Superfund Record of Decision: Wade Site, PA

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Superfund Record of Decision:

Wade SiteA ,P

000466 INSTRUCTIONS i, REPORT NUMBER Inxn Hit LPA icpoii number 11 li ipptui on the com of the publication. 2. LEAVE BLANK J, RECIPIENTS ACCESSION NUMBER Relented for UK by cavil itpon recipient. 4, TITLE ANP SUBTITLE Tlllc ihould indiciic clculy mil briefly ihc lubicci covcrafc at HK< report. and tw Ji<|il.i) i-J imnmiu'nil> .so wiunl?. n1 md, in iiiulu<> type or oihcrwlK lubordlnilc II lo mun Hilt, when * report l> prepiied IP mure Nun MV loluiiic, wpiMi llw iininaiy IIIK< jilj toluim' numbe d includrin e lubiul ipccifli ih r tcfo ink. I, REPORT DATE h reporbc t (full cisr dili y c Indicilln Icail fi l monl yeard hin . IndlraU w I unttliuln N 'U i n.i.wkMcd ns Jai c ,11 iuue dih-ol tpproHl.tliltofprtpintian.tle.l, ' ' I, nflrORMINQ ORGANIZATION CODE Utii blink, 7. AUTHORISI Olit nimtiil In wnrentionil order IMm R, Pot. / Ketxrl Dot, eie./. U»i juihur't alllluuun II' II iliilvit Iruni iliv ivrliiimiiii: »iuin- ullon, I, MltFORMINQ ORGANIZATION REPORT NUMBER Inmt If performing or|ininiion WIITIII 10 anifn ihi> number, t, PIHroilMINQ ORGANIZATION NAME AND ADDRESS Give rum, incti, cily, line, mil ZIP code. LIII no more ihin 1*0 lutli ol an oif jni/jimnjl liinuMi) . 10, ritOGRAMILIMiNT NUMBER profne (h K mU element number under wrik rcporc prcpircdh\ Ih lwj , Suboiilnulc nunik iiuliulfiN I > hnu l in luti'iiilu'wv 11. COflTRACT/QRANT NUMBER IBMI nmBKi M pint number under which upon w» prcpucd, 12, IWWORINaAOBNCY NAME AND AOOREK IneludtZtfcodt, 1J, TYPE OF RlfORT AND PERIOO COVERED Imilciie inlerim fuul, elf,, ind If ipplitible, dilci t,o*cred, 14, tPOttURINOAOkNCYCODE Insert ippropriale code. IB, tUPPLEMENTARV NOTES Enter Infomulion not included elwwneie but uteful, luch »: Prepared in vooperniiun wnli, I r,in>Uiiini ul, I'H-H'IIMI ji uniii'i.'ii,,' m, publlitii« b o T SupcrKdci, dIn , Supplcmcnli, etc, IB, AKTRACT Include i brief (100 watli or Iml ficluil wmmirx of the moti M^niliutii inluirrwiinn lunumnl m ihr iqmii. II iln' iv|»ni nmjw, i ilinmctni blblloiriphy or liieriiurc lutviy, mention n here. WORDY 17 .DOCUMENKE D SAN T ANALYSIS DESCRIPTOR) (I SSelec• t Thcuuru froc Ih m Lnjmminf o i Stmilild »an n Itrnis ihv piupti juilmn/tU inim ilui iilcnlily th\ em concept of the KKirch and ire luffiefenlly ipecilic «nd prcciw lo be uwd t\ mdvx cntnci lur i (b) IDENTiriERS AND OPHN^ENDED TERMS • UK IdinnOen for proieul ninns tudc nimtt, vquipmvnt dvMcnitors rlv. Uw linen, ended tctmi written In dcicrlpior form for thoK Hibfccii for which no dcwnpiw CMIII. (c) COSATI I ICLD GROUP • Held ind fioup iul|nmcnli ire lo be Mm dam Ihc I ¥65 «>SA1 1 Suli|vvl CaU'pny I,IM, lilniv Ihc mi. >orli documentf yo mullldlKlpllnire !ir niturcn yi Primarc ,Ih (tld/GiouI y p imiinmuiui tnnililv » lMb N liuiwiplincl n u.J m n,a Mduvor typr , o phyiio f eo l object ippliciuonlie ,Th ) wil croMieicrvnne lb h wi'umljrdwu ii'liir(iiiMi|I y > ^Mpninvul* that will Inllim Iht pclnwy poitinilil. IB. DIITRIEUTION STATEMENT Denote rehiubilllv to Ihc public or linniiiion for rciwnt other Ihin wtuniy for tmmplc "KdvjM' li'iiliiuiiul," <'ilv tm auiljluliiy in Ihc public.Vnh iddrci pnccd ian , It. fSECURIT. tM Y CLASSIFICATION DO NOT Hibmll cliulflcd icporii lo ihc Nilionil Technical Informmiun wrvitc. 21, NUMBER OF PAGES Inwi Ihc loul number of pi|«, includini ihii one ind unnumbered pj|t\ tiui eiduilv dhtnbuiiun IIM, il any. PRIC. 22 E Inurl Ihc puce KI by the Nitloni! rcchnicil Informxion SvrvKi1 ur Hit Coiurnmcm I'tinimt Olfkv, il known . • 000467 EPA F«m J2JO-I (Ri>, 4.771 (Ri..rit) TECHNICAL REPORT DATA Ifltut nail Imintliem on tht mint it/on compliling: 1, REPORT NO. EPA/ROD/R02-8V009 4. TITL SUBTITLD EAN E 9 REPORT DATE ' "~ SUPERPUND RECOR DECISIONF DO : OB/30/8.1 Wade Site (ASMA P ), 0. PERFORMING OROANIZATIONCODE

7. AUTHORISI IS PERFORMING ORGANIZATION REPORT It

>. PERFORMING ORGANIZATION NAM ADDRESD EAN S -:.....,-.,,«..,.-,.

