O.'ited States
Environmental Protection
Agencyl
Office of
emergency and
Remedial Response
E PA/ROD/R03-89/070
June 1989
5.EPA
Superfund
Record of Decision
Bally Ground Water
Contamination, PA
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REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-89/070
X Redptenr* AcceMlon No.
4. TM* and Subfile
SUPERFUND RECORD OF DECISION
Bally Ground Water, PA
First Remedial Action
5. Report Date
06/30/89
Auttior(e)
». Performing Organization Rept No.
». Perlonnlng Orgtlnlzrion Mum and Addle**
10. Pro|ect/Tuk/WoffclMtNo.
11. Contract(C) or Gr»m(G) No.
(C)
(O
12. Sponeoring Organization Nun* «nd Addraea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D..C. 20460
13. Type of Report * Period Covered
800/000
IS. Supplementary NotM
16. Abatract(UmrU 200 word*)
The Bally Ground Water site is a municipal water supply well field in the Borough of
Bally in Berks County, near the Philadelphia metropolitan area. The Bally Well Field
and the springs to the northwest of the site are the public water sources for
approximately 1,200 Bally residents. The area near the site includes wetlands to the
north and a manufacturing plant (the plant) 1,000 feet to the south of one of Bally Well
Field's municipal wells (Well No. 3). Since the 1930s degreasing solvents containing
methylene chloride, TCA, methanol, toluene, and TCE have been used in manufacturing at
the plant. One of the plant's facilities includes a drum storage area which contains
mpty drums, waste oil, and spent degreasers. A 1982 State water quality check
identified the plant as a source of VOC contamination in Sally's municipal wells.
Former lagoons underlie the plant and are also considered potential sources of aquifer
contamination. From December 1982 to March 1987 the Borough of Bally did not use the
contaminated Municipal Well No. 3 for water supply although the water was periodically
pumped and discharged into a nearby pond to contain the contaminant plume. Pumping,
however, had the effect of drawing VOCs deeper into the aquifer. The well was
completely shut down in March 1987. Results of additional ground water contamination
studies indicated that 19 of 35 wells sampled, contained detectable levels of VOCs..
Currently a plume of VOC-contaminated ground water extends from the plant to the east
(See Attached Sheet)
17. Document Analytic
Record of Decision - Bally Ground Water, PA
First Remedial Action
Contaminated Media: gw
Key Contaminants: VOCs (TCE)
In MenMera/Open^
c. COSATl RelaVGroup
11. Anftabttty Statement
It, Security Claee Onto Report)
None
20. Security Ctaae(Thle Page)
None
21. Ma. of Page*
88
I AHSI-ZM.U)
See eMtnjctfane en Arwnw
(Fomwty NTTS-JS)
t of Convnw ov
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EPA/ROD/R03-89/070
Bally Ground Water, PA
First Remedial Action
16. Abstract (Continued)
and northeast. Plume contaminant movement has become more controlled since pumping and
air stripping pilot testing began at Well No. 3. Ground water is the focus of this
remediation because no remaining source of VOC contamination has been identified on the
site. The primary contaminants of concern affecting the ground water are VOCs
including TCE.
The selected remedial action for this site includes abandoning appropriate wells in
the attainment area; pumping and treatment of ground water from Municipal Well No. 3 by
air stripping with either vapor phase carbon, regenerable vapor phase carbon, or vapor
phase catalytic oxidation, followed by discharging treated water to an adjacent stream
or into the municipal potable water system, as needed, to provide a suitable
alternative water supply; implementation of institutional controls restricting the use
of operable private wells and the construction of new wells within the attainment area;
and performing ground water and surface water monitoring to measure contaminant
concentration and migration. The estimated present worth cost for this remedial action
ranges from $2,950,000 to $3,640,000, which includes O&M costs from $105,000 to
$189,000 depending on the chosen treatment option.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Bally Groundwater Contamination Site
Borough of Bally, Berks County, Pennsylvania
Statement of Purpose
This decision document presents the selected remedial action for the Bally
Groundwater Contamination Superfund Site (Site) developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as
amended by the Superfund Amendments and Reauthorization Act of 1986 (CERCLA), 42
U.S.C. Section 9601 et seq., and to the extent practicable, the National Conting-
ency Plan (NCP), 40 C.F. R. Part 300.
Statement of Basis
This decision is based upon and documented in the contents of the
Administrative Record. The attached index identifies the items which comprise
the Administrative Record. The Commonwealth of Pennsylvania has reviewed,
commented and concurred on this Record of Decision.
Description of the Selected Remedy
The remedial alternative presented in this document is the permanent remedy
for resolving the groundwater contamination at the Site. This remedy is comprised
of the following components:
1. Abandoning appropriate existing private wells and implementing
institutional controls on the use of operable private wells and
the construction of new wells;
2. Performing groundwater and surface water monitoring to measure
contaminant concentrations and migrations by removing
contaminated groundwater from the aquifer through continuous
pumping of Municipal Well No. 3;
3. Treating the extracted groundwater by one of the treatment
options retained for consideration and discharging the treated
water from Municipal Well No. 3 to the adjacent stream or into
the Borough of Bally potable water system as needed to provide
suitable alternative water supply;
4. Performing necessary additional studies in the pre-design phase
to evaluate the configuration of any additional groundwater extraction
well(s) required.
Declaration
The selected remedy is protective of human health and environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective as set forth in Section 121(d) of CERCLA, 42 U.S.C.
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Section 9621 (d). This remedy satisfies the statutory preferences as set
forth in Section 121 (b) of CERCIA, 42 U.S.C. Section 9621 (b), for remedies that
employ treatment that reduce toxicity, mobility or volume as a principal element.
After extensive studies it has been concluded that a specific source of contam-
ination was not found. Although a specific contamination source area was not
identified, the shallow ground water contamination plume had the highest
concentration of contaminants. The aquifer contamination is attributed to
a historic release with no discernible current source. Finally, it is determined
that this remedy utilizes permanent solutions and alternative treatment technolo-
gies to 'the maximum extent practicable.
This is a permanent remedy and will be reevaluated within five years of the
completed remedial action in accordance with the NCP.
Date Edwin B. Erickson
Regional Administrator
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Table of Contents
for
Decision Suimvary
SECTION PAGE
I. INTRODUCTION 4
II. SITE NAME, LOCATION AND DESCRIPTION 4
III. 'SITE HISTORY 5
IV. ENFORCEMENT HISTORY 7
V. SITE CHARACTERISTICS 7
A. GEOLOGY/fcYDROLOGY 7
B. EXTENT OF CONTAMINATION 9
C. SUMMARY OF SITE RISKS 11
VI. COMMUNITY RELATIONS HISTORY 13
VII. REMEDIAL ALTERNATIVE OBJECTIVES 13
VIII, DESCRIPTION OF ARARS 16
IX. DESCRIPTION OF REMEDIAL ALTERNATIVES 20
X. COMPARITIVE ANALYSIS OF ALTERNATIVES 24
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 37
XII. SELECTED REMEDIAL ALTERNATIVE 37
A. EVALUATION CRITERIA 38
B. DETERMINATION OF PREFERRED REMEDIAL ALTERNATIVE 38
C. STATEMENT OF FINDINGS REGARDING WETLANDS
AND FLOODPLAINS 38
XIII. STATUTORY DETERMINATIONS 38
APPENDIX A. - SUMMARY OF ANALYTICAL DATA
APPENDIX B. - RESPONSIVENESS SUMMARY
APPENDIX C. - ADMINISTRATIVE RECORD INDEX
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I. INTRODUCTION
The Borough of Bally is located in Berks County, Pennsylvania near the
Philadelphia Metropolitan area. In 1982, the Bally Municipal Water Authority
conducted a water quality check of the Bally water system and discovered the
presence of elevated concentrations of chlorinated volatile organic compounds
(VOCs) in Bally Municipal Well No. 3. A survey conducted in 1983 by the
Pennsylvania Department of Environmental Resources (PADER) indicated that the
Bally Engineered Structures, Inc. (BES) plant was a potential source of the MX
contamination (See Figure 1). Bally Municipal Well No. 3 was removed from the
municipal supply system in December 1982 as a result of the presence of VOCs,
most notably 1,1,1-trichloroethane (TCA) and trichloroethene (TCE), both cocmonly
used industrial degreasers. These contaminants are both considered hazardous
substances under the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA).
BES signed a Consent Order in January 1987 with EPA to conduct the Remedial
Investigation and Feasibility Study (RI/FS) at this site to define the problem
and provide alternate ways to mitigate the problem. Groundwater remediation has
become the focus of the remediation since no remaining contamination source has
been identified on the facility's property.
The Bally Site was evaluated through the Hazard Ranking System (HRS) and
subsequently placed on the National Priority List (NPL) in 1987. The NPL is a
list of hazardous waste sites targeted for action under the Superfund program.
II. SITE NAME, LOCATION, AND DESCRIPTION
The Bally Site consists of the Borough of Bally well field, located off
Route 100 in Berks County, Pennsylvania (Figure 1). The Bally well field, along
with a spring located northwest of the site, is the public water source for the
Borough of Bally. Well No. 3 in Sally's system was initially found to be contam-
inated with up to 4,000+ parts per billion (ppb) total volatile organics from an
unknown source. A number of other wells, including industrial, domestic, and
monitoring wells and another municipal well (No. 1), have since been sampled and
found to be contaminated.
According to the preliminary information developed by EPA and the PADER, a
potential source was identified on the property of Bally Engineered Structures,
Inc. (BES). The plant has been in operation approximately 1,000 feet south of
the Municipal Well No. 3 since the early 1930's. Bally Case and Cooler Company
(BCC), the original plant owners, produced urethane insulated, metal skinned
panels for use in the construction of walk-in coolers, freezers and refrigerated
buildings. BCC was bought out in 1972 by Sunbeam Corporation, and was later
renamed BES. The Remedial Investigation (RI) confirmed the property as a source
of the observed contamination.
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SITE MAP . BOROUGH OF BALLY. WASHINGTON TOWNSHIP
Borough
Bally
X7
BERKS COUNTY
THE BALLY SITg
FIGURE 1
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Structures on Bally Engineered Structure's property consist of the plant
office and adjacent parking area, unoccupied trailer storage area, and lumber
storage area. The drum storage area is a fenced and secured enclosure, presently
containing empty drums, waste oil, and spent degreasers including Saf-T-Sol No.
15 and Saf-T-Sol No. 12. Additional facilities include a groundwater monitoring
well located adjacent to the production complex which is also heavily contaminated
with 1,1,1-trichloroethane (TCA) and trichloroethylene (TCE). Solvents containing
the contaminants found in Municipal Well No. 3 and in Bally Engineered Structures'
well were presumably used by BCC in the past. Waste disposal allegedly occurred
on site until the mid-1960s. Three lagoons onsite were reportedly used in the
past for waste disposal until they were backfilled and used for vehicular parking.
The lagoon areas are at present covered by the plant buildings.
BES currently uses solvents containing unspecified hydrocarbons and methylene
chloride in its manufacturing processes. Other solvents used within the past
two years have contained TCA, methanol, toluene, and TCE.
From December 1982 until March 1987, the Borough did not use Municipal
Well no. 3 for water supply, but periodically pumped the well, discharging to a
nearby pond, in an effort to contain the contaminant plume. The well has been
completely shut down since March 12, 1987, and an air stripper is currently
being pilot tested for use on the well to remediate the groundwater contamination.
III. SITE HISTORY
Based on the initial indication in 1982 that samples from Municipal Well
No. 3 contained elevated levels of TOCs, use of this well for public water supply
was stopped. This action forced Bally to revert to the use of Municipal Well
No. 1 and a series of springs to the northwest of the Borough as its municipal
water supply. This scheme had been operative from 1959 through 1979, prior to
bringing Municipal Well No. 3 on line. In addition to the municipal wells,
there are two active industrial wells and several residential wells, within the
+quifer downgradient of the BES plant.
Additional studies of the aquifer contamination problem were performed in
1983 by the PADER and the EPA. Although unaware of any sources of the TOC conta-
mination resulting from its activities, BES met with PADER in 1984 and retained
Environmental Resources Management (ERM) in 1985 to perform aquifer characteriza-
tion studies to determine the source of contamination of Municipal Well No. 3.
The results of the ERM study, published in October 1986, indicated that the BES
plant was a likely source of the VX contamination noted in the aquifer in the
plant vicinity.
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Manufacturing activities at the BBS plant began in the 1930s with the
production of high-quality cabinets and cedar chests by the Bally Case and Cooler
Company (BCC). Production facilities were briefly commissioned in the 1940s by
the government to assist in the war effort. In the 1950s the main product line
became continuous line, porcelaincoated meat display cases and porcelain panels
for use in constructing building facades. In 1972 BCC was acquired by Sunbeam
Corporation (Sunbeam), and became a subsidiary of Allegheny International, Inc.
(AI) in 1982 with AI's acquisition of Sunbeam. In 1984 BCC was renamed Bally
Engineered Structures, Inc., in response to an increased emphasis on the manufac-
ture of insulated panels and product diversification. On June 23, 1987, the
business was sold to Bally Acquisition Corporation, while Dagan, Inc., a subsidi-
ary of AI, has retained the property.
Use of degreasing solvents at the plant occurred in two principal areas.
A 2,000-gallon capacity degreasing tank was formerly located in what is now
the BES carpentry shop. This tank was used from the late 1950s until approximately
1969 to degrease the shells of the meat display cases prior to the application
of a urethane insulating material. The cases were dipped in the tank and staged
in the vicinity of the tank to dry prior to applying the insulation. TCE was
the only solvent used in this tank.
The second area is a 600-gallon degreasing tank for cleaning small parts
used to fabricate an interlocking mechanism for the insulated panels. . This tank
has been in continuous use since the early 1960s. TCA was used in the degreasing
tank.
In addition, solvents have been used as flushing agents in cleaning molds
and urethane foam injection nozzles in the plant foaming department since the
mid-1960s.
The principal chlorinated VXs found in the aquifer are TCA, TCE, and 1,1-
dichloroethene (OCE). Spent degreasing solvents have been managed as a Resource
Conservation and Recovery Act (RCRA) hazardous waste at BES since hazardous
waste regulation began in 1980. Flushing agents used in the foaming department
are recycled by a reprocessor and reused by BES. The major use of TCE was curtailed
in about 1969 with the cessation of production of the meat display cases. TCA
(Eaken Saf-T-Sol ) was used in the small parts degreasing tank from 1980 until
1986, when it was replaced by a nonchlorinated solvent currently in use (Eaken
Saf-T-Sol 31). None of the principal chlorinated VXs found in the aquifer have
been used as flushing agents in the foaming department since 1986. The history
of solvent use at the plant and the character of chlorinated VDCs present in the
aquifer suggested at the outset of the RI that the aquifer contamination may
have arisen as a result of an historical release.
Based on a review of archival aerial photographs, the EPA had also
suggested four former lagoons active in the 1950s and currently lying underneath
plant production and office areas as potential sources of the aquifer
contamination. Both the lagoons and the areas of degreasing solvent use in the
plant were examined in the RI in an effort to define whether source areas persist
at the BES facility.
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In response to comments received from the EPA after submittal of the RI
Report, Remcor the contractor for the responsibile party performed an additional
source investigation within a parking area immediately adjacent to the northern
perimeter of the BES plant. This investigation was conducted to determine whether
an active source of \£)C release to the aquifer was present within the unsaturated
zone soils in this area. The investigation consisted of soil borings and collection
of both soil and ground water samples for \£C analysis. This area was investigated
because it lies hydraulically downgradient of the former lagoons and current and
former degreasing areas, and hydraulically upgradient of contaminated shallow
wells MW 86-4 and MW 86-3S. The results of the analyses indicate that no active
subsurface source exists north of the BES plant.
