United Stales         Office of
           Environmental Protection   Emergency and
           Agency           Remedial Response
EPA/ROD/R02-91/158
September 1991
<&EPA  Superfund
          Record of Decision:
          Swope Oil & Chemical, NJ

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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R02-91/158
4. TWe «nd Subtitle
SUPERFUND RECORD OF DECISION
Swope Oil i Chemical, NJ
Second Remedial Action
7. Authors)
9. Performing Organization Nun* and Address
12. Sponsoring Organization Nun* and AddreM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
i. Report Dste
09/27/91
6.
8. Performing Organization Rspt. No.
10. Pro|ecVTaak/Work Unit No.
11. ContncttC) or Gr«nt(G) No.
(C)
(O
13. Type 04 Report • Period Covered
800/000
14.
 15. Supplementary Hotet
 16. Abstract (UmH: 200 words)
   The 2-acre Swope  Oil s Chemical site  is  a  former chemical reclamation  facility in
   Pennsauken, Camden County,  New Jersey.   Land use in the area is predominantly
   commercial and  industrial,  and Pennsauken  Creek lies 0.8 miles northeast of the site.
   The estimated 10,000 residents use ground  water from a public supply well screened in
   the lower underlying aquifer near the  site as their drinking water  supply.   At the
   time site operations ceased, pertinent site features included a main building,
   distilling house,  diked tank farm, open  drum storage area, and an unlined lagoon.
   From 1965 to 1979,  Swope Oil & Chemical  used the site for the reclamation of
   chemicals.  Site  operations included buying,  selling, manufacturing, and processing
   oils,  chemicals,  and paints, and discharging waste liquids and sludge  to an
   excavated, unlined lagoon.   Contaminated material also was contained within a diked
   tank farm and an  exposed drum storage  area.  In 1975, State investigations showed
   that discharge  of wastes to onsite drainage ditches had resulted in probable
   migration of chemicals to Pennsauken Creek via storm sewers.  The owners were cited
   for several disposal violations in 1975, and again in 1979, when the site operations
   ceased.  Beginning in 1984, PRPs removed drummed wastes and 3,000 tons of lagoon

   (See Attached Page)
 17. Document Analysis ft, Descriptors
   Record of Decision - Swope Oil  &  Chemical,  NJ
   Second Remedial Action
   Contaminated Medium:  soil
   Key Contaminants:  VOCs  (PCE, TCE),  other organics  (DEHP,  naphthalene)
   b. Identifiers/Open-Ended Term»
   e. COSATI Raid/Group
18. Availability Sutement
it. Security CUM (This Report)
None
20. Secwfty CUM flhta Page)
None
21. No. ol Pages
134
22. Price
(S*M ANSi.209.ie)
                                     S«# Instruction* on ft»
OPTIONAL rORU 272 (*-77)
(Formtily NTIS-35)
Dtportnwnt of Comnwrce

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EPA/ROD/R02-91/158
Swope Oil & Chemical, NJ
Second Remedial Action

Abstract (Continued)

sludge, and also fenced the perimeter of the site.  Later in 1984,  air strippers were
installed by the water commission on Municipal Well 1 to remove VOC contamination
detected in the aquifer.  A 1985 Record of Decision (ROD)  provided for removal,  offsite
disposal, and treatment of storage tanks and their contents; demolition of onsite
buildings;  and excavation and offsite disposal of PCB-contaminated soil and sludge area
material.  This ROD addresses remediation of subsurface soil,  which continues to leach
contaminants into ground water,  as Operable Unit 2.  Future actions will evaluate
whether further source control measures or ground water actions are necessary.   The
primary contaminants of concern affecting the soil are VOCs including PCE and TCE,  and
other organics including DEHP and naphthalene.

The selected remedial action for this site includes treating onsite approximately
153,000 cubic yards of contaminated unsaturated soil using in—situ vacuum extraction
with potential enhancement of biodegradation of soil contaminants,  if the results of the
treatability study so warrant; treating air emissions using carbon adsorption or thermal
destruction prior to discharge,  if necessary; and monitoring soil and ground water.  The
estimated present worth cost for this remedial action is $2,099,000,  which includes
estimated O&M costs of $397,500 for year 1 of the vapor extraction system and $234,200 a
year for 5 years of ground water monitoring.

PERFORMANCE STANDARDS OR GOALS:   Chemical-specific soil clean-up goals are based on New
Jersey Interim Soil Action Levels and include 1 mg/kg for total VOCs and 10 mg/kg for
semi-volatiles, and are designed to mitigate the threat of ground water contamination.

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                          ROD FACT SHEET
SITE

Name:
Location/State:
EPA Region:
MRS Score  (date)
NPL Rank (date) :

ROD

Date Signed:

Selected Remedy

Subsurface Soil:
Capital Cost:
O & M  (Vapor
Extraction System):
O & M  (Groundwater
Monitoring Program):
Present Worth:

LEAD
Swope Oil and Chemical Company
Pennsauken Township,  Camden Co.,  New Jersey
II
35.68 (August '82)
657 (March 1991)
September 27, 1991
In-place treatment, utilizing soil vapor
extraction with biodegradation, of
contaminated subsurface soil.

$   687,500

$   397,500 (first year)

$   234,200 (five years)
$ 2,099,000
Enforcement, EPA
Primary Contact (phone):  Joseph Cowers (212-264-5386)
Secondary Contact  (phone):  John La Padula  (212-264-5388)
WASTE

Type:


Medium:

Origin:
Subsurface Soil - VOC's & Semi-VOC's
Groundwater - VOC's.

Soil and Groundwater.

Pollution originated as a result of
operations conducted at the Swope Oil and
Chemical Company.  The chemical reclamation
operation conducted at this facility
resulted in the on-site storage and
disposal of hazardous materials.

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                      DECLARATION STATEMENT

              RECORD 07 DECISION - OPERABLE UNIT TWO

                  8WOPB OIL AND CHEMICAL COMPANY
SITB NAME AKP LOCATION

Svope Oil and Chemical Company
Pennsauken Township, Camden County/ New Jersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for
the Swope Oil and Chemical Company site, which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act of
1986, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan.  This decision
is based on the administrative record for the site.  The attached
index identifies the items that comprise the administrative
record upon which the selection of the remedial action is based.

The New Jersey Department of Environmental Protection and Energy
concurs with the selected remedy.

ASSESSMENT O7 THE SITE

Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.

DESCRIPTION OF THE SELECTED REMEDY

The remedy described in this document represents the second
operable unit for the Swope site.  Cleanup actions under the
first operable unit have resulted in the removal of buildings,
tanks, sludge and contaminated surficial soils from the site.
This remedy will address contaminated subsurface soils which are
acting as a source of groundwater contamination.  The treatment
of these subsurface soils is expected to mitigate the site's
contribution to groundwater contamination, thereby addressing the
principal threat to public health remaining at the site.
Subsequent to completion of the selected remedy, EPA will
determine whether it provides for adequate protection of
groundwater, as well as the need for further source control or
groundwater remedial measures.

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The major components of the selected remedy include the
following:

- In-place treatment, utilizing soil vapor extraction with
  biodegradation, of contaminated subsurface soils; and

- Implementation of a groundwater monitoring program, for a
  period of five years, to assess the effectiveness of the remedy
  and to evaluate whether groundwater remediation is warranted.


STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective.  This remedy utilizes
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element.

A review will be conducted within five years after commencement
of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
            Sidamon-Eris^o'ff
Regional Administrator
Date

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                        TABLE OF CONTENTS
SECTION                                                    PAGE

SITE NAME AND LOCATION	    1
SITE HISTORY AND ENFORCEMENT ACTIVITIES	    1
HIGHLIGHTS OF COMMUNITY PARTICIPATION	    3
SCOPE AND ROLE OF OPERABLE UNIT TWO WITHIN SITE STRATEGY..    4
SUMMARY OF SITE CHARACTERISTICS	    5
SUMMARY OF SITE RISKS	   10
SCREENING OF REMEDIAL TECHNOLOGIES	   14
SUMMARY OF REMEDIAL ALTERNATIVES	   17
EVALUATION OF ALTERNATIVES	   20
SELECTED REMEDY	   24
STATUTORY DETERMINATIONS	   26
DOCUMENTATION OF SIGNIFICANT CHANGES	   28

APPENDICES              -

APPENDIX A.  FIGURES
APPENDIX B.  TABLES
APPENDIX C.  ADMINISTRATIVE RECORD INDEX
APPENDIX D.  NJDEPE LETTER OF CONCURRENCE
APPENDIX E.  RESPONSIVENESS SUMMARY

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                         LIST OF FIGURES
Number          Name
  1             Swope oil and Chemical Company Site Location Map
  2             Swope Oil and Chemical Company Site Hap

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                         LIST OF TABLES

Number         Name

  1            Deep Soil Boring  Results

  2            Summary of Volatile  Organic  Compounds Detected in
               Groundwater

  3            Summary of Semi-Volatile  Organic Compounds
               Detected in  Groundwater

  4            Summary of Inorganic Compounds  Detected in
               Groundwater  (Unfiltered Samples)

  5            Occurrence of Constituents in the Shallow Aquifer
               Upgradient of the Swope Oil  and Chemical Company
               Site,  Pennsauken,  New Jersey.	

  6            Occurrence of Constituents in the Shallow Aquifer
               Downgradient of the  Swope Oil and Chemical Company
               Site,  Pennsauken,  New Jersey.

  7            Acceptable Doses  (ADs), Cancer  Slope Factors
               (CSFs), and  USEPA Cancer  Classification for
               Constituents of Concern at the  Swope Oil and
               Chemical Company  Site,  Pennsauken,  New Jersey.

  8            Noncarcinogenic Risk Estimates  (Hazard Indices)
               for the Swope Oil and Chemical  Company Site

  9            Carcinogenic Risk Estimates  for the Swope Oil and
               Chemical Company  Site

  10           Remedial Action Alternative  1 - No Action,
               Detailed-'Cost Analysis, Swope Oil and Chemical
               Company Site, Pennsauken,  New Jersey.

  11           Remedial Action Alternative  2 - Soil Vapor
               Extraction with Aerobic Biodegradation, Detailed
               Cost Analysis,  Swope Oil  and Chemical Company
               Site,  Pennsauken,  New Jersey.

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                         DECISION SUMMARY

              RECORD Or DECISION - OPERABLE UNIT TWO

                  8WOPB OIL AND CHEXICAL COMPANY
SITE NAME. LOCATION. AKD DESCRIPTION

The Svope Oil and Chemical Company (Svope) site is located at
8281 National Highway, in an industrialized area in the Township
of Pennsauken, Camden County, New Jersey.  Route 130 passes
approximately 1800 feet southeast of the site (Figure 1).

The Swope site, approximately two acres in size, is bounded to
the southeast by National Highway, and to the north and southwest
by railroad rights-of-way and warehouses  (Figure 2).  Numerous
commercial and industrial properties are located within 0.5 mile
of the site in all directions.  The Pennsauken Municipal Landfill
is located approximately 750 feet to the northwest.  The nearest
residential areas are in the Townships of Delair and Morrisville,
which are located about 0.5 mile west and 0.8 mile southwest of
the site, respectively.  Pennsauken High School is located
approximately 0.5 mile to the northeast.

The Swope site is underlain by the Potomac-Raritan-Magothy (PRM)
Aquifer System, which is the major source of potable groundwater
in the area.  Two water supply wells, operated by the
Merchantville-Pennsauken Water Commission, MPWC Well 1 and MPWC
Well 2, are located approximately 275 feet southwest and 1500
feet northeast of the site, respectively.  In addition, other
water supply wells are located throughout Pennsauken Township.
Only the lower aquifer of the PRM Aquifer System is used as a
source of potable groundwater in the vicinity of the site.

The nearest body of surface water is the Pennsauken Creek, which
is located 0.8 mile northeast of the site.  Pennsauken Creek
flows in a northwesterly direction to the Delaware River,  which
is located about 1.2 miles northwest of the site.

The Swope site is flat with no discernable surface features,
except a security fence which restricts site access.  Subsurface
features, including underground storage tanks, septic tanks and
septic lines, were removed during prior remedial activities.

SITE HISTORY AKD ENFORCEMENT ACTIVITIES

From 1965 to 1979, the Swope Oil and Chemical Company operated a
chemical reclamation facility at the site.  Facility operations
included buying, selling, manufacturing, and processing oils,
chemicals, and paints.  Materials believed to have been processed
at the site include phosphate esters, hydraulic fluids, paints
and varnishes, solvents, oils, plasticizers, and printing ink.
During operation of the facility, waste liquids and sludges were

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discharged to an excavated,  unlined lagoon.   Contaminated
material was also contained  within a diked tank farm and an
exposed drum storage area.   When the facility ceased operating,
significant site features included a main building,  a distilling
house, a diked tan\ farm, an open drum storage area, and an
unlined lagoon.

In 1975, an inspector from the State Bureau  of Air Pollution
visited the site and recommended that the Bureau of Water
Pollution Control inspect the site.  In subsequent visits,
officials observed discharges to drainage ditches on the site and
probable migration towards Pennsauken Creek  via storm sewers.
The Swope Oil and Chemical Company was cited in 1975 for
operating without proper permits, and again  in 1979 for failure
to prepare, maintain, or fully implement a Spill Prevention,
Control and Countermeasures  Plan.  The company ceased operation
in December 1979.

On October 17, 1983, a State Superfund Contract was signed by the
United States Environmental  Protection Agency (EPA)  and the New
Jersey Department of Environmental Protection (NJDEP) which
provided funds for the performance of a Focused Feasibility Study
on the drums and lagoon waste.  This study was completed in
February 1984.

On May 14, 1984, a group of  potentially responsible parties
(PRPs) entered into an Administrative Order  on Consent with EPA
to conduct the remedial activities recommended in the Focused
Feasibility Study.  Pursuant to this order,  drummed waste and
3,000 tons of lagoon sludge  were removed from the site.  In
addition, a fence was constructed around the site to restrict
access and to prevent the public from coming into direct contact
with the contaminants.

In Hay 1984, MPWC Well 1 was shut down due to the detection of
contamination in the well.   Since area-wide  groundwater
contamination occurs in the  vicinity of MPWC Well 1, the
Merchantville-Pennsauken Water Commission equipped the well with
an air stripper to remove volatile organic compounds from
groundwater, and returned the well to service in January 1989.
Approximately 10,000 residents use water from this well.

A Remedial Investigation and Feasibility Study (RI/FS) were
conducted by NUS Corporation for EPA from February 1984 to June
1985 in order to determine the nature and extent of contamination
at the Swope site and to evaluate appropriate remedial
alternatives.  Based upon the findings of this RI/FS, a Record of
Decision (ROD) was signed by EPA on September 27, 1985.  This ROD
specified a remedy for surficial contamination and provided for
the performance of a Supplemental RI/FS to address groundwater
contamination.

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In August 1986, EPA entered into an Administrative Order on
Consent with a group of 15 PRPs for the performance of the remedy
for surficial contamination specified in the ROD.  In September
1986, 8 PRPs entered into a separate Administrative Order on
Consent with EPA for the performance of the Supplemental RI/FS
and for the design and installation of a cap at the site.

In September 1987, ERT, a contractor for the PRPs, implemented an
extensive sampling and analysis program to characterize both on-
site and off-site soil contamination to a depth of approximately
18 inches, as well as tank contents.  Data obtained during this
sampling event were utilized to develop the engineering
specifications for the surficial remediation program.

On September 17, 1988, ERT initiated the remedial action program
to address surficial contamination at the site.  Activities
conducted as part of this program included the following:

- the removal and off-site disposal of tanks, with off-site
  treatment or incineration of tank contents,

- the demolition of on-site buildings,

- the excavation and off-site disposal of up to 1.5 feet of
  contaminated soil containing polychlorinated biphenyls
  (PCBs) at concentrations greater than 5 parts per million
  (ppm), and

- the excavation and off-site disposal of visibly contaminated
  material from the buried sludge area of the site.

The surficial remedial action program was completed by August
1989.  Subsequent to excavation, certified clean backfill
material was utilized to bring the site up to grade.  The
installation of a cap, which was a remedial activity specified by
the 1985 ROD, was postponed to provide for the installation of
monitoring wells and the performance of treatability studies
during the Supplemental RI/FS.

The Supplemental RI/FS for the Swope site was initiated in
October 1988 to evaluate the nature and extent of groundwater and
subsurface soil contamination at the site and to develop
appropriate remedial alternatives.

HIGHLIGHTS OP COMMUNITY PARTICIPATION

The Supplemental RI/FS Report and Addenda, and the Proposed Plan
for the Swope site were released to the public for comment on
July 18, 1991.  These documents were made available to the public
in two information repositories maintained at the Pennsauken
Municipal Building and the Pennsauken Township Library.  The
notice of availability of these documents was published in the

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Philadelphia Inquirer on July 18,  1991.   As part of EPA's public
participation responsibilities under Section 117 of the
Comprehensive Environmental Response,  Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986, a public comment period on these
documents was held from July 18,  1991 to August 17, 1991.  In
addition, a public meeting to discuss the findings of the
Supplemental RI/FS and to present EPA's  preferred alternative to
the public was held on August 1,  1991.  Comments which were
received by EPA during the public comment period are addressed in
the Responsiveness Summary which  is attached to this Record of
Decision.
SCOPE
AND ROL.R Of OPE!
The cleanup of the Swope site is being addressed in discrete
phases referred to as operable units (OUs).   They are described
as follows:

- OU 1:     Remediation of contaminated surface soil, sludges,
            tanks, tank contents,  and buildings, and

- OU 2:     Remediation of contaminated subsurface soil which
            continues to act as a source of  groundwater
            contamination.

The OU 1 remedy, except for installation of  a cap over the site,
has been completed.  This remedy has addressed potential threats
to human health which may have resulted due  to ingestion of, or
dermal contact with surficial contamination.  Additionally, this
remedial action has resulted in the removal  of surficial
contaminants from the site, which were, or had the potential of,
acting as a source of contamination of groundwater beneath the
site.  The objective of OU 2, which is the subject of this
document, is to mitigate the leaching of organic subsurface soil
contaminants into the groundwater.  The selected remedy will
remove and/or degrade volatile and semi-volatile organic
contaminants in subsurface soil, thereby decreasing the amount of
contaminants which may leach to the groundwater underlying the
site.  EPA further believes that remediation of subsurface soil
contamination will result in a significant reduction in the
levels of site-related groundwater contamination.  Since the OU 2
remedy is expected to decrease migration of  volatile and semi-
volatile compounds from site soil into the groundwater, EPA has
postponed a decision regarding the necessity of installation of
the OU 1 cap until after implementation of the selected source
control remedy.  If it is determined that a  cap is not required,
this approach would allow for a greater degree of unrestricted
future usage of the site.

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The results of groundwater samples collected as part of the
Supplemental RI indicate that the Swope site has contributed
volatile organic contaminants to the shallow aquifer beneath the
site, and may have contributed to the contamination of the deep
aquifer.  These results further indicate that other sources of
groundwater contamination exist upgradient of the Swope site.
Since EPA believes that the selected remedy will result in a
significant reduction of site-related groundwater contamination,
EPA has decided to postpone any decision regarding groundwater
remedial measures, until the selected source control remedy has
been completed.

Subsequent to completion of the selected remedy, EPA will
determine whether it provides for adequate protection of
groundwater and whether further source control measures, such as
capping, or if groundwater remedial measures are necessary.

SUMMARY OF SITE CHARACTERISTICS           _    	      _

Site Oeolocry

The Swope site is located within the Atlantic Coastal Plain
physiographic province, which is underlain by a wedge of
unconsolidated sediments that thickens and dips to the southeast
toward the Atlantic Ocean.  However, because the sediments
thicken as-they dip, the shallower sediments dip less than the
deeper sediments.

The unconsolidated sediments in the vicinity of the Swope site
are comprised of the Pleistocene-age Pennsauken Formation, which
is underlain by the Cretaceous-age Magothy and Raritan Formations
and the Potomac Group.  The Swope site is located within the
outcrop of the Potomac Group and the Magothy and Raritan
Formations. . The Cretaceous-age sediments comprise the Potomac-
Raritan-Magothy Aquifer System, and these sediments lie on
bedrock.  At the Swope -site, the upper 25 to 30 feet of the
unsaturated zone, which represents the Pennsauken Formation, is
composed of silty sand, with lenses of glaucontic sand, clay and
some gravel.  The remainder of the unsaturated zone and the
shallow water-table aquifer, which was encountered during the
Supplemental RI at depths ranging from 76 to 82 feet below land
surface, consist of medium to coarse grained sand and gravel from
the Raritan and Magothy Formations.

A semi-confining unit, consisting of clay with interbedded lenses
of fine grained sand, was encountered at depths ranging from 132
to 157 feet below land surface.  Below this unit, Potomac Group
sediments, consisting of medium to course grained sand and
gravel, comprise the deep aquifer.  These sediments are underlain
by bedrock.

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Subsurface Soil

As part of the Supplemental RI,  ten deep soil borings were
drilled to the water table (approximately 80  feet below land
surface) and subsurface soil samples were collected at five
different depths.  The results of this sampling event are
presented in Table 1.

Volatile organic compounds constituted the contaminants detected
most frequently and at the highest concentrations in subsurface
soil.  Volatile organic contaminants detected most frequently and
at the greatest concentrations include acetone, toluene, xylene,
ethylbenzene, 4-methyl-2-pentanone, trichloroethene,
tetrachloroethene and 2-butanone.  The maximum total volatile
organic concentration (3,991 milligrams per kilogram (mg/kg)) for
soil not remediated during the OU 1 remedial  action was detected
in a sample collected from boring B-6 at 14 to 16 feet.  Elevated
levels of volatile organic compounds were also detected in      _
subsurface soil samples collected from borings B-4 (81 mg/kg),  B-
5 (291 mg/kg), B-8 (797 mg/kg) and B-9 (17 mg/kg).

Additionally, elevated levels of semi-volatile organic
contaminants were also detected.  Semi-volatile organic
contaminants detected most frequently and at  the greatest
concentrations include bis(2-ethylhexyl)phthalate, naphthalene,
phenol and isophorone.  The highest concentration of semi-
volatile organic contaminants (275 mg/kg) was detected in a
sample collected from boring B-8 at 6 to 8 feet.  Elevated levels
of semi-volatile organic compounds were also  detected in samples
collected from borings B-4 (109 mg/kg), B-5 (42 mg/kg) and B-6
(229 mg/kg).   Since borings B-5 and B-6 were installed within
the former lagoon area, and borings B-8 and B-9 were installed in
the former buriel sludge area of the site, these results indicate
that subsurface soil contamination at the Swope site is due to
the past storage and waste disposal practices of the Swope Oil
and Chemical Company.  ',

The concentrations of inorganic constituents  in subsurface soil
were generally low, with the exception of arsenic and silver,
which were each found at elevated levels in only one of fifty-
five subsurface soil samples.  Arsenic was detected in a sample
collected from boring B-3 from 29 to 31 feet, at a concentration
of 23 mg/kg.  Silver was detected in a sample collected from
boring B-10 from 59 to 61 feet,  at a concentration of 7 ag/kg.
Additionally, nickel and zinc were detected at elevated
concentrations in one of two replicate samples collected from
boring B-9 from 84 to 86 feet, but not in the duplicate sample
collected from this location.  Polychlorinated biphenyls were
detected in two subsurface soil samples collected from the lagoon
area.  PCBs were detected at a concentration  of 0.19 mg/kg and
0.93 mg/kg in soil samples collected from borings B-5 at 6 to 8
feet and B-6 at 6 to 8 feet, respectively.

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.Subsurface  soil samples vere not collected from the area of the
former tank farm  (Figure 2) at the time that the Supplemental RI
soil boring program was conducted, because EPA was of the opinion
that this area was underlain by a concrete pad.  During
performance of the OU 1 remedial action, it was determined that a
concrete pad, which would have served to mitigate the
infiltration of contaminants into soil in this area, did not
exist beneath the tank farm.  Therefore, the extent of subsurface
soil contamination in this area is unknown.

The results of chemical analyses on subsurface soil samples
indicate that volatile and semi-volatile organic contamination
extends vertically to the water table, located approximately 80
feet below  land surface.  These sampling results further indicate
that volatile organic contaminants were primarily detected at
levels greater than the New Jersey Interim Soil Action Level
(NJISAL) of 1 mg/kg for total volatile organics, to a depth of
approximately 50 feet below land surface.  It should be noted,
however, that volatile organic contaminants were detected at
concentrations above 1 ing/kg at depths greater than 50 feet in
subsurface  soil samples collected from boring B-l at 74 to 76
feet and B-5 at 59 to 61 feet and 77 to 79 feet.  Semi-volatile
organic contaminants were detected at levels greater than the
NJISAL of 10 mg/kg for total semi-volatile organics to a depth of
approximately 30 feet below land surface.

Groundvater

Groundvater samples were collected from both the shallow
unconfined  and deep semi-confined aquifers.  A total of 18
monitoring  wells and public supply well MPWC 1 were sampled
during two  sampling rounds.  Fifteen of these monitoring wells
were sampled as part of the first sampling round in October and
December of 1989.  All 19 wells, including four downgradient
monitoring  wells installed after the first sampling round, were
sampled during January 1990.  Additionally, metals samples were
collected from all 19 wells in May 1990 and analyzed for total
metals, since samples were filtered during the first two sampling
rounds.

Volatile organic contaminants were detected in all veils screened
in both the shallow and deep aquifer underlying the Swope site.
The ranges  of concentrations of specific volatile organic
compounds detected in upgradient and downgradient wells are
provided in Table 2.

During the  first sampling round, the levels of total volatile
organics detected in shallow upgradient wells ranged from 37
micrograms  per liter (ug/1) (well GM-6S) to 114 ug/1 (well GM-
5S).  The levels of total volatile organics detected in shallow
wells located on site ranged from 60 ug/1  (well MW-l) to 443 ug/1
(well CM-IS).  Total volatile organics were detected at

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concentrations ranging from 5 ug/1 (well GM-6S)  to 128 ug/1 (well
GM-5S) in shallow upgradient wells,  and from 45  ug/1 (well MW-1)
to 676 ug/1 (well GM-8S)  in on-site  and downgradeent shallow
aquifer wells during the second sampling round.   These sampling
results clearly indicate that higher concentrations of volatile
organic contaminants were detected in shallow wells located on
and downgradient of the site than in samples taken from wells in
the shallow aquifer located upgradient from the  site.  These data
support the conclusion that the Swope site has contributed to the
contamination of shallow-aquifer groundwater.