1J. SPONSORING AGENCY NAM ADDRESD EAN S 13. TYPE OF REPORT AND PERIOD CO VERE U.S. Environmental Protection Agency Fina D ReoorRO l t 401 M Street, S.W. 14 SPONSORING AGENCY CODE Washington, D.C. 20460 800/00

10, SUPPLEMENTARY NOTES

i«, ABSTRACT The Wade site i? a three acre parcel of land on the banks of the Delaware °,iver. It is located nine miles .->uth of Philadelphia in Chester, Pennsylvania. Prom approximately 1950 until the early 1970's the site was the location of a rubber recycling facility which shredded tire othed san r post-consumer rubber products. During the early 1970' site s convertesth e wa illegan a o t d l industrial waste storagd ean disposal facility. Drum wastf so e were emptied either directly ont" groune 4- oth r do trenches, severely contaminating soil and the ground water, Approximately 150,000 gallon wastf so e cherricals remain on-site, The recommended alternative selected for this site consists of: removal, decontamination and disposal of on-site tires and tankers, removal of on-site waste pilesi demolishing buildings, leveling the site, and filling and grading the property inche2 1 o t s p oveu existine th r g grad coveo t eprotrudiny ran g subsurface structures which have not been removed) removal down to the depth at which the first acceptably contaminated sampl s founewa d (base contaminatioa n do n cutoff level recommendei th y db RI/FS contractor) coverind ;an site gth e with top-soio t seedind p lan ca e gth minimize erosion. Key Words; Compliance with Environmental Laws, Negotiations, Capping, Excavation, Ground Water, Cost Recovery, Potential Responsible Parties 17, KEY WORDS AND DOCUMENT ANALYSIS 1. DESCRIPTORS b.lOENTIPIERS/OPEN ENDED TERMS c, COSATI Field/Group Record of Decision: Wade Site (ABM) , PA Contaminated media soil, gw r :,ai Key contaminants: over 100 organics, metal ,nd inorganics

II. DISTRIBUTION STATEMENT None 30 PRIC, 21 E SECURIT. 90 HonY eCLASS iTHll flfll I PA P«M 1220-I (Hi*, 4-771 rnivioui C.OITION it onomt 0004.68 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20«0

J'.'L 30 1934

SUBJECT: Snisrsement Decision Memorandr Approvar fo a f o l Remedial Action at the Wade s.ite,,/ Chester, Pennsylvania FROM: Russe Wyer. H l , Hazardous Site Control Di^siofc (WH-548E) : TO Gen Lucero. eA , Director Office of Waste Programs Enforcement (WH-527)

The Enforcement Decision Memorandum and the Focused Feasibility Study for the Wade Site has been reviewed by my staff. :

I Concur *

I Do Not Concur

ConcuI r with Comment

r?Q ENFORCEMENT DECISION DOCUMENT REMEDIAL ALTERNATIVE SELECTION ^ Site: Wade Chester, Pennsylvania Documeats Reviewed I am basing my decision on the following documents describing the analysis of the cost and effectiveness of remedial alternatives for the Wade Site: - Focused Feasibilit! y Study, Wade site, Chester, Pennsylvania, Metoalf & Eddy, Inc., April 1964. - Draft Report, Result of Soil Analysis and Cost Estimates for selected Remedial Activities regarding (•he Wade Hazardous Waste Site in Chester, PA, RoWeston. F y , November 1983. - Summar f Remediao y l Alternatives Selection - Public Comment d Recommendationan s s - Responsiveness Summary Description of Selected Remedy - remove and dispose of tires and tankers - remove on-site waste piles - demolish buildings - test contentsi remove contents, and close two underground storage tanks The building on this site will be demolished and the remaining slabs wil e lefb l n sittr o futur fo e e usel Al , demolition rubble will remain on the property and used for fill material. - level debris, filgradd an l e property - remove and dispose of contaminated soil purpose Th f thieo s activit removo t s i ye froproperte th m y any contaminated material and any material that will,hinder subsequent effort o fild gradt s sitee an l th e . cove- r with topsoi seed p an lca d i - operatio d maintenancan n i f sito e e o 000470 r

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Peclarations Consistent wite Comprehensivth h e Environmental Response Compensation and Liability Act of 1980 (CERCLA) and the National Contingency Plan (40 CFR part 300), I have determined the removal, decontamination and disposal of tankers, tire d debrisan s ; destructio f buildingso n , leveling, filling and grading the site; and covering with a seeded topsoil cap at the Wade site is the least costly alternative, of all the remedial options reviewed that provide r currenfo s d futuran t e protection of public health, welfare and the environment. The State of Pennsylvania has been consulted and agrees with the approved remedy. In addition, the action will require future operatio maintenancd an n e activitie o ensurt s e th e continued effectivenes e remedyth f o s. Settlements have been reache e responsiblth d d betweean A eEP n parties based on the selected remedy. havI e also determined thaactioe th t n being taken which include off-site th s e transpor f contaminateto d materiala o st RCRA approved lined facilit e leasth ts i ycostl y alternative when compare othee th ro t dremedia l options revieweds i d ,an necessary to protect public health, welfare, or the environment.

rDater M. Thomas Assistant Administrator Offic f Solio e d Wastd ean Emergency Response

ono4.7i •S _£*_ \ Ul ITET STATES ENVIRONMENTAL, PROTECTION AGENCY WASHINGTON, D.C. 20460

'"N :««iet ct AU63 I9W SOilDWAS't I'.: SMSRdlNC' RESPONSE

MEMORANDUM SUBJECT: Enforcement Decision Document Approvae th r fo l Remedial Action at the Wade Site, Chester, Pennsylvania FROM: Gene A. Lucero, Director Ow^ n< Offic Hastf eo e Programs Enforcement TO: Lee M. Thomas Assistant Administrator This Office has reviewed the Enforcement Decision Document and the Focused Feasibility Study for the Wade Site. I recommend that you approve the recommended alternative which will provide r futurfo e protectio publif o n c health, welfaree th d ,an environment.

