PB95-963815
                                EPA/ROD/R02-95/261
                                May 1996
EPA  Superfund
       Record of Decision:
       King of Prussia Technical Corporation,
       Camden County, Winslow Township, NJ
       9/27/95

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          SEP  °T •'
         Issuance of a Record of Decision for a  No  Further Action Remedy for
         Residually Contaminated Soils at the King  of Prussia Superfund Site

         Kathleen C. Callahan,  Director
         Emergency  & Remedial  Response Division

         Jeanne M.  Fox,
         Regional Administrator
             Attached for your review and concurrence, please find a Record
        of Decision  (ROD)  for the King of Prussia  Site's  second operable
        unit  (OU2).   The  OU2  remedy is  intended  to address  residually
        contaminated  soils  around a Former Buried  Drum Area on the Site.
        This area .was the source of volatile organic chemical contamination
        of the  ground water  underlying  the  site.   The buried  drums  were
        removed from the area in 1991.  In  late 1992 the soil in the Former
        Buried  Drum  Area was  analyzed and in 1993 the EPA completed an
        assessment of the  human health  risks  from the soil.   During the
        risk assessment  the  EPA also  derived cleanup  goals for  the soil.

             In 1993 the PRPs requested permission from the EPA to excavate
        and remove soil  in the  Former  Buried Drum Area  that posed a human
        health risk.   The EPA issued an Action Memorandum for this work and
        directed the  PRP Group to complete  the work  under  the terms of the
        unilateral order.  In early 1994  the PRPs completed the  removal of
        all soil not meeting  EPA's  cleanup goal.

             All  soil  in  the  Former Buried  Drum Area  that  contained
        contamination above  the  EPA-approved risk-based cleanup level,  have
        been  excavated   and  removed  from  the  Site.   The  area has  been
        regraded and  revegetated.   The Former  Buried Drum Area no longer
        poses an unacceptable risk  to  human health  or the  environment and
        it will  no   longer   act  as  a  source  of  contamination  to  the
        underlying ground water.  EPA's decision is  that no further action
        be taken to remediate soils in the Former Buried Drum Area.

             This decision  is the same  as the one proposed  in the Proposed
        Plan,  which EPA  submitted to the public in August 1995.   The public
        comment period for the Proposed Plan ended  on September 14,  1995.
        EPA did not receive any  written comments during the public comment
        period.  A public meeting was held on August 23,   1995.   Comments
        received during  the public meeting  period are addressed in  the
        attached Responsiveness Summary.
G:\USER\SHARE\COVER.ROD

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                       DECISION DECLARATION

                       RECORD OF DECISION

              King of Prussia Technical Corporation


SITE NAME AND LOCATION

King of Prussia Technical Corporation
Winslow Township, Camden County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision presents the selected remedial action for
the King of Prussia Site in Winslow Township, New Jersey.  The
remedy was selected in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP).

The New Jersey Department of Environmental Protection concurs
with the selected remedy.  The information supporting this
decision is contained in the administrative record for the site.

DESCRIPTION OF THE SELECTED REMEDY

The response action described in this document represents the
second operable unit for the King of Prussia site.  It addresses
residually-contaminated soils associated with a buried drum area
at the site.  The Environmental Protection Agency  (EPA) has
determined that no further action is necessary with regard to
the subject soils.

A previous Record of Decision, signed on September 28, 1990,
addressed the remediation of contaminated soils, sediments and
sludges on the site and contaminated ground water  in the
underlying aquifer.  The remedy selected at that time also
included the removal of tankers and buried drums on the site.

EPA removed the tankers and buried drums in 1991.  Subsequently,
a group of potentially responsible parties has completed all the
remaining construction activities comprising the initial remedy
for the site.  Treatment of the contaminated ground water is
ongoing.  In addition, in February 1994, the responsible parties
completed the excavation and disposal of the contaminated soils
surrounding the former buried drum area exceeding the risk-based
cleanup goals established by EPA.  Consequently, no further
action in connection with these soils is necessary.

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                               -2-
DECIARATION OF STATUTORY DETERMINATIONS

In accordance with the requirements of CERCLA and the NCP, I
have determined that no further remedial action is necessary to
protect human health and the environment involving the second
operable unit at the King of Prussia site.  The response action
completed by the responsible parties in 1994 effectively removed
all contaminated soils above the cleanup goals established by
EPA.

Because the soils associated with the buried drum area no longer
contain hazardous substances above health-based levels, the five
year review puruant to CERCLA and the NCP does not apply to this
decision.
Jeanne M./fox 'l M/     V                     Date
Regional'Administrator   N

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 DECISION SUMMARY

 KING OF PRUSSIA TECHNICAL CORPORATION SITE

 INTRODUCTION

 This Record of Decision presents the no further action remedy for Operable Unit 2 (OU2) at
 the King of Prussia Site located in Winslow Township, Camden County, New Jersey.  The site
 was added to the National Priorities List (NPL) by the Environmental Protection Agency (EPA)
 in 1985.  On September 28, 1990, following the completion of a Remedial Investigation and
 Feasibility Study (RI/FS), EPA issued a Record of Decision (ROD) for Operable Unit 1 (OU1)
 of the King of Prussia Site.

 This OU2 ROD was developed in accordance with the requirements of the Comprehensive
 Environmental Response, Compensation and Liability Act (CERCLA) of 1980, as amended, and
 the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) of 1990.  This
 decision document serves to explain the factual and legal basis for selecting the no further action
 remedy for the site.

 Information supporting the no further action remedy is contained in tue adnv'nistrative record
 for the site. This ROD contains a Decision Declaration, Decision Summary, and a
 Responsiveness Summary.

 SITE DESCRIPTION

 Site Characteristics:

 The King of Prussia 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 of the site is within a  dense pine forest of
 the state-owned, 6,000-acre Winslow Wildlife Management area (Figure 2) and is primarily used
 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  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.

Two groundwater aquifers have been identified at the site. These aquifers are part of the
Kirkwood-Cohansey Aquifer System.  The  upper aquifer ranges from 15 feet to approximately
35 feet below the ground surface.  The lower aquifer ranges from 50 feet to approximately 250
feet below the surface.  The ground water  flows towards the southwest at a rate of one foot per
day in the upper aquifer and 0.4 feet per day in the lower aquifer.  The high porosity and
permeability of the soils in the area result  in rapid infiltration of precipitation to the  underlying
aquifer.

