United Su.iss -
Environitiental Prr.itn.'jjp.
Agency
Office of
Emergency and
Remedial Response
. EPA/ROO/R03-90/088
June 1990
SEPA
Superfund
Record of Decision:
Croyden TCE, PA
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DECLARATION
for the
RECORD OF DECISION
SITE NAME AND LOCATION
Croydon TCE .Site
Bristol Township, Bucks County, Pennsylvania
Ground Water Operable Unit
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Croydon TCE Site in Bucks County, Pennsylvania, selected in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and
to the extent practicable, the National Oil and Hazardous
Substances Contingency Plan (NCP). This decision is based on the
Administrative Record for this site (index attached).
The Commonwealth of Pennsylvania concurs with the selected
remedial action. A copy of the concurrence letter is attached.
ASSESSMENT OF THE SITE
•Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This ground water operable unit is the second of two operable
units planned for this site. The first operable unit involved
provision of an alternate water supply to those residents who
were not serviced by the public water supply system, and who were
dependent on ground water that was contaminated with volatile
organic compounds, primarily trichloroethene (TCE). This second
operable unit addresses the containment, treatment, and discharge
of the contaminated ground water plume. While the source(s) of
the ground water contamination have not been identified, the
objectives of the selected remedy will be to contain the further
migration of the contaminant plume while attempting to reduce
ground water contaminant levels.
The selected remedy includes the following major components:
• Construction and long-term operation of four
pumping/extraction wells located in positions to
adequately contain the migration of the contaminant
plume.
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• Treatment of the extracted ground water via air stripping,
followed by carbon adsorption as an ancillary treatment
step.
• Onsite discharge of the treated ground water to the East
Branch of Hog Run Creek.
. Ground water sampling will be conducted outside of the
TCE plume area to monitor the possible advancement of
ground water contaminants. Wells will be sampled and
analyzed for TCE, tetrachloroethene, vinyl chloride,
1,1,1-trichloroethane, 1,1-dichloroethane, and
1,1-dichloroethene.
STATUTORY DETERMINATION
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. However, because
treatment of the principal threats of the site was not found to
be practicable, the selected remedy does not satisfy the
statutory preference for treatment as a principal element of the
remedy. Because this remedy will result in hazardous substances
remaining onsite above health-based levels, a review will be
conducted within 5 years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection
of human health and the environment.
Date /Edwin B. Erockson
'Regional Administrator
Region III
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EPA/ROD/R03-90/088
Croydon TCE, PA
Second Remedial Action - Final
bstract (Continued)
The selected remedial action for this site includes ground water pumping and onsite
treatment using air stripping, followed by carbon adsorption as an ancillary treatment
step before onsite discharge of the treated ground water; vapor-phased carbon adsorption
treatment of air stripper exhaust, followed by offsite disposal or treatment of spent
carbon; implementation of institutional controls to prevent the use of contaminated
ground water during remediation; and ground water monitoring. The estimated present
worth cost for this remedial action is $1,345,000, which includes an estimated annual O&M
cost of $46,709 for 45 years (i.e., assuming that the State ARARs of remediating ground
water to background levels are to be met by extending treatment from 30 to 45 years).
PERFORMANCE STANDARDS OR GOALS: The ground water remedy is designed to contain further
migration of the plume while attempting to restore ground water to the State ARAR of
background levels, including TCE 1 ug/1 and 1,1-DCE 1 ug/1 (assuming no additional
release of contaminants to the aquifer). However, because the source of ground water
contamination has not been identified, a permanent solution may not be achieved.
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REMEDIAL ALTERNATIVE RECORD OF DECISION SUMMARY
CROYDON TCE SITE
SITE LOCATION AND DESCRIPTION
The Croydon TCE Site is located in the southernmost portion of
Bristol Township, Bucks County, Pennsylvania (see Figure 1).
Elevated levels of volatile organics, primarily trichloroethene
(TCE), are present in ground water and surface water, but the
actual source has not been determined.
Approximately 3.5 square miles in total area, the site is
bordered by Interstate 95 to the north, the Delaware River to the
south, Route 413 to the east, and Neshaminy Creek to the west.
The delineation of the study area is quite large, however this
was necessary since the source and extent of ground water
contamination was unknown, and widespread ground water
contamination was observed throughout this portion of Bucks
County. The Phase I Remedial Investigation (RI) conducted in
1988 assessed the entire study area.
Within this 3.5 square mile area is a smaller area on which the
Phase I and II remedial investigations were primarily focused.
This area, as depicted in Figure 2, is referred to as the
"focused area of investigation" and encompasses the area east of"
the Mary Devine Elementary School, west of Route 413, and north
of River Road, to just north of U.S. Route 13. The focused area
of investigation was studied extensively because (1) ground water
in this area was known to be contaminated with volatile organic
compounds, primarily elevated levels of TCE, (2) previous studies
in the local area provided data which indicated that the source
of the TCE-contaminated ground water might be located within this
area, and (3) analysis of historical aerial photographs
identified 11 potential source areas within the focused area of
investigation.
The focused area of investigation includes a portion of the
Croydon residential community and an area where several small- to
large-scale manufacturing and commercial establishments are
located. Most of the commercial establishments are located along
State Road and U.S. Route 13; the large manufacturing facilities
are located between these two roads in the southeastern portion
of the focused area of investigation.
The area outside of the focused area of investigation is mainly
residential communities, constructed in the 1940s to 1960s.
These communities include Croydon, Croydon Heights, Croydon
Acres, Maple Shade, West Bristol, Belardy, and Rockdale.
It is estimated that 2,000 to 3,000 people reside within the
study area. Land use within the study area is predominantly
single-family dwellings, and small- to large-scale industry.
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NORTHERN STUDY AREA BOUNDARY
EASTERN STUDY AREA BOUNDARY
WESTERN STUDY AREA BOUNDARY
SOUTHERN STUDY AREA BOUNDARY
LEGEND
Study Area Boundary
li'i Rohm and Haas Company Property
LQCATIO
C_ROYDON TCE SITE,
AP
,KS COUNTY, PA
QtJAUNANOlt tOCAIlON
MSC MAPS AN ENLAMSCMENT OF A PORTION OF THE USOS BtVtRll. PA • NJ QUtfl
MANGLE (75 MMUTE KNIES, 1966, PHOTOHt VIStO 1973, CONIOUfl mTlRVAL 2O FCC 11
AND A PORrON Of THE MISTQL.M-NJ QUAOMANOLE (78 MINUTE StRltS. I99S. HMO
TOdtVIStD 19*, CONTOUR MTEMMkL ZO FEET)
OOP ZOOO 3OOO 4OOO
SCALE M fTCT
FIGURE 1
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ROCKDAlfc (.)ii)
CROYOON ACHES SHAOt
POTENTIAL SOURCE
POTENTIAL SOURCE
AREA NO 1
POTENTIAL SORCE
AREA NO
*S&S&fiiu
LEGEND
5tudy Area Boundary
Rohm and Haas Company Property
Focused Area of Investigation
RESIDENTIAL AREAS
Belardy
Croydon
Croydon Acres
Croydon Heights
Maple Shade
Rockdale
West Bristol
BUILDINGS
1 Ntkoosa Packaging
2 Alpha Aromatics
3 Bristol Flare
4 Mack Warehouse
5 Coyne Chemical
1000 ZOOp 3000 4000
SCALE M FEET
GENERAL ARRANGEMENT
CROYDON TCE SITE. BUCKS COUNTY. PA
FIGURE 2
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Rohm & Haas Company is the largest employer in the area,
employing approximately 1,200 people. Most of the other
industries in the study area employ fewer than 50 people each,
for a combined total of approximately 600 people.
The geology of the Croydon TCE Site consists of unconsolidated
sand, gravel, silt, and clay deposits overlying metamorphic
bedrock. Total thickness of the unconsolidated deposits ranged
from 29 to 69 feet in the study area. Bedrock is described as
the Wissahickon Schist and is the base rock in the area. The
bedrock surface is irregular, with an overall regional slope to
the southeast.
The site is located in the Delaware River Basin. On a regional
and local basis, the Delaware River is the local discharge point
for both ground water and surface water. Portions of the study
area which are near to Neshaminy Creek and the Delaware River are
within the boundary of the 100-year floodplain; however, the
focused area of investigation is not within this boundary.
Ground water occurs in both the unconsolidated deposits and in
the underlying bedrock. Within the study area, ground water was
encountered at a depth of approximately 9 feet in the
unconsolidated deposits. The two flow systems are not
interconnected in the study area due to the presence of local
clay layers and a substantial thickness of weathered bedrock
(saprolite), which inhibit the movement of ground water between
formations. Ground water elevations in the underlying bedrock
aquifer are dependent on the depth of the saprolite layer between
the two flow systems. In the vicinity of the site, the
unconsolidated deposits are a source of domestic and industrial
ground water supply. The bedrock ground water flow system is of
minor importance to ground water supply in the vicinity of the
site due to poor yield and the availability of ground water in
the unconsolidated deposits.
Hog Run Creek and its tributaries (i.e., East Branch and West
Branch) are located within the focused area of investigation.
The tributaries emanate in the area between State Road and River
Road and form Hog Run Creek just north of River Road. Hog Run
Creek then flows southward and discharges into the Delaware
River.
A larger stream, Neshaminy Creek, also discharges into the
Delaware River. This stream constitutes the western border of
the study area. Neshaminy State Park, which attracts over
750,000 visitors annually, is located at the confluence of
Neshaminy Creek and the Delaware River.
A large variety of plant and animal species are found throughout
the study area. Areas providing habitat include open fields,
open water, woods, and freshwater tidal marshes. Open fields can
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be found between Bristol Lanes and Hartwell Trucking (along
Route 13) and along River Road. The largest wooded area is
situated between State Road and River Road near Hog Run Creek and
its tributaries. Tidal marshes are present along the Delaware
River. The Delaware River, Neshaminy Creek, and Hog Run Creek
provide open water for aquatic species and migratory birds. Five
wetland areas, ranging in size from 0.2 acres to 6 acres are
situated between State Road and River Road within the focused
area of investigation. No endangered or threatened species of
plant or animal life are known to be present in the study area.
As mentioned previously, 11 potential source areas, depicted in
Figure 3, were identified within the focused area of
investigation by the EPA Environmental Photographic
Interpretation Center (EPIC) through analysis of historical
photographs. All 11 potential source areas were studied during
the Phase I RI; 4 of the 11 (Nos. 1, 3b, 6, and 7) were studied
further during the Phase II RI as warranted by the findings of
the Phase I RI. The remaining 7 potential source areas were
ruled out as potential contamination sources by the findings of
the Phase I RI.
An industrial landfill owned by Rohm & Haas Company is located
south of River Road. This landfill which was operated from 1952
to 1975, is being studied by the Rohm & Haas Company under a
Resource Conservation and Recovery Act (RCRA) corrective action -
order. Based on the findings of the Phase I RI, the landfill has
been ruled out as the source of the TCE contamination in the
Croydon community.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Croydon TCE Site was identified by EPA after a remedial
investigation of the Rohm & Haas Site in Bristol Township which
forms part of the southern boundary of the Croydon TCE Site. In
1983, Rohm & Haas conducted studies of its Bristol Township
property, including the landfill, and released two reports:
Report on Landfill Investigation. April 1984. and Landfill
Investigation. February 1985. Based on these reports, EPA
proposed the Rohm & Haas Site for the National Priorities List
(NPL) in April 1985, thereby identifying the site for long-term
remedial action under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA). After the RI of the
Rohm & Haas Site, the site was reassigned to the RCRA program
because the Rohm & Haas plant manages hazardous waste and is
actively operating. As mentioned above, Rohm & Haas is currently
investigating its industrial landfill, pursuant to a RCRA
corrective action.
Rohm & Haas prepared 26 reports, which were compiled into
1 report entitled Landfill Remedial Investigation Report
Addendum. March 1988. Of most interest was the Report on TCE in
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Ground Water in the Vicinity of River Road. Bristol Township.
March 1986. which suggested that a plume of TCE was emanating
north of the Rohm & Haas property. EPA reviewed the report and
concurred with Rohm & Haas1 conclusion. Due to the uncertainty
that many of the businesses in the area might use products
containing TCE, EPA determined that a separate Remedial
Investigation/Feasibility Study (RI/FS) was necessary to
characterize the nature and extent of contamination, assess the
public health and environmental risks associated with the
contamination, and identify potential remedial alternatives.
In April 1985, a Hazard Ranking Score (HRS) of 31.60 was
calculated for the Croydon TCE Site based on studies conducted
primarily within the focused area of investigation. In
September 1985, the Croydon TCE Site was listed on the NPL.
A potential responsible party (PRP) search of commercial and
industrial facilities in the study area was conducted by Tech Law
in May of 1986 for EPA. PRP searches are conducted to assist EPA
in identifying owners/operators, transporters or generators who
may have contributed to site contamination. Based on information
gathered during the PRP search, CERCLA 104(e) information request
letters were sent by EPA to area businesses that have used
chemicals during past and present operations which may have
contributed to area ground water contamination. Based on the
responses to these information requests letters, EPA issued one
General Notice Letter.
In August 1987, a Final Phase I RI/FS Work Plan was prepared by
EPA's contractor, Ebasco Services, Incorporated. The Phase I
field investigations began in September 1987. The findings of
those field investigations and risk assessments were summarized
in the final Phase I RI, which together with the Phase II RI/FS
Work Plan, was submitted to EPA in August 1988. Because the
ground water was contaminated with TCE above health-based and
risk-based levels, a Focused FS was begun to identify response
actions for an alternate water supply for those Croydon residents
whose sole potable supply was contaminated ground water. A
Record of Decision (ROD) was signed by EPA in December 1988,
which resulted in providing public water to 11 residents within
the identified ground water contaminant plume area.
The Phase II RI was conducted from September 1988 to October
1989. A Final Phase II RI Report was submitted to EPA by Ebasco
Services, Incorporated in January 1990. Although numerous
studies were conducted throughout the focused area of
investigation during the Phase II RI in order to locate the
source of TCE ground water contamination, no source could be
positively confirmed ,however the ground water plume boundary was
well defined. In January 1990, a Final FS was submitted to EPA
which identified alternatives for remediating the ground water
contamination at the site. This ROD identifies the response
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action for addressing the ground water contamination at the
Croydon TCE Site..
COMMUNITY RELATIONS
A Community Relations Plan (CRP) was prepared to identify the
concerns of local residents and government officials regarding
the Croydon TCE Site. The primary goals of the CRP are to
establish and maintain open communication among federal, state,
and local officials and Croydon residents. Several activities,
described in the Final CRP, were conducted to meet these goals.
These activities included'the following:
• Onsite and telephone interviews with local residents in
June and July 1987.
. Preparation of a fact sheet for the August 1987 public
meeting.
• A public meeting at the Bristol Township Municipal Building
in August 1987 was held to discuss the Phase I RI/FS
Work Plan.
• Distribution of more than 450 well-survey questionnaires,
which requested such information as whether the household
operated a domestic well, and if so, the uses of the well
water.
• A public meeting at the Bristol Township Municipal Building
in December 1988 to hear comments on the proposed alternate
water supply remedial action. Local residents and
officials offered no criticism.
. A public meeting at the Bristol Township Municipal Building
in May of 1990 to hear comments on the proposed ground
water remedial action. Comments and questions by local
residents and officials are presented in the Responsiveness
Summary section of this ROD.
Although most of the residents continue to express a great deal
of concern regarding the Rohm & Haas Site, none of the residents
contacted during the onsite interviews were aware of the Croydon
TCE Site. Public awareness of the Croydon TCE Site was minimal
(prior to the Phase I RI/FS). However, during the course of the
Croydon TCE Site Phase I RI/FS, the community became more aware
that a separate investigation was being conducted to study other
sources that might be the cause of the TCE ground water problem.
The EPA Community Relations Coordinator had met with various
officials of the Mary Devine Elementary School during the fall of
1988, to update them on the Croydon TCE Site and address their
concerns about nearby monitoring wells and soil sampling
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activities. The school officials requested that they be included
on EPA's mailing -list.
In response to concerns raised by Croydon residents regarding the
quality of the public water supply during the December 1988
public meeting, EPA sampled three households connected to the
public water supply system. The analytical results were reviewed
by an EPA toxicologist and were found to be in compliance with
state and federal drinking water standards.
In summary, the community is concerned with environmental
contamination and the associated potential risks. Most citizens'
homes are connected to the public water supply system, thereby
diminishing some of the concern to area residents.
SCOPE AND RQT.F OF RESPONSE ACTION
This ROD addresses the second of two operable units at the site.
The first operable unit addressed an alternate water supply. A
ROD for the alternative water supply operable unit was signed in
December 1988.
This operable unit addresses ground water that is contaminated
with volatile organic compounds, primarily TCE in the community
of Croydon, Pennsylvania. The contaminated ground water is a
principal threat at this site because of the direct ingestion of '
drinking water from wells that contain TCE and other volatiles
above health-based and risk-based levels. Although public water
is currently being provided to the affected Croydon residents,
future use of the aquifer is in jeopardy if no action is taken.
In addition, because the aquifer is classified under the Ground
Water Protection Strategy as Class Ila, some action is required
to reduce the level of contamination to acceptable levels. The
purpose of this response is to contain the migration of the
ground water plume while attempting to reduce ground water
contaminant levels. If the source or sources of the ground water
contamination is depleted and only residual levels remain in the
subsurface, the cleanup goals (which are identified later in this
ROD) may be achieved within 30 years following implementation of
the alternative.
SUMMARY OF SITE CHARACTERISTICS
The Phase I RI/FS included a hydrogeologic investigation, a
residential well survey and sampling program, a surface water and
sediment investigation, and a limited amount of surface soil
sampling.
The findings of the Phase I field investigations are summarized
below.
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Hydroqeoloaic Investigation
The hydrogeologic investigation involved the sampling of 46 wells
located such that EPA was able to evaluate the impact of the
potential source areas on the ground water in both the shallow
(approximately 20 feet) and deep (approximately 55 feet) portions
of the unconsolidated aquifer. All samples were analyzed for
Target Compound List (TCL) volatile organics. As a precaution,
10 samples were analyzed for base/neutral and acid extractable
organics, target analyte list (TAL) inorganics, and selected
geochemical parameters (e.g., sulfate, alkalinity).
The primary ground water contaminants are volatile organics,
predominantly TCE. 1,1-dichloroethene, a chemical which results
from the biological transformation of TCE, was also detected in
excess of health-based criteria in a limited number of wells and
often in the same well where TCE was detected.
The TCE ground water plume appears to originate from one or two
potential source areas located north of U.S. Route 13. The plume
is migrating in a south-southeast direction, based on data
collected from static water levels in the wells. The highest
concentrations of TCE were observed in wells located between
State Road and River Road, specifically in the area where ground
water discharges into the East Branch of Hog Run Creek. Although
no Rohm & Haas monitoring wells located south of River Road were'
sampled as part of the Phase I RI, the TCE plume has probably
migrated into the Delaware River since this body of water is the
ultimate discharge point for all regional ground water and
surface water. Studies conducted by Rohm & Haas indicate the
presence of TCE in monitoring wells located near River Road by
Manufacturing Area B and near the confluence of Hog Run Creek and
the Delaware River.
Residential Well Investigation
As mentioned previously, more than 450 questionnaires were
distributed to study area residents. Subsequently, forty
residential wells were sampled and analyzed for TCL volatile
organics. Some residential well samples were also analyzed for
TCL base neutral and acid extractable organics, TAL inorganics,
and geochemical parameters.
Residential well sampling data corroborated the results of the
hydrogeologic investigation: residential well samples collected
in areas where TCE was detected during the hydrogeologic
investigation also exhibited elevated levels of TCE. Consistent
with the hydrogeological data, residential wells located north of
the focused area of investigation and west of Harris Avenue
(south of"U.S. Route 13) to Neshaminy Creek did not exhibit
elevated levels of TCE.
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Surface Water
Surface water samples were collected from Hog Run Creek and its
tributaries (East and West Branches), Neshaminy Creek, and the
Delaware River and analyzed for TCL organics and inorganics. TCE
(maximum concentration of 6.1 micrograms per liter (ug/1)) and
1,1,1-trichlorethene (maximum concentration of 2.3 ug/1) were
detected in the East Branch of Hog Run Creek and Hog Run Creek.
These two contaminants are the only potential contaminants of
concern. No organic contamination was detected in Neshaminy
Creek, the Delaware River, or the West Branch of Hog Run Creek.
Inorganic constituents were detected in surface water at levels
comparable to background levels.
The presence of TCE and 1,1,1-trichloroethene in the surface
water appears to be a result of ground water discharge. The East
Branch of Hog Run Creek is located in the area where the highest
concentrations of TCE and related constituents were detected in
ground water. The West Branch of Hog Run Creek is situated in an
area where no ground water contamination was detected; the West
Branch of Hog Run Creek did not exhibit organic contamination.
Sediment
Sediment samples were collected from the same locations as the
surface water samples. Inorganic constituents detected in the
sediments were present at or below site background levels with
the exception of metals of copper, lead, manganese, nickel, zinc,
and cyanide. These metals were present at levels within the
regional soil background ranges. Thus, no inorganic constituents
were identified as potential contaminants of concern.
The primary organic contaminants in the sediments were the
carcinogenic polynuclear aromatic hydrocarbons (PAHs). PAHs were
detected in Neshaminy Creek, Hog Run Creek, and the East Branch
of Hog Run Creek but not in background samples collected from
Neshaminy Creek north of Interstate 95. PAHs were identified as
chemicals of potential concern because of their carcinogenic risk
factor. It should be noted, however, that PAHs are commonly
found in industrial or urban areas; typical sources of PAHs
include automobile or boat exhausts, fireplace exhausts, and open
burning. Neshaminy Creek exhibited the highest levels of PAHs,
due possibly to the numerous boats which use this creek. PAHs
were also detected in Hog Run Creek and the East Branch of Hog
Run Creek, possibly due to surface runoff from the roadways. No
PAH compounds were detected in the surface waters, as expected
because PAHs are not readily soluble in water, but tend to
accumulate in sediment.
Two volatile organic contaminants, toluene and 1,2-
dichloroethene, (maximum detection of 6 micrograms per kilogram
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(ug/kg) and 17 ug/kg respectively) were detected in sediment
samples collected from Hog Run Creek and the East Branch of Hog
Run Creek, possibly due to migration of contaminants from ground
water discharge. The absence of toluene and 1,2-dichloroethene
from surface water may be due to volatilization into air or from
the dilution effect of the surface water.
Soil
Soil samples were collected from the ball field adjacent to the
Mary Devine Elementary School, an area near River Road across
from Rohm & Haas' Manufacturing Area B, and residential property
along River Road. Material from the Rohm & Haas Landfill was
allegedly disposed of in these three areas. Potential
contaminants of concern in soils (polychlorinated biphenyls
(PCBs), Arochlor 1242, Arochlor 1016, and PAHs) were detected in
all three sampling areas. The source of the PCBs is unknown;
possible sources of PAHs may be surface runoff from roadways,
automobile or dirt bike exhausts, or open fires. Concentration
of the PAHs in soils is higher than that detected in the
sediments.
Because the inorganic compounds present in surface soils were at
or below regional background concentration levels, no inorganic
compounds were selected as chemicals of potential concern.
As discussed above, the Phase I RI identified a TCE ground water
plume emanating from an area north of U.S. Route 13. Two
potential source areas were identified: Hartwell Trucking
Company and adjacent property (No. 1); and the Sherwood
Refinishing shop (No. 3b). Two EPA historical aerial studies
identified two different source areas as "No. 3." Specifically,
the second study designated as "No. 3" a tract which includes the
Sherwood Refinishing Shop. For clarity in this ROD, this tract
is designated "No. 3b."
Two other potential source areas, Nos. 6 and 7, were also
investigated during the Phase II RI because of the highest levels
of TCE ground water contamination were detected in their vicinity
(along River Road across from Rohm & Haas Manufacturing Area B).
A warehouse is located at Potential Source Area No. 6 and a
car/truck repair facility is located at Potential Source Area
No. 7. Photographs from 1940 to 1978 depict features such as
standing liquids and stained soils, which may be associated with
waste disposal. These features are no longer visible.