000472 4\ ' ' I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY / ' WASHINGTON, D.C, 20460 AUG 11984

MEMORANDUM SUBJECT: Enforcement Decision Memorandum for Approval of Re-medial Action at the Wade Site, Chester, Pennsylvania FROM! Frederick F. Acting Associate Enforcement for Waste (LE-134S) : TO Gen Lucero. eA , Director Offic Wastf o e e Programs Enforcement (WH-527)

e EnforcemenTh t Decision Memorandu Focusee th d dan m Feasibility Study for the Wade site has been reviewed by ay staff. I Concur ___ I Do Not Concur ConcuI r with Comment

000473 ..-v Summary of Remedial Alternative selection Wade Site Chester, Pennsylvania

Site Location, Description and History The wade site is a three acre parcel located on the banks of the Delaware Siver, just nine miles south of the Cit f Philadelphiao y Chester, ir , , Pennsylvania e sitTh .s i e located in the industrial portion of Chester and is two blocks froe residentiath m l portioCitye e sitth Th .f e o n is bounded by the Commodore Barry Bridge, the Delaware River a railroa, d right-of-way d propert,an ye owneth y b d Philadelphia Electric Company. From approximately 1950 unti earle th l y 1970's e locatioth site s ,th wa en of the Eastern Rubber Recycling Company, a firm which shredded tires and other post-consumer rubber products. s abandonewa Thi e us s d durin site e 1970's th th ge wa d san converted to an illegal industrial waste storage and disposal facility. Drums of wastes were emptied either directly onto the groun r intdo o trenches, thus severely contaminating soil at several locations, as well as jeopardizing the ground water beneat sitee Februarn th hI . y 1978 a fir, e brok whict eou h o severs s ewa tha Commodore tth e Barry Bridg closes ewa r fo d fireme5 6 hour4 d san n required examinatio locae th lt na e sithospitalth e f a resulbuildinge o fire s th e A .,on f t o s •.,'23 completely destroyed and two others were seriously damaged. Large piles of debris containing exploded drums, building materials, tires, and shredded rubber (from the rubber re- irycling operations), and chemically-contaminated earth littered the property. Approximately 150,000 gallons of waste chemicals remained afte e fireth r materiae ; th mos f to s containe lwa d in 2,500 55-gallon drums located inside the fire damaged buildings, althoug ha larg e portio s store bul5 nwa n ki d tankers in the front lot. In 1980 and 1981, contractors were engaged by the Pennsylvania Department of Environmental Resources (DER) and the U.S. EPA to remove and dispose of the drums (and their contents) contained in the buildings, to remove and dispose of the contents of the tankers, and to perform an investigation of the site's soil, ground water, and air quality. HESTON personnel served as the DER Site Representative for the day-to-day monitoring of Contractor activities.

000474 s

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Subsequen above th eo t ton-sit e activities, CECOs Swa engaged by the DER in the summer of 1983 to investigate and characteriz remainine th e g hazardou non-hazardoud san s elements of the site, such as debris piles and contaminated soil. The following activities composed the scope-of-work for CECOS: . 1 "pick through debrie th " d rubblan s o isolatt e e all drums; . 2 analyz e contentth e f drumo s s containing chemicals; . 3 repackage leaking drum securn i s e containers; . 4 stage drums containing chemical accordancn i s e with their contents; 5. crush all empty drums; 6. analyze soil and uebris for contamination; . 7 determine location d quantitiesan f contaminatedso - ••• 0 . . soi d debrislan d ;an B. determine quantitie compositionsd an s f drumme,o d chemicals. ' " In additio e aboveth o t ,n CECOS stage e debrith d s into separate piles (for tiros and shredded rubber, wood, scrap metal potentialld an , y contaminated soil d transporte)an d and disposed of all drums containing chemicals found during the site characterization. Since the number of drums containing chemicals was not known until the characterization was complete, removal and disposal of such drums were not included in the scope-of-work, as describe DER'e th sn i d reques proposalr tfo r thisfo s site characterization. It turned out that there were 750 drums containing chemicals. It was decided from a cost and safety standpoint that these drums shoul e removeb d d disposean d d under this contract rather than placing them in secure storage on the site for disposal under a later contract. The Contractor, therefore s directed,wa , unde explicin ra t contract optio r "out-of-lumnfo p sum" work perforo ,t e th m disposal activities. Empty drums werdisposet no e . of d