The groundwater quality data presented in Table  2 indicate that
some specific volatile organic compounds are present in shallow-
aquifer groundwater at greater concentrations on and downgradient
of the Swope site than upgradient.  These contaminants include
1,1-dichloroethene, 1,1-dichloroethane, 1,2-dichloroethene, 1,2-
dichloroethane, 1,1,1-trichloroethane, toluene,  trichloroethene,
tetrachloroethene, ethylbenzene and  xylene.  Of  these compounds,
1,1-dichloroethene, 1,2-dichloroethene, 1,2-dichloroethane,
1,1,1-trichloroethane,  trichloroethene, tetrachloroethene, and
xylene were detected at levels which exceeded Federal and/or
State Maximum Contaminant Levels (MCLs).  Of the volatile organic
compounds detected in upgradient shallow aquifer wells, 1,1-
dichloroethene, 1,2-dichloroethene,  chloroform,  1,2-
dichloroethane, and trichloroethene  were detected at
concentrations exceeding Federal and/or State MCLs.

The concentrations of total volatile organic contaminants
detected during the first sampling round in deep wells located
upgradient of the site ranged from 227 ug/1 (well GM-2D) to 331
ug/1 (GM-5D).   During this sampling  round, volatile organic
compounds were found in on-site and  downgradient deep wells at
concentrations ranging from 310 ug/1 (well MPWC  1) to 367 ug/1.
(well GM-3D).   During the second sampling round, total volatile.
organic contaminants were detected at levels ranging from 14 ug/1
(well GM-2D) to 331 ug/i (well GM-5D) in upgradient wells
screened in the deep aquifer, and from 24 ug/1 (well GM-8D) to
279 ug/1 (well GM-4D) in deep wells  located on and downgradient
of the site.

The deep-aquifer groundwater quality data presented in Table 2
indicate that specific volatile organic compounds were detected
at marginally higher concentrations  in on-site and downgradient
wells than in upgradient wells.  These compounds include vinyl
chloride, 1,1-dichloroethene, 1,2-dichloroethene, 1,2-
dichloroethane, 1,1,1-trichloroethane and benzene.  All of these
compounds, with the exception of 1,1,1-trichloroethane, were
detected at levels which exceed Federal and/or State MCLs.  Of
the volatile organic compounds which were found  in deep wells
located upgradient of the site, 1,1-dichloroethene, 1,2-
dichloroethene, chloroform, 1,2-dichloroethane,  carbon
tetrachloride, trichloroethene, and  tetrachloroethene were

                                8

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detected at concentrations in excess of Federal and/or State
MCLs.  The fact that some vocs were found in the deep aquifer at
higher levels in samples taken from on-site and downgradient
wells than in upgradient wells suggests that the Swope site may
be contributing to the contamination of the deep aquifer.

Semi-volatile organic compounds were detected in groundwater
samples from both the shallow and deep aquifers.  The maximum
concentration of total semi-volatile organics was 146 ug/1,
detected in deep downgradient well GM-7D.  Of the semi-volatile
organics, only bis(2-ethylhexyl)phthalate exceeded its New Jersey
State MCL (5 ug/1) in shallow upgradient well GM-5S (11 ug/1) and
deep downgradient well GM-7D (130 ug/1).  A summary of the semi-
volatile organic data is presented in Table 3.

As displayed in Table 4, arsenic, chromium, lead and mercury were
detected at concentrations which exceed Federal and/or State MCLs
or Action Levels.  Arsenic was detected above the Federal and
State MCL of 50 ug/1 in only one well, CM-IS, at a concentration
of 78.6 ug/1.  Chromium was detected in upgradient shallow
aquifer well GM-5S (77.5 ug/1)  and in on-site and downgradient
shallow wells GM-7S (123 ug/1), GM-8S  (88.5 ug/1) and MW-2 (135
ug/1) at concentrations above the State MCL of 50 ug/1.
Additionally, chromium was detected above the New Jersey State
MCL in one upgradient deep well, GM-5D (54.1 ug/1).  Lead was
measured at a concentration above the Federal Action Level of 15
ug/1 in on-site and downgradient shallow wells MW-2 (52.2 ug/1),
MW-4 (17.9 ug/1), GM-7S (23.1 ug/1) and GM-8S (22.5 ug/1), and
upgradient deep well GM-6D (17.4 ug/1).  Mercury was present in
groundwater from shallow on-site well MW-4 (6.0 ug/1) at a
concentration in excess of the Federal and New Jersey State MCL
of 2 ug/1.  Mercury was also detected at concentrations slightly
greater than the MCL in on-site and downgredient deep wells GM-7D
(2.4 ug/1) and MPWC 1 (2.9 ug/1).

Iron and manganese were--found in groundwater at levels which
exceeded secondary Federal and/or State MCLs.  Iron was detected
in all wells at concentrations in excess of the MCL of 300 ug/1,
except wells MW-1 and MPWC 1.  Manganese was detected at
concentrations in excess of the MCL of 50 ug/L in all wells
except well GM-6S.

Summary

In summary, subsurface soil sampling results indicate that
volatile and semi-volatile organic contaminants are present in
the unsaturated zone,  primarily in areas of the site which were
used for the storage and disposal of liquids and sludges during
facility operations.   Furthermore, shallow aquifer groundwater
sampling results indicate that the concentrations of volatile
organic contaminants,  many of which occur in subsurface soil, are
greater on and downgradient of the site than upgradient.  Based

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upon the data, it was concluded that contaminants  in the soil at
the Svope site are migrating into the shallow aquifer
groundwater.  Groundwater quality data further suggest that
contaminants in the soil at the Svope site may be  migrating into
the deep aquifer.  The detection of volatile  and semi-volatile
organics in shallow and deep wells screened upgradient of the
Swope site, as well as in monitoring wells at facilities located
hydrologically side-gradient of the site,  indicates that the
Swope site is contributing to a larger regional groundwater
contaminant plume.

Due to the continuing migration of volatile organic compounds
into the groundwater and the potential for the migration of semi-
volatile organic compounds into groundwater,  soil  contamination
in the unsaturated zone is of concern.  Specifically, soil which
contain organics at levels which exceed the NJISALs of 1 mg/kg
for total volatile organic contaminants and 10 mg/kg for total
semi-volatile organic contaminants may pose a threat to
groundwater quality.  Approximately 153,000 cubic  yards of soil
are contaminated above these cleanup levels.

Generally, inorganic compounds were detected  at low levels in
unsaturated soil.  Except for arsenic, inorganics  detected above
MCLs in groundwater were not detected at levels of concern in any
of the subsurface soil samples.  Arsenic was  detected in only one
subsurface soil sample in excess of the NJISAL of  20 mg/kg.

Sporadic occurrences of lead, mercury and arsenic  at levels in
excess of primary MCLs and/or Action Levels were observed during
the May 1990 groundwater sampling round.  Of  the metals which
were detected in groundwater during this sampling  round, only
chromium and lead were detected above a primary MCL or Action
Level in more than one shallow well.  The detection of elevated
levels of chromium in a shallow upgradient well and in monitoring
wells located at facilities which are hydrologically side-
gradient of the Swope site may indicate the presence of an
upgradient source.  __           _                 .•_.._

SUMMARY 07 SITE RISKS

A baseline Risk Assessment was conducted to evaluate potential
site-related risks to human health and the environment which may
result if no remedial action is taken.  The Risk Assessment for
OU 2 focuses on risks posed by contaminants detected in
groundwater.  The following discussion summarizes  the findings of
the Risk Assessment, as amended by EPA's Addendum  to the
Supplemental Feasibility Study and Risk Assessment.

As stated previously, the site and surrounding properties are
currently zoned for industrial use.  The nearest residential
areas to the Swope site are in the Townships  of Delair and
Morrisville, which are located approximately  0.5 mile west and

                                10

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0.8 mile southwest of the site, respectively.  In addition,
Pennsauken High School is located approximately 2000 feet to the
northeast.  Although Pennsauken High School land is zoned for
residential use, development of residential dwellings on this
land in the near future is not expected.

The Risk Assessment, as amended, identifies several potential
exposure pathways by which the public may be exposed to site-
related contaminants.  The following potential exposure routes
were identified:

 (1) Dermal contact with shallow aquifer groundwater by
     future industrial workers while handwashing;

 (2) Ingestion of groundwater by an industrial worker from a
     hypothetical potable well installed in the shallow aquifer
     downgradient of the site;

 (3) Ingestion of groundwater by a resident from a
     hypothetical potable well installed in the shallow aquifer
     downgradient of the site; and

 (4) Showering by a resident using water from a hypothetical
     potable well installed in the shallow aquifer downgradient
     of the site.

Risks associated with dermal contact and ingestion of site soil
were not quantified in this assessment.  It should be noted,
however, that as part of the OU 1 remedial action, up to 1.5 feet
of contaminated soil was removed from most of the site.  In
addition, sludge and visibly contaminated soil were removed to a
depth of approximately 10 feet.  Subsequently, clean backfill
material was utilized to bring the site up to grade.  Potential
risks associated with the possibility of ingestion of, or dermal
contact with contaminated soil, therefore, are considered to be
minimal.

The Risk Assessment identified 14 constituents of concern  (COCs)
for shallow aquifer groundwater.  These constituents were:

     Noncarcinoaens                      Carcinogens

     1,1-dichloroethane                  1,1-dichloroethene
     1,2-dichloroethene                  1,2-dichloroethane
     4-nitroaniline                      tetrachloroethane
     aluminum                            trichloroethane
     chromium                            vinyl chloride
     cyanide                             arsenic
     lead
     mercury
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A complete list of compounds detected in groundwater,  including
the detection frequency and upper-bound concentration of each
compound, is provided in Table 6.

Honcarcinogenic risk* are assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses).  Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects.  RfDs, which are expressed in units
of milligrams/kilograa/day (mg/kg/day), are estimates of daily
exposure levels for humans which are thought to be safe over a
lifetime (including sensitive individuals).  EPA-verified RfDs
are not available for all COCs, (i.e., 4-nitroaniline, aluminum
and lead), therefore, risks associated with some of these
chemicals could not be quantitatively assessed.  RfDs for the
COCs are presented in Table 7.  Estimated intakes of compounds
from environmental media (e.g., the amount of chemicals ingested
from contaminated groundvater) are compared with the RfD to
derive the hazard quotient for the contaminant in the particular
media.  The hazard index is obtained by adding the hazard
quotients for all contaminants across all media that impact a
particular receptor population.

A HI greater than 1 indicates that the potential exists for non-
carcinogenic health effects to occur as a result of site-related
exposures.  The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures
within a single medium or across media.  His were calculated for
the exposure scenarios assessed and are presented in Table 8.  A
HI of greater than 1 for the potential ingestion of shallow
aquifer groundwater by either industrial workers or residents
indicates that noncarcinogenic health effects would likely
result, if the shallow aquifer were utilized as a potable water
source in the vicinity of the Swope site.

Potential carcinogenic tisks were evaluated using the cancer
potency factors developed by EPA for compounds of concern.
Cancer slope factors (SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with.exposure to
potentially carcinogenic chemicals.  SFs, which are expressed in
units of (mg/kg/day)'1,  are multiplied by the estimated intake of
a potential carcinogen, in mg/kg/day, to generate an upper-bound
exposure to the compound at that intake level.  SFs for the COCs
are presented in Table 7.  The term "upper-bound" reflects the
conservative estimate of the risks calculated from the SF.  Use
of this approach makes the underestimation of the risk unlikely.
                               12

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For known or suspected carcinogens, EPA considers excess upper-
bound individual lifetime cancer risks between 10"4 to 10* to be
acceptable.  This level indicates that an individual has not
greater than a one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a
carcinogen under specific exposure conditions at the site.   The
potential cancer risks associated with the site are presented in
Table 9.  The cancer risk for use of shallow aquifer groundwater
as a potable water source by residents was determined to be 1.8 x
10J (1.8 in a thousand)  for an exposure duration of 30 years.

The quantitative risk characterization suggests that unacceptable
noncarcinogenic and carcinogenic risks under current or future
land-use conditions would exist, if the shallow aquifer was
utilized as a potable water source in the vicinity of the site.
Furthermore, the Supplemental RI concluded that a semi-confining
unit separates the shallow and deep aquifers, and that leakage of
groundwater to the deep aquifer occurs.  The Swope site,
therefore, may be contributing COCs to the deep aquifer, which is
currently utilized as a potable water source.

Bubsurface Soil

Volatile and semi-volatile organic contaminants in subsurface
soil have migrated into the shallow aquifer which presents a
threat to groundwater quality in the deep aquifer, which is a
potable water source.  Therefore, it is necessary to take a
remedial action to remove contaminants from the subsurface soil,
in order to reduce the site's contribution to groundwater
contamination.

The NJISALs for volatile and semi-volatile organic compounds will
be utilized as soil cleanup goals, in order to provide for
groundwater protection.  NJISALs are used to identify the
presence of contamination in soil.

Risks associated with potential dermal contact with, or ingestion
of contaminated subsurface soil were not quantified in this risk
assessment, since direct human contact with soil at depth is not
probable.

Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative, may present
a current or potential threat to public health, welfare, or the
environment through the continued presence of contaminants in
subsurface soil.

Uncertainties

The procedures and inputs used to assess risks are subject to a
wide variety of uncertainties.  The main sources of uncertainty
in this Risk Assessment include:

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- environmental sampling and analysis,
- exposure parameter estimation,  and
- toxicological values.

Uncertainty in environmental sampling arises mainly because of
the potential for uneven distribution of constituents in
environmental media.  Therefore,  there is significant uncertainty
as to the actual levels  of contaminants present.   Analysis error
results largely from errors inherent in the analytical methods
and characteristics of the matrix being sampled.

As part of the exposure  assessment,  estimates are generated as to
the frequency of exposure to chemicals of concern and the period
of time over which the exposure would occur.  These estimates
serve as a source of uncertainty.

Uncertainties in toxicological values result due  to extrapolation
of the effects of high doses of compounds on animals to low doses
in humans.  Additional uncertainties result because of
difficulties involved in determining the toxicity of chemical
mixtures.  The use of conservative assumptions and models during
performance of the risk  assessment addresses these uncertainties,
so as to ensure that the potential site-related risks are not
likely greater than those estimated.

                         Assessment
The potential for environmental/ecological impacts was examined
as part of the Supplemental RI.   Due to the extensive nature of
surficial activities performed as part of the OU 1 remedial
action, little of the original site habitat remains.   Surface
soil has been removed to a depth of 1.5 feet over most of the
site, and approximately 2 feet of clean fill has been placed over
the underlying soil.  Currently, the site unlikely supports any
complex terrestrial ecosystem, but may support invertebrates and
some small mammals.  Since contaminated soil is no longer
exposed, constituents present in the subsurface soil are not
likely to be transported off site via erosional runoff or wind.

SCREENING OF REMEDIAL TECHNOLOGIES

The Swope site OU 2 remedial objective focuses on mitigating the
leaching of volatile organic compounds and the potential for
migration of semi-volatile organic compounds into groundwater.

During the Feasibility-Study process, a wide range of remedial
technologies were evaluated to identify those appropriate to meet
the OU 2 remedial objective.  An evaluation of the alternatives
that passed the initial screening process is presented in the
next section.
                               14

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Initially, technologies and process options were identified which
were classified into four broad categories, namely, treatment
technologies, containment options, institutional actions to
reduce the potential for exposure to contaminants, and no
remedial action with media monitoring.  The technologies and
process options considered, and the results of the initial
screening processes are summarized below.

Institutional actions which were considered included site fencing
and deed restrictions on the use of the site property.  Since
neither of these actions would aid in meeting the OU 2 remedial
action objective of mitigating the leaching of subsurface soil
contaminants into groundwater, they were eliminated from further
consideration.

Site capping to reduce the mobility of site contaminants by
restricting the infiltration of precipitation was considered as a
containment option.  A variety of capping materials and capping
designs were evaluated.  A clay and soil cap, consisting of a
relatively impermeable clay layer overlaid by soil, was
envisioned to be susceptible to cracking and to require
maintenance and repair.  Concrete, asphalt, and additive-derived
caps were determined to be susceptible to cracking and
weathering.  A single-layer synthetic membrane cap was found to
be prone to tearing, and is often punctured by burrowing animals
and plant roots.  Of the capping options considered, the multi-
layer cap was determined to be the most reliable and, therefore,
was carried through the initial screening process. This cap would
consist of a layer of low permeability (e.g., clay or synthetic
membrane) which would be covered with sand, topsoil and
vegetation to protect the low permeability layer from the effects
of the atmosphere.

Ex-situ (i.e., technologies involving the excavation of soil,
prior to treatment) and.in-situ (i.e., in-place treatment)
technologies were also -evaluated.  Ex-situ treatment technologies
were not carried through the initial screening process due to the
difficulties that would be involved in excavating contaminated
site soil to the depth of contamination within the spatial
confines of the site.  As displayed on Figure 2, the site is
bounded to the northeast and southwest by railroad rights-of-way
and warehouses, and to the southeast by National Highway.
Excavation of site soil would, at a minimum, involve the
disruption of a railroad spur as well as National Highway.  In
addition, the excavation of contaminated site soil would require
shoring the sides of the excavation to about 80 feet to maintain
the integrity of the excavation walls during soil removal.  The
shoring of the excavation walls to the depth of contamination
would prove difficult and would result in the excavation of soil
outside the physical .boundaries of the site.
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In-situ treatment technologies evaluated in the Supplemental FS
included vitrification/glassification,  solidification/fixation of
contaminated soil, soil flushing,  soil  vapor extraction,  enhanced
volatilization, and biodegradation.

Vitrification/glassification involves Belting soil to bind
the contaminants in a glassy,  solid  matrix which is resistant to
leaching.  Large electrodes are installed in contaminated soil
through which a high current of electricity is passed to melt the
soil.  Nonvolatile contaminants are  bound in the vitrified mass,
while organic compounds are destroyed by pyrolysis.  Since this
technology has not been proven to  be implementable to the depth
of contamination at the site,  vitrification/glassification was
eliminated from further consideration during the initial
screening process.

The solidification/fixation technology  involves immobilizing
contaminants by binding them into  an immobile, insoluble matrix.
Generally, concrete or cement is mixed  with contaminated soil,
which become incorporated into the rigid matrix of the hardened
concrete.  Reviews of case studies indicate that this technology
has not been proven to be an effective  means to immobilize
organic compounds.  This technology, therefore, was not carried
through the initial screening process.

Soil flushing involves the use of  a  solvent to solubilize
contaminants attached to soil particles.  Due to the non-
homogeneous nature of the subsurface soil and the potential for
preferential pathways to develop within the 80-feet deep vadose
zone, soil flushing may only be of limited effectiveness.  Since
this technology may be only partially effective, it was screened
out.

Soil vapor extraction involves the removal of volatile organic
compounds from soil in the unsaturated  zone by increasing the
flow of air through the'soil.   Air is drawn from the surface of
the site through extraction wells, which are screened within the
contaminated soil.  Volatilized contaminants contained within the
soil gas are drawn from the subsurface  environment through the
extraction wells.  A treatability  study performed during the
Supplemental FS demonstrated that  a  soil vapor extraction system
would be an effective means to remove volatile organic
contaminants from subsurface soil.  This technology, therefore,
was carried through into the alternative development stage.

The enhanced volatilization technology  utilizes steam, hot air or
electrical probes to raise the temperature of contaminants in
soil, causing them to volatilize.  If steam were utilized to heat
the soil, condensate would be generated during the initial stages
of the process, thereby providing  a  pathway by which contaminants
could migrate to groundvater.   In  addition, this technology has
only been demonstrated to be effective  to a depth of about 30

                                16

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feet.  Therefore, enhanced volatilization was eliminated from
further consideration during the initial screening.

Zn-situ biodegradation involves the use of microorganisms that
are naturally occurring in soil to degrade organic contaminants.
Oxygen and nutrients nay be added to the subsurface environment
to enhance microbial catabolism or co-metabolism of organic
contaminants, resulting in the breakdown of these compounds.  In-
situ biodegradation has been successfully utilized to degrade
nonhalogenated organic compounds, but has not been demonstrated
to be effective in remediating halogenated organic contaminants.
Since this is a proven technology for the remediation of soil
contaminated with nonhalogenated organic contaminants, and non-
halogenated organic contaminants comprise a significant portion
of the subsurface soil contamination at the Swope site, this
technology was carried through into the remedial alternative
development stage.

SUMMARY OF REMEDIAL ALTERNATIVES

The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act (SARA), requires each selected site
remedy to be protective of human health and the environment,
cost-effective, and in accordance with statutory requirements.
Permanent solutions to contamination problems are to be achieved
wherever possible.  The use of innovative technologies and on-
site treatment are evaluated as a means to attain this goal.  The
remedial alternatives evaluated during the Supplemental FS are
described below.

Alternative l: No Action

Capital Cost:                                  $ 0

Annual Operation and
Maintenance Cost:                        $ 234,200

Present Worth Cost:                    $ 1,014,000

Estimated Months to Achieve Remedial
Action Objectives                               NA

The National Contingency Plan requires that a No Action
Alternative be evaluated at every site to provide a baseline
against which other remedial alternatives may be compared.  Under
this alternative, EPA would take no further action to prevent or
reduce the leaching of subsurface soil contaminants to
groundwater.  This alternative includes a five-year groundwater
monitoring plan, which would involve the sampling of existing
site wells on a quarterly basis to assess the impact of the
contaminated subsurface soil on groundwater quality.  Groundwater

                                17

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samples would be analyzed for Target Compound List volatile and
semi-volatile organic contaminants on a quarterly basis, and
Target Analyte List metals on an annual basis..

This alternative would not provide for protection of human health
and the environment.  The toxicity, mobility and volume of the
contaminants would not be reduced.  Contaminated subsurface soil
would remain on site and continue to act as a source of
groundwater contamination.

Alternative 2s Soil Vapor Extraction with Biodegradation

Capital Cost:                            $687,500

Annual Operation and Maintenance
Cost (Groundwater Monitoring Program):   $234,200

First-Year Operation and Maintenance          ---       - —       —
Cost (Vapor Extraction System):           $397,500

Present Worth:                         $2,099,000

Estimated Months to Achieve Remedial
Action Objectives:                             18

Under this alternative, soil vapor extraction and biodegradation
would be used to remove and/or degrade organic contaminants from
unsaturated soil.  Using the NJISALs of 1 ing/kg for total
volatile organic compounds and 10 mg/kg for total semi-volatile
organic compounds as cleanup goals, the estimated total volume of
unsaturated soil requiring treatment is 153,000 cubic yards.

A typical soil vapor extraction system consists of a network of
soil gas extraction and monitoring wells, which are installed
within contaminated soil.  The extraction wells are connected to
a vacuum pump(s) which create(s) a negative pressure gradient
within the contaminated soil, drawing air from the surface of the
site through the contaminated soil and into the extraction wells.
As the air passes through the unsaturated soil, volatile organics
tend to vaporize and travel with the induced air stream to the
extraction wells.  Soil-gas monitoring wells are utilized to
measure the induced pressure gradient to determine whether
contaminated soil is being effectively ventilated.  In addition,
wells which are used to inject air either passively or actively
into the subsurface environment, may be utilized to increase
horizontal air flow through contaminated soil or to limit the
system's influence to within the boundaries of the site.
                               18

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During the design of the soil vapor extraction system,  the
magnitude of volatile organic emissions that may result due to
operation of the system would be assessed to determine whether
air pollution control equipment would be necessary.   Air quality
regulations (N.J.A.C. 7:27) require that state-of-the-art air
pollution control technology be used for control of any source
where the emission rate of total volatile organic compounds is in
excess of 0.5 pound per hour and/or the rate of total toxic
volatile organic contaminants is in excess of 0.1 pound per hour.
Therefore, it may be necessary to treat the air stream by carbon
adsorption or thermal destruction prior to discharge.  The
estimated cost of this alternative includes the cost of a thermal
destruction unit.

The primary component of this alternative would be soil vapor
extraction.  In addition, biodegradation of site contaminants
would be accomplished as a by-product of the soil vapor
extraction process, because operation of a soil vapor extraction
system would also serve to increase oxygen levels within
contaminated soil, and thereby enhance the aerobic biodegradation
of nonhalogenated organic contaminants by microorganisms which
are present in soil.  This process would be effective in
degrading semi-volatile organic compounds which would not be
removed with the induced air stream.  The effectiveness of
biodegradation depends on several factors including the presence
of appropriate microorganisms, soil moisture content, oxygen
content in the soil gas, the presence of nutrients,  soil pH and
soil temperature.  If necessary, the contaminated soil could be
inoculated with appropriate microorganisms, and nutrients could
be injected into the subsurface environment through wells to
enhance the aerobic biodegradation process.

During the design phase of the soil vapor extraction system, a
treatability study would be conducted, utilizing EPA-approved
methodologies, to evaluate the effectiveness of biodegradation at
the site.  This study would assess whether environmental factors,
such as soil nutrients and moisture content or the number and
type of microorganisms present in soil, could be altered to
enhance the biodegradation of contaminants further.

During the operation of the soil vapor extraction system,
subsurface soil and soil gas samples would be collected to
evaluate the effectiveness of the system in remediating
subsurface soil contamination.  Subsurface soil samples would be
collected at the site during the design of the soil vapor
extraction system to characterize subsurface soil contamination
further and to provide a baseline for determination of the
effectiveness of the soil vapor extraction system in remediating
subsurface contamination.  During this sampling event,  a
subsurface soil boring(s) would be installed in the former tank
farm area, and soil samples would be collected to the water
table, to determine the nature and extent of subsurface soil

                                19

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contaminat    in this area.   Concentrations  of contaminants in
•oil gas     ;ies, collected  during operation of the soil vapor
extractic;  system, would be  evaluated to determine the continuing
effectiveness of the   -~-em  in remediating organic contaminants,
as veil as providing       'cation as to when soil samples should
be collected to determii,     "her soil cleanup goals have been
met.  Operation of the tre~     w. system would continue until the
soil cleanup goals have been &«. .,  or until EPA determines that
operation of the system is no longer practical.

