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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 111
FINAL DECISION AND RESPONSE TO COMMENTS
BASF Corporation
300 Brookside Avenue
Ambler, PA
PAD002348324
PURPOSE
The United States Environmental Protection Agency (EPA) is issuing this Final Decision
and Response to Comments (FDRTC or Final Decision) selecting the Final Remedy for the
BASF Corporation (formerly known as the Cognis Corporation) facility located in Ambler,
Pennsylvania (hereinafter referred to as the Facility or Site). The Final Decision is issued
pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and
Recovery Act (RCRA) of 1976, and the Hazardous and Solid Waste Amendments (HSWA) of
1984.42 U.S.C. Sections 6901, et seq.
On August 29, 2019. CPA issued a Statement of Basis (SB) in which it described the
information gathered during environmental investigations at the Facility and proposed a Final
Remedy for the Facility. The SB is hereby incorporated into this Final Decision by reference and
made a part hereof as Attachment A.
This FDRTC selects the remedy that EPA evaluated under the SB. Consistent with the
public participation provisions under RCRA, EPA solicited public comment on its proposed
Final Remedy. On August 29. 2019. notice of the SB was published on the EPA website:
I https://www.epa.nov/publicnoticcs/noticcs-searchl and in The Reporter newspaper. The thirty
(30) day comment period ended on September 28. 2019,
Since EPA did not receive any comments on the SB. the remedy proposed in the SB is
the Final Remedy selected by EPA for the Facility.
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FINAL REMEDY
l-.PA's final Remedy lor the facility includes the following:
1. I he Facility shall provide i-PA with a coordinate survey as well as a metes and hounds
sur\ey. of the Facility and .Area Parcel boundaries, and the survey limits where engineering
controls ai'e se^iliireel by the Post-Remediation (.'are Plans tor Building 14 and 23.
2. lor Building 23 and Area and Ball fields Parcel: implementation of land-use controls to
restrict the use ol the parcels to commercial, recreational and or industrial purposes and prohibit
use lor residential purposes.
3. I or Site wide Soils, Building 14 Area, Building 23 Area, and Ballftelds Parcel: compliance
with, and maintenance of, the following use restrictions:
A. i hese areas shall he restricted to commercial recreational and or industrial
purposes and shall not be used tor residential purposes, unless it is demonstrated to EPA that
such use will not pose a threat to human health or the environment or ad\ ersely affect or
interlerc with the selected remedy, and I-PA provides prior written appro\al for such use.
B. I he existing caps at Buildings 14 and 23 Areas shall he maintained, consistent
with their Post-Remediation Care Plans detailed in their respective f inal Reports. Inspection,
maintenance, reporting, and recordkeeping is required, in compliance with their Post-
Remediation fare Plans detailed in their respective final Reports.
4. l or Residential Soils Parcel: As the soils at the Residential Parcel meet residential Statewide
Health Standards (SI IS) under the Pennsylvania Land Recycling and Ln\ ironmental
Remediation Standards Act. no remedial action is necessary. "I his Parcel meets standards for
unrestricted use.
5. Lor groundwater:
A. Monitor and treat the groundwater until federal Maximum Contaminant Levels
(MCLs) promulgated pursuant to Section 42 l.S.C. 3()0fet seq. of the Safe Drinking Water
Act and codified at 40 C!:R Part 14. are met,
B. Compliance with, and maintenance of. groundwater-use restrictions that restrict
groundwater-use to non-potable and non-agricultural uses at the facility in order to present
exposure to contaminants while levels remain aho\e drinking water standards.
C. Submission of update of the Groundwater Monitoring Plan (Plan) for LP A approval.
1 his Plan must identify future monitoring acti\ities. schedules, and additional treatment
alternatives, as appropriate. This Groundwater Monitoring Plan may also include a proposal for
alternative cleanup levels which are protective of human health and the environment based on
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I;acilit\-speciik scenarios and uroimdwater use. If I.TA determines thai an\ such altcrnalhe
cleanup 1 o\els arc appropriate. hl\\ will solicit public comments on such cleanup levels prior to
amending this l-'DRTC and including them in the Kinal Remc\h tor the i aeilin.
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1)1 XL A RATION
Bused un the Administratec Record compiled for the correct i\e action at the BASI-"
Corporation Facility. 1 ha\e determined that the remedy selected in this Final Decision and
Response to Comments, which incorporates the August 24. 20! 9 Statement of Basis. is
protectee of human health and the environment.
Land. Chemicals, and Redevelopment Division
\ :S l-.l'A. Region I!1
Attachment A: Statement of Basis (August 29, 2019)
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ATTACHMENT A
STATF.MFNT OF BASIS
BASF Corporation
Ambler, PA
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m
Pno^°
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
BASF Corporation
(Formerly Cognis Corporation)
300 Hrookside Avenue
Ambler, PennsyIvania
EPA II) NO. PAD 002348324
Prepared by
RCRA Corrective Action Branch 2
Land, Chemicals, and Redevelopment Division
August 2019
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Tnhie of Contents
Suvlimi !: I il I rod ikM inn.
