United StatM
Environmental Protection
Agency
Office of
Emergency end
Remedial Response
EPA/ROD/R02-85/021
September 1985
EPA
Superfund
Record of Decision
Swope Oil, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing!
1. REPORT NO.
EPA/ROD/R02-85/021
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Swope Oil, NJ
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September 27.1985
6. PERFORMING ORGANIZATION
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
0. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
¥
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
The Swope Oil Company site ia located in an industrial complex in north-
ern Pannsaukan Township, Camden County, New Jersey. Swope Oil operated a
chemical reclamation operation at this two-acre site from 1965 until
December 1979. Operations included buying, selling, dealing in, manufac-
turing, and processing, chemicals, chemical compounds and paints. Products
processed at the site included phosphate esters, hydraulic fluids, paints
and varnishes, solvents, oils, plasticizers, and printing inks. Waste 1
uids and sludges from the Swope Oil operation were discharged to an exca-
vated, unlined lagoon. Contaminated material was also ponded within a diked
tank farm and in an exposed drum storage area. The Company, which ceased
operation in December 1979, has declined to take any action at the site.
The cost-effective remedial actions selected for this site include:
construction of a cap; preparation of a supplemental RI/PS to evaluate the
extent of ground water contamination and to develop and evaluate appropriate'
remedial alternatives; removal of tanks and buildings with offsita inciner-
ation, treatment (aqueous wastes) or disposal (non-incinarable wastes) of
contents, and off site disposal of tanks and building debris; excavation
offaita disposal of the buried sludge waste area; excavation of up to
7.
KEY WORDS AND DOCUMENT ANALYSIS
'DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Croup
Record of Decision
Swope Oil, NJ
Contaminated Media: gw, soil
Key contaminants: organics, PCBs,
sludge
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS iTIliS Reporti
None
21. NO. OF PAGES
83
20. SECURITY CLASS (This pagel
None
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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SWOPE OIL, NJ
(Continued)
1.5 feet of contaminated soil containing PCBs greater than Sppm and offsite
disposal; excavation of up to 1.5 feet of contaminated soils below the la-
goon containing PCBs greater than Sppm and offsite disposal (this remedial
action will be reevaluated should removal of 1.5 feet of soil not achieve
the Sppm goal); sampling, excavation and offsite disposal of contaminated
soils containing greater than Sppm PCBs in the parking lot area and along
the railroad right-of-way adjacent to the lagoon. The estimated total capi-
tal cost for this remedial action is $5,590,356 and the O&M costs are esti-
mated to be $33,000 per year.
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EPA Form 2220-1 (Rev. 4-77) (Reverse)
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RECORD OP DECISION
. REMEDIAL ALTERNATIVE SELECTION
Site: Swope Oil Company, Pennsauken, New Jersey
Documents Reviewed
I an basing my decision on the following documents describing
the analysis of cost-effectiveness of remedial alternatives
for the Swope Oil site:
• Swope Oil Company Site Remedial Investigation and
Feasibility Study, Pennsauken Township, New Jersey
dated June 1985.
- Staff summaries and recommendations.
- Responsiveness Summary for the Swope Oil site.
Description of Selected Remedy
- Removal of tanks and buildings with off-site incineration,
treatment or disposal of tank contents, and off-site
disposal of tanks and building debris.
- Construction of a cap at the site.
- Preparation of a supplemental remedial investigation
and feasibility study to evaluate the extent of groundwater
contamination and to develop and evaluate appropriate
remedial alternatives.
- Excavation and off-site disposal of the buried sludge
waste area in the northeast corner of the site.
- Excavation of up to 1.5 feet of contaminated soil
containing PCBs greater than 5 ppm and off-site
N disposal.
•,
- Excavation of up to 1.5 feet of contaminated soils
below the lagoon containing PCBs greater than 5 ppm
and off-site disposal. Should additional sampling in
this area during design determine that removal of 1.5
feet of soil will not achieve the 5 ppm goal, the
remedial action for this area will be reevaluated.
- Sampling, excavation and off-site disposal of contam-
inated soils containing greater than 5 ppm PCBs in
the parking lot area and along the railroad right-of-
way adjacent to the lagoon.
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Declaratipns
Consistent with the Comprehensive Environmental Response
Compensation and Liability Act of 1980 (CERGLA), and the
National Contingency Plan (40 CFR Part 300), I have determined
that the removal of tanks, buildings and debris as well as
contaminated soils and sludges for transport and disposal to
the appropriate RCRA and TSCA approved facilities in conjunction
with capping the site is the selected remedial alternative
for the Swope Oil site. I have also determined that a
supplemental remedial investigation and feasibility study
should be undertaken to address off-site groundwater
contamination attributable to the site.
I have determined that the implementation of this alternative
will provide adequate protection of public health, welfare and
the environment. The State of New Jersey has been consulted
and agrees with the proposed remedy.
I have also determined that the action being taken is appro-
priate when balanced against the availability of Trust Fund
monies for use at other sites. In addition, removing the
contaminated materials to the appropriate RCRA and TSCA
approved facilities, capping the site, and conducting a
supplemental remedial investigation and feasibility study to
address groundwater contamination attributable to the Swope
Oil site is cost-effective, implementable and technically
sound when compared to other remedial action alternatives,
and is necessary to protect public health, welfare and the
environment.
77
bL. J- A ;
Date Christopher J. Dagtjett
Regional Administrator
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SUMMARY FOR REMEDIAL ALTERNATIVE SELECTION
SWOPE OIL SITE
PENNSAUKEN TOWNSHIP, NEW JERSEY
Site Location & Description;
The Swope Oil Company Site is located in an industrial
complex in northern Pennsauken Township, Camden County,
Mew Jersey, at 8281 National Highway (see Figures 1 and 2).
The 2-acre site is roughly triangular, bounded on the
southeast by National Highway and on the southwest and north
by railroad rights-of-way and warehouses. Pennsauken Creek
is about 0.8 mile northeast of the site and the Delaware
River is 1.2 miles to the northwest. A water supply well
operated by the Merchantville-Pennsauken Water Commission
(MPWC) is located less than 100 feet southwest of the site.
Numerous other municipal wells are located in the area,
especially to the west near the Delaware River. Pennsauken
High School is about 0.5 mile to the northeast. The nearest
residential areas are the townships of Delair and Morrisville,
about 0.5 mile west and southwest, respectively.
Waste liquids and sludges from the Swope Oil operation were
discharged to an excavated, unlined lagoon. Contaminated
material is also ponded within a diked tank farm and in an
exposed drum storage area.
Pertinent features of the Swope Oil Company site include
two buildings, a diked tank farm, an open drum-storage area,
and an unlined lagoon. Primary access to the site is via
National Highway. A chain link fence erected by the potential
responsible parties encircles the site. The main building
is abandoned and contains equipment, and storage containers
used by a producer of textile processing agents, Berg
Laboratory, which had leased the site. A smaller structure,
the "distilling house" contains equipment used in the reclaiming
operation conducted by Swope Oil Company. A 10,000-gallon,
No.5 fuel oil storage tank is located underground near the
distilling house. Behind the distilling house is a drum
storage area. Adjacent to the drum storage area are about
sixteen 3,000- to 20,000-gallon storage tanks surrounded by
a 10-inch earth dike. Several inches of bluegreen liquid
have collected within the dike and near the drum storage
area.
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North of the main building is the unlined lagoon, estimated
to be 100 feet long, 50 feet wide, and three to ten feet
deep, containing 90,000 to 180,000 gallons of liquid and
sludge. An 8-inch earth dike surrounds the lagoon. The
liquid and sludge in the lagoon and the contents of the drums
are currently being removed from the site by the potential
responsibile parties.
Site History
Swope Oil Company operated a chemical reclamation operation
from 1965 until December 1979. Operations included buying,
selling, dealing in, manufacturing, and processing oils,
chemicals, chemical compounds and paints. Products believed
to have been processed at the site include phosphate esters,
hydraulic fluids, paints and varnishes, solvents, oils,
plasticizers, and printing ink.
In 1975, an inspector from the State Bureau of Air Pollution
visited the site and recommended that the Bureau of Water
Pollution Control inspect the site. In subsequent visits,
officials observed discharges to drainage ditches on the site
and probable migration towards Pennsauken Creek via storm
sewers. Swope Oil Company was cited in 1975 for operating
without proper permits, and again in 1979 for failure to
prepare, maintain, or fully implement a Spill Prevention,
Containment and Countermeasure Plan. The company, which
ceased operation in December 1979, has declined to take any
action at the site because of limited finances.
On October 17, 1983, a State Superfund Contract was signed by
both EPA and NJDEP. This contract provided funds for the.
performance of a focused feasibility study on the surface
drums and lagoon waste, and for the development of a long
term remediation plan to address the waste problems posed by
the Swope Oil site.
On February 8, 1984, a draft focused feasibility study (FFS)
was submitted to EPA. This report recommended the following:
1. Off-site disposal of drums. .
2. Off-site disposal of lagoon liquid and sludge, and
backfilling the lagoon prior to placing a temporary cap.
3. Installation of a security fence.
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On May 14, 1984, a group of the potential responsible parties
signed a consent order with EPA to undertake the actions
described in the FFS prepared for the site. This work is
currently underway and is expected to be completed in the
near future.
- Site Geology
The Swope Oil Site is located in Pennsauken Township, New
Jersey, within the Atlantic Coastal Plain which is a sandy
area characterized as a low-lying, gently rolling plain that
ranges in altitude from sea level to above 33 feet. The
Atlantic Coastal Plain is underlain by a wedge-shaped mass
of unconsolidated sediments composed of clay, silt, sand,
and gravel. This wedge-shaped deposit thins to a featheredge
along the Fall Line and attains a thickness of over 6,000
feet at the tip of the southern edge of New Jersey. Although
these deposits are covered by water further east, they continue !
to the edge of the continental shelf with a maximum thickness
of about 8 to 10 miles.
The outcropping coastal plain sediments in the study area are
the Potomac Group and the Raritan and Magothy Formations
(PRN) deposits. The thickness of PRM deposits increases in
a downdip (southeasterly) direction, reaching approximately
1400 feet in southeastern Camden County. In the Pennsauken
Township area, they are less than 300 feet thick. Basically,
PRM deposits consist of interbedded gravel, sand, silt, and
clay, which are channel deposits characterized by limited
areal extent, lenticular in shape, and interbedded with
gravel, sand silt, and clay. Higher percentages of coarse-
grained materials (sand and gravel) exist near the source
area, while downdip fine-grained sediments (clay and silt)
predominate, especially in the southeastern portion of Camden
County..
.The PRM aquifer is divided into three hydrologic units: upper,
-middle, and lower aquifers. The upper unit consists mainly
of sands of the Magothy Formation, and the middle and lower
units consist mainly of sands found in the Raritan Formation
and .the Potomac Group. The lower aquifer in the area is
overlain by and hydraulically connected to Pleistocene deposits
near the Delaware River where it is a water table (non-confined)
aquifer. Locally, the presence of clay lenses (10 feet or
more in thickness) makes the lower aquifer act as a semi-
confined aquifer. In northern Camden County, PRM sediments
form a highly productive aquifer.
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REMEDIAL INVESTIGATION ACTIVITIES AND RESULTS
Remedial Investigation Activities
The remedial investigation of the Swope Oil site included the
following activities:
- Collection of nine soil samples obtained from test borings
on-site and priority pollutant analyses of all samples.
- A magnetometer survey
- Collection of nineteen surface soil samples and priority
pollutant analyses of all samples
- Collection of samples from forty-one tanks and priority
pollutant analyses of all samples
- Drilling of five monitoring wells in the unconfined aquifer
- Collection of fifteen groundwater samples from new monitoring
wells and local potable wells and priority pollutant
analyses of all samples
- A pump test of the lower aquifer
Remedial Investigation Results
The results of the remedial investigative activities indicated
the following:
Laboratory analyses revealed that subsurface soils contained
significantly lower levels of contaminants than surface
soils. However, phthaiates, PCBs, volatile organics and
inorganic contaminants were detected in subsurface samples.
Contamination was found at depths as great as 23 and 42 feet.
PCB contamination is widespread in surface soils on-site.
All surface soil samples collected contained PCBs. Four
types of PCBs were found: PCB-1242, PCB-1248, PCB-1254 and
PCB-1260. PCB concentrations in surface soil samples were
generally in the 50-500 ppm range. Test boring samples
obtained at depths of 0-1.5 feet indicated a significant
reduction in PCB concentrations when compared to surface soil
samples. PCB levels below 1.5 feet depth are generally less
than 1 ppm. Only one sample, along the southwest border of
the site, contained PCBs greater than 500 ppm.
Surface soils are also highly contaminated with phthalate
esters. Concentrations of phthalates ranged from 1 to 6000 ppm
and bis (2-ethylhexyl) phthalate was found to be the most
predominant phthalate contaminant. High concentrations of
phthalates were found in surface soils and reduced levels in
shallow test borings obtained at 0-1.5 feet depths.
t^-f
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Several organic and inorganic contaminants were detected in
many of the surface soil samples. Tetrachloroethane, methylene
chloride, naphthalene, ethylbenzene, total xylenes, phenol,
trans-1,2-dichloroethene and 2-methyl naphthalene are organic
compounds which were found. Also detected in the surface
soil samples were inorganic contaminants including mercury,
copper, chromium, cadmium and barium.
As a result of investigative activities, an area of buried
sludge was identified at the site. A series of sixteen hand
auger borings were used to estimate the limits of the sludge
burial area. It is estimated that approximately 1,375 cubic
yards of contaminated sludge remains buried on-site in an
oval shaped area approximately 100x150 feet and 3 to 5 feet
in thickness.
Laboratory analyses of samples of the sludge indicates the
presence of xylene, phthalates, and PCBs. The results of a
magnetometer survey conducted over the sludge burial area
indicated that buried drums may have been disposed of with
the sludge.
It is estimated that the forty-one tanks on-site contain
41,000 gallons of still bottoms and paint wastes. None of
these tanks contained waste with PCB concentrations greater
than 50 ppm.
Laboratory results of groundwater samples collected on-site
and at nearby municipal wells indicated organic and inorganic
contamination. The unconfined aquifer beneath the site
contains volatile organics, including; tetrachloroethylene,
1,1,1-trichloroethane, trans-1,2-dichloroethene, and
1,1-dichloroethene. Bis (2-ethylhexyl) phthalate and di-n-
octyl phthalate were base neutral contaminants detected.
Inorganic contaminants including lead, chromium and mercury
were found. Also detected were PCBs up to 1.7 ppb.
'Samples taken from the confined aquifer beneath the site
were determined to be contaminated with volatile organics,
generally greater than 100 ppb, and mercury which at times
exceeded the drinking water standards Maximum Concentration
Limit (NCL) of 2 ppb. A pump test of National Highway Well
No. 1, located adjacent to the site, indicated a high leakage
rate from the unconfined to the confined aquifer. This
leakage appears to be to the south of the site, where a
window through the clay layer may exist. This indicates a
direct route of contaminant migration from the upper to the
lower aquifer. During non-pumping conditions, the downward
velocity would be very low.
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The municipal water supply well located adjacent to the site
is screened in the lower aquifer. This municipal well was
sampled in addition to three other municipal wells in the
area. Three of the four off-site wells showed contamination
though the specific compounds varied from one well to another.
Although volatile organics were found in the municipal wells,
only MPWC Well No. 1 contained the same contaminants that were
found at the Swope Oil site. They included volatile organics
and heavy metals. Due to the complex hydrogeology in the
vicinity of the site, variously located pumping stresses upon
the lower aquifer, and the industrialized nature of the area,
it has been extremely difficult to determine the impact of
the Swope Oil site, if any, on these other wells.
•
The current condition of the remaining tanks and process
vessels and the contaminated surface soils pose a threat to
the public and the environment. The materials contained in
the tanks and in the soil provide a potential for harm for
those who come in direct contact with them. Detrimental
impacts to the local environment may result from the release
of contaminants from these tanks.
Migration of pollutants into the underlying groundwater has
added to the contamination of the uncorifined and confined
aquifers. The actual limit of groundwater contamination in
these aquifers is currently unknown. The confined aquifer is
a major source of drinking water in the surrounding area.
Screening of Remedial Action Technologies
The evaluation of the results of the remedial investigation
provided the basis for establishing the cleanup goals and
objectives for site remediation. The cleanup goals and
objectives for the Swope Oil site include the following:
'Minimize the risk to the public from exposure to waste and
contaminated soils on the site.