IV. ENFORCEMENT HISTORY
BES signed a Consent Order in January 1987 with EPA to conduct the Remedial
Investigation and Feasibility Study (RI/FS) at this site to define the problem
and provide alternate ways to mitigate the problem. Special notice letters were
sent to the Site's Potential Responsible Parties (PRPs) on May 30, 1989, extending
to them the opportunity to implement the Remedidal Design and Remedial Action.
EPA is waiting for their response.
V. SITE CHARACTERISTICS
A. Regional Geologic/Hydrogeologic Setting
The BES site lies within the Triassic Lowlands Physiographic Province,
a former plateau-like region that has been modified by renewed erosion into
gently rolling hills with less than 200 feet of overall relief. Triassic
sediments, principally limestone fanglomerate with minor amounts of siltstone
and shale, underlie the site area. These sediments extend to depths of thousands
of feet. According to the geologic literature, the Reading Hills Physiographic
Province lies immediately northwest of the Borough, with its eastern extent
delineated by a major fault system, identified as the Triassic Border Fault.
The Reading Hills Province consists of Cambrian and Precambrian Age basement
rocks.
SITE GEOLOGIC INVESTIGATION
The uppermost geologic units defined within the site area consist of
plant fill and colluvial materials (see Figure 2). The colluvial materials
were found in all but the eastermost portions of the site area. These materials
are clayey silts with a little gravel and are derived from weathering of the
Precambriam and Cambrian rocks on the hillside to the west of the Borough. The
greatest thickness of these materials was found to the northwest and along drainage
courses.
A layer of residuum, weathered from the Triassic sediments, underlies
the colluvial materials and overlies bedrock throughout the site area. The
residuum is principally of silty clay to clayey silt composition with occasional
fragments of limestone. The material grades into bedrock and, as such, retains
much of the relict structure (e.g., joining, bedding) of the parent material.
The thickness of the residuum was found to be highly variable, raging from 10 to
80 feet.
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fACING NORTH EAST
soo
150
«no
too
.so
.DO
ISO
REDDISH BROWN *~
SI.I STONE AND SHALE
REDDISH BROWN n
SUSIONE AND SHALE
1OPOFPU*»> m
TO 3ocr
APPROX
CLAY. 9L! RESOUUM AND WEATHERED
SHALE FRAGMENTS
TD20S-
LEGEND
WAtEH LEVEL
MEASUREOIO/B/MJt
- 5 5/r OPEN BOREHOLE
TOTAL ESTIMATED YCLD
(gpm) FROM ffOCATED
DEPTH TO SURFACE. 10
RESET TO 0 gpm AT u
BASE OF CAStM TO 120 - TOTAL DEPTH
-V GROUTED CASMG
ESTMATED
TOP OF ROCK
TO I2O-
UMESTONE FANOLOMEHATE WITH
RED SUSTONE MATRIX. NTERBEDDEO
RED-BROWN SHALES
TD2tV
NOTE:
TOPOGRAPHY BASED ON
SURVEYED TRM/ERSE. 2/68
SEE FIGURE J FOR LOCATON
TO 177.51
SCALE:
HORUONTAL: f - 20O
VERTCAL: f - 5ff
VERTICAL EXAGGERATION 1:4
FIGURE
450
400
350-1
300 H
250-4
200 J
GEOLOGIC
CROSS SECTION A-A'
ALLEOOIY NTEflNATIONAL. NC.
PITTSBURGH PENNSYLVANIA
^
«y£
ONAWINa NUHKR
88548 B4
REMCOR
Figure 2
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8
Bedrock encountered during the subsurface investigation was found to
be exclusively of the Brunswick Formation. In the site area the bedrock was
composed of limestone fanglomerate with interbedded siltstone and shale. It is
significant to note that this finding differs from the published geologic
literature which indicates that the.western portion of the site should be
underlain by quartzite rock characteristics of the Reading Hills Province. This
finding is significant from a hydrogeologic perspective, in that the Triassic
Border Fault separating the two units must be presumed to occur immediately west
of Municipal Well No. 3. The frequency of discernible fractures in the
fanglomerate was found to decrease with depth. In an exploratory corehole (E-l)
in the .vicinity of Municipal Well No. 3, an extensive fractured zone was found
to occur to a depth of 140 feet, with more competent bedrock and more isolated
fracture zones occurring below this depth.
SITE HYEROGEOLDGY
From the hydrogeologic perspective, the site is characterized by a single,
thick, unconfined (or locally semi-confined) aquifer that occurs within the
limestone fanglomerate and overlying residuum. Transmission of ground water is
principally controlled by secondary porosity cause by fractures, joints, and
solutioning activity. The aquifer is presumed to extend vertically for several
hundred feet with fractures decreasing with depth to a point at which open
fractures no longer occur. The RI did not determine the effective depth
of the aquifer/extent of open fractures. In the vicinity of Municipal Well No.
3 the bedrock is severely fractured, possibly due to the proximity of this area
to the Triassic Border Fault. Well yields in this are were found to be several
hundred gallons per minute (gpm).
Groundwater flow direction was determined in the RI to be principally
eastward (Figures 3 and 4). Groundwater discharge to surface water may occur
east of Route 100, but it was apparent from the subsurface investigation that
this does not occur in the immediate site area. Surface water sampling results
also do not suggest a connection between surface and groundwater in the site
area. The horizontal hydraulic gradient under normal conditions ranged from
0.0025 to 0.02. A low hydraulic gradient occurs in the vicinity of Municipal
Well No. 3 and Chestnut Street due to extensive fracturing and weathering of the
aquifer in this area.
Influence of water levels from the daily pumping of Municipal Well No. 1
was found during baseline monitoring to extend to a point approximately halfway
between the well and the BES plant (i.e., a distances of about 1,200 feet).
Industrial withdrawal from the aquifer at Bally Ribbon Mill and the Great
American Knitting Mill are approximately 20 percent of that from the municipal
well and do not appreciably alter groundwater flow direction.
A 72-hours pumping test was performed at Municipal Well No. 3 to evaluate
the response of the aquifer to pumping at this point. Based on historic data,
it is possible to conclude that groundwater extraction and treatment at this
location may serve to mitigate further spread of contamination within the aquifer
and capture such contamination to a significant degree.
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rsnt
(ESTMATED LOCATION)
KWOUCH UNE
EMM ft REMCOR MONrTOMMC WELLS
S - SHALLOW
I - MTEMMEOMTE
0 - OOP
EXPLORATION CONE HOLE
STREAM
DM "Hi MOMEMOLAIUNC DOES NOT OOWCUTT
EXACTLY Mm TH»T or me KMCON NCUS.
M-l. M-2. M-JS. B« 4. vc
M-9S ME 9HWX0* ELLS UMXM THE NEMO*
SttltU. MAC M-30 AND M-90 APPfWXMATI
OCPTH WOLS.
____ CONTOUR UNES
EUMIWNS M FTTT
UCAN SEA LEVEL
500
1000
IICAI POTFNTIOMnmC HFAD DIFrtRENIIAL AND
IPflCAt FLOW OIRLCTION A! WELL CLUSTERS:
11 -» ooi n OP
< * «/ 41 071 IT DOWN :
4 Bi 50 Oft II IIOMM
-. * ; M 020 n UP
'< * ;-ioo oo« n UP
n * «/-MI oi* n UP
REFERENCE.
BASE MAP FROM TOPOGRAPHICAL SURVEY.
BOROUGH OF BAUr (1975)
MONITORING WELL AND MUNICIPAL WELL LOCATIONS
FROM SURVEY BY S.M. NORKEVICH 2/J/88
RGURE
POTENTIOMETRIC SURFACE FOR
SHALLOW WELLS
9:10 A.M. OCTOBER 4. 1988
PUMPING TEST TIME 0 HOURS
PMEPANED ro«
ALLEGHENY INTER^MT1ONAL. INC
PITTSBURGH. PENNSYLVANIA
NUUKR
88548-814
REMCOR
Figure 3
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IICAI PorrNiiOMrrmc HEAD DIFFERENTIAL AND
'"IICAL FIOW DIRECTION M WELL CLUSTERS:
; » *-» ooi n up
A n/ 41 0'I H DOWN
. * so OM n DOWN
< * «»-»i oio n ur>
> * '-100 OM n UP
'', * «7 in o } n UP
met A
7-101 O
LEGEND:
ofF-siE WELL LOCATION
(E3TMATED UDCATWN)
HMOUOH UNE
EMM NCMOM MONrramw wrus
% - 9HM10W
I - MltftMCNATC
D - OOF
CMC HOU
EMI «O1 NOMENCtATUV DOCS NOT OOmELATC
EXACar WTH DMT OF THE WHOM *CU5.
EMM KU* W-t. W-2. « JS. M-4. AND
M-SS ANC SM»OOW OTLLS UNOER THE MEMCON
snnM. WHLE M Jt> AM> M-W APPMOXMATC
MTEMMEMATC OCFTH WEU5.
CONTOUR LMC
EUVMUNS M FEET MOVE MEAN SEA LEVEL
500
300
1000
REFERENCE:
BASE MAP FROM TOF>OGRAPHICAL SURVEY.
BOROUGH OF BALLY (1975).
MONITORING WELL AND MUNICIPAL WELL LOCATIONS
FROM SURVEY BY S.M. NORKEVtCH 2/3/88
FIGURE
TOTENTIOMETRIC SURFACE FOR
INTERMEDIATE * DEEP MONITORING WELLS
9:10 AM OCTOBER 4. 1988
PUMPING TEST TIME 0 HOURS
ALLEGHENY INTERNATIONAL. INC
PITTSBURGH. PENNSYLVANIA
ICjjL io/ir/» I
^K * <-~7^\
DHMMO NUMMK
88548-B8
Figure 4
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The conduct and interpretation of the pumping test are discussed in Section
3.3 of the RI Report. The maximum cone of depression developed during the pumping
test was elongated in the north/south direction, reflecting the anisotropic
nature of the aquifer. After 72 hours of pumping, the capture zone of Municipal
Well No. 3 had reached the BES plant area, but did not extend significantly
beyond State Route 100 to the east. Sluggish response to pumping in a few of
the shallow monitoring wells indicated the presence of localized semi-confining
conditions.
Estimates of transmissivity (T) and storativity (S) were generated from
the pumping test and were found to range from 80,000 to 5,000 gallons per day
per foot (gpd/ft) for T and between 10"1 to 10~3 for S. Interpretation of the
data was complicated by aquifer anisotropy, partial penetration effects, and
unavoidable pumping of Municipal Well No. 1 during the test. These factors, to
an extent, limit the reliability of quantitative analysis from the test. The
values generated, however, can still be used for future approximation of capture
zones for different pumping schemes utilizing Municipal Well No. 3.
B. EXTENT OF CONTftMINftTION
Source Delineation Investigation
In an initial effort to evaluate suspected sources of the aquifer
contamination, borings were installed and subsurface soil samples were collected
from four specific areas (Figure 5):
- Former degreasing area
- Present small-parts degreasing area
- Former northern lagoon area
- Former southern lagoon area
Subsequently, the northern perimeter of the plant was investigated via a series
of borings.
An HNu photoionization (PID) was used to screen soil samples in the
field as a basis for selection of samples to be submitted for Target Compound
List (TCL) VDC analysis. Field screening readings are summarized in Table 2 of
the RI Report. Readings above background (zero parts per million) were found
only from soils taken from the former northern lagoon area and from selected
borings immediately north of the BES plant. Ten samples were submitted for
laboratory analysis from the former degreasing area, two from the present
degreasing area, five from each of the former lagoon areas, and 25 from the
northern perimeter area. TCL TOCs were detected in samples from the former
degreasing area, where very low levels of TCE, TCA (i.e., less than 10 micro-
grams per kilogram [ug/kg]), and toluene (13 to 43 ug/kg? ugAg=ppb) were found,
and from one boring on the northern perimeter where TCA, TCE, and DCE were
detected near the water table. Analytical data are summarized in RI Table 7.
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EXISTING MONfTORINC
WELL LOCATION
TEST BORING LOCATION
FORMER LAGOON OUTLINE
TEMPORARY PIEZOMETER
LOCATION
NORTHERN
LAGOON
FORMER
DECREASING
SMALL
PARTS
DECREASING
SOUTHERN
LAGOON
POTENTIAL SOURCE AREAS
AND
TEST BORING LOCATIONS
INTERNATIONAL. INC
PITTSBURGH. PENNSYLVANIA
NUUBCR
88548-B30
REMCOf?
Figure 5
-------
10
The results of the source delineation investigation do not indicate
conclusively that any of the suspected source areas are a principal source of
the current extent of \£>C ground water contamination. Nonetheless, the
configuration of the contaminant plume supports the conclusion drawn from
previous studies that the BES facility, is a source of the contamination. The
fact that specific source areas have not been found in the most likely areas
suggests that the contamination may have arisen as a result of historic solvent
management practices that permitted releases to the aquifer. These activities
would most likely have occurred over a substantial period from the late 1950s
until the early 1970s. These data suggest that there is no longer any active
release'of VDCs to the aquifer.
Nature and Extent of Groundwater Contamination
The presence of VDCs in ground water was determined by sampling 18
monitoring wells, 4 industrial wells, and 11 residential wells, in addition to
the 2 municipal wells and analyzing the samples for TCL VDCs. VXs were found
in 19 of the 35 wells sampled. The municipal well samples were also analyzed
for TCL organics, with none detected.
The RI chemical-analytical data (RI Tables 8 and 9) show that a ground-
water plume of WC contamination extends from the BES plant to the east and
northeast (Figures 6-8). The plume consists predominantly of TCA, TCE, and
DCE. It is apparent that the full-scale pumping of Municipal Well NO. 3 from
1979 to 1982 has had the effect of drawing the TOCs deeper into the aquifer and
to the north toward the well. Following cessation of pumping, the contaminant
movement has become more controlled by the natural ground water flow direction
to the east. Groundwater and contaminant migration has also been influenced by
the pumping of Municipal Well No. 1.
Surface Water Investigation
Site Hydrologic Evaluation
The BES plant area and its immediate vicinity north of Barto Road are
situated in a drainage basin of approximately 320 acres. Surface drainage is
captured in two principal drainageways, both unnamed tributaries to the West
Branch Perkicnen Creek. The more easterly of these receives approximately 80
percent of the drainage from the watershed and is a perennial stream. This
stream originates in springs at the head of the drainage and flows past
Municipal Well No. 3 and into an abandoned mill pond prior to discharging to the
Bally storm sewer system and, ultimately, to the West Branch Perkiomen Creek.
The second drainage is a minor feature, arising in a crop field northwest of the
BES plant and primarily serving as an outlet for a tile drainage system in the
fields.
-------
as*
NMZ A
LfOtNO;
WF-SIE WELL LOCATION
(ESTMATED LOCATION)
MMXMH UNE
"-IOI O ERM
C-l
* MEMOOR UONTTOWNC MIEUS
S - 9HUUMT
I - MOMEOATE
0 - "
REFERENCE:
BASE MAP FROM TOPOGRAPHICAL SURVEY.
BOROUGH OF BALLY (1975).
