2.8  x  10'*.   The
 His  are 0.15 for the adult  and  1.25 for the child.
 The  exposure pathways assume  dermal contact with soil,  ingestion
 of soil,  inhalation of volatiles in indoor  air, and  domestic use
 of Site ground water.

      The risk from potential  future use of  Site ground  water is
 unacceptable.   Therefore remediation  of the ground water is
 warranted.   Actual or threatened releases of hazardous  substances
 from this Site,  if not addressed by the preferred  alternative  or
 one  of the other remedial measures  considered, present  a current
 or potential threat to public health, welfare and  the environment
 from the  risk by contaminated ground  water.


 VTI.   DESCRIPTION OF REMEDIAL ACTION  ALTERNATIVES
ALTERNATIVES FOR GROUND WATER

l:  No action
2:  Natural Attenuation/Institutional Controls
3:  Extraction/Air Stripping
4:  Extraction/Carbon Absorption
5:  Extraction/Offsite  disposal


Common Components

A ground water extraction system will be common to each
alternative that includes ground water extraction (Alternatives
3, 4, and 5).  The cost estimates for the ground water extraction
system for the Site are based on the use of well RW-1; however,
the actual number and locations of extraction wells will be
determined in the remedial design.

One aspect of the ground water extraction alternatives is to
remove the contaminants from the ground water aquifer.  The
removal of the contaminants will be accomplished by pumping the
ground water.  Removal  through pumping is also a means of
hydraulic containment.  Pumping lowers the water table in the
vicinity of the well and creates an artificial ground water flow
gradient to prevent further migration of the contaminant plume.

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                                                                15

 Ground water monitoring is a  common component  of  Alternatives  2,
 3,  4  and 5.    For costing purposes  it has  been assumed  that
 sampling and analysis for volatile  organics will  be  conducted  on
 the following wells:  RW-1,  MW-2, MW-6, MW-7 and MW-8.   The actual
 wells selected for the monitoring well network will  be  determined
 in  the remedial design phase.   For  costing purposes  the O&M  time
 period was based on 30 years  for all alternatives

 ARARs for the Site

 The goal of  the remedy for the  Site is to  restore the quality  of
 ground water to comply with Federal and State  ARARs.  The
 Commonwealth of Pennsylvania  standards specify that  all ground
 water containing hazardous substances must be  remediated to
 "background" quality  pursuant to 25 PA code §§ 264.97 (i) , (j),
 and 264.100(a)(9).  Other ARARs are identified specific
 to  the evaluated alternatives.

 The ground water collected under Alternatives  3 and  4 shall  be
 treated to comply with the substantive requirements  of  Section
 402 of the Clean Water Act, 33  U.S.C. §1342, and  the National
 Pollutant Discharge Elimination System ("NPDES")  discharge
 regulations  set forth at  40 CFR §§  122.41-122.50, the
 Pennsylvania NPDES regulations  (25  PA Code §92.31),  the
 Pennsylvania Wastewater Treatment Regulations  (25 PA Code §§95.1
 - 95.3),  and the Pennsylvania Water Quality Standards (25 PA Code
 §§93.1 -  93.9).


 25  Pa.  Code  Section 123.31  is applicable to Alternatives 3,  4,
 and 5  and prohibits malodors detectable beyond the Site property
 line.

 The resource recovery and offsite disposal activities shall
 comply with  CERCLA  §  121(d)(3)  and  with EPA OSWER Directive
 #9834.11,  both  of which prohibit the disposal  of  Superfund Site
 waste  at  a facility not in  compliance with §§  3004 and  3005  of
 RCRA and  all applicable State requirements.

 25  Pa.  Code  Section 127.12(a)(5) is applicable to new point
 source air emissions  that result from implementation of
 Alternative  3,  4 and  5.   These  Commonwealth of Pennsylvania
 regulations  require that  emissions  be reduced  to  the minimum
 obtainable levels through the use of best  available technology
 ("BAT") as defined  in 25  Pa. Code §  121.1.

 25  Pa.  Code  Section 127.11  is applicable to Alternatives 3 and 4.
This Commonwealth of  Pennsylvania regulation requires a plan for
approval  for most air stripping and soil venting/ decontamination
projects  designed to  remove volatile contaminants from soil,
water,  and other materials regardless of emission rate.

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                                                               16

 Regulations  concerning well drilling as set forth in 25 Pa. Code
 Chapter 107  are applicable to the drilling of any new wells at
 the  Site.  These regulations are established pursuant to the
 Water  Well Drillers  License Act, 32 P.S.§ 645.1 et sea.

 The  substantive requirements of the Delaware River Basin
 Commission  (18  CFR Part 430) are applicable to Alternatives 3, 4
 and  5.   These regulations establish requirements for the
 extraction of ground water and discharge of water within the
 Delaware River  Basin.
Alternative  1:  NO ACTION

Estimated Capital Costs: $0
Estimated 30 Year Present Worth Total O&M Costs: $92,600.00
Estimated 30 Year Total Present Worth Costs: $92,600.00


The National Contingency Plan  ("NCP") requires that EPA consider
a "No Action" alternative for each site to establish a baseline
for comparison to alternatives that do require action.  There are
no capital costs associated with this alternative.  The costs
associated with this alternative include dismantlement of the
existing air stripper, well abandonment, disposal of system
components, and reporting.  The total O&M costs include the
closure costs.  Under this alternative, no additional remedial
activities or ground water monitoring would be conducted.


Alternative 2:  NATURAL ATTENUATION/INSTITUTIONAL CONTROLS

Estimated Capital Costs: $0
Estimated 30 Year Present Worth Total O&M Costs: $364,800.00
Estimated 30 Year Total Present Worth Costs: $364,800.00


Under this alternative, institutional controls would be in the
form of deed restrictions regarding ground water use at the Site
to prevent human exposure to the ground water contaminants.  This
alternative does not include an active treatment component.
Continued monitoring would be conducted to track natural
attenuation and will be used to determine a Site-specific
degradation rate.  The total O&M costs include the following
closure costs:  system dismantlement, system component disposal,
well abandonment, and closure reporting and ground water
monitoring.

Because this alternative would result in contaminated ground
water remaining on the Site, Five-Year Site Reviews pursuant to
Section 121 (c) of CERCLA would be required to monitor the
effectiveness of this alternative.

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                                                                17

Alternative  3:  EXTRACTION/AIR STRIPPING

Estimated Capital  Costs:  $125,000.00
Estimated 30 Year  Present Worth Total O&M Costs:  $556,500.00
Estimated 30 Year  Total Present Worth Costs:  $681,500.00


This  alternative involves ground water extraction and treatment
of the contaminated ground water by air stripping.  The air and
VOCs  exiting the air  stripping column would be treated by a
carbon adsorption  unit.   The  treated ground water discharge would
comply with  NPDES  effluent limitations for discharge to the
onsite intermittent creek.  Ground water monitoring and
institutional controls to restrict the use of ground water would
be required.    The total  O&M  costs also include the following
closure costs:  system dismantlement, system component disposal,
well  abandonment,  and closure reporting.

In addition  to  the "ARARs for the Site" identified in Section 7
above, the following  ARARs apply to this alternative.

Federal Clean Air  Act requirements, 42 U.S.C. §§7401 et seq. are
applicable to Alternatives 3  and must be met for  the discharge  of
contaminants to the air.  Pennsylvania's Air Pollution Control
Act is also  applicable, as are Pennsylvania's Air Pollution
Control Regulations (25 Pa. Code Chapters 121-142) to
Alternatives 3.

The requirements of Subpart AA (Air Emission Standards for
Process Vents)  and Subpart BB (Pumping Equipment  Leaks) of the
Federal RCRA regulations  set  forth at 40 CFR Part 264 are
relevant and appropriate, and (depending upon the levels of
organics in  the extracted ground water and treatment residuals)
may be applicable  to  the  air  stripping operations conducted as
part  of Alternative 3. These  regulations require  that total
organic emissions  from the air stripping process  vents must be
less  than 1.4 kg/hr (3 Ib/hr)  and 2800 kg/yr  (3.1 tons/yr).

Because this  alternative would result in contaminated ground
water remaining on the Site,   Five-Year Site Reviews pursuant to
Section 121(c)  of  CERCLA would be required to monitor the
effectiveness of this alternative.
Alternative 4: EXTRACTION/GRANULAR ACTIVATED CARBON

Estimated Capital Costs: $75,000.00
Estimated 30 Year Present Worth Total O&M Costs: $547,300.00
Estimated 30 Year Total Present Worth Costs: $622,300.00

This alternative involves ground water extraction and a system to
treat contaminated ground water with granular activated carbon

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                                                                18

 ("GAG").   The  effluent from the final GAG unit will be discharged
 to the intermittent stream onsite.  Spent carbon will be shipped
 offsite for regeneration.  Ground water monitoring and
 institutional  controls would be required.  The total O&M costs
 also include the  following closure costs:  system dismantlement,
 system component  disposal, well abandonment, and closure
 reporting.

 In addition to the "ARARs for the Site" identified in Section 7
 above, the following ARARs apply to this alternative.

 The requirements  of Subpart AA (Air Emission Standards for
 Process Vents) and Subpart BB (Pumping Equipment Leaks) of the
 Federal RCRA regulations set forth at 40 CFR Part 264 are
 relevant and appropriate, and (depending upon the levels of
 organics in the extracted ground water and treatment residuals)
 may be applicable to the air stripping operations conducted as
 part of Alternative 3. These regulations require that total
 organic emissions from the air stripping process vents must be
 less than  1.4  kg/hr (3 Ib/hr) and 2800 kg/yr (3.1 tons/yr).

 Because this alternative would result in contaminated ground
 water remaining on the Site, Five-Year Site Reviews pursuant to
 Section 121(c) of CERCLA would be required to monitor the
 effectiveness  of  this alternative.

 Alternative 5: EXTRACTION/OFFSITE DISPOSAL

 Estimated  Capital Costs: $40,000.00
 Estimated  30 Year Present Worth Total O&M Costs: $689,700.00
 Estimated  30 Year Total Present Worth Costs: $729,700.00


 The ground water  extraction and monitoring components are similar
 to Alternatives 3 and 4.  This alternative does not include
 onsite treatment  of contaminated ground water,  but rather
 includes discharge of the ground water to the local Publicly
 Owned Treatment Works ("POTW")  for treatment.  Ground water
monitoring and institutional controls would be required.  The
 total O&M  costs also include the following closure costs:  system
dismantlement, system component disposal, well abandonment, and
 closure reporting.

 In addition to the "ARARs for the Site" identified in Section 7
above,  the following ARARs apply to this alternative.

The discharge of  effluent to the POTW shall comply with the
federal Clean Water Act (33 U.S.C. §§1251 et sea.)  pretreatment
regulations for existing and new sources of pollution as set
forth at 40 CFR Part 403.

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                                                                19

 Because  this  alternative would result in contaminated ground
 water remaining on the Site, Five-Year Site Reviews pursuant to
 Section  121(c) of CERCLA would be required to monitor the
 effectiveness of this alternative.

 VIII.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     Each  of  the remedial alternatives described above were
 evaluated  using nine criteria.  The resulting strengths and
 weaknesses of the alternatives were then weighed to identify the
 alternative providing the best balance among the nine criteria.
 These nine criteria are:

 Threshold  Criteria

 - Overall  protection of human health and the environment
 - Compliance  with applicable or relevant and appropriate
  requirements ("ARARs")

 Primary  Balancing Criteria

 - Reduction of toxicity, mobility or volume
 - Implementability
 - Short-term  effectiveness
 - Long-term effectiveness and permanence
 - Cost

 Modifying  Criteria

 - State  acceptance
 - Community acceptance

 A. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

     A primary requirement of CERCLA is that the selected
 remedial action be protective of human health and the
 environment.  A remedy is protective if it eliminates, reduces,
 or controls current and potential risks posed through each
 exposure pathway to acceptable levels through treatment,
 engineering controls,  or institutional controls.

     Alternative 1,  the no action alternative, does not include
 treatment  or  controls,  provides no reduction in risk,  and is not
 protective.

     Alternatives 2,  3,  4,  and 5 are protective of human health.
 Since Alternative 2  does not provide for treatment of
 contaminated ground water or prevent migration of contaminants to
 currently unaffected areas it is not as protective of potential
 future human health risks as Alternatives 3,  4 and 5 and is not
protective of the Class IIA aquifer.

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                                                                20

     Alternatives 3,  4,  and 5  include extraction and treatment  of
 contaminated ground water.   These  alternatives  would eventually
 restore  contaminated  ground water  to background levels  or MCLs,
 whichever is more stringent.   Public and  environmental  risks  from
 direct contact  with,  and ingestion of, contaminated  ground water
 would be mitigated through  treatment of the ground water plume.
 Alternatives 3,  4,  and 5 would achieve a  greater degree of
 overall  protection of human health and the environment  than
 Alternatives 1  and 2.

 B.  COMPLIANCE  WITH ARARS

     Section 121(d) of CERCLA  requires that remedial actions  at
 CERCLA sites at least attain legally applicable or relevant and
 appropriate  federal and State  standards,  requirements,  criteria,
 and limitations  which are collectively referred to as "ARARs",
 unless such  ARARs are waived under CERCLA Section 121(d)(4).
 Applicable requirements  are those  substantive environmental
 protection requirements,  criteria, or limitations promulgated
 under federal or State laws that specifically address hazardous
 substances found at the  site,  the  remedial action to be
 implemented  at the  site,  the location of  the site, or other
 circumstances present at the site.