'Prevent the migration of contamination from wastes left on
the site.
'Protect workers from on-site wastes during remedial action
activities.
'Eliminate the future risk of ingestion by present and
potential users from contaminated groundwater resulting
from the Swope Oil site.
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The initial step in the evaluation of remedial alternatives
is the screening of potential remedial technologies. The
screening procedure was used to eliminate those technologies
which were technically infeasible or environmentally unacceptable,
In addition, cost considerations were used in the technology
screening process.
The results of the screening procedure identified the feasible
remedial action components, which when integrated, resulted in
establishing remedial alternatives.
REMEDIAL ALTERNATIVE COMPONENTS
The remedial alternative components for the Swope Oil site
are separated into three categories as follows:
(1) Tank and Building Alternatives
(2) Contaminated Soil Alternatives
(3) Water Supply Alternatives
Cost estimates for all remedial alternatives are included in
Appendix A.
Source Control/Removal and Disposal of Tanks and Building Waste
The alternatives discussed below will address the necessary
remedial actions for the buildings, tanks, foundations,
underground utilities and tank wastes.
Tank and Building Alternatives
T-1 No action
T-2 Tank and building removal; off-site incineration,
treatment or disposal of tank contents. Off-site disposal
(non-incinerable solids) of tanks and building debris.
T-3 Tank and building removal; off-site incineration,
treatment or disposal of tank contents. On-site landfill
disposal of the tank and building debris.
Alternative T-1
Under this alternative, no remedial action will be taken to
address the tanks, buildings, and wastes remaining in the on-
site tanks. A minimum action related to this alternative
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would include an inspection of the tanks and the sealing of any
tank openings. The implementation of this alternative depends
directly upon the selection of the no-action alternative for
the remediation of soil contamination.
Alternative T-2
This alternative .includes the removal of all buildings, tanks,
their foundations and appurtenances, and the tank wastes.
Underground utilities would be cleaned and sewer lines sealed.
Salvageable equipment would be cleaned and decontaminated as
•required. Materials that cannot be salvaged would be loaded
into trucks and hauled to an approved landfill.
The entire contents of the tanks will be removed as part of
this alternative. The materials will be then be separated
into aqueous wastes, organic phase wastes, and solid wastes
(incinerable and non-incinerable). Incinerable waste solids
and organic waste would be shipped off-site to a RCRA approved :
incineration facility. The non-incinerable solid waste -
material would be transported off-site to an approved RCRA
disposal facility. The aqueous waste would be transported to
an off-site to a RCRA approved treatment facility.
This alternative meets the goals of CERCLA and attains or
exceeds federal environmental regulations.
Alternative T-3
This alternative includes the removal of all buildings, tanks,
foundations and appurtenances, and tank wastes. Underground
utilities would be cleaned and sewer lines sealed. As part
of this alternative, the entire contents of the tanks would
be separated into aqueous, organic, and solid waste phases.
The aqueous waste would be transported to an approved RCRA
facility for treatment. Any incinerable waste solids and
organic waste would be shipped off-site to a RCRA approved
incineration facility. The non-incinerable solid waste would
be transported off-site to an approved RCRA disposal facility.
Salvageable equipment would be cleaned and decontaminanted as
required. The remaining demolition debris would be landfilled
on-site with the contaminated soils. A detailed description
of the on-site landfill is contained in the evaluation of
contaminated soil alternatives.
This alternative meets the goals of CERCLA and attains or exceeds
federal environmental requirements.
iym ;;; -: •,
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Source Control/Contaminated Soil Alternatives
The following remedial alternatives address the necessary
remedial action for the contaminated soil and sludges currently
on-site.
Contaminated Soil Alternatives
S-1 No action-monitoring
S-2 Cap site
S-3 Excavate 1.5 feet of soil*, landfill on-site, cap site
S-4 Excavate 1.5 feet of soil*, landfill off-site, cap site
S-5 Excavate 1.5 feet of soil*, incinerate off-site, cap site
S-6A Excavate sludge and 1.5 feet of soil*, incinerate sludge
and soil hotspots off-site, landfill remaining soils on-
site, cap site
S-6B Excavate sludge and 1.5 feet of soil*, incinerate sludge
and soil hotspots off-site, landfill remaining soils off-
site, cap site
S-6C Excavate sludge and 1.5 feet of soil*, incinerate soil
hotspots, landfill soils and sludge on-site, cap site
S-60 Excavate sludge and 1.5 feet of soil*, incinerate soil
hotspots, landfill soils and sludge off-site, cap site
S-7 Excavate soils to background concentrations of all
contaminants, landfill disposal off-site
5-8 Excavate soils to background concentrations of all
contaminants, incinerate off-site
*NOTE; For the purposes of developing cost estimates and
otherwise evaluating the relative merits of the various
alternatives, it was estimated that 1.5 feet of soil would
- . . need to be removed to reduce PCB levels to near background
conditions. Excavation of 1.5 feet of soil would also
remove a significant amount of the volatile organic
contamination.
Alternative S-1
Under this alternative, no remedial action will be taken for
the contaminated soil existing on-site. A long-term monitoring
program of air, groundwater, surface water and sediment would
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be.implemented. Groundwater monitoring wells constructed
during the remedial investigation would be used to monitor
the groundwater.
Alternative S-2
This alternative involves capping the entire site after the
tanks, buildings and foundations are dismantled and removed.
The contaminated soils would remain in place and be covered
by a RCRA approved cap. This alternative would minimize the
impact of contaminants at the site by reducing risks associated
with direct contact and contaminant migration. A cap constructed
over the site will minimize infiltration and act as a barrier
to isolate the contaminated soil. A typical cross section
of the cap is shown in Figure 3. The cap will.consist of a
low permeability clay (hydraulic conductivity £ 10~7 cm/sec)
and a flexible membrane. "~
The cap would be constructed with clay brought in from off- •
site borrow areas. Total clay thickness would be 24 inches.
On top of the clay barrier .would be a 50 mil synthetic liner
and a minimum 12-inch sand drainage layer which will act as a
conduit for any water that infiltrates the topsoil. A geo-
textile fabric would be placed on top of the drainage layer
to minimize clogging. A minimum 24-inch cover layer of
uncompacted topsoil/ loam or organic material capable of
supporting vegetation would be placed over the geotextile
fabric.
Alternative S-3
This alternative involves excavating the top 1.5 feet of soil
across the site for disposal in a landfill constructed on-
site in compliance with TSCA and RCRA requirements. Following
the excavation and disposal on-site of approximately 7,275
cubic yards of contaminated soil, the site would be capped.
The removal of the top 1.5 feet of soil will significantly
reduce the high concentration of contaminants in the surface
soils. This determination is based on the results of surface
soil samples and soil boring samples. PCB concentrations in
surface soil samples were generally in the 50-500 ppm range.
Test boring samples obtained at depths of 0-1.5 feet indicated
a significant reduction in PCB concentrations when compared
to surface soil samples. PCB levels below 1.5 feet are
generally less than 1 ppm. Similarly, high concentrations of
phthalates were found in surface soils and reduced levels in
shallow test borings obtained at 0-1.5 feet depths. Phthalate
levels below 1.5 feet were generally less than 25 ppm.
This alternative meets the goals of CERCLA and attains or
^exceeds_Pe_deral_ enyironmental regulations. ^
'"'""' ' " ' ' —«-».,-.-- " .-.. .~r- ..-_n^.^-^n~, .. -. . . ' '' ' - — •
-------
-11-
Alternative S-4
This alternative involves excavating the top 1.5 feet of soil
across the site. The PCB contaminated soil would be transported
for disposal to RCRA and/or TSCA approved hazardous waste
landfill. Following the soil excavation, the site would be
capped.
This alternative meets the goals of CERCLA, and attains or
exceeds Federal environmental regulations.
Alternative S-5
This alternative involves excavating the top 1.5 feet of soil
across the site. The PCB contaminated soil would be transported
off-site to an approved TSCA incineration facility, Following
the soil excavation, the site would be capped.
•
This alternative meets the goals of CERCLA and attains or
exceeds Federal regulations.
Alternative S-6A
This alternative involves the excavation of the top 1.5 feet
of soil and the buried sludge. The sludge material, and the
soils with PCB concentrations greater than 500 ppm, would be
taken to a TSCA approved incineration facility. The remaining
excavated material would be disposed of in an on-site landfill.
The on-site landfill would meet the requirements of RCRA and
TSCA The bottom liner would be a combination of clay and
synthetic material. A leachate collection and removal system
would collect any leachate generated during the life of the
landfill. A geotextile filter fabric would be placed between
the waste and the leachate collection zone to prevent clogging
of the collection zone by soil fines. The leak detection
zone is directly beneath the liner and monitors the integrity
'of the liner. Both the leachate collection and leak detection
zones would have a leachate collection system. The secondary
liner would be a composite liner of synthetic membrane and
clay. The membrane would have a minimum thickness of 30
mils. The clay barrier would be 24 inches thick and have a
permeability of 10~7 cm/sec. A typical landfill cross-section
is shown in Figure 4.
This alternative meets the goals of CERCLA and attains or
exceeds Federal environmental regulations.
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-12-
Alternative S-6B
This alternative involves the excavation of the top 1.5 feet
of soil and the buried sludge. The sludge material and the
soils with PCB concentrations greater than 500 ppm would be
taken to a TSCA approved incineration facility. The remaining
contaminated soil and sludges would be transported to off-site
RCRA and/or TSCA approved hazardous waste management facilities
for disposal. Following the excavation, the site would be
capped.
This alternative meets the goals of CERCLA and attains or
exceeds Federal environmental regulations.
Alternative S-6C
This alternative involves the excavation of the top 1.5 feet
of soil and the buried sludge. Soils with PCB concentrations
greater than 500 ppm would be transported to a TSCA approved
incineration facility for disposal. The remaining excavated
material would be disposed of in an on-site RCRA and TSCA
approved landfill. Following the excavation, the site would
be capped.
This alternative meets the goals of CERCLA and attains or
exceeds Federal environmental regulations.
Alternative S-6D
This alternative involves the excavation of the top 1.5 feet
of soil and the buried sludge. Soils with PCB concentrations
greater than 500 ppm would be transported to a TSCA approved
incineration facility for disposal. The remaining contaminated
soil and sludges would be transported to off-site TSCA and/or
RCRA approved hazardous waste management facilities for
disposal. Following the excavation, the site would be capped.
This alternative meets the goals of CERCLA and attains or
exceeds Federal environmental regulations.
Alternative S-7
This alternative includes the total removal of all contaminated
soils, sludges and wastes to background concentration limits.
-The excavated material would be transported off-site and
disposed in approved RCRA and/or TSCA approved hazardous
waste management facilities for disposal. The estimated volume
of material to be excavated would be 46,500 cubic yards.
This is based on excavation to a depth of 13 feet. Following
the excavation, the site would be backfilled with clean material,
No long-term monitoring would be required for this alternative.
This alternative exceeds applicable or relevant environmental
standards.
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-13-
Alternative S-8
This alternative includes the total removal of all contaminated
soil, sludge and wastes to background concentration limits.
The excavated material would be transported to a TSCA approved
incineration facility. The estimated volume of material to
be excavated is 46,500 cubic yards. Following the excavation,
the site would be backfilled with clean material,
This alternative exceeds applicable or relevant environmental
standards.
Water Supply Alternatives
•
The results of investigative activities indicate that
contaminants have been identified in the Potomac Raritan
Magothy Aquifer/ which supplies drinking water to local
public supply wells. Pumping of National Highway Well No. 1
was stopped due to mercury contamination. National Highway
Well No. 2 has also shown low levels of mercury, however, the
levels of mercury contamination have not been significant
enough to discontinue use of the water. To date, the evidence
is not-conclusive that National Highway Well No. 2 has been
impacted by the Swope Oil site. Based on currently available
information, it is not evident that the loss of National
Highway Well No. 1, which had supplied 1.4 mgd to the water
supply, will result in a shortfall to meet current demands.
The following remedial alternatives were considered to replace
the water supply capacity which has been lost (National
Highway Well No. 1) due to groundwater contamination from the
Swope Oil site. It is noted that the alternatives were
formulated and costed to replace both National Highway wells.1
Alternative Water Supply Alternatives
W-1 No action, blending
W-2A Increase capacity at Park Avenue field, pump to site
area via new pipeline
W-2B Increase capacity at Park Avenue field, pump to site
area via existing .distribution pipeline
W-3 Install new well, treat water prior to distribution
W-4 Pump Delaware River water, treat water prior to
distribution
W-5 Purchase water from Camden
W-6 Purchase water from Philadelphia
Bft-
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-14-
Alternative W-1
This alternative does not include any physical remedial
action. In addition, this alternative does not serve as a
permanent remedy since mercury levels could rise to unacceptable
levels above past recorded concentrations. Also, it relies
strongly upon monitoring. Water from National Highway Well
No. 2 would be mixed with water from Well No. 1 during peak
demand periods. This alternative has temporary approval from
the NJDEP. The blending of the two wells would result in
potable water which contains less than 2 ppb mercury, based
upon past mercury levels detected. The actual blend ratios
would vary depending on the mercury content of the groundwater
from each well.
This alternative attains applicable and relevant Federal
public health or environmental standards.
Alternative W-2A
This alternative would involve pumping the excess capacity
currently available at the existing Park Avenue wellfield and
transporting the water to the National Highway area. The
pumped water would be transported via a new 14-inch pipeline
to the National Highway existing treatment facility.
Alternative W-2B
This alternative is similar to Alternative W-2A in that it
would involve pumping excess capacity from the Park Avenue
wellfield. The existing Park Avenue treatment facility would
be expanded to accomodate the additional flow. Water would be
treated and then transported to the National Highway vicinity
via use of existing lines. However, a pump station would be-
added, along Crescent Boulevard, to maintain pressure in the
system and to supply water to the storage tank on National
Highway.
This alternative attains applicable and relevant Federal
public health or environmental standards.
Alternative W-3
This alternative involves the drilling of a new well in an
-area free from the influence of the site in order to replace
the wells lost due to contamination. Water obtained from the
new well would be added to the distribution system following
treatment. Since iron and managese levels have been found in
many wells throughout the area, the treatment for these
chemicals is included in this alternative. A package treatment
-------
-15-'
unit would be placed at the same location as the well, in
order to provide direct water service to the affected areas
without a large reorganization of the distribution system.
This alternative attains applicable and relevant Federal
public health or environmental standards.
Alternative W-4
The City of Philadelphia currently obtains a significant
portion of its water supply from the Delaware River. Water
is drawn from a surface intake and treated prior to entering
the distribution systems. A water intake and treatment
plant similar to that used by Philadelphia could be used to
replace the water lost by the closing of National Highway
wells. Water drawn from the river would be first sent to a
grit removal/settling chamber. Chlorine would be added for
partial oxidation of heavy metals. Following pH adjustment
and floculation, remaining particulates would be removed via
secondary settling and rapid filtration. If necessary,
carbon adsorbtion would be used for removal of organics.
Finally, the water would be chlorinated and flouridated
before being added to the distribution system.
This alternative attains applicable and relevant Federal
public health or environmental standards.
Alternative W-5
This alternative involves purchasing water from the City of
Camden. The City of Camden supply line runs parallel to a
Merchantville-Pennsauken Water Commission supply line along
River Road. A connection currently exists between the two
systems in the vicinity which would be used to transfer the
drinking water.
This alternative attains applicable and relevant Federal
public health or environmental standards.
Alternative W-6
This alternative involves the purchase of water from the City
of Philadelphia. Currently, it is estimated that the City of
Philadelphia has 100 million gallons of excess treatment
capacity. A proposal has been made to allow for the sale of
the excess capacity to the City of Camden and nearby areas.
A water line could be constructed across the river, either
suspended to a bridge or run under water. A portion of the
capacity of this line could be used to supply the area of
Pennsauken affected by the loss of the National Highway
wells.
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-16-
This alternative attains applicable and relevant Federal
public health or environmental standards.
Community Relations
A public meeting was held on March 12, 1984 at the Pennsauken
Township Municipal Building to discuss the proposed surface
cleanup and the RI/FS. Notices of the meeting were sent to
local officials and interested parties as outlined in the
Swope Oil Community Relations Plan. Representatives of the
Swope Oil Site Cleanup Committee and the press attended this
meeting. At this meeting, EPA officials and their consultants
discussed in detail the work to be conducted as part of the
RI/FS for the site. In addition, a proposed Consent Order
covering the cleanup of the lagoon and drummed waste, and
installation of a security fence was discussed. Following
the presentation, the meeting was concluded with a question
and answer session. :
A second public meeting was held on July 9, 1985 to discuss
the results of the RI/FS. In addition, EPA officials tentatively
recommended remedial alternative components T-2, S-6D and
W-1. Letters were sent to local and county officials and
other interested parties notifying them of the meeting.