MONITORING WELL AND MUNICIPAL WELL LOCATIONS
FROM SURVEY BY S.M. NORKEVICH 2/3/88
ISOCONCENTRATION OF TOTAL
ORCAN'CS
DEPTH WELLS
SAMPLED 1/88
CHM WU. NOHOCLATUIK OOCS NOT OMMOATC
EXMHir Mm TWT OF 1HC MMOOM HBLL5.
OW MUJ M-1. W-2. »-«. M-4. AND
M-9S AK 3WU4OT M11S UMXK THE IKMCOK
SmCU. «HU W-JO AND W-9O APPHOXMATt
MIBMEDW1E OEFIN MUS.
OOOONCOnHKnOM CONTOURS
(DASHED NNCME MTDCD
MTA M mm PCM MLLRM
Figure 6
-------
I
ma. A
7-101 O
OFF-STE WEU. LOCATION
(ESTBMftD LOCATION)
BOROUGH UNE
EM * REMCOR MONiraMNQ NOUS
S - SHALLOW
I - MTENMEDIME
o - oar
EXPLORATION cone HOLE
STREAM
DM WOL NOMENCLATURE DOES NOT CORRELATE
EXACTLY WIN THAT OF THE MEMO* WELLS
CRM MELU M-l. M-2. M-H M-4. AMD
M-9S ANE 3NHUO* wfUS UNDER THE MCMCOM
SrSTEM. «M>£ M-30 AMD M-9O APPROXIMATE
NTERMEDWTE OEP1N NE115.
OOCQNCENTRATION CONTOURS
(DASKD WCME IVEMCD)
DATA M PAITTS PER HLUON
500_ _^ 0_ SOO
rate: 1* - 900- (APPROX.)
1000
REFERENCE.
BASE MAP FROM TOPOGRAPHICAL SURVEY.
BOROUGH OF BALLY (1975).
MONITORING WELL AND MUNICIPAL WELL LOCATIONS
FROM SURVEY BY S.M. NORKEVICH 2/3/88
FIGURE
7
ISOCONCENTRATION OF TOTAL
CHLORINATED VOLATILE ORGANICS
IN INTERMEDIATE DEPTH WELLS
SAMPLED 1/88
PREPARED FtM
ALLEGHENY INTERNATIONAL. INC.
PITTSBURGH. PENNSYLVANIA
U«« I DRAMNC NUMBER
88548-B16
Figure 7
-------
IMOtt
^^^^K-
OFT-STC wu. LOCATION
(FSTMATtD LOCATION)
BOROUGH LME
EMI * REMOOR MOMTOWNC WELLS
S - SWUM
I - MltRMEOMTE
0 - OOf
CXPUMATON COHC HOU
MMM
. NOHOCLATUNE 00t5 NOT OOHNELATC
EXACIlr WTTH TWT Or THE MOKOH WTLLS
DM KU5 M-l. M-2. 86-3S. B*-4. AMD
MMZ A
7-101 O
C-l
MTERMEDMTE DEPTH WELLS.
OOCONCENTRATION CONTOURS
(DASHED WHERE mMCO)
DATA M PARTS PER BUJON
1000
REFERENCE:
BASE MAP FROM TOPOCRAPHtCAL SURVEY.
BOROUGH OF BALLY (1975).
MONITORING WELL AND MUNICIPAL WELL LOCATIONS
FROM SURVEY BY S.M. NORKEVICH 2/3/88
FIGURE
ISOCONCENTRATION OF TOTAL
CHLORINATED VOLATILE ORGANICS
IN DEEP WELLS
SAMPLED 1/88
PREPARED ran
ALLEGHENY INTERNATIONAL. INC.
PITTSBURGH. PENNSYLVANIA
g"L- 1 n-t-m t» l
?T?^ I*** i»/*/»* I
ORAWWG NUMBER
88548-B17
REMCOR
Figure 8
-------
- 11 -
The abandoned mill pond has been inactive for some time; the breast of
the impoundment was breached by the current owner within the past five years to
reduce liability associated with the impoundment. As a component of the RI a
preliminary wetlands assessment was conducted. A Palustrine wetlands has
developed in this area and is readily defined by the perimeter of the former
impoundment. Riparian weltland areas along the perennial stream form an
extension of the Palustrine wetland to the northwest. On the basis of this
preliminary assessment, it appears that these wetlands ares do not represent
critical habitat elements in the local area, nor are they likely to in the future
because of the extensive residential and commercial development in their immediate
vicinity. In addition, the U.S. Fish & Wildlife Service (USF&WS) has determined
that the site area is not of significant concern relative to the occurrence of
special status species.
Extent of VDC Contamination in Surface Water and Sediments
Samples of surface water and sediment were collected initially at
three locations during the RI, one within the perennial stream and two within
the Palustrine wetland. Later, in response to EPA comments, two surface water
and sediment samples were collected from the perennial stream to the east of
Route 100 (Figure 9). Analytical results are summarized in RI Table 10. The
initial samples revealed only the presence of acetone and methylene chloride at
levels consistent with laboratory-induced contamination. The most easterly of
the later samples revealed low levels of TOCs consistent with the suggestion
that ground water discharges to the stream in this area.
The hydrogeologic investigation determined that the wetland area north
of the BES plant could not be receiving discharge from the contaminated aquifer.
This fact is confirmed by the chemical-analytical results. It is possible,
however, that groundwater could be discharging to the perennial stream east of
Route 100 where the TOCs were detected.
SUMMARY OF SITE RISKS
An assessment of public health and environmental concerns was performed in
accordance with guidelines established by the EPA for performance of such
evaluations at Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) sites.
The following TOCs were selected as indicator compounds in the
characterization of risk because of their presence in groundwater and their
potential chronic health effects (i.e., primarily their suspected carcinogenicity)
at low levels:
- Trichloroethene (TOE)
- Tetrochloroethane (TCA)
- Tetrachloroethene (PCE)
- Dichloroethane (DCE)
- 1,1,-Dichloroethane (DCA)
- Methylene chloride
-------
N
HOPING WELL
SURFACE WATER AND
SEDIMENT SAMPL£ LOCATION
/' wvniwrwi
\ WELL f 3
* RBB-SW-SWt-001/00tA
^RBB-SD-SD1-OOI/001A
RBB-SW-SW2-002
SO-S02-00
SURFACE WATER AND
SEDIMENT
SAMPLE LOCATIONS
PKPMICD ran
ALLEGHENY INTERNATIONAL. INC.
PfTTSBURCH. PENNSYLVANIA
^^^^^^^^^^?^^^^^^^^"^^^1^^^^
OIWMNO NUMCR
88548-B25
Figure 9
-------
- 12 -
The assessment considered noncarcinogenic and carcinogenic health effects
and environmental toxicity for these compounds in defining risk to public health
and the environment.
The only known current human exposure takes place through potable use of
the contaminated municipal supply well (Municipal Well No. 1). The municipal
system currently services approximately 1,200 residents of Bally. Remcor
considered both ingestion and showering exposure pathways in defining cumulative
risk.
In assessing risks associated with use of the municipal water supply,
Remcor did not consider the effect of dilution of water drawn from the municipal
well(s) by water from the springs. The relative contribution of each source is
known to vary with seasonal conditions; significant pumping of the municipal
well(s) is required only during the summer and fall months to supplement the
springs. Existing data are not adequate, however, to permit a precise estimate
of the contribution of each source to actual consumption. A cumulative
carcinogenic risk estimated for use of the current municipal spring water, is
1.0 X 10 . In reality, this risk is significantly reduced by dilution of
uncontaminated spring water occurring within the Municipal system. The amount
of dilution is directly related to spring flow and, as such, will vary seasonaly.
The risk of noncarcinogenic health effects is deemed acceptable for the current
municipal ground water supply system in accordance with EPA guidance on risk
assessment.
Future plans for the municipal water supply system are to reduce reliance
on Municipal Well No. 1 and to use Municipal Well No. 3 as the primary supply
well. Well No. 3 has been equipped with an air-stripping treatment unit. TOC
concentrations to be achieved in the treated well water are those set forth in
water supply and National Pollutant Discharge Elimination System (NPDES) permits
issued by the PADER for this treatment system. The worse-case cumulative
carcinogenic risks estimated for use of treated water from Municipal Well No. 3,
again considering a worse-case scenario (no dilution of the well water with spring
water), is 3.3. x 10 . Estimated noncarcinogenic risks were again found
within acceptable limits.
Contaminated ground water is not discharging to surface water in the
immediate site vicinity. There is evidence, however, that groundwater discharge
to surface water does occur east of Route 100. Surface water VX concentrations
found in one sample from this area were found to be below applicable criteria
for the protection of aquatic biota. When using those concentrations to develop
an estimated dose for dermal contact and accidental ingestion, the carcinogenic
risk is estimated at 2.5 X 10~ , well below the lower limit of the risk range
considered acceptable for CERCLA sites by EPA policy (i.e, 10~4 to 10"').
-------
13
VI. Community Relations History
The main community concerns for the affected residents and businesses
revolve around the issues of:
1. Groundwater contamination on and off-site
2. Quality of alternate water supplies
3. Desire of affected residents to remain on private
wells
The Borough of Bally routinely sends Municipal Well No. 1 analytical
results to EPA. EPA has met on an individual basis with members of the community
and with local officials.
REMEDIAL ACTION OBJECTIVES
Contaminated Media and Exposure Pathways
The medium that requires remediation at the BES Site is groundwater. The
exposure pathway that is most critical is potable use through the municipal
supply system. Under the current water supply configuration in Bally/
residents are exposed to TOCs in groundwater extracted at Municipal Well No. 1.
This well is used, in conjunction with uncontaminated spring water, for potable
water supply within the Borough. The groundwater exposure routes that incur the
predominant risks are ingestion and inhalation during showering. Worst-case
cumulative carcinogenic risks have been calculated for these exposure routes for
both the current water supply system and for the proposed future water supply
system (Table 1). Daring the past two years, BES and the Borough of Bally have
taken action to provide treatment of groundwater from Municipal Well No. 3 as a
supplement to the springs. This approach reduces reliance on water from Municipal
Well No. 1 as the primary source of supply.
The worst-case for both current and future water supply systems considers
no use of (or dilution by) uncontaminated spring water. Although this is not
the actual case under either system, the configuration of the supply piping
makes it difficult to determine the actual contribution of either source to the
water arriving at the tap. A single line carries pumped water to the reservoir
and distributes water from the reservoir to the supply system. The estimated
worst-case carcinogenic risk with use of the current water supply system is 1.0
x 10 . Under the proposed future system (use of treated water from Municipal
Well No. 3), the worst-case risk is 3.3 x 10~5. The risk of noncarcinogenic
health effects was estimated to be acceptable for both current and proposed
water supply systems.
Potable use of groundwater from residential wells within the Borough is not
currently taking place. Risks were estimated for the hypothetical future use of
wells installed within the most contaminated portion of the aquifer. The
estimated carcinogenic risk is 1.8 10 ; the noncarcinogenic risk was
estimated to be unacceptable.
-------
TABLE 1
ESTIMATED WORST-CASE RISKS
FOR THE BES SITE
PATHWAY
CARCINOGENIC RISK NON-CARCINOGENIC
CURRENT RISKS:
Potable use of current
municipal water supply
1.0 x 10'
Acceptable^
Dermal contact/accidental
ingestion of surface water
2.5 x 10'
Acceptable
Use of ground water as Risks significantly less than those
process water supply for considered acceptable for workplace
local industries exposure
FUTURE RISKS:
Potable use of future .
Municipal Water Supply1
3.3 x to'5
Acceptable
Potable use of contami-
nant residential well
1.8 x 10'2
Unacceptable
Notes:
(1)
Assumes prioarly reliance on treated water from Municipal Well No. 3.
(2; Acceptability of non-carcinogenic risk based on calculated Hazard
Index (HI) less than unity, as documented in text.
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14
CERCLA requires that remedial actions comply with Applicable or Relevant
and Appropriate Requirements (ARARs) and are adequately protective of public
health and the environment. Remediation levels for the BES Site will reflect
the need to provide a suitable municipal water supply to mitigate current risk,
as well as to effect aquifer restoration. Table 2 summarizes remediation levels
by medium based on ARARs. The current air stripping treatment system at Municipal
Well No. 3 has received permit authorization to operate from the PADER. Limits
established in the NPDES permit for discharge of treated ground water to the
adjacent stream, as well as limits established in the Water Quality Permit for
use of the treated water as a public water supply, provide the primary ARARs for
these actions. The permit levels are noted in Table 2.
Remedial action objectives defined for the BES Site are as follows:
- Prevent current and future ingestion of groundwater
containing unacceptable levels of VOCs
- Restore the aquifer within a reasonable time frame to a
condition such that levels of the VOC contaminants of
concern are below remediation levels consistent with its
use as a Class II aquifer.
Prevention of Ingestion of Contaminated Groundwater
Groundwater Remedial Actions (GRAs) that will address the first response
objective include provision of an alternative municipal water supply and
institutional control of future use of groundwater within the attainment area
until such time as the aquifer has been adequately restored.
Remcor was retained by AI in 1987 to evaluate options for provision of an
alternative water supply for the Borough of Bally, concurrent with performance
of the RI/FS. An air stripping treatment system has been designed, permitted,
and installed at Municipal Well No. 3 to address this concern. The rationale
for Remcor's recommendation to proceed with treatment at Municipal Well No. 3
via air stripping is documented in Appendix A. The design and the operational
testing of the air stripping system is also discussed.
As stated in "Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites" (EPA, March 1988), "Institutional controls implemented at the
State or Local level that restrict ground water use should be implemented as
part of the response action at all sites where exposure poses a threat to human
health." There are no current risks via use of domestic wells at the BES Site.
However, institutional controls should be implemented within the attainment area
to prevent future use of any existing residential wells for drinking water and
also to prevent the installation of additional wells for this purpose until the
aquifer has been adequately restored. Additional investigation will be required
in the pre-design phase of remedial action to better define the limits of the
attainment area. Treatment of Municipal Well No. 3 will ensure the availability
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- 15 -
of a reliable source of drinking water for those served by the municipal system,
which includes all residents within the attainment area as defined by the current
data, as well as areas immediately downgradient. Institutional controls on use
of domestic wells for future potable use will not inconvenience local residents
primarily due to the ready accessibility of a reliable source of potable water
from the municipal supply system.
The availability of springs as a second source of potable water to the
Borough provides a measure of redundancy for Municipal Well No. 3. Periodic
maintenance may be scheduled during periods of the year when the flow from the
springs is adequate to satisfy the system demand. Institutional controls relative
to coniservation of water would permit the springs to meet demand at other times
if nonroutine maintenance of the municipal well was required. Such nonroutine
maintenance would result in minimal downtime for the municipal well during such
times.
To supplement alternative water supply and institutional controls,
appropriate general responses to prevent ingestion of contaminated groundwater
may include the following:
Abandonment of any existing domestic wells within the
attainment area found to contain unacceptable high levels
of VDCs
Currently the data suggest that only one well may require
abandonment to eliminate any potential for its use as a
drinking water supply in the future
Ground water monitoring
- A groundwater monitoring program will be required in
conjunction with remedial action to monitor attainment
of remedial action objectives. Because the attainment
area is not fully defined, additional site investigation
will be required in the pre-design phase of remedial
action to provide this definition. Groundwater monitoring
would be modified as required to reflect the
results of this investigation.
Ccnmunity relations/public awareness program
- Periodic updates regarding the status of aquifer resto-
ration and institutional controls will be required
throughout the remedial action implementation to ensure
public understanding.