     Relevant and appropriate  requirements are  those substantive
 environmental protection requirements, criteria,  or  limitations
 promulgated  under federal or State law which, while  not
 applicable to the hazardous materials found at  the site, the
 remedial  action  itself,  the site location or other circumstances
 at the site,  nevertheless address  problems or situations
 sufficiently similar  to  those  encountered at the site that their
 use is well-suited  to  the site.  ARARs may relate to the
 substances addressed  by  the remedial action (chemical-specific) ,
 to the location  of  the site (location-specific),  or  the manner in
 which the remedial  action is implemented  (action-specific).

     In addition to applicable or  relevant and  appropriate
 requirements, the lead and  support agencies may,  as  appropriate,
 identify other advisories,  criteria, or guidance to  be  considered
 for a particular release.   The "to be considered" ("TBC")
 category consists of advisories, criteria, or guidance  that were
 developed by EPA, other  federal agencies, or states  that may  be
 useful in developing CERCLA remedies.

      Additionally, Alternatives l and 2 would  not comply with
 the requirements of the  Pennsylvania Hazardous  Waste Management
 Regulations,  25  Pa. Code §§264.90-264.100 and in particular,  25
 Pa. Code §§264.97(i)(j)  and 264.100(a)(9), which require
 contaminated  ground water to be remediated to background levels.
Alternatives  l and  2 do  not involve any treatment of contaminated
ground water.  These regulations are relevant and appropriate to
 action taken  at  the Site.

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                                                                21

     With  respect to  location-specific ARARs, Alternatives  1 and
 2 would not  comply with  EPA's  Ground Water Protection Strategy
 Policy for a Class IIA aquifer, which is a TBC standard.

     With  respect to  location-specific ARARs, Alternatives  3, 4
 and  5 would  comply with  the  EPA's Ground Water Protection
 Strategy Policy  for a Class  IIA aquifer, which is a TBC standard.
 Alternatives 3,  4 and 5  would  protect current and potential
 sources of drinking water  and  waters having other beneficial
 uses.

     With  respect to  location-specific ARARs, Alternatives  3, 4,
 and  5 would  comply with  the  substantive requirements of the
 Delaware River Basin  Commission (18  C.F.R. Part 430).

     Alternatives 3,  4 and 5,  which  include ground water
 remediation,  would meet  the  performance standards as set forth  in
 Section IX.l.B of this ROD relating  to ground water remediation
 and  treatment.

     Alternatives 3,  4,  and  5  would  meet all action-specific
 ARARs relating to activities performed as part of the remedy,
 including  federal and State  air emission requirements, federal
 Pretreatment Standards for discharges to a POTW, and federal and
 State treatment,  storage,  and  disposal requirements for any
 hazardous  and solid wastes generated during the ground water
 treatment  process.

 C.   REDUCTION OF  TOXICITY. MOBILITY.  OR VOLUME

     This  evaluation  criterion addresses the degree to which a
 technology or remedial alternative reduces toxicity, mobility or
 volume of  hazardous substances.

     Alternatives 1 and  2  are  remedial actions that do not use
 treatment  technologies.  Therefore,  Alternatives 1 and 2 would
 not  reduce the toxicity, mobility, or volume of contaminants in
 the  ground water  plume at  the  Site.   Over time, contaminant
 levels in the present areas  of contamination may decrease
 gradually through natural  attenuation, but the ground water plume
 itself may increase in area.

     Alternatives  3,  4,  and  5  involve extraction and treatment
would result  in active reduction of  VOCs in the contaminated
 aquifer through removal.

D. IMPLEMENTABILITY

     Implementability refers to the  technical and administrative
feasibility of a remedy, from design through construction,
operation,  and maintenance.  It also includes coordination of
federal,  State, and local  governments to clean up the Site.   All

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                                                                22

 alternatives evaluated are considered  implementable  and use
 technologies that have been recommended and used at  other
 Superfund sites.   Alternatives 2 through 5 require ground water
 monitoring and Alternatives 3 and 4, require monitoring of
 treated ground water discharge; Alternative 5 would  require
 monitoring of the ground water prior to discharge to the POTW.

      Alternative  1 which includes no additional work would be the
 easiest alternative to implement.

      Alternative  2 can also be implemented easily.

      Because Alternatives  3, 4, and 5  involve the extraction and
 treatment of ground water,  there are more implementation and
 operation considerations associated with these alternatives.
 Alternatives 3, 4,  and 5 present minimum technical difficulties
 in designing and  constructing the treatment systems  or
 pretreatment that may be required under Alternative  5.

      The components of the air stripping and carbon  adsorption
 systems (Alternatives 3 and 4) are readily implementable using
 existing technologies.  The reliability of these treatment
 technologies has  also been established and demonstrated
 successfully at other hazardous waste sites.  No special
 materials or equipment would be required to implement
 Alternatives 3, 4,  or 5.   Operation and maintenance
 considerations can include,  where applicable, cleaning and
 replacement of wells and well pumps; maintenance of  blower units;
 cleaning of fouled packing;  and regeneration of the  carbon units.

 E.  SHORT-TERM EFFECTIVENESS

      Short-term effectiveness addresses the period of time needed
 to achieve protection of human health and the environment and any
 adverse impacts that may be posed during the construction and
 operation period  until performance standards are achieved.

      None of the  alternatives evaluated involve extensive
 construction, excavation,  or other remedial action measures that
would pose any appreciable short-term risks to the community or
to workers during construction or implementation.  Workers will
be required to wear appropriate levels of protection during
 installation of ground water extraction wells to avoid direct
contact with contaminated  ground water and during the sampling of
the monitoring wells.  During installation of the treatment
systems and other Site activities,  precautions mandated by the
Occupational Safety and Health Act ("OSHA")  for construction
activities will be  taken.   Disposal of any wastes generated
during  construction and operation will follow proper handling
practices  and therefore should not have an adverse environmental
impact.

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                                                                23


 F.  LONG-TERM EFFECTIVENESS AND PERMANENCE

      Long-term effectiveness and permanence refers to the ability
 of  a remedy  to maintain reliable protection of human health and
 the environment over  time.  This evaluation criterion includes
 the consideration of  residual risk and the adequacy and
 reliability  of controls.

      Since no actions would be taken to actively remediate the
 contaminated ground water under Alternative 1 and 2, the
 potential future human health risks remaining after
 implementation of this alternative would remain.  Implementing
 Alternative  1 and 2 would result in more than minimal residual
 risk from ground water ingestion, dermal contact, and inhalation
 under the potential future residential use of site ground water
 scenario, since ground water would not be treated or contained.

      Alternative 2 meets the objective of eliminating the public
 health risk  associated with use of contaminated ground water, but
 does not involve the  actual treatment or remediation of
 contaminated ground water.  Therefore, it would not maintain
 reliable protection of the environment over time.

     With respect to environmental risk, the contaminants in the
 ground water would continue to migrate over time under
 Alternatives 1  and 2.

      Alternatives 3,  4 and 5 would provide the greatest degree  of
 long-term effectiveness and permanence for ground water
 protection and  remediation and would result in minimal residual
 risk by attaining ARARs for ground water.

 G.  COST

      This criterion examines the estimated costs for each
 remedial alternative  evaluated in the Feasibility Study Report.
 For comparison,  capital, annual O&M, and present worth costs are
 shown in Table  25.

 H.  STATE ACCEPTANCE

      The Pennsylvania Department of Environmental Resources
 concurs with  EPA's selected remedy, Alternative 4.

 I.   COMMUNITY ACCEPTANCE

     A public meeting on the Proposed Plan was held on June 30,
 1994, in King of Prussia,  Upper Merion Township,  Pennsylvania.
 Comments received orally at the public meeting and in writing
during the public comment period are referenced in the
Responsiveness  Summary attached to this Record of Decision.   No

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                                                               24

residents  who live in the Upper Merion Township have  objected to
the selected remedy.


IX.  THE SELECTED REMEDY;   DESCRIPTION AND PERFORMANCE
STANDARD (S)  FOR EACH COMPONENT OF THE REMEDY

A.   GENERAL  DESCRIPTION OF  THE SELECTED REMEDY

      EPA has selected Alternative 4 as the selected remedy for
the Stanley  Kessler Site.   This remedy will restore the ground
water in the area of attainment to background levels  as
established  by EPA or to the appropriate MCLs or non-zero MCLGs
whichever  is more stringent.  The area of attainment  for the
cleanup  will be the area where the more stringent standard for
the contaminants are exceeded.  The exact location and the number
of  wells which comprise the ground water monitoring network will
be  determined by EPA in Consultation with PADER during the
remedial design.   Based on  current information, this  alternative
provided the best balance among the alternatives with respect to
the nine criteria EPA uses  to evaluate each alternative.  The
selected remedy consist of  the following components:

•Installation,  operation and maintenance of ground water
extraction well(s)  to remove contaminated ground water from
beneath  the  Site and to prevent contaminants from migrating
further;

•Installation,  operation and maintenance of granular  activated
carbon units at the ground  water extraction well(s) to treat
ground water to the required levels;

•Periodic  sampling of ground water and treated water  to ensure
that  treatment components are effective and that ground water
remediation  is progressing  towards the required cleanup levels.

•Deed Restrictions to prohibit the installation of new wells in
areas of contamination which do not meet ARARs.  These
restrictions can be withdrawn when ARARs are achieved.

Each  component of the selected remedy and its performance
standard(s)  is described in detail below.

1.    Extraction and  Treatment of Ground water

      A.  Description  of the Component of the Remedy

      The ground water shall be remediated through extraction and
treatment  of the  contaminated ground water throughout the area of
attainment.   The  extraction shall create ground water zones where
the contaminated  ground water is hydraulically contained and
prevent migration beyond the area of attainment.  Ground water

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                                                               25

 shall  be  treated using an  onsite  treatment system.  The  treatment
 system will  be  designed to reduce the  Site-related  contaminants
 in  the extracted ground water,  unattended,  on a  continuous, 24-
 hour-per-day performance basis.   The exact location, size and
 number of well(s)  shall be determined  during the design of the
 ground water extraction system.

     The  treated ground water effluent will be discharged to the
 intermittent stream on Site through a  new  outfall pipe  that shall
 be  constructed  as part of  the remedial action.   The treatment
 system will  be  designed to achieve 98  percent removal of VOCs in
 compliance with the substantive requirements of  PADER's NPDES
 regulations.  Final flow rates  and GAC system dimensions will be
 determined by EPA during remedial design.   The final combined
 pumping rate and the exact location, size  and number of wells
 shall  be  based  on the  ability to  hydraulically control  the
 contaminated ground water  plume as determined by EPA.   Extraction
 and treatment will continue until EPA, in  consultation  with the
 Commonwealth of Pennsylvania, determines that the performance
 standard  for each contaminant of  concern in the  ground  water has
 been achieved.

     Periodic monitoring of ground water will occur to  determine
 the performance of the pump and treat  system and the
 effectiveness of the selected remedy in meeting  the performance
 standards.

     B.   Performance Standards

 1.   The  performance standard for each contaminant  of concern in
 the ground water shall  be  the MCL or the non-zero MCLG  for that
 contaminant  [40  C.F.R.  Part 141]  or background concentration of
 that contaminant [25 PA Code §§264.97(i),  (j), and
 264.100(a)(9)],  whichever  is more stringent.  The background
 concentrations  for each contaminant of concern shall be
 established  in  accordance with the procedures for ground water
monitoring outlined in  25  PA Code §264.97.  Establishment of
 background concentrations  shall not delay ground water  extraction
 and treatment.   In the  event that a contaminant  of  concern is not
detected  in  samples taken  for the establishment  of  background
concentrations,  the detection limit for the method  of analysis
utilized  with respect to that contaminant shall  constitute the
 "background" concentration  of the contaminant.

2.   The  area of attainment for the cleanup will  be the area
where the more  stringent standard for the contaminants are
exceeded  and will  be determined in the remedial  design.  It
should be noted  that the remedy will address not  only
contaminants listed below but also other hazardous  substances at
the Site.

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                                                               26


 Contaminant            MCLfucr/H              MCLGfucr/ll

 TCE                          5                      0
 1,1,1-TCA                  200                   200
 1,1-Dichloroethene           7                     7
 Cis-l,2-Dichloroethene      70                    70
  1,1-Dichloroethane          810*
 1,2-Dichloroethane           5                     0
 Tetrachloroethene            5                     0
 1,1,2-Trichloroethane        5                     3
 Benzene                      5                     0
 Chlorobenzene                100                  100
 Dichloromethane               5                     0
 Chloroform                   100                    0
 Toluene                    1000                 1000

 *Non-carcinogenic health-based concentration

 3.   The performance  standard for the treated ground water prior
 to discharge to the intermittent creek shall be in compliance
 with the substantive  requirements of the NPDES discharge
 regulations set forth in 25 Pa. Code §92.31, and the Pennsylvania
 Water Quality  Standards (25 Pa. Code §§93.1-93.9).  Pursuant to
 the Pennsylvania  Department of Environmental Resources'
 determination  monitoring for all the hazardous substances shall
 also be required.

 4.   The management and ultimate disposition of the spent carbon
 and the associated hazardous substances from the granular
 activated carbon  units shall not degrade air quality nor
 contribute  to  ground-level ozone formation and will be
 determined, subject to EPA approval, during the remedial design.
 Such management may entail treatment and/or disposal of the
 carbon  filters.   In the event these units are a hazardous waste,
 the following  ARARS will apply as the Performance Standard for
 onsite  activities:  25 Pa.  Code Chapter 262 Subparts A (relating
 to hazardous waste determination and identification numbers), B
 (relating to manifesting requirements for off-site shipments of
 spent carbon or other hazardous wastes), and C (relating to
 pretransport requirements; 25 Pa. Code Chapter 263 (relating to
 transporters of hazardous wastes); and with respect to the
 operations  at  the  Site generally, with the substantive
 requirements of 25 Pa. Code Chapter 264, Subparts B-D, I (in the
 event that  hazardous waste generated as part of the remedy is
managed in  containers), 25 Pa.  Code Chapter 264,  Subpart J (in
 the event that hazardous waste is managed, treated or stored in
tanks).