Si'vtion 2: i;uilii\ U;ick» round
Section 3: Sumni:ir\ of 1 in ii onniI ln\ tsii^alious
Seel ion 4: (orrTt1 ti\ c Action Oh jt ciiv i s
Section 5: Proposed Kunitci\
Section (i: L\;ihi;tlion of'Pioposed ks.'i!K'd>
SfCtiOll i' ilKllll'iill ASSIIIMIK'I'
Si'iiion H; Public I'iirlk'ijuilion ...
Attachment A: lmh'\ to Adniinis!r:iti\ t Record
J-i mi re 1: i- i»urc u!FnciliU ,,
Tnide I ...
List of Acronyms
AR Administrative Record
C( K Constituent of Concern
I;PA Ln\ ironmertlal Protection Aucncv
l;I)R IC Final Decision Response to Comments
(iPRA Government Performance and Results Act
MCI. Maximum Contaminant Level
MSC Medium Speeilic Concentration
PADLP Pennsshunia Department of Lm ironniental Protection
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RSI Regional Screening Level
SB Statement of Basts
SI IS Statewide Health Standards
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Section 1: Introduction
1 he I tilled Slates I n\ ironmenial Protection Agencv il I' \| has prepared tins Statement
ol Basis (SBi to solicit public comment un its proposed remedv lor the BASF Corporation
t tonnerlv known as the t ognis { orporutionI I aeilitv located in Ambler. t'ennsv l\ ansa
IhercinaUer re I erred to as the Facilitv or Site). 1 PA\s proposed remedv lor the Facilitv consist*
ol compliance with ami ntaintcnance ol land-use restrictions. existing engineering controls, and
continued groundwater monitoring and related aetiv hies to he implemented through institutional
controls. I his SB highlights ke\ information relied upon bv F PA in proposing its remedv lor the
Facility.
1 he Facility is subject to F.P.Vs Corrective Action Program under die Solid Waste
Disposal Act. as amended In the Resource Conservation and Recover} Act (RCRA) ol" 19?6.
and the I la/ardous and Solid Waste Amendments (HSWA) of lv)X4. 42 I ,S,C. ^ 6901 et sey.
{Corrective Action Program). 1 he Corrective Action Program is designed to ensure that certain
lacilities subject to RCRA have investigated and cleaned up an> releases of hazardous waste and
hazardous constituents thai ha\e occurred at their property. The Commonwealth of
Pennsylvania (Commonwealth) is not authorized lor the Corrective Action Program under
Section 3006 of RCRA. Therefore. I-PA retains primarv authority in the Commonwealth tor the
Corrective Action Program.
1PA is providing a ihirtv (3d) da> public comment period on this SB. 1PA mav modify
its proposed remedy bused on comments received during this period. I PA will announce its
selection of a Una! remedy for the Facilitv in a Final Decision and Response to Comments t Final
Decision) after the public comment period has ended.
Information on the Corrective Action program as well as a fact sheet for the Facility can
be found bv navigating https: ;vvwvv.eixi.gov/hwconvctiveaciionsites eontact-infbrmation-
eorrectiv c-action-ha/ardous-w aste-clean-ups-dektware.
I he Administrative Record IAR) lor the Facilitv contains all documents, including data
and quality assurance information, on which F.PA's proposed remedy is based. See Section 8.
Public Participation, below, for information on how you mav review the AR.
Section 2: Facility Background
The Facility is located at 300 Brookside Avenue, in Ambler, Pennsylvania (Figure 1).
I he Facility was formerly owned by the Cognis Corporation (Cognis). I lenkel Corporation.
Amchem Products. Inc., Union Carbide Corporation, the Rorer Ciroup, and several priv atelv -
owned companies.
1 he 44-acre I aeilitv originally consisted of 20 buildings which housed administrative,
research and development, manufacturing operations, and support facilities. Properties
Statement ol Basis
BASF (formerly Cognis)- \mbler Aliens! 20p>
Page 1
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Section 2; FaciHh L£ai:lvi> round (continued)
surrounding the 1 acililv arc primarily residential. A commuter raihoad line border the west
side of the property,
I he facility manufactured metal treatment products between ll>23 and 2003. I lerbieides
and pesticides were manufactured between 1M3K and NXO.
In 20111. HAS! purchased the 1 aeility property from ('otitis Corporation (Connis).
Specialty laboratory work and general business and site-support service were conducted by
C'oynis between 20U3 and 2iUl). ()perations at the facility ceased in 2012, Currently the
I aciliis property is being rede\eloped and is known as Ambler Yards. Se\eral ol'ihe buildings
has e been leased to tenants lor commercial operations.
I he 1 aeility has been subdivided into the following areas and parcels for purposes of
investigation:
1. Building 14 Area and Building 23 Area housed manufacturing operations and were
investigated individual!):
2. the Residential Parcel is an approximate 1.5-acre parcel that encompasses
administrative (formerly residential) buildings in a southeast corner of the Site and
3. the 18-acre Ballllelds were transferred to Lower Ctvvynedd 1 ownship and the
Borough of Ambler in 2002:
4. Sitewide Soils which consists of the remaining the 44 acres of the facility, excluding
the Building 14 Area: Building 23 Area: Residential Parcel and Ballllelds Parcel, and
5. groundwater which was evaluated at each of the areas and parcels as well as site-wide
Section 3: Summary of Knviron mental Investigations
3.1 Km ironmcntai Investigations and Kemedimiim
Since 1980, multiple investigations and remedial activities have been conducted at the
Facility. I PA has included the most relevant reports in the Administrative Record lor this SB as
listed in Attachment A.
