: .Vl'.rr1 States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/066
December 1988
Superfund
Record of Decision
Croyden TOE Spill, PA
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50272-101
REPORT DOCUMENTATION i. REPORT Ha *•
PAGE EPA/ROD/R03-89/066
4. TMeOTdSuMMe
.SUPERFUND RECORD OF DECISION
pyden TCE Spill, PA
. "^Ptrst Remedial Action
7. Auttort*)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X Rectofanre Accmton Ha
i. ReportOett
12/28/88
t.
«. Performing Orginiatfon Off*. No.
10. Pro|ecVTM*/Work Urtft No.
11. ComradlC) or GrafM
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EPA/ROD/R03-89/066
Croyden TCE Spill, PA
First Remedial Action
16. Abstract (Continued)
The selected remedial action for this site includes connecting approximately 13
residences to the public water supply system via the construction of new water
services lines, mains, hydrants, and valves; and ground water monitoring to ensure
that homes located outside of the TCE-contaminated zone will not be at risk from the
migrating plume. The estimated present worth cost for this remedial action is $106,000
with annual O&M cost of $3,400 for 30 years.
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DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Croydon TCE Site, Bristol Township, Bucks County, Pennsylvania.
Alternate Water Supply Operable unit.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the alternate water supply operable unit at the Croydon TCE Site,
Bristol Township, Bucks County, Pennsylvania. The remedial action
was developed in accordance with the statutory requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and is consistent with the
National Contingency Plan (NCP) 40 CFR Part 300. This decision
has been based on the administrative record for this site (index
attached). The attached index identifies the items which comprise
the administrative record on which the selection of a remedial
action is based. The Commonwealth of Pennsylvania concurs on this
remedial alternative. A copy of the concurrence letter is attached.
A second Record of Decision (ROD) will be prepared following the
Phase II Remedial Investigation (RI) and Feasibility Study (FS)
and will address the ground water and contaminant source operable
units.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedial alternative for this operable unit will
prevent human exposure to contaminated ground water having
concentrations of trichloroetnene (TCE) and related constituents
in excess of Federal and State health-based Applicable or Relevant
and Appropriate Requirements (ARARs). This remedial alternative
does not address the ground water or contaminated soil (source)
operable units at this time since the Phase II RI/FS has not been
completed at present. A subsequent operable unit addressing the
contaminated ground water and soil is forthcoming.
The selected remedial alternative involves an alternate supply of
potable water for those residents in Croydon, Pennsylvania, who
solely depend on ground water for every day use. These residents
are located within the boundaries of a ground water plume that is
contaminated with TCE that exceeds health-based ARARs. It has been
estimated, that 13 residences, within the boundary of the
contaminated plume, are without the services of public water and
depend on ground water for potable use.
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The major components of the selected remedial alternative include:
o Construction of new water service lines, mains, hydrants, and
valves, and the connection to the Borough of Bristol Water and
Sewage Department water supply mains. It is estimated that
13 residences will be provided with this service, based on records
obtained through the Borough of Bristol Water and Sewage Department.
The number and location of residences which will receive public
water will be verified prior to the design of this remedial action.
o Approximately 300-feet of 6-inch, ductile iron, water main line
will be installed along Belleview Avenue. Service lines
(3/4-inch copper) with curb box and valve will be installed for
each of the 13 residences.
o Ground water sampling will be conducted outside of the TCE plume
area to monitor the possible advancement of contaminants. Wells
will be sampled annually and analyzed for TCE, tetrachloroethene,
vinyl chloride, 1,1,1-trichloroethene, 1,1-dichloroethane, and
1,1-dichloroethene.
o EPA will transfer control of the new water lines and services
to the Borough of Bristol Water and Sewage Department as soon
as construction is completed. Therefore, construction details
(i.e., diameter of lines, spacing of hydrants, etc.) must meet
the requirements of the State/Borough of Bristol and local fire
codes.
DECLARATION
The selected remedy is protective of human health, attains Federal
and State requirements that are applicable or relevant and
appropriate to the remedial action, and is cost-effective.
Connection to the public water supply is an effective remedy that
will prevent human exposure to contaminated ground water. This
remedial alternative is a non-final remedial action. It does not
reduce toxicity of the principal threats at the site (i.e., ground
water or contaminated soils), nor does it utilize permanent solutions
or treatment technologies to the maximum extent practicable. However,
this remedial action is an alternative that is solely designed to
eliminate the threat posed by the continued use of ground water for
potable use. Following ttie Phase II RI/FS, which is being conducted
at present, other remedial alternatives will be identified for
remediating contaminated ground water and soil.
Date r I L/Tames M. Sell
Regional Administrator
Region III
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REMEDIAL ALTERNATIVE RECORD OF DECISION SUMMARY
CROYDON TCE SITE
SITE LOCATION AND DESCRIPTION
The Croydon TCE Site is located in the southernmost portion of
Bristol Township, Bucks County, Pennsylvania (see Figure 1).
Elevated levels of volatile organics, primarily trichloroethene
(TCE), are present in ground water and surface water, but the
actual source has not yet been determined. The source of the
contamination is unknown, therefore a two-phased Remedial Investigation
(RI) and Feasibility Study (FS) is being conducted. The Phase I
portion of the study was completed and resulted in the preparation
of this record of decision for the alternate water supply operable
unit. The second phase of the study is currently under way.
Encompassing an area approximately 3.5 square miles in total area,
the study area is bordered by interstate 95 to the north, the
Delaware River to the south, Route 413 to the east, and Neshaminy
Creek to the west. Although the entire study area is quite large,
it was necessary since the source and extent of ground water
contamination was unknown, and widespread ground water contamination
was observed throughout Bucks County. Within this 3.5-square-mile
study area is a smaller area on which the remedial investigation
was primarily focused. This area, as depicted in Figure 2, is
referred to as the "focused area of investigation" and encompasses
the area east of the Mary Devine Elementary School, west of Route
413, and north of River Road to just north of U.S. Route 13. The
focused area of investigation was studied extensively because (1)
ground water in the area was known to be contaminated with elevated
levels of trichloroethene (TCE), (2) previous studies in the local
area provided data which indicated that the source of the TCE-contaminated
ground water may be located within this area, and (3) 11 potential
source areas were identified through the analysis of historical
aerial photographs.
The focused area of investigation includes a portion of the
Croydon residential community and an area where several small- to
large-scale manufacturing and commercial establishments are
located. Most of the commercial establishments are located along
State Road and U.S. Route 13, whereas the larger manufacturing
facilities are located between these two roads in the southeastern
portion of the focused area of investigation.
For the most part, the area outside of the focused area of investigation
is mainly residential. Several residential communities, constructed
in the 1940s to 1960s make up the study area. These communities
include''Croydon, Croydon Heights, Croydon Acres, Maple Shade, West
Bristol, Belardy, and Rockdale. . It is estimated that between 2,000
and 3,000 people reside within the study area. Land use within the
study area is predominantly single family dwellings, and small- to
large-scale industry.
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NORTHERN STUDY AREA BOUNDARY
EASTERN STUDY AREA BOUNDARY
• SOUTHERN STUDY AREA BOUNDARY
LEGEND
Study Area Boundary
Rohm and Haas Company Property
OUAI>HAf.;it lOCAIKM
BASE MAP IS AN CNUkNGEMENT Of A PORTION OF THE USO S BEVERLT, W-NJ QuAO-
HANCLEI75 MINUTE SEMES, IMC. PHOTOREVISfO 1*73, COMIOOH INTERVAL 2OFEETI
AND A POMrriON Of THE BRISTOL, P* -NJ QUAOMANOL£ <7S MlNUU SEMICS, 1935, ««>
TOMCVISEO 19*. CONTOUR WTtKVAL 2O FEET)
40OO
FIGURE i
LOCATION MAP
CROYDON TCE SITE. BUCKS COUNTY. PA
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EGEND
C__J Study Area Boundary
-V^1 Rohm and Haas Company Property
Focused Area of Investigation
RESIDENTIAL AREAS
Belardy
Croydon
Croydon Acres
Croydon Heights
Maple Shade
Rockdale
West Bristol
BUILDINGS
I Nekooto Pockoglng
2 Alpha Aromatics
3 Bristol Flare
4 Mack Warehouse
9 Coyne Chemical
JOQP 2000 3000
SCALE N fTET
4000
FIGURE 2
GENERAL ARRANGEMENT
CROYDON TCE SITE. BUCKS COUNTY. PA
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Rohm & Haas Company is the largest employer in the area and employs
approximately 1,200 people. Most of the other industries in the
study area employ fewer than 50 people each, or a combined total
of approximately 600 people.
The geology of the Croydon TCE Site consists of unconsolidated
sand, gravel, silt, and clay deposits overlying metamorphic
bedrock. Total thickness of the unconsolidated deposits ranged
from 29 to 69 feet in the study area. Bedrock is described as the
Wissahickon Schist and is the basement rock in the area. The
bedrock surface is irregular, and has an overall regional slope to
the southeast.
The site is located in the Delaware River Basin. On a regional
and local basis, the Delaware River is the local discharge point
for both ground water and surface water. Portions of the study
area which are in close proximity to Neshaminy Creek and the
Delaware River are within the boundary of the 100-year floodplain;
however, the focused area of investigation is not within this
boundary.
Ground water occurs in both the unconsolidated deposits and in the
underlying bedrock. The two flow systems are not interconnected
in the study area due to the presence of local clay layers and a
substantial thickness of weathered bedrock (saprolite), which
inhibits the movement of ground water between formations. In the
vicinity of the site, the unconsolidated deposits are a source of
domestic and industrial ground water supply. The bedrock
ground water flow system is of minor importance to ground water
supply in the vicinity of the site due to poor yield and the
availability of ground water in the unconsolidated deposits.
Hog Run Creek and its tributaries (i.e., East Branch and West
Branch) are located within the focused area of investigation. The
tributaries emanate in the area between State Road and River Road
and form Hog Run Creek just north of River Road. Hog Run Creek
then flows southward under River Road and discharges into the
Delaware River.
A larger stream, Neshaminy Creek, also discharges into the
Delaware River. This stream constitutes the western border of the
study area. Neshaminy State Park, which attracts over 750,000
visitors annually, is located at the confluence of Neshaminy Creek
and the Delaware River.
A large variety of plant and wildlife species can be found
throughout the study area. Areas providing habitat include open
fields, open water, woods, and freshwater tidal marshes. Open
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fields can be found between Bristol Lanes and Hartwell Trucking
(along Route 13) and along River Road. The largest wooded area is
situated between State Road and River Road near Hog Run Creek and
its tributaries. Tidal marshes are present along the Delaware
River. The Delaware River, Neshaminy Creek, and Hog Run Creek
provide open water for aquatic species and migratory birds.
