United States        Office of
             Environmental Protection   Emergency and
             Agency           Remedial Response
EPA/ROD/R03-90/097
September 1990
&EPA     Superfund
             Record of Decision
             Cryo-Chem,  PA

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50272-101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R03-90/097
3. Recipienh Acce88ion No.
4. TlUe and SubtiUe
SUPERFUND RECORD OF DECISION

Cryo-Chem, PA
Second Remedial Action
7. Au1hor(a)
5. Repor1 Date
09/28/90
6.
8. Performing Organization Rapt. No.
8. PerformIng Orgalnlzation Name and Addreaa
10. ProlectlTaaklWork Unit No.
11. Contrac1{C) or Gram(G) No.
(C)
(G)
12. ~ortng Organization Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Repor1 & Period Covered
Agency
800/000
14.
15. Supplememary Note.
16. Ab8tract (Umlt: 200 word.)
The 19-acre Cryo-chem site is a metal fabricating facility in Worman, Earl Township,
Berks County, Pennsylvania. A woodland area is located northeast of the site, and an
onsite stream has been identified west of the contaminant area. Between 1970 and 1982,
chemical solvents were used at the facility at a rate of two to three 55-gallon drums
per year. During this time, a chemical spill occurred at Cryo-chem, but cannot be
iefinitely linked to the source of contamination. Well sampling conducted during 1985
and 1987 showed ground water contamination in monitoring and residential wells within 1
mile of the site, which led to a removal action that required the installation of
activated-carbon filter units in 14 affected homes. In 1989, a Record of Decision (ROD)
was signed for Operable Unit One (OU1), which provided for the installation of a new
water supply well outside of the contaminant plume and hookups for all affected and
potentially affected residents. This ROD addresses OU2, the treatment of the ground
water and containment of the contaminant plume. A subsequent ROD will address
remediation of the source of the contamination onsite (OU3). The primary contaminants
of concern affecting the ground water are VOCs including PCE, TCE, DCA, DCE, and TCA.
(See Attached Page)
17. Document Analyaia L Deacriptora
Record of Decision - Cryo-Chem, PA
Second Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (PCE, TCE)
b. Identifler8l0pen-Ended Terrna
Co COSAll Reid/Group
18. AvailablDty Statemem
19. Security CI..a (Thi. Report)
None
21. No. of Pag"
110
I
(See ANSl-Z38.18)
20. Security Cia.. (Thia Page)
N()n~
22. PrIce
See IMlruclion6 on R6W!fIIe
272 (4-'7)
(Formetfy NTI~35)
Departmenl of Commerce

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EPA/ROD/R03-90/097
Cryo-Chem, PA
Second Remedial Action
bstract (Continued)
The selected remedial action for this site includes pumping and treatment of ground water
using air stripping, followed by carbon adsorption, if emissions are above Clean Air Act
levels, with onsite discharge of treated water to surface water; other discharge options
will be considered as necessary, including offsite discharge to a downstream wastewater
treatment facility or reinjection at the site, depending on the discharge rate; and
ground water and surface water monitoring. The estimated present worth cost for this
remedial action is $2,065,000, which includes an annual O&M cost of $75,200 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Ground water will be remediated to meet SDWA MCLs, or to
an excess cancer-risk level of 10-6 or less, if no current MCL exists for a particular
contaminant. Specific goals for ground water include DCE 0.007 mg/l (MCL), PCE 5 ug/l
. (proposed MCL), TCA 0.2 mg/l (MCL), TCE 5 ug/l (MCL). Surface water must meet Clean
Water Act Federal Water Quality Criteria (FWQC) including PCE 0.8 ug/l (FWQC) and TCE 2.7
ug/l (FWQC) for both water and fish ingestion.

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
CryoChem Site
Earl Township, Berks County, Pennsylvania
Operable Unit 2
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for Operable Unit 2 of the CryoChem Site (Site), Earl.
Township, Berks County, Pennsylvania, chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization. Act of 1986 (CERCLA),
and, to the extent practicable, the National Oil and Hazardous
Substances POllution Contingency Plan (NCP). This action is
based on the Administrative Record for the site.
The Commonwealth of Pennsylvania concurs with the selected
remedy. A letter of concurrence from the Commonwealth of
Pennsylvania is contained within Appendix D.
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 ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This Operable Unit is the second of three Operable Units for the
Site. This Operable Unit addresses ground water contamination
which is the principal threat posed by the Site.
The major components of the selected remedy include:
1 .
Completion of a ground water remedial design study to
determine the most efficient design for a ground water
treatment system.
2 .
Installation, operation~ and maintenance of ground
water extraction wells to remove contaminated ground
water from beneath the Site and to prevent contaminants
from migrating to currently unaffected areas.
3 .
Installation, operation, and maintenance of air
stripping towers to treat ground water to applicable
levels.

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4.
Construction, operation, and maintenance of a pipeline
from the air stripping towers to surface water near the
Site to discharge treated ground water.
5 .
Periodic ground water monitoring to ensure that the
remedy is effective.
STATUTORY DETERMINATIONS
The selected remedy for this Operable Unit is protective of human
health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and
appropriate to this action, and is cost-effective. This remedy
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because hazardous substances will remain in onsite soil, a review
will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~ .? D,
4L( - L v,-<---L---
Edwin B?-Erickson
Regional Administrator
Region III
SEP 28 19SO
Date

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SECTION
1.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
Table of Contents
for the
Decision Summary
INTRODUCTION
......... .... ...... ..........
SITE NAME, LOCATION, AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITY
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE.AND ROLE OF OPERABLE UNIT 2
SUMMARY OF SITE CHARACTERISTICS
. . . . .
. . . . .
.....
........
.........
SUMMARY OF SITE RISKS
....................
DOCUMENTATION OF SIGNIFICANT CHANGES
ALTERNATIVES
.....
................ ............
COMPARATIVE ANALYSIS OF ALTERNATIVES
.....
SELECTED REMEDY...........................
STATUTORY DETERMINATIONS
. . . . . . . . . . . . . . . .
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - ADMINISTRATIVE RECORD INDEX
APPENDIX C - SUMMARY OF SITE SAMPLING DATA
APPENDIX D - LETTER OF CONCURRENCE
PAGE
1
2
4
8
10
10
22
31
32
49
61
64

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List of Figures
1.
2.
3.
4 .
5.
6.
7.
8.
site Location Map
site Map
Residential Wells Currently Treated by
Extent of Ground Water contamination
Area of Soil Contamination
Geologic Map
Geologic Cross Section
Monitoring Well Locations
Carbon Filters
List of Tables
1. Summary of. Contaminants in Surface Soil
2. Concentrations of contaminants Which Could Remain in Soil
3. Highest Concentrations of Contaminants in Monitoring Wells
4. Mean and Maximum Concentrations Detected in Residential Wells
5. Summary of Stream/Sediment Sampling Results
6. Contaminants of Concern and Affected Media
7. Summary of Exposure Pathways
8. Exposure Assessment Assumptions
9. Cancer Potency Factors and Reference Doses
10. Cancer Risks - Current Exposure
11. Cancer Risks - Potential Future Exposure
12. Cancer Risks - All Exposure Pathways
13. Hazard Indexes - Current Exposure
14. Hazard Indexes - Potential Future Exposure
15. Hazard Indexes - All Exposure Pathways
16. Remedial Objectives for OU2
17. Remedial Technologies and Process Options
18. Costs of Alternative 2a
19. Costs of Alternative 2b
20. Costs of Alternative 2c
21. Costs of Alternative 2d
22. Applicable or Relevant and Appropriate Requirements
23. Summary of Costs

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I.
INTRODUCTION
The cryoChem Site (Site) is located in the Village of Worman,
Earl Township, Berks County, pennsylvania. . The Site is
approximately 19 acres in size, with CryoChem, Inc. 's
manufacturing plant and office buildings situated on the southern
4 acres. Past operations at the Site involved the use of
solvents for checking the integrity of metal welds. The solvent
used by CryoChem, Inc. contained 1,1,1-trichloroethane (TCA)
which is a hazardous substance as defined by CERCLA. Volatile.
organic compounds (VOCs), including TCA, have been detected by
the U.S. Environmental Protection Agency (EPA) and the
Pennsylvania Department of Environmental Resources (PADER) at the
site and in residential wells near the Site. The Site was added
to the National Priorities List (NPL) in October 1989 based on an
observed release of hazardous substances ("contaminants") to the
environment.
A Remedial Investigation and Feasibility Study (RI/FS) was
completed by the potentially responsible parties (PRPs) for the
Site in June 1990. The RI/FS investigated the nature and extent
of contamination at the Site and developed remedial alternatives
that addressed the environmental contamination.
Because several residential wells have become contaminated above
applicable federal and state standards, dual, activated-carbon
adsorption units have been installed at 14 of the most
contaminated wells by EPA's Superfund removal program. Because
the contaminated drinking water required an early response
action, EPA initially separated the Site into two operable units
to prioritize and better manage the response activities.
The operable units initially established by EPA were:
Operable unit 1 (OU1) - Drinking Water Supply, and
Operable Unit 2 (OU2) - Area Wide Ground Water and Source Area
After EPA issued the Proposed Plan, which described the response
action EPA preferred to implement for OU2, and upon review of
additional information which became available to EPA during the
30-day public comment period for OU2, EPA determined that
additional alternatives to remediate contaminated soil at the
Site should be developed and the public should be provided the
opportunity to review and comment on these remedial alternatives.
Thus, EPA has decided to further $eparate response activities at
the site into another operable unit. The third operable unit
(OU3) will consist only of the "Source Area" (soil) component of
the remedial alternatives described in the Proposed Plan for OU2.
The operable units developed for the site now are:
Operable Unit 1 (OUl) - Drinking Water Supply,
Operable unit 2 (OU2) - Area Wide Ground Water, and
Operable Unit 3 (OU3) - Source Area (soil)

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A new Proposed Plan for OU3 will be sent to the public in the
near future, and the public will be given the opportunity to
review and comment on the additional remedial alternatives
developed by EPA for contaminated soil at the Site. EPA
anticipates that a proposed plan for OU3 will be sent to the
public in November 1990. The rationale for developing three,
rather than two, operable units for the Site is explained in
detail within Section IX ("Documentation of Significant Changes")
of this ROD.
To the maximum extent practicable, the remedy selected for OU2 -
will be consistent and compatible with the remedy previously
selected for OU1. The remedy for OU1 is embodied in the Record
of Decision executed within a ROD by EPA on September 29, 1989.
The remedy for OU1 includes installation and operation of a new
water supply well, located outside the plume of contamination, to
deliver clean -drinking water to residents affected and
potentially affected by contaminants migrating from the Site.
The remedy for OU2 considers the location of the new water supply
well and includes precautions to ensure that the ground water
extraction system operated for OU2 will not reduce the yield of
the new water supply well and will not cause contaminants to
migrate toward the new water supply well. EPA believes that the
remedy for OU2 is flexible enough to accommodate any possible
modifications to the remedy for OU1, e.g., increased water demand
or obtaining water from a treatment system installed as part of
OU2. In addition, EPA believes that remediation of contaminated
soil behind the CryoChem, Inc. fabrication building (OU3) will be
enhanced by the remedy selected for OU2. For example, the remedy
for OU2 would result in a lower water table behind the
fabrication building thus allowing more soil to be drained and
remediated.
II. Site Name, Location, and Description
The CryoChem Site is located in the Village of Worman, Earl
Township, Berks County, Pennsylvania, approximately 3 miles west
of Boyertown, Berks County, Pennsylvania. The Site includes the
CryoChem, Inc. manufacturing plant and property as well as the
area of contamination. The cryoChem, Inc. property is
approximately 19 acres in size and is situated along Route 562 in
a semi-rural area of Berks County (Figure 1). There are
approximately 100 homes within one mile of the Site.
The Site is located on gently sloping ground at the base of Sand
Hill. Sand Hill is a topographically high area with 90 feet of
relief located immediately northeast of the Site and covered
primarily with forested woodland. A small stream, which drains
Sand Hill, flows across the western part of the Site and then
~
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Figure
1.
SITE LOCAT10N W~r

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through a residential area located south of the CryoChem plant.
The stream eventually discharges to Ironstone Creek that flows
into the Manatawny Creek. Surface runoff from Sand Hill is
combined with drainage from the CryoChem, Inc. fabrication
building and is then channeled to the small stream that runs
along the western part of the Site.
Several farms and single-family homes are located immediately
south and west of the CryoChem, Inc. manufacturing plant (within
one quarter mile of CryoChem, Inc.). The homes are located in
Earl and Douglass Townships, Berks County, Pennsylvania. Several
industries, in addition to CryoChem, Inc., are located along
Route 562 both east and west of the Site. cryoChem, Inc. 's
manufacturing facility includes a workshop area (fabrication
building ~nd Quonset Hut), a warehouse, and an office building
all located on the southern 4 acres of the CryoChem, Inc.
property (Figure 2).
According to available information, ground water flows from
northwest to southeast beneath the site and is controlled
predominantly by fractures in the bedrock. Ground water beneath
the CryoChem plant flows southeast towards several homes which
rely upon private wells for drinking water.
III.
Site History and Enforcement Activity
CryoChem, Inc. has been manufacturing metal products, primarily
pressure vessels, at the Site since 1962. The metal fabrication
process historically included the use of a solvent containing TCA
to wipe away dye used to check for faulty welds. Between 1970
and 1982, cryoChem, Inc. reportedly used the solvent at a rate of
two to three 55-gallon drums per year.
A series of environmental samples collected between 1981 and 1985
by PADER, CryoChem, Inc., and EPA have revealed the presence of
TCA, 1,1-dichloroethane (DCA), 1,1-dichloroethene (DCE),
trichloroethene (TCE), and tetrachloroethene (PCE) in an on-Site
production well and in nearby residential wells. TCA, DCA, DCE,
TCE, and PCE are hazardous substances as defined in CERCLA.
These field investigations also detected the presence of TCA in
on-Site soils.
In May 1985, EPA conducted a site Inspection (SI) at the Site and
collected samples from soil, ground water and surface water. The
results of the sampling would be used later to determine if the
potentially contaminated media at the site would require clean up
under Superfund. In June 1985, EPA ranked and scored the Site
according to the Hazard Ranking System (HRS). The HRS evaluates
hazardous substances (contaminants), defined in CERCLA and
identified at a site, their migration routes and the potential

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receptors, (i.e., populations that could be exposed to the
contaminants), and then calculates a score which determines the
relative hazard posed by a site. If a site scores greater than
28.5 it can be recommended for the National Priorities List (NPL)
making it eligible to receive federal money for investigation and
cleanup. . The CryoChem Site scored 28.58 and was subsequently
proposed for the NPL in July 1987. The CryoChem Site was added
to the NPL in October 1989.
In September 1987, EPA sampled water from residential wells
within 1/4 mile of the CryoChem plant. Due to the detection of
elevated levels of DCE, and other compounds, EPA's Superfund
removal program installed dual, activated-carbon filter units in
13 homes. A filter unit was placed in each home where the
removal action level of 23 ug/l (ppb) of DCE in drinking water
was exceeded. EPA subsequentty placed a filter unit at an
additional home where DCE levels were elevated. Fiqure 3 depicts
residences where EPA has installed a carbon filter unit.
In 1987, EPA met with the PRPs: CryoChem, Inc., C.S Garber &
Sons, Inc., and past owners and operators of CryoChem, Inc. and
the CryoChem, Inc. property. In February 1988, EPA and PRPs for
the Site entered into a Consent Order for the PRPs to conduct a
RI/FS at the Site. The RI/FS was conducted pursuant to a
Statement of Work that was attached to the Consent Order and was
completed in June 1990 under the supervision of EPA. The purpose
of the RI/FS was to determine the nature and extent of
contamination at the Site, to assess the risks to human health
and environment posed by the Site, and to develop remedial
alternatives that would address the risks posed by the Site. The
RI/FS addressed each of the operable units.
To simplify and expedite remedial action at the Site, EPA has
divided the Site into three manageable components or operable
units. The three operable units are:
1. Operable unit 1 (OU1) - Drinking Water Supply: 
2. Operable Unit 2 (OU2) - Area Wide Ground Water: and,
3. Operable Unit 3 (OU3) - Source Area (soil). 
EPA conducted a Focused Feasibility Study (FFS) in the spring of
1989 for OU1 to evaluate remedia~alternatives for providing an
alternate supply of clean drinking water to homes affected by the
Site. The FFS evaluated a total of 33 homes and businesses that
are affected or potentially affected by the Site. An affected
residence has a well with levels of contaminants that are
unacceptable, e.g., levels that exceed EPA's removal action leve~
of 23 ug/l of DCE. A potentially affected residence is located
in an area that could become contaminated at unacceptable levels.
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f
Figure 3.
RESIDE~TlAL WELLS CURRE~TL Y
TREATED BY CARB.ON FILTERS
~
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A Proposed Plan for OU1, which described EPA's preferred
alternative for supplying clean drinking water, was released to
the public on July 14, 1989. EPA's preferred alternative
included extending a water line from the nearest public water
supply to affected and potentially affected residents. Based.
upon its review of public comments received, EPA reevaluated the
alternatives in the Proposed Plan and selected a different
alternative in the ROD for OU1. The ROD for OU1 selected
installation and operation of a new water supply well to deliver
clean drinking water to affected and potentially affected
residents. The ROD for OU1, which selected an alternate water-
supply for 33 residences and businesses, was signed by EPA on
September 29, 1989. EPA's selected remedy for OU1 also included
installation of carbon filter units at homes which become
affected during the design and construction of a new water supply
well and distribution system. - Once the new well is completed by
EPA, each of the affected and potentially affected homes will
then be connected to the new water supply.
On July 14, 1989, EPA sent letters to all the PRPs notifying theD
of their potential liability for OU1 and requesting them to
implement the remedy for the clean drinking water supply.
Additional letters, again requesting PRPs to implement the clean
drinking water supply remedy, were sent to PRPs on November 17,
1989. To date, the PRPs have not committed to implementing the
clean drinking water supply remedy. EPA is currently designing a
new water supply system to distribute clean drinking water to
affected and potentially affected homes using Superfund monies.
After the RI/FS was completed, EPA prepared a Proposed Plan which
described the remedy EPA preferred to implement for OU2 (then
Area Wide Ground Water and Source Area), as well as other
remedial alternatives and associated options. The remedy EPA
preferred to implement included treatment of contaminated soil by
soil vapor extraction and pumping and treating contaminated
ground water by air stripping and discharging to nearby surface
water.
This ROD addresses only the
water since EPA has further
into three operable units.
remediation only. OU3 will
remediation of contaminated ground
separated the Site response actions
OU2 now includes ground water
address the source area.
IV.
Highlights of Community Participation
EPA has several public participation requirements which are
described in Sections 113(k)(2)(B), 117(a), and 121(f)(1)(G) of
CERCLA, 42 U.S.C. sections 9613(k) (2) (B), 9617(a), and
9621(f) (1) (G).
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The Proposed Plan for OU2 was released to the public on August J,
1990. A copy was mailed to each resident near the Site and also
to local government officials. The Proposed Plan defined a 30-
day period during which the public had the opportunity to comment
on the Proposed Plan and the remedial alternatives considered for
OU2. The 30-day public comment period provided in the Proposed
Plan started August 6, 1990 and ended September 7, 1990.
The RI Report and the FS were sent to the information
repositories, located at the Earl Township Building and the
Douglass-Berks Township Building, in July 1990. The availability
of these documents was stated in the Proposed Plan.
The Administrative Record file for OU2 of the Site was delivered
to the Earl Township Building on July 26, 1990. The
Administrative Record file contains documents that served as the
basis for EPA's selection of a remedial alternative for OU2 of
the Site.
On August 13, 1990, EPA published a notice of availability of the
Proposed Plan and Administrative Record file in two local
newspapers. The notice was published in The Readinq Times/Eagle
and in the Bovertown Times. Since the notice was not published
until August 13, 1990, which is 7 days after the start of the 30-
day public comment period as stated in the Proposed Plan, EPA
decided to extend the public comment period through September 11,
1990.
The public was encouraged to review the Proposed Plan and
Administrative Record file and to submit comments on EPA's
preferred remedial alternative. The public was given additional
opportunity to comment on the Proposed Plan and Administrative
Record file at a public meeting held at the Earl Township
Building on August 28, 1990. At this meeting representatives
from EPA answered questions and received comments about the Site,
the remedial alternatives under consideration, and the proposed
remedy. Community response to the then preferred alternative is
summarized within the "Comparative Analysis of Alternative"
section of this ROD. A stenographic report of the public meeting
was prepared by EPA. A response to comments received during the
30-day public comment period is included as part of this ROD in
the Responsiveness Summary (Appen4ix A) .