000475 r

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CECOS was on the site from August 1 to September 10, 1983. 'During that time approximately 5,000 cubic yards : of debris were picked throug d stagean h n separati d e piles, approximatel 0 drum75 y s containing chemicals were characterized; ; wastes were repackage n securi d e containers when : necessary; scnbineci in compatible groups when possible; 630 drums were disposed; and 320 soil samples were obtained and analyzed. The DER monitored work acceptability and efficiency through persons formall e CECOy th name n S (i dContract s )a Cleanup Director and site Representative. The Cleanup Director had ultimate responsibility for the site and for monitorin e Contractor'th g s performance e sitTh .e Representa- tive was an employee of WESTON who was on-site full-time and represented the Cleanup Director in his absence and was authorize mako t d e specific decision e DERn behalo sth .f o f All cleanup actions taken to date at the site by the DER were done witconcurrence th h f EPAeo e Agenc.Th s intimatelwa y y involved, both technically and legally, in the development and implementation cleanupphasee th f proposel so Al . d actions were reviewed to assure that they complied with p Federal environmental regulations which existed at the time. ^ A separate report has been prepared by WESTON titled, • I "Cost Estimate r Selectefo s d Remedial Activitie n Responsi s e to Hazardous Conditions present at the Wade Property in Chester, Pennsylvania. e analyticaTh " l resultsoie th l f so sampling program performed by CECOS are presented in that report since they provid cose th basie t r th eestimate fo s f so removing contaminated soil. A focused feasibility study ' (FFS d Endangermeri)an t Assessment for the Wade site were tasked to Metcalf & Eddy, Inc., by EPA in February 1984. The FFS considers the endangerment and recommariijs the most cost-effective remedial alternative.

000476 ^ - • .-,- "..,.,- '....' ' . .1 ' !, . .

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Current Site Status A' plan • .e sit • 'th s presentei e e n Figuri dTh . 1 e grid raar'i.v : ihown on the figure were used for locating the soil samplin e seegb pointsn ca froe figures th A m. , the sice contains seven structures, four rubber storage tanks, seven tankers a ,pum p pitd elevean , n pile f debriso s . The structures vary in structural integrity from moderat o poort e l havin,al g been damagee firn th i e y b d 1978. Although not indicated by the figure, the concrete pad e flooa two-storunderlyinth f ro s wa 3 y2 g d gridan 2 2 s ston d bricean k building whlci s completelwa i y demolished e fireith n . Ther heavs i e y machinery bolte o thit d pa s d alse buildin an placn th i o n i e g encompasse y gridb d s 24, 25, and 26. In general, the buildings on the site pose a physical hazard, due to lack of structural integrity, to persons entering them or walking near them. The tankers are empty with the possible exception of rainwater .sevee th Fiv nf eo tanker s were use contaio t d n soli semisolid an d d chemicals which were removed an d disposed during the DER's cleanup operation in 1980. Likbuildinge th esitee th structurae ,n th s o l integrity of the tankers ranges from moderate to poor and it is assumed that none of them is able to be towed over the road supported by its own undercarriage. The pump pit is a concrete rectangular structure greater than 15 feet deep and currently back filled with t believeno connectes s i soili e t t dth i pi , thao e t d th t river though it historically contained a pump used to obtain proces rubbese th wate r r fo rcompany' s operations. e pileTh debrif so s locate severat a d l e partth f so site were forme e sitresula th s ea df o tcharacterizatio n and contain separate categorie wastef so , suc : tirehas s and shredded rubber, potentially contaminated soil, scrap metal, scrap wood, and crushed empty drums. All of these separate materials were formerly found mixed together in scattered piles across the site prior to the site characterization. The site itself is level a1d essentially barren of vegetatio excavatioo t e ndu gradind an n g performed during the site characterization. Vegetation was present, however, prio o thost r e activitie expectes i t i o returnd t dsan .

000477 000473 fir- ...^^-vL.,..:.'!tci

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Over one hundred different organic and inorganic compounds and metals have been identified on the Wade property durin course th g f investigationeo e siteth .t sa Whil e majoritth e y have been identifie n surfaci d e soils many have been detected in both air and ground water samples taken from the site, Sampling by R.F. Weston indicated that contamination of soils on the site is widespread. Weston divided the sits into approximatel grid0 6 y d samplesan r totafo d l volatile organic compounds (VOC d totaan ) l baseneutral and acid extractable (BNA) fraction f prioritso y pollutants at four points within each grid. Their results showed contamination by VOC, BNAs, or both of the top 12 inches of soi nearln li y every grid generaln I . fractioA ,BN n was present in higher concentration than the VOC fraction. Despit e numerouth e s investigations that have taken place on the site, the data do not easily permit generali- areae zatioth lf no exten f contaminatioo t e on y an y nb compound. compounde th Man f yo s foun n sito d e have been associated wit varieta h f healto y h effect humansn i s , laboratory animals r both,o , when inhale r ingestedo n i d sufficient quantities t leasA .x organi si t c compoundr o s classes of compounds are suspect human carcinogens; benzene, chlorinated benzenes, chloroform, tetrachloroe- thylene, trichloroethylene d b,is(ethylhexy,an l phthalate). Certain metals found at the site - hexvalent chromium and arsenic - are also suspect human carcinogens. Lead is also present in the soils and ground water. e principaTh l conclusion e drawb o t sn froe sitth me investigation and endangerment assessment are: monitorine . Baseth 1 n o d g results, concentrationf so volatile organic compounds on the Wade site do not present acute exposure hazards to persons on or off site, Although low by acute standards, concentrations of benzene found did present slighty elevated lifetime risk f canceo s o persont r s directl n siteyo ,