 5.   To the extent that the implementation of this portion of the
remedy  impacts ecological features on site (e.g stream
vegetation) the performance standard shall include appropriate

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                                                               27

measures  to mitigate  damage which may occur during the remedial
design and remedial action.


      C.   Ground Water Remedy  Implementation

      Because the  selected remedy will result in contaminants
remaining on-site, 5-year Site reviews under Section 121(c) of
CERCLA will be required until the performance standards are
achieved.

      An operation and maintenance plan for the ground water
extraction and treatment system, including long-term ground water
monitoring, shall also be required.  The performance of the
ground water extraction and treatment system shall be carefully
monitored on a regular basis,  as described in the long-term
ground water monitoring component in 2.A. below, and the system
may be modified,  as warranted by the performance data collected
during operation.  These modifications may include, for example,
alternate pumping of  the extraction well(s) and the addition or
elimination of certain extraction wells.  In addition, all of the
extraction/treatment  alternatives 3 and 4 rated relatively evenly
against all of the criteria except the cost criterion.
Consequently, if, based on more detailed information gathered
during remedy implementation  or operation, variations occur, such
as a  change in the contaminant concentration or flow rate, the
selected  system may no longer be cost-effective when compared to
one,  or a combination, of the other extraction/ treatment
alternatives.  In that case,  based on the final design
parameters, EPA may consider  the utilization of a combination
of the ground water treatment technologies under Alternatives
3 and 4.

      It may become apparent during implementation or operation of
the ground water  extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant  at levels higher than the performance standards over
some  portion of the area of attainment.  If EPA, in consultation
with  the  Commonwealth of Pennsylvania, determines that
implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will  be technically impracticable to achieve and maintain the
performance standards throughout the entire area of attainment,
EPA,  in consultation with the  Commonwealth may require that any
or all of  the following measures be taken, for an indefinite
period of  time,  as further modification(s) of the existing
system:

a)  long-term gradient control  provided by low level pumping,  as
a containment measure;

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                                                                28

 b)   chemical-specific ARARs may be waived for those portions of
 the  aquifer that EPA, in consultation with the Commonwealth
 determine are technically impracticable to achieve further
 contaminant reduction;

 c)   institutional controls may be provided/maintained to restrict
 access  to those portions of the aquifer where contaminants remain
 above performance standards; and

 d)   remedial technologies for ground water restoration may be
 reevaluated.

 The  decision to invoke any or all of these measures may be made
 during  implementation or operation of the remedy or during the  5-
 year reviews of the remedial action.  It is not a component of
 this ROD.   If such a decision is made, EPA may amend the ROD or
 issue an  Explanation of Significant Differences.

 2.   Long-Term Ground Water Monitoring

     A.   Description of the Component of the Remedy

     A  long-term ground water monitoring program shall be
 implemented to evaluate the effectiveness of the ground water
 pumping and treatment system.  A plan for the long-term ground
 water monitoring program shall be included in the operation and
 maintenance plan for the ground water extraction and treatment
 system.   EPA will determine the number of monitoring wells
 necessary to verify the performance of the remedial action.  The
 installation of additional monitoring wells may be required.
 Numbers and locations of these monitoring wells shall be subject
 to EPA approval during the remedial design, in consultation with
 the  Commonwealth of Pennsylvania.

     The wells shall be sampled quarterly for the first three
 years and  semi-annually thereafter.  Sampling and operation and
 maintenance shall continue until such time as EPA, in
 consultation with the Commonwealth of Pennsylvania, determine
 that the performance standard for each contaminant of concern has
 been achieved throughout the entire area of ground water
 contamination.   If EPA and the Commonwealth make such a
 determination,  the wells shall be sampled for twelve consecutive
 quarters throughout the entire plume and if contaminants remain
 at or below the performance standards, the operation of the
 extraction system may be discontinued.

     Semi-annual  monitoring of the ground water shall continue
 for five years  after the system is shutdown.   If subsequent to an
extraction system shutdown, monitoring shows that ground water
concentrations  of  any contaminant of concern are above the
performance standard,  the system shall be restarted and continued
until the  performance standards have once more been attained for

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                                                               29

 twelve  consecutive quarters.  Semi-annual monitoring shall
 continue  until  EPA determines, in consultation with the
 Commonwealth  of Pennsylvania, that the performance standard for
 each  contaminant of concern can be achieved on a continuing
 basis.

      B.   Performance  Standards

      The  performance  standard for this component of the remedy is
 the implementation and the completion of the long-term ground
 water monitoring program.

 3.  Deed  Restrictions

      Deed restrictions shall be developed and submitted to EPA
 for approval.   Once approved, these deed restrictions shall be
 placed  in the deed to the Site by filing said restrictions with
 the Recorder  of Deeds of the appropriate County Court.  The deed
 restrictions  shall prohibit the use of ground water in the Site
 for as  long as  contamination remains above performance standards.
 The deed  restrictions shall be valid and binding in the Township
 and Commonwealth in which the Site is located.  The continuing
 need  for  these  restrictions shall be re-evaluated during the
 Five-year Site  reviews which are conducted under CERCLA Section
 121(C), 42 U.S.C. Section 9621(c).

  Worker  Safety

      During all Site  work, Occupational Safety and Health
Administration  ("OSHA") standards set forth at 29 C.F.R.
Parts 1910, 1926  and  1904 governing worker safety during
hazardous waste operations, shall be complied with.

  Five-Year Reviews

     Five-year  reviews shall be conducted after the remedy is
implemented to  assure that the remedy continues to protect human
health and the  environment.  A 5-Year Review Work Plan shall be
required  and  shall be subject to EPA approval in consultation
with the  PADER.
X.  STATUTORY DETERMINATIONS

     EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment.  Section 121 of CERCLA also requires that the
selected remedial action comply with ARARs, be cost-effective,
and utilize permanent treatment technologies to the maximum
extent practicable.  The following sections discuss how the
selected remedy for the Stanley Kessler Site meets these
statutory requirements.

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                                                               30

A. PROTECTION  OF HUMAN HEALTH AND THE ENVIRONMENT

     The  selected remedy will provide adequate protection of
human health and the  environment by extracting and treating the
contaminated ground water to achieve MCLs established under the
SDWA or background levels, whichever is lower.

     Implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts.  The
remedial  technologies employed in the selected remedy are proven
to reduce the  concentrations of volatile organic compounds to
acceptable levels.


B. COMPLIANCE  WITH AND ATTAINMENT OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS ("ARAKS")

     The  selected remedy will comply with all applicable or
relevant  and appropriate chemical-specific, location-specific,
and action-specific ARARs.  Those ARARs are:

1. Chemical-Specific  ARARs

     The  selected remedy will be designed to achieve compliance
with chemical-specific ARARs related to ground water and ambient
air quality at the Site.  The contaminants from the Stanley
Kessler Site and their respective MCLs which are listed in
Section IX.l.B of this ROD are relevant and appropriate for this
remedial  action.  If  a non-zero Maximum contaminant level goal
("MCLG")  has been established, the MCLG shall be attained by the
remedy.

     The  Commonwealth of Pennsylvania standards specify that all
ground water containing hazardous substances must be remediated
to "background" quality as set forth in 25 Pa. Code §§264.90 -
264.100,  and in particular, 25 Pa. Code §§264.97(i) and (j), and
264.100(a) (9).  The Commonwealth of Pennsylvania also maintains
that the  requirement  to remediate to background is found in other
legal authorities.  This requirement that all ground water be
remediated to  background levels is an ARAR if background levels
are determined to be more stringent than the appropriate MCLs or
non-zero MCLGs.  The method(s) by which background levels will be
determined are set forth under the description of the selected
remedial alternative.   These background levels, if more stringent
than the appropriate MCLs or the non-zero MCLGs, shall be
attained as part of this remedial action.   However, if EPA and
the FADER determine that attaining such levels is technically
impracticable, EPA may amend the ROD or issue an Explanation of
Significant Differences to address this situation.

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                                                                31

 2.   Location-Specific  ARARs

      The  substantive requirements  of the  Delaware River  Basin
 Commission (18  C.F.R.  Part 430)  are applicable.   These
 regulations establish  requirements for the  extraction of ground
 water and dishcarge of water within the Delaware  River Basin.

 3.   Action-Specific ARARs

      25 Pa.  Code  Section 123.31  is applicable to  the  selected
 remedial  alternative and prohibits ma1odors detectable beyond the
 Stanley Kessler property line.

      25 Pa.  Code  Section 127.12(a)(5) will  apply  to new  point
 source air emissions that result from implementation  of  the
 selected  remedial alternative.   These Commonwealth of
 Pennsylvania regulations require that emissions be reduced to the
 minimum obtainable levels through  the use of best available
 technology ("BAT") as  defined in 25 Pa. Code § 121.1.

      Regulations  concerning well drilling as set  forth in 25 Pa.
 Code Chapter 107  are applicable.   These regulations are
 established pursuant to the Water  Well Drillers License  Act, 32
 P.S.§  645.1  et  sea.

      The  ground water  collection and treatment operations will
 constitute treatment of hazardous  waste (i.e., the ground water
 containing hazardous waste), and will result in the generation of
 hazardous wastes  derived from the  treatment of the contaminated
 ground water.   The remedy will be  implemented consistently with
 the  requirements  of 25 Pa. Code  Chapter 262  Subparts  A (relating
 to hazardous waste determination and identification numbers), B
 (relating to manifesting requirements for off-site shipments of
 spent  carbon or other hazardous  wastes),  and C (relating to
 pretransport requirements; 25 Pa.  Code Chapter 263 (relating to
 transporters of hazardous wastes);  and with respect to the
 operations at the Site generally,  with the  substantive
 requirements of 25 Pa. Code Chapter 264,  Subparts  B-D, I  (in the
 event  that hazardous waste generated as part of the remedy is
 managed in containers), 25 Pa. Code,  Subpart J (in the event that
 hazardous waste is managed, treated or stored in tanks).  40
 C.F.R. Part  264,  Subpart AA (relating to  air emissions from
 process vents)  and Subpart BB (relating to pumping equipment
 leaks).

     25 Pa.  Code  Chapter 264, Subchapter  F,  regarding  ground
water monitoring  is applicable to  the selected remedial
 alternative.

     Any  surface water discharge of  treated  effluent will comply
with the  substantive requirements  of  the  Section 402 of  the Clean
Water Act, 33 U.S.C.  §1342, and  the  National Pollutant Discharge

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I	
                                                                             32

              Elimination System ("NPDES") discharge regulations set forth at
              40 C.F.R. Parts 122-124, the Pennsylvania NPDES regulations (25
              Pa. Code §92.31, and the Pennsylvania Water Quality Standards (25
              Pa. Code §§93.1-93.9).

                   The Occupational Safety and Health Act ("OSHA")  regulations
              codified at 29 C.F.R. Section 1910.170 are applicable for all
              activities conducted during this remedial action.

                   25 Pa. Code Sections 261.24 and 273.421 are applicable
              regulations for the handling of residual and other waste and for
              the determination of hazardous waste by the Toxic Characteristic
              Leaching Procedure ("TCLP").

                   This remedy will comply with CERCLA § 121 (d) (3), and with
              EPA OSWER Directive #9834.11, both of which prohibit the disposal
              of Superfund Site waste at a facility which is not in compliance
              with §§ 3004 and 3005 of RCRA and all applicable State
              requirements.


              4. To Be Considered Standards

                   Pennsylvania's Ground Water Quality Protection Strategy,
              dated February 1992 is a "to be considered" standard.

                   EPA's Ground Water Protection Strategy, dated July 1991,  is
              a "to be considered" standard.
              C.   COST-EFFECTIVENESS

                   The selected remedy is cost-effective in providing overall
              protection in proportion to cost,  and meets all other
              requirements of CERCLA.  The NCP,  40 C.F.R. Section
              300.430(f)(ii)(D), requires EPA to evaluate cost-effectiveness by
              comparing all- the alternatives which meet the threshold criteria
              - protection of human health and the environment and compliance
              with ARARs - against three additional balancing criteria:  long-
              term effectiveness and permanence; reduction of toxicity,
              mobility and volume through treatment;  and short-term
              effectiveness.   The selected remedy meets these criteria and
              provides for overall effectiveness in proportion to its cost.
              The estimated present worth cost for the selected remedy is
              $622,300.00.


              D.  UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
              TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

                   EPA has determined that the selected remedy represents the
              maximum extent to which permanent  solutions and treatment

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                                                               33

technologies can be utilized while providing the best balance
among the other evaluation criteria.  Of those alternatives
evaluated that are protective of human health and the environment
and meet ARARs, the selected remedy provides the best balance of
tradeoffs in terms of long-term and short-term effectiveness and
permanence, cost, implementability, reduction in toxicity,
mobility or volume through treatment, State and community
acceptance, and preference for treatment as a principal element.

     Under the selected remedy, treatment of the contaminated
ground water using granular activated carbon units will provide a
greater degree of reduction of toxicity, mobility, or volume than
Alternatives 1 and 2.  Alternative 4 will provide the same degree
of reduction of toxicity, mobility or volume as Alternatives 3
and 5 but for lesser costs.  Alternative 4 will reduce
contaminant levels in the Class IIA aquifer, a current source of
drinking water, and reduce the risks associated with direct
contact and ingestion of the ground water to the maximum extent
practicable, as well as provide long-term effectiveness.

E. PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

     The selected remedy satisfies the statutory preference for
treatment as a principal element.  Alternative 4 addresses the
primary threat of potential future ingestion and potential future
direct contact of contaminated ground water through treatment
using granular activated carbon.

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     APPENDIX A
      FIGURES
STANLEY KESSLER ROD

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                                                    UPPER
                                                    MERION
                                                    RESERVIOR
                                          SOURCE: ATLAS OF PRELIMINARY GEOLOGIC
     EXPLANATION                                QUADRANGLE MAPS OF PENNSYLVANIA
                                                 MAP 61. 1981 pg.429.
Tpb   PENSAUKEN  AND BRIDGETON  FMS.
Kp    PATAPSCO(?) FM.
Trs    STOCKTON FM.
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Coh   ANTIETAM foO HARPERS FMS.
Xwc   WISSAHICKON FM.. ALBITE-CHLORITE SCHIST   0          2,000       4,000
                                                SCALE
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             an®
             nan
        GrROUNDWATER 223 WILMINGTON WEST CHESTER PIKE
         m           CMALJU5 FORD, P.
         IECHNOLOGY  <2is> M8-17M
                     CHAOOS FORD, PA 19317
              IOJECT NO.:     1ACAD FILE:      IDRAWING DATE:
              01303-5026     50263-4        9/92
            DESIGNED:

              SAC
            DETAILED:

              DCC
CHECKED:

  MJW
                         REGIONAL GEOLOGY
CLIENT/LOCATION:

  STANLEY KESSLER NPL SITE
 UPPER MERION.  PENNSYLVANIA
FIGURE:


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-------
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GROUNDTATER ^Jg^g^,^
TECHNOLOGY (215) sse-tra*

U17
PROJECT NO.: IACAD FILE: IDRAWING pATE:
01303-5026 l50261-5a I 3/93
DESIGNED:
SAC
DETAILED:
DCC
CHECKED:
MJW
CONCEPTUAL
snEMooa
CLIENT/LOCATION:
STANLEY KESSLER NPL SITE
UPPER MERION, PENNSYLVANIA
c, !
.'i ."
/ •
FIGURE:
5

-------
    APPENDIX  B
      TABLES
STANLEY KESSLER ROD

-------
                      Summary of Analytical Parameters for Each Media Investigated
                     MEDIA
ANALYTICAL PARAMETERS
                   Surface Soil
        TCL VOAs
       TCL SVOCs
   TCL Pesticides & PCBs
        TAL Metals
                  Subsurface Soil
        TCL VOAs
       TCL SVOCs
   TCL Pesticides & PCBs
        TAL Metals
           TOC
       Geotechnical
      Moisture content
           pH
                     Soil Gas
       Vinyl Chloride
         1,1.1-TCA
           TCE
           PCE
                   Groundwater
        TCL VOAs
     TAL Total Metals
   TAL Dissolved Metals
                   Surface Water
        TCL VOAs
       TCL SVOCs
      TAL Total Metals
   TAL Dissolved Metals
       Surface Water
   TCL Pesticides & PCBs
                    Sediments
        TCL VOAs
        TCL SVOCs
   TCL Pesticides & PCBs
        TAL Metals
        Grain Size
           TOC
   Notes:
p:\PRQJECTS\KESSLER\WFINAL\SECT4.TXT
                                     TABLE 1

-------
                     TABLE 2
Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id

Depth
(FT)
Volatile Organic Compound! (ug/kg)
Atxtowt -•
--&!,**"*",*'••
^fffiWffiiJJtf-
, ,. J *}' z v
,?-BMM«WWO\ '%*
'S?&>3'J''t >
«« :/\"
Btwi&tfrN;::
"
-------
BLE  2  (continued)  Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id

Depth
(FT)
Volatile Organic Compound* (ug/kg)
Mrttytew ,
WCMwW*X
Trt^fttafr! .•/••
- ^v&mf)'" ' *'
iS MkHr^sv xV
"^Mo^tt^m^tf
/ |,l £•?¥&£/ \
^mwrtfomtT "
..yxtetiOfft* ,;<••
^ t&wir:'^:
, ,vfcfff
, CWwWk ^
Southwest Former Drum Storage Area
SS-009-1107
SB-009-1107
SB-009-1107
SB-009-1107
SS-015-1108
SB-015-1108
SB-015-1108
SS-018-1106
SB-018-1106
SB-018-1107
2-3
3.5-5.5
6.5 - 8.5A
6.5 - 8.5B
1.5-2.5
3-5
6-8
1.5-2.5
3-5
6-8
8 B
8 B
19
24
5 J
6 B
21
7 B
7 B
<11 U
<12 U

-------
TABLE  2  (continued)   Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id

Depth
(FT)

Awfcmft s -
vlS^ ' " Vi-
Volatile Organic Compound* (ug/kg)
Bwoeoo
', ^ '&>*"
2-Birt«w«w V
?*» ,-^V> ," -
"Cartxjfts -
DiroWWe
CMor*H'' '
Wrthswe- ,,
Iji-DfesMow- -
:40mp''*i--,''
TtaiU,:3HD*^ -
i •" ••
4-McthylrZ- : '„:
'"peofcnaie; ,/>
Former Waste Neutralization System
SS-201-1108

SS-202-1108
SB-202-1108
SB-202-1108
SB-202-1112
SB-202-1112
SB-202-1112
SB-202-1112
SB-203-1113
SB-203-1113
SB-203-1113
SB-203-1113
SB-204-1114
SB-204-1114
SB-204-1114
SB-204-1114
SS-205-1114
SB-205-1114
SB-205-1114
SB-205-1114
0.5-1.5

0.5-1.5
16 -ISA
16- 18B
28-30
34-36
40-42
46-48
10-12
28-30
40-42
46-48
4-6
22-24
40-42
52-54
1.5-2.5
22-24
40-42
52-54
16 B

<12 U
20 B
8 B
17 B
16 B
18 B
21 B
<12
12 B
<12
II B
20 B
20 B
32 B
14 B
10 B
36 B
12 B
22 B
1 B

<12 U
<12 U
2 J
<11 U
<12 U
2 B
1 B
1 B
1 B
1 B
<11 U
<11 U
<12 U
<12 U
<12 U
<12 U
<12 U
<12 U
<12 U
<12 U

<12 U
<12 UJ
<11 U
<11 UJ
<12 UJ
<11 U
<11 U
<12 U

-------
TABLE  2 (continued)   Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id

Depth
(FT)
Volatile Organic Compound* (ug/kg)
^M^fca*^ ;
^SWoifWo '*J ~?
J|ttfijNl5*tV
•>C «rtw»Ov£L«*' *
* *• •: *

' M,*-T^;;
ofdatoetJwnft *
Ttfcfctow
•: «4h«w \
VJ«fff
CMorW* -•
Former Waste Neutralization System
SS-201-1108
SS-202-1108
SB-202-1108
SB-202-1108
SB-202-1112
SB-202-1112
SB-202-1112
SB-202-1112
SB-203-1113
SB-203-1113
SB-203-1113
SB-203-1113
SB-204-1114
SB-204-1114
SB-204-1114
SB-204-1114
SS-205-1114
SB-205-1114
SB-205-1114
SB-205-1114
0.5-1.5
0.5-1.5
16 -ISA
16-18B
28-30
34-36
40-42
46-48
10-12
28-30
40-42
46-48
4-6
22-24
40-42
52-54
1.5-2.5
22-24
40-42
52-54
25
6 J
6 B
3 J
5 B
6 B
2 B
2 B
2 B
<12 U
2 B
<11 U
5 B
7 B
9 B
8 B
12 B
9 B
4 B
7 B

-------
                    TABLE  2  (continued)
                                                Volatile Organic Analytical Results for Surface and Subsurface Soil Samples
'
Sample Id


SB-206-II15
SB-206-1U5
SB-206-1115
SB-206-1II5
Depth

(FT)
10-12
22-24
40-42
46-48
Volatile Organic Compounds (ug/kg)
Mc j ""

*..>?, "CWorid* ,- '->
5 J
4 1
6 J
5 J
'^tawsWe^r !

'•ex-, iBttKm ^ ; if*
<13 U
<11 U
<12 U
<12 U
''; I»%4»|^TH»^C'4

^^Mfttortltamft^'''''
<13 U
<11 U
1 J
2 J
*l,i$rf$r ":'•«

' oMotoelfcinft ' '
<13 U
<11 U
<12 U
<12 U
/,T*faiM0»}~J^,

«tWW8'"^ >,
<13 U
<11 U
<12 U
<12 U
,' ^Vtot - »; ,


<13 U
<11 U
<12 U
<12 U
Upgradlent Background
SS-301-1106
0.5-1.5
6 B
<12 U
<12 U
ROJECT8\KESSLER\RrrABLEa\SLVOA.WK1

-------
TABLE 3   Semi-Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Semi-volatile Organic Compounda (ug/kg)
AdtlUNWJMW -.'';'
^ *«X*t'»^
f1" -jjS -.-iy v' $
•^•sVu'-S"
4¥>" ••V*'
JPCMISiQ^^^^
•• mtfanKrflttft \:' f ••
, F**W*&
'i'-»*«B»'£M'
^ ,'&*"',,
ItaWB^j,'/'
/'iwyJ>«w> , -•.',
<$*• * * *">'• *
8
-------
TABLE  3 (continued)
                       Semi-Volatile Organic Analytical Results (or Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Semi-volatile Organic Compounds (ug/kg)
^'"Plf^femr "
" '^bottddiuB'-- -
•.•.< i~-. V " " & " V \ •• •. -.
-M^r
JSSfe
•*$*.,, sliC^,
N DHHHrtyJr / ,
;r$*f»% r-:
*- .,,. jo*> ••*
% •• •> ••'•."'
DHrb0$h'j;
/ phttwlntft'*' ' *,
FjHWJ ' -
;'' -'-'''•"''',,
|fWMK!W
-------
TABLE  3 (continued)   Semi-Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Semi-volatile Organic Compound* (ug/kg)

""'f'¥X'
IRP
^SPx!
-,-': V'-
£?;'.
Southwest Former Drum Storage Area
SS-009-1107
SB-009-1107
SS-015-1108
SB-015-1108
SS-018-1106
SB-OI8-1I06
2-3
3.5-5.5
1.5-2.5
3-5
1.5-2.5
3-5
<390 U
<370 U
<380 U
<370 U
<380 U
<400 U
East Former Drum Storage Area
SS-103-1106
SB- 103- 1106
SS-1 18-1 105
SB-118-1105
SS-I31-110S
SB-131-1105
0.5-1.5
2-4
0.5-1.5
2-4
1-2
2-4
<400 U
<390 U
<400 U
<100 U
<390 U
<390 U
<980 U
<920 U
<950 U
<930 U
<960 U

-------
TABI K
         (continued)    Semi-Volatile Organic Analytical Results for Surface and Subsurface Soil Samples

Sample Id
SB-203-1113
SB-203-I113
SB-204-1114
SS-205-1114
SB-205-1114
SB-206-1115
Depth
(FT)
28-30
40-42
52-54
1.5-2.5
52-54
40-42
Semi-volatile Orgtotc Compound* (ug/kg)
^Kfcc |
- ^ 'I-Y% ^ "-
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
BOWP(»)-r , 1 3'
X?^?*HV
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
* jBkdBj^*)*1^'^'
ttiftMs^t
; ^ -{,,* x><, \"
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
jjS&ii^
^wM^V^j
/•-. ff '•*/ -$ '', -.j. ^
<400 U
<380 U
<380 U
<4IO U
<390 U
<410 U
'BaxHK^-* "' '
, •>"%*•>'/'''% " ''•'';'
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
,, tto|£HW, tf t t
* */ f '
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
bjteajjfoiiib/
"^&;v'L"i>
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
Upgradlent Background
SS-301-1106
0.5-1.5
<400 U
74 J
79 J
56 J
170 J
52 B
85 J
<400 U

-------
'E 3 (con
                     Semi-Volatile Organic Analytical Results (or Surface and Subsurface Soil Samples

Sample Id
SB-203-1113
SB-203-11I3
SB-204-H14
SS-205-1114
SB-205-1114
i.
SB-206-IH5
Dtj*h
(FT)
28-30
40-42
52-54
1.5-2.5
52-54
40-42
Seml-volatJlc Organic Caropouadi (ug/kg)
'$,3*«Pldildih>3,.. ,t«
*" v' liMijtitlmi ^
<400 U
O80 U
<380 U
<410 U
<390 U
<410 U
Hf
<400 U
<380 U
<380 U
130 I
<390 U
<410 U
ill
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
'$3$$ifc*
"'^~>TOf >h
> ",,>-$*" "if J-'
<400 U
<380 U
<380 U
170 i
<390 U
<410 U
-t^(^^ -\
*l?^V\^'*t ",
'"t''f f '•*' '^s ' ' <
<400 U
<380 U
<380 U
66 J
<390 U
<410 U
-yhw^ ,, ,
Mthmp :;-v
$r*'v ;/
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
]|fl.(WIW?JmHS>^T:; ,''-
!$***$l ;
'-S«4I««^' ^
<400 U
<380 U
<380 U
<410 U
<390 U
<410 UJ
^Jfe****'
' fjf ?
<400 U
<380' *U
<380 U
<410 U
<390 U
<410 U
Upgradlent Background
SS-301-1106
0.5-1.5
<400 U
<400 U
70 J
<400 U
<400 U
170 )
<400 U
61 J

