^*x( States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPWROCVR02-9(V113
September 1990
V-/EPA Superfund
Record of Decision
King of Prussia, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT MX
EPA/ROD/R02-90/113
X R»ctpt»nf« Ace««»lon No.
S. RcportDl*
SUPERFUND RECORD OF DECISION
King of Prussia, NJ
First Remedial Action
09/28/90
7. Autrart.*)
•. Performing Organlntton (tap*. No.
». PwfoiiningOrgiMirtonNimMidAddnM
10. ProiKVTnk/WoifcUnHNo.
11. Cenmc«(C) or Orwqa) No.
(C)
(O)
12. Sponsoring Orginlnlloii (term *nd AddrM*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IS. TyptofRoporttPwtodCovorad
800/000
14.
15. Supptainmtmy Note
IB. Abstract (UmH: 200 word*)
The 10-acre King of Prussia (KOP) site is an abandoned waste disposal and recycling
facility in Winslow Township, Camden County, New Jersey. The nearest residence is one
mile northeast of the site, and the nearest surface water body is the Great Egg Harbor
River, which flows 1,000 feet southwest of the site. In addition, an onsite swale,
which directs site runoff toward the river, has been dammed by two fire roads resulting
^•i the formation of onsite wetlands. Site features include three man-made, former
Btagoons, two rusting and torn tankers on a concrete pad, and an area with an
undetermined number of buried drums and containers. The waste recycling facility was
operated from 1970 to 1974 by the KOP Corporation. Past waste handling and disposal
practices at the facility, as well as suspected illegal dumping of trash and hazardous
materials after the facility closed, have resulted in organic and inorganic
contamination of site soil, sediment, and ground water. Soil and ground water
contamination were detected by the State in 1976, and subsequently confirmed by EPA
during site investigations conducted from 1978 to 1982. As a result of these
investigations, buried plastic containers and visibly contaminated soil west of the
lagoons were excavated and removed in late 1989 or 1990. However, several additional
(See Attached Page)
17. Do
•lyvte a. DMcripton
NJ
Record of Decision - King of Prussia,
First Remedial Action
Contaminated Media: soil, sediment, sludge, debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE), metals (chromium, lead)
e. COSATI FWd/Oroup
18. Avafllbitty StatMlwtt
19. SMWtty On* (TM« Report)
None
20. Security CtaM (Thto Pig*)
None
21. No. of Page*
161
22. Pita*
(So* ANSI-Z39.18)
SM Instruction* en fltwn*
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-S5)
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EPA/ROD/R02-90/113
King of Prussia, NJ
fctrst Remedial Action
Abstract (Continued)
discrete areas of contamination have been identified including: metal-contaminated soil
adjacent to the lagoons, lagoon sludges, swale sediment, and soil near the tankers;
VOC-contaminated soil in the drum disposal area; organic- and metal-contaminated ground
water; and possible contamination of the surface water and sediment in the river. This
Record of Decision (ROD) addresses the first operable unit for the site, including the
contaminated ground water, soil, sediment, sludges, drums and tankers. A future ROD
will address contaminated soil associated with the buried drum area. The primary
contaminants of concern affecting the soil, sediment, sludge, debris, and ground water
are VOCs including benzene, PCE, and TCE; and metals including chromium and lead.
The selected remedial action for this site includes excavating lagoon sludges, soil
adjacent to the lagoons, and sediment in the swale, treating these materials using soil
washing for metals removal, and redepositing the residual materials in their original
location onsite; excavating and disposing of buried drums, their contents, and
associated visibly contaminated soil onsite; removing tankers for offsite disposal;
ground water pumping and treatment using air stripping, followed by reinjection of
ground water and offsite disposal or treatment of residuals; conducting additional
sampling and analysis of surface waters and sediment of the Great Egg Harbor River and
soil in the buried drums area to determine the need for further site remediation; and
implementing institutional controls including ground water restrictions. The estimated
present worth cost for this remedial action is $14,889,000, which includes an estimated
annual O&M cost of $285,000.
PERFORMANCE STANDARDS OR GOALS: soil cleanup objectives are based on a 10-6 cancer
risk to human health, an HI less than 1, or State Action Levels and include chromium
483 mg/kg (Health-Based level), copper 3,571 mg/kg (Health-Based level), lead 500 mg/kg
(State) and nickel 1,935 mg/kg (Health-Based level). Ground water cleanup levels
are based on State and Federal MCLs, whichever is more stringent, including PCE 1 ug/1
(State), TCE 1 ug/1 (State), chromium 50 ug/1 (State), copper 1,000 ug/1 (State), and
nickel 210 ug/1 (State).
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ROD FACT SHEET
SITE
Name: King of Prussia Technical Corporation
Location/State: Winslow Township, Camden County, New Jersey
EPA Region: II
HRS score: 47.19 (7/22/82)
NPL rank: 244
ROD
Date Signed: September 28, 1990
Remedies: excavation and contaminant extraction of metal
contaminated soils, sediments and sludges; drum removal and off-
site disposal; tanker removal and off-site disposal; a pump and
treat system for contaminated ground water; and additional
monitoring of the Great Egg Harbor River.
Capital Cost: $10,501,000
0 & M/Year: $285,000
Present Worth: $14,889,000
LEAD
Enforcement
EPA/PRP
Primary Contact: James Hahnenberg, (212) 264-5387
Secondary Contact: John LaPadula, (212) 264-5388
Main PRPs: Cabot Beryl Company, Carpenter Technology, Ford Motor
Company, Johnson-Matthey, LNP Corporation, Reutgers-Nease
PRP Contact: Lynn Wright, (212)308-4411
WASTE
Type: metals and volatile organic compounds
Medium: soils, sediments, sludges, and ground water
Origin: abandoned lagoons, buried drums and carboys
Estimated quantity:
21,150 cubic yards metals contaminated materials
2,500 cubic yards organic contaminated materials
10 cubic yards tanker residue
contaminant plume: 900 feet x 1500 feet x 30 feet
(total volume 40,500,000 cubic feet)
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DECLARATION STATEMENT
RECORD O7 DECISION - OPERABLE UNIT ONE
XING 0? PRUSSIA TECHNICAL CORPORATION SITE
AD A' IjOea^ion
King of Prussia Technical Corporation Site
Winslow Township, Camden County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for the
King of Prussia Technical Corporation site, in Camden County, New
Jersey, developed 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 document explains the factual and legal basis for
selecting the remedy for this site. This decision is based on the
administrative record for the site. The attached index identifies
the items that comprise the administrative record.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
threat to public health, welfare or the environment.
Description ef the Selected Remedy
The remedial action described in this document is the first of two
planned operable units for the site. The final remedy for the first
operable unit action addresses groundwater and some soils, sediments
and sludges, and the removal of drums and tankers. The second
operable unit vill address contaminated soils associated with the
buried drum area.
The major components of the selected remedy include the following:
• Lagoon sludges, soils adjacent to the lagoons, and sediments
in the swale vill be excavated. Metal contaminants will be
extracted from these materials utilizing a multi-phass, soil-
washing process. Cleaned materials will then ba redeposited
in approximately their original location.
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Buried drums, their contents and visibly contaminated soils
will be excavated and disposed at an off-site location.
Additional characterization of residually contaminated soils
in the buried drum area will be conducted. This will provide
the basis for a remedial action decision regarding this soil.
A ground-water pumping system will be installed to capture the
contaminated ground water and prevent discharge of contaminants
to the Great Egg Harbor River.
An on-site ground-water treatment facility vill be installed
and maintained to remove contaminants from the collected
groundwater.
A ground-water reinjection system will be installed to reinject
treated ground water into the aquifer.
Tankers and their contents will be removed for off-site
disposal.
Additional sampling and analysis of surface waters and
sediments of the Great Egg Harbor River will be performed.
This will allow a determination on whether further remediation
of the river system is required.
Declaration of 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 it satisfies the
statutory preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances remaining
on site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
-^Constantine Sidamon-Eristoff / Da/£e "/
Regional Administrator
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DECISION SUMMARY
RECORD OF DECISION - OPERABLE UNIT ONE
KING OF PRUSSIA TECHNICAL CORPORATION SITE
SITE NAME. LOCATION. AND DESCRIPTION
The King of Prussia site (the "site") is located on Piney Hollow
Road on tax block 8801. lot 1A in Winslow Township, Camden
County, New Jersey (Figure 1). The ten-acre site is in a rural
area approximately 30 miles southeast of Philadelphia,
Pennsylvania.
The land to the northeast, northwest and southwest is within a
dense pine forest of the state-owned, 6,000-acre Winslow Wildlife
Management area (Figure 1) and is primarily utilized for
recreational purposes. The site is also within the New Jersey
Pinelands National Reserve, which encompasses portions of six
counties in southern New Jersey.
The nearest residence is a single family home approximately one
mile northeast (upgradient) of the site. Piney Hollow Road
borders the site to the southeast and an unnamed fire road is
located 200 to 500 feet southwest. The Atlantic City Expressway
and U.S. Route 322 (Black Horse Pike) are located 2 miles
northeast and southwest of the site, respectively.
The nearest body of surface water is the Great Egg Harbor River,
approximately 1000 feet southwest of the site (Figure 2). The
river is used for recreational purposes and has been proposed to
be nationally designated as a Wild and Scenic river.
A swale, which directs site runoff toward the river, is dammed by
two fire roads (Figure 2). The swale is a wetlands based on a
preliminary assessment by the Environmental Protection Agency
(EPA) personnel. During periods of heavy rainfall, water may
cross the roads and deliver surface runoff to the river.
Stressed vegetation and trees have been observed in the upper
swale area and are believed to be caused by metals-contaminated
runoff from the site.
Although no historic or landmark sites are directly affected by
the site, the area has a high potential for archeological
resources in areas not disturbed by modern activity.
There are no endangered species or critical habitats within close
proximity of the site, but the Great Egg Harbor River and
wetlands habitats along the river support migratory species which
could be impacted.
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The site itself is relatively level, rectangularly shaped, and
generally barren and sandy. Vegetation is limited to sparse
patches of tall seed grass. Three nan-made lagoons are still
evident, and a fourth may be identified by a slight depression.
These lagoons are located in a slightly elevated area near the
center of the property (Figure 2). Two rusting and torn tankers
are lying on a-concrete pad between Piney Hollow Road and the
lagoons (Figure 2). Toward the back of the site is an area with
an undetermined number of buried drums and containers (Figure 2).
BITE HISTORY
Origin of the Problem
On July 1, 1970, the King of Prussia Technical (KOP) Corporation
presented a proposal to the Winslow Township Committee for the
KOP Corporation to purchase a tract of land owned by the township
for the purpose of constructing a waste recycling facility. The
proposal was subsequently approved by the township and operations
at the site began by January 1971.
Six lagoons were used to process liquid industrial waste. The
stated intention by the KOP Corporation was to convert these
wastes to materials that would be marketed as construction
materials and other uses. However, the KOP Corporation was
unable to market these materials and the site soon had more waste
than it could process and sell. A minimum of 15 million gallons
of acids and alkaline aqueous waste were processed at the
facility when KOP Corporation was the operator, with excess
materials transported to other disposal locations.
The KOP Corporation filed for bankruptcy on April 8, 1974. Prior
to declaring bankruptcy, KOP Corporation sold its hauling
operation to Evor Phillips Incorporated which subsequently
purchased the site property. It is believed that operations
ceased and the site was abandoned in late 1973 to early 1974. in
1976, Winslow Township foreclosed on the property for failure of
the Evor Phillips Incorporated to pay taxes, and the township
resumed ownership of the property. The township is the current
owner of the property. Illegal dumping of trash and hazardous
materials is suspected, as the site was easily accessible until a
fence was installed by the Potentially Responsible Parties (PRPs)
in 1988.
Enforcement Actions
In April 1985, EPA entered into an Administrative Order on
Consent (AOC) with five PRPs to conduct a Remedial Investigation
a-.-i Feasibility Studv (RI/FS) .
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The RI was completed by the PRPs in July 1989. The FS, 'also
completed by the PRPs, was released by EPA in July 1990. EPA
also issued a Supplemental Feasibility Study (SFS) in August 1990
to clarify and explain alternatives not sufficiently addressed in
the FS.
In 1988 and 1989, EPA identified additional PRPs bringing the
total number of PRPs to fourteen. These PRPs are:
Cabot Beryl Company
Carpenter Technology
Sidney Dennis
Ford Motor Company
Sidney Fried
Robert Hauslohner (deceased)
Anthony D. Introcaso
Johnson-Matthey
King of Prussia Technical Corporation (bankrupt)
Harrison Kalbach
LNP Corporation
Evor Phillips
Reutgers-Nease Chemical Company
Ernest Roth
EPA's search for additional PRPs is continuing.
Remedial Actions and Initial Investigations bv the EPA and
the NJDEP
The New Jersey Department of Environmental Protection (NJDEP) was
first notified of possible unauthorized activities at the site in
January 1975. Subsequent site inspections by NJDEP and a ground-
water study by Geraghty and Miller in 1976 indicated
contamination of the soils and ground water at the site.
EPA confirmed contamination with additional sampling and
investigations during 1979, 1980 and 1982. In December 1985, the
site was formally listed on the National Priorities List.
Investigations conducted by the PRPs, with EPA oversight, were
started in 1985, with the RI being approved in August 1989 and
the FS issued to the public in July 1990. EPA also conducted a
Supplemental Feasibility Study which was also released in August
1990. The site property was fenced in July 1988 at the request
of EPA to restrict access and prevent health risks associated
with direct contact and prevent illegal dumping.
Buried plastic containers (carboys) and surrounding soils with
visible contamination, located inside the fence west of the
lagoons, were excavated and staged for removal in October 1989.
7ir.il r^-"'-"-'./r 1 and off-site disposal is now complete.
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Activities planned for the fall of 1990 include beginning the
expedited removal of buried drums and visibly contaminated soils.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and SFS Reports and the Proposed Plan for the KOP site
were released to the public for comment on July 16, 1990. These
three documents were made available to the public as part of the
administrative record which was maintained at the EPA Docket Room
in Region II at 26 Federal Plaza in New York City and at an
information repository at the Camden County Public Library. The
notice of availability for these documents was published in the
Courrier Post on July 22, 1990. A public comment period on the
documents was held from July 16, 1990 to September 14, 1990. In
addition, a public meeting was held on August 1, 1990. At this
meeting, representatives from EPA answered questions about
problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is part
of this Record of Decision (ROD).
SCOPE AND ROLE OF RESPONSE ACTION
This ROD addresses planned remedial actions for the first
operable unit.
Due to the wide variety of contaminants and multiple migration
routes present at the KOP site, EPA has divided the remedial
action for the first operable unit into the five components
described below.
Component It Metals-contaminated soils adjacent to lagoons,
sludges in lagoons, and sediments in the swale (Figure 2).
Component 2; Buried drums and soils contaminated with volatile
organic compounds located toward the rear (northwest) of the site
(Figure 2).
Component 3; Tankers and contents located near the front
(southeast) of the site. Soils under and adjacent to the tankers
will be addressed as part of Component 1 (Figure 2).
Component 4; Organic and metals-contaminated ground water
(Figure 2)#
Component 5; Surface waters and sediments and biota of the Great
Egg Harbor River (Figure 2).
This remedial action addresses thr principle threats presented ax.
the site which are included in the first operable unit.. A second
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operable unit will address residually contaminated soils
associated with the buried drum area. The Great Egg Harbor River
could also become an additional operable unit, if contamination
detected during the remedial design or subsequent monitoring
indicates that remediation is required.
SUMMARY OP SITE CHARACTERISTICS
Site Geoloov
The site is underlain by unconsolidated Coastal Plain sediments
of the Tertiary and Cretaceous Age. These sediments consist of
unconsolidated sands, gravels and clays which form a southeastern
thickening wedge approximately 2,000 feet thick. Unconformably
underlying these sediments is relatively low permeability
metamorphic bedrock.
The Cohansey Sand crops out at the site. This formation consists
of unconsolidated sands, silts and clays.
The Cohansey Sand, the Kirkwood Formation, and any younger
overlying sediments are collectively known in this area as the
Kirkwood-Cohansey Aquifer System. Due to the absence of
extensive regional confining beds, the Cohansey Sand and the
underlying Kirkwood Formation are generally in hydraulic
connection. Based upon regional data, the Kirkwood-Cohansey
Aquifer occurs at approximately 150 feet below mean sea level at
the site.
Two aquifers within the Kirkwood-Cohansey Aquifer System were
identified at the KOP site. The upper (also referred to as the
upper subzone) aquifer begins at 15 feet below the surface and
extends to approximately 35 feet. A second aquifer extends
downward from 50 feet below the surface to a depth of
approximately 250 feet. This is herein referred to as the deep
aquifer, but is referred to as the lower subzone aquifer in
various site investigations. A 10-foot to 20-foot semi-confining
layer separates the two porous and permeable aquifers and is
composed predominantly of discontinuous silt and clay zones.
These lithofacies grade to sands in some areas. This is herein
referred to as the intermediate aquifer, but is referred as the
middle subzone semi-confining (or confining) aquifer.
At the KOP site, the ground-water flow direction is southwest
toward the Great Egg Harbor River. High porosity and,
permeability of on-site soils produces rapid infiltration of
precipitation and rapid recharge of the underlying Kirkwood-
Cohansey Aquifer. Lateral ground-water flow in the upper aquifer
is approxirately one foot per day and 0.4 foot per day in the
lower aiiuiier. Tho vpper aquifer discharges to the Greax. £3;
Harbor River while the deeper aquifer may have a minor flow
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component that also discharges to the river.
The Great Egg Harbor River, located approximately 1000 feet
southeast of the site (Figures 1 and 2), drains eastern Camden
County and all of Atlantic County. The river discharges to the
Atlantic Ocean north of Ocean City, New Jersey.
There are no residential veils in the vicinity of the site. Two
wells, neither of which serve as potable water supplies, are
located within a half mile radius of the site. These wells are
located at the Johnson-Matthey Company located just across Piney
Hollow Road from the site and the field office of the New Jersey
Division of Fish, Game and Wildlife across the river from the
site (Figure 1). The nearest residential water well is
approximately one mile northeast and upgradient from the site.
Component 1 - Metals Contaminated Soils. Sediments and
Sludges
During the RI, shallow soil on site and swale sediments less than
2 feet deep ("surface") were investigated by the collection and
analysis of 117 samples from 100 locations. Soils from 2 to 10
feet in depth ("subsurface") were also investigated by collection
and analysis of 104 samples from 66 locations. Surface and
subsurface sludges were investigated by the collection and
analysis of samples from 18 locations.
Beryllium, chromium, copper, nickel and zinc are the principal
contaminants detected in the surface and subsurface soils
adjacent to the lagoons, sediments in the swale and sludges in
the lagoons and adjacent areas (Figure 2). Generally, the metals
contaminants are known or probable carcinogens, and also exhibit
harmful noncarcinogenic effects.
Distribution of site contamination demonstrated by analytical
results of sampling efforts indicate that migration through
environmental media is occurring. Contaminants residing in the
soils, sediments and sludges are believed to be migrating
vertically downward to the ground water.
Surface contamination from 0 to 2 feet depth is present in the
lagoons, as well as in soils adjacent to the lagoons and tankers,
and in the swale adjacent to the site. The highest
concentrations of surface contamination is in sediments at the
bottom of the swale. Maximum concentrations of contaminants that
exceed soil cleanup levels are chromium 8,010 parts per million
(ppm), copper 9,070 ppm, mercury 100 ppm (adjacent to the
tankers), and silver 18 ppm (Table 1).
Subsurface contamination from 2 to 10 feet deep is present in the
lagoons and adjacent on-site soils; deepest soils above the
cleanup levels (Table 2) are at a depth of seven feet. Highest
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concentrations have been detected in a zone of sludge-like
material at a depth of 3 to 4 feet northwest and adjacent to the
lagoons. Maximum concentrations for the following contaminants
are: 11,300 ppm for chromium, 16,300 ppm for copper, 389 ppm for
lead, 1.7 ppm for mercury, and 11,100 ppm for nickel (Table 2).
In general, the soils have infrequent and low concentrations of
volatile and semi-volatile organic compounds.
The volume of metals-contaminated soils, sediments and sludges in
the surface and subsurface above risk-based cleanup levels
(Tables 1 and 2) for this component is estimated at 21,150 cubic
yards. This includes 19,500 cubic yards of on-site soils and
sludges and 650 cubic yards of sediments in the swale located
between the site and the river (Figure 2). The total area
covered by these materials is approximately three acres.
Volatile Organic Compounds
The contents of a partially buried drum and two samples of
visibly contaminated soils were analyzed for determination of the
types and concentrations of contaminants. Conductivity and
magnetometer surveys were also conducted to determine the
location and number of buried drums.
Analysis from a buried drum located in the rear (northwest) of
the site (Figure 2) indicated high concentrations of volatile and
semi-volatile organic compounds. The total concentration for
volatile and semi-volatile organic compounds, including
tentatively identified compounds, is greater than 80 percent (%)
(Table 3) for the liquid contents sampled from the drum. Soil
sampling in the area adjacent to the drums also indicated
significant concentrations of volatile organic compounds (Table
4). Examples are: tetrachloroethane 270 ppm, 1,2-
dichlorobenzene 44 ppm, and naphthalene 3 ppm. Metals-
contaminant concentrations are above background levels but below
soil cleanup goals.
The total volume of drums and soils contaminated with volatile
and semi-volatile compounds is uncertain due to limited soils
sampling in this area. Magnetic and conductivity surveys and
sample data indicate an area of buried drums estimated to be
11,300 square feet. Assuming that the depth of contaminated
soils and drums is approximately six feet, the estimated total
volume is 2500 cubic yards of which 250 cubic yards (10% of total
volume) are estimated to consist of drums and 2250 cubic yards of
contaminated soils.
Many of the volatile and semi-volatile organic compounds
identified in the contents sampled from the buried drum and
adjacent soils have adverse carcinogenic and noncarcinogenic
health effects on humans.
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8
Contaminants in the buried drums and nearby soils have migrated
vertically downward to the ground water and are continuing to
discharge into the ground water. In order to prevent further
discharge of contaminants into the ground water and to remove any
physical hazard from the deteriorating drums, the drums and
visibly contaminated soils are planned for removal and off-site
treatment and disposal beginning in the fall of 1990.
Component 3 - Tankers and Contents
The contents of rusting, deteriorating tankers near the front
(southeast) of the site (Figure 2) were sampled and analyzed.
Major contaminants of the residues in the tankers included:
chromium 6,580 ppm, copper 10,080 ppm, and nickel 6,450 ppm
(Table 5).
The tankers occupy an area approximately 15 by 30 feet for a
total area of 450 square feet. Total tanker volume is estimated
to be 83 cubic yards and the volume of the residue in the tankers
is estimated to be 10 cubic yards.
These inorganic metals contaminants in the tanker residue are
known to have adverse noncarcinogenic and carcinogenic health
effects on humans.
Component 4 - Ground Water
Twenty-eight monitoring wells were installed to define the
extent, concentrations and types of contaminants in the ground
water (Figure 3). Wells located at the Johnson-Matthey facility
and the New Jersey State Fish and Game office were also sampled
and analyzed (Figure 1). Electric logs were run on 11 wells to
assist ir. defining the lithology and stratigraphy of the
aquifers.
The source for the ground-water contamination is believed to be
from contamination in the soils, sludges and sediments, and the
buried drums and tankers, discussed above. The highest
contaminant concentrations have been identified in the upper
aquifer in an area between the site and the Great Egg Harbor
River (Figure 3) approximately 1000 feet wide and 1500 feet
length.
Contaminants detected in the upper aquifer (also referred to as
the upper subzone) in excess of acceptable federal and state
levels under the Safe Drinking Water Act (SDWA) include metals
and volatile organic compounds. Examples of maximum
concer,«-rat:.cr.s ?T£: chrraiua 1,040 parts per billion (ppt) ,
copper l.:,50C ppb, nickel 4,670 ppb, tetrachloroethene .2,500 ppb,
trichloroethene 940 ppb, and ethylbenzene 80 ppb (Table 6) . The
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9
upper aquifer discharges to the Great Egg Harbor River a'nd is
believed to be the source of contaminants detected in river
sediments and surface waters.
These compounds are known to have adverse carcinogenic and
noncarcinogenic health effects on humans. :
Site-related contamination in concentrations above drinking water
standards was also detected in the intermediate and deep aquifers
(Tables 7 and 8). The intermediate and deep aquifers are also
referred to as the middle subzone semi-confining aquifer and
lower subzone aquifer, respectively.
Component 5 - the Great Boa Harbor River
Eight surface-water and nine sediment locations were sampled and
analyzed to determine the extent, concentration and types of
contaminants in the river (Tables 9 and 10).
Ground-water contamination has migrated toward the Great Egg
Harbor River, with contaminants in the upper aquifer discharging
to the river (Figure 3). The highest contaminant concentrations
in the aquifer have not yet reached the river and are estimated
to be approximately 500 feet east of the river (Figure 3).
The Great Egg Harbor River has low levels above background
concentrations of metals contamination in both the surface waters
and sediments (Tables 9 and 10). Maximum concentrations detected
in the surface water were 11 ppb of chromium and 110 ppb of
copper. Copper was the only compound that exceeded its Ambient
Water Quality Standards (12 ppb). Metals contaminants may
present a threat to stream biota, but are below those values
determined to present a risk to human health. No organic
compounds were detected above background levels in surface water
or river sediment samples.
Purple Stained Sands
A minor but visible feature at the site are purple stained sands
found intermittently in the surface and near-surface soils,
primarily northwest of the lagoons toward the rear of the site.
Analysis suggests these materials are rounded sand grains which
are thinly coated with methyl violet dye believed to have been
produced from a grinding process in dye manufacture. This
material was analyzed for priority pollutants and indicator
compounds with no significant concentrations found. Since purple
stained soils are not believed to present a human health or
environmental risk at the site, no remedial alternatives were
considered for these materials.
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10
SUMMARY OF SITE RISKS
Hazard Identification
EPA conducted an Endangerment Assessment (EA) of the "no action"
alternative to evaluate the potential risks to human health and
the environment associated with the King of Prussia site in its
current state. The EA focused on the site contaminants which are
likely to pose the most significant risks to human health and the
environment (indicator chemicals). These "indicator chemicals"
included volatile and semi-volatile organic compounds and metals.
The indicator compounds and their concentrations in site media
are shown in Tables 11 and 12.
Contaminants and Exposure Assessment
Contaminated media at the site include: metal-contaminated
soils, swale sediments, and lagoon sludges; buried drums
containing volatile and semi-volatile organic contaminants;
tankers containing metals residue; ground water contaminated with
volatile and semi-volatile organics and metals; and metal-
contaminated surface waters and sediments of the Great Egg Harbor
River.
EPA's EA identified several potential exposure pathways by which
the public may be exposed to contaminant releases from the site.
These include:
ingestion of site soils, sludges and swale sediments;
inhalation of contaminated dust from site soils and swale
sediments;
dermal contact with contaminated soils, sludges and swale
sediments;
ingestion and dermal contact with contaminated ground water;
• inhalation of compounds volatilizing from contaminated
ground water; and
• ingestion of fish caught from the Great Egg Harbor River.
The potentially exposed populations include adults or children
residing at the site or using the area for recreational
activities.
Dose-Response Evaluation
Tue dose-response evaluation presented available human health and
environmental criteria for the contaminants of concern, and
related the chemical exposure (dose) to expected adverse health
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effects (response). Included in this assessment are the
pertinent standards, criteria, advisories and guidelines
developed for the protection of human health and the environment.
An explanation of how these were applied is presented below.
The likelihood of carcinogenic (cancer causing) and
noncarcinogenic effects due to exposure to site chemicals are
considered separately. It was assumed that the toxic effects of
the site-related chemicals would be additive. Thus, carcinogenic
and noncarcinogenic risks associated with exposures to individual
indicator compounds were summed to indicate the potential risks
associated with mixtures of potential carcinogens and
noncarcinogens, respectively.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by the EPA for the indicator compounds.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to generate an upper-bound estimate of the excess
lifetime cancer risk associated with exposure to the compound at
that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the CPF. Use
of this approach makes the underestimation of the risk highly
unlikely. The CPFs for the indicator chemicals are presented in
Table 13.
Noncarcinogenic risks were 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 potential
adverse health effects. RfDs, which are expressed in units of
mg/kg-day, are estimates of daily exposure levels for humans
which are thought to be safe over a lifetime (including sensitive
individuals). Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) 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
compounds across all media. A hazard index greater than one
indicates that potential exists for noncarcinogenic 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. The reference doses for the indicator
chemicals at the King of Prussia site are presented in Table 13.
Risk Characterization
The risk characterization quantifies present and/or potential
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future threats to human health that result from exposure to the
contaminants of concern at the site. The site-specific risk
values are estimated by incorporating information from the hazard
identification, dose-response evaluation, and exposure
assessment.
The cancer risks for the King of Prussia site are shown in Table
14. For known.or suspected carcinogens, the EPA considers excess
upper bound individual lifetime cancer risks of between 10"4 to
10 to be acceptable. This level indicates that an individual
has an additional chance in ten thousand to one additional chance
in a million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year period under
specific exposure conditions at the site. Cancer risks at the
site primarily result from potential use of contaminated ground
water, although presently there are no users of the ground water
in the proximity of the site. vThe cancer risk associated with
the ingestion of site ground water is 2.4 x 10'2 (Table 14), well
above EPA's acceptable risk range of 10"4 to 10*. The proposed
remedial activities will reduce contaminant concentrations to
Maximum Contaminant Levels (MCLs) which are drinking water
standards (Table 16).