000479 -7-

2. Inhalation/ingestion of contaminated soil in potentiall mose th yt serious rout f exposuro e r fo e persons entering or playing on the site, under the assumption , lifetimFS e s th use en i drisk f canceo s r !!0"4) from inhaling/ingesting small amounts of contaminate e sitd th soie n o werl e higher than risks :':.?,11 other routes of exposure. Sampling results indicate that the concentrations of benzene found on the site associatear e d with risk f canceso r that e 5-1ar 0 times higher than those consideres a d negligible. This finding applies onl persono t y s with chronic exposures to soil on the site (i.e., children playing on the site over long periods of time). No evidence of potential acute health effects were found, a finding consistent with results of a study by the Center for Disease Control. . 3 Persons enterin exposee b site y th go toxima e t d c contaminaten i d chemicalan r ai de s th soibot n li h and are therefore the most susceptible population at risk from contaminant e Wadth e n o ssite . 4. Underground tanks and tunnels, structurally damaged buildings, and piles of flammable debris present immediate safety hazards to persons entering or playing on the site. . 5 Drinkin gt likele wateno b d fiso e t an yrar h significant route f exposurso o chemicalt e s from the Wade site. Ground water beneat site s th hi e sourca t use s no a df drinkin o e g wated an r concentration f chemicalo s e Delawarth n i s e resulting from contaminated ground water discharge to the Delaware are estimated to be negligible. . 6 Contaminatio Wade th et expecte n no sito n s i eo t d have a serious impact on the environment either through volatilization of chemicals to the air or release of contaminants via ground water to the Delaware River. Doth releases have been estimated to be extremely low.

000430 -8-

Enforcement Ip December of 1978, EPA asked the Regions to list candidates for RCRA S7003 actions. The Pennsylvania DER, whic d unsuccessfullha h y ordereo t M d AS Wad d ean e sit clean 1977th i e p u n, recommende e Wadth de site. Waste leaking, spilled, or otherwise disposed from drums, tank r otheso r containers deeme provido t d n a e imminen d substantiaan t l endangermene o healtth t t d an h environment by the EPA. On April 20, 1979, the EPA commenced, a civil action against Wade and ASM. The Court ordered them to clean up the site. The complaint was amended in March of 1980 to join Ellis Barnhouse and Frank Tyson, former presidents of ABM. When it became apparent that the current defendants were insolvent ,yeaa r long investigatiof o n ABN's generator customers took place, Afte2 r3 generators millio6 settle1. r nfo d dollars sueA e ,EP th d remainin generator6 g e originath n si l clean-up action i n December of 1981. In September of 1982 the Court dismisse injunctive th d e relief claims againse tth generator A theEP n d commencesan CERCLda A S107 cost recovery action which is the current basis for the action agains generatorse f 1984th to y remainine ,Ma th n I . g generators agree Statee settlo t dth d .ean witA EP h Settlement agreement beine sar g negotiated.

000431 fr~

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Initial Remedial Alternative Screening Se'veral alternatives were evaluate Mitrey b d , NEK, Weston, EPA and DER. Based on an initial screening, the following alternatives were rejected: . 1 Volatilizatio f volatilo n e contaminanty sb excavating the soil and spreading it in thin layers and turning periodically to expose it to the atmosphere or placing the soil in windrows. This technique was rejected on the basis of low efficience smalth o le sitet th size o ,f n du yeo off-site location available o removan , f BN/o l A contaminants, the requirement of ait monitoring, unpredictable weather conditionse th d ,an possible requiremen f mechanicao t l aeration. 2, Land farming and composting, for aerobic degradation of organic contaminants. This alternative was rejected because of the possible requirement for commercially-developed mutant ,•'" factor ia, the low concentrations of organic 'i Material presen e soilth n ,i t required treatability ""studie d pilosan t testing, specialized equipment, long processing times, continuous monitoring and because the technique had not been proven for decontaminatio f soilo n . 3. Creation of a secure cell on-site, by means of an impermeable cover, continuous monitoring of ground wate possibld an r y impermeable side wall r lineso r to prevent migration of contaminants away from the property boundaries. This alternative was rejected because the contaminated soil would remain in an urban area e cel,th l would perpetualle b hav o t e y monitoried, the hydrological properties of the site are not suitable for a secure cell, the property would have to be restricted from other use and State and Federal permits may be required. 4. Total removal and off-site disposal of soil at a licensed, secured landfill and backfilling the site with imported soil. This alternativ rejectes ewa d because site investigation show e soith sl contamination is localized in discrete areas and because of the high cos f thito s solution.

000482 -10-

Reroedial Alternative Screening In orde perforo t r detailea m d evaluations wa t ,i necessary to develop a list of remedial alternatives which would includ ActioNo a e n Remedial Alternative. MeteaI& f Eddy develope alternative2 1 d Wade th e r sitefo s , basen o d Weston's six soil removal options. (See Table 2 for soil removal options.) Alternatives: Actioo N . n1 2. Remove, decon & dispose of tires & tankers, remove on-site waste piles; demolish buildings, level site, filgradd an l e property. 3. Remove, deron s dispose of ti'.-os & tankers, remove on-site waste pile; demolish buildings, level site, , fil d gradan l e property, cover with asphalt cap, 4. Remove, decon 6 dispose of tires & tankers, remove on-site waste piles; demolish buildings, level site, filgradd an l e property, cover with topsoid lan seeded cap. 5. Remove, decon t dispose of tires t tankers, remove on-site waste piles; demolish buildings, level site, filgradd lan e property ^*oll removal optio, 1A n cover with asphalt cap. 6. Remove, decon t dispose of tires t tankers, remove on-site waste piles; demolish buildings, level site, fill and grade property, soil removal option 1A, cover with topsoi d seedelan d cap, 7. Remove, decon & dispose of tires i tankers, remove on-site waste piles; demolish buildings, level site, filgradd an l e property, soil removal option 1C, cover with asphalt cap. 8. Remove, decon t dispose of tires t tankers, remove on-site waste piles; demolish buildings, level site, fill and grade property, soil removal optio cove, 1C n r with topsoi d seedelan d cap. . 9 Remove, deco disposnt f tireo e tankerssi , remove on-site waste piles; demolish buildings, level site, fill and grade property, soil removal optio cove, 2A n r with asphalt cap. . Remove10 , deco ndispos& f tireo e tankersc sf , remove on-site waste piles; demolish buildings, level site, fill and grade property, soil removal option 2A, cover with topaoil and seeded cap.

