Superfund Record of Decision: Wade Site, PA · 1, report no. epa/rod/r02-8v009 4. title and subtitle superpund record of decision: wade site (asm) , pa 7. authorisi 9 report date

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SuperfundRecord of Decision:

Wade Site, PA

000466

INSTRUCTIONSi, REPORT NUMBER

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Relented for UK by cavil itpon recipient.4, TITLE ANP SUBTITLE

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I, nflrORMINQ ORGANIZATION CODEUtii blink,

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11. COflTRACT/QRANT NUMBERIBMI nmBKi M pint number under which upon w» prcpucd,

12, IWWORINaAOBNCY NAME AND AOOREKIneludtZtfcodt,

1J, TYPE OF RlfORT AND PERIOO COVEREDImilciie inlerim fuul, elf,, ind If ipplitible, dilci t,o*cred,

14, tPOttURINOAOkNCYCODEInsert ippropriale code.

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17. KEY WORDS AND DOCUMENT ANALYSIS(I) DESCRIPTORS • Select from Ihc Thcuurui of Lnjmmin» and Stmililn Itrnis ihv piupti juilmn/tU inim ilui iilcnlily the m\concept of the KKirch and ire luffiefenlly ipecilic «nd prcciw lo be uwd t\ mdvx cntnci lur i(b) IDENTiriERS AND OPHN^ENDED TERMS • UK IdinnOen for proieul ninns tudc nimtt, vquipmvnt dvMcnitors rlv. Uw linen,ended tctmi written In dcicrlpior form for thoK Hibfccii for which no dcwnpiw CMIII.(c) COSATI I ICLD GROUP • Held ind fioup iul|nmcnli ire lo be Mm dam Ihc I ¥65 «>SA1 1 Suli|vvl CaU'pny I,IM, lilniv Ihc mi.>orliy of document! ire mullldlKlpllniry in niturc, Ihc Primary I (tld/Gioup imiinmuiuiM » ill bv tnnilu .JN iplinc, am nl liuiwnMduvor, or type of phyiiol object, The ippliciuonli) will be croMieicrvnnd wuh wi'umljry I ii'liir(iiiMi|> Mpninvul* that will InllimIht pclnwy poitinilil.

IB. DIITRIEUTION STATEMENTDenote rehiubilllv to Ihc public or linniiiion for rciwnt other Ihin wtuniy for tmmplc "KdvjM' li'iiliiuiiul," <'ilv tm auiljluliiy inIhc public.Vnh iddrcii and pncc,

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22. PRICEInurl Ihc puce KI by the Nitloni! rcchnicil Informxion SvrvKi1 ur Hit Coiurnmcm I'tinimt Olfkv, il known

• . 000467EPA F«m J2JO-I (Ri>, 4.771 (Ri..rit)

1, REPORT NO.EPA/ROD/R02-8V009

4. TITLE AND SUBTITLESUPERPUND RECORD OF DECISION:Wade Site (ASM) , PA

7. AUTHORISI

9 REPORT DATE ' "~OB/30/8.1

0. PERFORMING OROANIZATIONCODE

IS PERFORMING ORGANIZATION REPORT It

>. PERFORMING ORGANIZATION NAME AND ADDRESS

1J. SPONSORING AGENCY NAME AND ADDRESSU.S. Environmental Protection Agency401 M Street, S.W.Washington, D.C. 20460

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13. TYPE OF REPORT AND PERIOD CO VEREFinal ROD Reoort

14 SPONSORING AGENCY CODE

800/00

10, SUPPLEMENTARY NOTES

TECHNICAL REPORT DATAIfltut nail Imintliem on tht mint it/on compliling:

i«, ABSTRACTThe Wade site i? a three acre parcel of land on the banks of the Delaware

°,iver. It is located nine miles .->uth of Philadelphia in Chester, Pennsylvania. Promapproximately 1950 until the early 1970's the site was the location of a rubber re-cycling facility which shredded tires and other post-consumer rubber products. Duringthe early 1970's the site was converted to an illegal industrial waste storage anddisposal facility. Drums of waste were emptied either directly onto the ground or 4-"trenches, severely contaminating soil and the ground water, Approximately 150,000gallons of waste cherricals remain on-site,

The recommended alternative selected for this site consists of: removal,decontamination and disposal of on-site tires and tankers, removal of on-site wastepilesi demolishing buildings, leveling the site, and filling and grading the propertyup to 12 inches over the existing grade to cover any protruding subsurface structureswhich have not been removed) removal down to the depth at which the first acceptablycontaminated sample was found (based on a contamination cutoff level recommended by thiRI/FS contractor); and covering the site with top-soil and seeding the cap tominimize erosion.

