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PRELIMINARY PUBLIC HEALTH ASSESSMENT
CRATER RESOURCES/KEYSTONE COKE/ALAN WOOD
KING OF PRUSSIA, MONTGOMERY COUNTY, PENNSYLVANIA


APPENDICES

APPENDIX A. Figures

Figure 1
Figure 1

Figure 2
Figure 2

Figure 3
Figure 3

Figure 4
Figure 4

Figure 5
Figure 5

APPENDIX B. Tables
Table 1. Contaminant Concentrations In On-Site Groundwater (1983 only) (1, 2)
ContaminantMaximum Concentration
ppb
Comparison Value
ppbSource
Beryllium4650.008CREG
Nickel1160200
(child)
RMEG
Cyanide30200
(child)
RMEG
TetrachloroetheneNR0.7CREG
BenzeneND1CREG
Cadmium367.0
(child)
EMEG

ppb - parts per billion
RMEG - Reference Dose Media Evaluation Guide
CREG - Cancer Risk Evaluation
EMEG - Environmental Media Evaluation Guide
ND - Not Detected
NR - Not Reported

Table 2. Contaminant Concentrations in On-Site Sediment (1, 2)
ContaminantMaximum Concentration
ppm
DateComparison Value
ppmSource
Beryllium1.55-830.2CREG
Nickel23.16-9040 PCRMEG
Cyanide7505-8340 PCRMEG
TetrachloroetheneND6-9010CREG
Benzene0.0325-8320CREG
Cadmium0.66-901.0 PCEMEG

ppm - parts per million
ND -Not Detected
PC - Pica Child
RMEG - Reference Dose Media Evaluation Guide
CREG - Cancer Risk Evaluation
EMEG - Environmental Media Evaluation Guide

Table 3. Maximum Contaminant Concentrations In Off-Site Groundwater (1, 2)
ContaminantMaximum Concentration
ppb
DateMonitoring WellComparison Value
ppbSource
Beryllium105-83MW-50.008CREG
Nickel1205-83MW-5200
(child)
RMEG
Cyanide305-83MW-5200
(child)
RMEG
Tetrachloroethene196-90Fountain0.7CREG
Benzene1605-83MW-51CREG
Cadmium 15-83MW-57
(child)
EMEG

ppb - parts per billion
RMEG - Reference Dose Media Evaluation Guide
CREG - Cancer Risk Evaluation
EMEG - Environmental Media Evaluation Guide

APPENDIX C - Attachment

PUBLIC COMMENTS AND RESPONSE

Response to Letters Received dated July 30, 1993:

Letter One

Comment:Sampling of the soil around the waste ammonia liquor (WAL) pipeline duringpipeline dismantling (1989) revealed no evidence of leaks, as stated by aneyewitness and referenced in the PHA.
Response:The samples collected at the locations on the figure (plant map) supplied toPADOH were taken at another site and not in the off-site area (about one-halfmile long) referred to by local residents. Therefore, the sample results youprovided are not relevant for the Crater Resources site.
Comment:The Consent Order between Keystone Coke and the Commonwealth ofPennsylvania was entered into prior to Keystone's purchase of the plant.
Response:This change has been made.
Comment:There are other inaccuracies regarding the pipeline easement and history.
Response:We have made changes and/or removed statements from the PHA in response toKeystone's comments.
Comment:TCE has not been identified as a contaminant in the quarry. Therefore, thequarry is not the source of TCE contamination in the irrigation well.
Response:The irrigation well is downgradient of and near the quarry. Although TCEcould be coming from another source quarry water data are not available toprove or even suggest that TCE is not present.
Letter Two
Comment:Vesper questions the conclusion that the site represents a public health hazardbecause existing data do not support such a conclusion.
Response:The physical hazards alone justify categorizing the site as a public health hazard. Furthermore, contact with some contaminants found on-site could cause healthproblems in some individuals. The lack of data to fully characterize the site inno way indicates that the site is safe. The recommendation for comprehensivemedia sampling remains unchanged.
Comment:PADOH admits that existing data do not support the conclusion thatgroundwater, soil, and surface water are contaminated. Still, the PHArecommends further sampling.
Response:No where in the Public Health Assessment does PADOH state thatenvironmental media are not contaminated. Data are too sparse to completelycharacterize the extent of contamination. Obviously more data gathering isindicated.
Comments:Statements in the PHA which rely on the EPA Hazard Ranking Study,particularly rock fractures and assumed groundwater flow directions, aresuspect.
Response:The statements concerning bedrock jointing were made as a result of fieldmeasurements compiled independently by the PADOH hydrogeologist. Thepredicted groundwater flow directions were not taken from EPA documents (orany other documents) and agree almost exactly with the conclusions expressedin the Golder report (11) and several masters theses on area geology andhydrogeology. The PHA will be changed to note this agreement.
Comment:The PHA states that pipeline leaks were common. Vesper requests evidence tosubstantiate this.
Response:As stated in the PHA, the reference to pipeline leaks came from eyewitnessaccounts. The names of private citizens supplying information are not given inpublic health assessments because of confidentiality policies.
Comment:Certain background statements may be inaccurate; specifically, Vesper disputesthat Alan Wood Steel pumped wastes into the quarry during the 1970s.
Response:We have made corrections in the background section of the PHA when the needfor such corrections could be supported by written documentation. We reliedon the historical accounts from reference documents listed in the PHA. IfVesper has written documentation to support the information, you shouldfurnish that documentation to PADOH.

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