In addition, a five-year groundwater monitoring program, which
would involve the sampling of all site wells on   -uarterly
basis, would be conducted to provide groundwater   ility data.
Groundwater samples would be analyzed for Target compound List
volatile and semi-volatile organic contaminants on a quarterly
basis, and Target Analyte List metals on an  annual basis.

Decision to Postpone Installation of a Cap

Alternative 2, as developed  and evaluated in the Supplemental FS,
originally included the installation of a multi-layer cap over
the site, following treatment of contaminated subsurface soil.  A
cap was originally included  as a component of this alternative,
because the installation of  a cap was a source control activity
specified in the September 1985 Record of Decision for the Swope
site.  It should be noted, however,  that extensive treatment of
subsurface contamination was not envisioned  when the 1985 remedy
was selected.  During preparation of the Proposed Plan, EPA
reevaluated the need to cap  the site in conjunction with the
active treatment of subsurface soil contamination.  EPA has
determined that treatment of subsurface soil contamination alone
may be adequate to protect the groundwater from continuing
degradation.  As a result, EPA has decided to postpone a decision
regarding a cap, until after completion of the selected source
control remedy.  If it ds later determined that a cap is not
required, this approach would allow for a greater degree of
unrestricted future usage of the site.  Subsequent to completion
of the selected remedy, EPA  will evaluate whether this remedy
provides for adequate protection of groundwater, and whether the
installation of a cap or further source control actions are
warranted.

EVALUATION OF ALTERNATIVES

Each of the alternatives was evaluated with  respect to the nine
criteria specified in the National Contingency Plan and utilized
by EPA as part of the remedy selection process.  These criteria
are classified into four categories: environmental/public health
protectiveness, compliance with cleanup standards, technical
performance and cost.  In addition,  the selected remedy should
result in permanent solutions to contamination problems and
should use treatment to the  maximum extent practicable.  The nine

                               20

-------
criteria are summarized below:

•    Overall Protection of Hujflfln Bealth and the Environment; This
     criterion addresses whether or not a remedy provides
     adequate protection and describes how risks posed through
     each pathway are eliminated, reduced or controlled through
     treatment, engineering controls or institutional controls.

     Compliance with ARARs; This criterion addresses whether or
     not a remedy will Beet all of the applicable or relevant and
     appropriate requirements (ARARs) of Federal and State
     environmental statutes and/or provide a basis for invoking a
     waiver.

-    Long-term Effectiveness and Permanence! This criterion
     refers to the magnitude of residual risk and the ability of
     a remedy to maintain reliable protection of human health and
     the environment over time, once cleanup goals have been net.-

—    Reduction of Toxicitv. Mobility or Volume Through Treatment;
     This criterion addresses the anticipated performance of the
     remedy in terms of reducing the toxicity, mobility or
     volume of the contaminants of concern at the site.

     Short-term Effectiveness; This criterion refers to the
     period of time needed to achieve protection, as well as the
     remedy's potential to create adverse impacts on human health
     and the environment that may result during the construction
     and implementation phase.

-    Iroplementability; Implementability is the technical and
     administrative feasibility of implementing a remedy,
     including the availability of materials and services
     required to implement a particular alternative.

     Cost; Cost includes the estimated capital and operation and
     maintenance costs of the remedy, and the net present worth
     cost.

-    State Acceptance; This criterion indicates whether, based on
     its review of the Supplemental RI/FS and Addenda, the
     Proposed Plan and the ROD, the State of New Jersey concurs
     with the preferred alternative.  The State has concurred
     with the preferred alternative.

     Community Acceptance; This criterion will be assessed
     following a review of the public comments received on the
     Supplemental RI/FS and Addenda and the Proposed Plan.
                                21

-------
Overall Protection of HUClfln Health and the Environment

The No Action Alternative for the Swope site consists of
monitoring groundwater quality.   No remedial measures which
provide protection for human health and the environment in terms
of soil contamination would be implemented as part of this
alternative.  Subsurface soil contamination would remain and
would continue to act as a source of groundwater contamination.

Alternative 2, which involves soil vapor extraction with
biodegradation, would actively remove subsurface soil
contaminants and, thus, mitigate the leaching of organic
subsurface soil contaminants to groundwater.  Operation of the
soil vapor extraction system would remove volatile organic
contaminants, while enhancing the biodegradation of residual
nonhalogenated organic contaminants.  Alternative 2 would provide
protection to human health and the environment by remediating
subsurface soil contaminants which are acting as a source of    ^-
groundvater contamination.

Compliance with ARARs

On-site soil vapor extraction with biodegradation (Alternative 2)
would be conducted in compliance with Federal and State ARARs.
Since no Federal or State regulations specify cleanup levels for
the volatile and semi-volatile contaminants in soil at the site,
NJlSALs for volatile and semi-volatile organic compounds will be
utilized as cleanup goals.

Due to the site's location within a New Jersey Coastal Zone,
implementation of Alternative 2 would be, to the maximum extent
practical, consistent with the New Jersey Coastal Zone Management
Plan.  Further, the requirements of N.J.A.C. 7:27-8.2 (a) 1 would
have to be met, if a carbon adsorption or catalytic oxidation
unit were necessary to control air emissions from the soil vapor
extraction system.  The on-site storage of drill cuttings
generated during installation of vapor extraction and monitoring
wells would be conducted in accordance with the requirements of
Part 264 of the Resource Conservation and Recovery Act (RCRA), if
these cuttings were to remain on site for more than 90 days.
Alternatively, Part 265, Subparts I and J standards would be
applicable, if storage of waste on site were less than 90 days.
Off-site treatment and/or disposal would be conducted according
to RCRA Part 262 standards which specify manifesting procedures,
transport and record-keeping requirements.  The shipment of
hazardous wastes off site to a treatment facility would be
consistent with OSWER Off-Site Policy Directive Number 9834.11,
which ensures that facilities authorized to accept CERCLA
generated waste materials will be in compliance with RCRA
operating standards.  RCRA Part 264, Subpart X standards are
applicable to the soil vapor extraction process which would be
used to treat contaminated subsurface soil.

                                22

-------
Under the No Action Alternative, no remedial action would be
taken to reduce the .levels of contaminants in subsurface soil.
Therefore, this alternative would not achieve the cleanup goals
established for site soil.

Long-term Effectiveness and Permanence

The NO Action Alternative would not prove to be effective in the
long term.  Alternative 2 would reduce volatile and semi-volatile
organic compound concentrations in subsurface soil, which would
reduce the amount of contaminants leaching into groundwater.
Therefore, soil vapor extraction with biodegradation is expected
to be effective in providing long-term reliable protection to
human health and the environment.

Reduction of Toxicity. Mobility or Volume Through Treatment

The No Action Alternative would not provide any reduction of the
toxicity, mobility or volume of contaminated soil at the Swope
site.  Soil vapor extraction with biodegradation would
permanently remove or degrade organic contaminants in the soil
matrix and, as a result, provide for a reduction in the volume of
subsurface soil contaminants which may migrate into groundwater.
Soil vapor extraction, by removing volatile organic contaminants
from the site, will result in a significant reduction in toxicity
and mobility of contaminants.

Short-term Effectiveness

Since no construction would occur under the No Action
Alternative, this alternative would not pose any additional risk
to nearby communities or on-site workers.  However, under this
alterrative, subsurface coil would continue to act as a source of
groundwater contamination.  During implementation of Alternative
2, on-site workers may be exposed to contaminants via dermal
contact or inhalation during installation of vapor extraction and
monitoring wells.  These health risks would be controlled through
the use of protective clothing and respiratory protection, as
necessary.  Air quality monitoring and, if necessary, the
installation of air emissions control equipment at vapor
extraction wells would ensure the protection of human health and
the environment during operation of the soil vapor extraction
system.  Soil vapor extraction with biodegradation should result
in a significant reduction of subsurface soil contamination
within 18 months of initiation of construction activities.

Implementabilitv

The No Action Alternative would not pose any implementation
problems, because no construction activities would be conducted
under this alternative.  Soil vapor extraction with
biodegradation are proven technologies and could be implemented

                                23

-------
at the site.  Implementation of a soil vapor extraction system
would require the installation of extraction wells,  piping and
vapor monitoring wells.  Air pollution control  equipment and
vacuum equipment could be placed on a mobile trailer that would
oe parked at the site for the duration of the remedial activity.
The biodegradation of site contaminants may require  the balancing
of environmental factors which affect the effectiveness of this
technology.  Therefore, activities such as the  inoculation of
contaminated soil with appropriate microorganisms or the
injection of nutrients into the subsurface environment through
wells, may be required to enhance the aerobic biodegradation of
organic contaminants.  Services and materials necessary for
implementation of the selected remedy are readily available and
no technical or administrative difficulties are foreseen.

Cost

Alternatives 1 and 2 have an estimated present  worth cost of
$1,014,000 and $2,099,000, respectively.  The total  capital,
annual operation and maintenance (O&M), and present  worth costs
for each alternative are presented in Tables 10 and  11.  It
should be noted that the capital and O&M costs  for Alternative 2
do not include costs which may be involved with enhancing aerobic
biodegradation of contaminants.  The capital cost for Alternative
2 also does not include the cost of performing  a biodegradation
treatability study, which would be conducted as part of this
alternative.

State and Community Acceptance

A review of the State and public comments received on the
Supplemental RI/FS and Addenda, and the Proposed Plan indicates
that both the State and the community concur with the selected
remedy.  Public comments are addressed in the Responsiveness
Summary, which is attached to this document.

SELECTED REMEDY

Based on consideration of the requirements of CERCLA, the results
of the Supplemental RI/FS and Addenda, and public comments, EPA
and the New Jersey Department of Environmental  Protection and
Energy have determined that Alternative 2, soil vapor extraction
with biodegradation, is the most appropriate remedy for
contaminated subsurface soil at the Swope site.  Site risks have
been identified as being primarily due to the potential for
ingestion of contaminated groundwater.  The results  of the
Supplemental RI indicate that contaminated soil at the Swope site
is a source of groundwater contamination.  The  selected remedy
will be effective in reducing the quantity of soil contaminants
that are available to migrate into the groundwater.
                               24

-------
The selected alternative involves the treatment of approximately
153,000 cubic yards of subsurface soil contaminated with volatile
and semi-volatile organic contaminants utilizing in-situ soil
vapor extraction with biodegradation.  Since ho Federal or State
regulations specify cleanup levels for volatile and semi-volatile
organic contaminants in soil at the site, NJISALs of 1 mg/kg for
total volatile organic compounds and 10 mg/kg for semi-volatile
organic compounds will be utilized as cleanup goals to provide
for groundwater protection.

During the design phase of the soil vapor extraction system, a
treatability study will be conducted, utilizing EPA-approved
methodologies, to evaluate biodegradation at the site.  This
study will assess whether environmental factors, such as soil
nutrient and moisture content, or the number and type of
microorganisms present in soil, could be altered to enhance the
biodegradation of contaminants further.

During implementation of the selected remedy, subsurface soil and
soil gas samples will be collected to evaluate the effectiveness
of the soil vapor extraction system in remediating subsurface
soil contamination.  Subsurface soil samples will be collected at
the site during the design of the soil vapor extraction system to
characterize subsurface soil contamination further and to provide
a baseline for determining the effectiveness of the soil vapor
extraction system in remediating subsurface contamination.
During this sampling event, a subsurface soil boring(s) will be
installed in the former tank farm area.  Since storage of
hazardous materials in this area may have resulted in releases of
contaminants into site soil, and subsurface soil contamination
beneath the tank farm was not investigated during the performance
of the Supplemental RI, soil samples will be collected to the
water table, to determine the nature and extent of possible
subsurface soil contamination in this area.  Concentrations of
contaminants in soil gas samples, collected during operation of
the soil vapor extraction system, will be utilized to evaluate
the continuing effectiveness of the system in remediating organic
contaminants, as well as providing an indication as to when soil
samples should be collected to determine whether soil cleanup
goals have been met.

A five-year groundwater monitoring program will be conducted to
provide groundvater quality data.  This will involve sampling
site wells on a quarterly basis for Target Compound List volatile
and semi-volatile organic compounds, and on an annual basis for
Target Analyte List metals.  Since several metals were
sporadically detected at elevated levels in groundwater during
the Supplemental RI, the analytical results of metals samples
will be used to characterize metal contamination more fully.  EPA
may decide to modify the monitoring program (in terms of
frequency and contaminant parameters), based upon the analytical
results of groundwater samples collected during the initial

                                25

-------
sampling event(s).

Operation of the treatment system will  continue  until  cleanup
goals have been mrt, or until EPA determines  that operation of
the system is no longer practical.  Subsequent to completion of
the selected remedy, EPA will determine whether  the selected
remedy provides for adequate protection of groundwater and
whether any further source control measures,  such as capping, or
if groundwater remediation is necessary.

Air quality monitoring will be performed  during  construction and
operation of the soil vapor extraction  system.   Air emissions
from the soil vapor extraction system will meet  air emission
ARARs.  If necessary, air emission control equipment will be
utilized to meet air emission ARARs.

The total present worth cost of this alternative is estimated to
be $2,099,000.  This cost does not include the cost of conducting
the biodegradation treatability study or  the  cost of any actions
which may be taken to enhance the aerobic biodegradation of
organic contaminants during operation of  the  soil vapor
extraction system.  The capital cost is estimated to be $687,500.
O&M costs for the first year of operation of  the soil  vapor
extraction system are estimated to be $397,500.   Annual O&M costs
for the groundwater monitoring plan are estimated at $234,200.

STATUTORY DETERMINATIONS

Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial  actions that  achieve
adequate protection of human health and the environment.  In
addition, Section 121 of the CERCIA establishes  several other
statutory requirements and preferences.  These specify that, when
complete, the selected remedial action  for a  site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is justified.  The  selected  remedy also
must be cost-effective and utilize permanent  solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.   Finally, the
statute includes a preference for remedies that  employ treatment
that permanently and significantly reduces the volume, toxicity
or mobility of hazardous wastes as its  principal element.  The
following sections discuss how the selected remedy meets these
statutory requirements.

Protection of Hunan Health and the Environment

The selected remedy, which includes the in-situ  vapor  extraction
of organic subsurface soil contaminants,  will permanently reduce
the quantity of contaminants in soil at the site.  This remedy,
therefore, will provide protection to human health and the

                               26

-------
environment by reducing this source of groundvater contamination.
Based upon the results of the Risk Assessment conducted for the
Svope site, the potential ingestion of contaminated groundvater
from the shallow aquifer which underlies the site presents an
unacceptable future risk to human health.  There are, however, no
short-term threats associated with the selected remedy that
cannot be readily controlled.

Compliance with Applicable or Relevant and Appropriate
Requirements

Alternative 2, which includes in-situ soil vapor extraction with
biodegradation, will comply with all Federal and State
requirements which are applicable or relevant and appropriate to
its implementation.

Cost-Effectiveness
The selected remedy is cost-effective and has been determined to
be the only alternative which would be effective in meeting the
remedial action objective of mitigating the migration or the
potential for migration of organic contaminants to groundwater.

Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable

The selected remedy, Alternative 2, provides reliable protection
of human health and the environment over the long term, and
reduces the toxicity, mobility and volume of soil contaminants
through treatment.  This alternative can be implemented without
resulting in any adverse impacts on human health and the
environment during construction and operation.  Services and
materials necessary for implementation of the selected remedy are
readily available and no technical or administrative difficulties
are foreseen.

The State and community concur with the selected remedy, and it
meets the statutory requirements to utilize permanent solutions
and treatment technologies to the maximum extent practicable.

Preference for Treatment as a Principal Element

By treating soil contaminated with volatile and semi-volatile
organic compounds in place with a soil vapor extraction system,
the selected remedy addresses threats posed by the site using
treatment technologies.  Therefore, the selected remedy meets the
statutory requirement to utilize permanent solutions and
treatment technologies to the maximum extent practicable.
                                27

-------
DOCUMENTATION OF SIOyiTTCXMT CHXHflBS

There are no significant changes in the preferred alternative,
Alternative 2, Soil Vapor Extraction with Biodegradation,  as
presented in the Proposed Plan.

Subsequent to release of the Proposed Plan,  EPA determined that
the groundwater monitoring program to be implemented as part of
the No Action Alternative and Alternative 2  should be expanded to
provide for the collection of samples for total metals analyses.
As a result, EPA revised the cost for implementing the No Action
Alternative and the selected remedy, which were specified in the
Proposed Plan, to include the cost for metals analyses.  This
revision to the scope of the groundwater monitoring program
results in an increase of $52,900 in the estimated cose of
conducting the five-year monitoring program.
                                28

-------
APPENDIX A - FIGURES

-------
                                            FIGURE I
   "T/
-'(?-;r«l
                         "s?*i
               /   /  /.   |f;"*,
              /!• "  -, —»    f- —•
               sr/.s    <-_ ,,.  j-  ^
              &'     .'•*«..   .
    \  /  '$
i    //'
     	. *•
                                                                      MERCHANTVILLE-PENNSAUKEN WATER ^f^'
                              ^^i5.-  ifc** N^^k-
          ?VNV\»
          ^ ^/^••S?%.v'
                                                                       PARK AVENUE WELL FIELD
  £S   /*••' ' \. . k»MiP*>ii .->*•,- ..  t/  I  %i«."'.    ^^.*l !«••?.:      -• .•   wlo- .^ !«*»
  BASE MAP IS A PORTION OF THE U3.0.S. CAMDEN. NJ -PA OUAORANOLE (75 MINUTE SERIES. 1967. PHOTOREVBEO 1973).
  CONTOUR INTERVAL K)'

                                LOCATION MAP
   1VNIOIHO    SWOPE OIL CO. SITE. PENNSAUKEN TWR. NJ
AiriVDO dOOd  	SCALED
                                                                                    5MUS
                                                                                 I
                                                                               CXDRPORAHON
                                                                                  A HaMburton Company

-------
     FIGURE 2 • SFTE MAP
OS
33:10
oo
                                                                                       UOMITOWNO WBLL nUflMO
                                                                                       w -nm BVULOW AQUMW
MONTTOMNO WELL
W HU OB11F AQUWBK
MUNKVAL WELL SCMEEtffiO
DECPKMLBOMNO
tnvrexca
MAUJUMOtfUl

-------
APPENDIX B - TABLES

-------
                                                  Table 1

                                          Peee Soil  torino Jesuits
Constituents Frequency of tang*
Detection
Volatile
Orqgnles
Acetone
2-Butanone
1,1-Clchtoroethane
1,2-Dichtoroethene
Ethylbenzene
2-Hexanone
Methylene Chloride
4-Methyl -2-Pentanone
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Trfchloroethene
Vinyl Acetate
Xylenea
Semi -Volatile
Orcanies
Benzole Acid
Benzyl Alcohol
Bis(2-ethylhcxyl)
phthalate
Butyl benzyl phthalate
Oiethylphthalate
Oimethylphthalate
Di-n-butytphthalate
Di-n-oetyl phthalate
Isophorone
2-Hethylnaphthalene
2-Methyl Phenol
4-Methyl Phenol
Naphthalene
N-Nitrosodiphenylamine
Phenol
Inorganics
Aluminum
Arcenic
Barluo
Beryllium
Calcium
Chrooriun
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mickel
Potass fuB
Selenium
Sodium
Vanadium
Zinc


28/43
15/43
1/43
4/43
9/43
1/43
17/43
19/43
4/43
13/43
2/43
5/43
4/43
12/43


4/43
1/43

19/43
1/43
5/43
1/43
6/43
3/43
8/43
4/43
1/43
1/43
5/43
4/43
10/43

43/43
29/43
42/43
18/43
37/43
43/43
36/43
19/43
4/43
43/43
39/43
37/43
43/43
26/43
36/43
3/43
18/43
43/43
36/43


0.064
0.014
•
0.074
0.002
•
0.0039
0.003
0.052
0.0019
0.12
0.0041
0.006
-0.0059


0.54
•

0.042
•
0.044
•
0.04
0.045
0.039
0.057
•
•
0.042
0.041
0.076

190
-.-. 0.25
1.9
0.29
54
2.0
0.89
1.3
1.4
210
0.7
20
3.0
1.1
58
0.3
9.5
2.9
3.2


. ZM
41
•
- 0.56
- 320
•
21
- 150
- 360
- 490
- 130
- 620
- 0.035
- -1900


40
*

15
•
- 0.19
•
- 0.076
- 0.34
- 1.0
23
•
•
85
- 0.081
52

-13,000
23
68
- 2.0
- 1,090
74
16
- 110
- 3.6
-31,000
• 240
• 2030
- 240
• 212
- 5,910
- 0.4
-12,100
90
- 438
Arithmetic
Heart *)


16
5
0
0
37
0
1
9
91
39
65
120
0
169


16
0

1
0
0
0
0
0
0
8
0
0
31
0
12

3,237
5
13
0
366
. 13
3
10
2
6.651
9
403
41
10
976
0
1.161
25
24


.4
.9
.05
.32
.7
.24
.6
.7

.7


.016
.8



.44

.7
.063
.096
.035
.05
.19
.30
.8
.066
.47
.2
.065
.3


.5
.6
.69

.9
.7
.8
.5

.0

.3
.9

.34

.0
.2
Location of Highwt


-5
-5
•3
-4
-6
-8
-6
-6
•6
-6
•6
•6
-9
•6


•5
-5

-4
•6
•1
-9
-9
B 10
•4
' -6
-5
1-5
1-6
8-9
B-4

B-6
• -3
1-9
-3
•5
-1
-6
-9

B-
1-
••
B-
•
-5
-1
-9
•3
•9


from
from
from
froa
from
from
from
from
from
from
from
from
froa
from


from
from

from
from
from
from
from
from
from
from
from
from
fron
from
from

from
from
from
froa
from
from
from
froa
froa
from
froa
froa
froa
froa
from
froa
froa
froa
froa


19'
19-
29'
24'
14'
14'
14'
14'
14'
14'
14*
14'
84'
14'


19'
19'

10'
29'
74'
84'
24'
54'
39-
14'
19'
19'
14'
84'
10'

14'
29'
84'
29'
19'
29'
29-
84'
14'
19-
84'
19'
14'
84'
19'
29'
84'
29-
84'


to
to
to
to
to
to
to
to
to
to
to
to
to
to


to
to

to
to
to
to
to
to
to
to
to
to
to
to
to

to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
Detect


21'
21'
31'
26'
16'
16'
16'
16'
16'
16'
16'
16'
86'
16'


21'
21'

12'
31'
76'
86'
26'
56'
41'
16'
21'
21'
16'
86'
12'

16'
31'
86'
31-
21'
31'
31'
86'
16'
21-
86'
21'
16'
86'
21-
31'
86'
Sl-
av'
All concentrations are in ailtigraw per kilogran (me/kg).

a      Arithmetic Man using detects only.
•      Constituent was only detected once.

-------
                                                 Table 2

                      Sumarv of VoLitll« Organic  Cencounds Detected In Croundnatar
Concoundi Uoaradtent S
1st Round '
Vinyl
M«thyl«n«

Carbon
1,1 Ofchlo.-o-
ethene 2J-5
1,1 Otchloro-
ethane 3J-8
1,2 Oichloro-
tthtnt 20X-44X
Chloroform 6
1,2 Olchloro-
tthine 5-6
1,1,1 Trlehloro-
ethane 3J-16
Carbon Tetra-
chloride 3J
1,2 Oichloro-
propane U-9
Tri :hloroethene 5
4 Mtthyl-2

Tttrachlorotthtnt 2J-3J



htllow Wei It
2nd Rotnd
51


1J-10
4J-10
3JX-26X
6
4J-5
4J-40
3J
1J-U
S-7


2J-3J


1J
Daradlent
1st Rtxrri
ij


2J-H
4J-26
33X-170X
2J-8
6-12
9J-47J
1J-5
2J-3J
ion
2J-60


3J-6
yj

1SQX
Shallow Wet It Uosradfent
2nd Rtxnd 1tt Round



6-14 3J-7
4J-38 11-17
1S-99X 120X-200EX
2J-8 8-17
2J-11 6-9
5-51 9-15
2J-3J 14-27
2J-3J 4J-5
»*A1 V
2J-30 18-25


2J-7 13-15 .


1BO-22Q.I 1«
DMO Wells Dortdlent 1
2nd 8«jrd 1st Rocrt



2J-7 5J-8
8-28 16-21
4JX-130X 190X-240X
11-36 10-17
5-18 6-24
7-19 13-18
13-29 15-28
4J-1S 3J-7J
2J-31 22-24

— -
2J-20 7J-U



De«o W*lls
2nd Round



U-8
10-19
11-110X
4J-17
2J-22
8-19
2J-29
2J-9
3J-29


3J-18



All eenctntntlom ar« 
-------
                                                  Table 3

                 Sumngrv ef Semi-Volatile Organic Compounds Detected In Croundwater
Ut lOUTd
1,2-Olchloro

2-Hethyt-
bis(2-Ethyl
bIs(2-CMoro



1,2,4 Trichloro
N-Nitroso
2nd Round 1st Round 2nd Round 1st Round 2nd Round 1st Round 2nd Round










Alt eenetntntlem art In •icrogrMi  per  liter (ug/L).

Upgrwjient shallow •qutftr Mil* include  GM-2S, GM-JS »nd GM-6S.
Dpwngrcdient shallow aquifer  wells  include MW-1, MU-2. CM-IS, GM-3RS. HW-4, GM-7S and GN-8S
Upgradient deep aquifer uellft include GM-2P. GM-5D and GM-60.
Oowngradient deep aquifer wells include GH-10. GM-30, CM-40, GM-7D. GM-8D and MPVC Well  fl.


