SDMS Document 100003 DECLARATION STATEMENT RECORD OF DECISION - OPERABLE UNIT TWO 8WOPE OIL AND CHEMICAL COMPANY SITE NAME AND LOCATION Svope Oil and Chemical Company Pennsauken Township, Camden County, New Jersey STATEMENT OF BASIS AND PURPOSE This decision document presents the selected remedial action for the Swope oil and Chemical Company site, which was chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, -—-- as amended by the Superfund Amendments and Reauthorization Act of 1986, and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan. This decision is based on the administrative record for the site. The attached index identifies the items that comprise the administrative record upon which the selection of the remedial action is based. The New Jersey Department of Environmental Protection and Energy concurs with the selected remedy. ASSESSMENT OF THE SITE Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in this Record of Decision, may present an imminent and substantial endangerment to public health, welfare, or the environment. DESCRIPTION OP THE SELECTED REMEDY The remedy described in this document represents the second operable unit for the Swope site. Cleanup actions under the first operable unit have resulted in the removal of buildings, tanks, sludge and contaminated surficial soils from the site. This remedy will address contaminated subsurface soils which are acting as a source of groundwater contamination. The treatment of these subsurface soils is expected to mitigate the site's contribution to groundwater contamination, thereby addressing the principal threat to public health remaining at the site. Subsequent to completion of the selected remedy, EPA will determine whether it provides for adequate protection of groundwater, as well as the need for further source control or groundwater remedial measures. 100064
Transcript
SDMS Document
100003
DECLARATION STATEMENT
RECORD OF DECISION - OPERABLE UNIT TWO
8WOPE OIL AND CHEMICAL COMPANY
SITE NAME AND LOCATION
Svope Oil and Chemical CompanyPennsauken Township, Camden County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action forthe Swope oil and Chemical Company site, which was chosen inaccordance with the requirements of the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980, -—--as amended by the Superfund Amendments and Reauthorization Act of1986, and, to the extent practicable, the National Oil andHazardous Substances Pollution Contingency Plan. This decisionis based on the administrative record for the site. The attachedindex identifies the items that comprise the administrativerecord upon which the selection of the remedial action is based.
The New Jersey Department of Environmental Protection and Energyconcurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response actionselected in this Record of Decision, may present an imminent andsubstantial endangerment to public health, welfare, or theenvironment.
DESCRIPTION OP THE SELECTED REMEDY
The remedy described in this document represents the secondoperable unit for the Swope site. Cleanup actions under thefirst operable unit have resulted in the removal of buildings,tanks, sludge and contaminated surficial soils from the site.This remedy will address contaminated subsurface soils which areacting as a source of groundwater contamination. The treatmentof these subsurface soils is expected to mitigate the site'scontribution to groundwater contamination, thereby addressing theprincipal threat to public health remaining at the site.Subsequent to completion of the selected remedy, EPA willdetermine whether it provides for adequate protection ofgroundwater, as well as the need for further source control orgroundwater remedial measures.
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rThe major components of the selected remedy include thefollowing:
- In-place treatment, utilizing soil vapor extraction withbiodegradation, of contaminated subsurface soils; and
- Implementation of a groundwater monitoring program, for aperiod of five years, to assess the effectiveness of the remedyand to evaluate whether groundwater remediation is warranted.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements thatare legally applicable or relevant and appropriate to the =remedial action, and is cost-effective. This remedy utilizespermanent solutions and alternative treatment or resourcerecovery technologies to the maximum extent practicable, andsatisfies the statutory preference for remedies that employtreatment that reduces toxicity, mobility, or volume as aprincipal element.
A review will be conducted within five years after commencementof the remedial action to ensure that the remedy continues toprovide adequate protection of human health and the environment.
SITE NAME AND LOCATION * 1SITE HISTORY AND ENFORCEMENT ACTIVITIES 1HIGHLIGHTS OF COMMUNITY PARTICIPATION 3SCOPE AND ROLE OF OPERABLE UNIT TWO WITHIN SITE STRATEGY.. 4SUMMARY OF SITE CHARACTERISTICS 5SUMMARY OF SITE RISKS 10SCREENING OF REMEDIAL TECHNOLOGIES 14SUMMARY OF REMEDIAL ALTERNATIVES / 17EVALUATION OF ALTERNATIVES 20SELECTED REMEDY 24STATUTORY DETERMINATIONS 26DOCUMENTATION OF SIGNIFICANT CHANGES 28
APPENDICES
APPENDIX A.APPENDIX B.APPENDIX C.APPENDIX D.APPENDIX E.
FIGURESTABLESADMINISTRATIVE RECORD INDEXNJDEPE LETTER OF CONCURRENCERESPONSIVENESS SUMMARY
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fLIST OF FIGURES
Number Name
1 Swope Oil and Chemical Company Site Location Map
2 Swope Oil and Chemical Company Site Map
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LIST OF TABLES
Number Name
1 Deep Soil Boring Results
2 Summary of Volatile Organic Compounds Detected inGroundwater
3 Summary of Semi-Volatile Organic CompoundsDetected in Groundwater
4 Summary of Inorganic Compounds Detected inGroundwater (Unfiltered Samples)
5 Occurrence of Constituents in the Shallow AquiferUpgradient of the Swope Oil and Chemical CompanySite, Pennsauken, New Jersey.
6 Occurrence of Constituents in the Shallow AquiferDowngrad'ient of the Swope Oil and Chemical CompanySite, Pennsauken, New Jersey.
7 Acceptable Doses (ADs), Cancer Slope Factors(CSFs), and USEPA Cancer Classification forConstituents of Concern at the Swope Oil andChemical Company Site, Pennsauken, New Jersey.
8 . Noncarcinogenic Risk Estimates (Hazard Indices)for the Swope Oil and Chemical Company Site
9 Carcinogenic Risk Estimates for the Swope Oil andChemical Company Site
10 Remedial Action Alternative 1 - No Action,Detailed 'Cost Analysis, Swope Oil and ChemicalCompany Site, Pennsauken, New Jersey.
11 Remedial Action Alternative 2 - Soil VaporExtraction with Aerobic Biodegradation, DetailedCost Analysis, Swope Oil and Chemical CompanySite, Pennsauken, New Jersey.
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DECISION SUMMARY
RECORD OF DECISION - OPERABLE UNIT TWO
8WOPE OIL AND CHEMICAL COMPANY
SITE NAME, LOCATION. AND DESCRIPTION
The Svope Oil and Chemical Company (Swope) site is located at8281 National Highway, in an industrialized area in the Townshipof Pennsauken, Camden County, New Jersey. Route 130 passesapproximately 1800 feet southeast of the site (Figure 1).
The Swope site, approximately two acres in size, is bounded tothe southeast by National Highway, and to the north and southwestby railroad rights-of-way and warehouses (Figure 2). Numerouscommercial and industrial properties are located within 0.5 mileof the site in all directions. The Pennsauken Municipal Landfillis located approximately 750 feet to the northwest. The nearestresidential areas are in the Townships of Delair and Morrisville,which are located about 0.5 mile west and 0.8 mile southwest ofthe site, respectively. Pennsauken High School is locatedapproximately 0.5 mile to the northeast.
The Swope site is underlain by the Potomac-Raritan-Magothy (PRM)Aquifer System, which is the major source of potable groundwaterin the area. Two water supply wells, operated by theMerchantville-Pennsauken Water Commission, MPWC Well 1 and MPWCWell 2, are located approximately 275 feet southwest and 1500feet northeast of the site, respectively. In addition, otherwater supply wells are located throughout Pennsauken Township.Only the lower aquifer of the PRM Aquifer System is used as asource of potable groundwater in the vicinity of the site.
The nearest body of surface water is the Pennsauken Creek, whichis located 0.8 mile northeast of the site. Pennsauken Creekflows in a northwesterly direction to the Delaware River, whichis located about 1.2 miles northwest of the site.
The Swope site is flat with no discernable surface features,except a security fence which restricts site access. Subsurfacefeatures, including underground storage tanks, septic tanks andseptic lines, were removed during prior remedial activities.
BITE HISTORY AND ENFORCEMENT ACTIVITIES
From 1965 to 1979, the Swope Oil and Chemical Company operated achemical reclamation facility at the site. Facility operationsincluded buying, selling, manufacturing, and processing oils,chemicals, and paints. Materials believed to have been processedat the site include phosphate esters, hydraulic fluids, paintsand varnishes, solvents, oils, plasticizers, and printing ink.During operation of the facility, waste liquids and sludges were
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discharged to an excavated, unlined lagoon. Contaminatedmaterial was also contained within a diked tank farm and anexposed drum storage area. When the facility ceased operating,significant site features included a main building, a distillinghouse, a diked tank farm, an open drum storage area, and anunlined lagoon.
In 1975, an inspector from the State Bureau of Air Pollutionvisited the site and recommended that the Bureau of WaterPollution Control inspect the site. In subsequent visits,officials observed discharges to drainage ditches on the site andprobable migration towards Pennsauken Creek via storm sewers.The Swope Oil and Chemical Company was cited in 1975 foroperating without proper permits, and again in 1979 for failureto prepare, maintain, or fully implement a Spill Prevention,Control and Counter-measures Plan. The company ceased operationin December 1979.
On October 17, 1983, a State Superfund Contract was signed by theUnited States Environmental Protection Agency (EPA) and the NewJersey Department of Environmental Protection (NJDEP) whichprovided funds for the performance of a Focused Feasibility Studyon the drums and lagoon waste. This study was completed inFebruary 1984.
On May 14, 1984, a group of potentially responsible parties(PRPs) entered into an Administrative Order on Consent with EPAto conduct the remedial activities recommended in the FocusedFeasibility Study. Pursuant to this order, drummed waste and3,000 tons of lagoon sludge were removed from the site. Inaddition, a fence was constructed around the site to restrictaccess and to prevent the public from coming into direct contactwith the contaminants.
In May 1984, MPWC Well 1 was shut down due to the detection ofcontamination in the well. Since area-wide groundwatercontamination occurs in the vicinity of MPWC Well 1, theMerchantville-Pennsauken Water Commission equipped the well withsin air stripper to remove volatile organic compounds fromgroundwater, and returned the well to service in January 1989.Approximately 10,000 residents use water from this well.
A Remedial Investigation and Feasibility Study (RI/FS) wereconducted by NUS Corporation for EPA from February 1984 to June1985 in order to determine the nature and extent of contaminationat the Swope site and to evaluate appropriate remedialeilternatives. Based upon the findings of this RI/FS, a Record ofDecision (ROD) was signed by EPA on September 27, 1985. This RODspecified a remedy for surficial contamination and provided forthe performance of a Supplemental RI/FS to address groundwatercontamination.
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In August 1986, EPA entered into an Administrative Order onConsent with a group of 15 PRPs for the performance of the remedyfor surficial contamination specified in the ROD. In September1986, 8 PRPs entered into a separate Administrative Order onConsent with EPA for the performance of the Supplemental RI/FSand for the design and installation of a cap at the site.
In September 1987, ERT, a contractor for the PRPs, implemented anextensive sampling and analysis program to characterize both on-site and off-site soil contamination to a depth of approximately18 inches, as well as tank contents. Data obtained during thissampling event were utilized to develop the engineeringspecifications for the surficial remediation program.
On September 17, 1988, ERT initiated the remedial action programto address surficial contamination at the site. Activitiesconducted as part of this program included the following:
- the removal and off-site disposal of tanks, with off-sitetreatment or incineration of tank contents,
- the demolition of on-site buildings,
- the excavation and off-site disposal of up to 1.5 feet ofcontaminated soil containing polychlorinated biphenyls(PCBs) at concentrations greater than 5 parts per million(ppm), and
- the excavation and off-site disposal of visibly contaminatedmaterial from the buried sludge area of the site.
The surficial remedial action program was completed by August1989. Subsequent to excavation, certified clean backfillmaterial was utilized to bring the site up to grade. Theinstallation of a cap, which was a remedial activity specified bythe 1985 ROD, was postponed to provide for the installation ofmonitoring wells and the performance of treatability studiesduring the Supplemental RI/FS. -^
The Supplemental RI/FS for the Swope site was initiated inOctober 1988 to evaluate the nature and extent of groundwater andsubsurface soil contamination at the site and to developappropriate remedial alternatives.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Supplemental RI/FS Report and Addenda, and the Proposed Planfor the Swope site were released to the public for comment onJuly 18, 1991. These documents were made available to the publicin two information repositories maintained at the PennsaukenMunicipal Building and the Pennsauken Township Library. Thenotice of availability of these documents was published in the
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Philadelphia Inquirer on July 18, 1991. As part of EPA's publicparticipation responsibilities under Section 117 of theComprehensive Environmental Response, Compensation, and LiabilityAct of 1980, as amended by the Superfund Amendments andReauthorization Act of 1986, a public comment period on thesedocuments was held from July 18, 1991 to August 17, 1991. Inaddition, a public meeting to discuss the findings of theSupplemental RI/FS and to present EPA's preferred alternative tothe public was held on August 1, 1991. Comments which werereceived by EPA during the public comment period are addressed inthe Responsiveness Summary which is attached to this Record ofDecision.
SCOPE AND ROLE OF OPERABLE UNIT TWO WITHIN SITE STRATEGY
The cleanup of the Swope site is being addressed in discretephases referred to as operable units (OUs). They are describedas follows:
- OU 1: Remediation of contaminated surface soil, sludges,tanks, tank contents, and buildings, and
- OU 2: Remediation of contaminated subsurface soil whichcontinues to act as a source of groundwatercontamination.
The OU 1 remedy, except for installation of a cap over the site,has been completed. This remedy has addressed potential threatsto human health which may have resulted due to ingestion of, ordermal contact with surficial contamination. Additionally, thisremedial action has resulted in the removal of surficialcontaminants from the site, which were, or had the potential of,acting as a source of contamination of groundwater beneath thesite. The objective of OU 2, which is the subject of thisdocument, is to mitigate the leaching of organic subsurface soilcontaminants into the groundwater. The selected remedy willremove and/or degrade volatile and semi-volatile organiccontaminants in subsurface soil, thereby decreasing the amount ofcontaminants which may leach to the groundwater underlying thesite. EPA further believes that remediation of subsurface soilcontamination will result in a significant reduction in thelevels of site-related groundwater contamination. Since the OU 2remedy is expected to decrease migration of volatile and semi-volatile compounds from site soil into the groundwater, EPA haspostponed a decision regarding the necessity of installation ofthe OU 1 cap until after implementation of the selected sourcecontrol remedy. If it is determined that a cap is not required,this approach would allow for a greater degree of unrestrictedfuture usage of the site.
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The results of groundwater sampxes collected as part of theSupplemental RI indicate that the Swope site has contributedvolatile organic contaminants to the shallow aquifer beneath thesite, and may have contributed to the contamination of the deepaquifer. These results further indicate that other sources ofgroundwater contamination exist upgradient of the Swope site.Since EPA believes that the selected remedy will result in asignificant reduction of site-related groundwater contamination,EPA has decided to postpone any decision regarding groundwaterremedial measures, until the selected source control remedy hasbeen completed.
Subsequent to completion of the selected remedy, EPA willdetermine whether it provides for adequate protection ofgroundwater and whether further source control measures, such ascapping, or if groundwater remedial measures are necessary.
SUMMARY OF SITE CHARACTERISTICS
Site Geology
The Swope site is located within the Atlantic Coastal Plainphysiographic province, which is underlain by a wedge ofunconsolidated sediments that thickens and dips to the southeasttoward the Atlantic Ocean. However, because the sedimentsthicken as-they dip, the shallower sediments dip less than thedeeper sediments.
The unconsolidated sediments in the vicinity of the Swope siteare comprised of the Pleistocene-age Pennsauken Formation, whichis underlain by the Cretaceous-age Magothy and Raritan Formationsand the Potomac Group. The Swope site is located within theoutcrop of the Potomac Group and the Magothy and RaritanFormations. . The Cretaceous-age sediments comprise the Potomac-Raritan-Magothy Aquifer System, and these sediments lie onbedrock. At the Swope site, the upper 25 to 30 feet of theunsaturated zone, which represents the Pennsauken Formation, iscomposed of silty sand, with lenses of glaucontic sand, clay andsome gravel. The remainder of the unsaturated zone and theshallow water-table aquifer, which was encountered during theSupplemental RI at depths ranging from 76 to 82 feet below landsurface, consist of medium to coarse grained sand and gravel fromthe Raritan and Magothy Formations.
A semi-confining unit, consisting of clay with interbedded lensesof fine grained sand, was encountered at depths ranging from 132to 157 feet below land surface. Below this unit, Potomac Groupsediments, consisting of medium to course grained sand andgravel, comprise the deep aquifer. These sediments are underlainby bedrock.
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Subsurface Soil
As part of the Supplemental RI, ten deep soil borings weredrilled to the water table (approximately 80 feet below landsurface) and subsurface soil samples were collected at fivedifferent depths. The results of this sampling event arepresented in Table 1.
Volatile organic compounds constituted the contaminants detectedmost frequently and at the highest concentrations in subsurfacesoil. Volatile organic contaminants detected most frequently andat the greatest concentrations include acetone, toluene, xylene,ethylbenzene, 4-methyl-2-pentanone, trichloroethene,tetrachloroethene and 2-butanone. The maximum total volatileorganic concentration (3,991 milligrams per kilogram (mg/kg)) forsoil not remediated during the OU 1 remedial action was detectedin a sample collected from boring B-6 at 14 to 16 feet. Elevatedlevels of volatile organic compounds were also detected in __subsurface soil samples collected from borings B-4 (81 mg/kg), B-5 (291 mg/kg), B-8 (797 mg/kg) and B-9 (17 mg/kg).
Additionally, elevated levels of semi-volatile organiccontaminants were also detected. Semi-volatile organiccontaminants detected most frequently and at the greatestconcentrations include bis(2-ethylhexyl)phthalate, naphthalene,phenol and isophorone. The highest concentration of semi-volatile organic contaminants (275 mg/kg) was detected in asample collected from boring B-8 at 6 to 8 feet. Elevated levelsof semi-volatile organic compounds were also detected in samplescollected from borings B-4 (109 mg/kg), B-5 (42 mg/kg) and B-6(229 mg/kg). Since borings B-5 and B-6 were installed withinthe former lagoon area, and borings B-8 and B-9 were installed inthe former buriel sludge area of the site, these results indicatethat subsurface soil contamination at the Swope site is due tothe past storage and waste disposal practices of the Swope Oiland Chemical Company.
The concentrations of inorganic constituents in subsurface soilwere generally low, with the exception of arsenic and silver,which were each found at elevated levels in only one of fifty-five subsurface soil samples. Arsenic was detected in a samplecollected from boring B-3 from 29 to 31 feet, at a concentrationof 23 mg/kg. Silver was detected in a sample collected fromboring B-10 from 59 to 61 feet, at a concentration of 7 mg/kg.Additionally, nickel and zinc were detected at elevatedconcentrations in one of two replicate samples collected fromboring B-9 from 84 to 86 feet, but not in the duplicate samplecollected from this location. Polychlorinated biphenyls weredetected in two subsurface soil samples collected from the lagoonarea. PCBs were detected at a concentration of 0.19 mg/kg and0.93 mg/kg in soil samples collected from borings B-5 at 6 to 8feet and B-6 at 6 to 8 feet, respectively.
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.Subsurface soil samples were not collected from tne area of theformer tank farm (Figure 2) at the time that the Supplemental RIsoil boring program was conducted, because EPA was of the opinionthat this area was underlain by a concrete pad. Duringperformance of the OU 1 remedial action, it was determined that aconcrete pad, which would have served to mitigate theinfiltration of contaminants into soil in this area, did notexist beneath the tank farm. Therefore, the extent of subsurfacesoil contamination in this area is unknown.
The results of chemical analyses on subsurface soil samplesindicate that volatile and semi-volatile organic contaminationextends vertically to the water table, located approximately 80feet below land surface. These sampling results further indicatethat volatile organic contaminants were primarily detected atlevels greater than the New Jersey Interim Soil Action Level(NJISAL) of 1 mg/kg for total volatile organics, to a depth ofapproximately 50 feet below land surface. It should be noted,however, that volatile organic contaminants were detected atconcentrations above 1 mg/kg at depths greater than 50 feet insubsurface soil samples collected from boring B-l at 74 to 76feet and B-5 at 59 to 61 feet and 77 to 79 feet. Semi-volatileorganic contaminants were detected at levels greater than theNJISAL of 10 mg/kg for total semi-volatile organics to a depth ofapproximately 30 feet below land surface.
Groundwater
Groundwater samples were collected from both the shallowunconfined and deep semi-confined aquifers. A total of 18monitoring wells and public supply well MPWC 1 were sampledduring two sampling rounds. Fifteen of these monitoring wellswere sampled as part of t e first sampling round in October andDecember of 1989. All 19 wells, including four downgradientmonitoring wells installed after the first sampling round, weresampled during January 1990. Additionally, metals samples werecollected from all 19 wells in May 1990 and analyzed for totalmetals, since samples were filtered during the first two samplingrounds.
Volatile organic contaminants were detected in all wells screenedin both the shallow and deep aquifer underlying the Swope site.The ranges of concentrations of specific volatile organiccompounds detected in upgradient and downgradient wells areprovided in Table 2.
During the first sampling round, the levels of total volatileorganics detected in shallow upgradient wells ranged from 37micrograms per liter (ug/1) (well GM-6S) to 114 ug/1 (well GM-5S). The levels of total volatile organics detected in shallowwells located on site ranged from 60 ug/1 (well MW-1) to 443 ug/1(well GM-lS). Total volatile organics were detected at
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concentrations ranging from 5 ug/1 (well GM-6S) to 128 ug/1 (wellGM-5S) in shallow upgradient wells, and from 45 ug/1 (well MW-1)to 676 ug/1 (well GM-8S) in on-site and downgradient shallowaquifer wells during the second sampling round. These samplingresults clearly indicate that higher concentrations of volatileorganic contaminants were detected in shallow wells located onand downgradient of the site than in samples taken from wells inthe shallow aquifer located upgradient from the site. These datasupport the conclusion that the Swope site has contributed to thecontamination of shallow-aquifer groundwater.
The groundwater quality data presented in Table 2 indicate thatsome specific volatile organic compounds are present in shallow-aquifer groundwater at greater concentrations on and downgradientof the Swope site than upgradient. These contaminants include1,1-dichloroethene, 1,1-dichloroethane, 1,2-dichloroethene, 1,2-dichloroethane, 1,1,1-trichloroethane, toluene, trichloroethene,tetrachloroethene, ethylbenzene and xylene. Of these compounds,-,1,1-dichloroethene, 1,2-dichloroethene, 1,2-dichloroethane,1,1,1-trichloroethane, trichloroethene, tetrachloroethene, andxylene were detected at levels which exceeded Federal and/orState Maximum Contaminant Levels (MCLs). Of the volatile organiccompounds detected in upgradient shallow aquifer wells, 1,1-dichloroethene, 1,2-dichloroethene, chloroform, 1,2-dichloroethane, and trichloroethene were detected atconcentrations exceeding Federal and/or State MCLs.
The concentrations of total volatile organic contaminantsdetected during the first sampling round in deep wells locatedupgradient of the site ranged from 227 ug/1 (well GM-2D) to 331ug/1 (GM-5D). During this sampling round, volatile organiccompounds were found in on-site and downgradient deep wells atconcentrations ranging from 310 ug/1 (well MPWC 1) to 367 ug/1(well GM-3D). During the second sampling round, total volatileorganic contaminants were detected at levels ranging from 14 ug/1(well GM-2D) to 331 ug/i (well GM-5D) in upgradient wellsscreened in the deep aquifer, and from 24 ug/1 (well GM-8D) to279 ug/1 (well GM-4D) in deep wells located on and downgradientof the site.
The deep-aquifer groundwater quality data presented in Table 2indicate that specific volatile organic compounds were detectedat marginally higher concentrations in on-site and downgradientwells than in upgradient wells. These compounds include vinylchloride, 1,1-dichloroethene, 1,2-dichloroethene, 1,2-dichloroethane, 1,1,1-trichloroethane and benzene. All of thesecompounds, with the exception of 1,1,1-trichloroethane, weredetected at levels which exceed Federal and/or State MCLs. Ofthe volatile organic compounds which were found in deep wellslocated upgradient of the site, 1,1-dichloroethene, 1,2-dichloroethene, chloroform, 1,2-dichloroethane, carbontetrachloride, trichloroethene, and tetrachloroethene were
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detected at concentrations in excess of Federal and/or StateMCLs. The fact that some VOCs were found in the deep aquifer athigher levels in samples taken from on-site and downgradientwells than in upgradient wells suggests that the Swope site maybe contributing to the cont?.mination of the deep aquifer.