000483 \r -11-

11. Remove, decon & dispose of tires & tankers, remove on-site waste piles; demolish buildings, level site, fill and grade property, soil ' removal option 2C, cover with asphalt cap. 12, Remove, decon & dispose of tires s tankers, remove on-site waste piles; demolish buildings, level site, fill and grade property, soil removal option 2C, cover with topsoil and seeded cap. Screening Considerations: A. Ground water The hydrological evaluation determined that the Delaware River is the outflow point for ground water from the Wade site. The results of the evaluation indicate that ,organil baseal n do c contaminants detected in ground water at the site, continued input of contaminated ground water to the Delaware River under the no-action alternative would not have a measurable adverse impact on water qualit biotar yo contaminatef ,i d soi removes lwa d from the aite e concentrationTh . f individuaso l organics after mixing of ground water with both the estimated full flow and half J&ojtof ,the Delaware River are all well below all applicable Ambient Water Quality Criteri U.Sd A an a .EP Health Advisorie r ingestiofo s f toxio n carcinogenid an c c compounds in water (Table 1), Therefore, due to the negligible impac grounf to d off-site wateth n ro e environmend tan public health, groundwater interception and withdrawal remedial actions were eliminated from further consideration. B. Soil Excavation/Removal Remedial Alternatives Six remedial alternative soil excavation/removal wer) 2C e d developean B option2 , y b d2A s, 1C (1A , ,IB Westo. F y nRo base o thresholn eitheo dtw f o r d levelf so organic contaminants for defining whether the soil is contaminated (se e threshole on Tabl ) 2. ed leve whicn lo h three of the alternatives (1A, IB, 1C,) were based was 100 mg/kg for both the volatile and base neutral/acid (BN/A) fractions. The second, on which the remaining three (2A,2B, 2C) alternatives were based, was 100 mg/kg for the volatile BN/e fractioth Amg/k0 r 50 fraction fo gd nan . Metcals f Eddy reviewe confirmee th d d contaminated toil excavation quantitie potentialld san y contaminated soil quantitier sfo Options 1A, 1C, 2A and 2C, determined by R.F. Weston. A conservative approac possiblo t s take e wa h du n e synergistic effects.

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000487 -16-

There »:•* r'jrrer-' .--.shards for exposure to total volatile org?.".i<: (VCC "3s• 1 e nsutral/acid extractable (3NA) fraction .-•;... ;r s; .icnicit e contaminateth f o y d soil 'r ;• :n i:: .-..Ividual comoounds -Mrassr.t ani Lr. i.iy jvaergistic effects chat the ;i..'.:cunds md'; =.:•:.t . tSinc>r .. o compellinn e g coxic1.'- '.r::cal avid*-:* su? ;threshol, • C .-g/V.10 ' :.--.if do c: g l VOCs or BNAs versus 5 ••:/-;g or 150 mg/kg, it is unlike!;1 thay meaningfuan t l distinctio e madb n e ca nbetwee n inj to "clean" depth cr to one foot below the last contaminated sample on the basis of public health impact, n severaI l grids concentratioe th , n composites indicated contaminant levels greatly exceedin t thresholse e th g d levels, yet analysis of the quadrants' analytical data indicate e oppositeth s othen i , r grids, this relationship was reversed. These results suggest that the sampling method may not be an accurate indicator of the extent of contaminatio whole th ef no grid . While this lac f correo k - lation is a general problem with all the soil removal options suggestt ,i s that making distinctions between soils that are 20%, 21-100% or greater than .100% over the threshold is not valid over .an entire quadrant, on the basis of the toxicological issues and the sampling discrepancies, Netcalf t Eddy concluded that soil removal options IB and 2B are unjustified and should be excluded, C, Remove Debris Removal and dispose'. <••': on-site, crushed fir.""? ?•"* contaminated soil pile'?! '-ore included in the Removal of Debris remedial item. T1.*^ had been included under the contaminated soil m;^. -.^vity. , however mors i e; i / appropriate to consider . .... &s part of removing site debris, A 50 percent swell fac::-; i?,s used for estimating the volume of crushed drums after Iv.-ing into trucks for subsequent hauling to a fir.al cispo^a. site. A 15 percent swell factor was used for estimating ^.e loading volume of soil from above- ground soil piles or excavated from the site for subsequent haulin finaa o t gl disposal site. . DemolisD h Building Several items wer; e Demolis addeth o t d h Buildings remedial activity. These include e followingth d : - Rough grading and site leveling up to 12 inches over existing grad orden i e o covet ry proan r - truding subsurface structures which have not been removed , - On-site sump sampling and analysis and waste removal. 000488 r