Aquifer Restoration
EPA guidance (EPA, March 1988) indicates that provision of a readily
accessible water supply with sufficient redundancy provides additional flexibility
in addressing the second major response objective (i.e., aquifer restoration).
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16
Despite a concerted effort in the RI to research history of solvent use and
management at the BES plant and to evaluate the potential active sources of
aquifer contamination no such source areas were found. The data indicate that
aquifer contamination may have resulted from routine spillage of solvents used
at the BES facility in the 1950s, 1960s, and early 1970s and that no definable
source area exists. As such, no source removal or control actions are suggested
that would aid in reducing the extent of aquifer restoration response actions.
GRAs identified to address the need for aquifer restoration involve
collection and treatment of the MX plume.
VIII. Description of ARARS
An ARAR, as defined, is an environmental law, regulation, or guideline
that is either "applicable" or "relevant and appropriate" to a remedial action.
"Applicable" requirements are those cleanup standards, standards of control, and
other environmental protection requirements, criteria, or limitations,
promulgated under Federal or State laws that specifically address
chemicals/contaminants of concerns, remedial actions, locations of remediation,
or other circumstances at a CERCLA-regulated site. "Relevant and appropriate"
requirements are those which address problems or situations sufficiently similar
to those encountered at a CERCIA-regulated site that their use is well suited to
the particular site (Section 121 of CERCLA, 42 U.S.C. Section 9621 and 40 C.F.R.
Section 300.68(i)).
ARARs can be divided into the following categories;
- Chemical/contaminant-specific requirements - Health or risk-based
concentration limits or ranges in various environmental media for
specific hazardous substances, pollutants, or chemicals/contaminants.
These limits may take the form of cleanup levels, discharge levels
and or maximum intake levels (such as for drinking water and breathing
air for humans).
- Action-specific requirements - Controls or restrictions on particular
types of remedial activities in related areas such as hazardous waste
management or wastewater treatment.
- Location-specific requirements - Restrictions on remedial activities
that are based on the characteristics of a site or its immediate
environment. An example would be restrictions on wetlands development.
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17
In accordance with the EPA Ground Water Protection Strategy, the aquifer
which currently supplies potable water to the Borough of Bally is categorized as
Class II. The presence of VDCs has affected the suitability of the aquifer for
use as a domestic and municipal water supply. The Ground Water Protection
Strategy will be considered relevant and appropriate guidance in development of
remedial action objectives at this site. Consistent with the established EPA
policy of returning contaminated ground water to the "highest beneficial use,"
chemical-specific ARARs established to protect drinking water supplies will be
considered in establishment of remediation levels for the aquifer, as well as
for any alternative water supply for the Borough.
Similarly, the PADER permitting authorities exercised in the National
Pollutant Discharge Elimination System (NPDES) Discharge Permit, Water Supply
Permit, and Air Operating Permit are action-specific ARARs that define acceptable
standards for ground water treatment systems considered in defining and selecting
remedial action technologies in the re.
No location-specific ARARs have been identified for the proposed remedial
response at the BES Site. Proposed activities will not directly or indirectly
result in any adverse affects on any areas.
2.1.2.1 Chemical-Specific ARARs
The applicable chemical-specific ARARs at the Site are established by
Maximum Contaminant Levels (MCLs) and Water Supply Permit requirements estab-
lished by the PADER for those contaminants of concern identified in the RI
endangerment assessment. MCLs are applicable, enforceable standards set for
public water supply system that are promulgated under Section 1411-12 of the
Public Health Service Act as amended by the Safe Drinking Water Act, 42 U.S.C.
Sections 300(g)-(g)l (SDWA). MCLs that are proposed (PMCLs), but not yet prom-
ulgated, are to be considered when final MCLs are not available. With the
exception of methylene chloride, MCLs and PMCLs are available for all contami-
nants of concern at this site.
In the absence of MCLs, and PMCLs, the next ARARs to be considered are
Health Advisories (HAs). HAs are nonenforceable contaminant limits published by
the Office of Drinking Water. They are published for 1-day, 10-day, longer term
(approximately 7 years), and lifetime exposures to chemicals. HAs are published
for noncarcinogenic end points of toxicity only. Lifetime HAs are not recommended
for Class A and Class B carcinogen because carcinogenic effects are expected to
result in more stringent health standards. For Class C chemicals, an additional
uncertainty factor of 10 is used to reflect possible carcinogenic effects.
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18
Risk-Specific Doses (RSDs) for carcinogens may also be considered in
establishing chemical-specific ARARs. RSDs are derived from cancer potency
factors (CPFs), developed by the EPA Carcinogen Assessment Group (CAG) in a
series of health assessment documents and by the EPA Environmental Criteria and
Assessment Office in a series of health effects assessments. The CPF is the
slope of the dose-response curve. The RSD represents an acceptable dose in
milligrams per kilogram of body weight per day (rag/kg body weight/day). To
calculate the concentration of a carcinogen in groundwater in milligrams per
liter (mg/1) associated with a given cancer risk level, the following equation
is used*
Concentration = RSD (mgAg/day) x body weight x cancer risk level
drinking water ingestion rate (liters per day [I/day])
Body weight is assumed to be 70 kg (approximately 155 Ibs.), and the
drinking water ingestion rate is assumed to be 2 liters/day.
In accordance with established EPA policy for carcinogen, acceptable
remediation levels generally lie within the 10~4 to 10~7 risk range, with the
10~6 risk used, as a starting point in establishing the preferred cleanup levels.
These ARARs are either applicable or to be considered relevant and
appropriate relative to the attainment area for groundwater remedial action.
The attainment area is defined as the area beyond the boundary of the waste
source and within the boundary of the contaminant plume. In the absence of a
defined source area at the BBS Site, the attainment area is generally defined by
the lateral limits of the TOC plume.
Action-Specific ARARs
Action-specific ARARs relating to the proposed remedial actions at the BES
Site fall into two categories:
- Those affecting discharge of TOC-containing groundwater
to surface water
- Those affecting releases of VXs to the air.
Applicable action-specific ARARs include NPDES standards for discharge
of groundwater to surface water. These standards are developed on a
compound- and site-specific permitting basis under the Clean Water Act
(CWA).
-------
19
Action-specific ARARs also may be relevant and appropriate for releases
of ^/DCs to ambient air from treatment of contaminated groundwater at extraction
wells. Regulations to be considered relative to air emissions from groundwater
treatment units at the BES Site have been defined by the EPA as follows (Abrams,
April 6, 1989):
- Part D of the Clean Air Act (42 U.S.C. Sections 7401-7642) -
This part deals with provisions for nonattainment areas. Berks County
is classified as a nonattainment area for ozone. Part D requires that
the lowest achievable emission rate (LAER) be achieved. This means
that for any source, the emission rate reflects either the most stringent
emission limitations contained in the implementation plan of any state
for such class or category of source, unless the owner or operator of
the proposed source demonstrates that such limitations are not achievable,
or the most stringent emission limitation which is achieved in practice
by such class or category of source, whichever is more stringent;.
In response to Part D of the Clean Air Act, Pennsylvania established
special requirements in Subchapter C, Sections 127.61 to 127.64 of
Pennsylvania's Air Resource Regulations for sources located in or signi-
ficantly impacting nonattainment areas. Relative to TOCs, this applies
to any new source with maximum allowable emissions greater than 50 tons
per year, 1,000 pounds per day, or 100 pounds per hour, whichever is
more restrictive.
- National Ambient Air Quality Standard (NAAQS) for Ozone (40 C.F.R.
Part 50) The ozone NAAQS is a one-hour standard concentration of 0.12
parts per million (ppm), not to be exceeded more than once per year.
Other guidance to be considered is the Pennsylvania Air Toxic Guidelines
(ATGs). This guideline requires that the ambient ground-level concentration
predicted for any air toxic substance for an aggregate of sources at a site be
equal to or less than one percent of its corresponding ATG. These ATGs represent
compound-specific ambient concentration guidelines.
Uncertainties relative to the application of air regulations to CERCLA
response actions prohibit establishment of sites-pecific performance standards
for release to ambient air from proposed groundwater treatment units at the BES
Site. From a technical perspective, information is not available to evaluate
whether LAER is relevant or appropriate; the de minimis nature of the anticipated
source in the current instance (i.e., less than 100 pounds per hour) indicates
that LAER is not applicable. However the current air stripping treatment system
at the BES Site is operating with permit authorization from the PADER Bureau of
Air Quality. The final PADER Air Operating Permit for this treatment system
will establish acceptable performance standards for air emissions and should,
therefore, be incorporated as the primary ARAR for air emissions at this site.
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20
A. Description of Major ARARs (See Table 2 and 2A)
Federal
- MCLs
- Ambient Water Quality Criteria
- Ozone Non-Attainment Area Criteria
- VDC standards
Safe Drinking Water Act
Clean Water Act
Clean Air Act, Part D
National Ambient Air
Quality Standards
State
Pennsylvania Clean
Streams Law - Section 402
Pennsylvania Safe Drinking
Water Act
Pennsylvania Rules and
Regulations
Title 25 Chapter 93
Pennsylvania Air Resource - TOC standards for Ozone Non-Attainment
- Ambient Water Quality Standards
Regulations
Pennsylvania Air Toxic
Guidelines
Areas
- Ambient Ground-level Contamination
Standards
B. Additional Requirements for Protectiveness
The selected site remedy must consider and be consistant with the
following:
Federal Executive Order 11988,
Floodplain Management
40 C.F.R. Part 6, Appendix A
Federal Executive Order 11990
Protection of Wetlands,
40 C.F.R. Part 6, Appendix A
Federal Clean Water Act
Action to avoid adverse
effects, minimize
potential harm, restore
and preserve natural and
beneficial value.
Action to minimize
destruction, loss, or
degradation of wetlands.
Differential Ground-
water Policy Class IIA
aquifer.
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TABLE 2
REMEDIATION AND DISCHARGE LIMITS
DERIVED FROM ARARS
CONTAMINANT CONCENTRATION ARARs
MEDIUM
Ground Water
Treated
Ground Water
Surface Water
TCE
0.005
(MCL)(1)
0.001
(MWS)(5)
0.033
(NPDESM6)
TCA
0.2
(MCL)
0.2
(MUS/MCL)
Monitor
Only
(NPDES)
DCE
0.007
(MCL)
0.007
(MWS/MCL)
0.00063
(NPDES)
PCE
0.005
(PMCLM2)
NE
0.0011
(NPDES)
METHYLENE
CHLORIDE
0.005
(RSD)(3)
NE
Monitor
Only
(NPDES)
1,1 -DCA
NE (4)
NE
Monitor
Only
(NPDES)
1,2-UCA
NE
NE
Monitor
Only
(NPDES)
(1) MCL - Maximum Contaminant Level
(2) PMCL - Proposed MCL
(3) BSD - Risk Specific Dose
(4) HE - None Established: These compounds have not been detected in Municipal Well No. 3
(5) MWS - Municipal Water Supply Permit
(6) NPDES - National Pollutant Discharge Elimination System Permit
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TABLE ? A
CONTAMINANTS EXCEEDING RELEVANT STANDARDS AND GUIDELINES
BALLY, PENNSYLVANIA
CONCENTRATION
(g/l)
DRINKING HA TEH (mg/l )
HEALTH ADVISORIES
Compound
Trlchloroethene
1 , 1-Dichloroethene
1,1, 1-Trichloroe thane
MUNICIPAL
NELL
0.015
0.019
0.073
GEHMAN
WELL
0.19
0.12
0.42
MCL<'>
(mg/l )
0.005
0.007
0.20
AHQC(2)
(mg/l)
2.8 x 10~3
3.3 x 10~5
18.4
1-DAY
10- kg
NA<3)
1.0
110
10-DAY
10- kg
NA
1.0
35.0
LIFETIME'
70-kg
NA
NA
1,0
- Maxlau* Contaminant Level - federal drinking water standard.
Ambient Water Quality Criteria (AUQC) values are adjusted for drinking water only
and represent the 10~° cancer risk.
(3)"NA" Indicates not available.
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21
IX. DESCRIPTION OF THE ALTERNATIVES
Conclusions of Screening Technology
Tables 3 and 4 contain summaries of the data contained in this section and
provide easy reference to the pertinent data concerning each option considered
and identifies those remedial technologies and treatment process options that
have been retained for incorporation into remedial action alternatives.
DEVELOPMENT AND EVALUATION OF REMEDIAL ACTION ALTERNATIVES
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
This section briefly identifies the rationale for development of remedial
alternatives at the BES Site. The number of different alternatives is limited
because of the practical limitations on containment technologies and the absence
of an active source of VDCs to the aquifer. The process options for treatment
of extracted groundwater were screened early in the FS to obviate the need
to perform additional screening prior to the final detailed evaluation in the
FS.
General Approach
The approach taken to development and evaluation of remedial action
alternatives for the BES Site follows that described in "Guidance on Remedial
Actions for Contaminated groundwater at Superfund Sites" (EPA, March 1988).
Remedial alternatives are developed by assembling component technologies and
treatment process options from those that passed the screening. These
technologies and process options are considered effective in meeting the defined
remedial response objectives and are implementable at the BES Site.
In conjunction with the RI/FS, an air stripping treatment system has been
implemented at Municipal Well No. 3 to provide a suitable alternative water
supply for the Borough of Bally. In configuring and evaluating alternative
remedial actions to be implemented at the BES Site, the air stripping treatment
system is considered an element of existing site conditions.
In general, there are two classes of response actions (EPA, March 1988)
that may be appropriate for remedial action at the BES Site. The first of these
is natural attentuation, embodied in the minimal/no action alternative. The
second is active restoration of the aquifer. In the absence of an active source
of VOCs to the aquifer, active restoration at the BES Site would consist of
groundwater extraction at one or more wells within the attainment area. The
third class of response, containment, was not found to be applicable to this
site because of hydrogeologic conditions (i.e., thick, highly productive aquifer
residing primarily within a fractured bedrock flow system), as discussed in the
technology screening.
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TABLE 3
TECHNOLOGIES TO BE SCREENED FOR SUITABILITY
BALLY ENGINEERED STRUCTURES SITE
FEASIBILITY STUDY REPORT
RESPONSE ACTION
TECHNOLOGY
CONTAMINATED
MEDIA
Minimal/No-Action
Ground Water Monitoring
Institutional Control of
Ground Water Use
Resident Relocation
Selective Well Abandonment
Ground water
Ground water
Ground water
Ground Water
Alternate Water
Supply
Installation of New Municipal
Supply Well
Provision of Potable Water From
Adjacent Municipalities or
Other Outside Sources
Treatment of Existing
Municipal Well
Ground water
Ground water
Ground Water
Aquifer Restoration
Via Ground Water
Extraction and
Treatment
Containment
Vertical Barriers
Ground water
Collection
Extraction Wells
Hydraulic Displacement
Ground water
Ground water
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RESPONSE ACTION
TABLE 3
(Continued)
TECHNOLOGY
CONTAMINATED
MEDIA .