Key Words; Compliance with Environmental Laws, Negotiations, Capping,Excavation, Ground Water, Cost Recovery, Potential ResponsibleParties

17, KEY WORDS AND DOCUMENT ANALYSIS1. DESCRIPTORSRecord of Decision:Wade Site (ABM) , PAContaminated media: gw, soil, airKey contaminants: over 100 organics, metal

,nd inorganics

II. DISTRIBUTION STATEMENT

b.lOENTIPIERS/OPEN ENDED TERMS

None90. SECURITY CLASS iTHll flfllHone

c, COSATI Field/Group

3021, PRICE

I PA P«M 1220-I (Hi*, 4-771 rnivioui C.OITION it onomt

0004.68

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20«0

J'.'L 30 1934

SUBJECT: Snisrsement Decision Memorandra for Approval ofRemedial Action at the Wade s.ite,,/ Chester, Pennsylvania

FROM: Russel H. Wyer,Hazardous Site Control Di^siofc (WH-548E)

TO: Gene A. Lucero, DirectorOffice of Waste Programs Enforcement (WH-527)

The Enforcement Decision Memorandum and the Focused Feasibility

Study for the Wade Site has been reviewed by my staff. :

*I Concur

I Do Not Concur

I Concur with Comment

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ENFORCEMENT DECISION DOCUMENTREMEDIAL ALTERNATIVE SELECTION

^ Site: WadeChester, Pennsylvania

Documeats Reviewed

I am basing my decision on the following documentsdescribing the analysis of the cost and effectiveness ofremedial alternatives for the Wade Site:

! - Focused Feasibility Study, Wade site, Chester,Pennsylvania, Metoalf & Eddy, Inc., April 1964.

- Draft Report, Result of Soil Analysis and CostEstimates for selected Remedial Activities regarding(•he Wade Hazardous Waste Site in Chester, PA,Roy F. Weston, November 1983.

- Summary of Remedial Alternatives Selection

- Public Comments and Recommendations

- Responsiveness Summary

Description of Selected Remedy- remove and dispose of tires and tankers- remove on-site waste piles

- demolish buildings- test contentsi remove contents, and close two undergroundstorage tanks

The building on this site will be demolished and theremaining slabs will be left on site for future use, Alldemolition rubble will remain on the property and used forfill material.- level debris, fill and grade property

- remove and dispose of contaminated soil

The purpose of this activity is to remove from the propertyany contaminated material and any material that will,hindersubsequent efforts to fill and grade the site.- cover with topsoil and seed cap

ii - operation and maintenance of site

o 000470

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Peclarations

Consistent with the Comprehensive Environmental ResponseCompensation and Liability Act of 1980 (CERCLA) and theNational Contingency Plan (40 CFR part 300), I have deter-mined the removal, decontamination and disposal of tankers,tires and debris; destruction of buildings, leveling, fillingand grading the site; and covering with a seeded topsoil capat the Wade site is the least costly alternative, of all theremedial options reviewed that provides for current and futureprotection of public health, welfare and the environment.The State of Pennsylvania has been consulted and agrees withthe approved remedy. In addition, the action will requirefuture operation and maintenance activities to ensure thecontinued effectiveness of the remedy. Settlements havebeen reached between EPA and the responsible parties basedon the selected remedy.

I have also determined that the action being taken whichincludes the off-site transport of contaminated materials to aRCRA approved lined facility is the least costly alternativewhen compared to the other remedial options reviewed, and isnecessary to protect public health, welfare, or the environment.

rDater M. ThomasAssistant AdministratorOffice of Solid Waste and

Emergency Response

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•S _£*_ \ Ul ITET STATES ENVIRONMENTAL, PROTECTION AGENCYWASHINGTON, D.C. 20460

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SOilDWAS't I'.: SMSRdlNC' RESPONSEAU63 I9W

MEMORANDUM

SUBJECT: Enforcement Decision Document Approval for theRemedial Action at the Wade Site, Chester, Pennsylvania

Ow^ n<FROM: Gene A. Lucero, DirectorOffice of Haste Programs Enforcement

TO: Lee M. ThomasAssistant Administrator

This Office has reviewed the Enforcement Decision Document

and the Focused Feasibility Study for the Wade Site. I recommend

that you approve the recommended alternative which will providefor future protection of public health, welfare, and theenvironment.

000472

4\ ' 'I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

'/ WASHINGTON, D.C, 20460

AUG 11984

MEMORANDUM

SUBJECT: Enforcement Decision Memorandum for Approval ofRe-medial Action at the Wade Site, Chester, Pennsylvania

FROM! Frederick F.Acting Associate Enforcement

for Waste (LE-134S)

TO: Gene A. Lucero, DirectorOffice of Waste Programs Enforcement (WH-527)

The Enforcement Decision Memorandum and the FocusedFeasibility Study for the Wade site has been reviewed by aystaff.