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 The nearest body of surface water is the Great Egg Harbor River, approximately 1,000 feet
 southwest of the site (Figure 2).  The river is used for recreational purposes and has been
 nationally designated as a Wild and Scenic River.  A natural land depression, known as a swale,
 once directed runoff from the site lagoons towards the Great Egg Harbor River.

 The nearest residential potable well is approximately one mile northeast and upgradient of the
 site.  There are additional wells which do not serve as potable water supplies, within a half-mile
 radius of the site. These wells are located at a Johnson Matthey Inc. facility, located just across
 Piney Hollow Road from the site, and the field office of the New Jersey Division of Fish, Game
 and Wildlife, located on the opposite  side of the Great Egg Harbor River.

 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 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
 by site contaminants.

 The site itself is relatively level, and rectangularly shaped.  The area has been revegetated with
 upland trees, shrubbery and grasses.  The swale has been revegetated with wetlan'4 species.

 SITE 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 could be marketed for construction
purposes 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 the 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  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 Evor Phillips 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 was suspected to have
occurred prior to installation of a fence by the Potentially Responsible Parties (PRPs) in  1988.

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 Remedial Actions and Initial Investigations by 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 the contamination with additional sampling and investigations during 1979, 1980
 and 1982. In December 1985, the site was formally included on the NPL.

 Investigations conducted by the PRPs with EPA oversight, were started in 1985, with the
 Remedial Investigation Report being approved in August 1989 and the Feasibility Study issued
 to the public in July 1990.  EPA also conducted a Supplemental Feasibility Study which was
 released  in August 1990.

 EPA performed several removal actions at the Site, including: the excavation and
 recycling/disposal of 120 plastic containers, 159 tons of heavy metal contaminated soil and 150
 gallons of acid (completed in September 1990); the excavation and off-site disposal of 200 rusted
 steel drums and 235 plastic carboys containing acids and organic liquids within the portion of the
 Site designated as the Buried Drum Area (now known as the Former Buried Drum Area)
 (completed in November 1991); and the disposal of two rusted steel tankers (completed in
 August 1991).

 In 1993, a Focused Feasibility Study (FFS) was conducted by the PRPs, under EPA direction, to
 evaluate remedial alternatives for the Former Buried Drum Area. On March 11, 1993, EPA
 issued its evaluation of Human Health Risks posed by residually contaminated soils in the
 Former Buried Drum Area. In February  1994, the PRPs completed a removal action which
 consisted of the excavation and off-site disposal of residually contaminated soils in the Former
 Buried Drum Area to meet the health-based soil cleanup goals established by EPA in its March
 1993 Risk Assessment.

 SCOPE AND ROLE OF THE OPERABLE UNITS

 Subsequent to the 1990 ROD, to facilitate remedial activities EPA divided the cleanup into
 three phases, or operable units (OUs).

 Operable Unit One

The ROD for OU1 addresses remediation of contaminated ground water and metals-
contaminated soils, sediments and sludges, as well as the removal of tankers and buried drums
from the site. To date, EPA has removed the rusted tankers from the site and the drums from
the Buried Drum Area (now known as the Former Buried Drum Area). On April 15,  1991,
EPA issued an Administrative Order, Index No.  II CERCLA 10106 (Order), directing a group
of five PRPs (PRP Group) to complete the remedial activities described in the September 1990
ROD.

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 In June 1993, the PRP Group completed OU1 by treating approximately 19,200 tons of metals-
 contaminated soils and sludges in a soil washing system.  The soil washing process removed
 contaminants from soil using particle size separation techniques. It has been shown that
 contaminants tend to bind to the fine particles contained in soil. By separating the fine particles
 from the sand fraction, the majority of contamination was removed. The sand was then washed
 using a washing solution to remove any residual contamination.  The treated sand was
 backfilled on site, and revegetated following the EPA-approved Habitat Restoration Plan.

 Operable Unit Two

 A second operable unit (OU2), which is the subject of this ROD, was identified in the
 September 1990 ROD. The  purpose of OU2 is to address the residually-contaminated soils
 associated with the Former Buried Drum Area.

 During a  1991 removal action, EPA  excavated and removed the drums from the Former Buried
 Drum Area.  Since then, studies found that the residually-contaminated soils in the Former
 Buried Drum Area were a potential threat to future residents and also a threat to the ground
 water underlying the KOP Site.  In the June 1993 Risk Assessment, EPA established a risk-
 based level of contaminants that would be protective of human health. In February 1994, the
 PRP Group completed excavation and disposal of all soils that had concentrations of
 contaminants exceeding this level. This removal action was authorized by EPA through a
 September 21, 1993 Action Memorandum.

 As EPA's risk-based cleanup levels have been met, the Agency has selected a no further action
 remedy for the Former Buried Drum Area.  This remedy complies with all federal and state
 requirements.

 Operable Unit Three

 Recently, the PRP Group completed construction of a groundwater extraction, treatment and
 reinjection system as described in the 1990 ROD.  The groundwater treatment system consists
 of a recovery system with eleven recovery wells. The recovery wells are pumped to produce an
 influent flow  of about 200 gallons per minute of ground water, or about 280,000 gallons per day.
The water is pumped into an influent holding tank and then passed through electrochemical
cells.  Ferrous ions are released from iron plates within the cells, and through a chemical
reaction, chromium, a contaminant of concern, is converted from its hexavalent state to its
trivalent state. Trivalent chromium is both less toxic and easier to  remove than hexavalent
chromium.

The ground water then passes into a mixing tank were it  is mixed with a polymer  solution.
Metal contaminants bind with the polymer and the polymer/metals mixture is settled out in a
clarifier tank. The water is passed through a multi-media filter where any remaining particles
are removed.  The water is then pumped to two air strippers were the majority of the volatile
organic compounds (VOCs) are removed. A carbon polishing unit is used to remove remaining
VOCs.

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 After treatment, the ground water is sampled to ensure that the ROD limits are being met
 before being reinjected into the aquifer through the ten infiltration galleries along the river, and
 the five infiltration trenches near the groundwater treatment facility building.  The reinjection
 scenario is designed so that the plume is contained, and contaminants cannot flow into the
 Great Egg Harbor River.

 This system began treating contaminated ground water in early 1995.  By August 1995 the
 treatment system had removed approximately 600 pounds of metals and 400 pounds of VOCs
 from the ground water. This remedial action will continue until the ground water meets the safe
 drinking water levels set forth in the September 1990 ROD.