I he environmental investigations al the Facility have focused tin soils, groundwater and
potential for vapor intrusion. Sitewide investigations arc described below, fable 1 summarizes
the investigations, remediation reports and applicable institutional and engineering controls at
each area.
SiteM ide S investigation, an extension of the 2003 and
Statement of Basis
August 201*)
Page 2
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Section 3: Snmman ofi\n\ironmenhil ln\ estimations (continued)
2004 investigations. was a more comprehcnsivc evaluation of the entire 1 uci 1 its. In total. the
2HII3, 2004 and the 2006 investigations included 2.% soi 1 samples collected from 167 locations
and included anal\>is li>r metak. volatile organic compounds. i \ ( H si. semi \olatile organic
compounds {K\ E!(\). pesticides, herbicides, polv chlorinated biphenv Is (P( lis j, cvanidc and
dioxin, I him-one samples identified cthv Iben/ene, x\ lenes and arsenic at concentrations alxn e
lheir applicable nun-residential Statewide I lealth Standards (SI IS) under Act 2 and I PA's non-
residential RSI.s.
Ixeavations in the vieinitv of former fank 2 removed 265 cubic vards of contaminated
soils. Post-excavation confirmation soil sampling confirmed cleanup levels were met for
ctln Ibcn/cne. x>lenes and arsenic.
In Sitewide soil investigations. cth>lhen/cne and x\ lene were the onl\ constituents found
to haw the potential for volatilization to indoor air. I-valuation of whether there is a potential
exposure risk of a contaminant volatilizing to building indoor air includes a number of factors,
notably the natural tendency of the contaminant to volatilize to the air and the contaminant's
location with respect to buildings, l.thv Iben/ene and xvlenc le\cls slightly exceed the criteria for
potential volatilization at two isolated areas. The \ olatili/ation to indoor air criteria for soils of
cih> Iben/ene is (>.5 nig'kg and 77 nig kg lor xylene. I he highest soil concentration found for
cthv (benzene is 91 nig'kg and 400 mg*'kg for xvlene. 1 hese two isolated areas are more than lot)
(eet {tt) troni buildings and were detected more than 5 ft below ground surface. Assessment of
this information shows thai there is not a risk of volatilization to indoor air from contaminants
remaining in soils.
1 he final Report on the 2003. 2004 and 2006 investigations on Sitewide soils was
submitted in 2008 and received PADFP Act 2 approval on June IK. 2015. An environmental
covenant was recorded with the Montgomery Couniv Recorder of Deeds on Jut> 21. 201b. 1 his
covenant requires HAS! and am future owner ol" I aeilitv properts to resit id land and
ground water-use activities to those compatible with non-residential uses,
liuildinn 14 Area
Pursuant to a i l>Xn Administrativ e Consent (>rder (AOC) (1 I'A Docket No, 111-86-16-
DC) issued to previous f acility owners Amchcm Products. Inc. and I :nion Carbide Agricultural
Products Companv. Inc., the Respondents were required to develop a soil sampling plan to
delineate am dioxin contaminated soils above I part per billion (ppb) around the southwestern
side of Building 14. Approximately 3RD cubic vards of dioxin-contaminated soil were excavated
from the railroad siding and Building 14 .Area. I he excavation ranged between 1 and 3-feet deep
over an area of approximate!} 5.500 sq ft, Dioxin cleanup tasks were successfully performed to
meet an HPA cleanup criteria of 0.246 mg'kg. Arsenic was remediated to meet an I-PA and
PAD!' P-approved. risk-based screening level of 3,066 mg kg. I-PA approved the clean-up b\
letter on Januar> 22. I 9W.
Statement of Basis
BASf (formerly Cognist-Anihler August 20B>
Page 3
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Section 3: Numiii;tr\ of Kn\ironmcnlnl fn\estimations (continued)
During she 2003 and 2004 investigations. 2.4.6-irichlorophenoI. 2,4-dichoIorphcnol <2.4-
iK 1'I. 2.4-dichloropheno\\ acetic acid, 2.4.5-lriehlorophcno\s acetic acid, naphthalene. diosin
and arsenic were lound in soils at concentrations above ilie St IS and 1 PA RSI.s in the Buildine
14 Area. I: FA an J PAI)I P determined that attainment of Sf IS and I- PA RSI s was not feasible
and required the installation of a cap the Building 14 Area.
Remedial action consisted ol the installation of 4-inelt thick asphalt cap on top of I - ft
deep fill along the entire south-southwestern side ol the Building 14 Area. Building 14 is roofed
and constructed of concrete, brick, and steel. With the addition of the asphalt cap. the Building
14 Area is complete!) surrounded hv asphalt and concrete, which serves as an engineerinu
control (capl for the area.
A risk assessment was developed using landscape and outdoor maintenance workers as
the anticipated receptors. I he assessment indicates that the remaining concentrations of
constituents at the Building 14 Area do not pose a risk to landscape and outdoor maintenance
workers.
Volatile organic compounds were not found in the Building 14 Area: therefore, potential
vapor intrusion is not a pathway of concern for this area.
I he 2008 final Report requires engineering and institutional controls and a Post-
Remediation Care Plan for Building 14 Area received PADl'P Act 2 approval on June IK. 2015.