-------
      TABLE  3  (continued)   Semi-Volatile Organic Analytical Results (or Surface and Subsurface Soil Samples

Sample Id
SB-203-1113
SB-203-I1I3
SB-204-1114
SS-205-1114
SB-205-1114
SB-206-1115
Depth
(FT)
28-30
40-42
52-54
1.5-2.5
52-54
40-42
Semi-volatile Organic Compound* (ug/kg)
;*-***^
'" iiuittfrtiuilArH? "•
.$*:&$**\
<400 UJ
<380 UJ
<380 U
<410 U
<390 U
<410 U
Wfcfc"
'«*€*7
,'"^;Y:ir
<1000 U
<950 U
<960 UJ
<1000 UJ
<980 UJ
<1000 U
'Wto&f^{
wxflino ; '
^5 > l!i '<•.'' ••<• o
••i « --x •. >' •.
<1000 UJ
<950 UJ
<960 UJ
<1000 UJ
<980 UJ
<1000 U
/wiiiteror* /--
jimJBW^V^
^' f~"\ j\ %\ •" ^
- ••% '< •& ',
<1000 U
<950 U
<960 UJ
<1000 UJ
<980 UJ
<1000 UJ
f&«^>/\\
<400 U
<380 U
<380 U
<410 U
<390 U
<410 U
l?yt
-------
                   TABLE A    Pesticide and PCBs Analytical Results for Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Pesticide Compound* (u
M'-W^t
>wp;
%$**?.
!<* '** ?
g/k«)
?%zyr
**&'
ttttfln'Mfir
EpwWo
Southwest Former Drum Storage Area
SS-009-0109
SB-009-0109
SS-015-0109
SB-015-0109
SS-018-0109
SB-018-0109
2-3
3.5-5.5
1.5-2.5
3-5
1.5-2.5
3-5
<4 U
<3.7 U
<3.9 U
<3.7 U
<3.9 U
<4.3 U
<2.1 U
<1.9 U
<2 U
<1.9 U
0.49 J
<2.2 U
<4 U
<3.7 U
<3.9 U
<3.7 U
<3.9 U
<4.3 U
<4 U
<3.7 U
<3.9 U
<3.7 U
<3.9 U
<4.3 U
<2.l U
<1.9 U
<2 U
<1.9 U
<2 U
<2.2 U
<2.l U

-------
TABLE 5   Inorganic Metal Analytical Results for Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Inorganic Compound* (rag/kg)
A«
Al
ff
**VJ*,.
* •: %
s JB* ^ x<
/•
>B* >
^ '
jNg« -
< < ><
"•C»> ^*
*
•: •:
; f.
,«fc *
Co > >
£fo
Fo
Hg
Southwest Former Drum Storage Area
SS-009-I107
SB-009-1107
SS-015-1108
SB-015-1108
SS-018-1106
SB-OI8-1I06
SS- 103- 11 06
SB-I03-1106
2-3
3.5-5.5
1.5-2.5
3-5
1.5-2.5
3-5
0.5- 1.5
2-4
<1 U
<1 U
<1 U
<\ U
<1 U
<1 U
<1 U
<1 U
6760
4340
3680
3410
S630
6470
10200
7390
0.88 J
1.6 J
0.82 J
0.52 J
1.3 J
0.96 J
1.3 R
0.72 R
46.4
16.5
24.5
17.8
33.9
72.3
29.4
54.6
<0.6 U
<0.6 U
<0.6 U
<0.6 U
<0.6 U
0.65
0.49
1.4
<0.6 U
<0.6 U
<0.6 U
<0.6 U
<0.6 U
<0.6 U
<0.6 U
<0.6 U
717
480
479
344
1220
1120
765
5400
9.9
18.3
14.4
12.3
9.3
9.3
14.1
8
5
5
6
14.6
12.7
8.4
11
50.9
5.2 J
21.2 J
6.9 J
13.1 1
17.2 1
11.6 J
22
28.6
16000 J
67100 J
39800 J
33400 J
43300 J
26100 J
21400
41000
<0.1 U
<0.1 U
<0.1 U
<0.l U
<0.1 U
<0.1 U
<0.l U
<0.1 U
East Former Drum Storage Area
SS-l 18-1 105
SB-l 18-1 105
SS-131-1105
SB-131-1105
0.5 -1.5
2-4
1-2
2-4
1

-------
TABLE  5 (continued)  inorganic Metal Analytical Results for Surface and Subsurface Soil Samples

Sample Id
Depth
(FT)
Inorganic Compound* (ing/kg)
&&&JV
s . *• "Nj •- >^
^>-^ *••*;-
•V*^ '

f%8|£4cC>
?,s!p!?,'f£>
s % ftf& .V \ 1

j- '• ntf'"'-'' ^5. <& '• '•
&'- !*N*iY '
*.* •> ^sf %•**> *
Af.>vlv-V
Southwest Former Drum Storage Area
SS-009-1107
SB-009-1107
SS-01S-1108
SB-015-1108
SS-018-1106
SB-018-1106
SS-103-1106
SB- 103-1 106
2-3
3.5 - 5.5
1.5-2.5
3-5
1.5-2.5
3-5
0.5 - 1.5
2-4
301
259
262
175
357
299
653
317
east Former Drum Storage Area
SS-U8-1105
SB-l 18-1 105
SS-131-110S
SB-131-1105
0.5 - 1.5
2-4
1-2
2-4
326
317
382
368
921
416
496
188
1170
814
1860
3130
160
93.9
165
462
339
310
162 J
1370 J
71.3
40.5
62
53.2
70.5
58
43.6
41.4
5.3
5.7
3.7
3.8
7.8
7.8
9.1
36.8
7.5 J
7.7 J
6.8 J
8 J
10.2 J
23.3 J
10.7 J
17.7 J
«/$bXM
sJ$'\;«V
vV^--r>;
>^
..V . t,-*^'*
,-.' f'f-. >,'i
31M'-
;W;-
$y
Za , ,

<6 U
<6 U
<6 U
<6 U
<6 U
<6 U
<6 UJ
<6 UJ
<1 R
<1 R
<1 R

-------
TABLE  5 Ccontinu,
d)  Inorganic Metal Analytical Results for Surface and Subsurface Soil Samples

Simple Id
SS-205-1114
SB-20S-1114
SB-206-I1I5
Depth
(FT)
1.5-2.5
52-54
40-42
Inorj
- ,Ag */s-
-»s --.?-
'•*%**$&
"^4V^
<0.6 U
<0.6 U
<0.6 U
*T,Ciif ?'••.'
1i;<»>*>'V
."-"<./?.>: j.
849
25900
84.2
>IC£ ^ ' - >
'-,,- ~'f,, ,?*
j--V-r»^ ',
y.. ',>!';"'
26.5
<2 U
4.1 B
jCtf,^' '
'"'/'X's-.'y
'''/'«*/''
8
17.2
13.7
: ,
-------
                          TABLE  5  (continued) Inorganic Metal Analytical Results (or Surface and Subsurface Soil Samples

Sample Id
SS-205-1114
SB-205-1H4
SB-206-1115
Depth
(FT)
1.5-2.5
52-54
40-42
Inorganic Compounds (rag/kg)
-/' i^~ */; <£
895
693
300
'& ^** J-"*-, f'
«>M x? s
2670
4150
412

160
762
1060

49.2
59.3
47.7
"••Nl &$?'•
> ' »*' «.•" <*
<.:-
-------
                                                           TABLE  6
                        Comparison of Reported Concentrations (or Inorganics Detected in Surface Soil
                                                  With Background Values
Compound
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Vanadium
Zino
Range of Reported Concentrations
(mg/kg)
0.99 - 1.0
3,680- 18,100
0.82-2.8
17.4-46.4
0.49 -0.61
479- 11,700
5.9 • 26.5
5-39.7
5.2-66.3
16,000-43,700
262 • 896
435 - 2,670
160-664
42.9 -71.6
3.7 - 19.6
6.8 - 28
14.6 - 44.6
14.3 - 162
Background (1) (mg/kg)
< 1
6,190
NO
66.3
0.6
2,240
9.9
36.2
26.6
27,400
349
x 966
820
36.3
21.8
24.6
21,4
106
Pennsylvania
US Geological Survey (2)
(mg/kg)
NO
70,000
6.5
600
1.0-1.6
360 • 620
60
16-70
60 - 700
NO
NO
600 - 700
1,000- 7,000
700
30 - 700
30-70
1 60 • 600
120 - 3,600
Native Soil (3)
(mg/kg)
0.1 - 5.0
10,000- 300,000
, 1 '4
100 - 3,600
0.1 • 40
100-400,000
6.0 - 3,000
1 - 40
2- 100
7,000 - 550,000
400 - 30,000
600 - 6,000
100- 4,000
750 - 7,500
6- 1,000
2 • 200
20 • 600
10 - 300
Notee:
NO = No Data
1 = SS-301
2 = Shacklette, T.H., (1984)
3 = Dragun, James, (1988)
p:\PROJECTS\KESSLER\HIFINAL\SECT6.TXT

-------
                                                                                     TABLE  7

                                                             Comparison of Reported Concentrations (or Inorganics Detected
                                                                      in Subsurface Soil with Background Values
Compound
Silver
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Thallium
Vanadium
Zinc
Range of Reported Concentrations
(mg/kg)
0.99 - 1
3,410- 18,100
0.52 • 3.5
16.6 -72.3
0.49 - 1.7
5.8
235- 11,700
5.9 - 26.5
6-221
5.2 - 63.4
16,000- 67,100
0.06-0.1
176-895
139- 3,130
93.9 - 2,080
30.4-71.5
3.7 - 46.5
5.6 - 28
0.65 - 1
14.6-44.6
14.3-276
Site-Specific Background (1) (mg/kg)
< 1
6,190
ND
56.3
0.6
< 0.6
2,240
9.9
36.2
26.5
27,400
0.1
349
966
820
36.3
21.8
24.5
0.7
21.4
106
US Geological Survey (2)
(mg/kg)
NO
70,000
6.6
600
1 - 1.5
NO
350 - 520
60
16- 70
50 - 700
ND
0.082-0.13
ND
600 - 700
1,000- 7,000
700
30 - 700
30-70
NO
160- 500
120-3,500
Native Soil (3)
(mg/kg)
0.1 -5
10,000 • 300,000
1 - 4
100 - 3,500
0.1 - 40
•'o.01 - 45
100 - 400,000
6 - 3,000
1 - 40
2-100
7,000 • 550,000
ND
400 - 30,000
600 - 6,000
100- 4,000.
750 - 7,500
5- 1,000
2 • 200
ND
20 - 500
10- 300
Notes:
ND  =   No Data
1    =   SS-301
2    =   Shacklette, T.H., (1984).
3    =   Dragun, Jamas, (1988).
                p:\PROJECTS\KESSLER\RIFINAL\SECT6.TXT

-------
                                      TABLE 8     Volatile Organic Results (or Surface Water Samples

Sample Id
SW-2
SW-3-A
SW-3-B
SW-4
SW-5
Volatile Organic Compounds. (ug/L)
r^d-
<0.5 UJ
<0.5 UJ

-------
            TABLE  9      Semi-Volatile Organic Results for Surface Water Samples

Sample Id

SW-2
SW-3-A
SW-3-B
SW-4
SW-5
Semi-volatile Organic Compound* (rcg/L)
fcisCfc-E%ih*syl)-
pbttabte ..
2 B
9 B
6 B
3 B
4 B
Upgradient Background
SW-l
2 B
EKe%fc*
pJrthalBte
<10 U
I J
1 J
<10 U
< 10 U
•FinonnniQBO-'

<10 U
< 10 U
<10 U
<10 U
1 J
4~*feti$i-
- phenol
<10 UJ
<10 U
<10 U
< 10 UJ
< 10 UJ
PyrenB
%
<10 U
< 10 U
< 10 U
< 10 U
i ;

< 10 U
<10 U
<10 UJ
< 10 U
NOTES:
Compounds which were nondetected for all samples are not listed.
SW-3-A and SW-3-B are duplicate samples.
B — Blank Contamination            U — Undetected at <**fd value
J - Estimated Value                UJ - Not detected, estimated value may be inaccurate and imprecise
P:\PROJECrSlKESSLER\RfTA8LESkSVOASW.WK1

-------
    TABLE  10
                 Pesticide and PCS Results for Surface Water Samples

Sample Id
SW-2
SW-3-A
SW-3-B
SW-4
SW-5
Pesticide and PCS Compounds (ng/L) ;
Arochlor-12S4 ]
0.21 J
0.22 J

-------
                                  TABLE  11   T0ta| inorganic Metal Analytical Results lor Surface Water Samples

Sample Id
SW-2
SW-3-A
SW-3-B

SW-4
SW-5

M ,
<4 U
<4 U
<4 U

<4 U
<4 U
Upgradlent Background
SW-1
<4 U
. M.'.*
13500
675
715

<45 U
1120

13500
M
<2 UJ
<2 UJ
<2 UJ

<2 UJ
<2 UJ

<2 UJ
Inorganic Compounds (iig/Lj
B»
81.9
23.3
30.2

32.5
23.3
Bo - '
< 1 U
< 1 U
<1 U

<1 U
<1 U
Ctf "
4.7 B
2.5 B
<2 U

<2 U
<2 U
,,C» *
14100
11000
11000

6680
7770
Cc ,
13.7
<6 U
<6 U

<6 U
<6 U
Co
8.5
<7 U
<7 U

<7 U
<7 U
C»
34.6 B
11.6
11.4

5.2
14.7
ft)
18700
1400
1460

61.1 B
2280
Hg
0.2 B
0.23 B
0.24 B
1
<0.10 U
0.19 B

77.2
< 1 U
6.5 B
14300
13.6
<7 U
30.3 B
18200
0.2 B

Sample Id
SW-2
SW-3-A
SW-3-B
SW-4
SW-S
Inorganic Compound* (ug/L)
&'"'^§
4030
2320
2340
789
1540
C'MlY 7?1
5720
3260
3220
1870
2780
..«to,v^ j
293
39
39
14.3
48.2
Upgradlent Background
SW-1
4000
5690
250
-H« v\
3530
5620
5600
2290
3710