 COMMUNITY RELATIONS HISTORY

 EPA and NJDEP rely on public comment and discussion to ensure that the concerns of the
 community are considered in selecting an effective remedy for each Superfund site. Towards
 this end, a  description of the proposed No Further Action  Remedy for OU2 was distributed to
 the public as a Proposed Plan. EPA sought comments during a 30-day public comment period
 which ended on September 14, 1995. In addition, on August 23, 1995, EPA held a public
 meeting in  Winslow Township to discuss this No Further Action remedy and to answer
 questions from interested parties.

 Comments received at the public meeting are addressed in the Responsiveness Summary Section
 of this ROD. It should be noted that no written comments were received during the public
 comment period.

 SUMMARY OF THE FORMER BURIED DRUM AREA SOILS CHARACTERISTICS

 The implementation of OU2 began with the analyses of soil within the Former Buried Drum
 Area. As stated above, during a  1991 removal action, buried drums and visibly contaminated
 soils were excavated and disposed of off-site by EPA.  However, residual soil contamination
 remaining in the area needed to be characterized.  The soil was sampled and analyzed by the
 PRP Group in 1992 in accordance with the December 5, 1991 KOP Remedial  Design Workplan.
Three soil samples from each of 21 borings were analyzed for VOCs, semivolatile organic
compounds and metals. These borings were placed on an approximately 30-foot grid within the
area of previous excavation (see Figure 3).

A compilation of the analytical data are contained in the July 1992 Analytical Quality Assurance
 Report for  the Former Buried Drum Area Samples.  Also, additional soil data are contained in
the August  3, 1993 FFS Report.

Using the soil data, EPA performed a Risk Assessment to evaluate any risks that may be posed
by the soils in the Former Buried Drum Area.  The results of the Risk Assessment are
summarized below.

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 SITE RISK SUMMARY

 Risks Posed bv Former Buried Drum Are'a Soils

 An EPA study entitled "Assessment of the Human Health Risks Associated with Contaminated
 Soils at the Former Buried Drum Area of the King of Prussia Site (June 1, 1993)" evaluated the
 risks posed by the soils in the Former Buried Drum Area and determined an acceptable cleanup
 goal for those soils.  During a three month period beginning in November 1993, soils around the
 Former Buried Drum Area at  the site were excavated and disposed of off-site by  the PRP
 Group, with EPA oversight, to meet the EPA-established risk-based cleanup goals.
 Consequently, the soils associated with the Former Buried Drum Area no longer  pose an
 unacceptable risk to human health or the environment.

 In the development of risk-based cleanup goals for the soils associated with the Former Buried
 Drum Area, EPA analyzed two exposure pathways,  including soil ingestion and groundwater
 impacts. The risks posed by surface soils and subsurface soils were assessed separately. The
 risks once associated with the Former Buried Drum Area and the cleanup goals developed to
 remedy those risks are discussed below.

 Surface Soils

 The levels of contamination that were detected in the Former Buried Drum Area in 1992 are
 presented in Table 1. The only area in which positively  identified compounds were detected in
 elevated concentrations in surface soils were at sample DB-3 (see Figure 3), which contained 14
 parts per million (ppm) of tetrachloroethylene (PCE) in the zero to two foot  range.

 Subsurface Soils

 Significantly higher concentrations of contaminants were detected in the subsurface soils of the
 Former Buried Drum Area.  Sample DB-2 was the most highly contaminated, with 16,000 ppm
 PCE detected in the four to six foot range, and 2,600 ppm in the six to eight foot  range.
 Xylenes, 1,2-dichlorobenzene, and 1,4-dichlorobenzene were also present in sample DB-2, with
 concentrations of 330 ppm, 240 ppm and 37 ppm in the  four to six foot range, respectively.
 Concentrations of PCE, xylene and dichlorobenzenes all decreased in  the six to eight foot range
 of sample DB-2. Sample DB-3 was similarly contaminated with PCE, xylene,  and 1,2-
 dichlorobenzene, though concentrations were not as elevated as those seen in sample DB-2.
 Less significant levels of contamination were detected in samples DB-8 and DB-10.

 Health Risk Assessment of Direct Contact with Surface  Soils

 Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for
 the indicator compounds.  Cancer slope factors (SFs) have been developed by EPA for
 estimating excess lifetime cancer risks associated with exposure to potentially  carcinogenic
chemicals.  SFs, which are expressed in units of (mg/kg-day)"1, are multiplied  by the estimated
intake of a  potential carcinogen, in mg/kg-day, to generate an upper-bound 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 SF. Use
of this approach makes the underestimation of the risk highly unlikely.

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 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 the 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 primary hazard potentially associated with PCE in surface or near-surface soils is incidental
 ingestion by potential .future residents. The risk associated with ingestion of soils contaminated
 with the maximum  detected concentration of PCE was assessed using the current default
 exposure parameters outlined in Office of Solid Waste and  Emergency  Response directive
 9285.6-03, as shown in Table 2.  The maximum detected concentration of PCE in surface soils
 (14 ppm), detected in sample DB-3, the exposure parameters described in Table 2 and the
 indices of toxicity shown in Table 3 were factored into the equations presented in Table 4, to
 determine the cancer risk and hazard  index potentially associated with exposure through
 ingestion of PCE-contaminated surface soils by future residents.  The cancer risk associated with
 this exposure was 4.2 x 10"7. The corresponding hazard index was below 0.01.  These results
 suggest that even under the most conservative  scenario, exposure to contaminated surface soils
 at the Former Buried Drum Area would have  been  highly unlikely to be associated with any
 adverse health effects even prior to remedial action.

 Health Risk Assessment of Direct Contact with Subsurface  Soils

 Subsurface soils associated with the Former Buried  Drum Area were more highly contaminated
 than surface soils in this area. Under EPA risk calculation  procedures, subsurface soils are not
 considered available under direct contact exposure scenarios, and thus were not of concern from
 the standpoint of incidental ingestion.   Nevertheless, EPA determined what the potential risk
 would be if the subsurface soils became available for direct  contact exposure, should they
 become available following excavation activities at the site.  Use of the maximum detected
 concentration of PCE (16,000 ppm in the four  to six foot range of sample DB-2) in the risk
 assessment calculations presented in Table 4, resulted  in a calculated cancer risk of 5 x 10"* and
 a hazard index of 2.3.  Both the cancer risk and the  hazard  index were greater than values which
 EPA has determined to be acceptable (cancer  risk of one in ten thousand (IxlO"4) to one in one
 million (IxlO"6) and hazard index of 1).