An environmental covenant was recorded with the Montgomery County Recorder of Deeds on
July 21, 2016. This covenant requires BASF and any future owner of facility proper!) to restrict
land and groundwater-use acti\itics to those compatible with non-residential uses. In addition,
the covenant requires inspection, maintenance, record-keeping and reporting to ensure the
integrity of the engineered cap that overlies Building 14 Area,
Building 23 Area
Building 23 was an operational research and development lahorator) thai could not be
accessed for purposes of an environmental investigation at the time of site-wide assessment
activities in 2006. Operations in Building 23 ceased in 2012, During that same % ear, an indoor
air and a soils investigation was initiated. A total of 11 soil samples were collected from 10
locations. Levels of arsenic exceeded non-residential standards at three locations and 1.2-
Diehloroethane 11,2-DCA) and 2.4-PCP exceeded non-residential SI IS and HPA RSl.s at one
location.
Based on risk assessment calculations similar to those completed for the Building 14
Area. 1 PA determined that the remaining concentrations of constituents in soils at the Building
23 Area do not pose a risk to receptors, provided the building slab remains in place. Given the
Statement of Basis
BASF (Formerly Cognis)-Ambler \ii
Page 4
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Section 3: Sumnuin of I'm ironnicntnl Investimations (continued)
concrete .slab con-»lructed over the Building 23 Area, all exposuic palhwav •. were found to he
incomplete. requiring no further remedial aciiv ilies, \ Posi-Remedialion t are Plan for
conducting inspections. maintenance, record-keeping, and reporting of the concrete slab is
required !n the final Re poll dated November 201 5.
During the 2012 Building 23 Area investigation. concentrations of l.2-()C'A.l,2
dieiiloropropane 11.2-1M PPI and chloroform in soil exceeded the screening \ alues for potential
risk lor vapor intrusion to indoor air. A further investigation di recti} sampling the indoor an-
nual it} found no constituents abov e SI IS and I-PA RSI.s in indoor air.
I'he 2015 Building 23 Area final Report received I'ADIT Act 2 approval on
January 26. 2016.
Residential Parcel
I Residential Parcel is an approximate 1.5-acre parcel that encompasses administrative
(former!} residential) buildings as well as landscaped and parking area. Between 2012 and 2014.
a focused environmental investigation and remedial actions were performed in the southern
portions of the f'acilitv. which includes the Residential Parcel. I his Parcel meets PADhP's
residential SI IS and 1-PA RSI .s. The Pinal Report lor this Parcel was submitted in 2015 and
received PADKP Act 2 approval on September 2T 201 5.
Balifields Parcel
In 2002. Cognis sold the Hall Ileitis Parcel, approximately IK acres in si/e, to I ovver
Cs. or metals. Alter review of facility Illes. in 2005.
a .subsequent investigation was performed to assess whether PCBs. pesticides, herbicides, and
dioxin were at the Balllields Parcel. 1-PA has determined that the investigations show that the
Parcel meets PADI.P's sum-residential health standards and I PA RSI.s for those constituents.
Currently there are no buildings at the Balllields Parcel, however the potential for vapor
intrusion into future buildings was evaluated. VOCs above screening levels for potential indoor
air were not found in the Balllields vapor investigation: therefore. I PA has determined that
potential vapor intrusion is not a pathway ol concern for future buildings.
A final Report for the Balllields Parcel was submitted to PADi'P in 2006. PADIP
approved the Report under Act 2 on May 3. 2t)0(i.
Statement ol Basis
BASF (formerlv Cogiml-Ambler Vuutist 20P)
Page 5
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Section 3: Numm;it\ of I.uv innimciiUil In\ i-sli<>Li (ions (continued)
Nil can i(kL <, fo ti n hut
(irotindwater beneath the facility has been evaluated since she curly LWOs lor V( >Cs.
S\'()(. s and metals. C'eriain V( K's such as 1.1-1 )ichloroeihe»c. 1,2-DCA, I.2-DCP.
triehloroethene. were found in the overburden and shallow bedrock aquifers above National
Primary Drinking Water Standard Maximum C ontuminant Levels iM( I s} promulgated pursuant
to Section 42 I' .SI'. §§ 3001'et set], of the Safe Drinking Water Aet and codified at 40 ( T R Part
141, Sampling shows the most impacted interval is from 20-50 feet below ground surface (bgs>.
Lesser impacts are shown from 50-80 feet bgs. Deeper impacts were not (bund. 1 he shallow
bedrock aquifer is known as the Stockton formation and is used as a drinking water source for
the local public water utility. However, the depth of the public water supply wells averages 306
feet, which is significantly deeper than the impacted groundwater at the Facility. and these public
water supply wells are at a significant distance from the Facility. further evaluation of using
MCl.s as appropriate clean-up goals has been discussed with the Facility and alternative goals
may be evaluated in the future.
In 2007, 1.2-DCA was found in groundwater at levels above 100.000 ug I in the shallow
bedrock aquifer, at the source area near the former lank Area 3. The MCI. for 1.2-DC A is 5
ug 1. (>ther compounds, such as v im I chloride, which are related to 1,2-DCA (products of
degradation), were also found periodically above MCI s, however at much lower levels and in
smaller areas within the larger 1.2-DCA plume. In this SB. 1.2-DCA is used as an indicator
parameter for discussion of Site wide groundwater contamination.