3790
CNivv
14.2
<9 U
<9 U
<9 U
<9 U

10.9
J* >:
71.2 J
9.8 B
9.5 B
< 1 U
12.3 J
' ft
< 14 U
<14 U
< 14 U
 , ~
1.3
< 1 UJ
< 1 UJ
<1 UJ
< I UJ
•n
<1 UJ
< 1 U
<1 U
<1 U
< 1 U
„ 'V *
24.9
<6 U
<6 U
<6 U
6.5
"Zn '
150
91.7 B
100 B
58.9 B
88 B

58.7 J
14.5 B
2
< 1 UJ
23
138
NOTES:
SW-3-A and SW-3-B are duplicate samples.
B - Blank Contamination            U - Undetected at stated value
J - Estimated Value                UJ - Not detected, estimated value may be inaccurate or imprecise
P:tPROJECT8UCESSLERlRITA8LESUNOnaW.MK \

-------
                                   TABLE  12  Dissolved Inorganic Metal Analytical Results for Surface Water Samples

Sample Id
SW-2
SW-3-A
SW-3-B
SW^t
SW-5
Inorganic Compounds (ug/L)
-;
^X'lt/W v* Y
2760
2130
2170
813
1370
~:**g ^,-
2750
2660
2660
1960
1560
;- !&«;/"
11.7
26.1
23.4
19.5
19.6
\^my/:,-
3590
5740
5700
1950
3570
~ JN"|^-V
<9 U
17.4 B
<9 U
<9 U
18 B
XJ*.V ',
<1 U
1.7
1.4
3.4
<1 U
.--*" "
<14 U
< 14 U
< 14 U
< 14 U
14.8 B
w . ....
<1 UJ
< 1 Ul
< 1 UJ
< 1 UJ
< 1 UJ
',11'"
1.3 B
2.6 B
< 1 U
2 B
1.5 B
<.Y~"'
<6 U
<6 U
<6 U
<6 U
<6 U
--*» -
14 B
80.1 B
66.6 B
63.6 B
42.4 B
Upgradlent Background
sw-l
2660
3020
9.7
4250
9.3 B
< 1 U
< 14 U
< 1 UJ
< 1 U
<6 U
147 B
NOTES:
SW-3-A and SW-3-B are duplicate samples.
B - Blank Contamination              U - Undetected at stated value
J - Estimated Value                  UJ - Not detected, estimated value may be Inaccurate or imprecise
P:\PROJECTa\KE8SLERUVrABLE8UNORSW.WK 1

-------
     TABLE  i 3   Volatile Organic Results for Sediment Samples

Sample Id

SD-2
SD-3-A
SD-3-B
SD-4
Volatile Organic Compounds (ug/kg)
MdbyUec
Chloride*
3 B
< 11 U
<11 U
<11 U
Acetone

4 B
2 B
< 11 U
< 11 U
Upgradient Background
SD-1
4 B
8 B
NOTES:
Compounds which were noodetectable for all samples are not listed.
SD-3-A and SD-3-B are duplicate samples.
B — Blank Contamination
U - Undetected at reported value
P-.VROJECTS\KESSt£I«R(TAfiLESWOASa>M(1

-------
                              TABLE  H semi-Volatile Organic Results for Sediment Samples
                                                   SwU-voUUlo Organic Compound* (ug/kg)
 Staple Id
   SD-2

  SD-3-A
  SD-3-B
190 J

 90 J
 65 J

110 J
380 J

300 J
 53 J

130 J
1900  J

 920  J
 480

 850
 1500 J
MBBMft

  800 J
  130 J

  460 J
                                                               4800 J

                                                               2500 J
                                                              <9EO UJ

                                                               1700 J
<410  UJ

<370  UJ
  340  J

  530  J
2600 J

1000 J
 520 J

 950 J
Upgradlent Background
   SD-1
< 370  U |       < 370 U I
                              350 J
                             280 J
                                1000 J
<370  UJJ
                                                    390 J
\
Sample Id
SD-2
SD-3-A
SD-3-B
SD-4
Serai-votrtflo Organic Cowpowd* (ug/kg)
,??S2£?^^
160 J
160 J
120 J
310 J
SJSSSS?]:
<410 UJ
<370 UJ
O90 U
<380 U
-;2Sfi¥
320 J
170 J
120 J
160 J
"££S?';
<4IO UR
<370 UR
<390 UR
<380 UR
iJIffiJivJ
<410 UR
<37() UR
<390 UR
<380 UR
ry^'i
2500 J
1300 J
690
1200
;> &Mi*«v'j
, 640 J
550 J
<390 UJ
120 J
Upgradlent Background
SD-l
60 J
<370 UJ
<370 U
<370 UR
070 UR
500 J
160 J

-------
                  TABLE 14  (continued)
                                          Semi-Volatile Organic Results (or Sediment Samples

Sample U
SD-2
SD-3-A
SD-3-B
SD-4
SemJ-voUifle Organic Compound!
DJfeOHCK
100 J
46 J
40 J
60 J
3,y-oww«w, o
y>Jfca«M&M»
<410 UJ
<370 UJ
<390 UJ
<380 UJ
,jyHfW^!V
: %j*«**'r::V0'
<4IO UR
<370 UR
<390 UR
<380 UR
-ytAiiiij*t&f<&
x '- i * i &** : 4-
. Jfrw4- *.$:*?••
<410 UR
<370 UR
<390 UR
<380 UR
Ufftf)
WHN^
'******' «•*.*
<410 U
220 J
<390 U
<380 U
•. '**±v^&'-- 1 ' t, ,
'*• i«ba9pl' ' '< "
<1000 UR
<930 UR
<980 UR
<940 UR
; 4,6-Dtoto^
3H«*yl0>«wl

-------
                        TABLE  14 (continued)    Semi-Volatile Organic Results for Sediment Samples

Sample Id
SD-2
SD-3-A
SD-3-B
SD-4
Semi-volatile Organic Compound* (ug/kg)
,44^^;
"* jPWdfll^^^^
< 1000 UR
<930 UR
<980 UR
<940 UR
"f ^vntftMsitffff jv> ••
:|j|fe§Vpfeow4 •• '*>.. '* '
< 1000 UR
<930 UR
<980 UR
<940 UR
ltt*M*AMit*«MMM
% V> f s -: "
J -. <^?-. v* rt v* r ••
' s^ ^% ^.s-:Sw *-.
2800
1400
1100
1700
\ ^r-** s \
s.>^*C^ <.•••• A sS
<410 UR
<370 UR
<390 UR
<380 UR
fr% ^ ^
^:^/4%^-
4700 J
2300 1
1300
2100
,j*j4f$~T!ric3wfl!W''! '';
>v^j«b*
-------
                                               TABLE  15     Pesticide and PCB Results for Sediment Samples

Sample
Id
SD-2
SD-3-A
SD-3-B
SD-4
Petttelde and PCB Compound* (ug/kg)
C$t&iu& *•$*•
1.2 J
1.2 J
0.73 J
< 1.9 UR

S3
24 J
29 J
<37 UR
ArfMBiar --
&'**>A-v:
0.73 I
<3.7 U
<3.9 U
<3.7 UR
v^W*^;
^^'V>"4^>
3.2 J
1.1 J
0.95 J
<3.7 UR
pfcjtfrtV'';^
"<5>W»'::
0.64 J
<3.7 U
<3.9 U
O.7 UR
JSaWwrtWEy^
™*&ifo»»:£\&;%
2.3 J
1.2 J
1.4 J
<3.7 UR
Uttdrtft """ "
fertwfe ;/-
3.3 J
<3.7 U
1.9 I
<3.7 UR
QV>MDf-~
ChtonJww •
<2.1 U
1.1 J
<2.0 U
< 1.9 UR
Hqxvchtar
<2.l U
0.72 J
<2.0 U
< 1.9 UR
KqttKfclor
8tK>nJ
-------
                                     TABLE  16     To(a| |norganjC Metal Analytical Results for Sediment Samples

Sample Id
SD-2
SD-3-A
SD-3-B
SD-4

Al'-..
<0.59 U
<0.58 U
<0.7 U
<0.68 U

:- &
3200 J
2100 J
2360 J
2160 J
A*
1.4 B
1.8
2.6
2.1
Inorganic Compound! (mg/kg)
B*
30.7
19.9
19.1
21.5
B» —
0.9
0.8
0.97
0.94
<3d •••
0.47
0.3
0.37
0.67
- ;
<2.8 U
<2.7 U
<3.3 U
<3.2 U
$*'.--
<0.24 U)
<0.21 UJ
<0.24 UJ
<0.2 UJ
.-.1>~' '
<0.24 U
<0.21 U
<0.24 U
<0.2 UJ
* ,V* '
no B
13.6 B
17.8 B
17.1 B
Ztt
127
85.6
141
180
Upgradlent Background
SD-1
329
26400 I
446 I
92.3 B
14.9
12.3 I
<2.6 U
<0.97 UJ
<0.19 UJ
12.5 B
103
NOTES:
SD-3-A and SD-3-B are duplicate samples.
B - Blank Contamination           U - Undetected at stated value
J - Estimated Value                UJ - Not detected, estimated value may be inaccurate or imprecise
P:\PflOJECT8KE83LER\WTABLEmiNOR80.WK1

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Table 17     Volatile Organic Results for Groundwater Samples

Sample Id
RW-1
MW-2
MW-4
MW-5A
MW-6
MW-7
MW-8
Volatile Organic Compounds (ug/L)
Benzene
3.4
<0.5 U
<0.5 U
7.3
<0.5
3.7
<0.5 U
,*?*«»
<0.5 UJ

-------
                           Table  17  continued
Volatile Organic Results for Groundwater Samples

Sample Id
RW-1
MW-2
MW-5A
MW-6
MW-7
MW-8
Volatile Organic Compound* (ug/L)
^Sf^\
37
<0.5 U
2.5
2.8
8.4
11
25
'*$$£$$
1.4
<0.5 U
<0.5 U
<0.5 U
<0,5 U
0.6
<0.5

7.3
1.4
1.6
0.6
1.9
2.2
2.3
^^S?
<0.5 UJ
<0,5 UJ
<0.5 UJ
<0.5 UJ
<0.5 UJ
<0.5 UJ
<0,5 UJ
^*t
240
67
11
24
100
90
97
'#!S£& ':*
0.8
<0.5 U
<0.5 U
<0.5 U
<0.5 U
<0.5

-------
               TABLE  18    Data Evaluation Summary of Total Inorganic Metals in Groundwater
s 
- ^;;-"^-r ;".
i
5
0
6
2
1
6
1
1
1
7
2
6
6
6
6
S
1
1
0
0
3
1
Numt)6r$i|
^i?M.h
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
1&W$S^
324
991

50.9
1
64
48000
6.9
91.2
199
1210
0.68
2640
22100
51.5
19800
9.1
80.6
14.4


6.4
1210
*#&«£:
^iBtfWtf-*
' -v «o/ti v
324
64400

3440
24.8
64
127000
6.9
91.2
199
218000
1.3
4730
29700
5440
43500
27.4
80.6
14.4


127
1210
-^•1*1*%^,,
48.0
10797.1

686.3
4.0
10.0
79028.6
5.3
16.0
34.0
35370.0
0.4
3576.4
23928.6
1495.4
27428.6
26.7
12.7
8.7


22.0
204.1
ft $ w „
^flfcftlta"?:
"^fllflte^
121.7
23710.2

1224.7
9.2
23.8
25293.9
4.5
33.1
72.8
80597.6
0.5
811.6
5926.7
1928.4
7474.1
38.5
29.9
2.8


46.4
443.8
;;^to&;<;^^
r "'";A -•.'-,""''- ] ;\-
137.4
28209.5

1585.7
10.8
27.5
97604.0
8.6 (2)
40.4
87.5
94559.7
0.7
4172.4
28281.0
2911.6
32917.4
55.0 (2)
34.7
10.7


56.0
530.1
UpgriWi
-------
              TABLE 19     Data Evaluation Summary of Dissolved Inorganic Metals in Groundwater
, ,6$Mp0*U& s
"\:~s;^ <'"*< ;I
.,- >-h->-
Silver
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
, flWk**r
: s ^Vl;,p4;
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
*ifiBw«r£p
75.5


62.8


47300
6



0.78
2670
20800
28.1
19900



1.2


75.8
'*H*?Sf»;
I?8S&';
75.5


887


121000
6



0.78
4380
28900
2270
39900



1.2


75.8
':W,'-
;£i« •
%f {AR'f -
U't'v*^; J ^/
/ ^ >^% ,> y^ < '*'* ss,'
32.9


511.6


92793.6
4.3



0.4
3671.0
27319.4
1159.9
30309.3



0.8


39.1
Upgradiem(2) ^
^>;|w(W'X'-
'' ' '/ ' ' ", ^ ' '-
<4
<38
<2
<137
<1
<2
71800
<6
<7
<4
<41.7
<0.10
1540
<31700
<21.5
<35300
<25
<1
<18.2
<1.6
<1
<6
<32.1
NOTES:
                     1.943
(1)t(0.95,6).
(2) Source-MW-3
P:U>noJECTaUCEa8LERVRATA8lEa\OMETaW.WK1