-17-

- Underground fuel oil tank/contents removal. -'Underground waste chemical. veni ,so t tank contents removal, - Closur f undergrouno e d t•-,-,,".•.;:" or , n . :'.:. • , . building basements and •!*::'-.'.u •• j .-.;- z'.s'isr, pit. The tunnels and pit are potential reservoirs for off-site contamination. These items were added to the Demolish Buildings remedial activity becaus woult i e e appropriatb d o undert e - take these items durin buildine th g g demolition activity. Off-site, handling quantities of building demolition debris were calculated for the following scenarios: remove all debris from site for each soil excavation option under consideratio 2C), n 2A (1A ., Thes1C , e quantitie usee sar d in the subsequent cost analysis of remedial alternatives, The site remains a safety hazard to persons entering or playing on the site and in abandoned buildings. Despite locked site e gateth o ,st person s frosurroundine th m g neighborhood are known to gain access to the site. ; Initial remedial activities on the site have not removed all safety hazards frositee o partiallth mTw . y full underground tanks, an underground 4-foot x 4-foot tunnel beneath the main building d structurall,an y damaged buildings present serious physical hazards to persons gaining access to the site. e identitTh f compoundo y e remaininth n si g underground tanks havbeet eno n establishe f thio s da writin neverthelest gbu s the tanks themselves are at least partly accessible from the ground. e tunne Bote tankth y contaith hd lma san n oxygen deficient or toxic atmospheres that increase the likelihood of accidents. The major fire at the Wade site in 1978 damaged the structural integrity of several buildings on-site, increasing the likelihood of unexpected collapse. Finally, remaining piles of debris (wood and tires) are potential fire hazards. E. Site Capping e resultEndangermene Th th f so t o AssessmenN e th r tfo Action remedial alternative, as previously discussed, in- dicited minimal riskresula s sa on-sitf to e ground water contamination. On this basis, ground water interception, withdrawal and treatment remedial alteratives were eliminated from further consideration and detailed evaluation. e sitTh e capping options range from relatively impermeable clay capping to asphalt capping to relatively permeable topsoil/seeding capping. Clay cappinmose th t s effectivi g e of these capping options at preventing infiltration of precipitation into the unsaturated soil zone (contaminated soil) and subsequent movement into the ground water, -18-

Precipitatio d doean s s infiltratha n e unsaturateth e d zone on-site and recharges the ground water, but its effect on ground water doe t possno e significant risk previousls a s y discussed, Therefore, it is not necessary to prevent infiltration by installing a relatively impermeable cl.v/ :-- or asphalt cap on the site,

000480 TABLE 3 REMEDIAL ALTERNATIVE COST ANALYSIS Total Remsdial Site Soil Implemen- Alterna- Debris Demolish Site Excava- tation tive Removal Bldga Capping tion Cost No. ($) (*) ($) (*) 1. o ; 0 0 0 0 2. 529,029 268,745 0 0 797,774 '3- 529,029 2535 ,7« 331,930 •: '',129,704 4. 529,029 268,745 75,620 0 873,394 5. 529,029 252,750 331,930 1,191,250 2,304,959 6. 529,029 252,750 75,620 1,191,250 2,048,649 7. 529,029 243,156 331,930 1,979,755 3,083,870 8. 529,029 243,156 75,620 1,979,755 2,827,560 9. 529,029 260,871, 331-.930 -714,530 1/"v'5,360 10. 529,029 260,871 ' 75, £20 .714,530 1,580,050 11. 529,029 256,439 '33T,m r,012,512 2,129,910 12. 529,029 256,439 75,^20 1,012,512 1,873,600

000491 r}''WW&V' Li! It • .. ...• .-. '".' .. .•!••; .

-19-

Cost Analysis Table 3 presents the site implementation costs for all the 12 remedial alternatives based on Metcalf & Eddy's cost estimates for Site Debris Removal, Building Demolition, Site Cappin d Contaminatean g d soil removal. Post Closure, Long Term Monitoring plan Once remedial activities have been completed on the Wade site, it is required that the site be further monitored a perioyear0 3 r determino f fo t so d effectivenese th e f so the raiiiedial activities. e plaTh n include e followinth s g tasks: 1. Site Inspection: e sitTh e inspection will includ a visuae l inspectio f surfaco n e condition monitorine th d san g wells.

. 2 Installatio f Upgradienno t Monitoring Wells: Two upgradient monitoring well clusters will be installed in off-site locations in order to monitor the water quality of the ground water before it flows under this site. 3. Water Sampling: e purposTh f thio e s samplin determino t s i g e ground water quality before ground water enters the sitground an e d water qualit leavet i sitee s a ysth . 4. Laboratory Analysis: Both water and soil samples will be analyzed for priority pollutants, cyanidX baseTO d ean upo n contaminants identified in previous site sampling. After five year f samplso e collections sampline ,th g protccol will be re-evaluated to determine if certain pollutant targetee b n sca d such thaa te b ther n ca e reduction in the cost of laboratory analysis without any reduction in monitoring effectiveness.