Semi-volatile organic compounds were detected in groundwatersamples from both the shallow and deep aquifers. The maximumconcentration of total semi-volatile organics was 146 ug/1,detected in deep downgradient well GM-7D. Of the semi-volatileorganics, only bis(2-ethylhexyl)phthalate exceeded its New JerseyState MCL (5 ug/1) in shallow upgradient well GM-5S (11 ug/1) anddeep downgradient well GM-7D (130 ug/1). A summary of the semi-volatile organic data is presented in Table 3.
As displayed in Table 4, arsenic, chromium, lead and mercury weredetected at concentrations which exceed Federal and/or State MCLsor Action Levels. Arsenic was detected above the Federal andState MCL of 50 ug/1 in only one well, CM-IS, at a concentrationof 78.6 ug/1. Chromium was detected in upgradient shallowaquifer well GM-5S (77.5 ug/1) and in on-site and downgradientshallow wells GM-7S (123 ug/1), GM-8S (88.5 ug/1) and MW-2 (135ug/1) at concentrations above the State MCL of 50 ug/1.Additionally, chromium was detected above the New Jersey StateMCL in one upgradient deep well, GM-5D (54.1 ug/1). Lead wasmeasured at a concentration above the Federal Action Level of 15ug/1 in pn-site and downgradient shallow wells MW-2 (52.2 ug/1),MW-4 (17.9 ug/1), GM-7S (23.1 ug/1) and GM-8S (22.5 ug/1), andupgradient deep well GM-6D (17.4 ug/1). Mercury was present ingroundwater from shallow on-site well MW-4 (6.0 ug/1) at aconcentration in excess of the Federal and New Jersey State MCLof 2 ug/1. Mercury was also detected at concentrations slightlygreater than the MCL in on-site and downgrrdient deep wells GM-7D(2.4 ug/1) and MPWC 1 (2.9 ug/1).
Iron and manganese were-found in groundwater at levels whichexceeded secondary Federal and/or State MCLs. Iron was detectedin all wells at concentrations in excess of the MCL of 300 ug/1,except wells MW-1 and MPWC 1. Manganese was detected atconcentrations in excess of the MCL of 50 ug/L in all wellsexcept well GM-6S.
Summary
In summary, subsurface soil sampling results indicate thatvolatile and semi-volatile organic contaminants are present inthe unsaturated zone, primarily in areas of the site which wereused for the storage and disposal of liquids and sludges duringfacility operations. Furthermore, shallow aquifer groundwatersampling results indicate that the concentrations of volatileorganic contaminants, many of which occur in subsurface soil, aregreater on and downgradient of the site than upgradient. Based
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upon the data, it was concluded that contaminants in the soil atthe Swope site are migrating into the shallow aquifergroundwater. Groundwater quality data further suggest thatcontaminants in the soil at the Swope site may be migrating intothe deep aquifer. The detection of volatile and semi-volatileorganics in shallow and deep wells screened upgradient of theSwope site, as well as in monitoring wells at facilities locatedhydrologically side-gradient of the site, indicates that theSwope site is contributing to a larger regional groundwatercontaminant plume.
Due to the continuing migration of volatile organic compoundsinto the groundwater and the potential for the migration of semi-volatile organic compounds into groundwater, soil contaminationin the unsaturated zone is of concern. Specifically, soil whichcontain organics at levels which exceed the NJISALs of 1 mg/kgfor total volatile organic contaminants and 10 mg/kg for totalsemi-volatile organic contaminants may pose a threat togroundwater quality. Approximately 153,000 cubic yards of soilare contaminated above these cleanup levels.
Generally, inorganic compounds were detected at low levels inunsaturated soil. Except for arsenic,.inorganics detected aboveMCLs in groundwater were not detected at levels of concern in anyof the subsurface soil samples. Arsenic was detected in only onesubsurface soil sample in excess of the NJISAL of 20 mg/kg.
Sporadic occurrences of lead, mercury and arsenic at levels inexcess of primary MCLs and/or Action Levels were observed duringthe May 1990 groundwater sampling round. Of the metals whichwere detected in groundwater during this sampling round, onlychromium and lead were detected above a primary MCL or Action'Level in more than one shallow well. The detection of elevatedlevels of chromium in a shallow upgradient well and in monitoringwells located at facilities which are hydrologically side-gradient of the Swope site may indicate the presence of anupgradient source. .,. _ -r ...... ,_
SUMMARY OF SITE RISKS
A baseline Risk Assessment was conducted to evaluate potentialsite-related risks to human health and the environment which mayresult if no remedial action is taken. The Risk Assessment forOU 2 focuses on risks posed by contaminants detected ingroundwater. The following discussion summarizes the findings ofthe Risk Assessment, as amended by EPA's Addendum to theSupplemental Feasibility Study and Risk Assessment.
As stated previously, the site and surrounding properties arecurrently zoned for industrial use. The nearest residentialareas to the Swope site are in the Townships of Delair andMorrisville, which are located approximately 0.5 mile west and
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0.8 mile southwest of the site, respectively. In addition,Pennsauken High School is located approximately 2000 feet to thenortheast. Although Pennsauken High School land is zoned forresidential use, development of residential dwellings on thisland in the near future is not expected.
The Risk Assessment, as amended, identifies several potentialexposure pathways by which the public may be exposed to site-related contaminants. The following potential exposure routeswere identified:
(1) Dermal contact with shallow aquifer groundwater byfuture industrial workers while handwashing;
(2) Ingestion of groundwater by an industrial worker from ahypothetical potable well installed in the shallow aquiferdowngradient of the site;
(3) Ingestion of groundwater by a resident from ahypothetical potable well installed in the shallow aquiferdowngradient of the site; and
(4) Showering by a resident using water from a hypotheticalpotable well installed in the shallow aquifer downgradientof the site.
Risks associated with dermal contact and ingestion of site soilwere not quantified in this assessment. It should be noted,however, that as part of the OU 1 remedial action, up to 1.5 feetof contaminated soil was removed from most of the site. Inaddition, sludge and visibly contaminated soil were removed to adepth of approximately 10 feet. Subsequently, clean backfillmaterial was utilized to bring the site up to grade. Potentialrisks associated with the possibility of ingestion of, or dermalcontact with contaminated soil, therefore, are considered to beminimal.
The Risk Assessment identified 14 constituents of concern (COCs)for shallow aquifer groundwater. These constituents were:
A complete list of compounds detected in groundwater, includingthe detection frequency and upper-bound concentration of eachcompound, is provided in Table 6.
Noncarcinogenic risks are assessed using a hazard index (HI)approach, based on a comparison of expected contaminant intakesand safe levels of intake (Reference Doses). Reference doses(RfDs) have been developed by EPA for indicating the potentialfor adverse health effects. RfDs, which are expressed in unitsof milligrams/kilogram/day (mg/kg/day), are estimates of dailyexposure levels for humans which are thought to be safe over alifetime (including sensitive individuals). EPA-verified RfDsare not available for all COCs, (i.e., 4-nitroaniline, aluminumand lead), therefore, risks associated with some of thesechemicals could not be quantitatively assessed. RfDs for theCOCs are presented in Table 7. Estimated intakes of compoundsfrom environmental media (e.g., the amount of chemicals ingestedfrom contaminated groundwater) are compared with the RfD to __derive the hazard quotient for the contaminant in the particularmedia. The hazard index is obtained by adding the hazardquotients for all contaminants across all media that impact aparticular receptor population.
A HI greater than 1 indicates that the potential exists for non-carcinogenic health effects to occur as a result of site-relatedexposures. The HI provides a useful reference point for gaugingthe potential significance of multiple contaminant exposureswithin a single medium or across media. His were calculated forthe exposure scenarios assessed and are presented in Table 8. AHI of greater than 1 for the potential ingestion of shallowaquifer groundwater by either industrial workers or residentsindicates that noncarcinogenic health effects would likelyresult, if the shallow aquifer were utilized as a potable watersource in the vicinity of the Swope site.
Potential carcinogenic risks were evaluated using the cancerpotency factors developed by EPA for compounds of concern.Cancer slope factors (SFs) have been developed by EPA1sCarcinogenic Risk Assessment Verification Endeavor for estimatingexcess lifetime cancer risks associated with exposure topotentially carcinogenic chemicals. SFs, which are expressed inunits of (mg/kg/day)'1, are multiplied by the estimated intake ofa potential carcinogen, in mg/kg/day, to generate an upper-boundexposure to the compound at that intake level. SFs for the COCsare presented in Table 7. The term "upper-bound" reflects theconservative estimate of the risks calculated from the SF. Useof this approach makes the underestimation of the risk unlikely.
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For known or suspected carcinogens, EPA considers excess upper-bound individual lifetime cancer risks between 10* to 10* to beacceptable. This level indicates that an individual has notgreater than a one in ten thousand to one in a million chance ofdeveloping cancer as a result of site-related exposure to acarcinogen under specific exposure conditions at the site. Thepotential cancer risks associated with the site are presented inTable 9. The cancer risk for use of shallow aquifer groundwateras a potable water source by residents was determined to be 1.8 xICT5 (1.8 in a thousand) for an exposure duration of 30 years.
The quantitative risk characterization suggests that unacceptablenoncarcinogenic and carcinogenic risks under current or futureland-use conditions would exist, if the shallow aquifer wasutilized as a potable water source in the vicinity of the site.Furthermore, the Supplemental RI concluded that a semi-confiningunit separates the shallow and deep aquifers, and that leakage ofgroundwater to the deep aquifer occurs. The Swope site,therefore, may be contributing COCs to the deep aquifer, which iscurrently utilized as a potable water source.
Subsurface Soil
Volatile and semi-volatile organic contaminants in subsurfacesoil have migrated into the shallow aquifer which presents athreat to groundwater quality in the deep aquifer, which is apotable water source. Therefore, it is necessary to take aremedial action to remove contaminants from the subsurface soil,in order to reduce the site's contribution to groundwatercontamination.
The NJISALs for volatile and semi-volatile organic compounds willbe utilized as soil cleanup goals, in order to provide forgroundwater protection. NJISALs are used to identify thepresence of contamination in soil.
Risks associated with potential dermal contact with, or ingestionof contaminated subsurface soil were not quantified in this riskassessment, since direct human contact with soil at depth is notprobable.
Actual or threatened releases of hazardous substances from thissite, if not addressed by the preferred alternative, may presenta current or potential threat to public health, welfare, or theenvironment through the continued presence of contaminants insubsurface soil.
Uncertainties
The procedures and inputs used to assess risks are subject to awide variety of uncertainties. The main sources of uncertaintyin this Risk Assessment include:
Uncertainty in environmental sampling arises mainly because ofthe potential for uneven distribution of constituents inenvironmental media. Therefore, there is significant uncertaintyas to the actual levels of contaminants present. Analysis errorresults largely from errors inherent in the analytical methodsand characteristics of the matrix being sampled.
As part of the exposure assessment, estimates are generated as tothe frequency of exposure to chemicals of concern and the periodof time over which the exposure would occur. These estimatesserve as a source of uncertainty.
Uncertainties in toxicological values result due to extrapolationof the effects of high doses of compounds on animals to low dosesin humans. Additional uncertainties result because ofdifficulties involved in determining the toxicity of chemicalmixtures. The use of conservative assumptions and models duringperformance of the risk assessment addresses these uncertainties,so as to ensure that the potential site-related risks are notlikely greater than those estimated.
IBnvironmental/Ecoloaical Assessment
The potential for environmental/ecological impacts was examinedas part of the Supplemental RI. Due to the extensive nature ofsurficial activities performed as part of the OU 1 remedialaction, little of the original site habitat remains. Surfacesoil has been removed to a depth of 1.5 feet over most of thesite, and approximately 2 feet of clean fill has been placed overthe underlying soil. Currently, the site unlikely supports anycomplex terrestrial ecosystem, but may support invertebrates andsome small mammals. Since contaminated soil is no longerexposed, constituents present in the subsurface soil are notlikely to be transported off site via erosional runoff or wind.
JiCREENING OF REMEDIAL TECHNOLOGIES
The Swope site OU 2 remedial objective focuses on mitigating theleaching of volatile organic compounds and the potential formigration of semi-volatile organic compounds into groundwater.
During the Feasibility-Study process, a wide range of remedialtechnologies were evaluated to identify those appropriate to meetthe OU 2 remedial objective. An evaluation of the alternativesthat passed the initial screening process is presented in thenext section.
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Initially, technologies and process options were identified whichwere classified into four broad categories, namely, treatmenttechnologies, containment options, institutional actions toreduce the potential for exposure to contaminants, and noremedial action with media monitoring. The technologies andprocess options considered, and the results of the initialscreening processes are summarized below.
Institutional actions which were considered included site fencingand deed restrictions on the use of the site property. Sinceneither of these actions would aid in meeting the OU 2 remedialaction objective of mitigating the leaching of subsurface soilcontaminants into groundwater, they were eliminated from furtherconsideration.
Site capping to reduce the mobility of site contaminants byrestricting the infiltration of precipitation was considered as acontainment option. A variety of capping materials and cappingdesigns were evaluated. A clay and soil cap, consisting of arelatively impermeable clay layer overlaid by soil, wasenvisioned to be susceptible to cracking and to requiremaintenance and repair. Concrete, asphalt, and additive-derivedcaps were determined to be susceptible to cracking andweathering. A single-layer synthetic membrane cap was found tobe prone to tearing, and is often punctured by burrowing animalsand plant roots. Of the capping options considered, the multi-layer cap was determined to be the most reliable and, therefore,was carried through the initial screening process. This cap wouldconsist of a layer of low permeability (e.g., clay or syntheticmembrane) which would be covered with sand, topsoil andvegetation to protect the low permeability layer from the effectsof the atmosphere.
Ex-situ (i.e., technologies involving the excavation of soil,prior to treatment) and.in-situ (i.e., in-place treatment)technologies were also evaluated. Ex-situ treatment technologieswere not carried through the initial screening process due to thedifficulties that would be involved in excavating contaminatedsite soil to the depth of contamination within the spatialconfines of the site. As displayed on Figure 2, the site isbounded to the northeast and southwest by railroad rights-of-wayand warehouses, and to the southeast by National Highway.Excavation of site soil would, at a minimum, involve thedisruption of a railroad spur as well as National Highway. Inaddition, the excavation of contaminated site soil would requireshoring the sides of the excavation to about 80 feet to maintainthe integrity of the excavation walls during soil removal. Theshoring of the excavation walls to the depth of contaminationwould prove difficult and would result in the excavation of soiloutside the physical .boundaries of the site.
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In-situ treatment technologies evaluated in the Supplemental FSincluded vitrification/glassification, solidification/fixation ofcontaminated soil, soil flushing, soil vapor extraction, enhancedvolatilization, and biodegradation.
Vitrification/glassification involves melting soil to bindthe contaminants in a glassy, solid matrix which is resistant toleaching. Large electrodes are installed in contaminated soilthrough which a high current of electricity is passed to melt thesoil. Nonvolatile contaminants are bound in the vitrified mass,while organic compounds are destroyed by pyrolysis. Since thistechnology has not been proven to be implementable to the depthof contamination at the site, vitrification/glassification waseliminated from further consideration during the initialscreening process.
The solidification/fixation technology involves immobilizingcontaminants by binding them into an immobile, insoluble matrix.Generally, concrete or cement is mixed with contaminated soil,which become incorporated into the rigid matrix of the hardenedconcrete. Reviews of case studies indicate that this technologyhas not been proven to be an effective means to immobilizeorganic compounds. This technology, therefore, was not carriedthrough the initial screening process.
Soil flushing involves the use of a solvent to solubilizecontaminants attached to soil particles. Due to the non-homogeneous nature of the subsurface soil and the potential forpreferential pathways to develop within the 80-feet deep vadosezone, soil flushing may only be of limited effectiveness. Sincethis technology may be only partially effective, it was screenedout.
Soil vapor extraction involves the removal of volatile organiccompounds from soil in the unsaturated zone by increasing theflow of air through the'soil. Air is drawn from the surface ofthe site through extraction wells, which are screened within thecontaminated soil. Volatilized contaminants contained within thesoil gas are drawn from the subsurface environment through theextraction wells. A treatability study performed during theSupplemental FS demonstrated that a soil vapor extraction systemwould be an effective means to remove volatile organiccontaminants from subsurface soil. This technology, therefore,was carried through into the alternative development stage.
The enhanced volatilization technology utilizes steam, hot air orelectrical probes to raise the temperature of contaminants insoil, causing them to volatilize. If steam were utilized to heatthe soil, condensate would be generated during the initial stagesof the process, thereby providing a pathway by which contaminantscould migrate to groundwater. In addition, this technology hasonly been demonstrated to be effective to a depth of about 30
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feet. Therefore, enhanced volatilization was eliminated fromfurther consideration during the initial screening.
In-situ biodegradation involves the use of microorganisms thatare naturally occurring in soil to degrade organic contaminants.Oxygen and nutrients may be added to the subsurface environmentto enhance microbial catabolism or co-metabolism of organiccontaminants, resulting in the breakdown of these compounds. In-situ biodegradation has been successfully utilized to degradenonhalogenated organic compounds, but has not been demonstratedto be effective in remediating halogenated organic contaminants.Since this is a proven technology for the remediation of soilcontaminated with nonhalogenated organic contaminants, and non-halogenated organic contaminants comprise a significant portionof the subsurface soil contamination at the Swope site, thistechnology was carried through into the remedial alternativedevelopment stage.
SUMMARY OF REMEDIAL ALTERNATIVES
The Comprehensive Environmental Response, Compensation, andLiability Act (CERCLA), as amended by the Superfund Amendmentsand Reauthorization Act (SARA), requires each selected siteremedy to be protective of human health and the environment,cost-effective, and in accordance with statutory requirements.Permanent solutions to contamination problems are to be achievedwherever possible. The use of innovative technologies and on-site treatment are evaluated as a means to attain this goal. Theremedial alternatives evaluated during the Supplemental FS aredescribed below.
Estimated Months to Achieve RemedialAction Objectives NA
The National Contingency Plan requires that a No ActionAlternative be evaluated at every site to provide a baselineagainst which other remedial alternatives may be compared. Underthis alternative, EPA would take no further action to prevent orreduce the leaching of subsurface soil contaminants togroundwater. This alternative includes a five-year groundwatermonitoring plan, which would involve the sampling of existingsite wells on a quarterly basis to assess the impact of thecontaminated subsurface soil on groundwater quality. Groundwater
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samples would be analyzed for Target Compound List volatile andsemi-volatile organic contaminants on a quarterly basis, andTarget Analyte List metals on an annual basis..
This alternative would not provide for protection of human healthand the environment. The toxicity, mobility and volume of thecontaminants would not be reduced. Contaminated subsurface soilwould remain on site and continue to act as a source ofgroundwater contamination.
Alternative 2: Boil Vapor Extraction with Biodegradation
Capital Cost: $687,500
Annual Operation and MaintenanceCost (Groundwater Monitoring Program): $234,200
Estimated Months to Achieve RemedialAction Objectives: 18
Under this alternative, soil vapor extraction and biodegradationwould be used to remove and/or degrade organic contaminants fromunsaturated soil. Using the NJISALs of 1 mg/kg for totalvolatile organic compounds and 10 mg/kg for total semi-volatileorganic compounds as cleanup goals, the estimated total volume ofunsaturated soil requiring treatment is 153,000 cubic yards.
A typical soil vapor extraction system consists of a network ofsoil gas extraction and monitoring wells, which are installedwithin contaminated soil. The extraction wells are connected toa vacuum pump(s) which create(s) a negative pressure gradientwithin the contaminated soil, drawing air from the surface of thesite through the contaminated soil and into the extraction wells.As the air passes through the unsaturated soil, volatile organicstend to vaporize and travel with the induced air stream to theextraction wells. Soil-gas monitoring wells are utilized tomeasure the induced pressure gradient to determine whethercontaminated soil is being effectively ventilated. In addition,wells which are used to inject air either passively or activelyinto the subsurface environment, may be utilized to increasehorizontal air flow through contaminated soil or to limit thesystem's influence to within the boundaries of the site.
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During the design of the soil vapor extraction system, themagnitude of volatile organic emissions that may result due tooperation of the system would be assessed to determine whetherair pollution control equipment would be necessary. Air qualityregulations (N.J.A.C. 7:27) require that state-of-the-art airpollution control technology be used for control of any sourcewhere the emission rate of total volatile organic compounds is inexcess of 0.5 pound per hour and/or the rate of total toxicvolatile organic contaminants is in excess of 0.1 pound per hour.Therefore, it may be necessary to treat the air stream by carbonadsorption or thermal destruction prior to discharge. Theestimated cost of this alternative includes the cost of a thermaldestruction unit.
The primary component of this alternative would be soil vaporextraction. In addition, biodegradation of site contaminantswould be accomplished as a by-product of the soil vaporextraction process, because operation of a soil vapor extractionsystem would also serve to increase oxygen levels withincontaminated soil, and thereby enhance the aerobic biodegradationof nonhalogenated organic contaminants by microorganisms whichare present in soil. This process would be effective indegrading semi-volatile organic compounds which would not beremoved with the induced air stream. The effectiveness ofbiodegradation depends on several factors including the presenceof appropriate microorganisms, soil moisture content, oxygencontent in the soil gas, the presence of nutrients, soil pH andsoil temperature. If necessary, the contaminated soil could beinoculated with appropriate microorganisms, and nutrients couldbe injected into the subsurface environment through wells toenhance the aerobic biodegradation process.
During the design phase of the soil vapor extraction system, atreatability study would be conducted, utilizing EPA-approvedmethodologies, to evaluate the effectiveness of biodegradation atthe site. This study would assess whether environmental factors,such as soil nutrients and moisture content or the number andtype of microorganisms present in soil, could be altered toenhance the biodegradation of contaminants further.
During the operation of the soil vapor extraction system,subsurface soil and soil gas samples would be collected toevaluate the effectiveness of the system in remediatingsubsurface soil contamination. Subsurface soil samples would becollected at the site during the design of the soil vaporextraction system to characterize subsurface soil contaminationfurther and to provide a baseline for determination of theeffectiveness of the soil vapor extraction system in remediatingsubsurface contamination. During this sampling event, asubsurface soil boring(s) would be installed in the former tankfarm area, and soil samples would be collected to the watertable, to determine the nature and extent of subsurface soil
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contamination in this area. Concentrations of contaminants insoil gas samples, collected during operation of the soil vaporextraction system, would be evaluated to determine the continuingeffectiveness of ths system in remediating organic contaminants,as well as providing an indication as to when soil samples shouldbe collected to determine whether soil cleanup goals have beenmet. Operation of the treatment system would continue until thesoil cleanup goals have been met, or until EPA determines thatoperation of the system is no longer practical.
In addition, a five-year groundwater monitoring program, whichwould involve the sampling of all site wells on a quarterlybasis, would be conducted to provide groundwater quality data.Groundwater samples would be analyzed for Target Compound Listvolatile and semi-volatile organic contaminants on a quarterlybasis, and Target Analyte List metals on an annual basis.
Decision to Postpone Installation of a Cap
Alternative 2, as developed and evaluated in the Supplemental FS,originally included the installation of a multi-layer cap overthe site, following treatment of contaminated subsurface soil. Acap was originally included as a component of this alternative,because the installation of a cap was a source control activityspecified in the September 1985 Record of Decision for the Swopesite. It should be noted, however, that extensive treatment ofsubsurface contamination was not envisioned when the 1985 remedywas selected. During preparation of the Proposed Plan, EPAreevaluated the need to cap the site in conjunction with theactive treatment of subsurface soil contamination. EPA hasdetermined that treatment of subsurface soil contamination alonemay be adequate to protect the grpundwater from continuingdegradation. As a result, EPA has decided to postpone a decisionregarding a cap, until after completion of the selected sourcecontrol remedy. If it is later determined that a cap is notrequired, this approach would allow for a greater degree ofunrestricted future usage of the site. Subsequent to completionof the selected remedy, EPA will evaluate whether this remedyprovides for adequate protection of groundwater, and whether theinstallation of a cap or further source control actions arewarranted.