 In addition to PCE, xylene,  1,2-dichlorobenzene and 1,4-dichlorobenzene were detected in
 subsurface soils.  Health risks associated with potential direct contact exposures to maximum
concentrations of these contaminants in subsurface soils were determined using the equations
presented in Table 4. The hazard indices associated with direct contact exposures to xylene and
 1,2-dichlorobenzene were below 0.01 and 0.04,  respectively,  demonstrating that the
concentrations of these contaminants in the soils of  the Former Buried  Drum Area were not of
concern. The cancer risk associated with direct contact with soils contaminated with 1,4-
 dichlorobenzene was determined to be 5 x 10"7, well  below EPA's level of concern.

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 The results of this conservative assessment of risks associated with direct contact with
 contaminated soils by future residents suggested that only PCE had the potential to present
 unacceptable risks. The risks due to incidental ingestion of soils contaminated with PCE were
 extraordinarily remote, given that the site is not developed for residential use; significant
 concentrations  of PCE were present only in subsurface soils; PCE would  be unlikely to remain
 in elevated concentrations in surface soils due to its high volatility; and the risk assessment was
 based on the maximum concentration of PCE that was detected at the site prior to remedial
 activities.

 Potential Contamination of Ground Water by Contaminants in Soil

 The Seasonal Soil  Compartment Model [SESOIL] (Bonazountas and Wagner, 1984;  Hetrick et
 al., 1989) was used to determine the potential impacts of subsurface PCE soil contamination on
 the degradation of ground water underlying the site.  The SESOIL model was developed for use
 by EPA, and is designed for determination of mobility of contaminants in unsaturated soils at
 hazardous waste sites.  Generic parameters for the State of New Jersey and meteorological data
 for Trenton, New Jersey were used to model impacts at the King of Prussia site.  Site
 contamination was assumed to extend from the soil surface to a depth of four feet. Ground
 water was assumed to be present ten feet below  the soil surface.  Soils were assumed to be
 sandy loam, with a moisture content of 0.2%, a porosity of 0.41, and an organic carbon content
 0.1%. For the purposes of modeling, degradation of PCE present in subsurface soils was
 assumed to be nonexistent. The input parameters for the model are considered to be a
 conservative, reasonable estimate of the conditions present at the King of Prussia site.

 The risk assessment for the OUl ROD determined that unacceptable health risks could be
 associated with  potential potable use of ground water contaminated with  PCE and other
 compounds. The SESOIL model was used to determine soil concentration levels resulting in
 groundwater contaminant concentrations below the ROD cleanup goal of 1 ppb.  The model
 assumed that a  100-fold dilution would occur as contaminants entered the ground water.
 Accordingly, the model was used to determine soil concentrations which would result in
 concentrations 100 times the groundwater target at the point the contaminant entered the
 groundwater column.  The soil concentration of PCE generated using this approach was 1 ppm.
 PCE was detected  at concentrations as much at 16,000 times this level in  subsurface  soils of the
 Former Buried  Drum Area. The presence of elevated concentrations of PCE  in the subsurface
 soils confirms that  the Former  Buried Drum Area may have served as a significant source of
 contamination to the ground water underlying the site.

 CLEANUP GOALS FOR CONTAMINATED  SOILS ASSOCIATED WITH THE FORMER
 BURIED DRUM AREA

 Direct Contact Exposures

 Only PCE was determined to present a potential hazard in subsurface soils due to incidental
 ingestion of contaminated soils by potential future site residents.  The most conservative cleanup
goal for PCE based on direct contact with contaminated soils was derived using the equation for
 the  determination of cancer risks (Table 4). It was determined that a cleanup goal of 33 ppm
would prevent unacceptable risks due to soil ingestion.

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 Protection of Ground Water

 The ground water cleanup goal for PCE specified in the 1990 ROD was 1 part per billion (ppb).
 The SESOIL model was used to determine that soil concentration levels of 1 ppm would result
 in groundwater contaminant concentrations below the ground water cleanup goal.

 Summary and Conclusions

 PCE, xylene, 1,2-dichlorobenzene, and 1,4-dichlorobenzene were detected  in soils at the Former
 Buried Drum Area of the King of Prussia site.  Contamination due to xylene, 1,2-
 dichlorobenzene, and 1,4-dichlorobenzene were determined not to present unacceptable levels of
 risk due to direct contact with  soils by potential future on-site residents.  Historically, these
 compounds have not been detected in ground water at the site, and are not considered to be of
 primary concern.

 The potential hazards associated with direct contact with PCE-contaminated soils were
 determined to be minimal even prior to the removal of soil from the Former Buried Drum
 Area.  While a highly conservative assessment of direct contact risks by potential future on-site
 residents generated potential risks slightly above EPA's target range, the series of events
 required to realize °uch risks were extremely unlikely.

 PCE was identified as a contaminant of concern in  ground water underlying the  site in the OUl
 ROD, and was determined to present unacceptable health risks.  PCE present in subsurface soils
 of the Former Buried Drum Area was a likely source for continued degradation  of ground water
 underlying the site.

 Cleanup levels for PCE were developed based on the mitigation of risks due to direct contact
 with contaminated subsurface soils and protection of ground water underlying the site. As
 stated above, the cleanup level based on the direct contact scenario was calculated to be 33 ppm.

 Cleanup goals based on the protection of ground water at the site were developed using the
 SESOIL model.  This modelling effort determined that PCE soil concentrations greater that 1
 ppm are expected to result in further degradation of the ground water underlying the site.

 The 1 ppm cleanup goal for protection of groundwater is more conservative than the goal
 derived for direct contact.  As such, the overall cleanup goal for the remediation of the Former
 Buried Drum Area was set at 1 ppm PCE.

 FORMER BURIED DRUM AREA SOIL REMOVAL ACTION

 The 1993 FFS was conducted to evaluate remedial alternatives for the Former Buried Drum
Area.  The FFS was based on the data and interpretations of the Former  Buried Drum Area
presented in the July 14, 1989 Draft Final Remedial Investigation, the data collected during the
 execution of the  December 5, 1991 Remedial Design Work Plan, and on additional field
sampling conducted in January 1993.  The remedial action objective established by EPA was to
be a risk-based cleanup level for PCE. The conclusions of the FFS indicated that the preferred
remedial alternative for the protection of human health and the environment from the residual
contamination in the soils associated with the Former Buried Drum Area  was the excavation
and off-site disposal of  the impacted soils.