The index for the Administrative ~ecord file, upon which this
decision document is based, is contained within Appen4ix B. This
decision document is also based upon comments contained within a
stenographic report of the public meeting on August 28, 1990 and
other comments received by EPA during the 30-day public comment
period, which are included in the Site file maintained at EPA.
The stenographic report and public comments will be added to the
Administrative Record file.
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v.
Scope and Role of Operable Unit 2
As explained above, EPA has divided the CryoChem Site into three
manageable components or operable units. The three operable
units are:
1. Operable Unit 1 ( OU 1) - Drinking Water Supply; 
2. Operable Unit 2 (OU2) - Area Wide Ground Water; and,
3. Operable Unit 3 (OU3) - Source Area (soil). 
This ROD .addresses OU2.
EPA has already selected a remedy for OU1 (Drinking Water
Supply). The contaminated drinking water is a principal threat
posed by the Site because of the direct ingestion of drinking
water from wells that contain contaminants above health-based
levels. The ROD for OU1 provided an alternate water supply for
homes affected and potentially affected by the Site. The remedy
for OU1 is currently in the Remedial Design stage.
The response action for OU2 addresses ground water contaminated
by the Site. Contaminated ground water at the Site poses a risk
to future ground water users if not addressed by OU2. The
primary objectives of this response action are to: 1) prevent
further off-Site migration of contaminated ground water, 2)
prevent migration of contaminated ground water into surface water
and into currently unaffected areas, and 3) restore the aquifer
to its beneficial use, if practicable. The remedy selected in
this ROD addresses each of these objectives. The remedial
alternative selected in this ROD can be adapted to be compatible
with the remedy selected for OU1.
The contaminated soil on the Site continues to leach contaminants
into ground water beneath the Site. The contaminated soil, which
is the source of ground water contamination, would be addressed
by OU3. This third operable unit will be the final response
action for the Site.
VI.
Summary of Site Characteristics
The RI/FS was conducted to determine the extent and nature of
contamination at the Site. The approximate extent of ground
water contamination is depicted on Fiqure 4. The results of the
RI are discussed in this Section.
During former operations at the CryoChem, Inc. plant, solvents
,
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-------
containing TCA were used to clean dye from metal welds. The
amount of solvent reportedly used between 1970 and 1982 was
approximately three 55-gallon drums per year. CryoChem, Inc.
also reported that a spill of solvent from a 55-gallon drum
occurred ~t some unspecified time in the past. The amount of
solvent spilled is unknown. Spilled solvent would have collected
in the shop drains and flowed, through underground pipes, into a
small stream located along the western edge of the CryoChem, Inc.
property.
During the RI, the sump into which the solvent spill reportedly
occurred was examined, hydraulically tested, and determined to be
intact. The pipes through which the solvent would have flowed
into the on-site stream were also examined, hydraulically tested,
and determined to be intact. Thus, it remains unclear if the
reported spill of solvent caused ground water contamination at
the Site. .
The design specifications and criteria of any ground water
remediation system to be constructed at the Site would be based,
in part, upon the location of contaminated soil and the type and
amount of contaminants identified within the soil. For example,
the extraction wells would be located to ensure that contaminants
leaching from the soil into ground water would be collected by
the extraction wells. Thus, the results of the soil sampling are
discussed in this ROD.
During the RI and during previous investigations, VOCs (e.g.,
TCA), were detected in soil samples collected at the site. The
highest concentrations were detected in a sample collected from a
depth of 9 to 12 inches behind the fabrication building near its
rear entrance (Soil Sample #17) (Fiqure 5). The levels of
contaminants found in soil sample #17 are depicted in Table 1.
The elevated levels of contaminants detected in soil near the
fabrication building indicate that solvent discarded behind the
fabrication building most likely contributed to ground water
contamination at the Site. The elevated concentrations of xylene
and ethylbenzene in soil sample #17 most likely result from minor
spills of fuel during refilling of the fuel tank located near the
back door.
Some of the compounds detected in soil sample #17 can easily
migrate through the soil column and leach into the ground water
system beneath the site. EPA ha~calculated the amount of
contaminants which could remain in the soil without posing a
threat to ground water. EPA's calculations are contained within
Attachment 3 of its May 22, 1990 correspondence with the PRPs
which is contained within the Administrative Record file.
The following assumptions were made to simplify the calculations:
- the contaminants that leach from the soil to ground water
1:
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beneath the site are diluted by clean ground water flowing
through the site;
- the vertical interval over which the contaminants are
diluted is equal to the average open interval of nearby
domestic wells;
- the presence of organic matter in soil (estimated from
literature value) is the only factor that retards the
migration of contaminants from the soil to ground water
since VOCs tend to adsorb onto organic matter; and
a
- the resulting concentration of contaminants in ground
water should not exceed EPA's most stringent enforceable
standard or. an excess cancer risk of 1X10-6 (which is
further discussed in the next section of this ROD).
TABLE 1
SUMMARY OF CONTAMINANTS
IN SURFACE SOIL
(SAMPLE #17)
CONTAMINANT
CONCENTRATION
TCA
DCA
PCE
TCE
XYLENES
ETHYL BENZENE
22,000
4,200
460
60
11,000
920
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Table 2 depicts the concentration of specific contaminants that
could remain in the soil without presenting an unacceptable risk
to ground water beneath the Site. Some of the concentrations may
seem high (e.g., xylene) due to the fact that the contaminant is
not particularly toxic and adsorbs strongly to organic matter in
soil. EPA's calculations indicate that the current levels of
certain contaminants, e.g., DCA and PCE, in the soil behind the
fabrication building pose a threat to ground water. The
approximate volume of contaminated soil based upon EPA's
calculations is 1875 cubic feet.
-------
TABLE 2
CONCENTRATIONS OF CONTAMINANTS
THAT COULD REMAIN IN SOIL
CONTAMINANT
CONCENTRATION
TCA
DCA
PCE
TCE
XYLENE
ETHYL BENZENE
23,100
8.6
190
306
1,824,000
585,200
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Figure 5 depicts the area of contaminated soil at the Site.
The bedrock beneath the Site consists of fractured quartzite
(Hardyston Formation) and crystalline limestone (Leithsville
Formation) overlain by soil derived from weathered bedrock
(overburden) (Figures 6,7). A fracture can be considered to be
any break in the rock matrix. Ground water moves predominantly
through the fracture system and through solution cavities formed
when certain minerals in the bedrock dissolve or weather from the
rock matrix over time. Therefore, residential or other wells
penetrating the same fractures or fracture systems containing
ground water contaminated from the Site may themselves become
contaminated. Some residential wells are contaminated by the
same VOCs as those found in ground water beneath the Site and in
soil behind CryoChem Inc. 's fabrication building.
A large fault, which is a fracture along which two separate
blocks of the bedrock have moved, exists south of the Site
(Figures 6, 7). The fault is significant in that it separates
crystalline limestone, which is also beneath the Site, from red
shale. As ground water moves towards the fault it may move
upward and discharge at the surface in the form of springs.
Simplified, ground water discharges as springs since it is easier
for ground water to move up the fault than it is for it to move
into the red shale.
During the RI, several ground water monitoring wells were
installed at and near the Site (F~gure 8). The main objective of
installing monitoring wells was to determine the extent of ground
water contamination. Wells were installed in clusters, (i.e., a
shallow well was installed adjacent to a deep well), for the
purpose of determining if the contamination was confined to
shallow zones or had spread deeper into the ground water system.
Since ground water tends to migrate in discrete zones, such as a
deep fracture, the monitoring wells were constructed to allow a
sample to be collected from either the shallow or deep zone. Th~.
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sampling results from these wells suggest that the contamination
is not confined to shallow ground water zones since both shallow
and deep monitoring wells contained contaminants. However, the
concentrations of contaminants in the shallow ground water
samples are typically higher than the concentrations in the
deeper samples suggesting that contaminants may not have sunk to
the bottom of the ground water syste~. Table 3 depicts the
highest concentration, at the most contaminated well, of the
contaminants identified in ground water monitoring wells during
the RI. Table 4 depicts the 95% upper confidence limit of the
mean concentration and the maximum concentration of contaminants
identified by EPA in the most contaminated residential well
downgradient from the Site. No vinyl chloride, which is a
degradation product of TCE and a known human carcinogen, has been
detected in the residential wells.
TABLE 3
HIGHEST CONCENTRATIONS OF CONTAMINANTS
IDENTIFIED IN GROUND WATER MONITORING WELLS
CONTAMINANT
MCL*
CONCENTRATION
LOCATION
TCA
DCA
PCE
TCE
DCE
200 ug/l
5 ug/l
5 ug/l
7 ug/l
280 ug/l
19 ug/l
8 ug/l
14 ug/l
62 ug/l
RI-1S
CC-2
RI-1S
RI-1S
RI-1S
* MCL for PCE is proposed
TABLE 4
MEAN AND MAXIMUM CONCENTRATION OF CONTAMINANTS
IDENTIFIED IN DOWNGRADIENT RESIDENTIAL WELLS
CONTAMINANT MCL* MAXIMUM MAXIMUM MEAN**
TCA 200 ug/l 1052 ug/l 516 ug/l
DCA  130 ug/l 22.5 ug/l
PCE 5 ug/l 15 ug/l 7.5 ug/l
TCE 5 ug/l - 37 ug/l 13 ug/l
DCE 7 ug/l 1734 ug/l 380.6 ug/l
* MCL for PCE is proposed
** Maximum mean is the highest mean concentration
identified in individual residential wells.
The results of ground water sampling during the RI indicate that
1 ~.
-------
the area of ground water contamination extends from CryoChe~,
Inc. facility nearly 2500 feet southeast to several springs
located along the tributary to Ironstone Creek (near Trout Farm) .
Based upon the results of the RI, the plume of contaminated
ground water may extend further south than these springs.
However, the presence of the fault and the large springs near the
Trout Farm suggest that ground water is discharging to surface
water at this location. Typically h1gh elevation areas, e.g.,
Sand Hill or Fancy Hill, are areas where ground water is
recharged by precipitation. In recharge areas, ground water
typically moves from high elevation to low elevation, or
downward. Ground water eventually moves towards low-lying areas,
e.g., swamps and streams, and then may move upward to discharge
into surface water. The presence of springs can be an indication
that ground water is moving upward to the ground surface.
. .
The lateral dimensions of the plume of contaminated ground water
are not fully defined in the area southeast of Fancy Hill Avenue.
However, the results of residential well sampling and the
distribution of contaminants in surface water and ground water
near the Trout Farm indicate that the plume continues to move
southeasterly from Fancy Hill Avenue, where it is defined by
residential well sampling, to the springs near the Trout Farm.
Figure 4 depicts the approximate extent of ground water
contamination based upon the results of the RI. The volume of
contaminated ground water is estimated to be nearly 1.5 billion
gallons assuming a uniform depth of contamination of 300 feet and
minimal lateral dispersion of the plume.
Since contaminated ground water discharges to streams on and near
the Site (i.e., into the on-site stream and into the stream near
the Trout Farm), surface water near the Site is also
contaminated. The level of contamination within the surface water
quickly dissipates downstream from the area where contaminated
ground water introduces the contaminants into the surface water.
contaminant levels in the surface water are most likely reduced
by volatilization and dilution. Table 5 depicts the highest
concentrations of contaminants detected in surface water and
stream sediment during the RI. The contaminated surface water is
limited to the on-site stream and to the area immediately
downstream of the springs at the southern extent of the plume.
2 ~
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TABLE 5
SUMMARY OF STREAM/SEDIMENT SAMPLING
CONTAMINANT
CONCENTRATION
SURFACE WATER
TCA
DCA
DCE
150 ug/l
5 ug/l
7 ug/l
SEDIMENT
TCA
DCA
13 ug/kg
3 ug/kg
The RI results also suggest that a potential source of ground
water contamination exists somewhere north of the CryoChem, Inc.
plant. Several residential wells located north of the CryoChem,
Inc. plant contained the highest levels of TCE detected in the
ground water. Since ground water in the area generally flows
from north to south, ground water contaminated by TCE from an
off-Site source north of CryoChem, Inc. may have migrated onto,
and may continue to migrate onto, the site. TCE was detected at
high concentrations in only one of the two rounds of sampling
conducted during the RI/FS in homes north of the site.
A wetland area was identified at the Site. The wetland area is
upstream of the area which has been identified as the source of
the Site-related ground water and surface water contamination and
therefore is most likely not impacted by the Site-related
contamination. One obligate wetland species, the common cattail,
was identified in the wetland area. No other wetland areas,
except the stream itself, were identified.
No federally listed or proposed endangered or threatened species
are known to occur on or near the Site. No endangered or
threatened species listed by the Commonwealth of Pennsylvania are
known to exist on or in the vicinity of the Site, but one State
endangered species, the bog turtle, may exist on or near the
Site. No structures listed on the National Register of Historic
Places exist within Earl Township, Berks County, Pennsylvania.
The Ironstone Bridge, which crosses the Ironstone Creek at
Farmington Avenue in Douglass Township, Berks County,
Pennsylvania, is listed on the National Register of Historic
Places, but is not located near the site and would not be
impacted by the alternatives considered for remediation of the
2:
-------
site.
Appendix C contains a summary of all sampling data collected
during the RI/FS.
VII.
summary of Site Risks
During the RI/FS, a baseline risk assessment was conducted that
quantified the risks posed by the Site if no response actions
were taken to address Site-related contamination. Both EPA and
JACA Corpqration (on behalf of the PRPs) conducted a baseline
risk assessment. EPA conducted its own risk assessment to 1)
double check calculations performed by PRPs, 2) make use of
additional data collected by EPA from carbon filter units, 3)
evaluate exposure pathways which were not evaluated by the PRPs,
and follow new EPA guidance. EPA's risk assessment followed
recent EPA guidance on conducting risk assessments (Risk
Assessment Guidance for Superfund, Volume 1 Human Health
Evaluation Manual, December, 1989). The focus of each risk
assessment was to determine human health effects that could
result from exposure to the contaminants of concern associated
with the site. JACA's results are consistent with EPA's results
when similar exposure pathways were evaluated.
During the RI, contaminants were detected in soil, ground water,
surface water, and sediments near the Site. Contaminants of
concern are those that 1) present a potential risk to human
health and the environment at the detected concentrations, 2)
originated from the Site, and 3) were above background levels. A
contaminant presents a potential risk to human health if its
concentration exceeds the 1x10'6 excess cancer risk level for
cancer-causing compounds or the maximum safe dose for non-cancer
effects. In other words, there is 1 extra chance out of
1,000,000 (one million) of contracting cancer due to a lifetime
of exposure to a carcinogenic compound in a concentration equal
to the 1x10'6 level. This risk is in addition to the risk posed
by all other sources, e.g., a 30,000 chance out of 1,000,000 of
contracting cancer from smoking. The NCP states that an
acceptable risk ran~e is between 1x10'~ (1 in 10,000 or 100 in
1,000,000) and 1x10' (1 in 1,000,000). However, EPA strives to
reduce risk to the 1x10-6 level and thus uses this level as the
point of departure. The contaminants of concern and the affected
media at the site are identified in Table 6.
2:
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TABLE 6
CONTAMINANTS OF CONCERN AND AFFECTED MEDIA
CONTAMINANT
l,l,l-trichloroethane (TCA)
AFFECTED MEDIA
ground water
surface water
ground water
surface water
 soil
ground water
 soil
ground water
ground water
surface water
l,l-dichloroethane (DCA)
tetrachloroethene (PCE)
trichloroethene (TCE)
l,l-dichloroethene (DCE)
An individual may
several different
exposure pathways
above.
be exposed to contaminants of concern via
exposure pathways. Table 7 identifies the
associated with the affected media identified
The assessment of risk involves many assumptions about the amount
of exposure to contaminants. EPA strives to select protective
remedies and thus utilizes risk estimating assumptions that are
somewhat conservative, e.g., EPA uses the upper bound estimates
of the mean values of certain parameters (95th percentile
concentration). For example, EPA assumes that an individual
lives at the same residence for 30 years. Table 8 lists each of
the assumptions EPA used to calculate exposure to contaminants of
concern at the Site. The exposure scenario, which is developed
using the assumptions identified below, is a reasonable maximum
exposure scenario.
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TABLE 7
SUMMARY OF EXPOSURE PATHWAYS
CONTAMINATED MEDIA
EXPOSURE PATHWAY
GROUND WATER
INGESTION (DRINKING)
INHALATION (SHOWERING)