I Concur ___I Do Not Concur

I Concur with Comment

000473

..-v Summary of Remedial Alternative selectionWade Site

Chester, Pennsylvania

Site Location, Description and History

The wade site is a three acre parcel located on thebanks of the Delaware Siver, just nine miles south of theCity of Philadelphia, ir, Chester, Pennsylvania. The site islocated in the industrial portion of Chester and is twoblocks from the residential portion of the City. The siteis bounded by the Commodore Barry Bridge, the DelawareRiver, a railroad right-of-way, and property owned by thePhiladelphia Electric Company. From approximately 1950until the early 1970's, the site was the locationof the Eastern Rubber Recycling Company, a firm whichshredded tires and other post-consumer rubber products.This use was abandoned during the 1970's and the site wasconverted to an illegal industrial waste storage and disposalfacility. Drums of wastes were emptied either directly ontothe ground or into trenches, thus severely contaminating soilat several locations, as well as jeopardizing the ground waterbeneath the site. In February 1978, a fire broke out whichwas so severe that the Commodore Barry Bridge was closed for6 hours and 45 firemen required examination at the localhospital. As a result of the fire, one of the site buildings•.,'23 completely destroyed and two others were seriously damaged.Large piles of debris containing exploded drums, buildingmaterials, tires, and shredded rubber (from the rubber re-irycling operations), and chemically-contaminated earth litteredthe property. Approximately 150,000 gallons of waste chemicalsremained after the fire; most of the material was containedin 2,500 55-gallon drums located inside the fire damagedbuildings, although a large portion was stored in 5 bulktankers in the front lot.

In 1980 and 1981, contractors were engaged by thePennsylvania Department of Environmental Resources (DER) andthe U.S. EPA to remove and dispose of the drums (and theircontents) contained in the buildings, to remove and disposeof the contents of the tankers, and to perform an investigationof the site's soil, ground water, and air quality. HESTONpersonnel served as the DER Site Representative for theday-to-day monitoring of Contractor activities.

000474

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Subsequent to the above on-site activities, CECOS wasengaged by the DER in the summer of 1983 to investigate andcharacterize the remaining hazardous and non-hazardous elementsof the site, such as debris piles and contaminated soil.

The following activities composed the scope-of-work for CECOS:

1. "pick through" the debris and rubble to isolateall drums;

2. analyze the contents of drums containing chemicals;

3. repackage leaking drums in secure containers;

4. stage drums containing chemicals in accordance withtheir contents;

5. crush all empty drums;

6. analyze soil and uebris for contamination;

7. determine locations and quantities of contaminated- •••soil and debris; and . . 0

B. determine quantities and compositions, of drummedchemicals. ' "In addition to the above, CECOS staged the debris into

separate piles (for tiros and shredded rubber, wood, scrapmetal, and potentially contaminated soil) and transportedand disposed of all drums containing chemicals found duringthe site characterization.

Since the number of drums containing chemicals was notknown until the characterization was complete, removal anddisposal of such drums were not included in the scope-of-work,as described in the DER's request for proposals for this sitecharacterization. It turned out that there were 750 drumscontaining chemicals. It was decided from a cost and safetystandpoint that these drums should be removed and disposedunder this contract rather than placing them in secure storageon the site for disposal under a later contract. TheContractor, therefore, was directed, under an explicitcontract option for "out-of-lump sum" work, to perform thedisposal activities. Empty drums were not disposed of.

000475

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CECOS was on the site from August 1 to September 10,1983. 'During that time approximately 5,000 cubic yards :of debris were picked through and staged in separate piles,approximately 750 drums containing chemicals were characterized; ;wastes were repackaged in secure containers when necessary; :scnbineci in compatible groups when possible; 630 drums weredisposed; and 320 soil samples were obtained and analyzed.

The DER monitored work acceptability and efficiencythrough persons formally named (in the CECOS Contract) asCleanup Director and site Representative. The CleanupDirector had ultimate responsibility for the site and formonitoring the Contractor's performance. The site Representa-tive was an employee of WESTON who was on-site full-timeand represented the Cleanup Director in his absence and wasauthorized to make specific decisions on behalf of the DER.All cleanup actions taken to date at the site by the DERwere done with the concurrence of EPA. The Agency was intimatelyinvolved, both technically and legally, in the developmentand implementation phases of the cleanup. All proposedactions were reviewed to assure that they complied with pFederal environmental regulations which existed at the time. ^

A separate report has been prepared by WESTON titled, • I"Cost Estimates for Selected Remedial Activities in Responseto Hazardous Conditions present at the Wade Property inChester, Pennsylvania." The analytical results of the soilsampling program performed by CECOS are presented in thatreport since they provide the basis for the cost estimates ofremoving contaminated soil.

A focused feasibility study (FFS) and Endangermerit 'Assessment for the Wade site were tasked to Metcalf & Eddy,Inc., by EPA in February 1984. The FFS considers the endanger-ment and recommariijs the most cost-effective remedial alternative.

000476

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Current Site Status

A' plan •. •' the site is presented in Figure 1. Thegrid raar'i.v : ihown on the figure were used for locatingthe soil sampling points. As can be seen from the figure,the sice contains seven structures, four rubber storagetanks, seven tankers, a pump pit, and eleven piles of debris.