As mentioned previously, 11 potential source areas were identified
within the focused area of investigation. These areas are shown
on Figure 3. The potential source areas vere identified by the
EPA Environmental Photographic Interpretation Center (EPIC) by
analyzing historical photographs. The potential source areas were
studied during the Phase I RI. Of the 11 source areas, two are
being studied further during the Phase II RI (potential Source
Area No. 1 and 3b). The other nine potential source areas were
not found to be the source of the TCE-contaminated ground water.
An industrial landfill, owned by Rohm & Haas Company, is located
south of River Road. This landfill was operated during the period
1952 to 1975 and is being studied by the Rohm & Haas Company under
a Resource Conservation and Recovery Act (RCRA) corrective action.
Based on the findings of the Phase I RI, the landfill has been ruled
out as the source of the TCE contamination.
SITE HISTORY
The Croydon TCE Site was identified by EPA after a series of
events led to a remedial investigation of the Rohm & Haas Site
which forms part of the southern boundary of the Croydon TCE Site.
In 1983, Rohm & Haas conducted studies of its Bristol Township
property, including the landfill. Subsequently, two reports were
released: Report on Landfill Investigation, April 1984, and Landfill
Investigation, February 1985. Based on these reports, EPA proposed
the Rohm & Haas Site for the National Priorities List (NPL) in April
1985 and thereby identified the site for long-term remedial action
under the Superfund Act. Following the study of the Rohm & Haas Site,
the site was assigned to the RCRA program instead of Superfund since
the Rohm & Haas plant manages hazardous waste and is actively operating.
A total of 26 reports were prepared by Rohm & Haas. All 26 reports
are compiled into one report entitled: Landfill Remedial Investigation
Report Addendum, March* 1988. The report of most interest was the
Report on TCE in Groundwater in the vicinity of River Road, Bristol
Township, March 1986. This report suggested that a plume of TCE
was emanating north of the Rohm & Haas property. The report was
reviewed by EPA's contractor who concurred with Rohm & Haas1 conclusion.
Due to the uncertainty that many of the businesses in the area may
use products containing TCE, EPA determined that a separate RI/FS
was necessary to characterize the nature and extent of contamination,
assess the public health and environmental risks associated with
the contamination, and identify potential remedial alternatives.
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In April 1985, a Field Investigation Team (FIT) prepared a Hazard
Ranking Score (MRS) for the Croydon TCE Site. An HRS of 31.60 was
calculated, based on studies conducted by the contractor and the FIT.
These studies were primarily conducted within the focused area of
investigation. In September 1985, the Croydon TCE Site was selected
for inclusion on the NPL.
CURRENT SITE STATUS
In August 1987, a Final Phase I RI/FS Work Plan was prepared and
the field investigations were subsequently initiated. The Phase I
RI included a hydrogeologic investigation, a residential well
survey and sampling program, a surface water and sediment
investigation, and a limited amount of surface soil sampling. The
field investigations were conducted to collect data to meet the
following phase I objectives:
o To characterize the nature and extent of ground water
contamination detected within the focused area of investigation.
o To assess the public health and environmental risks posed by
ground water within the study area.
o To determine the quality of local surface water to estimate
the impact from ground water discharge and estimate health and
environmental risks associated with the use of these waters.
o To identify potential source areas that may be contributing
to the ground water contamination which is present within the
southeastern portion of the study area.
o To determine the presence or absence of contaminants in soil
where suspected landfill material may have been disposed.
The various Phase I field investigation and findings are summarized
below.
Hydrogeologic Investigation
The hydrogeologic investigation involved the sampling of 46 wells.
Of these 46 wells, 17.were installed previously by Rohm & Haas as
part of their landfill investigation. The remaining 29 wells were
constructed as part of the Phase I RI. The locations of the wells
allowed EPA to evaluate the impact of the potential source areas
on the ground water. The wells were installed in clusters, which
allowed for the monitoring of the shallow (approximately 20 feet)
and deep (approximately 55 feet) portions of the unconsolidated
aquifer.. All samples were analyzed for Target Compound List (TCL)
volatile organics. Based on Rohm & Haas1 and EPA's previous
studies, volatile organics posed the only problem in the
ground water; however, as a precaution, a selected number of
samples (10) were analyzed for base/neutral and acid extractable
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organics, target analyte list (TAL) inorganics, and selected
gee-chemical parameters (i.e., sulfate, alkalinity, etc.).
The primary contamination in the ground water is due to volatile
organics, predominantly TCE. Table 1 identifies the contaminants
of concern in the ground water, along with the maximum concentration
detected, and a comparison of that value against human health-based
criteria. Table 1 also identifies the number of times (i.e.,
frequency) that the contaminant was detected in excess of the health-
based criteria.
1,1-dichloroethene, 4,4-DDT, and dieldrin, were also detected in excess
of health-based criteria, but only in a limited number of wells.
1,1-dichloroethene is a constituent of TCE. It was often detected
in the same well where TCE was observed. DDT was observed in only
one location, monitoring well 5(S), which monitors the shallow portion
of the. aquifer due south of Nakoosa Packaging. Trace levels of TCE
(0.4 ug/1) were detected in this well also. Dieldrin was detected
in well cluster LF-15, which monitors the shallow and deep portion
of the unconsolidated aquifer near the corner of Stella Avenue and
Third Avenue. Based on the limited number of occurrences for DDT
and dieldrin, it does not seem that these contaminants are associated
with the same source as the TCE contamination.
The TCE ground water plume appears to originate from one or two
potential source areas located north of U.S. Route 13. The plume
is migrating in a south-southeast direction, based on data
collected from static water levels in the wells. The Phase II RI
will attempt to define the source(s) of the TCE and will verify
the extent of the TCE plume. At present, it is known that the
highest concentrations of TCE were observed in wells located
between State Road and River Road, specifically in the area where
ground water discharges into the East Branch of Hog Run Creek.
Although no Rohm & Haas monitoring wells located south of River
Road were sampled as part of the Phase I RI, the TCE plume has
probably migrated into the Delaware River since this body of water
is the ultimate discharge point for all regional ground water and
surface water. Studies have indicated the presence of TCE in
monitoring wells located near River Road (by Manufacturing Area B)
and near the confluence of Hog Run Creek and the Delaware River.
The phase II RI will resample some of these monitoring wells to
assess the norizontal'extent of ground water contamination. Ground
water flow patterns south and east of the contaminant plume will
also be studied to determine if other sources of contamination are
contributing to the TCE ground water problem.
Residential Well Investigation
Forty residential wells were sampled as part of the Phase I RI.
The wells were selected following the distribution of over 450
questionnaires to residents throughout the study area. All
samples were analyzed for TCL volatile organics. A limited number
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TABLE 1
CONTAMINANTS OF POTENTIAL CONCERN DETECTED IN MONITORING WELLS
'Contaminant
trichloroethene (TCE)
tetrachloroethene (PCE)
1,1,1-trichloroethane
1 , 1-dichloroethane
1 , 1-dichloroethene
chloroform
DDT
dieldrin
Concentration (pg/1)
Geometric
Mean
1.05
0.09
0.46
0.073
0.16
0.15
0.06
0.08
Maximum
420
4
160
3
75
9
2.0
0.30
Human Health-Based
Criteria (M9/1)
MCL(a)
5
—
200
—
7
100(d)
—
—
ANQCC»
NA
NA.
NA
NA
NA
NA
0.0012
0.0011
Freguency(c)
16/46
0/46
0/46
0/46
4/46
0/46
1/10
2/10
I
00
I
(a) Maximum Contaminant Level. MCLs are enforceable standards that are set as
close to MCLGs as is feasible after consideration of treatment
technologies, costs, availability of analytical methods, and other factors.
(b) Ambient Water Quality Criteria, adjusted for drinking water only, are used
as ARARs for those chemicals for which no MCL or MCLG exists. Value in
parenthesis is the ambient water concentration corresponding to a 10-6
excess lifetime cancer risk assuming a person drinks 2 liters of water/day
and weighs 70 kg.
(c) Frequency represents the number of sampling locations where the
concentration of the contaminant exceeded the MCL or AWQC.
(d) Standard is for total trihalomethanes.
This criterion has not been developed for this chemical.
NA Not Applicable; other criteria, such as adjusted AWQC, are used as ARARs
only for those chemicals for which neither MCLs or MCLGs are available.
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of residential well samples were also analyzed for TCL base
neutral and acid extractable organics, TAL inorganics, and
geochemical parameters.
The residential well investigation served two purposes. First,
data collected from residential wells allowed for the assessment
of public health risks for those individuals who use ground water
for everyday use. Second, because the residential wells were
located throughout the entire 3.5-square mile study area, it
allowed EPA to assess ground water quality outside of the focused
area of investigation.
Residential well sampling data complemented the results of the
hydrogeologic investigation. For the most part, samples collected
in areas where TCE was detected during the hydrogeologic
investigation also exhibited elevated levels of TCE. Residential
wells located north of the focused area of investigation and west
of Harris Avenue (south of U.S. Route 13) to Neshaminy Creek did
not exhibit elevated levels of TCE. This corresponded to the data
collected during the hydrogeologic investigation.
Table 2 identifies the contaminants of potential concern in the
residential wells, along with the maximum concentration detected,
and a comparison of that value against human health-based criteria.
Eight of the forty residential wells exhibited TCE above the Maximum
Contaminant Level (MCL) of 5 ug/1. No other contaminant of potential
concern exceeded the MCL or the Ambient Water Quality Criteria (AWQC).
During the phase II RI, those residential wells which exhibited elevated
levels of TCE will be resampled to verify the presence of TCE.
Surface Water
Samples were collected from Hog Run Creek and its tributaries
(East and West Branches), Neshaminy Creek, and the Delaware River.
All of the samples were analyzed for TCL organics and inorganics.
TCE (maximum concentration of 6.1 ug/1) and 1,1,1-trichloroethene
(maximum concentration of 2.3 ug/1) were detected in the East
Branch of Hog Run Creek and Hog Run Creek and are the only
potential contaminants of concern. No organic contamination was
detected in Neshaminy Creek, the Delaware River, or the West
Branch of Hog Run Creek. Inorganic constituents detected in
surface water were all found at levels which were comparable to
background levels.
The source of the TCE and 1,1,1-trichloroethene in the surface
water is ground water discharge. The East Branch of Hog Run Creek
is located in the area where the highest concentrations of TCE and
related constituents were detected in ground water. The West
Branch of Hog Run Creek is situated in an area where no
ground water contamination was detected. Consequently, the West
Branch of Hog Run Creek did not exhibit organic or inorganic
contamination.