The Hazard Indices for the indicator compounds at the King of
Prussia site are shown in Table 15. The greatest noncancer risks
result from residential use of ground water in the upper aquifer.
For a child, a hazard index of 89.5, and 31 for an adult has been
calculated due to ingestion of copper, nickel and chromium (Table
15) at contaminant concentrations residing in the ground water.
The calculations presented in the EA indicate that the major
risks presented from surface and near surface contamination are
from soil ingestion. The greatest noncancer risk represented is
due to ingestion by a small child residing at the site and is
represented by a hazard index of 3.7 (Table 15). Based upon
these data, cleanup standards for surface soils were developed
during the FS (Table 17). These standards will reduce the hazard
index to less than one and will ensure that contaminants do not
continue to migrate to the ground water.
In summary, risks to public health include actual or potential
risks to recreational users and future residents at the site who
may be impacted from the ingestion or inhalation of contaminated
ground water and ingestion of contaminated soils. EPA has
determined that actual or potential site-related risks warrant a
remedial action for the site.
Environmental Impacts
Evaluation of adverse environmental impacts have not been
developed to the extent that public health standards have been
developed. Consequently, the evaluation of potential adverse
environmental impacts is qualitative.
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In many respects, environmental concerns at the KOP site are as
significant as the public health concerns presented above. The.
site is surrounded on three sides by the Winslow Wildlife
Management Area and is part of the Pinelands National Reserve.
Also, the Great Egg Harbor River has been proposed to be
nationally designated as a Wild and Scenic River.
The terrestrial flora or fauna on or in the vicinity of the site
could potentially be exposed directly or through bioaccumulation
from site-associated contamination.
Although concentrations of metals detected in sediments and
surface waters of the Great Egg Harbor River and the swale
suggest minimal potential for adverse effects to aquatic
receptors (primarily fish), contaminants may be in a bioavailable
form. Several of the metals found are bioaccumulative and also
exhibit other effects such as phytotoxicity (copper) and
carcinogenicity (chromium and nickel). In addition, migratory
birds may be receiving bioaccumulated contaminants through
invertebrates and fish in their food chain. Adverse effects to
terrestrial fauna cannot be discounted.
Environmental damage to the forested area surrounded by the King
of Prussia site is the most obvious impact of contamination
existing at and migrating from the site. Aerial photographs and
discussions with State Fish and Wildlife personnel indicate that
vegetation in the area was not stressed prior to establishment of
the KOP waste treatment facility in 1970 or 1971. A photograph
taken in 1975, just after site abandonment, shows stressed
vegetation throughout much of the area on and off site.
Information in the literature indicates that concentrations of
heavy metals well below those known to be present at the site
exert toxic effects on terrestrial ecosystems.
While there are few site-specific data to evaluate the effects of
the observed concentrations of indicator compounds on flora or
fauna which may come into contact with site-related
contamination, adverse affects cannot be discounted.
Data generated during the EA was utilized to develop soil cleanup
standards to assure that contaminants do not continue to migrate
into the ground water and risks to recreational users or
inhabitants at the site are reduced to an acceptable level.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, s's in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
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- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Environmental sampling uncertainty arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present over an extended area. Chemical
analysis error can stem from several sources including the errors
inherent in the analytical methods and characteristics of the
matrix being sampled. Uncertainties in the exposure assessment
are related to estimates of how often an individual would
actually come in contact with the chemicals of concern, the
period of time over which such exposure would occur, and in the
models used to estimate the concentrations of the chemicals of
concern at the point of exposure. Toxicological uncertainties
occur in extrapolating both from animals to humans and from high
to low doses of exposure, as well as from the difficulties in
assessing the toxicity of a mixture of chemicals. These
uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the
assessment. As a result, the EA provides upper bound estimates
of the risks to nearby populations, and is highly unlikely to
underestimate actual risks related to the site.
In conclusion, based on the results of the risk assessment,
actual or threatened releases of hazardous substances at the
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an endangerment
to public health, welfare or the environment.
DESCRIPTION OF ALTERNATIVES
The remedial alternatives which were selected for detailed
evaluation as described below, are presented for each area of
contamination, described herein as components. Estimated
implementation times for the alternative components represent
construction times and do not include remedial design.
Component
The objective of Remedial Component 1 is to achieve removal of
contaminants from site soils, lagoon sludges and swale sediments
that exceed cleanup levels (Table 17 for cleanup levels and
Figure 2 for areal distribution) developed during the FS; the
total volume of these materials is estimated to be 21,150 cubic
yards. These -t?.-.iards were developed based on risk to public
health. Although these standards are not considered applicable
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or relevant and appropriate requirements (ARARs), cleanup to
these levels would ensure that the contaminants do not continue
to migrate into the ground water and that risks to recreational
users or inhabitants at the site would be reduced to an
acceptable level (a hazard index of less than 1). Human health
risks presented by current contaminant concentrations of
ingestion of metal contaminated soils are calculated to have a
hazard index of 3.7.
ALTERNATIVE S-l: NO ACTION
Capital Cost: $ 0
Annual Operation and Maintenance Cost: $ 7,000
Total Present Worth: ' $79,000
Estimated Implementation Time: 2 Months
The No Action Alternative for metals-contaminated soils, sludges
and sediments provides a baseline against which other
alternatives may be compared. The fence that presently encloses
the site would remain to restrict public access. No remedial
activities would be performed but long-term ground-water
monitoring would be conducted. Potential health risks would not
be reduced as there would be no reduction in toxicity, mobility
or volume of metals contaminants in the soils, sediments and
sludges.
ALTERNATIVE S-2: LIMITED ACTION
Capital Cost: $ 43,000
Annual Operation and Maintenance Cost: $ 9,000
Total Present Worth: $144,000
Estimated Implementation Time: 6 Months
The Limited Action Alternative for mc-tals-contair.inated soils
consists of site and deed restrictions, additional fencing around
the swale and long-term, ground-water monitoring. Potential
public health risks would be somewhat reduced by limiting access
to contaminated soils, sediments and sludges. However, there
would be no reduction in toxicity, mobility or volume of metals
contaminants in the soils, sediments and sludges. Contaminants
from these media would also continue to migrate into the ground
water and eventually discharge to the Great Egg Harbor River.
This would pose minor risks to current recreational users and
higher risks to future users when higher concentrations of
contaminants subsequently reach the river.
ALTERNATIVE S-3: LIMITED EXCAVATION OF SEDIMENTS AND SOILS;
CONSOLIDATION; CAPPING
Capital Cost: $1,550,000
Annual Operation and Maintenance Cost: -- $ 17,000
Total Present Worth: . $1,741,000
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Estimated Implementation Tine: 12 Months
This alternative consists of excavation and consolidation of 650
cubic yards of swale sediments and 350 cubic yards of site soils
outside of the area to be capped. These materials would be
consolidated in'the lagoons and adjacent area followed by
installation of a multi-layer cap covering 2.6 acres. Long-
term, ground-water monitoring would also be conducted to
determine contaminant degradation and/or migration. Potential
health risks would be reduced by eliminating direct contact with
these materials, but there would be no reduction in toxicity or
volume of metals contaminants in the soils, sediments and
sludges. Migration of contaminants from these materials into the
ground water would be reduced but not eliminated.
ALTERNATIVE S-4: COMPLETE EXCAVATION OF SOILS, SEDIMENTS AND
SLUDGES; CONTAMINANT EXTRACTION; REDEPOSITION
ON SITE
Capital Cost: $8,050,000
Annual Operation and Maintenance Cost: $ 0
Total Present Worth: $8,050,000
Estimated Implementation Time: 18 Months
This alternative consists of excavating and treating 20,150 cubic
yards of contaminated soils, sediments and sludges in a multi-
stage soil washing/extraction process which would reduce the
concentration of contaminants so that they would no longer be
hazardous or would be "noncharacteristic". These materials would
be redeposited to their approximate former locations to restore
site topography followed by revegetation with native Pinelands
species. The site would be restored for unrestricted use.
Treatability studies would be required to optimize design of a
soil washing system.
ALTERNATIVE S-5: IN SITU STABILIZATION/SOLIDIFICATION; CAPPING
Capital Cost: $3,182,000
Annual Operation and Maintenance Cost: $ 10,000
Total Present Worth: $3,336,000
Estimated Implementation Time: 18 Months
This alternative consists of excavation and consolidation of 650
cubic yards of swale sediments and 350 cubic yards of site soils
outside of the area to be treated and capped. The area of
consolidation, stabilization and capping includes a 2.6-acre area
of the lagoons and adjacent area toward the rear of the site.
After consolidation, in situ stabilization would be performed
using P, systeia of injection and cixing augers and a mult3-layer
cap constructed. Mobility of contaminants would be reduced;
treated materials would then be rendered "noncharacteristic".
Long-term, ground-water monitoring would be required and site
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access restricted. Treatability studies would be required to
determine the design parameters for this alternative.
ALTERNATIVE S-5a: COMPLETE EXCAVATION OF SOILS, SEDIMENTS AND
SLUDGES; STABILIZATION/SOLIDIFICATION;
CAPPING
Capital Cost: $5,402,000
Annual Operation and Maintenance Cost: $ 10,000
Total Present Worth: $5,555,000
Estimated Implementation Time: 18 Months
This alternative is similar to S-5, except all contaminated
soils, sediments and sludges (20,150 cubic yards) would be
excavated and stabilized above ground. After excavation and
consolidation, these materials would be mixed with cementing and
stabilizing agents to create a structurally strong and inert
matrix. A multi-layer cap would then be constructed over a 2.6-
acre area over the lagoons and adjacent area. Long-term
monitoring would be required and site access restricted.
Treatability studies would be required to determine the design
parameters for this alternative.
ALTERNATIVE S-6: COMPLETE REMOVAL; OFF-SITE DISPOSAL
Capital Cost: $11,500,000
Annual Operation and Maintenance Cost: $ 0
Total Present Worth: $11,500,000
Estimated Implementation Time: 12 Months
For this alternative, approximately 20,150 cubic yards of
untreated contaminated soils, sludges and sediments would be
excavated and transported to an off-site Resource Conservation
and Recovery Act (RCRA) facility permitted for disposal of
hazardous materials. All soils, sludges and sediments above
action levels would be removed from the site, replaced with clean
fill and revegetated with native Pinelands species.
Because of the current limitations on the off-site treatment or
disposal of hazardous wastes caused by the unavailability of
permitted disposal locations, the potential exists that these
materials would have to be stored onsite in accordance with
appropriate RCRA mixed waste requirements until a treatment or
disposal facility becomes available.
Component 2 - Buried Drums and Soils CQ*fc»™
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yards of adjacent soils that may contain volatile and sem.i-
volatile organic contaminants.
ALTERNATIVE DR-1: NO ACTION
Capital Cost: $ 0
Annual Operation and Maintenance Cost: $ 7,000
Total Present Worth: $79,000
Estimated Implementation Time: 2 Months
The No Action Alternative for organically contaminated soils in
the buried drum area provides a baseline against which other
alternatives may be compared. The fence that presently encloses
the site would remain to restrict public access. Contaminants in
the soil and deteriorating drums would continue to migrate into
the ground water. Ground water would be monitored using existing
wells. The number and condition of buried drums would remain
undetermined.
ALTERNATIVE DR-2: DRUM REMOVAL AND OFF-SITE DISPOSAL; SAMPLING
AND ANALYSIS OF SOILS
Capital Cost: $386,000
Annual Operation and Maintenance Cost: $ 0
Total Present Worth: $386,000
Estimated Implementation Time: 12 Months
This alternative consists of removal and off-site treatment and
disposal of buried drums and visibly contaminated soils followed
by sampling and analysis of residually contaminated soils. The
volume of materials that would require off-site treatment and
disposal is estimated to be approximately 250 cubic yards. Post-
removal soil sampling and analysis would define contaminant
types, concentrations and soil volumes that may also require
remediation. A focused feasibility study including treatability
testing would be conducted to evaluate remedial alternatives for
residual soil contamination.
Component 3 - Tankers and Contents
The objective of Remedial Component 3 is to achieve removal of
the tankers and contents (Figure 2). The tankers are estimated
to have 83 cubic yards capacity, with approximately 10 cubic
yards of waste metals-contaminated residue. Contaminated soils
under and adjacent to the tankers would be addressed as part of
Component 1.
ALTERNATIVE TK-1: NO ACTION
Capital Cost: $0
Annual Operation ari rt^intenance Cost: $0
Total Present Worth: $0
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Estimated Implementation Time: 0 Months
This alternative would not include any remedial activity. The
fence that presently encloses the site would remain to restrict
public access to the tankers and their contents. There would be
no reduction in toxicity, mobility or volume of contaminants in
the tankers and deterioration of the tankers would continue.
Runoff from the tanker contents would continue to contaminate
nearby soils and migrate into the ground water.
ALTERNATIVE TK-2: TANKER REMOVAL AND OFF-SITE DISPOSAL
Capital Cost: $22,000
Annual Operation and Maintenance Cost: $ 0
Total Present Worth: $22,000
Estimated Implementation Time: 2 Months
This consists of removing the tankers and contents and their
treatment and disposal at an off-site facility. This would
permanently reduce mobility, toxicity and volume of the tanker
wastes at the site and eliminate the risks posed by this source
area.
Component 4 - Ground Water
Ground-water extraction scenarios were designed for aquifer
restoration and to prevent migration of contaminated ground water
(Figure 3) to the Great Egg Harbor River. The ground water at
this site is classified as GW-2 (drinking water quality) under
NJAC 7:9-6.7 and NJAC 7:9-6.4.
The cancer risk from drinking contaminated ground water is 2.4 x
102 although there are no users of the ground water in proximity
of the site. The nearest residential user of ground water is one
mile northeast (upgraciient) of the site.
New Jersey Ground Water Quality Criteria and Maximum Contaminant
Levels established pursuant to the federal and state Safe
Drinking Water Acts would be applicable or relevant and
appropriate federal and state ground-water requirements for this
remedial action. Table 16 identifies the ground-water remedial
ARARs for the site.
ALTERNATIVE GW-1: NO ACTION
Capital Cost: $ 0
Annual Operation and Maintenance Cost: $ 11,000
Total Present Worth: $122,000
Est-iaated Implementation Time: 2 Months
The No Action Alternative provides a baseline against which to
compare other alternatives. This alternative would not contain
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or recover the contaminated ground-water plume. Long-term
monitoring of ground-water contaminants would be conducted by
analysis of samples from existing monitoring wells. The Great
Egg Harbor River would also be sampled to determine current and
future levels of contamination in the river. Natural flushing
would not significantly reduce potential health risks. Health
risks would persist due to the continuing migration of the
contaminated ground water in the aquifer and discharge of
contaminants to the Great Egg Harbor River system. Additionally,
adverse impacts to the ecosystems of the Great Egg Harbor River
would continue.
ALTERNATIVE GW-2: LIMITED ACTION
Capital Cost: $ 0
Annual Operation and Maintenance Cost: $ 11,000
Total Present Worth: $122,000
Estimated Implementation Time: 6 Months
This alternative is the same as GW-l with the addition of
institutional controls such as deed and/or zoning restrictions to
prevent use of contaminated ground water at the site.
ALTERNATIVE GW-3: GROUND WATER PUMPING, TREATMENT AND
REINJECTION
Capital Cost: $2,043,000
Annual Operation and Maintenance Cost: $ 285,000
Total Present Worth: $6,431,000
Estimated Implementation Time: 30 Years
This alternative involves pumping ground water at an estimated
240 gallons per ninute from extraction wells southwest and
downgradient from the site to capture the contaminant plume
(Figure 3) currently discharging to the Great Egg Harbor River.
The ground water would be extracted and treated to drinking water
standards and subsequently reinjected into the aquifer at an
estimated rate of 240 gallons per minute, until contaminants in
the aquifer meet drinking water standards (Table 16). Extraction
and reinjection rates would be modified during the remedial
design to optimize the system. Institutional controls would be
imposed until ground-water contaminants fall below ARARs.
As part of the remedial design effort, additional monitoring
wells would be required to obtain data to define the vertical
extent of contamination more precisely. Based on this
information, the ground-water pumping, treatment and reinjection
design would be modified since the present design only considers
contarr-ir.atirv-! of the upper aquifer.
Initial sampling after installation of the extraction, treatment
and reinjection system would be quarterly for ground-water
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monitoring wells, and monthly for the treatment plant e'ffluent.
This may later be modified pending analysis of data and
determination of aquifer response to the remedial action.
ALTERNATIVE GW-4: GROUND WATER PUMPING, TREATMENT AND DISCHARGE
TO THE GREAT EGG HARBOR RIVER
Capital Cost:• $2,766,000
Annual Operation and Maintenance Cost: $ 406,000
Total Present Worth: $9,016,000
Estimated Implementation Time: 30 Years
This alternative involves pumping ground water at an estimated
460 gallons per minute from extraction wells southwest and
downgradient from the site to capture the contaminant plume
(Figure 3) currently discharging to the Great Egg Harbor River.
The ground water would be extracted and treated to drinking water
standards and subsequently discharged to the Great Egg Harbor
River until contaminants in the aquifer fall below ARARs (Table
16). This would require a waiver of Pinelands regulations that
restrict surface water discharge. The cost estimate for this
alternative was based on treating the contaminated ground water
to drinking water standards. This cost estimate may increase if
the discharge limitations for the river were determined to be
more stringent than drinking water standards.
As part of the remedial design effort, additional monitoring
wells would be required to obtain data to define the vertical
extent of contamination more precisely. Based on this
information, the ground-water pumping, treatment and discharge
system would be modified, since the present design only considers
contamination of the upper aquifer.
Initial sampling after installation of the extraction, treatment
and surface discharge system would be quarterly for ground-water
monitoring wells, -ird monthly for the treatment plant effluent.
This may be subsequently nodified pending analysis of data and
determination of aquifer response to the remedial action.
Component 5 - Great Ecrcr Harbor River
The river would be monitored before and during implementation of
the extraction/treatment system for ground-water remediation.
The objective of Component 5 is to assure that contamination from
this site is not causing the river to exceed federal and state
ARARs. Remedial alternatives for the Great Egg Harbor River
surface waters and sediments were not developed, because the
contamination in the river has not been completely characterized
and contaminant loading to the river would be reduced once the
flow of contaminated ground water is controlled by implementation
•of ?. ground-vats^- extrac±ion/treatment system.
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Data collected during the remedial design should provide a basis
for determination whether remediation of the Great Egg Harbor
River surface waters and/or sediments would be necessary or if
additional treatment of the ground water is required. Surface-
water and sediment monitoring would also be conducted during the
operation of the ground-water extraction/treatment system. If
remediation of "the river sediments or surface waters were
required, a focused feasibility study would be conducted to
evaluate remedial alternatives.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Contingency Plan, a detailed
analysis of each remedial alternative is conducted with respect
to each of the nine detailed evaluation criteria. All selected
remedies must at least attain the Threshold criteria. The
selected remedy should provide the best trade-offs among the
Primary Balancing Criteria. The Modifying Criteria were
evaluated following the public comment period.
Threshold Criteria
- Overall Protectiveness of Human Health and the Environment -
This criterion evaluates the adequacy of protection that the
remedy provides while describing how risks are eliminated,
reduced or controlled through treatment, engineering
controls, and/or institutional controls.
- Compliance with Applicable or Relevant and Appropriate
Requirements fARARs) - This criterion addresses whether a
remedy would meet all of the ARARs of other federal and
state environmental statutes and/or provide grounds for
invoking a waiver.
There are several types of ARARs: action-specific,
chemical-specific and location-specific. Action-specific
ARARs are technology or activity-specific requirements or
limitations related to various activities. Chemical-
specific ARARs are usually numerical values which establish
the amount or concentrations of a chemical that nay be in,
or discharged to, the ambient environment. Location-
specific requirements are restrictions placed on the
concentrations of hazardous substances or the conduct of
activities solely because they occur in a special location.
Primary Balancing Criteria
- Reduction of Toxicitv. Mobility or Volume Through
Treatment - This criterion addresses the anticipated
treatment performance of the remedy.
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- Short-Term Effectiveness - This criterion refers to the
speed with which the remedy achieves protection, as well as
the remedy's potential to create adverse impacts on human
health and the environment during the remedial action.
- Long-Term Effectiveness and Permanence - This criterion
evaluates the magnitude of residual risk and the ability of
the remedy to maintain reliable protection of human health
and the environment over time once the remedial action has
been completed.
- Implementabilitv - This criterion examines the technical and
administrative feasibility of executing a remedy, including
the availability of materials and services needed to
implement the chosen solution.
- Cost - This criterion includes the capital and operation and
maintenance costs of the remedy.
Modifying Criteria
- State Acceptance - This criterion indicates whether, based
on its review of the Feasibility Study and Proposed Plan,
the State of New Jersey concurs with, opposes, or has no
comment on the preferred alternative.
- Community Acceptance - This criterion evaluates the reaction
of the public to the remedial alternatives and EPA's
Proposed Plan. Comments received during the public comment
period and EPA's responses to those comments are summarized
in the Responsiveness Summary attached to this document.
Overall Protection ef Human Health and the Environment
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
Complete Removal with Off-Site Disposal (Alternative S-6) and
Soil Extraction (Alternative S-4) would provide the greatest
protection to human health and the environment by removing
contaminants present in concentrations determined to present an
unacceptable health risk (Table 17). Stabilization and
Solidification (Alternatives S-5 and S-5a) would render
contaminants in the soil insoluble and immobile, thus greatly
reducing leachate generation; capping, included with these
alternatives, would further reduce leaching and migration to the
ground water in addition to minimizing direct contact with
contaminated soil. Consolidation and Capping (Alternative S-3)
would reduce public health risks by minimizing direct contact
with the contaminated soil and prevent adverse impacts to the
environment by reducing leaching and subsequent migration of the
contaminants. However, if the capping system fails, the threat
to human health and the environment would be present. • The
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Limited Action (S-2) and No Action (S-l) Alternatives would
provide minimal protection to human health and the environment.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
Drum Removal and Off-Site Disposal (Alternative DR-2) would
remove contaminants from the site that currently present an
unacceptable risk to human health and the environment.
Additional sampling and analysis (included in Alternative DR-2)
would determine if further remediation would be required. The No
Action (DR-1) Alternative would provide minimal protection to
human health and the environment. Contaminants would continue to
migrate to the ground water and the potential for human exposure
to hazardous materials would remain.
COMPONENT THREE - TANKERS AND CONTENTS
Removal and Off-Site Disposal (Alternative TK-2) would remove
contaminants from the site that currently present an unacceptable
risk to human health and the environment. The No Action (TK-1)
Alternative would provide inadequate protection to human health
and the environment. Contaminants would continue to migrate to
the ground water and potential for human exposure to hazardous
materials would remain.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Ground-water extraction/treatment alternatives (GW-3 and GW-4)
would protect public health and the environment because they
would provide for the removal of contaminants from the ground
water to meet the required cleanup levels (drinking water
standards) in the aquifer (Table 16). Contaminant discharge to
the Great Egg Harbor River wculo be controlled and cor.tair.inants
presently ir. surface waters and sediments would be reduced by
natural river processes. A characterization of the river waters
and sediment quality, including a biologic assessment of
organisms inhabiting the river, would more completely determine
current levels of contamination, and determine if additional
remediation would be required.
The Limited Action (GW-2) Alternative would prevent the use of
contaminated ground water at the site, provide limited
protection for human health but would not restore the aquifer.
No protection would be provided to the environment as the upper
aquifer would continue to discharge to the Great Egg Harbor
River.
The No Action 'Gr.'-l) Alternate'-c -.j]d provide no protection to
the environment as contaminated ground water in the uppe.r aquifer
would continue to discharge to the Great Egg Harbor River. Human
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health would also not be protected since future residents would
potentially utilize contaminated ground water.
Compliance with ARARs
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
Extraction (Alternative S-4), Stabilization and Solidification
(Alternatives S-5 and S-5a), and Removal and Off-Site Disposal
(Alternative S-6) could be designed to meet all federal and state
ARARs. Consolidation and Capping (Alternative S-3), Limited
Action (Alternative S-2), and No Action (Alternative S-l) would
not aeet all Federal and State ARARs because untreated hazardous
materials would remain at the site.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS and
COMPONENT THREE - TANKERS AND CONTENTS
Removal and Off-Site Disposal of buried drums and tankers
(Alternatives DR-2 and TK-2) would be designed to meet all
federal and state ARARs. The No Action Alternatives (DR-1 and
TK-1) would not meet all federal and state ARARs.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Extraction, Treatment and Reinjection (Alternative GW-3) would
meet all federal and state ARARs.
The Pinelands surface water discharge restrictions (N.J.A.C.
7:50-7.83 and 7:50-6.84) would not allow surface water discharge
(Alternative GW-4) of treated ground water.
If long-term monitoring were executed and ground-water use were
restricted, the Limited Action (GW-2) and No Action (GW-l)
Alternatives would meet action-specific ARARs, but would not meet
contaminant-specific or location-specific ARARs.
Reduction cf Toxicity, Mobility, or Volume through Treatment
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
Excavation and Extraction (Alternative S-4) and Disposal and Off-
Site Removal (Alternative S-6) would reduce the toxicity,
mobility and volume of contaminants.
Stabilization and Solidification (S-5 and S-5a) Alternatives
would significantly reduce toxicity and mobility but would not
reduce the volume of contaminants at the site.
The Consolidation and Capping (S-3) Alternative would provide no
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reduction in toxicity or volume, but would achieve reductions in
mobility by minimizing infiltration of water through contaminated
media. The Limited Action (S-2) and No Action (S-l) Alternatives
would provide no reduction of the mobility, toxicity or volume of
the contaminants in the soil.
COMPONENT TWO- - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
Removal and Off-Site Disposal (Alternative DR-2) would reduce
toxicity, mobility and volume. Further evaluation of the soils
would determine what additional remediation would be required.
The No Action (DR-1) Alternative would offer no reduction in
toxicity, mobility or volume of contaminants in the drums or the
soils. Deteriorating drums would result in increased levels of
contamination being released into soils and the ground water.
COMPONENT THREE - TANKERS AND CONTENTS
Removal and Off-Site Disposal (Alternative TK-2) would reduce
toxicity, mobility and volume.
The No Action Alternative (TK-1) would offer no reduction in
toxicity, mobility or volume of contaminants in the tankers.
Deterioration of the tankers would result in increased levels of
contamination being released into soils and the ground water.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Ground-water extraction/treatment alternatives (GW-3 and GW-4)
would reduce toxicity, mobility and volume. Furthermore, the
discharge of contaminants to the Great Egg Harbor River would be
eliminated.
The Limited Action (GW-2) and No Action (GW-l) Alternatives would
not utilize'treatment to reduce toxicity, nobility or the volume
of contamination.
Short-Term Effectiveness
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
The No Action (S-l) and Limited Action (S-2) Alternatives would
take two months and six months, respectively, to implement and
would present no short-term risks to workers or the community;
these alternatives, however, would provide minimal protection.
Consriidatir- -v -i Capping (Alternative S-2) would achieve linited
protection against contaminants of concern within 6 months and
present minimal short-term risks to workers during remedial
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action through direct contact pathways and the normal hazards
associated with construction activities. These hazards would be
addressed in a health and safety plan which would be developed
for the construction activities. The plan would specify measures
to minimize such hazards.
Stabilization and Solidification that would mix/stabilize/cement
contaminated materials in situ (Alternative S-5) would require
excavation and consolidation of a limited volume of materials and
would also require 18 months to complete. Short-term risk to
human health would be minimized through implementation of the
health and safety plan.
Stabilization and Solidification involving above ground
mixing/stabilizing processes (Alternative S-5a) and Excavation
and Extraction by soil washing (Alternative S-4) would require 18
months to achieve full protection. These alternatives would
involve excavation and treatment of contaminated materials and
would increase the short-term risk to human health due to
increased direct contact pathways and construction hazards during
excavation activities. These hazards would be minimized through
implementation of the health and safety plan.
Removal and Off-Site Disposal (Alternative S-6) would pose short-
term risk of exposure to the community and workers during the
transport of the soil to an off-site facility for treatment and
disposal. These hazards would be minimized through
implementation of a health and safety plan.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The No Action (DR-1) Alternative would take approximately two
months to implement and would present a short-term hazard to
workers at the site (implementing remedies for other components)
or trespassers exposed to drum contents if a buried drum were to
surface.
Removal and Off-Site Disposal (Alternative DR-2) would pose a
short-term risk of exposure to the community and workers during
transport of the drums to an off-site facility for treatment and
disposal. These hazards would be minimized through
implementation of a health and safety plan.
COMPONENT THREE - TANKERS AND CONTENTS
The No Action (TK-1) Alternative would present no short-term
risks to on-site workers or the community. However, it would
provide little or no protection to human health and the
ervironrent.
Removal and Off-Site Disposal (Alternative TK-2) would-pose a
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short-term risk of exposure to the community and workers during
transport of the tankers to an off-site facility for treatment
and disposal. These hazards would be minimized through
implementation of a health and safety plan.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Limited Action (GW-2) and No Action (GW-1) Alternatives would
take about six months and two months, respectively, to implement
and present no short-term risks to on-site workers or the
community. However, these alternatives would provide little or
no protection to human health and the environment.