The structures vary in structural integrity frommoderate to poor, all having been damaged by the fire in1978. Although not indicated by the figure, the concretepad underlying grids 22 and 23 was the floor of a two-storystone and brick building whlcii was completely demolishedin the fire. There is heavy machinery bolted to this padand also in place in the building encompassed by grids24, 25, and 26. In general, the buildings on the sitepose a physical hazard, due to lack of structural integrity,to persons entering them or walking near them.

The tankers are empty with the possible exception ofrainwater. Five of the seven tankers were used to containsolid and semisolid chemicals which were removed anddisposed during the DER's cleanup operation in 1980.Like the buildings on the site, the structural integrityof the tankers ranges from moderate to poor and it isassumed that none of them is able to be towed over theroad supported by its own undercarriage.

The pump pit is a concrete rectangular structuregreater than 15 feet deep and currently back filled withsoil, it is not believed that the pit is connected to theriver though it historically contained a pump used to obtainprocess water for the rubber company's operations.

The piles of debris located at several parts of thesite were formed as a result of the site characterizationand contain separate categories of waste, such as: tiresand shredded rubber, potentially contaminated soil, scrapmetal, scrap wood, and crushed empty drums. All of theseseparate materials were formerly found mixed together inscattered piles across the site prior to the site character-ization.

The site itself is level a1d essentially barren ofvegetation due to excavation and grading performed duringthe site characterization. Vegetation was present, however,prior to those activities and it is expected to return.

000477

000473

fir-... -vL.,..:.'!tci

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Over one hundred different organic and inorganiccompounds and metals have been identified on the Wadeproperty during the course of investigations at the site.While the majority have been identified in surface soilsmany have been detected in both air and ground watersamples taken from the site,

Sampling by R.F. Weston indicated that contaminationof soils on the site is widespread. Weston divided thesits into approximately 60 grids and sampled for totalvolatile organic compounds (VOC) and total baseneutraland acid extractable (BNA) fractions of priority pollutantsat four points within each grid. Their results showedcontamination by VOC, BNAs, or both of the top 12 inchesof soil in nearly every grid. In general, BNA fractionwas present in higher concentration than the VOC fraction.

Despite the numerous investigations that have takenplace on the site, the data do not easily permit generali-zation of the areal extent of contamination by any onecompound.

Many of the compounds found on site have beenassociated with a variety of health effects in humans,laboratory animals, or both, when inhaled or ingested insufficient quantities. At least six organic compounds orclasses of compounds are suspect human carcinogens;benzene, chlorinated benzenes, chloroform, tetrachloroe-thylene, trichloroethylene, and b,is(ethylhexyl phthalate).Certain metals found at the site - hexvalent chromium andarsenic - are also suspect human carcinogens. Lead is alsopresent in the soils and ground water.

The principal conclusions to be drawn from the siteinvestigation and endangerment assessment are:

1. Based on the monitoring results, concentrations ofvolatile organic compounds on the Wade site do notpresent acute exposure hazards to persons on or offsite, Although low by acute standards, concentra-tions of benzene found did present slighty elevatedlifetime risks of cancer to persons directly on site,

000479

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2. Inhalation/ingestion of contaminated soil inpotentially the most serious route of exposure forpersons entering or playing on the site, under theassumptions used in the FS, lifetime risks of cancer!!0"4) from inhaling/ingesting small amounts ofcontaminated soil on the site were higher than risks:':.?,11 other routes of exposure. Sampling resultsindicate that the concentrations of benzene found onthe site are associated with risks of cancer thatare 5-10 times higher than those considered asnegligible. This finding applies only to personswith chronic exposures to soil on the site (i.e.,children playing on the site over long periods oftime). No evidence of potential acute health effectswere found, a finding consistent with results of astudy by the Center for Disease Control.

3. Persons entering the site may be exposed to toxicchemicals both in the air and in contaminated soiland are therefore the most susceptible population atrisk from contaminants on the Wade site.

4. Underground tanks and tunnels, structurally damagedbuildings, and piles of flammable debris presentimmediate safety hazards to persons entering orplaying on the site.

5. Drinking water and fish are not likely to besignificant routes of exposure to chemicals fromthe Wade site. Ground water beneath the site isnot used as a source of drinking water andconcentrations of chemicals in the Delawareresulting from contaminated ground water dischargeto the Delaware are estimated to be negligible.

6. Contamination on the Wade site is not expected tohave a serious impact on the environment eitherthrough volatilization of chemicals to the air orrelease of contaminants via ground water to theDelaware River. Doth releases have been estimatedto be extremely low.