Another possible source of TCE contamination considered by EPA
was (industrial) solvent disposal into sanitary sewer lines. The
similarity of the configuration and flow patterns of the sewer
lines along U.S. Route 13 and in the Croydon residential area to
the pattern of TCE ground water contamination, suggested that
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leaking sewer lines could be a potential source of TCE
contamination.
Phase II RI objectives were developed following the evaluation of
the Phase I data. The Phase II objectives were to:
•Investigate Potential Source Areas No. 1 and No. 3b to
determine whether they are the source of the TCE ground
water contamination.
• Investigate Potential Source Areas No. 6 and 7 to determine
if they are contributing to the ground water contamination
between the East Branch of Hog Run Creek and River Road,
where some of the highest levels of TCE were observed in
the ground water.
• Define the northern boundary of the TCE ground water plume.
• Determine whether the sewer lines along U.S. Route 13 are
contaminated with TCE.
• Characterize the hydrogeology of the focused area of
investigation.
• Confirm public health risks posed by the use of ground
water within the study area.
• Confirm the presence or absence of PCBs in the three
alleged dumping areas.
• Define the nature and extent of contamination in the
Delaware River and the unnamed stream located north of
U.S. Route 13.
The Phase II field investigations and findings are summarized
below.
Hydrogeologic Investigation - The Phase II hydrogeologic
investigation consisted of the installation of nine monitoring
wells to further delineate the upper boundary of the ground water
plume and to assess Potential Source Areas No. 1 and No. 3b.
Ground water samples were collected from 52 monitoring wells to
further characterize the plume boundary. Monitoring wells
installed downgradient of Potential Source Areas No. 1 and No. 3b
exhibited comparatively low levels of TCE; such low levels
suggest that these areas may not be current sources of ground
water contamination. This conclusion is supported by the fact
that there is no appreciable contamination in the soils taken
from these two areas. Table 1 provides the results of both
Phase I and Phase II ground water sampling.
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The boundary of the plume is described as follows: The northern
boundary of the plume appears to have migrated from an area just
north of U.S. Route 13. (Wells located one block north of
U.S. Route 13 were not contaminated.) The southern boundary of
the plume is just south of River Road. The eastern boundary is
to the west of Route 413 and the western boundary is to the east
of the ball field area. The highest levels of TCE (approximately
420 ug/1) were detected in the deeper monitoring wells, which
monitor the bottom portion of the unconsolidated aquifer. The
entire plume may consist of several separate ground water plumes
(from separate sources) as evidenced by localized areas of high
contamination within the entire 1.5-square-mile contaminated
ground water plume. Figures 3 and 4 are isoconcentration maps
of TCE concentrations detected in the shallow and deep monitoring
wells, respectively.
The occurrence and distribution of TCE contamination within the
study area does not pinpoint any obvious source of ground water
contamination. Potential sources of contamination other than the
potential source areas discussed thus far may include leaking
septic tanks and/or random spills (i.e., midnight dumping) in the
wooded portions of the study area between State Road and River
Road. The relatively low levels of TCE may also reflect a past
unidentifiable chemical spill or release.
Residential Well Investigation - In order to confirm the Phase I "
sampling results, seven residential wells were resampled and
analyzed for TCL organics. The seven wells either exhibited
elevated levels of TCE during the Phase I RI which indicated that
they were located within the ground water plume, or exhibited low
levels of TCE which indicated that they were located at the edge
of the ground water plume. Table 2 summarizes these results.
Surface Water and Sediment Investigation - This investigation
consisted of sampling and analysis of the Delaware River, an
intermittent stream north of Potential Source Area No. 1, Hog Run
Creek upstream from its discharge into the Delaware River, and a
small intermittent stream which discharges into the East Branch
of Hog Run Creek. These stations could not be sampled during the
Phase I RI.
The analytical results indicate that the most significant surface
water contamination is in the East Branch of Hog Run Creek where
TCE was detected at approximately 6 ug/1. The contamination in
Hog Run Creek upstream from its discharge into the Delaware River
is only 0.4 ug/1. The source of the contamination in the East
Branch appears to be ground water. The East Branch is located in
the center of the contaminated ground water zone.
13
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ISOCpNCfNIHATION CUNTUUN
CONTOUR INTERVAL IS LOGARITHMIC
NOT DETECTED
ISOCONCENTRAT1QN MAP OF TCE IN THE SHALLOW Mi QRING WELLS
CROYDQN TCE SITE. BUCKS COUNTY. PA
FIGURE 3
SCAIC IN FEET •
-------
VK'.I
\ BRISTOL
CRUrtlON ACHES
I
\j
-
\\\
V v
\A
va ^
x-^
x\ \
v v .
\ '\l
^
s- • \
- CB»* 10-4
„• '' «*«» «P Df>*« '' m • *
aolg.-*' ""^ - *NO TlO
A< S- " u a»« n-D c»»
i- *ND
^~ a-\»-i>
^•^
V*£-<"
;•'
c>
\ \\\
Ji riH
;/ I \;
^ rf
^
>*
Hv
,^
L£GEND
•cn-iOk-n MONITORING VCLL LOCATION AND NUMUt K ANIi
<10 tCt CONCENTRATIONS IN ffU
,„ ISOCONCtNTRAnON CONTOUR
CONTOUR INTERVAL IS LOGARITHMIC
NO NUT OCTtCTEO
THE TCI CONCENTRATIONS ARE AN AVERAGE (.» HIIAU I ANI< CMA'A II HI Mil !•_,.
TCE CONCENTRATIONS FOR ROHM AND HAAS KKLLS '.Oil III (It 1'iAK KUAIi wl Rt
OBTAINEO FROM. TCC IN GKOUNDWAIFR IN THE VIQNIlr ut HivtN ROAD
TOWNSHIP. PCNNStWAMA. MARCH l»86. BCM
FIGURE 4
MAP QF TCE IN Ttig DEEP MONITORING WELLS
mi INK, PA
-------
TABLE 1
TCE CONCENTRATIONS IN GROUNDWATER
PHASE I AND PHASE II RESULTS
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
Monitoring Well/
Residential Well
CR-1-22
CR-1-50
CR-18-30
CR-18-55
CR-19-15
CR-19-37
CR-21-17
CR-21-27
CR-21-35
CR-23-32
CR-23-53
CR-24-15
CR-24-7
CR-25-13
CR-25-34
CR-26-19
CR-26-38
CR-27-18
CR-27-38
LP-13-18
LF-13-43
LF-14-20
LF-15-26
LF-15-37
TCE Concentration (ug/1)
Phase I
NS
NS
6.8
44
22
180
' NS
NS
NS
4.0
15
ND
81
NS
NS
NS
300
ND
ND
1.6
3.2
ND
ND
ND
Phase II
ND
ND
10
15.5
18.6
62.8
123.1
144.0
52.4
2.9
11.1
ND
55.0
10.4
23.2
10.1
424.4
ND
ND
32.7
76.9
ND
ND
ND
16
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TABLE 1
TCE CONCENTRATIONS IN GROUNDWATER
PHASE I AND PHASE II RESULTS
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
PAGE TWO
Monitoring Well/
Residential Well
MW1-D
MW1-S
MW2-D
MW2-S
MW3-D
MW3-S
MW4-D
MW4-S
MW5-D
MW5-S
MW6-D
MW6-S
MW7-D
MW7-S
MW8-D
MW8-S
MW9-D
MW9-S
MW10-D
MW11-D
MW11-S
MW12-D
JW12-S
TCE Concentration (ug/1)
Phase I
0.6
1.7
ND
ND
ND
ND
0.3
0.2
80
0.5
14.3
2.3
ND
0.1
220
1.2
ND
ND
ND
ND
ND
ND
ND
Phase II
ND
ND
ND
ND
ND
ND
ND
ND
48.5
1.0
9.8
2.2
19.9
ND
128.3
0.6
ND
ND
ND
ND
ND
ND
ND
17
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TABLE 1
TCE CONCENTRATIONS IN GROUNDWATER
PHASE I AND PHASE II RESULTS
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
PAGE THREE
Monitoring Well/
Residential Well
MW13-D
MW13-S
MW14-D
MW14-S
MW15-D
MW15-S
MW16-D
MW16-S
MW17-D
MW17-S
MW18-D
MW18-S
MW19-S
MW20-D
MW20-S
TCE Concentration (yg/1)
Phase I
ND
0.2
ND
ND
420
320
Phase II
ND
NS
ND
ND
424
403
ND
ND
ND
ND
ND
ND
9.6
1.4
ND
NS: Not sampled
ND: Not detected above instrument detection level
: Well was constructed during Phase II RI
18
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TABLE 2
TCE CONCENTRATIONS IN GROUNDWATER
PHASE I AND PHASE II RESULTS
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
Monitoring Well/
Residential Well
RW1
RW2
RW21
RW25
RW26
RW32
RW34
TCE Concentration (ug/1)
Phase I
60.9
0.94
97
20.2
11.7
5.3
12.3
Phase II
62.3
1.0
150.7
10.7
4.6
1.8
18.6
19
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Phase II sediment analyses did not detect any volatile
contamination. However, one sample collected from the
intermittent stream was contaminated with low levels of PAHs
(less than 20 milligrams per kilogram (mg/kg) total PAHs),
possibly due to runoff from local roads. Table 3 summarizes the
findings of the Phase I and II surface water investigations.
Surface Soil Investigation - Three suspected dumping areas were
resampled in order to confirm the presence of low levels of PCBs
(less than 1 mg/kg), which were detected during the Phase I RI.
Additionally, background samples and samples from the Rohm & Haas
landfill, the alleged source area, were collected. The
resampling detected no PCBs in the three suspected dumping areas.
Pesticides and PAHs were detected, but background samples also
exhibited these contaminants to a lesser degree. The presence of
pesticides (less than 0.5 mg/kg) most likely results from past
mosquito control measures undertaken in the study area. PAHs,
common in urban settings such as this, may derive from open
burning, the decomposition of organic matter, or roadway surface
runoff.
Source Investigation (Potential Source Areas No. 1 and No. 3b) -
A soil gas survey was carried out at Potential Source Areas No. 1
and No. 3b. After evaluating the soil gas data, test borings
were drilled in areas in which TCE contamination was suspected.
Samples collected from the test borings were analyzed for TCL
organics and TAL inorganics. Six surface samples were also
collected from Potential Source Area No. 3b to determine whether
hazardous substances had been spilled on the ground surface, as
reported by a local resident.
Contamination at Potential Source Area No. 1 is limited to a
small area behind the garage of Hartwell Trucking Company.
Elevated levels of TCE (25 mg/kg maximum) were detected in only
1 of the 7 boreholes. Because the soil contamination is above
the water table and ground water near this borehole is not
contaminated, it does not appear that the soil contamination
present within this area is responsible for the ground water
problem in the study area. However, if this area of soil
contamination is not removed or treated, it may eventually
contribute to the ground water contamination. The Pennsylvania
Department of Environmental Resources (PADER) has been notified
of this matter.
No significant surface or subsurface contamination was detected
at Potential Source Area No. 3b. Although low levels of
tetrachloroethene (PCE) (15 ug/kg maximum) were detected in
surface soils, and samples obtained from a monitoring well
adjacent to the Sherwood Refinishing Shop detected TCE
concentrations of 9 ug/1, it is unlikely that these levels are
responsible for the TCE ground water problem which encompasses an
area of approximately 1.5 square miles.
20
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TABLE 3
~TCE CONCENTRATIONS IN STUDY AREA
SURFACE WATERS
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
Sample
Number
SW-01
SW-02
SW-03
SW-04
SW-05
SW-06
SW-07
SW-08
SW-09
SW-10
SW-11
SW-12
SW-13
SW-14
SW-15
SW-16
SW-17
SW-18
SW-19
SW-20
SW-21
Sample Location
Neshaminy Creek - upstream of study area
Neshaminy Creek - adjacent to study area
(north)
Neshaminy Creek - near docks
Neshaminy Creek - adjacent to study area
(south)
Neshaminy Creek - near confluence with
Delaware River
Delaware River - upstream
Delaware River - near Rohm & Haas Landfill
Delaware River - downstream of confluence
with Hog Run Creek
Delaware River - upstream of confluence
with Neshaminy Creek
West Branch of Hog Run Creek
East Branch of Hog Run Creek (upstream)
East Branch of Hog Run Creek (downstream)
Hog Run Creek (upstream)
Hog Run Creek (adjacent to Rohm & Haas
Landfill)
Pond behind VFW building (eastern bank)
Pond behind VFW building (western bank)
Intermittent stream in Rockdale
Intermittent stream draining into the East
Branch of Hog Run Creek
Intermittent stream near Potential Source
Area No. 1 (eastern portion of stream)
Intermittent stream near Potential Source
Area No. 1 (western portion)
Hog Run Creek prior to discharge into the
Delaware River
Concentration
(yg/D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.1
5.5
2.3
2.4
2.4
N.S
ND
ND
ND
0.4
ND Denotes not detected above analytical instrument detection
levels.
NS Denotes not sampled due to lack of water.
21
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Source Investigation (Potential Source Areas No.6 and No. 7) -
The EPA Environmental Response Team augered 20 soil borings
(approximately 40 to 50 feet deep) at or around Potential Source
Areas 6 and 7 which are located upgradient from the ground water
plume, where some of the highest levels of TCE were observed. A
total of 118 soil and 8 ground water samples were collected and
screened for volatile organics. A full gas chromatograph/mass
spectrophotometer (GC/MS) analysis was performed on 96 of these
samples for confirmatory purposes.
Potential Source Area No. 6 exhibited some soil and ground water
contamination. Low levels of TCE (less than 0.1 milligrams per
liter (mg/1)) were detected in soil samples collected from
boreholes located on the property of No. 6 or southwest of the
property. Samples collected from the mid- to bottom-portions of
the boreholes exhibited higher levels of TCE soil contamination.
This may suggest that the spill occurred several years ago,
especially since the levels of TCE contamination in the soil are
generally very low. Elevated levels of TCE (359 ug/1, maximum)
were observed in ground water samples collected from Borehole
Nos. 3 and 5, which are located just southwest of this potential
source area. It is uncertain whether the elevated levels of TCE
ground water contamination in the area near River Road can be
attributed to the contamination in Potential Source Area No. 6.
Although the boundary of the plume is rather well defined, the
source(s) of ground water contamination could not be identified
conclusively. The occurrence and distribution of TCE
contamination does not pinpoint any obvious source of
contamination. The entire area of ground water contamination may
consist of several separate ground water plumes as evidenced by
localized areas of significant contamination. Contamination may
be emanating from any of the following areas:
• Near Girard or Elm Avenue where small auto repair shops are
located - Residential wells in this area have exhibited
elevated levels of TCE.
• In the wooded area between State Road and River Road -
Monitoring wells CR-26-38 (424 ug/1) and CR-24-7 (55 ug/1)
in this area have exhibited TCE.
• Near Sherwood Refinishing (along U.S. Route 13) -
Monitoring wells and a residential well in this area have
exhibited TCE (18 ug/1, maximum).
Potential Source Areas No. 1 and No. 3b, which were thought to be
sources of ground water contamination after completion of the
Phase I RI, do not appear to be contributing to the ground water
contamination.
22
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The contaminants within the soil might eventually infiltrate the
water table and impact the quality of ground water near Hartwell
Trucking Company; At present, soil contaminated in Potential
Source Area No.l is above the water table and the ground water is
not affected.
The relatively low levels (less than 0.5 mg/1 maximum) of TCE
contamination in the ground water may suggest that the initial
release of TCE occurred many years ago and is essentially
unidentifiable today. It is also possible that the releases may
have occurred in more than one area of the site; the presence of
"mini plumes" (areas of comparatively high levels of TCE) within
the entire contaminated ground water zone supports this theory.
Sanitary Sewer Line Investigation - Six sewage samples from
various locations along U.S. Route 13 and adjoining streets were
collected to determine whether solvents were being disposed of
into the sanitary sewer lines from local businesses and analyzed
for TCE volatile organics.
TCE was not detected, however, low levels of 1,1,1-
trichloroethene (4 ug/1) and xylene (4 ug/1) were observed at two
locations. It is unlikely that ground water contamination at the
site is attributable to the contamination of the sewer lines.
SUMMARY OF SITE RISKS
if
Human Health Risks
A base-line risk assessment was conducted using the data
collected during the Phase I and Phase II RIs in accordance with
the guidelines of the Superfund Health Evaluation Manual (EPA,
1986) . Assumptions and calculations for potential adverse public
health impacts posed by the presence of contaminants at the site
are presented in Section 6 and Appendix G of the January 1990
Remedial Investigation Report for the Croydon TCE Site.
Household occupants located within the area of the TCE plume
would be at risk if not connected to the public water supply
system. Exposure pathways are ground water ingestion, inhalation
of contaminants volatilized from ground water household use
(i.e., showering or cooking), and dermal absorption of
contaminants while bathing were found to be 2.0xlO"3 for the
plausible maximum risk level and 2.5xlO"4 for the average risk
level which is above the EPA excess lifetime cancer risk. Excess
lifetime cancer risks are determined by multiplying the intake
level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific
notation(e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk
of IxlO'6 indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-
23
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year lifetime under the specific exposure conditions at a site.
Table 4 outlines the average and plausible maximum risk levels
(i.e., worst-case) for these exposure pathways.
Households that are located west or north of the TCE plume are
not at risk because the plume is migrating in a south-southeast
direction. No contamination was detected in residential wells
along streets located north of the plume (High Street, Maple and
Garfield Avenues). Samples collected from residential wells
along streets located west of the plume (Linton, Emily, Keystone,
and Summit Avenues) also did not indicate the presence of TCE or
other volatiles at elevated levels (<1 ug/1).
There are no households located east or south of the plume within
the study area.
Based on analyses of surface waters, sediments, and surface soils
within the study area, exposures to these media by children or
adults do not suggest the potential for adverse noncarcinogenic
health risks. As shown on Table 4, incremental cancer risks
calculated for several exposure routes to these same media are
below or slightly higher than the lower EPA target risk of 10 .
Environmental Risks
Although little site-related contamination was detected in study
area surface waters, plants and animals may be exposed in the
future to chemicals of potential concern in the surface waters of
the Croydon TCE Site because surface water contamination has been
identified in Hog Run Creek and the East Branch of Hog Run Creek.
Aquatic species in the Delaware River are also potential
receptors of contaminants from Hog Run Creek. Potential impacts
on these species are likely to be negligible because of the low
concentrations of volatiles detected in study area surface
waters. In addition, concentrations of contaminants reaching the
Delaware River will be reduced significantly by dispersion,
volatilization, and dilution within the River. This was verified
by the Phase II sample analyses in which no organics were
detected in the Delaware River.
Terrestrial species are not likely to be receptors at the site,
because few species are found in the areas of soil contamination
due to the area's industrial and residential development. Those
terrestrial species which inhabit the wooded areas around Hog Run
Creek may be exposed to chemicals of potential concern detected
in the surface water. Exposure to these chemicals via
biomagnification in the food chain is unlikely, due to the
extremely low levels of detected surface water contaminants.
PAHs were detected in site sediment samples. The maximum PAH
concentrations were detected in the intermittent stream behind
24
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TABLE 4
COMPARISON OF CARCINOGENIC RISKS
PHASE I AND PHASE II
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
Exposure Scenario
Domestic Use of
Groundvater (Inhalation
and Ingestion)
Dermal Contact to Soils
Accidental Ingestion of
Soils
Dermal Contact to
Sediments
Exposure to Surface
Waters (Dermal and
Accidental Ingestion)
Phase I
Worst
Case
2.2 x 10-3
3.4 x 10-6
9.9 x ID'7
3.1 x 10-8
MA
Average
Case
7.4 x 10-5
5.0 x 10-8
7.5 x 10-9
2.1 x 10-9
NA
. Phase II
Worst
Case
2.0 x 10"3
8.8 x 10'7
1.2 x 10"6
4.7 x 10'7
9.9 x 10-11
Average Case
2.5 x 10-*
1.8 x 10-8
3.5 x 10-8
6.8 x 10-8
1.5 x 10-11
NA - Not assessed due to an incomplete data base.
25
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Hartwell Trucking and along the Neshaminy Creek near State Road
at 3,700 and 3,OOO ug/kg, respectively. The ubiquitous nature
of PAHs prevents linking PAHs specifically to activities by any
particular industry within the study area. Moreover, the
concentrations of PAHs detected in study area sediment samples
are within the range of sediment concentrations believed to be
associated with no or minimal biological effects, as reported by
Chapman et al. (1987). Therefore, the sediment PAH
concentrations observed at the Croydon TCE Site are unlikely to
adversely impact aquatic life.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health and the environment.
DESCRIPTION OF ALTERNATIVES
Remedial alternatives were developed during the FS for the ground
water operable unit. With the exception of the "no action"
alternative, which is always considered as a baseline for
comparison against other alternatives, the development of
alternatives was based on the results of the risk assessment, and
applicable and relevant or appropriate requirements (ARARs). The
proposed alternatives focused on (1) preventing migration of
contaminants in ground water, (2) reducing the concentration of
contaminants to acceptable levels, and (3) preventing exposure to
ground water via institutional controls.
Listed below are the alternatives that were considered for
remediating the ground water plume at the Croydon TCE Site. The
description of these alternatives follows.
• Alternative No. 1: No action.
• Alternative No. 2: Ground water containment, physical/
chemical treatment, and discharge.
• Alternative No. 3: Ground water containment and offsite
treatment.
Alternative No. 1; No Action
Estimated Capital Cost: $0
Annual O&M: $5,975
Present Worth: $92,000
Estimated Time to Complete: None
This alternative is required by the National Contingency Plan
(NCP) as a baseline comparison to other alternatives. Under
this alternative, no action would be taken to remediate ground
water contamination in the study area. Seven wells would be
26
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sampled annually for a period of 30 years and samples would be
analyzed for TCE, tetrachloroethene, vinyl chloride, 1,1,1-
trichloroethane, 1,1-dichloroethane, and 1,1-dichloroethene. The
locations of the wells are shown in Figure 5. Ground water
monitoring would aid in evaluating plume migration and what, if
any, change in contaminant concentrations occurring over time.
This no action alternative may not be implementable because the
aquifer is classified as Class Ila (i.e. current source of
drinking water), which is expected to be returned to beneficial
use wherever practicable.
Unless additional releases of TCE into the aquifer occur,
modeling studies estimate that natural attenuation will lead to
the remediation of the site in about 120 years.
Alternative No. 2: Ground Water Containment. Physical/Chemical
Treatment, and Discharge
Estimated Capital Cost: $514,531
Annual O&M Costs: $46,709
Present Worth: $1,232,000
Estimated Time to Complete: 30 years
This alternative would contain the further migration of the
contaminant plume while attempting to restore ground water
quality to acceptable levels promulgated under the Safe Drinking
Water Act (SDWA). The SDWA has established maximum contaminant
levels (MCLs) which are the maximum permissible levels of
contaminants in water that are set based on health effect
concerns. The MCLs for TCE and 1,1,-dichloroethene in drinking
water are 5 ug/1 and 7 ug/1, respectively. See 40 C.F.R. Section
141.61. All other site contaminants are below SDWA MCLs.
A component of this alternative is ground water extraction using
extraction wells to lower the water table in order to halt the
discharge of contaminated ground water to the East Branch of Hog
Run Creek. The extracted ground water would then be pumped to a
single treatment plant that would be constructed on the Croydon
TCE Site. There are several effective physical/chemical
treatment options for treating the contaminated ground water,
including air stripping, steam stripping, carbon adsorption, and
ultra violent (UV)/ozone. Air stripping has been selected as the
representative physical/chemical option, however, this selection
will not preclude the use of the other viable physical/chemical
treatment options, if deemed appropriate during alternative
design. Also, carbon adsorption might be needed as an ancillary
treatment step for a by-product stream if air stripping, steam
stripping, or UV/ozone were implemented. Treated water could be
discharged to a Publicly Owned Treatment Works (POTW) or to an
offsite or onsite surface water body. Of these viable discharge
27
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•US ROUTE
PENNSYLVANIA AVENUC
n /.