INGESTION (RECREATION)
~ERMAL CONTACT (SWIMMING)
FISH INGESTION
SURFACE WATER
INGESTION (CHILD TRESPASS)
DERMAL CONTACT
INHALATION (WORKERS)
SOIL
TABLE 8
EXPOSURE ASSESSMENT ASSUMPTIONS
Adult Mass (kg)
Child Mass (age 3-6) (kg)
Length of Lifetime (yrs)
Length of Adult Exposure (yrs):
Length of Child Exposure (yrs):
Tap Water Consumed (l/d)
Fish Consumed (g/d)
Surface Water Ingested (l/d)
Adult
Child
Recreation Events/Year, Adult:
Recreation Events/Year, Child:
Rec. Event Duration (hour) :
Skin Surface Area, Adult (cm2):
Skin Surface Area, Child (cm2):
Soil Ingestion (mg/event)
Soil Ingestion Events/Year
70
17
75
30
4
2
35
0.01
0.1
30
60
1
18150
7540
200
10
* Tap Water Concentration is 90% Upper
Bound Confidence Level of the Mean
Concentration
* Surface Water Concentration is the
Maximum Observed Concentration
-------
Chemical intakes are calculated by combining the amount of
chemical (each contaminant of concern) with the duration of the
exposure to the contaminated environmental media.
Current and potential future exposure scenarios were evaluated in
the risk assessment. Since residential wells that are affected
are equipped with carbon filters, ingestion of contaminated
ground water was considered to be a potential future exposure.
For example, an individual could be exposed if a new well was
drilled into the contaminated area or if the existing filter
units were not properly maintained. Thus, the estimates are
based upon levels of contaminants in untreated water. Future use
scenarios also assume that current exposures continue into the
future, i.e., no remediation occurs. Current exposure scenarios
include incidental ingestion of surface water while playing in
the contaminated stream, dermal (skin) contact with surface water
while playing in the stream, incidental ingestion of soil by a
child who trespasses behind CryoChem, Inc. 's fabrication
building, and ingestion of fish caught in the contaminated
stream. Dermal contact with contaminated soil by CryoChem, Inc.
workers and inhalation of contaminants from soil by CryoChem,
Inc. workers are potential exposure pathways, but were not
evaluated by EPA since the exposure is expected to be minimal,
i.e., less than lxlO-6. JACA evaluated exposure to CryoChem,
Inc. workers and determined that exposures from contaminated soil
were well below (safer than) acceptable risk-based levels. The
risks resulting from exposure to contaminated soil will be
addressed in aU3.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
(cancer-causing) chemicals. CPFs, which are expressed in
units of (mgjkg-day)-', are multiplied by the estimated chemical
intake of a potential carcinogen, in mgjkg-day, to provide an
upperbound estimate of the excess lifetime cancer risk associated
with the exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. CPFs are derived from the
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. CPFs ~or the contaminants of concern
are depicted in Table 9.

Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mgjkg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
-------
the amount of chemical ingested from contaminated drinking wate~)
can be compared to the" RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help to ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur. RfDs for the
contaminants of concern are depicted in Table 9.
TABLE 9
CANCER POTENCY FACTORS (CPFs) AND
REFERENCE DOSES (RfDs) FOR CONTAMINANTS
OF CONCERN
CONTAMINANT ORAL INHALED ORAL INHALED
  RfD RfD CPF CPF
  (mgjkgjd) (mgjkgjd)-'
TCA 9x10 -2 NA NA NA
DCA 1.2x10-1 1.38x10" 9 .1x10'2 9. 1x10'2
PCE 1X10-2 NA 5.1X10-2 3. 3X10-3
TCE NA NA 1. 1x10'2 1.3x10-2
DCE 9x10'3 NA 6x10-1 1.2
NA = Not Available   
Excess lifetime cancer risks are determined by multiplying the
intake level with the CPF. These risks are probabilities that
are generally expressed in scientific notation (e.g., 1X10-6, or
1 million). An excess lifetime cancer risk of 1x10'6 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 his or her entire lifetime. Excess
lifetime cancer risks associated with Site-related exposures are
depicted in Tables 10-12.

Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the RfD for the
contaminant). By adding the hazard quotient for all contaminants
within a medium or across all media to which a given population
.may reasonably be exposed, the Hazard Index (HI) can be
generated. The HI provides a useful reference point for gauging
-------
the potential signific~nce of multiple contaminant exposures
within a single medium or across all media. The HIs associated
with site-related exposures are depicted in Table 13-15.
Because receptor populations could reasonably be exposed by all.
the exposure routes evaluated, risks and hazard indexes from each
exposure route were combined in Tables 12 and 15. Since exposure
to more than one chemical could occur through any of the exposure
pathways, carcinogenic risks and hazards for each chemical were
added to obtain the total risk or Hazard Index for any particular
exposure pathway. Cancer risks ~o children and adults were al~o
combined under the assumption that children raised near the Site
might continue to live there as adults. Hazard indexes for
children and adults were not combined because they were based on
I-year, rather than lifetime, exposures..
TABLE 10
CANCER RISKS POSED BY THE CRYOCHEM SITE
CURRENT EXPOSURES
EXPOSURE
RISK
Incidental
Child
Adult
Child+Adult
Surface Water
Inqestion
2.48xlO.7
2.26x10.a
2.71x10-7
Dermal Contact with Surface
Child
Adult
Child+Adult
Water
1.63x10-S
3.57x10-s
5.20x10-s
Fish Inqestion
Child
Adult
Child+Adult
3.11xlO.6
5.67xlO.6
8.78x10-6
All Current
Child
Adult
Child+Adult
Exposure Routes
Combined
1.96x10-s
4.14xlO.s
6.10X10-s
- ..
L
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TABLE 11
CANCER RISKS POSED BY THE CRYOCHEM SITE
POTENTIAL FUTURE EXPOSURES
EXPOSURE
RISK
Drinkinq Water
Child
Adult
Child+Adult
1. 45x10-3
2.64x10-3
4.09x10-3
Inhalation while
Child
Adult
Child+Adult
Showerinq
2.88x10-3
5.25x10-3
8.13x10-3
All Future Exposure
Child
Adult
Child+Adult
Pathways
Combined
4.33x10-3
7.89xlO.3
1.22xlO-z
TABLE 12
CANCER RISKS POSED BY THE CRYOCHEM SITE
ALL EXPOSURE PATHWAYS
EXPOSURE
RISK

4.35xlO.3
7.93XlO-3
1.23xlO.z
Child
Adult
Child+Adult
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TABLE 13
CURRENT EXPOSURE HAZARD INDEXES (HI)
EXPOSURE
HAZARD INDEX
Incidental Surface Water Inqestion
Child 2. 65x10.3
Ad u I t 3 . 43 x 1 0 .6
Dermal Contact with Surface Water
Child 1. 74x10"
AduJ. t 5. 07X10'2
Fish Inqestion
Child
Adult
4.43x10.2
1.07x10.2
All Current Exposure Routes Combined
Child 2. 21x10"
Adult 6.14X10.2
TABLE 14
POTENTIAL FUTURE EXPOSURE HAZARD INDEXES
EXPOSURE
HAZARD INDEX
Drinkinq Water
Child
Adult
5.76
1. 40
Inhalation while Showerinq
Child
Adult
1.92x10'2
4.67x10'3
All Future Exposure Pathways Combined
Child 5.78
Adult 1. 40
2'::'
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TABLE 15
HAZARD INDEXES FOR ALL EXPOSURE ROUTES
child
Adult
6.00
1.47
The total upper bound excess lifetime cancer risk associated with
the future use scenario including all current use exposures was
1.23x10-2 or approximately 1 in 100. This means that for every
1,000,000 people exposed to Site-related contaminants,
approximately 10,000 could contract cancer due to their exposure.
There are several important caveats to this estimate:
1. Nearly all the risk was associated with residential well
water, which is currently being treated with carbon filter units.
Therefore this exposure is not presently occurring.
2. Most of the residential well risk was associated with DCE
which is a Class C carcinogen. This classification means that
animal tumor data for this compound are equivocal. It is
possible that DCE is not carcinogenic in humans.
3. The risk estimate applies only to the most contaminated
homes. Cancer risks at the other homes would probably be less.
The total HI associated with the future use scenario was 1.47 for
adults and 6.00 for children. This risk originated almost
entirely from well water. The HI for inhalation may be
artificially low since inhalation RfDs were not available for
four of the compounds.
The following factors contributed elements of uncertainty in the
risk assessment: 1) the actual or potential use of the
contaminated stream for recreation, 2) limited sample database
for some media (e.g., surface water), 3) carcinogenic
contaminants at the site have been found to cause cancer in
animals only, 4) CPFs were extrapolated from high doses given to
animals to low doses received from environmental exposures, 5)
carcinogenic potency was extrapolated from animals to humans on
the basis of dose per surface area, 6) non-cancer effects were
extrapolated from animals to humans by a set of protective 10-
fold uncertainty factors, and 7) data on synergism or antagonism
among the contaminants were not available. However, the majority
of the risk posed by the Site resulted from contaminated ground
water which has an extensive database of high quality samples,
i.e., samples which passed a thorough quality assurance/quality
control review.
~
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VIII.
Documentation of Significant Changes
The Proposed Plan for OU2 contained 4 ground water treatment and
discharge alternatives which were detailed in subcategories under
two different general alternatives. The 4 ground water treatment
and discharge alternatives were identified under subcategories
"a", "b", "c", and "d". These 4 alternatives were grouped under
general Alternative 2 (i.e., 2a, 2b, 2c, and 2d) and general
Alternative 3 (i.e., 3a, 3b, 3c, and 3d). Alternatives 2a
through 2d and Alternatives 3a through 3d respectively contain
the same ground water components. Alternatives 3a through 3d
also included a soil remediation component. other than the
inclusion of soil vapor extraction in Alternatives 3a through 3d,
the subcategories under "general" Alternative 2 and "general"
Alternative 3 were the same. For example, the ground water
components of' Alternative 3a were the same as the ground water
components of Alternative 2a.
The Proposed Plan was sent to the two local information
repositories and residents near the Site on August 3, 1990.
addition, a minimum 30-day comment period was conducted from
August 3, 1990 to September 11, 1990, and a public meeting was
held August 28, 1990 to provide the public with an opportunity to
comment on the remedial alternatives for OU2. The public comment
period was subsequently extended to September 17, 1990 since the
notice of availability of the Proposed Plan was not published in
local newspapers until August 13, 1990.
In
After EPA issued the Proposed Plan, which described the response
action EPA preferred to implement for OU2, and upon review of
additional information which became available to EPA during the
30-day public comment period for OU2, EPA determined that
additional alternatives to remediate contaminated soil at the
Site should be'developed and the public should be provided the
opportunity to review and comment on these remedial alternatives.
Thus, EPA has decided to further separate response activities at
the Site into three operable units. The third operable unit
(OU3) will consist only of the "Source Area" (soil) component of
OU2 described in the Proposed Plan for OU2.
Since soil contamination will now be addressed as a third
operable unit, only Alternatives 2a through 2d, as described in
the Proposed Plan for OU2, are copsidered in this ROD. Because
this ROD addresses ground water, and the ground water components
of the alternatives identified in the Proposed Plan are
unaffected by exclusion of a soil treatment technology, EPA has
decided to eliminate consideration of Alternatives 3a through 3d
in this ROD.
., ,
.J ...
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IX.
Alternatives
This section of the ROD describes the process of screening and
developing remedial alternatives and discusses in detail each of
the ground water remediation alternatives evaluated in the
Proposed Plan. Remedial alternatives were developed to meet the
remedial objectives of this response action. The remedial
objectives are identified in Table 16.
TABLE 16
REMEDIAL OBJECTIVES FOR OU2
1. Protect public health, welfare, or environment
2. Prevent further off-Site migration of contaminants in
. ground water and surface water
3. Prevent contaminant migration into unaffected areas
4. Restore the aquifer to beneficial use, if practicable
The Commonwealth of Pennsylvania requires that ground water be
remediated to "background" quality as specified by 25 PA Code
Sections 264.90 through 264.100. The Commonwealth of
Pennsylvania also maintains that the requirement to remediate to
background is found in other legal authorities.
In order to restore the aquifer to its beneficial use, the
remediation system implemented in each of the alternatives would
operate until Site-specific remediation goals are achieved. Thus
the aquifer would be remediated until the contaminate levels
reach the MCLs, Non-zero MCLGs, or background, whichever are
lower.
If implementation of the selected remedy demostrates, in
corroboration with hydrogeological and chemical evidence that it
will be technically impracticable to achieve and maintain the
remediation goals throughout the 9rea of attainment, the USEPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals.
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screeninq of Alternatives
Table 17 identifies each of the remedial technologies and
management or process options which were screened in the FS and
considered in the development of remedial alternatives for
contaminated ground water. The significance of the screening
exercise is to determine which technologies and options can best
s~tisfy the remedial objectives. Each of the technologies and
-
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GrOLftdwII.r
G_II ReIpOnH
Acllonl
No AcUon
R.medlil
T 8ChnoIogy
None
1n8tII~
AcUanl
CoI8cUonI
D8IohIrg8
ConIIh'n8n8
Hoe88 :
(.~': ,~.
~ .."'..
Acc...
Realncllonl
AIIemII.
WII. ~
MonIIomg
Extr8C11on
$4Ibaur1ac.
Drllna
0naII.
Drllnage
0ttIII.
Dr8Inag8
v.uc..
Ian18r
.J
T8C~1 thaI are acrHOed ouI
Table 17
Hcmedial Technologies
Process
Opllons
Nol AppIc8ble
Deed ReSIr1cllons
New W" Oulslde Plume
CIV WII.
locll Tr.llmenI Ur*
individual Tr..."*" Ur*a
GrOLftdwIl. MonItoring
ExlrlCllon W'"
ExlracllonlRecharge Wells
CoIeoI II Spmga
. .
"
.. .
Deep w.. InteOUon
POTW
~ 10 RIv8r
Grout Curl..
.....
D.sC~11on
No Icllon
Propeny deeds In lhe Ire. 0' In'luenc.
would Include r.slr1c11ons on well
locil. new community w.. ouIslde
aft.Cled ar..