000430

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Enforcement

Ip December of 1978, EPA asked the Regions to listcandidates for RCRA S7003 actions. The PennsylvaniaDER, which had unsuccessfully ordered Wade and ASM toclean up the site in 1977, recommended the Wade site.Waste leaking, spilled, or otherwise disposed fromdrums, tanks or other containers deemed to provide animminent and substantial endangerment to health and theenvironment by the EPA. On April 20, 1979, the EPAcommenced, a civil action against Wade and ASM.The Court ordered them to clean up the site.The complaint was amended in March of 1980 to joinEllis Barnhouse and Frank Tyson, former presidents ofABM. When it became apparent that the currentdefendants were insolvent, a year long investigation ofABN's generator customers took place, After 32generators settled for 1.6 million dollars, EPA sued theremaining 6 generators in the original clean-up action inDecember of 1981. In September of 1982 the Courtdismissed the injunctive relief claims against thegenerators and EPA then commenced a CERCLA S107 costrecovery action which is the current basis for the actionagainst the generators. In May of 1984, the remaininggenerators agreed to settle with EPA and the State.Settlement agreements are being negotiated.

000431

fr~

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Initial Remedial Alternative Screening

Se'veral alternatives were evaluated by Mitre, NEK,Weston, EPA and DER. Based on an initial screening, thefollowing alternatives were rejected:

1. Volatilization of volatile contaminants byexcavating the soil and spreading it in thinlayers and turning periodically to expose it tothe atmosphere or placing the soil in windrows.This technique was rejected on the basis of lowefficiency due to the small size of the site, nooff-site location available, no removal of BN/Acontaminants, the requirement of ait monitoring,unpredictable weather conditions, and thepossible requirement of mechanical aeration.

2, Land farming and composting, for aerobicdegradation of organic contaminants. Thisalternative was rejected because of the possiblerequirement for commercially-developed mutant

,•'" factor ia, the low concentrations of organic'i Material present in the soil, required treatability""studies and pilot testing, specialized equipment,long processing times, continuous monitoring andbecause the technique had not been proven fordecontamination of soil.

3. Creation of a secure cell on-site, by means of animpermeable cover, continuous monitoring of groundwater and possibly impermeable side walls or linerto prevent migration of contaminants away from theproperty boundaries. This alternative was rejectedbecause the contaminated soil would remain in anurban area, the cell would have to be perpetuallymonitoried, the hydrological properties of the siteare not suitable for a secure cell, the propertywould have to be restricted from other use and Stateand Federal permits may be required.

4. Total removal and off-site disposal of soil at alicensed, secured landfill and backfilling the sitewith imported soil. This alternative was rejectedbecause site investigation shows the soil contaminationis localized in discrete areas and because of the highcost of this solution.

000482

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Reroedial Alternative Screening

In order to perform a detailed evaluation, it wasnecessary to develop a list of remedial alternatives whichwould include a No Action Remedial Alternative. MeteaIf &Eddy developed 12 alternatives for the Wade site, based onWeston's six soil removal options. (See Table 2 for soilremoval options.)

Alternatives:

1. No Action2. Remove, decon & dispose of tires & tankers, remove

on-site waste piles; demolish buildings, level site,fill and grade property.

3. Remove, deron s dispose of ti'.-os & tankers, removeon-site waste pile; demolish buildings, level site,

, fill and grade property, cover with asphalt cap,4. Remove, decon 6 dispose of tires & tankers, remove

on-site waste piles; demolish buildings, level site,fill and grade property, cover with topsoil andseeded cap.

5. Remove, decon t dispose of tires t tankers, removeon-site waste piles; demolish buildings, level site,fill and grade property *oll removal option 1A,cover with asphalt cap.

6. Remove, decon t dispose of tires t tankers, removeon-site waste piles; demolish buildings, level site,fill and grade property, soil removal option 1A,cover with topsoil and seeded cap,

7. Remove, decon & dispose of tires i tankers,remove on-site waste piles; demolish buildings,level site, fill and grade property, soilremoval option 1C, cover with asphalt cap.

8. Remove, decon t dispose of tires t tankers,remove on-site waste piles; demolish buildings,level site, fill and grade property, soilremoval option 1C, cover with topsoil and seededcap.

9. Remove, decon t dispose of tires i tankers,remove on-site waste piles; demolish buildings,level site, fill and grade property, soilremoval option 2A, cover with asphalt cap.

10. Remove, decon & dispose of tires fc tankers,remove on-site waste piles; demolish buildings,level site, fill and grade property, soilremoval option 2A, cover with topaoil and seededcap.

000483

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11. Remove, decon & dispose of tires & tankers,remove on-site waste piles; demolish buildings,level site, fill and grade property, soil

' removal option 2C, cover with asphalt cap.12, Remove, decon & dispose of tires s tankers,

remove on-site waste piles; demolish buildings,level site, fill and grade property, soilremoval option 2C, cover with topsoil and seededcap.