/fVHO \ / \\
LEGEND
A HESIOENtlAl WtIL
9 MONITORING WCH
PROPOSED GROUNDWATER MQMIORIN.G_STAI1C
'CROYDON TCE SITE. BUCKS COUNTY. PA
SCALt IN FEET
FICl
-------
options, discharge to an onsite surface water body has been
selected. Because the discharge point is within the site
boundary, a National Pollutant Discharge Elimination System
(NPDES) permit would not be required. However, compliance with
NPDES effluent concentration levels are required substantively
but not administratively. In addition to actively remediating
the ground water contamination, institutional controls which
include ground water use restrictions within the area affected by
the contaminant plume will also need to be implemented by state
or local authorities. New wells should be prevented from be-.ing
constructed, and existing wells should be sealed or not used for
potable water supply.
Two ground water extraction scenarios (ES-1 and ES-2) were
considered. ES-1 consists of four continuously pumping wells,
located as shown in Figure 6. These particular locations and
assumed pumping rates were selected so as to prevent migration of
ground water from the Rohm & Haas Landfill to the study area as
well as prevent additional contaminated ground water to migrate
in the study area. ES-2 consists of phased pumping of four wells
at the same locations shown in Figure 6. Based on the modeling
results of ES-1, two modifications were made to ES-2: 1) the two
wells located to the north of Hog Run Creek would be stopped
after 20 years because the maximum concentration of TCE in that
area was predicted to be lower than 5 ug/1; 2) the pumping rate
of the well closest to the Rohm & Haas ponds was increased by
50 percent.
Due to the similarity in flow rates of the two scenarios, only
one preliminary air stripping column design was developed. The
air stripper was designed to meet NPDES effluent concentration
levels based on surface water discharge to the East Branch of Hog
Run Creek. Preliminary effluent limitations were conservatively
set to achieve a TCE concentration of less than 1 ug/1 for
computer modeling design purposes, which is well below the MCL of
5 ug/1. TCE was chosen as the design indicator contaminant,
because its concentration in ground water was found to be an
order of magnitude greater than any other contaminant. The
average observed TCE ground water concentration and the assumed
pumping rate from each extraction well were used to estimate the
influent concentrations of the Croydon TCE Site stripper via a
mass balance.
The emission rates of volatile organics into the ambient air were
also assessed; exhaust gases from the stripper are estimated to
contain less than 140 ug/1 of TCE by volume before undergoing
treatment prior to its release to the atmosphere through an
activated carbon filter. The carbon filter will have a minimum
efficiency of approximately 98 percent, thereby limiting the TCE
exhaust gas concentrations into the atmosphere well below the MCL
of 5 ug/1. Periodic monitoring of air stripper exhaust gases to
29
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LEGEND
• EXTRACTION WELL
Hi LIFT STATION (BRISTOL PARK PUMP STA.)
UNDERGROUND PIPE
(CONTAMINATED GROUNOWATER)
AIR STRIPPER
X UNDERGROUND P
-------
ensure compliance with National Environmental Standards for
Hazardous Air Pollutants (NESHAP) will be performed.
The computer model, previously discussed, was also used to
determine the approximate time needed to achieve the remediation
level of 5 ug/1 for TCE. Based on a pumping rate of about
40 gallons per minute, the ground water MCL for TCE may be
achieved in approximately 30 years. It should be noted that the
model assumed no current sources of ground water contamination
within, or in the vicinity of, the study area. As mentioned
previously, no source has yet been definitively identified as an
ongoing contributor to ground water contamination at the site.
Ground water monitoring as described in Alternative No. 1 (No
Action), will also be performed.
Alternative No. 3; Ground Water Containment and Offsite
Treatment
Estimated Capital Cost: $270,021
Annual O&M Costs
(years 0 to 20/years 21 to 30 years): $133,557/$83,100
Present Worth: $2,177,000
Estimated Time to Complete: 30 years
As outlined in Alternative No. 2, this alternative will also
contain the ground water contaminant plume while attempting to
restore the ground water aquifer to its beneficial use. Both
Alternative No. 2 and Alternative No. 3 involve the same ground
water pumping scheme, but differ in how and where the
contaminated ground water would be treated. Under this
alternative the extracted ground water would be transported via
underground piping to the nearest sanitary sewer lift station for
treatment at the POTW.
Contaminant concentrations and flow rates that can be accepted
are based on the POTW requirements. Institutional controls as
described in the previous alternative, will also need to be
implemented.
The Bristol Township Authority, the owners of the POTW and
sanitary sewer system, have given preliminarily approval for the
discharge of 50 gallons per minute (gpm) of contaminated ground
water with less than 1 mg/1 VOCs into the Bristol Park Sanitary
Sewer Lift Station. Figure 7 depicts the location of this lift
station and a general diagram of Alternative No. 3.
As with all of the previous alternatives, ground water monitoring
will also be performed.
31
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LEGEND
EXTRACTION WELL
LIFT STATION (WBTOLPAim PUMP STA.1
UNOERWOUNO PIPE
(CONTAMINATED GAOUNOWATEft)
OVERVIEW OF ALTERNATIVE NO. 3
CROYDON TCE SITE. BUCKS COUNTY. PA
FIGURE 7
32
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives "identified were evaluated based on the following
nine criteria:
• Overall protection of human health and the environment.
• Compliance with all Federal and state applicable or
relevant and appropriate requirements (ARARs).
• Reduction of toxicity, mobility, or volume.
• Short-term effectiveness.
• Long-term effectiveness.
• Implementability.
• Cost.
• Community acceptance.
• State acceptance.
Table 5 describes these criteria.
A summary of the relative performance of the alternatives with
respect to each of the nine criteria follows. This summary
provides the basis for determining which alternative provides the
"best balance" of tradeoffs with respect to the nine evaluation
criteria.
Short-Term Effectiveness
Alternative No. 1 (No Action), will not result in any additional
type of human or environmental risk since the only action
involved with this alternative is long-term ground water
monitoring. Workers involved with the sampling of these wells
will be required to wear the appropriate protective clothing. No
impact to the community is anticipated with the construction and
implementation of either Alternative No. 2 (Ground Water
Collection, Physical/Chemical Treatment, and Disposal) or
Alternative No. 3 (Ground Water Collection and Offsite
Treatment). Both of these alternatives involve the same pumping
scheme, but differ in how (and where) the contaminated ground
water is treated. The impact of ground water pumping may reduce
the amount of water present in various wetlands throughout the
study area (between State Road and River Road in the southeastern
portion of the site).
Alternative No. 1 does not involve remediation, therefore it may
take more than 120 years for the aquifer to cleanse itself via
attenuation. This timeframe is based on modeling results that
assume no further TCE loading into the aquifer. The timeframe
for remediation of the aquifer, barring no further releases of
TCE into the aquifer, has been estimated to be approximately
30 years for both Alternatives No. 2 and No. 3. Both of these
alternatives will be equally effective in preventing the plume
from migrating. The containment action will occur within a short
period of time once pumping of the aquifer begins.
33
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TABLE 5
GLOSSARY OF EVALUATION CRITERIA
CROYDON TCE SITE
Overall Protection - The assessment against this
criterion describes how the alternative, as a whole,
protects and maintains protection of human health and
the environment.
Compliance with ARARs - The assessment against this
criterion describes how the alternative complies with
ARARs, or if a waiver is required and how it is
justified. The assessment includes information from
advisories, criteria, and guidance that the lead and
support agencies is necessary and appropriate.
Long-term Effectiveness and Permanence - The assessment
of alternatives against this criterion evaluates the
long-term effectiveness of alternatives in protecting
human health and the environment after response
objectives have been met.
Reduction of Toxicity, Mobility, and Volume - The
assessment against this criterion evaluates the
anticipated performance of the specific treatment
technologies.
Short-term Effectiveness - The assessment against this
criterion examines the effectiveness of alternatives in
protecting human health and the environment during the
construction and implementation period until response
objectives have been met.
Implementability - This assessment evaluates the
technical and administrative feasibility of alternatives
and the availability of required resources.
Cost - This assessment evaluates the capital and O&M
costs of each alternative.
State Acceptance - This assessment reflects the state's
(or supporting agency's) apparent preferences or concerns
about alternatives.
Community Acceptance - This assessment reflects the
community's apparent preferences or concerns about
alternatives.
34
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Long-Term Effectiveness and Permanence
Alternative No. I would not be effective in reducing or
containing the level of TCE contamination in the aquifer.
Aquifer restoration would solely depend on natural attenuation,
which may take as long as 120 years if no additional TCE enters
the ground water aquifer. Under this alternative, state or local
governments would have to ensure that ground water is not used as
a potable water supply. Additionally, long-term monitoring will
be required. Alternative No. 2 would be effective in containing
the plume to the general site area, and would eventually lead to
ground water restoration in about 30 years. This assumes, of
course, that no additional TCE loading will occur. Alternative
No. 3 would also be effective in containing the plume. Because
this alternative differs from Alternative No. 2 only in the
treatment aspects, it too will eventually lead to ground water
restoration in about 30 years.
The technologies proposed for Alternative No. 2 are proven.
Therefore, this alternative is expected to provide long-term
effectiveness. The technologies for Alternative No. 3 involve
pumping and discharging to the local POTW. This alternative is
also expected to provide long-term effectiveness and reliability
since it is anticipated that the local POTW will be operating for
some time into the future in order to serve the needs of the
local community.
Reduction of Toxicity. Mobility, and Volume
Alternative No. 1 does not result in any reduction in toxicity,
mobility, or volume since no action is performed. Alternatives
No. 2 and No. 3 would both result in containing the ground water
plume to the general site area. Therefore, either alternative
would reduce the mobility of the contaminants. Alternatives
No. 2 and No. 3 would both result in a reduction of toxicity
since they both employ effective treatment of TCE. Volume is not
applicable to this site since the source of TCE is unknown and
may be already depleted (volume reduction is usually associated
with source control).
Implementability
Alternative No. 1 would be the easiest to implement because it
only involves ground water monitoring. Existing onsite
monitoring wells could be used for long-term monitoring. Ground
water monitoring over the 30-year period would be the
responsibility of state and/or local authorities.
The technologies proposed for Alternative No. 2 are commercially
available--and widely used in wastewater extraction/treatment.
Negotiations with property owners will be required for the
installations of extraction wells and the onsite treatment plant.
35
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Additionally, piping of ground water to the onsite treatment
plant will require coordination with local utility companies.
Because the treated ground water would be discharged within the
site boundary, no NPDES permit will be require, although NPDES
effluent limitations would have to be met. Administrative
controls (i.e., ground water monitoring) can be implemented by
State and/or local authorities.
Alternative No. 3 can also be easily implemented. This
alternative involves treatment of contaminated ground water at
the local POTW. EPA's contractor and Bristol Township personnel
have determined that the treatment plant has adequate capacity
and could effectively treat the ground water without any
pretreatment. Therefore, this alternative could be implemented.
Ground water extraction via pumping wells would also be
implementable. However, property access and locating underground
utilities would need to be performed. It is anticipated that
this would be easily achievable. Institutional controls (i.e.,
ground water monitoring) would be conducted by the State and/or
local authorities.
Alternatives No. 2 and No. 3 are equally implementable.
Compliance With Applicable or Relevant and Appropriate
Requirements (ARARs)
Under Alternative No. 1, chemical-specific ARARs would not be met
in ground water, and contaminant concentrations would remain
above health-based and risk-based levels. Both Alternatives
No. 2 and No. 3 will attempt to meet all ARARs by reducing ground
water contaminant levels to below MCLs in about 20 to 30 years,
assuming that no further TCE will enter the aquifer.
Overall Protection of Public Health and Environment
Alternative No. 1 would not provide protection to the public
health. In light of the fact that an alternative source of
potable water is currently being provided to 11 households in
Croydon that did not have access to public water and depended on
ground water, there will be no direct exposure to ground water.
Risks to the environment will be unchanged under Alternative
No. 1. However, this risk is low based on data collected from
onsite surface waters and sediments in which contaminant levels
did not exceed Ambient Water Quality Criteria.
Alternative No. 2 is protective of the public health (future
potential exposure) because it will prevent the migration of the
contaminant plume and will reduce the toxicity of the plume over
time. Institutional controls to restrict the use of ground water
will also result in protecting the public health.
36
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The remediation of ground water will result in reducing the level
of contamination -discharged to Hog Run Creek and its tributaries.
However, continuous pumping of the ground water may impact the
wetlands between State Road and River Road. This factor can not
be fully evaluated until actual pumping begins, however, it is
anticipated that the amount of standing water in the wetlands
will be reduced to some degree.
Alternative No. 3 is protective of the public health (future
potential exposure) because it will also prevent the migration of
the contaminant plume and will reduce the toxicity of the plume
over time. Institutional controls to restrict the use of ground
water will also result in protecting the public health. The
cleanup of the aquifer will result in reducing the level of
contamination discharged to Hog Run Creek and its tributaries.
As with Alternative No. 2, continuous pumping of the ground water
may impact the amount of standing water in the wetlands between
State Road and River Road.
Alternatives No. 2 and No. 3 will provide equal overall
protection to the public health and environment.
Costs
Alternative No. 1 does not involve any capital costs since the
existing monitoring wells can be used for long-term monitoring.
Quarterly sampling of these wells and selected residential wells
will result in low annual operation and maintenance (O&M) costs.
The present worth cost of alternative No. 1 is $92,000.
Capital costs for Alternative No. 2 are the highest of the three
alternatives since these costs include the onsite treatment
plant. Capital costs for Alternative No. 3 are lower than
Alternative No. 2 because no treatment plant is required to be
constructed. Annual O&M costs for Alternative No. 2 are
estimated to be $46,709 versus $133,557 for Alternative No. 3,
thus the present worth cost of Alternative No. 3 ($2,177,000)
is higher than that of Alternative No. 2 ($1,232,000).
State Acceptance
The Commonwealth of Pennsylvania, Department of Environmental
Resources (PADER), has reviewed the information available for
this site and has concurred with the remedy selected in this
Record of Decision (ROD), which was described in detail at page
38. (See attached PADER concurrence Letter).
Community Acceptance
A public comment period for the Proposed Plan was held from May
2, 1990 to May 31, 1990. On May 18, 1990, a public meeting was
held at the Bristol Township Municipal Building to discuss EPA's
37
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preferred alternative as described in the Proposed Plan. Area
residents, local and state officials were in attendance at the
meeting.
Comments received during the public meeting and the public
comment period are presented in the attached responsiveness
summary.
SET.ECTED REMEDY
Alternative No. 2: Ground Water Containment. Physical/
Chemical Treatment and Discharge
This alternative involves installation of ground water extraction
wells equipped with pumps. Ground water would be pumped to an
air stripper to be constructed at the Croydon TCE Site. Treated
ground water would be discharged to the East Branch of Hog Run
Creek. Pumping would lower the water table; thus, wetland areas
would no longer receive the same volume of ground water
discharge. The impact to surrounding wetlands in the study area
from the pumping of ground water would be studied during the
design of the ground water pumping/treatment system. The
possibility of dewatering wetland areas by significantly reducing
the source of ground water recharge by lowering the water table
during pumping is a concern. One possible solution to minimize
potential harm to the wetlands would be to locate the effluent
discharge point from the treatment facility at an upgradient
location where it would recharge the potentially affected wetland
areas.
The ground water extraction scenario consists of four wells at
the locations indicated on Figure 6. The wells would intercept
ground water, as determined by computer modeling simulations,
previously discussed. The total pumping rate from all wells
would be approximately 45 gallons per minute (gpm) for the first
20 years and 21 gpm for years 21-30 (two of the four wells are
shut down after 20 years). It was assumed that the average depth
of the extraction wells would be 48 feet and that the diameter of
the wells would be 4 inches. One and one half horsepower pumps
at each well were estimated to provide sufficient pumping
capacity.
The pumping rate and well locations would also help to contain
the migration of the TCE plume from the site area.
To treat the extracted ground water, an air stripper would be
constructed at the Croydon TCE Site near the Bristol Park Pumping
Station. Piping would be installed from the extraction wells to
the air stripper. Based on the locations of the extraction wells
and the pumping rates, it was estimated that 3,400 linear feet of
1-inch-diameter PVC pipe would be required from the extraction
wells to the air stripper, assuming that the air stripper would
38
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be constructed near the Bristol Park Pumping Station. All pipe
would be underground. The air stripper would be a counter-
current packed tower, in which air enters at the bottom and
exhausts at the top, while the ground water flows down through
the packing media. The packing material would be approximately
30 feet in height and 3 feet in diameter. The ground water is
not expected to be excessively scale-forming; thus no
pretreatment to prevent fouling of the air stripper would be
required. Carbon adsorption may be required as an ancillary
treatment step prior to discharge. Discharge piping would also
be installed between the air stripper and the East Branch of Hog
Run Creek. Approximately 200 linear feet of 3-inch-diameter pipe
would be required from the stripper to this discharge point.
A vapor-phased carbon adsorption treatment device would be
attached to the exhaust of the air stripping tower to prevent the
release of volatile organic compounds to the atmosphere. The
carbon filter would require minimal maintenance as the spent
activated carbon would be periodically changed. Spent carbon
would be taken offsite as a hazardous waste for treatment or
disposal. The most cost effective means of dealing with the
spent carbon would determine which of the two methods is
selected. If disposal is selected, it would be in compliance
with the RCRA land disposal restrictions (LDR).
.Institutional controls, including ground water use restrictions
in the affected area, would also be implemented by state or local
authorities to prevent the use of contaminated ground water
during remediation.
Ground water monitoring of selected existing residential and
monitoring wells would be conducted annually for 30 years to
confirm the extraction system captures the contamination and thus
prevent further migration. For costing purposes, seven existing
wells near the plume boundaries would be monitored for the
following volatile organic compounds: TCE; tetrachloroethene;
vinyl chloride; 1,1,1-trichloroethane; 1,1-dichloroethane; and
1,1-dichloroethene. Ground water levels would also be measured
at the time of sampling. Additional sampling and analyses would
be used to monitor the progress of the remedial activities.
Also, for costing purposes, it was assumed that samples would be
obtained from each of the four extraction wells semi-annually for
30 years. These samples would be analyzed for the same
parameters as the samples from the residential and monitoring
wells discussed above.
This alternative would reduce the risks posed by ground water
contamination and migration. Once the ground water extraction
and treatment systems are installed, the contaminated plume would
slowly begin to recede from its current position, and the East
Branch of Hog Run Creek may no longer discharge contaminated
water to the Delaware River. A pumping time of 20 to 30 years
39
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would be required to reduce aquifer TCE contaminant
concentrations tcr 5 ug/1 and 7 ug/1 for 1,1-dichloroethene (the
MCLs) or lower risk-based levels, assuming no additional releases
of contaminants to the aquifer. This alternative would
effectively act to contain the contaminant plume to the general
site area.
Recent communications between EPA and the PADER have resulted in
EPA recognizing that cleanup of ground water to background is a
Pennsylvania ARAR (see Table 7). Background is not clearly
defined, but for volatile organic limits in this ROD, we are
establishing background as the current instrument detection limit
of 1 ug/1. As described above, the ground water remediation
model was run considering cleanup goals of the MCLs. Further
reduction of the contaminants to limits of detection can be
assumed to be possible with a longer period of ground water
extraction. For the purposes of estimating costs for this ROD,
EPA has assumed an additional 10 to 15 years would be necessary
to reach background as defined by the instrument detection
limits. This cleanup goal of 1 ug/1 each for TCE and 1,1-
dichloroethene are below the respective MCLs and are protective
of human health and will meet all ARARs.
There would be no risks to the general public during
implementation. Protective clothing would be needed for workers
who might contact contaminated ground water.
The technologies proposed for collection and physical/chemical
treatment are demonstrated and commercially available, and could
be implementable within 1 year after the completion of the design
phase. These systems are reliable if properly maintained.
Obtaining access to residential locations is a concern, because
pumping wells would need to be installed on private property in
the study area. Underground piping between the wells and the air
stripper and between the stripper and the East Branch of Hog Run
Creek would need to be installed beneath private property and
roadways in the residential area. Residential property would
need to be restored, and road pavement would need to be replaced
where the pipe trenches were excavated. It is likely that the
proposed pipelines would cross existing utility lines buried
beneath private property and roads in the community. The
effluent discharge from the air stripper would require periodic
monitoring to determine compliance with NPDES permit limits.
Although a NPDES permit is not required for an onsite discharge,
effluent limitations for such discharge must be met. Since the
state has been delegated the NPDES program by EPA, PADER would
set the discharge limits to Hog Run Creek for the ground water
treatment facility.
Institutional controls would be implemented by state and local
authorities.
40
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The capital and annual costs for this alternative are
approximately $514,531 and $46,709 respectively. Based on a
discount rate of 5 percent, the net present value of this
alternative is approximately $1,232,000. Table 6 summarizes the
major capital and annual cost items.
STATUTORY DETERMINATION
Section 121 of SARA requires that the selected remedy
. Be protective of human health and the environment;
. Attain ARARs (or explain rationale for invoking a waiver);
. Be cost effective;
. Utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable;
• Address whether the preference for treatment that reduces
toxicity, mobility, or volume as a principal element is
satisfied.
A description of how the selected remedy satisfies each of the
above statutory requirements is provided below.
Protection of Human Health and the Environment
The selected remedy will protect human health and the environment
through ground water extraction and treatment by reducing the
future potential threat to human health from ingestion of
contaminated ground water and reducing contaminated levels in the
East Branch of Hog Run Creek, where contaminated ground water
discharges to surface water. The selected remedy would also
reduce further environmental degradation. Reduction of the TCE
concentrations to the MCL of < 5 ug/L would require 20 to 30
years. Reduction to background levels as required by the
Pennsylvania ARAR for ground water would require an additional 10
to 15 years. Institutional controls would restrict ground water
use until remediation of the aquifer is completed. It is not
anticipated that the selected remedy will pose unacceptable
short-term risks or cross-media impacts.
While Alternative No. 3 would also provide equal protection to
human health, it would not provide equal protection to the
environment. Uncontrolled air releases of volatile organic
compounds would occur from the treatment of the contaminated
ground water at the Bristol Township POTW which would create
cross media impacts.
41
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TABLE 6
ESTIMATED COSTS OP SELECTED REMEDY
CROYDON TCE SITE
BUCKS COUNTY, PENNSYLVANIA
Components
Estimated Costs
CAPITAL COSTS
1.
2.
3.
4.
Equipment
Piping & instrumentation
Foundation & structural
Electrical
Subtotal
5.
Markups (labor, material and
subcontracting) and
contingencies
Total
$104,320
83,588
18,000
35,250
$241,158
273,373
$514,531
ANNUAL COSTS
1.
2.
3.
4.
Energy (electric)
Maintenance
Operator (8 hr/week)
Sampling, analysis, report
preparation
Total
$ 3,054
16.900
12,480
14,275
$46,709
Net present value (based on a 5 percent discount rate)
$1,232,000 for 30 years and $1,345,000 for 45 years.
42
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Compliance with ARARs
The selected remedy of ground water extraction, treatment of the
extracted ground water via air stripping, followed by carbon
adsorption as an ancillary treatment step and onsite discharge
will attempt to comply with all ARARS. Regulations in 40 C.F.R.
Parts 122.44 and 125.3 require the use of best-available
technology economically achievable (BAT) to control discharges of
toxic and nonconventional pollutants, such as the volatile
organics, to certain surface waters. Applicable federal and
state water quality standards will be complied with under this
response action. The aqueous discharge from the air stripper
will be monitored for the mass of pollutant, the volume of
effluent, and frequency of discharge as required in
40 C.F.R. 122.41. Monitoring requirements, including test
methods, quality control, sample preservation, containers, and
holding times in 40 C.F.R. Parts 122 and 136, are also applicable
and will be adhered to.
The Pennsylvania ARAR for ground water for hazardous substances
is that all ground water must be remediated to "background"
quality as specified by 25 PA Code Section 75.264(n). The
Commonwealth of Pennsylvania also maintains that the requirement
to remediate to background is also found in other legal
authorities.