Exlenalon 0' exlsllng Boyer1own WII'"
aVSlem 10 leMc. ,.8IdenI1 In ar.1 0' Influence

Exlracl oonl""'l8d wll., Ir.11 and
pipe 10 ,.8IdenI1 In ar.a 0' Inftuenc.

lnalll Ir.almenl unit In each ,.1Idenc.
or buAwal In ar.1 o. IntIu8no8
~ monitoring o. w...
Seftn of W8Is 10 .xlrlcl conlllmk1aled wII...
Recharge well r.lurn unconI.mnaled WII'"
10 Inor.... low 10 .XIr8C1Ion unlta

Pertoraled pipe In Irenohea blcldlled with
poroua mecIa 10 coIeel ocn""led WII'"

CoIeeI cont8mk\lled wil. II .xia~ apmga
EXlrlcled wal. clach8rged 10 10011 alr.1m on
the ...
ExlrlCled wII. cIIc:hIrged 10 deep well
Infection aysaem
Exlr8Cled wil. cIachIrged 10 Ioc8I POTW
EJClracled wll. clachlrged 10 rtver
on ...
~ CoV.
Trench IRUId eonl.mn.led arel II flied with
aoIIbenIonI. 8UJy

Preaaur. Infecllon of wout In I regtAr' pillem
of dr8ed hotea

Vlbrillng loree 10 Idvanc. bellTls Inlo the grOWld
wlh InIecllon 01 aIurry II belml1 wlthdrlwn
Cr.ll. hor1zontll ba.mer 10 pr.venl lurther
mgrallon downwird
Screening Commenll
Requk'ed lor conaIderaUon
by t.tcP
POlenllllV lppIcabie
POIenIIIIy 8PPIc1bl8
POIenUIIy IppIcIbl8
POlenlllly IppIcIbl8
POlen11llV lppIcabie
POlenll8ly appIclble
POlenlldv appIclbl8
AquIt.r and conlamn.llon
100 deep lor 1r81"1Ct181
POlenlllly apple'"
Slr.1ITI wcUd not ","I CWA
orIerIa
POlenlllly appIe8ble
POIenUIIIV appIe8ble
Polenlllly apple'"
Nol elf8Cllve; loa hi, only
"**nIl cont.mn.Uon
AquI... and oonIlI'IIhaUon
100 d88p 'or lrenoh8t
PoIendIIy 8PPIc8b18
Hoe 1ppIc8ble In fraclured rock
Nolle..", deplh 01
conlwnlnallon 001 dellnltetv knOwn
but mlY be 300 ,...
-------
GrOll ~
G....... ....
AK;1Ion8
CoIeollDn
T I'888m8I1I
D8Ich8rge
'--
I ~--- ;-'~=-=1
A8~.'
'ecMology
Exaractlon
S&GIW1I08
Dnn
(IIoIDgIo1l
T,...,...
flt¥llCllla.mc..
Tf88InWII
TtwmaI
Dettruollan
OffIll.
TreaInW1I
... lIu
TrUIm8nI
OnIIe
DI8charg8
Off...
Discharge
, echnologles Ihll are screened out
Table 17 (Continued)
Hemedlal ;nolngies

Process
Opllons
Exlracllon Wel.
Exlracllon/Recharge w...
........ ..
Coleel al Spmg8
I,'
,'~ "
I "
S~
Cubon AdIorpUon
.:.'" .
a.nc:1I Reaction
Rotary 01
A*IIed led
POM
ACRA Fac8ty
. ..
: :
Aerallon
J
a.nc:II Reacllon
loo" Slream
POTW
Deep W" "'18cllon
Pipeline 10 RIver
Oesc~11on
Sene. 0' ..ell 10 8xlrlcl contan*1aled ..ller
Recharge ..eI. relurn l.nConlamWlaled water
10 Incr.a.. IIow 10 exlracllon unit.
Perforated pipe ... Irenchel backftled wtth
porous rn8dIa to coI8ot cone8fN\ated wal.
COIeCI contanmated ..aler at .xlsllng sprtngl
08lJ'adlllon 0' organics uAIg moro organisms
... In leroblc erMrGnrlWlt '
OeIJ'adltlon of organics using rricfo organlama
... In ..,..obIc 8lMl0IiIMI1I
Alterliion 0' chemic" equ8bI1a 10 r~
soUJ8ty 0' oontarni1lnts
PISslng "ge vobn8a of air ov. lhe M81ao.
0' the waler ... a paaked ooIurm 10 ar...,. the
VOCI to the air
AdsorptIon of oonI8I1'INInt. 01110 acltvated carbon
bv puq w... UWoIVI oarbon ookmn

UN of ~ pr...... to '01'08 wat. Ihrougtl a
............ "a'*'8 DonI""". b8Nnd

R88CI oontarnhanl will oJlJdlmg. r8Ga0fng.
or ~ agent

CombuItIon ... a hortzont" rotlllng ~
Cont8fN\ated w... ~ted ""0 hol la*lZed
bed of .... where oombuI8Ion 000Uf8

Extracted gro&ntwat. dI8cItIarged to local
POM for tr8atIn8nI
EXlrecled wocn:tw... cI8CfIarged 10 Io8nNd
RCRA ,8C8ty tor tr'8atI1*1IliIWJTor dIIposal
SVilem of ~Iion IiIWJ .xtraction well 10
....r0dU08 b8Ctertl IiIWJ nubt8nts to ~
oontllNlaUon
SVilem of well 10 ~ air ""0 lJ'oundwaler
10 remove VOCs by air s~
Downgradl8nt trerlChel bactc!ll8d with acllvlled
clfbon to remove oont."...,.s fn)m ..II.
SVilem 0' ~11on well 10 Int8ct oJlJdller luch
a. hydrogen peroJdde to ~ DonIan*'-"I.
Elltrlcled wal. cIIaoharQ8d 10 local IIream on
the lit.
Extraoled wal. dI8charged to local POTW
EXlracled waler clacharged 10 deep w8I
"'j8011on IV-Iern

Ellirlcled ..ller elscharged 10 r1ver
011 .Ue
Screening Conmena.
Polenllally ippIo8b18
Potentlalv 8PPIc8b18
AqUter IiIWJ depth 0' Conlllr8\8Uo
too dHp 'or IrwIoh8t
Potentially sppIo8b18
Not ,....... DonI....,.,.
oonoenIndonI too low

Nol ,...... contamNnl
oonoentratIona 100 low
Nol ,..... - 10 type and
oono8f1Iratlon of 00I'It1RlNnl'
PotenUaly tppIotble
PotenUaly sppIo8b18
Nol ,...... coni....,.,.
ooncentratlona too low
PotenUaly ,,-8b18
PolenUaly ~
Potmialy tppIto8b18
Potentl8llv 8PPIcable
PotenU8lly 8A*abIe
Not ,...... oont"""
oonoenlradonl 100 low
POlentllly appIoable
AqUter and contart*\allon 100
deep 'or trench8ll0 Intercept
Polanllaly appIoable
POlentlllly apple'"
POlentlaly appIoab68
POlentlally appIo8b18
POlentlaly appIcab18
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options are evaluated on the basis of their effectiveness and
their ability to be implemented considering Site-specific
conditions. Only those measures that could conceivably meet the
remedial action objectives, or the majority of them, were further
developed into remedial alternatives. Remedial action
alternatives are further limited to proven and/or innovative
technologies and process options that have been used successfully
at other sites.
Description of Alternatives
Based upon the screening and evaluation of potentially applicable
remedial technologies and management or process options and the
requirement within the NCP (see 40 C.F.R. Section 300.430(e) (6))
to evaluate a "No Action" Alternative and/or a "No Further
Action" Alternative, the following remedial action alternatives
have been selected for further development and detailed
evaluation:
1. No Action
2. Ground Water Extraction, Treatment, and Discharge
a. Treatment by Air Stripping, Discharge to Recharge Wells
b. Treatment by Carbon Adsorption, Discharge to Recharge Wells
c. Treatment by Air Stripping, Discharge to Surface Water
d. Treatment by Carbon Adsorption, Discharge to Surface Water
The FS, which was prepared by JACA Corporation on behalf of the
PRPs, developed alternatives that combine treatment of ground
water with provision of clean drinking water to residents. In
the ROD for OUl, EPA has already evaluated alternatives to
provide drinking water to residents. Those drinking water
portions of the alternatives will not be discussed again here.
Only those alternatives in the FS that are applicable to OU2 will
be detailed in this ROD. Thus, the alternatives detailed below
are not identical to the alternatives identified in the FS, but
they include the same technologies and process options as
evaluated in the FS. Each alternative considered for OU2 is
detailed below. Alternatives 2a through 2d are similar, but rely
upon different combinations of technologies and process options.
ALTERNATIVE 1
NO ACTION
capital Cost
Annual O&M
N/A
: $14,000
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Present Worth
Implementation
:$423JOOO
N/A
The NCP requires that EPA consider a "No Action" Alternative fOi:"
each site (40 C.F.R. Section 300.430(e) (6)). This alternative
provides only for sampling and periodic reviews to monitor the
movement of the plume of contaminated ground water. This
alternative Qoes not provide for ground water remediation nor
does it reduce the further spread of contamination from the Site.
The future risks posed by the Site would not be reduced, except
by natural processes, and the remedial objectives would not be
met. This alternative serves only as a baseline against which
the other alternatives should be compared.
According to the risk assessment, the excess cancer risk to
potential future ground water users is in the range of 10.3 which
means that between 1,000 and 9,999 people out of 1,000,000 people
drinking contaminated water, at exposure levels discussed above,
could contract cancer. Thus, neither the "No Action" Alternative
nor the "No Further Action" Alternative provide acceptable
protection from cancer risks posed by the Site.
ALTERNATIVE 2 - GROUND WATER EXTRACTION, TREATMENT, AND DISCHARGE
Under this general alternative, two treatment technologies and
two process (discharge) options are considered. The treatment
technologies are air stripping and carbon adsorption. The
discharge options are discharge to surface water or reinjection
into the aquifer through recharge wells. The various
technologies and options are developed into four separate
alternatives. The four alternatives are:
Alternative 2a - Treatment by Air stripping, Discharge to
Aquifer Recharge Wells
Alternative 2b - Treatment by Carbon Adsorption, Discharge to
Aquifer Recharge Wells
Alternative 2c - Treatment by Air Stripping, Discharge to
Surface Water
Alternative 2d - Treatment by Carbon Adsorption, Discharge to
Surface Water -
Alternatives 2a through 2d have many common components. The
common components are 1) Ground Water Remedial Design Study; 2)
Ground Water Extraction; and; 3) Periodic Monitoring. These
common components will be discussed before individual
alternatives are described.
3-:-
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Ground Water Remedial Design studv
A Ground Water Remedial Design study must be completed before a
ground water remedy can be fully designed. Until EPA has more
information on the depth of the contaminants throughout the pluMe
area and the aquifer characteristics throughout the plume area,
it is difficult to determine the construction specifics of ground
water extraction wells and ~he numbe'r of extraction wells needed
to meet the remedial object~ves and clean up goals. In addition,
the existence of TCE in ground water upgradient to the CryoChe~,
Inc. plant and its potential effects upon the response action in
this ROD, should be evaluated. Therefore, a Ground Water
Remedial Design study would be the first component of each of the
remedial alternatives under consideration. In order to develop
costs to adequately compare alternatives, the FS assumed the need
for thirteen (13), 300-foot deep extraction wells. Each
alternative also includes two (2) 5,000 gallon storage tanks and
nearly 5,000 ~eet of collection piping which would deliver water
to two (2) centrally located treatment plants.
Ground Water Extraction
Alternatives 2a through 2d each involve pumping contaminated
ground water from beneath the CryoChem, Inc. plant and from the
downgradient area of the plume to prevent further migration of
the plume from beneath the CryoChem, Inc. plant and into
currently unaffected areas. The plume of contamination currently
extends from the Site to several springs near the Trout Farm.
The plume is approximately 2500 feet long and 600 feet wide and
includes up to 1.5 billion gallons of water (assuming a uniform
depth of contamination of 300 feet). Since the aquifer is a
Class IIA aquifer, which means that the aquifer is currently a
drinking water aquifer, EPA's cleanup goals would include
restoration of the aquifer to its beneficial use, if practicable.
Each alternative would rely in whole or in part upon natural
recharge of clean water (precipitation and upgradient ground
water) into the area of attainment, i.e., the plume or the area
in which the cleanup goals would be met. Since an apparent
source of TCE was identified upgradient to the Site during the
RI, the cleanup goal for TCE may not be achieved until the
upgradient source is addressed. The upgradient source of TCE
will be evaluated further during the Ground Water Remedial Design
Study.
It may not be practical, or possible, to precisely define the
area of attainment or the area of ground water above MCLs or
background without first making some assumptions, such as minimal
lateral dispersion of the plume. An extraordinary number of
monitoring wells would need to be installed to precisely define
the plume. Therefore, although the plume is not precisely
defined in the RI report, EPA would ensure that the ground wate~
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i-

I
i
,
,
remedy to be designed would include provisions to address the
edges of the plume, e.g., capture zones that extend slightly
beyond the assumed edge of the plume.

Extraction wells would not be placed immediately upgradient to
several springs in the vicinity of the Trout Farm since the Trout
Farm relies upon spring water for ra~sing fish. EPA anticipates
that high rates of ground water pumping close to the springs
could substantially reduce spring flow rates. Similarly,
extraction wells would not be placed within the residential area
since it is plausible that certain residential wells would stil:
be used for restricted uses. In addition, extraction wells that
must be located near the new water supply constructed pursuant to
OU1 would be operated in such a manner that the yield of the new
water supply well would not be diminished... EPA believes that
avoiding these two identified areas would not significantly
impact the ground water cleanup. However, a small area of
contaminated ground water located between proposed extraction
wells and the Trout Farm springs would continue to migrate to the
springs and discharge to surface water for an unknown length of
time until flushed via natural processes. The existing
contaminant levels in this area are not well defined, but appear
to be within drinking water standards, i.e., MCLs, and therefore
could be considered by EPA to be beyond the area of attainment.
Alternatively, the extraction wells could be placed at the
downgradient edge of the plume. This placement could decrease
the flow of springs in the vicinity of the Trout Farm.
Additional water needed by the Trout Farm could be delivered
following treatment to required levels, e.g., federal ambient
water quality criteria under the Clean Water Act. This option
would necessitate coordination with the owner and operator of the
Trout Farm.
The pumping and treating of ground water would continue until the
cleanup goals are achieved, if practicable. Once cleanup goals
are achieved, the risk posed by the ground water would be reduced
from the 10-3 excess cancer risk range to the 1x10-6 excess cancer
risk level, at minimum.
Periodic Monitorinq
Samples of treated ground water would be collected periodically,
e.g., monthly or quarterly, to ensure that the treatment
technologies employed are reducing contaminant levels to required
standards. Samples would also be collected from select
monitoring locations to ensure that the remediation is
progressing towards the cleanup goals.

Each alternative developed under general Alternative 2 is further
detailed below.
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ALTERNATIVE 2a
GROUND WATER EXTRACTION, TREATMENT BY AIR STRIPPING, AND
DISCHARGE TO AQUIFER RECHARGE WELLS
Capital ~ost : $2,003,000
Annual O&M Cost: $97,000
Present Worth: $2,923,000
Implementation: 10-16 months
The general components of Alternative 2a are:
1. Completion of a Ground Water Remedial Design Study to
determine the design specifications and performance criteria of
the remediation system,
2. Installation, operation, and maintenance of ground water
extraction wells to remove contaminated ground water,
3. Installation, operation, and maintenance of air stripping
towers to treat ground water,
4. Installation, operation, and maintenance of aquifer recharge
wells to inject treated ground water back into the aquifer, and
5. Periodic monitoring to ensure that the remediation is
progressing towards the cleanup goals and that treated ground
water meets required standards.
In addition to the Ground Water Remedial Design Study, ground
water extraction components, and periodic monitoring described
above, Alternative 2a employs air stripping towers to treat
contaminated ground water to required standards and recharge
wells to inject treated ground water back into the aquifer. An
air stripping tower is an effective technology that reduces the
levels of contaminant in water. contaminated ground water is
pumped to the top of an air stripping tower and discharged into a
column of plastic spheres with large surface areas. At the same
time, air is forced up through the contaminated ground water in
the tower. Since the contaminants are VOCs, which tend to leave
water and move into air, the air stripping tower efficiently
removes contaminants from the water. The air stream leaving the
top of the air stripping tower contains the contaminants which
are then vented into the atmosphere.

Preliminary calculations suggest that the total VOC emissions
from the air stripping towers would be well below federal and
state standards, e.g., National Ambient Air Quality standards
(NAAQS) (40 C.F.R. Part 50) promulgated pursuant to the Clean Air
Act, which are translated into source specific emission
limitations by the Commonwealth of Pennsylvania.
~
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':- -
An emission rate, more stringent than the NAAQS, to be considered
is EPA's policy of installing air controls on treatment units
that emit more than 3 lbs./hour or 15 lbs./day of total VOCs in
ozone non-attainment areas. An ozone non-attainment area is an
area in which the NAAQS for ozone is not met. The CryoChem Site
is in an'ozone non-attainment area. EPA's policy was developed
since .most VOCs treated at Superfund sites are precursors to the
formation of ground level ozone. However, current calculations
of air emissions from the air stripping towers suggest that total
emission rates would be approximately 1 lb/day, thus air controls
would not be required. A vapor phase, carbon adsorption unit.
could be installed, if needed, to treat emissions from the air
stripping tower.
The Commonwealth. of Pennsylvania requires'a "Request for
Determination of Requirement for Plan Approval/Operating Permit
Application" be submitted for approval before a new air stripping
unit is operated as part of this alternative. PADER would then
determine from the information provided whether a plan approval
or the substantive requirements of a permit action are, and if
so, what emission limits will be established.
The actual flow rate and VOC loading rate, i.e., the amount of
VOCs entering the air stripper per unit time, for this Site would
not be known until the Ground Water Remedial Design Study is
completed and the extraction system is operational. Afterwards,
the air stripping towers would be tested to ensure that they
perform satisfactorily. The testing would include periodic
sampling to ensure that the treatment units satisfactorily reduce
VOC levels in treated ground water to required levels, e.g., MCLs
identified in the Safe Drinking Water Act. Additionally, the
emissions from the air stripping tower would be tested to ensure
that maximum VOC emission rates do not exceed 3 lbs./hour or 15
lbs/day or the amount to be determined by PADER.
The ground levels of VOCs emitted from the air stripping towers
would be modelled to determine the concentrations that would be
expected in proximity to the air stripping tower. This
information is used by PADER to evaluate the air stripper
operation plan. PADER may determine that the air emissions must
be controlled using the best available technology unless the air
strippers are exempted pursuant to 25 PA Code Section 127 et ~