000492 -21-

i . 5 Replacemen f Monitorino t g Wells: The present three downgradient well clusters : were originally constructed with galvanized pipe and ' it is anticipated that the wells will need to be replaceupgradieno years0 tw 1 e n i dTh , t wells will be constructed with stainless stees i t li pip d an e anticipated thae wellth t s wil le replace b nee o t d d in 15 years. Monitoring well deterioration may result from corrosion of the pipe or screen, accumuJcisio welle f th sil no r pluggin n ,o i t e th f o g screens. 6. Well Maintenance and Rehabilitation: A program of well maintenance and rehabilitation wil e implementeb l d every five year o insurt s e that the monitoring wells will provide representative samples and that the surface integrity of the well hat beesno n compromised. 7. Topsoil Maintenance: A progra f topsoio m l maintenance wil e implementeb l d every two years to insure that the topsoil cap completely cover e siteth s . Periodicall e necessarb y ma t o fili t y l in erosion channels, to add topsoil to areas where the vegetatio becoms nha e sparse. . Mowin8 Grassf go : Once the topsoil cap has been constructed and it has been seeded and sodded it will be necessary to mow the new grass during the growing season. The task would be performe yearla n o d y basis probably durin summee th g r months and win become a integral part of the site maintenance. Community Relations Public meetings were held in October 1982, July 1983, and September 19)3 to discuss the remedial work performed b ystudiee CECOth d Ssan Weston. conducteF y Ro . y b dvariou s types of media (e.g., newspaper ads, fact sheets, radio) were utilize notifo t d publie th y f thesco e meetings. Representa- tives of U.S. EPA, State, local governments and the community wer l weleal l represented. Copie f reportso datd san a were provided, with a 20 day comment period. flflfMot) A public meetin discuso t g Wade th se site feasibility stud s hel Chesteyt wa a d r City Hal Wednesdayn lo , Jun1984, 13 e. The meeting was conducted by the PA DER and EPA. Public officials and citizens were very interested in the future use of the site as e timeframth wel s a l r completiofo e cleanupe th f o n . There wero n e -22-

Recommended Alternative Seption 300.68(j) of the National Contingency plan 31180R F (NCP7 ,[4 ) Jul 1982, 16 y ] states thaappropriate th t e extent of remedy shall be determined by the lead agency's selectio remediae th f no l alternative whic agence th h y determine cost-effectivs i s e (i.e. e lowes,th t cost alternative that is technologically feasible and reliable) and which effectively mitigate minimized an s s d damagan o t e provides adequate protection of public health, welfare, and the environment. Based on our evaluation of the cost- effectivenes propose2 1 e th f eacso df o h alternativese th , comments received from the public, information from the Endangerment Assessment, and information from DER and Weston, we recommend that alternative 10 be implemented. This alternative includes: the removal, decontamination, and disposa f tankerso l , tire d debrisan s ; destructiof o n buildings; soil removal; leveling, filling gradind ,an g the site d coverinan , g wit a seedeh d topsoil cap. e recommendeTh d alternativ e leasth ts i ecos t alternative tha technicalls i t y feasibl d reliableean , that meete sth requirements of the NCP and provides for future protection of public health, welfare e environmentth d ,an alst I .o complies with RCR y callinAb offsitr fo g e disposa f contaminatelo ~ '^ - - d aoil at a RCRA approved lined facility, and the level of cleanup was determined in a manner consistent with the RCRA methodology. In comparison with the other alternatives, alternative 10 has the following: 1. Fewer monitoring requirements as a result of the topsoil cap; . 2 Requires less tim e soiimplemeno t th el l al f o t excavation options (lowest quantit contaminatef o y d soil requiring excavation); 3. Easiest to install of the soil options due to the smaller soil excavation quantities; . Use4 s relatively proven technology, i.e., contaminant source removal with proper disposal; 5. More durability with a topsoil cap than asphalt due a longe o t r perio f timo d e thae leveth tf effective lo - maintainede b nes n sca ; . Mor6 e effectiv o eaction thae th n remedial alternative n sourcanno d e removal alternatives; 7. If no action was chosen, we would still have the proble a releas f o m e occurring which would ultimately grouna enn i d d water investiqation;

000494 -23-

exposure Th . B e rat mosf eo t Wadconcere th er fo n Site from the standpoint of public health is • inhalation/ingestio f contaminateo n d surface soils. Further removal of soil beneath the .5 foot level (Alternativ ) woul12 e d havo n e impac M thiC t s rout f exposureo e , and; . Remova9 contaminatef lo d soil fee5 dow o tt n allow r protectiofo s f humao n n healtd an h environment in the future. e estimateTh drecommendee th cost r fo s d action are; Remedial Action Estimated Cost Site Debris Removal $ 529,029 $ 260,87Demolis1 h Buildings Site Capping $ 75,620 Soil Excavation $ 714,530 Total Implementation Cost • $1,580,050 Operation & Maintenance $ 320,000 Tota $1,900,05* l 0

Project Schedule - Approve Record of Decision July 1984 - Award Contract September 1984 Star- t Construction September 1984

w ^00495" Table 2

Soil Excavation/Removal Remedial Alternatives

1. Remove contaminated soils exceeding organic cir.taT.ir.an concentratio f eitheo n mg/kO iO r g volatile orgar.icr o s 100 mg/kg base, neutral/acid organios.

. ExcavatA o Last e t Contaminated Depth1 . ExcavatB o Intermediatt e e Depth2 C. Excavate to Uncontaminated Depth3

2. Remove soils exceeding an organic contaminant concentration of eithe 0 mg/k10 r g volatile organic 0 mg/k50 gr so base, neutral/acid organics.

A. Excavate to Last Contaminated Depth1 B. Excavate to Intermediate DepthZ . Excavat'C - o Uncontaminateet d Depth3

I/ Soil removed lie1-1-. :: ii-.:.>. at which last contaminated ~~ soi s foundlwa . / 2 Soil removed dow o deptt n whict a h h last contaminated sample s foun' wa -.^resnol. '" : ~ d level exceede percen0 2 y b dr lesso t ; one foot despsr than last contaminated depth if threshold leve percentO IC l o exceedet d dow 1 ;an o dept2 t n ; y b da' h which first uncontaminaced sampl s foun wa ef threshol i d d level exceeded by greater than 100 percent. 3/ Soil removed down to depth at which first Uncontaminated sample was found.