Copies of the draft RI/FS were sent to local officials and
interested private parties for public review. Representatives
of the Swope Oil Cleanup Committee attended this July 19, 1985
meeting. An EPA fact sheet was available to the public at
the meeting. Following EPA's presentation on its remedial
cleanup recommendation, officials responded to concerns and
questions raised by the public. More detailed information
regarding The Community Relations Program is included in the
attached Responsiveness Summary.
Enforcement
A generator committee calling itself the Swope Oil Site Cleanup
Committee has been formed from the approximately 100 potentially
responsible parties (PRPs). In May 1984, the 12 PRPs entered
into an administrative consent order with EPA to remove
existing drums and waste from the lagoon. Also, they agreed
to place a temporary cap over the lagoon after the waste
material is removed and to construct a fence around the
perimeter of the site. These activities have not yet been
completed.
Representatives of the PRPs have attended two public meetings
on the site and have submitted comments on the RI/FS. The
PRPs are currently being given an opportunity to undertake
the work described in this Record of Decision. Negotiations
are expected to continue through September 1985.
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-17-
EVALUATION OF ALTERNATIVES
Tanks and Building Alternatives
The no action alternative (T-1) was ruled out since leaving
wastes on-site without remediation would not meet the technical
requirements of RCRA. In addition, the removal of the tanks
and their contents in conjunction with buildings and scattered
debris would be required to implement any of the soil remediation
alternatives other than no action. The proper construction
and long-term effectiveness of a RCRA cap would be impacted
should the existing buildings, tanks and debris remain.
Leaving the tanks and buildings would raise concerns over the
feasibility of prevention of infiltration through the cap at
building perimeters; limit surface options required for cap
design protection and encourage future building usage with
potential detrimental impacts on cap integrity resulting from
such usage. Also, the removal of the buildings would eliminate
site obstacles to soil excavation and thereby make the overall
cleanup less complex. Therefore, implementation of the no
action alternative would fail to mitigate the hazards currently
posed by the site in its existing condition.
Alternative T-3 involves the removal of tank waste for off-
site disposal and on-site landfilling of building debris.
This alternative is directly dependent upon the selection of
an on-site landfill for the disposal of contaminated soil.
Although alternatives S-6A and S-6C, which include the
construction of an on-site RCRA and TSCA approved landfill,
are less costly than off-site disposal, the siting of such a
facility adjacent to a major municipal well would be in
violation of the New Jersey regulations for siting new hazardous
waste facilities. Therefore, implementation of this alternative
was eliminated from consideration.
Contaminated Soil Alternatives
The no action alternative (S-1) was ruled out since it would not
-meet the goals and objectives established for site remediation.
The potential future risk of ingesting contaminated groundwater
by users in the vicinity of the site would remain since the
source material would not be removed. Also, the migration of
contaminants from waste remaining on-site and the exposure to
•the public from these contaminants at, and near ground level
.would not be eliminated.
The capping alternative (S-2) was eliminated from consideration
because of the high levels of PCB waste which would remain
on-site would be in violation of EPA's current PCB cleanup
policy under TSCA.
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-18-
Alternatives S-3 through S-5 included excavation of the top
1.5 feet of soil, disposal of excavated soil/ and capping
the site. However, these alternatives did not address the
removal of the buried sludge, and possible buried drums, and
therefore, were not considered for further evaluation because
these materials can be expected to be continuing sources of
groundwater contamination.
Alternatives S-6A and S-6C include excavation of the top 1.5
feet of soil and buried sludge and disposal of the non-hotspot
PCB contaminated soil in an on-site TSCA/RCRA landfill. :
.Although these alternatives are less costly than the recommended
alternative, the siting of a hazardous waste landfill adjacent
to a major municipal well would be in violation of the New
Jersey regulations for siting new hazardous waste facilities.
Therefore, the implementation of these alternatives was
eliminated from consideration.
t
Alternatives S-7 and S-8 include the excavation of soil to :
background level concentrations of all contaminants, and
disposal off-site in either RCRA and/or TSCA approved landfills
or an approved TSCA incineration facility. These alternatives
are far more costly than the selected alternative, and they
provide only a minimal amount, if any, of additional benefit.
The Agency has determined that excavation to background, in
this case, is not cost-effective, as defined by the NCP.
Therefore, these alternatives are not recommended as part of
the overall remedial action.
The remaining alternative, S-6D, is cost-effective. Moreover,
it appears that soils contaminated with PCBs at levels of
500 ppm or greater can be disposed of at a permitted landfill,
rather than at an incinerator. As a result, a cost savings
of approximately $170,000 can be realized. This figure is
calculated assuming disposal of 145 cubic yards of PCB
...contaminated soil at a TSCA approved landfill as opposed to a •-...
-TSCA approved incinerator.
. -JWater Supply Alternatives .......
Alternatives W-2 through W-6 all require major expenditures
to replace water supply capacity currently lost due to
groundwater contamination resulting from the site. Currently,
there is insufficient data to define the extent of the off-
site groundwater plume as well as the future direction and
pathways of migration of contaminants in the complex ground-
water system. Implementation of alternatives W-2 and W-3
rely on increased pumping from existing wells or installation
of a new well. Either of those options may impact plume
migration and may be reliable only for a short period of time
if the contaminants were induced toward these areas.
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-19-
Alternatives W-4 through W-6 rely on development of new water
supply sources and existing supply sources of other communities,
which may be more appropriate if future studies indicate
existence of regional water supply problems. Significant
institutional and implementation concerns affect these options.
Based upon the above, alternative W-1, which includes blending
water pumped from National Highway Well Nos. 1 and 2, if
required to meet peak demand, and a continuation of the
groundwater study to define the extent of groundwater impacts
attributable to the Swope Oil site is the most viable water
supply alternative.
Recommended Alternative
According to 40 CFR Part 300.68 (J), cost-effective is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and
minimizes damages and provides protection of public health,
welfare and the environment. A cost comparison of remedial
alternatives is presented in Appendix A. The evaluation of
the remedial alternatives in conjunction with the cost
comparison leads to the conclusion that the combination of
alternative components T-2, S-6D, and W-1 is the appropriate
cost-effective alternative which achieves the recommended
cleanup goals. This alternative includes: tank and building
removal; off-site incineration, treatment or disposal of
tank contents; off-site disposal of tank and building debris;
excavation of sludge and contaminated soil, and off-site
disposal; and capping of the site. Although alternative
component S-6D includes incineration of PCS hotspots
(PCBs >500 ppm), EPA believes that this contaminated soil can
be disposed of in an environmentally acceptable manner at a
TSCA approved landfill.
A supplemental remedial investigation and feasibility study
will,be conducted to determine the extent of groundwater
contamination attributable to Swope Oil. This work will be
coordinated with two other ongoing regional groundwater
studies in the area. The United States Geological Service is
currently conducting an extensive regional study of the PRM
aquifer. The NJDEP is conducting a water supply study for
Burlington, Camden and Gloucester counties. The results of
this supplemental remedial investigation will be used to
evaluate long-term remedial alternatives for the groundwater
and water supply impacts currently identified.
The waste material contained in on-site tanks and vessels
will be separated as follows:
- aqueous waste
- organic phase waste
. - solid waste
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-20-
Once separated and categorized, the wastes will be transported
off-site to the appropriate incineration, treatment or landfill
facilities in accordance with RCRA requirements. The existing
buildings and related appurtances will be dismantled, wipe
sampled and classified as hazardous or non-hazardous. All
hazardous materials will either be decontaminated and disposed
of in a municipal landfill or disposed of in an approved RCRA
disposal facility. All underground pipes and tanks will be
emptied and their contents properly disposed of prior to
sealing of the pipes and filling the tanks. This will insure
that the proposed cap will be properly constructed and will
effectively reduce the migration of contaminants which remain
after the soil excavation work.
Another component of the recommended alternative includes the
excavation of the buried sludge and up to 1.5 feet of soil
containing PCBs greater than 5 ppm. The sludges and soils
will be transported to approved RCRA or TSCA facilities as
appropriate. :
The plan to remove up to 1.5 feet of contaminated soil
is based on the laboratory results of surface soil samples
and soil boring samples. PCB concentrations in surface soil
samples were generally in the 50-500 ppm range. Test boring
samples obtained at depths of 0-1.5 feet indicated much lower
concentrations of PCBs. PCB levels below 1.5 feet depth are
generally less than 1 ppm. Similarly, high concentrations of
phthalates were found in surface soils and reduced levels in
shallow test borings obtained at 0-1.5 feet depths.
The removal of the contaminated sludge and soils will signif-
icantly reduce the levels of PCBs and other chemical compounds
on-site. The proposed extent of removal of PCB contaminated
soils will be in compliance with EPA's Draft PCB Cleanup
Policy dated August 23, 1985 which would establish a 10 ppm
soil cleanup goal for the site. This level is considered
prudent due to the proximity of the adjacent public water
-supply well and the potential for organics to enhance migration
of the PCBs.
However, the State of New Jersey has established a more
stringent PCB soil cleanup goal of 5 ppm based upon health
risk assessments. For this site it is anticipated that the
.additional excavation to 5 ppm will have minimal, if any, impact
on project costs. This soil removal action in conjunction
with capping will mitigate the impacts posed by the site in
its current condition.
Additional soil sampling will be performed during design in
the parking lot area to determine the extent of soil removal
and capping in this area.
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The area-of buried sludge will be excavated and transported
off-site for disposal. PCBs, phthalates and xylene were the
major contaminants detected in the sludge samples. A magnet-
ometer survey overlying the area indicated that buried drums
.may have been disposed of in the sludge burial area. If
buried drums exist in this area, they will also be transported
off-site for disposal.
Due to the fact that surface soil samples obtained along the
northern boundary of the site indicate PCB levels of concern,
additional off-site sampling along the railroad tracks to the
north of the site/ especially in the area adjacent to the
lagoon, will be performed during design. The results of this
sampling and EPA's Draft PCB Cleanup Policy and the NJDEP PCB
soil cleanup goal will be used to determine if any additional
soil removal action is required. Any additional soil excavation
will be included as part of the remedial action.
During remedial design activities, additional testing will be
performed on soils underlying the existing lagoon after the
removal of its contents. Currently, there exists insufficient
data to define the degree of contamination in soils below
the lagoon. During the evaluation of alternatives, it was
assumed that 1.5 feet of contaminated soil would be excavated
from under the lagoon. The actual extent of soil excavation
required in this area will be determined during design based
upon additional soil testing to be conducted under the lagoon
in conjunction with the evaluation of capping requirements.
Following the completion of all soil and sludge excavation
work/ a cap compatable with RCRA requirements will be installed.
Currently, EPA believes that construction of a cap over the
site is necessary to minimize the migration of any residual
contaminants. Soil testing will be performed after completion
of the soil excavation effort. The test results will be used
along with the Bydrologic Evaluation of Landfill Performance
;;(HELP) model or similar model to determine the specific
requirements of the cap.
"The HELP model is a two dimensional hydrologic model of water
movement across, into/ and through landfills. The output of
the BELP model can provide an approximation of leachate which
may be generated at a site under specified conditions. The
model accepts climatologic, soil and landfill design input
.data. The model's output takes into account such variables
as surface storage, runoff, infiltration, percolation,
evaporation, soil moisture storage and lateral drainage.
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-22-
Cost Summary of Recommended Alternative
Remedial Measure
Components
1. Tank & building
removal and off-
site disposal
2. Excavation of
soil & sludge,
off-site disposal
3. Cap site,
monitoring and
post closure
maintenance
4. Groundwater
RI/PS
Capital
Cost
$467,000
$3,134,683*
$1,488,671
$500,000
Present Worth Total Cost
of 0 & M Present Worth
0 $467,000
$3,134,683*
$311,000
$1,799,671
$500,000
Total $5,590,356 $311,000 $5,901,354
*Cost does not include any potential soil removal which may
be necessary just beyond the site boundary.
Consistency With Other Environmental Laws
The recommended remedial alternative for the Swope Oil site
will require the removal of an estimated 8650 cubic yards of
contaminated soil and sludge. The excavated materials will
be transported off-site for disposal at approved RCRA and TSCA
facilities as appropriate. The waste material contained in
on-site tanks and vessels will be separated into (1) aqueous
waste, (2) organic waste and (3) solid waste. All wastes
from the tanks and vessels will be transported from the site
to the appropriate RCRA facilities for disposal (incineration,
treatment, landfilling). The existing buildings, emptied
tanks and appurtances will be sampled, and any hazardous
material will be manifested for transport from the site for
disposal at an approved RCRA landfill. Any non-hazardous
materials will be transported and disposed of in .a local
landfill.
Constructing a cap over the site is another component of the
recommended remedial alternative. The cap will be compatable
with current RCRA requirements.
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-23-
Operable Units
Since the recommended remedial alternative includes distinct
individual components, it is possible that the remedial
measures could proceed in a phased manner. The initial phase
could include the removal and disposal of all surface wastes
including the excavation of contaminated soil and sludge.
Following this work, the site would be capped. A suppplemental
remedial investigation and feasibility study will be performed
to address groundwater contamination attributable to the
Swope Oil site. This study can be performed simultaneously
with the surface cleanup work.
Operation and Maintenance
Upon completion of the recommended remedial action, monitoring
of the site will be conducted to evaluate the changes in
quality of the local groundwater. Maintenance of the cap
would also be required.
Future Actions
Schedule Date
- Final Record of Decision September 19
- Continue negotiations
with potential responsible paties September 1985
- Obligate Design Funds (if necessary) Pending CERCLA
Reauthorization-
- Amend State Superfund Contract
(if necessary) Pending CERCLA
Reauthorization
'- Initiate RI/FS Pending CERCLA
, Reauthorization
- Initiate Surface Cleanup Design Pending CERCLA
Reauthorization
-Remedial Action Funding Obligation Pending CERCLA
• V, . Reauthorization
- Initiate Remedial Action Pending CERCLA
Reauthorization
-------
MATT
APPENDIX A
•XMHNAL ACTION AlTEIMATWi COST SUMMARY
SWOPE OH. COMTANV SITE
Capital Co»l Annual 09M COM ftatatH-ONnH Cotu ltl.0001
.1 Tank and BuBdUMi AtlataatM . It LOOM Itl.OOM jowatl EMaMna Htanatl
{ Tl NoaclkM 0 0 0 * • •
j 12 Tank, bufcttng. and uMNv removal: oflslU InrtMratHm. offsNo UaaUnanl 467 0 445 497 Ml
faquaous waslas). and on»Ma dHpotal Cnoii-linanriMi aoNdt) ol lank and
bwUtflna itabtU.
T3 Tank, butkflng. and wHMv ramowat; oHMia Inchiafatloii. off»Ma traatmwrt 341 • 320 341 398
(aquaou* wasivs). ofUUa dlspotal (non-lnclnafabl* aoMt| ol tank and buMIng
«••«!•». and onclia landlW dtsaotal of lha lank and buMbig dabrta.
A*atitall»a«* . •
S-l Mo action wHh monMofbtg • tO S3t Mt tM
S-2 Canpbig I.4M 33 I.SM I.WM 2.043
S-3 Ewawala 1-1/2 laat of toN. bMidM on tNa. cap aNa 2.040 37 2.IS2 2.3M 2.703
S-4 ticavata 1-1/2 laat of aoN. tondfM oil «Ha. cap «Ma 4.121 33 3. 960 4.437 5.476
S-5 fwavata t-l/2 faal of aoNl tacbioralo oft aMo. cap MO 12.626 33 11.011 12.937 16.645
S-OA CMMata thidgo and 1-1/2 fMl of toi. biclnarala tludga and hMtpolt ofl tllo. . 4.372 37 4.2S3 4.721 8. 735
landW lamalnlng aoNa on Mia. cap tHa
S-M iHcavaia Mudga and 1-1/2 faa« of sol. bidnoraia Mudga and holipott ON alia. . 9.409 33 9.0IS 9.720 9.440
lamMM famabtlng totta olt alia, cap aNa
S-OC fMawala Mudga and 1-1/2 fact of aoN. btcbMtaia boltpol*. landfM aoNa and 2.299 37 2.397 2.947 3.040
tkidga on tlia. cap tHa.