EVALUATION OF ALTERNATIVES
Each of the alternatives was evaluated with respect to the ninecriteria specified in the National Contingency Plan and utilizedby EPA as part of the remedy selection process. These criteriaare classified into four categories: environmental/public healthprotectiveness, compliance with cleanup standards, technicalperformance and cost. In addition, the selected remedy shouldresult in permanent solutions to contamination problems andshould use treatment to the maximum extent practicable. The nine
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criteria are summarized below:
— Overall Protection of Human Health and the Environment; Thiscriterion addresses whether or not a remedy providesadequate protection and describes how risks posed througheach pathway are eliminated, reduced or controlled throughtreatment, engineering controls or institutional controls.
Compliance with ARARs; This criterion addresses whether ornot a remedy will meet all of the applicable or relevant andappropriate requirements (ARARs) of Federal and Stateenvironmental statutes and/or provide a basis for invoking awaiver.
- Long-term Effectiveness and Permanence; This criterionrefers to the magnitude of residual risk and the ability ofa remedy to maintain reliable protection of human health andthe environment over time, once cleanup goals have been met.
- Reduction of Toxicity. Mobility or Volume Through Treatment;This criterion addresses the anticipated performance of theremedy in terms of reducing the toxicity, mobility orvolume of the contaminants of concern at the site.
Short-term Effectiveness; This criterion refers to theperiod of time needed to achieve protection, as well as theremedy's potential to create adverse impacts on human healthand the environment that may result during the constructionand implementation phase.
Implementability; Implementability is the technical andadministrative feasibility of implementing a remedy,ir.cluding the availability of materials and servicesrequired to implement a particular alternative.
Cost; Cost includes the estimated capital and operation andmaintenance costs of the remedy, and the net present worth .cost.
- State Acceptance; This criterion indicates whether, based onits review of the Supplemental RI/FS and Addenda, theProposed Plan and the ROD, the State of New Jersey concurswith the preferred alternative. The State has concurredwith the preferred alternative.
Community Acceptance; This criterion will be assessedfollowing a review of the public comments received on theSupplemental RI/FS and Addenda and the Proposed Plan.
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Overall Protection of Human Health and the Environment
The No Action Alternative for the Swope site consists ofmonitoring groundwater quality. No remedial measures whichprovide protection for human health and the environment in termsof soil contamination would be implemented as part of thisalternative. Subsurface soil contamination would remain andwould continue to act as a source of groundwater contamination.
Alternative 2, which involves soil vapor extraction withbiodegradation, would actively remove subsurface soilcontaminants and, thus, mitigate the leaching of organicsubsurface soil contaminants to groundwater. Operation of thesoil vapor extraction system would remove volatile organiccontaminants, while enhancing the biodegradation of residualnonhalogenated organic contaminants. Alternative 2 would provideprotection to human health and the environment by remediatingsubsurface soil contaminants which are acting as a source ofgroundwater contamination.
Compliance with ARARs
On-site soil vapor extraction with biodegradation (Alternative 2)would be conducted in compliance with Federal and State ARARs.Since no Federal or State regulations specify cleanup levels forthe volatile and semi-volatile contaminants in soil at the site,NJISALs for volatile and semi-volatile organic compounds will beutilized as cleanup goals.
Due to the site's location within a New Jersey Coastal Zone,implementation of Alternative 2 would be, to the maximum extentpractical, consistent with the New Jersey Coastal Zone ManagementPlan. Further, the requirements of N.J.A.C. 7:27-8.2(a)1 wouldhave to be met, if a carbon adsorption or catalytic oxidationunit were necessary to control air emissions from the soil vaporextraction system. The on-site storage of drill cuttingsgenerated during installation of vapor extraction and monitoringwells would be conducted in accordance with the requirements ofPart 264 of the Resource Conservation and Recovery Act (RCRA), ifthese cuttings were to remain on site for more than 90 days.Alternatively, Part 265, Subparts I and J standards would beapplicable, if storage of waste on site were less than 90 days.Off-site treatment and/or disposal would be conducted accordingto RCRA Part 262 standards which specify manifesting procedures,transport and record-keeping requirements. The shipment ofhazardous wastes off site to a treatment facility would beconsistent with OSWER Off-Site Policy Directive Number 9834.11,which ensures that facilities authorized to accept CERCLAgenerated waste materials will be in compliance with RCRAoperating standards. RCRA Part 264, Subpart X standards areapplicable to the soil vapor extraction process which would beused to treat contaminated subsurface soil.
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Under the No Action Alternative, no remedial action would betaken to reduce the .levels of contaminants in subsurface soil.Therefore, this alternative would not achieve the cleanup goalsestablished for site soil.
Long-term Effectiveness and Permanence
The No Action Alternative would not prove to be effective in thelong term. Alternative 2 would reduce volatile and semi-volatileorganic compound concentrations in subsurface soil, which wouldreduce the amount of contaminants leaching into groundwater.Therefore, soil vapor extraction with biodegradation is expectedto be effective in providing long-term reliable protection tohuman health and the environment.
Reduction of Toxicitv. Mobility or Volume Through Treatment
The No Action Alternative would not provide any reduction of thetoxicity, mobility or volume of contaminated soil at the Swopesite. Soil vapor extraction with biodegradation wouldpermanently remove or degrade organic contaminants in the soilmatrix and, as a result, provide for a reduction in the volume ofsubsurface soil contaminants which may migrate into groundwater.Soil vapor extraction, by removing volatile organic contaminantsfrom the site, will result in a significant reduction in toxicityand mobility of contaminants.
Short-term Effectiveness
Since no construction would occur under the No ActionAlternative, this alternative would not pose any additional riskto nearby communities or on-site workers. However, under thisalternative, subsurface poil would continue to act as a source ofgroundwater contamination. During implementation of Alternative2, on-site workers may be exposed to contaminants via dermalcontact or inhalation during installation of vapor extraction andmonitoring wells. These health risks would be controlled throughthe use of protective clothing and respiratory protection, asnecessary. Air quality monitoring and, if necessary, theinstallation of air emissions control equipment at vaporextraction wells would ensure the protection of human health andthe environment during operation of the soil vapor extractionsystem. Soil vapor extraction with biodegradation should resultin a significant reduction of subsurface soil contaminationwithin 18 months of initiation of construction activities.
Implementability
The No Action Alternative would not pose any implementationproblems, because no construction activities would be conductedunder this alternative. Soil vapor extraction withbiodegradation are proven technologies and could be implemented
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at the site. Implementation of a soil vapor extraction systemwould require the installation of extraction wells, piping andvapor monitoring wells. Air pollution control equipment andvacuum equipment could be placed on a mobile trailer that wouldbe parked at the site for the duration of the remedial activity.The biodegradation of site contaminants may require the balancingof environmental factors which affect the effectiveness of thistechnology. Therefore, activities such as the inoculation ofcontaminated soil with appropriate microorganisms or theinjection of nutrients into the subsurface environment throughwells, may be required to enhance the aerobic biodegradation oforganic contaminants. Services and materials necessary forimplementation of the selected remedy are readily available andno technical or administrative difficulties are foreseen.
Cost
Alternatives 1 and 2 have an estimated present worth cost of =$1,014,000 and $2,099,000, respectively. The total capital,annual operation and maintenance (O&M), and present worth costsfor each alternative are presented in Tables 10 and 11. Itshould be noted that the capital and O&M costs for Alternative 2do not include costs which may be involved with enhancing aerobicbiodegradation of contaminants. The capital cost for Alternative2 also does not include the cost of performing a biodegradationtreatability study, which would be conducted as part of thisalternative.
State and Community Acceptance
A review of the State and public comments received on theSupplemental RI/FS and Addenda, and the Proposed Plan indicatesthat both the State and the community concur with the selectedremedy. Public comments are addressed in the ResponsivenessSummary, which is attached to this document.
SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the resultsof the Supplemental RI/FS and Addenda, and public comments, EPAand the New Jersey Department of Environmental Protection andEnergy have determined that Alternative 2, soil vapor extractionwith biodegradation, is the most appropriate remedy forcontaminated subsurface soil at the Swope site. Site risks havebeen identified as being primarily due to the potential foringestion of contaminated groundwater. The results of theSupplemental RI indicate that contaminated soil at the Swope siteis a source of groundwater contamination. The selected remedywill be effective in reducing the quantity of soil contaminantsthat are available to migrate into the groundwater.
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The selected alternative involves the treatment of approximately153,000 cubic yards of subsurface soil contaminated with volatileand semi-volatile organic contaminants utilizing in-situ soilvapor extraction with biodegradation. Since no Federal or Stateregulations specify cleanup levels for volatile and semi-volatileorganic contaminants in soil at the site, NJISALs of 1 mg/kg fortotal volatile organic compounds and 10 mg/kg for semi-volatileorganic compounds will be utilized as cleanup goals to providefor groundwater protection.
During the design phase of the soil vapor extraction system, atreatability study will be conducted, utilizing EPA-approvedmethodologies, to evaluate biodegradation at the site. Thisstudy will assess whether environmental factors, such as soilnutrient and moisture content, or the number and type ofmicroorganisms present in soil, could be altered to enhance thebiodegradation of contaminants further.
During implementation of the selected remedy, subsurface soil andsoil gas samples will be collected to evaluate the effectivenessof the soil vapor extraction system in remediating subsurfacesoil contamination. Subsurface soil samples will be collected atthe site during the design of the soil vapor extraction system tocharacterize subsurface soil contamination further and to providea baseline for determining the effectiveness of the soil vaporextraction system in remediating subsurface contamination.During this sampling event, a subsurface soil boring(s) will beinstalled in the former tank farm area. Since storage ofhazardous materials in this area may have resulted in releases ofcontaminants into site soil, and subsurface soil contaminationbeneath the tank farm was not investigated during the performanceof the Supplemental RI, soil samples will be collected to thewater table, to determine the nature and extent of possiblesubsurface soil contamination in this area. Concentrations ofcontaminants in soil gas samples, collected during operation ofthe soil vapor extraction system, will be utilized to evaluatethe continuing effectiveness of the system in remediating organiccontaminants, as well as providing an indication as to when soilsamples should be collected to determine whether soil cleanupgoals have been met.
A five-year groundwater monitoring program will be conducted toprovide groundwater quality data. This will involve samplingsite wells on a quarterly basis for Target Compound List volatileand semi-volatile organic compounds, and on an annual basis forTarget Analyte List metals. Since several metals weresporadically detected at elevated levels in groundwater duringthe Supplemental RI, the analytical results of metals sampleswill be used to characterize metal contamination more fully. EPAmay decide to modify the monitoring program (in terms offrequency and contaminant parameters), based upon the analyticalresults of groundwater samples collected during the initial
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sampling event(s).
Operation of the treatment system will continue until cleanupgoals have been met, or until EPA determines that operation ofthe system is no longer practical. Subsequent to completion ofthe selected remedy, EPA will determine whether the selectedremedy provides for adequate protection of groundwater andwhether any further source control measures, such as capping, orif groundwater remediation is necessary.
Air quality monitoring will be performed during construction andoperation of the soil vapor extraction system. Air emissionsfrom the soil vapor extraction system will meet air emissionARARs. If necessary, air emission control equipment will beutilized to meet air emission ARARs.
The total present worth cost of this alternative is estimated tobe $2,099,000. This cost does not include the cost of conductingthe biodegradation treatability study or the cost of any actionswhich may be taken to enhance the aerobic biodegradation oforganic contaminants during operation of the soil vaporextraction system. The capital cost is estimated to be $687,500.O&M costs for the first year of operation of the soil vaporextraction system are estimated to be $397,500. Annual O&M costsfor the groundwater monitoring plan are estimated at $234,200.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility atSuperfund sites is to undertake remedial actions that achieveadequate protection of human health and the environment. Inaddition, Section 121 of the CERCLA establishes several otherstatutory requirements and preferences. These specify that, whencomplete, the selected remedial action for a site must complywith applicable or relevant and appropriate environmentalstandards established under Federal and State environmental lawsunless a statutory waiver is justified. The selected remedy alsomust be cost-effective and utilize permanent solutions andalternative treatment technologies or resource recoverytechnologies to the maximum extent practicable. Finally, thestatute includes a preference for remedies that employ treatmentthat permanently and significantly reduces the volume, toxicityor mobility of hazardous wastes as its principal element. Thefollowing sections discuss how the selected remedy meets thesestatutory requirements.
Protection of Human Health and the Environment
The selected remedy, which includes the in-situ vapor extractionof organic subsurface soil contaminants, will permanently reducethe quantity of contaminants in soil at the site. This remedy,therefore, will provide protection to human health and the
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environment by reducing this source of groundwater contamination.Based upon the results of the Risk Assessment conducted for theSwope site, the potential ingestion of contaminated groundwaterfrom the shallow aquifer which underlies the rite presents anunacceptable future risk to human health. There are, however, noshort-term threats associated with the selected remedy thatcannot be readily controlled.
Compliance with Applicable or Relevant and AppropriateRequirements
Alternative 2, which includes in-situ soil vapor extraction withbiodegradation, will comply with all Federal and Staterequirements which are applicable or relevant and appropriate toits implementation.
Cost-Effectiveness
The selected remedy is cost-effective and has been determined tobe the only alternative which would be effective in meeting theremedial action objective of mitigating the migration or thepotential for migration of organic contaminants to groundwater.
Utilization of Permanent Solutions and Alternative Treatment forResource Recovery) Technologies to the Maximum Extent Practicable
The selected remedy, Alternative 2, provides reliable protectionof human health and the environment over the long term, andreduces the toxicity, mobility and volume of soil contaminantsthrough treatment. This alternative can be implemented withoutresulting in any adverse impacts on human health and theenvironment during construction and operation. Services andmaterials necessary for implementation of the selected remedy arereadily available and no technical or administrative difficultiesare foreseen.
The State and community concur with the selected remedy, and it -meets the statutory requirements to utilize permanent solutionsand treatment technologies to the maximum extent practicable.
Preference for Treatment as a Principal Element
By treating soil contaminated with volatile and semi-volatileorganic compounds in place with a soil vapor extraction system,the selected remedy addresses threats posed by the site usingtreatment technologies. Therefore, the selected remedy meets thestatutory requirement to utilize permanent solutions andtreatment technologies to the maximum extent practicable.
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100095
There are no significant changes in the preferred alternative,Alternative 2, Soil Vapor Extraction with Biodegradation, aspresented in the Proposed Plan.
Subsequent to release of the Proposed Plan, EPA determined thatthe groundwater monitoring program to be implemented as part ofthe No Action Alternative and Alternative 2 should be expanded toprovide for the collection of samples for total metals analyses.As a result, EPA revised the cost for implementing the No ActionAlternative and the selected remedy, which were specified in theProposed Plan, to include the cost for metals analyses. Thisrevision to the scope of the groundwater monitoring programresults in an increase of $52,900 in the estimated cost ofconducting the five-year monitoring program.
28
100096
APPENDIX A - FIGURES
100097
FIGURE 1
NEWJERSEV.
QU*()R»NGIEV-
/ nw *• / t i
"*' ' •>'^y'» .• x. ;-]^
PENNSAUKEN
MERCHANTVILLE-PENNSAUKEN WATER COMMISSION WELL N« 1 VJ• * ». r ^ J0* m^ ' ^-.' - tss *. l i J.JTS ,:i». • --_ .. <\%"
PUCHACK WELL FIELD
BASE MAP IS A PORTION OF THE U.S.6.S. CAMDEN, NJ -PA QUADRANGLE (75 MINUTE SERIES, 1967. PHOTOREVBED 1973).CONTOUR INTERVAL 10'
LOCATION MAP jSWOPE OIL CO. SITE. PENNSAUKEN TWR. NJ i
B-5 from 19' to 21'B-5 from 19' to 21'B-3 from 29' to 31'B-4 from 24' to 26'B-6 from 14' to 16'B-8 from 14' to 16'B-6 from 14' to 16'B-6 from 14' to 16'B-6 from 14' to 16'B-6 from 14' to 16'B-6 from 14' to 16'B-6 from 14' to 16'8-9 from 84' to 86'B-6 from 14' to 16'
B-5 from 19' to 21'B-5 from 19' to 21'
B-4 from 10' to 12'B-6 from 29' to 31'B-1 from 74' to 76'B-9 from 84' to 86'B-9 from 24' to 26'
B-10 from 54' to 56'B-4 from 39' to 41'
J B-6 from 14' to 16'B-5 from 19' to 21'B-5 from 19' to 21'B-6 from 14' to 16'B-9 from 84' to 86'B-4 from 10' to 12'
B-6 from 14' to 16'B-3 from 29' to 31'B-9 from 84' to 86'B-3 from 29' to 31'B-5 from 19' to 21'B-1 from 29' to 31'B-6 from 29' to 31'B-9 from 84' to 86'B-6 from 14' to 16'B-5 from 19' to 21'B-9 from 84' to 86'B-5 from 19' to 21'B-8 from 14' to 16'B-9 from 84' to 86'B-5 from 19' to 21'B-1 from 29' to 31'B-9 from 84' to 86'B-3 from 29' to 31'B-9 from 84' to 86'
using detects only.onlv de>tected once.
100101
Table 2
Summary of Volatile Organic Compounds Detected in Groundwater
Corrjounds Uoaradient1st Round
Vinylf'h 1 APIJ^A T 1
Methylene
Carbon
1,1 Dichloro-ethene 2J-5
1,1 Dichloro-othane 3J-8
1,2 Dichloro-ethene 20X-48X
Chloroform 6
1,2 Dichloro-uthane 5-6
1,1,1 Trichloro-ethane 3J-16
Carbon Tetra-chloride 3J
1,2 Dichloro-proparve 1J-9
Trichloroethene 5
4 Methyl -2
Tetrachloroethene 2J-3J
Vulanoe ....
Shallow Wells2nd Round
1J-10
4J-10
3JX-26X
6
4J-5
4J-40
3J
1J-14
5-7
1 t.9 I
—
2J-3J
5.A
1 I
1.1
Oaradient1st Round
9 t.c i
2J-14
4J-26
33X-170X
2J-8
6-12
9J-47J
1J-5
2J-3J
2J-60
3J-6
9 i
97
isnv
Shallow Wells Uoqradient2nd Round 1st Round
6-14 3J-7
4J-38 11-17
15-99X 120X-200EX
2J-8 8-17
2J-11 6-9
5-51 9-15
2J-3J 14-27
2J-3J 4J-5
3J-OI 5
2J-30 18-25
cJOJ -•
2J-7 13-15.
8./D \ 1
i«n-5?np mv
Deeo Wells Dgradient2nd Round 1st Round
c 1 9 l.fi 1
2J-7 5J-8
8-28 16-21
4JX-130X 190X-240X
11-36 10-17
5-18 6-24
7-19 13-18
13-29 15-28
4J-18" 3J-7J
2J-31 22-24
— — :.
2J-20 7J-14
Deeo Wells2nd Round
A 1. 19
1J-8
10-19
11-110X
4J-17
2J-22
8-19
2J-29
2J-9
2J
3J-29
ZJ-7
__-••
3J-18
1 J- 17
All concentrations are in micrograms per liter (ug/L).
Upgradient shallow aquifer wells include GH-2S, GM-5S and GH-6S.Downgradient shallow aquifer wells include KW-1, HW-2, GM-1S, GM-3RS, MW-4, GH-7S and GM-8SUpgradient deep aquifer wells include GM-2D, GM-50 and GM-6D.Downgradient deep aquifer wells include GM-1D, GM-3D, GM-40, GM-7D, GM-80 and HPWC Well #1.-- = Not DetectedJ = Estimated ValueX = Combination of two or more isomersI - Concentration exceeds calibration range of instrument
100102
Table 3
Surmary of Semi-Volatile Organic Compounds Detected in Groundwater
All concentrations are in micrograms per liter (ug/L).
Upgradient shallow aquifer wells include GH-2S, GM-5S and GM-6S.Downgradient shallow aquifer wells include MW-1, MW-2, GM-1S, GM-3RS, HW-4, GM-7S and GM-8SUpgradient deep aquifer wells include GM-2D, GH-5D and GM-60.Downgradient deep aquifer wells include GM-1D, GM-30, GM-4D, GM-7D, GM-80 and MPUC Well #1.
••- = Not Detected.1 = Estimated Value
100103
Table 4
Surmary of Inorganic Compounds Detected in Groundwater (Unfiltered Samples)
Compounds Upgradient Shallo1. Wells
Muni nun.
Arseni c
Barium
Beryllium .
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Hercury
Nickel
Potassium
Selenium
Sodium
\lanaHi i mvsnaui ura
Zinc
1688-446
55.08-92.68
7340-15000
11.0-77.5
15. 3B .
6.28-27.5
357-1070
4.6B-7.4
3700-8850
35.9-242
1.9
18.0B-49.6
3430B- 12200
9290-25700
28.5-44.0
Dqradient Shallow Wells
1168-36600
4 no -7ft A. Uo rO.D
69.4B-220
2.2B-2.6B
7300-26600
11.4-135
8.8B-74.4
7.8B-210
266-70400
3.1B-52.2
1490B- 13000
150-3400
.7-6
17.7B-117
2660B- 12500
2.3B
7070-24700
7 TD.1 19• 3D "1 l£
27.9-?38
Upqradient Deep Wells
350-565
658-1118
14400-28800
3.4B-54.1
11.5B-16.9B
8.8B-30.8
388-1140
5.1-17.4
3180B-4900B
186-266
.5-1.1
21.3B-25.0B
11800-37700
14300-20800
37.7-59.5
Dgradient Deep Wells
96.3B-4630
2 no. 9 AD.Ub'c.oo
56.4B-155B
1.08
7930-32600
6.1B-48
8.8B-29.7B
9.9B-52.1
129-4120
2.3B-14.1
3140B-4600B
98.4-461
.5-2.9
14.7B-32.3B
25008-17000
2.9B
9030-30900
H 7D /I / D. ia-<tl ,4B
41.9-78.2
All concentrations are in micrograms per liter (ug/L).
Upgradient shallow aquifer wells include GH-2S, GH-5S and GH-6S.Downgradient shallow aquifer wells include MW-1, HW-2, CM-1S, GH-3RS, MU-4, GM-7S and GM-8SUpgradient de«p aquifer wells include GH-2D, GM-5D and GM-60.Downgradient deep aquifer wells include GM-1D, GM-3D, GM-4D, GM-7D, GM-80 and MPUC Well #1.
-- = Not DetectedB - Analyte was detected at a concentration less than the Contract Required Detection Limit but greaterthan the Instrument Detection Limit.
100104
TABLES
Occurrence of Constituents in the Shallow Aquifer Upgradisnt of the Swope Oil and Chemical Company Site,Pennsauken, New Jersey.
• x/y; where x - number of samples with analytical results above the detection limit.samples analyzed.
6.3
27075
12,00033IS18
6206.0
5,7001201.934
6,60016,000
35
0.210.06
andy - the total
11.0
530110
19,00098-
371,300
1510,000
300-
13015,00031,000
49
0.980.09
number of
b Arithmetic mean using detects only.UCL Upper 95 percent confidence limit.
Constituent was detected only once; 95 percent UCL cannot be calculated.Constituent was only detected once.Upgndient ih&Dow (quite web include GM-2S, GM-SS lad GM-6SDowngmSeol ifadov aquifer welb include MW-1. MW-2, CM-IS, GM-3RS, MW-4, GM-7S aad OM-8S
CoaceirtnUoai hive bees iDmxfad off
100105
TABLE 6Occurrence of Constituents in the Shallow Aquifer Downgradiem of the Swope Oil and Chemical Company Site,Pennsauken, New Jersey.
All concentrations are reported in micrograms per liter (ug/L).
a x/y; where x » number of samples with analytical results above the detection limit, and y «samples analyzed.
b Arithmetic mean using detects only.c Cyanide was not analyzed for in the May 1990 sampling event and resultsUCL Upper 95 percent confidence limit.
Constituent was detected only once; 95• Constituent was detected once.JOt ThrlTI Jrrr Prim iitm -M rthititirri »
ConceniraUom hive been noDded offT TnffWftHiMrt BlkAlUw Afiulfor M»tk fa^jiwl*
percent UCL cannot be calculated.
line an laoonect »•*••* oooceoftnttak
nu_9« flu.** «_• siu_£e
the total number of
from January 1990 were used.
•
100106
TABLET
Acceptable Doses* (ADs), Cancer Slope Factors (CSFs), and USEPA Cancer Classificationfor Constituents of Concern at the Swope Oil and Chemical Company Site, Pennsauken,New Jersey.