-- • Not Detected
J  • Estimated Value

-------
                                                  Table 4
Comoind* Uosradfent Shttlott Uelli
AlUBfnuB
LrlL"
Beryl 1 lin
CalcluB
Chro»f(j»
Cobalt
Cooper
Iron
Lead
Magnet fun
Nang.r»t«
Mercury
Nickel
Potatiium
Selenium
SodfuB
Zinc
1688-446
55.08-92.68

7340-15000
11.0-77.5
15.38 .
6.28-27.5
357-1070
4.68-7.4
3700-8850
35.9-242
1.9
18.08-49.6
34308-12200


9290-25700
28.5-44.0
aaradlent Shaltex V*\l|
1168-36600
69.48-220
29B.9 £A
.£8 Z.Oo
7300-26600
11.4-135
8.88-74.4
7.88-210
266-70400
3.18-52.2
14908-13000
150-3400
.7-6
17.78-117
26608-12500
2. 38
7070-24700
7*D • 11 9
• JB lie
27.9-738
Uoaridient De«o Wei It
350-565
658-1118

14400-28800
3.48-54.1
11.58-16.98
8.88-30.8
348-1140
5.1-17.4
31808-49008
186-266
.5-1.1
21.38-25.08
11800-37700


14300-20800
37.7-59.5
3J.
Daradfent De«o W*
96.38-4630
2.08-2.88
56.48-1558

1:01
7930-32600
6.18-48
8.88-29.78
9.98-52.1
129-4120
2.38-14.1
31408-46008
98.4-461
.5-2.9
14.78-32.38
25008-17000
2.98
9030-30900
14.78-41.48
41.9-78.2
All concent ritterM irt In mtcrogrmt ptr llttr (ug/L).
Upgr»dftnt th*Uow iquffcr  wilU  tnclud* GM-2S,  GM-5S ind GM-6S.
Downgr«df«nt *h.llew aqulftr  Ml If tnclud* MW-1, MU-2,  GM-1S, GM-3RS. NU-4. GM-7S «nd «-8S
Upgr«d
-------
                              TABLES


Occurrence of Centtituenu ia the Shadow Aquifer Upindient of the Swope Oil and Chemical Computer Site,
Pemauken. New Jcney.
Consiltueati Frequency of '
Detection'
Volatile Or^anici
Acetone
Benzene
Carbon letrachloride
Chlorobeniene
Chloroform
,1-Dichloroethine
,1-Didiloroeihtne
,7-Dichtoroethane
,2-Dichloroeihene
,2-Dichlorapropane
Eihylberuene
Meihytene chloride
Tetrachloroethcne
1.1,1-Trichlorcethane
Trichloraethene
Vinyl chloride
Xylena
Acid ind Bf «e/N«itT«it
Biltt-ethylhexyl)
phihalaB
Inomniei
Aluminum
Barium
Calcium
Chromium
Cobalt
Copper
Iron
lad
Magnesium
Manganese
Mercury
Nickel
Poiaujura
Sodium
Zinc
Ounma-BHC
Ittenotica

2/6
5/6
2/6
3/6
2/6
5/6
4/6
4/6
6/6
4/6
1/6
1/6
5/6
5/6
5/6
1/6
1/6


4/6

3/3
3/3
3/3
3/3
1/3
3/3
3/3
2/3
3/3
3/3
1/3
2/3
3/3
3/3
3/3
2/6
3/6

73
1
3
4
6
3
1
4
3
1
•
•
2
3
5
-•
*


3

170
55
7,300
11
•
6.2
360
4.6
3,700
36
•
IS
3,400
9,300
29
0.086
0.036
Ranft

260
2
3
1
6
10
10
6
a
14
•
•
3
40
7
-•
*


II

450
93
- 15,000
78
•
28
. 1,100
7.4
- 8,900
• 240
r
50
• 12.200
• 26.000
44
• 0.33
- 0.08
All eoncenuiooni are reponed in microframi per liter (ut/L).
a a/y; when i • number of aunpla with analytical reailB above the detecB
aamptei analysed.
b Arithmetic mean using ddeea

only.




Arithmetic UCL
Me»'

167
1.8
3
5.7
6
5.8
4J
5
27
6J
1
2
2.6
13
5.4
J
1


6.3

270
75
12,000
33
15
18
620
6.0
5,700
120
1.9
34
6,600
16,000
35
0.21
0.06
ce Unit, and y •



757
2.2
3
9.2
6
8.7
9J
«
40
14
«
.
3.1
28
6.3
- - .
•


11.0

530
110
19.000
98
—
37
1,300
15
10.000
300
—
130
15.000
31.000
49
0.98
0.09
the ml number of


UCL Upper 95 percent confidence both.
Consituent wu detected only once; 93 percent UCL cannot be filrnhml
• Constituent wn only detnaad
once.



Upendieat tteDc* aqvller •*& fcdudt OM-H, OU-SS aad OM4S
ttumi*l*M ituOkw tquiiv mk kvtek kfW-L UW4. OM-IS. OM-JM. MW4. OM-7S «d

au-ts

-------
                                TABLE  6

Occurrence of Constituent! in tte Shallow Aquifer Down(ndient of the Swope OU and Chemical Company Sitt,
Pennuuken, New Itney.
Conjlltueati
Vplilllt Omnla
Acetone
Benane
Carte* tdnchlonde
Chlorobenzene
Chloroform
1 . 1 -Dichlorocihanc
I.l-Dichlorccthene
1.2-Dichtoroethane
U-Dichloroethene
1 ,2-Dichloropropane
Ethylbenzene
2-Heunone
Mtlhylene chloride
4-Melhyl-2-penianone
Styrene
Tench loroethene
Toluene
l;l.l-Trichloradhaae
Trichloroeihene
Vinyl chloride
Xylenet
Acid tra\ H«»/V»utp>li
Biifl-ethylhexyl)
phthalate
hophoronc
4-Methylphenol
Naphthalene
4-Nitroaniline
1 ,2.4-Tnehlorobouene
Aluminum
Anenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Cyanide
Iran
Lead
Mafne&om
ManfaneM
Mercury
Nickd
FottmuB
Selenium
Sodium
Vanadiua
Zinc
Alpha-BHC
Camma-BHC
Aroclor 1234
rBenoucs
DftectW

6/12
3/12
4/12
4/12
6/12
12/12
6/12
11/12
12/12
4/12
V12
1/12
1/12
1/12
1/12
tin
3/12
11/12
12/12
4/12
3/12


V12
1/12
1/12
1/12
1/12
1/12
7/7
4/7
7/7
VI
7/7
7/7
7/7
7/7 •
2/12 •
7/7
7/7
7/7
7/7 '
3/7
7/7
7/7
1/7
7/7
4/7
7/7
1/12
3/12
2/12
4/12
Ra.fi

31
2
1
1
2
4
2
2
13
2
1
•
•
•
•
2
33
S
2
2
130


2


.
•
•
120 •
4.0 •
69 •
2.2 •
7,300 .
11 •
l.t •
7.1 •
10 •
270 •
3.1 '
1400 •
130 •
0.70 •
II
rw
• .
7.100 -
7.3 .
21 •
0.044
0.33
0.02

300
3
3
4
1
31
14
12
170
3
41
•
•
•
•
7
100
31
60
3
220


3





37,000
79
220
2.*
27,000
140
74
210
301
70,000
32
13.000
3.400
6.0
120
. 13000
.. . «
13.00C
110
240
- 0.11
1.6
• 0.076
Moat

202
2.7
2.1
2J
3J
17
9.2
6.1
39
2J
21
190
1
94
1
4.1
71
21
14
3.3
10


3.7
6
2
1
10
4
9.900
24
130
2.4
16.000
63
37
33
139
32.000
	 II
6.000
9tO .
2.2
39
sno
2.3
13.000
39
100
0.1
0.01
I.I
0.049
Artthnetfc
UCL

341
3.6
4.1
4
7.1
23
13
1.6
14
3.2
61
.
.
•
-
6
III
30
22
3.3
243


6.2





20,000
67
170
3.7
22.000
100
33
110
1.100
33.000
31
l.<00
1,100
4J
t7
' B
.
2C.300
120
160
0.14
4.4
0.0
All eoncentratioru arc reported in Bucrofram per liter (ut/L).
• t/y; where s • mmber of aunpta with analytical rcaula above the de
lampla analyvd.
b Arithmetic man iamj

detaeoonhr.
c Cyinidt wu not analyad for • the May


1990 •rnpUnf evi


lecm bant, and j •


the total nambar of


ft and rttuhi from January 1990 wen oad.
UCL Upper 95 percent confidence limit
Constituent wu oeecui
• Conjutuem wu dense*
XX Ta» UCL tor faumlim
d only oner, 95 pi
donee.
icMUCLanM

becateba

rt.


,
                                       mt OM4S

-------
                                     TABLET
           Acceptable Doses* (ADs). Cancer Slope Facton (CSFs), and USE?A Cancer Classification
           for Constituents of Concern at the Swope Oil and Chemical Company Site, Peniuauken,
           New Jersey.
  Constituents
                              AD (mj/ks/day)
                         CSF
Oral
Inhalation     Oral
          Cancer
Inhalation     Class
Volatile Organic*
Acetone                     0.1*        (0.1)
1.1-Dichloroethane            0.1*         0.1*
1,1-Dichloroethene            0.009*      (0.009)
1,2-Dichloroethane            0.25*        0.025'
1,2-Dichloreethene            0.02*       (0.02)
Ethylbenzene                 O.T        (0.1)
Methylene chloride            0.06*        0.9
Tetrachloroethene             0.01'       (0.01)
Toluene                     0.3*        (0.3)
Trichloroethene              0.0074     (0.0074)
1,1,1-Trichloroethane          0.09*       (0.3)
Vinyl chloride                0.0013'     (0.0013)
Xylene                      2.01        (2.0)
                      6.0E-1'
                      9.1E-2'
                      7.SE-3
                      5.1E-2*

                      0.011

                      2.3E+0-
                        1.2E+0*
                        9.1E-2'
                        1.4E-2
                        3.3E-3'

                       0.017

                        3.0E-1'
            D
            C
            C
            B2
            D
            D
            B2
            B2
            D
            B2
            D
            A
            D
Acid and Basf'N'tutrals
Bii(2-ethylhexyl)phthalate
2-Methylniphthilene
Naphthalene
4-Nitroaniline
Phenol
Inorganics
Aluminum
Arsenic
Chromium"
Cyanide
Lead
Mercury

0.02'
0.004'
0.004'
0.8'
0.6'

NA
0.001'
0.005*
0.02'
NA
0.0003'

(0.02)
(0.004)
(0.004)
(0.8)
(0.6)

NA
(0.001)
0.0000006*
(0.02)
NA
0.00005'

1.4E-2'
—
—
—
-

NA
1.8E+0*
_
—
NA
—

(1-4E-2)
—
—
' —
—

NA
5.0E+1'
42»
—
NA
••

B2
D
D
D
D

D
A
A
D
B2
D
NOTE: Data in parenthesis indicate inhalation value not available; oral value used.
•   Chronic ADs art listed; subchronic ADs are assumed to be 10 times the chronic AD. The term AD
    in  this context is used synonymously with the term RfD.
a   USEPA, 1990.
b   IRIS, 1990.
c   ATSDR, 1989a.
d   USEPA. 1987.
e   ATSDR, 1988b.
f   No USEPA verified data available; AD derived from RTEC,  1985.
I   ATSDR, 1989b.
h   USEPA, 19866.
i   Assumes toxiriry of naphthalene from USEPA, 1990.
j   Criteria provided are for Chromium VI.

-------
                                           TABLES
        NOMCARCIMOGEMIC BISK ESTIMATES OUZABD  IWOICES) FOt THE SUOPE OIL OHO CHEMICAL CONPAMT SITE


                   (AU USB ME KM POTETTIAL EXPCSUK TO SMLLOW MUIFB GKUDyATDt)

Route	 Potentially Exnos«d Population*

Inge*t
-------
                                             TABLE 9
                  CASCINOSEHIC RISK  ESTIMATES FOR THE SUOPE OIL AHP CHEMICAL COMP«HT  tlTE

                   (ALL RISKS ARE FOR POTEVTIAL EXPOSURE TO SHALLOW AQUIFER aKUDUATER)

Reutt                                Eot>ntl»Uv Expend Poeulitleot

                         Adult Werktr                               Rnidtnti
               7 veer txoesurt  ?0 vtir  txpeturt    9-vtir «»pesur« 30-vttr t«po«ur«  TD-vtir  «npe«urt

Ir«Mt1en              1.4E-4            4.0E-4            5.3E-4           1.7E-3           4.2E-S

0«rul                 1.9E-7            5.5E-7            	           2.5E-6           	

Inhitttien					.......           8.0E-S	•	•

Total Rteiptor
lUk                   1.4E-t            4.0E-*            5.3E-4           1.8E-3           4.2E-3

-------
                             Table It
Remedial Action Alternative 1 - No Action,  Detailed Cost
Analysis, Swope Oil and Chemical Company Site,  Fennsauken, New
Jersey.
Item                       Description                     Cost

A. Capital Cost                                                SO
B. Annual O&M*  (for groundwater monitoring on a
               quarterly basis for 5 years)
     Laboratory procurement; sample collection            $61,000
     and project management:                   .                   :
     Groundwater       VOC analyses:                      $54,000
     Sample Analyses   $450/sample * 120 samples
                       Semi-VOC analyses:                 $78,000
                       $750/sample * 104 samples
                       Inorganic analyses:
                       $200/sample * 26 samples            $5,200
     Containerization and disposal of purged              $36.OOP
     groundwater:
     Total:                                              $234,200
     Present Worth (5 years)                           $1,014,000
     Soil Remedial Action Alternative 1 Total Co»t:    $1,014,000

-------
                            Table 11
Remedial Action Alternative 2 - Soil Vapor Extraction with Aerobic
Biodegradation, Detailed Cost Analysis,  Swop* Oil  and Chemical
Company site, Pennsauken, Nev Jersey.
 Item
Description
  Cost
 A.  Capital

        well Installation


        Slower

        Air mission
        control

        System
        Automation

        Labor


        Decon Facility


        Subtotal:

        Enginctring (151):

        Contingtncy (25%):

        Total:
14 vcs veils and 1,600 feet
of overland piping

One 30-Hp blower

Catalytic oxidizer
Transducers, switches,
alarm and controls

Installation of blower
and oxidizer unit

1,600 ft1 insulated
building  ($36/ftJ)
 $48,000



'$13,000

$350,000


 $14,000


  $8,000


 $58,000


$491.000

 $73,700

$122.800

$687,500

-------
                            Table 11  (continued)

Remedial Action Alternative 2  - Soil  Vapor  Extraction with Aerobic
Biodegradation Detailed Cost Analysis,  Svope  Oil  and Chemical
Company Site, Pennsauken,  New  Jersey.

Item            :           Description                      Cost


B. Annual o&M*  (for groundwater monitoring on a
               quarterly basis for 5  years)

     Laboratory procurement; sample collection            $61,000
     and project management:

     Groundwater       VOC analyses:                       $54,000
     Sample Analyses   $450/sample *  120  samples

                       Semi-VOC analyses:                  $78,000
                       $750/sample *  104  samples

                       Inorganic analyses:
                       $200/yample *  26 samples            $5,200

     Containerization and  disposal of purged  groundwater: $36.000

     Total:                                              $234,200

     Present Worth (5 years)                           $1,014,000

C. First-year O&M (for VES system only)

     Electricity       Blower  and oxidizer                $112,000

     Chemicals         Caustic for neutralization         $10,000

     Soil Samples      6 soil  borings,  50 feet deep,      $76,000
     (2 Sampling       2-ft interval  sampling, 150
     Rounds)           soil samples total (VOC,
                       semi-volatile  organic  compound
                       and PCB analysis)                  $110,000

     Air sampling      12  air  samples (VOC  analysis)      $10.OOP
                       (one/month)

     Subtotal:                                    •       $318,000

     Contingency (25%)                                    $79.000

     Subtotal:                                           $397,500

     Soil Remedial Action  Alternative 2 Total Cost*'   $2.099.000

-------
APPENDIX C - ADMINISTRATIVE RECORD INDEX

-------
DOCUMENT NUMBER INDEX

-------
08/26/91                             Index Document Nutber Order                                    •         fege: 1
                                     SWOPE OIL  SITE, OPERABLE UNIT « Ooevmnts
OeeuMnt Nunber: SOP-001-0001 To 0239                                               Batt:  07/01/88

Title: Operations Plan for the Supplemental Renedfal  Investigation/Feasibility Study at the Swope
       Oil and Chemical Company Site,  Penraauken Township, Caoden County, Hew Jersey (Second Revision)

     Type: PLAN
   Author: Wolfert. Michael  F.:  Geraghty i Miller
Recipient: none:  none
OocuMnt Number: SOP-001-0240 Te 0427                  •                            Date:  07/01/88

Title: Addendum to the Operations Plan for  the Swope Oil and Chemical Coapany site, Penmauken, New
       Jersey (Second Revision)

     Type: PLAN
   Author: Uolfert, Michael F.:  Geraghty t Miller
lecipient: none:  none
Document Number: SOP-001-W28 Te 0519                                               Oate:  09/01/87

Title: Design Sampling work Plan

     Type: PLAN
   Author: none:  none
lecipient: none:  Swope Oil Company site


Document Number: SC?-001-0520 To 0589         •                                      Date:  09/01/87

Tftle: Work Plan for Supplemental lemedial  Investigation/Feasibility Study at the Swope Oil and Chemical
       Coopany Site, Pennsauken Township, Caoden County, New Jersey (Second Revision}

     Type: PLAN
   Author: none:  Geraghty t Miller
Recipient: none:  none

-------
02/26791                             Index Docunent  Nunber Order         '                                      Page:  2
                                     SWOPE OIL  SITE, OPERABLE UNIT Ti Documents
Oocunent number: SOP-001-0590 To 0854                                               Oate: 03/01/91

Titlt: Supplements! Remedial  Investigation Conducted at  the Swop* Oil and Chemical Conpany Sit*,
       •tnrvauken Township, C«adan County, NaH Jersey, Volune  I of V

     Type: REPORT
   Author: none:  Cerighty (  Miller
leeipient: none:  none
Oocunent Number: SOP-001-0855 To 0905                   -                            Data: 03/01/91

Title: Supplemental tenedial  Investigation Conducted  at  the Swope Oil and Chaafcal Cospany Site,
       Pennssuken Township,  Camden County, New Jersey -  Volume  II of V

     Type: REPORT
   Author: none:  Cersghty ( Miller
tecipient: none:  none
Oocunent tfunber: SOP-001-0906 To 1333                                               Date: 03/01/91

Title: Supplemental Remedial  Investigation Conducted  at  the Suope Oil and  Chemical Conpany Site,
       Pennsauken Township, Camden County, New Jersey -  Volume  lit of V

     Type: REPORT
   Author: none:  Ceraghty I  Miller
Recipient: none:  none
Oocunent number:-SOP-001-1334 To 1713        '                                       Data:  03/01/91

Title: Supplemental Remedial  Investigation Conducted at  the Swope Oil and Cheolcal Ceopany  Site,
       Pennsauken Township,  Camden County, New Jersey, Volume  IV of V

     Type: REPORT
   Author: none:  Cersghty t Miller
Recipient: none:  none

-------
08/26/91                             Index Document  Number Ord«r                                              Page:  3
                                     HOPE OIL  SITE,  OPERABLE UNIT *2 Documents
Document Number: SOP-001-1714 To 1932                                               Ottt: 03/01/91

Title: Sjustementat Remedial  Investigation Conducted at  the Swope Oil and Chemical Company Site,
       Pemsauken Township,  Canden County, New Jersey, Volun V of V

     Type: REPORT
   Author: none:  Genghty ( Miller
Recipient: none:  none
Document Nuitcr: SOP-001-19JJ To 1933                   •                            Oete: 05/22/91

Title: (Letter approving the Jupplen»nt»l  (emcdiel  Investigation (RI) Report for the Swop* Oil «nd
       Chemical Company site end forwerding  the  Addendvn Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:   US EPA
Recipient: Nicoloro,  Robert:  EXSR
 Attached: SOP-001-1934

Oocunent Ni/nber: SOP-001-19J4 To 20U                  Parent: SOP-001-1933          Date: 05/01/91

Title: Addendun tc the Supplemental  Remedial  Investigation for the Suope Oil and Chemical Company
       Site

     Type: REPORT
   Author: none:  US  EPA
Recipient: none:  none
Document Nonber:-SOP-OOV2015  To 2015        .                                       Data: 03/13/91

Title: (Letter discussing the  obtaining of  an Industrial Prttreatnent Permit to discharge treated
       groundyater from the Suope Oil site)

     Type: CORRESPONDENCE
   Author: Lopcrfido,  Samuel N., jr.:  Caoden County Municipal Utilities Authority
Recipient: Cowers, Joseph A.:   US EPA

-------
08/26/91                             Index  Document Ninber order                                  '            p8ge: 4
                                     SUOPE  OIL SITE, OPERABLE UNIT 12 Docunents
Document number: SOP-001-2016 To 2017                                               Pete: 02/27/91

Title (ictcr sdvijing  of  the results of discussions ufth the Camden Count/ Municipal Utilities
     . Authority (CCXUA) and the Pennseuken Sewerage Authority (PSA) with regard to the acceptance
       of treated grounduater froa the Swepe Oil site)

     Type: CORRESPONDENCE
   Author: Vernick,  Arnold  S.:  Ceraghty t Miller
Recipient: Cowers, Joseph A.:  US EPA
Oocunent Nuitwr: SOP-001-2018 To 2019                                            '   Date: 07/06/90.

Tftte: (Letter approving the feesibftlty Study (FS> work plan for the Supplemental RI/FS)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:   US EPA
Recipient: Oiks, Diane:   OeSoto


Document Number: SOP-001-2020 To 2020                                               Date: 04/17/90

Title: (Letter forwarding the attached Memorandum addressing comnents provided in EPA's February
       5, 1990, memo in  connection with the inorganic data validation for the deep toil boring program)

     Type: CORRESPONDENCE
   Author: Newton, Douglas  J.:  Ceraghty t Miller
Recipient: Cowers, Joseph A.:  US EPA
 Attached: SOP-001-2021

Document Number:JOP-001-2021 To 2036        _         Parent: SOP-001-2020          Date: 04/10/90

Title: (Menorsndus) US EPA  Commnti en the Inorganic Data Validation of the Soil Sample* Collected
       at the Swope Oil  and Chemical Company Site, Pemsauken, New Jersey, During the Deep Soil ioring
       Proflrao

     Type: CORRESPONDENCE
   Author: none:  Ceraghty  t Miller
Recipient: none:  US EPA

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08/26/91                             Index Document Number Order         '                                    p(ge: 5
                                     SWOPE OIL  SITE, OPERABLE UNIT *2 Documents
Oocunent Number: SOP-001-2039 Te 2039                                               Oatt:  04/17/90

Titlt: (Letter forwarding tht attached Mnorandui addressing cements provided 
-------
08/26/91                             Index Oocuaent Hunter Order         '                                     Page: 6
                                     SUOPE OIL SITE, OPERABLE UNIT *7 DocuntntS
Ooeuatnt Himber:  SOP-001-20S8 To 2060                                               Oat*: 10/14/88

Title: (letter approving  several, change* to the Operation* Plan (OP) for the Suppleocntal RI/FS at
       the Swope  Oil  »fte and forwarding additional cosnentt en the Addendm of the OP)

     Type: CORRESPONDENCE
   Author: Czaper,  John V.:   US EPA
Recipient: Diks,  Diane:  DeSoto
Oocusent Kutber:  SOP-001-2061  To 2063                  •                            Date: 09/19/88

Title: (Letter deicribing  concern* about the proposed location* for Wells GM-20, GM-5S, and W-50.
        Soil boring location nap attached)

     Type: CORRESPONDENCE
   Author: Newton,  Douglas J.:  Ceraghty t Miller
Recipient: Dunktlnan,  Thomas:   US EPA
Docuvnt Nuifcer: SOP-001-2064 To 2064                                               Date: 08/30/88

Title: (Letter stating that  EPA approves the Operation* Plan for the Supplemental Rl/FS at the Swope
       Cil and Chemical Company site, as well a*  the Addendum to the Operation* Plan)

     Type: CORRESPONDENCE
   Author: Czapcr,  John V.:   US EPA
Recipient: Diks, Diane: OeSoto
Docunent *irt>er:_SOP-001-2065 To 2065                                               Date: 01/13/88

Title: (Letter stating that  EPA approve* the Swope Oil and CheatcaI CcotMny Work Plan for the Stpplanental
       tl/FS and that deep Mil boring* cut be performed a* part of the RI/FS)

     Type: CORRESPONDENCE
   Author: Czapor, John V.t   US EPA
Recipient: Walarukl, K.A.t  DeSoto

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08/26/91                             Index Document Nunber Order         '                         '            plge: 7
                                     SWOPE OIL  SITE,  OPERABLE UNIT »2 Documents
Ooeunent Kunber: SOP-001-2066 To 2067                                               Date: 01/05/88

Title: (Letter confirming • December 7,  1987,  conversition discussing the  Itplementatlon of • toil
       boring program et the Swope Oil site)

     Type: CORRESPONDENCE
   Author: Guarrala, Philip 0.:  US EPA
Recipient: Ualanski, K.A.:  OeSoto
Ooeunent Nunber: SOP-001-2068 To 2073                   •                            0«te: 10/20/87

Title: (Letter stating thet EPA epproves ERT'» De*lgn Sanplfng Work Plan (Septeober, 1987) for the
       Swope Oil end Chemical Company site provided that the attached codification* are complied with
       during the appropriate activities)

     Type: CORRESPONDENCE
   Author: Guarraia, Philip D.:  US EPA
Recipient: Nicotoro. Robert:  ERT
Ooeunent Nunber: SOP-001-2074 To 2087                                               Date: 06/01/90

Title: Feasibility Study Work Plan,  Swop* Oil  and Chemical  Company Site, Pemsauken Township, Camjen
       County, New Jersey

     Type: PLAN
   Author: none:  Ceraghty I Miller
Recipient: none:  Swope Cleanup Committee
Ooeunent Mutter: SOP-001-2068 To 22(9                                               Date: 05/01/91