Screening Considerations:

A. Ground water

The hydrological evaluation determined thatthe Delaware River is the outflow point for groundwater from the Wade site. The results of the evaluationindicate that, based on all organic contaminants detectedin ground water at the site, continued input of contami-nated ground water to the Delaware River under the no-actionalternative would not have a measurable adverse impact onwater quality or biota, if contaminated soil was removed fromthe aite. The concentrations of individual organics aftermixing of ground water with both the estimated full flowand half J&ojtof ,the Delaware River are all well below allapplicable Ambient Water Quality Criteria and U.S. EPAHealth Advisories for ingestion of toxic and carcinogeniccompounds in water (Table 1), Therefore, due to the negli-gible impact of ground water on the off-site environment andpublic health, groundwater interception and withdrawalremedial actions were eliminated from further consideration.

B. Soil Excavation/Removal Remedial AlternativesSix remedial alternative soil excavation/removal

options (1A, IB, 1C, 2A, 2B and 2C) were developed byRoy F. Weston based on either of two threshold levels oforganic contaminants for defining whether the soil iscontaminated (see Table 2.) one threshold level on whichthree of the alternatives (1A, IB, 1C,) were based was 100mg/kg for both the volatile and base neutral/acid (BN/A)fractions. The second, on which the remaining three (2A,2B,2C) alternatives were based, was 100 mg/kg for the volatilefraction and 500 mg/kg for the BN/A fraction. Metcalf sEddy reviewed the confirmed contaminated toil excavationquantities and potentially contaminated soil quantities forOptions 1A, 1C, 2A and 2C, determined by R.F. Weston. Aconservative approach was taken due to possible synergisticeffects.

000484

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r"»\ ,••:• .•i:v;l"l'.V«-'i.1.1l.f.SJ'-1./"l-Ji;.->, •:::.:;||;;;|:p. j f .ia i ^ i *' ^ ^ ^

"•\_

000486

J, ;.» /;

W™X*F:.

IS!

S I

,. . ,. , . , .. . ,.• a • ae a a a eo a a «o ca 11 • a a •BOOB a a •

. . . . .o' a a' a a a a a .' .' a o a o a o1 a' o' a e .' •' o1 a' .' a' .' o' o' a o' o o' a a o

000487

-16-

There »:•* r'jrrer-' .--.shards for exposure to totalvolatile org?.".i<: (VCC1 • "3se nsutral/acid extractable (3NA)fractions ;r. .-•;... ; icnicity of the contaminated soil

'r ;• :n i:: .-..Ividual comoounds -Mrassr.t ani Lr.i.iy

;i..'.:cunds md'; =.:•:.t t'.r::cal avid*-:* su?;VOCs or BNAs versus 5

jvaergistic effects chat the. . >r. Since no compelling coxic1.'-• , threshold of 10C .-g/V.g c:' :.--.il••:/-;g or 150 mg/kg, it is unlike!;1

that any meaningful distinction can be made betweeninj to "clean" depth cr to one foot below the last contami-nated sample on the basis of public health impact,

In several grids, the concentration composites indicatedcontaminant levels greatly exceeding the set thresholdlevels, yet analysis of the quadrants' analytical dataindicates the opposite, in other grids, this relationshipwas reversed. These results suggest that the samplingmethod may not be an accurate indicator of the extent ofcontamination of the whole grid. While this lack of corre-lation is a general problem with all the soil removaloptions, it suggests that making distinctions between soilsthat are 20%, 21-100% or greater than .100% over the thresholdis not valid over .an entire quadrant, on the basis of thetoxicological issues and the sampling discrepancies, Netcalft Eddy concluded that soil removal options IB and 2B areunjustified and should be excluded,

C, Remove Debris

Removal and dispose'. <••': on-site, crushed fir.""? ?•"*contaminated soil pile'?! '-ore included in the Removal ofDebris remedial item. T1.* had been included under thecontaminated soil m; . . -.^vity, however/ i; is moreappropriate to consider . .... &s part of removing site debris,A 50 percent swell fac::-; i?,s used for estimating the volumeof crushed drums after Iv.-ing into trucks for subsequenthauling to a fir.al cispo^a. site. A 15 percent swell factorwas used for estimating ^.e loading volume of soil from above-ground soil piles or excavated from the site for subsequenthauling to a final disposal site.

D. Demolish Building

Several items wer; added to the Demolish Buildingsremedial activity. These included the following:

- Rough grading and site leveling up to 12 inchesover existing grade in order to cover any pro-truding subsurface structures which have not beenremoved ,

- On-site sump sampling and analysis and wasteremoval.

000488

r-17-

- Underground fuel oil tank/contents removal.

-'Underground waste chemical., soi vent tankcontents removal,

- Closure of underground t•-,-,,".•.;:, :'.:.. ,• .n or"building basements and •!*::'-.'.u •• j .-.;- z'.s'isr,pit. The tunnels and pit are potential reservoirsfor off-site contamination.