NOTE: Data in parenthesis indicate inhalation value not available; oral value used." Chronic ADs are listed; subchronic ADs are assumed to be 10 times the chronic AD. The term AD
in this context is used synonymously with the term RfD.a USEPA, 1990.b IRIS, 1990.c ATSDR, 1989a.d USEPA, 1987.e ATSDR, 1988b.f No USEPA verified data available; AD derived from RTEC, 1985.g ATSDR, 1989b.h USEPA, 1986b.i Assumes toxicity of naphthalene from USEPA, 1990.j Criteria provided are for Chromium VI.
100107
TABLES
NONCARCIMOGEN 1C RISK ESTIMATES (HAZARD INDICES) FOR THE SWOPE OIL AND CHEMICAL COMPANY SITE
(ALL RISKS ARE FOR POTENTIAL EXPOSURE TO SHALLOW AOUIFER GROUNMIATER)
Route Potentially Exposed Populations
Hngestion
Dermal
Inhalation
Total Receptordisk
Adult7 vear exposure
1.3
.0018
1.3
Worker20 year exposure
1.3
.0018
1.3
9-year exposure
3.8
.0054
.059
3.9
Residents30-vear exposure
3.8
.0054
-059
3.9
70-year exposure
3.8
.0054
.059
3.9
100108
TABUE9
Route
CARCINOGENIC RISK ESTIMATES FOR THE SWOPE OIL AND CHEMICAL COMPANY SITE
(ALL RISKS ARE FOR POTENTIAL EXPOSURE TO SHALLOW AQUIFER GROMDUATER)
Air sampling 12 air samples (VOC analysis) $10.000(one/month)
Subtotal: . $318,000
Contingency (25%) $79.000
Subtotal: $397,500
Soil Remedial Action Alternative 2 Total Cost:' $2.099.000
100112
APPENDIX C - ADMINISTRATIVE RECORD INDEX
100113
DOCUMENT NUMBER INDEX
100114
08/26/91 Index Document Number Order • Page: 1SWOPE OIL SITE, OPERABLE .UNIT #2 Documents
Oocunent Number: SOP-001-0001 To 0239 Date: 07/01/88
Title: Operations Plan for the Supplemental Remedial Investigation/Feasibility Study at the SwopeOil end Chemical Company Site, Pennsauken Township, Camden County, New Jersey (Second. Revision)
Type: PLANAuthor: Wolfert, Michael f.: Geraghty & Killer
Recipient: none: none
Document Number: SOP-001-0240 To M27 • Date: 07/01/88
Title: Addendum to the Operations Plan for the Swope Oil and Chemical Company Site, Pennsauken, NewJersey (Second Revision)
Type: PLANAuthor: Wolfert, Michael F.: Geraghty & Mi Her
Recipient: none: none
Document Number: SOP-001-0428 To 0519 Date: 09/01/87
Title: Design Sampling Work Plan
Type: PLANAuthcr: none: none
Recipient: none: Swope Oil Company site
Document Number: SOP-001-0520 To 0589 . • Date: 09/01/87
Title: Work Plan for Supplemental Remedial Investigation/Feasibility Study at the Swope Oil and ChemicalCompany Site, Pennsauken Township, Camden County, New Jersey (Secoivj Revision)
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
100115
08/26/91 Index Docunent Number OrderSWOPE OIL SITE, OPERABLE UNIT #2 Documents
Page: 2
SSSSSSSSSS a SSSSSSSSSSSSSSSSSSSSSS5SSSSSSSCSS=S5S=======S===SSSSS=5=SS=SS
Dociment Number: SOP-001-0590 To 0854 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Suope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume I of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document: Number: SOP-001-0855 To 0905 - Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey - Volume II of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-0906 To 1333 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey - Volume III of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number:-SOP-001-1334 To 1713 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume IV of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
100116
08/26/9 'i Index Document Number Order Page: 3SUOPE OIL SITE, OPERABLE UNIT *2 Documents
Documem Number: SOP-001-1714 To 1932 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,I'ennsauken Township, Camden County, New Jersey, Volume V of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document number: SOP-001-1933 To 1933 • Date: 05/22/91
-Title: (Letter approving the Supplemental Remedial Investigation (RI) Report-for the Swope Oil andChemical Company site and forwarding the Addendum Report)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Document Number: SOP-001-1934 To 2014 Parent: SOP-001-1933 Date: 05/01/91
Title: Addendum to the Supplemental Remedial Investigation for the Swope Oil and Chemical CompanySite
Type: REPORTAuthor: none: US EPA
Recipient: none: none
Document Nuit>er:-SOP-001-2015 To 2015 Date: 03/13/91
Title: (Letter discussing the obtaining of an Industrial Pretreatment Permit to discharge treatedground water from the Swope Oil site)
Type: CORRESPONDENCE
Author: Loperfido,' Samuel N., Jr.: Camden County Municipal Utilities AuthorityRecipient: Cowers, Joseph A.: US EPA
100117
08/26/91 Index Docunent Number Order Page: 4SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Docunent Number: SOP-001-2016 To 2017 . Date: 02/27/91
Title: (Letter advising of the results of discussions with the Camden County Municipal UtilitiesAuthority (CCHUA) and the Pennsauken Sewerage Authority (PSA) with regard to the acceptanceof treated groundwater from the Suope Oil site)
Type: CORRESPONDENCEAuthor: Vernick, Arnold S.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPA
Document Number: SOP-001-2018 To 2019 ' Date: 07/06/90 .
Title: (Letter approving the Feasibility Study (FS) work plan for the Supplemental RI/FS)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Recipient: Diks, Diane: DeSoto
Document Number: SOP-001-2020 To 2020 Date: 04/17/90
Title: (Letter forwarding the attached memorandum addressing conments provided in EPA's February5>, 1990, memo in connection with the inorganic data validation for the deep soil boring program)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPAAttached: SOP-001-2021
Document Number:_SOP-001-2021 To 2038 Parent: SOP-001-2020 Date: 04/10/90
Title: (Memorandum) US EPA Comments on the Inorganic Data Validation of the Soil Samples Collectedfit the Swope Oil and Chemical Company Site, Pennsauken, New Jersey, During the Deep Soil BoringProgram
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Recipient: none: US EPA
100118
08/26/9'! Index Document Number Order Page: 5SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Nuifcer: SOP-001-2039 To 2039 Date: 04/17/90
Title: (Letter forwarding the attached memorandum addressing comments provided in EPA's December20, 1989, letter in connection with the Organic Data Validation for the deep soil boring program)
Type: CORRESPONDENCE ~Author: Newton, Douglas J.: Geraghty & Miller
Recipient: Jackson, Amelia: US EPAAttached: SOP-001-2CKO
Document: Number: SOP-001-2040 To 2052 Parent: SOP-001-2039 Date: 03/29/90
Title: (Memorandum) US EPA Comments Concerning Suope Oil and Chemical Company Site Organic Data Validationfor Soil Samples Collected During the Deep Soil Boring Program
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Recipient: none: US EPA
Document Number: SOP-001-2053 To 2055 Date: 11/01/89
Title: (Letter approving an amendment to the Operations Plan for the Supplemental Rl/FS, locationof doungradient wells, and a time extension for the Draft RI Report submittal)
Type: CORRESPONDENCEAuthor: Pavlou, George: US EPA
Recipient: Diks, Diane: DeSoto
Document: Number:-SOP-001-2056 To 2057 ~ -— ~- Date: 10/20/88
Title: (Letter following-up on 0 telephone conversation indicating that EPA is in agreement withthe list of analyses to be performed on the soil samples that Mill be collected at the SwopeOil site)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Dunkelman, Thomas: US EPA
100119
08/26/91 Index Document Number Order Page: 6SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-2058 To 2060 Date: 10/14/83
Title: (Letter approving several changes to the Operations Plan (OP) for the Supplemental RI/FS atthe Swope Oil site and forwarding additional comments on the Addendum of the OP)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Oiks, Diane: DeSoto
Document Number: SOP-001-2061 To 2063 - Date: 09/19/88
Title: (Letter describing concerns about the proposed locations for Wells GM-2D, GM-5s;-and CM-5D.Soil boring location map attached)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Dunkelman, Thomas: US EPA
Document Number: SOP-001-2064 To 2064 Date: 08/30/88
Title: (Letter stating that EPA approves the Operations Plan for the Supplemental RI/FS at the SwopeCil and Chemical Company site, as well as the Addendum to the Operations Plan)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Diks, Diane: DeSoto
Document Number:_SOP-001-2065 To 2065- Date: 01/13/88
Title: (Letter stating that EPA approves the Swope Oil and Chemical Company Work Plan for the SupplementalRI/FS and that deep soil borings must be performed as part of the RI/FS)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Walanski, K.A.: DeSoto
100120
02/26/91 Index Document Number Order ' Page: 7SWOPE OIL SITE, OPERABLE UNIT *2 Documents
Doevjiient Number: SOP-001-2066 To 2067 Date: 01/05/88
Title: (Letter confirming a December 7, 1987, conversation discussing the implementation of a soiltoring program at the Swope Oil site)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Valanski, K.A.: OeSoto
Document Number: SOP-001-2068 To 2073 - Date: 10/20/87
Title: (Letter stating that EPA approves ERT's Design Sampling Work Plan (September, 1987} for theiiwope Oil and Chemical Company site provided that the attached modifications are complied with(luring the appropriate activities)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Nicoloro, Robert: ERT
Document Number: SOP-001-2074 To 2087 Date: 06/01/90
Title: feasibility Study Work Plan, Swope Oil and Chemical Company Site, Pennsauken Township, CamdenCounty, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: Swope Cleanup Committee
Document Number: SOP-001-2088 To 2249 Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site; Pennsauken Township,Camden County, New Jersey, Volume I of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
100121
08/26/9'! ' Index Document Number Order Page: 8SUOPE OIL SITE, OPERABLE UNIT #2 Documents •
Document Number: SOP-001-2250 To 2380 . Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume II of IV
Type: PLANAuthor: none: Gereghty & Miller
Recipient: none: none
Document Number: SOP-002-0001 To 0242 - Date: 05/0.1/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site, Pennsauken Township,- Camden County, New Jersey, Volume III of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-002-0243 To 0479 Date: 05/01/91
Title: Risk Assessment for the Swope Oil and Chemical Company Site, Pennsauken Township, Camden County,Hew Jersey, Volume IV of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number:-SOP-002-0480 To 0494 Date: 07/01/91
Title: Shallow Ground-Water Monitoring Plan of the Supplemental Feasibility Study for the Swope Oilnnd Chemical Company Site, Pennsauken Township, Camden County, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
100122
08/26/91 Index Document Number Order Page: 9SWOPE OIL SITE, OPERABLE UNIT *2 Documents
Docunent Number: SOP-002-0495 To 0526 Date: / /
Title: Addendum to the Supplemental Feasibility Study and Risk Assessment for the Suope Oil and ChemicalCompany Site
Type: PLAN ' -Author: none: US EPA
Recipient: none: none
Document Number: SOP-002-0529 To 0542 - Date: 07/01/91
Title: Super-fund Program Proposed Plan: Swope Oil end Chemical Company Site, Pennsauken Township,New Jersey
Type: PLANAuthor: none: none
Recipient: none: none
Document Number: SOP-002-0543 To 0543 Date: 07/15/91
Title: (Letter amending and approving the May 1991 Supplemental FS and Risk Assessment Reports forthe Swope Oil and Chemical Company site)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Recipient: Nicoloro, Robert: ENSR
Document Number:-SOP-002-0544 To 0546 Date: 12/13/90
Title: (Letter submitting New Jersey State applicable or relevant and appropriate requirements (ARARs)which pertain to the Swope Oil and Chemical site located in Pennsauken Township, New Jersey}
Type: CORRESPONDENCEAuthor: Curtis, Ian R.: NJ Dept of Environmental Protection
Recipient: Cowers, Joseph A.: US EPA
100123
08/26/91 Index Document Number Order Page: 10SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-002-0547 To 0547 , Date: 11/15/90
Title: (Letter in which EPA requests that the New Jersey Department of Environmental Protection (NJDEP)provide all New Jersey state ARARs regarding the discharge of treated groundwater from thesite to the Pennsauken Creek and the Delaware River)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipiert: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Nunber: SOP-002-0548 To 0548 Date: 06/04/90 •
Title: (Letter requesting additional New Jersey state ARARs)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Nunber: SOP-002-0549 To 0549 Date: 02/26/90
Title: (Letter requesting information regarding state ARARs and concerns as they pertain to the SwopeOil and Chemical Company site)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Nimber:-SOP-002-0550 To 0578 ' Date: 09/30/86
Title: Administrative Order on Consent, Index No. II CERCLA-60113, Swope Oil Superfund Site
Type: LEGAL DOCUMENTAuthor: Daggett, Christopher J.: US EPA
Recipient: none: various parties associated with the site
100124
08/26/91 Index Docunent Number Order Page: 11SWOPE OIL SITE, OPERABLE UNIT *2 Documents
08/26/91 Index Author Name Order Page: 1SUOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-0428 To 0519 Date: 09/01/87
Title: Design Sampling Work Plan
Type: PLANAuthor: none: none
Recipient: none: Suope Oil Company site
Document: Nunber: SOP-002-0529 To 0542 Date: 07/01/91
Title: Superfund Program Proposed Plan: Swope Oil and Chemical Company Site, Pennsauken Township,. ~ Hew Jersey ' '~'~ ' ' ' - , . - ' - -- - -- ~
Type: PLANAuthor: none: none
Recipient: none: none
Document: Number: SOP-001-0520 To 0589 Date: 09/01/87
Title: Work Plan for Supplemental Remedial Investigation/Feasibility Study at the Swope Oil and ChemicalCompany Site, Pennsauken Township, Camden County, New Jersey (Second Revision)
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-0590 To 0854 • Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site, ~ "" ~Pennsauken Township, Camden County, New Jersey, Volume I of V
Type: REPORTAuthor: none:. Geraghty & Miller
Recipient: none: none
100127
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Document Number: SOP-001-0855 To 0905 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Permsauken Township, Camden County, New Jersey - Volume II of V
Type: REPORT " -Author: none: Geraghty & Hi Her
Recipient: none: none
Document Number: SOP-001-0906 To 1333 - Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site, ~Pennsauken Township, Camden County, New Jersey - Volume III of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-1334 To 1713 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume IV of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number:-SOP-001-1714 To 1932 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume V of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
100128
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Document Number: SOP-001-1934 To 201.4 Parent: SOP-001-1933 Date: 05/01/91
Title: Addendum to the Supplemental Remedial Investigation for the Suope Oil and Chemical CompanySite
Type: REPORTAuthor: none: US EPA
Recipient: none: none
Document Number: SOP-001-2021 To 2033 Parent: SOP-001-2020 Date: 04/10/90
Title: (Memorandum) US EPA Comments on the Inorganic Data Validation of the Soil Samples Collected -- —at the Suope Oil and Chemical Company Site, Pennsauken, New Jersey, During the Deep Soil BoringProgram
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Recipient: none: US EPA
Document Neuter: SOP-001-2040 To 2052 Parent: SOP-001-2039 Date: 03/29/90
Title: (Memorandum) US EPA Comments Concerning Swope Oil and Chemical Company Site Organic Data Validationfor Soil Samples Collected During the Deep Soil Boring Program
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Title: Feasibility Study Work Plan, Swope Oil and Chemical Company Site, Pennsauken Township, CamdenCounty, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: Swope Cleanup Committee
100129
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Document Number: SOP-001-2088 To 2249 Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site; Pennsauken Township,Camden County, New Jersey, Volume I of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-2250 To 2380 • . Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume II of IV
Ty(3e: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-002-0001 To 0242 Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume III of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number:-SOP-002-0243 To 0479 Date: 05/01/91
Title: Risk Assessment for the Swope Oil and Chemical Company Site, Pennsauken Township, Camden County,New Jersey, Volume IV of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
100130
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Document Number: SOP-002-0480 To 0494 Date: 07/01/91
Title: Shallow Ground-Water Monitoring Plan of the Supplemental Feasibility Study for the Swope Oiland Chemical Company Site, Permsauken Township, Camden County, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-002-0495 To 0528 - Date: / /
Title: Addendum to the Supplemental Feasibility Study and Risk Assessment for the Swope Oil and ChemicalCompany Site
Type: PLANAuthor: none:. US EPA
Recipient: none: none
Document Number: SOP-002-0608 To 0617 Date: 04/06/89
Title: Health Assessment for Suope Oil Company, Pennsauken, Camden County, New Jersey CERCLIS No.NJD041743220 .
Document Number:-SOP-001-1933 To 1933 . Date: 05/22/91
Title: (Letter approving the Supplemental Remedial Investigation (RI) Report for the Suope Oil andChemical Company site and forwarding the Addendum Report)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
08/26/91 Index Author Name Order page: 5SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-2018 To 2019 Date: 07/06/90
Title: (Letter approving the Feasibility Study (FS) work plan for the Supplemental RI/FS)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Recipient: Diks, Diane: DeSoto
Document Number: SOP-002-0543 To 0543 Date: 07/15/91
Title: (Letter amending and approving the May 1991 Supplemental FS and Risk Assessment Reports for '- the Swope Oil and Chemical Company site) " " ' " " . . "
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Recipient: Nicoloro, Robert: ENSR
Document Number: SOP- 002- 0544 To 0546 Date: 12/13/90
Title: (Letter submitting New Jersey State applicable or relevant and appropriate requirements (ARARs)which pertain to the Swope Oil and Chemical site located in Pennsauken Township, New Jersey)
Type: CORRESPONDENCEAuthor: Curtis, Ian R.: NJ Dept of Environmental Protection
Recipient: Cowers, Joseph A.: US EPA
Document Number: SOP-001-2058 To 2060 - Date: 10/14/88
Title: (Letter approving several changes to the Operations Plan (OP) for the Supplemental RI/FS atthe Swope Oil site and forwarding additional conments on the Addendum of the OP)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Diks, Diane: DeSoto
100132
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Document Number: SOP -00 1-2064 To 2064 Date: 08/30/88
Title: (Letter stating that EPA approves the Operations Plan for the Supplemental RI/FS at the SwopeOil and Chemical Company site, as well as the Addendum to the Operations Plan)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Oiks, Diane: DeSoto
Document Number: SOP -00 1-2065 To 2065 • Date: 01/13/88
-Title: {Letter stating that EPA approves the Suope Oil and Chemical Company Work Plan for the SupplementalRI/FS and that deep soil borings must be performed as part of the RI/FS)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Walanski, K.A.: DeSoto
Document Number: SOP-002-0550 To 0578 Date: 09/30/86
Title: Administrative Order on Consent, Index No. II CERCLA-60113, Swope Oil Superfund Site
Type: LEGAL DOCUMENTAuthor: Daggett, Christopher J.: US EPA
Recipient: none: various parties associated with the site
Document Number: SOP-002-0547 To 0547 r Date: 11/15/90
Title: {Letter in which EPA requests that the New Jersey Department of Environmental Protection (NJDEP)provide all New Jersey state ARARs regarding the discharge of treated groundwater from thesite to the Permsauken Creek and the Delaware River)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
100133
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Document Number: SOP-002-0548 To 0548 Date: 06/04/90
Title: (Letter requesting additional New Jersey state ARARs)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Oept of Environmental Protection
Document Number: SOP-002-0549 To 0549 Date: 02/26/90
Title: (Letter requesting information regarding state ARARs and concerns as they pertain to the Swope._ -_ ~ Oil and Chemical Company site) ~
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Number: SOP-001-2066 To 2067 Date: 01/05/88
Title: (Letter confirming a December 7, 1987, conversation discussing the implementation of a soilboring program at the Swope Oil site)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Ualanski, K.A.: DeSoto
Document Number: SOP-001-2068 To 2073 • Date: 10/20/87
^Tltle: {Letter stating that EPA approves ERT's Design Sampling Work Plan (September, 1987) for theSwope Oil and Chemical Company site provided that the attached modifications are complied withduring the appropriate activities)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Nicoloro, Robert: ERT
100134
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Document Number: SOP-002-0591 To 0596 Date: 04/28/86
Title: (107(a) Notice Letter - mailing list attached)
Type: CORRESPONDENCEAuthor: Librizzi, William J.: US EPA
Recipient: none: various PRPs
Docunent Number: SOP-002-0597 To 0607 Date: 04/18/86
Title: (107(a) Notice Letter - mailing list attached)
Type: CORRESPONDENCEAuthor: Librizzi, William J.: US EPA
Recipient: none: various PRPs
Document Number: SOP-001-2015 To 2015 Date: 03/13/91
Title: (Letter discussing the obtaining of an Industrial Pretreatment Permit to discharge treatedgroundwater from the Swope Oil site)
Typ«: CORRESPONDENCEAuthor: Loperfido, Samuel H., Jr.: Camden County Municipal Utilities Authority
Recipient: Cowers, Joseph A.: US EPA
Document Number: SOP-002-0579 To 0590 Date: 09/05/86
Title: (107(a) Notice Letter - mailing list attached)
Type: CORRESPONDENCEAuthor: Marshall, James R.: US EPA
Recipient: none: various PRPs
Document Number: SOP-001-2020 To 2020 Date: 04/17/90
Title: (Letter forwarding the attached memorandum addressing comments provided in EPA's February5, 1990, memo in connection with the inorganic data validation for the deep soil boring program)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPAAttached: SOP-001-2021
100135
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Document Number: SOP-001-2039 To 2039 Date: 04/17/90
Title: (Letter forwarding the attached memorandum addressing comments provided in EPA's December20, 1989, letter in connection with the Organic Data Validation for the deep soil boring program)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Jackson, Amelia: US EPAAttached: SOP-001-2040
Document Number: SOP-001-2056 To 2057 • Date: 10/20/88
Title: (Letter following-up on a telephone conversation indicating that EPA is in agreement withthe list of analyses to be performed on the soil samples that will be collected at the SwopeOil site)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Dunk el men, Thomas: US EPA
Document Number: SOP-001-2061 To 2063 Date: 09/19/88
Title: (Letter describing concerns about the proposed locations for Wells GM-2D, GM-5S, and GM-5D.Soil boring location map attached)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Dunkelman, Thomas: US EPA
Docuttent Number: SOP-001-2053 To 2055 " " Date: 11/01/89
Title: (Letter approving an amendment to the Operations Plan for the Supplemental RI/FS, locationof downgradient wells, end a time extension for the Draft RI Report submittal)
Type: CORRESPONDENCEAuthor: Pavlou, George: US EPA
Recipient: Diks, Diane: DeSoto
100136
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Document Number: SOP-001-2016 To 2017 Date: 02/27/91
Title: (Letter advising of the results of discussions with the Camden County Municipal UtilitiesAuthority (CCMUA) and the Permsauken Sewerage Authority (PSA) with regard to the acceptanceof treated groundwater from the Swope Oil site)
Type: CORRESPONDENCE .Author: Vernick, Arnold S.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPA
Document Number: SOP-001-0001 To 0239 Date: 07/01/88
Title: Operations Plan for the Supplemental Remedial Investigation/Feasibility Study at the SwopeOil and Chemical Company Site, Permsauken Township, Camden County, New Jersey (Second Revision)
Type: PLANAuthor: Uolfert, Michael f.: Geraghty & Miller
Recipient: none: none
Document Nunber: SOP-001-0240 To 0427 Date: 07/01/88
Title: Addendum to the Operations Plan for the Swope Oil and Chemical Company Site, Pennsauken, NewJersey (Second Revision)
Type: PLANAuthor: Wolfert, Michael F.: Geraghty & Miller
Recipient: none: none
100137
CHRONOLOGICAL INDEX
100138
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Docunent Nunber: SOP-002-0495 To 0528 , Date: / /
Title: Addendum to the Supplemental Feasibility Study and Risk Assessment for the Swope Oil and ChemicalCompany Site
Type: PLAN ' . -Author: none: US EPA
Recipient: none: none
Docunerit Hunter: SOP-002-0597 To 0607 - Date: 04/18/86
Title: (107(a) Notice Letter - mailing list attached) — . . ______ - _.