Ground-water extraction/treatment Alternatives (GW-3 and GW-4)
would present minimal short-term risks to workers through direct
contact pathways and contaminated water resulting from piping
leaks, and normal construction hazards during remedial action.
These alternatives would also present a small additional risk due
to emissions from the air stripper which would be minimized by
installation of a system to capture air emissions. Each of these
ground-water extraction/treatment alternatives would take 15 to
30 years or longer to achieve aquifer restoration. This time
estimate is based on remediating contaminated soils and removing
buried drums and tankers at the site.
Long-Term Effectiveness and Permanence
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
Excavation and Off-Site Disposal (Alternative S-6) and Excavation
and Extraction (Alternative S-4) would be effective in
permanently reducing risks to recreational users and any future
inhabitants of the site to acceptable levels. These alternatives
would permanently remove contamination, completely restore the
site and allow for future unrestricted use. Stabilization and
Solidification (S-5 and S-5a) would not be as effective or as
permanent as Alternative S-4, and would require institutional
controls, maintenance of the capping system and continued
monitoring of the ground water. Consolidation and Capping
(Alternative S-3) would reduce migration of contaminants into the
ground water, but if the cap were to fail or during periods of
high seasonal ground water (estimated to occur every two to three
years), contamination would come into contact with ground water
and migration could occur. It would also require long-term
monitoring, is not as permanent, and does not satisfy preference
for treatment. Consolidation and Capping would require a long-
-.crr. Transparent program, tc detect migration of contain irwXv:: into
the ground water and determine whether the ground water.had
contacted contamination materials. The Limited Action (S-2) and
No Action (S-l) Alternatives would not remediate contaminated
media and a significant risk associated with contaminant
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migration into the ground water would remain.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
Removal and Off-Site Disposal of Drums (Alternative DR-2) would
be effective and permanent in removing risks to recreational
users and future inhabitants of the site. Alternative DR-2 would
provide for characterization of soils and would provide the basis
to determine if additional action would be required. The No
Action (DR-1) Alternative would not remediate contaminated media
and risks to human health and the environment would persist.
COMPONENT THREE - TANKERS AND CONTENTS
Removal and Off-Site Disposal (Alternative TK-2) would be
effective in permanently removing risks to any recreational users
and future inhabitants of the site. The No Action (TK-1)
Alternative would not remediate contaminated media and risks to
human health and the environment would persist.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Ground-water extraction/treatment (GW-3 and GW-4) Alternatives
would present no long-term threat to public health because these
alternatives clean up the aquifer to contaminant levels which
would be health protective. These alternatives would utilize
proven technologies (e.g., extraction wells, air stripping,
chemical precipitation, injection wells) which have been used
frequently for treatment of industrial and hazardous waste.
These alternatives (GW-3 and GW-4) are reliable and would present
no major operational problems assuming proper maintenance.
The Limited Action (GW-2) and No Action (GW-1) Alternatives would
present a long-term risk to public health and the environment
because contaminated ground water would not be cleaned to health
based levels and would continue to discharge to the Great Egg
Harbor River. Since the discharge of ground-water contaminants
from the aquifer into the river would increase with time,
contaminant concentrations in the sediments and surface waters in
the river would also be expected to increase.
Implementability
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
The No Action (S-l) and Limited Action (S-2) Alternatives would
be the easiest soil alternatives to implement. The required
services erd naterials would be readily obtained and no special
equipment would be needed. Consolidation and Capping
contaminated materials (Alternative S-3) would be readily
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implementable and would use standard road construction equipment
with a limited amount of specialized equipment for installation
of the cap. Stabilization and Solidification Alternatives (S-5
and S-5a) would require specialized equipment, materials and
labor which would be readily available. Treatability studies
would be required to select the optimum reagent mixture and
processing techniques. Specialized equipment, materials and
labor required for Contaminant Extraction (Alternative S-4) would
also be readily available. Treatability studies would be
required to determine the optimum extraction agents. Materials,
equipment and labor to implement on-site activities for Removal
and Off-Site Disposal (Alternative S-6) of contaminated materials
would be readily available. However, the availability of off-
site disposal facilities is uncertain and Land Disposal
Restrictions would prevent implementation of this alternative
without first treating the material.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The No Action Alternative (DR-1) would be the easiest to
implement. Material, labor, equipment and services needed for
Drum Removal and Off-Site Disposal (Alternative DR-2) would be
readily available.
COMPONENT THREE - TANKERS AND CONTENTS
The No Action Alternative (TK-1) would be easiest to implement.
Materials, labor, services and for Removal and Off-Site Treatment
and Disposal (Alternative TK-2) would be readily available.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
The No Actirn (3W-1) and Limited Action (GW-2) Alternatives would
be easiest to implement but would not provide adequate protection
of human health and the environment. Ground-water
extraction/treatment alternatives (GW-3 and GW-4) would begin in
relatively short periods of time. The proposed treatment
technologies and equipment required for Alternatives GW-3 and GW-
4 would be available as prefabricated packages from a number of
vendors. These packages would be installed as part of an on-
site treatment plant.
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
The No Action (S-l) and Limited Action (S-2) Alternatives would
not provide adequate protection for a present worth of $79,000
and $144,000. rescertively. Consolidation and Capping
(Alternative S-3) V.'is a present worth of $1,740,000 and would
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achieve only limited protection against contaminants of concern.
Stabilization and Solidification utilizing in-situ and above-
ground treatment processes (Alternatives S-5 and S-5a) have
present worths of $3,336,000 and $5,555,000, respectively; these
alternatives would minimize human health risk but would not fully
restore the site for unrestricted use. Moreover, these
alternatives would not reduce toxicity or volume of the
contaminants. Excavation and Contaminant Extraction
(Alternative S-4) with a present worth of $8,050,000 would
achieve long-term protection of human health, comply with ARARs
and restore the site for unrestricted use in a cost-effective
manner. Removal and Off-Site Disposal (Alternative S-6) would
also achieve long-term protection of human health and fully
restore the site and would be the most costly alternative with a
present worth of $11,500,000.
Costs for all alternatives are presented in Table ISA. This
table includes Capital, Annual Operation and Maintenance Costs
and Total Costs which is expressed as present worth.
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The No Action (DR-1) Alternative would be the least costly to
implement with a cost of $79,000 but would not provide adequate
protection. Removal and Disposal (Alternative DR-2) would be
protective, permanent and complete, and has a cost of $386,000.
Costs for alternatives considered for this component are included
in Table 18B.
COMPONENT THREE - TANKERS AND CONTENTS
The No Action (TK-1) Alternative has no cost and would not
provide adequate protection. Removal and Disposal (Alternative
TK-2) has a relatively low cost of $22,000 and would be
protective, permanent and complete.
Costs for the alternatives considered for this component are
included in Table 18C.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
Cost for remediation of ground water and the Great Egg Harbor
River's sediments and surface waters are included in the ground
viter (GW; alternatives. Although the No Action (GW-1) and
Limited Action (GW-2) Alternatives would be the least costly to
implement with both having a present worth of $122,000, both
actions would be inadequate to protect human health and the
environment. Ground-water extraction/treatment alternatives (GW-
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3 and GW-4) have present worths of $6,431,00 and $9,016,000 and
would be protective of human health and the environment, and
would achieve ARARs in a cost-effective manner.
Costs for the alternatives considered for this component are
included in Table 18D.
State Acceptance
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
The New Jersey Department of Environmental Protection (NJDEP)
concurs with Contaminant Extraction of metals-contaminated media
(Alternative S-4).
COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The NJDEP concurs with drum removal and the conduct of additional
soil sampling and analysis of the nearby soils (Alternative DR-
2).
COMPONENT THREE - TANKERS AND CONTENTS
The NJDEP concurs with removal and disposal of tankers
(Alternative TK-2).
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
The NJDEP, while concurring with Alternative GW-3 for ground-
water remediation, has raised concerns regarding the impact of
the GW2 discharge ARARs upon the FW1 stream standards for the
Great Egg Harbor River.
EPA acknowledges this concern, and will evaluate the need for
further action as part of conitoring efforts which will be
conducted during design and implementation of the remedy.
The Pinelands Commission has provided comments that have been
addressed in the attached Responsiveness Summary.
Community Acceptance
COMPONENT ONE - METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
The community supports Contaminant Extraction (Alternative S-4)
and Removal and Off-Site Disposal (Alternative S-6) since these
actions would remove contaminants and restore the cite for
unrestricted use. The other alternatives (S-l, S-2, S-3, S-5,
S-5a) are not supported by the community since they do not remove
carterin?rts nor restore the site for unrestricted use.
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COMPONENT TWO - BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The community supports Removal and Off-Site Disposal (Alternative
DR-2) of the drums. The No Action (DR-1) Alternative would not
be supported by the community, since it would not remove the
drums from the site.
COMPONENT THREE - TANKERS AND CONTENTS
The community supports Removal and Off-Site Disposal (Alternative
TK-2), since this would remove the tankers from the site. The No
Action Alternative (TK-1) would not be supported by the
community.
COMPONENT FOUR - GROUND WATER and
COMPONENT FIVE - THE GREAT EGG HARBOR RIVER
The community supports ground-water extraction/treatment
(Alternatives GW-3 and GW-4) which would restore the ground water
to drinking water standards and control contaminant discharge to
the Great Egg Harbor River.
The No Action (GW-1) and Limited Action (GW-2) Alternatives would
not receive community support since the ground water would not be
restored to drinking water standards and contaminants from the
aquifer would continue to discharge to the river.
SELECTED REMEDY
EPA has evaluated the remedial alternatives in accordance with
Section 121 of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 ("CERCLA"), as amended ,
42 U.S.C. Section 9621 and Section 300.432 of the National
Contingency Plan ("NCP"), and has selected a remedial action for
the site based on the findings of the RI/FS and SFS and input by
the public. The components of the remedial action are as
follows:
• 6-4, Complete Excavation, Contaminant Extraction,
and Replacement On-Site;
• DR-2, Drum Removal and Off-Site Disposal and
Sampling and Analysis of Soil*;
• TK-2, Tanker Removal and Off-Site Disposal; and
GW-2. Ground Water Pumping, Treatment and
Reinj£-clt;n. (GVv-3 includes sampling and .
analysis of sediments, surface waters and an
assessment of biota of the Great Egg Harbor River.)
The costs associated with these remedial alternatives are
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presented in Table 19. A summary of the selected alternatives
follows.
ALTERNATIVE S-4: COMPLETE EXCAVATION; CONTAMINANT
EXTRACTION; REPLACEMENT ON SITE
This consists of excavation of metals-contaminated soils that
exceed the cleanup objectives (Table 17) in the area adjacent to
the lagoons, sediments in the swale and sludges in the lagoons.
Extraction of metals contaminants from the 20,150 cubic yards of
excavated materials will be performed in a multi-stage batch
process until the soil cleanup objectives (Table 17) are met.
Treatability studies will be required to determine optimum
extraction agents and system design parameters. Treated
materials will then be redeposited in their original locations to
restore site topography, followed by revegetation with native
Pinelands species.
During the initial phases of the remedial design, additional
sampling of on-site soils, sludges, and sediments in the swale,
including the lower swale between the fire road and the river,
will be conducted to ensure that all soils requiring remediation
are identified. Sampling and analysis will also include
sediments and surface waters in a depression approximately 50
feet across and 10 feet deep adjacent to the fire road,
approximately 200 feet northwest of the swale.
Soil cleanup objectives (Table 17) developed during the FS were
based on risk to human health. Although these standards are not
considered ARARs, cleanup to these standards will ensure that
contaminants do not continue to migrate into the ground water and
human health risks are reduced to a protective Hazard Index of
less than one. This remedial action component, in combination
with the other remedial action components, will allow full
restoration of tne site conditions, including re-establishment of
an indigenous ecosystem.
The alternative requires specialized equipment, materials and
labor but these are readily available and are easily implemented.
Contingency plans will be developed during implementation of the
remedial action component, to address any short-term problems,
i.e., protective equipment for workers, plastic covers for
temporary material storage, and water/surfactant sprays.
The selected remedy has an estimated implementation cost of
$8,050,000. This includes construction and operation of the
contaminant extraction system.
ALTERNATIVE TF-2: DRUM REf!3VAL ANT-I> OFF-SITE DISPOSAL; SAMPLING
AND ANALYSIS OF SOILS
This consists of removal and off-site treatment and disposal of
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the buried drums and visibly contaminated soils1 followed by
sampling and post-removal analysis of residually contaminated
soils to define types and concentrations of residual
contaminants.^ This will provide an additional characterization
of soils contamination and volumes. These soils will be
addressed as a separate operable unit and a focused feasibility
study will be conducted to evaluate remedial alternatives.
Implementation of this remedial alternative component would
utilize standard construction industry equipment and practices,
and would not rely on new, untested technologies or procedures.
The cost associated with this component is estimated at $386,000.
ALTERNATIVE TK-2: TANKER REMOVAL AND OFF-SITE DISPOSAL
This involves removing the two tankers and their contents for
off-site treatment and disposal. Implementation of this remedial
alternative would utilize standard construction industry
equipment and practices and would not rely on new untested
technologies or procedures. The cost associated with this
component is estimated to be $22,000.
ALTERNATIVE GW-3: GROUND WATER PUMPING, TREATMENT AND
REINJECTION
This involves pumping the contaminated ground water from the
upper aquifer, treating it to drinking water standards (Table 16)
and reinjecting it into the aquifer. The process will continue
until drinking water standards are achieved in the aquifer.
Implementation of this alternative will require the construction
of a treatment plant and installation of pumping wells and
piping. The locations of the pumping wells, pumping rates for
extraction and reinjection wells, and the configuration of the
treatment plant will be developed during the design phase. Waste
streams produced by the ground-water treatment system will be
treated and/or disposed off site. Treatment and/or disposal
would comply with all ARARs.
Prior to design of this alternative, additional monitoring wells
will be installed, sampled and analyzed to provide data to define
the concentrations, types and extent of contamination in the
intermediate and deep aquifers. Based on this information, the
extraction/treatment/reinjection ground-water alternative (GW-3)
will be modified to include contaminated ground water in the
deeper aquifer. The design presently assumes that only the upper
aquifer will be remediated.
Mcnirorir.y veils will be sampled end analyzed after installation
of the treatment and pumping system to determine hydrologic
' Visibly contaminated soils constitute those soils that are
grossly contaminated and are adjacent to the drums.
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effects, ground-water movement and contaminant concentrations.
Initial sampling and analysis will be on a quarterly basis for
ground-water monitoring wells, and monthly for treatment plant
effluent. This may be modified after analysis of monitoring well
data and a determination of the aquifer response to the remedial
action. Sampling and analysis of monitoring wells will continue
after cleanup objectives are achieved to assure that aquifer
remediation is permanent and complete.
The goal of this remedial action is to restore ground water to
beneficial use as a drinking water aquifer, and to meet all state
and federal ARARs in the Great Egg Harbor River due to discharge
of contaminants in the ground water. Based on information
obtained during the remedial investigation and on a careful
analysis of all remedial alternatives, EPA believes that the
selected remedy will achieve this goal. However, studies suggest
that ground water extraction and treatment are not always
completely successful in reducing contaminants to health-based
drinking water standards in the aquifer (Table 16). EPA
recognizes that operation of the selected extraction and
treatment system may indicate the technical impracticability of
reaching health-based ground water quality standards using this
approach. If it becomes apparent during implementation or
operation of the system, that contaminant levels have ceased to
decline and are remaining constant at levels higher than the
remediation goal, the goal and the remedy may be reevaluated.
The selected remedy assumes operation of the ground-water
extraction for a period of 30 years, during which the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. Modifications may include:
a) discontinuing operation of extraction wells in areas where
cleanup goals have been attained;
b) alternating pumping at wells to eliminate stagnation
points; and
c) pulse pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into ground water.
The treatment system will control contaminant discharge to the
Great Egg Harbor River. Any modifications to the ground-water
extraction/treatment system will consider impacts to the Great
Egg Harbor River.
As pa.Tt of Alternative GW-3, additional sampling and analysis of
the Great Egg Harbor River will be conducted to provide a basis
for determining whether remediation of the river is required.
During the remedial design, sampling and analysis will further
determine bioavailability and concentration and distribution of
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contaminants in the river sediments.
Surface-water and sediment sampling and analysis will continue
during the operation of the ground-water pumping and treatment
system to ensure that the Great Egg Harbor River meets all state
and federal ARARs. If monitoring data indicate that.remediation
of the river sediments or surface waters is required, the river
will be designated as a separate operable unit and a focused
feasibility study will be conducted to evaluate remedial
alternatives. The feasibility study will consider appropriate
alternatives to remediate and/or prevent impacts to the river,
including additional treatment of the ground water.
This selected remedial component for ground-water remediation and
river monitoring has an estimated total present worth of
$6,431,000. The remedy will cost approximately $2,043,000 to
construct. The estimated annual operation and maintenance cost
is $285,000.
ADDITIONAL ACTIVITIES
Additional activities which will be performed as part of the
remedial action include, but are not limited to the following:
• During the remedial design, a wetlands characterization
(delineation/assessment) will be conducted for the upper
reaches of the swale (between the fire road and the site) to
identify impacts of remedial activities to wetlands and
procedures to reduce any impacts. If additional sampling
indicates the lower portion of the swale requires
remediation, the wetland characterization will also include
the lower portion of the swale. This delineation and
assessment will include, but not necessarily be limited to,
a description of soils and vegetation, and a map delineating
the areas of concern.
• A habitat restoration plan will be prepared.
• During the remedial design, a cultural resource survey
(Stage IB archeological investigation) will be completed
which will include any previously undisturbed portion of the
project area that will be affected by remedial activities.
• Following completion of the remedial actions, the areas
affected will be recontoured, restored and revegetated to
their original conditions.
STATUTORY DETERMINATIONS
The EPA has been explicitly directed by Congress in Section 121
(b) of CERCLA to select remedial actions which utilize permanent
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solutions and alternative treatment technologies or resource
recovery options to the maximum extent practicable. In addition,
the Agency is to prefer remedial actions that permanently and
significantly reduce the mobility, toxicity or volume of site
wastes.
Protection of Human Health and the Environment
The selected site remedy protects human health and the
environment by dealing effectively with the principle threats
posed by the King of Prussia Technical Corporation site. These
principle threats involve ingestion of contaminants found in the
soils and ground water. The selected alternative addresses these
contaminant pathways by capturing and treating the contaminated
plume, removing and treating contaminated soils, and removing
buried drums and tankers at the site. The primary contaminants
of concern in the ground water and soils identified in the RI
report are the indicator compounds discussed in the summary of
site risks in this document. Exposure levels for these and other
contaminants will be reduced so human health risk will be less
than 10"6 for carcinogens and to a hazard index of less than one
for noncarcinogens. This remedial action is permanent and
provides for complete restoration of the site which will allow
for future unrestricted use.
id Appropriate
Action-Specific
Metals-contaminated soils, sediments and sludges on site and in
the swale are RCRA characteristic wastes which will be rendered
noncharacteristic by treatment. Residual materials (e.g.,
sludges) from the ground-water treatment system and soil-
extraction processes will be treated and/or disposed in a manner
consistent with applicable RCRA Land Ban Restrictions.
The reinjection process for the treated ground water will meet
underground injection well regulations by its status as a
Superfund remedial action. Ground-water extraction/treatment/
reinjection will continue until drinking water standards are
achieved in the aquifer.
Buried drums and tankers at the site, will be also be disposed
off site consistent with applicable RCRA Land Ban Restrictions.
PCRA federal air regulations which are considered applicable
requirements, i/?_ud3 40 CFR Parts 2?4-301(i) and 264.273(f);
applicable state requirements include NJAC 7:26 Parts 10.8(d) and
10.6(e).
Under the Clean Air Act, the National Ambient Air Quality
-------
39
Standards (as contained in 40 CFR Parts 50.6 and 50.9) are
considered applicable federal requirements for limiting the
concentration of ozone and particulate matter which may be
emitted from the air stripping unit, the water precipitation
process, soil extraction processes and other removal or
construction activities in the selected remedial actions. The
Ambient Air Quality Standards (NJAC 7:27 Parts 5 and 13) are
considered applicable state requirements. Relevant and
appropriate state requirements include the emission standards
provided in NJAC 7:27-6 (Control and Prohibition of Particulate
from Manufacturing), the substantive requirements for the
operation of air pollution equipment under NJAC 7:27-8.5(b)
(Permits and Certificates), NJAC 7:27 Parts 16.6 and 17.4 and the
proposed federal regulation 52 FR 3748.
Contaminant-Specific
To date, there are no promulgated federal or state standards for
cleanup of contaminated soils. Therefore, in lieu of ARARs, "To-
Be-Considers" (TBCs) for contaminated soils were developed during
the FS. These values are based on protection of human health and
protection of ground water and are presented in Table 17. These
are the cleanup goals for contaminated soils, sediments and
sludges at the site, and will provide for unrestricted future use
of the site.
The ARARs determined for the ground-water remediation were
developed for this site consistent with the New Jersey Water
Pollution Control Act (NJPDES 58:10A and 7:14A) and the MCLs
under the Federal Safe Drinking Water Act (Table 16). The
selected alternative, GW-3, is anticipated to achieve these
concentrations by the end of the remedial action. After
completing the implementation of Alternatives S-4, DR-2, and TK-
2, contaminants will not migrate into the ground water.
Location-Specific
In compliance with the Endangered Species Act of 1973 (87 Stat.
884, as amended; 16 U.S.C. 1531 et seq.), a consultation with the
U.S. Fish and Wildlife Service has been carried out to evaluate
the potential for encountering federal endangered or threatened
species in the vicinity of the site. Except for occasional
transient species, no federally listed or proposed or endangered
species are known to exist at the site. It is expected that the
selected remedy will not have any detrimental impact on these
species because of their transient nature in this area. If
additional information indicates a likelihood for the presence of
endangered species, the U.S. Fish and Wildlife Service will be
consulted.
The site is located about 1000 feet from the Great Egg Harbor
River which is proposed as a nationally designated Wild and
-------
40
Scenic River. The selected remedial action will not have an
adverse impact on the river. Sampling and analysis of sediments
and surface waters before and during implementation of the
selected remedial action components will determine impacts to the
river.
The remedial action will comply with the Flood Hazard Area
Control Act of New Jersey. All remedial activities with the
exception of river sampling will be conducted above the 500 year
flood plain.
The swale that directs runoff from the site toward the Great Egg
Harbor River may be a wetland. Therefore, before the remedial
action is implemented, a wetlands assessment will be conducted to
assure compliance with Executive Orders 11988 and 11990 and the
Clean Water Act (Section 404).
The site is located within the Protection Area of the New Jersey
Pinelands National Reserve. Therefore, pursuant to N.J.A.C.
7:50-6.77, storage of toxic waste is prohibited at the site. All
contaminated materials will either be treated or removed.
The site will be in compliance with the Farmland Preservation Act
and National Historic Preservation Act which are ARARs for the
site.
Cost-Effectiveness
After evaluating all of the alternatives which most effectively
address the principal threats posed by the contamination at the
site and the statutory preference for treatment, EPA has
concluded that the selected remedial action components afford the
highest level of overall effectiveness proportional to their
cost. The selected remedial action components are cost-effective
because they provide the highest degree of protectiveness for
human health and the environment among the alternatives
evaluated, while representing a reasonable value for the cost and
will allow for unrestricted use of the site.
Utilization of Permanent Solutions and Alternative Treatment
for Resource Recovery) Technologies to the Maximum Extent
Practicable
The selected remedial action components utilize permanent and
effective solutions and alternative treatment technologies to the
maximum extent practicable and provide the best balance among the
nine evaluation criteria of all of the alternatives examined.
i...; (.,iu-nd-water treatment: alternative will redact the
contaminants of concern to health protective levels.
The soil treatment will assure that any contaminants that remain
-------
41
at the site are in concentrations below levels determined to be a
human health risk either from direct exposure or due to migration
to the ground water.
Removal of other sources of contamination (buried drums and
tankers) will jalso be permanent and effective in removing risks
at the site.
In summary, the selected remedial actions will achieve a complete
restoration of the site for unrestricted use and reduce public
health and environmental risks.
Preference for Treatment as a Principal Element
The statutory preference for treatment is satisfied by the
selected remedy which employs on-site treatment of the ground
water through precipitation processes and air stripping. It also
includes on-site contaminant extraction for contaminated soils
and sediments and removal and off-site treatment and disposal of
buried drums and tankers. These treatment methods effectively
reduce the toxicity, mobility and volume of contaminants.
Documentation of Significant Changes
There are no significant changes from the Proposed Plan.
-------
ROD FIGURES
Figure 1. Site Location and Regional Topographic Map
Figure 2. Areas Considered for Remediation
Figure 3. Area Considered for Remediation-Component Four
-------
•o ••-
WINS;
FIGURE 1
Site Location and Regional Topographic Map
King of Prussia Technical Corporation Site
Winslow Township, New Jersey
Johnson Katthsy
^
Division
Wildlife
Winslov Tovnanip
Landfill
Municipal
Off-Bit* wat«r Supply Walls
' X S
-------
FIGURE 2
Araaa Conaidarad for Raaadiation
King of Pruaaia Technical corporation Bit*
Wiaalov Townahip, Na« Jaraay
Coapoaaat two
•orlafl Onaia aa4 aaila
•Itk Volatile Orvaale Coaponada
eoaeoaaat Tkraa
Taakara and Ceataata
LEGEND
Araaa Coaaldarad (or taaadlatioa
180 0 108 200 300 480 800
-------
DECLARATION STATEMENT
RECORD Or DECISION - OPERABLE CHIT ONE
KINO O? PRUSSIA TECHNICAL CORPORATION SITE
King of Prussia Technical Corporation Site
Kinslow Township, Camden County, New Jersey
Statement of Baaii and Purpose
This decision document presents the selected remedial action for the
King of Prussia Technical Corporation site, in Camden County, New
Jersey, developed 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 document explains the factual and legal basis for
selecting the remedy for this site. This decision is based on the
administrative record for the site. The attached index identifies
the items that comprise the administrative record.
Assessment cf the Bite
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision, nay present an imminent and substantial
threat to public health, welfare or the environment.
Description cf the Selected Remedy
The remedial action described in this document is the first of two
planned operable units for the site. The final remedy for the first
operable unit action addresses groundwater and some soils, sediments
and sludges, and the removal of drums and tankers. The second
operable unit will address contaminated soils associated with the
buried drum area.
The major components of the selected remedy include the following:
• Lagoon sludges, soils adjacent to the lagoons, and sediments
in the swale will be excavated. Metal contaminants will be
extracted from these materials utilizing a multi-phase, soil-
washing process. Cleaned materials will then be redeposited
in approximately their original location.
-------
• Buried drums, their contents and visibly contaminated soils
will be excavated and disposed at an off-site location.
Additional characterization of residually contaminated soils
in the buried drum area-will be conducted. This will provide
the basis for a remedial action decision regarding this soil.
• A ground-water pumping system will be installed to capture the
contaminated ground water and prevent discharge of contaminants
to the Great Egg Harbor River.
• An on-site ground-water treatment facility will be installed
and maintained to remove contaminants from the collected
groundwater.
• A ground-water reinjection system will be installed to reinject
treated ground water into the aquifer.
• Tankers and their contents will be removed for off-site
disposal.
• Additional sampling and analysis of surface waters and
sediments of the Great Egg Harbor River will be performed.
This will allow a determination on whether further remediation
of the river system is required.
Declaration of 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 it satisfies the
statutory preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances remaining
on site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
-^Constantine Sidamon-Eristoff "/ Da/ie 7
Regional Administrator
-------
FIGURE 3
•*»» ,
9MMXX)
LEGEND
Monitoring ••!! vltk Total TOA Cono. (|ig/l|
Ce*pon«Bt Four
Contui0at*d around »t«r in tb« Kqaifcr
King of fraaeia T*atuiieal Corperatioa fit*
•invleW Towaabipf Mm J«r*«y
108 0 100 100 300 400 600
•otot Tfc« teta for •*•!§• wr* ofct«i»o4 o»
alfforoat «•!• thu tfeo otbor «•!! data
-------
ROD TABLES
Table l. Major Contaminants in Surface Soils, Sediments and
Sludges
Table 2. Major Contaminants in Subsurface Soils, Sediments and .
Sludges
Table 3. Major Contaminants in Buried Drums
Table 4. Major Contaminants in Soils in the Buried Drum Area
Table 5. Major Contaminants of Tanker Contents
Table 6. Major Contaminants in the Upper Aquifer
Table 7. Major Contaminants in the Intermediate Aquifer
Table 8. Major Contaminants in the Deep Aquifer
Table 9. Compounds Detected in Surface Waters of the Great Egg
Harbor River
Table 10. Compounds Detected in Sediments of the Great Egg
Harbor River
Table 11. Concentrations of Carcinogenic Indicator Compounds for
All Site Components
Table 12. Concentrations of Noncarcinogenic Indicator Compounds
for All Site Components
Table 13. Cancer Potency Factors (CPFs) and Reference Doses
(RfDs) for Indicator Compounds
Table 14. Cancer Risks for Indicator Compounds
Table 15. Non-Cancer Risks for Indicator Compounds
Table 16. Ground Hater Cleanup Goals
Table 17. Soil Cleanup Goals
Table 18. Cost Summary for all Remedial Alternatives
Table 19. Cost Summary for Selected Remedial Alternatives
-------
TABLE 1
MAJOR-CONTAMINANTS OF
SURFACE SOILS, SLUDGES AND SEDIMENTS (0 TO 2 FEET DEPTH)
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS .
Arsenic
Beryllium
Cadmium
Total Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
* of detects/
# of samples
taken
17/44
41/88
9/54
92/102
86/102
59/88
15/61
69/102
25/31
1/10
53/78
Maximum
concentration
detected
(ppm)
5.7
8.3
2.6
8010
9070
87
100
387
3.5
18
300
Soil
Cleanup
Levels
fDDin)
190
485
107
483
3,571
250-1000
1
1,935
4
5
3,800
NOTE: Concentrations exceeding cleanup levels are in BOLD.
-------
TABLE 2
MAJOR CONTAMINANTS OF
SUBSURFACE SOILS, SEDIMENTS AND SLUDGES (2 TO 10 FEET DEPTH)
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
*
Arsenic
Beryllium
Cadmium
Total Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
# of detects/
I of samples
taken
39/75
26/101
6/43
98/102
84/115
80/107
5/76
27/109
3/24
0/7
49/89
Maximum
concentration
detected
(ppm)
22
361
27
11,300
16,300
389
1.7
11,100
2.9
ND
1,270
Soil
Cleanup
Levels
(upm)
190
485
107
483
3,571
250-1000
1
1,935
4
5
3,800
NOTES: 1) Concentrations exceeding cleanup levels are in BOLD.
2) ND=Not Detected.
-------
TABLE 3
MAJOR CONTAMINANTS OF BURIED DRUM CONTENTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
" CONTAMINANTS
Contaminant
Concentration
(ppm)
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Volatile Oroanics
Ethylbenzene
Tetrachloroethene
Trichloroethene
Toluene
ND
ND
ND
ND
2.9
24.7
1
ND
ND
14
43,000
4,400
7,800
1,100
NOTE: ND=Not Detected.
-------
TABLE 3 (continued)
MAJOR CONTAMINANTS OF BURIED DRUM CONTENTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Contaminant
Concentration
(ppm)
Semi-Volatile Oraanics
1,4-Dichlorobenzene
1,2-Dichlorobenzene
2,4-Dimethylphenol
Phenol
1,2,4-Trichlorobenzene
Total Phenols
99
18,000
21
1,300
72
4,650
TENTATIVELY IDENTIFIED
CONTAMINANTS (TICs)
Volatile Oraanics
2-Butanone
1,4-Dinethylbenzene
1,2-Diroethylbenzene
Semi-Volatile Oroanics
Benzenes
Ethylhexane
4-Ethyl-2-Methylhexane
2-Methylphenol
4-Methylbenzaldehyde
Unknowns (total)
2,250
350,000
250,000
2,056
620
. 280
2,400
150
180,000
-------
TABLE 4
MAJOR CONTAMINANTS OF
SOILS IN THE BURIED DRUM AREA
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Inorganics
Arsenic
Chromium
Copper
Lead
Zinc
Volatile Oraanics
Tetrachloroethene
Trichloroethene
1,1, 2-Trichloroethane
Toluene
Semi-Volatile Orcranics
Bis (2-ethylhexyl)phthalate
1 , 2 -Dichl orobenzene
1,4-Dichlorobenzene
Naphthalene
Phenathrene
Phenol
Pentachlorophenol
1,2, 4-Trichlorobenzene
Concentration
(com)
Location A
9.6
25
18
11J
16
0.55
0.011
0.002J
ND
0.052J
ND
ND
ND
ND
ND
ND
ND
Location B
44
354
697
12J
81
270J
0.019
ND
0.017
0.1J
44
0.3J
3.2
0.41J
0.14J
0.44J
0.48
NOTE: J«E.=1 .'tinted Value, ND=Not Detected.
-------
TABLE 4 (continued)
«AJOR CONTAMINANTS OF
SOILS IN THE BURIED DRUM AREA
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Pestlcldes/PCBs
Chlordane
Dieldrin
4,4' -DDE
4 -4 '-DDT
Toxaphene
Tentatively Identified
Compounds
Dimethyl Benzene Isomer
Unknown Hydrocarbons
ADcyl Substituted Benzenes
Total Unknown
Unknown Fatty Acid
Concentration
form)
Location A
0.192
0.160
ND
0.4
1.4
ND
29.7
ND
ND
ND
Location B
0.470J
0.230J
0.019J
0.13J
5.6J
40J
644J
992J
573J
99 J
NOTE: J=Estimated Value, ND=Not Detected.
-------
TABLE 5
HAJOR CONTAMINANTS OF TANKERS CONTENTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Inorganics
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Zinc
Concentration
(com)
Tanker #1
ND
22
38
ND
6,450
8,940
3
35
6,580
317
Tanker $2
24
ND
38
1.8
1,430
10,080
1.4
30
1,790
ND
NOTE: ND=Not Detected.
-------
TABLE 6
MAJOR GROUND-WATER CONTAMINANTS
IN UPPER AQUIFER
KING OF PRUSSIA TECHNICAL CORPORATION SITE
*
UPPER AQUIFER
CONTAMINANTS
Inorganics
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Zinc
Volatile Orqanics
Benzene
1-1-Dichloroethane
Trans-1 , 2-Dichloroethene
Ethylbenzene
Tetrachl oroethene
1,1,2 , 2-Tetrachloroethane
Trichloroethene
1,1,1-Trichloroethane
Toluene
# detects/
I samples
taken
8/12
2/12
10/12
11/12
0/12
9/12
12/12
1/12
1/12
1/12
1/12
3/12
3/12
5/12
3/12
1/12
Maximum
concent.
detected
(ppb)
233
6.2
1,040
12,500
ND
4,670
2,030
8
64
12
80
2,500
2,900
940
570
190
ARARs
(MCLS)
(PPb)
none
10
50
1000
2
210
5000
1
2
10
50
1
1.4
1
26
none
NOTES: 1) Ground-water data included in this Table are from Phase II
of the RI. Sampling during Phase I of the RI and during the
Ff ?huw similar concentrations to those presented here.
2) Concentrations exceeding cleanup levels are in BOLD.
3) ND=Not detected.
-------
TABLE 7
MAJOR GROUND-WATER CONTAMINANTS
IN INTERMEDIATE AQUIFER
KING OF PRUSSIA TECHNICAL CORPORATION SITE
INTERMEDIATE AQUIFER
CONTAMINANTS
Inorganics
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Zinc
Volatile Orqanics
Benzene
1-1-Dichloroe thane
Trans-1 , 2-Dichloroethene
Ethylbenzene
Tetrachl or oethene
1,1,2, 2-Tetrachloroethane
Trichloroethene
1,1, 1-Trichloroethane
Toluene
# detects/
# samples
taken
2/3
0/3
2/3
2/3
1/3
2/3
1/3
1/3
0/3
0/3
1/3
0/3
0/3
0/3
0/3
0/3
Maximum
concent .
detected
(PPb)
31
ND
26
3,070
0.46
699
627
1
ND
ND
3
ND
ND
ND
ND
ND
ARARs
(MCLs)
(PPb)
none
10
50
1000
2
210
5000
1
2
10
50
1
1.4
1
26
none
NOTES 1) Ground-water data included in this Table are from Phase II of
the RI. Sampling during Phase I of the RI and during the FS
show slaiiar concentrations to those presented here.
2) Concj- ':*-ii:.lon£ exceeding cleanup levels are in BOLD.
3) ND=Not detected.
-------
TABLE 8
MAJOR GROUND-WATER CONTAMINANTS
IN DEEP AQUIFER
KING OF PRUSSIA TECHNICAL CORPORATION SITE
DEEP AQUIFER -
CONTAMINANTS
Inorganics
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Zinc
Volatile Oraanics
Benzene
1-1 -Di chl or oethane
Trans-1 , 2-Dichloroethene
Ethylbenzene
Te t rachl or oethene
1,1,2, 2-Tetrachloroethane
Trichloroethene
1,1, 1-Trichloroethane
Toluene
# detects/
# samples
taken
3/10
0/10
2/10
1/10
0/10
1/10
7/10
0/10
0/10
0/10
0/10
0/5
0/10
1/10
0/10
0/10
Maximum
concent .
detected
(PPb)
1.3
ND
77
8.9
ND
34
89
ND
ND
ND
ND
ND
ND
3
ND
ND
ARARs
(MCLs)
(PPb)
none
10
50
1000
2
210
5000
1
2
10
50
1
1.4
1
26
none
NOTES 1) Ground-water data included in this Table are from Phase II of
the RI. Sampling during Phase I of the RI and during the FS
show p.inilar concentrations to those presented here.
2j Coi <•.:?,-.• at::cr.s exceeding cleanup levels are in BOLD.
3) ND=Not detected.
-------
TABLE 9
COMPOUNDS DETECTED IN SURFACE WATERS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Chromium
Copper
Mercury
Lead
Nickel
Zinc
Great Eqq Harbor River Surface Water Samples
SW-3
uostream
NO
ND
na
na
ND
260
SW-4
ND
ND
na
na
ND
140
SW-5
ND
110
na
na
ND
130
SW-6
ND
50
na
na
ND
110
SW-208
upstream
ND
ND
na
2.8
ND
ND
SW-209
ND
ND
0.32
3.8
ND
ND
SW-210
11
ND
ND
5.1
83
49
SW-211
ND
ND
ND
3.2
ND
54
Ambient
Water
Quality
Standards
11
12
0.12
3.2
96
47
NOTES : 1) ND=not detected
2) na=not analyzed.
3) Concentrations ppb.
-------
TABLE 10
COMPOUNDS DETECTED IN RIVER SEDIMENTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Great Eqo Harbor River Sediment Samples
SD-3
upstream
ND
ND
na
ND
ND
2.4
SD-4
38
220
na
0.4
ND
4.3
SD-5
35
300
na
0.4
ND
1.9
SD-6
40
35
na
0.3
ND
5.5
SD-208
upstream
ND
ND
11
ND
ND
25
SD-209
43
199
49
ND
28
37
SD-210
131
13
3.9
0.5
ND
18
SD-211
9.3
6.8
3.2
ND
ND
ND
SD-212
ND
55
36
ND
16
ND
NOTES: 1) ND=not detected
2) na=not analyzed
3) Concentrations are ppm
-------
TABLE 11
CONCENTRATIONS OF CARCINOGENIC INDICATOR COMPOUNDS
FOR ALL COMPONENTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CARCINOGENIC
INDICATOR
CONTAMINANTS
Inorganics
Leryllium (Bl)
Cadmium (Bl)
Chromium-VI (A)
Lead (B2)
Nickel (A)
Volatile Oroanics
Benzene (A)
1-1-Dichloroethane (C)
Tetrachloroethene (B2)
1,1,2, 2-Tetrachloroethane
• Trichloroethene (B2)
Maximum Contaminant Concentration
Component
One
Soils, etc.
room)
361
27
11,300
389
11,100
ND
ND
ND
(C) ND
ND
Component
Two
Drums/Soil
fppm)
ND/ND
ND/ND
2.9/25
1/11J
ND/ND
ND/ND
ND/ND
4,400/270J
ND/ND
7,800/0.11
Component
Three
Tankers
(pom)
38
1.8
1,430
35
6,580
ND
ND
0.55
ND
0.02
Component
Four .
Ground Water
fDDb)
233
6.2
1,040
ND
4,670
8
64
2,500
2,900
940
Component
Five-River
Seds. /Water
fDDm/DDb)
ND/ND
ND/ND
131/11
ND/5.1
ND/83
ND/ND
ND/ND
ND/ND
ND/ND
ND/ND
NOTES: 1) ND=Not Detected.
2) A-Human Carcinogen, Bl and B2-Probable Human Carcinogen,
C-Possible Human Carcinogen.
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TABLb ^
CONCENTRATIOMS OF NONCARCIMOGEN 1C A...
FOR ALL OPPONENTS
KING OF PRUSSIA TECH»PkL CORPORATION SITE
NONCARCINOGENIC
INDICATOR
CONTAMINANTS
Inorganics
Copper
Mercury
7, inc
Volatile Oroanics
Trans-1 , 2-Dichloroethene
Ethylbenzene
1,1, 1-Trichloroethane
Toluene
Maximum Contaminant Concentration
Component
One
Soils, etc.
(pom)
i
16,300
1.7
1,270
ND
ND
ND
ND
Component
Two
Drums/Soils
(ppm)
24.7/18
ND/ND
14/16
ND/ND
43,000/ND
ND/ND
1,100/ND
Component
Three
Tankers
(com)
8,940
ND
ND
ND
ND
ND
0.02
Component
Four
Ground Water
fDDbl
12,500
ND
2,030
12
80
570
190
Component
Five-River
Seds. /Water
(DDm/ppb)
300/110
0.4/0.32
37/260
ND/ND
ND/ND
ND/ND
ND/ND
NOTE: ND=Not Detected
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TABLE 13
CANCER POTENCY FACTORS AND REFERENCE DOSES
FOR INDICATOR COMPOUNDS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
INDICATOR
COMPOUNDS
Inorganics
Beryl Hum
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Volatile Orqanics
Benzene
1-1-Dichloroethene
Trans-1,2-Dichloroethene
Ethylbenzene
Tetrachloroethene
1,1,2,2-Tetrachloroethane
Trichloroethene
1,1,1-Trichloroethane
Toluene
Carcinogenic Potency
Factor (CPFi
(roq/kq-davr
Inaestion
8.4
6.1
4. 1X10'
1.7
2.9X10"
1.16
3.3x10*
2X10'1
3x10*
Oral
•2
2.9x10
6X10°
S.lxlO'2
2X101
1.1X10'2
Reference Doses
(RfDs)
ma/kg/day
Inqestion Oral
IxlO"
3x10"'
1.0
SxlO'3
5x10"
5xlO-3
3.7xlO'2
1.4X103
3X10"
2X10'J
2x1
9x10s
1x10°
IxlO'2
9X10"2
3X10'1
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TABLE 14
CANCER RISKS FOR INDICATOR COMPOUNDS
FROM RESIDENTIAL USE OF GROUND WATER IN THE UPPER AQUIFER
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Primary Risk
Maximum Average Source
Off-Site Wells 2.4xl02 2.8xlOJ 1,1,2,2-Tetrachloroethane
Tetrachloroethene
1-1-Dichloroethane
On-Site Wells 4.7x10* l.SxlO"6 Trichloroethene
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TABLE 15
NONCANCER RISK
RESIDENTIAL SETTING
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Ground Water
Off-site Wells
On-site Wells
On-site Soils
Swale Sediments
HAZARD INDICES
ADULT
Maximum Averacre
31 5.23
1.7 0.48
Not Evaluated
Not Evaluated
CHILD ,
Maximum Averacre
89.5
4.3
3.7 0.
2.2
15.7
1.7
2-1.0
1.2
Primary
Risk Source
Cr, Cu, Ni
Cr, Cu
Cr, Cu, Ni,
Cr, Cu, Pb
NOTE: Cr=Chromium, Cu=Copper, Ni«Nickel, Pb=Lead
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TABLE 16
MAJOR GROUND-WATER CONTAMINANTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
CONTAMINANTS
Inorganics
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Zinc
Volatile Oraanics
Benzene
1-1-Dichloroethane
Trans-1 , 2-Dichloroethane
Ethylbenzene
Tetra chl oroe thene
1,1,2, 2-Tetrachloroethane
Trichloroethene
1,1, 1-Trichloroethane
Toluene
ARARs
(ppb)
1
10
50
1000
2
210
5000
1
2
10
50
1
1.4
1
26
2000
Source
2
1
1
1
1
1
2
1
1
1
1
1
1
1
1
2
NOTE: Sources-
l=Drinking Water Standards (Maximum Contaminant Levels
[MCLs]) under NJSA 7:9-6, 7:10-16.7, 58:10A and 7:14A
2=Federal Safe Drinking Water Act (40 CFR, Parts 141 and
142)
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TABLE 17
SOIL-CLEANUP GOALS FOR
MAJOR INORGANIC CONTAMINANTS
KING OF PRUSSIA TECHNICAL CORPORATION SITE
-CONTAMINANTS
Inorganics
Arsenic
Beryllium
Cadmium
Total Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Soil
Cleanup
Levels
190
485
107
483
3,571
500
1
1,935
4
5
3,800
Source
1
1
1
1
1
2
2
1
2
2
1
NOTE: Sources-
l=Based on human health risk which will result in a cancer
risk less than 1x10* and a Hazard Index of less than one
2=New Jersey Soil Action Levels
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TABLE ISA
COST SUMMARY-FOR REMEDIAL ALTERNATIVES ...
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Annual
Remedial Alternative
Component One
Alternative
No Action
S-J. -
Alternative S-2 -
Limited Action
Alternative
S-3 -
$
$
$
Capital
Costs
0
43,000
1,550,000
Operation and
Maintenance
$
$
$
7,
9,
17,
000
000
000
$:
$
$
Total
79,
144,
1,741,
000
000
000
Consolidation &
Capping
Alternative S-4 -
Excavation &
Extraction
Alternative S-5 -
In-Situ Stabilization
& Solidification
Alternative S-5a -
Above-Ground
Stabilization &
Solidification
$ 8,050,000
$ 3,182,000
$ 5,402,000
Alternative S-6 - $11,500,000
Removal & Disposal
$ 8,050,000
$ 10,000 $ 3,336,000
$ 10,000 $ 5,555,000
$11,500,000
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TABLE 18B
COST SUMMARY FOR REMEDIAL ALTERNATIVES .
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Annual
Remedial Alternative Capital Operation and
Component Two Costs Maintenance Total
Alternative DR-1 $ 0 $ 7,000 $ 79,000
No Action
Alternative DR-2 $ 386,000 $ 0 $ 386,000
Removal & Disposal
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TABLE 18C
COST SUMMARY.FOR REMEDIAL ALTERNATIVES
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Remedial Alternative
Component Three
Alternative TK-1
No Action
Alternative TK-2
Capital
Costs
$ 0
$ 22,000
Annual
Operation and
Maintenance
S 0
S o
Total
$
$ 22,
0
000
Removal & Disposal
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TABLE 18D
COST SUMMARY FOR REMEDIAL ALTERNATIVES .
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Remedial Alternative Capital
Component Four & Five Costs
Annual
Operation and
Maintenance
JTotal
Alternative GW-1
No Action
Alternative GW-2
Limited Action
Alternative GW-3
Extraction,
Treatment &
Reinjection
Alternative GW-4
Extraction,
Treatment &
Surface Discharge
$ o
S o
$ 2,043,000
$ 2,766,322
$ 11,000 $ 122,000
$ 11,000 $ 122,000
$ 285,000 $6,431,000
$ 406,000 $9,016,000
NOTE: Remedial Component Five (the Great Egg Harbor River) is
included in the GW alternatives for costing purposes.
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TABLE 19
COST SUMMARY FOR
SELECTED REMEDIAL ALTERNATIVES
KING OF PRUSSIA TECHNICAL CORPORATION SITE
Annual
Selected Capital
Alternative Costs
S-4
DR-2
TK-2
GW-3
TOTAL
$8,050,000
386,000
22,000
2.043.000
$10,501,000
Operation &
Maintenance
$ 0
0
0
285.000
$ 285,000
Present
Worth
$ 8,050,000
386,000
22,000
6.431.000
$14,889,000
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
KING OF PRUSSIA TECHNICAL CORPORATION SITE
I. Introduction .'
The King of Prussia Technical Corporation site, located in
Winslow Township, New Jersey, consists of an abandoned waste
disposal facility. Past waste handling and disposal practices at
the facility have resulted in organic and inorganic contamination
of site soil, ground water and sediments in an adjacent swale.
The site was placed on the National Priorities List of
uncontrolled hazardous waste sites in 1985. A Remedial
Investigation and Feasibility 'Study were completed for the site
in July 1990.
In accordance with the U.S. Environmental Protection Agency's
(EPA's) community relations policy and guidance and the public
participation requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act, the EPA Region II
office originally established a public comment period from July
16, 1990 through August 15, 1990 to obtain comments on the
Proposed Plan for this site. At the request of the potentially
responsible parties (PRPs) for the site, who have formed the King
of Prussia Technical Corporation Site Committee, the public
comment period was extended an additional 30 days to September
14, 1990.
On August 1, 1990, EPA held a public meeting to receive public
comments on the Proposed Plan. Copies of the Proposed Plan were
distributed at the meeting and placed in the information
repositories for the site.
The Responsiveness Summary, required by the Superfund Law,
provides a summary of citizens' comments and concerns. Section
II of this document provides a brief background of the community
involvement and concerns regarding the site. Section III
presents a summary of the significant questions and comments
expressed by the public at the public meeting concerning the
proposed remedy selection. Section IV presents a summary of the
PRP's and their contractor's comments on the Proposed Plan and
Supplemental Feasibility Study. A summary of the comments
received from The Pinelands Commission is also contained in
Section IV. Each question or comment is followed by EPA's
response. Written comments received during the public comment
period and EPA's response are attached in Appendices as described
below. It is ret..-*, that no written comments were received fron
-------
the community. Written comments were provided by the Pinelands
Commission and the King of Prussia Technical Corporation
Committee. All comments expressed to EPA were considered in
EPA's final decision for selecting the remedial alternatives for
addressing contamination at the site.
Attached to the Responsiveness Summary are the following
Appendices:
• Appendix A - Proposed Plan and Public Comment
• Attachment A.I - Proposed Remedial Action Plan,
King of Prussia Technical
Corporation site, Winslow
Township, New Jersey, July 1990.
• Attachment A.2 - Public Notice
• Attachment A.3 - August 1, 1990 Public Meeting
Attendance Sheet
• Attachment A.4 - Notice of Public Comment Period
Extension
• Appendix B - King of Prussia Technical Corporation Site
Committee's Comments on the Proposed Plan
and Supplemental Feasibility Study
• Attachment B.I - King of Prussia Technical
Corporation Site Committee Comments
• Appendix C - The Pinelands Commission Comments on the
Proposed Plan and EPA's Response
• Attachment C.I - The Pinelands Commission Comments
• Attachment C.2 - EPA's Response
II* Background on Community Involvement and Concerns
The King of Prussia Technical Corporation site initially became
an issue of public concern when local residents noticed illegal
dumping occurring at the site. Subsequent sampling by EPA and
the New Jersey Department of Environmental Protection (NJDEP)
revealed the presence of organic and inorganic contaminants in
the soils, ground water and surface water.
Major issues and concerns expressed by the community regarding
the King of Prussia Technical Corporation site are listed below:
• Potential contamination of potable wells and if the
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3
contaminated ground water is spreading to residential areas.
• Potential health risks associated with exposure to
contaminants in sediments, surface waters, and the contents
of buried drums and tankers.
• Potential health effects to the community during the
implementation phase of the remediation.
• Responsibility for remediation of the site, i.e., Winslow
Township's financial liability.
This section contains verbal questions and comments received from
the community during the August 1, 1990 public meeting. Comments
contained in this section are grouped according to subject
discussed.
A. Aquifer Contamination
1. A member of the Winslow Township Committee asked whether
metal contaminants were detected in the lower aquifer at the
site, and if so, would the lower aquifer require
remediation. It was also asked/ if additional areas of
contamination were discovered, how would this affect cleanup
costs.
EPA Response: Yes, site-related contamination above
drinking-water standards was detected in the deep aquifer.
EPA proposes to install additional monitoring wells during
the remedial design to delineate contamination in the deep
aquifer more completely. EPA will expand the ground-water
treatment system as needed, to address contamination in the
deeper aquifer. This would increase the cost associated
with ground-water remediation. The increase in cost would
be dependant on the extent of the ground-water contamination
in the deep aquifer.
2. A resident asked if an intermediate layer or aquifer existed
between the deep and shallow aquifers underneath the XOP
site.
EPA Response: There is an intermediate layer which is
called the middle subzone semi-confining aquifer. This
intermediate layer has an average thickness of approximately
six feet, and partially separates ground water in the lower
and upper aquifers. The intermediate subzone is primarily
.--.': of ?ol*-.fi ani cl?»ys, and is semi-permeable.
-------
3. Two residents asked where the closest downgradient private
veils were located, and whether EPA had sampled any
residential veils in the area for metal or volatile organic
compound contamination.
EPA Response: There are no private veils dovngradient of
the site. Contaminated ground vater at the site flovs
toward the Great Egg Harbor River, and the ground vater on
the other side of the river also flovs tovard the river.
Once the ground vater reaches the river, it flovs
downstream. No residential veils have been sampled because
EPA tested monitoring veils beyond the extent of the
contaminant plume and these veils have met drinking vater
standards. The area of the plume is veil defined by the
monitoring veils installed at and around the site and on
both sides of the river. These data indicate that the
contaminant plume is located in an area between the site and
the river.
4. A resident questioned whether the ground-water contaminant
plume reaches the Great Egg Earbor River.
EPA Response: Yes, contamination has been detected in the
river's surface vater in levels exceeding ambient vater
quality criteria. It is estimated that the highest
contaminant levels in the ground vater are presently halfway
between the site and the river.
5. An Evesham Township resident wanted to know what the flow
rate of the ground water is, and whether significant amounts
of contamination could reach the river within a couple of
years.
EPA Response: The ground vater at the site has been
calculated as floving at a rate of about one foot per day
(or 430 feet per year). Hovever, contaminants in the ground
vater move at a much slower rate than the ground vater
itself; the highest concentrations of contaminants in the
ground vater have taken about 15 years to move approximately
500 feet which is about half the distance from the site to
the river. If a pump and treat system is not implemented at
the site, it is estimated that the highest levels of
contaminants in the ground vater vould probably begin to
reach the river in 30 to 40 years.
6. Several residents asked whether any contamination from the
XOP site extended as far as Gloucester County, and whether
any water wells have been sampled and tested on the other
side of Great Egg Harbor River.
EP/T. r.espor:^^. i'-o uur.'t«..i v'lion has beta detected on the
other side of the river in Gloucester County. Two ground-
-------
water monitoring wells located on the other side of the
river in Gloucester County were sampled. Analyses of these
samples indicated no contamination.
B. Operable Unit One Pcasibility Study/Remedial Alternatives
1. A resident asked whether the PRPs help determine the
remedial 'treatment that will be implemented at the site.
EPA Response: As part of the Feasibility Study, the PRPs
identified and evaluated a number of remedial alternatives.
Based on this assessment, the PRPs recommended a series of
remedial components to EPA. EPA, however, independently
reviewed the PRPs1 effort and made the final decision
regarding the remedies that will be implemented at the site.
2. A resident commented that new remedial technologies are
constantly being developed. The resident asked whether
different proven technologies for remediating the site could
be implemented later on/ to replace the current chosen
technology, if it becomes outdated within a few years.
EPA Response: Generally, a Record of Decision will specify
the cleanup levels or goals which will be achieved by
implementing the remedy. In some cases, particular
treatment technologies may also be specified. If, after the
remedial action had begun, a new technology becomes
available which can achieve the same or greater degree of
protectiveness in the same or shorter time frame, EPA could
consider using such a technology, if significant cost or
time savings would be realized in doing so. EPA believes,
however, that the likelihood of such a cost or time savings
would be small.
3. A resident asked whether EPA would be remediating the soil
and ground water concurrently at the site, or if they would
be remediated separately.
EPA Response: The remedial systems for the soil and the
ground water will be designed simultaneously. Ideally, it
would be easier to treat the ground water, if the source of
the contamination in the soil had already been removed. To
expedite the total site cleanup, however, all remedial
components will begin concurrently.
4. Two residents commented that the Great Egg Harbor River is
being proposed for designation as a Wild and Scenic River.
They asked if this would be used as a reason to ensure the
cleanup of the FOP site/ and whether the treated ground
water ecuId potentially be discharged to the river.
-------
EPA Response: The proposed designation does indicate that
river has high resource value and one of the goals of site
remediation is to prevent adverse impacts to the river and
meet applicable or relevant and appropriate requirements
(ARARs) for the river. The treated ground water will not be
discharged to the river, due to a Pinelands Commission
regulation which prohibits surface-water discharge of ground
water extracted from the aquifer.
5. A member of the Winslov Township Environmental Commission
asked if there is any aspect of the remedial process which
would involve incineration, and if there is any risk of
fire, explosions or emissions associated with any process of
the remedial action.
EPA Response: Incineration is not proposed as part of the
remediation for the KOP site. As with any construction
activities, there may be risks of fire or explosion. Since
hazardous substances are involved, there is also a degree of
risk associated with emissions or air releases of these
materials. As a result, all activities will be conducted
according to an EPA-approved Health and Safety Plan, which
will describe procedures and precautions to minimize risks
resulting from remedial activities.
6. A resident questioned whether the proposed ground-water pump
and treat system had been successfully utilized at any other
Euperfund sites.
EPA Response: Ground-water extraction/treatment technology
has been used extensively at Superfund sites around the
country. It has not been in operation for long periods at
all the sites, but recent studies have proven it to be an
effective technology for significantly improving ground-
water quality.
7. A resident asked if the proposed reinjection of the treated
ground water could disperse the contaminant plume.