These items were added to the Demolish Buildingsremedial activity because it would be appropriate to under-take these items during the building demolition activity.Off-site, handling quantities of building demolition debriswere calculated for the following scenarios: remove alldebris from site for each soil excavation option underconsideration (1A, 1C, 2A, 2C). These quantities are usedin the subsequent cost analysis of remedial alternatives,

The site remains a safety hazard to persons entering orplaying on the site and in abandoned buildings. Despitelocked gates to the site, persons from the surroundingneighborhood are known to gain access to the site. ;

Initial remedial activities on the site have not removedall safety hazards from the site. Two partially full under-ground tanks, an underground 4-foot x 4-foot tunnel beneath themain building, and structurally damaged buildings presentserious physical hazards to persons gaining access to the site.The identity of compounds in the remaining underground tankshave not been established as of this writing but neverthelessthe tanks themselves are at least partly accessible from theground. Both the tanks and the tunnel may contain oxygendeficient or toxic atmospheres that increase the likelihoodof accidents. The major fire at the Wade site in 1978 damaged thestructural integrity of several buildings on-site, increasing thelikelihood of unexpected collapse. Finally, remaining piles ofdebris (wood and tires) are potential fire hazards.E. Site Capping

The results of the Endangerment Assessment for the NoAction remedial alternative, as previously discussed, in-dicited minimal risks as a result of on-site ground watercontamination. On this basis, ground water interception,withdrawal and treatment remedial alteratives were elimi-nated from further consideration and detailed evaluation.The site capping options range from relatively impermeableclay capping to asphalt capping to relatively permeabletopsoil/seeding capping. Clay capping is the most effectiveof these capping options at preventing infiltration ofprecipitation into the unsaturated soil zone (contaminatedsoil) and subsequent movement into the ground water,

-18-

Precipitation has and does infiltrate the unsaturatedzone on-site and recharges the ground water, but its effecton ground water does not pose significant risks as previouslydiscussed, Therefore, it is not necessary to preventinfiltration by installing a relatively impermeable cl.v/ :--or asphalt cap on the site,

000480

RemsdialAlterna-tiveNo.

1.2.

'3-4.5.6.7.8.

9.10.11.12.

TABLE 3

SiteDebrisRemoval($)

o ;529,029

529,029

529,029

529,029

529,029

529,029

529,029

529,029

529,029

529,029

529,029

REMEDIAL

DemolishBldga(*)

0

268,745

253, 7«5268,745252,750

252,750

243,156

243,156

260,871,

260,871

256,439

256,439

ALTERNATIVE

SiteCapping($)

00

331,93075,620

331,930

75,620

331,93075,620

331-.930' 75, £20 .

'33T,m75, 20

COST ANALYSIS

SoilExcava-tion(*)

00

•:0

1,191,250

1,191,250

1,979,7551,979,755-714,530

714,530r,012,512

1,012,512

TotalImplemen-tationCost

0797,774

'',129,704

873,394

2,304,959

2,048,6493,083,8702,827,560

1/"v'5,360

1,580,050

2,129,9101,873,600

000491

r}''WW&V'i! It • .. ...• .-. '".' .. .•!••; .L

-19-

Cost Analysis

Table 3 presents the site implementation costs forall the 12 remedial alternatives based on Metcalf & Eddy'scost estimates for Site Debris Removal, Building Demolition,Site Capping and Contaminated soil removal.

Post Closure, Long Term Monitoring plan

Once remedial activities have been completed on theWade site, it is required that the site be further monitoredfor a period of 30 years to determine the effectiveness ofthe raiiiedial activities.

The plan includes the following tasks:

1. Site Inspection:

The site inspection will include a visualinspection of surface conditions and the monitoringwells.

2. Installation of Upgradient Monitoring Wells:Two upgradient monitoring well clusters will

be installed in off-site locations in order tomonitor the water quality of the ground waterbefore it flows under this site.

3. Water Sampling:The purpose of this sampling is to determine

ground water quality before ground water enters thesite and ground water quality as it leaves the site.

4. Laboratory Analysis:

Both water and soil samples will be analyzed forpriority pollutants, cyanide and TOX based uponcontaminants identified in previous site sampling.After five years of sample collections, the samplingprotccol will be re-evaluated to determine if certainpollutants can be targeted such that there can be areduction in the cost of laboratory analysis withoutany reduction in monitoring effectiveness.

000492

-21-

5. Replacement of Monitoring Wells: i

The present three downgradient well clusters :were originally constructed with galvanized pipe and 'it is anticipated that the wells will need to bereplaced in 10 years, The two upgradient wells willbe constructed with stainless steel pipe and it isanticipated that the wells will need to be replacedin 15 years. Monitoring well deterioration mayresult from corrosion of the pipe or screen,accumuJcision of silt in the well, or plugging of thescreens.6. Well Maintenance and Rehabilitation:

A program of well maintenance and rehabilitationwill be implemented every five years to insure thatthe monitoring wells will provide representativesamples and that the surface integrity of the wellhas not been compromised.7. Topsoil Maintenance:

A program of topsoil maintenance will be implementedevery two years to insure that the topsoil cap completelycovers the site. Periodically it may be necessary to fillin erosion channels, to add topsoil to areas where thevegetation has become sparse.8. Mowing of Grass:

Once the topsoil cap has been constructed and it hasbeen seeded and sodded it will be necessary to mow thenew grass during the growing season. The task would beperformed on a yearly basis probably during the summermonths and win become a integral part of the sitemaintenance.