-------
APPENDIX A
MMFDML AC1KM AlTENMAIWf COST SUMMARY
SWOPE OO, COMPANY SHE
PACE 1WO
'• ' • . V-iV
S-6O {••••vale stmkja and 1-1/2 laal of soft.
MtMiCM till >H0 CftO tMO
S-7 EwawMa softs lo
S-0 Emavata softs
fcottpota. landlM BO* ami
off atta
Wfl AAfl^ ^^ain^
" I IMP •C1NM,
W-lAlncr«M« ctptcNy M PMfc A«MM« EtaMl pump lo •«• MM vto
W-2BtailM wa ot Pwk AVOMW FtaM. pwnp to alM MM
W-3 hisuN MW wot UMl
W-4 Pump IMmwo Mvor wctor. tint
W-6 PurclUM wMor trow Cimdoii
W-« PurcM<« wMor trom EMtodolpM*
C«pM«ICo(l
ltl.0001
4.7M
17.463
71.411
0
2.711
3.6M
«.»S
t.OM
493
OMICotl
U1.000J
33
0
§
0
3i
4
301
237
n i.oooi
iowotl
4.M3
f.100
18.700 17.403
00.714 71.411
2.066 3.060
3.000 3.040
3.004 0.002
0.200 0.240
403 403
Mtahati
0.342
10.014
06.774
0
3.446
3.001
12.000
0.771
403
•SoO •NwiMthMs. mcopt MM no-octloii •NomMlM. •(•urn* ttw iMikt end buOdhigs
w« iMiHwcd pflot lo hnptamwillno MM soH •lt*mallw«.
i
Th« r*no« ot pr*»oiM-wofMi costs to baud OH MM MMtHlvNv MMlvsta. Com era In
AprH I9B6 doHws.
NA - Cost* could MM ba daiarmlaad. taa !•«! lor a«pianatlon.
-------
MERCHANTVILLE- PENNSAUKEN WATER
COMMISSION WELLN«2
•*^4* ips*/
• ^^M ^_1 * ^^ t'i.-; »
k JMI ft>* ^ _'*^ ._-. . *
^•MERCHANTVILLE-PENNSAUKEN WATER COMMISSION WELL N*jl \,
. .. -
PUCHACK WELL FIELD
••^ennsauken
!• w^_.«. ^-^""i
-*$ , A^
BASE MAP 1$ A PORTION OF THE U3OS CAMDEN. NJ -PA OUADRANQLE (75 MINUTE SERIES. 1967.PHOTOREVBEO 1973}.
CONTOUR INTERVAL 10*
FIGURE 1
LOCATION MAP
SWOfrE OIL CO. SITE. PENNSAUKEN TWR. NJ
SCALE -I's
OORPORAT1O
A Halliburton Compa
-------
TANK FARM
PONDED WATER
. N \
PONDED WATER
LLING HOUSE
.. 'I- s .•? .*••
.
j, j. •—' ....
FIGURE 2
SITE PLAN
SWOPE (M. CQ StTE. PENNSAUKEH TWR
3OU.E-r.6CC
DRAFT
-------
CAP3
PROPOSED
DOUBLE
LINER2
T VEGETATIVE COVER
QEOTEXTILE FILTER FABRIC
1* DRAINAGE LAYER
20 MIL (MM.) UNER1
g£ 2* CLAY HO'7 CM/SEC HERMEABttJTYl
: WASTE;
NOTE: 1. 6010O MM. IS FREQUENTLY USED
BY INDUSTRY
2. SOME VARIATIONS OF THE CAP AND
DOUBLE LINER ARE ACCEPTABLE
QEOTEXTILE FILTER FABRIC
V LEACHATE COUECTION
O AND REMOVAL SYSTEM
30 MIL (MM.! LINER
o-
O
O
O1* LEAK DETECTION.
COLLECTION. REMOVAL SYSTEM
30 MIL (MINI LINER1
•
2* CLAY MO'7 CMISEC
PERMEABILITY!
COMPOSITE LINER
SOURCE: NSCD 1/BS
FIGURE 3
RCRA CAP AND DOUBLE UNER
SWOPE OIL CO. SITE, PENNSAUKEN TWR. NJ
NOT TO SCALE
IMUS
OCF»=CIRA71ON
A HaHiburton Company
-------
12" FLOW ZOME(K«UIO-< «•%•)
20 MIL SYNTHETIC LINER—
24"
•24 TOPSOIL
-FILTER FABRIC
ONTAMINATEO SOILS S WASTES
12" LEACHATE COLLECTION
(K« I • lO'4 **%««)
2% SLOPE
12" LEACHATE DETECTION ZONE-
90 MIL SYNTHETIC LINER-
IK* I • KT? «•*•€»
FIGURE
TYPICAL ONSITE LANDFILL CROSS-SECTION
SWOPE OIL (0 Mir,, I'l llljl^y'l M IWP M \
NOT TO SCAL'
4* DIA
MANHOLE
LEACHATE DETECTION PIPE
TOSOOOGAL.
STORAGE TANK
OXDN
7J A HaHiburton Comoany
-------
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RESPONSIVENESS SUMMARY
FOR THE.
SHOPE OIL SITE
PENNSAUKEN, NEW JERSEY
BASED ON COMMENTS FROM
PUBLIC MEETING OF JULY 9. 1985
TOPIC: HATER QUALITY
Issue:
On a scale of 1 to 10, with 1 being poor and 10 being excellent,
what do you consider the quality of the drinking water 1n the
area to be now and 1n the future?
Discussion: We think the quality of the drinking water 1s good now. We
not sure of the extent of the groundwater contamination or the
plume. We will not numerically scale the quality of the drinking
water because we have not conducted enough groundwater testing to
give a definite answer.
Issue:
Do I have to drink bottled water?
Discussion: We don't feel that this 1s necessary. The water 1s being tested
and, to date, 1t 1s meeting health requirements.
Issue:
An article 1n the newspaper stated that the water was tainted.
Discussion: We did not see that article and, therefore, cannot comment on 1t.
Issue: What 1s an acceptable limit for contaminants 1n the water, with
respect to our health?
Discussion: The quality of the water 1s being closely monitored. It 1s
tested according to potable water quality limits 1n a state-
certified laboratory, and the results Indicate that the water 1s
safe* The water that you are getting 1s from the public supply
which Is meeting public health standards.
TOPIC: ALTERNATIVE HATER SUPPLY
Issue: When will efforts begin to locate an alternative water supply?
Discussion: We will start Immediately. Hopefully, we will drill new wells
and have results In about 6 months.
-------
Issue: As Vice President of the Merchantvllle-Pennsauken Water
Commission, I would like a more definite answer. Fourteen months
ago, we turned off well No. 1— 1s 1t usable or not? If we have
• major dry period, we will need that well. We have an obllgati
to serve area communities with a water supply.
Discussion: We are actively Investigating alternative sources of water at
this time. However, we don't have any answers right now. We are
definitely looking at ways that we can help if you should have a
problem tomorrow.
TOPIC: ADMINISTRATIVE ISSUES
Issue:
Discussion:
Issue:
Discussion:
Issue:
Can the township, at this point, be reasonably assured that the
responsible parties Involved are going to cover the costs
entirely, based on whatever options are chosen?
The government 1s prepared to Implement a selected option with
Its own money but will give the potentially-responsible parties a
chance to Implement and pay for the remedy. If, 1n fact, the
responsible parties choose to Implement the selected option, the
money 1n Superfund will be used for sites where there are no
potentially responsible parties Identified. Whether the
allocation of funds 1s a combination of responsible party and
government funds 1s unknown—but rest assured that funds either
from the government or from the responsible parties will be made
completely available to fund the option selected.
You said you have several recommendations—that you ar
recommending different options. This tends to make me belle
that you're recommending the options to someone else. Is tha
the case? Who 1s the ultimate authority to say we'll Implement
Alternative 6 or Alternative 1, etc.? And when can the residents
of our town expect the work to begin?
We are saying "recommending" because all of our final decisions
have to Include public Input; that 1s why we couldn't come here
tonight and say "this 1s what we selected." What we are doing 1s
recommending what we think 1s the best option that 1s cost-
effective and does the Job. Our recommendation will go to the
Regional Administrator, Christopher Daggett; the decision does
not have to be approved In Washington, D.C. A lot of that
repons1b111ty has already been delegated to specific regions. A
combination of our recommendations here and your Input will
determine what alternative will be Implemented.
What about the time period? From the outcome of this meeting to
Mr. Daggett's approval of the alternative, can you give us an
Indication of when a decision will be made?
ry^yv,- "^"
-------
Discussion:
Issue:
Discussion:
I would expect that the final decision would be made within the
next 30 days. Between now and that period of time, we will be
talking to the responsible parties to see whether, in fact, they
will be prepared to Implement this remedy. We will have to
develop some planning for the excavation of onsite material, but
this should occur rather quickly. It will be roughly 6 months
before you start to see any removal of the material.
In all sincerity, if the responsible parties decide to go ahead
and Implement the alternative, the cleanup will probably be done
faster than 1f the government does 1t.
As far as the alternative water supply options are concerned, how
will the final option be selected? By cost or effectiveness?
The problem with the alternative water supply 1s that cost really
1s not an Issue. I think the Issue 1s that we just have not
developed enough data to Identify the most appropriate
alternative.
Sometime in the future, we will have another meeting similar to
this one to discuss whatever recommendation you decide upon or
whatever recommendation we would like to make to you. At that
meeting, we would like to obtain your Input just as we are doing
now. We would then make a decision. Currently, what we are
deciding upon 1s how best to clean up the site proper; that 1s,
what we call visibly contaminated material, such as the tanks,
the buildings, and the contents of both. In general, we would
like to take all contaminated material off site and dispose of it
either via Incineration or in an approved landfill. In this
particular case, we are not recommending that we build something
on site and then put everything Inside of it. We want to take
the material away. We're just not sure what to do with the
groundwater.
It would be very simple to say, "For another 3 million dollars,
we could put a well 500 feet away and it will be okay."
But there 1s just enough doubt in our minds that we do not want
to do that and then, a year or two from now, learn that the plume
moved and that we should have drilled the well someplace else.
I really wish we had that data now, so that we could say what we
want to do. But we don't. The State 1s currently evaluating the
groundwater problem on a regional scale.
Hopefully, 1t will not be much longer before we have an answer;
we just want to make sure It's the right answer.
TOPIC: DISPOSAL SITE AVAILABILITY
Issue:
How lucky have you been 1n locating a place to incinerate and/or
landfill the wastes?
-------
Discussion: We have had problems ourselves. We think that we will have
disposal availability, but we cannot be positive. Incinerators
per se have not been the primary method of off site disposal.
TOPIC: OTHER CONCERNS
Issue: What about air contamination from aluminum dust emissions on the
site and 1n the area?
Discussion: We really don't have an answer for that. This meeting primarily
addresses groundwater and potable water concerns.
-------
Swope Oil Responsiveness Summary
Written Comments
As a result of the Swope Oil RI/FS public meeting held on
July 9, 1985 in Pennsauken Township, the Agency received four
letters (copies attached). The concerns raised in each of
the letters and the Agency's response to these concerns are
summarized below:
Letter Dated July 10, 1985 From Camden County Department
of Health
Mr. David Sweeney of the Camden County Department of Health
applauded EPA for its recommendation to complete the surface
cleanup of the Swope Oil site. He indicated that the adjacent
well was clearly impacted by the Swope Oil site, and he called
for the replacement of the well's capacity using Superfund
monies. He also indicated that blending of water from the
impacted well would not be an acceptable long-term solution.
EPA Response
EPA is negotiating with the potential responsible parties
(PRPs). If the PRP's do not consent to undertake the site
cleanup, the Agency will do so using Superfund monies. As
part of the remedial action, EPA will perform a supplemental
remedial investigation and feasibility study (RI/FS) to
determine the extent of groundwater contamination attributable
to the Swope Oil site and determine the appropriate long-term
remedial action for the groundwater and water supply related
impacts.
Letter Dated July 9, 1985 From The City of Camden
Mr. Melvin Primas, Mayor of the City of Camden expressed his
concern that the, Swope Oil site may be the source of a regional
groundwater problem. He feels that no final action be taken
until completion of the NJDEP contaminated well field study.
EPA Response "
EPA feels that the surface cleanup of the site should begin
as soon as possible. A remedial investigation which will
determine the extent of the groundwater contamination resulting
from the Swope Oil site is being recommended as part of the
remedy for the site. The results of the NJDEP regional ground-
water study will be considered. It is believed that the
results of this remedial investigation will determine if
Swope Oil has contributed to the regional groundwater
contamination problem.
-------
Letter Dated July 15, 1985 From KMD Associates
Mr. Edward Korab. of KMD Associates , the consultant for the
Merchantville Pennsauken Water Commission recommended the
construction of a new well, pump system/ and distribution
feed main to replace the capacity lost by the contamination
of National Highway Well No. 1. The new well would be located
approximately 2,000 feet south of National Highway along the
median area of Route 130.
EPA Response
EPA feels that additional remedial investigation work is
necessary to determine the extent of groundwater contamination
resulting from the Swope Oil site prior to undertaking any
long-term remedial alternative, for the water supply impacts
currently identified.
•
The implementation of the alternative, identified by Mr.
Korab, may indeed provide potable water to the Merchantville
Pennsauken water system. However, without knowing the extent
of the groundwater impacts, resulting from Swope Oil, the useful
life of any new well cannot be ascertained. Therefore, the
Agency has recommended that additional remedial investigative
work be completed prior to the the evaluation of alternatives
and subsequently the selection of a long-term remedial
alternative.
Letter Dated August 1, 1985 From Mr. John F. Stoviak
Mr. Stoviak' s letter was submitted on behalf of certain
members of the Swope Site Cleanup Committee who have been
participating in the surface cleanup. In his letter, he
expresses his agreement with EPA's recommendation that a more
comprehensive hydrogeological investigation, followed by a
feasibility study be undertaken. He indicates the Committee's
desire to perform this work. In addition, he provides a
proposal for the surface cleanup of the Swope Oil site.
Attached to his letter were comments provided by their
consultant Geraghty & Miller Incorporated on the Draft Swope
RI/FS report.
EPA Response
EPA has provided as part of this Record of Decision a point
for point response to the technical questions and concerns
raised by Mr. Stoviak and Geraghty and Miller. That response
vis attached. With' regard to the proposal to pump National
Highway Well No.1, EPA believes that a decision on this issue
cannot be made until additional hydrogeological data is made
available. In response to the PRP's proposed remedy, EPA's
Record of Decision has provided in detail, its rationale for
the selected remedial action. On August 21, 1985 representative
of the Swope Cleanup Committee met with EPA officals to
discuss in detail the proposed site cleanup. Another meeting
is in the process of being scheduled.
-------
MUS
Park West Two
Cliff Mine Road
--v-tf-u-u-TPA-ni-ML . Pittsburgh. PA 15275
CORPORATION 412-788-1080
R-33-8-5-10
September 12, 1985
NUS Project Number S758
Mr. Donald Lynch
U. S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
Subject: Swope Oil Company Site Remedial Investigation/ •
Feasibility Study (RI/FS)
Response to Comments on the Swope Oil Company Site
Draft RI/FS Report *
Dear Mr. Lynch:
In a letter to Mr. K. A. Walanski, P.E., Corporate Environmental Engineer for
DeSoto, Inc., dated July 29, 1985, Geraghty & Miller, Inc., (G&M) proposed pre-
liminary remedial measures and studies for the Swope Oil Company Site. Following
are several comments concerning the proposed remedial measures and studies.
• G&M initially states that "Insufficient data exist pertaining to the site to
adequately select and design appropriate remedial measures." However,
remedial measures pertaining to surface soil remediation, surface water
remediation, and eventual capping of the site are proposed.
• Task 1 is titled "Excavation and Removal of 'Hotspof to Offsite Facility."
This would involve the excavation and removal of all visibly contaminated
soil (soil which is oil-stained). If it is assumed that "hotspots" are soils
containing PCBs at concentrations greater than 500 ppm, the definition
used in the draft RI/FS report then the proposed method of identifying
"hotspots" as visibly oil-stained areas must be disputed. A correlation
between PCS concentration, or any other contaminant concentration, and
visible oil stains has not been established. It is highly unlikely that visible
oil stains will correlate with PCS concentrations greater than 500 ppm
and is therefore not recommended as a means of identifying such
"hotspots."