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 Removal Action Work Plan

 In an August 20,  1993 letter to EPA, the PRP Group requested permission to perform the
 necessary soil excavation as a removal action, pursuant to the April 15, 1991 Order. On
 September 21, 1993, EPA issued an Action Memorandum for the performance of a removal
 action at the Former Buried Drum Area of the KOP site. Subsequently, in an October 8, 1993
 letter, EPA approved the PRP Group's request to perform the removal action. In addition,
 EPA directed the PRP Group to prepare a work plan for soil excavation, staging, sampling,
 analyses and off-site disposal of impacted soils exceeding the EPA established soil cleanup level.

 Removal Action Criteria

 Since there are no contaminant-specific Applicable or Relevant and Appropriate Requirements
 (ARARs) for soils, EPA developed soil cleanup levels through the performance of a site-specific
 human health risk assessment. As explained in a previous section of this document, PCE was
 selected  as the indicator contaminant upon which the cleanup of the Former Buried Drum Area
 was based.  The most stringent calculated cleanup goal for the Former Buried Drum Area soils
 is 1 ppm of PCE.  This was the level selected by EPA for soil remediation.

 Description of Former  Buried Drum Area Removal  Action

 Based on the available  data, two areas were identified for excavation during the removal action
 (Figure 4).  These were designated as Area No. 1 and Area No. 2. The dimensions of Area No.
 1 were approximately 40 feet by 60 feet and the dimensions of Area No. 2 were approximately
 25 feet by 25 feet.  Each of these areas was delineated by estimating the concentration contours
 for PCE  and then selecting the 1 ppm contour as the boundaries of the removal areas. The
 estimated depth of remediation was approximately 8 feet based on the groundwater level at the
 site.

 All activities were completed following EPA approval of the Work Plan submitted by the PRP
 Group. Areas No. 1 and No. 2 were identified during the previous investigations  and
 established during the FFS for the Former Buried Drum Area.  Soils containing elevated levels
 of PCE were removed from both areas until established cleanup goals were demonstrated to be
 met.

 During the excavation of the areas, qualitative preliminary screening was conducted using field
 sampling techniques to  segregate the soils as they were being removed. Soils were then
 stockpiled in the appropriate categories.  This screening technique was also used to define
 perimeters that were below EPA's risk-based cleanup level for PCE.

 Soil samples were collected from each excavation to  confirm that the established cleanup goals
 had been achieved. Each perimeter sample was screened using field analyses  techniques for
 PCE and other select VOCs.  Subsequent to the field screening, select samples maintaining the
 highest concentrations of PCE were submitted for confirmatory laboratory analyses of VOCs.

 Beginning in November 1993, the excavated soils were stockpiled in 30 mounds.  Soil samples
were collected from each of the 30 stockpiles. Each  sample was screened for PCE and
 subsequently submitted for laboratory analyses of VOCs. Of the 30 stockpile samples analyzed
 for VOCs, 12 were above the cleanup level of 1 ppm of PCE.
                                           10

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 Beginning in February 1994, impacted soils above the established risk-based cleanup level of 1
 ppm of PCE that were characterized through testing as non-hazardous waste were transported
 off-site for disposal at the Waste Management, G.R.O.W.S. Landfill in Morrisville, Pennsylvania
 (approximately 556 tons). Soils characterized as hazardous waste were transported off-site for
 disposal at the Chemical Waste Management's landfill in Model City, New York (approximately
 277 tons).  Soils demonstrated to be below the  established cleanup goals (approximately 1,300
 tons) were used as backfill material for the excavations.

 DESCRIPTION OF THE NO FURTHER ACTION REMEDY

 All soils in the Former Buried Drum Area that contained concentrations of PCE above the
 EPA-approved cleanup level have been excavated and removed from the site. The area has
 been regraded and revegetated.  The Former Buried Drum Area no longer poses an
 unacceptable risk to human  health or the environment and will no longer act as a source of
 contamination to the  underlying ground water.

As EPA's risk-based cleanup levels have been met, the Agency has determined that no further
 action needs to be taken to remediate the soils in the Former Buried  Drum Area. This
proposed no further action remedy complies with all federal and state requirements.
                                          11

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                           ROD FIGURES

Figure 1.      Site Location and Regional Topographic Map

Figure 2.      Site Plan

Figure 3.      Former Buried Drum Area Sampling Locations

Figure 4.      Areas Identified for Removal Action in the Former
               Buried Drum Area

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                      FIGURE 1
       Site Location and Regional Topographic Map
       King of Prussia Technical Corporation Site
              Winslow Township, New Jersey

       AX£A
\\^=^^.viV*-r-^. •
                                                         . rl
                                  Zae.
              -^   \-
                    \  - *
             Kew j«rs«y Division
            Fish Ciat and Wildlift
                Fi«ld Offic* v   ^~
                     Winslow Township
                    Municipal Landfill
                                                         w
                                                     • «_^
                                                     • ^
A-
                                    •*..
                JOOO


              SCALCWfCIT
                        4000
       Off-Sit« Watar Supply Walls

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             Figure  2
             Site Plan
King of Prussia Technical Corporation Slid
    Wlnslow Township, New Jersey

-------
Figure 3
                                                    Sampling Locations In
                                                Ilia Formar Burlad Drum Araa
                                              Kbt( at PriMtl* Technical Corporalloa
                                                       Whitlow  TowtttMp
                                                     Cwmlwi, Naw
                                                     M-t  a  Onm tffO •»•>« Icraliox

                                                     HW-n»  Monila>iti« «M l
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                                             FIGURE 4
                              Areas Identified for Removal Action
                                    Former  Burled Drum Area
                                King of Prussia Technical Corporation
                                         Wlnslow  Township
                                        Camdan, Haw Jarsay
                                                                   Decontominotion Zone
40    20    0
      •

       Scale in Tee!
                t

Drum Area Boring Location

Monitoring Well Location

Areas Designated for Removal
 Action

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                            ROD TABLES

Table l.       VOCs Detected  in the Former Buried Drum Area

Table 2.       Exposure Parameters For Incidental Soil Ingestion

Table 3.       Indices of Toxicity for Contaminants of Concern  in
               Former Buried  Drum Area

Table 4.       Risk Determination Equations

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                                                         TABLE 1