I wo types of treatment technologies have been employed at the Facility to address the
groundwater contamination. Between 2007 and 2011. the lirst treatment phase consisted of low -
flow extraction and ex-situ o/one-peroxide treatment of contaminants from the shallow bedrock
aquifer. 1 his step removed much of the most highly contaminated parts of the plume. 1 Sow ever,
it was determined that this technology would be inefficient in remediating the remaining
contamination.
In 2010. the second treatment phase used hydraulic and pneumatic fracturing in
conjunction with in-situ injections of a biodegradation product which stimulates chemical
reduction of organic contaminants. The effectiv eness of this second phase was evaluated
periodically to determine if modifications were needed to the system. Subsequent sampling
showed 1.2-DCA levels as well as the si/e of the plume were decreased significantly. [n 2012.
the most contaminated well showed a level of 76.000 ug/1 and the extent of contamination was
reduced by half from 20117. In 2018, the most contaminated well showed a level of 4,200 ugl
and the plume extent wits reduced significantly.
Sampling in 2018 shows the overburden aquifer wells meet drinking water standards for
1.2-DCA and other associated contaminants. Three weathered rock wells adjacent to the former
source area show several volatile organic compounds slightly above their drinking water
Statement nf Basis
BASF (Formerly Cugitki-Antbler Atmitst 20i"
Page b
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Section 3: Sttmmnrv of i-~ in iron mental In\ estimations (continued)
standards. Sev era! >h;i I It i\\ bedrock wells show ing 1,2-1 K "A and other associated contaminants
above drinking water standards vvere mostlv located wiihin 200 feet of the source area. Annual
monitoring across the facilitv is planned to determine it"the remedial strateg} eontinues to
reduce containinam plume concentration and size
On-site exposure evaluation
in 2tl| N. groundwater results show that the overburden at|uit*er does not exceed the
screening le\ els lor polential indoor air puthwav across the Facilitv. other than direelh adjacent
to the former source area at former I ank Area 3. These impacted wells arc located more than
I till feet from all existing buildings at the facility, 1 herefore. potential sapor intrusion for on-
site buildings is not an exposure pathwav of concern.
The 2018 sampling shows that the plume is contained within the Facililv properh
boundary and does not extend off-site, 1 here is no current human exposure to groundwater at
the Facility, as all wells are used solely for em ironmcntal monitoring purposes.
Off-site exposure e\ a 1 nation
In 2013, BASF submitted to Ki'A a summary and discussion of the potential indoor air
pathway for off-site buildings. At the downgradient facility property boundary, all volatile
organic compounds in both overburden and bedrock wells are below the screening levels for
potential volatilization to indoor air: demonstrating that off-site building vapor intrusion is not a
pathway of concern.
Historic IWDI !' sampling has shown 1,2-IX'A is not found above drinking water levels
in off-site wells downgradient of the I neiliiv. Assessment of the PADFP off-site well data and
the on-site Facilitv perimeter well monitoring data demonstrates there is not an off-site
component to the groundwater plume or potential for off-site exposure to Site contaminants,
An environmental covenant was recorded with the Montgomery Count} Recorder of
Deeds on Julv 21. 2016, I his covenant prohibits BASF or am future owner of" Facilitv propert}
from withdraw ing or extracting groundwater tor agricultural or potable purposes.
Statement of Basis
BAM (formerly (.'ognisl-Amhlor \iigu\t 2lill>
I'auc 7
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Section 3: Summing oi l jn irmimentai I in estimations (continued)
3.2 {.in iruiinu'iitiil Indicator?.
I 'ndcr the ( iov eminent Performance anil Results Act it sPRAt, 1 PA has set national n.uK
to address RCRA corrective action facilities. I ndcr (il'RA. LP A evaluates two key
cm irnnincnlal clean-up indicator lor each laeilitv: (I} Migration of Contaminated (irounduatcr
1 'ndcr Control, and (2 > Current I lunian iwposures I 'ndcr Control. The Facility met these
indicators on November 13, 2U|i and September 2v 2'>lf\ respeetivch,
Section 4: Corrective Action Objectives
hPA s Corrective Action (>bjeeti\es lor the specilie cm ironmental media areas at the
Facility arc the following:
1, Soils - Facility and Ballficlds
I-PA lias determined that Pennsylvania's Act 2 non-residential SliS arc protective of human
health and the environment provided that the Facility is not used for residential purposes,
a. Sitewidc Soils - I here is no contaminant in Siteutde Soils in concentrations above its non-
residential standard, IPA's Correctiv e Action ()bjectivc for Sitewidc Soils at the Facilitv is to
prevent exposure to hazardous constituents remaining in soils above residential standards.
b. Building 14 Area and Building 23 Area ¦ Some contaminants at Building 14 Area and
Building 23 Area remain above non-residential SI fS, Currently there are engineering controls
(caps) in place at each of these Areas which present exposure to these contaminants. I he
engineering controls consist of permanent slab asphalt caps. FPA's Corrective Action Objective
for these two Areas is to prevent exposure to hazardous constituents remaining in soils above
non-residential and residential standards.
c. Ballllckls Parcel- I here is no contaminant in Balllields soils in concentrations above its non-
residential standard, M\<\ s C orrecti\e Action Objective for Balllields soils is to prevent
exposure Hi hazardous constituents remaining in soils above residential standards.