Type: CORRESPONDENCEAuthor: Librizzi, William J.: US EPA '
Title: (107(a) Notice Letter - mailing list attached)
Type: CORRESPONDENCE*or: Librizzi, William J.: US EPA
Recipient: none: various PRPs
Docunent Number: SOP-002-0579 To 0590 Date: 09/05/86
Title: (107(a) Notice Letter - mailing list attached)
Type: CORRESPONDENCEAuthor: Marshall, James R.. US EPA
Recipient: none: various PRPs
Docunent Number: SOP-002-0550 To 0578 Date: 09/30/86
Title: Administrative Order on Consent, Index No. II CERCLA-60113, Swope Oil Superfund Site
Type: LEGAL DOCUMENTAuthor: Daggett, Christopher J.: US EPA
Recipient: none: various parties associated with the site
100139
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Docunent Number: SOP-001-0428 To 0519 Date: 09/01/87
Title: Design Sampling Work Plan
Type: PLANAuthor: none: none"
Recipient: none: Swope Oil Company site
-ocument Number: SOP-001-0520 To 0589 Date: 09/01/87X
Title: Work Plan for Supplemental Remedial Investigation/Feasibility Study at the Swope Oil and ChemicalCompany Site, Pennsauken Township, Camden County, New Jersey (Second Revision) ^- - . -----
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-2068 To 2073 ' Date: 10/20/87
Title: (Letter stating that EPA approves ERT's Design Sampling Work Plan (September, 1987) for theSwope Oil and Chemical Company site provided that the attached modifications are complied withduring the appropriate activities)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Nicolc.-o, Robert: ERT
Document Nunber:-SOP-001-2066 To 2067 Date: 01/05/88
Title:: (Letter confirming a December 7, 1987, conversation discussing the implementation of a soilboring program at the Swope Oil site)
Type: CORRESPONDENCEAuthor: Guarraia, Philip D.: US EPA
Recipient: Walanski, K.A.: DeSoto
100140
08/26/91 Index Chronological Order Page: 3SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-2065 To 2065 . Date: 01/13/88
Title: (Letter stating that EPA approves the Swope Oil and Chemical Company Work Plan for the Supplemental. RI/FS and that deep soil borings must be performed as part of the RI/FS)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Walanski, K.A.: DeSoto
Document Number: SOP-001-0001 To 0239 - -Date: 07/01/88
Title: Operations Plan for the Supplemental Remedial Investigation/Feasibility Study at the Swope ~Oil and Chemical Company Site, Pennsauken Township, Camden County, New Jersey (Second Revision)
Type: PLAN.thor: Uolfert, Michael F.: Geraghty & Hi Her
kecipient: none: none
Document Number: SOP-001-0240 To 0427 Date: 07/01/88
Title: Addendum to the Operations Plan for the Swope Oil and Chemical Company Site, Pennsauken, NewJersey (Second Revision)
Type: PLANAuthor: Uolfert, Michael F.: Geraghty S Miller
Recipient: none: none
Document Number :-SOP-001 -2064 To 2064 Date: 08/30/88
Title: (Letter stating that EPA approves the Operations Plan for the Supplemental RI/FS at the SwopeOil and Chemical Company site, as well as the Addendum to the Operations Plan)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Diks, Diane: DeSoto
100141
08/26/91 Index Chronological Order Page: 4SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Hunter: SOP-001-2061 To 2063 . Date: 09/19/88
Title: (Letter describing concerns about the proposed locations for Wells GM-2D, GH-5S, and GM-5D.Soil boring location map attached)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Dunkelman, Thomas: US EPA
Document Number: SOP-001-2058 To 2060 - Date: 10/14/88
Title: (Letter approving several changes to the Operations Plan (OP) for the Supplemental RI/FS atthe Swope Oil site end forwarding additional comments on the Addendum of the OP)
Type: CORRESPONDENCEAuthor: Czapor, John V.: US EPA
Recipient: Diks, Diane: DeSoto
Document Number: SOP-001-2056 To 2057 Date: 10/20/88
Title: (Letter following-up on a telephone conversation indicating that EPA is in agreement withthe list of analyses to be performed on the soil samples that will be collected at the SuopeOil site)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
08/26/91 Index Chronological Order Page: 5SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-2053 To 2055 Date: 11/01/89
Title: (Letter approving an amendment to the Operations Plan for the Supplemental Rl/FS, location• of doungradient wells, and a time extension for the Draft RI Report submittal)
Type: CORRESPONDENCEAuthor: Pavlou, George: US EPA
Recipient: Oiks, Diane: DeSoto
Document Number: SOP-002-0549 To 0549 . - . Date: 02/26/90
Title: (Letter requesting information regarding state ARARs and concerns as they pertain to the SwopeOil and Chemical Company site)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Number: SOP-001-2040 To 2052 Parent: SOP-001-2039 Date: 03/29/90
Title: (Memorandum) US EPA Comments Concerning Swope Oil and Chemical Company Site Organic Data Validationfor Soil Samples Collected During the Deep Soil Boring Program
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Recipient: none: US EPA
Document Number:-SOP-001-2021 To 2038 Parent: SOP-001-2020 Date: 04/10/90
Title: (Memorandum) US EPA Comments on the Inorganic Data Validation of the Soil Samples Collectedat the Swope Oil and Chemical Company Site, Pennsauken, New Jersey, During the Deep Soil BoringProgram
Type: CORRESPONDENCEAuthor: none: Geraghty & Miller
Recipient: none: US EPA
100143
08/26/91 Index Chronological Order . Page: 6SWOPE OIL SITE, OPERABLE UNIT #2 Docunents
Document Number: SOP-001-2020 To 2020 Date: 04/17/90
Title: (Letter foruarding the attached memorandum addressing comments provided in EPA's February5, 1990, memo in connection with the inorganic data validation for the deep soil boring program)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPA. Attached: SOP-001-2021
Document Number: SOP-001-2039 To 2039 - - Date: 04/17/90
.Title: (Letter forwarding the attached memorandum addressing comments provided in EPA's December - —• —20, 1989, letter in connection with the Organic Data Validation for the deep soil boring program)
Type: CORRESPONDENCEAuthor: Newton, Douglas J.: Geraghty & Miller
Recipient: Jackson, Amelia: US EPAAttached: SOP-001-2040
Document Number: SOP-001-2074 To 2087 Date: 06/01/90
Titles Feasibility Study Work Plan, Swope Oil and Chemical Company Site, Pennsauken Township, CamdenCounty, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: Swope Cleanup Committee
Document Nunber:_SOP-002-0548 To 054S Date: 06/04/90
Title: (Letter requesting additional New Jersey state ARARs)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Oept of Environmental Protection
100144
08/26/91 Index Chronological Order Page: 7SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-2018 To 2019 Date: 07/06/90
Title: (Letter approving the Feasibility Study <FS) «ork plan for the Supplemental RI/FS)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
Recipient: Diks, Diane: DeSoto
Document Number: SOP-002-0547 To 0547 Date: 11/15/90
Title: (Letter in which EPA requests that the New Jersey Department of Environmental Protection (NJDEP).-~ - provide all New Jersey state ARARs regarding the discharge of treated groundwater from the --
site to the Pennsauken Creek and the Delaware River)
Type: CORRESPONDENCEAuthor: Cowers, Joseph A.: US EPA
Recipient: Curtis, Ian R.: NJ Dept of Environmental Protection
Document Number: SOP-002-0544 To 0546 Date: 12/13/90
• (Letter submitting New Jersey State applicable or relevant and appropriate requirements (ARARs)which pertain to the Swope Oil and Chemical site located in Pennsauken Township, New Jersey)
Type: CORRESPONDENCEAuthor: Curtis, Ian R.: NJ Dept of Environmental Protection
Recipient: Cowers, Joseph A.: US EPA :
Document Number:-SOP-001-2016 To 2017 Date: 02/27/91
Title: (Letter advising of the results of discussions with the Camden County Municipal UtilitiesAuthority (CCMUA) and the Pennsauken Sewerage Authority (PSA) with regard to the acceptanceof treated groundwater from the Swope Oil site)
lype: CORRESPONDENCEAuthor: Vernick, Arnold S.: Geraghty & Miller
Recipient: Cowers, Joseph A.: US EPA
100145
08/26/91 Index Chronological Order Page: 8SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Document Number: SOP-001-0590 To 0854 ' Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Suope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume I of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-0855 To 0905 • Date: 03/01/91
Title: Supplemental 'Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey - Volume II of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-0906 To 1333 ' Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil end Chemical Company Site,Pennsauken TownsKip, Camden County, New Jersey - Volume III of V
Type: REPORTAuthor: none: Geraghty & Killer
Recipient: none: none
Document Number:-SOP-001-133A To 1713 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Swope Oil and Chemical Company Site,Pennsauken Township, Camden County, New Jersey, Volume IV of V
Type: REPORTAuthor: none: Geraghty & Miller
Recipient: none: none
100146
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Document Umber: SOP-001-1714 To 1932 Date: 03/01/91
Title: Supplemental Remedial Investigation Conducted at the Suope Oil and Chemical Company Site,Pennsauken Township, Camden County, Neu Jersey, Volume V of V
Type: REPORT ' -Author: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-001-2015 To 2015 - Date: 03/13/91
Title: (Letter discussing the obtaining of an Industrial Pretreatment Permit to discharge treatedgroundwater from the Swope Oil site)
Type: CORRESPONDENCEAuthor: Loperfido, Samuel M., Jr.: Camden County Municipal Utilities Authority
Recipient: Cowers, Joseph A.: US EPA
Document Number: SOP-001-1934 To 2014 Parent: SOP-001-1933 Date: 05/01/91
Title: Addendum to the Supplemental Remedial Investigation for the Swope Oil and Chemical CompanySite
Type: REPORTAuthor: none: US EPA
Recipient: none: none
Document Number:-SOP-001-2088 To 2249 _ Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site; Pennsauken Township,Camden County, New Jersey, Volume I of IV
Type: PLAfcAuthor: none: Geraghty & Miller
Recipient: none: none
100147
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Document Number: SOP-001-2250 To 2380 Date: 05/01/91
Title: Supplemental Feasibility Study for the Suope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume II of IV
Type: PLANAuthor: none: Gereghty & Miller
Recipient: none: none
Docunent Number: SOP-002-0001 To 0242 • Date: 05/01/91
Title: Supplemental Feasibility Study for the Swope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume III of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-002-0243 To W79 Date: 05/01/91
title: Risk Assessment for the Swope Oil and Chemical Company Site, Pennsauken Township, Camden County,New Jersey, Volume IV of IV
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number:-SOP-OOM933 To 1933 •- - Date: 05/22/91
Title: (Letter approving the Supplemental Remedial Investigation (RI) Report for the Swope Oil andChemical Company site and forwarding the Addendum Report)
Type: CORRESPONDENCEAuthor: Basso, Raymond: US EPA
08/26/91 Index Chronological Order Page: 11SWOPE OIL SITE, OPERABLE UNIT #2 Documents
Oocunent Number: SOP-002-0529 To 0542 Date: 07/01/91
Title: Superfund Program Proposed Plan: Swope Oil and Chemical Company Site, Pennsauken Township,• New Jersey
. T>pe: PLAN. Author: none: none
Recipient: none: none
Document Number: SOP-002-0480 To 0494 • . Date: 07/01/91
Title: Shallow Ground-Water Monitoring Plan of the Supplemental Feasibility Study for the Swope Oiland Chemical Company Site, Pennsauken Township, Camden County, New Jersey
Type: PLANAuthor: none: Geraghty & Miller
Recipient: none: none
Document Number: SOP-002-0543 To 0543 Date: 07/15/91
Title: (Letter amending and approving the Hay 1991 Supplemental FS and Risk Assessment Reports forthe Swope Oil and Chemical Company site)
Type: CORRESPONDENCE.-::sr: Basso, Raymond: US EPA
Recipient: Nicoloro, Robert: ENSR
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APPENDIX D - NJDEPE LETTER OF CONCURRENCE
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Sep 27, 91 16:22 N.J. DEFT. OF WASTE F. 02
Scotl A. We int.-1Commissioner
State of New JerseyDepartment of Environmental Protection A".cl Energy
Mr. Conetantlne Sidamon-EristoffRegional AdministratorUSEPA Region II26 Federal PlazaNew York, 1C* 10776
Dear Mr. Sidamon-Eristoff •.
Re: Record of Decision, Svope Oil, Pentieaukea TownshipCanden County, New Jersey
This is to f omally rctify the United States Envircrvmental ProtectionAgency that the New Jersey tepartner.c of Environmental Protection and Energyhas evaiufitec* the eelected plan for the remedial action at the Swope OilSuperfur.d Sice and concurs wirh the remedy «e eteted in the- i'ir.al Record ofDecision.
This Record of Decision is for the volatile and semi-volatile organicconreolnated subsurface soils. It is understood that after the initiationof this remedial action, it will be determined whether ground waterremediation will be necessary.
The components of the Record of Decision Include:
A
ft
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Vapor extraction system;Enhanced bloremediation;Quarterly ground water itonitorlng.
New Jersey fully appreciates the importance of the Record of Decisionlr the cleanup process and will continue to take all reasonable steps toensure that the State'e commitments In this area are ir.et.
Scott A. WeinTIrCommissioner
SAW:PH/k.j
Jersey li an Cquil Opportunity Ittyjlttycr
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APPENDIX E - RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
8WOPE OIL AND CHEMICAL COMPANY SOPERFUND SITE
I. Introduction
The Swope oil and Chemical Company (Svope) site, is located in anindustrial complex in Pennsauken Township, New Jersey. From 1965to 1979, the Swope Oil and Chemical Company operated a chemicalreclamation facility at this locale. Past handling and disposalpractices have resulted in the organic contamination of soil andgroundwater. Additionally, when the facility ceased operation,significant quantities of hazardous material were left on site intanks, drums, and in a lagoon.
The Swope site was listed on the National Priorities List ofhazardous waste sites in 1983. Recognizing the complexity of thesite, the U.S. Environmental Protection Agency (EPA) isaddressing its remediation in phases or operable units. TheOperable Unit 1 remedial action resulted in the removal ofsurficial contamination. Operable Unit 2, which is the subjectof this document, addresses the remediation of contaminatedsubsurface soil which is a continuing source of groundwatercontamination. A Supplemental Remedial Investigation andFeasibility Study (RI/FS) and Addenda, which address the natureand extent of subsurface soil and groundwater contamination andevaluated alternatives for cleanup of subsurface soilcontamination, was released for public comment on July 18, 1991.
In accordance with EPA's community relations policy and thepublic participation requirements of the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA),EPA held a public comment period from July 18 through August 17,1991 to obtain comments on the Supplemental RI/FS and Addenda,and the Proposed Plan for the Swope Oil and Chemical CompanySite.
EPA held a public meeting on August 1, 1991 at the PennsaukenTownship Municipal Building, Pennsauken Township, New Jersey. Atthis meeting, EPA provided a general overview of the Superfundprocess, the site history, the results of the Supplemental RI/FSand Addenda, and discussed the Proposed Plan. Subsequent to thispresentation, EPA responded to the questions and comments ofinterested parties. A summary of the questions received duringthe public meeting and EPA's responses to them are contained inthis Responsiveness Summary.
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The Responsiveness Summary, required as part of the Superfundprocess, provides a summary of citizens' comments and concerns.Section II of this document provides a brief background of thecommunity interests and concerns regarding the site. Section IIIpresents a summary of the oral questions presented to EPA at thepublic meeting and EPA's responses to these questions. Section:CV presents a summary of the comments from the potentiallyresponsible parties and their contractor on the Addendum to theSupplemental Feasibility Study and Risk Assessment and theProposed Plan. Each question or comment is followed by EPA'sresponse. Written comments received during the public commentperiod are attached in Appendices as described below. Allcomments summarized in this document were considered in EPA'sfinal selection of the remedial alternative for cleanup of thesite.
The following Appendices have been attached to the ResponsivenessSummary:
o Appendix A - Proposed Plan and Public Comment
o Attachment A.I - Proposed PlanSwope Oil and Chemical Company SitePennsauken Township, New JerseyJuly 1991
o Attachment A.2 - Public Notice
o Attachment A.3 - August 1, 1991 Public MeetingAttendance Sheet
o Appendix B - Comments from the Swope Site CleanupCommittee and its Contractor on theProposed Plan and the Addendum to theSupplemental Feasibility Study and RiskAssessment
o Attachment B.I - July 31, 1991 Comment Letter from theSwope Site Cleanup CommitteeConcerning the Addendum to theSupplemental Feasibility Study andRisk Assessment
o Attachment B.2 - August 1, 1991 Comment Letter fromGeraghty & Miller (G&M) Concerning theAddendum to the SupplementalFeasibility Study and Risk Assessment
o Attachment B.3 - August 5, 1991 Comment Letter fromMichael L. Krancer, Regarding thePreferred Remedy
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o Attachment B.4 - August 15, 1991 Comment Letter fromG&M Concerning the Proposed Plan
o Appendix C - Letter from EPA's Contractor ConcerningG&N's Vadose Zone Modeling and Proposed SoilRemediation Levels
II. Background on community Involvement and Concerns
A Commmunity Relations Plan for the Swope site was completedin May of 1986. At that time, citizens were primarilyconcerned with the impact of the site on property values.Local officials felt that the schedule of remedialactivities should be accelerated and were concerned withthe possibility that the Swope site may contaminategroundwater aquifers and result in the shutdown of publicsupply wells.
Community interviews were held on July 10, 1991 to solicitcurrent concerns of citizens and local officials. On August1, 1991, EPA held a public meeting to present EPA's ProposedPlan for remediation of contaminated subsurface soil to thecommunity. No concerns were expressed by the public oneither occasion.
III. summary of Questions Asked During the August 1. 1991Public Meeting
This section contains inquiries made during the August 1, 1991public meeting.
1.- A resident asked whether soil samples would be collected atthe site to evaluate the effectiveness of the preferredremedy in cleaning up contaminated soil.
EPA Response: Subsurface soil and soil gas samples will becollected during operation of the soil vapor extractionsystem. The analytical results of these samples^will be used to determine the effectiveness of the treatmentsystem in remediating subsurface soil contamination.In addition, groundwater quality will be monitored duringdesign, construction and operation of the soil vaporextraction system.
2.- A representative of a potentially responsible party askedfor an estimate of the total cost incurred for site cleanupand the future cost to be incurred in this project.
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EPA Response: The estimated future cost for performance ofthe selected remedy is $2,099,000. This cost does notinclude the cost of conducting a biodegradation treatabilitystudy or the costs which may be involved with enhancingaerobic biodegradation of contaminants. A representative ofthe Swope Site Cleanup Committee has indicated to EPA thatthe total cost incurred by the potentially responsibleparties for remedial activities conducted to date isapproximately $15,000,000.
IV. suimnarv of Com|t|ents from Other Interested Parties and EPAResponses
This Section contains written comments received during the publiccomment period from the Swope Site Cleanup Committee and itstechnical consultant, Geraghty and Miller, Inc. (G&M).
It should be noted that references to the Supplemental RI/FSapply to documents prepared by G&M. The Addenda to theSupplemental RI and the Supplemental FS and Risk Assessment weredeveloped by EPA.
A. summary of Swope Site Cleanup Committee Comments on theAddendum to the Supplemental Feasibility Study and RiskAssessment, (refer to complete letter in Appendix B).
1. The Addendum Report appears to discuss New Jersey Soil ActionLevels (NJSALs) as if they might be the cleanup goals for theremediation of the subsurface soils at the Swope site. Theuse of NJSALs as cleanup standards would be whollyinappropriate since they are not promulgated Applicable orRelevant and Appropriate Requirements (ARARs). At most,the NJSALs fall within the To Be Considered (TBC) category ofenvironmental guidelines. However, as is stated in thePreamble to the National Contingency Plan (NCP), "TBCs shouldnot be required as cleanup standards in [40 C.F.R.300.400(g)(3)] because they are, by definition, generallyneither promulgated nor enforceable so they do not have thesame status under CERCLA as ARARs". The Preamble furtherprovides that "EPA believes that TBCs are meant to complementthe use of ARARs by EPA, states, and PRPs, not to be incompetition with ARARs."
EPA's decision to utilize NJSALs at this late stage in theremedy-selection process could be construed as an attempt byEPA to evade the procedural safeguards in the NCP requiringEPA to consider, inter alia, the implementability, technicalfeasibility and cost effectiveness of a remedial alternative,prior to selection of that remedy. The reference to NJSALsin the Addendum Report should therefore be deleted.
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In addition to being inappropriate and unenforceable as acleanup standard under the NCP, it should be noted thatNJSALs are also inapplicable to soil remediation plans.Under the New Jersey Environmental Cleanup ResponsibilityAct, N.J.8.A. 13:lK-6 et sea.. soil action levels are merelyused by the Mew Jersey Department of Environmental Protection(NJDEP) to determine whether remediation may be required.Once NJDEP determines that remediation is required, cleanupstandards are developed on a case-by-case basis depending onsite characteristics. N.J.S.A. !3tlK-10(a). significantly,however, NJSALs are not used as cleanup remediationstandards, not even by the NJDEP, the agency that developedthem.
Based on the foregoing, NJSALs are inapplicable andunenforceable as subsurface soil cleanup standards.Accordingly, it is recommended that EPA reconsider the use ofthe Soil Remediation Levels (SRLs) which were properlydeveloped in the Risk Assessment. The only purported basisfor use of the NJSALs as cleanup standards is that EPA couldnot verify the SRLs.
EPA Response: In the Addendum to the Supplemental FS andRisk Assessment, NJSALs were identified as cleanup goals forcontaminated subsurface soil, not promulgated ARARs.Federal and/or State regulations specifying soil cleanuplevels for contaminants of concern at the site do not exist.Because soil cleanup ARARs do not exist, the use of NJSALsdoes not place them "in competition" with ARARs at the site.Further, it is entirely consistent with EPA policy to utilizeTBCs to determine remediation goals when ARARs do not exist.
Since the NJSALs are cleanup goals and not promulgatedstandards, it is not a statutory requirement that theselevels be achieved. As specified in the Record of Decision,operation of the selected soil treatment system wouldcontinue until these cleanup goals have been met, or untilEPA determines that operation of the system is no longer "practical. Therefore, EPA maintains that regardless ofthe cleanup goals established for contaminated subsurfacesoil at the site, the selected remedy is technicallyfeasible, implementable and cost-effective. EPA furthercontends that the use of NJSALs as soil cleanup goals for thesite is appropriate, since these TBCs have been developed bythe New Jersey Department of Environmental Protection andEnergy (NJDEPE) to identify the presence of soilcontamination and have been used to establish cleanup goalsat numerous other Superfund sites.
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NJSALs have been selected as soil Cleanup goals for the sitebecause EPA is unable to conclude that the site-specific SRLsdeveloped as part of the Risk Assessment would provide foradequate groundwater protection. EPA believes that thevadose-zone transport modeling analysis conducted as part ofthe Supplemental FS is oversimplified and that the soilremediation levels developed based upon the results of thismodel may not be sufficient to prevent the leaching ofcontaminants into groundwater at levels in excess ofgroundwater ARARs. The method utilized by Geraghty andMiller to model contaminant transport through the unsaturatedzone is not actually a vadose (unsaturated) zone transportmodel, but a solution to a one-dimensional partialdifferential equation for saturated flow. Furthermore,G&M oversimplified contaminant movement by assuming anaverage groundwater velocity through the unsaturated zoneequal to the groundwater recharge rate. EPA, consequently,has been unable to conclude that the SRLs developed from thisapproach would provide for groundwater protection (refer to =Appendix C).
B. Comments by the Swope Site Cleanup Committees technicalconsultant, G&M.
1. Proposed Plan Reference: SITE BACKGROUND, p.4, Paragraph 1:"In May 1984, MPWC Well 1 was shut down due to the detectionof volatile organic compounds in the well. Since area-widegroundwater contamination occurs in the vicinity of MPWC Well1, the well was equipped with an air stripper to remove thesecompounds from groundwater, and returned to the water supplysystem in January 1989. It is believed that the Swope site,as well as a number of unidentified sources, may becontributing to the contamination of this well."
G&M: "As discussed in the supplemental Remedial Investigation(RI) report and reiterated in the November 6, 1990 and June27, 1991 letters to the USEPA, the difference betweenupgradient and downgradient ground-water quality in the deepaquifer is marginal. As such these data do not conclusivelydemonstrate that the Swope site has impacted water quality inthe deep aquifer. Since MPWC Well 1 is completed in the deepaquifer, these data do not conclusively demonstrate that theSwope site has impacted water quality in this well. Asstated by the USEPA, there are a number of unidentifiedsources that may be contributing to the contamination of thiswell."