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TABLE 2
CONTAMINANTS OP POTENTIAL CONCERN DETECTED IN RESIDENTIAL WELLS
u Contaminant
trichloroethene
AWQC<°)
MA
NA
HA
NA
NA
NA
Frequency (c )
8/40
0/40
0/40
0/40
0/40
0/40
o
I
(a) Maximum Contaminant Level. MCLs are enforceable standards that are set
as close to MCLGs as is feasible after consideration of treatment
technologies, costs, availability of analytical methods, and other
factors.
(b) Ambient Nater Quality Criteria, adjusted for drinking water only, are
used as ARARs for those chemicals for which no MCL or MCLG exists.
Value in parenthesis is the ambient water concentration corresponding to
a 10~6 excess lifetime cancer risk assuming a person drinks 2 liters of
water/day and weighs 70 kg.
(c) Frequency represents the number of sampling locations where the
concentration of the contaminant exceeded the MCL or AWQC.
(d) Standard is for trihaloraethanes.
This criterion has not been developed for this chemical.
NA Not Applicable; other criteria, such as adjusted AWQC, are used as ARARs
only for those chemicals for which neither MCLs or MCLGs are available.
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Sediment
Sediment samples were collected from the same location where surface
water samples were collected. Inorganic constituents detected in the
sediments were present at or below background levels with the
exception of copper, lead, manganese, nickel, zinc, and cyanide.
These metals were, however, present at levels within the regional
soil background ranges. Thus, no inorganic constituents were
selected as potential contaminants of concern.
Organic contamination in the sediments primarily included the
carcinogenic polynuclear aromatic hydrocarbons (PAHs). PAHs were
detected in Neshaminy Creek, Hog Run Creek, and the East Branch of
Hog Run Creek. PAHs were not detected in background samples
(i.e., samples collected from Neshaminy Creek north of Interstate
95). PAHs were selected as chemicals of potential concern because
of their carcinogenic risk factor; however, it should be noted
that PAHs are commonly found in industrial or urban areas.
Typical sources of PAHs are automobile or boat exhausts,
fireplaces, and open burning. Table 3 identifies the potential
contaminant of concern and the maximum concentration detected in
each surface water body sediment.
Neshaminy Creek exhibited the highest levels of PAHs. This is
most likely due to the numerous, boats which use this creek. The
presence of PAHs in Hog Run Creek and the East Branch of Hog Run
Creek may be due to surface runoff from the roadways (i.e., River
Road, State Road, etc.). PAHs are not readily soluble in water
and tend to accumulate in the sediment. As a result, no PAH compounds
were detected in the surface waters.
Two volatile organic contaminants, toluene, and 1,2-dichloroethene,
were detected in Hog Run Creek and the East Branch of Hog Run Creek.
The presence of toluene (maximum detection of .6 ug/kg) and
1,2-dichloroethene (maximum detection of 17 ug/kg) may be due to
migration of contaminants from ground water discharge. The absence
of toluene and 1,2-dichloroethene in surface water may be due to
volatilization into air or from the dilution effect of the surface
water.
Soil
*
Soil samples were collected from three areas within the study area
where fill material from the Rohm & and Haas landfill was
allegedly disposed. The three areas include the ballfield
adjacent to the Mary Devine Elementary School (four samples), an
area near River Road across from Rohm & Haas1 Manufacturing Area B
(two samples) , and residential property along River Road (two
samples) .., The alleged dumping of waste material was brought to
EPA's attention by a local resident during a public meeting in
August 1987.
As shown on Table 4, potential contaminants of concern in soils
include polychlorinated biphenyls' (PCS) Aroclor 1242 and Aroclor
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TABLE 3
CONTAMINANTS OP POTENTIAL CONCERN DETECTED IN SEDIMENT
4
Contaminant
benzo(a)anthracene
benzo( b) f luoranthene
benzo(a)pyrene)
chrysene
indeno(l,2,3-cd)pyrene
Concentrations (ug/kg)
Neshaainy
Creek (a}
1,700
3.000
2,200
1,800
1,500
Delaware
River(b)
ND(d)
MD
NO
NO
NO
Hog Run
Creek
368
1,449
363
400
MD
East
Branch of
Hog Run
Creek
780
2000
1,400
930
990
West
Branch of
Hog Run
Creek
ND
ND
ND
ND
ND
Background(c)
ND
ND
ND
ND
ND
I
!-•
N>
<») Samples collected on the eastern shore adjacent to the study area.
(b) Sample was collected prior to the confluence with Neshaminy Creek.
(c) Sample was collected from Neshaminy Creek, north of the study area.
(<*) ND: denotes not detected above instrument detection level.
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TABLE 4 '
POTENTIAL CONTAMINANTS OF CONCERN DETECTED IN SOILS
Contaminant
benzo( a) anthracene
benzo ( b ) f luoranthene
benzo(k) £ luoranthene
benzo(a)pyrene)
chrysene
d i benzo ( a, h) anthracene
indeno( 1, 2, 3-cd)pyrene
Aroclor-1016
Aroclor-1242
Maximum Concentration (ug/kg)
Area Ad)
1,500
3,100
NO
2,200
940
1,400
2,600
295
ND
Area B(2)
MD(«)
ND
NO
ND
300
ND
ND
240
300
Area C<3)
2,700
12,000
610
5,200
4,100
ND
ND
590
ND
(!) Area A represents a residential property near River
Road.
(2) Area B represents the ballfield near the Mary Devine
Elementary School.
(3) Area C represents the land across from Manufacturing
Area B (north of River Road).
(4) None detected above the instrument detection level.
- '13 -
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1016, and potential carcinogenic PAHs. These contaminants were
detected in all three sampling areas. The source of the PCBs are
unknown at present. The presence of the PAHs may be due to
surface runoff from roadways, automobile or dirt bike exhausts, or
open fires. The concentration of the PAHs in the soils are higher
than those PAHs detected in the sediments.
A comparison of the inorganic compounds measured in the surface
soils with regional background concentrations reveals that all are
present at or below background levels. As a result, no inorganic
compounds will be selected as chemicals of potential concern.
Soil samples will be collected from the same three areas during
the phase II RI to verify the presence of these contaminants.
Additionally, soil samples will be collected from outside of the
study area and from the Rohm & Haas landfill. Background levels
of PCBs between 10 and 40 ug/kg have been reported for soils from
15 urban areas. PAH levels in urban areas range from 6,000 to
300,000 ug/kg.
In August 1987, a final Phase I RI/FS Work Plan was submitted to
EPA under the REM III Program. The final phase I RI Report, which
documented the results of the phase I field activities and assessed
public health and environmental risks, was completed in August 1988.
A Focused Feasibility Study (FFS), which evaluated various remedies
for preventing human exposure to contaminated ground water, was
submitted in September 1988. The Phase II RI/FS is being conducted
at present.
RISK ASSESSMENT
A base-line risk assessment was conducted using the data collected
during the Phase I RI. This risk assessment was performed using
the guidelines established in the Superfund Health Evaluation
Manual (EPA, 1986). A full risk assessment for all media is
presented in the phase I RI Report (August 1988). This section
only summarizes the risks associated with ground water exposure.
Household occupants located within the area of the TCE plume who
use ground water are at risk. The risks associated with
ground water ingestion, inhalation of contaminants volatilized from
ground water household •xise (i.e., showering or cooking) , and dermal
absorption of contaminants while bathing were found to be above
the EPA benchmark of a 10"^ carcinogenic risk. A risk level of
10~"6 represents an upper bound probability that one excess cancer
case in 1,000,000 individuals for a period of 70 years, might result
from exposure to potential carcinogens. The average and plausible
maximum risk levels are outlined in Table 5 for these exposure path-
ways. Future use of the ground water was also evaluated. These
risk calculations are based on data collected from monitoring wells
within the TCE-contarninated zone.
- 14 -
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TABLE 5
SUMMARY OF RISK ASSESSMENT SCENARIOS FOR HUMAN EXPOSURE TO
GROUNDWATER CONTAMINANTS AT THE CROYDON TCE SITE
Exposure Pathways
Ingestion of Groundwater
Inhalation of Volatile
Organic Chemicals Released
Indoors from Contaminated
Groundwater
Dermal Absorption While
Bathing in Contaminated
Groundwater
Current Total Excess
Upperbound Lifetime
Cancer Risk*
Average
Cased)
2 x 10-6
4 x 10-6
5 x 10-6
Plausible
Maximum
Case(2)
1 x 10-4
2 x 10-4
4 x 10-4
Current Hazard Index
for Noncarcinogenic
Risks*
Average
Cased)
<1
<1
<1
Plausible
Maximum
Case(2)
<1
<1
<1
* Risks are based on data collected from residential wells and
represent current conditions.
Exposure Pathways
Ingestion of Groundvater
Inhalation of Volatile
Organic Chemicals Released
Indoors from Contaminated
Groundwater
Dermal Absorption While
Bathing in Contaminated
Groundwater
Future Total Excess
Upperbound Lifetime
Cancer Risk**
Average
Cased)
7 x 10-5
7 x 10-6
7 x 10-6
Plausible
Maximum
Case(2)
2 x 10-3
3 x 10-3
3 x 10-3
Future Hazard Index
for Noncarcinogenic
Risks**
Average
Cased)
<1
<1
<1
Plausible
Maximum
Case(2)
<1
<1
<1
** Risks are based on data collected from monitoring wells and
represent future conditions.
(1) Average case calculations use the average concentration
detected.
(2) Plausible maximum case calculations use the maximum
concentration detected.
- 15 -
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Households that are located west or north of the TCE plane are not
at risk since the plume is migrating in a south-southeast
direction. Samples collected from residential wells along Linton,
Qnily, Keystone, and Summit Avenues did not indicate the presence
of TCE or other volatiles at elevated levels (<1 ug/1). These
streets are located west of the plume. Additionally, no
contamination was detected in household wells located along High
Street, Maple Avenue, or Garfield Avenue. These streets are
located north of the plume. No households are located east or
south of the plume within the study area.
COMMUNITY RELATIONS
A Community Relations Plan (CRP) was prepared to identify the
concerns of local residents and government officials regarding the
Croydon TCE Site. The primary goals of the CRP are to establish
and maintain open communication among Federal, State, and local
officials, and the residents of Croydon. Several activities, which
are described in the Final CRP, were conducted to meet these goals.