EPA Response: No, the design for the extraction/treatment/
reinjection system during the remedial design will be
developed to assure that this will not occur. The system
will be designed to capture the contaminated ground water
from extraction wells and reinject water treated to
drinking-water standards in a closed circulation system.
8. A resident asked bow EPA vill determine what soils are
excavated and what concentrations are included in excavation
and treatment.
EPA Respcr.sii: Soil sampling and ^rmlysis conducted rjuring
the Remedial Investigation and Feasibility Study provided a
-------
good characterization of-the areas and volume of soil above
the cleanup goals. All soils with contaminants in
concentrations above the cleanup levels will be excavated
and treated. Additional sampling conducted during the
remedial design phase as well as after soil remediation has
been conducted, will ensure that all of the soils
contaminated above cleanup levels are identified and
remediated. The levels to which the soils will be
remediated are presented in Table 17 of the Record of
Decision.
9. A resident wanted to know when the KOP site property would
be remediated to the point where it could be used for other
purposes.
EPA Response: The surface contamination problem will be
remediated within several years, but the property will
remain a Superfund site until the ground water has been
restored. This could require 30 years or longer.
10. A Gloucester County resident asked whether there will be any
potential for release of air-borne contaminants during the
remedial action.
EPA Response: All operations occurring at the site will be
carried out in an environmentally safe manner to both
residents and on-site workers. The ground-water treatment
system will capture volatile contaminants. Other
operations, such as soil washing, will also effectively
control air-borne contaminants. EPA will also be conducting
air monitoring during the implementation of the remedial
action to ensure that all operations are within acceptable
limits.
C. Health and Safety Issues
1. A resident commented that EPA had released a report in
September 1989 stating that it could be harmful to the
health of a 90-pound child, if that child ate half a pound
of fish per day from the KOP site area of the Great Egg
Harbor River. The resident asked whether that assessment
was still valid a year later.
EPA Response: The report referred to is the Endangerment
Assessment for the KOP site. The example of the 90-pound
child which was used in the Endangerment Assessment is a
hypothetical one, because the assessment considers a worst-
case scenario to determine human health risks. For example,
the assessment was done on the assumption that the fish in
the Great Egv JIarbor are actually contaminated. Kovever, r.c
biologic studies have been conducted on the fish to
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8
determine if they contain contaminants.
2. Several residents asked why samples of fish had not yet been
taken from the river and tested for contaminants/ and wanted
to know when this will occur.
EPA Response: Investigations of sites are normally done in
stages. .EPA has already sampled the river water and the
sediments near the KOP site which show low, but detectable
concentrations of contaminants in the river. These data
indicate minimal risk to human health. During the next
stage of investigation, additional types of testing will be
conducted and this concern will be addressed.
3. A resident asked whether a flood of the XOP site area would
result in significant spreading of the on-site contaminants.
He also asked whether there is an emergency plan that EPA
would implement in the event of a flood.
EPA Response: There is no specific emergency plan that EPA
would implement in the event of a flood. However, areas
planned for remedial activities and all the areas with
significant concentrations of contamination are above the
500-year flood plain. Thus, flooding would not be likely to
spread any significant additional contamination.
4. A representative of the Winslow Board of Health questioned
whether it is safe for hunters to consume game animals, such
as deer, which may have foraged in the XOP site area.
EPA Response: EPA consulted with a representative from the
Agency for Toxic Substances and Disease Control Registry to
develop this response. It is thought that consuming game
animals in the KOP site area would be safe, with the
exception of their internal organs (i.e., kidneys or
livers). While EPA would have to analyze animal tissue in
order to determine whether an animal had accumulated harmful
levels of contaminants due to ingestion of plants in the
area, mammals (i.e., deer) do not bioaccuroulate inorganic
contaminants in tissues (flesh). Contaminants, if ingested
by animals, would be concentrated in internal organs (e.g.,
kidneys or livers) which could present a health risk if
consumed. The areas with the greatest contaminant
concentrations have been fenced and are not accessible to
most mammals that are likely to be consumed.
5. A resident asked whether it would be possible for EPA to
fence the drainage swale near the sit* in order to prevent
animals from potentially drinking water from the swale.
••'"& K^.sr".-3 ••.. •-'!'. ivP.l :... .istigate whether th« levels in
the swale would constitute a significant threat to
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9
indigenous species warranting fencing.
D. Removal Actions
1. A resident asked how many carboys were excavated and how
nany drums could potentially be buried in the drum area.
EPA Response: One hundred twenty carboys were excavated.
EPA estimates 80 to 90 fifty-five gallon drums to be buried
at the site. There is, however, considerable uncertainty
with the drum estimate; the number will not be known until
the drums are excavated.
2. A resident asked if EPA vill furnish Winslov Township vith
an Emergency Response Plan the next time trucks have to
remove material from the site and travel through the
township.
EPA Response: Yes, when the project approaches the stage of
excavation and site disturbance, EPA will prepare and
provide an Emergency Response Plan which will be a component
of the Health and Safety Plan for the site. The Emergency
Response Plan will address emergency evacuation routes,
hospital locations, medical concerns and personnel
responsibilities regarding possible fires, explosions,
spills, leaks or releases.
E. Future Activities
1. Several residents asked EPA to outline the schedule for the
remedial action/ and they also asked if there is any vay to
expedite the schedule.
EPA Response: Implementation of the remedial action is
expected to begin within two years. The overall remedy is a
long-term project. The sequential steps required for
implementation are:
1) EPA's decision on remedy selection, anticipated by
September 1990;
2) Settlement activities for implementation of the
Remedial Action (six to nine months);
3) Remedial design activities 12 to 18 months;
4) Construction activities - These will take one to two
years to remove surface materials and treat
contaminated materials and many years (possibly
decades) of operation of the ground-water pumping
and treatment system to achieve the remedial goals.
EPA viJ. cA|,<2uite the removal of the drums. This activity
is expected to begin by the end of 1990 and should be
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10
completed by the summer-of 1991. Due to the extent and
complexity of the contaminants at the site, however, the
long-term Remedial Action will proceed according to the
process and time frame described above.
IV. summary cf Comments from Other Interested Parties and EPA
Responses-
This Section contains written questions and comments received
during the public comment period from the King of Prussia
Technical Corporation Site Committee representing Cabot
Corporation, Carpenter Technology Corporation, Ford Electronics
and Refrigeration Corporation, Johnson-Matthey Corporation, LNP
Corporation and Ruetgers-Nease Chemical Company, Inc. and their
technical consultants, Environmental Resources Management, Inc.
It is noted that references to the Feasibility Study (FS) apply
to the document prepared by the King of Prussia Technical
Corporation Site Committee's technical consultant Environmental
Resources Management, Inc. (ERM). The Supplemental Feasibility
Study (SFS) document was developed by EPA and its contractor.
A. Summary of King of Prussia Technical Corporation Site
Committee's Comments (refer to complete letter in Appendix
B).
1. The XOP Site Committee maintains that the recommended
alternative (E-2A from the Feasibility Study) vill meet
ARARs, remediate the ground vater as much as is technically
practical and be protective of human health. The Bite
Committee also maintains that the EPA's selected remedy is,
"not based on proven and reliable technologies/11 is not
cost-effective/ and that drinking-water standards should be
waived since they are not appropriate objectives for the
ground vater at the KOP lit*. The KOP Site Committee
recommended alternative E2-A from the FS which consists of:
"removal and off-site disposal of drums, the consolidation,
soil vacuuming, stabili2ation and capping of contaminated
sludges and soils, and institutional controls, consisting of
site access and land use restrictions and future monitoring,
including a five-year groundwater pump and treat review to
assess the effectiveness of the groundwater treatment
approach and appropriateness of the proposed applicable or
relevant appropriate requirements (ARARs) for groundwater.11
EPA Response: Alternative E-2A was evaluated by EPA and
rejected because it was not the most protective remedy,
i.e., would not meet all ARARs (e.g., drinking-water
stand';•--!£ f--.- ground water). Alsc, Alternative E-2A would
not remove contaminants in the soils or the ground water and
would not restore the site for unrestricted use. EPA's
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11
selected remedy achieves ARARs and removes contaminants that
present a human health risk. The selected remedial action
components are cost-effective because they provide the
highest degree of protectiveness for human health and the
environment among the alternatives evaluated, while
representing a reasonable value for the cost and will allow
for unrestricted future use of the site.
The KOP Site Committee's comments are addressed more fully
below in EPA responses to page specific comments on the
Proposed Plan made by the Committee's technical consultant,
Environmental Resources Management, Inc. (ERM).
B. comments/ by tbe King of Prussia Technical Corporation Site
Committees technical consultant, Environmental Resources
Management/ Inc. (ERM).
1. Proposed Flan Reference: p.7, 2nd complete paragraph, 1st
sentence: "The cancer risk from drinking contaminated ground
water is 2.4 x 10*2, although presently there are no users of
the ground water in the proximity of the site."
ERM: This is an oversimplification of the potential risk
associated with drinking contaminated ground water at the
site. First/ the risk level of 2.16 z 10* is for the
maximum VOC concentrations detected. The risk level based
on average concentrations/ which represents the most
probable exposure condition/ is lower/ at 2.5 z 10"3. This
is the appropriate risk level to be cited for the
residential use scenario.
Second/ ERM believes that residential development is not the
most likely future land use at the site. The most plausible
future land use scenario for the site is recreational use/
as the site is within the Pine Barrens, adjacent to a
wildlife management area/ and owned by the township. ERM
believes that tbe carcinogenic risk level from the EA which
corresponds to tbat type of land us* should accordingly be
presented as tbe existing site risk in tbe final ROD. Tbat
risk level is 4.9 z 10*.
EPA Response: EPA policy is to present the maximum possible
risk when discussing human health risks. Therefore, both
maximum and average cancer risks were presented in the
Endangerment Assessment.
While recreational use is a possible future use for the
site/ residential use should not be precluded due to partial
site restoration. Also, to restrict residential development
beciwse of incomplete remediation would require permanent
institutional controls.
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2. Proposed Plan Reference* p. 7, 2nd complete paragraph, 2nd
sentence: "The proposed remedial activities will reduce
contaminant concentrations to Maximum Contaminant Levels
(MCLs) that are drinking water standards.11
ERM: This sentence indicates that MCLs vill be achieved via
ground vater remediation. While this may be possible for
the orgarric contaminants, it has been clearly demonstrated
in the site F6 that metals in the ground vater vill not be
reduced to MCLs in any foreseeable time period. The
presentation of this concept in the PRAP results in a
misleading oversimplification of the site ground vater
remedy, vhich vill create unrealistic public expectations
for the ultimate degree of cleanup.
EPA Response: While it is not a certainty that MCLs (i.e.,
ARARs) are achievable using an extraction/treatment/
reinjection system for ground-water remediation, EPA
maintains there is a solid basis that makes this a
reasonable expectation. ERM's FS does not clearly
demonstrate that ground-water remediation cannot achieve
MCLs. Pages 3-31 and 3-32 of the FS state: "Attainment of
Potential Ground Water ARARs...It should be noted that the
exact conditions attainable under ground water recovery
cannot be accurately simulated; they can only be determined
during operation of a long-term recovery system." EPA
maintains that regardless of the final cleanup levels
obtained by the pumping and treatment system, a significant
removal of contaminants will be achieved and, therefore,
will aid in protecting the Great Egg Harbor River and
accelerate aquifer restoration. These concepts are
continually neglected in ERM reports and comments.
3. Proposed Plan Reference: p.7, 3rd complete paragraph: "The
RI indicates metals contamination may present a threat to
stream biota due to metals contamination in the sediments
and possible bioaccumulative effects. Additional data on
contaminant concentrations and biologic effects are
necessary."
ERM: The EA, not the RI, discusses potential threats to
stream biota. The EA concluded that the concentration of
metals detected suggest a "minimal potential for adverse
effects to aquatic receptors...", noting, however, that no
definitive conclusions are possible vith the available data.
The EA conclusion of minimal impact potential is not
accurately reflected in the PRAP language. Furthermore, if
the potential for impact is truly minimal, as concluded in
the EA, there should be no need for additional data
collection.
EPA Response: The EA mentions that only minimal a.verage
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13
concentrations of contaminants were detected in the river to
date. The EA also states, however, that these average
concentrations are above background levels and maximum
concentrations exceed Ambient Water Quality Criteria. Thus,
the river has been adversely impacted by site-related
contamination. Furthermore, the river has not been
adequately characterized and additional data are required to
determine the full extent of contamination and its impacts
on stream biota. Monitoring is also necessary to determine
the effect of the ground-water treatment system on surface
water and sediments of the river.
4. Proposed Plan Reference: p.14, Component 5, Surface Waters
and Sediments of the Great Egg Harbor River; p. 16,
Selection of Remedy for Component 5: "Sampling and analysis
of the Great Egg Harbor River's surface waters and sediments
will further characterize contaminants concentrations and
distribution in the river. This will include biological
sampling to evaluate organisms responses to changes in the
river environmental related to contamination. A
determination will then be made if remediation of the Great
Egg Harbor River waters and/or sediments will be necessary."
ERM: As discussed above, the »it« EA determined that
minimal potential for impacts exists in the Great Egg Harbor
River. The purpose of collecting the RI data was to provide
the basis for preliminary determination of the likelihood of
impact, on the basis of those data, it vas determined that
long-term protection of the river vould be achieved by
removal of metals from the ground water system via pump and
treat technology. Further remediation of the river vould
require dredging to remove metals from the sediments, which
would in itself cause adverse impacts to the river by
mobilizing metals in suspension and destroying benthic
habitats. Given the unlikelihood of current impacts,
further remediation by dredging of sediments clearly
represents a greater potential for adverse impact on the
river than does the current condition.
EPA Response: The selected remedy of extraction, treatment
and reinjection of contaminated ground water will be
designed to control contaminants discharging to the river.
This is expected to result in a reduction in contaminant
concentrations in the river over time. One of the goals of
site remediation is to ensure that the site does not cause
nonattainment of ARARs in the river. EPA maintains,
therefore, that it is necessary to sample and analyze river
surface water and sediments and further monitor the effects
of the ground water remediation system on the river. EPA is
not proposing any remi-.-Iii activiiries for the river (e.g.,
dredging) at this time, since any such recommendation would
be premature. Rather, EPA's selected remedy includes
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14
obtaining additional data before and during implementation
of the ground-water treatment system. If site contaminants
are adversely impacting the river, the river will become a
separate operable unit, and a focused feasibility study will
evaluate all appropriate remedial alternatives, including
modifications of the ground-water treatment system, to
ensure that river ARARs are met.
5. Proposed Plan Reference: p.15, paragraph 2: Selection of
remedy for Component 1 (Metals-Contaminated Soils,
Sediments, and Sludges):
ERM: The PRAP selects contaminant extraction for this
component of the site remedy. The 76 recommendation vas for
stabilization and containment in the former lagoon area.
ERM has several observations regarding the remedy proposed
in the PRAP:
- Contaminant extraction is an emerging technology vhich
has not been performed at full scale to any significant
extent. Thus/ there are many unknowns associated with the
performance of contaminant extraction/ including its
ultimate effectiveness. Treatability studies vill be
required to determine the degree of effectiveness at the KOP
site. Until such evaluation are done/ it is premature to
select this technology as the remedy for Component 1.
- No evaluations have been done to determine if this
technology is the most cost-effective method of achieving
protectiveness at the site. Until such evaluation are done,
it is premature to select this technology as the remedy for
Component 1.
- The contaminant extraction technology would remove the
metals from the site media and merely transfer them to
another location/ as they are not destructible. Since it is
well documented that the site ground water will not likely
be usable for future significant development of the site/ no
added value to relocating the site contaminants has been
demonstrated.
- Stabilization is a well-established, proven technology
for treatment of metals-contaminated soils and sludges and/
as such/ has been designated as Best Demonstrated Available
Technology (BDAT) under the Land Disposal Restrictions.
Stabilization and capping of the soils and sludges on site
would effectively encapsulate the contaminated soils/
preventing both contaminated soils/ preventing both
continued leaching to ground water and direct contact.
Thus, under the no«?t reasonable future land use for
rtcreat:cr>al pu-po:,,^jf os-site stabilization '.»itu capping is
both technically feasible and protective.
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Given the factors described above/ we believe that on-site
stabilization is the appropriate Component 1 remedy for
application at the site. However, should contaminant
extraction be specified in the final ROD, it should include
a requirement for treatabilitv testing. Given the fact that
contaminant extraction is unproven/ such a ROD should also
provide for a contingent on-site stabilization remedy.
EPA Response: Above ground contaminant extraction has been
demonstrated to be effective for removal of inorganic (and
organic) contaminants at NPL sites. These data support
successful application of this technology for removal of
inorganic contaminants, especially where sandy and silty
soils are treated (as at the KOP site). This experience
also indicates economic competitiveness with other remedial
technologies (Raghavan, R., Coles, E., and Dietz, D, 1990,
Cleaning Excavated Soil Using Extraction Agents: A State-
of-the-Art Review, EPA/600/S2-89/034). Other considerations
in the selection of contaminant extraction is that it
removes contaminants above health-based cleanup levels, is
permanent, and restores the site for unrestricted use.
Treatability Studies are included as part of the remedial
design to determine optimum extraction agents and system
design parameters for the Extraction and Contaminant
Extraction Alternative.
To presuppose that ground water at the site will not be used
because there will be no future development is premature and
is not consistent with EPA's policy for returning ground
water to beneficial use. Residual materials (e.g., residual
sludges from the treatment processes) will be removed and
treated and/or disposed at an approved off-site facility.
This is consistent with EPA policy of a preference for
treatment and reduction in mobility, volume, toxicity of
contaminants at the site.
Although stabilization is a proven technology, it would be
less protective than the selected remedy, since its
protectiveness assumes proper maintenance of the capping
system and requires permanent monitoring of the ground
water. Additionally, the site would not be fully restored
for unrestricted use, as contaminants would remain at the
site.
6. Proposed Plan Reference: p. 15, last paragraph, to p. 16:
Selection of remedy for Component 4 (Ground Water):
ERM: The remedy selected is a ground water recovery,
tre 'twent, and reinjection program which was evaluated in
* .,.•» $.-*i:. ?his program incorporates numerous, recovery and
injection wells throughout the ground water contamination
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plume, with the intent that ground vater remediation will be
conducted until the ground vater ARARs are met. By
contrast, the ground vater remediation program designed in
the FS takes into account the technical constraints shown in
the F8 to preclude reaching of metals ARARs using pump and
treat technology. The F8 design includes one line of
recovery wells located in the area of highest concentration
in the plume, with the intent that VOCs would be reduced to
either ARARs or to practical minima within a reasonable
period of time, while coincident mass removal of metals
would protect the Great Egg Earbor River over the long term.
It is ERK's opinion that the proposed remedy selected in the
PRAP fails to take into account the technical constraints on
reaching metals ARARs, as described in detail in the site
FS. This results in several issues being inadequately
addressed by the PRAP, including the following.
- The ability of the SFS system design to meet ARARs: The
PRAP assumes that ARARs can be met, while the F8
demonstrates that this will not be the case.
- Remedial goals/expectations: The PRAP sets the remedial
goal as attainment of ARARs, which has been demonstrated in
the FS to be infeasible.
- Time period to remediation: The PRAP appears to be
inconsistent on the issue of time to achieve remediation.
- The SFS design vs. the FS design: The SFS design has been
assumed by the EPA to be superior to the FS design, but
again, this assumption ignores the constraints on metals
removal.
• Degree of environmental protection: The PRAP has failed
to consider the deleterious effects on the environment of
installing the more complex SFS system design.
• Evaluation of remedy effectiveness: The PRAP has failed
to take into account the need to evaluate the effectiveness
of the ground water recovery system during its operation,
the effects of system design on the evaluation process, and
the effects of the evaluation on reexamining remedial goals.
• Consistency of the PRAP with EPA internal guidance on
ground water remedies: The PRAP has failed to follow the
guidance provided in the EPA internal memo of October 18,
1989 regarding evaluation of ground water recovery systems,
flexibility in ground water recovery systems, flexibility in
ground va{.».••- r^iovet-y Koto, and the need to address
contingent rc-uedies and potential waivers of ARARs in RODs.
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17
EPA Response: See comments A.I, B.7, B.8, B.9, B.10, B.ll,
B.12, B.13, and B.14. '
7. ERM:
Ability of the STB System to Achieve XRARs
In tbe modeling performed in the SFS, the ultimate goal of
tbe ground vater recovery program is not clearly defined.
The PRAP indicates the goals of the ground vater recovery
program to be attainment of XRARs and prevention of metals
discharge to the Great Egg Earbor River. Like the F6
modeling, the SFS effort vas focused on time to remediation
of vocs in the ground vater. Zn theory/ the SFS design
remediates VOCs more quickly than the FS design, leading EPA
to the conclusion that the SFS design is superior for the
purpose of meeting ARARs. However, unlike the FS, the SFS
did not address the problems inherent in meeting ARARs for
metals due to their high retardation in soils. It is veil
established that metals generally exhibit very low rates of
partitioning from soils to ground vater. This factor vas
shown in the FS to severely restrict the potential for any
ground vater recovery system to achieve ARARs for metals,
even over the very long term.
The SFS ground vater recovery modeling vas limited to a
demonstration of the time frame for theoretically meeting
the VOC ARARs at the site. Metals vere ignored. However,
the metals are actually more limiting for ground vater usage
potential than the VOCs. Treatment of metals to potable
levels for vater supply is generally not practiced due to
technical and economic limitations, vhile treatment of vater
supplies for VOC removal is a proven, cost-effective
technology. Thus the PRAP, by ignoring the metals issue,
fails to address the more significant technical limitation
on ground vater remediation at the site.
EPA Response: Metals contaminants were not specifically
addressed in EPA's SFS because the purpose of the modeling
exercise vas to compare the relative cleanup times of
different designs developed in the SFS. The modeling
completed in the SFS was not meant to quantify actual
cleanup times, rather the goal of the modeling vas to
determine the relative effectiveness for different
conceptual designs of various extraction and reinjection
systems. EPA's SFS, as well ERM's FS, did not address
metals contamination in the ground water because data
generated during the RI/FS vere insufficient to define
retardation factors accurately for metals contaminants for
th- site.
Treatment of metals to achieve aquifer restoration ("potable
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18
levels for water supply.") is a commonly used technology at
Superfund Sites. Of 31 sites with ground-water metals
contaminants in an EPA study, 26 have aquifer remediation as
the goal (EPA, 1989, Evaluation of Ground-Water Extraction
Remedies, EPA/540/2-89/054).
It should be noted that the conceptual design utilized in
the Proposed Plan was taken from the SFS but is not
necessarily the final design that will be implemented. The
conceptual design will be refined based on the collection of
additional data obtain during the Remedial Design.
8. ERM:
Remedial Goals/Expectations
By ignoring the metals issue as addressed in the FS, the
PRAP reaches the erroneous and misleading conclusion that
ARARs will be met in ground water by using the SFS recovery
system. Again/ it was clearly demonstrated on a technical
basis in the FS that it is highly unlikely that the metals
concentrations can be reduced to the levels of ARARs in the
foreseeable future and that organics may or may not be
reduced to the ARARs. Given this knowledge/ the ROD for the
site should discuss the constraints of ground water recovery
at the site and should set reachable goals/ based on
technical realities. To do any less is considered by ERM to
be overly optimistic and misleading; it can only create
unrealistic expectations in the minds of the public
regarding the degree of and time frame required for site
remediation.
Given the inability of ground water recovery to achieve
metals ARARs/ the FS proposed that mass removal of metals
from the upper aquifer should be conducted until the
reduction would be permanently protective of the river.
This provides a goal for permanent protectiveness that
recognizes and takes into account the technological
limitations on ground water remediation at the site. Since
the ground water will never be usable without treatment for
metals (and possibly for VOCs)/ the FS goal concept should
be incorporated into the final ROD.
EPA Response: As discussed previously, EPA maintains that
achieving ARARs for complete restoration of the aquifer is a
reasonable goal. In addition, remediation of the upper
aquifer should also be conducted to evaluate that ARARs are
met in the Great Egg Harbor River. EPA's selected
alternative of pumping and treating ground water, in
combination with monitoring the river, will achieve this
goal. Protection of the riv^r can only be confimoJ by
river sampling and analysis before and during the operation
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19
of the ground-water remediation system. The remedial
alternative proposed in ERM's FS would not achieve complete
protection of the river since the inorganic contaminants,
although slightly reduced, would continue to discharge to
the river at relatively high levels.
9. ERM:
Time to Remediation [sic]
The PRAP appears to select the SFS ground water recovery
system because it will theoretically meet the VOC ARARs
faster than the FS system design. However, the cost
estimate for the remedy is based on 30 years of operation,
presumably due to the presence of the metals, which was not
addressed in the 6FS. since the time required to remediate
the metals will determine the duration of system operation,
it is inappropriate to base the recovery system design on
the voc ARARs. The FS showed that even 30 years of
operation is unlikely to achieve the metals ARARs. As also
demonstrated in the F8, if realistic (i.e., truly
achievable) goals are set for the remediation [in terms of
vocs], the duration of system operation may be considerably
less than 30 years.
EPA Response: Since the time required for remediation of
the aquifer is uncertain and could be longer than 30 years
for complete aquifer remediation (achieving ARARs for both
organic and inorganic contaminants), EPA's policy is to
assume a period of performance of 30 years for costing
purposes.
10. ERM:
SFS Design vs. FS Design
It is not clear that the SFS system design will provide
superior cleanup performance, despite higher pumping rates
and injection of treated water. The sorption/desorption
equilibria for metals in soils are very complex. At the
present time, it is unknown whether the rates of metals
release and/or mass removal would increase, remain
essentially the same, or decrease under the SFS system
design. The increase in flow velocity, along with the
injection of treated water, Bay result in the appearance of
remediation on a concentration basis during operation of the
system. However, the ultimate remediation is dependent on
mass removal by partitioning from the soils. If the SFS
system were to inadvertently reduce mass partitioning, the
metals concentrations in grour.3 v;ter -v-c'd be expected to
rise after the system wai shut do»a, as Lie original
equilibrium conditions returned. Thus, it not clear whether
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the 8F8 design is superior to, or possibly inferior to, the
TB design for metals removal.
EPA Response: EPA's SFS design was developed to consider
additional extraction and reinjection designs than those
presented in ERM's FS. The conceptual design utilized in
the Proposed Plan for costing purposes was based on one of
the design scenarios presented in EPA's SFS, but did not
represent the final specification of the groundrwater
remediation system. The final design of the ground-water
remediation system will be based on additional data and
modeling and analysis and will be prepared during the
remedial design phase. This effort will consider factors
mentioned in this comment and other considerations such as
pulsed pumping, different extraction/reinjection veil
designs, impacts to wetlands, effective contaminant capture
and control (both vertically and horizontally), etc.
11. ZRM:
Environmental Protection
The expansive EPS system vill place veils and piping systems
throughout the area from the site to the river. This
configuration vould be far more environmentally destructive
than the F6 design. The construction and maintenance of
this system vould unnecessarily disrupt a currently
undisturbed area of the Pinelands between the Fire Road and
the river over the very long term. This factor constitutes
a long term adverse impact vhich vas unaccounted for in the
SFS evaluation and the PRAP.
EPA Response: EPA recognizes that there vill be some
disturbance to the site and adjacent area to construct the
components of the ground-water remediation system. However,
these temporary effects are necessary to restore the site
and provide adequate protection of public health and the
environment.
12. ERM:
Evaluation of Remedial Action
The ground water recovery system must be re-evaluated, by
lav, on a five-year basis. The selection of a system in the
PRAP has failed to take into consideration the needs of the
evaluation process. Current scientific understanding of
metals remediation in the subsurface is limited. If EPA
hopes to maximize metals remediation at the XOP site, a
serious effort must be undertaken to evaluate the mobility
cf rj'..-K. Jr. t;.-» sc-?? r,r-4 v;.-ter phases on a aito-upc-ci?ic
basis. The fcFi; system vill produce a complex potcntiometric
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surface and high spatial variability in water quality. This
will complicate evaluation of remedial progress and the
mechanisms affecting remediation. For example, ae described
previously/ if desorption of contaminants from the soil is
reduced by dilution and increasing flow rate/ the
effectiveness of the 6FS system may be inadvertently
overestimated.
The 76/ on the other band/ has presented a system which
vould remediate VOCs in ground water and provide long-term
protection of the river/ vhile providing the simplicity to
allow more effective evaluation of the remedial process for
metals. Based on the five-year findings/ the PS system
could be modified to optimise metals removal, if necessary/
or might possibly be terminated/ if sufficient metals
removal had been achieved.
EPA Response: EPA disagrees with this comment. The ground-
water remediation system will actively remove both organic
and inorganic contaminants from the aquifer and will not
complicate the evaluation of the effectiveness of the
remedial action. The system presented in the FS would only
provide partial aquifer remediation as it would primarily
address volatile organic compounds. The ground-water
remediation system will be monitored on a regular basis and
adjusted as warranted by the performance data.