-------
                                            TABLE 20     Depth Discrete Groundwater Analytical Results from RW-1

S*mplo
Interval
(depth: feet)
103-115
126-138A
126-138B
149-161
ns-m
TRIP BLANK
m ', . 	 -.. . . Volatile Organic Compounds (ug/t)
HM$M-&
'*\> ",-"*'*>
<'K'J- 'V " ^ "
5% * ••' ^
330
250
(^340
330
170
 0.9
<5
<3
 ^' '^ ' ;
<5
<5
1.6
<5
<3
<0.5
«>«xn»^'
, s %'"-
" V ' *

-------
                                                        TABLE  21
                                        Summary ot Hotenu.   .xpusure
                                                       Current Use
Population
Oneite Worker
t
Off-site Worker
Area Resident
(Adult & Child)
SB
TO
.0
z>
>o
7\
Tt
Exposure
Point
Surface Soil
Groundwater
Surface Water
(Drainage Ditoh)
Sediment
(Drainage Ditoh)
Soil Gas
Surface Soil
Ground water
Surface Water
(Drainage Ditch)
Sediment
(Drainage Ditoh)
Soil Gas
Surface Soil
Groundwater
Surface Water
(Drainage Ditch)
Sediment
(Drainage Ditch)
Soil Gas
Potential Route
of Exposure
• dermal contact with surface soil
• Incidental Ingeetlon of surface soil
• Inhalation of fugitive dust
• Ingestion of drinking water
; • dermal contact with surface water
• Incidental Ingestion of surface water
• dermal contact with sediment
• Incidental Ingestion of sediment
• Inhalation of volatlles in Indoor air
• dermal contact with surface soil
• Inpidental Ingestion of surface soil;
• Inhalation of fugitive dust
• Ingestion of drinking water
• dermal contact with surface water -,-.
• Incidental Ingeetlon of surface water
• dermal contact with sediment
• Incidental Ingestion of sediment
• Inhalation of volatiles In Indoor air
• dermal contact with surface eoil while playing or trespassing onsitt
• Incidental Ingestlon of surface soil while playing or trespassing oneite
• Inhalation of fugitive duet
• Ingestion of drinking water
• dermal contact while showering or bathing
• inhalation of volatlles while showering or bathing •
• dermal contaot with surface water while playing or trespassing onsite
• Incidental Ingestion of surface water while playing or trespassing
ensile
• dermal contaot with sediment while playing or trespassing onsite
• Incidental Ingestion of sediment while playing or treepaeslng oneite
• Inhalation of volatiles In Indoor air
Quantified In
Risk Assessment
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yae
Yee
Yes
No
Reason for
Exclusion
site mainly paved/grass covered
not used as drinking water source
drainage ditch Is Intermittently filled with water;
child more sensitive reoeptor
drainage ditoh la Intermittently filled with water;
child more sensitive receptor

onslte worker more sensitive receptor
oneite worker more sensitive receptor
site mainly paved/grass covered ' .
not used as drinking water source In area
drainage ditoh Is Intermittently filled with water;
child more sensitive reoeptor
drainage ditoh Is Intermittently filled with water;
child more sensitive receptor
onsite worker more sensitive receptor
child only-more sensitive reoeptor '
child only-more sensitive receptor
site mainly paved/grass covered

child only-more sensitive receptor
child only-more sensitive reoeptor
no residences adjacent to property; onsite
worker more sensitive population
WJECTS\KESSL£R\RIFINAL\SECTe.TXT

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                                                                TABLE  22
                                                      Summary of Potential Exposure Pathways
                                                                    Future Use
Population
Construction Worker
Area Resident
.(Adult & Child)
Exposure
Point
Surface Soil '!
Groundwatar
Surface Water
(Drainage Ditch)
Sediment
(Drainage Ditch)
Soil Gas
•Surface Soil
Qroundwater
Surface Water
Sediment
Soil Gas
Potential Route
of Exposure
• dermal contact with soil
• Incidental Ingestlon of soil
e Inhalation of fugitive dust
• Ingestlon of drinking water
• dermal oontect with groundwater
• Incidental Ingestlon of groundwatar
• dermal oontect with surface water
• Incidental Ingsetlon of surface water
• dermal contact with sediment
• Incidental Ingeetlon of sediment
• Inhalation of volatilee In Indoor air
• dermal contact with surface soil
• Incidental Ingeetion of surface soil '•'
• Inhalation of fugitive dust
• Ingestlon of drinking water
• dermal oontaot while showering or bathing
• Inhalation of volatlles while showering or bathing
• dermal contact with surface water while playing oneite
• Incidental Ingeetlon of surface water while playing onsite
• dermal oontaot with sediment while playing oneite .
• Incidental Ingastion of sediment while playing onsite
• Inhalation of volatlles In Indoor air
Quantified In
Risk Assessment
Yes
Yes
Yes
No
No
No
No
No
No
No
No
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
Yes
Reason for
Exclusion

not used as drinking water source
groundwater is deep (> 60 feet)
groundwater Is deep (> 60 feet)
drainage ditch Is Intermittently filled with water; soil
exposure more frequent and likely
drainage ditch le Intermittently filled with water; soil
exposure more frequent and likely
onsite worker exposed to indoor air (current use) more
sensitive receptor
construction worker more sensitive receptor
• •»
drainage ditch is Intermittently filled with water; soil
exposure more frequent and likely
dreinege ditch is intermittently filled with water; soil
exposure more frequent and likely

p:\PROJECTS\KESSLER\RIFINAL\SECTB.TXT

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                                    TABLE 23
                             Risk Characterization Summary
              Assumed Future Residential Development and Groundwater Use
Potential
Receptor
Onsite
Construction
Worker

Onsite
Resident
(Adult)
Exposure
Pathway
• dermal contact with subsurface soil
• incidental ingestion of subsurface soil
• inhalation of fugitive dust
TOTAL
• dermal contact with surface soil
• incidental ingestion of surface soil
• ingestion of drinking water
• dermal contact while showering or bathing
• inhalation of volatiles while showering or bathing
• inhalation of volatiles in indoor air
TOTAL
Onsite
Resident
(Child)
• dermal contact with surface soil
• incidental ingestion of surface soil
• ingestion of drinking water
• dermal contact while showering or bathing
• inhalation of volatiles while showering or bathing
• inhalation of volatiles in indoor air
TOTAL
Upper-
Bound
Estimated
Cancer Risk
8.7 x 10"9
1.7 x W'7
8.4 X10'10
2.6 X tO7
2.3 X 1CT7
1.7 X10'7
2.0 X W*
3.0 X 10"6
1.5X10'5
5.8 X 10"6
2.2 X tO*
1.0 X 10"6
1.4 X 10*
2.5 X 10"*
2.5 X 10"6
1.8 X10*
4.8 X 10*
2.8 X tO*
Estimated
Hazard
Index
0.005
0.010
0.002
0.02
0.001
0.001
0.15
0.002
0002
0.0003
0.15
0.03
0.030
1.22
0.003
0.005
0.0004
1.25
p:\PROJECTS\KESSLEH\RIF1NAL\SeemTXr

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                                   TABLE  24

                         Risk Characterization Summary - Current Use
Potential
Receptor
Onsite
Workers
Exposure
Pathway
• dermal contact with surface soil
• incidental ingestion of surface soil
• inhalation of volatiles in indoor air
TOTAL
Trespassing
Area Resident
(Adult)
• ingestion of drinking water
• dermal contact while showering or bathing
• inhalation of volatiles while showering or bathing
TOTAL
Trespassing
Area Resident
(Child)
• dermal contact with surface soil
• incidental ingestion of surface soil
• ingestion of drinking water
• dermal contact while showering or bathing
• inhalation of volatiles while showering or bathing
• dermal contact with surface water
• incidental ingestion of surface water
• dermal contact with sediment
• incidental ingestion of sediment
above)
TOTAL
Upper-Bound
Estimated
Cancer Risk
6.2 x 10'7
2.3 x 10'7
9.5 X 10'7
1.8 X 10*
8.4 X 10'7*
1.3X10*
1.1 X 10'7
9.6 X 10'7
1.9 x10"7
1.1 x10'7
1.1 x 10**
i.oxio*
1.3X 10~7
9.8 X 10*
3.3 X NT8
7.4 X 10*
1.6x10*
1.1 X 10*
Estimated
Hazard
Index
0.005
0.001
0.00005
0.006
0.0007
0.00001
0.00003
0.0007
0.003
0.001
0.004
0.00001
0.00006
0.0001
0.00004
0.01
0.002
0.02
NOTES:
* = Risk was calculated based on a transport model assuming only site groundwater reaches the UMR
and that the water was untreated prior to use. Currently, groundwater withdrawn from the UMR is
treated to meet MCLs before use.
    p:\PROJECTS\KESSl£R\R!RNAL\SECT5.TXT

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                                                                            FABLE  25
COST SUMMARY Of ALTERNATIVES
KESSLER NPl SITE
COMPONENT
Alternative 1: No Further Action
Alternative 2: Institutional Controls
Alternative 3: Air Stripping with Discharge to Surface
Water (with vapor phase carbon)
Alternative 4: Granular Activated Carbon with
Discharge to Surface Water
Alternative 5: Off-site Disposal to POTW
TOTAL
CAPITAL
COSTS
$0.00
' $0.00
$125.000.00
$75,000.00
$40,000.00
0 & M COSTS
YEARS
13
$0.00
$121,200.00
$250.800.00
$247,200.00
$340.600.00
YEARS
416
$0.00
$417,600.00
NA
NA
NA
YEARS
46
NA
NA
$228,000.00
$224,400.00
$318,000.00
YEARS
7-12
NA
NA
$211,800.00
$211,800.00
$211,800.00
CLOSURE
COSTS
" $100,000.00
"$180,000.00
" $225,000.00
"$215,000.00
"$210,000.00
PRESENT
WORTH
0& M
COSTS
• * •
$92,600.00
$364,800.00
$556,500.00
$547,300.00
$689,700.00
TOTAL
COSTS
$92.600.00
$364,800.00
$681.500.00
$622.300.00
$729,700.00
NOTES:
Present worth analysis assumes ROD to be issued in 1994 and an 8% Interest rate.
1         Closure costs to be incurred one year from issuance ol ROD
"        Closure cost to be incurred at project completion
'"       Includes closure costs
••••      Total Cost In 1994 dollars.

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                      RESPONSIVENESS SUMMARY
                  STANLEY KESSLER SUPERFDND SITE
                       UPPER MERION TOWNSHIP

 PART I.   This section provides  a summary of commentors' major
 issues and concerns,  and expressly acknowledges and responds to
 those raised by the  local community. "Local Community" may
 include local homeowners, businesses, the municipality, and not
 infrequently,  potentially responsible parties  ("PRPs").

 PART II.   This section provides a comprehensive response to all
 significant comment,  explains how the Record of Decision
 incorporates or addresses the issues raised and is comprised
 primarily of the specific legal and technical questions submitted
 in writing during the public comment period.

 Any  points of conflict or ambiguity between information provided
 in Parts  I and II of  this responsiveness summary will be resolved
 in favor  of the detailed technical and legal presentation
 contained in Part II.

 PART I.   SUMMARY OF THE MAJOR COMMENTS AND QUESTIONS RECEIVED
 DURING THE PUBLIC MEETING AND EPA/S RESPONSES

 Comment:   A Township  Supervisor asked if the Site posed any risk
 factor to the potential residential development of a tract of
 land near the O'Hara  Site which extends from Henderson Road
 almost down to Route  202.

 EPA  Response:   Potential human  health risks from this Site
 primarily are  due to  exposure to contaminated ground water.
 Since any new residential development currently is required by
 local authorities to  have public water, this Site does not pose a
 risk to the residential development of that area.

 Comment:   A Township  Supervisor referred to remedial action or
 pumping that has  already been conducted by Kessler and wanted to
 know if they (Kessler)  determined whether it was effective.

 EPA  Response:   Based  on data and calculations presented in the RI
 Report, the pumping conducted thus  far has been able to reduce
 the  contaminant concentration in the plume by approximately 97 -
 98%.   Thus,  pumping of  contamination has been shown to be
 effective.   However, the estimated  2% of the contaminant
 concentration  in  the ground water plume is two orders of
magnitude  greater than  the maximum  contaminant level for TCE.

 Comment:   A Township Supervisor  asked what level of contaminants
would  be  in the treated ground water that will be discharged to
the  intermittent  stream.

 EPA Response:  Any discharge to  the stream of treated ground
water must according to this ROD, comply with the substantive
requirements of Section 402 of the  Clean Water Act, and the

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 National Pollutant  Discharge Elimination System ("NPDES").   The
 discharge limits  for the treated ground water will be set by the
 Commonwealth of Pennsylvania Department of Environmental
 Resources ("PADER").

 Comment:  A Township Supervisor asked who would be responsible
 for monitoring the  treatment system and ensuring that it is
 properly maintained and operated.

 EPA Response:  If Kessler conducts the remedial action under the
 terms  of a Federal  Consent Decree, then it would be responsible
 for the  O&M,  and  EPA would oversee its work.  If EPA conducts the
 remedial action,  then either EPA or Pennsylvania would be
 responsible for the O&M.