These activities include the following:
o Onsite (and telephone) interviews with local
residents in June and July 1987.
o Public meeting at the Bristol Township Municipal
building in August 1987. The meeting was held to discuss the
various aspects of the Phase I RI/FS.
o Preparation of a fact sheet for the August 1987
public meeting.
o Distribution of over 450 well-survey questionnaires. The
questionnaire requested information on whether the household
operated a domestic well, and for what purposes (i.e., drinking,
cooking, car washing, etc.) the well water was used.
Although most of the residents continue to express a great deal of
concern regarding the Rohm & Haas Site, none of the residents
contacted during the onsite interviews were aware of the Croydon
TCE Site. However, during the course of the Croydon TCE Site
Phase I RI/FS, the community became more aware that a separate
investigation was being conducted to study other sources that might
be the cause of the TCE ground water problem. Public awareness of
the Croydon TCE Site was minimal (prior to the Phase I RI/FS) . Area
residents expressed only one concern related to the site; concern that
there may be potential health risks associated with the use of ground
water (well water) for bathing, filling swimming pools, and doing
laundry. ^Although no one interviewed during the preparation of
the CRP was still drinking well water, some people indicated that
they use the well water for almost everything else.
- 16 -
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The EPA Community Relations Coordinator met with various school
officials (Mary Devine Elementary School) to update them on the
Croydon TCE Site. The officials were concerned because monitoring
wells and soil samples were to be collected nearby. The school
officials requested that they be included on EPA's mailing list.
In summary, the community is very concerned with environmental
contamination and the potential risks associated with it.
However, because most citizens' homes are connected to the public
water supply system, ground water contamination at the Croydon TCE
Site does not appear to be a primary concern for many residents.
ALTERNATIVE EVALUATION
The feasibility study process involves the identification and
screening of remedial technologies, the development of
alternatives, and the detailed evaluation of the alternatives for
the remediation of the site problem(s). These alternatives usually
address contamination on a site-wide basis., In some cases, the
alternatives are developed for a particular operable unit as
opposed to the entire site. This POD is representative of the
latter case.
A focused feasibility study (FFS) was conducted following the
Phase I RI to develop and evaluate remedial alternatives that
eliminated or reduced the health risk posed to humans by exposure
to contaminated ground water. (Following the phase II RI, a
feasibility study will be conducted to evaluate remedial
alternatives for ground water and source cleanup.) Each.
alternative was evaluated against the following nine criteria:
its short-term effectiveness; its long-term effectiveness; how
well it reduces toxicity, mobility, and volume; the
impleraentability of the alternative; how well it complies with
state and Federal laws and advisories (ARARs); the overall
protection to public health and the environment; the acceptance
(or rejection) of the state and community; and the total cost of
the alternative.
The nature of the Croydon TCE Site FFS was such that it was
designed to eliminate the present risk to humans who use
contaminated ground water for everyday use. The FFS was not
designed to remediate the source or the contaminated ground water
plume. With this in mind, the technologies and alternatives that
were identified, screened, and developed during the FFS were
primarily associated with either an alternate supply of
ground water or treatment of contaminated water at the exposure
point (in the home). The No Action Alternative was retained
throughout the FFS for comparative purposes only.
- 17 -
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Potential remedial technologies considered during the FFS include:
o Connection to an existing water supply
o Development of new water sources
o Oversized conmunity storage facilities
o Treatment (carbon adsorption) of the ground water in each home.
The development of a new water source was not retained for
detailed analysis since the extent of ground water contamination
has not been defined and the location of the source is unknown.
Additionally, an extensive water distribution systam would be
required. The feasibility of the use of oversized community storage
facilities was not retained for further evaluation since the Borough
of Bristol Water and Sewage Authority has adequate capacity to
handle the increase in demand. Thus, water storage is not required.
The remedial technologies which passed the screening step were
used to develop remedial alternatives. Due to the focused nature
of the feasibility study, the remedial technologies themselves are
sufficient to meet the focused site objectives and can serve as
individual alternatives. A total of three remedial alternatives
have been identified:
o No. 1 - NO Action
o No. 2 - Connection to Public Water System with Monitoring
o No. 3 - individual Well Treatment with Granular Activated
Carbon (GAC) and with Monitoring
Remedial alternatives are normally screened for effectiveness,
implementation, and cost prior to performing a detailed
evaluation. However, since only three alternatives remained, the
remedial alternative screening step was eliminated and a detailed
evaluation on each of the above remedial alternatives was performed.
Table 6 summarizes the results of the detailed evaluation. A more
in-depth analysis of each alternative is presented in the FFS
Report. The three alternatives are described below.
Remedial Alternative No. 1 - No Action
The No Action alternative is required by the National Contingency
Plan (NCP) to be considered during the detailed analysis and is
included in the FFS for"purposes of comparison. Normally, the No
Action alternative is selected only if the site posed little or no
risk to the public health or environment.
If No Action was chosen at the Croydon TCE Site, the present and
future potential health risks would go unabated. These risks have
been identified previously (See Table 5) and involve unacceptable
risks to residents using contaminated ground water for drinking, cooking, or
showering. The No Action alternative does not meet SARA's mandate
to be protective of public health and the environment.
- 18 -
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TABLE 6
SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES
CROYDON TCB SITE
Criteria
•o. 1
Ho Action
••••dial Alternative*
•o. 2
Alternate Hater Supply
•o. 3
Individual Hell Treatment Mith CAC
Short Term
Effectiveness
»ot Applicable
Public water systems are very reliable
and require only minimal maintenance.
Construct ion time is estimated to be
1 Math.
Effectiveness la dependent on the
specific chemicals present, their
concentration, and the required degree
of [••oval. GAC nould be effective at
the Croydon TCB Site, but monitoring of
the effluent and TCI plume i« required.
Estimated conatruction time for
installation of CAC unit* U S Maeka.
Long Term
Effectiveness and
Permanence
Mot Applicable
vo
I
This alternative provides long-tern
reliability and any Maintenance required
would be the responsibility of the
Borough of Briatol Hater and SeMage
Department. Maintenance of the Mater
service lines on private property Mould
be the responsibility of the homeowner,
but this should be •iaimal.
For the contaminants detected at the
site, CAC Mould be effective in reducing
the concentration to acceptable levels.
future release of contaminants may
increase in concentration or new
contaminants may appeal that cannot be
effectively treated by CAC units (vinyl
chloride). If contaminant concentra-
tions increase significantly, the
contamination may eshaust the carbon
supply. Therefore, monitoring of both
the groundMater and the treated effluent
is required, for optimum operation,
replacement of the carbon filter is
necessary approiimataJy every 6 months.
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TABLE 6
SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES
CROYDON TCE SITE
PACE TWO
Criteria
••••d.ial Alternatives
Mo. 1
Mo Action
Mo. 2
Alternate Hater Supply
Ho. 3
Individual Hull Treatment Nith GAC
Reduction of Toiiicity,
Mobility, and VoluM
Mo reduction in toniclty,
•obility, or volume since no
treatment or Action it involved.
This alternative Hill eliminate esposure
to contamination, but will not reduce
the level of contamination in the
groundwater. A forthcoming VS will
address remediation of the groundwater
plume and the source of contamination,
if identified.
Reduction in toiiicity at th* esposure
point is achieved. A forthcoming rs
will address remediation of the
groundwater plume and the source of
contamination, if identified.
Implementability
MotjApplicable
ro
O
This alternative will need the approval
of the Borough of Bristol Hater and
Sewage Department since KPA will
transfer control once the operation
begins. The Borough of Bristol Hater
and Sewage Department has adequate
capacity to include the proposed number
of new customers. Construction of the
new water lines would not be difficult
since enisling lines are located
throughout the area.
Availability of equipment and
technicians to install and service the
treatment units may present a problem
since the vendor would be responsible
for hauling the spent carbon away and
disposing of it properly. Pilot testing
would be required. Monitoring ot the
plume and GAC effluent would also be
required. Right of Kntry Agreements are
necessary to Install, service, and
monitor the GAC units.
Compliance Kith ARARs
Does not meet ARARs
The Borough of Bristol water supply is
regulated by the National Primary
Drinking Hater Regulations. Health'
based ARARs (at the exposure point) will
be satisfied. Groundwater contamination
will remain, but this will be addressed
in a forthcoming rS.
Health-based ARARs would be met (at the
esposure point), but monitoring of the
effluent is necessary to confirm that
non-removable contaminants such as vinyl
chloride do not appear in concentrations
greater than the MCL (2 M9/<)•
Groundwater contamination will remain,
but this will be addressed in a
forthcoming tS.
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TABLE 6
SUMMARY MATRIX FOR DETAILED EVALUATION OF ALTERNATIVES
CROYDON TCE SITE
PAGE THREE
Criteria
Remedial Alternatives
Ho. 1
Ho Action
Mo. 2
Alternate Hater Supply
Ho. 3
Individual Hell Treatment With CAC
Overall Protection of
man Health and the
Environment
•ublio health ciake will go
unabated since no remedial action
ie undertaken. At present, there
is a risk to groundwater users.
N)
h-
I
Implementation of this alternative Mould
eliminate the health risks associated
with groundwatar anposure. This
remedial alternative will not address
protection of environmental receptors or
risks resulting from exposure to media
other than groundwater. A forthcoming
tS will address these issues. Residents
within the area who continue to use
their groundwater for nonpotablu
purposes (i.e., watering the lawn) are
not enpected to incur any significant
risk since e«posure would be minimal.
However, if residents wished to operate
their private well in addition to having
the services of a public water supply,
the homeowner will be required to ensure
that cross-contamination will not occur.
Otherwise, the private wells will be
sealed. A limited amount of groundwater
monitoring will be necessary to ensure
that homes located outside of the TCK
contaminated zone without public water
will not be at risk.
Health risks associated with exposure to
contaminated groundwater would be
reduced to acceptable levels, but would
not eliminate all risks since future
contaminants may inciesse in
concentration or new contaminant* may
occur that cannot be effectively treated
(i.e., vinyl chloride). Periodic
replacement of the carbon filter in
necuKsary or contaainant breakthrough
could occur and exposure to contaminants
would result in an unacceptable health
rick. This remedial alternative will
not address protection of environmental
receptors or risks reuulting fcou
exposure to other media. A forthcoming
PS will address these concerns.
-------
TABLE 6
SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES
CROYDON TCB SITE
PAGE POUR
Criteria
Reatadial Alternatives
•o. 1
Mo Action
Alternate Hater Supply
Mo. 3
Individual Well Tiealmenl Hill) CAC
Coawunity and State
Acceptance
It ia very unlikely that the
State or coaauinity would accept
thit alternative.