It must be noted that the letter from Dilworth, Paxson, Kalish &
Kauffman to Ms. Carole Peterson, U. S. Environmental Protection Agency
(USEPA), dated August 1, 1985, does indicate that soils containing PCB
levels in excess of 500 ppm would be excavated for incineration.
However, a separate task also calls for the removal and disposal of visibly
contaminated soil. Again, it is our opinion that visual observation of soil
contamination is not recommended as a means of identifying soils for
removal and disposal.
| A Halliburton Company
-------
R-33-8-5-10
Mr. Donald Lynch „'•;•''
U. S. Environmental Protection Agency
September 12, 1985 - Page Two
• Task 2 addresses remediation of ponded water on site. The task
description indicates that the water would be tested for volatile organic
compound content and treated off site if determined to be contaminated.
Data collected during the Remedial investigation (Rl) indicate that the
ponded liquid in the tank farm contains, in addition to volatile organics,
extractable organics, low levels of PCB 1254, and heavy metals, including
lead at a concentration greater than the drinking water maximum
contaminant level. The ponded liquid behind the distilling house also
contains similar contaminants. Thus, testing for volatile organic content
only would be insufficient to characterize the ponded water on site.
• In Task 4, G&M proposes that "PW-1 should be pumped on a continuous
basis ... in order to contain and prevent further spread of the plume."
The idea behind this approach is that the contaminated plume over which
PW-1 exerts influence through pumping would be controlled, thereby
minimizing contaminant migration to other wells in the area pumping this
aquifer.
Based on the hydraulic connection between the upper and lower aquifers
. observed in this study, the upper aquifer contaminants will be drawn into
the lower aquifer, admittedly under controlled conditions. The
advisability of this approach from the standpoint of further lower aquifer
deterioration is uncertain without more extensive hydrogeological data.
From a management of migration approach with the specific objective of
protecting other pumping wells, this alternative is viable. However, in
our opinion, this pumping should only be considered as a short-term
remedy.
Also to be considered, upon the development of additional hydrogeologic
data, is pumping the upper aquifer with the same objective as stated
above.
• In Task 5, Eventual Capping of the SOCC Site, G&M states that 'It is
recognized that some type of cap may be needed for the site. Presently
available data is insufficient to determine the type of cap required and
the size of the area over which it must be placed." It is our opinion that
the data from surface and subsurface soil samples are sufficient to show
the widespread nature of surface soil contamination at the site, and are
thus sufficient to evaluate the type and size of the cap required. 'G&M
states in the same task description "... the wastes are at land surface and
soils containing high levels of contaminants are approximately one to two
feet below land surface." This statement showing a general understanding
of the degree of surface soil contamination at the site appears to be
contradictory to the previous statement that insufficient data are
available to determine the type and size of cap.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Three
• G&M makes no mention of tank content, tank, and building remediation.
It must be noted that the letter from Dilworth, Paxson, Kalish &
Kauffman to Ms. Carole Peterson, USEPA, dated August 1, 1985, does
propose disposal of tank contents, dismantling of the buildings and
disposal of the building contents and demolition debris, and plugging of all
site utilities.
Following please find the responses to the comments made by Geraghty & Miller,
Inc., regarding the Swope Oil Company Site draft Remedial
Investigation/Feasibility Study (RI/FS) Report. The responses have been listed in
the same order as the comments.
GENERAL OVERVIEW AND CONCLUSIONS
1. A review of the contaminants found in Tables 4-4 and 4-5 in the draft RI/FS
report indicates there is a subset of contaminants that are common to the
onsite lagoon, the upper aquifer onsite monitoring wells, and the offsite lower
aquifer. The common contaminants are as follows:
1,1,1-trichloroethane
1,1-dichloroethane
trans-1,2-dichloroethene
1,1-dichloroethene
trichloroethene
These contaminants are typical industrial solvents. Table 4-6 of the draft
RI/FS report Indicates that the Swope Oil Company probably processed used
solvents as feedstocks (i.e.. Tanks 30, 32, 34).
The above mentioned common contaminants are regarded as highly mobile In
soil/groundwater systems (see Appendix D of the draft RI/FS report). The
sandy soils, high conductivity, and appreciable recharge (30.48 - 55.88 cm/yr)
from precipitation are conducive to contaminant leaching and groundwater
transport as solutes by advectlon. tt is entirely conceivable that
contaminants percolated and/or leached from the soil to the groundwater and
were transported by advection with the groundwater. Data from the Rl field
activities indicate that the upper aquifer is responsive to pumping in the
lower aquifer. This information implies that the lower aquifer is hot
completely confined and that groundwater does, in fact, move between the
two zones. Contaminants dissolved in the groundwater will therefore be
transported with the groundwater.
On this basis, it is reasonable to conclude that the contaminants measured in
the National Highway Well No. 1 (PW-1) are, at least in part, a consequence
of previous dumping of Swope Oil Company process wastes into the lagoon
and other places on the site.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Four
While some contaminant concentration reduction by adsorption to organic
materials, by diffusion, and by chemical/biological reactions would be
expected during transport such mechanisms would not be expected to
dissipate contaminant concentrations entirely within the relatively small area
of the Swope Oil Company Site region of impact
2. At the direction of NJDEP, monitoring wells were not installed in the
confined aquifer. NUS did not attempt to determine groundwater flow
direction in the confined aquifer under non-pumping, conditions of PW-1.
However, it is known that groundwater flow direction in the confined aquifer
during pumping of PW-1 is radially toward PW-1. It is also known that a
change in groundwater flow direction and gradient exists in the water table
aquifer under pumping conditions of PW-1. Therefore, contaminants could
migrate from the water table aquifer to PW-1 via the hydraulic connection.
3. there is a possibility that PW-1 may also be contaminated by offsite sources.
Until monitoring wells are installed in the confined aquifer, the possibility of
PW-1 being contaminated by offsite sources cannot be properly addressed.
4. It is the belief of NUS that there is a sufficient number of monitoring wells
to establish site contamination. The scope of work was not intended to
delineate in detail contaminant plumes or address offsite sources. In
addition, physical constraints (buildings, tanks, ponded liquid, and the lagoon)
limited the number and location of monitoring wells installed on the site.
5. There is a downward hydraulic gradient under static water level conditions.
The water level of PW-1, which is screened In the confined aquifer, is
-26 feet msl, or 91 feet below the ground surface elevation (see p. 3-38 of
the draft RI/FS report) versus water table elevations of approximately
-16 feet msl (see the hydrographs in Appendix A of the draft RI/FS report).
'. The clay layer appears to be extensive across the site. However, when PW-1
was pumped at 1,000 gpm for 24 hours, a drawdown of 0.5 feet was recorded
In MW-3. MW-1 and MW-4 were also monitored during the pump test and
-drawdowns of 0.44 feet and 0.40 feet respectively, were recorded. A change
in groundwater flow direction and gradient occur in the upper aquifer during
. pumping conditions of PW-1 versus non-pumping conditions, as shown on
Figures 3-8 and 3-10 In the draft RI/FS report
The clay layer was not encountered at all monitoring wells. MW-2 was not
drilled to a depth sufficient to contact the clay. The cross-section does show
the clay as continuous across the she with inferred contacts. The cross-
section shown in the report is only one vertical plane that cuts through the
site. A cross-section of an area to the south of the site would show the clay
layer as discontinuous.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Five
Reports on the regional geology of the study area indicate that the
unconsolidated sediments vary in thickness, lateral extent, tithology, and
water bearing characteristics (Vowinkel, E. F., and W. K. Foster, 1981), as
indicated on p. 3-7 of the draft RI/FS report
6. Water levels for the monitoring wells were taken over a period of 9 months
(see the hydrographs in Appendix A of the draft RI/FS report). This
information served as a sufficient baseline for water level data under non-
pumping conditions of PW-1. The pump test lasted.less than 2 days, thus
ruling out the possibility of water level changes due to seasonal water level
fluctuations.
Stage-level changes in the Delaware River will not affect the pump test data
since the distance of the site from the Delaware River is greater than 1 mile.
7. The scope of work was not structured to identify sources of contamination
other than the Swope Oil Company Site. Other potential sources cannot be
ruled out as contributors to the contamination of PW-1.
8. A total of nineteen (19) surface soil samples were collected on site. All of
these soil samples showed PC8 contamination. Additional sampling will be
required in minor portions of the site to further define the extent of PCB
contamination.
Excavation of 1-1/2 feet of soil was proposed in several remedial alternatives
to remove the majority of contaminated soil. Data from the uppermost soil
samples from the test borings, composite samples generally from 0 to
1-1/2 feet in depth, indicate that removal of soil to 1-1/2 feet should in most
areas remove PCBs to less than 1 ppm and phthalates to less than 25 ppm
(data from TB-3 indicate somewhat higher levels in the uppermost sample.)
Since these samples were composites from the sampling interval, including
surface soil that generally contained PCBs in the 50-500 ppm range and
phthalates In the 20-1,000 ppm range, It is probable that the concentrations
of PCBs and phthalates at the 1-1/2 feet depth are less than 1 ppm and 25
ppm, respectively, in most cases.
Responses to Summary of Non-Supportable Conclusions
p.3-49 The observed drawdowns in the monitoring wells during the pumping test
showed a direct hydraulic connection between the water table aquifer and
the confined aquifer, implying the existence of a leaky clay layer. The
change in gradient and flow direction in the upper aquifer under pumping
conditions supports the statement that the clay deposits are not
continuous.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Six
p.3-50 The horizontal flow rate was calculated as follows:
The permeability of the lower aquifer at PW-2 is defined as
K - T(b x 7.48)
Where K • permeability (ft/day)
T « transmissivity (38,800 gpd/tt)
b • aquifer thickness (230-167 - 63 ft)
38.800
63 x 7.48
K • 82.33 ft/day
Velocity is defined by the following equation:
K I
I
V
K
n
Ah
hydraulic gradient • Ah/AL in ft/ft
velocity in ft/day
permeability in ft/day
effective porosity (0.15)
change in water levels between pumping and non-pumping
conditions in the confined aquifer (feet)
AL • distance between PW-1 and PW-2 (1,500 feet)
The pumping water level at PW-2 is -50 msl. The non-pumping water
level at PW-1 is -21 feet msl. Therefore, the potentiometric head
difference between PW-1 and PW-2 is:
-50 - (-21) • 29 feet - Ah
The horizontal flow velocity in the confined aquifer is thus
w 82.33 ft/dav x 29 ft
v 1500 ft x 0.15
V • 10.61 ft/day
The downward vertical flow velocity through the clay is defined as
K I
•'••"
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Seven
Where K - 4.5 x 10~7 cm/sec or 1.276 x 10~3 ft/day (the highest
permeability value for the clay from Table 3-6 of the draft
RI/FS report)
I • gradient (2.1 ft at PW-1 - see the response to the comment
on p.3-42 of the draft RI/FS report)
n • porosity of clay (0.30)
Therefore, the velocity (V) is calculated to be
•
V " (1.276 x 10-3)(2.1)/0.30
V • 8.9 x ID"3 ft/day
p.4-6 Several data points were incorrectly labelled in Appendix C of the draft
RI/FS report. Specifically, the last 3 data points on page 10 and the first
5 data points on page 11 were incorrectly labelled as National Highway
Well #2 (PW-2) data in the 'source' column. However, the "sample
number" and "CLP number" columns correctly identify these samples as
being from National Highway Well #1 (before treatment). Valid analytical
data indicate that PW-2 is not contaminated with volatile organics.
p.4-36 The major pathway for contaminant migration through soils to the
groundwater is logically the column of soil extending from the base of the
lagoon (the major source of contamination) through the unsaturated zone
to the water table. No test borings have been drilled in this area.
Consequently, the major pathway has not been characterized. Soil
samples taken from test borings provide evidence of vertical contaminant
migration. Soil samples from borings 6, 7 and 9 showed some volatile
organic contamination. A sample from boring 6, which is located west of
the lagoon, was found to contain 1,1,1-trichloroethane, 1.1,2-
trichloroethane, trans-1,2-dichloroethene, and trichloroethene (soil
sample TB-6A).
The lagoon and the soil directly beneath is believed to be a major source
of contaminants affecting the groundwater. It is also likely that other
soils in or near the region of the saturated zone are contaminated with
liquid contaminants which have percolated to their present location after
many years.. Such subsurface "hotspots* can act as discrete continuous
sources of groundwater contamination.
The primary mechanism for contaminant migration through soils is
leaching from the soil to the interstitial water (pore space water) or other
water. One measure of the leaching potential of an organic contaminant
in soils is the chemicals soil/sediment adsorption coefficient, Koc. Koc
may be thought of as the ratio of the amount of chemical adsorbed on a
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Eight
solid per unit weight of organic carbon in the soil or sediment to the
concentration of the chemical in solution at equilibrium. Koc is defined as
follows:
ug contaminant adsorbed/gram organic carbon
oc * yg contaminant dissolved/ml solution
The interpretation of this equation is that for slightly or moderately
soluble organic chemicals, there will always be an equilibrium solubility
concentration of the contaminant in solution. Consequently, if a
significant quantity of soil is contaminated, such as the lagoon, soil
column beneath the lagoon, or other subsurface "hotspot," such
contaminated soils can be acting as sources of contaminants that are
leaching into the groundwater. The solvent for leaching (i.e., the water
needed for dissolution of contaminants from the soil particles) can be
groundwater recharge precipitation or interstitial water. Interstitial
transport without groundwater or recharge precipitation would tend to be
a slow but persistent process.
p.4-38 See the response to the comment on p.4-36.
p.4-42 See the response to Item 1 under General Overview and Conclusions and
the response to the comment on p.3-49 in this section.
Response to Specific Comments Referenced to Report Section and Page
p.ES-1 All groundwater samples for metals analysis were filtered through a
0.45 micron filter prior to preservation as described in the Site Operations
Plan.
p.ES-2 Subsurface soil sampling procedures, as outlined in the Site Operations
Plan, were followed.
As stated previously, the scope of the groundwater monitoring program
was limited.
p.ES-3 See the response to the previous comment.
p.ES-4 This comment was previously addressed in the response to the comment
on p.3-49.
p.ES-6 (First Paragraph) The potential for offsite groundwater contamination
resulting from sources on the Swope Oil Company Site was addressed as
Item 1 under the Response to General Overview and Conclusions section.
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R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Nine
p.ES-6 (Last Paragraph) National Highway Well No. 1 (PW-1) is not presently
being used for consumption; hence, there is no operating exposure
pathway. However, the well has not been closed by a legal mandate and
could be used at anytime. If for any reason, the deep aquifer at the
National Highway Well No. 1 location is used for human consumption or
domestic use, the exposure pathway will be complete. Hence, a potential
health risk exists as a result of chemical contamination.!1)
p.ES-7 The statement in the draft RI/FS report identifies -a completed exposure
pathway for the Park Avenue Well 2 and Puchack Well 2 based on samples
collected during the Rl. The statement addresses the public health
concern associated with these sources of water. The statement makes no
mention of the source of contamination in these
p.3-1 The draft RI/FS report has outlined the limitations of the subsurface
Investigation and includes a recommendation for additional studies.
p.3-13 The transmissivity values discussed on this page are regional values and
are not intended for site-specific situations.
p.3-14 The last sentence in Section 3.2.3.3 should only reference Figure 3-4 and
not Table 3-4.
The distance drawdown curves (Figure 3-4 in the draft RI/FS report) with
non-leaky artesian characteristics were developed based on regional
hydrogeologic information, not site-specific hydrogeologic information.
These curves wre presented in the regional geology section of the report
and were presented as general background information.
0) Hearth risk assessments are conducted by scientists, but they are not
•classical science* in the strictest sense. For regulatory purposes, risk
assessments represent a tool that can be used to analyze scientific evidence
In order to evaluate the relationship between exposure to toxic substances
and the potential occurrence of disease. The risk assessment process
involves, on one extreme, scientifically verifiable findings, and, on the other
; extreme, judgments about the use of various kinds of scientific information.
No one should be misled into believing that results using present techniques
have the status of incontrovertible scientific agreement. Despite its
uncertainties, however, risk assessment is the only tool EPA has for
discriminating among environmental health problems.
(USEPA, December 1984, Risk Assessment and Management: Framework for
Decision Making. EPA 600/9-85-002. Washington, DC.)