2, Soil - Residential Parcel
I he soils at the Residential Parcel meet residential SI IS and I-.PA residential RSI.s,
Therefore, this Parcel meets standards for unrestricted use. Therefore, no HPA
Corrective Action Objective is needed for this Parcel.
3, (inmiuhv hut
P.PA expects linal remedies to return ""usable" groundwaters to their maximum
beneficial use. wherever practicable, within a timeframe that is reasonable given the
particular circumstances of the facility. I he maximum beneficial use of the impacted
overburden and shallow bedrock aquifers under the facility is use as drinking water,
Statement of Base.
BASF (Formerly Cognisi- \mbler
AuuuM 201^
Page
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Si'dion 4: ( 'otTecl 1m- Action Objectives (coritinnctl)
i herctore. I'i'A > lung- term ( orrecthc Ac!ion (ihjcctiv es tor faeilh) groundwater consists ol
on-going monitoring until MCI > tor RSI s where MCI S do not exist) and to prevent exposure to
contaminants remaining in groundwater above dunking water standards.
Set-(ion 5: Proposed kemedv
1. tie#eral
I he facility shall pi*o\ ide I I1 \ with a coordinate sune\ as well as a metes and hounds
survev, ol the facilitv ami Area Parcel boundaries, and the .survev limits where engineering
controls arc required h\ the Post-Remediation Care Plans for Building 14 and 23. Mapping the
extent of the land-use restrictions will allow lor presentation in a public!) accessible mapping
program such as Google Karth or (ioogle Maps
2. Soils - Site*\ ide Soils, Biiildin" 14 Area, Building 23 Area. and Ballfidds Parcel
Because some contaminants remain in Sitcwide Soils. Building 14 Area. Building 23
Area, and Mall fields Parcel soils at levels which exceed residential use. FPA's Proposed Remed\
requires compliance with, and maintenance ol. the following use restrictions and engineering
controls:
A. I hese areas shall be restricted to commercial recreational and'or industrial
purposes and shall not be used lor residential purposes, unless it is demonstrated to I PA
that such use will not pose a threat to human health or the environment or adversely
all eel or interlere with the selected remedy, and PPA provides prior written approval for
such use.
B. 1 he existing caps at Buildings 14 and 23 Areas shall be maintained, consistent
with their Post-Rcmcilialion Care Plans detailed in their respective Pinal Reports.
Inspection, maintenance, reporting, and recordkeeping is required, in compliance with
their Post-Remediation Care Plans detailed in their respective Pinal Reports.
3. Soils Residential Parcel
As the soils at the Residential Parcel meet residential SI IS. no remedial action is
necessary. I his Parcel meets standards for unrestricted use.
4. Crounds aUt
A. PPA s proposed rented} lor groundwater is to monitor and treat the groundwater
until MCI.s are met and require the compliance with, and maintenance ot, groundwatcr-
usc restrictions that restrict ground water-use to non-potable and non-agricultural uses at
the Paeilit} in order to prevent exposure to contaminants while levels remain abo\e
drinking water standards.
Statement of Basis
BASl (formerly Cognisi- \mbler \tmust 20Il>
Page fi
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Section 5: Proposed Rcnu'ih (continued)
I PA "s Proposed Rented) also a\|iiiie-» an update of the ( mnindnatcr Monitoring
I'fan {I'lan) lor I' I1 A npprov al. I he Plan must identil\ 1 uturc monitoring aetiv itics,
schedules, and additional treatment allei nativ es. as appropriate, I his (mumd water
Monitoring Plan nu> alsu include a proposal lor alternative cleanup levels which arc
protective of human health and the cm ironmcnt based on I ucililv-specific scenarios and
groundwater use. Il l PA determines that an\ such alternative cleanup levels arc
appropriate. I PA will solicit public comments on such cleanup lev els prior to amending
the I l)l< IX' and including them in the Una! teinedv (or the l acilitv,
1 able 1 summarizes Proposed Remedy elements which have been completed and those
which are incomplete.
Statement ol Basis
B \SI (I ormerlv I ot'imJ-Ambler
August 2(1 Pi
Page 10
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Section (>: IA nhiation of Proposed Remedy
I his section pro\ idc\ a description of the criteria I P X used to ev aluate the proposed
reined} consistent with I 1\\ guidance. I he criteria are applied in two phases. In the first phase.
I'I'A cvaltiates three decision threshold criteria as genera? goals. In the second phase, for those
remedies which mecl the threshold ciileria. I PA then evaluates seven balancing criteria.
Threshold
Criteria
i) I'retlccl human
lieal th and the
em ironmenl
2) Achieve media
cleanup objectives
t.
^) Remediating the
i Kouiee of Releases
Evaluation
I PA's proposed remcdv for the lacilitv protects human health
and the env ironment bv eliminating, reducing, or control ling
potential unacceptable risk through the implementation and
maintenance of use restrictions and engineering controls.
I hider KPA's proposed remcdv. there would he no risk
associated with the soil as long as the Faciiit) propertv use
remains non-residential. Soil sampling showed exeeedanccs of
industrial screening levels. l-.PA's proposed rented) requires
compliance with Post-Remediation Care Hans for those Areas.