13. BRM:
Inconsistency of PRAP with EPA Internal Guidance
As detailed above, the PRAP fails to adequately address the
issues of metals remediation and system performance
evaluation in the selection of a ground water recovery
system for the KCP site. The EPA'e own internal uemo of
October 18, 1989 indicates that such factors should be taken
into account in site RODS. Specifically, Recommendation 2
(p.4) calls for ROD flexibility and contingent remedies,
where appropriate. The contingent remedy, when appropriate,
should be discussed "in equal detail to the primary remedial
option and should provide substantive criteria by which the
Agency will decide whether or not to implement the
contingency." (p.5). Based on the technical findings of
the site F6 and on the EPA's internal guidance memo, the
issues of metals removal limitations, system performance
evaluation, and contingent remedies should be fully
addressed in the final site ROD.
In conclusion, it is not at all clear that the technical
basis fcr fia gro-;*? t/a^r reL-.aCy specified in tJi* TRAP is
correct. Her is it clear that the proposed remedy is more
environmentally protective than the F6 system design. Zt is
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clear, however, that the PRXP appears to be inconsistent
with EPA internal guidance OB selection of ground vater
remedies. ERM's design is in agreement with the technical
considerations which fora the basis for the EPA internal
guidance; we believe that it should be followed in the ROD
for the XOP Site.
EPA Response: The ground-water remedy described in the
Proposed Plan is consistent with EPA's internal guidance.
Furthermore, EPA maintains that providing a contingency
remedy is premature and inappropriate at this time because
removal of metals contaminants from ground-water has been
shown to be effective.
The remedy would provide flexibility where appropriate, as
the ground-water remediation system will be carefully
monitored on a regular basis and adjusted as warranted by
the performance data collected during operation. Modeling
results from the FS and 5FS indicate the ERM's proposed
design would not restore the aquifer as efficiently as that
conceptual design presented in EPA's SFS.
14. Proposed Plan Reference: p. 16, Selection of Remedy for
Component 4 (Ground Water): "Additional monitoring wells be
required to provide data to define more completely the
vertical extent of contamination."
ERM: The EPA feels that since the lower sub2one aquifer
wells are not screened immediately below the middle
confining subzone, the potential exists for significant
contamination to be present in the lower aquifer. The RI
data and evaluations of the lower aquifer clearly
demonstrate the absence of significant impact on the
aquifer. For example, the vertical hydraulic conductivity
(K) of the con'initg unit was shown to be 2.7 z 10'7 cm/sec
from the pump test and 1.8 z 10* cm/sec (maximum) as
calculated using analytical data. Using Darcy's Law (Q
flow) s k z i (hydraulic gradient) z A (cross sectional area
of flow) and RI data on the confining and lower aquifer
subzones, it can be calculated from the data that the
dilution factor from a unit area of the confining unit into
the 5-foot upper thickness of the lower aquifer is a minimum
of 4200 times. The maximum metals concentrations detected
in the upper subzone aquifer were 1040 ug/1 chromium/ 12/500
ug/1 copper, and 4670 ug/1 nickel (all at veil JCff 5-8).
Thus, the maximum potential contribution to the lower
aquifer is 0.25 ug/1 chromium, 3.0 ug/1 copper, and 1.1 ug/1
nickel, all below MCLs or other possible drinking vater
standards.
Except for one anomalous detection of chromium above its MCL
(at well MW 14-D), all data collected from the lower aquifer
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confirm this analysis. -The average chromium concentration
in the lover aquifer vas approximately 11 ug/1 (belov the
MCL of 50 ug/1), vith 6 of 8 •ample* belov the detection
limit of 1 ug/1.
When the ground vater recovery system in the upper subzone
aquifer goes on line, the dovnvard hydraulic gradient vill
be reduced, possibly even to an upvard gradient!. Thus, not
only do the current conditions clearly indicate no threat to
the lover aquifer, but the ground vater remediation program
in the upper aquifer vill further protect the lover aquifer.
Furthermore, any ground vater recovery program in the lover
subzone aquifer vould diminish the protection provided by
the upper aquifer recovery program and might risk inducing
additional discharge through the confining subzone, thus
possibly creating an impact vhere none nov exists.
In summary, ERM has concluded that the lover subzone aquifer
is not adversely affected by the site and vill be best
protected for the long term by the upper subzone aquifer
recovery system. Given these conditions, the lover subzone
aquifer is adequately monitored, and no additional
monitoring veils are needed.
EPA Response:
EPA maintains that the aquifer lithologies and sample
analysis data indicate significant additional contamination
of the deeper aquifer. Correlation of electric logs and
detailed delineation of site stratigraphy clearly indicate
that the confining nature of the middle sub-zone aquifer is
oversimplified and misrepresented in the RI/FS. The clay
thickness of the intermediate subzone is thinner directly
under site source areas (lagoons, buried drums, etc.) than
vhere off-site pump tests were conducted and the type-log
(MD-8D) was selected. The pump test data are not
necessarily representative of permeabilities in the site
source area due to lateral heterogeneities of the
intermediate aquifer across the area. The clay layer is
thinner, sandier and relatively permeable in the site source
areas vhere contaminants are migrating vertically dovnvard
to the deeper aquifer. The maximum potential contributions
cited in the above comment are theoretical and may be flaved
due to the considerations discussed above. The veil vith
the "anomalous1* detection of chromium must be considered to
represent additional contamination in the deep aquifer.
The remedial design vill consider the effects that vill be
induced by the ground-vater remediation system and vill be
design^:' to assure th?t no adverse impacts are created by
•che operation of the system.
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24
An additional consideration of deeper aquifer contamination
relates to the monitoring wells previously identified as
screened in the intermediate subzone. Electric log
correlations with intermediate wells lithology descriptions
for the intermediate wells clearly show that previously
identified "intermediate wells" are not screened in the
intermediate sub2one, but are screened in the upper portion
of the deeper aquifer (or just below the intermediate
aquifer). Samples from these wells represent deep aquifer
contamination whose data are incorrectly labelled in the
RI/FS as representing ground-water from the intermediate
aquifer. Two wells previously identified as intermediate
wells have contaminant concentrations as follows:
MW-2J MW-4J Cleanup Goals
Beryllium 29 ppb 31 ppb 1 ppb
Chromium 20 ppb 26 ppb 50 ppb
Copper 3,070 ppb 2,830 ppb 1000 ppb
Nickel 783 ppb 899 ppb 210 ppb
Zinc 232 ppb 627 ppb 5000 ppb
Concentrations which exceed cleanup goals are bold in the
listing above. The only other well that is screened in the
deep aquifer and previously identified as an intermediate
well is MW-6i in which no contamination was detected.
In addition to considerations discussed above, contamination
may also be under-represented since all ground-water
analyses were conducted for filtered samples which would not
include contaminants in the colloidal or suspended phases
and thereby not reflect the total concentration of
contaminants in the samples.
Additional monitoring wells are needed along with a detailed
stratigraphic analysis using electric logs wherever possible
to define the nature of intermediate subzone relationship to
contamination in the deep aquifer. The ground-water
remediation system will be modified to address deeper
contamination since the conceptual design does not consider
remediation of the deeper aquifer.
The remedial design will consider in detail, ground-water
remedial designs that will best remediate the deeper
acroifer. 3t nay be possible that extraction wells are not
actually screened in the deeper aquifer, but any
contamination above MCLs in the deeper aquifer must be
considered to ensure that it is captured and treated
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25
concurrently with the upper aquifer.
Thus, further delineation of contamination in the deep
aquifer is required.
15. Proposed Plan Reference: p.17, Alternative 8-4, first
paragraph
ERK: The need for treatability testing and the fact that
this is an emerging technology should be included.
EPA Response: See comment B.5.
16. Proposed Plan Reference: p. 18, last paragraph, to p. 19,
Alternative GW-3
ERM: The comments presented above for pp. 15 to 16,
Selection of Remedy for Ground Water, apply here as well.
EPA Response: See comments A.I, B.7, B.9, B.10, B.ll, B.12,
B.13, and B.14.
17. ERM Comment: The issue of institutional restrictions for
the site is not included in the PRAP. Because the ground
water will not be remediated in the foreseeable future,
institutional measures such as deed restrictions will be
necessary to ensure that no land use will ever occur which
is incompatible with site conditions. These restrictions
are also necessary to ensure that the integrity of any on-
site remedial actions is maintained and that the property is
not used in a way that would create environmental problems
in the future. For example, if a long-term ground water
recovery system was installed, as proposed by EPA, deed
restrictions would be necessary to ensure that future land
uses would not contribute new contaminants to the ground
water. As shown in the site F6, institutional restrictions
are needed under any of the remedial alternatives.
EPA Response: Institutional controls will be imposed until
the ground water achieves drinking water standards.
18. The cost estimates presented for the ground water recovery
scenarios assume a 30-year period of operation. Zt is ERM's
opinion that a recovery effort of as long as 30 years'
duration is not necessary. The F8 has shown that MCLs for
metals are highly unlikely to have been achieved in that
time frame; thus achieving MCLs is not a feasible goal for
the operation of the recovery system. Eowever, protection
of the Great Egg Earbor River is an achievable goal that is
c*nsble of being met by both the system's presented ir. the FS
and in the EPS. As discussed in the FS, protection of the
river may be obtained in a shorter period than 30 years,
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26
thus providing equivalent protectiveness at a lover cost
that the 30-year system.
EPA Response: EPA maintains that the goal of the ground-
water remediation system is to return the ground water to
its beneficial uses. It is premature and inappropriate to
provide a contingency at this time because insufficient
information does not exist which would indicate that the
goal cannot be achieved.
Furthermore, to equate a long period of treatment with the
inability to achieve the cleanup goals is erroneous. Even
if 30 years or longer of ground-water treatment are required
to achieve cleanup goals, EPA's preference is to return the
ground water to beneficial use.
At this time it is uncertain how long would be required to
return the aquifer to drinking-water quality and the river
to meet ARARs. The system will be carefully monitored on a
regular basis and adjusted as warranted by the performance
data.
C. Summary of Comments raeaivad from Tba Pinelands Commission
(refer to complete letter in Appendix C)
The Commissions generally agrees vitb EPA's preferred
alternatives for remediation of soils, sediments, sludges,
tankers and buried drums and additional river sampling.
s proposal to treat contaminated ground water to Beet
drinking-water standards, however, is not acceptable. The
Commission believes that this proposal would not comply with
the nondegradation standard of the New Jersey Comprehensive
Management Plan which requires that BO development ba
permitted which degrades surface- or ground-water quality.
The Commission believes that the nondegradation standard
should be the goal of ground-water remediation.
As the ground-water plume has bean idantifiad as the source
of contamination of the Great Egg Earbor River surface water
and sediments, the remedial goals for ground water Bust
consider the affaeta of the plume on the river. Tha state's
surface-water standards within tba Pinelands require that
surface water must ba maintained at its existing quality or
that quality necessary to protect the designated uses of the
river.
EPA Response: EPA's proposed cleanup action should not be
considered new development which may degrade water quality
in tho ?iv.e? inds. Rather, the grovnd water in the aquifer
underlying the Site is contaminated as a result of improper
hazardous waste disposal. By extracting and treating this
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27
ground water, the water-quality will be significantly
improved. For this reason, EPA does not believe that the
nondegradation objective of the Pinelands CMP is an
applicable requirement.
In addition, the ground water underlying the Site is
considered to be Class GW2. Accordingly, drinking water
standards-, or Maximum Contaminant Levels (MCLs) established
under the New Jersey Safe Drinking Water Act, N.J.A.C. 7:10-
16.7, are the applicable cleanup standards for the Site.
Concerning the potential adverse impacts to the Great Egg
Harbor River, EPA agrees that further information is needed
to characterize present contaminant levels more completely
and assess the impact of the ground-water treatment system
on the river. Monitoring will be conducted during Remedial
Design and during the operation of the system for this
purpose. If .it is determined during operation of the system
that the river is being degraded by site-related
contamination, the river will be addressed as a separate
operable unit. Appropriate remedial alternatives, including
additional treatment of the ground water will be evaluated,
to ensure that the remedial action is protective of the
river and will meet river ARARs.
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Appendix A
Proposed Plan
Public Notice
Public Meeting Attendance Sheet
Notice of Public Comment Extension
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KING OF PRUSSIA TECHNICAL CORPORATION SITE
Winslow Township, New Jersey
PROPOSED REMEDIAL ACTION PLAN
July 1990
PURPOSE 0? TEE PROPOSED PLAN ;
I
This document flescribes the preferred alternatives for
remediation of contaminated ground water/ sludges and soils at
the Xing of Prussia (KOP) Superfund site in Winslow Township,
Camden County, New Jersey. It also describes the preferred
remedial alternatives for the drainage swale adjacent to the
site.
The plan was developed by the U.S. Environmental Protection
Agency (EPA) in conjunction with the New Jersey Department of
Environmental Protection (NJDEP). The plan also outlines all of
the remedial alternatives which were evaluated and the rationale
Site MOD
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that EPA used to Bake the preliminary selection. The preferred
remedial alternatives are primarily based on four key documents:
- the Remedial Investigation (RI) report which
characterizes the nature and extent of the
contamination present,
- the Endangerment Assessment (EA) which addresses
potential impacts to human health and the environment,
- the -Feasibility Study (FS) report which describes
how the various remedial alternatives were
developed and evaluated, and
- a Supplemental Feasibility Study (SFS), a companion
document to the FS, which describes additional remedial
alternatives to those presented in the FS.
The proposed plan is being distributed, along with the RI, EA,
Draft Final FS and SFS reports to solicit public comment
regarding the most acceptable methods to remediate the
contaminated sludges, soils, sediments and ground water at the
King of Prussia site. Detailed information on all of the
material included in the proposed plan may be found in these
reports. The documents listed above have been placed at the
following information repositories:
* vinslov Township Municipal Hall
Route 73
Braddock, New Jersey 08073
(609) 567-0700
* Camden County Library
Echelon Urban Center
Laurel Road
Voorhes, New Jersey 08043
(609) 772-1636
Additional documentation regarding the remedy selection is
available in the administrative record for the cite. The
administrative record is being established at the Camden County
Library, Echelon Urban Center, Laurel Road, Voorhes, New Jersey
08043.
COMMUNITY ROLE IK SELECTION PROCESS
EPA relies on public comment and discussion to ensure that the
problem being addressed and the remedial alternatives being
evaluated for each Superfund site are fully understood, and that
the needs of the local community have been considered. To this
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end, this Proposed Remedial Action Plan (PRAP) is being
distributed to the public. EPA is providing a 30-day public
comment period to give the local community an opportunity to
have input into this selection process. During this period EPA
staff will visit the community to discuss the PRAP, RI, TS and
STS, and to answer questions. The Agency will hold a public
meeting on August 1, 1990 at the Winslov Township Municipal Hall
on Route 73 in Braddock, New Jersey.
Written and verbal comments on the PRAP and the RI, FS and SFS
reports will be welcomed through August 15, 1990 and will be
documented by EPA in the subsequent Record of Decision (ROD), the
formal document that describes the selected remedy.
All written comments should be addressed to:
James Hahnenberg
Project Manager
U.S. Environmental Protection Agency
Room 720
26 Federal Plaza
New York, NY 10278
It is important to note that while the option described herein is
IPA's preferred alternative for this site, the final decision
will be made only after consideration of all comments received
during the public comment period on any of the remedial
alternatives addressed in the PRAP, the FS and SFS.
SITE BACKGROUND
The site, approximately ten acres in size, is in a rural area
within the Pinelands National Reserve. It is also adjacent to
the State of New Jersey's Winslow Wildlife Refuge. The nearest
residence is a single family home approximately one mile
northeast (upgradient) of the site. The Great Egg Harbor River,
located approximately 1000 feet southwest and downgradient of the
site, is used for recreational purposes and has been proposed as
a Nationally designated Wild and Scenic River. A swale, which
drains most of the site runoff, lies between the site and the
river. Stressed vegetation and trees have been observed in the
upper swale area and is believed to be caused by aetals-
contaminanted runoff from the site.
The King of Prussia Technical Corporation purchased the site from
Winslow Township in 1970 to process and recycle hazardous waste.
Six lagoons were used to process liquid industrial waste with the
intention to convert these wastes to useful chemicals and
construction materials. Sometime between 1973 and 1975
cperatit" « ceassr? and the site was ab*ndo;isd. In 1976, Winslov
Township foreclosed on the property and resumed ownership because
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the company failed to pay taxes.
Records indicate that six lagoons were originally utilized for
industrial waste processing. Three of the lagoons are still
evident, and a fourth nay be identified by a slight depression.
These lagoons are located in a slightly elevated area near the
center of the property (refer to Site Map).
Two rusting and torn tankers are lying on a concrete pad between
Piney Hollow Road and the lagoons on the southeast part of the
site. Toward the back of the cite is an area with an
undetermined number of buried drums and containers. The cite has
sandy soil and is mostly barren of vegetation.
The site property was fenced in July 1988 to restrict access and
prevent the public from coming into direct contact with the
contaminants. The fence was also installed to prevent illegal
dumping.
Buried plastic containers (carboys) and surrounding coils with
visible contamination, located inside the fence west of the
lagoons, were excavated and containerized by EPA in September
1989. Final removal and off-site disposal of these materials is
anticipated to occur during the fall of 1990.
Currently, EPA is evaluating the removal of buried drums and
aboveground tanXers.
In April 1985 EPA entered into an Administrative Order on Consent
with five Potentially Responsible Parties (PRPs) to conduct the
RI and FS activities. In 1988 and 1989, EPA identified
additional PRPs bringing the total number of PRPs to fourteen.
EPA's search for additional PRPs is continuing.
RZKTDIAI INVESTIGATION SUMMARY
The RI for the XOP cite was conducted in two phases, with the
final report approved in August 1989. The first phase wac
completed in July 1987, at which time EPA determined that
sufficient data and information had not been obtained to
characterize site-related contamination adequately. In March
1968, EPA requested that the PRPs initiate a cecond phaee of the
investigation to provide additional information on contaminant
source areas and more complete definition of aquifer
contamination. On September 19, 1989, EPA representatives Bet
with local citizens and interested parties to present the
findings of the RI.
The objectives of the RI were to: characterize the nature and
extent of contamination associated with the site, identify off-
site contdzinazi^n end its impact on the environment anu public
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health, and determine the need for remedial measures to mitigate
the impact of the cite on public health and the environment.
These objectives were net by examining all available information
regarding the site and by performing field investigations to
gather additional data.
The following tasks were accomplished during the RI:
- Pre-existing geological, geophysical, hydrological and
chemical information were reviewed and evaluated.
- Two hundred and ten test pits and boreholes vere drilled/dug
to sample soils, sediments and sludges to determine the
types and concentrations of contamination.
- Twenty-seven monitoring wells and one observation well were
installed to define the site geology and determine the types
and concentrations of contaminants in the ground water.
- Conductivity, magnetometer and resistivity surveys were
conducted to determine the location of areas with potential
contamination.
- Surface-water and stream-bottom sediments were sampled at
fourteen locations to characterize contamination in the
Great Egg Harbor River.
- The contents of tankers, a buried drum and carboys vere
sar.pled and analyzed.
The findings of the RI report are as follows:
- Lagoon sludges and soils adjacent to the lagoons indicated
high concentrations of chromium, copper, nickel and zinc as
veil as other metals. These are contaminant source areas
for metals concanination detected in the upper aquifer.
- Silty sediments in the portion of the swale upslope from the
fire road also showed high concentrations of chromium,
copper, nickel and zinc as well as other metals. This is
believed to be a source of metals contamination in the upper
aquifer.
- Carboys and tankers contents were found to have high levels
of chromium, copper, nickel and zinc as veil as other
metals.
•.
- A sample analysis from a buried drum located in the rear
(northwest) of the site indicated high concentrations of
volatile and! ss^i-volatile organic corpovmds above cleanup
levels. L-''.-. te3 L^wpling indicates soils in this area had
significant concentrations of volatile organic compounds.
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This area is believed to be the source for organic
contamination of the ground water.
Two aquifers within the Xirkwood-Cohansey Aquifer System
were identified at the KOP cite. The upper aquifer begins
15 feet below the surface and extends to approximately 35
feet. A second aquifer extends downward from 50 feet below
the surface to an undetermined depth. A 10 to 30-foot semi-
confining, layer composed primarily of silt and clay
separates the two aquifers.
The highest levels of ground-water contamination have been
identified in the upper aquifer. Metals, including
chromium, copper and nickel were identified at
concentrations in excess of acceptable Federal and State
levels established under the Safe Drinking Water Act. The
upper aquifer also contained volatile organic compounds.
Some metals contamination has been identified in the lower
aquifer.
Ground-water contamination has migrated toward the Great Egg
Harbor River, with contaminants in the upper aquifer
discharging to the river. The highest contaminant
concentrations have not reached the river and are
approximately 500 feet east of the river. The deeper
aquifer is not believed to discharge a significant volume of
water to the Great Egg Harbor River.
The Great Egg Harbor River has low levels of metals
contamination in both the sediments and the surface waters.
The upper aquifer is believed to be the source of these
metals into the river. No organic compounds were detected
above background levels in surface water or in river
sediments.
SDXK&RY 07 Bill. RISKS
An Endangerment Assessment (EA) was conducted by EPA to determine
risks presented by hazardous substances at the site. Indicator
chemicals from each media were selected to ensure that
representative contaminants from all exposure routes at the site
would be evaluated.
The following exposure routes were assessed: 1) breathing dust
contaminated from site soils and swale sediments; 2) ingestion
of site soils, sludges and swale sediments; 3) skin contact with
contaminants in the groundwater, site soils and sludges, and
swale sediments; 4) drinking the groundwater at the site; 5)
inhalation of conta-fnants volatilizing from ground water during
/»> '.:-r:.••;•;; av,d *; «sd-;j.:Vj r!f;* froa th- Great Egg H^ibjr River.
rhcj-e analyses indicate vhat the greatest risks to human health
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at the site are from ingesting site soils, sludges and swale
sediments, and from drinking the groundvater.
Hunan health risks from soil ingestion are calculated to have a
Hazard Index of 3.7. A Hazard Index greater than 1 is considered
to exceed the maximum recommended exposure. The soil remediation
proposed in this plan will reduce human health risk to a Hazard
Index of less than 1.
The cancer risk from drinking contaminated ground water is 2.4 x
103 although presently there are no users of the ground water in
the proximity of the site. The proposed remedial activities will
reduce contaminant concentrations to Maximum Contaminant Levels
(MCLs) which are drinking water standards.
The RI indicates metals contamination may present a threat to
stream biota due to metals contamination in the sediments and
possible bioaccumulative effects. Additional data on contaminant
concentrations and biologic effects are necessary.
SCOPE AND BOLE OF PROPOSED RESPONSE ACTION
AKD SUMMARY OF REMEDIAL ALTERNATIVES EVALUATED
Due to the vide variety of contaminants and multiple migration
routes presented at the KOP site, EPA has divided the site into
the five components listed below to effectuate a more protective
remedial action. The alternatives considered for each of these
components are based on those evaluated in the FS, which was
initiated during the spring of 1989, and the SFS conducted by the
EPA during the spring of 1990.
Component 1:
Metals-contaminated soils adjacent to lagoons, sludges in
lagoons, and sediments in the swale.
Component 2:
Buried drums and soils contaminated with volatile organic
compounds located toward the rear (northwest) of the site.
Component 3:
Tankers and contents located near the front (southeast) of the
site. Soils under and adjacent to the tankers will be addressed
as part of Component 1.
Component 4:
Organic and metals contaminated ground water.
Component 5:
Surface waters and sediments of the Great Egg Harbor River.
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8
SPECIAL EPA INSERT
SUMMARY OF ALTERNAT1VESEVALUATED
The Superfund lav requires each site remedy selected to be
protective of human health and the environment, and in accord
with statutory requirements. Permanent solutions to
contamination problems are to be achieved wherever possible.
The following provides a description of all remedial alternatives
evaluated for the King of Prussia Technical Corporation Site.
The numbers assigned to the alternatives correspond to those used
in the F5 and SF5 reports.
COMPONENT 1- XJBTAL8 CONTAMINATED SOILS, SEDIMENTS AKD SLUDGES
The objective of Remedial Component 1 is to achieve removal of
contaminants from site soils, lagoon sludges and swale sediments
that do not meet cleanup standards developed during the FS.
These standards were developed based on risk to public health.
Although these standards are not considered applicable or
relevant and appropriate requirements (ARARs), cleanup to these
levels will ensure that the contaminants do not continue to
migrate into the ground water and risks to recreational users or
inhabitants at the site are reduced to an acceptable level.
ALTERNATIVE S-l: NO ACTION
Construction Cost: 0
Annual O&M Costs: $7,000
Present Worth: §79,000
Months to Implement: 2
The No Action alternative for metals-contaminated soils, sludges
and sediments provides a baseline against which other
alternatives may be compared. No remedial activities would be
performed but long-term ground-water monitoring would be
conducted. Potential health risks would not be reduced as there
would be no reduction in toxicity, nobility or volume of metals
contaminants in the soils, sediments and sludges.
ALTERNATIVE S-2: LIMITED ACTION
Construction Cost: $43,000
Annual O&K Costs: $9,000
Present Worth: $144,000
Months to Implement: 6
for mitals-contandr.ated soils
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consists of site and deed restrictions, additional fencing around
the svale and long-tern ground-water monitoring. Potential
public health risks would be somewhat reduced by limiting access
to contaminated soils, sediments and sludges. However, there
would be no reduction in toxicity, nobility or volume of metals
contaminants in the soils, sediments and sludges. Contaminants
from these materials would also continue to migrate to the ground
water and eventually discharge to the Great Egg Harbor River.
This would pose minor risks to current recreational users and
higher risks to future users when higher concentrations of
contaminants are anticipated to reach the river.
ALTERNATIVE S-3: LIMITED EXCAVATION OF SEDIMENTS AND SOILS;
CONSOLIDATION; CAPPING
Construction Cost: $1,550,000
Annual O&M Costs: $17,000
Present Worth: $1,740,000
Months to Implement: 12
This alternative consists of excavation and consolidation of
1,000 cubic yards of svale sediments and 350 cubic yards of site
soils outside of the area to be capped. These materials would be
consolidated in the lagoons and adjacent area followed by
installation of a multi-layer cap covering 2.6 acres. Long term
ground-water monitoring would also be conducted to determine
contaminant degradation and/or migration. Potential health risks
would be reduced by eliminating direct contact with these
materials, but there would be no reduction in toxicity or volume
of metals contaminants in the soils, sediments and sludges.
Migration of contaminants from these materials to the ground
water would be reduced but not eliminated.
ALTERNATIVE S-4: COMPLETE EXCAVATION OF SOILS, SEDIMENTS AND
SLUDGES; CONTAMINANT EXTRACTION; REDEPOSITION ON SITE
Construction Cost: $8,050,000*
Annual O&M Cost: 0
Present Worth: $8,050,000*
Months to Implement: 16
This consists of excavating and treating 20,150 cubic yards of
contaminated soils, sediments and sludges in a multi-stage soil
washing/extraction process which reduces the concentration of
contaminants so that they are no longer hazardous. Treated
materials would be redeposited to their approximate former
locations. Contaminants would be removed from treated materials
and the site would be restored for unrestricted use.
Note: Costs presented here were developed in the SFS; EPA
believes thos,? o^sts to be a more realistic f>si iisate than ccrtE
presented for this Alternative in the FS.
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10
ALTERNATIVE S-5: IN SITU STABILIZATION/SOLIDIFICATION;' CAPPING
Construction Cost: $3,182,000*
Annual O&M Costs: $10,000
Present Worth: $3,336,000*
Months to Implement: 18
This alternative consists of excavation and consolidation of
1,000 cubic yards of swale sediments and 350 cubic yards of cite
soils outside of the area to be treated and capped. The area of
consolidation, stabilization and capping includes a 2.6-acre area
of the lagoons and adjacent area toward the rear of the cite.
After consolidation, in citu ctabilization would be performed
using a system of injection and mixing augers and a multi-layer
cap constructed. Mobility of contaminants would be reduced;
treated materials could then be rendered "non-characteristic."
Long-term ground-water monitoring would be required and cite
access restricted.
Note: Costs presented here were developed in the SFS; EPA
believes these costs to be a more realistic estimate than costs
presented for this alternative in the FS.
ALTERNATIVE S-5a: COMPLETE EXCAVATION OF SOILS, SEDIMENTS AND
SLUDGES; STABILIZATION/SOLIDIFICATION; CAPPING
Construction Cost: $5,402,000
Annual O&M Costs: $10,000
Present Worth: $5,555,000
Months to Implement: 18
This alternative is similar to S-5, except all contaminated
soils, sediments and sludges would be excavated and stabilized
above ground. After excavation and consolidation these materials
would be mixed with cementing and stabilizing agents to create a
structurally strong and inert matrix. A multi-layer cap would
then be constructed over a 2.6-acre area over the lagoons and
adjacent area. Long-term monitoring would be required and cite
access restricted.
Note: This alternative ic presented in the SFS.
ALTERNATIVE S-6: COMPLETE REMOVAL; OFF-SITE DISPOSAL
Construction Cost: $11,500,000
Annual O&M Costs: 0
Present Worth: $11,500,000
Months to Implement: 12
This elter.'at .ve consists of the removal and off-site disposal at
a permittee facility cf 20,150 cubic yards of untreated
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11
contaminated soils, sludges and sediments. All soils/ sludges
and sediments above action levels would be removed from ..the site,
replaced with clean fill and revegetated.
COMPONENT 2- BURIED DRUXfl AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
The objective of Remedial Component 2 is to achieve removal of
drums and contaminated adjacent soil.