EPA Response: During preparation of the Addendum to theSupplemental RI, EPA compared the upgradient/downgradientdistribution of specific compounds detected in the shallowand deep aquifers at the Swope site. The results of thiscomparison indicate that specific compounds were detected at
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higher concentrations in samples collected from downgradientmonitoring wells. Many of these compounds were also detectedin the shallow aquifer. EPA maintains that these datasuggest that the Swope site may have impacted deep aquifergrouridwater quality. The Swope site, which is locatedhydrologically upgradient of MPWC Well 1, therefore, may becontributing to the contamination of this well.
2. Proposed Plan Reference: SUMMARY OF THE SUPPLEMENTAL REMEDIALINVESTIGATION AND ADDENDUM, p.5, Paragraph 2, Note 4:"Similar to the shallow aquifer, the highest levels ofgroundwater contamination in the deep aquifer generallyexists beneath and downgradient of the Swope site.Contaminants present in the deep aquifer consist primarily ofvolatile organic compounds, many of which were also detectedin the shallow aquifer. This suggests that the Swope sitemay be contributing to the contamination of deep aquifergroundwater. RI groundwater sampling results furtherindicate that contaminated groundwater flows beneath theSwope site in the deep aquifer from an upgradient source(s)and that the site may, therefore, be contributingcontaminants to a larger regional groundwater plume in thedeep aquifer."
GSM: "It should be noted that some volatile organic compounds(VOCs) but not all VOCs were reported at higherconcentrations downgradient than upgradient of the Swope sitein the deep aquifer. In fact, some VOCs were reported athigher concentrations upgradient than downgradient of thesite in the deep aquifer. Therefore, these data do notconclusively demonstrate that the Swope site has impactedwater quality in the deep aquifer. This has been discussedin detail in the supplemental RI and Feasibility Study (FS)reports, as well as the November 6, 1990 and June 27, 1991letters submitted to the USEPA."
EPA Response: Refer to EPA's response to comment B.I. TheSupplemental RI concludes that the Swope site has impactedshallow aquifer groundwater quality. Of the VOCs which thesite has contributed to shallow aquifer groundwater, 1,1-dichloroethene, 1,2-dichloroethene, 1,2-dichloroethane, and1,1,1-trichloroethane were also detected at higherconcentrations downgradient than upgradient of the site inthe deep aquifer. EPA believes that these data suggest thatthe Swope site may have also contributed to the contaminationof the deep aquifer.
Based on deep aquifer groundwater results, EPA agrees thatsome VOCs detected in deep aquifer groundwater were presentat higher concentrations upgradient of the site thandowngradient of the site.
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3. Proposed Plan Reference: SUMMARY OF SITE RISKS, p.6,Paragraph 1: "A baseline quantitative Risk Assessment wasconducted to determine the risks presented by the presence ofhazardous substances in groundwater which are attributable tothe site. Th' Risk Assessment focussed on the identificationof contaminants of potential concern and possible exposurepathways at the site."
G&M: "In this paragraph it is indicated that only riskspresented by the presence of hazardous substances in groundwater were evaluated in the Swope site risk assessment(Geraghty & Miller, Inc., Supplemental Feasibility Study forthe Swope Oil and Chemical Company Site, Pennsauken Township,Camden County, New Jersey, Volume IV of IV, May 1991). Riskspresented by the presence of hazardous substances insubsurface soils were also evaluated and quantified in thesite risk assessment."
EPA Response: After site soil was sampled and analyzed, ~~contaminated surficial soil was excavated as part of theOperable Unit 1 remedial action and replaced with cleanfill. As a result, only three subsurface soil samplesremained that accurately characterized contaminated soilremaining on site after the excavation, which may present athreat to human health via ingestion or dermal contact. Asindicated in the Addendum to the Supplemental FS and RiskAssessment, EPA determined that the analytical results ofthese three soil samples were insufficient to quantifypotential risks associated with exposure to contaminatedsubsurface soil. Therefore, EPA has concluded that theevaluation of risks posed by the presence of hazardoussubstances in subsurface soil, as presented in the RiskAssessment, does not quantify potential risks posed by thismedium accurately.
In addition, as part of the remedial action conducted at thesite from the fall of 1988 to August 1989, up to 1.5 feet ofcontaminated soil were removed from most of the site.Also, sludge and visibly contaminated soil were removed to adepth of approximately 10 feet. Subsequently, clean backfillmaterial was utilized to bring the site up to grade.Therefore, EPA considers potential risks associated with thepossibility of dermal contact with, or ingestion ofcontaminated soil to be minimal.
4. Proposed Plan Reference: SUMMARY OF SITE RISKS, p.6,Paragraph 2: "The following exposure routes were assessed:1) dermal contact with contaminants in shallow aquifergroundwater; 2) drinking of groundwater from the shallowaquifer at the site; and 3) inhalation of contaminantsvolatilizing from groundwater during showering. Exposuresfor potential future workers at the site and for residents
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have been considered in this assessment. These exposureroutes were assessed as hypothetical future pathways, sincecurrent pathways for exposure to shallow aquifer groundwaterare not believed to exist. These analyses indicate that thegreatest potential future human health risk presented by thesite is from the drinking of contaminated groundwater."
G&M: "This paragraph does not include the following threeexposure routes which were assessed in the site riskassessment: (l)oral, dermal, and inhalation exposure tosubsurface soils by a future construction worker; (2)oral,dermal, and inhalation exposure to subsurface soils by afuture adult resident; and (3)oral, dermal, and inhalationexposure to subsurface soils by a future child resident."
EPA Response: Refer to EPA's reponse to Comment B.3.
5. Proposed Plan Reference: SUMMARY OF SITE RISKS, p.7.Paragraph 1: "Human health risks from the drinking of^contaminated groundwater were calculated to have a HazardIndex of 3.8. A Hazard Index greater than 1 is consideredto exceed the maximum recommended exposure. The cancer riskassociated with residents drinking contaminated groundwateris 4.2X1CT3 (4.2 in a thousand), which exceeds EPA'sacceptable risk range of 10* - 1CT4 (one in a million to onein ten thousand). It should be noted that although there arepresently no users of shallow aquifer groundwater in thevicinity of the site, some groundwater does migrate from theshallow aquifer into the deep aquifer, which is currentlyutilized as a potable water source."
G&M: "This paragraph states that human health risks from thedrinking of contaminated ground water, were calculated to havea hazard index of 3.8 and an excess lifetime cancer risk of4.2x10 . It should be noted that these values are calculatedfor a resident that 'lives in the same home for 75 years anddrinks 2 liters of water per day, 365 days per year." ___
EPA Response: EPA agrees with this statement.
It should be noted that EPA typically utilizes an exposureduration of 30 years, not 75 years, in order to quantifypotential risks posed by exposure to contaminated media. Forthe Swope site, use of shallow aquifer groundwater byresidents as a drinking water source and for showering wouldresult in a hazard index of 3.9 and an excess lifetime cancerrisk of 1.8x10 (1.8 in a thousand). These values werecalculated for a resident who lives in the same home for 30years and drinks 2 liters of water per day, 365 days peryear.
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<5. Proposed Plan Reference: SUMMARY OF SITE RISKS, p.7,Paragraph 2: "Risks associated with dermal contact andingestion of site soils have not been quantified in thisassessment. It should be noted, however, that as part of theremedial action conducted at the site from the Fall of 1988to August 1989, up to 1.5 feet of contaminated soils wereremoved from most of the site. In addition, visiblycontaminated material was removed to a depth of 10 feet.Subsequently, clean backfill material was utilized to bringthe site up to grade. Potential risks associated with thepossibility of ingestion of, or dermal contact withcontaminated soils, therefore, are considered to be minimal.11
G&M: "This paragraph states that risks associated with denialcontact and ingestion of site soils have not been quantifiedin the site risk assessment. While it is true that extensivesoil remediation has been performed by the PRPs, andpotential risks associated with contact with soils at thesite are considered to be minimal, nine future hypotheticalscenarios (construction worker, adult resident, and childresident subject to oral, dermal, and inhalation exposure tosubsurface soils) were evaluated quantitatively in the siterisk assessment (Geraghty & Miller, Inc., May 1991). Thehazard indices and excess lifetime cancer risks for theexposure to subsurface soil scenarios were calculated andfound to be below the values typically deemed "acceptable" bythe USEPA."
EPA Response: Refer to EPA's response to Comment B.3.
7. Proposed Plan Reference: SUMMARY OF ALTERNATIVES, p.9
ALTERNATIVE 2 - SOIL VAPOR EXTRACTION AND BIOD^GRADATION
Capital Cost: $687,400
Annual Operation and Maintenance Costs: $222,000(Groundwater Monitoring Program)
First-Year Operation and Maintenance Costs: $397,500(Vapor Extraction System)
Present Worth: $2,046,100
Months to Achieve Remedial Action Objectives: 18
G&M: "Alternative 2 should be entitled "Ground-WaterMonitoring Program, Soil Vapor Extraction, and NaturalBiodegradation." The annual operation and maintenance(O&M) cost for the ground-water monitoring program isestimated to be $222,000. Therefore, the present worth O&Mfor this program, at an interest rate of 10 percent and an
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inflation rate of 5 percent, over a 5-year period would be$967,503. The capital cost of $687,400 is that capital costestimated for the vapor extraction system (YES), only. Asstated in Table 7-1 of the supplemental FS Report (Geragbty tMiller, Inc., May 1991), the first year O&M estimated costthat was calculated for the operation of a VES at the Swopesite was $281,000. Therefore, the total estimated cost forAlternative 2 is $967,503 plus $687,400 plus 281,000, or$1,935,903, for one year of VE8 operation. This estimatedcost does not include any costs for bioremediationenhancement."
EPA Response: Alternative 2, as described in the ProposedPlan, includes a provision for considering whether actionsshould be taken to enhance natural biodegradation of organiccontaminants during operation of a soil vapor extraction(SVE) system. If actions are taken to alter or enhance thenaturally occurring biodegradation processes at the site,then the resulting biodegradation of site-relatedcontaminants would no longer be considered naturallyoccurring. Furthermore, many remedies typically includegroundwater monitoring even though such monitoring may not beincluded in the title. Therefore, EPA believes that thetitle for Alternative 2, as detailed in the Record ofDecision, is appropriate.
In order to determine if enhancement of naturally occurringbiodegradation would be included as part of the selectedremedy, a treatability study will be required. This studywill provide an indication of whether environmental factors,such as soil nutrients, moisture content, and the number andtype of microorganisms present in soil, could be altered toenhance biodegradation of contaminants. Because EPA isuncertain as to the extent of actions which may be taken toenhance biodegradation of soil contaminants, the costsassociated with enhancing biodegradation were not included aspart of the total remedy cost. - ^.^
The annual operation and maintenance (O&M) cost documented inthe Addendum 'to the Supplemental FS and the Proposed Plan forthe groundwater monitoring program is estimated at $222,000.It should be noted that subsequent to release of the ProposedPlan, EPA determined that samples for total metals analysesshould be collected on an annual basis as part of thegroundwater monitoring program, since several metals weresporadically detected at elevated levels during previoussampling rounds. These data will be used to characterizemetals contamination more fully. EPA's recalculated estimateof the annual O&M cost for groundwater monitoring, includingmetals, is approximately $234,200. The present worth of theO&M for groundwater monitoring, assuming a 5 percent discountrate, is $1,014,000.
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The capital cost estimate for the SVE system is $687,400. Asindicated in the Addendum to the Supplemental FS, theestimated first-year O&M cost for the operation of the SVEsystem is $397,500. This figure includes the cost of a soilsampling event prior to operation of the SVE system, toprovide a baseline for determining the effectiveness of thesystem in remediating subsurface soil contamination. Thissampling round was not included in the Supplemental FS costestimate for first-year SVE system O&M costs. The totalestimated cost for the selected remedy is $1,014,000 plus$687,500 plus $397,500, or $2,099,000.
<B. Proposed Plan Reference: SUMMARY OF ALTERNATIVES, p.9,Paragraph 3: "Under this alternative, a network of vaporextraction and passive air injection wells would be installedwithin contaminated subsurface soils at the site. Theextraction wells would be connected to a blower(s) in orderto create a vacuum within the subsurface soils. This vacuumwould draw air from the site surface and the passive airinjection wells through the contaminated subsurface soils,stripping volatile organic compounds from the subsurfaceenvironment. The air stream would then be passed through acatalytic oxidizer prior to discharge in order to regulatecontaminant emissions. On-site storage and off-sitetreatment and/or drill cuttings generated during installationof vapor extraction wells will be conducted in accordancewith the requirements of the Resource Conservation andRecovery Act (RCRA), as amended by the Hazardous and SolidWaste Amendments of 1986."
G&M: "It is stated in this paragraph that the effluent airstream from the air blower will be passed through a catalyticoxidizer. It should be noted that for purposes of costestimation, worst case scenarios were considered. Thus,catalytic oxidation as a means of air emission controlrepresents a worst case scenario. The actual air emissioncontrol equipment that is to be included in the final VES
-- design vill be determined during the remedial design (RD)phase of this project.11
EPA Response: The magnitude of potential volatile organicemissions that may result due to operation of the SVE systemwill be assessed during the remedial design phase todetermine whether emissions from the system would potentiallyexceed air emission ARARs. If necessary, the air streamwould be treated by carbon adsorption or thermal destructionprior to discharge, to ensure compliance with air qualityregulations. EPA agrees that the design of the emissionscontrol system would be determined during the remedial designphase.
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9. G&M:
"Biodecrradation of Subsurface Soil
As discussed in the Response to U8EPA and NJDEP Comments onthe Supplemental Feasibility Study Report for the Swope Oiland Chemical Company Site, it must be noted that semi volatileorganic compounds were not detected at concentrationssignificantly higher than soil remediation levels (SRLs) .Residual semivolatile organic compound concentrations will bepermanently reduced by natural biodegradation that isenhanced by soil vapor extraction (SVE) , as discussed in theMay 1991 Supplemental PS Report and the aforementionedresponse document.**
EPA Response: Regarding the SRLs, refer to EPA's response tocomment A.I.
It should be noted that based upon the results of themicrobial evaluation of site soil and the SVE-systemtreatability studies conducted as part of the SupplementalFS , EPA has been unable to conclude that operation of a SVEsystem at the site, without further actions taken to enhancethe aerobic biodegradation of site contaminants , would besufficient to remediate site-related contaminants to levelsthat would provide for groundwater protection. Specifically,it was not demonstrated during the microbiological evaluationthat microorganisms that would lead to the biodegradation ofsite contaminants were present in the most contaminated sitesoil. Therefore, as part of the selected remedy, atreatability study will be conducted, utilizing EPA-approvedmethodologies, to evaluate biodegradation at the site morecompletely. This study will evaluate whether environmentalfactors, such as soil nutrients, moisture content, and thenumber and type of microorganisms present in soils, could bealtered to enhance the biodegradation of contaminantsfurther. . . ._ ._
10. G&M:
"Groundwater Monitoring Progrr*1"
As part of the supplemental Feasibility Study, Geraghty £Miller prepared and submitted The Shallow Ground-waterMonitoring Plan of the Supplemental Feasibility Study (July1991) . The purpose of the ground-water monitoring program isto evaluate the quality of ground water beneath the Swopesite throughout the operation of the VES. Ground-watersamples collected during the first and fourth quarters willbe analyzed for VOCs and semivolatile organic compounds byusing EPA Methods 624 and 625, respectively. Because of thelow mobility of semivolatile organic compounds, samples
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collected during the second and third quarters vill beanalyzed for VOCs only.
As stated in the supplemental Rl report (March 1991), waterquality data for the deep aquifer is insufficient toconclusively demonstrate that the Swope site has impactedground-water quality in the deep aquifer. Although Geraghty& Miller agrees with the D8EFA that ground-water samplesshould be collected from wells screened in the deep aquiferas part of the proposed monitoring program, samples should beanalyzed for VOCs only and not semivolatile organiccompounds. Specifically, semivolatile organic compoundanalyses should not be performed on ground-water samplescollected from the deep aquifer for the following reasons.
o Impacts, if any, of semivolatile organic compounds on waterquality conditions in the deep aquifer would first beobserved in the shallow aquifer wells.
o Semivolatile organic compounds have been detected lessfrequently and at lower concentrations than VOCs in bothshallow and deep wells.
o Semivolatile organic compounds have a lower mobility thanVOCs and the impacts, if any, to water quality would first benoted based on a review of VOC data.1'
EPA Response: The results of subsurface soil samplescollected during performance of the Supplemental RI indicatethat volatile and semi-volatile organic compounds are presentin subsurface soil at levels which exceed site cleanupgoals. Therefore, EPA believes that both volatile and semi-volatile organic compounds in site soil present a threat togroundwater quality. Furthermore, based on the findings ofthe Supplemental RI and Addendum, EPA has determined that theSwope site has contributed to the contamination of theshallow aquifer and may have impacted deep aquifergroundwater quality (refer to comment B.I). It should alsobe noted that bis(2-ethylhexyl)phthalate, a semi-volatileorganic compound present in the site soil at elevatedlevels, was detected at its highest concentration in deepaquifer monitoring well GM-7D, which is downgradient of theSwope site. As a result, EPA decided that groundwatersamples should be collected from both shallow- and deep-aquifer monitoring wells and undergo analyses for volatileand semi-volatile organic compounds. Samples should becollected on a quarterly basis to determine any seasonaleffects on groundwater quality. As stated in this Record ofDecision, however, EPA may modify the groundwater monitoringprogram (in terms of frequency and contaminant parameters),based on the analytical results of groundwater samplescollected during the initial sampling event(s).
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The Shallow Ground-Water Monitoring Plan of the SupplementalFeasibility Study indicates that EPA Method 624 will beutilized to determine the concentrations of volatile organiccompounds in groundwater. EPA has determined that thismethod of analysis is inappropriate and that the 500 seriesmethod must be used for volatile organic compoundanalysis.
Subsequent to release of the Proposed Plan, EPA determinedthat samples for total metals analyses should be collected onan annual basis as part of the groundwater monitoringprogram, since several metals were detected at concentrationsabove Primary Maximum Contaminant Levels during previoussampling events. Although these metals data may representisolated occurrences, future metals data will be used tocharacterize groundwater quality more fully.
11. G&M ._ .._ _ . _. — ._- __
"Soil Remediation Levels (SRLsl
On July 31, 1991, Sally Odland of CDM telephoned Frank Jonesof Geraghty & Miller (Risk Assessment Group) and stated thatCDM was able to duplicate the SRLs presented in theSupplemental FS Report, using the same model and inputparameters discussed in that report."
EPA Response: EPA has determined that the vadose zonetransport modeling analysis conducted as part of theSupplemental FS is oversimplified and that the soilremediation levels developed based upon the results of thismodel may not be sufficient to provide for groundwaterprotection (refer to EPA's response to Comment A.I).
C. Comment on the Preferred Remedy from Dilworth, Paxson, Kalish& Kauffman (Dilworth), representing News America Publications
_ Inc., and other Potentially Responsible Parties. _,_Hir.._„,.,._ .__.
Dilworth: "[T]he proposed remedial alternative applies toboth subsurface soil and groundwater. The Agency itself hasrecognized this on numerous occasions. Just a sampling ofoccasions on which EPA has recognized this are the following.Raymond Basso, in a letter dated May 21, 1991, stated that"EPA believes that remediation of the source material wouldresult in the reduction of the contamination of thegroundwater." Also, EPA's Addendum to the SupplementalFeasibility Study and Risk Assessment for the Swope Oil andChemical Company site notes that EPA believes that soil vaporextraction would be effective in reducing subsurface soilcontamination and thereby reduce contaminant migration intothe groundwater."
15
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EPA Response: As indicated in the Proposed Plan, thepreferred remedy addresses the remediation of contaminatedsubsurface soil, which is a continuing source of groundwatercontamination, but does not specifically address theremediation of contaminated groundwater at the Swope site.As such, this remedy is considered a source control action,not a groundwater remedy. However, EPA believes thatremediation of the contaminated subsurface soil willindirectly result in a reduction of groundwatercontamination. Subsequent to completion of this remedy, EPAwill determine whether it provides for adequate protection ofgroundwater and whether any further source control measures,or if groundwater remedial measures, are necessary.
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APPENDIX AProposed Flan and Public Comments
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ATTACHMENT A.IProposed Plan for the Swope oil and Chemical Company Site
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Soperfand Program Proposed Plan.
SWOPE OIL AND CHEMICAL COMPANY SITEPENNSAUKEN TOWNSHIP, MW JERSEY
EPARegion 2 Inly 1991
EPA ANNOUNCES PROPOSEDPLAN
This Proposed Plan describes thepreferred alternative for remediation ofcontaminated subsurface soils at theSwope Oil and Chemical CompanySuperfund site (Swope site) inPennsauken Township, CamdenCounty, New Jersey. This document isissued by the U.S. EnvironmentalProtection Agency (EPA), the leadagency for site activities, and the NewJersey Department of EnvironmentalProtection (NJDEP), the supportagency for this response action. EPA,in consultation with NJDEP, will selectthe remedy for the subsurface soils atthe site, only after the public Commentperiod has ended and informationsubmitted during this time has beenreviewed and considered.
THE COMMUNITY'S ROLE INTHE SELECTION PROCESS
EPA is issuing this Proposed Plan aspart of its public participationresponsibilities under Section 117(a) of
the Comprehensive EnvironmentalResponse, Compensation, and LiabilityAct of 1980, as amended by theSuperfund Amendments andReauthorization Act of 1986. ThisProposed Plan summarizes informationthat can be found in greater detail inthe Supplemental RemedialInvestigation (RI) report, theSupplemental Remedial InvestigationAddendum, the Supplemental
• MtfNOTIDKAU
SITE MAP FOR THE SWOPS OIL AND CHEMICAL COMPANY SUTtWHD SITE
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Feasibility Study (?£>), the 'RiskAssessment, the Addendum to theSupplemental FS and Risk Assessmentand other documents contained in theadministrative record file for this site.EPA and NJDEP encourage the publicto review these documents in order togain a more comprehensiveunderstanding of the site and therelated Superfund activities conductedto date. These documents are availableto the public in repositories at thefollowing locations:
document.
y
I Pennsanken Township JLabrary| 5605 North Cresent Boulevard! Pennsauken, New Jersey 08110i (609) 665-5959IHours: M,W,Thurs. 9:30am-9:99pm\ T,F ' £30am-0;00praI Sat. 10;00am4:QOpm
r ' and ^ - .'>•-
I Clerk's Office! Pennsauken Municipal Building
5605 North Cresent Blvd.I Pennsauken, N«F 08110f (609) 665-1000
Hours: M-F,<•r -.
6:30anv4;30pm
EPA, in consultation with NJDEP, maymodify the preferred alternativepresented in this Proposed Plan andthe Supplemental Feasibility Studybased on new information or publiccomments. Therefore, the public isencouraged to review and comment onall of the alternatives identified in this
&ATES TO BEMEMBBR1$, 1891 - August 17, 1001
iblic comment period Cor ^ ,jntaminated subsurface soil preferred
Thursday August 1, 19017rf)0pm * 8K)Opm
; , , Public Meeting irt:/'
Pennsauken Municipal Building5605 North Cresent Boulevard -Pennsauken» Hew Jersey 08UO
EPA solicits input from the communityon the cleanup methods proposed foreach Superfund response action. EPAhas set a public comment period fromJuly 18,1991 through August 17,1991,to encourage public participation in theselection of a remedy for the Swopesite. The comment period includes apublic meeting at which EPA willdiscuss the Supplemental RI,Supplemental RI Addendum,Supplemental FS, Risk Assessment, theAddendum to the Supplemental FS andRisk Assessment and Proposed Plan,answer questions, and accept both oraland written comments.
The public meeting for the Swope siteis scheduled for August 1, 1991, from7:00pm to 9:00pm, and will be held atthe Pennsauken Township MunicipalBuilding, 5605 North CresentBoulevard, Pennsauken, New Jersey08110.
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Comments will be summarized \indresponses provided in theResponsiveness Summary section of theRecord of Decision. The Record ofDecision will be the document thatpresents EPA's final selection for thesubsurface soil cleanup. To sendwritten comments or obtain furtherinformation, contact:
Joseph Cowers " s , %v" Project Manager -V"V ;:
|IS, Environmental Protection AgencyI Emergency & RemedialI Response Division< 26 Federal Plaza, Room 720* New York, New York 10278
All comments must be postmarked onor before August 17, 1991 for inclusionin the Record of DecisionResponsiveness Summary.