Treatment
Ultraviolet (UV) Photolysis-
Ozonation
Wet Air Oxidation
Chemical Treatment
Liquid Phase Carbon Adsorption
Air Stripping
Steam Stripping
Air Stripping with Vapor-Phase
Carbon Adsorption
Air Stripping with Regenerable
Vapor Phase Carbon
Air Stripping with Vapor Phase
Catalytic Oxidation
Distillation
Reverse Osmosis
Biological Treatment
Ground water
Ground water
Ground water
Ground water
Ground water
Ground water
Ground water
and emissions
to the air
Ground water
and emissions
to the air
Ground water
and emissions
to the air
Ground water
Ground water
Ground water
Off-Site
Disposal
Transport to Treatment Center
Discharge to Surface Water
Ground water
Ground water
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TABLE 4
TECHNOLOGIES TO BE RETAINED
FOR THE DEVELOPMENT OF ALTERNATIVES
BALLY ENGINEERED STRUCTURES SITE
FEASIBILITY STUDY REPORT
RESPONSE ACTION
TECHNOLOGY
CONTAMINATED
MEDIA
Minimal/No-Action Ground Water Monitoring
Institutional Control of
Ground Water Use
Selective Well Abandonment
Ground Water
Ground Water
Ground Water
Alternative Water
Supply
Treatment of Existing
Municipal Well
Ground Water
Aquifer Restoration
Via Ground Water
Extraction and
Treatment
Collection
Extraction Wells
Ground Water
Treatment Ultraviolet (UV) Photolysis-
Ozonation
Liquid Phase Carbon Adsorption
Air Stripping
Air Stripping with Vapor-Phase
Carbon Adsorption
Air Stripping with Regenerable
Vapor Phase Carbon
Air Stripping with Vapor Phase
Catalytic Oxidation
Off-Site Disposal Discharge to Surface Hater
Ground Water
Ground Water
Ground Water
Ground Water
and Emissions
to the Air
Ground Water
and Emissions
to the Air
Ground Water
and Emissions
to the Air
Ground water
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22
Because of its location within the attainment area, Municipal Well No. 3
may also function as an extraction well for contaminated groundwater. Monitoring
of VDC concentrations in water pumped.from the well since continuous pumping was
initiated on February 6, 1989 suggest that this may be the case (Appendix A).
The capture zone for Municipal Well No. 3, as well as its ultimate effect on
the VOC contaminant plume, cannot be determined presently with the available
date. The degree to which Municipal Well No. 3 may contribute to remedial action
can best be determined through a period of monitoring. The Borough of Bally
intends to begin utilizing treated groundwater from this well in June 1989.
This source will provide a suitable alternative water supply to meet the demands
of the municipality for the near future. All residents within the attainment
area have access to the municipal supply system and none are currently using
domestic wells as a potable supply.
EPA guidance (March 1988) suggests that three to five alternatives be
carried through the detailed evaluation to provide a suitable range of response
options and cost. The guidance further suggests that one of the alternatives
for Class II groundwaters represent a rapid remediation scenario for comparison.
In the absence of an active source of TOCs to the aquifer, active remediation at
the BBS Site will involve one or more extraction wells, with treatment of the
extracted groundwater. Adequate data is not currently available to predict
the optimal configuration or^extraction wells, nor to estimate the time frame
required for successful aquifer restoration.
The presence of an operational alternative water supply, coupled with
appropriate institutional controls to prevent use of contaminated groundwater
and the absence of an active source of contamination, reduce the urgency of
overall aquifer restoration at this site. In consideration of the above, the
prudent course of action at the BBS Site involves performance of additional
studies to evaluate the need for further remedial action prior to implementing
any actions beyond the ongoing pumping at Municipal Well No. 3. This approach
has provided the frame work for development of remedial action alternatives.
It is apparent that if active restoration of the aquifer is selected as the
recommended remedial response, additional site investigation required as an
element of the additional studies will need to address the following issues:
- Resolution of the limits of the attainment area, especially
in the direction of downgradient groundwater flow
- Evaluation of the effects of continuous pumping of
Municipal Well No. 3 on aquifer contaminant levels
- Determination of the effective capture zone of Municipal
Well No. 3 during long-term pumping
- Determination of the appropriate well location and the
optimal means of treatment of extracted groundwater in
the event that an additional extraction well(s) is
required.
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23
Anticipated components of such additional studies are as noted:
- Periodic monitoring of water levels and target TOCs in
observation wells in the vicinity of Municipal Well No. 3
during continuous pumping of the well
- Installation of additional nested groundwater monitoring
wells at one or more locations
- Sampling of the new groundwater monitoring wells and
selected existing wells for target VOCs
- Installation of an aquifer test well and performance of
pumping tests utilizing this well and suitable observation
wells
The time frame for initiation of the additional field studies for predesign
should provide an adequate period for evaluation of the effects of pumping at
Municipal Well No. 3. The need for additional extraction wells can be
established prior to conducting these studies. CEPCLA, as amended, requires
that the effectiveness of groundwater remedial actions be evaluated within five
years of implementation. A period of from two to three years to monitor pumping
at Municipal Well No. 3 would provide an adequate basis for evaluation. The
provision of a suitable alternative water supply via treatment at Municipal Well
No. 3 affords the necessary flexibility to defer further remedial action for
this period of time without risk to public health or environmental receptors.
Definition of Remedial Alternatives
Two basic alternatives have been defined for remedial action at the BBS
Site:
Alternative No. 1 - Minimal/No-Action (Natural
Attenuation)
Alternative No. 2 - Groundwater Extraction and Treatment
and Alternative Water Supply
The second of these alternatives will involve use of Municipal Well No. 3
both as an alternative water supply and a groundwater extraction well. Pre-
design studies associated with this alternative will determine the need for
additional extraction wells to fully address remedial action objectives within
the attainment area.
Alternative No. 1 - Minimal/Mo-Action (Natural Attenuation)
The minimal/no-action remedial alternative consists of the following
elements:
- Abandoning appropriate existing private wells in the attainment
area (e.g./ Mable Gehman Well)
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24
- Implementing institutional controls (e.g., deed restric-
tions) on the use of operable private wells and the
constructions of new wells within the attainment area
- Conducting public education programs to increase public
awareness about the presence of these restrictions
- Performing groundwater and surface water monitoring to
measure contaminant concentrations and migration
- Performing semiannual site inspections
- Performing a site review every five years.
This option does not actively reduce the Toxicity, Mobility and Volume
(TMV) of the contaminants. The Minimal/ no action option reduces the risk
of the general public's potential of future exposure to contaminants in
groundwater from private wells by reducing the potential for contact with the
contaminated groundwater. In the absence of an active source, natural
attenuation of TOC contamination would ultimately result in aquifer restoration.
This option utilizes the existing monitoring wells located at the BES Site.
The use of Municipal Well No. 3 as an alternative water supply would not be
mandated as a part of this option (although this action may occur independent of
the recommended CEPCIA remedial action). In any event, this alternative does
not assume that Municipal Well No. 3 would be pumped continuously as a groundwater
extraction well.
Alternative No. 2 - Groundwater Extraction and Treatment
and Alternative Water Supply
This alternative is composed of the following items:
- Abandoning appropriate existing private wells in the
attainment area
- Implementing institutional controls on the use of operable
private wells and the construction of new wells within the
attainment area
- Performing groundwater and surface water monitoring to
measure contaminant concentrations and migration
- Removing contaminated groundwater from the aquifer
through continuous pumping of Municipal Well No. 3 (with
the potential for installation of additional extraction
wells in the attainment area, if required)
- Treating the extracted groundwater by one of the treat-
ment options retained for consideration
- Discharging the treated water from Municipal Well No. 3 to
the adjacent stream or into the Borough of Bally potable
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25
water system, as needed to provide a suitable alternative
water supply
- Performing necessary additional studies in the pre-design
phase to evaluate the optimal configuration of any
additional groundwater extraction well(s) required.
Implementation of this alternative reduces the mobility and volume of the
contamination within the aquifer. Treatment process options resulting in
destruction of the MXs also reduce the toxicity of the contaminants. This
alternative also reduces the risk associated with public use of contaminated
water.
The following process options have been identified for Alternative No. 2:
Option No. Description
2A UV Photolysis-Ozonation Treatment
2B Liquid Phase Carbon Adsorption Treatment
2C Air Stripping Treatment
2D Air Stripping Treatment with Vapor Phase Carbon
2E Air Stripping Treatment with Regenerable Vapor
Phase Carbon
2F Air Stripping Treatment with Vapor Phase
Catalytic Oxidation
The capital costs associated with this alternative would be significantly
reduced if the existing air stripping system were selected as the recommended
treatment process. Treated water would be used by the Borough of Bally to supply
the potable system and excess treated water would be discharged to the adjacent
stream. Existing monitoring wells would be used to monitor the concentration
and migration of the contaminants.
DETAILED ANALYSIS OF REMEDIAL TECHNOLOGIES
This section contains a detailed analysis of each of the remedial options.
The analysis is based on the following criteria in accordance with EPA guidance
(EPA, August 1988):
Snort-term effectiveness
Long-term effectiveness
Implementabi1i ty
Reduction of TMV of contaminants
Cost
Compliance with ARARs
Overall protection of human health and the environment
State and comnunity acceptance.
State and community acceptance of each alternative and process option will
be discussed in the final FS document prepared after receipt of public comments.
In general, however, state acceptance of the existing pumping and treatment
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26
system at Municipal Well No. 3 is documented in its approval of operating
permits for the treatment system. Process flow diagrams for each of the treatment
options are provided in Figures 6 thru 11.
Analysis of Alternative No. 1 - Minimal/No Action (Natural
Attenuation
This option consists primarily of reducing the risk of contact with the
contaminants and monitoring the extent and degree of contamination.
Short-Term Effectiveness
Implementation of the minimal/no-action alternative is not expected to
result in an increased risk to the community or to the environment. Remedial
actions contemplated under this alternative (i.e., well abandonment) can be
completed expeditiously. The reliability of the abandonment procedure in
preventing future access to the well is essentially 100 percent.
During the abandonment of existing private wells in the contaminated zone,
workers should be aware of the possibility of organic vapors being released from
the well. Field screening instruments would be used to monitor for the presence
of any hazardous vapors. Dermal protection may also be warranted for workers
closing the well(s). Local residents would be asked to avoid the work areas
during closure. The Mabel Gehman well is the only private well that is currently
being considered for abandonment.
Long-Term Effectiveness and Performance
The risks established for use of the current municipal water supply system
(i.e., baseline risks) would not be actively reduced. As presented in the RI,
the estimated worst case carcinogenic risk posed by using the contaminated
Municipal Well No. 1 water supply for potable purposes is 1.0 x 10 . The
non-carcinogenic risks posed by this exposure pathway were estimated to be
acceptable.
Elimination of risk to potential future residential well users would be
achieved through this alternative by implementing institutional controls. The
effectiveness of such controls will depend on strict enforcement.
Long-term management associated with this option would include semiannual
site inspections and site reviews every five years. Groundwater and surface
water monitoring would also be performed on a long-term basis to monitor
contaminant levels and migration.
Implementability
Implementation of this option would be very simple. The abandonment of the
Mabel Gehman well would consist of removing the pump and pressure grouting the
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27
well bore. A bentonite-rich group would be used to absorb any water in the well
during the grouting process. Deed restrictions are easily implemented but
difficult to enforce in long-term operation. Use of monitoring wells and
residential wells will facilitate implementation of a monitoring program.
Reduction of Toxicity, Mobility/ or Volume of Contaminants
Because no treatment or containment technologies are included as part of
this option, the TMV of the contaminants would not be reduced and exposure due
to the migration of VOCs within the aquifer would continue.to occur.
Cost
Costs associated with the minimal/no-action alternative include costs for
grouting existing wells and performing periodic monitoring. Administrative
costs for implementing and enforcing deed restrictions, conducting public
education programs, and site inspections and reviews must also be considered.
The initial capital costs for this option are estimated $82,800. These costs
include implementing deed restriction, a public awareness program, and abandoning
the Gehman well. An annual operating cost of $10,000 is estimated for the
monitoring and inspection procedures. Based on a 30-year operating life and an
annual inflation rate of 5 percent, the net present cost of this option is
$264,000.
Compliance with ARARs
This alternative does not comply with ARARs for an alternative municipal
water supply. Chemical specific ARARs for aquifer restoration within the
attainment area may ultimately be achieved via natural attenuationn.
Overall Protection of Human Health and the Environment
Provision of a suitable alternative water supply will adequately mitigate
the potential for ingestion or contact with contaminated water in the municipal
supply system. Institutional controls will ensure that no future use of
contaminated domestic wells will occur. Groundwater extraction and discharge of
treated effluent to surface waters will pose no unacceptable impact to
environmental receptors and will be performed in full compliance with applicable
regulations (i.e., NPDES discharge permits).
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28
Analysis of Process Option 2A - Liquid Phase UV Photolysis-
Ozonation Technology
This option provides UV photolysis-ozonation (UV/Ozone) treatment with
Alternative No. 2.
Short-Term Effectiveness
Implementation of this option would not cause an increased risk to the
community provided institutional controls are properly administered and
an alternate municipal water source was available during construction and
permitting of the treatment system. Implementation of this system would require
that Municipal Well No. 3 be taken off-line from the potable water supply system
for a portion of the construction phase. This period would be expected to last
approximately three to six months. During the replacement of the pump at
Municipal Well No. 3, workers should be aware of the possibility of organic
vapors being released from the well. Continuous air monitoring would be
undertaken during construction and appropriate personal protective equipment
(PPE) would be utilized.
Long-Term Effectiveness
This process would provide adequate treatment capability in long-term
operation. Contaminant levels in the water would be reduced to the effluent
requirements as specified in the appropriate permits. No releases to the air
would be expected because the contaminants are destroyed.
Because O&M of this system is somewhat complex, the possibility of a system
malfunction is increased. The overall reliability of the various treatment
options must be considered when comparing this option to less complicated
treatment methods with similar results.
Implementability
Installation of the treatment system would require the replacement of the
current well pump at Municipal No. 3. The uV/Ozone reaction unit would arrive
on-site, pre-assembled. The existing piping, electrical and control systems
would be modified to install the new treatment systems. New pad and foundations
would be required while utilizing the existing structure for housing electrical
and control systems. All design and permitting would be done prior to bringing
the treatment system on-line with the potable water supply system.
Reduction of Toxicity, Mobility, and Volume of Contaminants
UV/Ozone treatment in conjunction with ground water extraction reduced the
toxicity, mobility and volume of the contaminants. Mobility and volume
reductions are provided by ground water extraction. This treatment technology
consists of chemical treatment (as opposed to physical treatment); thus/ the
contaminants are oxidized to inert products (water and carbon dioxide).
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29
Because the contaminants are chlorinated hydrocarbons, chloride products will
also result and may require further treatment if concentrations exceed recommended
values.
Cost
Capital costs for this option include those costs associated with
implementation of the minimal/no-action technologies, and the equipment needed
for the.UV/Ozone treatment system. These initial costs are estimated to be
$793,000. Capital costs for replacement and reconditioning of equipment are
expected to be approximately $98,000 every five years. Operating costs for this
system are approximately $131,000 per year. The operating cost is largely
composed of the electrical costs for the UV lamps and the ozone generator. The
net present worth cost of this option is $3.10 million for a 30 year operating
life and a five percent discount rate.
Compliance with ARARs
This process option complied with ARARs for municipal water and discharge
to surface waters. No air emissions would occur because TOCs are completely
destroyed in the treatment process.
Overall Protection of Human Health and the Environment
Protection from dissolved organics in the water pumped to the potable water
system is provided by the UV/Zone treatment system. Because this option reduced
the TMV of the contaminants, it provided a great deal of overall protection.
Institutional controls proposed as part of the basic alternative provide
protection by obviating the future possibility of exposure to untreated ground
water from residential wells. This alternative effectively protects the public
from hazards created by absorption, ingestion, and inhalation exposure via the
municipal water supply. Because no air releases are generated, no risks via
this pathway are created. The estimated carcinogenic risk of using the municipal
water supply is lowered from 1.0 x 10~3 (baseline case) to at least 3.3 x 10~ ,
with adherence to the contaminant levels established in the Water Supply
Permit for Municipal Well No. 3 by the PADER (Appendix A).