Air stripper effluent will be discharged onsite to the East
Branch of Hog Run Creek, therefore NPDES requirements will not be
applicable. Even though a NPDES permit is not required, specific
effluent discharge limits will be monitored and must be
maintained by the treatment facility. The atmospheric emissions
from the air stripper would be subject to air pollution control
requirements. Based on preliminary estimates, these emissions
would not exceed applicable standards. Since the treatment
scheme was designed to meet applicable state and federal
discharge and emission control requirements, all pertinent ARARs
should be met by the selected remedy. A summary of the pertinent
state and federal ARARs are listed in Table 7 and are identified
as either action, chemical, or location specific.
Cost-Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs. The net present worth value of the selected remedy being
$1,232,000 for the initial thirty years of operation, and a
recalculated present worth cost of $1,345,000 which consists of
an additional 15 year period in an attempt to reach background
ground water levels. While Alternative No. 3 also affords a high
degree of protection to human health and the environment, its
present worth value is $2,177,000 for a thirty year period of
operation. For comparison, if Alternative No. 3 were modified to
43
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Table 7
ACTION-SPECIFIC ARARS
Standard, Requirement,
Criteria, or Limitation
Clean Water Act
Clean Water Act
Citation
40 C.F.R.
Section
122.44(a)
40 C.F.R.
Section
122.44
Description
Discharge of air
stripper effluent
to East Branch of
Hog Run Creek.
Ambient Water
Quality Standards
for discharge of
treatment system
effluent to East
Branch of Hog Run
Creek.
Applicable/
Relevant and
Appropriate
yes/no
yes/no
Discussion
Alt. 2
Best available
technology
economically1
achievable and
best conven-
tional
pollution
control tech.
required to
control toxic
& nonconven-
tial pollu-
tants &
conventional
pollutants,
respectively.
Alt. 2
-------
Standard, Requirement,
Criteria, or Limitation
Clean Water Act
Pennsylvania Clean
Streams Law
Pennsylvania National
Pollution Discharge
Elimination System
Regulations
Pennsylvania Waste-
water Treatment
Regulations
Table 7 (continued)
ACTION-SPECIFIC ARARS
Citation
40 C.F.R.
Sections
125.100,
125.104,
136.1-136.4
25 PA Code
Section 5
25 PA Code
Section 5
25 PA Code
Section 95
Description
Discharge of
treatment system
effluent to East
Branch of Hog Run
Creek.
Applicable/
Relevant and
Appropriate
yes/no
Discussion
Alt. 2
Best
Management
Program to
prevent
release of
toxic
constituents
to surface
waters.
Alt. 2
Alt. 2
Discharge of yes/no
treatment system
effluent to East
Branch of Hog Run
Creek.
State Water Quality yes/no
Standards for
discharge of
treatment system
effluent to East
Branch of Hog Run
Creek.
Discharge of yes/no Alt. 2
treatment system
effluent to East
Branch of Hog Run Creek.
-------
Standard, Requirements,
Criteria, or Limitations
Solid Waste Management
Act
Pennsylvania Hazardous
Waste Management
Regulations
Pennsylvania Hazardous
Waste Management
Regulations
Pennsylvania Hazardous
Waste Management
Regulations
Table 7 (continued)
ACTION-SPECIFIC ARARS
Citation
40 C.F.R.
Section 268
(Subpart D)
25 PA Code
Sections
75.264,
75.265
25 PA Code
Section
75.264(n)
25 PA Code
Sections
75.264,
75.265
Applicable/
Relevant and
Appropriate
yes/no
Description
Land-disposal
restricted
requirements for
offsite disposal
of carbon residue
from ancillary
carbon adsorption
and vapor phase
treatment of air
stripper emissions.
Offsite disposal of yes/no
carbon residue from
ancillary carbon
adsorption and vapor
phase treatment of
air stripper emissions
to a permitted treatment,
storage, disposal
facility.
Remediation of yes/no
ground water to
background levels.
Onsite container yes/no
storage of vapor
phase treatment of
air stripper
emissions.
Discussion
Alt. 2
Alt. 2
Alts. 2 & 3
Alt. 2
-------
Standard, Requirement,
Criteria, or Limitation
Safe Drinking Water Act
Clean Air Act
Table 7 (continued)
CHEMICAL-SPECIFIC ARARS
Citation
40 C.F.R
Section
141.61
40 C.F.R.
Part 61
(Subpart F)
Pennsylvania Water Quality
Standards
25 PA Code
Section 93
Description
Maximum contaminant
levels for discharge
of treatment system
effluent to East
Branch of Hog Run
Creek.
National Emission
Standards for
Hazardous Air
Pollutants (NESHAPs)
for air stripper
emissions.
Applicable/
Relevant and
Appropriate
yes/no
Site-specific limits
for discharge of
treatment system
effluent to East
Branch of Hog Run
Creek.
yes/no
yes/no
Discussion
Alt. 2
Alt. 2
TCE may bio-
degrade to
vinyl chloride
(VC), for
which a NESHAP
is applicable.
VC would be
managed in
accordance
with the
NESHAP.
Alt. 2
Monthly avg.
& max. daily
avg. for TCE
(3 & 6 ug/1);
vinyl chloride
(0.02 & 0.04
ug/1); & 1,1,1
- TCA (605 &
1210 ug/1).
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Table 7 (continued)
CHEMICAL-SPECIFIC ARARS
Applicable/
Standard, Requirement, Relevant and
Criteria, or Limitation Citation Description Appropriate Discussion
Pennsylvania Air 25 PA Code Site-specific limits yes/no Alt. 2
Pollution Control Sections for air stripper Total volatile
Regulations 121.1-143.3 emissions. emissions not
to exceed 4
tons/year or I
pound/hour.
oo
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Standard, Requirement,
Criteria, or Limitation
Fish and Wildlife
Coordination Act
Pennsylvania Air
Pollution Control
Regulations
Table 7 (continued)
LOCATION-SPECIFIC ARARS
Citation
40 C.F.R.
Section
6.302
25 PA Code
Sections
121.1-
143.3
Description
Floodplain and
fish and wildlife
protection.
Site-specific
limits for
air stripper
emissions.
Applicable/
Relevant and
Appropriate
yes/no
yes/no
Discussion
Alts. 2 & 3
Alt. 2
Total volatile
emissions not
to exceed 4
tons/year or
1 pound/hour.
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include an additional 15 years of operation in an attempt to
reach background," the estimated present worth cost would be
$2,370,000.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
ground water operable unit at the Croydon TCE Site. Because the
principle threat, the source of the ground water contamination,
has not been identified, none of the alternatives including the
selected remedy may achieve a permanent solution. Of those
alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that this
selected remedy provides the best balance of tradeoffs in terms
of long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term
effectiveness, implementability, cost also considering the
statutory preference for treatment as a principal element and
considering state and community acceptance. If, however, the
source of the ground water contamination is depleted or consists
only of residuals in the vadose zone (unsaturated soil layer
above the level of ground water), the selected remedy may result
in a permanent solution because the ground water will be treated
to acceptable health- and risk-based action levels. Therefore,
the statutory preference for remedies that employ treatment as a
principal element is satisfied.
Reduction of Toxicity. Mobility, or Volume
The selected remedy reduces the mobility and volume of the
contaminant plume, since ground water from outside the study area
replaces water pumped from the aquifer and thereby causes the
plume to decrease in size. The remedy's pumping would also lower
the water table, such that the East Branch of Hog Run Creek would
no longer discharge contaminants to surface water. Air stripping
provided in the remedy would reduce contaminant concentrations
and, therefore, toxicity, within the study area.
Schedule
The anticipated schedule is for the design to begin in the summer
of 1990. Once the design is completed, a construction period of
approximately one year will be required for the installation of
the extraction wells and the ground water treatment facility.
50
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-90/088
3. Redpienf s Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Croydon TCE, PA
Second Remedial Action - Final
5. Report Date
06/29/90
7. AuthOf(»)
8. Performing Organization RepL No.
9. Performing Organization Name and Addrea*
10. ProiecVTaek/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
12. Sponsoring Organization Name and Addrea*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report I Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Croydon TCE site is in Bristol Township, Bucks County, Pennsylvania. A series of
studies conducted by EPA beginning in 1984 led to the detection of VOC contamination in
the ground water over a 3.5-square mile area referred to as the study area. The study
area is predominantly residential with an estimated 3,000 residents. A small
southeastern portion of the study area containing elevated levels of VOCs, particularly
'TCE, and numerous potential source areas have been identified and are referred to
collectively as the "focused area of investigation." This smaller area is composed of
the Croydon residential community and several manufacturing and commercial
establishments. The study area is bordered on the south by the Delaware River.
Neshaminy Creek, which borders the study area to the west, and Hog Run Creek, which
flows through the focused area of investigation, both discharge to the river. Although
the source of contamination has not been identified, the contaminant plume appears to be
flowing south-southeast into the East Branch of Hog Run Creek and probably into the
Delaware River. A 1988 Record of Decision (ROD) documented the provision of a public
water supply to 11 residents within the identified ground water contaminant plume area.
This 1990 ROD addresses the remediation of the ground water contamination at the site.
The primary contaminants of concern affecting the ground water are VOCs including TCE
and 1,1-DCE.
17. Document Analysis a. Descriptors
Record of Decision - Croydon TCE, PA
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, 1,1-DCE)
b. Identifiers/Open-Ended Terms
c. COSATt Field/Group
<8. Availabilty Statement
18. Security Clasa (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
128
22. Price
(See ANSI-Z38.18)
See Inttnjction* en Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-SS)
Department of Commerce
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RESPONSIVENESS SUMMARY
CROYDCN TCE SUPERFUND SITE
-------
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION
AT THE
CROYDON TCE SUPERFUND SITE
BRISTOL, PENNSYLVANIA
TABLE OF CONTENTS
.SECTION PAGE
I. Introduction 1
II. Summary of May 18, 1990 Meeting
Presentations 2
A. Purpose of Meeting and Meeting
Introduction 2
B. Site Background and Proposed Plan .... 3
III. Public Meeting Comments 5
A. The Proposed Remedy for the
Croydon TCE Site 5
B. Cost of the Remedial Action for
Croydon TCE Site 9
C. Site History and Current Status 9
D. General Comments 12
E. Other Potential Sources of
Contamination 15
Appendix A - Comments on the Proposed Remedial Action
Plan for the Croydon TCE Superfund Site from Rohm & Haas
Appendix B - Comments on the Proposed Remedial Action Plan
for the Croydon TCE Superfund Site from Unitech Engineers
ii
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RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION
AT THE CROYDON TCE SUPERFUND SITE
BRISTOL, PENNSYLVANIA
I. INTRODUCTION
In accordance with the U.S. Environmental Protection Agency's
(EPA) community relations policy and guidance, the EPA Region III
office announced a public comment period from May 2, 1990 to May
31, 1990, to obtain comments on Phase II of the Proposed Remedial
Action Plan (PRAP) for the Croydon Trichloroethylene (TCE)
Superfund site in Bristol Township, Bucks County, Pennsylvania.
The Croydon TCE site encompasses a 1.5 mile area where a
contaminated plume that poses a threat to residents who rely on
groundwater as their sole source of potable water has been
identified. On May 18, 1990, EPA and the Pennsylvania Department
of Environmental Resources (DER) held a public meeting to receive
public comments on the proposed remedy. Approximately 45 community
residents and interested persons attended the meeting. Copies of
the PRAP were distributed at the meeting and placed in the
information repositories for the site.
Public comments received during the comment period are
documented and summarized in this Responsiveness Summary. Section
II, immediately following, summarizes the presentations made at the
public meeting on May 18, 1990. Section III presents a summary of
questions and comments expressed by the public at the May 18 public
meeting. Appendices A and B cntain written comments. All
questions and comments are grouped into general categories,
according to subject matter. Each question or comment is followed
by EPA's response.
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II. SUMMARY DF MAY 18. 1990 MFRTTNG
A . Purpo«« of Meeting and Heating Introduction
Laanna Nurse, the U.S. EPA Region III Community Relations
Coordinator for the Croydon TCE Superfund site, welcomed meeting
attendees. She explained that EPA and PADER were holding the
meeting during the public comment period on the Proposed Remedial
Action Plan (PRAP) for the Croydon TCE Superfund site. A secondary
function of the meeting was to allow concerns about enforcement-
related questions to be addressed by State staff members. She then
introduced some guests present, as well as the speakers for the
night.
Ms. Nurse explained the Superfund program itself. She stated
that the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund), was passed by Congress in
1980. That law authorized money to identify some of the worst
hazardous waste sites in the country. These sites are evaluated
for the kinds of substances that are present and the risks that
they pose to the public. If they qualify, the sites are placed on
the National Priorities List (NPL) . Once on the NPL, the sites are
eligible to receive Superfund money for cleanup.
Ms. Nurse further explained the remedial process at individual
sites. She told attendees that once a site is listed on the NPL, a
Remedial Investigation (RI) is undertaken. The Remedial
Investigation involves a team of scientists evaluating the
substances present at a site, the quantities which are present, and
the risk posed to human health and the environment. During the
Remedial Investigation, an Information Repository is set up to
provide information about the site to the public in the site
vicinity, and a Community Relations Plan is developed to involve
the community in site activities. Once the Remedial Investigation
is conducted, a Feasibility Study (FS) is begun to study the best
ways to clean up contamination at the site and evaluate possible
remedial actions for the site. At the conclusion of the
Feasibility Study , the public is given an opportunity to comment
on the PRAP for site cleanup during an advertised 30-day public
comment period.
Ms. Nurse stated that this is where the Croydon TCE site
currently i* in the Superfund process. She explained that the
purpose of the meeting was to present to the public several
alternative* for the remediation of the site. She further
explained that EPA and PADER would be soliciting input. At the end
of May the comments would be studied and a Record of Decision (ROD)
would be written in June. Once completed, the ROD would be
presented to the public. She invited meeting attendees to comment
on the proposed action.
Sha added that all comments made at the meeting were being
recorded and' a transcript would be made. Additionally, EPA will
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prepare a Responsiveness Summary to summarize all comments received
at the meeting and in writing, and EPA's responses to them. These
become part of the final ROD, in which EPA states the next cleanup
action for the site. Once this decision is made, it will be
published in a local newspaper and the public will have another 30-
day opportunity to comment on the Record of Decision.
B. Site Background and Proposed Plan
Jeffrey B. Winegar, P.E., the EPA Remedial Project Manager
(RPM) for the Croydon TCE site, briefly explained the site layout
and history, and the findings of the Remedial Investigation and the
Feasibility Study (RI/FS).
Mr. Winegar explained that the Croydon Site Remedial
Investigation was begun after the results of investigations at
nearby the Rohm & Haas site were released in 1984. That study
identified groundwater contamination which was originating north of
the Rohm & Haas site, thus emanating from a separate source. EPA
concurred with this conclusion of the 1984 study which led to the
placement of the Croydon Site on the NPL in September 1985.
Mr. Winegar then explained that in 1986, Phase I of EPA's
Remedial Investigation of the Croydon Site began. Through the use
of historical aerial photography, investigators were able to detect
potential sources of the groundwater contamination. Aerial
photographs narrowed the study area to a 1.5 square mile area in
Croydon. The Remedial Investigation identified groundwater
contaminants to be trichloroethene (TCE), with a maximum
concentration of 420 parts per billion; 1,1-dichloroethene at 160
parts per billion; and 1,2-dichloroethene at 16 parts per billion.
Surface water contamination was concentrated in the east branch of
Hog Run Creek with TCE at 6.1 parts per billion; and 1,1,1-
trichloroethane at 2.3 parts per billion. These levels of TCE are
well above the Maximum Contaminant Level allowed under the Safe
Water Drinking Act for human ingestion. The investigation also
found sediment contamination in the east branch of Hog Run Creek.
The compounds found were toluene, 1,2-dichloroethene, and methylene
chloride. Soils tested in the study area showed the presence of
polychlorinated biphenyls (PCBs) at 590 parts per billion, which is
low. The action level for PCBs is 50 parts per million.
Mr. Winegar added that an Endangerment Assessment was
conducted as part of the Phase I Remedial Investigation to identify
site risks and ways that people and the environment were exposed to
site contaminants. This study found that domestic use of
groundwater (ingestion and inhalation of contaminants) posed
unacceptable risks to human health. However, skin contact with
both soil..near the Rohm & Haas property and sediments in Hog Run
Creek did not pose unacceptable risks. The action taken as a
result of these findings was to provide alternate water sources for
residents whose wells were contaminated. EPA tested the water from
the Bristol Borough at three locations, which all tested safe.
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Based on those results, EPA connected residents to the city water
lines; the final connection was completed several weeks ago.
Mr. Winegar told meeting attendees that, at the conclusion of
Phase I of the Remedial Investigation, investigators had partially
identified the groundwater contamination boundaries, but had not
pinpointed the source or sources of contamination. As a result, a
Phase II Remedial Investigation was conducted to better define the
boundaries of the contamination and to locate the sources of
contamination. The study focused on three potential sources:
Sherwood Refinishing, Hartwell Trucking and its adjacent property,
and Scorpio Industries. To monitor the potential sources,
monitoring wells were placed upgradient and downgradient of all
three properties. The wells installed varied in depth ranging from
55 to 112 feet. Because the levels of TCE were found to be minimal
in the deeper wells, the study focused on the shallow aquifer which
supplies potable water for area residents. Extensive soil testing
was done using soil boring and soil gas technologies. The soil
testing indicated conclusively that there was no threat to human
health resulting from dermal contact. Phase II of the Remedial
Investigation also sought to confirm or dispel public concerns
raised during Phase I public meetings that material from the Rohm &
Haas landfill had been used as fill in the Croydon area. Suspected
areas were tested and were found to be clean.
Mr. Winegar stated that no definite source had been identifie
at the end of the Phase II Remedial Investigation field study. Tht
investigators next tested a theory that the properties in question
were dumping TCE into the sewer lines. Following key manhole
sampling, the only contaminants found were low concentrations of
xylenes and tetrachloroethene, but no TCE or 1,1-dichloroethene
were detected. Next, looking at the area around Scorpio
Industries, investigators found numerous ground stains on the
aerial photographs dating back to the 1950s. Soil borings were
taken and, again, only low levels of TCE were found. However, when
the samples were taken from groundwater level, the concentrations
increased. This coincided with the Phase I results. The Hartwell
Trucking property also was tested and seven locations were detected
to have volatile contaminants. None of these concentrations,
however, was the source of contamination.
Mr. Winegar concluded his presentation by stating that after
the field investigations were completed, the Feasibility Study was
conducted to identify and evaluate possible courses of action for
the site. The Feasibility Study examined three potential
alternatives: 1) take no action, which the National Contingency
Plan (NCP) requires EPA to consider for comparison purposes; 2)
perform groundwater extraction followed by air stripping and
activated carbon treatment; and 3) perform groundwater extraction
and discharge to the Bristol Township wastewater treatment
facility. EPA is recommending alternative two because it best
protects public health and the environment.
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III. PUBLIC MEETTNfl COMMENT??
This section contains questions and comments presented at the
May 18, 1990, public meeting. Comments contained in this section
are grouped according to subject discussed.
A. The Proposed Remedy for the Croydon TC2 Site
1. One commenter asked whether the proposed treatment
system would allow EPA to distinguish if the
current source of contamination would continue to
affect groundwater.
EPA Response: Because past investigations have been
unable to identify the source of contamination, this
action will not be the final remedy at the Croyden site.
The proposed remedy for this phase will pump and treat
the contaminated groundwater for a period of time, after
which EPA will evaluate whether it is decreasing the
contamination. If concentrations of TCE are found to be
diminishing, the contamination source is probably not a
continuous source, but rather is a historic spill that is
effectively being cleaned up.
2. A commenter asked whether EPA would continue to
look for the source of contamination during the
two years it will take to get a groundwater
treatment facility up and running.
EPA Response: The State is responsible for the
continuous monitoring of the existing wells to see if the
groundwater contamination is affecting other residences
that use private wells. EPA will conduct annual sampling
to see if the contamination is migrating to additional
residential areas.
3 . A meeting attendee asked if residents who are in
the contaminated area and are now booked up to the
city water lines are still using their wells. The
attendee asked EPA to identify the 11 affected
homes and tell how deep their wells are.
EPA Response: The residents whose wells EPA disconnected
and whose homes EPA then connected to public water were
told they could still use their wells for outside use
such as watering and car washing. However, any internal
use* in the household is strictly prohibited, as is any
cross-connection between their wells and the public water
supply that EPA provided. The residential wells were
above the saprolite layer and varied in depth from 20 to
65 feet. Mr. Jeffrey Winegar, the EPA Project Manager
for the site, said he was not at liberty to disclose the
identity of the 11 homes.
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4 . Several commenters asked about the planned desi'
of the treatment plant and how it would impact t
community. Some asked whether the plant will be
placed in anyone's backyard, whether the level of
~~ noise and air pollution would be safe, and whether
it would include several 40- to 50-foot stacks?
EPA Response: EPA will take great care in selecting an
appropriate site for the treatment plant. During the
meeting that will be held when the plant design is 30
percent completed, a secure location should be presented
and EPA will hold a Remedial Design briefing; site
selection will take into account the public's views. The
treatment plant will not be located in a residential
area. The extraction wells may be located on property
lines, but as yet no specific sites for the wells have
been decided. The treatment system will be designed so
that it does not emit gases and thus will present no
health threat. It will require only one air stripping
tower that will be 30 feet tall; no other stacks will be
built. Additionally, the treatment plant will be
equipped with muffler systems that effectively abate
noise.
5. One commenter asked to be shown the proposed
location of the groundwater treatment plant.
EPA Response: The present proposed location for the
treatment plant is south of the East Branch of Hog Run
Creek, off of Oak Street.
6. A commenter asked whether a flood would affect the
integrity of the extraction system and treatment
facility.
EPA Response: The treatment plant will be built above
the 50-year historical flood line. The extraction wells
would not be affected by a flood because they would have
flush covers and be sealed. The treatment plant would
only receive water through the underground piping system,
which means that an increase flow in surface water would
not affect the volume of water to be treated.
7 . One) meeting attendee asked why EPA did not plan to
locate the treatment facility on any of Rohm &
Haas' property holdings in the area. The attendee
stated that building the system in these locations
would place it further away from residential
areas.
EPA Response: EPA will take that suggestion into
consideration when choosing the final location of the
treatment facility. However, EPA has no intention of
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placing it in a densely populated area even though the
exhaust gases pose no threat to the public.
8. On« comment«r asked what will happen if EPA does
'not extend city water to his area and his well
dries up due to the removal of groundwater by the
extraction system.
EPA Response: EPA will construct a groundwater
monitoring system using existing residential and
monitoring wells to track the effect of water
displacement on the areas within the extraction zones.
If necessary, in consultation with the County and
Township, EPA may implement restrictions on groundwater
use. As the final design of the treatment system is
developed, more study will be directed at the effects of
the extraction system on local groundwater.
9 . Several commenters asked whether the treatment
plant would produce any by-products and where such
materials would be disposed.
EPA Response: The process by which TCE is precipitated
out of the groundwater would produce a by-product that
would be affixed to the activated carbon media in the air
stripping tower. All the volatile compounds will be
captured on the activated carbon media, which will then
be sent out to be either regenerated, cleaned with high
pressure steam, or burned. The ultimate decision is left
to the contractor that will be selected to build and
operate the system. Whatever method is chosen will be
carefully monitored. If the by-product is landfilled, it
would be taken to a landfill permitted under the Resource
Conservation and Recovery Act (RCRA). If it is burned,
it would go to an approved RCRA incinerator; because
there are none in the area, the material would probably
be taken out of State. Whatever method is chosen, the
substance will be disposed of in compliance with Federal
and State guidelines.
10. A> commenter asked whether the treatment plant will
be> used for other purposes.
EPA Response: No, it is a single-use facility that
cannot be used for contamination from sources other than
the Croydon TCE site. The function of the treatment
system is to treat the highly concentrated area of the
plume and to draw the contamination in towards the
treatment plant and identify the source.
11. One meeting attendee asked how long it will take
to reach a final design, receive final approval,
and begin operation.
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EPA Response: EPA anticipates that a Record of Decision
will be signed in June 1990. The final design should b
completed within six to eight months following signature
_ The only necessary step in finalizing approval is State
"~ concurrence. A public briefing will be held at the 30-
percent design stage. In early 1991/ shortly after
finalizing the design, bids will be taken for the
construction contract. This generally takes an
additional three to four months. Groundbreaking should
take place in approximately 1 to 1-1/2 years from now and
operation should commence in at least two years.