Treated ground water would then be injected into the aquifer
through several recharge wells. A recharge well injects water
back into the aquifer under pressure. The water would be
injected outside the boundaries of the plume to elevate the water
table and prevent the plume from expanding. Because the recharge
wells would increase hydraulic gradients, they could also
decrease the remediation time frame by causing contaminants to
move towards the extraction wells more quickly. The FS estimates
-. .
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that 7 recharge wells ,would be needed. Since Alternative 2a
utilizes injection wells, the substantive requirements of an
underground injection well permit would be met.
The estimated capital cost, operation and maintenance cost, and
net present worth cost for Alternative 2a are depicted in Table
18. In addition, EPA anticipates the implementation timeframe
for Alternative 2a to be between ten and sixteen months.
ALTERNATIVE 2b
GROUND WATER EXTRACTION, TREATMENT BY CARBON ADSORPTION, AND
DISCHARGE TO AQUIFER RECHARGE WELLS
Capital Cost: $2,152,000
Annual O&M Cost: $167,700
Present Worth: $3,086,000
Implementation: 10-16 months
The general components of Alternative 2b are:
1. Completion of a Ground Water Remedial Design Study to
determine the design specifications and performance criteria of
the remediation system,
2. Installation, operation, and maintenance of ground water
extraction wells to remove contaminated ground water,
3. Installation, operation, and maintenance of carbon adsorption
units to treat ground water,
4. Installation, operation, and maintenance of aquifer recharge
wells to inject treated ground water back into the aquifer, and
5. Periodic monitoring to ensure that the remediation is
progressing towards the cleanup goals and that treated ground
water meets required standards.
In addition to the Ground Water Remedial Design study, ground
water extraction components, and periodic monitoring described
above, Alternative 2b employs carbon adsorption units to treat
contaminated ground water and rel1es upon recharge wells to
inject treated ground water back into the aquifer. Alternative
2b is similar to Alternative 2a except carbon adsorption units
would be used to treat ground water.
A carbon adsorption unit is a pressurized vessel filled with
activated carbon. The units are similar to the carbon units
currently installed at affected homes, only larger, in order to
. .
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Table 18

ESTIMATED COSTS FOR ALTERNATIVE 2a
REMEDIATE GROUNDWATER BY EXTRACTION WELLS. AIR STRIPPING
DISCHARGE TO RECHARGE WELLS,GROUNDWATER MONITORING
Direct Costs
Extraction wells. 13, 8 inch x 300 feet
Recharge wells, 7, 8 inch x 100 feet
Extraction wett pumps, 13 at $5,000
Air strippers, 2 at $31,SOO each
Storage tanks, 2, 5000 gal. tanks at
$20.000 each
Recharge pumps and spares, 4 at $3,750 each
Collection piping - 4 inch PVC installed in trench,
4,880 feet at S55/foot
4, 50 foot road crossings at S200/foot
Recharge piping - 4 inch PVC ins tat led in trench,
4,400 feet at $55/foot
2, 50 foot road crossings at S200/foot

Subtotal
Electrical at lS~ of S.T.
Instrumentation at 14~ of S.T.
Total Direct
Indirect Costs
Engineering and supervision at JO~ of Direct

Subtotal
Contractor's fee at 51 of S.T.
Contingency at 251 Of S.T.
Total Capital Investment
Annual O&M Costs
Electric power, 34.8 kw x 8.000 hrs. x $0.07/kwh
Sampling for groundwater monitoring.
23 nours/qtr at $45/hr
Sample InI1ys.s, 40 . $250 .ach
Operation and mechanical maintenance.
S hours/day. 3 days/week at $45/hr
Maintenance materia1s at 11 of the tota1
capital investment
Tota1 O&M
Present worth at 10' discount
Years
--w-
30
40
50
-----
----
Thousand
Dollars
120.9
3S.0
65.0
63.2
40.0
15.0
268.4
40.0
242.0
20.0
911.0
146.0
128.0
1,185.0
356.0
1.541.0
77.0
385.0
2.003.0
21.5
4.1
10.0
42.0
20.0
97.6
2,834.0
2,923.0
2,957.0
2,S71.0
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handle increased flow. As contaminated ground water passes
through the carbon unit, the contaminants adsorb onto the
surfaces of the carbon. If contaminated ground water passes
through sufficient carbon surface area, contaminants are
completely removed from the discharged ground water.
There are no air emissions that would require air controls, but
the carbon has limited adsorptive capacity and must be replaced.
When the carbon is saturated with contaminants or spent, i.e.,
contaminants have adsorbed onto all available surface area,
additional contaminants are not removed from ground water which
continues to pass through. The spent carbon must be removed,
regenerated, and replaced. During the regeneration process, the
carbon vendor typically heats the carbon to drive off the
contaminants and then collects the contaminants. The
contaminants could then be completely destroyed or otherwise
reused. The spent carbon could not be disposed of in a landfill
since it would most likely fail the Toxicity Characteristic
Leaching Procedure (TCLP) and would therefore be restricted under
the RCRA Land Disposal Restrictions. The TCLP is a test during
which a media, e.g., spent carbon, is subjected to standardized
tests during which the amount of contaminants which could leach
from the tested media is determined. EPA believes that the
amount of VOCs leached from the spent carbon would be high enough
to trigger the Land Disposal Restrictions under RCRA, meaning
that a non-land based disposal method would be required (such as
incineration). Thus, the spent carbon likely would be
regenerated by the carbon vendor, an entity which would possess a
RCRA permit allowing the vendor to regenerate the carbon, contain
the VOCs, and provide for their ultimate destruction. For
example, the contaminants removed from the spent carbon could be
incinerated.
The estimated capital cost, operation and maintenance cost, and
net present worth cost for Alternative 2b are depicted in Table
19. In addition, EPA estimates the implementation timeframe for
Alternative 2b to be between ten and sixteen months.
.. -,
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-:ABL~ 19

ESTIKATED COSTS FC~ A~TERNATIVE 2b
REMEDIATE GROUNDWATER BY EXTRACTION WELLS, CARuON ADSORPTION
DISCHARGE TO RECHARGE WELLS
I
I .
Direct Costs
Extraction wells, 13, 8 inch x 300 feet
Recharge wells, 7, 8 inch x 100 feet
Extraction well pumps, 13 at $5,000 each
Carbon adsorbers, 2 at $66,000 each
Storage tanks 2, 5,000 gal. tanks at $20,000 ea.
Transfer pumps and spares 4 at $3,750 ea.
Collection piping - 4 inch PVC installed in trench,
4,880 feet at $55/foot
4, 50 foot road crossings at $200/foot
Recharge piping, 4 inch PVC installed in trench,.
4,400 feet at $55" foot
2, 50 foot road crossing at $200/foot

Subtotal
Thousand
Dollars
120.9
36.0 "
65.0
132.0
40.0
15.0

268.4
40.0
242.0
20.0
979.0
Electrical at 16% of S.T.
Instrumentation at 14% of S.T.
Indirect Costs
Engineering and supervision at 30% of Direct

Subtotal
Total Direct
157.0
137.0
1,273.0
382.0
1,655.0
Contractor's fee at 5% of S.T.
Contingency at 25% of S.T.
83.0
414.0
Total Capital Investment
2,152.0
Annual O&M Costs
Electric power, 34.8 kv x 8,000 hrs. x $0.07/kwh
Sampling for groundwater monitoring,
23 hours/qtr at $45/hr
Sample analyses, 40 . $250 each
Operation and mechanical maintenance
6 hours/day, 3 days/wlek at $45/hr.
Maintenance materials at 11 of the total
capital investment
Carbon replacement'
21.5
4.1
10.0
42.0
21.5
68.6
-
Total O&M
167.7
Present worth at 10% discount
Years
20
30
40
50
2,996.0
3,086.0
3,121.0
3,135.0
aE!t1mated by v!ndor to require 0.5 pounds carbon per 1,000 gallons at $1.10
pound carbon
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ALTERNATIVE 2c
GROUND WATER EXTRACTION, TREATMENT BY AIR STRIPPING, AND
DISCHARGE TO SURFACE WATER
Capital Cost: $1,356,000
Annual O&M Cost:. $75,200
Present Worth: $2,065,000
Implementation: 10-16 months
The general components of Alternative 2c are:
1. Completion of a Ground Water Remedial Design Study to
determine the design specifications and performance criteria of
the remediation system,
2. Installation, operation, and maintenance of ground water
extraction wells to remove contaminated ground water,
J. Installation, operation, and maintenance of air stripping
towers to treat ground water,
4. Installation and maintenance of a discharge pipe to local
surface water, and
5. Periodic monitoring to ensure that the remediation is
progressing towards the cleanup goals and that treated ground
water meets required standards.
In addition to the Ground Water Remedial Design Study, ground
water extraction components, and periodic monitoring described
above, Alternative 2c employs air stripping towers to treat
contaminated ground water and relies upon a pipeline to the
nearby stream to discharge treated water. The treatment
component, air stripping towers, of Alternative 2c is similar to
that of Alternative 2a and has been discussed above.
A pipeline would be constructed from the air stripping towers to
the nearby stream. The pipeline would be sized to accommodate
the maximum flow from the treatment units. The construction of
the pipeline would consider the location of any identified
wetlands or other sensitive habitats. The location of any seeps
of contaminated ground water alo~ the stream would also be
considered as candidate locations for the treated ground water
discharge. Prior to full operation of the treatment units,
appropriate testing of the treated water would be completed to
ensure that no impacts to sensitive downstream environments would
result from the discharge of treated water into the stream.
The amount of contaminants discharged from the treatment unit
into the stream would comply with the substantive requirements of
~.
-------
 a National  Pollutant  Discharge Elimination System  (NPDES) permit.
 The NPDES requirements  would establish discharge limits which are
 protective  of the  receiving stream.  The discharge limits
 consider the  designated uses of the receiving stream, i.e.,
 Ironstone Creek.   Substantive requirements of NPDES would includ.e
 Water  Quality Criteria  and Standards established by EPA and the
 Commonwealth  of  Pennsylvania under Sections 303 and 304 of the
 Clean  Water Act, 33 U.S.C. Sections 1313 and 1314.  Since the
 discharge would  be located in an "on-Site" area, i.e., into an
 area of the stream which is considered part of the site, the
 administrative requirements of the permitting process and an
 actual NPDES  permit would not be needed.

 The estimated capital cost, operation and maintenance cost, and
 net present worth  cost  for Alternative 2c are depicted in Table
 20.  In addition,  EPA estimates the implementation timeframe for
 Alternative 2c to  be between ten and sixteen months.
ALTERNATIVE 2d
GROUND WATER EXTRACTION, TREATMENT BY CARBON ADSORPTION, AND
DISCHARGE TO SURFACE WATER

Capital Cost     : $1,507,000
Annual O&M Cost  :   $145,300
Present Worth    : $2,877,000
Implementation   : 10-16 months


The general components of Alternative 2d are:

1. Completion of a Ground Water Remedial Design Study to
determine the design specifications and performance criteria  of
the remediation system,

2. Installation, operation, and maintenance of ground water
extraction wells to remove contaminated ground water,

3. Installation, operation, and maintenance of carbon adsorption
units to treat ground water,

4. Installation and maintenance of a discharge pipe to  local
surface water, and

5. Periodic monitoring to ensure that the  remediation is
progressing towards the cleanup goals and  that treated  ground
water meets required standards.
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TABLE 20
ESTIMATED COSTS FOR ALTERNATIVE 2c
REMEDIATE GROUNDWATER BY EXTRACTION WELLS, AIR STRIPPING
DISCHARGE TO ON-SITE CREEK,GROUNDWATER MONITORING
Direct Costs
Extraction wells, 13, 8 inch x 300 feet
Extraction well pumps, 13 at 5000
Air str1ppers, 2 at $31,600 each
Storage tanks. 2. 5000 gal. tanks at
20,000 each
Transfer pumps and spaces 4 at $1.700 ea.
Collection piping - 4 inch PVC installed in trench,
4880 f'eet at $55/foot
4, 50 foot road crossings at S200/foot
Discharge p1pfng to on-site creek
4 1nch PVC 1nstalled 1n trench, 230 feet at $55/foot

Subtotal
Electrical at 161 of S.T.
Instrumentation at 141 of S.T.
Total Direct
Indirect Costs
Engineering and superv1s10n at 301 of D1rect

Subtotal
Contractor's fee at 51 of S.T.
Contingency at 251 of S.T.
Total Cap1tal Investment
Annual O&M Costs
Electric power. 34.8 kw x 8.000 hrs. x $0.07/kwh
Samp11ng for groundwater mon1tor1ng
23 hours/Qtr at $45/hr
Sample analysIs. 40 . $250 each
Operation and mechanica' ma1ntenance
4 hours/day. 3 days/wlek at $4S/hr.
Ma1ntenance ..ter1als at l' of the tota'
cap1ta' investment
Present worth at 101 d1scount
Tota' OlM
Years
20
30
40
50
Thousand
Dollars
120.9
65.0
63.2

40.0
6.8
268.4
40.0
12.7
617.0
99.0
86.0
802.0
241.0
1,043.0
52.0
261.0
1.356.0
19.5
4.1
10.0
28.0
13.6
75.2
1.996.0
2.065.0
2.091.0
2.102.0
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In addition to the Ground Water Remedial Design Study, ground
water extraction components, and periodic monitoring described
above, Alternative 2d employs carbon adsorption units to treat
contaminated ground water and a pipeline to discharge treated
ground water into the nearby stream. The treatment component of
Alternative 2d, carbon adsorption units, is similar to that of
Alternative 2b and has been discussed above. The discharge
component of Alternative :d, surface 'water discharge, is similar
to that of Alternative 2c and has been discussed above.
The estimated capital cost, operation and maintenance cost, and.
net present worth cost for Alternative 2d are depicted in Table
21. In addition, EPA estimates the implementation timeframe for
Alternative 2d to be between ten and sixteen months.
x.
Summary of. the Comparative Analysis of Alternatives
Each of the remedial alternatives for OU2 was compared and
evaluated against nine criteria to determine which remedial
alternative and combination of technologies and process options
would best meet the remedial objectives of this response action.
The evaluation of remedial alternatives against the nine criteria
is required by the NCP, see 40 C.F.R. Section 300.430(e) (9) (iii).
The nine criteria, grouped by classification, are:
THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment: whether
each alternative provides adequate protection of human health and
the environment and describes how risks posed through each
exposure pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
Compliance with ARARs: whether each alternative will meet all of
the Applicable or Relevant and Appropriate Requirements (ARARs)
of Federal and State environmental laws and/or justifies invoking
a waiver: whether a remedy complies with advisories, criteria and
guidance that EPA and PADER have agreed to follow.
PRIMARY BALANCING CRITERIA
Lonq-term Effectiveness and Permanence: the ability of each
alternative to maintain reliable protection of human health and
the environment over time, once clean-up goals have been met.
Reduction of Toxicity, Mobility, or Volume throuqh Treatment:
addresses the statutory preference for selecting remedial actions
that employ treatment technologies that permanently and
significantly reduce the toxicity, mobility or volume of
hazardous substances.
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TABLe: Zl
ESTIMATED COSTS FOR ALTERNATIVE 2d
REMEDIATE GROUNDWATER BY EXTRACTION WELLS, CARBON ADSORPTION
DISCHARGE TO ON SITE CREEK
Direct Costs
Extraction wells, 13, 8 inch x 300 feet
Extraction well pumps, 13 at $5,000 ea.
Carbon adsorbers, 2 at $66.0 ea.
Storage tanKs 2, 5,000 gal. tanks at $20,000 ea.
Transfer pumps and spares, 4 at $1,700 ea.
Collection piping - 4 inch PVC installed in trench.
4,880 feet at $55/foot
4, 50 foot road crossings at $200/foot
Discharge piping to on-site creek.
4 inch PVC installed in trench, 23P feet at
$55/foot
Thousand
Do 11ars
120.9
65.0
132.0
40.0
6.8