Analysis of Process Option 2B - Liquid Phase Carbon
Adsorption Technology
This option provides liquid phase granular activated carbon treatment for
Alternative No. 2.
Short-Term Effectiveness
Implementation of this technology is not expected to result in an increased
risk in the short term provided the institutional controls are administered
properly and an alternative water supply (e.g., springs) is available to the
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30
residents during construction. Implementation of this system would required
that Municipal Well No. 3 be taken off-line from the potable water supply system
for a portion of the construction phase. This period would be expected to last
approximately two to four months. During the replacement of the pump at
Municipal Well No. 3, workers should be aware of the possibility of organic vapors
being released from the well. Screening instruments would be used to monitor
the breathing zone. Effectiveness during the periods when the carbon is
approaching saturation would not be reduced if a standby adsorption unit was
always available. This setup would allow the operator to bring the stand by
carbon unit on line and remove the spent bed in a short period of time.
Long-Term Effectiveness and Permanence
Long-term effectiveness should remain high through the lifetime of the
project with this treatment option. Carbon adsorption is a very effective
methods of removing low levels of VXs from ground water. Monitoring of the
effluent discharge from the carbon units will identify the most efficient
changeout time and maximal carbon usage. In this event that contaminant
concentrations in the water rise, the system will retain its effectiveness but
the carbon usage will increase with more frequent changeout.
Implementability
Implementability of carbon adsorption system is relatively simple. Granular
activated carbon units are pre-assembled and are easily linked. The control
system, associated with this treatment technology, is not complex and can be
installed in a short period of time. Construction of the system is expected to
take two to four months. Carbon adsorption is effective at reducing the volume
of contaminants but not their toxicity, thus spent carbon must be disposed of or
regenerated.
Cost
Costs for Alternative No. 2 with the liquid phase carbon system are the
highest among process options presented here due to the high operating cost
associated with carbon replacement. The initial capital expenditure projected
for this option is expected to be approximately $584,000.
Five year replacement/reconditioning costs can be converted to a net present
worth cost of $4.77 million for a 30 year lifetime and 5 percent discount rate.
Compliance with ARARs
This treatment option complied with ARARs for water supply and discharge to
surface waters. No air emissions would be associated with this treatment option.
Overall Protection of Human Health and the Environment
This option reduces the possibility of contact with contaminated ground
water by implementation of institutional controls, and the use of liquid phase
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31
liquid phase carbon reduces the level of contamination in the ground water
before it is sent to the potable water system. This protection can be seen in
the reduction of risk from 1.1. x 10~J to at least 3.3. x 10"5 for use of the
municipal water supply. Because no vapor effluent is generated, no risk is
associated with airborne contaminants.
Analysis of Process Option 2C - Air Stripping Technology
This option provides air stripping treatment for Alternative No. 2.
Appendix A contain a detailed explanation of the air stripping system currently
in use at Municipal Well No. 3.
Short-Term Effectiveness
Because there is an operational air stripping system at the BES site,
implementation of this alternative would not cause an increased risk to the
conmunity or the environment in the short-term. This system is capable of 24
hour per day operation and can be initiated immediately.
Long-Term Effectiveness and Permanence
The air stripping system currently in operation at Municipal Well No. 3
has been proven to be effective at reducing the WC concentrations in the ground
water to levels below those required by the Pennsylvania Safe Drinking Water Act
of May 1, 1987 (Public Law [P.L.] 206, No. 43); the Clean Water Act, 33 U.S.C.,
Section 1251, et seq. (the "Act"); and the Pennsylvania Clean Streams Law, as
amended, 35 P.S., Section 69.1., et seq. The effectiveness of the air stripping
towers at removing VDCs from the ground water to acceptable levels will remain
constant unless the contaminant concentrations in the water increase markedly.
A determination of the overall effectiveness of this alternative must also
consider the risks associated with the release of the VDCs to the air.
Estimated risks were calculated in the RI for future ground water supply
conditions that would utilize this alternative, assuming a switch from primary
reliance on Municipal Well No. 1 to treated Municipal Well No. 3 for potable
water supply. The risk was calculated as a worst-case because the total supply
was assumed to be derived from Municipal Well No. 3 with no dilution from the
springs. The carcinogenic risk for potable water exposure is reduced from 1.0 x
10~3 (current conditions) to 3.3. x 10""-* under the this alternative. This
reduction is consistent with achieving the contaminant levels specified in the
PADER Water Quality Permit.
Risk reduction is accomplished over the long-term by reducing contaminant
concentrations in the water used by the public, while also reducing the
possibility of residents contacting untreated water at private wells through the
use of institutional operation and maintenance of the air stripping system, a
ground water monitoring program, and performance of semi-annual site inspections
and site reviews every five years.
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32
Carcinogenic risks associated with WC releases from the stripping towers
to the air have been estimated by utilizing an air-dispersion model and actual
weather data (i.e., stability classes and wind speeds) from Allentown, Pennsylvania
for 1981. Using the nearby residents and children playing in the adjacent ballfield
as worst-case receptors, the airborne concentrations were estimated using an air
dispersion model. The carcinogenic risk for exposure to these levels was calculated
to be in the range of 7.3 x 10~b to 1.8 x 10~5. The details of the air-dispersion
model and exposure assumptions and calculations are presented in Appendix B.
Implementability
Implementation of this option is demonstrated by the presence of the air
stripping system on site.
Reduction of Toxicity, Mobility, and Volume of Contaminants
The air stripping treatment system, in conjunction with other components of
Alternative No. 2, is capable of reducing the mobility of VOCs in ground water.
Because TOCs are not destroyed but are transferred from ground water to air, no
reduction in toxicity of contaminants occurs directly as a result of air stripping.
However, VDCs will be subject to some photolytic degradation and dispersion upon
release to the air.
Cost
Costs for the air stripping alternative are significantly reduced due to
the presence of the operating air stripping treatment system at Municipal Well
No. 3. For this reason, no capital costs are required to implement this treatment
process option. A capital cost for repairing or replacing equipment of $47,000
every five years is expected. An annual operating cost of $57,700 includes the
administrative costs for institutional controls and operation of the air stripping
system. These cost represent a net present worth cost of $1.2 million with a
discount rate of 5 percent and a 30-year operating life.
Compliance with ARARs
The air stripping process option has demonstrated effectiveness in achieving
ARARs for public water supply and discharge to surface waters. Acceptable emissions
levels will be established in the PADER Air Operating Permit.
Overall Protection of Public Health and the Environment
The air stripping treatment system provides adequate protection from adverse
effects caused by contact with contaminated water. This protection is seen in
the reduction in risk associated with use of the current municipal water supply
from 1.0 X 10"3 to 3.3 x 10~5 for lifetime use of treated water from Municipal
-------
33
Well No. 3. Air stripping does not, however, provide protection from contact
with airborne MXs. However, the worst-case risk calculated for 30 year exposure
to the airborne \£>Cs is only 7.3. x 10~5 which is within acceptable risk range
of 10~4 to 10~7 established by EPA policy for CERCLA remedial action.
Analysis of Process Option 2D - Air Stripping/Vapor Phase Carbons
Technology
This option combines ground water extraction with the air stripping treatment
option and vapor phase carbon adsorption for treatment of. the off-gas containing
the \OCs with Alternative No. 2. Figure 9 provides the process flow diagram for
this option.
Short-Term Effectiveness
Implementation of this option will require retrofitting of the existing
treatment system, estimated to take approximately four to six months. During a
portion of this period, the current air stripping system could not function to
provide an alternative water supply or as a remedial response action. For this
reason, minimal effectiveness would occur in the short term. After completion
of the modifications to the air stripping system, the entire treatment system
can be operated full time for remedial purpose.
The minimal protection provided during construction is identical to that
presented with the minimal/no-action alternative. When the air stripper is
operating following the installation of the carbon units, the protection provided
for potable water use is identical to that given for the air stripping alternative.
Long-Term Effectiveness and Permanence
Reduction in the risk associated with use of the municipal water supply
from 1.0 x 10~3 (current risk) to 3.3. x 10~5 would occur after implementation
of this treatment option. The estimated risk associated with inhalation of MXs
emitted from the air stripping towers without gas collection and treatment (Option
2C) would be reduced by approximately two orders of magnitude with Process Option
2D. This reduction in risk associated with air is the result of treating the
effluent gas from the air stripping towers with the vapor phase carbon adsorption
units based on 99.9 percent removal efficiency.
Implementability
Implementation of this option is greatly facilitated by the existence of an
air stripping system on-line at Municipal Well No. 3. This option would require
that vapor effluent from the existing stripping towers be vented to vapor phase
carbon adsorption units to remove the \OCs before discharging the air. In order
to improve the efficiency of the carbon units, a heater would be installed on
each air duct leaving the towers to reduce the relative humidity of the air
stream prior to adsorption. These modifications to the existing system are
expected to take three months for completion. Permits currently applying to the
air stripping system would require modifications to account for alterations to
the system.
-------
34
Reduction in Toxicity, Mobility/ and Volume of Contaminants
TMV considerations relative to mobility and volume are identical to those
with Process Option 2C though collection of VX emissions on the activated carbon
air emissions are essentially eliminated. Regeneration of the spent carbon will
be performed by the vendor.
Cost
Initial capital costs for this option include those costs associated with
implementation of the minimal-action technologies, modifications to the existing
air stripping system, and the first set of activated carbon units. These costs
are estimated to be $484,000. Capital costs for replacing or reconditioning
equipment are estimated to be $82,000 every five years. Operating costs for the
air stripping/vapor phase carbon adsorption option are considerably higher than
for air stripping due to the added cost of carbon replacement. The total annual
operating cost is estimated to be $189,000. For comparison, these costs can be
converted to a net present worth cost of $3.64 million for the 30-year operating
life and a discount rate of five percent.
Compliance with ARARs
Treatment with this process option would comply with ARARs for water supply
and aquifer restoration. No release of TOCs to ambient air would occur. Spent
carbon units would be regenerated by the vendor.
Overall Protection ofHuman and the Environment
Protection from hazards created by contaminated water is provided by the
air stripping treatment of the ground water. Protection from inhalation of
airborne VXs is through off-gas collection by the activated carbon units. This
process option effectively provides protection from the contaminants affecting
the public through absorption, ingestion, and inhalation. The decrease in risk
associated with use of ground water from the municipal supply system is identical
to that given for the air stripping alternative. The risk associated with
inhalation of airborne VXs is also reduced by about two orders of magnitude in
comparison with that calculated for the air stripping option alone.
Analysis of Process Option 2E - Air Stripping with Regenerable Vapor
Phase Carbon Technology
This process option combines air stripping treatment and vapor phase carbon
adsorption for treatment of the gas containing the TOCs with Alternative No.
2. It differs from Option 2D in that the carbon is regenerated on site and the
VDCs are periodically destroyed in a thermal oxidation unit.
Short-Term Effectiveness
Installation of this equipment is estimated to take four to six months.
During a portion of this period, the current air stripping system could not
-------
35
function to provide an alternative water supply or remedial response. For this
reason, the effectiveness is considered minimal during this initial period.
After completion of the modifications to the air stripping system, the entire
treatment system can be operated full time for water .supply, as well as ground
water extraction and treatment.
The minimal protection provided during construction is identical to that
presented with the minimal/no-action alternative. When the air stripper becomes
operati9nal with this process option, the protection provided to the municipal
water supply is identical to that given for the air stripping alternative.
Long-Term Effectiveness and Permanence
After the four to six month construction period, this treatment option will
provide an adequate level of protection for water supply purpose. Protection
from adverse effects caused by elevated VDC concentrations can be seen in the
reduction in the risk associated with use of the municipal water supply from 1.0
x 10"-1 to 3.3. x 10~b. The risk associated with the airborne TOCs will be
reduced approximately two orders of magnitude through collection of off-gases.
This risk reduction is based on 99.9 percent removal efficiency, which can be
achieved via vapor phase carbon treatment.
Implementability
Implementation of this option is greatly facilitated by the existence of an
air stripping system on-line at Municipal Well No. 3. This option would require
that the air discharge from the existing stripping towers be routed to vapor
phase carbon adsorption units to remove the TOCs prior to being discharge to the
air. In order to improve the efficiency of the carbon units, a heater would be
installed on each air duct from the towers to reduce the relative humidity of
the air stream. Also, a thermal regeneration unit is included to regenerate the
spent carbon on site and to destroy the TOCs by thermal oxidation. This
significantly reduced the operating costs associated with vapor phase carbon.
These modifications to the existing air stripping treatment system would require
four to six months to complete. Permits currently applying to the air stripping
system would require modifications to account for alterations to the system.
These issues are included in the cost estimate prepared for this option.
Reduction in Toxicity, Mobility and volume of Contamination
TMW considerations for this process option are the same as those identified
for Option 2D. The on-site thermal oxidation unit would ensure destruction of
the WDCs, thereby reducing toxicity.
Cost
Initial capital costs for this process option include modifications to the
existing air stripping system and the first set of activated carbon units. These
costs are estimated to be $992,000. Capital costs for replacing or reconditioning
-------
36
equipment are estimated to be $116,000 every five years. Operating costs for
the air stripping/vapor phase carbon adsorption option are considerably higher
than or air stripping due to is estimated to be $105,000. For comparison, these
costs can be converted to a net present worth cost of $2.95 million for the 30-year
operating life and a discount rate of five percent.
Compliance with ARARs
This process option complied with all ARARs for water supply and aquifer
restoration. There are also no significant air emissions.
Overall Protection of Human Health and the Environment
Protection from hazards created by contaminated water is provided by the
air stripping treatment of the ground water. Protection from inhalation of
airborne \TOCs is ensured by the activated carbon units. This alternative
effectively provides protection from the contaminants affecting the public through
absorption, ingestion, and inhalation. The decrease in risk associated with use
of the municipal water supply is identical to that discussed for the air stripping
alternative. The risk associated with airborne TOCs is also reduced by
approximately two orders of magnitude in comparison to Option 2C.
Analysis of Process Option 2F - Air Stripping/Vapor Phase
Catalytic Oxidation Technology
This option provides air stripping treatment and vapor phase catalytic
oxidation for treatment of the off-gas containing the TOCs with Alternative No.
2.
Short-Term Effectiveness
Installation of this equipment is estimated to take four to six months.
During a portion of this period, the air stripping system could not function to
treat water from Municipal Well No. 3. For this reason, the effectiveness is
only minimal for the initial construction period. After completion of the
modifications to the air stripping system, the treatment system would be fully
operational to address both alternative water supply and ground water extraction
and treatment.
The minimal protection provided during construction is identical to that
presented with the minimal/no-action alternative. When the air stripper becomes
operational with this process option, the protection provided for potable water
use is identical to that give for the air stripping alternative.
Long-Term Effectiveness
After the four to six month construction period and the modifications are
complete, adequate protection will be provided by the system. The risk associated
with use of the municipal water supply will be reduced from 1.0.
-------
37
x 10~3 to 3.3. x 10~5. The risk associated with the airborne WCs will also
be reduced by approximately two orders of magnitude. This increased protection
is the result of treating the effluent gas from the air stripping towers with
the vapor phase catalytic oxidation unit. This risk reduction is based on 99.9
percent removal efficiency, which can be achieved via vapor phase catalytic
oxidation.
