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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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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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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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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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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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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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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("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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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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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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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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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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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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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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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
-------
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;
-------
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
-------
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.
-------
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.
-------
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
-------
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
-------
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.
-------
APPENDIX A
FIGURES
STANLEY KESSLER ROD
-------
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.
OCc CONESTOGA FM.
Ce ELBROOK FM.
Cl LEDGER FM.
Coh ANTIETAM foO HARPERS FMS.
Xwc WISSAHICKON FM.. ALBITE-CHLORITE SCHIST 0 2,000 4,000
SCALE
FEET
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:
/
-------
: . -" •-: ' : 4,4 Jt^c-it'dUbi^Mjlr *^*..^^'—A ". . •*• > ^^1
Water Table Contour
z./*c' /{(.'')/>.'n
-------
tfJj&MJ -^ " SW/50-3
t8 ll
eft X
«S *
\ ^
\ ' *
Pi
— - ^B
— .
— . . .
t
BM
CUP
ss*
SS/5B
swe
®
sw/sow
iF^
SURROUNOCD BT BOILAR03
STORU DRAM SEWER
FENCE UNC (CHAIN UHK; B' HIOH)
INTERMITTENT STREAM
CENTER UNE
BENCH MARK
CORRUGATED UET/M. PPE
SURFACE SCM.
SAUPUNO LOCATIONS
SURFACE * SUBSURFACE
SAUPUNQ LOCATIONS
SURFACE WATER
SAMPUNO LOCATION
SJRFACE WATER ft SEQUENT
SAMPLING LOCATIONS
FIGURE ;•;
son
8/.I
HHMBMK.
CUCH1
SI
uxxno"
UPI
SAC
(MUMNO 1
B/:
PDWCCT 1
OIJO
a***
-------
MM
Stanley Kessler Superfund Site
Areas of TCE Concentrations
Sfftd}
K»W»T
n-^
mA
("OW»)
V
IHOpil)
•
\
\
•
-FORMER DRUM
'STORAGE AREA (EAST)
<«**)
(i«»m
o
WCTRIC
nuwiraMiai
x
s
V
N'XNX'NNXN'N'SNN'XNNXX'S
rnnurn u»»rr
v* rwnnvcn wn^iK
^NEUTRALIZATION SYSTEM AREA
\
X
S
\
\
\
S
s
X
s
^
\
\
nwntn
1 STORY
MASONRY BUHOINQ
^
\
\
$
s
^
V
^
s
\
s
c
s
s
s
^
x
v\V>N
FORMER DRUM
STJJRAQEA*EA
-------
PRIMARY
SOURCES
PRIMARY
RELEASE
MECHANISM
Stanley Kessler
Packaging Plan!
I
1—•
ikomWutt _
Leaching komWutt
NMtrdMUonSyHtm
drums of
New Solvent
I Dip
Oegreaser
Spool
Degreaser
OrumSlongiAraai
(bottutmoved)
SECONDARY
SOURCE
IJ
L
SECONDARY
RELEASE
MECHANISM
Dust & Volatile L..
Emissions |
PATHWAY
*[_*• i
t
JoTl
iln»|
tmmmm
Inimr
Leac
aiion 1 T
lung r\.
Surface &
Slormwater
Runoff
••••
Groundwaier
Surface
Water
Surface
Sediments
POTENTIAL
EXPOSURE
Ingestlon
Inhalation
Ingestlon
Dermal
Contact
Ingestlon
Inhalation
Dermal
Contact
Ingestlon
Inhalation
Dermal
Contact
Ingesllon
Inhalation
Dermal
Contact
POTENTIAL RECEPTOR
HUMAN
Residential Industrial
Neighbors
.
*
*
*
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.
.
.
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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
-------
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
-------
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
-------
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
-------
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
-------
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.
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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
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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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