Title: Supplemental Feasibility Study for the Swope Oil  end Chemical Company site; Pemsauken Tounthlp,
       Camden County, New Jersey, Volume I of IV

     Type: PLAN
   Author: none:  Ceraghty < Miller
Recipient: none:  none

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08/26/91         '                     Index Oocuaent Muter Order                                              p(ge: 8
                                     MOPE OIL SITE, OPERABLE UNIT fZ DocvraentS
Oocunent Nunber:  SOP-001-2250  To 2380                                                out:  05/01/91

Title: Supplementel  feilibtUty Study  for the Swop* OU and Chemical  Conpany Site,  Pennsauken Township,
       Cenben County,  New Jersey, velum II of IV

     Type:  PLAN
   Author:  none:   Cereghty i Miller
Recipient:
Oocuaent Nunber:  SOP-002-0001  To 0242                   •                             Oete:  05/0.1/91

licit: Supplemental  Feiifblllty Study for the SMOP* Oil and Cheated Conpeny Site,  P'    jken Township,
       Cuden County,  New  Jersey, Volune III of IV

     Type: PLAN
   Author: none:   Cereghty i Miller
leclpient: none:   none
Ooeunent Nunber:  SOP-002-0243  To 0479                                                Bete:  05/01/91

Title: llsk Assessment  for  the Swope OU end Chsaleel Conpeny Site,  Pemseuken Township,  Csmden County,
       New Jersey,  Volume IV of IV

     Type: PLAN
   Author: none:   Cersghty  t Miller
leelpient: none:   none
Document Number:-SOP-002-0480  To 0494         /                                      Date:  07/01/91

Title: Shallow Cround-Uatar Monitor Ins Plan of the Supplanental Feasibility Study for tha Swope Oil
       and Chanfeal  Coopsny Site,  Penmeuken Township, Caoden County, MM Jersey

     Type: PLAN
   Author: none:   Sersjhty * Miller
leelpient: none:   none

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08/26/91                             Index Ooeuntnt  Number Order                                             p(g(: 9
                                     SUOPE OIL  SITE, OPERABLE UNIT f2 Documents
Oocunent Number: SOP-002-0495 To 0526                                               D*t«:    /  /

Title Addenda to th< Supplemental Feasibility Study and Risk Assessment for tht Suope Ofl  and Chemical
       Company Site

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Nunber: SOP-002-0529 To 0542                  •                            Date:  07/01/91

Title: Superfind Program Proposed Plan:  Cwope Oil end Chemical Company Site, Pemtiuken Township,
       New Jersey

     Type: PLAN
   Author: none:  none
Recipient: none:  none
Document Nunber: SOP -002 -0543 To 0543                                               Date:  07/15/91

Title: (Letter amending and approving the May 1991 Supplemental FS and Risk Assessment Reports for
       the Swspe Oil and Chemical  Company site)

     Type: CORRESPONDENCE
   Author: lasso, Raymond:  US EPA
Recipient: Nicoloro, Robert:  ENSR
Document Nint*r:-SOP-002-05U To 0546       •                                        Date:  12/13/90

Title: (Letter submitting New Jersey State  applicable or  relevant and appropriate requirements (ARARs)
       which pertain to the Swope Oil and Chemical site located  In Pemaauken Township,  New Jersey)

     Type: CORRESPONDENCE
   Author: Curtis, Ian R.:  NJ Dept  of Environmental Protection
Recipient: Cowers, Joseph A.:  US EPA

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08/26/91                              Index Ooeunent Nunber Order                                              Page:  10
                                     SUWE OIL SITE. OPERABLE UNIT « Documents
OoeuMnt Number:  SOP-002-0547 To 0547                                               Date:

Title (Ltttir In which EPA  requests that tht New Jersey Oepartnent of Environmental Protection (NJDEP)
     . provide »U New Jersey state ARARs regarding the discharge of treated grounduater frca the
       site to the Pemauken Creek and the Delaware liver)   '

     Type:  CORRESPONDENCE
   Author:  Cowers, Joseph A.:  US EPA
Reeiplert:  Curtis, Ian R.:   NJ Oept of  Envfrorntntsl Protection
Ooeunent Nunber:  SOP-002-0548  To 0548                                             .  Oate: 06/04/90 •

Title: (Letter requesting  additional  Mew Jersty statt ARARs)

     Type: CORRESPONDENCE
   Author: Cowers,  Joseph  A.:   US EPA
Recipient: Curtis,  Ian R.:  NJ Oept of Environmental Protection


Ooeunent Nunber:  SOP-002-0549  To 0549                                               Date: 02/26/90

Title: (Letter requesting  information regarding state ARARs and concerns as they pertain to the Swepe
       Oil and Chemical  Conpany site)

     Type: CORRESPONDENCE
   Author: Cowers,  Joseph  A.:   US EPA
Recipient: Curtis,  Ian R.:  NJ Dept of Environmental Protection


Document Nunfeer:-SOP-002-0550  To 0578        '                                      Date: 09/30/86

Title: Administrative Order en Consent, Index No. II CERCLA-60113, Swept Oil Superfund Site

     Type: LEGAL  DOCUMENT
   Author: Oaggett, Christopher j.:  us EPA
Recipient: none:   various  parties associated with the site

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08/26/91                             index Document Number Order                                 '           p,8e:
                                     SWOPE OIL SITE, OPERABLE  UNIT *2 Documents
DocilMnt Number: SOP-002-0579 To 0590                                               Date: 09/05/86

Title: (107(8) Notice Letter • nailing lift attached)

     Type: CORRESPONDENCE
   Author: Marshall, J«nes R.:  US EPA
Recipient: none:  various PRPs


Ooujnent Number: SOP-002-0591 To 0596                                               Date: 04/28/86

Title: C107(a> Notice Letter • mail ins Ust attached)

     Type: CORRESPONDENCE
   Author: Librizzi, Will lam J.:  US EPA
Recipient: none:  various PRPs


Oocuoent Nureber: SOP-002-0597 To 0607                                               Date: 04/18/86

Title: O07(«; Notice Letter • Bailing list attached)

     Type: CCSRESPONDENCE
   Author: Librizzi, William J.:  US EPA
Recipient: none:  various PRPs


Document Number: SOP-002-0608 To 0617                                               Date: 04/06/89

Title: Health Assessment for Sx»p* Oil Company,  Pennsauken,  Camden County, New Jersey CERCLIS No.
       MJD041743220

     Type: PLAN
   Author: none:  Agency for Toxic Substances t Disease Registry  (ATSDR)
Recipient: none:  none

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AUTHOR INDEX

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08/26/91                             Index Author Name Order                                                  p,Be:  i
                                     SUOPE OIL SITE,  OPERABLE UNIT «2 Doeunents
Document Nuifeer: SOP-001-0428 To 0519                                               Date: 09/01/87

Titli: Design Sampling Work Plan

     Type: PLAN
   Author: none:  none"
ttcipiem: none:  Swope Oil Company site


Document Nunber: SOP -002 -0529 To 0542                                               Date: 07/01/91

Title: Super find Program Proposed Plan:  Swope Oil  and Chemical Company site, Pemaauken Township,
       New Jersey

     Type: PLAN
   Author: none:  none
Recipient: none:  none


Oocuaent Nuifcer: SOP-001-0520 To 0589                                               Date: 09/01/87

Title: Work Plan for Supplemental Remedial Investigation/Feasibility Study at the Swope Oil and Chemical
       Company site, Peryuauken Township, Camden County,  Nev Jersey (Second Revision)

     Type: PLAN
   Author: none:  Ceraghty t Miller
Recipient: none:  none
Document tierce r: S2P-OC1-0590 To 0854        '•                                      Oate: 03/01/91

Title: Supplemental Remedial Investigation Conducted at the Snope Oil and Chemical Company Site,
       Pennaauken Township, Cwnden County, New Jersey, Volune I of V

     Type: REPORT
   Author: none:  Ceraghty t Miller
Recipient: none:  none

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08/26/91                             Indtx Author Nairn Order                                                  Page:  2
                                     SWOPE OIL SITE, OPERABLE UNIT 12 OocunentS
Oocuraent Number: SOP-001-085S To 090.5                                               Oat*: 03/01/91

Title: Supplemental  Remedial Investigation Conducted at the Swop* Oil  an* Cheoical Conpany Sitt,
       Pemaauken Township, Canden County, New J«r««y • Volim II of V

     Types «EPORT
   Author: none:  Gereghty I Hitler
Recipient: none:  none
Oocuwnt Mirfetr: SOP-001-0906 To  1333                   •                            Oatt:  03/01/91

Title: Supplemental  Kemediat Investtgatlon Conducted at the Suope Oil  and Chemical Coopany  Site,
       Penncauken Township, Camden County, New Jersey • Volune HI of  V

     Type: REPORT
   Author: none:  Ceraghty I Miller
leeipient: none:  none
Pocunent Nurtxr: SOP-001-13Ji  To  1713                                               Date:  03/01/91

Title: Supplemental  Remedial  Investigation Conducted et the Swope Oil  and Chemical Company  Site,
       Pennsauken Township, Camden  County, New Jersey, Volune IV of V

     Type: REPORT
   Author: none:  Ceraghty t Miller
leeipient: none:  none
Oocunent NumMr:-SOP-001-17U To  1932        '                                       Date:  03/01/91

Title: Supplemental  Remedial Investigation Conducted at the Swope Oil and Chemical Coopeny  Site,
       •emsauken Township, Caoden County, New Jersey, Voluae V ef V

     Type: REPORT
   Author: none:  Ceraghty t Hitler
leeipient: none;  none

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08/26/91                             Index Author Name Order                           .                       ftgt: 3
                                     SWOPE Oil SITE,  OPERABLE UNIT K Documents
Document Hu*er: SOP-001-1934 To 20U                  Parent: SOP-001-1933          Date: 05/01/91

Title: Addendum to the Supplemental  leneditl  Investigation for the Swope Oil «nd Chemical Company
       Site

     Type: REPORT
   Author: none:  US EPA
lecipient: none:  none
Document Number: SCP-001-2021 To 2038                  Parent: SOP-001-2020          Date: 04/10/90

Title: (Memorandum) US EPA Comments on the Inorginic  Data  Validation of  the Soil SaspleJ Collected
       •t the Swope Oil and Chemical Conpany Site,  Pennsauken, New  Jersey, During  the Deep Soil Boring
       Program

     Type: CORRESPONDENCE
   Author: none:  Ceraghty I Miller
lecipient: none:  US EPA
Document Nuntxr: SOP-001-2CUO To 2052                  Parent:  SOP-OD1-2039          Date: 03/29/90

Title: (Mencrinc^n) US EPA Comments Concerning Swope Oil  end Chemical  Company Site  Organic Data Validation
       for Soil S»nples Collected During the Deep Soil  lorfng Program

     Type: CORRESPONDENCE
   Author: none:  Ceraghty I Miller
Recipient: none:  US EPA
Becujnent Noiber: SOP-001-207A To 2087                                               Date:  06/01/90

Title: Feasibility Study Work Plan, Swope Oil and Chemical  Company Site,  Penraau-.en Township, Canden
       County, New Jersey

     Type: PLAN
   Author: none:  Ceraghty ( Miller
lecipient: none:  Swope Cleanup Conn ittee

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08/26/91                              Ind«x Author Name Order                                                  page. ^
                                     SUOPE OIL SITE, OPERABLE UNIT f2 Documents
Oocanent Nirber:  SOP-001-208a  To  2249                                                0*t«:  05/01/91

Title: Supplemental  Feasibility Study  for  tht Swop* Oil and Chenical Company Sltt;  Pemsauken Township,
       Camber, County,  New  Jersey. Volumt I of IV

     Typt: PLAN
   Author: none   Ctrighty t Htlltr
Recipient: none:   non*
Docimnt Nurtser:  SOP-001-2250  To 2380                   •                            0*t«:  05/01/91

Title: Supplemental  F*»»ibility Study  for  the Swopt Oil and Chemical Company Site,  Pemsauken Township,
       Camden County,  Ne«  Jersiy,  Volume  II of IV

     Type: PUN
   Author: none:   C«rtghty t Miller
Recipient: none:   none
Docunent Nunfeer:  SOP-002-0001  To 0242                                                Date: 05/01/91

Title: Supplemental  Feasibility Study  for  the Swope Oil and Chemical Company Site,  Pemsauken Township,
       Canden County,  New Jersey,  Volume  III of IV

     Type:  PLAN
   Author:  none:   Ccraghty t Miller
Recipient:  none:   none
Document Nunb*r:-SOP-002-0243  To 0479                                               Date: 05/01/91

Title: Risk Assessment  for  the Swop* Oil  and Chemical Company site, Ptnr»auken Township, Candcn County,
       New Jersey,  Votim IV of IV

     Type: PLAN
   Author: non*: Ceraghty ( Miller
Recipient: none: none

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08/26/91                             Index Author Name Order                                                  Page:  5
                                     SWOPE OIL SITE,  OPERABLE UNIT «2 Documents
Document Kuntxr: SOP-002-0480 To  MM                                             '  Oiti: 07/01/91

Title: Shallow Ground-Water Monitoring Plan of the Supplemental Feasibility Study for the Swope Oil
       and Chemical Company Site, Penmeuken Township,  Caoden County, Hew Jersey

     Type: PLAN
   Author: none:  Geraghty i Mi ll«r
Recipient: none:  none
Document Nirter: SOP-002-0495 To 0538                   •                            Date:   /  /

Title: Addendun to the Supplemental  Feasibility Study and Risk Assessment for the Swope Oil end Chenical
       Company Site

     Type: PLAN
   Author: none:  US EPA
•eeipient: none:  none
Document Kinotr: SOP -002 -0608 To 0617                                               Date: 04/06/89

Title: Health Assessment for Swop* Oil Company,  Pennsauken,  Canden County, Neu jersey CEKCLIS No.
       KJDOA17.3220

     Type: PLAN
   Author: none:  Agency for Toxic Substances t  Disease Registry  (ATSOR)
Recipient: none:  none
Document Nui6er:-$OP-001-1933 To 1933                                               Date: 05/22/91

Title: (Letter approving the Supplemental Remedial Investigation  (HI) Report for the Suope Oil and
       Chemical Company site and forwarding the Addendun Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Nicoloro, Robert:  ENSR
 Attached: SOP-001-1934

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08/26/91                              Index Author Nm Ord«r                                                  Page: 6
                                     SWOPE OIL SITE, OPERABLE UNIT « Docunents
Oounent Number:  SOP-001-2018  To 2019                            .             .       Data: 07/06/90

Title: 
-------
08/26/91                             Indtx Author Nnc Order                                                  ttge: 7
                                     SVOPE OIL SITE,  OPERABLE LIMIT «2 Documents
Document Number: SOP-001-20M To 20M                                               Date: 06/30/83

Titlt: (Letter stating that EPA •pprovei the Operations Plan  for the Supplemental RI/FS at the Swape
       Oft and Chemical Conpany tfte, •« well at the Addendum to the Operation* Plan)

     Type: CORRESPONDENCE
   Author: Czapor, John V.:  US EPA
Recipient: Oiks, Diane:  DeSoto
Document Number: SOP-001-2065 To 2065                   •                            Date: 01/13/88

Title: (Letter atating that EPA approve* the fwope Oil  and Chemical Company Work Plan for the Supplemental
       RI/FS and that deep soil borings oust be performed as part of the Rl/FS)

     Type: CORRESPONDENCE
   Author: Czapor, John V.:  US EPA
Recipient: Walanski, E.A.:  OeSoto
Coojwnt Number: SOP-002-0550 To 0578                                               Date: 09/30/86

Title: Administrative Order on Consent, Index No.  tl  CERCLA-60113, Swope 0(1 Superfund Site

     Type: LEGAL DOCUMENT
   Author: Daggett, Christopher J.:  US EPA
Recipient: none:  various parties associated with  the site


Document Kumoer; SOP-002-0547 To 0547        _                                       Date: 11/15/90

Title: (Letter in irfiich CPA requests that the New  Jersey Oepartatnt of Environmental Protection (NJDEP)
       provide all New Jersey state ARARs regarding the discharge of  treated groundwater from the
       site to the Pennsauken Creek and the Delaware River)

     Type: CORRESPONDENCE
   Author: Cowers, Joseph A.:  US EPA
Recipient: Curtis, Ian R.:  NJ Dept of Environnantal  Protection

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08/26/91                             Index Author Naae Order                                                  Page:  8
                                     SW5PE OIL SITE, OPERABLE UNIT *2 Documents
Ooevwent «u*er:  SOP-002-0548  To  0543                                               Data: 06/04/90

Tltli: (letter requesting additional  New Jersey stats ARARs)

     Type:  CORRESPONDENCE
   Author:  Cower*,  Jos*ph A.:  US EPA
Recipient:  Curtis,  Iin «.:  MJ Dept of  Environnental Protection


Document Munber:  SCP-002-0549  To  0549                                               Date: 02/26/90

Title: (Letter requesting  infernal ion regarding state ARAR* and concern* as they pertain  to  the Swop*
       Oil  and Cheoical Company site)

     Type:  CORRESPONDENCE
   Author:  Covers,  Joseph A.:  US EPA
Recipient:  Curtis,  Ian R.:  NJ Dept of  Environmental Protection


Ooctment Nunber:  SOP-001-2066  To  2067                                               Date: 01/05/U

Title: (Letter confirming a December  7,  1987, conversation discussing the lopleaentation  of  a  soil
       boring program at the Swope Oil  site)

     Type:  CORRESPONDENCE
   Author:  Cuarraia,  Philip D.:   US EPA
Recipient:  Watantki,  K.A.:  DeSote


Docunent Number:  SOP-001-2068  To  2073        •                                       Date: 10/20/87

Title: (Letter stating that EPA approves CRT's Design Sailing Work Plan (Septaober, 1987) for the
       Suope Oil  and  Chemical  CoBpany site provided that the attached nodif leations are ccoplied  with
       during the appropriate  activities)

     Type:  CORRESPONDENCE
   Author:  Cuarraia,  Philip 0.:   US EPA
Recipient:  Mfcotoro,  Robert:   ERT

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08/26/91                             Index Author Mine Order                                                 plge: 9
                                     SVOPE OIL SITE,  OPERABLE UNIT f2 DocunentS
Document Number: SOP-002-0591  Te 0596                                               Date: 04/28/86

Title: (107(1) Notice Letter • tilling ittt attached)

     Type: CORRESPONDENCE
   Author: Llbrizii. vfllfam J.:  US EPA
Recipient: none:  vtriou* PRPs


Document Ntrotr: SOP-002-0597 To 0607                                               Olte: 04/18/86

Title: (107(i) Notice Letter • mailing list attached)

     Type: CORRESPONDENCE
   Author: Librizri, William J.:  US EPA
Recipient: none:  various PRP$


Document Nusber: SOP-001-201S To 2015                                               Dete: 03/13/91

Title: (Letter discuts ins the obtiining of in Industriil  Pretreetfflent  Permit to dischirge treited
       jrouncxiter from the Sxope Oil iite)

     Type: CCRRESPOMOENCE
   Author: Loperfido, Senuel M.t Jr.:  Cimden County Municipal  Utilities Authority
Recipient: Covers, Joseph A.:  US EPA


Document Nireer: SOP-OC2-0579 To 0590                                               Olte: 09/05/86

Title: (107(i) Notice Letter • milling list attached)

     Type: CORRESPONDENCE
   Author: Marshall, James I.:  US EPA
Recipient: none:  various PRPs


eocunem Hunter: SOP-001-2020 To 2020                                               (ate: 04/17/90

Titla: (Letter forwarding the attached sttnorandua addressing consents  provided In EPA't February
       S, 1990, ateno In connection with the Inorganic  data validation  for  the  deep  soil boring program)

     Type: CORRESPONDENCE
   Author: Newton, Douglas J.:  Ceragttty * Nfder
Recipient: Cowers, Joseph A.:  US EPA
 Attached: SOP-001-2021

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08/26/91                             Index Author Name Order                                                   Page:  10
                                     SWOPE OIL SITE, OPERABLE UNIT *2 Documents
Document Number:  SOP-001-2039 To 2039                                               Data: 04/17/90

Tttlt: (Letter forwarding  tht attached atemoranduB addressing eooMntt provided in EPA't December
       20,  1989,  letter In connection with tht Organic Data Validation for the deep soil boring program)

     Type:  CORRESPONDENCE
   Author:  Newton,  Douglas J.:  Ceraghty ( Miller
Recipient:  Jackson, Amelia:  US EPA
 Attached:  SOP-001-2040

Oocunent Ninber:  SOP-001-2056 To 2057                   •                            Date: 10/20/88

Tftte: (Letter following-up on a telephone conversation  indicating that EPA ia In agreement with
       the list of  analyses to be performed on the toil  samples that will be collected at the Swope
       Oil  tite)

     Type:  CORRESPONDENCE
   Author:  Newton,  Douglas J.:  Ceraghty I Miller
Recipient:  Dun*«1 man,  Thomas:  US EPA
Document Number:  SOP-001-2061  To 2063                                               Date: 09/19/88

Title: (Letter describing concerns about the proposed  locations for wells GM-2D, W-5S, end  GM-5D.
        Soil boring location map attached)

     Type: CORRESPONDENCE
   Author: Newton, Douglas J.:  Ceraghty t Miller
Recipient: Dunkelman,  Thomas:   US EPA
Oocunent Number: SOP-001-2053 To 2055                                               Oate:  11/01/89

Title: (Letter approving an amendment to the Operation*  Plan  for  the Supplemental II/FS.  location
       of downgradient wells, and a time extension for the Draft  (I Report sutnittal)

     Type: CORRESPONDENCE
   Author: Pavlou, George:  US IPA
Recipient: Oiks, Diane:  Delete

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08/26/91                          .   index Author Name  Order             '                                     Page:  11
                                     SUOPE OK SITE,  OPERABLE UNIT «2 Documents
Document Number: SOP-001-2016 To 2017                                               Oite: 02/27/91

Titlt: (Letter advising of the rtsutts of discussions  with  the Candcn Canty Municipal utilities
       Authority (CCMUA) and the Pennsauken Sewerage Authority (PSA) with rtg*rd to the acceptance
       ef treated groundwater fron the Swop* Oil  site)

     Type: CORRESPONDENCE
   Author: vernick, Arnold S.:  Gereghty 4 Miller
R:cfpient: Cowers, Joseph A.:  US EPA
Coeunent Nurtoer: SOP-001-0001  To 0239                                               Date: 07/01/8S

Title: Operations Plan for the Supplemental  Remedial  Investigation/Feasibility Study at the Swope
       Oil and Chemical Company Site, Pemsauken Township, Camden Covnty, Meu Jersey (Second Revision)

     Type: PLAN
   Author: Wolfert, Michael F.:  Gerajhty I  Milter
lecipient: none:  none
document uartoer: SOP-001-0240 To 0427                                               Date: 07/01/8S

Title: Addendum to the Operations Plan for the Swope Oil and Chemical Company Site, Pennsauken, New
       Jersey (Second Revision)

     Type: PLAN
   Author: Wolfert, Michael F.:   Ceraghty t Miller
Recipient: none:  none

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CHRONOLOGICAL INDEX

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08/26/91                             Index Chronological  Order                                               Page: 1
                                     SWOPE OIL SITE,  OPERABLE  UNIT  f2 Documents
Ooeunent Number: SOP - 002-W 95 Te 0528                                               Date:   /  /

Title: Addendum to the Supplemental Feasibility Study »nd Risk  Assessment  for  the Swop* 011 and Chemical
       Ceopany Site

     Type: PLAN
   Author: none:  US EPA
leeipient: none:  none
fioevnent Nuaber: SOP-002-0597 To 0607                   .                            Bate: 04/16/86

Title: (107(a) Notice Letter • Bailing list attached)                               _ .   .  • _ .