Implementability
Implementation of this option is greatly facilitated by the existence of an
air stripping system on-line at Municipal Well No. 3. This option would require
that air discharge effluent from the existing stripping towers be routed to a
vapor phase catalytic oxidation unit to remove the VXs prior to being discharge
to the air. These modifications to the existing system are expected to take
four to six months for completion. Permits currently applying to the air stripping
system would require modifications to account for alterations to the system.
All of these issues are included in the cost estimate prepared for this option.
Reduction in Toxicity, Mobility/ and Volume of Contaminants
TMW considerations are identical to those discussed for Option 2E.
Cost
Initial capital costs specified to this option include those costs associated
with modifications to the existing air stripping system, and acquisition of the
catalytic oxidation unit. These costs are estimated to be $707,000. Capital
costs for replacing or reconditioning equipment are estimated to be $110,000
every five years. The total annual operating cost is estimated to be $145,000.
For comparison, these costs can be converted to a net present worth cost of
$3.28 million for the 30-year operating life and an annual inflation rate of 5
percent.
Compliance with ARARs
Compliance with ARARs is identical to that discussed for Option 2E.
Overall Protection of Human Health and the Environment
Protecting from hazards created by contaminated water is provided by the
air stripping treatment of the ground water. Protection from inhalation of
airborne TOCs is achieved via the catalytic oxidation unit. This alternative
effectively provided protection from the contaminants affecting the public
through absorption, ingestion, and inhalation. The decrease in risk associated
with use of the municipal water supply is identical to that estimated for other
air stripping options. The risk associated with airborne TOCs is reduced by
about two orders of magnitude with referenced to Option 2C through off-gas
collection.
-------
38
XI. Documentation of Significant Changes
No significant changes to the preferred alternative presented in the
proposed plan have occurred.
XII. Selected Remedial Criteria
A. Evaluation Criteria
, Section 121 of SARA and the current version of the National
Contingency Plan (NCP) (50 Fed. Reg. 47912, November 20, 1985) establish a
variety of requirements pertaining to remedial actions under CERCIA. The
following nine criteria were used in the evaluation of the remedial action
alternatives at Bally:
- Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protection and describes how
risks posed through each pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
- Compliance with ARARs addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements of other Federal
and State environmental statutes and/or provides ground for invoking a waiver.
- Long-term effectiveness and j>ermanence refers to the ability of a
remedy to maintain reliable protection of human health and the environmental
over time once cleanup goals have been met.
- Reduction of toxicity,mobility or volume is the anticipated
performance of the treatment technologies a remedy may employ.
- Short-term effectiveness addresses the period of time needed to
achieve protection, and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period until cleanup
goals are achieved.
- Implementability is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implement
a particular option.
~ Cost includes estimated capital and operation and maintenance costs
and net present worth costs.
- State Acceptance indicates whether, based on its review of RI/FS and
Proposed Plan, the State concurs on, opposes, or has no comment on the preferred
alternative at the present time.
- Community Acceptance will be assessed in the Record of Decision
following a review of the public comments received on the Administrative Record
and Proposed Plan.
-------
39
B. Determination of Preferred Remedial Alternative
The preferred alternative is alternative number 2 with D, E, or F
process option selection based on final design decisions and air emission
concentration. This alternative selects the treatment of groundwater by
airstripping with appropriate air emissions controls and meets the goal of
protecting human health and the environment and restoring the contaminated
groundwater to a clean and uncontaminated condition.
The preferred alternative provides complete protection and final
remediation in the short and long-term.
EPA, in consultation with PADER, has made a preliminary determination
that the preferred alternative provides the best balance of tradeoff with respect
to the nine criteria. The preferred alternative is anticipated to meet the
following statutory requirements to:
- Protect human health and the environment
- Attain ARARS
- Be cost-effective
- Utilize permanent solutions and alternative treatment
(or resource recovery) technologies to the maximum extent
practicable
In summary, at this time the preferred alternative is believed to
provide the best balance of trade-offs among alternatives with respect to the
criteria used to evaluate remedies. Based on the information available at this
time, therefore, EPA and PADER believe the preferred alternative would be
protective, would attain ARARs, would be costeffective, and would utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
Schedule
Remedial Design and Construction for the final remedy is anticipated to
commence in Fall 1989.
C. Statement of Findings Regarding Wetlands and Floodplains
The focus of this decision is to provide and interim remedial alternative
for the contaminated groundwater, defined as the first operable unit for this
site. Further work at this site will consider the impact of contamination on
wetlands, floodplains and surface water. A wetlands assessment will be performed
during the next phase of this project.
XIII. Statutory Determinations
A. Protection of Human Health and the Environment
The selected remedy will reduce and controls the amount of groundwater
contamination which will ensure adequate protection of human health and the
environment. No unacceptable short and long-term risks or cross-media impact
will be caused by implementation of the remedy.
-------
40
Based on a review of volatile organic chemical analytical data from
collected groundwater samples from impacted off-site wells and given the vinyl
chloride concentrations in the untreated groundwater, the use of granular
activated carbon filters has proven to be successful in reducing the
concentrations of the contaminants of concern (TCE, DCE) to non-detectable levels.
B. Attainment of ARARs
The selected remedy will attain the applicable or relevant and
appropriate requirements by:
. Preventing current and future ingestion of ground water containing
unacceptable levels of TOCs, and
. Restoring the aquifer within a reasonable time frame to a condition
such that levels of indicator VXs are below remediation levels
and the aquifer may be suitable for use as a Class II aquifer.
The ARARs are as follows:
Federal
Safe Drinking Waste Act
Clean Water Act
Clean Air Act, Part D
National Ambient Air Quality
Standards
State
Pennsylvania Clean
Stream Law - Section 402
Pennsylvania Air Resource
Regulations
Pennsylvania Air Toxic Guidlines
- MCLs
- Ambient Water Quality
Criteria
- Ozone Non-Attainment
Area Criteria
- VDC Standards
- Ambient Water Quality
Standards
- VX Standards for Ozone
Non-Attainment Areas
- Ambient Ground-level
Contamination Standards
-------
41
Additional Requirements for Protectiveness
The selected site remedy is consistent with the following:
Federal Executive Order 11988, - Action to avoid adverse
Floodplain Management effects, minimize potential
40 C.F.R. Part 6, Appendix harm, restore and preserve
natural beneficial value.
' Federal Executive Order 11990, - Action to minimize
Protection of Wetlands, 40 C.F.R. destruction, loss, or
Part 6, Appendix A degradation of wetlands.
Federal Clean Water Act - Differential Groundwater
Policy Class IIA aquifer
C. Cost-effectiveness
The selected remedy provides overall effectiveness commensurate to its
costs such at that it represents value for the money. The PRPs are maintaining
the current systems described in the selected remedial alternative in compliance
with the PADER Consent Order and Agreement. This is a cost savings to the
government.
D. Utilization of permanent solutions employing alternative
technologies to the maximum extent practicable
The selected remedy is the most appropriate solution for this operable
unit and represents the maximum extent to which permanent solutions and treatment
can be practicably utilized.
E. Preference for treatment a principal element
The preference is satisfied since treatment is the principle element
of the chosen alternative.
-------
APPENDIX A
ANALYTICAL DATA
-------
5-1
ON-/Orr-SHC MEUS - SAMPLIN8 MCSULTS
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Source:
"Hydrogeologic Investigation of the Bally
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-------
7
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-------
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-------
BALLY GROUNDTOTER CONTAMINATION SUPERFUND SITE
PROPOSED REMEDIAL ACTION PLAN
PRESENTED BY
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
The United States Environmental Protection Agency (EPA) is seeking conroents
on the proposed remedial action plan for the Bally Groundwater Contamination
Superfund Site.
This proposed plan presents actions that EPA has considered with regard to
public.concern related to the Bally Groundwater Contamination Site in the
Borough of Bally, Berks County, Pennsylvania. These actions were identified by
Remedial Investigation Reports and a Feasibility Study which were prepared to
evaluate the extent of the contamination problem at the site, the potential
risks to the public health and the environment and the steps to be taken to
correct the problem.
Section 117(a) of the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA), 42 U.S.C. Section 9617(a), requires publication of
a notice and a brief analysis of a Proposed Plan for any remedial action at a
Site. The proposed plan begins with a brief history of the Bally Site, followed
by a summary of each of the remedial alternatives EPA considered for dealing
with the groundwater contamination at this site, and includes EPA's rationale
for recommending and, in some cases eliminating, any one of these remedial
alternatives. In addition, this proposed plan identifies the preliminary decision
on a preferred alternative and explains the rationale for the preference. EPA
is seeking public comment on all of the remedial alternatives currently under
consideration. At the conclusion of this proposed plan, a glossary of terms
that may be unfamiliar to the general public is provided.
SITE DESCRIPTION AND HISTORY
The Borough of Bally is located in Berks County, Pennsylvania near the
Philadelphia metropolitan area. In 1982, the Bally Municipal Mater Authority
conducted a water quality check of the Bally water system and discovered the
presence of elevated concentrations of chlorinated volatile organic compounds
(VOCs) in Bally Municipal Well NO. 3. A survey conducted in 1983 by the
Pennsylvania's Department of Environmental Resources indicated that the Bally
Engineered Structures, Inc. (BBS) plant was a potential source of the \CC
contamination (See Figure 1). Bally Municipal Well No. 3 was removed from the
municipal supply system in December 1982 as a result of the presence of TOCs,
most notably 1,1,1, trichloroethane (TCA) and trichloroethene (ICE), both
commolly used industrial degreasers. These contaminants are both considered
hazardous substances under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA).
-------
- 2 -
3ES signed a Consent Order in January 1987 with EPA to conduct the
Remedial Investigation and Feasibility Study (RI/FS) at this site to define
the problem and provide alternate ways to mitigate the problem. Groundwater
remediation has become the focus of the remediation since no remaining
contamination source has been identified on the facility's property.
The Bally Site was evaluated through the Hazard Ranking System (HRS) and
subsequently placed on the National Priorities List (NPL) in 1987. The NPL
is a list of hazardous waste sites targeted for action under the Superfund
program.
SITE MAP - BQRQUQH Of BALLY. WASHIMQTQM TQWM8HIP
Borough
of Batty
BERKS COUNTY
THE BALLV SITE
FIGUkE 1
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- 3 -
COMMUNITY RDLE IN THE SELECTION PROCESS
This proposed plan is being distributed to solicit public comment regarding
the proposed alternative and the other alternatives to clean up the contamination
at this Site. Detailed information on all of the material discussed here may
be found in the documents contained in the Administrative Record (AR) for the
Site, including the RI/FS Report. Copies of these documents are available for
review at the following information repository location:
Bally Borough Business Office
South Seventh Street
Bally, Pennsyvalnia 19503
215-845-2351
The public comment period will run from May 21, 1989, to June 19, 1989.
If a public meeting is requested or if you have any written comments, questions
and requests for information can be sent to:
Patricia Tan, Project Manager Barbara Brown
U.S. EPA Region III Community Relations Coordinator
841 Chestnut Street U.S. EPA Region III
Philadelphia, PA 19107 841 Chestnut Street
215-597-3164 Philadelphia, PA 19107
215-597-9871
A request for a public meeting should be made by June 1st.
EVALUATION CRITERIA
A Remedial Investigation/Feasibility Study (RI/FS) performed under a 1987
Consent Order with EPA, was completed in May 1989. The RI/FS identified
remedial action alternatives that would address the contamination of the Site.
These alternatives were then evaluated against the following nine criteria:
- Overall protection of human health and the environment; whether the remedy
provides adequate protection and describes how "risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.
- Compliance with ARARs: whether or not a remedy will meet all of the appli-
cable or relevant and appropriate requirements (ARARs) of other Federal
and State environmental statutes and/or provides grounds for invoking a
waiver. Whether or not the remedy complies with advisories, criteria and
guidance that EPA and PADER have agreed to follow.
- Long-term effectiveness and permanence; the ability of the remedy to main-
tain reliable protection of human health and the environment over time
once cleanup goals have been met.
- Reduction of toxicity, mobility or volume: the anticipated performance of
the treatment technologies the remedy may employ.
-------
- 4 -
- Short-term effectiveness; the period of time needed to achieve
protection, and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period
until cleanup goals are achieved.
- Implementability: the technical and administrative feasibility of a
anedy, including the availability of materials and services needed to
implement a particular option.
- Cost; includes estimated capital, operation and maintenance, and net
present worth costs.
- State Acceptance; indicates whether, based on its review of KL/FS and
Proposed Plan, the State concurs on, opposes, or has no comment on the
preferred alternative at the present time.
- Community Acceptance; will be assessed in the Record of Decision
following a review of the public comments received on the Administrative
Record and the Proposed Plan.
REMEDIAL INVESTIGATION AH) RISK ASSESSMENT FHOIMGS
The historical problem at the BES site is VOC contamination of ground-
water. Site investigations have not identified significant contamination of
any other media or located the specific source or sources of the groundwater
contamination. The source is believed to be a historic release or releases
associated with solvent use and management of spent solvents at the BES plant.
The following compounds were selected as indicator compounds:
- Trichloroethane (TCA)
- Trichloroethene (TCE)
- Dichloroethene (DCE)
- Tetrachloroethene (PCE)
- Methylene chloride
- Dichloroethane (OCA)
These compounds were selected because of their presence in groundwater
and their potential chronic health effects at low levels, primarily suspected
carcinogenicity.
The only known current human exposure takes place through potable use of
the contaminated municipal water supply. VOCs currently enter the supply via
Municipal Well No. 1 which taps the contaminated aquifer. A cumulative
carcinogenic risk estimated for use of the current municipal system,
considering no dilution of well water with uncontaminated spring water, is
9.9 x 10 . This means that there is the potential for approximately ten
additional incidence of cancer in an exposed population of 10,000 people, or
one in 1,000. The risk of noncarcinogenic health effects is deemed acceptable
for the current municipal groundwater supply system.
-------
- 5 -
Future plans for the municipal water supply system are to revert to using
Municipal Well No- 3, which has been equipped with an air-stripping treatment
unit. VDC concentrations to be achieved in the effluent of this well are those
set forth in water supply and NPDES permits issued by the PADER. The cumulative
carcinogenic risk estimated for use of this well and these TOC concentrations,
again considering no dilution of the well water with spring water, is
3.6 X 10~5, or approximately four additional incidence of cancer in an exposed
population of 100,000 people. Estimated noncarcinogenic health risks are
acceptable.
Currently, no residential wells know to be contaminated are being used.
Use of wells know to be contaminated, or installation of wells in contaminated
areas, should be restricted. The carcinogenic risk estimates for use of the
Gehman residential well is 6.4 X 10"3, or approximately six additional
incidence of cancer in an exposed population of 1,000 people. The
noncarcinogenic health risks associated with using this well are estimated to be
marginally acceptable; the estimated contaminant dose is 81 percent of that
deemed unacceptable.
Contaminated groundwater is not discharging to surface water in the wetland
adjacent to the BES plant. There is evidence that groundwater discharges to
the unnamed tributary further to the southeast. Surface water TOC concentrations
have not been found in this stretch of the unnamed tributary. However, VOC
concentrations detected in well MW 87-101 in this vicinity are far lower than
Ambient Water Quality Criteria established for the protection of aquatic biota.
Based upon the information presented in the Remedial Investigation and Risk
Assessment, the following remedial action objectives have been developed:
1. Hydraulic groundwater control should be established to contain
the identified Site contaminants and to reduce the concentration and
mass of these contaminants present in groundwater.
Two alternatives were specifically developed to address the ground-
water contamination at the Site. These alternatives were identified and evaluated
according to the previous described criteria required by CERCIA.