SITE BACKGROUND
The site, approximately two acres insize, is located in an industrial complexin northern Pennsauken Township,Camden County, New Jersey. Thetriangular site is bounded on thesoutheast by National Highway, and onthe north and southwest by railroadrights-of-way and warehouses (refer tosite location map). The PennsaukenCreek and the Delaware River arelocated 0.8 miles northeast and 1.2miles northwest of the site,respectively. Two municipal watersupply wells operated by the
24erchantville-Pennsauken WaterCommission, MPWC Well 1 and MPWUWell 2, are located approximately 275feet southwest and 1500 feet northeastof the site. Pennsauken High School islocated approximately 0.5 milesnortheast of the site. The nearestresidential areas are in the Townshipsof Delair and Morrisville, which arelocated about 0.5 miles west and 0.8miles southwest of the site,respectively.
From 1965 to 1979, the Swope Oil andChemical Company operated a chemicalreclamation facility that includedbuying, selling and processing solvents,oils, plasticizers, hydraulic fluids andother chemicals. In 1975, inspectorsfrom NJDEP cited the Swope Oil andChemical Company for operatingwithout proper permits. The SwopeOil and Chemical Company was citedagain in 1979 for failure to prepare,maintain, or fully implement a SpillP r e v e n t i o n , C o n t r o l a n dCounter-measures Plan. The companyceased operation in December 1979.
During operation of the facility, wasteliquids and sludges were discharged toan excavated, unlined lagoon.Contaminated material was alsocontained within a diked tank farm andan exposed drum storage area. Whenthe facility ceased operating, significantsite features included a main building,a distilling house, a diked *-»nlc farm, anopen drum storage area, and an unlinedlagoon.
A Focused Feasibility Study wascompleted by EPA in February 1984.On May 14,1984, EPA entered into an
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Administrative Order on Consent witha group of the Potentially ResponsibleParties (PRPs) for the performance ofthe remedial activities recommended inthe Focused Feasibility Study.Pursuant to this order, drummed wasteand 3,000 tons of lagoon sludge wereremoved from the site. In addition, afence was constructed around the siteto restrict access and to prevent thepublic from coming into direct contactwith the contaminants.
In May 1984, MPWC Well 1 was shutdown due to the detection of volatileorganic compounds in the well. Sincearea-wide groundwater contaminationoccurs in the vicinity of MPWC Well 1,the well was equipped with an airstripper to remove these compoundsfrom groundwater, and returned to thewater supply system in January 1989.It is believed that the Swope site, aswell as a number of unidentifiedsources, may be contributing to thecontamination of this well.
In June 1985, EPA concluded the firstRemedial Investigation and FeasibilityStudy (RI/FS). Based upon thefindings of the RI/FS, a Record ofDecision, addressing surfacecontamination, was signed by EPA onSeptember 27, 1985.
In August and September 1986, EPAentered into Administrative Orders onConsent with a group of PRPs toperform the Remedial Action specifiedin the Record of Decision and toconduct a Supplemental RI/FS.
The Remedial Action addressingsurficial contamination was initiated by
tile PRPs in the fall of 1988 and wasessentially completed by August 1989.This program included the demolitionand disposal of on-site buildings, thejff-site disposal of tanks with off-sitedisposal or incineration of tankcontents, the excavation and off-sitedisposal of up to 1.5 feet of soilsfnnt.flminfit.Afl with PCBs, and the off-site disposal of visibly contaminatedmaterials from the buried sludge areaof the site. Subsequent to excavation,clean backfill material was utilized tobring the site up to grade. Theconstruction of a cap at the site, whichwas an activity specified by theSeptember 1985 Record of Decision,was postponed to provide for theinstallation of monitoring wells and theperformance of treatability studiesduring the Supplemental RI/FS.
SUMMARY OF THESTTPPT/RMENTAL REMEDIALINVESTIGATION ANDADDENDUM
The Supplemental RI for the Swope Oiland Chemical Company site wasconducted from October 1988 to March1991. The original objectives of theSupplemental RI/FS were to evaluatethe extent of groundwatercontamination at the site and todevelop appropriate remedialalternatives. Based upon informationobtained during the design phase of thesurface remedy, EPA decided to expandthe scope of the Supplemental RI toinclude the determination of the natureand extent of subsurface soilcontamination at the site.
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The following tasks were performedduring the RI:
- pre-existing geological, geophysical,hydrological and chemicalinformation was reviewed andevaluated;
- ten deep soil borings were drilled todefine the site geology further andto sample soils for determination ofthe types and concentrations ofcontaminants existing in soils abovethe water table;
- fourteen additional monitoring wellswere installed to define the sitehydrogeology further and todetermine the nature and extent ofgroundwater contamination. A totalof eighteen monitoring wells andpublic supply well MPWC Well 1were sampled during thisinvestigation; and
- an aquifer test was conducted at thesite to determine the direction ofgroundwater flow and the hydraulicrelationship between the shallowand deep aquifers underlying thesite.
The findings of the RI are as follows:
- Two aquifers were identifiedbeneath the site. The first is awater table aquifer which begins atapproximately 80 feet below landsurface and extends down toapproximately 135 feet below landsurface. The second aquifer extendsfrom approximately 170 feet to 240feet below land surface. A-35 foot
semi-counning layer composedprimarily of silt and clay withinterbedded layers of fine-grainedsand separates the two aquifers.
The direction of groundwater flow inboth the shallow and deep aquifersis to the southwest. Deep aquifergroundwater in the vicinity of thesite flows toward public supply well,MPWC Well 1, when this well is inoperation.
The highest levels of groundwatercontamination in the shallow aquiferexist beneath and downgradient ofthe site, indicating that the site has"contributed to the contamination ofthis aquifer. Contaminants presentin the shallow aquifer consistprimarily of volatile organiccompounds. RI data further indicatethat contaminated groundwaterflows beneath the Swope site in theshallow aquifer from an upgradientsource(s) and that the site'scontaminant plume is part of alarger regional groundwater plume.
Similar to the shallow aquifer, thehighest levels of groundwatercontamination in the deep aquifergenerally exist beneath and — r^downgradient of the Swope site.Contaminants present in the deepaquifer consist primarily of volatileorganic compounds, many of whichwere also detected in the shallowaquifer. This suggests that theSwope site may be contributing tothe contamination of deep aquifergroundwater. RI groundwatersampling results further indicatethat contaminated groundwater
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flows beneath the Swope site in thedeep aquifer from an upgradientsource(s) and that the site may,therefore, be contributingcontaminants to a larger regionalgroundwater plume in the deepaquifer.
Subsurface soil samples indicate thepresence of volatile and semi-volatileorganic compounds. The highestconcentrations of these contaminantswere detected hi samples collected inthe vicinity of the former TankFarm Area, Lagoon Area and BuriedSludge Area. Significant levels ofvolatile and semi-volatile organic "compounds were detected insubsurface soils to a depth of about50 feet below land surface. Many ofthe volatile organic compoundsdetected in these soils are alsopresent in groundwater beneaththe Swope site. Accordingly, thesesoils represent a continuing andsignificant source of thecontamination of groundwater.
were being performed.
EPA designated surficial contaminationas the first operable unit of siteremediation. EPA's preferredalternative for the second operableunit, which is the subject of thisdocument, focuses on the remediationof contaminated subsurface soils, whichare a continuing source of groundwatercontamination. EPA believes thatremediation of the source material willresult in a significant reduction of thegroundwater contamination. As aresult, EPA has decided to postpone adecision regarding groundwaterremediation, until source controlmeasures have been implemented.Groundwater monitoring will berequired during and after the designand implementation phases of theselected source control alternative, inorder to determine the effectiveness ofthese measures in mitigatinggroundwater contamination andwhether future groundwaterremediation would be required.
SCOPE OF THIS QPFRART.F
Based on the groundwater results ofthe 1985 RI, EPA concluded thatinvestigation of the nature and extentof deep aquifer and off-sitegroundwater contamination wasessential to address this mediumappropriately. As a result, EPA decidedto address contamination at the site indiscrete phases, referred to as operableunits, so that a remedy for surficialcontamination could proceed, whileadditional groundwater investigations
SUMMARY OF SITE RISKS
A baseline quantitative RiskAssessment was conducted todetermine the risks presented by thepresence of hazardous substances ingroundwater which are attributable tothe site. The Risk Assessment focussedon the identification of contaminants ofpotential concern and possible exposurepathways at the site.
The following exposure routes wereassessed: 1) dermal contact with
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contaminants in shallow aquifergroundwater; 2) drinking ofgroundwater from the shallow aquiferat the site; and 3) inhalation ofcontaminants volatilizing fromgroundwater during showering.Exposures for potential future workersat the site and for residents have beenconsidered in this assessment. Theseexposure routes were assessed ashypothetical future pathways, sincecurrent pathways for exposure toshallow aquifer groundwater are notbelieved to exist. These analysesindicate that the greatest potentialfuture human health risk presented bythe site is from the drinking ofcontaminated groundwater.
Human health risks from the drinkingof contaminated groundwater werecalculated to have a Hazard Index of3.8. A Hazard Index greater than 1 isconsidered to exceed the maximumrecommended exposure. The cancerrisk associated with residents drinkingcontaminated groundwater is 4.2 x 10"3
(4.2 in a thousand), which exceedsEPA's acceptable risk range of 10"6 -10"1
(one in a million to one in tenthousand). It should be noted thatalthough there are presently no usersof shallow aquifer groundwater in thevicinity of the site, some groundwaterdoes migrate from the shallow aquiferinto the deep aquifer, which iscurrently utilized as a potable watersource.
Risks associated with dermal contactand ingestion of site soils have not beenquantified in this assessment. It shouldbe noted, however, that as part of theremedial action conducted at the site
from the Fall of 1988 to August 1989,up to 1.5 feet of contaminated soilswere removed from most of the site. Inaddition, visibly contaminated maf drialwas removed to a depth of 10 feet.Subsequently, dean backfill materialwas utilized to bring the site up tograde. Potential risks associated withthe possibility of ingestion of, or dermalcontact with contaminated soils,therefore, are considered to beminimal
SUMMARY OF ALTERNATIVES
The Superfund legislation requires eachselected site remedy to be protective ofhuman health and the environment,cost-effective, and in accord withstatutory requirements. Permanentsolutions to contamination problemsare to be achieved wherever possible.The use of innovative technologies andon-site treatment are evaluated as ameans to attain this goal.
During the FS process, a wide range oftreatment technologies were identifiedand screened for use in applicableremedial alternatives. As describedbelow, many of these technologies andalternatives were eliminated fromfurther consideration due to physicalconditions or other limitations at thesite.
Ex-situ treatment options, whichinvolve the excavation of contaminatedsoil prior to treatment, were screenedout due to the difficulties involved inexcavating contaminated site soils to adepth of approximately 50 feet within
100177
th* spatial confines of the site. Asdisplayed on the site map, the site isbounded to the northeast andsouthwest by railroad rights-of-way andwarehouses, and to the northwest byNational Highway. Excavation ofcontaminated site soils would, at aminimum, involve the disruption of anactive railroad spur as well as NationalHighway. In addition, the excavation ofcontaminated site soils would requireshoring the sides of the excavation tomaintain the integrity of the excavationwalls during removal of soils. Theshoring of the excavation walls to adepth of 50 feet would prove difficultand would require the excavation ofsoils outside the physical boundaries ofthe site.
In-situ or in-place treatment optionsevaluated in the FS include:v i t r i f i c a t i o n / g l a s s i f i c a t i o n ,solidification/fixation, soil flushing, soilvapor ex t rac t ion , enhancedvolatilization and bioremediation.Vitrification/glassification was screenedout, since this technology is notimplementable to the depth ofc o n t a m i n a t i o n at the site.Solidification/fixation techniques havenot been proven to be effective inreducing the mobility of organiccompounds and, therefore, wereeliminated from further consideration.Soil flushing would involve washingorganic contaminants from subsurfaceSoils. This technology Was eliminatedbecause the contaminants wouldultimately be transferred to thegroundwater. Enhanced volatilizationtechniques were eliminated fromconsideration, due to the high costassociated with heating the soils to the
temperature required to volatilize theorganic contaminants, and since thistechnology has not been shown to bereadily implementable to the depth ofcontamination at the site. In all, twotreatment options, in-situ vaporextraction and bioremediation, weredetermined to be viable for remediationof contaminated site soils.if
Institutional actions, such as sitefencing and access restrictions, andcontainment options, such as capping,were also evaluated. Institutionalactions were screened out, since theywould not meet the remedial actionobjective of eliminating on-sitesubsurface soils as a source ofcontamination to groundwater. Of thecapping alternatives evaluated in theFS, a multi-layer cap originally wasdetermined to be the most reliable and,therefore, was retained forincorporation into applicable remedialalternatives.
The technologies that were noteliminated from consideration duringthe screening were assembled intoremedial alternatives. The followingprovides a description of the remedialalternatives that were evaluated for theSwope site.
ALTERNATIVE 1 - NO ACTION
Capital Cost: 0
Annual Operation and MaintenanceCosts: $222,000
Present Worth: $961,000
8
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Months to Achieve Remedial ActionObjectives: Not Applicable*
under this alternative.
Groundwater quality would bemonitored quarterly for five yearsunder this alternative.
Superfund regulations require that aNo Action alternative be evaluated atevery site to provide a baseline againstwhich other remedial alternatives maybe compared. Under this alternative,no action would be taken at the site toprevent or reduce the leaching ofsubsurface soil contaminants togroundwater. This alternative includesa five-year groundwater monitoringplan, which would involve the samplingof existing site wells on a quarterlybasis, to assess the impact of thecontaminated soils on groundwaterquality.
ALTERNATIVE 2 - SOIL VAPOREXTRACTION ANDBIODEGRADATION
Capital Cost: $687,400
Annual Operation and MaintenanceCosts: $222,000(Groundwater Monitoring Program)
First-Year Operation and MaintenanceCosts: $397,500(Vapor Extraction System)
Present Worth: $2,046,100
Months to Achieve Remedial ActionObjectives: 18*
Groundwater quality would bemonitored quarterly for five years
Under this alternative, a network ofvapor extraction and passive airinjection wells would be installedwithin contaminated subsurface soils atthe site. The extraction wells would beconnected to a blower(s) in order tocreate a vacuum within the subsurfacesoils. This vacuum would draw airfrom the site surface and the passiveair injection wells through thecontaminated subsurface soils, strippingvolatile organic compounds from thesubsurface environment. The airstream would then be passed through acatalytic oxidizer prior to discharge inorder to regulate contaminantemissions. On-site storage and off-sitetreatment and/or disposal of drillcuttings generated during installationof vapor extraction wells will beconducted in accordance with therequirements of the ResourceConservation and Recovery Act (RCRA),as amended by the Hazardous and SolidWaste Amendments of 1986.
Additionally, operation of a vaporextraction system (VES) would addoxygen to the subsurface soils, therebyenhancing the natural aerobicbiodegradation of non-halogenatedorganic contaminants. This processwould prove effective in reducing thelevels of semi-volatile organiccompounds in subsurface soils. Theinoculation of subsurface soils withappropriate microorganisms as well asthe injection of nutrients into thesubsurface would be considered duringdesign of the VES, to determine ifbiodegradation of subsurface soil
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contaminants could be enhanced
Subsurface soil, soil gas andgroundwater samples would becollected as part of this alternative todetermine the effectiveness of the VESin remediating subsurface soilcontamination. A quarterlygroundwater monitoringprogram wouldbe implemented to providegroundwater quality data for the abovedetermination. Subsurface soil sampleswould be collected prior to operation ofthe VES to provide a baseline fordetermination of the effectiveness ofthe VES in remediating subsurfacecontamination. Contaminantconcentrations in the soil gas samples,collected during operation of the VES,would indicate when soil samplesshould be collected to determinewhether soil cleanup goals have beenmet. If cleanup levels have not beenmet, and the VES continues to removesignificant quantities of contaminants,then operation of the VES wouldcontinue.
Decision to Postpone Installationof a Cap
Alternative 2, as developed andevaluated in the Supplemental FS,originally included the installation of amulti-layer cap over the site, followingtreatment of contaminated subsurfacesoils. A cap was originally included asa component of this alternative, sincethe installation of a cap was a sourcecontrol activity specified in theSeptember 1985 Record of Decision. Itshould be noted, however, thatextensive treatment of subsurface
contamination was not envisioned whenthe 1985 remedy was selected. Duringpreparation of this Proposed Plan, EPAreevaluated the need to cap the site inconjunction with the active treatmentof subsurface contamination. EPA hasdetermined that treatment ofsubsurface soil contamination alonemay be adequate to protect thegroundwater from continuingdegradation. As a result, EPA hasdecided to postpone a decisionregarding a cap, until afterimplementation of the selected sourcecontrol remedy. If it is laterdetermined that a cap is not required,this approach would have the potentialbenefit of minimal institutional controlsand would allow for a greater degree ofunrestricted future site use.Subsequent to completion of theselected remedy, EPA will evaluate theeffectiveness of this remedy inproviding for groundwater protectionand determine whether the installationof a cap or further source controlactions are warranted.
Rationale for Selection
Each of the alternatives was evaluatedagainst nine criteria utilized by EPA inthe remedy selection process. Thesecriteria fall into four categories:environmental /public healthprotectiveness, compliance with cleanupstandards, technical performance, andcost. In addition, the selected remedyshould result in permanent solutions tocontamination problems and should usetreatment to the maximum extentpracticable. The nine criteria are
10
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summarized below:
• Overall protection of human healthand the environment addresseswhether or not a remedy providesadequate protection and describeshow risks posed through eachpathway are eliminated, reduced orcontrolled through treatment,engineering controls, or institutionalcontrols.
• Compliance with ARARs addresseswhether or not a remedy will meet allof the applicable or relevant andappropriate requirements (ARARs) offederal and state environmentalstatutes and/or provides a basis for aw.aiver.
• Long-term effectiveness refers to theability of a remedy to maintainreliable protection of human healthand the environment over time, oncecleanup goals have been met.
• Reduction of toricity. mobility orvolume through treatment is theanticipated performance of theremedy in terms of reducing thetoxicity, mobility, or volume of the ~~"contaminants of concern In theenvironment.
• Short-term effectiveness addresses theperiod of time needed to achieveprotection, and any adverse impactson human health or the environmentthat may be posed during theconstruction and implementationperiod until cleanup goals areachieved.
• Implementabilitv refers to thetechnical and administrativefeasibility of implementing a remedy,including the availability of materialsand services required to implement aparticular option.
Cost includes estimated capital andoperation and maintenance costs ofthe remedy, and the net presentworth cost. A summary of theestimated costs for the remedialalternatives considered is presented inTable 1.
- State Acceptance indicates whether,based on its review of the RI and FSand the Proposed Plan, the Stateconcurs with the preferredalternative. The State has concurredwith the preferred remedy presentedin this Proposed Plan.
- Communitv Acceptance will beassessed in the ROD following areview of the public commentsreceived on the RI, RI Addendum, andFS reports and the Proposed Plan.
EPA, in consultation with NJDEP, isrequired to select the remedialalternative which provides the bestbalance among the nine criteria.However, the selected alternative mustsatisfy the first two criteria: protectionof human health and the environment,and compliance with ARARs, unless awaiver is granted. The manner inwhich the alternatives address thecriteria is presented below.Community comments and acceptanceare being solicited at this time.
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ALTERNATIVE 1 - NO ACTION
The No Action Alternative would offerno reduction in the toxicity, mobility orvolume of contaminants in thesubsurface soils. Since these soilswould continue to serve as a source ofgroundwater contamination, thisalternative would not protect humanhealth and the environment or prove tobe effective in the long term. Thisalternative presents little risk to on-siteworkers, since no construction activitieswould be implemented. However, thisalternative would not reduce any of theexisting site risks. Implementation ofthis alternative would be easy since itonly involves the collection ofgroundwater samples.
ALTERNATIVE 2 - SOIL VAPOREXTRACTION ANDBIODEGRADATION
The remediation of contaminatedsubsurface soils through in-situ vaporextraction and biodegradation wouldprotect human health and theenvironment by reducing potential risksto future users of groundwater. Thetoxicity, mobility and volume ofsubsurface soil contaminants would bereduced through in-situ vaporextraction. This alternative wouldemploy only proven technologies andwould be easily implemented at thesite. Aerobic biodegradation ofcontaminants would occur during andafter the operation of the vaporextraction system.
Since no Federal or State regulationsspecify cleanup levels for soils, New
Jersey State Soil Action Levels will beutilized as soil cleanup goals to providefor groundwater protection. Operationof the soil treatment system wouldcontinue until the cleanup goals havebeen attained or until continuedoperation of the system provestechnically impractical. An ARARswaiver would not be required if cleanupgoals were not achieved, since NewJersey State Soil Action Levels are notpromulgated ARARs.
In-situ soil vapor extraction would beconducted in compliance with State andFederal ARARs. In addition, due to thesite's proximity to the Delaware River,implementation of this alternativewould be consistent with the CoastalZone Management Act. Off-sitetreatment and/or disposal of drillcuttings generated during installationof vapor extraction wells would beconducted in accordance with therequirements of RCRA, as amended bythe Hazardous and Solid WasteAmendments of 1986.
This alternative would permanentlyreduce the migration of contaminantsto groundwater and, therefore, wouldprove effective over the long term. Inthe short term, actions would be takento reduce potential risks to on-siteworkers. These measures may includerequirements for protective clothingand respiratory protection. Airemissions control equipment would beinstalled at the VES extraction wells toprotect the community.
12
100182
SUMMARY OF THE PREFERREDALTERNATIVE
After careful consideration of allreasonable alternatives, EPA proposesutilizing Alternative 2 - Soil VaporExtraction and Biodegradation for theremediation of contaminated subsurfacesoils at the Swope Oil and ChemicalCompany site. The preferredalternative provides the best balanceamong the alternatives with respect tothe criteria used to evaluate remedies.Based upon the information available atthis time, EPA believes that thepreferred alternative would beprotective, attain ARARs, be cost-effective, and would use permanenttreatment technologies to themaximum extent practicable.Subsequent to implementation of thisremedy, EPA will determine whetherthis remedial action provides foradequate protection of groundwater andwhether any further source controlmeasures, such as capping, or ifgroundwater remedial measures arenecessary.
13
100183
TABLE 1
SUMMARY OF REMEDIAL ALTERNATIVES
REMEDIALALTERNATIVE
PRESENT WORTHCOST rsi.oooi
TIME TO ACHIEVEREMEDIALACTION(MONTHSr COMMENTS
1: No Action 961 NA Inadequate toprotect humanhealth and theenvironment.
Groundwater quality would be monitored quarterly for five yearsunder these alternatives.
14
100184
ATTACHMENT A.2Public Notice
100185
Proof of Publication of Notice in The PEu'ladelphia InquirerUnfer Act No. 160, 9JL 977, My 9,1976
Commonwealth of PennsylvaniaCounty of Philadelphia
ss.:
L...C.ij?.;r.U;>.P being duly tworn deposes and My» that THE PHILADELPHIAINQUIRER is a daily newspaper published at Broad and Callowhiil Streets, Philadelphia County, Pennsylva-nia, which was established in the year 1829, since which date Mid daily newspaper has been regularly publishedand distributed in said County, and that a copy of the printed notice of publication is attached hereto exactly as'trie same was printed and published in the regular editions and issues of Mid daily newspaper on'the followingdates, viz.:
.and the I.?.*.1? day of. ..A.D.19..?.?.
Affiant further deposes that he is duly authorizedby Philadelphia Newspapers, Inc., a corporation,p u b l i s h e r of THE PHILADELPHIA IN-QUIRER, a daily newspaper, to verify the forego-irig statement under oath, end also declares thataffiant is not interested in the subject matter ofthe aforesaid notice or publication, and that allallegations in the foregoing statement as to time,place and character of publication are true.