     Type: CORRESPONDENCE
   Author: librizzi, William J.:  US EPA
leeipient: none:  various PRPs


Document Nurber: SOP-002-0591 To 0596                                               Date: 04/28/86

Title: (107(«) Notice Letter • mailing list attached)

     Type: CCKKcSrCNSEliCE
       :r: Librizzi, William J.:  US EPA
kecipient: none:  various PRPs


Document Number: SOP-002-0579 To 0590                                               Date: 09/05/86

Title: (107(a) Notice Letter - nailing list attached)

     Type: CORRESPONDENCE
   Author: Marshall, Janes R.:  US EPA
leeipient: none:  veriou* PRPs


Document Nuober: SOP-002-0550 To 0578                                               Date: 09/30/86

Title: Administrative Order en Consent, Index Mo.  II CERCLA-60113,  Suope Oil  Superfund Site

     Type: LEGAL DOCUMENT
   Author: Oaggett, Christopher J.:  US EPA
Recipient: none:  various parties associated with  the site

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08/26/91                              Index Chronological Order                                                Page 2
                                     SWOPE OIL SITE, OPERABLE UNIT *7 Documents
Document Number:  SOP-001-0428 To  0519                                                Date: 09/01/87

Title:  Design Sampling Work  Plan

     Type: PLAN
   Author: none:   none'
Recipient: none:   Swope  Of I  Company site


 icument Nircer:  SOP-001-0520 To  0589                                                Date: 09/01/87

Title:  Work Plan for Supplemental Remedial  Investigation/Feasibility Study at the Swope Oil and Chemical
       Company Site, Pemsauken Township, Caoden County, New Jeraey (Second Revision)

     Type: PLAN
   Author: none:   Ceraghty t Miller
Recipient: none:   none


Document Number:  SOP-001-2068 To  2073                                                Date: 10/20/87

Title:  (Letter itating  that  EPA approves ERT't Design Sampling Work Plan (September, 1987) for the
       Suope Oil  and Chemical Company  site  provided that the attached modifications are complied with
       during the appropriate activities)

     Type: CORRESPONDENCE
   Author: Cuarraia, Philip  D.:  US EPA
Recipient: Nicolc-o, Robert:  ERT


Document Number:-SOP-001-2066 To  2067         '                                       Date: 01/05/88

Tittt:  (Letter confirming a  December 7, 1987, conversation discussing the ioplmentation of • toll
       boring program at the Swope Oil site)

     Type: CORRESPONDENCE
   Author: Cuarrala, Philip  0.:  us EPA
Recipient: Ualanskl, K.A.:  OeSoto

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08/26/91                             Index Chronological  Order                                   '            pBge. 3
                                     SVOPE OIL  SITE,  OPERABLE  UNIT  *2  Documents
Document Mumper: SOP-001-2065 To 2045                                               o»te: 01/13/88

Title: (Letter stating that EPA approves the Swope Oil  and Chemical  Ccopany Work Plan for the Supplemental
     . ll/FS and that deep soil borings tust be performed as  part  of the RI/FS)

     Type: CORRESPONDENCE
   Author: Cjtpor, John V.:  US EPA
lecipient: Walanski, K.A.:  OeSoto
Oocunem Umber: SOP-001-0001 To 0239                   -                            -Oete: 07/01/88

Title: Operations Plan for the Supplemental  Remedial  Investigation/Feasibility Study at the Swope
       Oil and Chemical Company Site, Pennsauken Township,  Camden  County,  New Jersey (Second Revision)

     Type: PLAN
     —,or: wolfert, Nichael F.:  Ceraghty t  Miller
Recipient: none:  none
Document Kunber: SOP-001-0240 To 0427                                               Date: 07/01/88

Title: Addendum to the Operations Plan for the Swope  Oil  and Chemical  Conpeny Site, Pennsauken, New
       Jersey (Second Revision)

     Type: PLAN
   Author: Uolfert, Michael F.:  Ceraghty t Miller
lecipient: none:  none
Document Nunber:-SOP-001-206A To 2064         '                                      Date: 08/30/88

Title: (Letter stating that EPA approves the Operations  Plan for  the  Supplements I RI/FS at the Swope
       Oil and Chemical Conpany site, as well as  the Addendum to  the  Operations Pi an)

     Type: CORRESPONDENCE
   Author: Czapor, John V.:  US tPA
lecipient: Oiks, Diane:  OeSoto

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08/26/91                             Index Chronological Order                                                Page: 4
                                     SUOPE OIL SITE, OPERABLE UNIT *2 Documents
Document Nusber: SOP-001-2041  To 2063                                               Dati: 09/19/88

Title (Utter describing eonctrns about the proposed  locations for Utlla GM-2D, GM-5S, and CX-50.
        Soil  boring location map attached)

     Type: CORRESPONDENCE
   Author: Newton,  Douglas J.:  Geraghry I Millar
lecipient: Ounkelman,  Thomas:   US EPA
Oocuwnt Nunber: SOP-001-2058 To 2060                  •                            Data: 10/14/88

Title: (Latter approving several changes to the Operations Plan (OP) for the Supplemental II/FS at
       the S«op« Oil site and forwarding additional carmenti on the Addendum of the OP)

     Type: CORRESPONDENCE
   Author: Czspor, John V.:  US EPA
lecipient: Oiks, Diane:  DeSoto
Document Number: SOP-001-20J6 To 2057                                               Date: 10/20/88

Title: (Letter foltowing-up on a telephone conversation  indiesting that EPA is In agreement with
       the list of analyses to be performed on the  soil  samples that will be collected at the Suope
       Oil site)

     Type: CORRESPONDENCE
   Author: Newton, Douglas J.:  Ceraghty t Millar
tecipient: Dunkelman, Thomas:  US EPA
Document Number: SOP-002-0608 To 0617                                               Date: 04/06/89

Title: Health Assessment for Swop* Oil Company,  Pennsauken,  Canden County, New Jersey CIRCLIS do.
       HJ0041743220

     Type: PLAN
   Author: none:  Agency for To*ie Substances t  Disease  Registry (ATSOR)
Recipient: none:  none

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02/26/91                             index Chronological Order                                                page: 5
                                     SWOPE OIL SITE,  OPERABLE UNIT #2 Documents
Deeunent Number: SOP-001-2053 To 2055                                               0»t«: 11/01/89

Title (Letter approving an amendment to the Operation  Plan for the Supplemental RI/FS, location
      • of downgradient M*U«, and a tin* ax ten* ion for the Draft HI deport •ubnittal)

     Type: CORRESPONDENCE
   Author: Pavlou, George:  US EPA
Recipient: Diks. Oiane:  OeSoto
Document Number: SOP-002-0549 To 0549                   .                         .   Date: 02/26/90

Title: (Letter requesting information regarding state  ARARi  and concern* a* they pertain to the Swop*
       Oil and Chemical Company aite)

     Type: CORRESPONDENCE
   Author: Covers, Joseph A.:  US EPA
Recipient: Curtis, Ian R.:  NJ Dept of Environmental Protection
Document Nuroer: SOP-001-2WO To 2052                  Parent: SOP-001-2039          Date: 03/29/90

Title: (Memcrandir:) US EPA Garments Concerning Swope Oil  and Chemical Company Site Organic Data Validation
       for Soil Samples Collected During the Deep Soil  Soring Program

     Type: CORRESPONDENCE
   Author: none:  Ceraghty t Miller
Recipient: none:  US EPA
Document NuTfcer:-SOP-001-2021 To 2038                 Parent: SOP-001-2020          Date: 04/10/90

Title: (Memorandum) US EPA Conmenta on the Inorganic Data  Validation of the Soil Samples Collected
       at the SMODC Oil and Chemical Company Site,  Pemaauken, New Jersey, During the Deep Soil Boring
       Program

     Type: CORRESPONDENCE
   Author: none:  Ceraghty t Miller
Recipient: none:  US EPA

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08/26/91                             Index Chronologic*! Ord«r                                                Page: 6
                                     SWOPE Oil SITE, OPERABLE UNIT *2 Documents
Document Nuafcer:  SOP-001-2020  To 2020                                                oete: 04/17/90

       (Letter forwarding  tht  attached memorandum addressing eofimnts provided in EPA's February
       5, 1990, nemo in eon-net ion with  the inorganic data validation for the deep eoil boring program)

     Type: CORRESPONDENCE
   Author: Hewton,  Doug Ia* J.: Gereghty t Miller
Itefpient: Cowers,  Joseph  A.:  US EPA
 Attached: SOP-001-2021

Ooeunem Ntraber:  SOP-001-2039  To 2039    '              .                            Cate: 04/17/90

Title: (Letter forwarding  the  attached CMoorandkB addressing cements provided in EPA's Decenber
       20, 1989,  letter in connection  with the Organic Data Validation for the deep soil boring program)

     Type: CORRESPONDENCE
   Author: Newton,  Oouglas J.: Ceraghty t Miller
lecipient: Jackson, Amelia:  US EPA
 Attached: SOP-CO1-2040

Document Nunber:  SOP-001-2074  To 2087                                                Date: 06/01/90

Title: Feasibility Study Work  Plan, Swop* Oil and Chemical Company Site, Pemsauken Township, Camden
       County, Ne« Jersey

     Type: PUN
   Author: none:   Cenphty t Miller
lecfpient: none:   Svope Cleanup Committee
Document NLPOer: JOP-002-0544  To  OSiB        ,'                                       Date: 06/M/90

Title: (Letter requesting additional New Jersey atate AJUJts)

     Type: CORRESPONDENCE
   Author: Cowers,  Joseph A.:  US CPA
lecipient: Curtis,  Ian «.:  NJ Dept Of Invfreraental Protection

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OS/26/91                             Indtx Chronological  Order                                                Page:  7
                                     SVOPE OIL SITE,  OPERABLE UNIT f2 Documents
Document Nurcber: SOP-001-2018 To 2019                                               Ottt: 07/06/90

Title: (Letter approving the Feasibility Stuoy (FS) Kork plan  for the Supplemental RI/FS)

     Type: CORRESPONDENCE
   Author: lasso, Raymond:  US EPA
Recipient: Oiks, Diane:  OeSeto


Document Number: SOP-002-0547 To 0547                                               Date: 11/15/90

Title: (Letter in which EPA requests that the Me* Jersey Department  of Environmental Protection (NJDEP)
       provide all New Jersey state ARARs regarding the discharge of treated grounduater from the
       site to the Pennsauken Creek and the Delaware River)

     Type: CORRESPONDENCE
   Author: Cowers, Joseph A.:  US EPA
Recipient: Curtis, Ian R.:  NJ Dcpt of Environmental Protection


Document Number: SOP-002-0544 To 0546                                               Date: 12/13/90

     • (Letter submitting New Jersey State applicable or relevant and appropriate requirements (ARARs)
       wnicn pertain to the Suope Oil and Chemical site located In Pennsauken  Township, New Jersey)

     Type: CORRESPONDENCE
   Author: Curtis, Ian R.:  NJ Dept of Environmental Protection
Recipient: Cowers, Joseph A.:  US EPA


Document Number:-SCP-001-2016 To 2017       •                                       Date: 02/27/91

Title: (Letter advising of the results oi discussions with the Canritn County Municipal Utilities
       Authority (CCMUA) and the Pennsauken Sewerage Authority (PSA) with  regard to the acceptance
       of treated groundwater from the Swoc* Oil site)

     Type: CORRESPONDENCE
   Author: Vernick, Arnold S.:  Ceraghty I Miller
Recipient: Covers, Joseph A.t  US EPA

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08/26/91                             Index Chronological Order                                                p,ge: 6
                                     SWOPE OIL SITE, OPERABLE UNIT tZ Documents   •
Document Nutter: SOP-001-0590 To MS*                                               Citt: 03/01/91

Title: Suopteinenut  Remedial  Investigation Conducted it the Swope Oft end Chemical Company Site,
       Pemsauken Township, Caraden County, Mew Jersey, Votum I of V

     Type: REPORT
   Author: none:  Geraghty <  Miller
(eeipient: none:  none
Oocunent Nurtoer: SOP-001-0855 To 0905                  •                            Date: 03/01/91

Title: Supplemental Remedial  Investigation Conducted at the Swope Oil and Chemical Company Site,
       Pemsauken Township,  Camden County, New Jersey • Volume II of V

     Type: REPORT
   Author: none:  Cerighty t Miller
Recipient: none:  none
Document Number: SOP-001-0906 To 1333                            '                   Oate: 03/01/91

Titlt: Supplemental Remedial  Investigation Conducted at the Swope Oil and Chemical Company Site,
       Pemsauken Township,  Ce/nden County, New Jersey - Volume III of V

     Type: REPORT
   Author: none:  Ceraghty t Miller
Recipient: none:  none
Document Nunber:-$OP-001-1334 To 1713                                               Oate: 03/01/91

Title: Supplemental Remedial  Investigation Conducted at the Swop* Oil and Chemical Conpany Site,
       Pennsauken Township, Caflrien County, MM Jersey, Volume IV of V

     Type: REPORT
   Author: none:  Ceraghty t  Millar
Recipient: none:  none

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08/26/91                             Index Chronological  Order                                               Page: 9
                                     SWOPE OIL SITE,  OPERABLE UNIT 12 Documents
Doeunent «Li*er: SOP-001-1714 To 1932                                               Ditt: 03/01/91

Title Supplrmentil Remedial Investigation Conducted it  the Swope Oil and Cheoicil Company Site,
       Pemsauken Township, Caraben County, Mew Jersey, Voluae V of V

     Type: REPORT
   Author: none:  Geraghty I Mi Her
Recipient: none:  none
Oocunent number: SOP-001-2015  To 2015                   •                            Datt: 03/13/91

Title: (Letter discussing the  obtaining of in Industrial Pretreatment Permit to discharge treated
       groundwater from the Swope Oil site)

     Type: CORRESPONDENCE
   Author: Loperfido, Sanuft M., Jr.:  Cimden County Municipal Utilities Authority
Recipient: Cowers, Joseph A.:   US EPA
Document Kuicer: SOP-001-1934 To 2014                  Parent:  SOP-001-1933          Date: 05/01/91

Title: Aocencjs to the Supplemental Remedial  Investigation for  the Swope Oil and Chemical Conpany
       Site

     Type: REPORT
   Author: none:  US EPA
Recipient: none:  none
Document Number:-SOP-001-20U To 2249                                               Date: 05/01/91

Title: Supplemental Feasibility Study for the Swope Oil and Chemical Conpany Site; Penniauken Township,
       Camden County, «*w Jersey, Volume 1 of IV

     Type: PLAN
   Author: none:  Ceraghty t Miller
Recipient: none:  none

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08/26/91                             Index Chronological Order                                                Page: 10
                                     SUOPE OIL SITE, OPERABLE UNIT K Documents
Bocument Number:  SOP-001-2250  To 2380                                                Date 05/01/91

Title: Supplemental  Featfbfllty Study  for  the Swop* OU and CheatcaI Company Site.  Penroauken Te«nship,
       Canden County,  New  Jersey,  Volume II  of IV

     Type: PLAN
   Author: none:   Ceraghty t Miller
leelpient: none:   none
Document Nuifcer:  SOP-002-0001  To 0242                   -                            Date: 05/01/91

Title: Supplemental  Feasibility Study  for the Swope 011 and Chemical Company Site,  Permsaufcen Township,
       Camden County,  New  Jersey,  Volume III of IV

     Type: PLAM
   Author: none:   Ctraghty I Milter
leelpient: none:   none
Boeunent Num&er:  SOP-002-0243  To 0479                                               Date: 05/01/91

title: Risk Assessment  for  the Swop* Oil  and Chemical Company Site, Pennsauken Township, Camden County,
       New Jersey,  Volume  IV of IV

     Type: PLAN
   Author: none:   Geraghty t Miller
Iceipient: none:   none
Document «u*er:-$OP-001-1933 To 1933                                               Oat*: 05/22/91

Title: (Letter approving the  Supplemental  Remedial  Investigation 
-------
02/26/91                             Index Chrone logic*I  Order                                               fejt:  11
                                     SWOPE OIL SITE, OPERABLE UNIT  (T2 Documents
Doeui«nt Hotter: SOP-002-0529 To 0542                                               Dite: 07/01/91

Title: Superfund Program Proposed Plan:  Suope Oil end Chemical  Company Site, Pemsaulcen Township,
      • Hew Jersey

     Type: PLAN
   Author: none:  none
lecipient: none:  none
Document Nunber: SOP-002-OA80 To 0494                   .                          .  c»tt: C7/01/91

Title: Shallow Ground-Water Monitoring Plan of the Supplemental  Feasibility Study  for the Swope Oil
       and Chemical Company Site, Pennseuken Township,  Camden County,  New Jersey

     Type: PLAN
   Author: none:  Geraghty t Mi Her
Recipient: none:  none
Document Nurtoer: SOP-002-0543 To 0543                                               Date: 07/15/91

Title: (Letter amending and approving the May 1991 Supplemental  FS  and Risk  Assessment Reports for
       the Swope Oil end Chenical  Company site)

     -VDC: CORRESPONDENCE
     -•;-: Basso, Raymond:  US EPA
lecipient: Nicoloro, Robert:  ENSR

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APPENDIX D - KJDEPE LETTER OF CONCURRENCE

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                                      State of New Jersey
                        Department of Environmental Protection And Energy
                                     Office of tht Commissioner
                                           CN402
                                     Trenton. NJ 06625-0402
                                      Tel.» 609-292-Z88S
Scott A Wcincr                           fui. • 609-964-3962


                                                   October 2,  1991

      Mr. Conscsntlne Siciamon-Erlstoff
      Regional Adniniat/ator
      USEPA Region  II
      26 Federal Plate
      New York, KY  10776

      Dear hi. Sidanon-irietoff•-

      Re:  Kecord of r-tcision, Svcpc Oil.  Fenueaukea Township
           Casden County, New Jersey

           'hit  is  tc-  fomally  notify  the  Ur.lced  Stares  Envlrcraer.tsl Protection
      Age.icy thac the Vev Jereey tepartntnc of  Enviror.sfcntal Protection and Energy
      hat  evaluetec- th*  telectfed plan  for the remedial action  at  the  Swope Oil
      S-perfurd  £it«  ind  cor.curs vlth the  rer.edy «E stated  lr. the final Record of
      Decision.

           Tr.is  r.ccord  of Ctfislon  la  for  the  volatile and secil-volatile organic
      cor.tenlnattc1  subsurface  solla.   It  la  understood  that  after  the Initiation
      of  chi«s  remedial  action,  it  will   be   determined  whether  ground  water
      remediation will be necessary.

           The components of the  Record  of Declaiou include:

           *    Vapor extraction  •y»tet; 7                                        ~
           *    Enhanced blorenBdiation;
           *    Quarterly ground water Bonltoring.

           Kev Jersey  fully appreciate* the importance  of the Record  of Lccislen
      lr.  the  cleanup process  and will  continue  to taVe  all reasonable  step* :o
      er.aure that the State's coamitaenta  in this  area are icel.
                                               Scott A.  Welnlr
                                               Cosmiaalooer
      SAV:?H/kj
                                               tft*

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           APPEKDIT X
Proposed Flan and Public consent*

-------
                     ATTACHMENT A.I
Proposed Plan for the 6vop* Oil  and Cba&ieal  Company 8it«

-------
Snperfimd Program Proposed Plan.
      SWOPE  OIL  AND CHEMICAL  COMPANY  SITE
               PEIVXSAIEBV TOWNSHIP, NEW JERSEY
 O EPA
Region 2	    July 1991
EPA ANNOUNCES PROPOSED
PLAN

This Proposed Plan  describes the
preferred alternative for remediation of
contaminated subsurface soils at the
Swope  Oil  and Chemical  Company
Superfund   site  (Swope  site)   in
Pennsauken  Township,  Camden
County, New Jersey. This document is
issued  by  the U.S.  Environmental
Protection  Agency (EPA),  the  lead
agency for site activities, and the New
Jersey Department of Environmental
Protection   (NJDEP),  the  support
agency for this response action. EPA,
in consultation with NJDEP, will select
the remedy for the subsurface soils at
the site, only after the public comment
period  has  ended and information
submitted during  this time has been
reviewed and considered,
THE COMMUNITY'S ROLE IN
THE SELECTION PROCESS

EPA is issuing this Proposed Plan as
part   of   its  public  participation
responsibilities under Section 117(a) of
the  Comprehensive   Environmental
Response, Compensation, and Liability
Act of 1980, as  amended  by the
Superfund   Amendments  and
Reauthorization Act of 1986.  This
Proposed Plan summarizes information
that can be found in greater detail in
the   Supplemental  Remedial
Investigation  (RI)  report,   the
Supplemental Remedial Investigation
Addendum, the Supplemental
                                    tat MAT rot nt iwon on. ANB
                                                         IGU. COMTAXY cawvm an.

-------
 Feasibility  Study  (IS),  the  "Bisk
 Assessment,  the  Addendum  to the
 Supplemental FS and Risk Assessment
 and other documents coata&ed in the
 administrative record file for this site.
 EPA and NJDEP encourage the public
 to review these documents in order to
 gain  a   more  comprehensive
 understanding  of the  site aad the
 related Superfund activities conducted
 to date. These documents are available
 to  the public in  repositories at the
 following locations:
    Pennsanken Township library
   , 5605 North Cresent Boulevard
    Pennsauken, New Jersey 08110
I          (609) 665-5959  "
I-                   ,   v> ^
flours: M,W,Thurs. 9:30am-9:00pm
       T.F       ' 9-.30am-6;DOpm
       Sat        10;00am-l:00pm
r
            and   -•--"-'"',;,  '•'

        Clerk's Office
Fennsauken Municipal Building
  5605 North Cresent Bhwy  ~-
   Pennsauken, N J 08110
        (609)665-1000,   .,
Hours: M-F
              8:30am-4:30pm •
EPA, in consultation with NJDEP, may
modify  the   preferred  alternative
presented  in this Proposed Plan and
the Supplemental  Feasibility Study
based on  new information or public
comments.  Therefore, the  public is
encouraged to review and comment on
all of the alternatives identified in this
                                         BATES TO REMEMBER
                                      July 18,1991 - August 17,1991
                                     *ublic comment period for ''^ -   ^
                                     bntaminated subsurface soil preferred
                                     emedy.',,,'-    ,,,(  "/v'Ji	

                                         Thursday August 1,1991
                                             Public Meeting at
                                       Pennsauken Municipal Building
                                       €605 North Cresent Boulevard
                                       Pennsauken, New Jersey 08110
EPA solicits input from the community
on the cleanup methods proposed for
each Superfund response action.  EPA
has set a public comment period from
July 18,1991 through August 17,1991,
to encourage public participation in the
selection  of a remedy  for the Swope
site. The comment period includes a
public  meeting at  which  EPA will
discuss  the   Supplemental   RI,
Supplemental   RI   Addendum,
Supplemental FS, Risk Assessment, the
Addendum to the Supplemental FS and
Risk Assessment  and Proposed Plan,
answer questions, and accept both oral
and written comments.

The public meeting for the Swope site
is scheduled for August 1, 1991, from
7:00pm to 9:00pm, and will be held at
the Pennsauken Township Municipal
Building,  5605   North   Cresent
Boulevard, Pennsauken, New  Jersey
08110.

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Comments  will be  summarized '-and
responses   provided   in  the
Responsiveness Summary section of the
Record of Decision.  The Record of
Decision  will be the document that
presents  EPA's final selection for the
subsurface  soil cleanup.    To  send
written  comments  or obtain  further
information, contact:
          Joseph Cowers
          Project Manager '
 J.S. Environmental Protection Agency
      Emergency & Remedial    .4
I -    -   Response Division - "-' .  73
i    26 Federal Plaza, Room 720    "
\"'  New York, New York 10278
All comments must be postmarked on
or before August 17,1991 for inclusion
in   the  Record  of  Decision
Responsiveness Summary.
SITE BACKGROUND

The site, approximately two acres in
size, is located in an industrial complex
in northern Pennsauken  Township,
Camden County, New Jersey.  The
triangular  site  is  bounded  on  the
southeast by National Highway, and on
the north  and southwest by railroad
rights-of-way and warehouses (refer to
site location map).   The Pennsauken
Creek and the Delaware  River  are
located 0.8 miles northeast and 12
miles  northwest   of  the  site,
respectively.  Two  municipal  water
supply  wells   operated   by   the
Merchantville-Pennsauken  Water
Commission, MPWC Well 1 and MPWC
Well 2, are located approximately 275
feet southwest and 1500 feet northeast
of the site. Pennsauken High School is
located   approximately  0.5  miles
northeast  of the  site.   The nearest
residential areas are in the Townships
of Delair and Morrisville, which are
located about 0.5  miles west and 0.8
miles   southwest  of  the   site,
respectively.

From 1965 to 1979, the Swope Oil and
Chemical Company operated a chemical
reclamation   facility  that   included
buying, selling and processing solvents,
oils,  plasticizers, hydraulic fluids and
other chemicals.  In 1975, inspectors
from NJDEP cited the Swope Oil and
Chemical   Company  for  operating
without proper permits.  The  Swope
Oil and Chemical  Company was cited
again in 1979 for failure to prepare,
maintain, or fully implement a Spill
Prevention,   Control   and
Countermeasures Plan.  The company
ceased operation in December 1979.

During operation of the facility, waste
liquids and sludges were discharged  to
an   excavated,   unlined  lagoon.
Contaminated  material   was   also
contained within a diked tank farm and
an exposed drum storage  area.  When
the facility ceased operating, significant
site features included a main building,
a distilling house, a diked tank farm, an
open drum storage area, and an unlined
lagoon.

A Focused   Feasibility  Study  was
completed by EPA in February 1984.
On May 14,1984, EPA entered into an

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Administrative Order on Consent with
a group of the Potentially Responsible
Parties (PRPs) for the performance of
the remedial activities recommended in
the   Focused  Feasibility  Study.
Pursuant to this order, drummed waste
and  3,000 tons of lagoon sludge were
removed from the site. In addition, a
fence was constructed around the site
to restrict access and to prevent the
public from coming into direct contact
with the contaminants.

In May 1984, MPWC Well  1 was shut
down due to the detection of volatile
organic compounds in the well Since
area-wide groundwater contamination
occurs in the vicinity of MPWC Well 1,
the  well  was equipped with an  air
stripper  to  remove these  compounds
from groundwater, and returned to the
water supply system in January 1989.
It is believed that the Swope site, as
well  as  a  number of unidentified
sources,  may be contributing to the
contamination of this well

In June 1985, EPA concluded the first
Remedial Investigation and Feasibility
Study  (RI/FS).    Based  upon  the
findings  of  the  RI/FS,  a  Record  of
Decision,   addressing   surface
contamination, was signed by EPA on
September 27,1985.

In August and September  1986, EPA
entered into Administrative Orders on
Consent  with a group  of PRPs  to
perform the Remedial Action specified
in the  Record  of  Decision and  to
conduct a Supplemental RI/FS.

The   Remedial  Action   addressing
surfidaJ contamination was initiated by
tiie PRPs in the fall of 1988 and was
essentially completed by August 1989.
This program included the demolition
aiid disposal of on-aite buildings, the
off-site disposal of tanks with off-site
disposal   or  incineration  of  tank
contents,  the excavation and off-site
disposal  of up to  1.5 feet of soils
contaminated with PCBs, and the off-
site disposal  of visibly contaminated
materials from the buried sludge area
of the site. Subsequent to excavation,
dean backfill  material was utilized to
bring the site up to grade.   The
construction of a cap at the site, which
was  an   activity  specified  by  the
September 1985 Record of Decision,
was  postponed to provide  for the
installation of monitoring wells and the
performance  of treatability  studies
during the Supplemental RI/FS.
SUMMARY OF THE
FT.TPPT.FMENTAL REMEDIAL
INVESTIGATION AND
ADDENDUM

The Supplemental RI for the Swope Oil
and Chemical  Company site  was
conducted from October 1988 to March
1991.  The original objectives  of the
Supplemental RI/FS were to evaluate
the  extent  of  groundwater
contamination at  the site  and to
develop  appropriate   remedial
alternatives.  Based upon information
obtained during the design phase of the
surface remedy, EPA decided to expand
the scope of the Supplemental RI to
include the determination of the nature
and  extent  of  subsurface   soil
contamination at the site.