268.4
40.0
Subtotal
12.7
686.0
Total Direct
110.0
96.0
892.0
Electrical at 16~ of S.T.
Instrumentation at 14' of S.T.
Indirect Costs
Engineering and supervision at 30' of Direct
267.0
....
Subtotal
1,159.0
Total Capital Investment
58.0
290.0
1,507.0
Contractor's fee at 5' of S.T.
Contingency at 25' of S.T.
Annual 0&1-4 Costs
Electric power, 34.8 kw x 8,000 hrs. x $0.07/kwh
Sampling for groundwater monitoring,
23 hours/Qtr at $45/hr
Sample analyses, 40 at $250 each
Operation and mechanical maintenance
4 hours/day, 3 days/week at $45/hr.
Maintenance materials at 11 of the total
capital investment
Carbon rep1acementa
19.5
4.1
10.0
28.0
15.1
68.6
Tota'- O&M
145.3
Present worth at 10' discount
Years
20
30
40
50
2,744.0
2,877.0
2,928.0
2,948.0
aEst1mated by vendor to require 0.5 pounds carbon per 1,000 9allons at $1.10
pound carbon
.260 qal/min _x 8,000 hrs. x 60 min./hr.
v n ~ v ., ,nf.r- ~~A.~4n/v.a~
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Short-term Effectiveness: the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period, until clean-up goals are achieved.
Implementabilitv: the technical and administrative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular option.
Cost: estimated capital, operation and maintenance (O&M), and net
present worth costs.
MODIFYING CRITERIA
State/Support Aqencv Acceptance: whether the State concurs with,
opposes, or has no comment regarding the preferred alternative.
Community Acceptance: the pUblic's general response to the
alternatives.
The following section compares each of the remedial alternatives
developed in this ROD against each of the nine evaluation
criteria.
A. Overall Protection of Human Health and the Environment
Alternatives 2b and 2d provide the most protection of human
health and the environment from current and future risks posed by
the Site. The response action for OUl addressed the most
significant current risk posed by the site (ingestion of
contaminated ground water), but did not address the potential
future exposure to contaminated ground water via ingestion and
inhalation. Alternatives 2b and 2d provide protection from any
potential risk that might result from air emissions from the
treatment units since Alternatives 2b and 2d employ carbon
adsorption units that do not generate air emissions. Since
Alternative 2b relies upon aquifer recharge wells which could
result in migration of contaminants outside the capture zones of
the extraction wells, resulting in potential unknown future risk,
Alternative 2d provides the most protection because the treated
water would be discharged at a known location at regulated
levels.
The air stripping tower emissions that would result from
implementation of Alternatives 2a and 2c are not expected to
result in unacceptable risk to public health. The contaminants
would be vented into the atmosphere. The expected contaminant
emission levels would be well below standards under the Clean Ai~
-
-------
Act and would also be below EPA's more stringent levels to be
considered under EPA's air emission control policy (which
considers reductions in ground level ozone). The emissions still
present a small risk which makes carbon adsorption units (the
treatment components under Alternatives 2b and 2d) more
protective.
Alternatives which employ air stripping towers can be as
protective as alternatives employing carbon adsorption units if
vapor phase carbon adsorption units are installed on the air
stripping towers to treat emissions. PADER would first review
the operation plan for the air stripping towers and determine if
air controls are needed. The air stripping towers may be
exempted by PADE~ from the need for air controls pursuant to 25
PA Code Section 127 et ~
Alternatives 2a through 2d provide protection of human health
from potential future risks posed by contaminated ground water at
the Site. Alternative 1, the No Action Alternative, does not
provide protection of human health or the environment since
contaminants would remain in the ground water above health-based
levels. Therefore, Alternative 1 will no longer be considered.
Alternatives 2a through 2d each protect the environment. Ground
water pumping would serve to lower the water table and reduce or
prevent the discharge of contaminated ground water into the
nearby streams. In addition, remedial alternatives employing
surface water discharges would first treat the contaminated
ground water to levels protective of the receiving stream
pursuant to the NPDES permit requirements.
B. Compliance with ARARs
Table 22 identifies ARARs for the alternatives developed in this
ROD.
Under Section 121(d) of CERCLA, 42 U.S.C. Section 962l(d), and
EPA guidance, remedial actions at CERCLA sites must attain
legally applicable or relevant and appropriate Federal and State
environmental standards, requirements, criteria, and limitations.
Applicable requirements are those substantive environmental
protection requirements, criteria, or limitations promulgated
under Federal or State law that specifically address hazardous
substances found at a site, the remedial action to be
implemented, the location of a site, or other special
circumstances. Relevant and appropriate requirements are those
substantive environmental protection requirements, criteria, or
limitations promulgated under Federal or State law which, while
not a~plicable to the hazardous substances at a site, the
remedial action, site location, or other circumstances,
nevertheless address problems or situations sufficiently sirnila~
~
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TABLE
22
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
and TO-BE-CONSIDERED (TBC) REQUIREMENTS
---- --
-- "-
CHEMICAL SPECIFIC
--,.- - - -
--- - - - ~ .
--------.
'- - - - .
'__-.__0.
---
Safe Oinking Water Act (42 U.S.C. Section 300(f»
Maximum Contaminant Levels (MCLs)
(40 C.F.R. Section 141.11-141.16)
TCA
TCE
DCE
.200 mg/l
.005 mg/l
.007 mg/l
For water that is to be used
for drinking, the MCLs are
relevant and appropriate
standards. The a~uifer should
be cleaned to these levels, if
practicable, in order to return
to beneficial use.
Proposed Maximum Contaminant Levels (PMCLs)
PCE
.005 mg/l
For water that is to be used
for drinking and an MCL is not.
yet established, a PMCL may be
relevant and appropriate.
Clean Water Act (33 U.S.C. Section 1251)
Federal Water ~uality Criteria (FWQC)
(Qu~~i~y Crite~~a for W~~~~, 1986,
51 Fed. Reg. 43665)
protection of human health
Water and Fish
Ingestion
Fish Consumption
Federal standards which must be
met in the stream adjacent to
the CryoChem Site. These
standards are relevant and
appropriate since edible fish
are raised in the stream and
the stream may be used for
recreational purposes.
DCE
PCE
TCA
TCE
- .000033
- .0008
18
- .0027
mg/l
mg/1
mg/1
mg/l
.0019
.0089
1000
.0081
mg/l
mg/1
mg/1
mg/l
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l\~an i~. C~~I!!~~~ l-~~~iX~~ _~~ARs

Clean Streams Law
(25 PA Code Section 93.1 et ~)
Penl
Water Quality Standards
State standards for the quality
of Pennsylvania's surface water
ACTION SPECIFIC
Clean Air Act (Part D)
(42 U.S.C. Sections 7401-7642)
National Ambient Air Quality Standards (NAAQS)
(40 C.F.R. Part 50)
The NAAQS for ozone should not
be exceeded more than 1 time per
year. VOCs are precursors to
the development of ground-level
ozone. Pertains to use of air
strippers.
Ozone - 0.12 ppm (1 hour)
Resource Conservabion and Recovery Act
(42 U.S.C. Section 6901 e! ~~~)
Land Disposal Restrictions
(40 C.F.R. 268.1-268.50)
Requires use of specific technolo~y to
treat specific hazardous wastes. Spent
carbon from carbon adsorption units is
most likely a characteristic RCRA waste.
General handling, transportation
of hazardous waste
(40 CFR Parts 262, 263)
Transportation and handling of charac-
teristic hazardous wastes to comply with
all requirements of RCRA. The spent
carbon from the carbon adsorption units
would most likely be a charcteristic RCRA
hazardous waste.
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Underground Injection Control Regulations
(40 C.F.R. Parts 144, 145, 146, 147)
Provides regulations governing injection
of treated water back into the a~uifer
(Class IV well). Injected water could
not exceed drinking water standards.
Pennsylvan~a Action-Specific ARARs
25 PA Code Sections 127.1 et ~
Requires that ait emissions from new
sources, such as air stripping towers,
be controlled with best available
technology. In addition approval is
required for any air stripping/soiL
venting plan.
25 PA Code Sections 92.1 et ~
Sets forth provisions for the NPD~S
program administration within Penna.
PADER would set discharge limitations
based upon the designated uses of the
receiving stream and Site-specific
parameters related to the design of the
proposed treatment system.
25 PA Code Section 264.90-264.100
Requires that all ground water must
be remediated to background quality.
REQUIREME~TS TO-BE-CQ~SIDERED
EPA OSWER Directive 9355.0-28
Air Stripper Control Policy
Suggests that total VOC releases from
air strippers should not exceed 3 lbs/hr.
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to those encountered at a site that their use is well suited to
that site.
Alternatives 2a through 2d would comply with all ARARs related to
ground water.
The Commonwealth of Pennsylvania's ARAR for ground water is that
all ground water must be remediated to "background" quality as
specified by 25 PA Code Sections 264.90 through 264.100. The
Commonwealth of Pennsylvania also maintains that the requirement
to remediate to background is also found in other legal .
authorities.
The ground water cleanup goal for the Site would be to restore
the aquifer to its beneficial use asa drinking water aquifer. In
order to restore the aquifer to its beneficial use, the
remediation system implemented in each of the alternatives would
operate until Site-specific remediation goals are achieved. Thus
the aquifer would be remediated until the contaminate levels
reach the MCLs, Non-zero MCLGs, or background, whichever are
lower.
If implementation of the selected remedy demostrates, in
corroboration with hydrogeological and chemical evidence that it
will be technically impracticable to achieve and maintain the
remediation goals throughout the area of attainment, the USEPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals.
Alternatives 2a and 2c, which employ air strippers, would not
exceed National Ambient Air Quality Standards (NAAQS) established
under the Clean Air Act, codified at 40 C.F.R. Part 50, and
regulated by the Commonwealth of Pennsylvania. However, EPA has
established a more stringent policy to be considered in Superfund
cleanups that occur in ozone non-attainment areas. The most
stringent emission rate from all sources employed in a Superfund
cleanup would be 3 lbs./hour or 15 Ibs./day of total VOCs (Office
of Solid Waste and Emergency Response, OSWER, Directive 9355.0-
28). Current calculations suggest that total emissions from the
air strippers would not exceed 1 Ib./day.
PADER requires that a "Request for Determination of Requirement
for Plan Approval/Operating Permi~ Application" form be submitted
before a new air stripping tower is operated. An operation plan
must be submitted and reviewed by the Department in accordance
with 25 PA Code Section 127.11. PADER typically requires that
operators of new sources of air contamination control emissions
utilizing the best available technology in accordance with 25 PA
Code Section 127.1, unless otherwise exempted. Before air
strippers are operated at the Site, an operation plan will be
submitted to PADER. Should air controls be required, as
- '"
J
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determined by PADER upon review of the information submitted,
vapor phase carbon adsorption units would be installed. Vapor
phase carbon adsorption units remove VOCs from the air stream
exiting the air stripping tower. Once contained within the
carbon adsorption unit, the VOCs could then be destroyed.

Alternatives 2b and 2d, employ carbon adsorption units that would
not cause release of contaminants into the air. The spent
carbon, however, would require regeneration or disposal subject
to the Land Disposal Restrictions and other applicable
requirements of RCRA. The spent carbon would most likely be a.
characteristic RCRA hazardous waste because of its saturation
with VOCs. Thus, it could not be disposed of in a landfill.
most cases, however, the carbon vendor has appropriate RCRA
permits. Thus, the vendor would ensure that the carbon is
regenerated and the VOCs are disposed of or recycled in
accordance with requirements of RCRA. In addition, the spent
carbon would be properly transported and manifested in accordance
with RCRA regulations, see 40 C.F.R. Parts 262 and 263. If vapor
phase carbon is used to control air emissions in Alternatives 2a
and 2c, then the same disposal restrictions would apply.
In
Alternatives 2a and 2b, which rely upon aquifer recharge wells,
would need to comply with the substantive requirements of an
underground injection well permit. The requirements are stated
within the Underground Injection Control program regulations
within the Safe Drinking Water Act, see 40 C.F.R. Parts 144, 145,
146 and 147.
Alternatives 2c and 2d, which rely upon discharging treated
ground water into a nearby surface water body, would comply with
the substantive requirements of a National Pollutant Discharge
Elimination System (NPDES) permit. The NPDES permitting
procedure is regulated by the Commonwealth of Pennsylvania under
the Clean Streams Law, 25 PA Code Sections 92.1 et ~ In
addition, the contaminant levels in the stream would comply with
ambient water quality criteria established under the Clean Water
Act and Pennsylvania water quality criteria established under the
Clean Streams Law, 25 PA Code Chapter 93. The treatment
technologies in each of the alternatives can be designed to meet
required standards.
C. Long-term Effectiveness and Permanence
Alternatives 2a through 2d employ potentially reliable treatment
technologies. The levels of contaminants in the ground water
would be reduced to drinking water standards or background, if
practicable. Long-term periodic sampling would be required to
ensure that the carbon adsorption units and air strippers are
properly maintained and are operating according to performance
standards.
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Alternatives employini air stripping towers (2a and 2C) have
fewer operation and maintenance requirements, but may need
additional controls installed if emission rates exceed required
standards. Air emissions controls may also be required upon
PADER review of the operation plans for the air strippers, unless
these new sources are exempted. Alternatives employing carbon
adsorption units to treat ground water may require increased
sampling frequency to ensure that contaminants do not break
through the carbon and, therefore, discharge at levels above the
required standards. Alternatives employing carbon treatment'
units would result in the destruction of contaminants, whereas
alternatives that employ air stripping towers would result in ION
levels of uncontrolled releases of contaminants into the
atmosphere (at levels that are, not considered to present a risk).

Alternatives which employ aquifer recharge wells (2a and 2b) are
sUbject to potential failure if recharge wells are not properly
maintained. Recharge wells tend to clog over time, necessitating
continued maintenance. In addition, recharge wells could cause
contaminants to migrate outside the capture zone of the,
extraction wells, resulting in residual risk within the ground
water system if not properly located and operated.
D. Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 2d provides the greatest reduction in contaminant
volume, toxicity, and mobility. The contaminants, which were
dispersed throughout the ground water, would be adsorbed onto
activated carbon and could then be collected for appropriate
disposal or destruction. Treated water would no longer contain
toxic levels of contaminants. Aquifer recharge wells could
potentially result in the movement of contaminants outside the
capture zone of the ground water extraction system thereby
increasing the volume of contaminated media. Alternative 2c
would provide the same reduction in toxicity, mobility, or volume
if air controls were installed on the air stripping towers.

The ground water risk posed by the site is in the range of 10-3.
The risk posed by the emissions from the air stripp.ing towers to
nearby residents would most likely be less than 10-6.
E.
Short-term Effectiveness
EPA anticipates that implementation of any of the alternatives
would not result in increased exposure to contaminants.
Sensitive environments, potentially located downstream of the
Site, could be negatively affected in the near-term by increased
stream flow and potential increases in contaminants of concern.
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F.
Implementability
Additional fieldwork must be completed before an efficient remedy
can be designed and constructed. Therefore, actual construction
requirements and associated implementation requirements are
unknown at this time. However, the technologies considered in
each alternative are generally easily constructed from readily
available components. EPA has extensive experience in
implementing ground water pump and treat remedies.
Alternatives employing aquifer recharge wells rather than surface
water discharges may be unreliable since recharge wells may be
difficult to locate and construct to efficiently inject treated
water back into the aquifer. Each alternative requires
coordination with the PADER. Surface water discharges require
development of discharge requirements, aquifer recharge wells
require development of permit requirements, and air stripping
towers require development and approval of operation and
management plans.
G.
Cost
The estimated cost of each alternative is depicted in Table 23.
Alternative 2c provides the necessary protection during
remediation, i.2., a risk level within the acceptable range
stated within the NCP, for the most reasonable cost. Alternative
2d, which is more costly than Alternative 2c and the most costly
of all alternatives, employs a different treatment technology
(carbon adsorption) than Alternative 2c, but provides the most
protection, i.e., no risk.
H.
State Acceptance
The Commonwealth of Pennsylvania has reviewed the Record of
Decision and has concurred with the selected remedy.
I .
Community Acceptance
The public generally agreed with EPA's selection of ground water
pumping, treating by air stripping towers, and discharging to
surface water (Alternative 2c or Alternative 3c as discussed in
the Proposed Plan). During the public comment period and public
meeting, the community expressed concern about the lengthy
remediation timeframe since use of their private wells would be
restricted during remediation. Some community members expressed
concern that the ground water extraction system would lower water
levels in their wells or reduce spring flows critical to their
business. The majority of the community's concerns applied
similarly to all alternatives. EPA's response to public comment~ .
is contained within Appendix A.
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   TA.r '23  
   CRYOCHEM SUPERFUND SITE 
   SUMMARY-OF ESTIMATED COSTS 
ALTERNATIVE CAPITAL ANNUAL O&M PRESENT IMPLEHENTATION
(FS REFERENCE) COST COST  WORTH TIME
     COST (MONTHS)
  ( $ ) ( $ )  ( $ ) 
1. NO ACTION / N/A 14,100  N/A
 NO FURTHER ACTION     
2a. EXTRACTION 2,003,000 97,600 2,923,000 10-16
 AIR STRIPPING     
 RECHARGE WELLS     
 (I1Aa(2»     
2b. EXTRACTION 2,152,000 167,700 3,086,000 10-16
 CARBON ADSORB.     
 RECHARGE WELLS     
 (I1Ab(2» ,     
2c. EXTRACTION 1,356,000 75,200 2,065,000 10-16
 AIR STRIPPING     
 SURFACE WATER     
 (IIAa(I»     
2d. EXTRACTION 1,507,000 145,300 2,877,000 10-16
 CARBON ADSORB.     
 SURFACE WATER     
 (IIAb(I»     
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XI.
Selected Remedy
The remedial action alternatives included in the final analysis
for OU2 of the Site were:
1. No Action
2. Ground Water
a. Treatment
b. Treatment
Wells
c. Treatment
d. Treatment
Water
Extraction, Treatment, and Discharge
by Air Stripping, Discharge to Recharge Wells
by Carbon Adsorption, Discharge to Recharge
by Air stripping, Discharge to Surface Water
by Carbon Adsorption, Discharge to Surface
The selected remedial alternative for OU2 is Alternative 2c.
Specifically, this ROD selects:
1. Completion of a Ground Water Remedial Design Study to
determine the design specifications of the remediation
system:
2. Installation, operation, and maintenance of ground water
extraction wells to remove contaminated ground water:
3. Installation, operation, and maintenance of air stripping
towers to treat ground water:
4. Installation and maintenance of a discharge pipe to local
surface water: and
5. periodic monitoring to ensure that the remediation is
progressing towards the cleanup goals and that treated
ground water meets required standards.
The number, location and construction specifics of the ground
water extraction well system would be determined during the
course of the Ground Water Remedial Design Study. This study
will be initiated as soon as possible. Similarly, the design
criteria for the treatment units (air stripping towers and
associated pumps and piping) would be determined once the
extraction wells are located and a ground water flow rate and
contaminant loading rate could be determined. The probable
locations of the discharge of treated ground water into the
nearby stream are known, but the actual amount of contaminants
and the volume of water that may be discharged would be
determined during the course of the Ground Water Remedial Design
Study.
r: :
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EPA intends to locate the surface water discharge points upstrea8
of identified seeps of contaminated ground water. Thus, the
treated discharge could serve to minimize any adverse stream
effects caused by the seeps of contaminated ground water via
dilution. In the-event that the amount of water discharged from
the treatment units exceeds the available capacity of the strean
channel, which is small in the vicinity of the Site, EPA may opt
to modify the remedy and discharge water from a treatment plant
located near the CryoChem, Inc. plant into a downstream on-Site
area, where the stream channel is wider, or to use a contingency
technology, i.e., aquifer recharge wells, as needed. The
contingency remedy is discussed later in this section.
In addition to the components of the selected remedial
alternative discussed above, a-pre-discharge evaluation of the
stream biota would be conducted for the purpose of providing a
baseline against which any potential impacts of the discharge
upon the receiving stream could be evaluated. An effluent
toxicity test would be performed on the treated discharge and
post-discharge downstream sampling would be conducted to evaluate
the persistence of the potential toxicants discharged from the
treatment units. In addition, downstream potentially sensitive
environments, if any, would be fully evaluated to determine if
the discharge results in adverse impacts.
One goal of this remedial action is to restore ground water to
its beneficial ~se as a drinking water aquifer. Based upon
information obtained during the RI/FS and upon a careful analysis
of all the remedial alternatives, EPA believes that the selected
alternative will achieve this goal. If implementation of the
selected remedy demostrates, in corroboration with
hydrogeological and chemical evidence that it will be technically
impracticable to achieve and maintain the remediation goals
throughout the area of attainment, the USEPA in consultation with
the Commonwealth of Pennsylvania, intends to amend the ROD or
issue an Explanation of Significant Differences to inform the
Public of alternative groundwater goals.
The selected remedy includes ground water extraction, treatment,
and discharge for an estimated period of 30 years, during which
time the system's performance would be carefully monitored on a
regular basis and adjusted as wa~anted. For example, certain
extraction wells could be removed from service or pumped at
higher levels, or intermittently, to improve the performance of
the extraction system.
If it is determined that certain portions of the aquifer cannot
be restored to their beneficial use, all of the following
measures involving long-term management may occur, for an
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indefinite period of time, as a modification of the existing
system:

a) low level pumping would be implemented as a long-term gradient
control, or cont~inment, measure: .
b) chemical-specific ARARs would be waived for the cleanup of
those portions of the aquifer based on the technical
i~practibility of achieving further contaminant reduction: and/or
c) institutional controls would be provided/maintained to
restrict access to those portions of the aquifer which remain
above health-based goals and to ensure that public wells are
routinely monitored and treated as necessary.
The decision to invoke any or all of these measures may be made
during a periodic review of the remedial action, which would
occur at 5-year intervals.
An Explanation of Significant Differences would be issued to
inform the public of the details of these actions if and when
they occur.
After the remediation is completed, the lifetime excess cancer
risk levels posed by the Site would be within the 10.4 to 10-6
excess cancer risk range consistent with the NCP.
Thus, ground water extraction, treatment, and discharge would
continue until clean up goals are reached within the area of
attainment, if practicable.
Alternative 2c would meet the ground water cleanup goal
(background) within the area of attainment, up to the boundary of
the contaminated soil left in place, if practicable; would meet
NPDES discharge standards at the point of discharge into surface
water; and would meet ambient water quality criteria standards
downstream of the surface water discharge points.
After the remediation is completed, the excess cancer risk levels
posed by the Site would be within the 10-4 to 10-6 excess cancer
risk range consistent with the NCP. EPA expects that Alternative
2c would reduce the excess cancer risk level less than or equal
to lxlO-6.
Alternative 2c complies with all ARARs and provides a high
of protection for a reasonable cost. Each of the remedial
objectives for OU2 would be met. The estimated costs for
Alternative 2c are summarized in Table 20.
degree
,-
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XII.
statutory Determinations
The selected remedy which was outlined in Section X satisfies the
remedy selection requirements of Section 121 of CERCLA (42 D.S.C.
Section 96Z1) and the NCP (40 C.F.R. Section 300.430 (e)). The
remedy provides protection of human health and the environment,
achieves compliance with ARARs, utilizes permanent solutions to
the maximum extent practicable, contains treatment as a principal
element, and is cost effective.
A. Protection of Human Health and the Environment
The selected alternative is protective of human health and the
environment. The ground water remediation would reduce
contaminant leve~s to background and/or health-based levels,
whichever is lower or more protective, if practicable. The
ground water discharged from the treatment units into surface
water would be treated to levels protective of the receiving
stream.
The residual cancer risk is expected to be less than 1X10'6, but
would certainly be within the 10'4 to 10'6 risk range consistent
with the NCP. The residual risk from non-carcinogenic compounds
is expected to be less than 1. EPA expects to meet the ground
water cleanup goal (background) within the area of attainment, up
to the boundary of the contaminated soil left in place, if
practicable.
EPA expects to meet NPDES discharge standards at the point of
discharge into surface water. EPA expects to meet ambient water
quality criteria standards downstream of the surface water
discharge points. EPA expects to meet air quality standards
within 100 meters of the air stripping towers.
Although the selected alternative transfers contaminants from the
ground water into the air, preliminary calculations indicate that
the resulting risk is within the acceptable range. EPA would
install air controls should design sampling indicate that the
potential risk posed to human health is outside the acceptable
excess cancer risk range of 1x10'4 to lxlO'6 or if the operation
plan is not approved by PADER and air emissions control are
required. If air controls must be installed, the remedy would be
more protective of human health since any risk which may result
from low levels of uncontrolled releases of VOCs would be
addressed. No unacceptable short:term risks would result from
implementation of the selected alternative.
8. Compliance with ARARs