The atate and community will matt
likely accept thia alternative. EPA
will seek transfer of control as soon as
construction ia complete. Sone
hoswowners >ay object to the fact that
they will have to pay for the public
water.
EPA will seek transfer of control as soon
as construction is complete. State
authorities will nost likely not want to
accept the expense of •onitorlng and
servicing the CAC units.
Coatd)
• Baseline Capital
• OUt (annual)
•aaeline Present
North"'
-0-
-0-
-0-
$3,420 (for years 1-30)
$106,000 .
$64.496
$29.900 (yrs. 1-5), $10,700 (yrs. 6-30)
$312.000
*° O) Sources include vendor estimates and Means 1988 - Site Work Data.
I <2) Baseline present worth calculated for OfcM period of 30 years at a 5 percent discount rate.
-------
Additionally, it is very unlikely that the State or community
would accept No Action at the Croydon TCE Site.
Remedial Alternative No. 2 - Connection to Public Water System
With Monitoring
This alternative involves the construction of new water service lines,
mains, hydrants, and valves and the connection to the Borough of Bristol
Water and Sewage Department supply mains (see Figure 3). The
intent of this alternative is to eliminate the present and future
health risks associated with potable and non-potable' use of
contaminated ground water. During the FFS, the only street within
the zone of ground water contamination without a water main was
Belleview Avenue. Only two homes are located along this street.
One household is connected to a water main from an adjacent
street. The other household is not serviced. In addition to this
household, 12 other households throughout the study area are not
serviced by the public water supply. These homes are located
along streets with an existing water main. For one reason or
another, these homes are not connected to the water main along
their street or adjacent streets.
It is recommended that the homes without the services of a public
water supply be verified for number, location, and usage before
designing this remedial action. This is necessary because the
Township has just recently installed water lines along five
streets within the study area and it is possible that the Township
may continue to expand the water service.
EPA will not be responsible for the operation and maintenance of
the water supply system once it is operational. EPA will transfer
control of the new water lines to the Borough of Bristol Water and
Sewage Department as soon as construction is complete. Therefore,.
construction details (i.e., diameter of lines, spacing of fire
hydrants, etc.) must meet the requirements of the State/Borough of
Bristol and local fire codes.
This alternative also involves ground water monitoring to ensure
that homes located outside of the TCE-contarainated zone (without
public water) will not be at risk. At present, homes located west
of Central Avenue without public water are not affected by the
ground water contamination since the plume is migrating in a south-
southeast direction. Monitoring wells and residential wells located
west of Harris Avenue did not exhibit TCE contamination. As a
safeguard, however, a limited number of residential wells west of
the plume will be sampled annually to confirm the absence of ground
water contamination in this area.
This alternative could be implemented relatively quickly to mitigate
health risks under both present and future conditions. The estimated
construction time for installation of additional water lines in the
community of Croydon is approximately one to two months.
- 23 -
-------
I
ro
NOTE- HOMES LOCAIL'U WISI Uf UHANI AVI
ARC NOT LUCAIED winiiN nit ^
IN AREA
seas.? 17;
-------
The techniques involved in connecting the residences to the public
water system are well established and use common engineering and
construction practices. Generally, public water systems are very
reliable and require only minimal maintenance. This alternative
provides long-term reliability and any maintenance required to the
water mains would be provided by the Borough of Bristol Water and
Sewage Department. Maintenance of the water service lines (on private
property) is the responsibility of the property owner, but this
would be minimal.
This alternative will require the approval of the Borough of
Bristol Water and Sewage Department. Since the water department
currently has excess capacity and the proposed water hook-ups are
within the corporate boundaries of Croydon, no opposition is
anticipated by the water department. The construction of the new
water main and service lines would require the coordination of EPA
and the water department to ensure that the new construction complies
with the design and construction standards of the State/Borough of
Bristol. By connecting to the public water system, the water quality
will be regulated by the National primary Drinking Water Regulations
and the Pennsylvania Water Quality Standards, in conjunction with the
requirements of the Bucks County Health Department and the Borough of
Bristol Water and Sewage Department. This action will be in compliance
with the health-based ARARs for the Croydon TCE Site.
If some residents wish to use their private well in addition to
having the services of public water, the homeowner must ensure
that cross-contamination will not occur. Otherwise, the private
well will be sealed once the public water service is installed.
Residents who elect to continue to use their private wells for
non-potable purposes are not expected to incur any significant
risk. Non-potable water uses, such as car washing and watering of
lawns, will result in short-term exposure to the contaminants
present in the ground water.
A public health issue of concern is the ground water control
required for future residential development in the contaminated
zone. Specifically, the development of new residential wells
within the TCE-contaminated zone should be restricted. In order
to prevent new wells from being constructed, a zoning ordinance
which restricts access to a polluted aquifer may be employed.
However, it does not appear that any municipal entity within
Pennsylvania has adopted an ordinance either generally prohibiting
the withdrawal of water for any purpose, or specifically, for the
purpose of human consumption.
The state and community will most likely support this alternative.
However, some residents may object to paying for water which was
once free"to them.
Base-line and high sensitivity cost estimates have been developed
for this alternative (See Table 7 for a breakdown of capital,
operation and maintenance (O&M) , and Present Worth cost estimates).
The base-line estimate of 13 homes (to be serviced with public water)
- 25 -
-------
is based on information provided by the Borough of Bristol Water
and Sewage Department. The high sensitivity cost estimate for this
alternative assumes that seven more residential wells (i.e., a total
of 20 residential wells) will be connected to the public water supply.
Since no "door to door" check or survey was made throughout the area
of concern, and the number of "non-serviced" -households was provided
by the water department, it is possible that more homes along "serviced"
streets are without public water. As previously mentioned, the
location and number of non-serviced households should be verified before
designing this remedial alternative. O&M costs include long-term
monitoring of the ground water.
Due to the focused nature of this FS, this alternative does not
address the reduction of the source of contamination, toxicity,
mobility, and volume of contamination; however, a forthcoming FS
will address remediation of the ground water.
Remedial Alternative No. 3 - Individual Well Treatment with Granulated
Activated Carbon (GAC) and Monitoring
<
This alternative involves the installation of a GAC treatment unit
in each of the 13 homes using private wells in the ground water
contamination zone. The rationale for estimating the number of
affected households is the same as for Alternative No. 2. The
intent of this alternative is to reduce the present and future
health risks associated with the potable and non-potable use of
contaminated ground water.
In order to provide proper operation and maintenance of the units,
periodic service is required. Replacement of the carbon which is
dependent on the concentration of ground water contaminants, is
anticipated approximately every 6 months.
Monitoring of the GAC effluent will be periodically required as
part of this alternative to verify that the system is operating
properly. Since contaminant concentrations may increase and new
contaminants may appear that cannot be effectively treated by the
GAC treatment (e.g., vinyl chloride), a limited number of
monitoring wells will be monitored annually. Additionally, a
limited number of residential wells (seven wells) along Grant and
Linton Avenues will be monitored annually to confirm the absence
of ground water contamination west (outside of) of the ground water
contamination zone. Under this alternative, Right of Entry Agreements
would be required between the State and the private property owners.
This alternative could be implemented relatively quickly to
mitigate health risks under both present and future conditions.
The estimated construction time for the installation of GAC units
in the 13 homes is approximately five weeks. This construction
estimate does not include pilot testing.
Implementation of this alternative would reduce the health risks
associated with exposure to contaminated ground water, but would
not eliminate all risks since future contaminants may increase in
- 26 -
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concentration or new contaminants may appear that cannot be effectively
treated by GAC units (such as vinyl chloride). Although GAG units
generally have a removal efficiency of between 60 to 90 percent
for most organic chemicals, it is apparent that these treatment
systems will be ineffective in mitigating longterm removal efficiency
of ground water use, should non-removable contaminants arrive at
the receptor wells. Additionally, if contaminant concentrations
increase significantly, the contamination may exhaust the carbon
supply, permitting contaminants to pass through untreated. Thus,
monitoring of both ground water and treatment effluent is required
to indicate the presence or absence of contaminants (i.e., TCE,
vinyl chloride) in the wells.
The techniques associated with installing individual treatment
systems and maintaining the systems use common engineering and
construction practices, pilot testing would be required for the
design of the treatment systems, but a significant delay is not
anticipated.
The installation of individual well treatment units in the homes
using private wells should satisfy the applicable drinking water
standards/ based on the current contaminants and degree of contamination
in the residential wells. Should non-removable contaminants such
as vinyl chloride occur in concentrations greater than the M3L (2
ug/1) in the residential wells, then this alternative would not
comply with the ARARs for the Croydon TCE Site.
Implementation of this alternative will result in a decrease in
the contaminant levels in ground water used in the home. The
effectiveness of this alternative is based on the assumptions that
the granulated activated carbon filter will operate at peak efficiency
and that adequate maintenance will be performed. If the filter is
not replaced as scheduled (i.e., every 6 months), contaminant
breakthrough could occur and exposure to the contaminants present
in the ground water at levels greater than or equal to the original
concentrations could result.
State acceptance of this alternative is questionable, since the
State will be responsible for the long-term operation and maintenance
of the treatment system once it is operational. EPA will seek
transfer of control to the State as soon as construction is complete.
Monitoring of the ground water and effluent is also required under
this alternative. Cost's associated with collecting samples and
providing analysis would result from this monitoring. EPA would
pay for the operation and maintenance cost of monitoring for the
first year. Thereafter, these costs would be the responsibility of the
State.
Because of the focused nature of this FS, this alternative does
not address the reduction/ mobility/ or volume of the source of
contamination; however/ a forthcoming FS will address remediation of
- 27 -
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the ground water. The toxicity of the contaminants will only he
reduced at the point of exposure.
Table 7 outlines the capital, O&M, and present worth costs for
this alternative. The baseline and high sensitivity cost
estimates are based on 13 GAC units and 20 GAG units, respectively.
The rationale for estimating the number of affected households is
the same as for Alternative No. 2. Detailed cost information is
provided in the FFS Report. The O&M costs include long- term
monitoring of the ground water and the GAC effluent.
Selected Remedy
Based on available data and analysis conducted to date, Alternative 2
is selected as the most appropriate remedy for meeting the goals of
the initial operable unit at the Croydon TCE Site. This alternative
consists of:
o Connection of approximately 13 residences to the public water
supply system
o Ground water monitoring
This action is an operable unit measure to prevent human exposure
(i.e. ingestion, inhalation, dermal contact) to contaminated water
having concentrations of TCE and related constituents in excess of
Federal, State, and local health-based ARARs. This alternative will
also not be inconsistent with a final remedial action for this site.
