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Record of Decision System (RODS)



City & State:  UPPER MERION TOWNSHIP  PA  19406
EPA ID:  PAD980419097
EPA Region:  03
NPL Status:  Currently on the Final NPL
ROD Type:  Record of Decision
ROD ID:  EPA/541/R-00/015
ROD Date:  09/27/2000
Operable Unit(s):  01
Abstract:  From 1918 until 1977, the Alan Wood Steel Company (Alan Wood) and its successors operated a coke and coke byproduct manufacturing facility in nearby Swedeland, Pennsylvania. The facility was located on the west side of the Schuylkill River, approximately one mile northeast of the Site. After Alan Wood declared bankruptcy in 1977, the facility and property were first leased and subsequently sold to the Keystone Coke Company (Keystone Coke). Keystone Coke produced and sold coke at the facility from 1978 until the spring of 1981, when all operations at the facility ceased.

The coking process typically generated coal gas, light oils, tars containing phenolic compounds, naphthalene (resulting from the destructive distillation of coal), ammonia, and wastewater. Waste ammonia liquor (WAL) was pumped via pipeline from the Alan Wood facility to Quarries 1,2, and 3, and remnants of the pipeline are still visible near the western edge of Quarry 3. The RI found no evidence that Quarry 4 was used directly for WAL disposal, but it may have received impacted water as a result of overflows from Quarry 3 and releases from the WAL pipeline.

The Pennsylvania Department of Health (PADOH) initiated an environmental investigation on January 6, 1969 that was carried through by the Pennsylvania Department of Environmental Resources (PADER) which lasted throughout the 1970s. PADER, now the Pennsylvania Department of Environmental Protection (PADEP), continually asserted into the early 1980s that the use of the quarries was adversely affecting local groundwater. In March 1969, PADOH estimated the levels of phenol in the 43,000 gallons per day (gpd) of waste being discharged into this quarry at 1,888 parts per million (ppm). The sampling documented elevated levels of cyanide, ammonia, and phenol in the WAL discharge and in groundwater in the area. Quarries 1 and 2 were filled in with demolition waste sometime after 1969.

In 1975, Alan Wood installed a prototype treatment plant to treat its industrial wastes and discharge them to the Schuylkill River. However, PADER found that the levels of phenol and cyanides in the plant's effluent exceeded the levels specified in the National Pollution Discharge Elimination System (NPDES) permit. On November 26, 1975, Alan Wood signed a Consent Order with PADER, in which Alan Wood agreed to achieve specified effluent limitations for the phenol and cyanides in its discharges before October 31, 1979. Until those limitations were met, Alan Wood was allowed to continue to discharge its effluents to Quarry No. 3. After Alan Wood filed for bankruptcy, discharges to Quarry 3 ceased until Keystone Coke signed a Consent Order with PADER on April 24, 1978, and thereafter reactivated the plant.

During 1977-1979, PADER sampled the WAL discharges to Quarry No. 3, groundwater discharges at neighboring quarries in the region and area wells. PADER reported that sampling showed elevated levels of cyanide, ammonia, and phenol in the WAL discharge and in groundwater in the area during that period of time. In addition, on February 25, 1980, PADER determined that numerous violations of the interim effluent limits had occurred.

On May 16, 1979, EPA conducted a Groundwater Monitoring Survey which involved sampling of Quarry 3 and the surrounding area and included an investigation of possible sources of contamination threatening the Upper Merion Reservoir, a public drinking water source located about one mile to the northwest of the site and operated by the Philadelphia Suburban Water Company. While conducting sampling at the site, EPA found phenolic compounds, chlorides, naphthalene, and other organic contaminants in Quarry 3. EPA conducted additional sampling at the site on May 25, 1979. Subsequently, EPA reported finding trans-1,2-dichloroethylene (DCE) in both the Upper Merion Reservoir and Quarry 3.

On April 8, 1983, EPA conducted a Preliminary Assessment (PA) of the site, followed by a Site Inspection (SI) on May 9, 1983, during which samples were obtained from Quarry 3 and from three of the monitoring wells that had been installed in 1982 by PADEP in the vicinity of Quarry 3. The PA and SI revealed that hazardous substances were present in Quarry 3 including benzene, toluene, naphthalene, cyanide, zinc, arsenic, lead, phenolic compounds and polynuclear aromatic hydrocarbons (PAHs). Analysis of groundwater in the vicinity of the site, taken from the monitoring wells, showed the presence of benzene and metals including arsenic, cyanide, lead, mercury, zinc, beryllium, nickel, cadmium, and selenium.

In June 1990, EPA took additional samples at the site. Samples were collected from waste and soil in Quarry 3, ponded water near the quarry, borings of fill material taken from an area believed to be Quarry 1, off-site monitoring and private wells, and the Upper Merion Reservoir. Waste in Quarry 3 contained elevated levels of various contaminants including cyanide, arsenic, benzene, lead, zinc, and PAHs.

The site was proposed for listing on the National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List (NPL) of uncontrolled hazardous substances releases pursuant to CERCLA Section 105, 42 U.S.C. § 9605, in February 1992. The site was listed on the NPL on October 14, 1992.

On September 17, 1994, Beazer East, Inc., Keystone Coke Company, Inc., and Vesper Corporation (herein referred to as the "Crater Resources Participating Parties Group" or "Crater PRP Group") entered into an Administrative Order on Consent (AOC) with EPA under CERCLA Sections 104 and 122, 42 U.S.C. § § 9604 and 9622. Under the AOC, the Crater PRP Group agreed to perform a RI/FS at the Site to determine the nature and extent of the contamination at or from the site, and to evaluate alternatives for remedial action to prevent, mitigate or otherwise respond to or remedy the release or threatened release of hazardous substances, pollutants, or contaminants at or from the site.