12. One commenter asked how long the contamination
would continue and what the long-term outcome is
expected to be.
EPA Response: Once the treatment plant is in place and
operational, it will prevent the movement the plume; the
extraction process also will change the configuration of
the plume. If there is a specific source of
contamination, the treatment system will create a
"hallway of contamination" that will point to and
indicate the source. It is not possible at this time to
predict how long treatment will be needed; however, EPA
is required under the Superfund law to return to the site
at least every five years, or earlier if warranted, to
evaluate the effectiveness of the treatment.
13. Several commenters were concerned that the map EPA
was presenting to show the potential site of the
treatment facility did not show street names.
They felt EPA should have supplied such
information.
EPA Response: At the 30-percent design stage meeting EPA
should be able to provide the final proposed locations
for the extraction wells and the treatment plant. At
that time the public will have an opportunity to comment.
Mr. Winegar apologized for the absence of street names.
14. A commenter asked which of the three proposed
alternatives EPA is recommending.
EPA Response: The three alternatives considered for the
site are as follows: 1) Take no action, as required by
the NCP; 2) perform groundwater extraction followed by
air stripping and activated carbon treatment; and 3)
perform groundwater extraction and discharge to the
Bristol Township wastewater treatment facility. EPA is
recommending alternative two because it best protects
public health and the environment
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B. Cost of the Remedial Action for the Croydon TCB Site.
1 . On* commenter aaked what the coat of the remedial
action will be and how future costs were
_ calculated.
EPA Response: EPA looks at capital costs/ which are
costs to build the plant; operation and maintenance
costs, which are costs to operate the plant; and present
worth, which is the amount of money that EPA needs to put
aside to pay for construction and operation of the plant.
The present worth for capital costs is just over
&500,000; the present worth of the annual operating costs
is estimated to be $46,000 per year for the next 30-year
operation period. EPA calculates a 5 percent increase in
costs for each operating year, then calculates the costs
using the value of these costs based on 1990 terms. In
this case, EPA will be budgeting to cover the first 10
years of operation with the State assuming the remaining
operation which is estimated to be 20 years.
2 . Several commenters asked who the responsible
parties are and who will pay for the costs of the
remedial action. They expressed, the concern that
the required money would be obtained from tax
payers.
EPA Response: Superfund was established as a trust fund
to clean up hazardous sites on an emergency basis. The
intention is to identify potentially responsible parties
(PRPs) and recover the costs of the response or get the
PRPs to initiate the cleanup. It is EPA's policy to
recover 100 percent of all past and future costs from the
responsible parties. Superfund is funded through several
different industrial levies, not individual tax payers.
Unfortunately, in this instance the PRPs have yet to be
identified. EPA hopes that the cleanup will point to the
source so that action may be taken to identify the PRP(s)
and recover costs.
C. Site History and Current Status
1 . Several meeting commenters asked whether any wells
had tested positive for TCS outside of EPA's
designated site perimeters and asked what will
happen if the plume is expanding. Another
attendee added that his well, tested
independently, had been found to be contaminated.
EPA Response: Of the wells tested outside the 1.5-mile
radius, only one near Neshaminy Creek showed any
contamination. EPA believes this was the result of a
faulty laboratory test, because this well is not located
in the area of identified groundwater contamination. The
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State will continue to monitor wells in the area to
ensure there are no wells being used with unsafe level«
of TCE. If the plume expands, EPA will expand water
services. Mr. Winegar, the Project Manager, asked who
had tested the commenter's well and when the testing had
been conducted; he said that he would check on the
results and contact the individual.
2 . A commenter asked where the areas of highest
concentrations of TCI are located.
EPA Response: Sampling results show the TCE
concentration in the lower portion of the shallow
aquifer. The outer perimeter of the area of
contamination contains concentrations of one part per
billion; the concentrations increase toward the center of
the contamination. The highest areas of concentration,
to the north of the East Branch of Hog Run Creek, are 420
parts per billion. The treatment processes will place
extraction wells in this area to draw out the
contaminants.
3. One commenter asked how the extraction wells will
be constructed.
EPA Response: The treatment system will initially
require four extraction wells, each of which will be six
to eight inches in diameter. The wells will be
positioned to contain the plume and will reach down to
the saprolite layer of the groundwater. TCE is known to
sink since it is heavier than water; therefore, the
highest concentrations have been found in the deeper
wells. Underground piping will be installed which will
transport the groundwater to the treatment plant where
volatile compounds, including TCE, can be removed.
4 . Several commenters asked about the potential
sources of contaaination and whether EPA had
conducted tests at Coyne Chemical.
EPA Response: The currently identified potential sources
of contamination are Sherwood Refinishing, Hartwell
Trucking and its adjacent property, and Scorpio
Industries. These are being investigated because each
may have used the same chemicals that are currently
causing groundwater contamination. Tests were conducted
at Coyne Chemical as part of the Phase I Remedial
Investigation and no evidence of contamination was found.
5 . One commenter asked what action EPA would take
once the potential contaminators were identified.
The commenter further asked whether these
businesses would be permitted to continue normal
10
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operations, especially given their close proximity
to a residential area.
EPA Response: Once the source or sources are identified,
monitoring wells would be placed upgradient and
-' downgradient of the properties. Soil boring samples and
soil gas samples would be taken throughout the properties
to detect if any illegal dumping was taking place.
Legally, these business may continue to operate until
conclusive evidence is available to take action. Their
close proximity to residential areas constitutes a
Township zoning issue and should be acted upon
accordingly.
6. Several commenters were concerned about possible
soil contamination and the effects of eating
vegetables and fruits grown within the site area.
EPA Response: After extensive soil testing in the area,
EPA found nothing wrong with the soil. There is no
danger in eating foods grown in local gardens.
7 . One cozxunenter asked how soil samples are obtained
and how far into the soil they were taken.
EPA Response: To test the risk of dermal contact, soil
tests are conducted on the first six inches of soil. The
first six inches represent the soil humans are most
likely to come into contact with through ingestion and
airborne particulates.
8 . A commenter asked if, in the case of Rohm £ Haas,
EPA had tested soil deeper due to objects buried
deeper than six inches.
The Rohm & Haas landfill is not included in this study;
however, EPA has determined that Rohm & Haas did not
contribute to the groundwater contamination that is
affecting the Croydon area. The Rohm & Haas landfill
falls under RCRA. Mr. Winegar offered to entertain
questions about the Rohm & Haas study at the end of the
meeting.
9. A commenter asked if EPA had identified potential
TCS polluters through historical data of former
companies in the area.
EPA Response: EPA conducted title and deed searches of
the industrial-use properties, going back many years
prior to the current ownership, to determine if any
previous businesses had used processes requiring the use ,
of TCE. No new PRPs were identified.
11
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10. One commenter asked whether EPA had notified
resident* living near the three identified
potential sources of contamination of potential
well contamination.
-" EPA Response: Yes. One resident who lives next to the
Sherwood Refinishing plant subsequently found that his
well was contaminated. He has now been hooked up to the
city water lines.
11. One commenter was concerned about people who for
years have been exposed to the contaminants
through the use of their wells. The commenter
asked when the first study had come out and
whether someone could conduct an epidemiological
test.
EPA Response: The first study was completed in 1987,
after a field investigation was conducted. After
contamination was discovered in the sampled wells, the
affected residents were notified by letter. They are
definitely at risk if they were drinking the well water
from 1960 through 1980. Unfortunately, if they want to
be examined for possible adverse effects, they will have
to bear the expense.
12. One commenter asked if those people in the
affected area who had hooked up to the city watez
lines before EPA knew of the contamination would
have been hooked up had they waited, even though
the first study indicating contamination came out
in 1984.
EPA Response: If EPA had discovered contamination in
those wells, the connection to city water lines would
have been covered by Superfund. However, EPA did not
conduct the 1984 study; Rohm & Haas did. Because of the
need to verify these results, EPA decided to conduct its
own study during which sampling and analytical procedures
were carried out to meet EPA's stringent requirements.
General Comments
1 . Oae> commenter asked if the practice of oiling the
streets to control dust, employed up to 1950,
could have caused the TCI problem.
EPA Response: The oil used for that purpose should have
contained solvents allowing the oil to bond with the
soil. Any possible water contamination would have
resulted if the the substance contained in the oil was
stripped from the oil and soil, thus allowing it to seep
into groundwater. It is not a likely source of the
current contamination.
12
-------
2. Several mooting attendees were concornod about tho
abort public notico poriod and tboir inability to
proparo for tbo mooting.
"" EPA Response: EPA apologized for the delay in placing, a
public notice about the meeting in the local paper. This
occured because of a change in the scheduling of the Town
Council meeting. This EPA meeting date was changed to
avoid a conflict. EPA's customary practice is to
announce the meeting at least two weeks in advance.
Every effort will be made to follow normal public
announcement procedures before future site meetings.
3. A mooting attendee roforrod to a cleanup of
underground tanks whicb was ovorsoon by EPA in the
area between tbo Hartwoll and Sherwood properties.
Tho attendee asked wetbor tbat tbat problem bad
contributed to tbo current contamination.
EPA Response: EPA is aware of the cleanup which probably
came under the jurisdiction of the EPA removal program.
The cleanup would have included testing to ensure that
the removal was effective.
4. Another mooting attondoo askod bow EPA would bo
alerted to a midnight dumper sinco tbo soil in tho
aroa is sandy and tbo spill would migrate quickly.
EPA Response: EPA has in place monitoring wells that go
down to the saprolite area. These wells are deep enough
to detect such fluctuations in contamination levels.
5. Ono commonter felt tbat tbo stack at tbo treatment
facility would only bo transferring tbo problem to
tbo air, which would bo compounded by Rohm & Haas'
proposed incineration facility.
EPA Response: EPA is predicting 96 to 99 percent removal
of TCE from stack emissions from the Croydon treatment
plant. There is no health risk associated with the
exbaust gases from the air stripping unit.
6. On* commonter askod wbon a site is designated as
requiring no further action. Tbe commonter askod
wbetber tbe site is tben considered to be "clean"
and can be removed from tbe National Priorities
List (NPL).
EPA Response: The process for removing a site from the
NPL is called deletion. Once a site has meet the
relevant and appropriate requirements of Superfund to
protect the public health and safety/ a public hearing is
held to decide on whether or not to remove the site from
13
-------
the NPL. This is done only after the site is deemed
clean after many years of monitoring its stability by
EPA.
7 . -~ A commenter asked whether homes ia close proximity
to Sherwood Refinishing or Dave's Furniture were
in any danger from air pollution.
EPA Response: Any danger posed from emissions is not
covered under Superfund. The Township ordinances govern
the level of current emissions.
14
-------
2. Other Potential Sources of Contamination
1 . X commenter asked if EPA was aware of a pesticides
_ facility that used to be located on River Road.
EPA Response: No, the current investigation was based on
the historical aerial photographs that indicated ground
stains as far back as 1950 as well as the stockpiling of
drums and other debris. Mr. Winegar asked for an address
which was given as 2901 River Road.
2 . One meeting attendee referred to a letter in the
site information repository which recommended
geophysical techniques be used on the Hartwell
property. Additionally, the questioner expressed
dismay that, with the current level of technology,
the source of contamination could not be located.
EPA Response: EPA did conduct a magnetometer survey of
the Hartwell property and the adjacent property. Through
the technique of soil gas technology and soil borings,
contamination of TCE was found. However, the
contamination was 20,000 parts per billion at four to six
feet below the ground surface. This- has not reached the
groundwater level. Because this spill could affect the-
groundwater in the future, EPA notified PADER of the
site. PADER will take the appropriate action of
notifying the property owner and getting him to clean the
site. If the property owner does not take immediate
action, the Superfund program would initiate cleanup.
3 . One commenter who lives near one of the monitoring
wells near the Hartwell Trucking property was
concerned about the safety of animals and children
that played in the creek which also ran through
the Hartwell property.
EPA Response: In order to be at risk, the children would
need to come in direct contact with the identified "hot"
spot on Hartwell property. They would have to
intentionally inhale dirt or dig directly in the
contaminated soil to come into skin contact with the
contamination. Contact with the creek or sediments in
the creek poses no threat to either humans or animals.
4 . One commenter informed SPA of a rumor that there
was an illegal dump within the wetlands adjacent
to the Scorpio property near Excelsior.
EPA Response: EPA did not test in that particular area
because it was not identified as a potential source from
-the aerial photography.
15
-------
APPENDIX A
COMMENTS ON THE .PROPOSED REMEDIAL ACTION PLAN
FOR THE CROYDON TCE SUPERFUND SITE
FROM
ROHM & HAAS
-------
ROHM AND HRRS DELflWBRE VRL . EY INC.
P O. CJOX 819. BRISTOL. PA. 19007
(219) 783-9000
May 30, 1990
Mr. Jeff Winegar
Remedial Project Manager
U.S.EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
Dear Mr. Winegar
«
During the public hearing on the Croydon TCE Superfund Site a question was raised by Ms. Anna
Rogers, Councilwpman of Bristol Township regarding notification of local authorities and other
appropriate agencies of analytical results when the issue of potential TCE contamination was first
discovered.
Dr. Paul Rosenstock of Rohm and Haas Company stated such notifications of the analytical results
was made to the local government in 1984 --a statement clearly questioned by Ms. Rogers.
Attached is a chronology of the correspondence and copies of those communications to the Bristol
Township officials detailing the analytical results of individual homeowner's wells. You will note
copies of all analysis were also sent to the Bucks County Health Department.
We would ask that the public record on this issue reflect these documents so as not to confuse or
misrepresent the situation.
Sincerely,
Brian McPeak
cc: Councilwoman Anna Rogers
BMcP/dew
Attachments
SUBSIDIARY OF NOMM AND HAM COMPANY
-------
ROHM flND HflflS DELRWRRE VOLLEY INC.
P O BOX 719. BRISTOL. PA. 19O07
:213) 79S-80OO
May 24, 1990
Ms. Anna Rogers
Councilwoman
2591 Oxford Valley Road
Bristol Township Municipal Building
Levittown, PA 19057
Dear Ms. Rogers:
At the public hearing on theCroydon TCE Superfund site you publicly questioned the statement that
Rohm and Haas had notified the local officials of the results of the monitoring of homeowner wells
conducted in 1984. By the tone and manner of your comment, you raised publicly a question as to
whether such notification indeed took place.
We have reviewed our files and found the following list of documents to be related to this issue and
forwarded to your local government at that time.
October 13. 1983:
To:
From:
Subject:
February 2. 1984:
To:
Fro a:
Subject:
Copy tat
Mr. Carmen Raddi, Acting Manager, Bristol Township
Richard Grzywinski, P.E. - V.P.
Betz, Converse, Murdoch
Invitation to offer residents and businesses in Croydon a laboratory analysis of
water provided for their private wells at Rohm and Haas* expense.
Requested name & other information of residents requesting this service.
Mr. Robert Lewis, President
Board of Supervisors
Mr. Richard J. Grzywinski, P.E. - V.P.
BCM Eastern, Inc. (formerly Betz, Convene, Murdoch)
Analysis of residential wells
The analytical results of water samples collected by BCM from nine Township
residential wells in the Croydon area.
Bucks County Board of Health
Ffbruarv 16. 1994:
To:
From:
Subject
Copy to:
Mr. Robert Lewis, President
Board of Supervisors
Richard J. Grzywinski, BCM Eastern, Inc.
Final Analytical results for nine residential well in Croydon
Bucks County Board of Health
SUBSIDMHY rf MM* AND MAM COMPANY
-------
-2-
June 11. 1984:
To:
From:
Subject:
Copy to:
Mr. Robert Lewis, President
Board of Supervisors
Richard J. Grzywinski, BCM Eastern, Inc.
Analysis of 4 additional residential wells in Croydon
Bucks County Department of Health
October 18. 1984:
To:
From:
Subject:
Copy to:
Mr. Robert Lewis, President
Board of Supervisors
Richard J. Grzywinski, BCM Eastern, Inc.
Analysis of results from one residential well in Croydon
Bucks County Board of Health
Auftat 7. 1984:
To:
From:
Subject:
Copy to:
Mr. Robert Lewis, President
Board of Supervisors
Richard J. Grzywinski, BCM Eastern, Inc.
Analysis of results from one residential well in Croydon
Bucks County Board of Health
May 30. 1985:
To:
From:
Subject:
Copies to:
Mr. George Foster/Maple Beach Road
Richard J. Grzywinski, BCM Eastern, Inc.
Analysis of well
Bucks County Health Department
Stanley Gawel, Bristol Township Manager
Each of the refertaced letters included a packet of information which detailed the analytical results.
They are also put of the previous studies on our site conducted by BCM and submitted to the
U.S.E.P.A. with copies to Bristol Township.
-------
-3-
Frankly as the list of references indicates, we fully informed all the agencies and local community.
To suggest otherwise was grossly unfair. We are submitting this letter along with appropriate
references to the U.S.E.P.A. so that the official proceedings and record of the public hearing will be
complete. In the event you no longer have these files at the municipal building, you can call me at
785-8828 to discuss the matter, or contact the Bucks County Department of Health, which received
copies of all the correspondence listed.
Sincerely,
Brian McPeak
C. Raddi
J. Gallagher
A. Cipullo
C. Cini
V. Lattanzi
R. Lewis
P. Roseostock, Rohm and Haas DVI
State Representative Anthony Melio
BMcP/dew
-------
7 14 1335
BCM] Befz • Converse • Murdoch • Inc.
Consulting Engineers. Planners and Scientists
October 13, 1983
Mr. Carmen Raddl "-k
Acting Manager .r>xc j~ _
Bristol Township " p,n ~
-s — A- ._ » ,, « • M . ' - * f r* 'V JT^f
250 Oxford valley Road WJF__ GC)t__ , ?_
levittown, PA 19057 ta HJ(^ ,'ll§_
Subject: Groundwater Analysis 5f? — •: 3^7-47 1.
"*" /
Dear Mr. Raddl:
The Rohm and Haas Company has authorized BCM Eastern Inc. (BCM) to offer
residents and businesses In Bristol Township a laboratory analysis of
water provided from their private wells. This offer Is made to any rest- ••
dent or business within an area bounded by China Lane (River Road), State-
Road, Elm Avenue and Cedar Avenue. The fees for the analyses are, of
course, being paid for by Rohm and Haas Company.
Please provide me with the name, address, and phone number of any township
resident or business within the delineated area who desires this service.
In order to complete this work in a reasonable time frame, I ask that you
provide BCM with this information by October 31, 1983.
Samples must be taken by a qualified BCM technician only. No samples
other than those collected by a trained technician, using the prescribed
EPA sampling methodology, can be included in the program.
Please call me at any time if you have any questions. I look forward to
hearing from you by the end of the month.
Very truly yours
Richard J. Grrywlnskf, P.E.
Vice President
pd
cc: P. 0. Rosenstock, Rohm and Haas Company
6. A. Schnabel, Rohm and Haas Company
Eastern Group.
One Plymouth Meetirv? Moll • Plymouth M- Ji
-------
BCM
BCM Eastern Inc.
Engineers. Planners and Scientists
One Plymouth Meeting • Plymouth Mee/ing. PA 19442 • Phone.- (215) 825-3800
February 2, 1984
j'.Ji/ 14 13c5
Mr. Robert Lewis, President
Board of Supervisors
Bristol Township
Bristol, PA 19007
Subject: Analysis of Residential Wells
Dear Mr. Lewis:
BCM Eastern Inc. (BCM) is pleased to provide you with the analytical
results of the water samples collected by BCM from nine township residen-
tial wells (Table 1). The names and addresses of the well owners are
presented in Table 2. The well locations are as provided to BCM by
Bristol Township.
With one exception, concentrations of each of the parameters for which
there is an associated U.S. Environmental Protection Agency Interim Pri-
mary Drinking Water Standard are within those standards. The exception
is the nitrate concentration in well 6 which is 11.05 mg/1 (milligrams
per liter or ppm), which is 1.05 mg/1 above the drinking water standard.
Trichloroethylene (TCE) was detected in five of the wells.
Should you have any questions or require additional information, please
do not hesitate to contact me.
Very truly yours,
Richard J. Grzywinski, P.E.
Vice President
pd
Attachments
cc: Bucks County Board of Health
A Member firm of Sett •Converse -Murdoch* inc.
-------
CM :
Parameter
Units
Johnson Residence
Orchard Avenue
Priority Pollutants - 3ase Neutral Orqanics (Continued)
2,6-Oinitroteuene ug/1
Acenaphthene ug/1
2,4-Oinitrotoluene ug/1
Oiethyphthalate ug/1
Fluorene ug/1
4-Chlorophenyl phenyl ether ug/1
diphenyla/nine-n-nitroso ug/1
1,2-Diphenylhydrazin'e ug/1
(Azobenzene)
4-8romopher.yl phenyl ether ug/T
Hexachlorobenzene ug/1
Phenanthrene ug/1
Anthracene ug/1
Oi-n-butyl Phthalate ug/1
Fluoranthene ug/1
Benzidine ug/1
Pyrene , ug/1
Butybenzyphthalate ug/1
8enzo(a)anthracene ug/1
3,3'-Oich1orobenzidine ug/1
Chrysene ug/1
bis-(2-Ethylhexy1) phthalate ug/1
Di-n-octyl phthalate ug/1
8enzo(b)fluoranthene ug/1
8enzo(k)fluoranthene ug/1
8enzo(a)pyrene ug/1
Indeno(l,2,3-c,d)pyrene ug/1
Oibenzo(a,h)anthracene ug/1
Benzo(g,h,i)perylene ug/1
Priority Pollutants - Acid Extractable Organlcs
29
<25
<25
<25
Phenol
2-Chlorophenol
2-NitrophenoI
2,4-0fmethyl phenol
2,4-Dlchlorophenol
p-Chloro-m-Cresol
2,4,6-Trlchlorophenol
2,4-Oinitropnenol
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
<25
<2S
<25
<25
<25
<25
<25
<250
-------
FECM
Parameter
Units
Johnson Residence
Orchard Avenue
CATEGORY 5
Volatile Organics - EPA Method 601 (Continued)
1,1,1-Trichloroethane ug/1
Carbon tetrachloride ug/1
Bromodichloromethane ug/1
1,2-Dichloropropane ug/1
trans-l,3-0ichloropropylene ug/1' 1
Trichloroethylene ug/1
Dibromochloromethane and/or
1,1,2-Trichloroethane and/or
cis-l,3-0ichloropropylene ug/1
Bromoform ug/1
1,1,2,2-TetrachJoroethane and/or
Tetrachloroethene ug/1
Chlorobenzene ug/1
4.3
3.1
Volatile Oroanics - EPA Method 602
Benzene
Toluene
Chlorobenzene
Ethylbenzene
1,2-Oichlorobenzene
1,3-Dichlorobenzene
1,4-Oichlorobenzene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
Priority Pollutants - Base Neutral Organics
N-Nitrosodimethylam1ne ug/1
bis-(2-Chloroethy1) ether ug/1
1,3-Dichlorobenzene ug/1
l,4-01chlorobenzene ug/1
1,2-Oichlorobenzene ug/1
bis-(2-Chloro1sopropyl) ether ug/1
Hexachloroethane ug/1
N-Nitrosodl-n-prophylamine ug/1
Nitrobenzene ug/1
Isophorone ug/1
bis-(2-Chloroethoxy) methane ug/1
1,2,4-Trichlorobenzene ug/1
Naphthalene ug/1
Hexachlorobutadiene ug/1
Hexachlorocyclopentadiene ug/1
2-Chlororraphthalene ug/1
Oimethyphthalate ug/1
Acenaphthylene ug/1
-------
IEGV1 -
Johnson Residence
Parameter Units Orchard Avenue
CATEGORY 3 - NON-PRIORITY
Cellosolve acetate
Butyl cellosolve
Karathane
Lethane
ONCP
Oi thane
2,4-0
2,4,5-TP
POLLUTANT
mg/1
mg/1
mg/1
mg/1
mg/1
mg/J
ug/1-
ug/1
CATEGORY 4 - PRIORITY POLLUTANTS -
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thall ium
Zinc
Cyanida
Phenols
CATEGORY 5
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
ORGANICS (Continued)
<0.1
<0.1
<0.01
<0.001
<0.01
<0.02
<1
<0.5
METALS, CYANIDE, PHENOLS
<0.15
0.004
<0.01
7^<0.0005
• t- 0.003
<0.03
0.016
0.0004
<0.1
<0.001
<0.001
<0.3
<0.01
<0.005
0.009
Volatile Organic* - EPA Method 601
Chloromethane
Bromomethan*
Vinyl chloride
Chloroethan*
Methyl ene chloride
Trichlorofluoromethane
1,1-Dichloroethylene
1,1-Oichloroethane
trans-l,2-0ich1oroethylene
Chloroform
1,2-Dichloroethane
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
-------
ECM.