ALTERNATIVE DR-1: NO ACTION
Construction Cost: $0
Annual OtM Costs: $7,000
Present Worth: $79,000
Months to Implement: 2
The No Action alternative for organically contaminated soils in
the buried drum area provides a baseline against which other
alternatives may be compared. The number and condition of buried
drums would remain undetermined and contaminants would continue
to migrate into the ground water.
Note: This Alternative is identical to Alternative BD-1
presented in the FS.
ALTERNATIVE DR-2: DRUM REMOVAL AND OFF-SITE DISPOSAL; SAMPLING
AND ANALYSIS OF SOILS
Construction Cost: $386,000
Annual OiM Costs: $0
Present Worth: $386,000
Months to Implement: 12
This consists of drum removal and off-site disposal followed by
sampling and analysis of nearby soils. The volume of materials
that would require off-site treatment and disposal is estimated
to be approximately 250 cubic yards. Follovup soil sampling and
analysis will define contaminant types, concentrations and soil
volumes that nay require remediation. If further remediation of
soils in the area of buried drums is necessary, a focused
Feasibility Study will be conducted to evaluate remedial
alternatives. This Feasibility Study nay include treatability
testing as there would be a preference for treatment in
remediating the organically contaminated coils.
Note: This alternative is presented in the 5FS.
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12
COMPONENT 3- TANKERS AND CONTENTS
The objective of Remedial Component 3 is to achieve renewal of
tankers and contents. Contaminated soils under and adjacent to
the tankers would be addressed as part of Component 1.
ALTERNATIVE TK-1: NO ACTION
Construction Cost: $0
Annual 04M Costs: $0
Present Worth: $0
Months to Implement: 0
This alternative does not require any remedial activity.
ALTERNATIVE TK-2: TANKER REMOVAL AND OFF-SITE DISPOSAL
Construction Cost: $22,000
Annual OiM Costs: $0
Present Worth: $22,000
Months to Implement: 2
This consists of removing the tankers and contents and their
disposal at an off-site facility. This would permanently reduce
mobility, toxicity and volume of tanker wastes at the cite. This
would eliminate risks posed by this source area.
COMPONENT 4- GROUND WATER
Ground-water extraction scenarios were designed for aquifer
restoration and to prevent migration of contaminated ground water
to the Great Egg Harbor River.
ALTERNATIVE CW-1: NO ACTION
Construction Cost: $0
Annual OiM Costs: $11,000
Present Worth: $122,000
Months to Implement: 2
The No Action alternative provides a baseline against which to
cor.pare other alternatives. This alternative Includes sampling
existing monitoring wells installed during the remedial
investigations to conduct long-term monitoring of ground-water
contaminants. The Great Egg Harbor River would also be sampled
to determine current and future levels of contamination in the
river.
V.7~.»'ATIVE GW-?r LIMITED ACTION
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13
Construction Cost: $0
Annual OiM Costs: $11,000
Present Worth: $122,000"
Months to Implement: 6
This alternative is the same as GW-1 with the addition of
institutional controls such as deed and/or zoning restrictions to
prevent use of contaminated ground water at the site.
ALTERNATIVE CW-3*: GROUND WATER PUMPING, TREATMENT AND
RZINJECTION WITHIN THE PLUME
Construction Cost: $2,043.000
Annual OiM Costs: $285,000
Present Worth: $6,431,000
Months to Implement: 360
This alternative involves pumping ground water at 240 gallons per
minute from extraction wells southwest and downgradient from the
site to capture the contaminant plume. This will capture
contaminated ground water currently discharging to the Great Egg
Harbor River. Extraction would be followed by treating the
ground water to drinking water standards. Treated water would be
reinjected to the aquifer at 240 gallons per minute until
contaminants in the aquifer fall below ARARs.
' Note: Alternative GW-3 discussed above is a modification of
the design presented in the FS; additional information can be
found in the SFS.
ALTERNATIVE GW-4*: GROUND WATER PUMPING, TREATMENT AND DISCHARGE
TO THE GREAT EGG HARBOR RIVER
Construction Cost: $2,766,000
Annual OtK Costs: $406,000
Present Worth: $9,016,000
Months to Implement: 360
This alternative involves pumping ground water at 460 gallons per
minute from extraction wells southwest and downgradient from the
site. This will capture contaminated ground water currently
discharging to the Great Egg Harbor River. Extraction would be
followed by treating the ground water to drinking water standards
and then discharged to the Great Egg Harbor River until
contaminants in the aquifer fall below ARARs. This would require
a waiver of Pinelands regulations that restrict surface water
discharge.
* Note: Alternative GW-4 discussed above is a modification of
the design presented in the TS; additional information can be
found in the SFS.
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14
COMPONENT 5- BURPACE WATERS AND SEDIMENTS OF TEE GREAT BOG HARBOR
RIVER
Sampling and analysis of the Great Egg Harbor River's surface
waters and sediments will further characterize contaminants
concentrations and distribution in the river. This will include
biological sampling to evaluate organisms responses to changes in
the river environment related to contamination. A determination
vill then be made if remediation of the Great Egg Harbor River
waters and/or sediments will be necessary. Costs and detailed
discussion of this alternative are included as part of the
Component 4 cost and discussion of ground-water alternatives in
the T3 and SFS.
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15
Frefenefl Alternatives
After careful consideration of all reasonable alternatives, EPA
proposes utilizing the following alternatives for the remedial
action for the KOP cite:
COMPONENT 1- KETALS CON7AKIKATED BOILS, SEDIMENTS AMD SLUDGES
ALTERNATIVE S-4: COMPLETE EXCAVATION; CONTAMINANT EXTRACTION;
REPLACEMENT ON SITE
This consists of excavation of Betels-contaminated coils that do
not iceet the cleanup objectives in the area adjacent to the
lagoons, sediments in the svale and sludges in the lagoons.
Extraction of metals contaminants will continue until the cleanup
objectives are met. This alternative will reduce human health
risks to a protective Hazard Index of less than 1. After
excavation, these materials would be consolidated and contaminant
extraction would be performed in a multi-stage batch process.
The treated soils, sediments, and sludges would then be
redeposited in their original locations after meeting the cleanup
objectives.
COMPONENT 2- BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
ALTERNATIVE DR-2: DRUM REMOVAL AND OFF-SITE DISPOSAL; SAMPLING
AND ANALYSIS OF SOILS
This consists of removal and off-site disposal of the buried
druirs and visibly contaminated coils followed by campling and
post-removal analysis of nearby coils to define types and
concentrations of residual contaminants. Thic will provide a
complete characterization of coils contamination and volumes that
may require further remediation. If further remediation is
warranted, a focused feasibility ctudy will be conducted to
evaluate remedial alternativec.
COMPONENT 3- TANKERS AND CONTENTS
ALTERNATIVE TK-2: TANKER REMOVAL AND OFF-SITE DISPOSAL
This involves removing the tankers and their contentc for off*
site disposal.
COMPONENT 4- GROUND WATER
ALTERNATIVE CW-3: GPOVND WATER PUMPING, TREATMENT AND
REISJECT'ON
This involves pumping the contaminated ground water fron the
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16
upper aquifer and treating to MCLs. -.Treated ground water would
be reinjected into the aquifer. This process will continue until
MCLs are achieved in the aquifer. The treatment system will also
prevent contaminants in the upper aquifer from discharging into
the river. Additional nonitoring wells will be required to
provide data to define nore completely the vertical extent of
contamination. The pumping, treatment and reinjection design nay
need to be modified, if data indicate contamination in the deeper
aquifer.
COMPONENT 5- SURFACE WATER AKD 8EDIMZNT8 07 TEE GREAT BOG HARBOR
RIVER
Additional sampling of the Great Egg Harbor River's surface
waters and sediments will be conducted to define contamination
more completely, assess biological impacts and to monitor future
contaminants concentrations in the river. This information will
be used to determine if remediation of the Great Egg Harbor River
waters and/or sediments will be necessary. Costs and detailed
discussion are presented in the ground-water alternatives in the
TS and SFS.
Rationale for Selection
The nine criteria used to evaluate all remedial alternatives fall
into four categories: environmental/public health, compliance
with required cleanup standards, technical performance and cost.
In addition, the selected remedy should result in permanent
solutions and should use treatment to the maximum extent
practicable. The criteria are summarized below:
- Overall protection of human health and the environment
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.
- Corcpllance with ARASs 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 basic for a waivar.
- 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 Bet.
- Reduction of toxieity, mobility or veluwe is the
anticipated pfcrfersanc* of the remedy in terms of reducing
the ucxicity, mot.lity or volume of the contaminants of
-------
18
cite hazardous landfill cites, and costliness. Moreover./
excavation and disposal would not neet the statutory preference
for a remedy that involves treatment as a principal element.
COMPONENTS 2- BURIED DRUMS AND SOILS CONTAMINATED WITH VOLATILE
ORGANIC COMPOUNDS
ALTERNATIVE DR*2: DRUM REMOVAL AND OFF-SITE DISPOSAL;
Removal and off-site disposal of drums would be effective and
permanent in removing risks to recreational users and any
inhabitants of the site. It would also eliminate the major
source of organic contaminants migrating to the aquifer.
Additional characterization of coils contamination will provide
the basis to determine if additional action ic required.
The No Action Alternative would offer no reduction in toxicity,
mobility or volume of contaminants in the drums. Deterioration
of the drums could result in increased levels of contamination
being released to soils and the ground water.
COMPONENT 3- TANKERS AND CONTENTS
ALTERNATIVE TK-2: TANKER REMOVAL AND OFF-SITE DISPOSAL
Renoval of tankers and their contents would be effective and
permanent in removing risks to any recreational users and any
inhabitants of the site.
The No Action Alternative would offer no reduction in toxicity,
mobility or volume of contaminants in the tankers. Deterioration
of the tankers could result in increased levels of contamination
being released to soils and the ground water.
COMPONENT 4- GROUND WATER
ALTERNATIVE CW-3: GROUND WATER PUMPING, TREATMENT AND
REINJECTION
The pumping of contaminated ground water from the upper aquifer
until required cleanup levels are net, and the treatment of the
ground water to drinking water ctandardc (MCLs), followed by
reinjection to the upper aquifer will be protective of human
health and the environment. Long-term effectiveness and
permanence would be achieved once the ground-water cleanup level
is reached. Toxicity, mobility and volume of the ground-water
cortarinar.ts wculd bt reduced, and discharge of ground-water
contaminants to the Great Egg Harbor River would be eliminated.
-------
17
concern in the •nvironment.
- Short-tern effectiveness and jpermanence addresses the
period of tine needed to achieve protection, and any adverse
impacts to human health or the environment that say be posed
during the construction and implementation period until
cleanup goals are achieved.
- Inpleneritabilitv refers to the technical and v
administrative feasibility of implementing a remedy,
including availability of materials and services required to
implement a particular option.
- Cost includes estimated capital and operation and
maintenance costs of the remedy, and the net present worth
cost.
- State Acceptance indicates whether, based on its review of
the RI and F5 and the Proposed Remedial Action Plan (PRAP),
the state concurs with the preferred alternative.
- Coimunitv Acceptance will be assessed in the Record of
Decision following a review of the public comments received
on the RI, F5 and 5FS reports and the Proposed Plan.
EPA in consultations with NJDEP, is required to select the
remedial alternatives which offer the best balance among the nine
criteria. The manner in which the preferred alternatives meets
the criteria are presented briefly below. Community comments and
acceptance are being solicited at this tine.
COMPONENT 1- METALS-CONTAMINATED SOILS, SEDIMENTS AND SLUDGES
ALTERNATIVE S-4: COMPLETE EXCAVATION; CONTAMINANT EXTRACTION;
REPLACEMENT ON SITE
Excavation of metals-contaminated soils, sediments and sludges
and extraction of metals contaminants would be effective and
permanent in removing risks to recreational users and any future
inhabitants of the site. This soil alternative permanently
removes contamination, completely restores the site and allows
for future unrestricted use. Toxicity, nobility and the volume
of contaminants would be reduced once cleanup goals are met.
Human health risks would be reduced to a Hazard Index of lass
than 1.
Competing alternatives such as stabilization/solidification or
containment are less attractive because they do not remove
cor.taitinant.s and would limit future use of the site. In
j-idition, ether Alternatives s-c.i as excavation and disposal nay
not be implecentacle due to the uncertainties of available off-
-------
19
The ground water would be returned for use as a potable, water
source.
This remedy is highly implementable because reliable commercial
operations are available for pumping and treatment. The cost for
this alternative is reasonable relative to the protectiveness of
this remedy.
Competing alternatives such as No Action or Limited Action are
less attractive because contaminants will not be removed and will
continue to discharge to the Great Egg Karbor River. Furthermore,
alternatives such pumping, treatment and discharge to the river
may not be implementable due to regulatory restrictions (e.g.,
pumping, treatment and discharge to the river).
COMPONENT 5- SURFACE WATER AND SEDIMENTS 07 TEE GREAT EGG EARBOR
RIVZR
Additional sampling and analysis of surface waters and sediments
of the Great Egg Harbor River will allow a determination on
whether further remediation of the river system may be necessary
to protect the public health and environment. The monitoring
program is included in the ground-water alternatives in the F5
and SFS.
SUMMARY
The preferred alternatives represent the best balance among the
criteria used to evaluate remedial actions. Based on the
information available at this time, EPA believes that the
preferred alternatives would be more protective than competing
alternatives, attain ARAF.s, be cost effective and would use
permanent arid c&rrpiete treatment technologies to the maximum
extent practicable.
Selected Alternatives and Costs are summarized below:
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20
Present
Component Alternative Worth*
1- Metals 5-4: Excavation/Extraction $8,050,000
Contamination and Redeposit
of Soils,
Sediments &
Sludges
2- Buried Drums and DR-2: Drum Removal & Off Site 386,000
Soils Contaminated Disposal/Soil Sampling
vith Volatile and Analysis
Organic Compounds
3- Tankers £ TK-2: Tanker Removal and Off 22,000
Contents .Site Disposal (including
Tanker contents)
4- Contaminated GW-3: Pumping, Treatment and
Ground Water Reinjection into the 6,431,000
aquifer
5- Great Egg Additional Sampling:
Harbor River included in GW-3
ESTIMATED TOTAL COST $ 14,689,000
': Present Worth is the amount of money needed to invest now at a
discount rate of 5% interest in order to have the appropriate
funds available at the time the remedial action is implemented.
-------
KING OF PRUSSIA TECHNICAL CORPORATION SITE
SUMMARY OF REMEDIAL ALTERNATIVES
REMEDIAL
ALTERNATIVE
FRESENT
WORTH
COST
f 1.0001
DURATION
Of REMEDIAL
ACTION rVEARSI
COMMENTS
• COMPONENT ONE (METALS CONTAMINATED SOILS, SEDIMENTS AND SLUDOCS)
1-1: Me Action
C-2: Liaitad Action
(Fencing and Institutional
controls)
t-3: Liait«i Excavation/
Con*elic-*tion/Capping
•-4: Cea;]*ta Kxeavatloa/
zxtractie&/*.*d*poait
•ella OB-m*
S-S: In-Situ Stabilisation
* Soiifi:fic«tion/C*pplnfl
«-S« : Cospittt txovatlon/
5t&t:l:zatlen t
Solidification/Capping
*-4:
0.2 Znadcguat* to protect
feuMJi b*altA and tba
•itvlronMflt.
144
1,740
•,e»e
9,996
1,402
u.»oo
to protect
buB*n bcaltb and tit*
•nvlronacnt.
Halted prot»ctlvan*»i;
not p*nun«nt;
contaminant*- raaaia
aoil
•f
rroteetlv*; eent&alnanta
laeoblll(*d but
en-«lt«;
uncart a in; no reduction
in toxiclty or voltiM;
•it* topography
affected; contaainants
would b« rendered "non-
eharacteriatic.*
Protective; contaainanta
iaaoblllted but remain
on-alte; no reduction
In toxiclty or volute;
ait* topography affected;
eontaalnants would be
rendered •non-
character iatic. •
Protective; permanent;
eontaainanta dlapoaed
eff-alt*; coaplet*
restoration of alta;
blgb relative coat.
-------
REMEDIAL
ALTERNATVE
PRESENT
WORTH
COST
rvoooi
DURATION
OF REMEDIAL
ACTION (YEARS)
• COMPONENT TWO (BURIED DRUMS AND CONTAMINATED SOILS)
»-!*: lie Action 7* 0.2
M-J i fina ItamoTal •
•upllag *
• COMPONENT THREE (TANKERS)
TK-1: Me Action
n-Si Talker teBoval •
Disposal
• COMPONENT FOUR (GROUND WATER)
Cf-i: He Action
CV-2: lisited Action
(Institution*! control §)
0*»I i Doraeradieat
Capture/Treataeat/
ftsiBjectioa
CW-4 : Dovr>sradient
Capture/Treatment/
aac
0.2
it
122
122
t,431
»,016
0.2
•0
COMPONENT FIVE (GREAT EGG HAAdOR RIVER)
All Croundvater AlttmitivM f
>0
COMMENTS
Xna4*quat« to protect
buMn health snd th«
•nviron»«nt.
•aapliag r*«nlt* will
«*t*rmi>* if furtkar !•
to
bum«n health wtd
•nviron»*nt.
•ff •
Xn»d»ffuit« to protect
huain health and the
•nviron>«nt;
Btonltoring of th« Croat
B99 Harbor Rivar
Inadequate to protect
huaan health and
the environment;
B>onltorinfl of the OBOl.
Vreataeat redveea
toEieity? olimiBatoe
ooBtulBUt Civebarge to
the am; •oBiterl»9 of
the
Treatment roduooa
tozicity; eliminates
eontavinant diecharoe
to the CCKIt: waiver of
ourface vater discharge
reatrictiona required:
includes oonitoring of
CttR.
Cupling of the CBOt
ourfaee waters and
•edicentt to provide
additional
eharacteriiation of
contamination; further
remediation will be
eonaiderod.
* Presented in the «f«.
' Identical to Alternative BD-1 presented in the PS.
f Coats include? with CV altemativee.
N »OLD
-------
~. « rwoi»c wiling on the Proposed Remedial
After native* for the King Of Pruwia Technical Corporation Site
Wtntfow Townthip, New Jersey
Tht U.S. EnwronmeniaJ ProtaeBon Aganey (EPA) * oenjunctton «*D> the Mew Jtraay Department of
Environment* Protection Stwdy
(P/r/rsj vid t Supplement*; raaatt*i> Study (SfS) for tnt 09 Of PnaaM Technteei Cbrportton S^
it^wtMehjs toeaiefl.ir^wifgbw Townary. M»* Jnay. Baaed en tha noun of thest tfudm. EPA has
O*x*op6tf t Proootod Aaniedial Action Plan (WlAP) to otsanup tha tnt A Puocc MeaOrtg vKN Dt hold
It u* wrms^ow TowntMp Municipal Mafl. toeatad on Moutt 73 in Bnjddock. Me* Janwy. on Wedne*-
C*j. August 1. 1990 it 7:00 pm to dtocuu trw RtTS, the SFS and to prtoant the PRAP The puWc •
tnvtied to discuu tht PJ/TS rapon. tha SFS and tha PAAP at the pu&ac meeting and to tubmrt oral
ar< wntien eonvntnu to EPA eunr»g tnt put*c eautiern oenod. wttioh eoneuoea on Auoutt is.
1990. PPA ind KJDCP Beicomt the puPAe'i comment! on tf anarnitSet UenPned batow EPA wtil
cneoM tht tirut remedy after the puocc eonvnent penod and* and eonakTUtton *nh MJDEP • eon.
ovoee EPA may mtect an option other than the pertarred *«emits^t present ad'in the PRAP. after
of aff comment* a conducted The totovng oar* tha anamatfxa'. pnaaantad In tht
>, ier me KM Of Pruaata Taehncaf Corporatten Ma.
A/ttmttnrt S>£
Altarnfthrt S4:
Unftatf.
of So*.
and
E*cwTtiori ot Soat,
Sotdmcroon and CappaiQ
^W and!
Drum Removal Attemative
rreOM: MoAcoon
t On*n «ame*a/ and Ofl-Sfta CKepos* and the S«rnpang antf Anar>«i of
a* !ZLeXInkeri af>d
An*rra tnrt TX-1: MO Aeaon
Art»rrvilrre TK-2: Tartar torm« and
Remetffetfon Aftefnatrvet
6roundwat«f RemMittion AJtefnathrtt
Aft*mjlJTf GW-f MoAeaon
QW-i urMaOAcaon
CW-3: Graund^jar puriptio. traaamam
CW-4;
»wcmam and
Caar propoad
to the Onitrt Egg Har-
of the Onwt Fgg Mfc'tor
cam»> eonatdarttton of r« •vrtettar aftarmMB, EPA and
$*t* CompM* Euwvtton. Contmmtunl Extraction and
On»5ita. tar nmadfroun of Iha matan coman*iaiad a
frwn
and Of««» Mpocat. Samptng antf Anafy* of Sottt lor
of tr» p^iod on*r» and aoai oantar*«ad *«m veuata
A/tenvttrrf TK-i Tanur ramo«« and off-afti <
of M
and
of ma tartan and
of ffia Orvct Egg Harftor
Tht puwc car
th»
fha Supptamanaf FS and tha PfUP at
(6O9J M7*O700
IPrWf
M aant fe Mr.
Canter
^^
(•Of) 77*ia4*
K3fc*»
i Tort.
«tha U.S
-------
UNITED BTATBB ENVIRONMENTAL PROTECTION AGENCY
REGION II
POBLIC INFORMATION NBETINO
POR
ATTENDEES
(Pleane Print)
NA
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CITY
ZIP
PHONE
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/*4 i'0** If $'/ At-*7-.'P»..l£(,../1<,^ />/^rX
-------
• •
tfNITCO BTATEOfenriRONNENTAE. PROTECTION AGENCY
O^fenr
I^P>
I.IC I
PUDI.IC INFORMATION MEETING
FOR
^-XJ
ATTENDEES
(Pleane Print)
MAILING
LIST
-------
UNITED BTATE8 ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC INFORMATION MEETING
FOR
<7 '
ATTENDEES
(Please Print)
NAME
STREET
I ¥
*t~tf0*jt sLu,J^ Jf*»*.jL.t^ ato*)'? ^TC/- ?/a?
CITY
ZIP
PHONE
MAILING
REPRESENTING LIST
'71ft
C - A. T«
0*0^ 7C, 7 -
V. / r .. t,/.
-------
90 ( ) Pat Seppi (212)264-9369
FOR RELEASE:
EPA EXTENDS PUBLIC COMMENT PERIOD FOR TEE KING OF PRUSSIA
6UPERFUND SITE
NEW YORK — The U.S. Environmental Protection Agency has extended
the public consent period for the King of Prussia Superfund site
in Kinslow Township, N.J. to Friday, September 14, 1990.
Copies of the Proposed Plan, which discusses the preferred
remedial alternative, as veil as copies of the Remedial
Investigation and Feasibility Study (RI/FS), which discusses the
nature and extent of contamination and evaluated alternatives for
addressing the contamination, can be reviewed at the following
repositories:
Winslow Township Municipal Hall
Scute 73
BraddocX, N.J. 08073
Camden County Library
Echelon Urban Center
Laurel Road
Voorhees, N.J. 08043
All written comments on the RI/FS and the preferred alternative
may be sent to James Hahnenberg, Remedial Project Manager, U.S.
EPA, Region II, Emergency and Remedial Response Division, 26
Federal Plaza, Room 720, New York, NY 10278.
-------
Appendix B
King of Prussia Technical Corporation Site Committee Comments
on the Proposed Plan and Supplemental Feasibility Study
-------
September 14, 1990
VIA FEDERAL EXPRESS
Mr. James Hahnenberg
Project Manager :
U.S. Environmental Protection Agency .
Room 720
2600 Federal Plaza
New York, NY 10278
Mr. George Pavlou
Associate Director for Enforcement Programs
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
Region II
Jacob X. Javits Federal Building
New York, NY 10278
Re: Proposed Remedial Action Plan
King of Prussia Technical Corporation Site
Winslow Township, New Jersey
Dear Sirs:
The following comments are submitted on behalf of the
signatories to the Administrative Consent Order and Agreement dated
April 17, 1985 ("KOP Site Committee") concerning the proposed
remedial action plan dated July 1990 ("PRAP") issued by the United
States Environmental Protection Agency ("EPA") at this site. It
is the Site Committee's understanding that these comments, and
previous correspondence between the EPA and Site Committee
representatives, are part of the administrative record and will be
considered prior to issuance of a record of decision ("ROD").
PROPOSED REMEDIAL ACTION PLAN
ERM COMMENTS
In a letter dated September 14, 1990 to the Site Committee,
its technical consultant, Environmental Resources Management, Inc.
("ERM") has prepared comments on the PRAP which are appended hereto
("Attachment 1"). The members of the Site Committee adopt and
incorporate ERM's comments as their own.
ADDITIONAL COMMENTS
In addition to ERK's comments, the Site Committee submits the
v-tIrving rcrr.Ticr.ts on the TRAP.
-------
Mr. James Hahnenberg
Mr. George Pavlou
U.S. Environmental Protection Agency
September 14, 1990
Page Two
In the Feasibility Study Report dated April 6, 1990, ERM and
the KOP Site Committee recommended selection of Alternative E-2A
as the appropriate remedy for this site. The position of the KOP
Site Committee continues to be that Alternative E-2A should be
selected by EPA. as the remediation plan.
Alternative E-2A calls for the removal and off-site disposal
of drums, the consolidation, soil-vacuuming, stabilization and
capping of contaminated sludges and soils, and institutional
controls, consisting of site access and land use restrictions and
future monitoring, including a five-year groundwater pump and treat
program to assess the effectiveness of the groundvater treatment
approach and appropriateness of the proposed applicable or relevant
and appropriate requirements (ARARs) for groundwater. Alternative
E-2A will be protective of the public health and the environment.
As noted in ERH's comments (Attachment 1), it is unlikely that even
the proposed remedial plan will meet drinking water standards for
metals.
The KOP Site Committee objects to the PRAP as an excessive and
unreasonable remedy in light of the conditions found at this site.
The remedy in the PRAP is not necessary to protect human health or
the environment, not justified by data from the RI/FS, not cost-
effective, not based on proven and reliable remedial technologies,
and not based on realistic remedial objectives. The thirty-year
punp and treat program for groundwater and the contaminant
extraction treatment program for soils depend on remedial
technologies which are not proven or cost-effective. They are not
based upon a realistic assessment of future land uses for this site
or realistic remedial objectives for groundwater. In light of
background conditions and the limited public health and
environmental risks at this site, especially after implementation
of the cth»r remedial components of Alternative E-2A, drinking
water standards are not appropriate requirements for this site or
should be waived. The groundwater and soil component remedies in
the PRAP are not cost-effective or necessary to protect public
health or the environment.
As pointed out in the attached ERM comments, ingestion of
groundwater or soils by residents living on or near the site is an
unlikely and unrealistic exposure scenario. There are no
residences on or in the immediate vicinity of the site, nor are
there any plans for such residential development known to the Site
Committee. In fact, such residential development is unlikely given
existing development restrictions in present laws and regulations
respecting the Pine Barrens, the Wildlife Management Area,
landfills, floodplains and wetlarxfs. With the adoption of
irstitvt ,:•".'! cc -trcis f?r th« site, including lane u&e and site
-------
Mr. Janes Hahnenberg
Mr. George Pavlou
U.S. Environmental Protection Agency
September 14, 1990
Page Three
access restrictions in keeping with the Pine Barrens Protection
District and nearby Wildlife Management Area, the theoretical rick
of harmful human exposure to residually-contaminated soils, even
if any such risk exists after stabilization and capping, can easily
controlled.
Additionally, the KOP Site Committee objects to the PRAP as
not cost-effective. The estimated cost of the PRAP is $14.8
million (Table 1)— almost three times the $5.75 million cost of
Alternative E-2A (Table 4-2 of the Feasibility Study Report). The
KOP Site Committee is not aware of anything in the Remedial
Investigation and Feasibility Study (RI/FS) Reports or
administrative record demonstrating that the expenditure of an
additional $9 million is a cost-effective remedial approach for
this site or will substantially enhance protection of the public
health and the environment. See ERM's attached comments.
Simpler and more cost-effective remedial alternatives
achieving substantially the same objectives have been identified
in the FS Report or are otherwise available, including Alternative
E-2A, which are fully capable of addressing the limited risks at
this site and should be adopted by EPA.
SUPPLEMENTAL FEASIBILITY BTPDY
On April 6, 1990, ERM submitted the KOP Site Committee's final
FS Report to EPA. Subsequently, EPA issued a Supplemental
Feasibility Study ("SFS") Report. To the extent that the SFS
Report is inconsistent with, or fails to incorporate, the comments
and recommendations of the KOP Site Committee's RI/FS Reports, and
other recommendations and comments of ERM, the Site Committee
objects to the findings of the SFS Report.
CONCLUSION
Please accept these comments by the KOP Site Committee and ERM
in the spirit of cooperation to assist EPA in review and selection
of an appropriate .and reasonable remedial plan for this site.
Nothing in these comments should be construed as an admission of
any responsibility, fault or legal liability on the part of the
Site Committee or any of its nembers.