A summary of each of the individual major components of this selected
remedy is described in the following:
o Construction of new water service lines, mains, hydrants, and
valves, and the connection to the Borough of Bristol Water and
Sewage Department water supply mains. It is estimated that 13
residences will be provided this service, based on records obtained
through the Borough of Bristol Water and Sewage Department.
The number and location of residences which will receive public
water will be verified prior to the design of this remedial action.
o Approximately 300-feet of 6-inch, ductile iron, water main will he
installed along Belleview Avenue. Service lines (3/4-inch
copper) with cur>h box and valve will be installed for each
of the 13 residences.
o Ground water monitoring will be conducted outside of the TCE
plume area to monitor the possible advancement of contaminants.
Wells will be sampled annually and analyzed for TCE, tetrachloro-
ethene, vinyl chloride, 1,1,1-trichloroethene, 1,1-dichloroethane,
and 1,1-dichloroethene. These wells are primarily located west
of the TCE plume (ground water flow direction is south-southeast).
- 28 -
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TABLE 7
REMEDIAL ACTION ALTERNATIVE COST SUMMARY
CROYDON TCE SITE
Remedial Action
Alternative
Mo. 1 - Mo Action
No. 2 - Alternate
Water Supply
No. 3 - Individual
Well Treatment with
GAG
Sensitivity Cost Item
Not Applicable
Number of homes to be
serviced with public
water is estimated to
be 13.
A sensitivity high
range of 50 percent
was used.
Number of homes to be
treated is estimated
to be 13.
A sensitivity high
range of 50 percent
was used.
.
Capital
Costs
(1000s)
-0-
53.6
69.1
64.5
89.2
Annual O&M
Costs (1000s)
( Includes
Monitoring)
Years
1-5
-0-
3.4
3.4
29.9
39.2
Years
6-30
-0-
3.4
3.4
10.7
14.3
Present
Worth
CostsU)
(1000s)
-0-
106
121
312
417
(1) Present worth costs are calculated for an O&M period of
30 years at a 5 percent discount rate.
- 29 -
-------
o EPA will transfer control of the new water lines and services to t N,
Borough of Bristol Water and Sewage Department as soon as construci Jn.
is completed.
Statutory Findings
The selected remedy satisfies, in part, the requirements of Section 121 of
CERCLA for being protective of human-health, attainment of ARARs, and cost
effectiveness. Utilizing permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable, are not applicable to this operable unit. Neither is the
preference for treatment that reduces toxicity, mobility or volume as a
principal element. These statutory requirements will be addressed in the
second operable unit which will consider ground water, sediment, and soil
remediation alternatives.
Applicable or relevant and appropriate requirements (ARARs) pertaining to
this remedy will be attained. The selection of this alternative has
generated a limited number of ARARs, due to common and accepted
engineering/construction practices associated with the installation of
water mains and water service connections. These requirements
consist of State/local plumbing and fire codes which are to be considered
for the installation of water mains, service connections, and fire
hydrants. Also, the residences targeted, herein, are to be connected
to the public water system which must be in compliance with the N,
National primary Drinking Water Regulations, the Pennsylvania . .
Water Quality Standards, and the requirements of the Bucks County
Health Department and Borough of Bristol Water and Sewage Department.
Schedule
The anticipated schedule is for the design to begin in the winter of
1988/89. Once the design is completed, a construction period of one
to two months will be required for the installation of the water main,
service connections and other appurtenances.
- 30 -
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CROYDON TCE SITE
BRISTOL TOWNSHIP, PENNSYLVANIA
FINAL RESPONSIVENESS SUMMARY
DECEMBER 1988
This Responsiveness Summary documents public concerns and
comments expressed during the public comment period. The
summary also documents EPA's responses to the comments and
concerns that were received. Information is organized as
follows:
1.0 Overview
2.0 Summary of Community Involvement
3.0 Summary of Comments and Responses Regarding the Focused
Feasibility Study and Proposed Plan
4.0 Remaining Concerns
Attachment: Community Relations Activities at the Croydon TCE
Site.
1.0 OVERVIEW
The public comment period for the Croydon TCE Site began on
November 17, 1988, and extended to December 16, 1988. To
facilitate commenting, EPA held a public meeting at the Bristol
Township Municipal Building on December 13, 1988.
At the meeting, EPA discussed the Focused Feasibility Study
performed for the site and explained the EPA's Proposed Plan for
providing a safe drinking water supply to area residents
currently depending on groundwater wells. The plan involves
connecting 13 households to the Bristol Township public water
supply.
Local residents and officials offered no criticism of the plan;
however, residents on public water stated that they would like
their tap water tested and that they feel the township water
authority should be more closely supervised.
2.0 SUMMARY OF COMMUNITY INVOLVEMENT
Residents in the vicinity of the Croydon TCE Site were not
generally aware of the site until mid-1987, when several of them
were contacted during the EPA community assessment or when they
received well-survey questionnaires in the mail. Of the 482
area residents who were sent questionnaires, 120 recipients
responded.
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Two public meetings have been held regarding the site, and
attendance has been low. However, residents are very concerned
about the current and potential environmental and human health
risks associated with the many commercial and industrial
businesses located in the area. They have requested help from
their Congressman, Representative Kostmeyer, to secure
health-screening for local residents.
3.0 SUMMARY OF COMMENTS AND RESPONSE
The comments and responses summarized in this section were made
during the public comment period held in late November and early
December 1988. They reflect concerns regarding both the Focused
Feasibility Study (FFS) and the RI/FS, as well as citizens'
concerns regarding potential hazardous waste problems throughout
the communities surrounding the site.
1. An official inquired whether citizens' comments had to be
submitted to EPA in writing.
EPA Response: Although letters-of-comment are
preferred, comments and issues raised during the
public meeting are part of the official meeting
record. The presence, at the meeting, of a court
reporter assures the comments presented will be
entered into the official meeting transcript.
2. Questions were raised about the NFL (National Priorities
List) and the HRS (Hazard Ranking System). Of particular
interest was the HRS Score for the Croydon TCE Site.
EPA Response: EPA explained how sites are listed on
the NPL and how HRS scores are established, saying
that any site scoring 28*5 or above becomes an NPL
site eligible for remediation under Superfund. The
Croydon TCE Site score of 31.6 was due primarily to
the contamination of surface water and groundwater in
the site vicinity. This score, according to the EPA
spokesman, is considered an average one for the region
which has a high score of 38.
«
3. Questions were asked about the groundwater monitoring
program and what it entailed, as well as whether the
Pennsylvania Department of Environmental Resources (FADER)
participated in the monitoring program.
EPA Response: EPA explained how monitoring wells are
., installed and said that EPA had installed 29
monitoring wells in addition to the 17 monitoring
wells installed earlier by the Rohm & Haas Company.
These wells were used during the Phase I RI to
2'
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evaluate the extent of groundwater contamination and
they will continue to he monitored during Phase II.
Monitoring well depths ranged from 15 to 20 feet for
shallow wells and from 55 to 60 feet for deep wells.
In addition to the monitoring wells, the Phase I
groundwater monitoring program also utilized 40
residential wells.
PADER participates in every project EPA does in
Pennsylvania hy reviewing all of EPA's work and plans
and making comments on them.
4. Several public meeting participants inquired about the
boundaries of the RI/FS and the FFS study areas and whether
they included Rohm & Haas Company property.
EPA Response: EPA displayed an enlarged map showing
the boundary of the 3.5-square-mile RI/FS study area
and the boundary of the 1.0-square-mile FFS study area
with familiar geophysical and natural landscape
features clearly labeled to help residents understand*
The EPA spokesman explained that the FFS boundary was
based on information provided by previous studies of
the site vicinity, particularly, on information from a
prior Rohm & Haas Company report that revealed
contamination of unknown origin in the area. The
Rohm & Haas property, however, was not included in the
Croydon TCE Site studies.
5. Numerous questions regarding the possibility of soil and
groundwater contamination in areas not included.in the FFS
were raised, and several people expressed concern about
long-term health effects that contamination in these areas
may have on the local residents, particularly those who
cultivate vegetable gardens. A spokeswoman, representing
the Croydon Civic Association, expressed concern that many
areas in the community of Croydon and the neighborhoods
between Route 13 and 413, may have an increased incidence
of cancer because these communities may be built on filled
wetlands. Long-term residents claim that much of the area
was filled, in J.952, with silt dredged from the Delaware
River which they believe may have been contaminated by
heavy industry on both shores. One speaker said that
residents have asked Congressman Kostmeyer for help in
getting a health study underway in Croydon and surrounding
areas.
., EPA Response: EPA explained that the concentration of
TCE in soil is not high enough to pose a health risk
and stated that the risk assessment indicated that
though groundwater is contaminated, surface soil
-------
concentrations of ICE should not increase from
contamination in the groundwater. Thus, vegetables
grown in the area should not pose an increased health
risk. The health-risk stems primarily from drinking
contaminated groundwater.
EPA was not aware that much of the area was built on
over-fill and suggested that the civic association
spokeswoman contact the RPM with additional
information at a later date.
6. Several questions were raised regarding the preferred
remedial alternative, including questions about the cost to
home-owners, hook-up, enforcement, and the possibility of
similar action in the future.
EPA Response: The preferred alternative involves
connecting 13 homes in the FFS area to the public
water supply. The cost for connection would he paid
by the EPA; residents would pay only the monthly water
bills. Should these residents decide to hook into the
public water supply, they would have to abandon their
private wells to avoid cross-contamination. Although
there is concern over the TCE levels in the aquifer,
the 13 residents would not be required to connect to
the public water supply system. As long as they
understood the health risks, as extracted from the
study, they could not be forced to abandon their
private wells. The possibility of other homes
requiring hook-up to the municipal water supply would
he determined by the Phase II RI. Similar action
might be needed, if the study findings are- similar.
7. Questions arose on several occasions about the safety of
the water in the public water-supply system. Some speakers
suggested the system is antiquated and stated that they
don't feel it is closely regulated. They asked to have
their tap water sampled.
EPA Response: The township water supply is regulated
by EPA to guarantee safety. Also, the Bucks County
Health Department is active here, and the water
authority *is required to submit reports to PADER and
to EPA to demonstrate that the water meets safe
drinking water standards. The EPA spokesman explained
that a public supply well located in one area, south
of the area of concern, had previously exhibited
elevated levels of TCE. This problem was corrected by
installing an Air Stripping Column to reduce the TCE
levels to less than one part per billion (ppb
concentration of TCE must be less than five ppb
according to safe drinking water standards).