Community RelationsPublic meetings were held in October 1982, July 1983,

and September 19)3 to discuss the remedial work performedby CECOS and the studies conducted by Roy F. Weston. varioustypes of media (e.g., newspaper ads, fact sheets, radio) wereutilized to notify the public of these meetings. Representa-tives of U.S. EPA, State, local governments and the communitywere all well represented. Copies of reports and data wereprovided, with a 20 day comment period. flflfMot)

A public meeting to discuss the Wade site feasibilitystudy was held at Chester City Hall on Wednesday, June 13, 1984.The meeting was conducted by the PA DER and EPA. Public officialsand citizens were very interested in the future use of the site aswell as the timeframe for completion of the cleanup. There were no

-22-

Recommended Alternative

Seption 300.68(j) of the National Contingency plan(NCP) [47 FR 31180, July 16, 1982] states that the appropriateextent of remedy shall be determined by the lead agency'sselection of the remedial alternative which the agencydetermines is cost-effective (i.e., the lowest costalternative that is technologically feasible and reliable) andwhich effectively mitigates and minimizes damage to andprovides adequate protection of public health, welfare, andthe environment. Based on our evaluation of the cost-effectiveness of each of the 12 proposed alternatives, thecomments received from the public, information from theEndangerment Assessment, and information from DER andWeston, we recommend that alternative 10 be implemented.This alternative includes: the removal, decontamination,and disposal of tankers, tires and debris; destruction ofbuildings; soil removal; leveling, filling, and gradingthe site, and covering with a seeded topsoil cap.

The recommended alternative is the least cost alternativethat is technically feasible and reliable, that meets therequirements of the NCP and provides for future protectionof public health, welfare, and the environment. It also complieswith RCRA by calling for offsite disposal of contaminated - - '^~aoil at a RCRA approved lined facility, and the level of cleanupwas determined in a manner consistent with the RCRA methodology.In comparison with the other alternatives, alternative 10 hasthe following:

1. Fewer monitoring requirements as a result ofthe topsoil cap;

2. Requires less time to implement of all the soilexcavation options (lowest quantity of contaminatedsoil requiring excavation);

3. Easiest to install of the soil options due to thesmaller soil excavation quantities;

4. Uses relatively proven technology, i.e., contaminantsource removal with proper disposal;

5. More durability with a topsoil cap than asphalt dueto a longer period of time that the level of effective-ness can be maintained;

6. More effective than the no action remedial alternativeand non source removal alternatives;

7. If no action was chosen, we would still have theproblem of a release occurring which would ultimatelyend in a ground water investiqation;

000494

-23-

B. The exposure rate of most concern for the WadeSite from the standpoint of public health is

• inhalation/ingestion of contaminated surfacesoils. Further removal of soil beneath the.5 foot level (Alternative 12) would have noimpact CM this route of exposure, and;

9. Removal of contaminated soil down to 5 feetallows for protection of human health andenvironment in the future.

The estimated costs for the recommended action are;

Remedial Action Estimated Cost

Site Debris Removal $ 529,029

Demolish Buildings $ 260,871

Site Capping $ 75,620

Soil Excavation $ 714,530

Total Implementation Cost • $1,580,050

Operation & Maintenance $ 320,000

Total * $1,900,050

Project Schedule

- Approve Record of Decision July 1984- Award Contract September 1984- Start Construction September 1984

w^00495"

Table 2

Soil Excavation/Removal Remedial Alternatives

1. Remove contaminated soils exceeding organic cir.taT.ir.anconcentration of either iOO mg/kg volatile orgar.ics or100 mg/kg base, neutral/acid organios.

A. Excavate to Last Contaminated Depth1B. Excavate to Intermediate Depth2C. Excavate to Uncontaminated Depth3

2. Remove soils exceeding an organic contaminant concentrationof either 100 mg/kg volatile organics or 500 mg/kg base,neutral/acid organics.

A. Excavate to Last Contaminated Depth1B. Excavate to Intermediate DepthZ

- 'C. Excavate to Uncontaminated Depth3

I/ Soil removed lie1-1-. :: ii-.:.>. at which last contaminated~~ soil was found.

2/ Soil removed down to depth at which last contaminated sample~ was foun': '". -.^resnold level exceeded by 20 percent or less;

one foot despsr than last contaminated depth if thresholdlevel exceeded by 21 to ICO percent; and down to depth a';which first uncontaminaced sample was found if thresholdlevel exceeded by greater than 100 percent.

3/ Soil removed down to depth at which first Uncontaminatedsample was found.