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Mr. James Kahnenberg
Mr. George Pavlou
U.S. Environmental Protection Agency
September 14, 1990
Page Four
Should you have any questions or wish to discuss the natters
set forth above, please do not hesitate to contact the Site
Committee representatives. Thank you for your careful attention
to the views expressed herein.
Respectfully submitted,
Cabot Corporation
Carpenter Technology Corporation
Ford Electronics and Refrigeration
Corporation
Johnson-Matthey Corporation
LKP Corporation
Ruetgers-Nease Chemical Company, Inc.
Attachment
cc: Joseph McVeigh, Esg,
U.S. Environmental Protection Agency
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855 Gpringdaie Drive • Erlon. PtrmcyKnnia 19341 • (215) 524-3500 • Fax On«: 524-7335 • Fax Two: 524 7798
KOP Site Committee
c/o Lynn Wright, esq.
Edwards and Angell
750 Lexington Avenue
New York, NY 10022
14 September 1990
Dear Members of the Site Committee:
Environmental Resources Management, Inc. (ERM) has reviewed
the EPA's Proposed Remedial Action Plan (PRAP) for the KOP site in
Winslow Township, New Jersey. Based on our review of the PRAP,
the EPA's Supplemental Feasibility Study (SFS), and the site
feasibility study (FS), we are submitting a number of comments for
consideration by the EPA in preparation of the final Record of
Decision (ROD) for the site. Cur major comments relate principally
to:
• the EPA's preliminary selection of contaminant extraction
for the Component 1 remedy,
• our continued opinion that on -site stabilization and capping
is appropriate as the Component 1 remedy, and
• inadequate consideration on EPA's part of metals in ground
water when selecting the ground water remediation goals
and system.
Our specific comments on the PRAP are as follows.
• p. 7, 2nd complete paragraph, 1st sentence: "The cancer risk
from drinking contaminated ground water is 2.4 x 10"2,
aJ (Lough presently there are no users of the ground water in the
proximity of the rite,"
This is an oversimplification of the potential risk associated with
drinking contaminated ground water at the site. First, the risk
level of 2.16 x 10*2 is for the maximum VOC concentrations
detected. The risk level based on average concentrations, which
represents the most probable exposure condition, is lower, at 2.5
x 10-3. This is the appropriate risk level to be cited for the
residential use scenario.
An affiliate of tfw Environmental Resource* Management G'oup wflh offices worW*io> ""^^o,^
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KOP Sit* Committee
14 September 1990
Page 2
Second, ERM believes that residential development is not the most
likely future land use at the site. The most plausible future land
use scenario for the site is recreational use, as the site is within
the Pine Barrens, adjacent to a wildlife management area, and
owned by the township. ERM believes that the carcinogenic risk
level from the EA which corresponds to that type of land use
should accordingly be presented as the existing site risk in the
final ROD. That risk level is 4.9 x 10'5.
p. 7,2nd complete paragraph, 2nd sentence: The proposed
remedial activities trill reduce contaminant concentrations to
Maximum Contaminant Levels (MCLs) that are drinking water
standards."
This sentence indicates that MCLs will be achieved via ground
water remediation. While this may be possible for the organic
contaminants, it has been clearly demonstrated in the site FS
that metals in the ground water will not be reduced to the MCLs
in any foreseeable time period. The presentation of thifc concept
in the PRAP results in a misleading oversimplification of the
site ground water remedy, which will create unrealistic public
expectations for the ultimate degree of cleanup.
p. 7,3rd complete paragraph: 'The RI indicates metals
contamination may present a threat to stream biota due to
metals confAmination in the sediments and possible
bioaccumulative effects. Additional data on contaminant
concentrations and biologic effects are necessary."
The EA, not the RI, discusses potential threats to stream biota.
The E.A concluded the* the concentrations of metals detected
f-Zge-si a "minimal potential for adverse efTecte to aquatic
receptors...", noting, however, that no definitive conclusions are
possible with the available data. The EA conclusion of minimal
impact potential is not accurately reflected in the PRAP
language. Furthermore, if the potential for impact is truly
minimal, as concluded in the EA, there should be no need for
additional data collection.
p. 14, Component 5, Surface Waters and Sediments of (he Great
Egg Harbor River; p 16, Selection of Remedy for Component 5:
'Sampling and analysis of the Great Egg Harbor River's surface
waters and sediments will further characterize contaminants
concentrations and di*iribution in the rivw. This tvill include
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bit* Committee
14 September 1990
PageS
biological sampling to evaluate organisms responses to changes
in the river environment related to contamination. A
determination wilJ then be made if remediation of the Great Egg
Harbor River waters and/or sediments will be necessary."
As discussed above, the Bite EA determined that minimal
potential for impacts exists in the Great Egg Harbor River. The
purpose of collecting the RI data was to provide the basis for
preliminary determination of the likelihood of impact. On the
basis of those data, it was determined that long-term protection
of the river would be achieved by removal of metals from the
ground water system via pump and treat technology. Further
remediation of the river would require dredging to remove
metals from the sediments, which would in itself cause adverse
impacts to the river by mobilizing metals in suspension and
destroying benthic habitats. Given the unlikelihood of current
impacts, further remediation by dredging of sediments clearly
represents a greater potential for adverse impact on the river
than does the current condition.
p. 15, paragraph 2: Selection of remedy for Component 1
(Metals-Contaminated Soils, Sediments, and Sludges):
The PRAP selects contaminant extraction for this component of
the site remedy. The FS recommendation was for stabilization
and containment in the former lagoon area. ERM has several
observations regarding the remedy proposed in the PRAP:
Contaminant extraction is an emerging technology which
has not been performed at full scale to any significant
extent. Thus, there are many unknowns associated with
the p^rfcrmsnre cfconUminant extraction, ir-eluding its
ultimate effectiveness. Trealability studies will be required
to determine the degree of effectiveness at the KOP site.
Until such evaluations are done, it is premature to select
this technology as the remedy for Component 1.
No evaluations have been done to determine if this
technology is the most cost-effective method of achieving
protectiveness at the site. Until such evaluations are done,
it is premature to select this technology as the remedy for
Component 1.
• • The contaminant extraction technology would remove the
rne!?l« from the File media and merely transfer them to
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KOP Site Committee
14 September 1990
Page 4
another location, as they are not destructible. Since it is
well documented thtt the site ground water will not likely
be usable for future significant development of the site, no
added value to relocating the site contaminants has been
demonstrated.
Stabilization is a well-established, proven technology for
treatment of metals-contaminated soils and sludges and, as
such, has been designated as Best Demonstrated Available
Technology (BDAT) under the Land Disposal Restrictions.
Stabilization and capping of the soils and sludges on site
would effectively encapsulate the contaminated soils,
preventing both continued leaching to ground water and
direct contact. Thus, under the most reasonable future
land use for recreational purposes, on-site stabilization
with capping is both technically feasible and protective.
Given the factors described above, we believe that on-site
stabilization is the appropriate Component 1 remedy for
application at the site. However, should contaminant extraction
be specified in the final ROD, it should include a requirement for
treatability testing. Given the fact that contaminant extraction
is unproven, such a ROD should also provide for a contingent
on-site stabilization remedy.
p. 15, last paragraph, to p. 16: Selection of remedy for
Component 4 (Ground Water):
The remedy selected is a ground water recovery, treatment, and
reinjection program which was evaluated in the SFS. This
progrem incorporates numerous recovery and injection wells
throughout the ground water ccplprrination plume, with the
intent that ground water remediation will be conducted until the
ground water ARARs are met By contrast, the ground water
remediation program designed in the FS takes into account the
technical constraints shown in the FS to preclude reaching of
metals ARARs using pump and treat technology. The FS design
includes one line of recovery wells located in the area of highest
concentration'in the plume, with the intent that VOCs would be
reduced to either ARARs or to practical minima within a
reasonable period of time, while coincident mass removal of
metals would protect the Great Egg Harbor River over the long
term.
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14 September 1990
Page 5
It is ERM's opinion that the proposed remedy selected in the
PRAP fails to take into account the technical constraints on
reaching metals AKAKs, as described in detail in the site FS.
This results in several issues being inadequately addressed by
the PRAP, including the following.
The'ability of the SFS system design to meet ARARs: The
PRAP assumes that ARARs can be met, while the FS
demonstrates that this will not be the case.
Remedial goals/expectations: The PRAP sets the remedial
goal as attainment of ARARs, which has been
demonstrated in the FS to be infeasible.
Time period to remediation: The PRAP appears to be
inconsistent on the issue of time to achieve remediation.
The SFS design vs. the FS design: The SFS design has been
assumed by the EPA to be superior to the FS design, but
again, this assumption ignores the constraints on metals
removal.
Degree of environmental protection: The PRAP has failed
to consider the deleterious effects on the environment of
installing the more complex SFS system design.
Evaluation of remedy effectiveness: The PRAP has failed to
take into account the need to evaluate the effectiveness of the
ground water recovery system during its operation, the
effects of system design on the evaluation process, and the
effects of the evaluation on reexaming remedial goals.
Consistency of the PRAP with EPA internal guidance on
ground water remedies: The PRAP has failed to follow the
guidance provided in the EPA internal memo of October 18,
1989 regarding evaluation of ground water recovery
systems, flexibility in ground water recovery RODs, and the
need to address contingent remedies and potential waivers
of ARARs in RODs.
These issues are addressed in greater detail as follows.
Ability of tie SFS System to Achieve ARARs
In the modeling performed in the SFS, the ultimate goal of the
ground water recovery program is not clearly defined. The
PRAP indicates the goals of the ground water recovery program
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KOP Site Committee
14 September 1990
PageG
to be attainment of ARARs and prevention of metals discharge to
the Great Egg Harbor River. Like the FS modeling, the SFS
effort was focused on time to remediation of VOCs in the ground
water. Jn theory, the SFS design remediates VOCs more quickly
than the FS design, leading EPA to the conclusion that the SFS
design is superior for the purpose of meeting ARARs. However,
unlike the FS, the SFS did not address the problems inherent in
meeting ARARs for metals due to their high retardation in soils.
It is well established that metals generally exhibit very low rates
of partitioning from soils to ground water. This factor was
shown in the FS to severely restrict the potential for any ground
water recovery system to achieve ARARJ5 for metals, even over
the very long term.
The SFS ground water recovery modeling was limited to a
demonstration of the time frame for theoretically meeting the
VOC ARARs at the site. Metals were ignored. However, the
metals are actually more limiting for ground water usage
potential than the VOCs. Treatment of metals to potable levels
for water supply is generally not practiced due to technical and
economic limitations, while treatment of water supplies for VOC
removal is a proven, cost-effective technology. Thus the PRAP,
by ignoring the metals issue, fails to address the more
significant technical limitation on ground water remediation at
the site.
Remedial GoalsExpectations
By ignoring the metals issue as addressed in the FS, the PRAP
reaches the erroneous end misleading conclusion that ARARs
will be met in ground water by using the SFS recovery system.
Again, it was clearly demonstrated on a technical basis in the
F5 that it is highly unlikely that metals concentrations can be
reduced to the levels of ARARs in the foreseeable future and that
organics may or may not be reduced to the ARARs. Given this
knowledge, the ROD for the site should discuss the constraints of
ground water recovery at the site and should set reachable goals,
based on technical realities. To do any less is considered by ERM
to be overly optimistic and misleading; it can only create
unrealistic expectations in the minds of the public regarding the
degree of and time frame required for site remediation.
C»en th? inability of ground water recovery to achieve metals
AT-ARs, the FS proposes t!*s! mass removal of metals from the
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KOP Site Committee
14 September 1990
Page?
upper aquifer should be conducted until the reduction would be
permanently protective of the river. This provides a goal for
permanent protectiveness that recognizes and takes into account
the technological limitations on ground water remediation at the
site. Since the ground water will never be usable without
treatment for metals (and possibly for VOCs), the FS goal
concept should be incorporated into the final ROD.
Time to Remediation
The PRAP appears to select the SFS ground water recovery
system because it will theoretically meet the VOC ARARs faster
than the FS system design. However, the cost estimate for the
remedy ie based on 30 years of operation, presumably due to the
presence of the metals, which was not addressed in the SFS.
Since the time required to remediate the metals will determine
the duration of system operation, it is inappropriate to base the
recovery system design on the VOC ARARs. The FS showed
that even 30 years of operation is unlikely to achieve the metals
ARARs. As also demonstrated in the FS, if realistic (i.e., truly
achievable) goals are set for the remediation, the duration of
system operation may be considerably less than 30 years.
SFS Design vs. FS Design
It is not clear that the SFS system design will provide superior
cleanup performance, despite higher pumping rates and
injection of treated water. The sorption/desorption equilibria for
metals in soils are very complex. At the elevated ground water
velocitins induced by the SFS design, the metals desorption rate
from soils may change. At the present time, it is unknown
whether the rates of metals release and/or mass removal would
increase, remain essentially the same, or decrease under the
SFS system design. The increase in flow velocity, along with the
injection of treated water, may result in the appearance of
remediation on a concentration basis during operation of the
system. However, the ultimate remediation is dependent on
mass removal by partitioning from the soils. If the SFS system
were to inadvertently reduce mass partitioning, the metals
concentrations in ground water would be expected to rise after
the system was shut down, as the original equilibrium
conditions returned. Thus, it not clear whether the SFS design
•Ir-1-. pcrior to, or prsr!u!y inferior I/, th*» FS design for rnetale
re ft oval.
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HOP Sit« Committee
14 September 1990
Page 6
Environmental Protection
The expansive SFS system will place wells and piping systems
throughout the area from the site to the river. This
configuration would be far more environmentally destructive
than the FS design. The construction and maintenance of this
system would unnecessarily disrupt a currently undisturbed
area of the Pinelands between the Fire Road and the river over
the very long term. This factor constitutes a long term adverse
impact which was unaccounted for in the SFS evaluation and
the PRAP.
Evaluation of Remedial Action
The ground water recovery system must be re-evaluated, by law,
on a five-year basis. The selection of a system in the PRAP has
failed to take into consideration the needs of the evaluation
process. Current scientific understanding of metals
remediation in the subsurface is limited. If EPA hopes to
maximize metals remediation at the KOP site, a serious effort
must be undertaken to evaluate the mobility of metals in the soil
and water phases on a site-specific basis. The SFS system will
produce a complex potentiometric surface and high spatial
variability in water quality. This will complicate evaluation of
remedial progress and the mechanisms affecting remediation.
For example, as described previously, if desorption of
contaminants from the soil is reduced by dilution and
increasing flow rate, the effectiveness of the SFS system may be
inadvertently overestimated.
The FS. cr» the other hand, hes presenter! a system which would
remediate VOCs in ground water and provide long-term
protection of the river, while providing the simplicity to allow
more-effective evaluation of the remedial process for metals.
Based on the five-year findings, (he FS system could be modified
to optimize metals removal, if necesssary, or might possibly be
terminated, if sufficient metals removal had been achieved.
Inconsistency of PRAP with EPA Internal Guidance
As detailed above, the PRAP fails to adequately address the
issues of metals remediation and system performance
evaluation in the selection of a ground water recovery system for
the KOP site. The EPA's own internal memo of October 18,1989
ino::^s tMt such factors should be taken into account in site
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KOP Site Committee
14 September 1990
Page 9
RODs. Specifically, Recommendation 2 (p.4) calls for ROD
flexibility and contingent remedies, where appropriate. The
contingent remedy, when appropriate, should be discussed "in
equal detail to the primary remedial option and should provide
substantive criteria by which the Agency will decide whether or
not to implement the contingency." (p.5). Based on the technical
findings of the site FS and on the EPA's internal guidance
memo, the issues of metals removal limitations, system
performance evaluation, and contingent remedies should be
fully addressed in the final site ROD.
In conclusion, it is not at all clear that the technical basis for the
ground water remedy specified in the PRAP is correct. Nor is it
clear that the proposed remedy is more environmentally
protective than the FS system design. It is clear, however, that
the PRAP appears to be inconsistent with EPA internal
guidance on selection of ground water remedies. ERM's design
is in agreement with the technical considerations which form
the basic for that EPA internal guidance; we believe that it
should be followed in the ROD for the KOP Site.
p. 16, Selection of Remedy for Component 4 (Ground Water):
"Additional monitoring wells will be required to provide data to
define more completely the vertical extent of contamination.''
The EPA feels that since the lower subzone aquifer wells are not
screened immediately below the middle confining subzone, the
potential exists for significant contamination to be present in the
lower aquifer. The RI data and evaluations of the lower aquifer
clearly demonstrate the absence of significant impact on that
aquifer. For example, the vertical hydraulic conductivity (K) of
the confining unit was shown to be 2.7 x 10*? cm/sec from the
pump test and 1.8 x 10'& cm/sec (maximum) as calculated using
analytical data. Using Darcy's Law (Q (flow)« K x i (hydraulic
gradient) x A (cross sectional area of flow)) and RI data on the
confining and lower aquifer subzones, it can be calculated from
the RI data that the dilution factor from a unit area of the
confining unit into the 5-foot upper thickness of the lower aquifer
is a minimum of 4200 times. The maximum metals
concentrations detected in the upper subzone aquifer were 1040
ug/7 chromium, 12,500 ug/1 copper, and 4670 ug/1 nickel (all at
well MW 5-S). Thus, the maximum potential contribution to the
' lower aquifer is 0.25 \ig/l c'nomujrn. 3.0 ug/1 copper, tnd 1.1 ug/1
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KOPSite Committee
14 September 1990
Page 10
nickel, all below MCLs or other possible drinking water
standards.
Except for one anomalous detection of chromium above its MCL
(at well MW 14-D), all data collected from the lower aquifer
confirm this analysis. The average chromium concentration in
the lower aquifer was approximately 11 ug/I (below the MCL of
50 ug/I), with 6 of 6 samples below the detection limit of 1 ug/1.
When the ground water recovery system in the upper subzone
aquifer goes on line, the downward hydraulic gradient will be
reduced, possibly even to an upward gradient Thus, not only do
the current conditions clearly indicate no threat to the lower
aquifer, but the ground water remediation program in the upper
aquifer will further protect the lower aquifer. Furthermore, any
ground water recovery program in the lower subzone aquifer
would diminish the protection provided by the upper aquifer
recovery program and might risk inducing additional discharge
through the confining subzone, thus possibly creating an impact
where none now exists.
In summary, ERM has concluded that the lower subzone
aquifer is not adversely affected by the site and will be best
protected for the long term by the upper subzone aquifer recovery
system. Given these conditions, the lower subzone aquifer is
adequately monitored, and no additional monitoring wells are
needed.
p. 17, Alternative S-4, first paragraph, Comment*:
The need for trealability testing and the fact that this is an
emerg-ir.g le;;hii:>!cgY she ;ld be included.
p. 18, last paragraph, to p. 19, Alternative GW-3:
The comments presented above for pp. 15 to 16, Selection of
Remedy for Ground Water, apply here as well.
General Comments:
The issue of institutional restrictions for the site is not included
in the PRAP. -Because the ground water will not be remediated
in the foreseeable future, institutional measures auch as deed
restrictions will be necessary to ensure that no land use will ever
occur which is incompatible with site conditions. These
resirict'*ons Err R!:O necessary to onsturt that the integrity of eny
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KOP Site Committee
14 September 1990
Page 11
on-site remedial actions is maintained and that the property is
not used in a way that would create environmental problems in
the future. For example, if a long-term ground water recovery
system Was installed, as proposed by EPA, deed restrictions
would be necessary to ensure that future land uses would not
contribute new contaminants to the ground water. As shown in
the site FS, institutional restrictions are needed under any of the
remedial alternatives.
The cost estimates presented for the ground water recovery
scenarios assume a 30-year period of operation. It is ERM'i
opinion that a recovery effort of as long as 30 years' duration is
not necessary. The FS has shown that MCLs for metals are
highly unlikely to have been achieved in that time frame; thus,
achieving MCLs is not a feasible goal for the operation of the
recovery system. However, protection of the Great Egg Harbor
River is an achievable goal that is capable of being met by both
the systems presented in the FS and in the SFS. As discussed in
the FS, protection of the river may be obtained in a shorter period
than 30 years, thus providing equivalent protectiveness at a
lower cost than the 30-year system.
The above comments represent ERM's opinion of the technical issues
related to the EPA's PRAP. In short, we continue to support on-site
stabilization with capping for the soils and sludges and the FS design
for a ground water recovery system as the most appropriate remedies
for the site. If you have any questions concerning this submission,
please contact either Joe Hochreiter (609-520-8779) or me (215-524-
3512).
Sincerely,
Hewitt
Director
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Appendix C
The Pinelands Commission Comments on the Proposed Flan
U.S. EPA Response
-------
KEJt
The Pinelands Commission
P.O. Box 7, New Lisbon, N. J. 08064 (609)894-9342
August 15, 1P?0
Mr. Jar.es Hahneberg
P. S. Environmental Protection Agency
Pooir 7?o
?6 Federal Plaza
Kev York, New York 10278
Re: King of Prussia
Kinslow Township
Mr. Kshneberg:
The Pinelands Commission staff has reviewed the "Sup-
pjerrental Feasibility Studv Peport" (SFS) and the Proposed
Feredial Action Plan fPPAP) issued by your agency for the
Fine cf Prussia Superfund site in Winslow Township, New
Jersey.
As you are aware, the site is located within the
Pine! arcs Protection Area as established by the National
PerVf ert*. Fecreation Act o* 1978 (P.L. 95-625, Section 502)
erf the Fire3ends Protection Act W.J.S.A. 1BA-1 et »eo.>.
The Pire3erds Comprehensive Management Plan fN.J.A.C.
?:5C-.'1.] et seq.i was adoptee? pursuant to the federal and
state ZeriF^etior. The regulations and standards contained
in the Finelands Comprehensive Management Plan fPCMP) were
accrt.ec? in orner to protect the significant and unique
r:6*.urel end ecolcgical resources of the Pinelands as
required by the Federal Act and the Pihelands Protection
Act.
Please' consider the following comments regarding the
consistencv of the preferred remedial alternatives with the
and standards of the PCKP:
Groundwater
The PRAP indicates that the applicable, relevant and
appropriate requirements (ARARs) are the state MCL's or
r'rirking water standards. As the Commission staff has
previously indicated to your office, the water quality
standards cf the PCMP prohibit development that would
f <•::'*.?'* th-2 reality of surf&re or groundvator. These
iter.csrcs s>ru3d be considered as AVARs and the remedi-
al goals should be to reduce the concentrations of all
contaminants to natural background levels.
The Pinelands - Our Country's First National lUitrv*
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It should also be considered that the State has set
"PL" surface water standards for the Great Bog Harbor
Paver within the Pinelands. These standards "require
that surface water must be maintained at its existing
quality or that quality necessary to protect the
designated uses of the water (including "maintenance
and propagation of the natural and established biota
indigenous to this unique ecological system"). As the
groundwater plume has been identified as the source of
contamination of the river surface water and sediments,
the remedial goals for the groundwater must consider
the effects of the groundwater plume upon the surface
water.
The proposal to continue to treat the groundwater until
the State MCL's are met will result in a degradation of
the quality of both the ground and surface waters of
the Pinelends. The groundwater plume would be a
continued source of contamination to the river. The
levels of several of the inorganic contaminants in the
pluir.e discharging to the river would exceed the State's
V-'ater Quality Criteria for the Protection of Aquatic
Life if the treatment of groundwater was to cease when
the MCL's ere attained.
Therefore, the proposed remedial alternative for
crcundweter requirements cannot be considered to be
consistent with the Pinelands Comprehensive Management
P?an, the Federal Act or the Pinelands Protection Act.
Furfec° T-.'e*er ard Sediments of the Preat Egg Harbor P.i^er
The Ccrjrission staff agrees that additional sampling is
necessary to fully de'ine the extent of contamination
c* the sediments and surface water of the river. As
the =rv.rre cf this contamination has been identified as
the discharge of contaminated groundwater, it is likely
that ar.y future proposal for remediation of the river
v.-iil effect the design of the groundwater treatment
facilities. Any record of decision on oroundwater
remediation will directly effect the possibility of
remediation of the river. Therefore, the proposed
remedial alternative for groundwater should be designed
to provide for treatment of groundwater to meet the
non-degradation standards for both surface and ground-
water and the State's PL standards for surface water.
.Metals Contarineted Soils, Pediment and Sludges
It arrearr that the proposal to excavate, treat anc
r«rrla"-"S th - .or.ts r-inc-teS £.ofl?., ^ci^r.t s and
vii: be consistent with the requirements of the
the material is adequately treated. The PCMP • does
contain specific requirements that may effect the
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design cf the on-site treatment system and the methods
of storage and removal of the resulting concentrate.
Puried Drums, VOC Contaminated Soils, Tankers and Contents
The Commission supports the proposal to remove and
dispose of these materials off-site at an appropriate
facility.
In summary, the PRAP is not consistent with the water
quality standards of the Pinelands Comprehensive Management
Plan, the Pinelands Protection Act or the National Parks and
Fecrestion Act of 1978. The Commission will object to any
record o* decision that is not consistent with these water
quality standards.
If there are any questions concerning this matter,
please cor.tact me.
Villiam F. Harrison, Esquire
Assistant Director
T-TH/sci
cc: >'r. Arthcny Farro, Director,
Division o^ Hazardous Site
Xitieation - KJ DEP
Vr. Leroy Cattaneo, Acting
Deputy Director, Division of
Water Fesources - KJ DEP
Ms. Kathleen Swioon
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• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
- REGION II
%* *~l" JACOB K. JAVfTS FEDERAl BULDING
NEW YORK. NEW YORK 10276
S£P 2 1 1330
Mr. William F. Harrison, Esq.
Assistant Director
The Pinelands. Commission !
P.O. Box 7
New Lisbon, New Jersey 08064
Dear Mr. Harrison:
This is in response to your letter, dated August 15,1990, to
James Hahnenberg of my staff, which provided comments on the
Supplemental Feasibility Study and the Proposed Plan for the King
of Prussia Technical Corporation (KOP) Superfund site in Winslow
Township, New Jersey.
In accordance with the U.S. Environmental Protection Agency's
(EPA's) community relations policy and guidance and the public
participation requirements of the Superfund Program, EPA
established a public comment period from July 16, 1990 to
Septerier 14, 1990. After review of all comments which EPA has
received, EPA intends to select a remedial solution for the site
that is protective of human health and the environment, cost-
effective, and attains federal and state requirements that are
applicable or relevant and appropriate.
As part of the Feasibility Study and Supplemental Feasibility
Study, numerous alternatives were evaluated to identify a
permanent remedy for the first operable unit. These alternatives
will be discussed in detail in the Record of Decision (ROD) for
the KOP site. The remedial action proposed by EPA includes the
follcvir.g: excavaticn and contaminant extra-tier, of metal
cc.-.ta-ir.c ts-5 soil 7, secinentfc and sludges; drum removal and off-
site disposal; tanker removal and off-site disposal; a ground-
water extraction, treatment and reinjection system; and
additional monitoring of the Great Egg Harbor River.
In your letter, you indicated that the Pineland's Commission
supported some of the remedial action components proposed by EPA.
You also indicated, however, that elements of the Proposed Plan
were inconsistent with the Pinelands Comprehensive Management
Plan (CMP). Specifically, you stated that the proposed cleanup
goals for ground water should be set at natural background levels
for all substances, based on the nondegradation standard of the
Pinelands CMP. You also noted that the Pinelands CMP prohibits
development which nay degrade the surface-water and ground-water
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EPA would like to Bake a number of points relative to these
comments. As you are aware, the ground water in the aquifer
underlying the KOP site is contaminated as a result of improper
hazardous waste disposal. Extracting and treating this ground
water will result in significant improvement in ground-water
quality. For this reason, EPA does not believe that the non-
degradation objectives are applicable or relevant and appropriate
requirements (ARARs) for the site.
Although the site is located in the Hew Jersey Pinelands, it is
not in the preservation area or the central Pine Barrens. As
such, it would not be subject to the more stringent
nondegradation requirements, or restoration of ground water to
background conditions.
The ARARs or cleanup goals for the contaminants at the XOP site,
are drinking-water standards or Maximum Contaminant Levels
(MCLs), established under the New Jersey State Drinking Water Act
N.J.A.C. 7:10-16.7.
Your letter also expressed concern regarding ground-water cleanup
levels and potential adverse impacts to the Great Egg Harbor
River. EPA agrees with your comment that further information is
needed to characterize present contaminant levels more completely
and assess the impact of the ground-water treatment system to
sediments, surface waters and biota of the river. Monitoring
will be conducted during Remedial Design and during the operation
of the ground-water remediation system to assess the impact of
the system on the river. If it is determined during operation of
the system that the river is being degraded by site-related
contamination, the river will be addressed as a separate operable
unit, and a focused feasibility study will be conducted to
evaluate apprc-pr'ate remedial alternatives. The feasibility
study will consider all appropriate alternatives including
additional treatment of the ground water, to ensure that the
remedial action is protective of designated uses of the river
water and the river's biota.
Your cooperation in providing comments on our proposed remedial
action is appreciated. I hope that the concerns raised by the
Pinelands Commission have been fully addressed. Should you have
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any further questions in this natter, do not hesitate to contact
me at (212) 264-8673, or have your staff call James Hahnenberg,
the project manager for the KOP site, at (212) 264-5387.
Sincerely yours-,
(/
"
^Richard L. Caspe, P.E.
" Director
Emergency and Remedial Response Division
cc: J. Schnitzer, NJDEP
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