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The following tasks were  performed
during the RI:

•  pre-existing geological, geophysical,
   hydrological and chemical
   information was reviewed and
   evaluated;

•  ten deep soil borings were drilled to
   define the site geology further and
   to sample soils for determination of
   the types and concentrations of
   contaminants existing in soils above
   the water table;

•  fourteen additional monitoring wells
   were installed to define the site
   hydrogeology further and to
   determine the nature and extent of
   groundwater contamination. A total
   of eighteen monitoring wells and
   public supply well MPWC Well 1
   were sampled during this
   investigation;  and

-  an aquifer test was conducted at the
   site to determine the direction of
   groundwater flow and the hydraulic
   relationship between the shallow
   and deep  aquifers underlying the
   site.

The findings of the RI are as follows:

-   Two aquifers were identified
   beneath the site.  The first is a
   water table aquifer which begins at
   approximately 80 feet below land
   surface and extends down to
   approximately 135 feet below land
   surface. The second aquifer extends
   from  approximately 170 feet to 240
   feet below land surface.  A-35 foot
 semi-couoning layer composed
 primarily of silt and clay with
 interbedded layers of fine-grained
 sand separates the two aquifers.

The direction of groundwater flow in
 both the shallow and deep aquifers
 is to the southwest.  Deep aquifer
 groundwater in the vicinity of the
 site flows toward public supply well,
 MPWC Well 1, when this well is in
 operation.

 The highest levels of groundwater
 contamination in the shallow aquifer
 exist beneath and downgradient of
 the site, indicating that the site has
 contributed to the contamination of
 this aquifer.  Contaminants present
 in the shallow aquifer consist
 primarily of volatile organic
 compounds. RI data further indicate
 that contaminated groundwater
 flows beneath the Swope site in the
 shallow aquifer from an upgradient
 source(s) and that the site's
 contaminant plume is part of a
 larger regional groundwater plume.

 Similar to the shallow aquifer, the
 highest levels of groundwater
 contamination in the deep aquifer
 generally exist beneath and
 downgradient of the Swope site.
 Contaminants present in the deep
 aquifer consist primarily of volatile
 organic compounds, many of which
 were also detected in the shallow
 aquifer. This suggests that the
 Swope site may be contributing to
 the contamination of deep aquifer
 groundwater.  RI groundwater
 sampling results further indicate
 that contaminated groundwater

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   flows beneath the Swope sif« in the
   deep aquifer from an upgradient "
   source(s) and that the site may,
   therefore, be contributing
   contaminants to a larger regional
   groundwater plume in the deep
   aquifer.

   Subsurface soil samples indicate the
   presence of volatile and semi-volatile
   organic compounds.  The highest
   concentrations of these contaminants
   were detected in samples collected in
   the vicinity of the former Tank
   Farm Area, Lagoon Area and Buried
   Sludge Area. Significant  levels of
   volatile and semi-volatile organic
   compounds were detected in
   subsurface soils to a depth of about
   50 feet below land surface. Many of
   the volatile organic  compounds
   detected in these soils are also
   present in groundwater beneath
   the Swope site. Accordingly, these
   soils represent a continuing and
   significant source of the
   contamination of groundwater.
 were being performed.

 EPA designated surficial contamination
 as  the first  operable  unit  of site
 remediation.      EPA's   preferred
 alternative for the  second operable
 unit, which  is  the subject  of this
 document, focuses on the remediation
 of contaminated subsurface soils, which
 are a continuing source of groundwater
 contamination.   EPA  believes  that
 remediation of the source material will
 result in a significant reduction of the
 groundwater   contamination.   As  a
 result, EPA has decided to postpone a
 decision  regarding  groundwater
 remediation,   until  source   control
 measures  have  been  implemented.
 Groundwater  monitoring  will  be
 required during and after the design
 and  implementation phases   of the
 selected source control alternative, in
 order to determine the effectiveness of
 these   measures  in  mitigating
 groundwater   contamination  and
 whether  future   groundwater
 remediation would be required
SCOPE OF THIS OPERABLE UNIT

Based on  the  groundwater results of
the  1985  RI,  EPA concluded  that
investigation of the nature and extent
of  deep  aquifer  and  off-site
groundwater   contamination   was
essential  to   address  this  medium
appropriately. As a result, EPA decided
to address contamination at the site in
discrete phases, referred to as operable
units, so that a remedy for surficial
contamination   could proceed, while
additional groundwater investigations
SUMMARY OF SITE RISKS

A  baseline   quantitative  Risk
Assessment   was   conducted   to
determine the risks presented by the
presence of hazardous substances  in
groundwater which are attributable to
the site. The Risk Assessment focussed
on the identification of contaminants of
potential concern and possible exposure
pathways at the site.

The  following exposure routes were
assessed:  1)   dermal  contact with

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 contaminants  in   'shallow  aquifer
 groundwater;  2)  drinking  of
 groundwater from the shallow aquifer
 at the  site;  and  3)  inhalation of
 contaminants  volatilizing   from
 groundwater   during   showering.
 Exposures for potential future workers
 at the site and  for residents have been
 considered in this assessment  These
 exposure routes  were  assessed as
 hypothetical future pathways,  since
 current  pathways   for  exposure to
 shallow  aquifer groundwater are not
 believed  to  exist.    These analyses
 indicate  that the  greatest potential
 future human health risk presented by
 the  site is from  the  drinking of
 contaminated groundwater.

 Human health risks from the drinking
 of contaminated  groundwater  were
 calculated to have a Hazard Index of
 3.8.  A Hazard Index greater than 1 is
 considered to  exceed  the maximum
 recommended exposure.   The cancer
 risk associated with residents drinking
 contaminated groundwater is 4.2 x 10J
 (4.2  in  a thousand), which exceeds
 EPA's acceptable rsk range of IQ* • 10"4
 (one  in   a  million to  one in  ten
 thousand).  It  should be noted that
 although there  are presently no users
 of shallow aquifer groundwater in the
 vicinity of the site, some groundwater
 does migrate from the shallow aquifer
 into  the  deep  aquifer,  which  is
 currently utilized as a potable  water
 source.

 Risks associated with dermal contact
 and ingestion of site soils have not been
 quantified in this assessment. It should
be noted, however, that as part of the
remedial action conducted at the  site
 from the Fall of 1988 to August 1989,
 up to 1.5  feet  of contaminated soils
 were removed from most of the site. In
 addition, visibly contaminated material
 was removed to a depth of  10 feet.
 Subsequently, clean backfill material
 was utilized to  bring the site  up to
 grade. Potential risks associated with
 the possibility of ingestion of, or dermal
 contact  with  contaminated  soils,
 therefore,   are   considered  to   be
 minimal
SUMMARY OF ALTERNATIVES

The Superfund legislation requires each
selected site remedy to be protective of
human health and the environment,
cost-effective,   and  in accord   with
statutory  requirements.   Permanent
solutions  to  contamination problems
are to be  achieved wherever possible.
The use of innovative technologies and
on-site  treatment are  evaluated as  a
means to attain this goal

During the FS process, a wide range of
treatment technologies were identified
and  screened  for use in applicable
remedial alternatives.   As described
below, many of these technologies and
alternatives   were  eliminated  from
further consideration due to physical
conditions or other limitations at the
site.

Ex-situ treatment  options,   which
involve the excavation of contaminated
soil prior to treatment, were screened
out due to the difficulties involved in
excavating contaminated site soils to  a
depth of approximately 50 feet within

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 the spatial--confines of the ate.  Aa
 displayed on the site map, the site is
 bounded   to  the   northeast  and
 southwest by railroad rights-of-way and
 warehouse?, and to the northwest by
 National  Highway.    Excavation  of
 contaminated site  soils  would, at a
 minimum, involve the disruption of an
 active railroad spur as well as National
 Highway. In addition, the excavation of
 contaminated site soils would require
 shoring the sides of the excavation to
 maintain the integrity of the excavation
 walls during removal  of soils.   The
 shoring of the excavation walls to a
 depth of 50 feet would prove  difficult
 and would require the excavation of
 soils outside the physical boundaries of
 the site.

 In-situ  or in-place treatment  options
 evaluated  in   the  FS   include:
 vitrification/glassifi cation,
 solidification/fixation, soil flushing, soil
 vapor   extraction,   enhanced
 volatilization   and  biorexnediation.
 Vitrification/glassifi cation was screened
 out,  since  this  technology  is  not
 implementable   to  the  depth  of
 contamination  at  the   site.
 Solidification/fixation techniques have
 not been proven  to  be  effective in
 reducing  the  mobility   of  organic
 compounds   and,   therefore,   were
 eliminated from further consideration.
Soil flushing would  involve  washing
organic  contaminants from subsurface
soils.  This technology  was eliminated
because   the  contaminants   would
ultimately   be   transferred  to  the
groundwater. Enhanced volatilization
techniques  were   eliminated  from
consideration,  due to  the high cost
associated with heating the soils to the
 temperature required to volatilize the
 organic contaminants, and since this
 technology has not been shown to be
 readily implementable to the depth of
 contamination at the site.  In all, two
 treatment  options,   in-situ  vapor
 extraction and  bioremediation, were
 determined to be viable for remediation
 of contaminated site soils.

 Institutional actions,  such  as  site
 fencing and access restrictions, and
 containment options, such as capping,
 were  also  evaluated.   Institutional
 actions were screened out, since they
 would not meet the remedial  action
 objective   of   eliminating   on-site
 subsurface  soils  as  a   source  of
 contamination to groundwater.  Of the
 capping alternatives evaluated  in the
 FS,  a multi-layer cap originally was
 determined to be the most reliable and,
 therefore,   was  retained  for
 incorporation into applicable  remedial
 alternatives.

 The  technologies   that   were  not
 eliminated from consideration  during
 the  screening  were assembled  into
 remedial alternatives.  The following
 provides a description of the  remedial
 alternatives that were evaluated for the
 Swope site.

ALTERNATIVE 1 - NO ACTION

 Capital Cost: 0

Annual Operation  and Maintenance
 Costs: $222,000

Present Worth: $961,000

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Months to Achieve  itemedial Action
Objectives: Not Applicable*

   Groundwater  quality  would  be
monitored quarterly for  five  years
under this alternative.

Superfund regulations require that  a
No Action alternative be evaluated at
every site to provide a baseline against
which other remedial alternatives may
be compared.  Under this alternative,
no action would be taken at the site to
prevent  or reduce  the leaching  of
subsurface  soil  contaminants   to
groundwater. This alternative includes
a  five-year groundwater  monitoring
plan, which would involve the sampling
of existing site  wells on a quarterly
basis, to  assess  the impact of the
contaminated  soils  on  groundwater
quality.

ALTERNATIVE 2 - SOIL VAPOR
EXTRACTION AND
B10DEGRADATION

Capital Cost: $687,400

Annual  Operation and  Maintenance
Costs: $222,000
(Groundwater Monitoring Program)

First-Year Operation and Maintenance
Costs: $397,500
(Vapor Extraction System)

Present Worth: $2,046,100

Months  to Achieve Remedial Action
Objectives: 18*

   Groundwater  quality  would  be
monitored  quarterly for  five  years
under this alternative.
Under this alternative, a network  of
vapor  extraction   and  passive  air
injection  wells  would be installed
within contaminated subsurface soils at
the site. The extraction wells would be
connected to a blower(s)  in order  to
create a vacuum within the subsurface
•oils.  This vacuum would draw air
from the site surface and the passive
air  injection   wells  through  the
contaminated subsurface soils, stripping
volatile organic compounds from the
subsurface environment.    The air
stream would then be passed through a
catalytic oxidizer prior  to discharge  in
order   to  regulate   contaminant
emissions. On-site storage and off-site
treatment  and/or  disposal  of  drill
cuttings generated during installation
of  vapor  extraction   wells  will  be
conducted  in  accordance  with  the
requirements   of  the   Resource
Conservation and Recovery Act (RCRA),
as amended by the Hazardous and Solid
Waste Amendments of  1986.

Additionally,  operation of a vapor
extraction system (VES)  would  add
oxygen to the subsurface soils, thereby
enhancing  the   natural  aerobic
biodegradation   of  non-halogenated
organic contaminants.   This  process
would prove effective in reducing the
levels  of  semi-volatile  organic
compounds in  subsurface  soils.   The
inoculation of subsurface  soils with
appropriate microorganisms as well  as
the  injection of  nutrients into  the
subsurface would be considered during
design of the  VES, to determine  if
biodegradation  of  subsurface  soil

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 contaminants could be enhanced.
 Subsurface   soil,   soil   gas  and
 groundwater   samples  would  be
 collected as part of this alternative to
 determine the effectiveness of the VES
 in   remediating  subsurface  soil
 contamination.     A  quarterly
 groundwater monitoringprogram would
 be  implemented   to  provide
 proundwater quality data for the above
 determination. Subsurface soil samples
 would be collected prior to operation of
 the  VES to  provide  a  baseline for
 determination of the  effectiveness of
 the  VES in  remediating subsurface
 contamination.     Contaminant
 concentrations in the soil  gas samples,
 collected during operation of the VES,
 would indicate  when soil samples
 should  be  collected   to determine
 whether soil cleanup goals have been
 met.  If cleanup levels have not been
 met, and the VES continues  to remove
 significant quantities of contaminants,
 then  operation  of the  VES  would
 continue.

 Decision to Postpone Installation
 of a Cap

Alternative  2,  as  developed  and
evaluated in  the  Supplemental FS,
originally included the installation of a
multi-layer cap over the site, following
treatment of contaminated subsurface
soils.  A cap was originally included as
a component of this alternative, since
the installation of a cap was a  source
control   activity  specified   in  the
September 1985 Record of Decision. It
should  be  noted,  however,   that
extensive  treatment  of subsurface
 contamination was not envisioned when
 the 1985 remedy was selected. During
 preparation of this Proposed Plan, EPA
 reevaluated the need to cap the site in
 conjunction with the active treatment
 of subsurface contamination.  EPA has
 determined   that  treatment   of
 subsurface soil  contamination  alone
 may  be  adequate  to  protect  the
 groundwater   from  continuing
 degradation.  As a result, EPA has
 decided   to  postpone   a  decision
 regarding   a   cap,  until  after
 implementation of the selected source
 control   remedy.     If  it  is  later
 determined that a cap is not required,
 this approach would have the potential
 benefit of minimal institutional controls
 and would allow for a greater degree of
 unrestricted  future   site   use.
 Subsequent  to   completion  of the
 selected remedy, EPA will evaluate the
 effectiveness   of  this  remedy   in
 providing for groundwater protection
 and determine whether the installation
 of  a  cap or further source control
 actions are warranted
Rationale for Selection

Each of the alternatives was evaluated
against nine criteria utilized by EPA in
the remedy selection process.  These
criteria   fall  into  four  categories:
environmental/public  health
protectiveness, compliance with cleanup
standards, technical performance, and
cost. In addition, the selected remedy
should result in permanent solutions to
contamination problems and should use
treatment to the marimuTn extent
practicable.   The nine criteria are
                                    10

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summarized below:
- Overall crotertion
                           health
                     addresses
 whether or not a remedy provides
 adequate protection and describes
 how risks posed through each
 pathway are eliminated, reduced or
 controlled through treatment,
 engineering controls, or institutional
 controls.
            wifh ARARs addresses
 whether or not a remedy will meet all
 of the applicable or relevant and
 appropriate requirements (ARARs) of
 federal and state environmental
 statutes and/or provides a basis for a
 waiver.

• Long-term effectiveness refers to the
 ability of a remedy to maintain
 reliable protection of human health
 and the environment over time, once
 cleanup goals have been met

• Reduction of toxicity. mobility or
 volume through treatment is the
 anticipated performance of the
 remedy in terms of reducing' the
 toxicity, mobility, or volume of the
 contaminants of concern in the
 environment

• Short-term effectiveness addresses the
 period of time needed to achieve
 protection, and any adverse impacts
 on human health or the environment
 that may be posed during the
 construction and implementation
 period until cleanup goals are
 achieved.
- Imy]gmentabilitv refers to the
 technical and administrative
 feasibility of implementing a remedy,
 including the availability of materials
 and services required to implement a
 particular option.

. gost includes estiir«ited capital and
 operation  and ma:r .enance costs of
 the remedy, and the net present
 worth cost.  A summary of the
 estimated costs for the remedial
 alternatives considered is presented in
 Table 1.

- State Acceptance indicates whether,
 based on its review of the RI and FS
 and the Proposed Plan, the State
 concurs with the preferred
 alternative.  The State has concurred
 with the preferred remedy presented
 in this Proposed Plan.

. ^offlfnunitv Acryptflpffe, will be
 assessed in the ROD following a
 review of the public comments
 received on the RI, RI Addendum, and
 FS reports and the Proposed Plan

EPA, in consultation with NJDEP, is
required  to  select   the  remedial
alternative  which provides the best
balance  among  the  nine  criteria.
However, the selected alternative must
satisfy  the first two criteria: protection
of human health and the environment,
and compliance with ARARs,  unless a
waiver is granted.   The  manner in
which  the  alternatives address the
criteria   is  presented  below.
Community comments and acceptance
are being solicited at this time.
                                    11

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ALTERNATIVE 1 - NO ACTION

The No Action Alternative would offer
i*o reduction in the toxicity, mobility or
volume  of   contaminants  in   the
subsurface soils.   Since  these  soils
would continue to serve as a source of
grouudwater   contamination,   this
alternative would not protect human
health and the environment or prove to
be effective in the long  term.   This
alternative presents little risk to on-site
workers, since no construction activities
would be implemented. However, thia
alternative would not reduce any of the
existing site risks.  Implementation of
this  alternative would be  easy since it
only   involves  the   collection   of
groundwater samples.
ALTERNATIVE 2 - SOIL VAPOR
EXTRACTION AND
BIODEGRADATION

The  remediation of   contaminated
subsurface soils through in-situ vapor
extraction  and biodegradation would
protect   human  health   and  the
environment by reducing potential risks
to future users of groundwater.  The
toxicity,  mobility and  volume   of
subsurface soil contaminants would be
reduced   through   in-situ   vapor
extraction.    This alternative would
employ only proven technologies and
would be  easily implemented at the
site.    Aerobic  biodegradation   of
contaminants would occur during and
after  the  operation  of the vapor
extraction system.

Since no Federal or State regulations
specify cleanup levels for soils, New
Jersey State Soil Action Levels will be
utilized as soil cleanup goals to provide
for groundwater protection.  Operation
of the  soil treatment system would
continue until the cleanup goals have
been  attained  or  until  continued
operation  of  the  system   proves
technically impractical  An ARARs
waiver would not be required if cleanup
goals were not  achieved, since New
Jersey State Soil Action Levels are not
promulgated ARARs.

In-situ soil vapor extraction would be
conducted in compliance with State and
Federal ARARs. In addition, due to the
site's proximity to the Delaware River,
implementation  of  this  alternative
would be consistent with the Coastal
Zone  Management  Act.    Off-site
treatment  and/or disposal  of  drill
cuttings generated during installation
of vapor extraction  wells  would be
conducted  in   accordance  with   the
requirements of RCRA, as amended by
the  Hazardous  and  Solid  Waste
Amendments of 1986.

This alternative  would permanently
reduce the migration of contaminants
to groundwater and,  therefore, would
prove effective over the long term. In
the short term, actions would be taken
to reduce potential  risks  to  on-site
workers. These measures may include
requirements for protective  clothing
and  respiratory   protection.     Air
emissions control equipment would be
installed at the YES extraction wells to
protect the community.
                                    12

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SUMMARY OF THE PREFERRED
ALTERNATIVE

After  careful  consideration  of  aH
reasonable alternatives, EPA proposes
utilizing  Alternative  2 • Soil  Vapor
Extraction and Biodegradation for the
remediation of contaminated subsurface
soils at the  Swope Oil and Chemical
Company  site.     The   preferred
alternative provides the best balance
among the alternatives with respect to
the criteria used to evaluate remedies.
Based upon the information available at
this time,   EPA believes  that  the
preferred   alternative  would   be
protective,  attain  ARARs, be  cost-
effective, and would use  permanent
treatment    technologies  to   the
maximum   extent   practicable.
Subsequent to implementation of this
remedy, EPA will determine whether
this remedial   action  provides   for
adequate protection of groundwater and
whether  any further source  control
measures, such  as  capping,  or  if
groundwater  remedial  measures are
necessary.
                                    13

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                              TABLE 1

                 SUMMARY OF REMEDIAL ALTERNATIVES
 REMEDIAL
 ALTERNATIVE
PRESENT WORTH
COST fSI.0001
TIME TO ACHIEVE
   REMEDIAL
    ACTION
                                                   COMMENTS
 1:  No Action
      961
      NA
Inadequate to
protect human
health and the
environment.
 2:  Soil  Vapor      2,046
    Extraction, and
    Biodegradation
                     18
                   Recommended
                   Alternative  for
                   subsurface coil
                   remediation.
                   Protective;  tox-
                   icity, mobility,
                   and volume of
                   contaminants
                   reduced;  easily
                   implemented;
                   cost-effective.
  Groundvater quality would be monitored quarterly for five years
under these alternatives.
                                14

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ATTACHMENT A.2
 Public  Motie*

-------
ui
                                   ii ui ftyuyt lit  liic i iii

                              Unator Act N«. 1*0, PX 177, Mr »,
Commonwealth of Penntylvtni*  2
County o/ Wu7« dx.'phi*            J
                   «*..•
 	Lr...C.ij?.ri.«;).Q	 being duly sworn depute* and says that THE PHILADELPHIA
 INQUIRER it a daily newipiper publiihed at Broad and Callpwhul Suecu, Philadelphia County, Pcnniylva-
 aia. which wat eitablithed in the ytar 1129. since which date Mid daily newspaper hat been rtfularly published
 and dittributed in said County, and that a copy of the printed notice of publication if attached hereto exactly at
'the tame wat printed and published in the regular editions and issues of aaid daily newspaper on the following
 datet. viz.:
                  ..and the	.?.?*J?	.day of.....
Affiant further deposes that he it duly authorized
by Philadelphia  Newspapers, Inc., a corporation,
publisher of THE  PHILADELPHIA IN-
QU1RER, • daily newspaper, to verify the forego-
ing statement under oath, and alto declare* that
affiant is not interested in the subject matter of
the aforesaid notice or publication, and that all
allegations in the foregoing statement as to time,
place and character of publication are true.
                                       16th
day of
    Swerr. to and tubtcrioed before me this.


            July                   '   91
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                ATTACHMENT A. 3
August 1, 1991 Public Meeting Attcndaac* 8b««t

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                          TOZTED fTXTIfi WVZRONMENTAI, PROTEC2Z&N AGENCY
                                           RESIGN ZZ
                                        PUBLIC XXZTZKC
                                              FOR
                                    •BOPI OIL  fUERFUKt) fZTE
                                        9SNNSAUXEN, HEW JERSEY

                                        >OCUST 1,  1911
                                       XEETZN9 XTTEKDEES
                                                Print)
KAKE
STREET
CITY
IIP
PHONE
                                                             REPRESENTING
                           y.  fr^kftj
£r'c.
                        R.

             KM
             (J
                                                              5^* e

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      REGION ZZ
                                   PUBLIC MEETING
                                         FOR
                              flWOPE OIL  fUERrUND SITE
                                   PZNNSAUXZN, VTW JERSEY

                                   AUGUST 1, Itffl
                                  XEETZNG ATTENDEES


                                   (Pl«a«« Print)


XAXE          STREET        CITY      IIP    .  PHONE     REPRESENTING

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                    APPENDIX B
     Swop* Site Cleanup Committee's Comments
   on the Proposed Plan and the Addendum to the
supplemental feasibility Study and Risk Assessment

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                         ATTACHMENT B.I
    July 31, 1991 Comment Letter froa the Svope Site Cleanup
Committee Concerning the Addendum to  the  Supplemental  Feasibility
                    Study and Rick Assessment

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                       DlLWORTH. PAXSON. KAUSH & KAUFTMAN
                                     -----

                                                         ' ew M»*W*« «••*•»•   * •**• •*»•*••* *c
                                                         " ***c •!••(• o* »* •*•   • itf^ «c»ei* •• •*
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•nrv»sjfc«<«i»t»i*       " * **
      July 31, 1991

     FOR INCLUSION IN
TEE ADMINISTRATIVE RECORD
       Kr. Raymond Basso
       United States Environmental  Protection Agency
       Region II
       Jacob K. Javits Federal Building
       New York, New York  10278
            Re:  Swope Site Cleanup Committee Consents on the Addendum  to
                 the Supplemental  Feasibility Study  and Risk Assessment
                 for the Swope Oil and Chemical  Company Site, located  in
                 Pennsauken Township. Candan County.  Kav
       Dear Kr.  Basso:

                 We have received • copy of your July 15, 1991, letter to
       Robert Nicoloro  vhich enclosed the  Agency's  Addendum  to  the
       Supplemental Feasibility  Study  and Risk  Assessment   ("Addendum
       Report")  for the  Swope Oil and  Chemical Company Site.   Although
       more detailed technical comments will follow, we vanted to respond
       to  several issues in the Addendum Report.

                 The Addendum Report  appears  to discuss Nev  Jersey Soil
      Action Levels ("NJSALs") as if they might b* the cleanup goals for
      the  remediation of the subsurface ••oil* at the Svope site,   see
      Addendum  Report,  p. 14.  The  only purported basis for the  use of
      NJSALs is that EFA'a  contractor, Caap,  Crasser C McXae  ("CDM"),

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To:  Mr. Raymond tease


could not verify the Soil Remediation Levels  ("SRL*")  which were
properly  derived  by Ceraghty  & Miller, the  Swope Site  Cleanup
Committee's  consultant,  as  part of the Risk  Assessment  for the
site.  £££ Addendum Report, p. 6. However, as you well know, there
are several key technical questions which have prompted the Agency
to  approve  CDM's   repeating  the SRL  verification  effort  with
Ceraghty  £  Killer's assistance.  In  light of  this fact,  EFA's
apparent decision to disregard the SRLs is at best preaature and
at worst a dereliction of Agency responsibility.