                                       VOLATILE ORGANIC COMPOUNDS  (VOCs)
                               DETECTED IN THE  FORMER BURIED  DRUM  AREA  SOILS
voc
Acetone
2-butanone
trichloroeth-
ene
tetrachloroeth-
.ene (PCE)
xylene
DB-1 (2-4')
ND
ND
ND
ND
ND
DB-1 (4-61)
SOB
ND
ND
ND
ND
DB-1 (6-8')
ND
ND
ND
ND
ND
DB-2 (2-4')
3300B
7100J
ND
20000
1400
DB-2 (4-6')
ND
ND
92000J
16000000
330000
DB-2 (6-8')
ND
ND
ND
2600000
10000J
DB-3 (0-21)
ND
1800
ND
14000
1800
DB-3 (4-6')
ND
ND
ND
2300000
160,000
DB-3 (6-8')
ND
ND
ND
540000
29,000
VOC
Acetone
tetrachloroeth-
ene (PCE)
xylene
DB-4 (2-4')
ND
3J
ND
DB-4 (4-6')
ND
ND
ND
DB-4 (6-8')
ND
ND
ND
DB-5 (0-2')
ND
12J
ND
DB-5 (2-4')
ND
24
ND
DB-5 (4-6')
ND
10J
ND
DB-6 (0-21)
ND
900J
ND
DB-6 (2-4')
38
41
ND
DB-6 (6^')
11
ND
ND
B: The result is qualitatively invalied because the compund was also detected in the blank at a similar concentration
J: This result should be considered a quantitative estimate
ND: This compound was analyzed but not detected.

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                                                               TABLE 1 (cont.)
                                                  VOLATILE ORGANIC COMPOUNDS (VOCs)
                                           DETECTED IN THE FORMER BURIED DRUM AREA SOILS
voc
Acetone
1,1,2,2 -
tetrachloroeth-
ane
toluene
tetrachloroeth-
ene (PCE)
•2-butanone
DB-7 (0-21)
ND
ND
ND
36
ND
DB-7 (2-41)
ND
ND
ND
ND
ND
DB-7 (6-8')
ND
ND
ND
ND
ND
DB-82-4'
3600
ND
ND
980J
2000
DB-8 (4-61)
660J
ND
ND
III
ND
DB-8 (6-8')
160B
ND
ND
ND
ND
DB-9 (0-2')
41B
28
2J
120
ND
DB-9 (2-4')
ND
26
ND
700
ND
DB-9 (4-6')
190
10
ND
50
ND
VOC
Acetone
2-butanone
1.1A2-
tetrachloro-
ethane
tetrachloroeth-
ene (PCE)
ethylbenzene
xylene
DB-10 (0-2')
ND
ND
ND
350J
ND
ND
DB-10 (2-4')
1800B
1500B
ND
6700
ND
ND
DB-10 (4-6')
ND
ND
ND
27,000
ND
480000
DB-11 (0-2')
ND
ND
ND
17
ND
ND
DB-11 2-4'
33B
ND
ND
10J
ND
ND
DB-11 4-6'
ND
ND
ND
12
ND
ND
DB-12 0-2'
ND
ND
ND
34
ND
ND
DB-12 2-4'
ND
ND
ND
11
ND
ND
DB-12 4-6'
34B
ND
ND
4J
ND
ND
B: The result is qualitatively invalied because the compund was also detected in the blank at a similar concentration
J: This result should be considered a quantitative estimate
ND: This compound was analyzed but not detected.

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                                                               TABLE 1 (cont.)
                                                  VOLATILE ORGANIC COMPOUNDS (VOCs)
                                           DETECTED IN THE FORMER BURIED DRUM AREA SOILS
voc
2-butanone
xylene
tetrachloroeth-
ene (PCE)
DB-13 (0-2')
ND
ND
2B
DB-13 (4-6')
ND
ND
ND
DB-13 (6-81)
9B
ND
IB
DB-14 (0-2')
ND
ND
SO
DB-14 4-45'
8B
ND
ND
DB-14 (6-81)
ND
ND
ND
DB-15 0-2'
ND
5J
200
DB-15 (2-4')
ND
2J
ND
DB-15 (4-6')
ND
3J
3J
VOC
Acetone
tetrachloroeth-
ene (PCE)
xylene
DB-16 (0-2')
ND
2J
ND
DB-16 (2-4')
ND
3J
ND
DB-16 (4-6')
ND
3J
ND
DB-17 (0-2')
ND
7800
ND
DB-17 2-4'
2700
430J
ND
DB-17 (4-61)
200
8J
ND
DB-18 2-4'
ND
21
ND
DB-18 (4-61)
26B
ND
ND
DB-18 (6-81)
21B
ND
ND
VOC
Acetone
methylene
chloride
tetrachloroeth-
ene (PCE)
xylene
DB-19 0-2'
ND
ND
ND
ND
DB-19 2-4'
ND
2J
ND
ND
DB-19 4-6'
ND
ND
ND
ND
DB-20 0-2'
12B
110
ND
1J
DB-20 2-4'
35B
3B
ND
580J
DB-20 4-6'
ND
IB
ND
ND
DB-21 (0-2')
ND
ND
20
ND
DB-21 2-4'
ND
ND
27
ND
DB-21 4-6'
ND
ND
4B
ND
B: The result is qualitatively invalied because the compund was also detected in the blank at a similar concentration
J.  This result should be considered a quantitative estimate
ND: This compound was analyzed but not detected.

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                            Table 2

      Standard Default Exposure Assumptions for Incidental
           Ingestion of Contaminated  Soils  by  Residents
 Body Weight, Adult  (kg)                      70

 Body weight, age  1-6  (kg)                    15


 Averaging time  (years of life):              70


 Soil ingestion  -  age adjusted  (mg/d)         100


 Soil ingestion  age  1-6  (mg/d)                200


 Soil ingestion  -  adult  (mg/d)                100


 Exposure frequency  (d/y)                     350


 Exposure duration (y):               .        30
     The oral potency slope factor and oral RfD for PCE are
presented in Table 2.