TABLE 1
RESIDENTIAL WELL ANALYTICAL DATA
BRISTOL BOROUGH, PENNSYLVANIA
Parameter
Units
Johnson Residence .i
Orchard Avenue
CATEGORY 1 - INDICATOR PARAMETERS
PH
Specific conductance
BOD
COO
TOC
CATEGORY 2 - NON-PRIORITY
Ammonia (as N)
Boron
Chloride
Fluoride
Iron
Nitrate (as N)
Phosphate, Total as P
Sulfate
Sodium
Potassium
Barium
Manganese
Sulfide as S
Tin
CATEGORY 3 - NON-PRIORITY
Surfactants (M8AS)
Oil and grease
Methyl ethyl ketone
Isobutyl alcohol
N-butyl alcohor
Isopropyl alcohol
Ethanol
Butyl methacrylate
Methyl methacrylate
Ethyl acrylate
Sutyl acrylate
Styrene
Acetone
Ethyl acetate
Standard units
umhos
" mg/1
mg/1
mg/1
POLLUTANT INORGANICS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
POLLUTANT ORGAN I CS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
5.4
86.6
<6
15
4
<0.05
-------
Parameter units Steele Residence*
Priority Pollutants -
4-Nitrophenol
4,6-Dinitro-o-Cresol
Pentachloro phenol
Priority Pollutants -
Aldrin
Alpha-8HC
8eta-3HC •
Ga/nma-8HC
Delta-8HC
Chlordane
4,4'-OOT
4,4'-OOE
4,4'-000
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Heptachlor
Heptachlor Epoxide
PC8-1242
PC8-1252
PCB-1221
PC8-1232
PCB-1248
PC8-1260
PC8-1016
Toxaphene
Acid Extractable Oroanics (Continued)
ug/1 <25
ug/1 <250
ug/1 <25
Pesticides and PC8s
ug/1 <10
ug/1 <10
ug/1 <10
ug/1 <10
ug/1 <10
ug/1
-------
!BCM
Parameter Units Steele Residence'
Priority Pollutants - Base Neutral Organics (Continued)
2,6-Oinitroteuene ug/1
Acenaphthene ug/1
2,4-Oinitrotoluene ug/1
Diethyphthalate ug/1
Fluorene ug/1
4-Chlorophenyl phenyl ether ug/1
diphenyla/nine-n-nitroso ug/1
1,2-Oiphenylhydrazine ug/1
(Azobenz°re)
4-8romophenyl phenyl ether ug/1
Hexachlorobenzene ug/1
Phenanthrene ug/1
Anthracene ug/1
Di-n-butyl Phthalate ug/1
Fluoranthene ug/1
Benzidine . ug/1
Pyrene ug/1
Butybenzyphthalate ug/1
Benzo(a)anthracene ug/1
3,3'-Oich1orobenzidine ug/1
Chrysene ug/1
bis-(2-Ethylhexyl) phthalate ug/1 29
Oi-n-octyl phthalate ug/1
Benzo(b)fluoranthene ug/1
Benzo(k)f1uoranthene ug/1
Benzo(ajpyrene ug/1
Indeno(l,2,3-c,d)pyrene ug/1 <25
Oibenzo(a,h)anthracene ug/1 <25
Benzo(g,h,i)perylene ug/1 <2S
Priority Pollutants - Acid Cxtractable Organics
Phenol ug/1 <25
2-Chlorophenol ug/1 <25
2-Nitrophenol ug/1 <25
2,4-Oimethylphenol ug/1 <25
2,4-Oichlorophenol ug/1 <25
p-Chloro-m-Cresol ug/1 <25
2,4,6-Trichlorophenol ug/1 <25
2,4-Oinitrophenol ug/1 <250
-------
BOM
Parameter
Units
Steele Residence*
CATEGORY 5
Volatile Organfcs - EPA Method 601 (Continued)
1,1,1-Trichloroethane ug/1
Carbon tetrachloride ug/1
Bromodichloromethane ug/1
1,2-Dichloropropane • ug/1
trans-l,3-DichIoropropylerte ug/1
Trichloroethylene ug/1
Dibromochlcromethane and/or
1,1,2-Trichloroethane and/or
cis-l,3-0ichloropropylene ug/1
Sromoform ug/1
1,1,2,2-Tetrachloroethane and/or
Tetrachloroethene ug/1
Chlorobenzene ug/1
Volatile Organics - EPA Method 602
Benzene ug/1
Toluene ug/1
Chlorobenzene ug/1
Ethylbenzene ug/1
1,2-Dicnlorobenzene ug/1
1,3-Dichlorobenzene ug/1
1,4-Oichlorobenzene ug/1
Priority Pollutants - Base Neutral Organics
N-Nftrosodiraethylamine
bis-(2-Chloroethy1) ether
1,3-Oichlorobenzene
1,4-Oichlorotenzene
l,2-OichToro6enzene
b1s-(2-ChT«rofsopropyl) ether
HexachloroetJiine
N-Nitrosodf-n-prophylaraine
Nitrobenzene
Isophorone
bis-(2-Chloroethoxy) methane
1,2,4-Trichlorobenzene
Naphthalene
Hex achlorobutadiene
Hexachlorocyclopentadiene
2-Chloronaphthalene
Oimethyphthalate
Acenaphthylene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
-------
iBCM
Parameter Units Steele Residence*
CATEGORY 3 - NON-PRIORITY POLLUTANT ORGANICS (Continued)
Cellosolve acetate
Butyl cellosolve
Karathane
Lethane
ONCP
Di thane ....
2,4-0
2,4,5-TP
Total XylericS
mg/1
mg/1
mg/1
mg/1
mg/1
. mg/J
ug/1 •'<
ug/1
ug/1
<0.1
<0.1
<0.0l
<0.001
<0.01
<0.02
<0.05
<0.01
<1.0
CATEGORY 4 - PRIORITY POLLUTANTS - METALS, CYANIDE, PHENOLS
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thall ium
Zinc
Cyanide
Phenols
CATEGORY 5
Volatile Organic* - EPA Method
ChToromethin*
Bromomethaiwfr
Vinyl chlorfd*
Chloroethane
Methyl ene chloride
Trichlorofluoromethane
1,1-Oichloroethylene
1,1-Oichloroethane
trans-l,2-0tchloroethylene
Chloroform .
1,2-Oichloroethane
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
601
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
<0.16
0.009
<0.01
<0.0005
<0.002
<0.03
<0.002
0.0004
<0.10
<0.001
<0.001
<0.30
<0.011
<0.005
0.002
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
1.7
<1.0
-------
ECM
BCM Eastern Inc.
Engineers. Planners and Scientists
On* Plymouth Meeting • Plymouth Meeting. PA 19462 • Phone: (215) 825-3800
October 18, 1984
Mr. Robert Lewis, President
Board of Supervisors
Bristol Township
Bristol, PA 19007
Subject: AnalyticaT Results From the Steele Residential-Wei 1-
BCM Project" No. 00-4061-10
Dear Mr. Lexis:
BCM Eastern, Inc. (BCM) is pleased to provide you with the analytical
results of the water sample collected by BCM from a well at the Steele
residence at 740 Church Street, Croydon, Pennsylvania. The well is no
longer used as a source of drinking water.
The concentration of each of the parameters for which there is an associ-
ated U.S. Environmental Protection Agency (USEPA) Interim Primary Drinking
Water Standard is within standard. Iron and manganese concentrations
exceed the USEPA secondary standards of 0.3 mg/1 and 0.05 mg/1 by 3.46
mg/1 and by 0.49 mg/1, respectively.
Should you have any questions or require additional information, please
do not hesitate to contact me.
Ver* truly yours,
Richard J. Grzywlnski, P.E
Vice President
Pd
Enclosure
cc: Sucks County Board of Health
A Member firm of 8efz« Converse'Murdoch* Inc. •
-------
BCM
TABLE 1
STEELE RESIDENTIAL WELL ANALYTICAL DATA
BRISTOL BOROUGH, PENNSYLVANIA
Pardmeter Un1ts Steele Residence*^
CATEGORY 1 - INDICATOR PARAMETERS
PH
Specific conductance
BOD
COD
TOC
Fecal Col i form
Total Col iform
CATEGORY 2 - NON-PRIORITY
Ammonia (as N)
Chloride
Fluoride
Iron
Nitrate (as N)
Phosphate, Total as P
Sulfate
Sod i urn
Potassium
Barium
Manganese
Sulfide as S
Standard units
umhos
mg/1
mg/1
mg/1
MPN/100 ml
MPN/100 ml
POLLUTANT INORGANICS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
ma/ 1
J
mg/1
mg/1
mg/1
mg/1
mg/1
5.6
162
<3
24.6
6.9
<2
<2.2
0.08
8.9
<0.1
3.76
0.87
0.05
37.5
16.6
2.22
<0.01
0.54
<1
CATEGORY 3 - NON-PRIORITY POLLUTANT ORGANICS
^actants (MBAS) mg/1 JOT}
Oil and gr*asr mg/1 *T?q «
Methyl ethy> ketone mg/1 <0i
Isobutyl alcohol mg/1
-------
4-Nitrophenol
4,6-Dinitro-o-Cresol
Pentachlorophenol
ug/1
ug/1
ug/1
PRIORITY POLLUTANTS
<25
<250
<25
<25
<250
<25
<25
<250
<25
<25
<250
<25
Aldrin
Alpha-BHC
8eta-8HC
Garrma-BHC
Oelta-BHC
Chlordane
4,4'-OOT
4,4'-OD£
4,4'-000
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Heptachlor
Heptachlor Epoxide
PC8-1242
PCB-1252
PC8-1221
PC8-1232
PCB-1248
PCB-1260
PCB-1016
Toxaphene
Me,!L0wnJrSraBd
" ' 0$ter»
•
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
Road
- — - -~ '"vci i ci ence
•' HFW . 02/07/84; NSW - 02/U/84; GBW - 03/05/84; TKW - 03/06/84
Source: BCM Eastern. Inc.
-------
_ Well*
Parameter Units RPw HGW —GBW TKW"
CATEGORY 5 - VOLATILE ORGANICS - EPA METHOD 601 (Continued)
1,1,1-Trichloroethane. ug/1 <1.0 <1.0 <0.1 <0 1
Carbon tetrachloride ug/1 '
-------
flig«inLPOUUTANTS - BASE MP,.m, no,,.,., (Cont1nued)
2,6-Dinitroteuene
Acenaphthene
2,4-Oinitrotoluene
Oiethyphthalate
Fluorene
4-Chlorophenyl phenyl ether
diphenylamine-n-nitroso
• 1,2-0iphenylhydra*ine
(Azobenzene)
4-8romophenyl phenyl ether
Hexachlorobenzene
Phenanthrene
Anthracene
Oi-n-butyl Phthalate
Fluoranthene
Senzidine
Pyrene
Sutybenzyphthalate
8enzo(a)anthracene
3,3'-Oich1orobenzidine
Chrysene
b1s-(2-£thylhexyl) phthalate
Di-n-octyl phthalate
8enzo(b)fluoranthene
Benzo(k)fluoranthene
8enzo(a)pyrene
Indeno(l,2,3-c,d)pyrene
Oibenzo(a,h)anthracene
8enzo(g,h,ijperylene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
"ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
Phenol
2-Chlorophenol
ug/1
ug/1
2-Nitrophenol
2,4-Ofmethylphenol
2,4-D1chlorophenol
p-Chloro-m-Cresol
2,4,6-Trfchlorophenol
2,4-Oinitrophenol
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
PRIORITY POLLUTANTS - ACID EXTRACTABLE
<25
<25
<25
<25
<25
PRIORITY POLLUTANTS - ACID »TR4rTap. r
120
<25
<25
<25
<25
<25
<25
<25
<25
<25
<25
<250
<25
<25
<25
<25
<25
<250
<2S
<25
<25
<25
<25
<25
<25
<25
<25
<25
<250
<25
<25
<25
<25
<25
<25
<25
<25
<25
<25
<250
-------
TABLE 1
RESIDENTIAL WELL ANALYTICAL DATA
BRISTOL BOROUGH, PENNSYLVANIA
CATEGORY 1 - iNDirATHP PARAMETERS
PH
Specific
BOD
COD
TOC
conductance
Standard units
umhos
mg/1
mg/f
mg/1
- NON-PRIORITY POLLUTANT INORGANICS
Ammonia (as N)
Boron
Chloride
Fluoride
•
Iron
Nitrate (as N)
Phosphate
Sulfate
Sodium
"ntassium
rium
..anganese
Sulfide as S
Tin
CATEGORY 3 - NON-PRIORITY
Formaldehyde **
Surfactants (MBAS)
Oil and grease
Methyl ethyl ketone
Isobutyl alcohol
N-butyl alcohol
Isopropyl alcohol
Ethanol
Butyl methacrylate
Methyl methacrylate
Ethyl acrylate
Butyl acrylate
Styrene
Acetone
Ethyl acetate
mg/1
mo/1
y
mn 1 1
nry/ i
mg/1
ma /I
1 1 iy / i
mg/1
mg/1
ma/ 1
Miy/ i
mg/1
mg/1
mg/1
ma/1
II INJ I 1
mg/1
mg/1
POLLUTANT ORGAN ICS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
0.40
0.16
40.0
0.03
3.15
3.50
<0.01
45.0
18.8
224.0
0.065
0.6
0.39
0.041
3.0
CO.l
CO.l
:o.i
<10.0
<0.1
<0.1
<0.1
<0.1
<0.1
0.09
0.04
5.6
0.34
0.05
<0.09
,10
,25
42.1
1.63
0.051
<0.02
0.
1
<0.001
0.032
2.0
<10.0
5.9
161
<3
<4
<1
<0.05
0.04
23.2
0.13
2.33
0.83
0.01
21.5
15.9
1.77
0.083
0.08
6.7
857
<3
8
1
0.36
0.10
14.0
0.09
8.00
1.19
0.05
248
14.8
79.5
0.080
3.7
0.01
0.05
2.0
0.08
0.22
<10.0 <10.*0
-------
Parameter
Units
CATEGORY 3 - NON-PRIORITY
Cel losolve acetate
Butyl cellosolve
Karathane
Lethane
DNCP
Oithane
2,4-0
2,4,5-TP
POLLUTANT ORGANICS (Continued)
ma/1 'rt '
n**j/ i
ma/1
"'gr '
mg/1
mg/1
mg/1
mg/1
mn/ 1
'•ly/ i
mg/1
CATEGORY 4 - PRIORITY POLLUTANTS - METALS. CYANIDE.
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Phenols
CATEGORY 5 - VOLATILE ORGAN
Chloromethane
Bromomethane
Vinyl chloride
Chloroethane
Methylene chloride
Trichlorof luoromethane
1,1-Oichloroethylen*
1,1-Oichloroethane
trans-l,2-0ichloroethy1ene
Chloroform
1,2-Oichloroethane
. - — — T
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mrt / 1
my/ i
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
ICS - EPA METHOD 601
ua/1
U ^ / 1
ua/1
uy/ i
ua/1
uy/ i
ua/1
uy/ i
ug/1
ug/1
ug/1
ua/1
uy/ i
ug/1
ug/1
ug/1
NW. 1
XA i
vu. 1
<0.01
<0.001
<0.01
<0.02
xi n
<1 .U
<0.5
PHENOLS
<0.15
0.001
<0.01
<0.01
<0.02
<0.03
0.003
<0.0002
xA 1
<0.1
<0.001
<0.02
<0.30
1.28
<0.005
0.003
xi A
VI .U
xl A
<1 .0
xi A
-------
BCM BCM Eastern Inc. ....
J Engineers. Planners and Scientists / b / /*
On« Plymouth Meeting • Plymouth Meeting. PA 19462 • Phone. (215) 825-3800
June 11, 1984
Mr. Robert Lewis, President 1.3V 141385
Board of Supervisors
Bristol Township : ••*%..%-• „
Bristol, PA 19007
Subject: Analysis of Residental Wells
Dear Mr. Lewis:- _ ~_
BCM Eastern Inc. (BCM) is pleased to provide you with the analytical
results of the water samples collected by BCM from four township residen-
tial wells (Table 1). The names and addresses of the well owners are
also presented in Table 1. Please note that only the HGW well is util-
ized for drinking purposes as the other wells are used for outdoor or
lawn watering purposes.
With two exceptions, concentrations of each of the parameters for which
there is an associated U.S. Environmental Protection Agency Interim Pri-
mary Drinking Water Standard are within those standards. The exceptions
are the cadmium concentrations in the G8W and TKW wells which are 0.21
milligrams per liter (mg/1) (parts per million), and 1.14 mg/1, respec-
tively. These concentrations are over the drinking water standard of
0.01 mg/1. Trichloroethylene (TCE) was detected in the HGW and TKW wells
at concentrations below the Pennsylvania state guidance concentration of
4.5 micrograms per liter (ug/1) (parts per billion). Bis(2-Ethylhexyl)
phthalate was found in the TKW well at a concentration of 120 ug/1.
Should you have any questions or require additional information, please
do not hesitate to contact me.
Very truly yours,
R1
Vice President
Industrial Services
/Jmk
Attachments
cc: Bucks County Department of Health
P. Rosenstock, Rohm and Haas*/
6. Schnabel, Rohm and Haas
A Member firm of Befz•Converse'Murdoch*Inc.
-------
BRISTOL BOROUGH SUPPLY WELL ANALYTICAL DATA Page 1 of £
FEBRUARY 10, 1984
Bristol Borough
Supply Well (BBW) USEPA Interir
BCM Sample No. 14417 Primary Drink
Parameter Units ' Sample Date: 10/14/83 Water Standai
CATEGORY 1 - INDICATOR PARAMETERS
PH
Specific Conductance
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Organic Carbon
CATEGORY 2 - NON-PRIORITY
Boron
Iron
Manganese
Sodium
Tin
Chloride
Fluoride
Potassium
Ammonia (as N)
Nitrate (as N)
iulfate
Phosphate
Sulfide
Standard units
Umhos
mg/1
mg/1
mg/1
POLLUTANT INORGANICS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
6.0
484
<3.0
4.0
41.0
0.18
0.16
1.05
35.7
<0.76
59.7
0.035 2.4 - 1.4-
5.80
0.1
3.32 10
57.49
0.02
<1.0
CATEGORY 3 - NON-PRIORITY POLLUTANT ORGANICS
Formaldehyde mg/1 <0.016
Xylene (MiP) mg/1 <0.02
Xylene (0) mg/1 <0.01
2,4-0 ug/1 <1.0 100
2,4,5-TP ug/1 <0.5 10
Oil and grease mg/1 2.0
Methyl Ethyl Ketone mg/1 <0.1
Isobutyl Alcohol mg/1 <0.1
N-8utyl Alcohol mg/1 <0.1
Isopropyl Alcohol mg/1 <0.1
Ethanol mg/1 <0.1
Butyl Methacrylate mg/1 <10.0
Methyl Methacrylate mg/1 <0.1
Ethyl Aerylate mg/1 <0.1
Butyl AeryTate mg/1 <0.1
Styrene " mg/1 <0.1
Acetone mg/1 <0.1
Fthyl Acetate . mg/1 <0.1
llosolve Acetate mg/1 <0.1
jtyl Cellosolve mg/1 <0.1
Lethane mg/1 <0.001
Karathane mg/1 <0.01
ONCP mg/1 <0.01
Surfactants (M8AS) mg/1 0.511
-------
Page 2 of 2
Parameter
Units
Bristol Borough
Supply Well (88W)
BCM Sample No. 14417
Sample Date: 10/14/83
USEPA Interi
Primary Drink
Water Standa
CATEGORY 4 - USEPA PRIORITY POLLUTANTS
Category 4a - Inorganics
Cyanide mg/1
Antimony mg/1
Arsenic mg/1
Barium mg/1
Beryllium mg/1
Cadmium mg/1
Chromium . mg/1
Copper mg/1
Mercury mg/1
Selenium mg/1
Silver mg/1
Nickel mg/1
Lead mg/1
Thallium mg/1
Zinc mg/1
Category 4b - Volatile Organics
Tetrachloroethylene
All others
ug/1
Category 4b - Volatile Organics (Halogenated) *
Methylene Chloride
Chloroform
Tetrachloroethylene
ug/1
ug/1
ug/1
Category 4c - Base Neutrals
Category 4d - Add Extractables
Category 4e - Pestfcfdes PCBs
Dloxin (TCOO)
CATEGORY 5 - RADIOLOGICAL
Gross Alpha Radioactivity PC1/L
Gross Seta Radioactivity PC1/L
Total Radium PC1/L
<0.005
<0.15
0.004
0.029
<0.01
0.0006
<0.002
<0.03
<0.0002
<0.001
<0.001
<0.1
<0.002
<0.30
<0.01
42.0
Below Detection Limits
15.5
2.1
5.0
Below Detection Limits
Below Detection Limts
Below Detection Limits
Below Detection Limits
<2
<3
2.1 + 1.5
0.05
1.0
0.01
0.05
0.002
0.01
0.05
"0.05
15
* Res amp led January 12, 1984 for Category 4t>, halogenated volatile organics
mg/1 - milligrams per liter (parts per million)
mg/1 - micrograms per liter (parts per billion)
Source: BCM Eastern Inc.
-------
BCM1
j
BCM Eastern Inc.
Engineers. Planners and Scientists
One Plymouth Meeting • Plymouth Meeting. PA 19462 • Phone: (215) 825-3800
Mr. Fidel Esposito
Borough Manager
Bristol, PA 19007
Subject: Analysis of Bristol Borough Well No. 10
Dear Mr. Esposito: ~" ~~
BCM Eastern Inc. (BCM) is pleased to provide you with the attached final
analytical results from the sample obtained by BCM from the Bristol
Borough Well No. 10. Please note that the only revision to our February
2, 1984 report is the addition of the Lethane concentration, which was
reported then as "N/A - analytical data not yet available".
Should you have any questions or require additional Information, please
do not hesitate to contact me.
Very truly yours
Richard J. Grzywinskl, P.E.
Vice President
Pd
Attachments
cc: Bucks County Board of Health
A Member Firm of 8etz•Converse*Murdoch •Inc. •
-------
SUMMARY OF RESIDENTIAL WELLS
SAMPLED 8Y BCM S
Map"
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Occupant
R. Rhodes
Mrs. Clattenbury
R. Whitman
R. Offenback
Mrs. O'Brien
Mrs. Eisenmann
C.
.
C. Sffuder
J. Cochran
T. Karlinski
H. Foster
Mr. Bosch
H. Gaettner
Mrs. Johnson
Mrs. Steele
Address
826 Lfnton Ave.
8^2 Girard Ave.
2314 Brighton Ave
814 Girard Ave.
1905 Summit Ave
318 Girard Ave."
1019 Emily Ave/"
211 Elm Ave.
1039 Anne Street
River Road
River Road
1*14 state Road
Orchard Ave.