Some contaminants remain in groundw ater above their
respective MCLs. I'hereibre. groundwater will continue to be
treated until MCi.s or alternative cleanup levels, as applicable,
are attained. Groundwater monitoring will continue to confirm
that the plume is shrinking. Therefore. 11'A is also proposing
lo restrict land use to non-residential and groundwater use to
non-potable purposes at the Facility,
HPA's proposed remcdv meets the media cleanup objectives.
]'he cleanup objective for soils is to contain the hazardous
constituents that remain in place and control exposure to those
wastes in an industrial land-use scenario. 1 he proposed
remedy meets this objective through the implementation and
maintenance of land-use restrictions and engineering controls.
"I he cleanup objective for groundwater is to prevent access to
potable uses of groundwater and to restore to maximum
beneficial use, 1 he groundwater at the facility does not meet
drinking water standards and its use is being restricted. Il is
being treated and monitored and until protective cleanup levels
arejnet throughout the plume. _
In all proposed remedies. I• PA seeks to eliminate or reduce
further releases of hazardous wastes and hazardous
constituents that mav pose a threat to human health and the
environment and the 1 aeilitv met this objective.
I Ik* source of contaminants has been removed from the soil at
the faciiit). therebv. eliminating, to the extent practicable,
further releases of hazardous constituents from on-site soils.
Statement of Basis
HAS! (formerlv Counls (-Ambler
Auutisi 20 ll)
-------
Section 6: Evaluation of Proposed Reim-th (continued)
Balancing Criteria Evaluation «
4) I ong-term I lie I-ad I in is, and is expected to remain. non-residential,
effectiveness 1 herefore. the proposed long-term effectiveness of the
remedv lor the f acilitv will he maintained hv the
implementation ol use restrictions and engineering controls.
5) Reduction ol toxicit), | I lie reduction of to\icit>. niobilitv and volume of hazardous
urobilin. or volume of 1 constituents will continue hv restricting kind-uses at the :
the I la/ardous | l aeilitv, Groundwater is being treated until contaminants
: ( onstituents achieve their respective MCl.s or alternative cleanup levels, ,
as applicable. _ S
lil'A's proposed remedv docs not involve any activities,
¦ such as construction or excavation that would pose short-
term risks to workers, residents, and the environment. EPA
anticipates that the land-use restrictions at Balllieltis and
Building 23 Area, and Ground water Monitoring Plan will be
fullv submitted and implemented shortly after the issuance
' of the Final Decision and Response to Comments, Land-use
and grounduater-use restrictions are currently in place at
, other parcels at the Facility. _
i I P X's proposed remcdv is readilv implementable. EPA
J proposes to implement the use restrictions through an
j enforceable mechanism such as an Environmental
i Covenant, permit or order. _
1 FPA's proposed remedy is cost effective. The costs
associated with this proposed remedy have already been
incurred_and the remaining costs are minimal.
I I' A will evaluate community acceptance of the proposed
i remedy during the public comment period, and it will be
described in the final Decision and Response to Comments,
i PADKP has reviewed anil concurred with the proposed
i remedy for the Facility. _____ 1
6) Short-term
effectiveness
7) Implementabiliiv
K) Cost
i>) ("ommunitv
Acceptance
10) State'Support
Agency Acceptance
Statement of Basis
Aunusi 2019
Page 12
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Section 7; I'iiiinicinl Assurance
l-PA has evaluated uhether financial assurance lor eoireetixe action is neecssar\ to
implement I'PA s proposed reined) at the l-aeilit). PIWs proposed reniedv does not require an\
lurihcr construction actions to remediate soil, groundwater or indoor air contamination at this
time, I'PA estimates t hat the cost of implementing the two < 21 Post-Remediation Care Plans and
the eonlituted groundwater monitoring uili he Slii.lKK) annually 1 heteloie. I PA is proposing
that no linancia! assurance he required at t!i»^ lime.
Once the post-remedial groundwater monitoring program is established and groundwater
data is generated. I PA will reevaluate the need lor iinancial assuranee il'ilie additional treatment
options are implemented.
Statement of Ba>is
H \SI t hnmerh C'ognis)-Ainhler August 2(119
Pane 13
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Section H\ Public Participation
In'.crested persons are im itcd to comment on 1 PA's proposed rcmeds. I he public
comment period will last thirt> 15lij calendar da\s front the dale that notice is published tit a
local newspaper Comments ma) he submitted in mail. fax. or electronic mail to I inda
Mats skiela at the contact inlbrntation listed below,
A public meetiny will be held upon request. Requests tor a public meet inn should be
submitted to Undo Matyskiela in writing at the contact information listed below. A meeting will
not he scheduled unless one is requested.