          In any event,  the use of NJSALs  as cleanup standards
would be  wholly inappropriate.  Ac  was correctly noted  in the
Agency's Proposed Plan  of July, 1991, which was developed pursuant
to the public participation requirements of CERCLA Section 117(a),
NJSALs "are  &££ promulgated  ARARs".   Proposed Plan, p.  12 (July
1991); see a_l££ Addendum Report, p.  14  (stating that there are no
ARARs which dictate soil  remediation levels}.  At most, the NJSALs
fall within the To  Be Considered ("TBC")  category of environmental
guidelines.   However, as  is stated in the Preamble to the National
Contingency Plan, "TBCs should not be required as cleanup standards
in  [40  C.F.R.   300.400(g) (3)]  because  they are,  by  definition,
generally neither promulgated nor enforceable  so they do not have
the same status under CERCLA as ARARs".   Preamble to the National
Oil and Hazardous  Substances Pollution  Contingency  Plan,  55 Fed.
Reg. 8665 (Aarch 8, 1990)(emphasis added).  The  Preamble further
provides that "EPA believes  that TBCs are meant to compliment the
use of ARARs. by EPA, states,  and PRPs,  net to be  in  competition
vith ARARs.*  Id..

          Here, the Agency's apparent attempt to involve NJSALs as
if they were ARARs  — despite the fact that it has recognized that
NJSALs are  not ARARs  — is  clearly at  odds with the  express
language  of the  National  Contingency  Plan.    Moreover,  EPA's
apparent invocation of NJSALs  at this  late  stage in  the remedy-
selection process could be construed as an attempt  by the Agency
to evade the procedural safeguards in the NCP requiring the Agency
to   consider,   inter ' alia.   the   implementability,   technical
feasibility and cost effectiveness of a  selected remediation plan
prior to the selection of that remedy.  Accordingly, the reference
to NJSALs in the Addendum Report should  be delated.

          In addition to being inappropriate and unenforceable as
a cleanup standard under the NCP, it should be noted  that NJSALs
are also inapplicable to  soil  remediation plans.  Under  the New
Jersey Environmental Cleanup Responsibility Act, N.J.S.A. 13:1K-
« ££ lilt./  soil action  levels  are merely used by the  New Jersey
Department  of   Environmental  Protection ("NJDEP")  to  determine
whether remediation mjy. s>s -     ~4.   Once NJDEP determines that
remediation is  required, clear,,.   .indards are developed on a case-
by-case basis depending on cite characteristics.1 N.J.S.A. 13:1K-
     1  Ironically,  this  is  exactly the  approach used by Ceraghty
t Killer in the Risk Assessment to derive the SRLs.

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let  AT.


10(a).   Significantly,  however, NJSALs are  not used as  cleanup
remediation standards —  not «ven by the iJJDEP,  the agency that
developed them.
                                                   5
          Based  on the  foregoing,  NJSALs are inapplicable  and
unenforceable as subsurface soil cleanup standards.  Accordingly,
it is recommended that the Agency reconsider the use of SRLs which
were properly developed  in  the  Risk Assessment.   The Swope Site
Cleanup Committee is prepared to discuss the issues raised in this
letter at any time.  Indeed, ve  are hopeful that an agreement can
be reached on this issue shortly.
                                   Michael L. Krancer
                                   Barbara A. Brown
                                   On behalf  of' the Swope  Site
                                   Cleanup Committee
cc:  Peter M. Abel, Esq.
     Bernard Reilly, Esq.
     Mr. Rodney J. McQueen
     Mr. Barry L. Sams
     Kr. Charles E. Stauber
     Leonard F. Charla, Esq.
     Kr. Anthony Montalbano
     Mr. Radford A. Mead
     David B. MacGregor, Esq.
     Ronda P. Bayer, Esq.
     Bonnie Fine Kaufman, Esq.
     Joel R. Herz, Esq.
     Patricia Kick, Esq.
     Mr. Joseph Cowers
     Mr. John LaPadula

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                         ATTACHMENT B.2
 August 1, 1991 Comntat L«tt*r  from 0«r»ghty  & Miller Coac«raing
tbt Addendum to the Supplemental r«a«ibility  study aad
                         Risk A«««a«a«at

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^GERAGHTY
   v^NDLLER.lNC
   'nvironmemal Services
                        Ground Water     Engineering     Hydrocarbon       Remediation      Education


                                                August 1,1991


  FOR INCLUSION IN THE ADMINISTRATIVE RECORD


  VIA FEDERAL EXPRESS

  Raymond Basso, Chief
  New Jersey Superfund Branch II
  United States Environmental Protection Agency
  Region II
  Jacob K. Javits Federal Building
  New York, New York 10378                                        .  _


  Dear Mr. Basso:


        Geraghry & Miller, Inc. and the Swope Site Cleanup Committee have reviewed the

  United States Environmental Protection Agency (USEPA) Addendum to the Supplemental

  Feasibility Study (FS) for the Swope Oil and Chemical Company Site, Pennsauken Township,

  Camden County, New Jersey and are pleased that the supplemental FS has been approved

  by the USEPA.  We  have the following comments concerning the FS addendum.
  ISSUES CONCERNING REMEDIAL ALTERNATIVES AND RISK
  CHARACTERIZATION
  NO ACTION ALTERNATIVE


       The  December 1990 supplemental FS report included and evaluated a no action
  alternative. At the direction of the USEPA, a no action alternative was not developed and
  evaluated as part of the May 1991 Supplemental FS.  In the April  19, 1991  USEPA
  comment letter regarding  the supplemental FS, General Comment 13 stated that  The
  current no action alternatives assessed in the Supplemental FS Report should be modified
            125 East Bethpaje Road • Plainvieu, Neu York 11803 • (516) 249-7600 • FAX (516) 249-7610

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GERAGHTY & MILLER. INC.

                                                                              2
  to provide for the implementation of monitoring programs for contaminated media at the
  Swope Site."  At a meeting held on May 13,1991 at the USEPA Region II office, attended
  by Geraghty & Miller, the Swope Site Cleanup Committee, Camp, Dresser & McKee
  (CDM),  John LaPadula, Patricia Hick, and Joseph Gowers, the USEPA reiterated its
  request that the May 1991 report be revised such that the no action alternative include
  institutional  controls.

  BIODEGRADATION OF SUBSURFACE SOIL CONTAMINANTS

       As discussed in the Response to USEPA and NJDEP Comments on the Supplemental
  Feasibility Study Report for the Swope Oil and Chemical Company Site, it must be noted
  that semivolatile organic compound:   :e not detected at concentrations significantly higher
  than soil remediation levels (SRLs;.

       Residual semivolatile organic compound concentrations will be permanently reduced
  by natural biodegradation that is  enhanced by soil vapor extraction (SVE), as discussed in
  the May 1991 Supplemental FS Report and the aforementioned response document.

  INSTALLATION OF A MULTI-LAYER CAP

       In the supplemental FS, SVE was considered in conjunction with a multi-layer cap
  because the  installation of a cap  was a source control activity specified in the September
  1985 Record of Decision for the Swope Site.  We concur with the USEPA's decision to defer
  a final determination on the need for a cap until the completion of the vapor extraction
  system (VES) operation.  However, in the absence of a cap, careful consideration must be
  given to the operational time needed for the VES. At the point of diminishing returns with
  respect to constituent recovery from soils, the cost-effectiveness of further operation of the
  system must be considered.  We agree with the USEPA Addendum to the Supplemental FS
  Report that operation of the VES should cease when significant quantities of constituents
  are no longer being removed.

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GERAGHTY & M]LLER. INC.
 VAPOR EXTRACTION SYSTEM PERIOD OF OPERATION

      Soil vapor extraction  (SVE) does not reach permanent steady-state operation.
 Ground-water extraction does reach permanent steady-state operation, but SVE does not.

      The effectiveness of the VES wfl] be determined by evaluating constituent concentra-
 tions in extracted soil gas (air samples taken of extracted sofl gas at a point before the air
 blower influent), subsurface soils (soil boring samples at various depths), and ground water.

 SHALLOW GROUND-WATER MONITORING PLAN

      As part of the  supplemental Feasibility Study, Geraghty &  Miller prepared and
 submitted The Shallow Ground-Water Monitoring Plan of the Supplemental Feasibility Study
 (July 1991). The purpose of the ground-water monitoring program is to evaluate the quality
 of ground water beneath the Swope site throughout the operation of the VES.  Ground-
 water samples collected during the first and fourth quarters will be analyzed for VOCs and
 semivolarile organic compounds by using EPA Methods 624 and 625, respectively. Because
 of the low mobility of semivolatile organic compounds, samples collected during the second
 and thiid quarters will be analyzed for VOCs only.

      As stated in the supplemental RI report (March 1991), water quality data for the deep
 aquifer is insufficient to conclusively demonstrate that the Swope site has impacted ground-
 water quality in the deep aquifer. Although Geraghty & Miller agrees with the USEPA that
 ground-water samples  should be collected from wells screened in the deep aquifer as pan
 of the proposed  monitoring program, samples should be analyzed for VOCs only and not
 semivolatile organic compounds. Specifically, semivolatile organic compound analyses should
 not be performed on ground-water samples collected from the deep aquifer for the following
 reasons.

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CERAGHTY & STILLER. INC.

                                                                              4
      o    Impacts, if any, of semivolatile organic compounds on water quality conditions
           in the deep aquifer would first be observed in the shallow aquifer wells.

      o    Semivolatile organic compounds have been detected less frequently and at lower
           concentrations than VOCs in both shallow and deep wells.

      o    Semivolatile organic compounds have a lower mobility than VOCs and the
           impacts, if any, to water quality would first be noted based on a review of VOC
           data.

DEEP AQUIFER GROUND- WATER CONTAMINATION

      As stated in both the supplemental RI and FS reports, there  is a marginal difference
between upgradient and downgradient water quality in the deep aquifer and the water
quality data is not sufficient to conclude that the Swope site has impacted water quality in
the deep aquifer. In addition, as stated  in the  USEPA Proposed Plan at the Swope site
(July  19, 1991),  "...RI ground-water sampling results further indicate that contaminated
ground  water flows beneath the  Swope site in the deep aquifer from an upgradient
source(s)..."
SOIL REMEDIATION LEVELS
     On July 31, 1991, Sally Odland of CDM telephoned Frank Jones of Geraghty & Miller
(Risk Assessment Group) and stated that CDM was able to duplicate the SRLs presented
in the Supplemental FS Report, using the same model and input parameters discussed in
that report.

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APPENDIX A:  SPECIFIC COMMENTS ON THE SUPPLEMENTAL FEASIBILITY
STUDY REPORT AND THE RISK ASSESSMENT
     The comments included in this Appendix have been addressed in the Supplemental
RI and FS Reports, and the responses to USEPA and NJDEP comments on these reports
with the exception of the following comment:

PAGE 20. FIRST FULL PARAGRAPH. THIRD SENTENCE
     Comment:  The sentence indicates that the future ground-water exposure scenario
                applies a 7-year exposure duration for hand washing and a 20-year
                exposure duration for ingestion of ground water. It should be noted that
                a 25-year exposure duration should have been utilized for this combined
                exposure scenario. Use of the 25-year exposure duration would provide
                a more conservative estimate of risks that may result from use of shallow
                aquifer ground water.

     Response:  The December 4, 1990 Risk Assessment Guidance  for Superfund,
                Volume I:  Human Health Evaluation Manual Supplemental Guidance
                "Standard Exposure Factors" indicates that an individual is assumed to
                work 25 years  at the same location  (95th percentile value).  This
                guidance was issued after the original Supplemental FS Report submittal
                date  (December 7,  1990).  This  value (25 years) could have been
                incorporated into the May 1991 Supplemental FS Report (document with
                revisions as per USEPA comment), but was not as this was not requested
                by the USEPA in their comment  letters (April 19, 1991  and  July 15,
                1991) or at the meeting held on May 13,1991 at the USEPA Region II
                office.

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CERAGHTV & MILLER. INC.


                                                                             6

      If you have any questions concerning these comments, please do not hesitate to call.

                                                Sincerely,

                                                GERAGHTY & MILLER, INC.
                                                Doug Newton
                                                Principal Scientist/Project Manager
                                                Betty Martinovich
                                                Principal Engineer/Project Engineer
                                                Arnold S. Vernick, P.E.
                                                Vice President/Project Officer
                                                Michael Wolfert
                                                Vice President/Project Officer

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                    ATTACHMENT B.3
August 5, 1991 Comaent Letter from Michael L. Xraacer/
            Regarding the Preferred Reaedy

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                                       u»* or rices

                       DILWORTH, PAXSON.  KALISH £ KAUFFMAN

                                26OO THC FiOCLi 'Y BUILDING
                            PHILADELPHIA. PENNSYLVANIA I9IO9-IO94  J^v'J.iiJS?"
                                      C1ISIBTS-7OOO
                                             D.C               - -
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                                    •CHANTON »CNNSYLVANIA         .t.-C'-t II >'.me'-
                                                           •uec c M*«T«*M
                                     •OCA BATON 'LOI»IOA          S.'«?.l" SV°" "

c-~... . c.. .. ,.     ......«=,.-,.—           	' ATLANTIC CITY. NCWJtaSCY       S?."Vc..i'"*""*

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je-w . coe*>c«*       «ew»i
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                                  DIRCCT DIAL I2ISI S7S- 6520
                                    August 5,  1991       :.So*!Tin!™~KS    :itt?:"!"SJRtil
                                                          "•. o* -V »*•    ««I»e - -.i.e. DC tout
                                                          * *t»0 HCMBC. *» C* •«•    » A44C •  't.O'O^BAM
i «eec. w-ttt.Ms j«     ..*..c^
         Mr.  Joseph Cowers
         United States Environmental
           Protection Agency
         Region II
         26  Federal Plaza
         Room 720
         New York, NY  10278

               Re:  Swope Superfund Site/Notice Letter to
                    Triangle Publications	

         Dear Mr. Cowers:

               Thank you for your  letter of July  24,  1991 addressed to
         "Triangle Publication/ c/o Dilworth, Paxson" regarding  the Swope
         Superfund Site.  In that letter, you state  that EPA  is  taking
         this opportunity to notify Triangle "once again" that information
         available to EPA indicates that the company is a potentially
         responsible party with respect to the Site.

               As you know, this firm represents  Triangle, which  is now
         known as News America Publications Inc., and others  with respect
         to  the Site.  We do not  agree with the  Agency's suggestion that
         Triangle is liable with  respect to the  Site and we believe that
         we  have meritorious defenses to liability.   In any event, as you
         know,  News America has cooperated with  the  Agency in the
         implementation of remedial actions performed via three
         Administrative Orders on Consent and News America will  entertain
         settlement discussions with respect to  the  implementation of the
         further component of remediation outlined in the Proposed Plan
         provided that other parties participate and to the extent that a
         reasonable Remedial Design can be agreed upon.

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Dilvorth, razson, Kalish i Kauff:
To:  Mr. Jostph Covers
Page 2
     Also, your letter erroneously refers to EFA's current
proposal for remediation applicable to subsurface soil only.  Of
course, the proposed remedial alternative applies to both
subsurface soil and, groundwater.  The Agency itself has
recognized this on numerous occasions.  Just a sampling of
occassions on which EPA has recognized this are the following.
Raymond Basso, in a letter dated May 21, 1991, stated that "EPA
believes that remediation of the source material would result in
the reduction of the contamination of the groundwater".  Also,
EPA's Addendum to the Supplemental Feasibility Study and Risk
Assessment for the Swope Oil and Chemical Company Site notes that
EPA believes that soil vapor extraction would b« effective in
reducing subsurface soil contamination and thereby reduce
contaminant migration into the groundwater.
                                   Michael L. Krancer
MLK/ls

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                         ATTACHMENT B.4
August 15, 1991 Cooaent Letter from Oeraghty t  Miller Concerning
                        the Proposed Plan

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^GERAGHTY
    cfMJl.LER.INC.
    nrtroninental Services
                         Ground Wjier     Engineering      Hydrocarbon       Remediation      Education

                                                August 15, 1991

     FOR INCLUSION IN THE ADMINISTRATIVE RECORD

     VIA FEDERAL EXPRESS

     Raymond Basso, Chief
     New Jersey Superfund Branch II
     United States Environmental Protection Agency
     Region II
     Jacob K. Javits Federal Building
     New York, New York  10378
     Dear Mr. Basso:
           Geraghty & Miller, Inc. and the Swope Site Cleanup Committee have reviewed the
     United  States  Environmental  Protection  Agency  (USEPA) Proposed Plan for  the
     remediation  of contaminated  subsurface soils at the Swope  Oil and Chemical Company
     (Swope) site and have the following comments concerning this plan:

     SITE BACKGROUND

     Page 4. Paragraph 1                                           _                	

           As discussed in the supplemental Remedial Investigation (RI) report and reiterated
     in the November 6, 1990 and June 27, 1991 letters to the USEPA, the difference between
     upgradient and downgradient ground-water quality in the deep aquifer is marginal. As such,
     these data do not conclusively demonstrate that the Swope site has impacted water quality
     in the deep aquifer.  Since MPWC Well 1 is completed in the deep aquifer, these data do
     not conclusively demonstrate that the Swope site has impacted water quality in this well. As
     stated by the USEPA, there are a number of unidentified sources that may be contributing
     to the contamination of this well.

              125 East Bethpage Road • Plainview. New \brk 11803 • (516) 249-7600 • FAX (516) 249-7610

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GERAGHTY <£«• MILLER. INC.

                                            .                                   2
 SUMMARY  OF THE SUPPLEMENTAL REMEDIAL INVESTIGATION AND ADDEN-
 DUM

 Page 5, Paragraph 2. Note 4

      .It should be noted that some volatile organic compounds (VOCs) but not all VOCs
 were reported at higher concentrations downgradient than upgradient of the Swope site in
 the deep aquifer. In fact, some VOCs were reported at higher concentrations upgradient
 than downgradient of the site in the deep aquifer. Therefore, these data do not conclusively
 demonstrate  that the Swope site has impacted water quality in the deep aquifer. This has
 been discussed in detail in the supplemental RI and Feasibility Study (FS) reports, as well
 as the November 6, 1990 and June 27, 1991 letters submitted to the USEPA.

 SUMMARY OF SITE RISKS

 Page 6. Paragraph  1

       In this  paragraph it is indicated that only risks presented by the presence of hazardous
 substances in ground water were evaluated in the Swope site risk assessment (Geraghty &
 Miller, Inc., Supplemental Feasibility Study for the Swope Oil and Chemical Company Site,
 Pennsauken Township, Camden County, New Jersey,  Volume IV of IV, May 1991). Risks
 presented by  the presence of hazardous substances in subsurface soils were also evaluated
 and quantified in the site risk assessment.

 Page 6. Paragraph 2

       This paragraph does  not include the following three exposure routes  which were
 assessed in the site risk assessment: (1) oral, dermal, and inhalation exposure to subsurface
 soils by a future construction worker; (2) oral, dermal, and inhalation exposure to subsurface

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GERAGHTV & MILLER. INC.

                                                                                  3
 soils by a future adult resident; and (3) oral, dermal, and inhalation exposure to subsurface
 soils by a future child resident.

 Page 7. Paragraph 1

       This paragraph states that human health risks from the drinking of contaminated
 ground water were calculated to have a hazard index of 3.8 and an excess lifetime cancer
 risk of 4.2 x 10'. It should be noted that these values are calculated for a resident that lives
 in the same home for 75 years and drinks 2 liters of water per day, 365 days per year.

 Page 7. Paragraph 2

       This paragraph states that risks associated with dermal contact and ingestion of site
 soils have not been quantified in the site risk assessment While it is true that extensive soil
 remediation has been performed by the PRPs, and potential risks associated with contact
 with soils at  the  site are considered to be minimal, nine future hypothetical scenarios
 (construction worker, adult  resident, and  child resident subject to oral, dermal, and
 inhalation exposure  to  subsurface soils)  were evaluated quantitatively  in the  site risk
 assessment (Geraghty &  Miller, Inc., May 1991). The hazard indices and excess lifetime
 cancer risks for the exposure to subsurface soil scenarios were calculated and found to be
 below the values typically deemed "acceptable" by the USEPA.  —• •-:=--•

 SUMMARY OF ALTERNATIVES
       Alternative 2 should be entitled "Ground-Water Monitoring Program, Sofl Vapor
 Extraction, and Natural Biodegradation." The annual operation and maintenance (O&M)
 cost for the ground-water monitoring program is estimated to be $222,000.  Therefore, the
 present worth O&M for this program, at an interest rate of 10 percent and an inflation rate

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GERAGHTY & MILLER. INC.
                                                                                 4
  of 5 percent, over a 5-year period would be $967,503. The capital cost of $687,400 is that
  capital cost estimated for the vapor extraction system (YES), only.  As stated in Table 7-1
  of the Supplemental FS Report (Geraghty & Miller, Inc., May 1991), the first year O&M
  estimated cost that was calculated for the operation  of  a VES at the  Swope  site was
  $281,000. Therefore, the total estimated cost for Alternative 2 is $967,503 plus $687,400 plus
  $281,000, or $1,935,903, for  one year of VES operation.  This estimated cost does not
  include any costs for bioremediation enhancement.

  Page 9. Paragraph  3

       It  is stated in this paragraph that the effluent air stream from the air blower will be
  passed through a catalytic oxidizer. It should be noted that for purposes of cost estimation,
  worst case scenarios were considered.  Thus, catalytic oxidation as a means of air emission
  control represents a worst case scenario. The actual air emission control equipment that is
  to be included in the final VES  design will be determined during the remedial design (RD)
  phase of this project.

       If you have any questions concerning these comments, please do not hesitate to call.
                                             Sincerely,
                                             GERAGHTY & vm.TP.Tt, INC.
                                             Douglas J. Newton ^
                                             Principal Scientist/Project Manager
                                             Betty Martinovich
                                             Principal Engineer/Project Engineer
                                             Arnold S. Veraick
                                             Vice President/Project Officer
 DJN/BM/ASV/MW:pg                        Michael Wolfert
                                             Vice President/Project Officer

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                         APPEKPIZ C
Letter from EPA'a Contractor Concerning Geraghty & Killer's
 Vadoae  2one Modeling and Proposed Soil Remediation Levela

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COM     FEDERAL     PROGRAMS    CORPORATION


September 13, 1991

Mr. Joseph Covers
U.S. Environmental Prrotection Agency
26 Federal Plaza
Nev York, Nev York 10278

PROJECT:        TES V, Contract:68-V9-0002
                Vork Assignment C02032
                Svope Oil and Chemical Site              .         _
                Pennsauken, Nev Jersey       —        ~-—-      -----

DOCUMENT NO.:   TESV-C02032-LR-CDXH

SUBJECT:        Reservations concerning Soil Remediation Levels
                Derived by the PRP using a Vadose-Zone Transport
                Equation


Dear Joe:

This letter synthesizes CDM FEDERAL PROGRAMS CORPORATION'S  (CDM FPC)
evaluation of the soil remediation levels derived by the PRP
contractor, Geraghty and Miller, using a modified contaminant
transport equation for the Svope Oil and Chemical Site in Pennsauken
Tovnship, Nev Jersey.  Our comments are based on extensive  reviev of
the PRP's data and the equations used, as presented in the  PRP
Feasibility Study, including sensitivity analysis of the equation to
various parameters.  This summarizes our comments as presented to EPA
in our technical reviews, dated January 23, 1991, and June  24, 1991,
of the draft and final PS reports  and our June 27 letter report
revieving the PRP equation and presenting additional SRL calculations
performed by CDM FPC.

The "Model"

The model used to calculate toil remediation levels is a simplified
solution to the one-dimensional partial differentiation equation  used
for saturated flov contaminant transport, for compounds vhich decay
vith time and are adsorbed by the soil matrix. As such, it  is probably
more appropriate to refer to the aodel as an equation, or an
analytical solution.

The analytical solution is a one-dimensional transport equation
developed by Van Genuchten and Alves (1982) to estimate the
attenuation of organic chemical constituents in the saturated zone.
The analytical "model" vas not designed as a "vadose-zone transport
model". It has been modified by the Gradient Corporation (in a
presentation of analytical models at the "Management of Manufactured
Gas Plants" seminar organized by the Gas Research Institute in Chicago


                    111 Wwn Stnct. Suitt 710 Ni* York. KY 100J8 212

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                                          CDM FEDERAL  PROGRAMS CORPORATION
in 1988) to represent unsaturafed zone contaminant transport by
assuming a constant average groundvater velocity through the ,.  .  •
unsaturated zone, -vhidi is assumed to equal the recharge rate at the
site. The revised'equation specifically calculates the concentration
of a chemical compound in the leachate as it coves through the
unsaturated zone at a specified soil depth and transport tine.

The fate of a chemical constituent in the coil column depends on its
mobilization, volatilization, and decomposition rates. Contaminant
transport through the unsaturated cone is extremely complex, and
requires large amounts of data input to adequately describe
characteristic processes affecting the transport of chemical
compounds. The modified Van Cenuchten equation only considers aerobic
biological decay of organic compounds, but ignores important physical
and chemical processes in the unsaturated zone such asi

- volatilization     ~~~  — —  ~-  —   -  -^—         -=**-   -~
- adsorption
- soil moisture characteristics
- time-dependent Infiltration
- oxygen transport
- mass fluxes of constituents betveen air, vater, and hydrocarbon
  phases
• the associated exchanges betveen each phase.

As such, the "model" does not simulate true field conditions. Rather,
due to the sioplistic analytical approach and generalized assumptions
Inherent in the solution, this method grossly oversimplifies a very
complex transport system. In addition, the sensitivity analyses
performed by COM FPC (letter report dated June 27, 1991) indicated
that the equation's results are very sensitive to small changes in the
deca;- rate and the fraction of organic carbon applied to the equation.
More importantly, significant fluctuations in calculated SRL's
occurred depending on the method chosen to calculate the complementary
error function (erfc) values.               	           -.-=.^-^^.-^__

Consequently, CON FPC has little confidence in the applicability of
the SRL results calculated by Ceraghty and Miller, and believes soil
remediation levels should be based on more empirical solutions.

If you have any questions concerning these comments, please do not
hesitate to contact me at (212) 393-9634.

Sincerely,

CDM FEDERAL PROGRAMS CORPORATION
Sally Odland
Vork Assignment Manager
                                 -2-

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