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                            Table 3

      Indices of Toxicity for Contaminants Potentially
       of Concern in Former  Drum Burial Area Soils

  Contaminant       Oral RfD  (mg/kg/d)   Oral Potency Slope
  PCE                  l.OOe-02   (a)        5.20e-02  (c)
  Xylene               2.00e+00   (a)
  1,2-dichlorobenzene  9.00e-02   (a)
  1,4-dichlorobenzene      NA              2.40e-02  (b)

  a    Obtained from the IRIS database.
  b    Obtained from the Health Effects Assessment
      Summary Tables
  c    Provided by EPA  Environmental Criteria and Assessment
      Office (ECAO), Cincinnati, OH.
  NA   Not Available
     The algorithms for determination of  the cancer risk and
hazard index associated with incidental ingestion of soils
contaminated with PCE are shown in Table  3.

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                            Table 4
Determination  of  cancer  risk:

                                    IRS.
Cancer Risk  =             SC  «  EF  •  ED  •  106ma/kq •  SF
                             BW .  AT •  365 d/yr

                                    IRS.
Hazard Index =           SC  •  EF  •  ED  •  I06ma/ka	
                          BW  •  ED  •  365 d/yr  • RfD
Where,

AT   =         Averaging Time

BW   =         Body Weigl.t

ED   =         Exposure Duration

EF   =         Exposure Frequency

IRS.  =          Soil Ingestion Rate for Adults

RfD  =         Reference Dose

SC   =         Contaminant Concentration in Soil  (mg/kg)

SF   =         Cancer Slope Factor

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RESPONSIVENESS SUMMARY

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                        RESPONSIVENESS SUMMARY
                     KING OF PRUSSIA SUPERFUND SITE
                     WINSLOW TOWNSHIP, NEW JERSEY
 INTRODUCTION

 This Responsiveness Summary provides a summary of the public's comments and
 concerns regarding the Proposed Plan for Operable Unit Two (OU2) for the King of
 Prussia (KOP) Superfund Site.  OU2 deals with the soils associated with the Former
 Buried Drum Area at the site. This Responsiveness Summary also summarizes the
 Environmental Protection Agency's (EPA's) responses to the comments received.

 EPA held a public comment period from August 16, 1995 through September 14, 1995 to
 provide interested parties the opportunity to comment on the Proposed Plan.  In
 addition, on August 23, 1995, EPA held a public meeting to discuss the preferred remedy
 identified in the  Proposed Plan for OU2 along with the rationale for this preference, and
 to provide an update on the progress of the cleanup of the site.

 No objections to the Proposed Plan for OU2 were received during the  public comment
 period.

 This Responsiveness Summary is divided into the following sections:

 I.     RESPONSIVENESS SUMMARY OVERVIEW:  This section briefly describes
      the site background and preferred remedial alternative for the soils associated
      with the Former Buried Drum Area.

 II.    BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS:
      This section provides the history of community concerns and interests regarding
      the King of Prussia site.

 III.   COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
      CONCERNS AND RESPONSES: This section summarizes the oral comments
      received by EPA at the public meeting, and EPA's responses to  those comments.
      No written comments were received during the public comment  period.

I.  OVERVIEW

The King of Prussia site is located on Piney Hollow Road in Winslow Township,
Camden County, New Jersey (see Figure 1).  The ten-acre site is in a rural area
approximately 30 miles southeast of Philadelphia, Pennsylvania.

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 In 1970, the King of Prussia Technical Corporation purchased a tract of land owned by
 Winslow Township for the purpose of constructing a waste recycling facility.  Operations
 at the site began by January 1971.  Six lagoons were used to process liquid industrial
 waste.  The stated intention of the KOP Technical Corporation was to convert these
 wastes to materials that could be marketed for construction purposes and other uses.
 However, the  KOP Technical Corporation was unable to market these materials and the
 site soon contained more waste than it could process and sell.

 The KOP Technical Corporation filed for bankruptcy in 1974. Prior to declaring
 bankruptcy, KOP sold its hauling operation to Evor Phillips, Inc. which subsequently
 purchased  the site property. It is believed that operations ceased and the site was
 abandoned in  late 1973 or early 1974. In 1976, Winslow Township foreclosed on the
 property for failure of Evor Phillips to pay taxes.  Winslow Township is the current
 owner of the property.

 The New Jersey Department of Environmental Protection (NJDEP) was first notified of
 possible unauthorized activities at the site in January 1975.  Subsequent field inspections
 and a groundwater study performed in 1976 indicated contamination of site soils and the
 underlying ground water.

 EPA confirmed the contamination with additional sampling and field investigations
 during 1979, 1980 and 1982. In December 1985, the site was formally placed on the
 National Priorities List of Superfund sites. Under EPA oversight, a group of potentially
 responsible parties (PRPs) conducted a Remedial Investigation and Feasibility Study
 (RI/FS) at the site starting  in 1985.

 The RI showed that beryllium, chromium, copper, nickel and zinc were the principal
 contaminants detected in the soil and sludge in and around the former lagoon area and
 in the swale.  Additional metals contaminants were found in two torn and rusted tankers
 on the site. The site also had an area with an undetermined number of buried drums
 and containers. A partially buried drum and some soil in this Buried Drum Area were
 sampled during the RI.  Analysis of these samples indicated that  the drums and soils in
 the Buried Drum Area contained high concentrations of volatile and semi-volatile
 organic compounds.

 During the RI, it became evident that organic and inorganic (metals)  contamination was
 migrating vertically downward to the ground water.   Many of the compounds found in
the soil, sludge and upper aquifer are known to have adverse carcinogenic and non-
carcinogenic health effects on humans.

Based on the studies and public input, EPA issued a Record of Decision (ROD) on
September 28, 1990 selecting a remedy for the KOP site. The remedy addresses the
metals-contaminated soil, the contaminated ground water, as well as the contaminated
sediments,  sludges, and buried drums and tankers on the site.

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 One component of the 1990 ROD was a requirement to characterize the residually-
 contaminated soils in the buried drum area. EPA further explained in the ROD that a
 subsequent remedial decision involving the soils associated with this area would be made
 after the additional soils data resulting from this characterization were obtained and
 evaluated.

 To facilitate remedial  activities, EPA divided the cleanup  into three remedial phases, or
 operable units (OUs).  OU1 deals with the cleanup of the metals-contaminated soil;
 OU2 addresses the removal of contaminated soils in the Former Buried Drum Area; and
 OU3 involves the cleanup and reinjection of the ground water.

 In November 1991, EPA removed the rusted tankers from the site and the drums from
 the Buried Drum Area (now known as the Former Buried Drum Area) through a
 removal action.  In April  1991, EPA issued an Administrative Order, Index No. II
 CERCLA 10106, directing a group of five Potentially Responsible Parties (PRP Group)
 to complete the  remedial activities described in the September 1990 ROD.  Since then,
 the PRP Group  has actively pursued the site's remediation.