'..'''."•^•s^V
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R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Ten
p.3-17 Sampling protocols were outlined in the Site Operations Plan.
and
p.3-19
p.3-36 It is believed that Q&M is commenting on page 3-26, not page 3-36. On
page 3-26 there is a typographical error. The text should reference the
reader to Table 3-7. The scales for the data plots given in Appendix A are
analyzed according to: Bouwer, H. and R. C. Rice (1976). These data are
plotted correctly and are not reversed.
p.3-27 The statement in the text should read: The well is screened from 195 to
200 feet and from 210 to 230 feet below ground level. Both screens are
located below a 20 foot thick clay.*
p.3-31 The report stated that "...this clay deposit may be extensive in the area
and may act as a confining lower-layer for the upper aquifer.*
Drawing S758-01 does show thin facies changes from clay to silt and vice
versa.
p.3-36 The text should indicate that the Delaware River is located west of the
site.
p.3-38 Drawdown in the water table aquifer monitoring wells during pumping of
PW1 proves that there is a direct hydraulic connection between the upper
and lower aquifers. Assumptions that were made before the pumping test
was conducted were disproved after the pump test results were evaluated.
p.3-39 The anticipated drawdown in MW3 was assumed for conditions where the
pumping well and observation wells were in the same hydrologic unit
This was disproved when the drawdown in MW3 was less than anticipated.
Figure 3-8 and Figure 3-10 show a change in groundwater flow direction
and gradient between non-pumping and pumping conditions.
p.3-42 The value of 4.5 x 10~7 cm/sec was considered as a highest permeability
value for analysis to give a worst case leakage estimate.
The vertical gradient can be calculated based on the following
information.
Pumping level of PW-1 • 124 feet
Water level in unconflned aquifer » 81 feet
Clay thickness • 20 feet
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R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Eleven
The gradient is therefore (124-81)720 • 2.15 ft/ft
The connection of the two aquifers and the results for the pumping test
were previously discussed in response to items 5 and 6, General Overview
and Conclusions.
p.3-43 Calculations to substantiate this claim are located in the text on p.3-43
and in Table 3-9.
Refer to pumping test data for information proving the existence of a
"window* in the clayey layer.
p.3-47 There was a fluctuation in the discharge during the first minute of the
pumping test. This data was not used for interpretation purposes. An
average pumping rate of 13.71 gpm was used for the calculation of
transmissivity.
p.3-48 A vertical gradient of 2.1 ft/ft was given earlier in the text
p.3-49
and
p.3-50 The continuity of the clay layer, the calculation of the horizontal flow
velocity, and the vertical gradient through the clay have all been
discussed previously.
p.4-2 The title of Table 4-1 should be renamed 'Concentration Ranges of
Chemical Contaminants Detected in Environmental Samples Taken During
the Remedial Investigation.*
p.4-3 The following information should be added to the Base/Neutral Section of
Table 4-1:
PP No. 69B
CAS NO. 117-84-0
Contaminant di-n-octyl phthalate
Groundwater
ug/l 2K-58
Obs/sample 2/19
p.4-4 Problems with the pumping equipment precluded sampling MW2.
1.7 U9/I PCB 1254 corresponds to a soil PCB concentration of 85.2 ug/kg
given a Koc of log 4.53 and 0.1 percent soil organic carbon content.
PCB 1254 soil concentrations ranged from 91.3-10,290 ug/kg in the
borings and from 970-2,300,000 ug/kg in the surface soil.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Twelve
While it is true that the PCS 1254 detections in MW's 1 and 5 could be due
to drilling or sampling procedures, protocols for preventing such errors
were Inplace and there is no evidence that they were breached. On the
other hand, it is obvious that the PCB contamination in subsurface and
surface soils is more than adequate to have generated groundwater
concentrations of PCB 1254 equal to and even well in excess of the
1.7 yg/l observed in MW1 and 5. While the speculative conclusion
forwarded by O&M is plausible, the explanation provided, based on
empirical and theoretical evidence, is more plausibJe. This conclusion is
also substantiated by the occurance of PCB 1254 in surface water
samples. See the response to G&M comment 4-36 for a discussion of
organic contaminant leaching.
Several of the volatile organic contaminants found in MW-3, including
1,1,1-trichloroethane, tetrachloroethene, and 1,1-dichloroethene, exceed
Preliminary Protective Concentration Limits (PPCLs). The contamination
can therefore be considered major.
p.4-6 All groundwater samples submitted for metals analysis were filtered.
The typographical errors In Appendix C relating to the identification of
data for PW-2 were discussed previously.
The Swope Oil Company was known to have processed solvents from
different sources and those mentioned by G&M (except landfills) could
very well have been sources of material processed at the site.
p.4-7 This is a correct statement
p.4-8 See the response to G&M comment p.4-6. Table 4-4 is correct.
Historical analytical data for PW-1 were obtained from the
Merchantville-Pennsauken Water Commission and from NJDEP. Some
data were received verbally, and copies of some data sheets were
obtained. It could not be determined if the data had been validated.
Also, the historical record appeared to be incomplete. For these reasons,
historical analytical data were not included In the test
p.4-9 See the response to G&M comment 4-6 concerning volatile organic
contamination in PW-2. The next to last sentence on this page contains a
typographical error. PW-1 is located adjacent to the site, not PW-2.
p.4-15 The adequacy of soil data was previously discussed in reference to G&M
proposed remedial measure Task 5 and in response to General Overview
and Conclusion Item 8.
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R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Thirteen
p.4-19 Data validation was conducted by EPA Region II for all analytical data for
samples sent to Contract Laboratory Program (CLP) laboratories. The
validation process was conducted before any data were released to NUS.
Thus, all data used in the draft RI/FS report were considered valid.
Invalidated data were not used to assess site contamination. Invalid data
points have been included in Appendix C and are marked with the letter I
in the "value" and "Rel" columns.
p.4-20 Six organic contaminants are mentioned on this page as compounds
detected in the sludge, two of which have been detected in MW-3. These
two contaminants, bis(2-ethyihexyl)phthalate and di-n-octyl phthalate,
have passed EPA validation and are considered valid. It is only the
opinion of G&M that these data are questionable. Thus, the sludge could
be the source of the common contaminants found in MW-3.
p.4-36 See the response to the previous G&M comment for p.4-36.
p.4-39 See the reponse to the first G&M comment for p.4-36.
p.4-40 The word permeability should be substituted for the word transmissivity.
The groundwater velocity in the confined aquifer was previously addressed
in the response to G&M comment on p.3-50.
p.4-41 The typographical errors in Appendix C concerning the labeling of volatile
organic data for PW-2 have already been discussed. No volatile organics
have been detected in PW-2.
p.4-42 It is our opinion that the aquifer contaminants would not differ
.significantly over a 3-month period.
See the response to General Overview and Conclusion Item 1 and 2 for a
discussion of contaminant migration.
Sec. 7 Analytical data for samples collected from the tanks are presented in
Appendix C. Building and tank removal will be required if a cap is to be
placed on the site.
An asphalt cap is susceptible to cracking, and was therefore screened
from further consideration (see p.6-7 in the draft RI/PS report).
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R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Fourteen
Responses to Miscellaneous Comments
p.3-25
p.3-13
Table
4-2
Figure
3-8
Drawing
S758-01
Appendix
C
Table 3-6 contains a typographical error. The value of 18.41 g/cm3
should be 1.841 g/cm3. .
The value is incorrect and will be changed.
MW-2 was not sampled because of mechanical problems with the well
and sampling equipment. The values for bis(2-ethylhexyl)phthalate and
di-n-octyl phthalate in MW-3 passed EPA validation and are
considered valid.
G&M note that two organic contaminants (acetone and total xylenes)
were detected in MW-5 but not in MW-1. However, it must also be
noted that four other organic contaminants (1,1,1-trichloroethene,
tetrachloroethene, bis(2-ethylhexyl)phthalate, and PCB-1254) were
detected in both wells. While MW-5 is upgradient of MW-1, MW-5 is
also downgradient of the northwest corner of the lagoon area where
sludge was buried.
MW-4 is located adjacent to the area of buried sludge along the
southeastern side of the site, possibly the source of contamination in
MW-3 and MW-4.
The higher water level in MW-1 than in MW-2 on the date measured,
January 31, 1985, is probably the result of measurement error. As
indicated on Table 3-5 of the draft RI/FS report, the water level in
MW-2 was measured five times. Three water level readings in MW-2
(July 11, 1984; March 5, 1985; and April 1, 1985} show close agreement
with the water levels in MW-1. The other two readings show water
level differences of approximately 2 inches.
The respective values for calcium, chloride, and nitrate for samples
collected April 10, 1985 were the same for National Highway Wells 1
and 2. The reported values are hot typographical errors. The values
passed EPA validation and are thus considered valid.
When contaminants are detected in blank samples, EPA validation
protocols outlined on p.5-3 and 5-4 of the draft RI/FS report are
followed. All samples in question were analyzed by CLP laboratories
and the analytical results were validated by EPA prior to release to
NUS.
-------
R-33-8-5-10
Mr. Donald Lynch
U. S. Environmental Protection Agency
September 12, 1985 - Page Fifteen
General Historical analytical data for PW-1 were obtained from the
Merchahtville-Penaauken Water Commission and from NJDEP. Some
data were received verbally, and copies of some data sheets were
obtained. It could not be determined if the data had been validated.
Also, the historical record appeared to be incomplete. No data were
available for the period prior to 1982, the period of active site
operation. It is possible that some or all site-related contaminants
appeared in PW-1 during this period. For these reasons, historical
analytical data were not included in the text.
If you have any questions concerning this response to comments, please call me.
Very truly yours, Approved for Submlttal,
Richard M. Ninesteel Donald R. Brenneman
Project Manager Regional Manager
Region II
RN/slk
-------
MELVIN R. PRIMAS, JR.
MATO*
CITY OF CAMIDEN
OFFICE OF THE MAYOR
M '>''.
Mr. Donald Lynch
Project Manager
Environmental Protection Agency
26 Federal Plaza
New York, New York, 10278
re: Swope Oil Site Work
Dear Mr. Lynch,
On behalf of the City of Camden, I would like to express my
concern with respect to the findings of NUS and reserve the right
to submit additional written testimony for the record.
Preliminary review by City staff seems to still point towa
Swope as a source of contamination to the regional groundwater
The City of Camden requests that no final action be taken
reguarding site mitigation activities until the completion of the
N3DEP contaminated well field study currently underway. The area
near the confluence of the Delaware River and Pennsauken Creek
represents too valuable a regional water resource to allow a less
than complete mitigation of the ground water contamination.
Thank You for your assistance in this matter. If you have
any questions, please contact Mr. Frederick Martin, Or., of my
staff at 609-757-7680.
Sincerely,
Melvin R. Primes,
Mayor
cc: F. Martin,Jr, Dept. of Utilities
Distribution List
CITT HALL / SIXTH A*»» KA*XET STREETS / CAMDEN, MEW JERSEY OBIOI / (6OO) f»7-TaOO
' '
-------
Camden County"
BOARD OF CHOSEN FREEHOLDERS
Chp ^^sgr DEPARTMENT OF HEALTH
1800 Pavilion. 2101 Ferry Ave.. Camden. NJ. 08104
Phone: (609) 757-8600
July 10, 1985
Donald Lynch, P.E.
N.J. Remedial Actior Branch
O.S.E.P.A.
26 Federal Plaza, Room 402
New York, N.Y. 10278
Dear Mr. Lynch:
•
Regarding the Remedial Investigation and Feasability Study
of the Swope Oil Site in Pennsauken, New Jersey, we agree that
further hydrogeological investigation is necessary to determine
the extent of contaminant plumes from this site. The remedial •
alternatives regarding the tanks, building, utilities, sludge
and soils will remove the threat of immediate health problems
at the site and should be initiated as soon as possible.
Our "comment" involves the contamination of the Merchantville
Pennsauken Water Commission Well Number 1. We feel that this
well has clearly been impacted by this hazardous waste site.
The impact of the Swope Oil site is that not only has the ground-
water in the area of the site been degraded but that the resource
of the well has been effectively taken from the residents of
Pennsauken and Merchantville. We feel that the eventual remediation
of the site should not only consider treating the groundwater at the
site but also replacement of the well's capacity for the Merchant-
ville Pennsauken water system using Superfund monies. We don't
believe that the "blending" of water from well #1 with other
uncontaminated Merchantville Pennsauken system water is an acceptable
future alternative and that this well should be formally condemned
by NJDEP. The well is now not being used voluntarily by the Merchant-
ville Pennsauken Water Commission, this leaves the potential for
future use open.
In conclusion, our department applauds the steps being taken
to protect the health of the citizens of Pennsauken Camden County
and stress that this hazardous waste site has not only damaged the
environment but has also impacted the.infrastructure of this
community in its reduction of potable water capacity.
Yours truly,
David Sweeney
Administrative Analyst
DS: ra
cc: Pennsauken BOH-MGB
Pennsauken Merchantville Water
• DEP ...,-;. .- ..,.-,.,.
Sebastian
-------
Korab. McConnell & Dougherty Assoc. P.A.
Engineering, Land Surveying & Land Planning
July 15, 1985
U.S. Enviromental Protection Agency
Region II
26 Federal Plaza
New York/ N.Y. 10278
Attn: Mr. Donald Lynch/ PE
Re: MPWC - Swope Oil Site - National Highway Well #1
Dear Mr. Lynch:
This response is being prepared on behalf of the Merchantville & Pennsauken
Water Commission.
The Commission has reviewed the various reports and the evaluation of re-
medial alternatives.
The Commission believes that the most cost effective and beneficial alternative
to this matter is the construction of a new well pump system and distribution
feed main to the National Highway Treatment Plant. The Commission feels that
a satisfactory location would be in the median area of tf.J. Route 130.
This site is located approximately 2000 feet from National Highway and the
Commission feels that this is an ideal and expedient solution to replacement .
of National Highway Well II.
The estimated cost of such an alternative would be $300/000.00.
Test veils in this area would indicate existing ground water quality and the
Commission urges these tests be taken as soon as possible.
We have included sketches outlining this proposal for your review.
-------
Korab. McConnell & Dougherty Assoc. P.A.
Engineering, Land Sun/eying & Land Planning
MPWC - Swope Oil Site
Page 2 of 2
July 15, 1985
Please review this alternative and advise the Comnission of your intentions
on this matter.
Should there be any questions/ please feel free to contact me.
Respectfully submitted,
E.A. Korab, PC
EAR:rag
cc: MPWC
R. Brown
L. Holland
-------
-------
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HAND DELIVERED
Ms. Carole Peterson
Hazard Assessment Section
Hazardous Waste Site Branch
U.S. EPA - Region II
26 Federal Plaza
New York, NY 10278
Dear Ms. Peterson:
This letter and its attachments constitute the comments
of certain members of the Swope Site Cleanup Committee to the draft
Remedial Investigation/Feasibility Study ("RI/FS") for the Swope
Oil Superfund site located in Pennsauken, New Jersey.
.A. As our consultants have pointed out in their attached
comments, the draft RI/FS provides insufficient data upon which
.the kgency can make a rational decision as to an appropriate
remedial program for the Swope site at this time. We__therefore
agree with the Agency's recommendation that a more comprehensive
hydrog'eo'logicai" investigation, "followed by a" Feasibility Study,
be undertaken. The Committee strongly desires to perform the
additional groundwater studies recommended by the draft RI/FS.
As the Agency is well aware, the Swope site is located in a heavy
industrial area and there exists in the vicinity of the Swope site
.many other potential sources of groundwater contamination.
Accordingly, we believe that it would be improper for the scope
of the contemplated groundwater study to be substantially broader
than an investigation to determine the extent and significance
of contamination, if any, resulting from the Swope site.
-------
. PAXSON. KALISM & KAUFMAN CONTINUATION SMGET No. 2 To Ms . Peterson
August 1, 1985
•Accordingly, this shall constitute our formal request
that the Agency permit the Committee to undertake a more compre-
hensive hydrogeological investigation to determine the presence
and extent of contaminant plumes, if any exist, resulting from
the Swope site.
Furthermore, the Committee strongly desires to perform
any Feasibility Study which may be necessary to evaluate potential
groundwater remedial alternatives. This letter shall also constitute
the Committee's formal request that EPA permit the Committee to
undertake this Feasibility Study. Geraghty 6 Miller has estimated
that the groundwater study will take approximately six months after
approval of a work plan.
B. In addition, because the draft RI/FS provides
insufficient data, the selection and full implementation of
alternative S-60, which has been tentatively selected by the Agency,
would be premature, arbitrary and capricious and an abuse of
discretion by the Agency. Furthermore, full implementation of
alternative S-6D is inappropriate because it is not cost effective.