740 Church Street
** Jllll "" " 'fme0f SOT»lin9
*» no Ion9er utt for househo)d purMses ^ t!^
Well Use*
Sampling
Date
Household
Household
Household
Household
Household
Household
• I . _ ' ' '
-Hou4«hold
L^
awn
Household
L_
awn
i
Lawn
•
Lawn
Household
Household
Household**
H/ll/83
H/ll/83
H/ll/83
11/11/83
H/ll/83
H/ll/83
H/lt/83
H/11/83
11/11/83
03/06/84
02/07/84
03/05/84
02/13/84
05/24/84
08/13/84
of sampling
-------
/
BCM I
ROHM AND HAAS COMPANY
Brittel. PA.
rifajftiyt*'
'-ir*
(BCM Proj.el MO. 00-4061-10)
RESIDENTIAL WELL
SAMPLING LOCATIONS
-------
IABU 1
Him 101 TOWNSHIP. ffhNSVlVANlA
ftCSllU'NlMl WCU UAIfH ANALYIICAl DATA
1 Of 4
P«r Meier ~
• ^
CATfGOiU 1 . lnnir.T/w
PM
Specific Conductance
BOO
COO
IOC
• *^»
CATEGORY 2 . Ufla.Pi.iM
AMoni* (u N)
Boron
Clilorlde
Fluoride
Iron
ttitrtte (u N)
Phoipint«
Sulfate
SodllM
PAI *•• ii^
* v» •»» IUM
AA^ *..— .
•*•• IIMI
M AAtl AA^ *! jk
**V*yWMTkC
Sulflde »i S
CATteORt 3 . HOM-PBioam
forauldehyde
*ylene» (H4P)
lylent (0)
Z.4-D
2.4.S-TP
Surf* tints (MBAS)
H«lhyl ethyl keiont
Uobut/1 «lcohol
M-ll I.O.: w.-ll ,l
..,,,.
LPAHAHflfHS
St*mlj,u oi,|tt j j
uulioi 2/3
•9/T rr POLturAur mnneniifc
•S/l 37.9
•9/1 16.1
•9" 1.36
•9/1 <0.4
•9/1 <0.02
•9/1 <1.0
r POtLUrAMT QBfi*iiir<
"9/1 ' O.OU
ug/l <0.2
ug/| <0>|
kja/ 1 ^t
U9' • <1
ug/l <0.5
•9/1 <0.022
•g/l 6
<0.05 <0.05
0.14 0.09
«-6 31.0
0.053 0.046
0.09 0.09
•.O' 1.61
<0.01 ii«i ,,,
«uj 263
<3 <\ ,1
. •* <3
16 N
* 0 fl
£ c
6 5 6
<°.05 n9 U«(er Sl*ndi
" ~ ~ • -
*•' 5.4
"2 190
<* <3
« 4
6 4
<0.05 0.15
0.08 0.09
*0.8 13.3
/ '•"*] ... ° -MS 2.4 - 1.4
\ 0.051 / 0.019 -^
'•*•»'" ~ 3.65 10
o.oi
-------
johnson Residence
Parameter Units Orchard Avenue
Priority Pollutants - Aod Extractable Organlcs (Continued)
4-Nitrophenol ug/1 <25
4,6-Oinitro-o-Cresol ug/1 <250
Pentachlorophenol ug/1 <25
Priority Pollutants - Pesticides and PC3s
Aldrin ug/1
Alpha-3HC ug/1
8eta-3HC ug/1
Gamma-3HC • ug/1
Oelta-SHC ug/1
Chlordane ug/1
4,4'-DDT ug/1
4,4'-OOE ug/1
4,4'-DOO ug/1
Oieldrin ug/1
Endosulfan I . ug/1
Endosulfan II ug/1
Endosulfan Sulfate ug/1
Endrin ug/1
Endrin Aldehyde ug/1
Heptachlor ug/1
Keotachlor Epoxide ug/1
PC3-1242 ug/1
PC8-1252 ug/1
PC8-1221 ug/1
PC3-1232 ug/1
PC3-1248 ug/1
PC3-1260 ug/1
PC8-1016 ug/1
Toxaphene ug/1
CATEGORY S - RADIOLOGICAL PARAMETERS
Gross A - Radioactivity PCi/1 <2
Gross 3 - Radioactivity PCi/1 <3
Total Radium
Source: BCM Eastern, Inc.
-------
P«9« 3 of 4
SamulCjM.^
UnTu
14352
Well 13
14354
HJS6
l5
Well i; Uel, lfl
l4Ji« nj59
CAT t COHV 5 - VOIATIIE
Ch lor Methane
BroMMettune
Vinyl Chloride
Chloroellune
Methylene Chloride
Trichlorofluoro«elh«ne
1.1-Okhloroelhene
1,1-0 Ichloroellune
Tr«ni-l,2-0lchlorocthene
Chloroform
1.2-0lchloruclh«ne
l.l.l-Trichloroclhiae
C«rbon Ielr«cMorldr
Brown! Ich I or o«e I h joe
1.2-Okh loi-opi up^ne
Tr«nt l.3-0iclilnrupiopene
Tried loroelhene
nli/9 nS£PA '"l"!.Pr,«rF
14J«>« Drinking H4Ur S»*nul,di
ril'f'i'nV'T"61"1"" "»<«/or
tl»-l.3-0lthloropropen« Ug/l
Bro*,for» ,, ug/|
I'Tif;2i.S:fiStli>» -/flr
Chlorobcoiene
Cthjrlcn* Olchlorlde
1.6
1.6
i.;
<0.1
0-6 ( 30.1
1.8
<0.1
ug/l
ug/l
ug/l
<0.1
<0.1
o.s
^^ '<*.»
-------
PAT Meier
_
CAKCQHV 3 . MQti.pa
Uopropy) Alcoho)
Cthwol
Butyl •etlucryUle
Methyl •eth«cryl«te
Ethyl Krylite
Butyl AcryUte
Styrene
Acetone
Ethyl «cet«le
Cellotolve «cet«te
Butyl cellotolve
K'rctlune
OUCP
Cthylene Oichldrlde
CAUCOfty 4 - Mioair»
Ant liuny
Arsenic
Btry|||u«
C««*|UM
Chroalu*'
Copper
le«d
Mercury
Nickel
Selenium
Silver
Tlulltua
Zinc
Cy*nlde
»h«noli
tell |.o.: u.-ll i
lfc.it i
1 • .
loam POIIUT
••j/i
••j/i
-i/i
•9/1
•.j/i'
•.j/i
•.j/i
•9/1
•9/1
•id/I
mV '
•9/1
•9/1
•9/1
U9/I
POILUTANIS -
•9/1
•9/1
•9/1
•9/1
•9/1
•9/1
•«/>
•9/1 .
•9/1
•9/1
•9/1
•9/1
•9/1
ng/1
•g/l
^_^^^^ ••^rfrft
•
ANT OOGANICS (C
<0.l
<0.l
<10
<0.1
<0.|
<0.
<0.
<0.
<0.
ft\
vO.
<0.
-------
TA8LE 1
RESIDENTIAL WELL ANALYTICAL DATA
BRISTOL BOROUGH, PENNSYLVANIA
CATEGORY 1 - INDICATOR PARAMFTFPC
pH
Specific conductance
800
COO
TOC
CATEGORY
Ammonia
Boron
Chloride
Fluoride
Iron
Nitrate (as
Phosphate
Sulfate
Sodium
Potassium
Barium
Manganese
Sulfide as !
Tin
(as N)
N)
Standard
umhos
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
units
CATEGORY 3 - NON-PRIORITY POLLUTANT
Formaldehyde **
Surfactants (M8AS)
011 and grease
Methyl ethyl ketont*
Isobutyl alcohol
N-butyl alcohol
Isopropyl alcohol
Ethanol
Butyl methaerylate
Methyl methacrylate
Ethyl aerylate
Butyl aerylate
Styrene
"cetone
hyl acetate
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mo./l
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
6.2
311.0
14.0 ;
24.0
7.0
8.3
183
<3
<4
<3
5.9
161
<3
<4
<1
6.7
- 85-7-
<3
3
1
0.40
0.16
40.0
0.03
3.15
3.50
<0.01
45.0
18.3
224.0
0.065
0.6
f\ n
0.09
0.04
5.6
0.34
0.05
<0.09
0.10
1.25
42.1
1.63
0.051
<0.02
./t M
<0.05
0.04
23.2
0.13
2.33:
0.83
O.Ol
21. 5
15.9
1.77
0.083
0.08
0.3S
• o.io
14.0
0.09
3.00
1.19
.. 0.05
248 *
14.8
79.$
a. 030
3.7f
3.0
<0,
<0.
<0.
<10.0
<0.1
<0.1
<0.1
<0.001
0.032
2.0
0.01
0.05
2.0
.2^
<10.0
<10.0 <10.*0
-------
4 of 4
it in ioni.il
F«r«actcr UiTiU
CATCCOAV 6 • VOIATII
Icnzene
Toluene
Cnlorobeniene
Cthjrl lenient
1.2-Oichlorobeniene
1 .3-0 Icfc lorobenjenc
1 ,4-0 Icblorobeniene
£ ORGANIC* •
** i \
ug/l
* i
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
1.
14)5?
Rli." B&° """•
60?
«u
, ., et
«U
HJSS
m^S fi'l^'6 «?.»*' Men
14JS9
Mell <9 USfPA Inter la i>ri««ry
14360 Drinking U«ter Sl*nfl*rdv
«U
-------
Parameter
Units
TO-
Well*
OT"
7RTT
1.4
CATEGORY 5 - VOLATILE ORGANICS - EPA METHOD 601 (Continued)
1,1,1-Trichloroethane ug/1 <1.0
Carbon tetrachloride ug/1 <1.0
Bromodichloromethane ug/1 <1.0
1,2-Oichloropropane ug/1 <1.0
trans-l,3-0ichloropropylene ug/1 <1.0
Trichloroethylene ug/1
Oibromochloromethane and/or
1,1,2-Trichloroethane and/or
cis-l,3-0ich1oropropy1sne ug/1
Sromoform ug/1
1,1,2,2-Tetrachloroethane and/or
Tetrachloroethene ug/1
Chlorobenzene ug/1
CATEGORY 6 - VOLATILE ORGANICS - EPA METHOD 602
).l
).l
1.1
1.1
CO.l
CO.l
CO. I
CO.l
CO.l
0.8
3.3
Benzene
Toluene
'hlorobenzene
^thylbenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
PRIORITY POLLUTANTS - BASE NEUTRAL QR6.ANICS
N-Nitrosodimethylamfne ug/1
bis-(2-Chloroethyl) ether ug/1
1,3-Oichlorobenzene ug/1
1,4-Oichlorobenzene ug/1
l,2-D1chlorobenzene ug/1
bis-(2-Ch1oroisopropy1) ether ug/1
Hexachloroethane ug/1
N-Nitrosod1-n-propby1a»fne ug/1
Nitrobenzene ug/1
Isophorone ug/1
bis-(2-Ch1oroethoxy) methane ug/1
1,2,4-Trichlorobenzene ug/1
Naphthalene ug/1
Hexachlorobutadlene ug/1
Hexachlorocyclopentadlene ug/1
2-Chloronaphthalene ug/1
Dfmethyphthalate ug/1
*naphthylene ug/1
-------
__
Parameter
Units
HPW
Wei
1*
HSU GBU
'
TkU
CATEGORY 3 - NON-PRIORITY POLLUTANT ORGANICS (Continued)
Cellosolve acetate
Butyl cellosolve
Karathane
Lethane
ONCP
Oi thane .»>jjx**\
2,4-D •***%>*• 5*;.,. ...jSr
245 -TP '"^* JL"v-ru*^ \ • '
£ i~\V>*' ^'^^k^' ^^j>^_ lvl ,a
mg/1
mg/1
mg/1
mg/1 iji^^
mg/1 ,<^sj \jL **** 3**
mg/llVW*^ ^iA1**"
^ mg/K **^/^
^ >- ^* * 1 .. 1 1 ( v
CATEGORY 4 - PRIORITY POLLUTANTS - METALS, CYANIDE,
Antimony
Arsenic
Beryl 1 ium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thall ium
Zinc
Cyanide
Phenols
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
«
PHENOLS
<0.15
0.001
<0.01
<0.01
<0.02
<0.03
O.C03
<0.0002
<0.1
<0.001
<0.02
<0.30
1.28
<0.005
0.003
<0. 1
<0. 1
<0.01
<0.001
<0.01
<0.02
•e <1.0
• <0.5
<0.17
<0.001
<0.01
<0.01
<0.02
<0.03
0.005
<0.0002
<0.1
<0.001
<0.02
<0.30
<0.01
<0.005
<0.002
<0. 1
<0. 1
<0.01
<0.001
<0.01
NT
<1.0
<0.5
<0.15
0.001
<0.01
0.21
<0.03
<0.03
<0.002
<0.0002
<0.1
<0.001
<0.02
<0.30
<0.01
<0.005
<0.002
<0. 1
<0. 1
<0.01
<0.001
<0.01
NT
<1.0
-------
Wen*
Parameter -~ Units HFHITCH5BTJ1W
PRIORITY POLLUTANTS - ACID EXTRACTABLE QRGANICS (Continued)
4-Nitrophenol ug/1 <25 <25 <25 <25
4,6-Oinitro-o-Cresol ug/1 <250 <250 <250 <250
Pentachlorophenol ug/1 <25 <25 <25 <25
PRIORITY POLLUTANTS - PESTICIDES AND PCBs
Aldrin ug/1 <10 <10 <10 <10
Alpha-BHC ug/1 <10 <10 <10 <10
8eta-8HC ug/1 <10 <10 <10 <10
Gamma-BHC ug/1 <10 <10 <10 <10
Delta-BHC ug/1 <10 <10 <10 <10
Chlordane ug/1 <10 <10 <10 <10
4,4'-DDT ug/1 <10 <10 <10 <10
4,4'-DDE ug/1 <10 <10 <10 <10
4,4'-000 ug/1 <10 <10 <10 <10
Oleldrin ug/1 <10 <10 <10 <10
Endosulfan I ug/1 <10 <10 <10 <10
^ndosulfan II ug/1 <10 <10 <10 <10
Endosulfan Sulfate ug/1 <10 <10 <10 <10
Endrin ug/1 <10 <10 <10 <10
Endrin Aldehyde ug/1 <10 <10 <10 <10
Heptachlor ug/1 <10 <10 <10 <10
Heptachlor Epoxide ug/1 <10 <10 <10 <10
PCB-1242 ug/1 <10 <10 <10 <10
PC8-1252 ug/1 <10 <10 <10 <10
PC3-1221 ug/1 <10 <10 <10 <10
PC8-1232 ug/1 <10 <10 <1.0 <10
PCB-1248 ug/1 <10 <10 <10 <10
PCB-1260 ug/1 <10 <10 <10 <10
PCB-1016 ug/1 <10 <10 <10 <10
Toxaphene ug/1 <10 <10 <10 <10
* Well Owners an
-------
Well *
Parameter Units HFU HGT35Sw TKW"
PRIORITY POLLUTANTS - BASE NEUTRAL ORGANICS (Continued)
2,6-Oinitroteuene ug/1 <10 <10 <10 <10
Acenaphthene ug/1 <10 <10 <10 <10
2,4-Oinitrotoluene ug/1 <10 <10 <10 <10
Diethyphthalate ug/1 <10 <10 <10 <10
Fluorene ug/1 <10 <10 <10 <10
4-Chlorophenyl phenyl ether ug/1 <10 <10 <10 <10
diphenylamine-n-nitroso ug/1 <10 <10 <10 <10:
1,2-Diphenylhydrazine ug/1 <10 <10 <10 <10
(Azobenzene)
4-8romophenyl pheny' ether ug/1 <10 <10 <10 <10
Hexachlorobenzene ug/1 <10 <10 <10 <10
Phenanthrene ug/1 <10 <10 <10 <10
Anthracene ug/1 <10 <10 <10 <10
D1-n-butyl Phthalate ug/1 <10 <10 <10 <10
Fluoranthene ug/1 <10 <10 <10 <10
Benzidine ug/1 <10 <10 <10 <10
Pyrene . ug/1 <10 <10 ' <10 <10
Butybenzyphthalate ug/1 <10 <10 <10 <10
Benzo(a)anthracene ug/1 <10 <10 <10 <10
3,3'-01ch1orobenzidine ug/1 <10 <10 <10 <10
Chrysene ug/1 <10 <10 <10 <10
bis-(2-Ethylhexyl) phthalate ug/1 <10 <10 <10 120
01-n-octyl phthalate ug/1 <10 <10 <10 <10
Benzo(b)f1uoranthene ug/1 <10 <10 <10 <10
8enzo(k)fluoranthene ug/1 <10 <10 <10 <10
Benzo(a)pyrene ug/1 <10 <10 <10 <10
Indeno(l,2,3-c,d)pyrene ug/1 <25 <25 <25 <25
Oibenzo(a,h)anthracene ug/1 <25 <25 <25 <25
Benzo(g,h,1)pery1'ene ug/1 <25 <25 <25 <25
PRIORITY POLLUTANTS - ACID EXTRACTABLE ORGANICS
Phenol ug/1 <25 <25 <25 <25
2-Chlorophenol ug/1 <25 <25 <25 <25
PRIORITY POLLUTANTS - ACID EXTRACTABLE ORGANICS
2-N1trophenol ug/1 <25 <25 <25 <25
2,4-D1methy1phenol ug/1 <25 <25 <25 <25
2,4-01chloropheno1 ug/1 <25 <25 <25 <25
p-Chloro-m-Cresol ug/1 <25 <25 <25 <25
2,4,6-Trlchlorophenol ug/1 <25 <25 <25 <25
2.4-01n1trophenol/ ug/1 <250 <250 <250 <250
-------
BCM
; • i / 1 A 1 ** ^ •
I.- / 14 Ii03
BCM Eastern Inc.
Engineers. Planners and Scientists
One Plymouth Meeting • Plymouth Meeting. PA 19442 • Phone: (215) 825-3800
August 7, 1934
Mr. Robert Lewis, President
Board of Supervisors
Bristol Township
Bristol, PA 19007
Subject: Analysis of Residential Wells
Dear Mr. Lewis:
BCM Eastern, Inc. (BCM) is pleased to provide you with the analytical
results of the water sample collected on May 24, 1984 by BCM from the
supply well at the Alex Johnson residence on Orchard .Lane.
Should you have any questions or require additional' information, please
do not hesitate to contact me.
Very truly yours
Richard J. Grzywinski, P.E,
Vice President
Pd
Enclosure
cc: Bucks County Department of Health
P. Rosenstock, Rohm and Haas.X
G. Schnabel, Rohm a/id Haas
A. Johnson, Resident of Bristol Township
A Member firm of Befz • Converse • Murdoch • Inc. •
-------
BOV!
Parameter
Cellosolve acetate
Butyl cellosolve
Karathane
Lethane
DNCP
Oithane
2,4-0
2,4,5-TP
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
11i urn
Units
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
ug/1
ug/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Zinc mg/1
Cyanide mg/1
Phenols mg/1
CATEGORY 5
Volatile Organics - EPA Method 601
Chloromethane ug/1
Bromomethane ug/1
Vinyl chloridf, ug/1
Chloroethane ug/1
Methyl ene chtorfdt ug/1
Trichlorofluoromethane ug/1
1,1-Ofchloroethylene ug/1
1,1-Ofchloroethane
«. ,„..--
1,2-Oichloroetha
ne
ug/1
ug/1
Johnson Residence
Orchard Avenue
<0.01
<0.001
<0.01
<0.02
<0.15
0.004
<0.01
' <0.0005
0.003
<0.03
0.016
0.0004
<0.1
<0.001
<0.001
<0.3
<0.01
<0.005
0.009
-------
.ECM
/
TABLE I
/ RESIDENTIAL WELL ANALYTICAL DATA
/ . BRISTOL BOROUGH, PENNSYLVANIA
Johnson Residence
Parameter Units Orchard Avenue
CATEGORY 1 - INDICATOR PARAMETERS
PH
Specific conductance
BOO
COD
TOC
CATEGORY 2 - NON-PRIORITY
Ammonia (as N)
Boron
Chloride
Fluoride
Iron
Nitrate (as N)
Phosphate, Total as P
Sulfate .
Sodium
Potassium
Barium
Manganese
Sulfide as S
Tin
CATEGORY 3 - NON-PRIORITY
Surfactants (MBAS)
011 and grease
Methyl ethyV ketone
Isobutyl alcohol
N-butyl alcohol
Isopropyl alcohol
Ethanol
Butyl methacrylate
Methyl methacrylate
Ethyl acrylate
Butyl acrylate
Styrene
Acetone
Ethyl acetate
Standard units
umhos
mg/1 .
mg/1
mg/1
POLLUTANT INORGANICS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
POLLUTANT ORGAN I CS
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
5.4
86.6
<6
15
4
<0.05
<0.1
14.0
<0.1
0.05
2.0
0.04
<0.1
5.81
1.21
<0.01
<0.02
<1
-------
/fECM
Parameter
Units
Johnson Residence
Orchard Avenue
Priority Pollutants - 3ase Neutral Organics (Continued)
2,6-Oinitroteyene ug/1
Acenaphthene ug/1
2,4-Oinitrotoluene ug/1
Oiethyphthalate ug/1
Fluorene ug/1
4-Chlorophenyl phenyl ether ug/1
diphenylamine-n-nitroso ug/1
1,2-Oiphenylhydrazine-- ug/1
(Azobenzene)
4-8romophenyl phenyl ether ug/1
Hexachloroben^Sne ug/1
Phenanthrene ug/1
Anthracene ug/1
Oi-n-butyl Phthalate ug/1
Fluoranthene ug/1
Senzidine ug/1
Pyrene ug/1
Sutybenzyphthalate1 ug/1
8enzo(a)anthracene ug/1
3,3'-Oichlorobenzidine ug/1
Chrysene ug/1
bis-(2-£thylhexyl) phthalate ug/1
Di-n-octyl phthalate ug/1
8enzo(b)fluoranthene ug/1
Benzo(icjfluoranthene ug/1
8enzo(a)pyrene ug/1
Indeno(l,2,3-c,d)pyrene ug/1
Oibenzo(a,h)anthracene ug/1
8enzo(g,h,i)perylene ug/1
Priority Pollutants - Acid Extractable Organics
29
<25
<25
<25
Phenol
2-ChlorophenoK
2-Nitropnenof
2,4-DimethylpheflO)
2,4-Oicnloropnenol
p-Chloro-m-Cresol
2,4,6-Trichlorophenol
2,4-Oinitrophenol
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
<25
<25
<25
<25
<25
<25
<25
<250
-------
Parameter-
Units
Johnson Residence
Orchard Avenue
CATEGORY 5
Volatile Organics - EPA Method 601 (Continued)
1,1,1-Trichloroethane ug/1
Carbon tetrachloride ug/1
Bromodichloromethane ug/1
1,2-Oichloropropane ug/1
trans-l,3-0ichloropropylene ug/1
Trichloroethylene ug/1
Oibromochloromethane and/or
1,1,2-TricMoroethane and/or
c1s-l,3-0ichloropropylene ug/1
Bromoform ug/1
1,1,2,2-Tetrachloroethane and/or
Tetrachloroethene ug/1
Chlorobenzene ug/1
4.3
3.1
Volatile Oraanics-- EPA Method 602
Benzene
Toluene
Chlorobenzene
Ethylbenzene
1,2-0iChlorobenzene
1,3-Oichlorobanzene
1,4-Dichlorobenzene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
Priority Pollutants - Base Neutral Organics
N-Nitrosodimethylamine ug/1
b1s-(2-Chloroethyl) ether ug/1
1,3-01Chlorobenzene ug/1
1,4-01Chlorobenzene ug/1
1,2-Oichlorobenzsne ug/1
b1s-(2-Chloro1sopropy1) ether ug/1
Hexachloroethane ug/1
N-NHrosodi-n-prophylam1ne ug/1
Nitrobenzene ug/1
Isophorone ug/1
bis-(2-Chloroethoxy) methane ug/1
1,2,4-Trichlorobenzene ug/1
Naphthalene ug/1
Hexachlorobutadiene ug/1
Hexachlorocyclopentadlene ug/1 •
2-Chloronaphthalene ug/1
Oimethyphthalate ug/1
Acenaphthylene ug/1
-------
/; ECM
/•
. . Johnson Residence
Units Orchard Avenue
Priority Pollutants - Acid
4-Nitrophenol
4,6-Oinitro-o-Cresol
Pentachlorophenol
Priority Pollutants - Pest
Aldrin
Alpha-BHC
Beta-BHC
Gaima-BHC
Oelta-BHC
Chlordane
4, 4 '-DOT
4,4'-OOE
4,4'-DOD
Oieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Heptachlor
Heptachlor Epoxide
PC8-1242
PC8-1252
PC8-1221
PC8-1232
PC8-1248
PC8-1260
PC8-1016
Toxaphene
Extractable Organics
ug/1
ug/1
ug/1
icides and PCBs
ug/1
ug/1
ua/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ua/1
ug/1
ug/1
ug/1
(Continued)
<25
<250
<25
<10
<10
<10
<10
<10
- <10
-------
[BCM]
TABLE 1
RESIDENTIAL WELL ANALYTICAL DATA
BRISTOL BOROUGH, PENNSYLVANIA Page .1 of 5
G. 3. Foster
Parameter Units WellPool
CATEGORY 1 - INDICATOR PARAMETERS
pH ; " Standard units 6.0 .. 6.4
Specific conductance umhos 89 132
BOO mg/1 <3 5
COO mg/1 <4 • 63
TOC mg/1 2 6
TOH ug/1 23.3 28.8
CATEGORY 2 - NON-PRIORITY POLLUTANT INORGANICS .