 In June 1993, the PRP  Group completed OU1  by treating approximately 19,200 tons of
 metals-contaminated soils and sludges. Subsequently, the  PRP Group initiated
 construction of the groundwater extraction, treatment and reinjection system designated
 OU3.  This system began treating contaminated ground water in early 1995 and will
 continue operating until the ground water meets the safe drinking water levels set forth
 in the September 1990  ROD.

 The implementation of OU2 began with the analyses of soil within the Former Buried
 Drum Area.  The soil was sampled and analyzed by the PRP Group in 1992. Using this
 data, EPA performed a Risk Assessment to evaluate any risks that may be posed by the
 soils in the Former Buried Drum Area. Based on this assessment, and the subsequent
 removal of soils posing an unacceptable risk, EPA has  selected a No Further Action
 remedial alternative to  address the soils associated with the Former  Buried Drum Area.

 II     COMMUNITY INVOLVEMENT AND CONCERNS

The EPA relies on public comment and discussion to ensure the concerns of the
 community are considered in selecting an effective remedy for each Superfund site.
 From the early stages of the remedial investigations, through remedial design and
 remedial actions, EPA has worked closely with the local community  near the KOP site.
EPA has held public meetings prior to each stage of the remedial process, and has been
and continues to be available to meet with and answer questions from the local
community.

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 The Proposed Plan for OU2 was distributed to the public and EPA provided a 30-day
 public comment period which ended on September 14, 1995.  In addition, on September
 23, 1995, EPA held a public meeting in Winslow Township to discuss this No Further
 Action recommendation and to answer questions.

 Comments received at this public meeting are addressed in Section III of this
 Responsiveness Summary.

 Ill    COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS
       CONCERNS. AND RESPONSES

 This section summarizes comments received from the public during the public comment
 period, and EPA's response to those comments.  It should be noted that  no written
 comments were received and all comments summarized below were received during the
 August 23, 1995, Public Meeting.

 SUMMARY OF QUESTIONS AND EPA'S RESPONSES FROM THE AUGUST 23, 1995
 PUBLIC MEETING

 A public meeting was held on August 23, 1995 at 7:00 p.m. at the Winslow Township
 Municipal Hall, Route 73, Braddock, New Jersey. A brief presentation was given by
 EPA on the history of the site, the current status of the cleanup and on the proposed No
 Further Action remedy for the soils associated with the Former Buried Drum Area. A
 representative from the PRP Group updated the community regarding the operation of
 the soil washing plant that was previously located on site and that had successfully
 cleaned the metals-contaminated soils at the site.  The PRP Group representative also
 discussed the groundwater treatment plant, which is currently operating at the site.

 Although the main purpose of the Public Meeting was to present the Proposed Plan for
 OU2, all comments and questions were in reference to the groundwater cleanup
 activities.  They are provided below.

 Comment 1:  What happens to the materials that are being moved off-site during the
groundwater treatment? Where is off-site?

 Response: Currently, the only material being moved-off site is the sludge from the
groundwater treatment plant.  The treatment process produces what is considered non-
hazardous waste. The waste has been accepted by the Pennsylvania Department of
Environmental Resources as non-hazardous material. It is shipped from  the KOP site to
the GROWS Landfill in Pennsylvania.  The GROWS facility is a permitted landfill.

Comment 2:  Are volatile organics being vented into the air during operation of the
groundwater treatment plan?

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 Response: Yes.  The groundwater treatment facility is regulated by an air permit that
 allows a certain amount of volatile organic compounds to be released into the air.  If
 levels of such volatiles exceed the allowable  levels, additional treatment would be
 necessary. As the volatile contamination in the ground water is in the low part per
 billion range, it is unlikely that the permit levels will be contravened. All volatiles
 released to date are within the permit requirements.

 Comment 3:  Are particulates being vented into  the air during operation of the
 groundwater treatment plant?

 Response: There are no particulates being vented into the air during operation of the
 groundwater plant.

 Comment 4:  Which direction does the ground water flow?

 Response: The ground water flows towards the southwest, in the direction of the Great
 Egg Harbor River.

 Comment 5:  Is the water problem on Spring Road related to what is going on at the
 King of Prussia site.

 Response:  No. The contamination at the King of Prussia site is very localized. The
 plume of contamination is relatively small and does not pass near Spring Road.

 Comment 6:  How long will it take to clean the ground water?

 Response:  Based on computer modelling, it  should take about  17 years to reduce the
 contamination in  the water to drinking water levels.  However,  actual cleanup could be
 faster or slower depending on a number of variables such as the concentration of the
 influent, and  the ability of the local soils to retain the volatile chemical contaminants.

 Comment 7:  Who is paying for the cleanup? How much does  it cost?

 Response:  A group of five  Potentially Responsible Parties is paying for the cleanup. To
date, the PRPs have spent $10 million for remedial activities and about $2 million  on
investigations at the site.  Future cost, in current value dollars, could range from $3
million to $10 million, depending on how long groundwater pumping and treatment are
required.

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SITE
Name            :
Location/State  :
EPA Region      :
HRS Score  (date)
Site ID #       :

ROD	
Date Signed:
Remedy:
                          ROD FACT SHEET
King of Prussia
Winslow Township, New Jersey
2
29.58 (10/23/81)
SID 00551; EPA ID NJD980505341
9/27/95
No Action (contaminants in.the soil around a
former buried drum area are below EPA's risk
based cleanup level, therefore remedial
action is not warranted)
Operating Unit Number:   OU-2
Capital cost:             NA
Construction Completion:  NA
0 & M        :            NA
Present worth:            NA
LEAD
Lead:
Primary contact:
Secondary contact
Main PRP(s)
PRP Contact:
     EPA
     Jon Gorin, USEPA   (212)  637-4361
     Kim O'Connell, USEPA   (212) 637-4397
     Johnson Matthey Inc.,  Cabot Beryl
     Company, Carpenter Technology, Ford
     Motor Company, Reutgers-Nease' Chemical
     Company
     Frank Opet, Vice President Health,
     Safety & Environmental Affairs Johnson
     Matthey, Inc. (609) 384-7278
WASTE
Type:
Medium:
Origin
Est.  quantity:
     Volatile Organic Chemicals
     Soil,  Ground Water
     Buried Drums
     NA

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