 PART II.   SUMMARY OF WRITTEN COMMENTS RECEIVED  AND EPA'S
 RESPONSES

 Copies of all written comments received are contained in the
 Administrative Record for the Site.  These comments were received
 by mail  during the  public comment period.  The  written comments
 and EPA's responses are summarized below.

 PRP Comments:   On  August 19, 1994 the Law Offices of Beveridge &
 Diamond,  P.C. submitted comments on behalf of Stanley Kessler &
 Co. ("Kessler").  These comments and EPA's responses are
 summarized below.
Comment:  Kessler comments that EPA stated at a public meeting
for the proposed plan that the health risk is acceptable.
Kessler also comments that the FS concludes there are no human
health or environmental risks posed by the Site.

EPA Response:  There are unacceptable health risks posed by this
Site, as described in detail in the Record of Decision
particularly the risk assessment section.  Under the current-use
scenarios: an on-site worker and the child trespasser, the risks
are within the acceptable range.  However, under a future use
scenario, which assumes domestic use of Site ground water, site-
related risks to residents exceed the upper boundary of 1 x 10"4
for carcinogenic risks, thus .supporting the need for remedial
action.  Therefore, the FS does conclude that the Site poses an
unacceptable risk to human health.  In addition, the affected
ground water is a current source of drinking water because, as
discussed below, Site ground water flows to the Upper Merion
Reservoir which has been contaminated above acceptable drinking
water standards.  Therefore, the environment also has been
adversely affected due to releases from the Site.

Comment:  Kessler states that the Site is not a drinking water
source and relies on this statement to support its contention

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 that Alternative 2,   Natural  attenuation, should be preferred
 over Alternatives 3,  4, or  5.

 EPA Response:   The ground water under the Site  is not currently
 used as  a  drinking water source because it is too contaminated.
 In  its pristine condition,  it would be an excellent source  of
 drinking water.   The  aquifer  beneath the Kessler Site is
 classified as  a Class IIA Aquifer, a current source of drinking
 water in accordance with EPA  document "Guidelines for Ground
 Water Classification".  The Upper Merion Reservoir ("UMR")  which
 is  located approximately 3500 feet north of the Kessler Site,
 receives ground water from  this aquifer.  The water at the  UMR is
 currently  contaminated with many of the same contaminants which
 have been  released at the Kessler Site.  The operator of the  UMR
 uses air strippers to remove  contaminants from  the water.   The
 ground water beneath  the Site flows toward the  UMR.

 Comment: Kessler contends that because of the nature, land  use
 (present and future)  and risks at the Site that its preferred
 remedy of  "natural attenuation" should be selected by EPA.

 EPA Response:   Although the Kessler Site is located in an area
 where the  land surface is zoned for industrial  use, this does not
 in  any way preclude the use of the Site's ground water as
 drinking water,  now or in the future.  As discussed above,  the
 aquifer  beneath the Site is classified as a Class IIA Aquifer, a
 current  source of drinking  water.  Federal and  State requirements
 which are  ARARs  for actions to be taken at the  Kessler Site
 require  the removal of the  contaminants from the ground water as
 described  in detail in the  ROD.

 Comment:   Kessler states that Alternative 2, Natural Attenuation
 should be  the  preferred Alternative since the Site is located in
 an  area where  the ground water has been contaminated by other
 sources and that  VOCs may be migrating from other properties  to
 the  Site.

 EPA Response:  Chemical despoilation of the aquifer by several
 sources  is  an  illogical reason for the public to abandon this
 natural resource  as a contaminated ground water dump.  EPA  and
 PADER are  investigating and responding to the various possible
 sources of  chemical contamination in the area which will
ultimately  result  in the ground water being restored to its
beneficial  use.  The location of the Site in an  area zoned
 industrial, and the fact that other sources in the region may be
contributing to the contaminant levels in the large regional area
 is not a sound basis for leaving the contaminants in the ground
water at the Kessler Site.   Kessler's own data proves that  the
ground water beneath this Site is still contaminated at levels
that are two orders of magnitude greater than the Maximum
Contaminant Levels ("MCLs")  which are enforceable, health-based
drinking water standards established under the  Safe Drinking

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Water Act.

Comment: Kessler cites a "prepublication" release of a National
Research Council ("NRC") report, "Alternatives for Ground Water
Cleanup", which it says casts serious doubts on the efficacy of
pump and treat systems to achieve cleanup goals and to control
the migration of ground water contaminants.  It makes this
comment in support of its preference for Alternative 2, Natural
Attenuation, to address the contaminated ground water plume.

EPA Response: Nevertheless, good faith efforts are appropriate to
restore this natural resource.  Kessler's own pump and treat
efforts in the past have been successful in removing significant
contamination from the groundwater, as described above.  Similar
continued efforts are appropriate to recapature and remove the
contamination.

     Unfortunately, Kessler distorts the statements from the NRC
study pertaining to the efficacy of pump and treat technology.
The NRC Study does conclude that pump and treat systems, as
commonly used at many ground water contamination sites, may not
be able to completely restore a significant number of these sites
regardless of the technology employed (conventional or
innovative) due to site complexities.  However, at sites, such as
Kessler, where the remaining contamination in the ground water is
in a dissolved aqueous plume, the NRC study concludes that pump
and treat is capable of providing many benefits including:
cleanup of the aqueous contaminant plumes, containment, and mass
reduction.  The RI states on page 4-9 "These data, in addition to
the actual magnitude of VOC concentrations detected when compared
to solubility limits indicate that non-aqueous phase liquids are
not present, and that only dissolved phase VOCs have impacted the
ground water at the Site."

Comment:  Kessler states that Alternative 2, Natural Attenuation,
would control contaminant migration through attenuation and
degradation of the contaminants in the aquifer.  Kessler further
comments that Alternative 2 should be the preferred alternative
because it questions the efficacy of pump and treat technology.

EPA Response:  As discussed immediately above, Kessler's prior
pump and treat has proved capable of controlling the migration of
contaminated ground water at the Site.   In this case, "Natural
Attenuation" would mean that the chemical contamination would
just continue to spread, thereby affecting other portions of the
water system.  The FS states that Alternative 2 would not
preclude further movement of TCE in ground water.  Furthermore,
Kessler implies that pumping and treating will not achieve
cleanup levels when by its own calculations in the FS, Kessler
does predict that ground water pumping and treat will achieve
remediation.  This is consistent with EPA's conclusions, and
EPA's selected remedy.

-------
 Comment::   Kessler comments that the FS demonstrates that
 Alternative 2  is no less effective  in complying with ARARs  than
 any of other Alternatives.

 EPA Response:   The FS  does not demonstrate  that Alternative 2  is
 no  less effective in complying with ARARS than any  other
 Alternative.   Ignored  in this  statement was the State's ARAR
 which requires active  restoration of ground water.   Moreover,  the
 NCP and EPA's  ground water policy require that usable groundwater
 be  restored to its beneficial  uses  within a reasonable timeframe.


 Comment: Kessler states  that the estimated  timeframe for cleanup
 of  the aquifer under Alternative 2  would be within  a period of 2
 to  18 years (a median  of ten years).   The calculations in the  FS,
 for active pumping estimate 7  years to achieve the  same cleanup
 level.  Based  on this, Kessler contends that Alternative 2  should
 be  the preferred alternative since  the time period  to achieve
 remediation may be even  shorter or  may be longer.

 EPA Response:  The main question is  the issue of chemical
 contamination  in the Site ground water:  "natural attenuation"
 would not  remove this  contamination—it would just  spread out.
 Additionally,  EPA does not  accept Kessler's conclusions on  the
 ability of Alternative 2, Natural Attenuation, to achieve cleanup
 in  2  years.  Data generated over a  number of years  by Kessler
 does  not support a theory of rapid  biodegradation of the
 contaminants in the ground  water.   EPA believes it  is erroneous
 to  state that  Alternative 2, Natural  Attenuation, would achieve
 cleanup levels sooner  than  a remedy which also includes actively
 pumping and removing the contaminants.  Any possible
 biodegradation processes that  might reduce  contaminant
 concentrations in the  ground water  plume under Alternative  2
 would,  of  course,  also be occurring during  the pumping of the
 plume.  EPA does not accept the  calculations presented by Kessler
 on the  estimated efficacy of Alternative 2. Kessler's modeling of
 ground  water pumping overpredicts required  cleanup times and the
 equation used  to evaluate the  combined alternative of pumping  and
 decay is not correct.  Specifically,  the two separate exponential
 equations  cannot be  added to or  subtracted  from one  another to
 combine the effects  of pumping and  decay.

 Comment::   Kessler comments  that  Alternative  2 would  achieve a
 level of contaminant reduction in toxicity, mobility and volume
 comparable to  the levels that  may be  achieved by Alternative 3,
 4, and  5.

 EPA Response:  As  described in detail  in the ROD, EPA has
 concluded  that Alternative  2 is  not comparable to Alternatives 3,
 4 and 5 in its ability to reduce the  toxicity, mobility, and
volume  of  the  contaminants  in  the Site ground water.   Alternative

-------
 2 could not possibility reduce the toxicity in an equivalent
 timeframe.  As stated in the FS, Alternative 2 does not reduce
 the mobility of the contaminants in the Site ground water.
 Moreover, the size of the contaminant plume would increase,
 because it would be constantly spreading out thereby increasing
 the volume of ground water that is contaminated. The natural
 resource would be further damaged by the migration of the plume.

 Comment:  With respect to the evaluation criterion,"Short-term
 effectiveness," Kessler comments that Alternative 2 is superior
 to Alternatives 3, 4 and 5 with respect to short-term impacts.
 As EPA acknowledges, Alternatives 3, 4, and 5 all have short-term
 impacts related to dermal hazards... physical hazards . . . and
 potential hazards to onsite personnel.  Kessler also states that
 Alternative 2 has no adverse short-term impacts whatsoever.

 EPA Response:  It is unfortunate that chemical contamination
 exists in the Site ground water such that workers need to avoid
 exposure to it.  The criterion,"short-term effectiveness",
 addresses the period of time needed to achieve protection of
 human health and the environment and any adverse impacts that may
 be posed during the construction and operation period until
 remediation requirements are achieved.  Of course, implementing a
 remedy that includes construction would pose short-term risks
 that would not exist if this activity were not conducted.  The
 construction required under Alternatives 3, 4 or 5 would not pose
 unacceptable short-term risks to the community or workers during
 construction or implementation, particularly compared to any
 other construction project.   In addition, it is erroneous to
 state that Alternative 2 has no adverse short-term impacts
whatsoever.  The potential dermal contact hazards due to exposure
 to contaminated ground water would exist during the sampling of
 the ground water monitoring wells proposed under Alternative 2.
However, as stated in EPA's June 20, 1994 Proposed Plan on page
 11 and as described in detail in the ROD, these potential dermal
hazards can be easily controlled or minimized by the use of
protective gear when exposure to contaminated ground water
 occurs.
Comment:  Kessler comments that Alternative 2 is easily
implementable and can be instituted immediately.  It states that
Alternatives 3, 4, and 5 all would be more difficult, and would
require more time.

EPA's Response:  EPA agrees that those alternatives which require
actual construction are more "difficult" to implement than one
that proposes no construction and just sampling of existing
ground water monitoring wells.  The preferred remedy, Alternative
4 Ground Water Extraction And Treatment With GAC, is a proven
technology.  The materials and services needed to implement this
remedy are readily available, and the long-term benefits through

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 reduction of contamination are superior  to Alternative 2.


 Comments:  Kessler asserts that Alternative  2 can  attain the  sane
 level  of incremental risk reductions as  the  other  alternatives  at
 a much lower cost,  and therefore  is far  more cost  effective than
 Alternative 3,  4,  or 5.

 EPA's  Response: As discussed  above, Kessler's proposed
 alternative is  not protective  of  the environment because it does
 not remove contaminants from the  ground  water in a Class IIA
 aquifer which is a current source of drinking water.   Also as
 discussed above, EPA believes  it  is appropriate to recapture the
 contamination and  restore the  natural resource.  Because
 Kessler's proposed remedy would not meet ARARs and is  not
 protective of the  environment,  the threshold for analyzing the
 criterion of "cost effectiveness" has not been met.  A remedial
 action is to be cost effective, provided that it first satisfies
 the criteria of overall  protection of human  health and the
 environment and meets ARARs.
Comment: Kessler comments that EPA unlawfully preselected a pump
and treat alternative before completion of the RI/FS Report and
refers to an  informational meeting with the Township Supervisors
where EPA was discussing the findings of the draft RI/FS reports.

EPA'S Response:  EPA has attempted to keep the public fully
informed throughout this process, and has been very frank and
open concerning  the matters it was considering.  At the time of
the identified informational meeting with the Township
Supervisors,  EPA had reviewed the draft RI/FS Reports.  These
reports documented that the Class IIA Aquifer, a current source
of drinking water, was still contaminated at levels significantly
higher than drinking water standards and that the risk to human
health under  a potential future use scenario were unacceptable.
Because of these facts EPA believed at that point that some type
of active removal of the contaminants from the ground water in
the aquifer would be necessary.  This statement did not represent
a final determination on a remedy selection.   However,instead of
hiding this preliminary conclusion, EPA attempted to provide as
full information on its deliberations as possible.


The following comments were submitted by the Upper Merion
Township.

Comment:  The Township recommended that protection of human
health and the environment be achieved by adopting Alternative 3
or Alternative 4 and agrees with whichever EPA feels is best
suited as the remediation method.  The Township requested that
periodic monitoring reports be submitted to the Township

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Supervisors for review and comment and a copy of the Record of
Decision.

EPA Response:  EPA will provide the Township with periodic
monitoring reports.  A copy of the ROD will be provided to the
Township Supervisors.

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