-------
EPA agreed to collect and analyze samples from some
household taps connected to the public water supply
and said that they would contact either a local council
woman, who was present, or the representative of the
civic association at a later date.
8. Questions arose about the possible sources of the TCE
contaminant plume associated with the Croydon site. People
wanted to know if Rohm & Haas was directly responsible, or
if some other nearby companies might he at fault. Concern
also was expressed about contaminant sources in Central and
Upper Bucks County.
EPA Response: EPA explained the ongoing program to
find the PRP(s) (potentially responsible party(s).
The discussion included how the EPA identifies the
PRP(s) and what steps are taken to get the PRP(s) to
perform the cleanup or to reimburse EPA for the work.
Based on current information, EPA does not believe
that Rohm and Haas is responsible because earlier
studies indicated that "a plume of contaminated
groundwater, from an unknown source upgradient of
Rohm and Haas was migrating onto the company's
property." The source is believed to be in one of
two areas located north of Route 13. Locating the
contaminant source(s) is the primary purpose of
the Phase II RI/FS. With regard to whether a source
may he located even further north of the area of
concern, EPA explained that two monitoring wells were
installed upgradient of the site to be used as
background wells. Should those wells exhibit
contamination, then the possibility of a source
further north would not be unreasonable considering
that the direction of groundwater flow is
south-southeast toward the Delaware River.
9. One resident was under the impression that the Croydon TCE
Site had been taken off the NPL and that the Rohm and Haas
Site had been delisted and placed "on the backhurner".
«
EPA Response: The Croydon TCE and Rohm & Haas sites are
still on the Superfund NPL. Rohm & Haas has been proposed
to be delisted from the NPL. If this does occur, Rohm &
Haas will undergo a RCRA (Resource Conservation and
Recovery Act) corrective action. As a result, it will still
be regulated by EPA and will be closely monitored. It will not
, be "on the backhurner"; RCRA is a very active program and
is a counterpart to Superfund. RCRA deals with active
facilities; Superfund usually deals with sites that have
been abandoned.
-------
10. Residents inquired about the effect of flooding, which is a
common occurrence in the area. They wondered if flooding
might spread contaminants and increase risks. They also
wondered whether it was possible that the contaminant
levels detected today may actually he greatly reduced from
• what they were when contamination first occurred.
EPA Response: Rather than increasing risks, flooding
may actually have reduced them over time, because
flooding may have flushed some contaminants from the
soils and the groundwater, thereby reducing
contaminant concentrations. It's possible that
contamination may have resulted from an event such as
the accidental spilling of a few barrels of solvent
and may have occurred as many as 20 years ago. If
that is the case, then contaminant concentration
levels would, most likely, have reduced over time.
11. One resident inquired whether chemicals volatilizing from
the groundwater posed any threat to health.
EPA Response: There are cases where groundwater is
just below the soil surface, and at some of these
sites vapors from the groundwater enter crawl spaces
and present a risk; this is not the case at the
Croydon TCE Site .where the groundwater is 20 feet
below surface and the contaminant levels are low.
12. One gentlemen, who stated he did not live in the Croydon
community, expressed concern about the potential for
spreading contaminants into the deep aquifer by piercing
the clay layer while installing monitoring wells.
EPA Response: Monitoring wells do not pierce the clay
layer. They are set above it. When the drill begins
picking up clay, the drilling stops.
13. Questions were asked concerning the Phase II RI, including
the area it will cover and how it is progressing.
Residents requested to be kept informed, during the ongoing
program, regarding important developments.
EPA Response: Field activities for Phase II were
recently completed and analytical results will
probably be back from the laboratory in a few months.
The Phase II study encompassed the entire Croydon TCE
Site and extended a bit north of Route 13 to look at
the two potential source areas identified by the FFS.
" It will take some time to complete the RI/FS report
and develop remedial alternatives to address soil,
surface water, and groundwater contamination
-------
throughout the site. When EPA has developed
alternatives, another public meeting will he held to
discuss the Phase II RI/FS report and to provide
opportunities for the public to comment on EPA's
proposed plan. This will probably occur around the
end of 1989.
No new developments are anticipated since the field
work is completed; however, if any occur, EPA will
Inform residents.
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4.0 REMAINING CONCERNS
Concerns not conclusively addressed during the comment period
include the following:
o Concern regarding contamination from fill reportedly
dredged from the Delaware River or located in areas
beyond the study boundary.
o Concern for protection of public health and the leed
for a health study.
o Concern that the public water supply system may be
out-dated and that it is not monitored closely enough.
8
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ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES AT THE CROYDON TCE SITE
Community Relations Activities conducted to date:
o EPA conducted onsite interviews with local residents
and officials in June and July 1987.
o EPA prepared and distributed a well-survey
questionnaire to local residents and businesses.
o EPA held a public meeting, in August 1987, to discuss
the RI/FS and the Superfund process.
o EPA distributed copies of the Proposed Plan to local
residents, who would be affected by .EPA's preferred
alternative, and made copies available at local
information repositories located in the Margaret R.
Grundy Memorial Library and the Bristol Township
Municipal Building. The plan discussed the Focused
Feasibility Study, the remedial alternatives it
considered feasible for the site, and the alternative
preferred by the EPA.
o An EPA advertisement, notifying the public of the
availability of the Proposed Plan and the opening of
the public comment period, appeared in the Bucks
County Courier Times on November 17, 1988.
o ' A public meeting was held on December 13, 1988, to
provide residents and officials an opportunity to
discuss the EPA's Proposed Plan and the ongoing
remedial action program for the site.
-------
CROYDON TCE SITE
ADMINISTRATIVE RECORD FILE* **
INDEX OF DOCUMENTS
SITE IDENTIFICATION
Preliminary Assessment and Site Identification Reports
1) Site Inspection Report, 4/3/85. P. 1-16. References are listed on
P. 15-16.
2) Memorandum to Mr. Harold Byer, U.S. EPA, from Mr. Charles B. Salmon,
NUS Corporation, re: Transmittal of the Technical Directive Document
for the Croydon TCE Site, 12/2/86. P. 17-28. The Technical Directive
Document, two site maps, the Preliminary Assessment, and a list of
references are attached.
* Administrative Record File available 12/20/88.
** Supporting Sampling Data is located at the EPA Region III Central
Regional Laboratory in Annapolis, Maryland.
.•»
Note: Company or organizational affiliation is identified in the index only
when it appears in the record.
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REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Final Phase I, RI/FS Work Plan, Croydon TCE Site, Bucks County,
Pennsylvania, prepared by NUS Corporation, 8/87. P. 1-114. References
are listed on P. 104-106.
2) Report: Final Phase I, Field Operations Plan, Croydon TCE Site RI/FS,
Bucks County/ Pennsylvania, prepared by NUS Corporation, 10/87. P. 115-251.
3) Report: Final Phase II, Field Operations Plan, Volume I of II, Croydon
TCE Site RI/FS/ Bucks County, Pennsylvania, prepared by NUS Corporation,
9/88. P. 252-366.
4) Report: Final Phase II, Field Operations Plan, Volume II of II, Croydon
TCE Site RI/FS, Bucks County/ Pennsylvania, prepared by NUS Corporation,
9/88. P. 367-643. References are listed on P. 643.
Remedial Investigation/Feasibility Study
1) Report: Final Phase I, Remedial Investigation Report, (Volume I of III),
Croydon TCE Site/ Bucks County, Pennysylvania, prepared by NUS
Corporation, 8/88.P. 1-206. References are listed on P. 194-202.
2) Report: Final Phase I, Remedial Investigation Report, Appendices
(Volume II of III), Croydon TCE Site/ Bucks County,. Pennsylvania, prepared
by NUS Corporation, 8/88. P. 207-405.
3) Report: Final Phase I, Remedial Investigation Report, Appendices
(Volume III of III), Croydon TCE Site/ Bucks County, Pennsylvania, prepared
by NUS Corporation, 8/88. P. 406-709.
4) Report: Final Focused Feasibility Study Report, Croydon TCE Site, Bucks
County, Pennsylvania, prepared by NUS Corporation, 9/88. P. 710-80-7.
References are listed on P. 784.
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Correspondence and Supporting Documentation
1) Letter to Ms. Nanci Sinclair, U.S. EPA, from Mr. Donald B. McCoy,
McCoy & Auchinleck, re; Contaminated groundwater supply in the Croydon
Bristol Township area, 9/14/87. P. 1-1.
2) Letter to Mr. William E. Waldron, Owens-Illinois, from Mr. Harry Harbold,
U.S. EPA, re: Right-of-Entry Agreement, 9/23/87. P. 2-3a. Two certified
mail receipts are attached.
3) Letter to Mr. Paul Rosenstock, Rohm and Haas, from Mr. Harry Harbold, U.S.
EPA, re: Right-of-Entry Agreement, 9/23/87. P. 4-5a. Two certified mail
receipts are attached.
4) Letter to Mr. M. E. Tryon from Mr. Harry Harbold, U.S. EPA, re:
Right-of-Entry Agreement, 9/23/87. P. 6-7a. Two certified mail receipts
are attached.
5) Letter to Mr. and Mrs. Robert Robinson from Mr. Harry Harbold, U.S. EPA,
re: Right-of-Entry Agreement, 9/23/87. P. 8-9a. Two certified mail
receipts are attached.
6) Letter to Mr. Robert J. Sabatini from Mr. Harry Harbold, U.S. EPA, re:
Right-of-Entry Agreement, 9/23/87. P. 10-lla. Two certified mail receipts
are attached.
7) Letter to Mr. James Lautz, Bristol Cemetary, from Mr. Harry Harbold, U.S.
EPA, -re: Right-of-Entry Agreement, 9/23/87. P. 12-13a. Two certified mail
receipts are attached.
8) Letter to Mr. John Weirman, Coyne Chemical, from Mr. Harry Harbold, U.S.
EPA, re; Right-of-Entry Agreement, 9/23/87. P. 14-15a. Two certified mail
receipts are attached.
9) Letter to Mr. Tony Lapolla from Mr. Harry Harbold, U.S. EPA, re:
Right-of-Entry Agreement, 11/2/87. P. 16-17a. Two certified mail
receipts are attached.
10) Letter to Mr. Robert Ward from Mr. Harry Harbold, U.S. EPA, re: Sampling
results of well water, 1/26/88. P. 18-18.
11) Letter to Mr. Evertt Hogg, Bucks County Health Department, from Mr. Jeffrey
B. Winegar, U.S. EPA, re: Nitrate contamination of residential wells,
4/19/88. P. 19-19.