1 he Administrative Record contains all the information considered bv hPA for the
proposed remed) at this hicilit). Hie Administrative Record is a\ailable at the following
location:
I'.S. HPA Region III
I ft50 Arch Street
Philadelphia. PA 19105
Contact; Linda Mat \ .skiela (31J)2D)
Phone: (215)814-342(1
Pax:(215)814-3113
1'inaili Matvskiela.l inda a epa.go\
Attachments:
Attachment A: Index to Administrative Record
l igute I: Pigtire of l'aeilit)
fable I
/
/
1>ate:
/
s ^ /
S/i
Statement of lijsis
BASf (fornictiv Counisl-Ambler
\nsiiisi 2019
Pane 14
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Attachment A: Index lo Administrath e Record
Ftnironmental Indicator Inspection Rcpor! l or ('ognis Corporation (lortnerl) Ameheni Products
ami llenkel ("orporation|, 300 Brookside Avenue Ambler PA 1l)t)02. August 2nu4,
(>rder on Consent. Docket No. Iil~N6-l6-I)C, Amehem Products. Inc. and I nion Carbide
Agricultural Products Companv. Inc.. August I1). llW6
Groundwater
2014 Groundwater Remediation Progress Monitoring Report; BASI- Corporation. Ambler.
Penns) K unia Property. April 2lF 2015
2015 (iroimdwater Remediation Progress Monitoring Report: BANI Corporation Ambler,
Pennsv Kania Property, February 16. 2016
201 (i (iroundwater Reniediation Progress Monitoring Report: BASF Corporation Amblei.
Pennsy Kania Pro pert), February 16. 2017
I nconsoliduled t 'nits (irotindwater Monitoring Results & Assessment; BASI Corporation
Ambler. Pennsy K ania Facility, February 16. 2016
[ ^consolidated I "nits (iroundwater Monitoring Results & Assessment: B ASI Corporation
Ambler. PennsyKania Facility. February 16. 2017
201? and 201K Analytical Results Summaries lor (iroundwater: BASI' Corporation Ambler.
Pennsy Kania Proper!). September 11. 20IK
Soil and (iroundwater Results Summary I ahles 2014
Down-Gradient (iroundwater Summary Project Memorandum. BASI- Corporation. Ambler,
Penns\ l\ ania March 01. 2013
Soils:
Pinal Report: Site investigation Results & Remedial Action Report for Soil. Cognis Corporation,
Ambler. Pennsylvania Facility, Submitted under PennsyKama's I and Recycling and
Finironmental Remediation Standards Act (Act 2). October 14. 2(108
PADI-P - Fetter of Substantive Deficiency of Site Investigation Results & Remedial Action
Report for Soil. Cognis Corporation. Ambler. Penns)Kania Facility. October 2008. June 17.
2<1(W
Statement of Basis
BASF (Former!) Cognis)- \mblei August 2ilin
I \me I ^
-------
Atktdnnenl A: huiex (o At!mitiisf l itti\ e Record (coiihnucd)
PAPl P- Statewide 1 leal I li Nonresidential and Site-Specific Standard 1 inal Report Approv al
Cognis Corporation H.\SI ( orporation. Juno IX, 2015
hn iromnental Covenant recorded Jn 1 \ 1 I. 2
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Figure 1: Figure of Facility
Siateinent of Basis
BASF {Formerly Cognis)-Ambler
August 2019
Page 17
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'] able
Pat eel
Remedial Repnrt
I'i iipiisoii
P V! H P A el 2
Remed\
( Hitii ill Rcmedv
Report
Instrument
\ ppj o\ :d
( loenant l)a(v
¦ Sitcw itlc
Final Ri '/>(((/ Site
| Noti-reskleiHral
i June 18. 2015
Jul} II. 2(111:
Soils
Investigation AVwills tV
land-use
superseded bv
Rt'iiiCt/ittl K n< hi Report
restriction.
July 2 1. 201 ci
for Si >il. ( >e(obcr 1-1.
_ 2008
j Building 14
ft/hi! Re/torl. Site
Building slab and
: June IS. 2015
Jul) 1 I. 21! 11;
| Area
Investigation Results il. C Ictober 14,
residential use
2(108
restriction.
!
Building^
> Final Report Site
Buikliiiii slab and
Januai) 2<>,
( meiiattl in
Area
l Investigation Results iV
Post-Remedial
2016
progress is It
|
RemeJhil. letion Report
Care Plan. Non-
BASF :,nd
1
¦ fur fkiihfiti2i . 11:('
residential use
I'ADI-'P
1
Si til, November 2015
restriction.
f Residential
Filial Report:
None
September 29.
None
^ Parcel
i
Site Investigation Results
21115
(V* Remetlial Action
Report
for Residential Parcel
Soil, JuK 2015
lialltkldsilS
Final Report
Non-residential
\la> (11 2t)0f>~
Covenant in
1 acres sold to
Rail Fiekl Area
land-use
progress w idi
1 oner
Investigation Results
restriction.
BASF, Lower
th\\ IK'dd
A- Deinonsirtiiioii of
{i \ nedd
1 ovvnship and
Attainment of
l'n« nship .hkI
the Borough
Statewisle Health
P U>1 P
of Ambler
S|)() "* J
StaikhtrJs. March 200(>
(in Hindu ater
\nnmil (i\\ remediation
Non-potable use
Non-use t i\\
Jul) 17.2011:
progress monitoring
restriction.
restriction in
superseded b\
repoifs
Continued
covenant
i -J
monitoring.
subsequent to
Sti hmil
2008 Sitcw ide
(irmimlM ;iter
Soils report
Munitiu iii" Plan
approval. Ci\V
Report has not
been submitted
for Act 2 at this
time.
^11 Proposed Remed\ elements ;ne completed except those in
BOLD.
Statement of Basis
B\M 11 ormerk ( ouuisi- \mblcr
August 2(11M
Page ! S
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