The RI field work was completed in January 1999 and the RI Report was approved by EPA on June 23, 1999. After completion of the RI, the Crater PRP Group commenced the FS to evaluate various remedial alternatives to address the nature and extent of contamination identified in the RI.

In December 1999, EPA completed a Human Health Risk Assessment, which is documented in the Final Baseline Risk Assessment Report, to evaluate the human health risks that could result if no remedial action were taken at the site. The Final Baseline Risk Assessment Report and RI Report are available for review in the Administrative Record for the site.

On February 29, 2000, a draft FS report was submitted to EPA by the Crater PRP Group. On April 20, 2000, pursuant a Section IX.A.(3) (Submissions Requiring Agency Approval) of the AOC, EPA notified the Crater PRP Group of its intention to modify and subsequently approve the Draft FS Report. EPA has reviewed the Draft FS report and completed an Addendum to the FS Report on June 16, 2000, which is available for review in the Administrative Record for the site.

Area 6 History

In 1997 improvements of Parcel 44 (Area 6) were started. An investigation was conducted to determine subsurface conditions at the lot. Borings advanced in the parcel showed a tarry layer at 20 to 22 feet below ground surface. Samples obtained from this layer showed elevated levels of PAHs and volatile organic compounds (VOCs). It was determined that unsuitable soils for development were present; therefore, the owners proceeded with excavation to uncover and remove unsuitable materials. The excavation was 35 feet in depth. Materials were segregated with soils and cinders suitable for backfilling returned to the excavation. Materials geotechnically unsuitable for development were disposed off-site. The tarry materials were tested for Resource Conservation and Recovery Act (RCRA) characteristics and disposed as non-hazardous. Confirmation samples taken from the bottom of the excavation and from the remaining materials which were mixed and returned to the excavation were collected and compared to PADEP Act 2 Statewide Health MSCs for non-residential direct contact with soils and protection of soil-to-groundwater for non-residential soils. Results showed levels below the Act 2 standards.
Remedy:  The selected remedy consists of Alternative SW-3, S-5, and GW-3, which includes removal of all contaminated soils and sediments in Quarry 3, construction of a multi-layer cap to prevent infiltration of surface water into the contaminated soils of Quarries 1,2, and 4 and other contaminated soil areas, monitored natural attenuation of the groundwater, and further investigation of the former waste ammonia liquor (WAL) pipeline that was located between the Alan Wood Steel facility and Quarries 1,2, and 3 located on the Crater Resources Site.

The first component of the selected remedy, removal of all contaminated soils and sediment in Quarry 3, will be completed by dewatering Ponds 1,2, and 3, which are located within Quarry 3, and transporting the water to an offsite disposal facility. The sediments at the bottom of the ponds will be excavated down to the bedrock layer or to the level where contaminant concentrations in the sediments are at levels protective of groundwater, human health or ecological risk-based concentrations, dewatered, and taken off-site for proper disposal or recycling. The Quarry 3 plateau area will be excavated down to the bedrock layer or to the level where the contaminant concentrations in the
soils are at human health or ecological risk-based concentrations, and the soil taken off-site for proper disposal or recycling. All remaining soil areas in Quarry 3 with contaminant levels above human health or ecological risk-based concentrations will be removed and taken off-site for proper disposal or recycling. The excavated areas will then be filled with clean soil to establish a uniform grade, and graded for proper drainage.

Construction of a cap to prevent infiltration of surface water into the contaminated soils of Quarries 1,2, and 4 and other contaminated soil areas, the second component of the selected remedy, will be implemented by installing a multi-media cap consisting of a series of low-permeability clays, geotextile liners, sand drainage layers, and soil or other appropriate covers to prevent unacceptable leaching of contaminants from the soils and sediment into the groundwater. The cap will be constructed in accordance with the Commonwealth's Residual Waste Management Regulations.

The third component includes groundwater monitoring conducted at on-site and off-site locations in order to sample for selected site-related semi-volatile organic compounds (SVOCs), metals, cyanide, and volatile organic compounds (VOCs) that presently exceed preliminary remediation goals. Additional parameters representative of the natural attenuation process will also be included in the monitoring program. This monitoring will provide a basis to determine the rate at which natural attenuation is taking place. EPA has determined that this rate needs to be sufficient to attain the remedial goals within a fifteen-year time period. If, during the fifteen-year time period, it is evident that the rate of natural attenuation is not sufficient to attain such goals in the fifteen year time frame, the EPA will then seek to implement the contingent groundwater remedy.

The contingent groundwater remedy calls for groundwater recovery and treatment from the center of the groundwater plume at the site. The purpose is to extract and treat the most highly contaminated groundwater from beneath the site. The recovery system would pump the water near the down gradient edges of Quarries 2 and 3 using a line of recovery wells spread across the width of the plume. The groundwater would then be pumped to an on-site treatment facility to remove contaminants to specified treatment levels and the treated water would be discharged to the Schuylkill River or Matsunk Creek.

Further investigation of the former WAL pipeline that runs from the former Alan Wood Steel facility to Quarries 1,2, and 3 located on the site is the fourth component of the selected remedy. Some sections of the pipeline have been removed by the Crater PR
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