CERCLA requires that responses be cost effective. 42 U.S.C.
$9605(7).. The National Contingency Plan directs EPA to choose the
appropriate extent of remedy which it determines is cost effective.
40 C.F.R. S300.68(j). The "cost-effective" remedy is defined as
that remedy which is the lowest cost alternative that is techno-
logically feasible and reliable and which effectively mitigates
and minimizes damage to, and provides adequate protection of, pub
health, welfare or the environment. 40 C.F.R. $300.68(j). Here,
the draft RI/FS admits that the capping plan (Alternative S-2)
is an effective remedy which would cost one-third the amount of
Alternative S-6D. Therefore, alternative S-6D is clearly not the
cost effective remedy in this case.
However, without admitting any liability or obligation,
and despite the critical comments of its consultants Geraghty &
Miller concerning the draft RI/FS, the Committee requests that
the Agency agree to permit it to voluntarily implement the following
steps, at the Swope site pending the collection of additional data:
1. To dismantle the presently existing structures
at the site and properly dispose of the contents of the buildings
as well as the demolition debris. The Committee is willing to take
this measure as a gesture of good faith and our continued willing-
ness to cooperate with the Agency in resolving the Swope situation;
" 2. To remove and properly dispose of any residual
waste material in the tanks. steam clean the tanks, and remove
them from the site;
3. To plug all sewer lines and any pipes which
are found beneath the existing structures;
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TM. PAXSO*. KALISK & KAUFMAN
CONTINUATION SHEET No. 3 To
Ms. Peterson
August 1. 1385
4. . To pump and remove surface water from areas
in which ponding has occurred;
5. To grade the area to control surface water
run-off and prevent further ponding on the site;
6. To excavate, remove and incinerate soil with
PCS levels in excess of 500 ppm;
7. To remove and dispose of the sludge;
8. To remove and dispose of visibly contaminated
soil.
As a precautionary measure, the Committee proposes that
National Highway Well #1, which is currently shut down, be pumped.
We are advised by our consultants Geraghty & Miller that the pumping-
of National Highway Well #1 will assist in containing any possible
migration of contaminants which may currently be located beneath
the site, whatever their source.
The Committee feels that these measures are consistent
with the National Contingency Plan and further are consistent with
the CERCLA goals of effectively preventing, mitigating and mini-
mizing damage to, and providing adequate protection of, public health,
welfare and the environment.
C. Finally, we feel that a significant number of specu-
lative comments and wholly unsupportable conclusions are mislead-
ingly presented in the draft RI/FS as scientifically provable
findings. Accordingly, all such speculative findings should be
deleted, including those contained in the Executive Summary alleging
an increased risk of cancer. Additional unsupportable conclusions
of the draft RI/FS are referenced on pages 4-6 of Geraghty &
Miller's comments.
'The Committee is hopeful that the Agency will agree to
these proposals and that we may be permitted to implement this
plan forthwith.
Sincerely,
ohn F. Stoviak
on behalf of certain members of
the Swope Site Cleanup Committee
who have been participating
in the surface cleanup
JFS:fad
Enclosures
cc w/enclosures:
William K. Sawyer, Esquire
Mr. Donald Lynch, P.E.*'
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*3r°GERAGHTY
MILLER, INC.
Ground-Water Consultants
July 29, 1985
Mr. K.A. Walanski, P.E.
Corporate Environmental Engineer
DeSoto, Inc.
Administrative and Research Center
1700 South Haunt Prospect Road
Oes Plaines, Illinois 60018
Dear Mr. Walanski:
Geraghty & Miller, Inc. (G&M) has reviewed the RI/FS report submitted
by NUS Corp. for the SOCC site in Pennsauken, New Jersey, and we have con-
cluded that insufficient data exists pertaining to the site to adequately
.select and design appropriate remedial measures. G&M has taken this oppor-
tunity to propose to the PRPs several preliminary remedial steps and fur-
ther studies which would provide an adequate data base upon which a final
remedial plan can be desiqned.
The proposed preliminary remedial measures and studies are as follows*
Task 1: Excavation and Removal of "Hotspot" to Offsite Facility
Task 2: Surface-Water Control Measures
Task 3: Additional Soil and Ground-Water Studies
Task 4: Pumping of Merchantville-Pennsauken National Highway Well 1 to Con-
tain Contaminated Ground Water in the Confined Aquifer
Task 5: Eventual Capping of the SOCC Site.
A discussion of each task follows.
Task 1. Excavation and Removal of "Hotspot" to Offsite Facility
All visibly contaminated soil (soil which is oil-stained) will be ex-
cavated and removed from the SOCC site and properly disposed in a Hazardous
Waste Facility (HWF). Areas containing sludge deposits will be excavated
and removed from the site and contained in a HWF.
Task 2. Surface-Water Control Measures
All surface water at the SOCC site (particularly water ponded in the
lagoon and the tank farm) will be removed, tested for total volatile organ-
ic compound content and if determined to be contaminated, will be treated
offsite.
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G'ERAGHTYc'MILLER. INC. -2-
After all ponded water is removed, areas at the SOCC site where sur-
face water is known to pond will be graded in a manner to encourage proper
drainage and prevent the ponding of surface water. Care will be taken to
protect the monitoring wells at the SOCC site during the grading operation.
Task 3. Additional Soil and Ground-Water Studies
This program will be designed to provide the additional data which is
necessary to select the appropriate remedial measures for the SOCC site.
The focus of the study will be to define the potential pathways for contam-
inants to enter the ground-water system at the SOCC site and the extent of
ground-water contamination in the unconfined and confined aquifers.
Generallyt the program will entail; the collection and retention of
soil cores for chemical analyses to determine the presence/absence of con-
taminants from the land surface to the water table; the installation of
monitoring *ells in the unconfined and confined aquifers to determine
ground-water flow directions and water quality in both aquifers, and de-
scribe upqradient water quality; and a ground-water monitoring program
utilizing the existing and proposed monitoring wells and Merchantville^
Pennsauken National Highway Well V. Each well will be used to obtain
water-level and water quality data. The program will extend over a period
of six months and will provide a statistically valid data base.
Task A. Pumping of Merchantville-Pennsauken National Highway Well 1
The well is presently contaminated with volatile organic compounds and
mercury and has been shutdown. The plume of contaminated ground water that
PW-1 taps and over which it probably exerted some control through pumping,
i? now free to further migrate in the aquifer in response to existing hy-
draulic gradients.
PW-1 should be pumped on a continuous basis or as much as possible and
at as high a rate as feasible in order to contain and prevent the further
spread of the plume. If PW-1 remains shutdown, the ground-water plume may
move and contaminate presently clean portions of the confined aquifer.
Task 3. Eventual Capping of the SOCC Site.
It is recognized that some type of cap may be needed for the site.
Presently available data is insufficient to determine the type of cap re-
quired and the size of the area over which it must be placed. Installation
-of a cap at this time would be premature. Installation of a cap at present
would also be premature because if it is determined, based on the addition-
al site investigative work, that onsite remedial work is required to ad-
dress the ground-water contamination problem, then a significant portion of
a cap would be damaged in carrying out this remedial work.
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CEftAGHTY & MILLER. ING. -3-
i CT^^
Additional site investigations are required before a decision on
tyoe and' size of cap can be made. These investigations are described above.
There are two basic ways for solid waste to cause ground-water contamina-
tion: either by percolation of rainfall through the waste to form leachate
and then movement of the leachate to the water table, or by ground water
coming in contact with the wastes by flowing through them and dissolving
contaminants from the waste. Capping of the site would significantly mini-
mize infiltration of precipitation and therefore, preclude generation of
leachate.
At the SOCC site the depth to water below land surface is approximate-
ly 80 feet while the wastes are at land surface and soils containing high
levels of contaminants are approximately one to two feet below land surface.
Therefore, ground water cannot flow through the wastes to produce leachate.
Capping the areas of contamination at the SOCC site would remove the
site as a source of contamination, if it is indeed shown to be a signifi-
cant source through the extra site investigation discussed above.
We hope that these alternatives are acceptable to you. Please call if
you have.any questions or require additional information.
Sincerely,
, GERAGHTY
Christopher Creed
Staff Scientist
Douglas R. MacCallum
Senior Scientist
, Michael F. Wolfert
CC:DRM:MFW:me Associate
-------
MILLER, INC.
Ground-Water Consultants
July 30, 1985
Mr. K.A. Walanski, P.E. .
Corporate Environmental Engineer
DeSoto, Inc.
Administrative and Research Center
1700 South Mount Prospect Road
Oes Plaines, Illinois 60018
Re; Review, Evaluation, and Comments on the Swope
Oil and Chemical Company (SOCC) Remedial
Investigation/Feasibility Study (RI/FS)
Dear Mr. Walanski:
As requested, Geraghty & Miller, Inc. has reviewed the RI/FS work plan
and the RI/FS report prepared by the EPA Contractor (NUS Corporation) for
the SOCC site located in Pennsauken Township, New Jersey. Based on the
findings reported by NUS in the SOCC RI/FS, it is our opinion that suffi-
cient data does not exist to determine what remedial measures, if.any, are
appropriate for the SOCC site. Briefly, our review of the RI/FS reveals
that adequate and appropriate remedial alternatives cannot be determined or
implemented until supportive data are developed indicating: (1) the extent
of contamination attributable to the SOCC site and the impact of any such
contamination on the unconfined (shallow) and confined (deep) aquifer; (2)
the extent of soil contamination at the SOCC site; and (3) the pathway, if
any, for the contamination at land surface to reach the unconfined aquifer.
Absence of such data prevents proper selection and implementation of any
remedial plan addressing soil contamination and possible ground-water
contamination at this time. Furthermore, it is impossible to determine the
area! extent and composition of a cap for the site at this time due to the
undefined extent of soil contamination.
Our comments and opinions on the above documents have been separated
into four main categories. The first category contains a general overview
of the reports and our major conclusions. The second section lists conclu-
sions made in the NUS report which are not supported by the data. The
third section contains detailed comments referenced to specific report
pages. The final section describes miscellaneous errors and inconsisten-
cies that are less significant than the discussions in the other sections.
North Shore Atrium • 6800 Jericho Turnpike • Syosset. New York 11791 • (516) 921-6060
J^
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GERAGHTYc" MILLER. INC. -2-
GENERAL OVERVIEW AND CONCLUSIONS
Review of the RI/F5 report prepared by NUS Corporation for the SOCC
site has revealed several major deficiencies in the planning and implemen-
tation of the field work, data interpretation, and reporting. These are
summarized as follows.
1. Data developed to date relating surficial contamination at the
SOCC site to the contamination in PW-1 (tapoing the confined aquifer) are
speculative and totally inadequate to prove any connection between the al-
leged source and contaminated well.
2. Because monitoring wells were not installed in the confined (deep)
aquifer, the direction of ground-water movement in this aquifer cannot be
determined with confidence and, therefore, it cannot be known if contami-
nants could migrate to PW-1 from beneath the SOCC site if they exist there
in the deep aquifer (which is not known at present).
• 3. Because monitoring wells were not installed in the confined aqui-
fer it cannot be determined if there is a plume of contaminants traceable
from the SOCC site to PW-1. Additionally, due to the lack of monitoring
wells, the water quality in the confined aquifer upgradient (direction un-
known at present) of the SOCC site cannot be determined. Therefore, the
oossibility of PW-1 being contaminated by offsite sources cannot be ade-
quately addressed at present.
A. Although monitoring wells have been installed on the SOCC site in
the unconfined (shallow) aquifer, the number and distribution are not suf-
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GERAGHTYtf MILLER. INC. -3-
ficient to adequately describe water quality conditions onsite and the
quality conditions of water flowinq onto the site.
5. All available data, which includes geologic logs, geophysical logs,
cross sections, and pumping test data strongly indicate that the unconFined
and confined aquifers are hydraulically distinct units separated by a con-
tinuous clay layer. Although the clay layer has a very low permeability, a
downward hydraulic gradient could allow leakage of water through this unit.
However, data on such a vertical gradient have not been produced.
The suggestion in the NUS report that a "window" exists in the clay is
totally speculative and contradicted by all available data. The report
states that the clay layer is extensive and acts as a confining layer be-
tween the unconfined and confined aquifers. The clay layer was encountered
at all monitoring wells at the SOCC site and was logged during the drilling
of PW-1. In addition, the geologic cross section (Drawing 5758-01) in-
cluded in the NUS report shows the clay layer as a continuous unit.
6. Sufficient pre-test and post-test water-level data were not col-
lected from the unconfined aquifer monitoring wells measured during the 24-
hour test on Production Well 1 (confined aquifer) and therefore, the cause
of water-level declines observed in these wells during the test cannot be
confidently determined. Pumpaqe of National Highway Well 1 or any other
well in the site vicinity, stage-level changes in the Delaware River, or
seasonal regional water-level changes or any combination of the above are
all possible factors which could cause the observed water-level declines.
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GERAGHTYc-MILLER. INC.
7. Based on data presented to date, contamination of National Highwa
Well 1 cannot be attributed to activities at the SOCC site. Because of the
industrialized nature of the area, other potential sources are as likely
causes of contamination as SOCC.
8. Because approximately one-third of the site was not studied, the
determination of PC9 extent in surficial soils is not sufficient to deter-
mine what remedial actions are needed for the entire site. Specifically,
the alternative presented by NUS to excavate 1.3 feet of soil from the site
is arbitrary and exceeds any reasonable remedial effort.
SUMMARY OF NON-SUPPORTABLE CONCLUSIONS
Page
3-49: "The clay deposits are not continuous." Data presented in the NU
reports contradict this statement. Boring logs from PW-1 and the
monitoring wells installed under NUS supervision report a clay layer
at all well locations. The 24-hour pumping test at PW-1 indicated
that there is no direct connection between the shallow and deep
aquifers, implying the existance of a continuous clay layer.
"The clay deposits may be pinching out to the south of the site."
No data are presented in the NUS report (in the form of boring logs
and geophysical logs) from the vicinity south of the SOCC site and
PW-1 to indicate that the clay zone pinches out south of the site.
Until such data are presented the statement is speculative.
3-50: "Under PW-1 pumping conditions, the horizontal ground-water flow v
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• GERAGHTY e- MILLER. INC.
-5-
Paqe
locity in the confined aquifer is estimated to be 10.61 ft/day
(3,870 ft/yr)." NUS has not presented any data (in the-.form of
•*»-•*•'
water-level measurements or aquifer testing in the confined aquifer)
7 '' ~~^.-i-^K.---"^ ft^fe'^S *"
properly predict the horizontal flow rate pr qif ection* In Jbhe
aquifer.
• • - v -
'.'•,' * 4
...
-r * f-
?W-1 .pumping conditions, the downward vertical ' velocity
through the clay deposits is about 8.9 x 10"* ft/day (3.2 ft/yr)."
Estimates of vertical flow velocities through the'^oT^nTnTF^Sri!
(the clay deposit) cannot be made until a vertical flow gradient has
been calculated. Based on the information presented in the NUS re-
port, a vertical gradient has not been calculated
4-6: "...National Highway Well 2 has not yet shown any volatile organic
contamination..." Contrary to this statement, PW-2 is contaminated
with volatile organic compounds as indicated in Appendix C.
4-36: NUS lists three mechanisms for environmental contamination at the
-; , HSOCC site: "Percolation of contaminants from the.iagoon-^fcanl^'farm.
- v*:'-'S>"S!*! •
and Bonded surface water through the soils to the griJundawater."
'-•-.•• . " . • • *""•.''." ^••'.!$^-tf^
"Percolation of contaminants through the soil to the ground^watet^
'•'••" ' ' fe$* '^
from spillage due to handling, orocessing, and disposal 61
used or processed at the site" and "movement of contaminants into
the soil and ground water following spillage over the ^surface of the
site." The alleged envirorWntal^;cbnftamihat£§n^ with "respect to
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GERAQHTY,? MILLER. INC. -6-
Page
ground water beneath the site is unsubstantiated as no continuous
pathway between the contaminant source and ground water has been
shown to exist.
4-38: "Movement of the site-associated chemicals as constituents of the
ground water is the major route of contaminant migration associated
with the site." No evidence of contamination throughout the entire
. •
thickness of the unsaturated zone has been demonstrated. The shal-
low water table well (MW-2) has not been sampled. If the site were
the source of deeper ground-water contamination (Monitoring Wells 1,
3, 4, and 5) contamination would likely be present in the interven-
ing zones.