Develcqaent and Screening of Remedial Action Alternatives
The following remedial action alternatives were developed, each providing a
different degree of remediation:
Alternative No. 1 - Minimal/No Action: Abandoning appropriate existing
private wells; implementing institutional controls on the use of operable private
wells yand the construction of new wells; conducting public education programs to
increase public awareness about the presence of these restriction; performing
groundwater and surface water monitoring to measure contaminant concentrations
and migration; performing semiannual site inspections; performing a site review
every five years.
Estimated Construction Cost: $82,800.
Estimated Operation and Maintenance Cost: $264,345.
Estimated Implementation Timeframe: 30 year
-------
- 6 -
Alternative No. 2 - Groundwater Extraction and Treatment and Alternative
Water Supply:Abandoning appropriate existing private wells;~~
inplementing institutional controls on the use of operable private wells and
the construction of new wells; performing groundwater and surface water monitoring
to measure contarainent concentrations and migrations by removing contaminated
groundwater from the aquifer through continuous pumping of Municipal Well No.
3; treating the extracted groundwater by one of the treatment options retained
for consideration; discharging the treated water from Municipal Well NO. 3 to
the adjacent stream or into the Borough of Bally potable water system, as
needed to provide a suitable alternative water supply, performing necessary
additional studies in the pre-design phase to evaluate the optimal configuration
of any additional groundwater extraction well(s) required.
Estimated Construction Cost: $991,818.
Estimated Operation and Maintenance Cost: $323,132
Estimated Implementation Timeframe: 30 year
PRBLDCMMg DETEHMINATIOM OF PREFERRED REMEDIAL ALTERNATIVE
ReoouiaaiJations for Remedial Actions
Alternative No. 2 is recommended since it is the most protective, technically
feasibility, practical and effective remedial action for the Bally Groundwater
Contamination Site.
Implementation of these recommended remedial activities will meet the
objectives of CERCLA to protect human health and the environment, to be cost
effective, and to utilize treatment technologies to the maximum extent possible.
EPA, in consulation with PADER, has made a preliminary determination that
the preferred alternative provides the best balance with respect to the nine
criteria. In addition, groundwater remediation is consistent with the policy
of the Pennsylvania Clean Streams Law which provides for the remediation and
restoration of polluted streams and groundwater to a clean and unpolluted
condition.
SOMJARIZIHG THE STATOTOBT FDPIMGS
In summary, at this time the preferred alternative is believed to provide
the best balance of trade-offs among alternatives with respect to the criteria
used to evaluate remedies. Based on the information available at this time,
therefore, EPA believes the preferred alternative would be protect human
human health and the environment, would attain ARARs, would be cost-effective,
and would utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
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- 7 -
The proposed remedial activities focus on the known Site contamination.
These activities will reduce the risk the Site currently presents to human
health and the environment. If unknown conditions or information becomes
available and actions are warranted to protect human health and the environment
or to prevent abate, or minimize an actual or threatened release of hazardous
substances on at or from the Site, previous activities performed at the Site
shall not be deemed to limit the power and authority of EPA and the
Commonwealth of Pennsylvania.
NEXT STEPS
Following the conclusion of the 30-day public comment period on this
proposed remedy/ a Responsiveness Summary will be prepared. Changes to the
preferred alternative or a change from the preferred alternative to another
alternative may be made if public comments or additional data indicate that
modifications to the preferred alternative or a different remedy would better
achieve the cleanup goals for the Site. The Responsiveness Summary will
summarize citizen's comments on the proposed remedy and EPA's responses to
these comments. Thereafter/ EPA will prepare a formal decision document that
summarizes the decision process and the selected remedy. This document will
include the Responsiveness Summary. Copies will be made available/ for public
review/ in the information repository listed previously.
-------
GLOSSARY OF TERMS
Administrative Record (AR) - A legal document that contains information on a
Superfund site. The AR serves as the basis for the selection of a Superfund
response action, and this record is available to the public.
ARARs - Applicable or relevant and appropriate Federal, State or
other promulgated public health and environmental requirement.
CERCLA - Comprehensive Environmental Response, Compensation, and Liability
Act established a Trust Fund for the purposes of cleanup at hazardous waste
sites identified on the National Priority List.
Feasibility Study (FS) - The purpose of this study is to identify and screen
cleanup alternatives for remedial action, and to analyze in detail the technology
and costs involved with the various alternatives.
National_Cpjitingency Plan iNCP) - Contains the regulations that govern the
Superfund program.
National Priorities List (NPL) - EPA's list of the nation's top priority
hazardous waste sites that are eligible to receive federal money for response
under Superfund.
Remedial Design - An engineering phase that follows the Record of Decision
when technical drawings and specifications are developed for the subsequent
remedial action at a site on the National Priorities List (NPL).
Remedial Investigation .(RJO - The purpose of this study is to gather the
data necessary to determine the type and extent of contamination at a Superfund
site.
Supjsrfund - The common name used for the Comprehensive Environmental
Response, Compensation, and Liability Act, also referred as the Trust fund. The
Superfund program was established to help pay for cleanup of hazardous waste
sites and to take legal action to force those responsible for the sites to clean
them up.
-------
APPENDIX B
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE BALLY GKXJNDWATER CONTAMINATION
SUPERFUND SITE
BERKS COUNTY, PENNSYLVANIA
JUNE 20, 1989
-------
RESPONSIVENESS SUMMARY FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE BALLY GKOUNDWATER CONTAMINATION
SUPERFUND SITE
BERKS COUNTY, PENNSYLVANIA
JUNE 20, 1989
Table of Contents
I. Introduction
II. Suncnary of Ccrrmunity Relations Activities
III. Written Contents
Attachment I. Proposed Remedial Action Plan
for the Bally Superfund Site
-------
I. Introduction
The Bally Superfund Site in the Borough of Bally is located in Berks
County, Pennsylvania near the Philadelphia metropolitan area. In 1982,
the Bally Municipal Water Authority conducted a water quality check of
the Bally water system and discovered the presence of elevated concentra-
tions of chlorinated volatile organic compounds (VOCs) in Bally Municipal
Well No. 3. A survey conducted in 1983 by the Pennsylvania Department
of Environmental Resources indicated that the Bally Engineered Structures,
Inc. (BES) plant was a potential source of the VOC contamination. Bally
Municipal Well No. 3 was removed from the municipal supply system in
December 1982 as a result of the presence of VOCs.
BES signed a Consent Order in Jaunary 1987 with EPA to conduct the
Remedial Investigation and Feasibility Study (RI/FS) at this site to define
the problem and provide alternate ways to migitate the problem. Groundwater
remediation has become the focus of the remediation since no remaining
contamination source has been identified on the facility's property.
The Bally Site was placed on the Superfund National Priorities List
(NPL) in 1987.
II. Summary of Community Relations Activities
Concern about potential TCE contamination of Bally's water supply
originated in 1982 with the news of contamination of private wells in
adjacent townships. Aftert Bally oficials tested the Borough's water
supply, they confirmed the test results with DER and EPA officials and,
in January 1983, notified Bally residents of the contamination and that
well Number 3 was shut off. The information was released through local
newspapers. Borough officials also notifed residents, by use of a mobile
public address system, of a Borough meeting and advised residents to boil
water until additional sampling of the Borough's distribution system
could be completed. Approximately 40 to 50 Borough and area residents
attended an initial meeting which was succeeded by meetings the following
two weeks. Citizen concern subsided once it became clear that Well Number
3, the exposure route of the contamination, was not being used. Few
individuals attended the third public meeting.
The Proposed Remedial Action Plan was made available for comment and
review by placing an advertisement in a local newspaper in May of 1989.
A public meeting to discuss the Proposed Remedial Action Plan was also
offered to area residents. However, requests for such a meeting were
never received.
III. Written Comments
EPA did not receive written or verbal comments on the Proposed
Remedial Action Plan for the Bally Superfund Sites.
-------
APPENDIX C
ADMINISTRATIVE RECORD INDEX
-------
BALLY GROUND WATER CONTAMINATION SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
SITE IDENTIFICATION
1) Hazard Ranking System Report, prepared by NUS
Corporation, 8/29/85. P. 100002-100037. References are
listed on P. 100037.
2) Report: Preliminary Assessment and Site Inspection of
Bally Case and Cooler Company, prepared by NUS
Corporation, 9/20/85. P. 100038-100209. References are
listed on P. 100065.
* Administrative Record File available 5/19/89.
Note: Company or organizational affiliation is mentioned
only when it appears in the file.
-------
REMEDIAL ENFORCg_MENT PLANNIMr,
1)
-------
REMEDIAL RESPONSE PLANNING
I) Report: Bally Engineered Structures Plant Letter Report,
prepared by Environmental Resources Management, 2/11/86.
P. 300001-300140. References are listed on P. 300079-
300080.
2) Report: Final Evaluation Report, Evaluation of the
Hydrogeologic Investigation of the Bally Engineered
Structures, Inc. Facility, Phase II Report, prepared by
NUS Corporation, 2/87.p. 300141-300151.
3) Report: Work Plan, Scope of Work, Phase III Remedial
Investigation/Feasibility Study, Bally Engineered
Structures Site, Bally, Pennsylvania, prepared by REMCOR,
Inc., 9/23/87. P. 300152-300301. References are listed
on P. 300230-300231.
4) Report: Quality Assurance Project Management Plan-Index,
Phase III Remedial Investigation/Feasibility Study, Bally
Engineered Structures Site, Bally, Pennsylvania, prepared
by REMCOR, Inc., 9/23/87. p. 300302-300324. References
are listed on P. 300324.
5) Report: Health and Safety Plan, Phase III Remedial
Investigation/Feasibility Study, Bally Engineered
Structures Site, Bally, Pennsylvania, prepared by REMCOR,
Inc., 9/23/87. P. 300325-300407.
6) Report: Field Sampling and Analysis Plan, Phase III
Remedial Investigation/Feasibility Study, Bally
Engineered Structures Site, Bally, Pennsylvania, prepared
by REMCOR, Inc., 9/23/87.P. 300408-300497.
7) Letter to Ms. Patricia Tan, U.S. EPA, from Mr. John A.
George, REMCOR, Inc., re: Transmittal of November 1987
status report for the Remedial Investigation/Feasibility
Study, 12/8/87. P. 300498-300541. The following are
attached:
a) November 1987 monthly status report;
b) December 1987 monthly status report;
c) a letter regarding the resumption of the RI/FS
activities;
d) June 1988 monthly status report;
e) 'July 1988 monthly status report;
f) August 1988 monthly status report;
-------
g) September 1988 monthly status report;
h) October 1988 monthly status report;
i) November 1988 monthly status report;
j) December 1988 monthly status report;
k) January 1989 monthly status report;
1) April 1989 monthly status report.
8) Letter to Ms. Patricia Tan, U.S. EPA, from Mr. Dean R.
Parson, REMCOR, Inc., re: Transmittal of the Borough of
Bally, Water Well No. 3, Air Stripping System Revised
Specifications report, 1/5/88. P. 300542-300558. The
report is attached.
9) Letter to Ms. Mabel Gehman from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300559-300561.
10) Letter to Mr. Joseph Melcher from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300562-300564.
11) Letter to Reverend Ted Nace from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300565-300567.
12) Letter to Mr. Joseph Melcher, Sr. from Mr. John A.
George, REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300568-300570.
13) Letter to Mr. Carl Stofflet from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300571-300573.
14) Letter to Mr. Gene Smith from Mr. John A. George, REMCOR,
Inc., re: Evaluation of ground water contamination,
8/26/88. P. 300574-300576.
15) Letter to Mrs. Paul R. Newman from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300577-300579.
16) Letter to Ms. Lyn Moser from Mr. John A. George, REMCOR,
Inc., re: Evaluation of ground water contamination,
8/26/88. P. 300580-300582.
17) Letter to Mr. Henry Kehs, Kehs Brothers' Garage, from Mr.
John A. George, REMCOR, Inc., re: Evaluation of ground
water contamination, 8/26/88. P. 300583-300585.
-------
18) Letter to Mr, Charles Conrad from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300586-300588.
19) Letter to Mr. Richard Bauman from Mr. John A. George,
REMCOR, Inc., re: Evaluation of ground water
contamination, 8/26/88. P. 300589-300591.
20) Report: Draft Phase III Remedial Investigation Report,
Bally Engineered Structures Site/ Bally, Pennsylvania,
Volume I-Text, prepared by REMCOR, Inc., 12/88. P~.
300592-300780. References are listed on P. 300779-
300780.
21) Report: Draft Phase III Remedial Investigation Report,
Bally Engineered Structures Site, Bally, Pennsylvania,
Volume II, Appendices A through I, prepared by REMCOR,
Inc., 12/88. P. 300781-301009. References are listed on
P. 300976, 300977, 300980-300981, 300984-300985, 300989
and 300992-300993.
22) Memorandum to Mr. Jeff Orient, NUS Corporation, from Mr.
Haia Roffman, NUS Corporation, re: Comparison of REMCOR
and CLP analytical chemical results, 12/27/88. P.
301010-301047.
23) Letter to Ms. Patricia Tan, U.S. EPA, from Mr. Dean R.
Parson, REMCOR, Inc., re: Status of the Air Stripper
Startup and Performance Testing, 1/12/89. P. 301048-
301049.
24) Report: Work Plan, Additional Source Investigation,
Bally Engineered Structures Site, Bally, Pennsylvania,
prepared by REMCOR, Inc., 2/89. P. 301050-301074.
25) Letter to Ms. Patricia Tan, U.S. EPA, from Mr. Dean R.
Parson, REMCOR, Inc., re: Transmittal of the Temporary
Air Operating Permit for the Bally Air Stripping System
at Well No. 3, 3/29/89. P. 301075-301097.
26) Report: Draft Feasibility Study Report, Bally Engineered
Structures Site, Bally, Pennsylvania, prepared by REMCOR,
Inc., 5/89.P. 301098-301270.References are listed on
P. 301231-301270.
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COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1) Report: Site Analysis, Bally Case and Cooler, Bally
Pennsylvania, prepared by The Bionetics Corporation,
8/86. P. 500001-500025.
2) Report: Final Report, Community Relations Plan, Bally
Site, Bally, Pennsylvania, prepared by Booz, Allen &
Hamilton, Inc., 10/19/88. P. 500026-500049.
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
Deputy Secretary for June 29, 1989
Environmental Protection 717-787-5028
Mr. Edwin B. Erickson
Regional Administrator
USEPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
Bally Superfund Site, draft Record Of Decision (ROD)
Dear Mr. Erickson:
The draft Record Of Decision (as received June 7, 1989,
and amended by telefax June 21, 1989) for the Bally Superfund
site has been reviewed by the Department. It is my understanding
that this Record of Decision will be submitted to you for your
approval.
The proposed remedy would consist of pumping the
contaminated groundwater in municipal well #3, treating the
groundwater, and using the treated water in the Borough of Bally
potable water system as needed, while discharging any excess not
needed by the water system. Design studies would be conducted to
determine the best configuration of the overall pump and treat
system.
I hereby concur with the EPA'e proposed remedy, with
the following conditions:
* BPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DER design specific
ARARs.
* The Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
* The Department will reserve our right and
responsibility to take independent enforcement actions
pursuant to state and federal law.
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This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to* SARA
Section 104(c)(3).
Thank you for the opportunity to concur with this EPA
draft Record Of Decision. If you have any questions regarding
this matter please do not hesitate to contact me.
cere
rk M. McClellan
Deputy Secretary
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