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My Commission Expires:
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100186
ATTACHMENT A.3August 1, 1991 Public Meeting Attendance Sheet
100187
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION XI
PUBLIC XEETINGFOR
BWOPE OIL SUERFUKD SITEPENNSAUKEN, NEW JERSEY
AUGUST 1, 1991MEETING ATTENDEES
(Pitas* print)
HAKE STREET CITY 2IP PEONE REPRESENTING
100188
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION XI
PUBLIC MEETINGTOR
8WOPE OIL SUERFUND SITEVENNSAUKEN, NEW JERSEY
AUGUST 1, 1991MEETING ATTENDEES
(Pl«as« Print)
NAME STREET CITY ZIP .' PHONE REPRESENTING
100189
APPENDIX BSwope Site Cleanup Committee's Comments
on the Proposed Plan and the Addendum to theSupplemental Feasibility study and Risk Assessment
100190
ATTACHMENT B.IJuly 31, 1991 Comment Letter from the Svope Site Cleanup
Committee Concerning the Addendum to the Supplemental FeasibilityStudy and Risk Assessment
ei"" "i TV?*'.*" «OCA BATON. FLORIDAIIII'SV.oo"*-"! WEST ATLANTIC CITY NEW JERSEY«ti.»es c JC-~»ON- CAMDEN NEW JERSEY
MAVB* K r«v*
LOS ANGELES CALIFORNIA »*•?•-'• V*1JK Sio""«8i.ISii
DIRECT DIAL (215) B75-
85201 Av»O MCMft
• A^fte MCM»C« or c* •«• • Ak»e •*(•••£• or •••; •«•• Cb „ TT AfcSO MC«*M« Or MV »*• • AtAO HCMtC* O» **TitrT
LAU»rNCC S »«TA*CkVT
ftC**AC*>«A*< ._. July 31, 1991
FOR INCLUSION INTEE ADMINISTRATIVE RECORD
Mr. Raymond BassoUnited States Environmental Protection AgencyRegion IIJacob K. Javits Federal BuildingNew York, New York 10278
Re: Swope Site Cleanup Committee Comments on the Addendum to:F the Supplemental Feasibility Study and Risk Assessment
for the Swope Oil and Chemical Company Site, located inPennsauken Township, Camden County. New Jersev
Dear Mr. Basso:
We have received a copy of your July 15, 1991, letter toRobert Nicoloro which enclosed the Agency's Addendum to theSupplemental Feasibility Study and Risk Assessment ("AddendumReport") for the Svope Oil and Chemical Company Site. Althoughmore detailed technical comments will follow, we wanted to respondto several issues in the Addendum Report.
The Addendum Report appears to discuss New Jersey SoilAction Levels ("NJSALs") as if they might be the cleanup goals forthe remediation of the subsurface soils at the Swope site. SeeAddendum Report, p. 14. The only purported basis for the use ofNJSALs is that EPA1s contractor, Camp, Dresser & McKee ("COM"),
100192
Dilvorth, pucson, Kalish i Xauffman Page 2To: Mr. Raymond Basso
could not verify the Soil Remediation Levels ("SRLs") which wereproperly derived by Geraghty £ Miller, the Swope Site CleanupCommittee's consultant, as part of the Risk Assessment for thesite. See Addendum Report, p. 6. However, as you well know, thereare several key technical questions which have prompted the Agencyto approve CDM's repeating the SRL verification effort withGeraghty & Miller's assistance. In light of this fact, EPA'sapparent decision to disregard the SRLs is at best premature andat worst a dereliction of Agency responsibility.
In any event, the use of NJSALs as cleanup standardswould be wholly inappropriate. As was correctly noted in theAgency's Proposed Plan of July, 1991, which was developed pursuantto the public participation requirements of CERCLA Section 117(a),NJSALs "are not promulgated ARARs". Proposed Plan, p. 12 (July1991); see also Addendum Report, p. 14 (stating that there are noARARs which dictate soil remediation levels). At most, the NJSALsfall within the To Be Considered ("TBC") category of environmentalguidelines. However, as is stated in the Preamble to the NationalContingency Plan, "TBCs should not be required as cleanup standardsin [40 C.F.R. 300.400(g)(3)] because they are, by definition,generally neither promulgated nor enforceable so they do not havethe same status under CERCLA as ARARs". Preamble to the NationalOil and Hazardous Substances Pollution Contingency Plan, 55 Fed.Reg. 8665 (March 8, 1990)(emphasis added). The Preamble furtherprovides that "EPA believes that TBCs are meant to compliment theuse of ARARs by EPA, states, and PRPs, not to be in competitionwith ARARs." Id.
Here, the Agency's apparent attempt to involve NJSALs asif they were ARARs — despite the fact that it has recognized thatNJSALs are not ARARs — is clearly at odds with the expresslanguage of the National Contingency Plan. Moreover, EPA'sapparent invocation of NJSALs at this late stage in the remedy-selection process could be construed as an attempt by the Agencyto evade the procedural safeguards in the NCP requiring the Agencyto consider, inter ' alia. the implementability, technicalfeasibility and cost effectiveness of a selected remediation planprior to the selection of that remedy. Accordingly, the referenceto NJSALs in the Addendum Report should be deleted.
In addition to being inappropriate and unenforceable asa cleanup standard under the NCP, it should be noted that NJSALsare also inapplicable to soil remediation plans. Under the NewJersey Environmental Cleanup Responsibility Act, N.J.S.A. 13:1K-6 et seq.. soil action levels are merely used by the New JerseyDepartment of Environmental Protection ("NJDEP") to determinewhether remediation mav be required. Once NJDEP determines thatremediation is required, cleanup standards are developed on a case-by-case basis depending on site characteristics. N.J.S.A. 13:IK-
1 Ironically, this is exactly the approach used by Geraghty& Miller in the Risk Assessment to derive the SRLs.
100193
Dilvorth, Paxson, Kalisb I Kauffaan Page 3Tot Mr. Raymond Basso
10(a). significantly, however, NJSALs are not used as s^sanupremediation standards — not even by the NJDEP, the agency thatdeveloped them.
Based on the foregoing, NJSALs are inapplicable andunenforceable as subsurface soil cleanup standards. Accordingly,it is recommended that the Agency reconsider the use of SRLs whichwere properly developed in the Risk Assessment. The Swope SiteCleanup Committee is prepared to discuss the issues raised in thisletter at any time. Indeed, we are hopeful that an agreement canbe reached on this issue shortly.
Michael L. Krander
Barbara A. Brown
On behalf of the Swope SiteCleanup Committee
cc: Peter M. Abel, Esq.Bernard Reilly, Esq.Mr. Rodney J. McQueenMr. Barry L. SamsMr. Charles E. StauberLeonard F. Charla, Esq.Mr. Anthony MontalbanoMr. Radford A. MeadDavid B. MacGregor, Esq.Ronda P. Bayer, Esq.Bonnie Fine Kaufman, Esq.Joel R. Kerz, Esq.Patricia Hick, Esq.Mr. Joseph CowersMr. John LaPadula
100194
ATTACHMENT B.2August l, 1991 Comment Letter from Geraghty i Miller Concerningthe Addendum to the Supplemental Feasibility Study and
Risk Assessment
100195
^ITGERAGHTY& MILLER, INC.nvironment] Services
Ground Water Engineering Hvdrocarbon Remediation Education
August 1, 1991
FOR INCLUSION IN THE ADMINISTRATIVE RECORD
VIA FEDERAL EXPRESS
Raymond Basso, ChiefNew Jersey Superfund Branch IIUnited States Environmental Protection AgencyRegion IIJacob K. Javits Federal BuildingNew York, New York 10378 - ,
Dear Mr. Basso:
Geraghty & Miller, Inc. and the Swope Site Cleanup Committee have reviewed the
United States Environmental Protection Agency (USEPA) Addendum to the Supplemental
Feasibility Study (FS) for the Swope Oil and Chemical Company Site, Pennsauken Township,
Camden County, New Jersey and are pleased that the supplemental FS has been approved
by the USEPA. We have the following comments concerning the FS addendum.
Arnold S. Vernick, P.E.Vice President/Project Officer
DN/BM'ASV/MFW:pg
" Vice President/Project Officer
100201
ATTACHMENT B.3August 5, 1991 Comment Letter from Michael L. Krancer,
Regarding the Preferred Remedy
100202
LAW OFFICES
DAVID H. PlTTINSKYTCOW if* M. GOLDSMITH, iJOHN r. SMITH, inTHEODORE A. VOUMOSTEVEN L. FRIEDMANRICHARD ft. CUTLCIVIIOSERT P. BEDELL"«TER J. PiCOTTE. IITT
THOMAS c. SLINEY-JAMES * MONTElTwSHERYL L. AUERB*CHJUSTIN R. KLEIN*MARK J. LEVINTHOMAS i. VAN AS* itJOHN W SCNMEHLRAUL W BASKOWS«YCARL W. HITT(NOE*>*STEPHEN O SURN*t
HAY MO NO PAUL PCPE»TE»HEN L. PARKIR*JOHN r. eooNcr*LOVIDA MARD'N COLEMAN. JR.*PAUL " SALERNO*MARRY I JACOBS'
.THOMAS j. FOLEY. '"JAMCS J 0REtNFIEt.D»MARRY J. CARR*MICHAEL L KHANCER
DILWORTH. PAXSON. KALISH & KAUFFMANJULES I WNITMANttWILLIAM J HENRICH.JOSCB* M. JACOVINIJOHN M. riTTBATHlCKCARL H HANZtL'K
THOMAS A. LEONARDrCDCC P. CUTLER'ROSSJ REESCJOHN PHILIP CRAMPTONRICHARD M SEGALROOERF WOODCARL O ROBERTSALAN J HOFrMANOOu
PAUL S DIAMONDJAMC9 J RODGERSDANIEL S EVANSPATRICK H McCARTMY*O
NELSONC JOHNSON*DAVID J LtVCNSON*EDWARD N. BAROLNANCY L. DASsorr*ROBERT * PHiLiPSON*ERIC HEYWOOD POOKRUM-
DOUGLAS M. LURiO"VICTORIA M KOMARN-CKIJAY s BLUMENKOPF*SCOTT N SILVERCJAMES T SMtTHC
S6OOTHE FIOELI/V BUILDING
PHILADELPHIA, PENNSYLVANIA I9IO9-IO94
1215) 875-7OOO
FAX 1215) 875-BS4O
WASHINGTON DCLOS ANGELES. CALIFORNIASCRANTON. PENNSYLVANIA
HARRISBURG PENNSYLVANIABOCA RATON. FLORIDA
WEST ATLANTIC CITY. NEW JERSEYCAM DEN NEW JERSEY
COUNSEL TO THE FIRMWILDAM M MARUTANlA
JAMES A BUTTONJ. ROOER WILLIAMS. JRJAMES W ARTZ*STEVEN A TAUBE"STEPHEN SCMACNMANA1ATMANIEL BUD"*'STANLEYS MCNDCLL*
COUNSELLAURENCE s SMTASELTT
DIRECT DIAL (215) 875- 8520
August 5, 1991
•TEVCN c COMBSMICHAEL P. OALLAOHERDOMiNtC S LiBtRi"*J ERiC RATMBURNBARBARA ALDCM BROWN*EDMUNDS J. SPOKANSTIMOTHY B BROOERICKT*«•ART DC LONEORCOORT F. ClR'LLO*CAMILLE J WOLF*JONATHAN J. BARTTtCHRiSTiNC S DUTTONJAN IS ABRAMS'J BRADFORD M*'L\'AIN"JOHN N ELLISON*VIRGINIA L FLICK ' .JEFFREY » OREENBAUMKENNETH E ZEILBEROCR*THOMAS C QROSMCNS•RUCE E. MARTMANOLIVER M JOHNSON IIMARTIN J WEI*ROBERT F ZiELiNSK****UIL R E CARP-CATHERINE a o OONNCLL*THOMAS J FACERDANIEL M QOLUBo*HEATHER H MOVERLYNN A ftOSNERPENNY M CONLT*
WALTER F CASPER- JMARIA T. DOUGLASSJAMES F. MANNION"SUSAN H STERN*
- NOT ADM i. TE D TO PA BAR" ALSO MEMBER OF FL BAR
RALPH J KELLYWILLIAM J. LEONARDLAWRENCE r. SHAYVIRGINIA H MILLERLAWRENCE A. MUSiCK*ROBERT I. rtELDtT*MARY T. TOMtCH'-TTKATHLEEN M McADAMSOJOEL L. FRANKHARRIET J KORENVICTOR P STABILESTEVEN L DANIELS*THOMAS D BROWNPATRICK T DAVISHMAURA E FAY*RICHARD L FOxtTSCOTT M SHEPHERD*BENJAMIN J BEMflEROOOERALD J. OUARCiNILISA A O DONNELLOMARIA R McOARRYJAMES J MCHUOH JRMARjORiE L MCMAHONJOHN P McLAUOHkiNMAROARET M CALLAHAM*OAMY A FOXODEBORAH riNKLE MITCHELL*KEVIN C OU1NNSTEVEN ROTHCHRISTOPHER R MOM JI ANJOHN V O HARAORANAE S McELVAiNE»OERALD E BURNS, uiJOSEPH DOMiMOUEZoMARTIN FARRELLOMARK A NATIONLAURA C VEND2ULES
SCR OF CA BAR
• ALSO MEMBER OF DC BARO ALSO MEMBER OF MA BAR00ALSO MEMBER OF DE BAR• ALSO MEMBER OF WJ BAR
Mr. Joseph CowersUnited States EnvironmentalProtection Agency
Region II26 Federal PlazaRoom 720New York, NY 10278
Re: Swope Superfund Site/Notice Letter toTriangle Publications
Dear Mr. Cowers:
Thank you for your letter of July 24, 1991 addressed to"Triangle Publication/ c/o Dilworth, Paxson" regarding the SwopeSuperfund Site. In that letter, you state that EPA is takingthis opportunity to notify Triangle "once again" that informationavailable to EPA indicates that the company is a potentiallyresponsible party with respect to the Site.
As you know, this firm represents Triangle, which is nowknown as News America Publications Inc., and others with respectto the Site. We do not agree with the Agency's suggestion thatTriangle is liable with respect to the Site and we believe thatwe have meritorious defenses to liability. In any event, as youknow, News America has cooperated with the Agency in theimplementation of remedial actions performed via threeAdministrative Orders on Consent and News America will entertainsettlement discussions with respect to the implementation of thefurther component of remediation outlined in the Proposed Planprovided that other parties participate and to the extent that areasonable Remedial Design can be agreed upon.
100203
Dilworth, Paxson, Kalish i KauffmanTo: Mr. Joseph Covers
Page 2
Also, your letter erroneously refers to EFA's currentproposal for remediation applicable to subsurface soil only. Ofcourse, the proposed remedial alternative applies to bothsubsurface soil and groundvater. The Agency itself hasrecognized this on numerous occasions. Just a sampling ofoccassions on which EPA has recognized this are the following.Raymond Basso, in a letter dated May 21, 1991, stated that "EPAbelieves that remediation of the source material would result inthe reduction of the contamination of the groundwater". Also,EPA's Addendum to the Supplemental Feasibility Study and RiskAssessment for the Swope Oil and Chemical Company Site notes thatEPA believes that soil vapor extraction would be effective inreducing subsurface soil contamination and thereby reducecontaminant migration into the groundwater.
Michael L. Krancer
MLK/ls
100204
ATTACHMENT B.4August 15, 1991 Comment Letter from Geraghty & Miller Concerning
the Proposed Plan
100205
MILLER, INC.nvironmental Services
Ground Water Engineering Hydrocarbon Remediarion Education
August 15, 1991
FOR INCLUSION IN THE ADMINISTRATIVE RECORD
VIA FEDERAL EXPRESS
Raymond Basso, ChiefNew Jersey Superfund Branch IIUnited States Environmental Protection AgencyRegion IIJacob K. Javits Federal Building -New York, New York 10378
Dear Mr. Basso:
Geraghty & Miller, Inc. and the Swope Site Cleanup Committee have reviewed the
United States Environmental Protection Agency (USEPA) Proposed Plan for the
remediation of contaminated subsurface soils at the Swope Oil and Chemical Company
(Swope) site and have the following comments concerning this plan:
SITE BACKGROUND
Page 4. Paragraph 1
As discussed in the supplemental Remedial Investigation (RI) report and reiterated
in the November 6, 1990 and June 27, 1991 letters to the USEPA, the difference between
upgradient and downgradient ground-water quality in the deep aquifer is marginal. As such,
these data do not conclusively demonstrate that the Swope site has impacted water quality
in the deep aquifer. Since MPWC Well 1 is completed in the deep aquifer, these data do
not conclusively demonstrate that the Swope site has impacted water quality in this well. As
stated by the USEPA, there are a number of unidentified sources that may be contributing
to the contamination of this well.
125 East Bethpage Road • Plainview, New York 11803 • (516) 249-7600 • FAX (516) 249-7610
100206
GERAGHTY'of MILLER. INC.
2
SUMMARY OF THE SUPPLEMENTAL REMEDIAL INVESTIGATION AND ADDEN-
DUM
Page 5. Paragraph 2. Note 4
.It should be noted that some volatile organic compounds (VOCs) but not all VOCs
were reported at higher concentrations downgradient than upgradient of the Swope site in
the deep aquifer. In fact, some VOCs were reported at higher concentrations upgradient
than downgradient of the site in the deep aquifer. Therefore, these data do not conclusively
demonstrate that the Swope site has impacted water quality in the deep aquifer. This has
been discussed in detail in the supplemental RI and Feasibility Study (FS) reports, as well
as the November 6, 1990 and June 27, 1991 letters submitted to the USEPA.
SUMMARY OF SITE RISKS
Page 6. Paragraph 1
In this paragraph it is indicated that only risks presented by the presence of hazardous
substances in ground water were evaluated in the Swope site risk assessment (Geraghty &
Miller, Inc., Supplemental Feasibility Study for the Swope Oil and Chemical Company Site,
Pennsauken Township, Camden County, New Jersey, Volume IV of IV, May 1991). Risks
presented by the presence of hazardous substances in subsurface soils were also evaluated
and quantified in the site risk assessment.
Page 6, Paragraph 2
This paragraph does not include the following three exposure routes which were
assessed in the site risk assessment: (1) oral, dermal, and inhalation exposure to subsurface
soils by a future construction worker; (2) oral, dermal, and inhalation exposure to subsurface
100207
GERAGHTY #'MILLER. INC.
3
soils by a future adult resident; and (3) oral, dermal, and inhalation exposure to subsurface
soils by a future child resident.
Page 7. Paragraph 1
This paragraph states that human health risks from the drinking of contaminated
ground water were calculated to have a hazard index of 3.8 and an excess lifetime cancer
risk of 4.2 x 103. It should be noted that these values are calculated for a resident that lives
in the same home for 75 years and drinks 2 liters of water per day, 365 days per year.
Page 7. Paragraph 2
This paragraph states that risks associated with dermal contact and ingestion of site
soils have not been quantified in the site risk assessment. While it is true that extensive soil
remediation has been performed by the PRPs, and potential risks associated with contact
with soils at the site are considered to be minimal, nine future hypothetical scenarios
(construction worker, adult resident, and child resident subject to oral, dermal, and
inhalation exposure to subsurface soils) were evaluated quantitatively in the site risk
assessment (Geraghry & Miller, Inc., May 1991). The hazard indices and excess lifetime
cancer risks for the exposure to subsurface soil scenarios were calculated and found to be
below the values typically deemed "acceptable" by the USEPA. ~- --'—^ ^=- -
SUMMARY OF ALTERNATIVES
aee 9
Alternative 2 should be entitled "Ground-Water Monitoring Program, Soil Vapor
Extraction, and Natural Biodegradation." The annual operation and maintenance (O&M)
cost for the ground-water monitoring program is estimated to be $222,000. Therefore, the
present worth O&M for this program, at an interest rate of 10 percent and an inflation rate
100208
GERAGHTY & MILLER, INC.
of 5 percent, over a 5-year period would be $967,503. The capital cost of $687,400 is that
capital cost estimated for the vapor extraction system (VES), only. As stated in Table 7-1
of the Supplemental FS Report (Geraghty & Miller, Inc., May 1991), the first year O&M
estimated cost that was calculated for the operation of a VES at the Swope site was
$281,000. Therefore, the total estimated cost for Alternative 2 is $967,503 plus $687,400 plus
55281,000, or $1,935,903, for one year of VES operation. This estimated cost does not
include any costs for bioremediation enhancement.
Page 9, Paragraph 3
It is stated in this paragraph that the effluent air stream from the air blower will be
passed through a catalytic oxidizer. It should be noted that for purposes of cost estimation,
worst case scenarios were considered. Thus, catalytic oxidation as a means of air emission
control represents a worst case scenario. The actual air emission control equipment that is
to be included in the final VES design will be determined during the remedial design (RD)
phase of this project.
If you have any questions concerning these comments, please do not hesitate to call.
DJN/BM/ASV/MW:pg " Michael WolfertbaK.H5.ie, Vice President/Project Officer
100209
APPENDIX CLetter from EPA's Contractor Concerning Geraghty £ Miller'sVadose Zone Modeling and Proposed Soil Remediation Levels
100210
C O M F E D E R A L P R O G R A M S C O R P O R A T I O N
September 13, 1991
Mr. Joseph CoversU.S. Environmental Prrotection Agency26 Federal PlazaNev York, Nev York 10278
PROJECT: TES V, Contract:68-V9-0002Vork Assignment C02032Svope Oil and Chemical SitePennsauken, Nev Jersey ~~~
DOCUMENT NO.: TESV-C02032-LR-CDXH
SUBJECT: Reservations concerning Soil Remediation LevelsDerived by the PRP using a Vadose-Zone TransportEquation
Dear Joe:
This letter synthesizes COM FEDERAL PROGRAMS CORPORATION'S (CDM FPC)evaluation of the soil remediation levels derived by the PRPcontractor, Geraghty and Miller, using a modified contaminanttransport equation for the Svope Oil and Chemical Site in PennsaukenTownship, Nev Jersey. Our comments are based on extensive reviev ofthe PRP's data and the equations used, as presented in the PRPFeasibility Study, including sensitivity analysis of the equation tovarious parameters. This summarizes our comments as presented to EPAin our technical revievs, dated January 23, 1991, and June 24, 1991,of the draft and final FS reports and our June 27 letter reportreviewing the PRP equation and presenting additional SRL calculationsperformed by CDM FPC.
The "Model"
The model used to calculate soil remediation levels is a simplifiedsolution to the one-dimensional partial differentiation equation usedfor saturated flov contaminant transport, for compounds vhich decayvith time and are adsorbed by the soil matrix. As such, it is probablymore appropriate to refer to the model as an equation, or ananalytical solution.
The analytical solution is a one-dimensional transport equationdeveloped by Van Genuchten and Alves (1982) to estimate theattenuation of organic chemical constituents in the saturated zone.The analytical "model" vas not designed as a "vadose-zone transportmodel". It has been modified by the Gradient Corporation (in apresentation of analytical models at the "Management of ManufacturedGas Plants" seminar organized by the Gas Research Institute in Chicago
-1-
111 Fulton Street, Suite 710 New York. NY 10038 21?
100211
' COM FEDERAL PROGRAMS CORPORATION
in 1988) to represent unsaturated zone contaminant transport byassuming a constant average groundwater velocity through the runsaturated zone,,-which is assumed to equal the recharge rate *at thesite. The revised equation specifically calculates the concentrationof a chemical compound in the leachate as it moves through theunsaturated zone at a specified soil depth and transport time.
The fate of a chemical constituent in the soil column depends on itsmobilization, volatilization, and decomposition rates. Contaminanttransport through the unsaturated zone is extremely complex, andrequires large amounts of data input to adequately describecharacteristic processes affecting the transport of chemicalcompounds. The modified Van Genuchten equation only considers aerobicbiological decay of organic compounds, but ignores important physicaland chemical processes in the unsaturated zone such as:
- volatilization - -- adsorption- soil moisture characteristics- time-dependent infiltration- oxygen transport- mass fluxes of constituents between air, water, and hydrocarbonphases
- the associated exchanges between each phase.
As such, the "model" does not simulate true field conditions. Rather,due to the simplistic analytical-approach and generalized assumptionsinherent in the solution, this method grossly oversimplifies a verycomplex transport system. In addition, the sensitivity analysesperformed by COM FPC (letter report dated June 27, 1991) indicatedthat the equation's results are very sensitive to small changes in thedecay rate and the fraction of organic carbon applied to the equation.More importantly, significant fluctuations in calculated SRL'soccurred depending on the method chosen to calculate the complementaryerror function (erfc) values. ,,. ._
Consequently, CDH FPC has little confidence in the applicability ofthe SRL results calculated by Geraghty and Miller, and believes soilremediation levels should be based on more empirical solutions.
If you have any questions concerning these comments, please do nothesitate to contact me at (212) 393-9634.