4-42: "Mobile contaminants seem to move fairly well from the upper to low-
er aquifer depending upon the influence of the dominant cone of de-
pression of the time." There is no evidence supporting this state-
ment. A continuous clay layer, which separates the shallow and deep
aquifer acts as a confining unit between the aquifers. The clay
unit retards the vertical movement of ground water. It is unlikely
that mobile contaminants "move fairly well" between aquifers.
SPECIFIC COMMENTS REFERENCED TO REPORT SECTION AND "PAGE
ES-1: The claim that "ground water in the unconfined aquifer beneath the
site is contaminated, primarily with volatile organics and heavy
metals," is based on one round of analysis of samples from four
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GERAGHTYc/ MILLER. INC. -7-
Paqe
wells. It is not known (by us) whether the samples for metals'
analyses were passed through a 0.45-micron filter prior to preserva-
tion for shipment, as proper protocol dictates. No data were pro-
vided on samoling and analytical techniques.
CS-2: The reported subsurface soil contamination to a depth of at least &Q
feet at only one location could be the result of improper sampling
•
techniques that resulted in contamination of that sample.
As noted, the area is heavily industralized and a landfill is loca-
ted some 3,000 feet north of the site. No mention is made of the
possibility that off-site sources may be responsible for ground-
water contamination beneath the site. Data from any on-going or
completed studies of ground-water contamination in the area should
have been researched and included in this report.
ES-3: Although the subsurface investigation was not intended to identify
sources of ground-water contamination other than the Swope Oil Com-
pany site, other sources should have been investigated at least as
noted above. We believe that this is a major deficiency.
ES-4: The statement that "the leakage appears to be to the south of the
site where a window through the clay might exist" is speculative.
CS-6: First paragraph. At this point, we do not believe sufficient data
exist to attribute any off-site contamination to the Swope Oil Com-
pany site.
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GERAGHTY,? MILLER. INC. -8-
Page
ES-6 Last paragraph. Since PW-1 is not in use, there is no completed ex-
posure pathway for individuals using the lower aquifer for consump-
tion and hence no health risk.
-^
~\<* % '
v -\v ES-7: The implication that the Swope Oil Company site is responsible for
V
V risks associated with Park Avenue Well 2 and Puchack Well 2 is to-
v; ^
tally unwarranted.
•
3-1: NUS states that the scope of work was designed to abide by the re-
quest made by the N3DEP to avoid installing monitoring wells in the
confined aquifer to prevent cross contamination between aquifers.
Geraghty & Miller, Inc. is of the opinion that if the confined aqui-
fer is already contaminated (based on the preliminary analysis
water samples from PW-1), then the cross contamination issue is a
minor concern. In addition, the NODEP has drilling specifications
designed specifically to prevent the cross-contamination of water-
bearing zones during monitoring well installation. Until-monitoring
wells are installed in the confined aquifer, the pathway for contam-
inants to enter the confined aquifer cannot be properly determined.
3-13: The discussion of transmissivities for the confined aquifer fails to
to clarify the purpose of evaluating several sets of data from.pro-
duction wells in the area. The data are not presented and the cal-
culated transmissivity values and storage coefficients vary consid-
erably. The wide range in values indicates that the data cannot be
applied to site-specific situations.
.:*>.
••'•'
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GERAGHTYe" MILLER. INC. . -9-
Page
3-14: At the bottom of the second paragraph, there is a discussion of
drawdown in various pumping wells versus distance and time. The
referenced Table 3-4 and Figure 3-4 do not agree with the interpre-
tation described in the text. Table 3-4 is an inventory of five
monitoring wells screened in the unconfined aquifer and two produc-
tion wells screened in the confined aquifer and not a series of
wells screened in the confined aquifer. The distance drawdown
curves shown on Figure 3-4 are for an aquifer with non-leaky arte-
sian characteristics. The text describes the aquifer as leaky arte-.
sian and therefore the drawdowns shown are much greater than would
actually occur.
3-17 This section of the text describes the test boring field program.
and
3-19 There are no references to the decontamination of the augers or
split-barrel samplers between borings and sample intervals. A soil
sampling protocol must be submitted to verify that cross contamina-
tion did not occur between samples.
3-36: The first paragraph describes the analysis of data collected during
the performance of slug tests. The scales for the data plots given
in Appendix A apparently are reversed. Time is usually plotted on
the logarithmic scale and the change in head is plotted on the arith-
metic scale. The last sentence of the first paragraph is inconsis-
tent with Tables 3-5 and 3-6. These tables list the laboratory data
only and not the hydraulic conductivity data calculated from the
"slug" tests.
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GERAGHTY,? MILLER. INC. «itf
Page
3-27: In the second paragraph, the two screens in PW-1 are described as be-
• ing separated by 20 feet of clay. As illustrated on Drawing S758-01,
the screened intervals of this well are both below the 20-foot thick
clay layer.
3-31: The report states in the third paragraph that the clay layer is ex-
tensive and acts as a confining layer between the unconfined and
confined aquifers. However, at several other places in the text it
is suggested that the clay is discontinuous or that a "window" ex-
ists which is contrary to all existing data. The last paragraph
states that the clay changes to silt. The geologic cross-section
s
(Drawing 5758-01) does not show this.
3-36: In the second paragraph it is stated that the Delaware River is sit-
uated southwest of the SOCC site. The location diagram shows the
Delaware River to be west of the site.
3-38: In Section 3.3.3.4 the reasoning behind pumping PW-1 for a 24-hour
period is described. The basic assumpiton that the unconfined and
confined aquifers constitute one hydrological unit is a contradic-
tion of all previous statements made in this report concerning the
aquifers. A 20-foot thick clay unit separates the two aquifers and
they must be considered separate.
3-39: The first paragraph contradicts the previous statement by reporting
that the drawdown in MW 3 was less than anticipated and indicat
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GERAGHTYc* MILLER. INC. -11-
Page
that the two aquifers are not part of the same hydrological unit.
The discussion of the findings from the pumping test with reference
to Figures 3-8, 3-9, 3-10 is incorrect. The water-level contours
prior to and at the end of the test indicate that the ground-water
flow direction in the unconfined aquifer remained the same during
pumping of PW 1.
In the last paragraph, three possibilities of discharge of water
from the unconfined aquifer are listed. One additional possibility
was not mentioned. A decline in the water table could simply be the
result of lateral movement of water away from the SOCC site in the
unconfined aquifer.
3-42: In the second paragraph it is mentioned that the permeability value
7 —8
of the clay is 4.5 x 10~ cm/sec. A value of 5.4 x 10 cm/sec is
referenced in the report. In the same paragraph, the vertical gra-
dient through the clay is reported to be 2 ft/ft. There are no data
to substantiate this estimate. The leakage estimate of 17,000 gal-
lons per day (gpd) would be reduced to approximately 1,700 gpd using
Q
the permeability value of 5.4 x 10" cm/sec.
In the last paragraph a deflection of water-table contours after
pumping is described. This is not illustrated on the water-level
contour maps. The estimate of 500,000 gpd is absurd because the
pumping test did not indicate that a direct connection exists be-
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GERAGHTYe'MILLER. INC. -12-
Page
tween the two aquifers. Data are not available that indicate a win-
dow exists in the clay layer.
3-43: In the second paragraph it is stated that the radius of influence of
National Highway Well 2 (PW-2) extends into the study area. No data
are presented to defend this statement.
In Section 3.3.3.6, the first paragraph states that ground-water ve-
locities will be affected by pumping patterns. The pumping patterns
are the result of a hydraulic connection through a "window" in the
clay. Again, there is no evidence of a "window" in the clay.
3-47: Figure 3-11 shows the results of a pumping test where the discharge
(Q) was not constant. Also, the discharge was apparently greater
than 16 gpm during the first minute of the pumping test. Maintain-
ing a constant discharge rate during a pumping test is a major re-
quisite in developing interpretable data.
3-48: The vertical velocities presented in the second paragraph were cal-
culated without presenting a vertical gradient. The numbers are not
considered reliable unless a vertical gradient is given.
3-49 Some of the conclusions are questionable or incorrect because there
•-and ' " •••••'• • • .. . '• ...
3-50 is no evidence that the clay zone is not continuous; evidence is not
.presented indicating that the clay deposits pinch out to the south
of the site; data are not given on which to base the estimate of the
horizontal ground-water flow velocity under PW-2 pumping conditions;
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• GERAGHTY i? MILLER. INC. -13-
Page
and the estimate of vertical downward velocity in the clay while PW-
1 is pumping cannot be determined without a vertical gradient.
4-2: The title of Table 4.1 is inappropriate as contaminants listed are
not necessarily associated with the'site. According to this table
and Table 4-2, carbon tetrachloride and chlorobenzene were never de-
tected on or beneath the site. Two compounds, 1,1-dichloroethane and
1,1-dichloroethene, were not detected in test borings, surface soil
or surface water at the site. Their presence in monitoring wells
does not mean that they are site-associated.
4-3: As stated on p. 4-4, 58 ug/L of di-n-octyl phthalate was found in
MW3. Table 4-1 does not so indicate.
4-4: No explanation is given for the lack of analytical data for MW2.
The trace amounts of PCB-1254 reported for MW 1 and MW 5 are ques-
tionable. The results could be erroneous or the result of contami-
nation attributable to drilling techniques or improper or careless
sampling orocedures (PCB's are reportedly widespread in soil at the
site).
The maximum amount of total volatiles found beneath the site in MW3
(114 ppb) is relatively low and hardly indicative of a major contam-
ination source.
4-6: Sample collection techniques are not described. If samples collec-
ted for dissolved metals' analysis are not filtered, the results may
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GERAGHTYe" MILLER. INC. -14-
Page
indicate concentrations in excess of those actually present in dis-
solved form (fine sand, silt and clay particles may have various con-
taminants adsorbed to them which are dissolved by acidic sample
preservatives).
PW-2 does show volatile organic contamination according to results
given in Appendix C.
PW-1 contains only six volatiles that are also present in on-site
monitoring wells. These are all compounds that could be attributable-
to a number of sources such as dry cleaning establishments, auto re-
pair facilities, many types of manufacturing plants, and landfills.
4-7: Carbon tetrachloride, found in PW-1, was not detected in any on-site
monitoring well.
4-8: The high concentration values shown for PW-1 apparently are actual
values for PW-2 and have been typed in the wrong column.
4-9: The historical data showing that the concentration of mercury in PW-1
fluctuates above and below 2.0 ppb are not given nor is any informa-
tion on sampling techniques.
. Contrary to Table 4-4, PW-2 does contain volatile organics according
to Appendix C. The author evidently based his conclusion that it
does not on Table 4-4.
PW-2 is not located adjacent to the site.
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GERAGHTYc' MILLER. INC. -15-
Page
4-15: No soil samples were collected over about one third of the site;
therefore, the overall distribution of PCB's is not known and the
extent of remedial measures cannot be determined.
4-19: A number of analyses on this paqe were considered invalid by NUS;
this raises questions as to the extent of quality control measures
and the validity of other data.
4-20: MW 3 is located downgradient of the buried sludge. With the excep-
tion of 58 ug/L of bis (2-ethylhexyl) phthalate and 58 ug/L of di-n-.
octyl phthalate, the well does not contain constituents common to
the sludge. As noted previously, the reported results for the two
phthalates are questionable. Thus, there are insufficient data to
indicate that the sludge is contributing to ground-water contamina-
tion; the need for its removal is questionable.
4-36: The alleged environmental contamination with respect to ground water
beneath the site is unsubstantiated as no continuous pathway between
- the contaminant source and ground water has been shown to exist.
4-39: See preceding. No evidence of contamination throughout the entire
thickness of the unsaturated zone has been demonstrated. The shal-
low water table (MW 2) has not been sampled. If the site were the
source of deeper ground-water contamination (Monitoring Wells 1,3,
43 and 5), contamination would likely be present in the intervening
zones.
Vyt$W**i".'
. f '- -' T
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Paqe
4-40: Transmissivity is not measured in centimeters per second.
No data exist to calculate the velocity of ground-water flow in the
confined aquifer.
4-41z Mercury was not the only contaminant detected in PW-2.
4-42: There is no basis for assuming that "upper aquifer contaminants were
•
similar in April 1984 to those actually observed in July 1984."
There is no evidence that "mobile contaminants seem to move fairly
well from the upper to the lower aquifer depending upon the influ-
ence of the dominant cone of depression at the time."
REMEDIAL ALTERNATIVES
Section 7
Results of RI did not show any levels of hazardous chemicals or ma-
terials in the tanks or buildings. Therefore, demolition of exist-
ing tanks and buildings exceeds any reasonable remedial effort.
' Covering of all soils and sludges with asphalt should be considered
to minimize leachate production and chances for direct contact.
All other remedial alternatives in regard to the soils are excessive
and extremely expensive.
No action should be taken in regard to supplying water to compensate
for the shutdown of PW-1 because additional studies are needed to
determine the source(s) of contaminants found in this well.
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GERAGHTYS MILLER. INC -17-
MISCELLANEOUS COMMENTS
On page 3-25, Table 3-6 lists the results of laboratory analysis of
Shelby tube soil samples. The density of a soil sample for MW3 appears to
be inaccurate. The reported value of 18.41 g/cm is an order of magnitude
greater than for the other samples in the table and probably reflects a
decimal place error.
The third paragraph on page 3-13 presents a discussion of the amount
of water that large-diameter wells yield in the area. Based on the range
of yields presented, the average of 720 gallons per minute (gpm) is incor-
rect.
Table 4-2 gives analytical results for samples collected from four of
the five monitoring wells which were installed on site. No explanation is
given as to why MW 2 was not sampled. The reported presence of 58 ug/L of
bis(2-ethylhexyl) phthalate and 58 ug/L of di-n-octyl phthalate in MW 3 is
suspect. According to Table 0-1 in the Appendix, the former compound is
classified as being "very immobile11 while the latter is "slightly mobile."
We question the presence of both compounds in equal concentrations.
According to Figure 3-8, which indicates the direction of ground-water
flow, MW 5 is upgradient of MW 1. However, 41 ug/L of acetone and 30 ug/L
of total xylenes were detected in MW 5; none were present in MW 1. This
raises the possibility that an off-site source of contamination exists. MW
4 is also at an apparent upgradient location and exhibits a degree of con-
tamination similar to that of MW 3 which is downgradient. This further
substantiates the possibility of an off-site source.
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G£RAGHTYc> MILLER. INC ' -18-
Drawing 5758-01 indicates that, on the date measured, the water level
in MW 1 was higher than that in MW 2. Both wells are screened in the un-
confined aquifer, MW 1 at a greater depth than MW 2. The head difference
indicates that there is an upward component of ground-water flow which
would preclude downward migration of ground water and/or contaminants. The
gradient might be reversed under pumping conditions; no such data were pre-
sented.
A number of questions are raised by the analytical data presented in
Appendix C. For example, the 4/10/84 analyses for National Wells 1 and 2
indicate that each well had a calcium concentration of 4.1 mg/L, chloride
11.5 mq/L and nitrate 4.44 mq/L. For two wells located some distance apart
to have exactly the same concentrations of three constituents is unusual.
If typographical errors are the reason, other data become suspect. The
7/12/84 sample blank was reported to contain 66 mg/L COD, 38 ug/L acetone,
6.1 ug/L chloroform, and 8.6 ug/L methylene chloride. The 7/10/84 blank
was reported to have 440 mg/L nitrate, 254 mg/L total dissolved solids, 30
ug/L acetone, 5 uq/L chloroform, and 7 ug/L methylene chloride. An error
on a "traffic report" made it impossible to differentiate between samples
for PW-1 and PW-2 (7/10/84). These unexplained results raise questions
about quality control or the lack thereof and cast further aspersions on
the validity of other data. .
Since it is implied that the Swope Oil Company site is responsible for
contamination of PW-1, historical analytical data for this well should have
been presented and compared with estimated ground-water velocities. A lac
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GERAGHTY & MILLER. INC.
-19-
of correlation between travel time and initial detection of contamination
in the well could point to another source.
Please call if you have any questions or wish to discuss anything
further.
Sincerely,
ChristopheY' Creed
Staff Scientist
Doug-as R. MacCallum
Senior Scientist
* ¥
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GERAGHTY & MILLER. INC
of correlation between travel time and initial detection of contamination
in the well could point to another source.
Please call if you have any questions or wish to discuss anything
further. .
CC:DRM:MFW:me
Christopher Creed
Staff Scientist
Douglas R. MacCallum
Senior Scientist
Michael F. Wolfert
Associate
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