Ammonia (as N) mg/1 <0.05 <0.05
Chloride ' mg/1 3.3 7.5
Fluor-ide_ mg/1 0.11 0.11
Iron mg/1 <0.04 0.37
Nitrate (as N) mg/1 0.52 <2.0
Phosphate, Total as P mg/1 0.05 0.12
Sulfate mg/1 24.0 <2.0
Sodium mg/1 <0.71 3.75
Potassium mg/1 1.06 7.46
Barium mg/1 0.026 0.035
Manganese mg/1 <0.02 0.23
Sulflde as S mg/1 <1 <1
CATEGORY 3 - NON-PRIORITY POLLUTANT ORGANICS
Surfactants (MBAS) mg/1 • <0.03 0.05
011 and grease mg/1 <1 <1
Methyl ethyl ketone mg/1 <0.1 <0.1
Isobutyi alcohol mg/1 <0.1 <0.1
N-butyl alcohol mg/1 <0.1 <0.1
Isopropyl alcohol mg/1 <0.1 <0.1
Ethanol • mg/1
Butyl methacrylate mg/1
Methyl methacrylate mg/1
Ethyl acrylate mg/1
Butyl acrylate mg/1
Styrene mg/1
Acetone mg/1
Ethyl acetate mg/1
-------
BCM]
-hie
BCM Eastern Inc.
Engineer. Planners and Scienf/stj
On« Plymouth Meeting • Plymouth Meeting. PA 19443 • Phone"
(215) 825-3800
30, 1985
Mr. George Foster or Jonn Oelancey
Maple Beacn Road
Bristol, PA 19007
Subject: Well and Pool Water Chemistry
Analytical Results
BCM Project No. 00-4061-10
Dear Sirs:
BCM Inc. (BCM) 1s pleased to provide you with
>npl. =o.,ected „
•-,
109 Mater Standard is within standard h.«i-
eentrations exceed the USEM Int"rira Seclnd.rv '
of 0.3 mg/1 and 0.05 »g/l, re p«f
Drfnk
con
„..,.
/pd
Enclosurt
cc: Sucks County Board'of Health
Stan Gawel, Bristol Township Manager
truly
Richard J. Grzyw1nsk1, P.£
Senior vice President
A Member Rrm of Bett•Converse•Mudocft*Inc.
-------
ECM
Table 1 (Continued)
Page 3 of 5
Parameter
Units
G. 8. Foster
wet <
Pool
CATEGORY 5
PRIORITY POLLUTANTS - PURGEASLE HALOCAR8QNS (Continued)
1,1,1-Trichloroethane ug/1 <1.0
Carbon tetrachloride ug/1 <1.0
Sromodichloromethane ug/1 <1.0
1,2-Oichloropropane ug/1 <1.0
trans-l,3-Jichloropropy1ene ug/1 <1.0
Trichloroethylene ug/1 <1.0
Oibromochloromethane and/or
1,1,2-Trichloroethane and/or
cis-l,3-0ichloropropy1ene ug/1 <1.0
Bromoform ug/1 <1.0
1,1,2,2-Tetrachloroethane and/or
Tetrachloroethene ug/1 <1.0
Chlorobenzene - ug/1 <1.0
bis (Chlorcmethyl) ether ug/1 <1.0
PRIORITY POLLUTANTS - PURGEA8LE AROMATICS
Benzene
Toluene
Chlorobenzene
Ethylbenzene
1,2-Oichlorobenzene
1,3-Oichlorobenzene
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
PRIORITY POLLUTANTS - BASE NEUTRAL ORGANICS
N-Nitrosodiraethyl a/nine ug/1
bis-(2-CMoroethyl) ether ug/1
1,3-Oichlorobenzene ug/1
1,4-OichTorobenzene ug/1
1,2-Oichlorobenzene ug/1
bis-(2-Chloro1sopropy1)- ether ug/1
Hexachloroethane ug/1
N-Nitrosodt-n-prophylaffllne ug/1
Nitrobenzene ug/1
Isophorone - ug/1
bis-(2-Ch1oroethoxy) methane ug/1
1,2,4-Tricholobenzene ug/1
Naphthalene ug/1
-------
BCM!
Table 1 (Continued)
2 of 5
NON.p,,n,m poullTMT „„...,„
Cellosolve
Butyl cellosolve
Karathane
Lethane ~"
ONCP
2,4-0
2,4,5-TP
Xylenes
Antimony
Arsenic
Beryllium
Cadmium__
Chromium"
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Phenols
CATEGORY 5
mg/l
mg/l
mg/l
mg/l
mg/l
ug/1
ug/1
ug/1
CATEGORY 4 - PRIORITY POLLUTANTS - METALS,
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
<0.01
<0.001
<0.01
.CYANIDE. PHFMtt
0.25
<0.002
<0.01
<0.0005
0.003
0.09
0.011
<0.0002
<0.1
<0.001
<0.0005
<0.3
0.01
<0.005
<0.002
<0.01
<0.1
<0.1
<1.0
0.25
<0.002
<0.01
<0.0005
<0.001
<0.03
0.004
<0.002
<0.1
-------
ECM
Table 1 (Continued)
Pa3e 5 of
Parameter
Units
G. 8. Foster
wel I
Pool
PRIORITY POLLUTANTS - ACID EXTRACTA8LE ORGANICS (Continued)
2,4-Oichlorophenol
p-Chloro-m-Cresol
2,4,6-Trichlorophenol
2,4-Oinitrophenol
4-Nitrophenol
4,6-Oinitro-o-Cresol
Pentachlorophenol
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
PRIORITY POLLUTANTS - PESTICIDES AND PC8S
Aldrin
Alpha-BHC
Beta-BHC
Gairma-SHC
Delta-8HC
Chlordane
4,4'-OOT
4,4'-OOE
4, 4 '-000
Oieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Heptachlor
Heptachlor Epoxlde
PC8-1242
PCS- 125*
PC8-1221L
PC8-123*
PC3-124*-
PCB-1260
PC8-1016
Toxaphene
ug/1
' ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
<2S
<25
<25
<250
<25
<250
<25
<0
<0
<0
<0
<0
<2
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<25
<25
<25
<250
<25
<250
<2S
<0.5
Sampling Date: 03/08/85
Source: 8CM Inc (00-4061-10)
-------
Table 1 (Continued) Page 4 of 5
G. 8. Foster
Parameter Units Jeil Pool
PRIORITY POLLUTANTS - 6ASE NEUTRAL QRGANICS (Continued)
Hexachlorobutadiene ug/1
Hexachlorocyclopentadiene ug/1
2-Chloronaphthalene ug/1
Oimethyphthalate ug/1
Acenaphthylene ug/1
2,6-Oin*troteuene ug/1
Acenaphthene ug/1
2,4-Oinitrotoluene ug/1
Diethyphthalate ug/1
Fluorene .. ug/1
4-Chlorophenyl phenyl ether ug/1
diphenylamine-n-nitroso ' ug/1
1,2-Oiphenylhydrazine ug/1
(Azobenzene)
4-3romophenyl phenyl ether ug/1
Hexachlorobenzene ug/1
Phenanthrene ug/1
Anthracene ug/1
Di-n-butyl Phthalate ug/1
Fluoranthene ug/1
Senzidine ug/1
Pyrene ug/1
Butybenzyphthalate ug/1
Benzo(a)anthracene ug/1
3,3'-01chlorobenzidine ug/1
Chrysene ug/1
b1s-(2-Ethy1hexy1) phthalate ug/1
Dl-n-octyl phthalate ug/1
8enzo(b)f1uoranthene ug/1
3enzo(fcjfTuoranthene ug/1
Benzo(i)pyren« ug/1
Indene(l,2.3-c,d)pyrene ug/1 <25 <25
01benzo(a,h)anthracene ug/1 <25 <2S
Benzo(g,hti)perylene • ug/1 <2S <2S
PRIORITY POLLUTANTS - ACID EXTRACTABLE ORGANICS
Phenol — - .ug/1 <25 <25
2-ChIorophenol ug/1 <25 <25
2-Nitrophenol ug/1 <2S <2S
2t4-01methy1phenol ug/1 <2S <2S
-------
REF.FTU2: BT-1
UNITECH ENGINEERS
Ccmuning Engirt*** 4 Survtyor*
MJ PENNA. OFFICE
M.J.
P O 30X M 654 M VVOO08OURNE flOAO
1608 COLUMBUS RO. UNGHOBNE, PA f«M7
BURLINGTON. NJ C80l«-~ (2l5j 752-2240
; 609) 387-0777 FAX (21 5) 752-4745
May 24, 1990
FEDERAL EXPRESS 1835664353
Mr. Jeff Winegar (3HW22)
Remedial Project Manager
U. S. EPA - Region III
841 Chestnut Street
Philadelphia, PA 19107
Reference: Proposed Plan for Croydon TCB Site,
Bristol Township, Bucks County, Pennsylvania
Dear Mr. Winegar:
Your presentation of the proposed remedial alternative to
eventually eliminate the long ten TCE contamination in your
specifically described area was exceptionally informative. As the
Environmental Engineers for Bristol Township we presented a short
summary report to the Bristol Township Sewer Authority members on
the 22 May, 1990, regarding the objectives of the most effective
processes that EPA is considering to remove established TCE
deposits from the ground water network which underlies a specific
area in the Township delineated in your slide presentation. We
also presented a review and explanation of the proposed air
stripping process in conjunction with an activated carbon scrubber
to remove the volatiles released from the groundwater. The main
objective of the carbon filters is to prevent TCB from entering the
atmosphere within the Croydon Area.
After completing our overview of the proposed superfund
options to remove TCB from the designated groundwater network, the
members voiced an objection to the proposed location of the air
stripping tower and strongly recommended that it be located at the
Authority's wastewater treatment facility located on River Road. It
seems logical that this location could serve to protect the
equipment, 4>ut more importantly would be conveniently monitored by
the plant personnel on a daily basis rather than an appointed
contractor who would visit the proposed site on a periodic
schedule, thus leaving the air stripping system unmanned and would
be subject to vandalism.
-------
APPENDIX B
COMMENTS ON THE PROPOSED REMEDIAL ACTION PLAN
FOR THE CROYDON TCE SUPERFUND SITE
FROM
UNITECH ENGINEERS
-------
UNITECH ENGINEERS INC. Ref . Pile? BT-1
Mr. Jeff Winegar, EPA
May 24, 1990
Page Three
In conclusion, I would like to point out to the U. S. EPA
office that the Croydon Area of Bristol Township is a
socio-economic depressed area, as well as other areas within the
Township. Therefore, any financial help from the federal agency
such as fee's for maintenance and operation of the proposed ground
water renovation facility that could be located at their wastewater
treatment facility would certainly assist the Sewer Authority in
eliminating a budget short fall which they are experiencing to
date.
The Bristol Township Sewer Authority's chairman would like to
schedule a meeting with the EPA to discuss in detail about this
recommended alternative at the earliest convenient time possible.
Please advise us accordingly.
If you have any questions regarding this matter, please do not
hesitate to contact us.
Very truly yours,
UNITECH ENGINEERS, INC.
S. J. Campbell, P.E.
SJC/lal
Enclosures:
cc: Harry Fawkea, Chairman, BTA
James Gallagher, Township Executive
Carmen Raddl, Township Manager
Betti Began, Office Manager, BTA
654 N Woodbourni Road. Suite »\, Langhorne. Pa. 19047 • (215) 752-2240
-------
UNITECH ENGINEERS INC. Ref. Pile: BT-1
Jeff Winegar, EPA
May 24, 1990
Page Two
The Authority also voiced an additional objection to the proposed
location of the process equipment and its proximity to the Township
residences. They.feel that the process location at the Bristol
Township wastewater treatment facility could best serve the
township residences to eliminate the exposure of volatile
chlorinated hydrocarbons, noise pollution and the aesthetics. In
consideration of this recommendation it will also assist the
township financially if supplemental dollars from the contractual
management of the groundwater renovation process proposed by the
EPA could be diverted to the Township for the same services by the
sewer authority.
In considering the above recommended alternative, a transfer
pump could be eliminated if located at the Authority's sewage
treatment plant (STP) because the renovated groundwater from the
Air Stripper could be transferred by gravity to the STP's chlorine
contact basin's outfall (See Exhibit /I). This concept will also
provide dilution of the STP's effluent constituents such as BOD,
COO, TSS and Free Ammonia. The present outfall lines from the STP
to the Delaware River Estuary is 1200 ft long.
The C.I.P. (outfall line) is 36 inches in diameter. Using
Manning's equation, the existing first section of the outfall line
will transfer 22.6 MGD at an existing slope of 0.29% (See Exhibit
12 for detailed hydraulic profile of the outfall line). This
water quality change certainly will be beneficial to the river,
when compared to the proposed method of discharging renovated
groundwater into Hogs Run Creek. The discharge into Hogs Run Creek
will foster the erosion of the creek bed and will contribute
additional suspended solids loading to the Delaware River Estuary,
since the Creek is a tributary of the river.
In an effort for you to visualize the concept recommended
above we have attached a plot plan (Exhibit II) of the existing
wastewater treatment facility and the placement of the air
stripper, carbon scrubber and the air blower on a concrete pad.
The process equipment would be located very near to the chlorine
contact basin outfall line going to the river. The relative
hydraulic capacities of the effluent line going to the river have
been documented by the attached exhibit sited above. Also because
of the depth and location of the effluent line the treated
groundwater could be transferred by gravity to chlorine contact wet
well. Using this location concept places the process in a real
remote area, coupled with the fact that the EPA will meet with
reduced opposition from the Bristol Township residences, the
Council members and its Executive.
654 N Woodbourr* Road.-Suite »1. Langhorne. Pa. 19047 • (215) 752-2240
-------
8
1
Lj
22.6 ML
OR
35 CH
W
•
I
/A
to
1200 OFT.
CAPACITY -22.6 M6D
OA 35 CFS
90.29 •/•
$ &
CAPACITY • 44.4 MGO
OR 64 CFS
283 76'
5 -0
CAPACITY '226 M6D
OR 35 CFS _
CO O.23 '/•
IV. IN
•99 -2
CAPACITY
666MGP
^OR IOO CFS
ISO'
G0?.57~/'
036"
V. IN
.15 -C.
'V.
01
EXHIBIT 2
BRISTOL TOWNSHIP
WASTEWATER TREATMENT EFFLUENT LINE
-------
tOUM MD HAAS COMFAHY
1 J
AH*
amour
MOM CARSONflrcf)
v
SCRUBBER fOR VOLATILE!
BlDWf/f
» A » » M »—'
VACAM LAM) fff CHIMICAL LfMMAN COMPANY
EXHIBIT 1
rtoroseo UKATION OF AIR STKIFPER
FOR CROUNDWATCR RENOVATJON
BRISTOL TOVNSHIP WASTENATER TRCATNCHT PLAN
BRISTOL TOWNSHIP, PEMNSY1.VANTA
NO SCALE
-------
CROYDON TCE SITE OU2
ADMINISTRATIVE RECORD FILE * **
INDEX OF DOCUMENTS
III. REMEDIAL RESPONSE PLANNING
1. Letter to Mr. John J. Camerlingo, Jr., from Mr.
Jeffrey Winegar, U.S. EPA, re: Sampling of
Monitoring Wells, 8/30/88. P. 300001-300004.
2. Letter to Ms. Barbara King, from Mr. Jeffrey
Winegar, U.S. EPA, re: Transmittal of comments of
the data package of water samples, 2/3/89. The
comments are attached. P. 300005-300006.
3. Letter to Mr. Abraham Ferdas, U.S. EPA, from Mr.
Stephen D. Von Allmer, Department of Health & Human
Services, re: Transmittal of a Preliminary Health
Assessment, 4/10/89. P. 300007-300011. The Health
Assessment is attached.
4. Letter to Telford Industrial Development Authority,
from Mr. Jeffrey Winegar, U.S. EPA, re: Phase two
of an evaluation of contaminated media, 7/31/89. P.-
300012-300020. A transmittal letter with a Right of
Entry form, a handwritten telephone conversation
memorandum and two certified mail receipts are
attached.
5. Letter to Mr. Stanley Skwarlo, from Mr. Jeffrey
Winegar, U.S. EPA, re: Phase two of an evaluation
of contaminated media, 7/31/89. P. 300021-300027.
A sampling location map, two Right of Entry forms
and two certified mail receipts are attached.
* Administrative Record File available 4/30/90
** Further documentation for the Croydon TCE OU2
Administrative Record can be found in the Croydon TCE OU1
Record.
Note: Company or organizational affiliation is identified
in the index only when it appears in the record.
-------
6. Letter to Mr. Paul D. Rosenstock, Rohm & Haas,
Delaware Inc., from Mr. Jeffrey Winegar, U.S. EPA,
re: Phase two of an evaluation of contaminated
media, 7/31/89. P. 300028-300032. A sampling
location map, a Right of Entry form and two
certified mail receipts are attached.
7. Letter to Mr. Jeffrey B. Winegar, from Mr. Paul D.
Rosenstock, Rohm & Haas Delaware Valley Inc., re:
Transmittal of a Right of Entry form, 8/7/89. P.
300033-300034. The Right of Entry form is attached.
8. Letter to Mr. Stanford S. Hunn, from Ms. Denise
Parkinson, U.S. EPA, re: Certification oflnsurance
and Indemnification, 8/16/89. P. 300035-300035.
9. Letter to Mr. Stanford S. Hunn, from Ms. Janet E.
Sharke, U.S. EPA, re: Change of party conducting
response work, 9/27/89. P. 300036-300036.
10. Letter to Mr. Jeffrey B. Winegar, U.S. EPA, from Mr.
R. Thomas Numbers, BCM Engineers, re: Request for
analytical results, 12/14/89. P. 300037-300037.
11. Letter to Mr. Thomas Numbers, BCM Engineers, from
Mr. Jeffrey B. Winegar, U.S. EPA, re: Transmittal
of a potential source area investigation report,
12/22/89. P. 300038-300038.
12. Report: Final Phase II, Remedial Investigation
Report, prepared by EBASCO Services Incorporated,
1/90. P. 300039-300496.
13. Report: Final Feasibility Study Report, prepared by
EBASCO Services Incorporated, 1/90. P. 300497-
300712.
14. Report: Declaration for the Record of Decision, (no
author), (undated), P. 300713-300764. A previous
index and a letter regarding the remedy for the site
is attached.
15. Updated Cost Information, Croydon TCE Site,
Atlernative 12, Phase II FS, (undated). P. 300765-
300773.
Maps for Monitoring Wells are part of the Final Phase II,
Remedial Investigation Report. These maps are located on
the sixth floor at U.S. EPA Region III, 841 Chestnut
Street, Philadelphia, PA.
-------
V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
IMAGERY
1. Letter to Mr. Jack Kelly, U.S. EPA, from J.G.
Rooney, Hudson GEOTECH International, re: Concerns
of groundwater contamination, 2/12/86. P. 500001-
500001.
2. Letter to Mr. J. G. Rooney, Hudson GEOTECH
International, from Mr. Bruce P. Smith, U.S. EPA,
re: Information request under FOIA, 3/3/86. P.
500002-500003. The request is attached.
3. Letter to Mr. Jim Rooney, Hudson GEOTECH, from Mr.
Jack Kelly, U.S. EPA, re: Transmittal of report on
Groundwater contamination, 5/9/86. P. 500004-
500004.
4. Freedom of Information Act Request, to the U.S. EPA,
from Mr. Robert Martineau Jr., Skadden, Arps, Slate,
Meagher & Flom, re: Request for site information,
6/11/87. P. 500005-500007.
5. Handwritten letter to Mr. Jack Kelly, U.S. EPA, from
Mr. Harry Foster, re: Request for a copy of TCE
testing, 7/7/86. P. 500008-500008.
6. Letter to Mr. Harry Foster, from Mr. Jack Kelly,
U.S. EPA, re: Tranmsittal of the TCE Investigation
Report, 7/17/86. P. 500009-500009.
7. Letter to Mr. Robert J. Martineau, Jr., Skadden,
Arps, Slate, Meagher & Flom, from Mr. William A.
Hagel, U.S. EPA, re: Transmittal of FOIA request,
7/22/87. P. 500010-500015. The previous formal
request is attached.
8. Newspaper Article from the Bristol Pilot, entitled
"EPA Moves Ahead on Croydon Cleanup," 7/30/87. P.
5000016-500016.
9. Newspaper Article from the Bucks County Courier
Times, entitled "EPA plans to find TCE source in
Croydon," 8/87. P. 500017-500017.
10. Newspaper Article from the ADVISOR, entitled "EPA
Moves Ahead on Croydon Cleanup," 8/4/87. P. 500018-
500018.
-------
11. Public Meeting Summary, Croydon TCE Site, 8/20/87.
P. 500019-500029.
12. Newspaper Article from the Bucks County Courier
Times, entitled "Tests to Chart Croydon Water
Contamination," 8/21/87. . 500030-500031.
13. Letter to Ms. Mary Blakinger, Bucks County Courier
Times, from Mr. Charles L. Kleeman, U.S. EPA, re:
Transmittal of FOIA request, 10/16/87. P. 500032-
500034. The formal request is attached.
14. Report: Final Community Relations Plan, Croydon TCE
Site, prepared by EBASCO Services Incorporated,
2/18/88. P. 500035-500054.
15. Letter to Mr. Jeffrey B. Winegar, U.S. EPA, from Ms.
Babara King, Croydon Civic Association, re:
Appreciation for water sampling, 2/15/89. P.
500055-500059. Two newspaper articles are attached.
16. Newspaper Article from the Bucks County Courier
Times, entitled "Clean Water for Croydon Families,"
6/16/89. P. 500060-500060.
17. U.S. EPA, Public Notice, Croydon TCE Site,
(undated). P. 500061-500061.
-------
2
PtNNSYlVANIA
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
June 29, 1990
Deputy Secretary
Environmental Protection , 717-787-5028
Mr. Edwin B. Erickson
Regional Administrator
US EPA, Region III x
841 Chestnut Building
Philadelphia, PA 19107
Re: Record of Decision (ROD) Concurrence
Croyden TCE, Bristol Twp., Bucks Co.
Operable Unit II - Groundwater Containment
Dear Mr. Ericksoni
The Record of Decision for Operable Unit II will
address the containment, treatment, and discharge of the
contaminated groundwater plume.
The major components of the selected remedy includes
1. Construction and long-term operation of four
pumping/extraction wells, located in positions to
adequately contain the migration of the contaminant
plume.
2. Treatment of the extracted groundwater via air
stripping, followed by carbon absorption as an
ancillary treatment step.
3. On-site discharge of the treated groundwater to the
East Branch of Hog Run Creek.
I hereby concur with the EPA's proposed remedy, with the
following conditions:
*
-------
A. i -
Mr. Edwin B. Erlckson - 2 - ' ' /"June 29, JLS98'9-.-
Regional Administrator "
* The Department will reserve- our- right and responsibility
to take independent enforcement actions pursuant to
state and federal law.
* This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SA$A
Section 104(c)(3). :
If you have any questions regarding this matter please
do not hesitate to contact me.
Sincerely*
terk M. McClellan
Deputy Secretary
Environmental Protection
------- |