12) Letter to Mr. Johnson from Mr. Jeffrey B. Winegar, U.S. EPA, re: Residential
well water sample, 4/19/88. P. 20-21.
13) Letter to Mr. Francis Clark from Mr. Jeffrey B. Winegar, U.S. EPA, re:
Residential,well water sample, 4/19/88. P. 22-23.
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14) Letter to Mr. Brown from Mr. Jeffrey B. Winegar. U.S. EPA, re: Residential
well water sample, 4/19/88. P. 24-25.
15) Letter to Mr. Ralph Whitman from Mr. Jeffrey B. Winegar, U.S. EPA.
re: Residential well water sample, 4/19/88. P. 26-27.
16) Letter to Mr. David Grafenstein from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Residential well water sample, 4/19/88. P. 28-29.
17) Letter to Mr. Hugh Templeton from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Residential well water sample, 4/19/88. P. 30-31.
18) Letter to Mr. Frank Hayden from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Residential well water sample, 4/19/88. P. 32-33.
19) Letter to Ms. Barbara Higginson from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Residential well water sample, 4/26/88. P. 34-35.
20) Letter to Mr. Alexander Johnson from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Residential well water sample, 6/14/88. P. 36-37.
21) Letter to Mr. Martin Mellor from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 38-38.
22) Letter to Mr. Hugh Templeton from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 39-39.
23) Letter to Mr. Frank Hayden from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 40-40.
24) Letter to Mr. Robert Ward from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 41-41.
25) Letter to Mr. Charles A. Lehr, Jr. from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 42-42.
26) Letter to Mr. Bosak from Mr. Jeffreys. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 43-43.
27) Letter to Ms. Pam Denner from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 44-44.
28) Letter to Ms. Barbara Higginson from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 45-45.
29) Letter to Ms. Elizabeth Tryon from Mr. Jeffrey B. Winegar, U.S. EPA,
re: Nitrate contamination of residential well, 6/14/88. P. 46-46.
30) Letter to Mr. Thomas Hartwell, Hartwell's Garage, from Mr. Jeffrey B. Winegar,
U.S. EPA, re: Transmittal of a Right-of-Entry Agreement, 6/15/88. P. 47-52
A monitoring well locations map, a Right-of-Entry Agreement, a letter
regarding access to Mr. Thomas Hartwell's property, and two certified
mail receipts are attached.
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31) Letter to Ms. Elizabeth Tryon, Tryon Agency, from Mr. Jeffrey B.
Winegar, U.S. EPA, re: Transmittal of a Right-of-Entry Agreement,
6/15/88. P. 53-57. A monitoring well -locations man, a Right-of-Entry
Agreement, and two certified mail receipts are attached.
32) Letter to Mr. Paul Aucker from Ms. Denise M. Parkinson, U.S. EPA, re:
response to Mr. Paul Aucker's reouest for a release from any damages arisina
from the storage of drums at the site, 8/9/88. P. 58-59.
33) Letter to Ms. Elizabeth Tryon, Tryon Agency, from Mr. Jeffrey B.
Winegar, U.S. EPA, re: Remedial Investigation activities, 8/23/38.
P. 60-60.
34) Letter to Mr. and Mrs. John and Mary Sytnik from Mr. Jeffrey B. Winegar,
U.S. EPA, re: Transmittal of a Right-of-Entry Agreement, 8/30/88.
P. 61-70. The following are attached:
a) a site map;
b) a Right-of-Entry Agreement:
c) a signed Right-of-Entry Agreement;
d) a letter regarding the Right-of-Entry Agreement;
e) a letter regarding access to Mrs. Mary Sytnik's property;
f) two certified mail receipts;
g) a memorandum of call regarding Mrs. Sytnik's property.
35) Letter to Sherwood Refinishing from Mr. Jeffrey B. Winegar, U.S. EPA, ,
re: Transmittal of a Right-of-Entry Agreement, 8/30/88. P. 71-75a. «
A site map, a Riqht-of-Entry Agreement, a signed Right-of-Entry Agreement,
and two certified mail receipts are attached..
36) Transmittal letter to Mr. Jeff Winegar, U.S. EPA, from NUS Corporation
re: Transmittal of two proposed drilling locations maps, 9/9/88.
P. 76-78. The maps and a description of the maps are attached.
37) Letter to Mr. Walter Gosik, Bristol Homing Society, from Mr. Jeffrey B.
Winegar, U.S. EPA, re: Transmittal of a Right-of-Entry Agreement,
9/14/88. P. 79-84. A site map, a Right-of-Entry Agreement, a signed
Right-of-Entry Agreement and two certified mail receipts are attached.
38) Letter to Ms. Elizabeth Tryon, Tryon Agency, from Mr. Jeffrey B. Winegar,
U.S. EPA, re: Transmittal of an additional Right-of-Entry Agreement,
9/19/88. P. 84a-87. A Right-of-Entry Agreement, a monitoring well
locations map, and a signed Right-of-Entry Agreement are attached.
.»
-. •*
39) Letter t
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40) Letter to Mr. Paul D, Rosenstock, Rohm and Haas Delaware Valley Inc.,
from Mr. Jeffrey B. Winegar, U.S. EPA, re: Transmittal of a Right-of-Entry
Agreement, 10/18/88. P. 95-98. The Right-of-Entry Agreement and two
certified mail receipts are attached.
41) Letter to Mr. Jeffery [sic] Winegar, U.S. EPA, from Mr. Paul n. Rosenstock.
Rohm and Haas Delaware Valley Inc., re: Transmittal of a signed
Right-of-Entry Agreement, 10/24/88. P. 99-100. The Right-of-Entry agreement
is attached.
n-
42) Letter to the owner, Shervood Furniture Stripping and Refinishinq, from
Mr. Gregg Crystal!, U.S. EPA, re: Request for information concerning the
release of hazardous substances, 11/4/88. P. 101-102.
43) Letter to Mr. Jeffrey B. Winegar, U.S. EPA, from Ms. Mary M. King,
3CM Engineers, re: PCB soil sampling, 11/7/88. P. 103-104.
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COMMUNITY INVOLVEMENT
Corniunity Relation Plans
1) Report: Final Community Relations Plan, prepared by Ebasco Services
Incorporated, 2/18/88. P. 1-21.
2) Report: The Citizen's Guidance Manual for the Technical Assistance
Grant Program, prepared by U.S. EPA, 5/88.P. 22-340.
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GENERAL GUIDANCE DOCUMENTS *
1) "Interim Priorities List," Federal Register, dated 10/23/81.
2) "Expanded Eligibility List," Federal Register, dated 7/32/82.
3) "Proposal of First National Priority List," Federal Register, dated 12/30/8?,,
4) Community Relations in Superfund; A Handbook (interim version), dated 9/83.
5) "Proposal of Update 1," Federal Register/ dated 9/8/83.
6) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled "Transmittal
at Superfund Removal Procedures - Revision 2," dated 8/20/84.
7) EPA Groundwater Protection Strategy, dated 9/84.
8) "Proposal of Update 2," Federal Register, dated 10/15/84.
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activities at
Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 3," Federal Register, dated 4/10/85.
11) Guidance on Remedial Investigations under CERCLA, dated 6/85.
12) Guidance on Feasibility Studies under CERCLA, dated 6/85.
13) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, dated 8/6/85.
14) Groundwater Contamination and Protection, prepared by Mr. Donald V.
Feliciano, dated 8/28/85.
15) Memorandum to U.S. EPA from Mr. Gene Lucero re: Community relations
at Superfund Enforcement sites, dated 8/28/85.
16) "Proposal of Update 4," Federal Register, dated 9/18/85.
17) "Promulgation of Sites frgm Updates 1-4," Federal Register, dated 6/10/86.
18) Superfund Public Health Evaluation Manual, dated 10/86.
19) CERCLA Compliance with Other Laws Manual, dated 5/88.
20) Guidance for Conducting Remedial Investigations and Feasibility Studies
under CERCLA,- Interim Final, prepared by the U.S. EPA Office of Energy and
Remedial Response, dated 8/88.
* Located in EPA Region III office.
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
PENNSYIVANIA Post Offlca Box 2063
Harrltburg, Ptnnsytvanla 17120
December 29, 1988
Dtputy S«cr«t0ry for (717) 797.5028
Environmental Protection
Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Ret Letter of Concurrence, Croyden TCE
Record of Decision (ROD), Alternate Water Supply
Dear Mr. Wassersugi
The Department has reviewed the documents associated
with the above referenced Superfund Site. The Initial operable
unit addresses the following Applicable or Relevant and
Appropriate Requirements (ARARs):
- To prevent human exposure to contaminated
groundwater having concentrations of
trichloroethene (TCE) and related compounds in
excess of Federal and State Health-based(ARARs).
- Compliance with the National Primary Drinking
Water Regulations, the Pennsylvania Department of
Environmental Resources, the Bucks County Health
Department and Borough of Bristol Water and sewage
Department.
It is the Department's position that the appropriate
remedy for the site is the followingt
- Construction of new water service lines, mains,
hydrants, and valves, and the connection to the
Borough of Bristol Water and Sewage Department
supply^water mains. It is estimated that 13
residences will be provided with this service,
based on records obtained through the Borough of
Bristol Water and Sewage Department. The number
and location of residences which will receive
public water will be verified prior to the design
of this remedial action.
I
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Stephen R. Wassersug, Director 2 December 28, 1988
- EPA will transfer control of the new water lines
and services to the Borough of Bristol Water and
Sewage Department, as soon as construction is .
completed. Therefore/ construction details (i.e.,
diameter of lines/ spacing of hydrants, etc.) must
meet the requirements of the State/Borough Qf,
Bristol and local fire codes.
- Ground water monitoring will be conducted at the
residences located outside of the TCE plume area
to monitor the possible migration of contaminants.
Wells will be sampled annually until the second
opeable unit/ RI/FS, ROD/ is completed. At that
time additional alternatives may be chosen.
Permanent solutions and alternatives treatment
technologies or resources recovery technologies are not
applicable to this operable unit. Neither is the preference for
treatment that reduces toxicity, mobility, or volume of
contaminants. These requirements will be addressed in the second
operable unit which will consider groundwater, sediment/ and soil
remediation alternatives.
This latter should not be construed to provide any
assurance pursuant to SARA Section 104(c)(3).
The Department reserves its right to take an
enforcement action pursuant to SARA Section 121(e) and 121(f).
The Department views its design standards as ARARs
pursuant to Section 121, and reserves its right to enforce those
design standards.
Thank you for the opportunity to concur with this EPA
Record of Decision* If you have any questions regarding this
matter, please do not hesitate to contact me.
Sincerely,
Mark M. McClellan
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