The selected remedy complies with all ARARs. The ARARs for
Alternative 2c are identified in Table 22. In addition, the VOC
~~
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emissions from the air strippers would not exceed levels
identified within OSWER Directive 9355.0-28.
C. Cost Effectiveness
The selected remedy is cost effective. The only Alternative
which provides more protection is Alternative 2d. Alternative 2d
utilizes carbon adsorption, rather than air stripping which is
less costly, to treat contaminated ground water. Since the
emissions from the air stripping towers are not expected to
exceed the most stringent levels to be considered for the Site
and are not expected to result in a risk to the public outside
the acceptable range identified in the NCP, additional treatment
to provide additional protection is not necessary. In addition,
Alternative 2c utilizes a surface water discharge, rather than
aquifer recharge wells which are more costly and less reliable,
to discharge treated ground water. Thus, because Alternative 2c
includes air stripping towers and surface water discharge, it
provides the most protection for the most reasonable cost.
D. utilization of Permanent Solutions to the Maximum Extent
Practicable
The selected alternative provides the highest level of protection
for the most reasonable cost. The selected alternative employs
permanent solutions and treatment technologies to remove
contaminants from ground water.
Those criteria potentially affecting the long-term operation and
maintenance of the remedy (e.g., long-term effectiveness,
implementability, and cost) were most critical in the selection
decision. Air stripping towers and surface water discharge were
not difficult to operate and maintain, were easily implemented,
were not subject to failure, and were less costly than carbon
adsorption units and aquifer recharge wells. Yet, air stripping
towers and surface water discharge options provided similar
protection of human health and the environment. In addition,
aquifer recharge wells could potentially spread the contaminants
into currently unaffected areas.
The Commonwealth of Pennsylvania and the public supported EPA's
selection of treatment by air stripping and discharge to surface
water. -
E. Preference for Treatment as a Principal Element
The selected remedy utilizes proven and readily available
treatment technologies to reduce the ground water risks posed by
the Site.
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APPENDIX A
RESPONSIVENESS SUMMARY
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Responsiveness Summary
cryoChem Superfund site
Operable Unit 2
A. overview
EPA's preferred remedial alternative for contaminated ground
water (Operable Unit 2) was outlined in the Proposed Plan and.
released to the public on August 6, 1990. During a 30-day public
comment period (August 6, 1990 through September 11, 1990) and
during a public meeting conducted August 20, 1990, the public was
provided the opportunity to submit comments on EPA's preferred
alternative. In.general, the public provided comments which
supported EPA's preference to treat ground water by air stripping
and to discharge treated ground water into the nearby stream. No
written comments were received by EPA during the comment period.
All comments were delivered at the public meeting. Based upon a
comparative analysis of several remedial alternatives and upon
public comments received during the 30-day comment period, EPA
selected Alternative 2c; Ground water Extraction, Treatment by
Air Stripping, Discharge to Surface Water; for Operable Unit 2 of
the CryoChem Site. The Record of Decision (ROD) details the
remedial alternative selected by EPA.
B. Summary of Comments
The public comment period was held from August 6, 1990 to
September 11, 1990. A public meeting was held August 28, 1990.
a stenographic report of the public meeting was prepared by EPA.
No written comments were received by EPA during the comment
period. All comments were received at the public meeting and are
contained within a Stenographic Report of Public Hearing held at
the Earl Township Municipal Building, Route 73, Boyertown,
Pennsylvania, August 28, 1990.
Comments concerning OU2 raised at the public meeting are
summarized below. Following each comment summary is EPA's
response.
cost/Fundinq Issues
EPA received comments concerning who would operate and pay for
the remedy that EPA selected for OU2.
EPA ReSDonse: Under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended, EPA has the
authority to require responsible parties to pay for environmenta~
cleanup or to reimburse the government for the costs it incurs
responding to contamination. EPA will provide. the parties
potentially responsible for the contamination of ground water at
the Site the opportunity to operate and pay for the selected
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remedy. If these parties are unable or unwilling to do so, EPA
will implement the remedy and attempt to recover its costs from
these parties.
Decision - Makinq Process
EPA received comments concerning th~ length of time which passed
before any response action was taken at the Site.
EPA ResDonse - Prior to implementing a remedy at a Superfund.
Site, EPA is required, pursuant to the NCP, to conduct studies
intended to determine the nature and extent of contamination at a
Site, the risks posed by that contamination, and a range of
alternatives for responding to the risks posed by the Site. Upon
completion of these studies, EPA can then select the alternative
which best addresses the risks posed by the Site for the most
reasonable costs. In order for EPA to expend public funds
addressing the remediation of the Site contamination, the Site
must first be listed on the National Priorities List(NPL). This
site was listed on the NPL in October 1989. Prior to October
1989, the work conducted at the Site to determine appropriate
response actions for contaminated ground water was conducted by
the potentially responsible parties.
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Technical Concerns Regarding Alternatives
1.
EPA received comments concerning the length of time for the
Site to be cleaned.
EPA ReSDonse: The contaminants have migrated a long way in the
ground water system. It is very difficult and a lengthy process
to remove these contaminants since they are dispersed in millions
of gallons of water and most likely adsorbed, in part, onto
aquifer material. The ground water remediation would continue
until the. aquifer. is restored.
2 .
EPA.received
ground water
the location
excess noise
comments regarding the proposed location of the
treatment units. Concerns were raised about
of these units in a residential area. Possible
from the air stripper was also a concern.
EPA ResDonse: The actual location of the ground water treatment
units would be determined during the design stage of the response
action. The extraction wells would go in the areas of high
contamination and in areas where the contaminants are migrating
from the Site. The treatment units can be placed almost
anywhere. EPA 'vould not locate the air stripping tower within
the residential area if possible. The units can be designed to
be quiet.
3.
EPA received comments concerning the extent of contam-
ination. Specifically the commentator wanted to know if
other sources of contamination are known or if the
contamination in residential wells originated from CryoChern,
Inc.
EPA Res~onse: Although there appears to be an upgradient source
of TCE contamination, the sampling data support the conclusion
that the CryoChem, Inc. plant caused contamination of residential
wells downgradient to the plant.
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
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4.
5 .
6.
CRYOCH~M G?SUNDWATER CONTAMINATION SITE OU2
ACMINIS~RA~IVE RECORD rI:E
INCEX OF DOCUMENTS
C::-""t"
-.i..-
I D :: ~J T r F :: C A :' :: : ~J
.
Le:~er to Mr. An:hony T. Calzolaio, Cryochem,
I~c., from Mr. Robert E. Day-Lewis,
Co~~onwealth of Pennsylvania Department of
Environmental Resources (PADER), re: Well
water samples in the locality of Worman, Earl
Township, and Douglass Township, 7/8/82. P.
100001-100002.
2.
Letter to Mr. Anthony T. Calzolaio, Cryochem,
lric., from Mr. Robert E. Day-Lewis, PADER, re:
Findings from August 10, 1982 meeting and plant
inspec~ion, 10/12/82. P. 100003-100005.
3 .
Letter to Mr. Walter Stanley, PADER, from Mr.
David J. Stanislawczyk, Gilbert/Commonwealth,
re: Hydrogeologic Study-Work Plan prepared on
the behalf of Cryochem, Inc., 11/15/82. P.
100006-100011. The work plan is attached.
Report: Site Inspection of Cryochem,
Incorporated, prepared by NUS Corporation,
5/13/85. P. 100012-100273.
Letter to Mr. Anthony Calzolaio, Cryochem,
Inc., from Mr. Willard A. Wade, III,
Gilbert/Commonwealth, re: G/C Project No. 04-
5119-000, 10/16/85. P. 1000274-100275. A
summary of 1, 1, 1-Trichloroethane Sampling
Results are attached.
Letter to Mr. Walter E. Stanley, PADER, from
Mr. Anthony T. Calzolaio, Cryochem, Inc., re:
Continuation of Hydrogeologic Report at
Cryochem, Inc., 10/23/85. P. 100276-100276.
Administrative Record File available 7/26/90,
updated 7/31/90, updated 8/23/90.
*
Entries with an asterisk are documents that can be
located in the CryoChem OU1 Administrative Record.
Note: Company or organizational affiliation is identified in
index only when it appears in file.
J
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11.
12.
7 .
Letter to Mr. Anthony Ca1zo1aio, Cryochem,
Inc., from Mr. David J. Stanisla.....czyk,
Gilbert/Cc:r.monwealth, re: Ground'....ater sampling
at the Cryochem Site, 7/11/86. P. 100277-
100280. A Certificate of Analysis for
Cryochem, Inc. is attached.
5.
Letter to Mr. Russell H. Wyer, U.S. EPA, from
Mr. Anthony Calzolaio, Cryochem, Inc., re:
Spillage of Trichloroethane, 7/25/86. P.
100281-100283. A hand-drawn map of the
Cryochem property is attached.
9.
Letter to Ms. Humane Zia, U.S. EPA, from A.T.
Calzolaio, Cryochem Inc., re: Hydrogeologic
Evaluation conducted by Gilberts/Commonwealth,
8/25/86. P. 100284-100307. The Hydrogeologic
Evaluation is attached.
10.
Memorandum to Ms. Kathryn Hodgkiss, U.S. EPA,
from Ms. Humane Zia, U.S. EPA, re: Closeout
for the Cryochem Potentially Responsible Party
Search, 9/29/86. P. 100308-100310.
Memorandum to Cryochem File, Central Office,
CERCLIS IPA 866, from Mr. Thomas Sheehan,
Divislon of Emergency and Remedial Response
Ridley Creek State Park, re: Surface Water,
10/28/86. P. 100311-100311.
Memorandum to Ms. Humane Zia, U.S. EPA, from
Ms. Libby Rhoads, U.S. EPA, re: Presence of
Wetlands in Cryochem Site, (undated). P.
100312-100312.
2
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- T
1 .. .
5 .
6.
7.
8 .
K~~EJrAL ENFORCE~ENT PLANNING
1 .
Letter to ~r. Harold L. Nettles, C=yochem, frcm
Mr. Bruce P. Smith, U.S. E?A, re: Reques': :0=
information pursuant to Section l04(e),
7/26/86. P. 200001-200005. Two ce=tified
mail receipts are attached.
~ .
Let':er to Mr. Edward J. Edwards, Berks County
Industrial Development Authority, from Ms. K.
Hodgkiss for Mr. Bruce P. Smith U.S. EPA re:
Request for information pursuant to Section
104 (e), 7/26/86. P. 200006-200010. Two
certified mail receipts are attached.
3 .
Letter to Mr. Gordon John Straube and Mrs.
Betty L. Straube from Mr. Bruce P. Smith, U.S.
EPA, re: Request for information pursuant to
Section 104{e), 7/26/86. P. 200011-200014.
An envelope is attached.
4.
Mr. Russell E. Garber from Mr. Bruce P. Smith
U.S. EPA, re: Request for information pursuant
to Section 104 (e), 7/26/86. P. 200015-200019.
Two certified mail receipts addressed to Mr.
Claude w. Garber are attached.
Letter to Mr. Claude S. Garber from Ms. K.
Hodgkiss for Mr. Bruce P. Smith, U.S. EPA, re:
Request for information pursuant to Section
104 (e), 7/29/86. P. 200020-200024. Two
certified mail receipts are attached.
Letter to C.S. Garber & Sons, Inc., from Mr.
Bruce P. Smith, U.S. EPA, re: Request for
information pursuant to Section 104{e),
7/30/86. P. 200025-200029. Two certified
mail receipts are attached.
Handwritten memo to File from Ms. Humane Zia,
re: Gordon Straube conversation, 7/30/86. P.
200030-200030.
Letter to Ms. Kathryn N. Reigner from Mr. Bruce
P. Smith, U.S. EPA re: Request for information
pursuant to Section 104{e), 7/31/86. P.
200031-200035. Two certified mail receipts are
attached.
3
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14.
15.
16.
9.
Letter to Russell E. Garber from Ms. K.
Hodgkiss .fo:- Mr. Bruce P. Smith, U.S. EPA, re:
Request for information pursuant to Section
104 (e), 7/31/86. P. 200036-200040. Two
certified ~ail receipts are attached.
, ...-\
:'e': ': e r to Mr. Will i am C. Ear 1 y, U. S. E P A, f r Qm
Ms. Kathryn N. Reigner, re: Response to
Section l04(e), 7/31/86. P.200041-200041.
- ~ .
11.
:'etter to Ms. Humane Zia, U.S. EPA, from Mr.
John G. Schofer, C.S. Garber & Sons, Inc., re:
Response to Section 104 (e), 8/8/86. P. 200042-
200043.
12.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Ralph E. Mirarchi, Bluestein, Rutstein &
Mirarchi, P.C., re: Response to Section
104 (e), 8/13/86. P. 200044-200082. The
following are attached:
a)
an industrial/commercial project
agreement;
a deed;
a Resolution of Berks County
Industrial Development Authority;
and a Lease agreement.
b)
c)
d)
13.
Handwritten report of telephone conversation to
Mr. Bill Early from Ms. Humane Zia, re: Berks
County Development Authority's failure to
respond to 104 (e) letter, 8/19/86. P. 200083-
200083.
Handwritten report of telephone conversation to
Ms. Humane Zia from Mr. Robert Day-Lewis, re:
Cryochem culpability, 8/19/86. P. 200084-
200084.
Memorandum to Cryochem File from Ms. Humane
Zia, re: Report of meeting with Cryochem,
Inc., 8/20/86. P. 2J)0085-200086.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Matthew S. Santangelo, Santangelo, Skypala &
Santangelo, re: Response to request for
information [104 (e) J, 8/20/86. P. 200087-
200203. The following are attached:
4
-------
19.
20.
17.
a)
b)
c)
d)
e)
f)
g)
h)
i)
j )
k)
l)
m)
n)
0)
an EFA letter 8/13/86;
Cryochem Comments 8/7/86;
an EFA letter 8/5/86;
a~ EFA letter 7/25/86;
an EFA letter 7/25/86;
a Cryochem letter 7/25/86;
an E?A Letter 5/21/86;
Cryochem Co~~ents 6/10/86;
a Settlement Sheet 7/14/82;
a Lease Agreement 7/13/82;
a Lease Agreement 7/14/82;
a Memorandum of Lease 7/14/82;
an Assignment 7/14/82;
a Mortgage note 7/14/82;
and an Industrial/Commercial Project
agreement 7/14/82.
Letter to Mr. William C. Early, U.S. EPA, from
Mr. Edward J. Edwards, Berks County Industrial
Development (BCIDA), re: Reply to telephone
request for information, 8/20/86. P. 200204-
200206. A letter to Cryochem, Inc. dated July
29, 1986 and a certified mail receipt are
attached.
18.
Letter to Ms. Susie Olson, BCIDA, from Mr.
William C. Early, U.S. EPA, re: Confirmation
of telephone conversation of August 19th, 1986,
8/21/86. P. 200207-200207.
Letter to Mr. Hal Snyder, U.S. EPA, from Mr.
Matthew S. Santangelo, Santangelo, Skepala,
Santangelo, re: Cryochem Inc., 11/3/86. P.
200208-200214. The following are attached:
a)
b)
c)
d)
a copy requisition form;
a letter to the EPA from SSM;
a copy of comments on the HRS
documentation;
and a copy of an envelope;
Handwritten report of telephone conversation to
Mr. Anthony Calzolaio~rom Ms. Humane Zia, re:
Arranging a date for a site visit, 3/17/87.
P. 200215-200215.
5
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24.
25.
26.
27.
28.
21.
Letter to Mr. Russell E. Garber, Sr., from Mr.
Stanley'L. LaskO'wski, U. S. EPA, re: RIIFS of
Site, 3123187. P. 200216-200219. A certified
mail receipt is attached.
22.
Letter to Ms.' Kathryn N. Reigner from Mr.
Stanley L. Laskowski, U.S. EPA, re: Request
for participa:ion in the RIIFS, 3123/87. P.
200220-200226. Two certified mail receipts and,
a copy of the letter are attached.
23.
Letter to Mr. Edward J. Edwards, Berks County
Industrial Development Authority, from Mr.
Stanley L. Laskowski, U.S. EPA, re: Request
for' participation in the RIIFS, 3123/87. P.
200227-200230. A certified mail receipt is
attached.
Letter to Mr. Claude W. Garber from Mr. Stanley
L. Laskowski, U.S. EPA, re: Request for
participation in the RIIFS of site, 3123/87.
P. 200231-200235. Two certified mail receipts
are attached.
Letter to Mr. John G. Schofer, C.S. Garber of
Sons, Inc., from Mr. Stanley L. Laskowski, U.S.
EPA, re: Request for participation in the
RIIFS, 3123/87. P. 200236-200240. Two
certified mail receipts are attached.
Letter to Mr. Harold Nettles, Cryochem Inc.,
from Mr. Stanley L. Laskowski, re: Request for
participation in the RIIFS, 3123/87. P. 200241-
200245. Two certified mail receipts are
attached.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Joseph E. DeSantis, DeSantis, Schmehl &
DeSantis, re: Response to request for
participation in the RIIFS, 3/30/87. P.
200246-200248.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Robert T. Miller, Stevens & Lee, re: Response
to request for participation in the RIIFS,
4/1/87. P. 200249-200250.
6
-------
...
...
35.
36.
37.
38.
29.
Letter to Ms. Hu~ane Zia, U.S. EPA, from Mr.
Ralph E". Mirarchi, Bluestein & MirarChi, re:
Response to request for participation in the
RI/FS, 4/6/87. P. 200251-200251.
30.
:et~er to Mr~ Stanley L. Laskowski, U.S.
Mr. Ronald L. Putt, Cryochem Inc., re:
request for participation in the RI/FS,
200052-200059. Three letters regarding
Ranking Score are attached.
Hazardo~s
£PA fr:~
ResFonse :0
4/8/87. :-'.
31.
Handwritten report of telephone conversation to
Mr. Matthew Santangelo from Ms. Humane Zia,
U.S. EPA, re: Status of response to request
for participation in the RI/FS, 4/9/87. P.
200260-200260.
32.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Matthew B. Santangelo, Santangelo, Skypala &
Santangelo, re: Response to request for
participation in the RI/FS, 4/9/87. P. 200261-
200262.
33.
Report: Cryochem, Incorporated Final Letter
Report, prepared by NUS Corporation, 4/14/87.
34.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Matthew S. Santangelo, Santangelo, Skypala &
Santangelo, re: Inability to attend Cryochem
meeting, 5/18/87. P. 200263-200263.
Handwritten list of people who attended the
Cryochem meeting, 5/20/87. P. 200264-200264.
Letter to Ms. Humane Zia, U.S. EPA, from Mr.
Ronald L. Putt, Cryochem Inc., re: A proposed
work plan, 5/26/87. P. 200265-200265.
Handwritten Report of Telephone conversation
(Conference call) from Mr. Bill Early, Mr. Nick
DiNardo & Ms. Humane Zia to Mr. Victor Dodd,
re: Additional sampling of well water,
6/12/87. P. 200266~200266.
Memorandum to Ms. Humane Zia to File [sic], re:
Summary of notice letter responses, 9/21/87.
P. 200267-200269.
Document is found in the Administrative Record for
Cryochem OU1.
-------
44.
42.
43.
39.
Letter to Mr. Matthew S. Santangelo,
Santangelo, Skypala & Santangelo, from Mr.
Stephen R. Wassersug, U.S. EPA, re: Request
for participation in the RI/FS, 10/1/87. P.
200270-200280. Two drafts of the letter and
two certified ~ail receipts are attached.
~J.
Letter to Mr. William C. Early, U.S. EPA, from
Mr. Robert D. Fox, Wolf, Block, Schorr and
Solis-Cohen, re: Response to request for
participation in the RI/FS, 10/9/87. P.
200281-200284.
41.
Letter to Mr. William C. Early, U.S. EPA, from
Mr. Robert D. Fox, Wolf, Block, Schorr & Solis-
Cohen, re: Response to request for
participation in the RI/FS, 10/9/87. P.
200285-200344. An agreement for purchase and
sale of stock, two letters, and comments on the
' HRS documentation are attached.
Letter to Mr. Brian Nishitani, U.S. EPA, from
Mr. Robert D. Fox, Wolf, Block, Schorr & Solis-
Cohen, re: Update on status of Cryochern's
offer to fund RI/FS, 10/28/87. P. 200345-
200350.
Letter to Mr. William C. Early, U.S. EPA, from Mr.
Robert D. Fox, Wolf, Block, Schorr and Solis-Cohen,
re: Agreement by Cryochem PRPs to fund the RI/FS,
11/18/87. P. 200351-200352.
Administrative Order by Consent In The Matter
of The Cryochem Site, 2/14/88. P. 200353-
200385.
8
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r:1. REMEJIAL RES?CNS2 P~ANNING
8 .
1 .
Handwritten l:st of people present at C=yoc~e~
meeting, 3/22/82. P. 300001-300001.
2.
Record of CO~~~~ication to Mr. Ar.thony
Calzclaio, Crjcc~em trom Ms. Laura Boo=naz:a~,
U.5. EPA, re: NPL Update 5 announcement,
5/20/86. ? 300002-300002.
3 .
Letter to Mr. Jeffrey A. Pike, U.S. EPA, from
Dr. Albert C. Gray, JACA Corporation, re: EPA
proposed RI/FS Work Plan, 10/15/87. P. 300003-
300011. The following are attached:
a)
a map of potential groundwater
contamination Sources;
a map of sampled well locations pre-July,
1988;
a map of TCA concentrations in ground
water;
and a map of DCE & DCA concentrations in
groundwater.
b)
c)
d)
4 .
Letter to Mr. Robert T. Miller, Stevens and
Lee, from Ms. Humane Zia, U.S. EPA, re: Basis
fer C.S. Garber & Sons, Inc., potential
responsibility, 10/22/87. P. 300012-300013.
5 .
Letter to Ms. Humane Zia, U.S. EPA, from Dr. Albe=t
C. Gray, JACA Corp., re: Cryochem RI/FS Study,
11/25/87. P. 300014-300014.
6 .
Letter to Mr. Robert D. Fox, Wolf, Block,
Schorr, and Solis-Cohen, from Ms. Humane Zia,
U.S. EPA, re: Approval of JACA as contractor
for RI/FS, 12/7/87. P. 300015-300015.
7 .
Letter to Mr. [sic] Alan Gray, JACA Corp., from
Ms. Humane Zia, U.S. EPA, re: Modifications to
JACA Work plan to conform to EPA standards,
12/30/87. P. 300016-300018.
Report: ~ation of Environmental Anal~ses
Performed in the Vicinity of Cryochem Cor.
[sic], Worman, PA, prepared by JACA Corp.,
2/24/88. P. 300019-300067.
9
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13.
14.
15.
16.
17.
18.
9 .
Letter to Ms. Humane Zia, U.S. EPA, from Dr.
Albert ~. Gray, JACA Corp., re: EPA, Cryochem
PRP Group Administrative Order By Consent,
3/4/88. P. 300068-300068.
10.
Letter to Dr. Al Gray, JACA Corp, from Ms.
Humane Zia, U.S. EPA, re: Co~ments on the
scope of work, 3/14/88. P. 300069-300072.
11.
Letter to Ms. Humane Zia, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Copies of the
Revised Scope of Work, 4/4/88. P. 300073-
300128. The Scope of Work is attached.
12.
Letter to Dr. Albert C. Gray, JACA Corp., from
Ms.' Humane Zia, U.S. EPA re: Approval of Scope
of Work as final, 4/14/88. P. 300129-300129.
Letter to Ms. Humane
Albert C. Gray, JACA
approval of Scope of
300130.
Zia, U.S. EPA, from Dr.
Corp., re: Response to
Work, 4/15/88. P. 300130-
Letter to Dr. Albert C. Gray, JACA Corp., from
Ms. Humane Zia, U.S. EPA, re: Formal
notification of a change of EPA Project
Coordinators, 5/13/88. P. 300131-300131.
Letter
Albert
review
Safety
to Ms. Humane Zia, U.S. EPA, from Dr.
C. Gray, JACA Corp., re: Request for
of Sampling & Analysis Plan and Health
Plan, 5/16/88. P. 300132-300132.
&
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
progress report, 6/28/88. P. 300133-300133.
Letter to Dr. Albert C. Gray, JACA Corp., from
Mr. Christopher B. Pilla, U.S. EPA, re:
Comments concerning the JACA Sampling and
Analysis Plan, 7/12/88. P. 300134-300159. The
Sampling & Analysis Plan report & two DHL
express mail receipts- are attached.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
progress report, 7/14/88. P. 300160-300160.
10
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25.
26.
27.
28.
21.
22.
23.
24.
19.
Report: Site Visit Tri ReDact, Technical Rev:e~
Documents and Oversi ht of ?RP ACtivit for Crvcs~~.-
S i t~ ' pre par e d by COM, 7 / 2 0 / 8 8 . P. 300 1 6 1 - .3 00 1 7 ~ .
20.
Letter to Dr. Albert C. Gray, .JACA Corp., fcom
Mr. Christopher B. Pilla, U.S. E?A, re:
Co~ments conCerning the Cryochem Sampling &
Analysis Plan, 7/27/88. P. 300175-300177. A
Sampling & Analysis Plan/Quality Assurance
Project Plan Review is attached.
Report: Sam lin & Anal sis Plan for Cr ochem
{sic] Site, Earl Township, PA, prepared by JACA
Corp., 8/88. P. 300178-300318.
Letter to Mr. Christopher Pilla, U.S. EPA, from
.Dr. Albert C. Gray, JACA Corp, re: Revised
Sampling of Analytical Plan 8/11/88. P.
300319-300320.
Letter to Dr. Albert C. Gray, JACA Corp,
Mr. Christopher B. Pilla, U.S. EPA, re:
Receipt of revised Sampling & Analytical
8/16/88. P. 300321-300323.
from
Plan,
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: RI/FS
progress report, 8/17/88. P. 300324-300325.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Mr. Philip S. Getty, JACA Corp., re:
Cryochem revised Quality Assurance Project Plan
(QAPjP), 8/30/88. P. 300326-300491. The
laboratory QA Plan is attached.

Letter to Mr. Chistopher Pilla, U.S. EPA, from
Mr. Philip S. Getty, JACA Corp., re: Cryochem
residential well sampling program, 9/8/88. P.
300492-300494. The compiled data from a
Residential Well Questionnaire is attached.
Letter to Mr. Christopher B. Pilla, U.S. EPA, from
Dr. Albert C. Gray, re: Response to request for
revision to Sampling & Analytical Plan, 9/15/88.
300495-300496.
P.
Letter to Mr. Christopher B. Pilla, U.S. EPA, from
Dr. Albert C. Gray, re: Monthly progress report,
9/19/88. P. 300497-300497.
11
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*
*
*
33.
34.
35.
29.
Letter to Dr. Albert C. Gray, JACA corp, frem
Mr. Christopher B. Pilla, U.S. EPA, re:
Receipt of Cryochem Revised Quality Assurance
Project Plan Phase I Residential Well Sampling
Proposed Location and SA? Revision, 9/23/88.
Residential Sa~pling Results are attached.
30.
Letter to Mr. Christopher 8. Pilla, U.S. EPA,
from Mr. Philip S. Getty, JACA Corp., re:
Cryochem Remedial Investigation/Feasibility
Study (RI/FS), 10/6/88. The compiled data from
the Residential Well Questionnaire is attached.
31.
Letter to Dr. Albert C. Gray, JACA Corp., from
Mr. Christopher B. Pilla, U.S. EPA, re: EPA
approval of additional QAPjP information,
10/11/88. P. 300498-300499.
32.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Dr. Albert C. Gray, JACA Corp., re:
Monthly progress report, 10/18/88. P. 300500-
300501.
Handwritten Telephone Record Log to Ms. Joan
Lacava, Skinner & Sherman Inc., from Ms.
Annette Lage, U.S. EPA, re: Questions about
lab samples, 10/18/88. P. 300502-300505. A
handwritten note, a letter, and another
telephone record log are attached.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Mr. Philip S. Getty, JACA Corp., re:
Photographs of suspected Sources of
contamination, 10/20/88. P. 300506-300508.
copy of one photograph is attached.
A
Letter to Dr. Albert C. Gray, JACA Corp.,
Mr. Christopher B. Pilla, U.S. EPA, re:
Proposal for the soil gas work for RI/FS,
10/22/88. P. 300509-300509.
from
Documents are found in the Administrative Record for
Cryochem OU1.
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*
36.
Letter to Mr. Christopher Pilla, U.S. EPA, frc:71
Mr. Micha.el A. Johnson, PRC Enviror.:r.ent
Management, Inc., re: Activities during
residential well split sa~pling, 10/26/88. P.
300510-300519. An I~o=ganic Traffic Report, an
Orga0ic Traffic Report, four Chain 0: CustOdy
Records, and an EPA Sa~ple Shippi~g Log are
attached.
37.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
progress report, 11/15/88. P. 300520-300522.
A data table is attached.
...
38.
Letter to Dr. Albert C. Gray, JACA Corp., from
Mr. Christopher B. Pilla, U.S. EPA, re:
Residential well sample results, 11/18/88.
39.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Mr. Jeffrey A. Ross, PRC Environmental
Management, Inc., re: Summary of PRC's
oversight activities at Cryochem, 11/28/88. P.
300523-300534. A soil gas screening location
map and photographs taken Oct. 27 & Nov. 3,
1988 are attached.
40.
Report: Results of Phase I of Remedial
Investi ation Stud for Cr ochem Site, Earl
Township, PA, prepared by JACA Corp., 12/88.
P. 300535-300634.
41.
Report: Preliminary Health Assessment for
Cryochem Inc., prepared by the Agency for Toxic
Substances and Disease Registry (ATSDR),
12/2/88. P. 300635-300640.
42.
Letter to Mr. Peter Willings from Mr. Robert D.
Fox, Wolf, Block, Schorr & Solis-Cohen, re:
Heimbach Dump as potential Source of
Contamination, 12/2/88. P. 300641-300642.
43.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Dr. Albert C. Gray, JACA Corp., re:
Monthly progress report, 12/14/88. P. 300643-
300644.
Documents are found in the Administrative Record for
Cryochem OU1.
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47.
48.
49.
50.
51.
52.
44.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Philip S. Getty, JACA Corp., re: Phase I
Laboratory Analysis QA/AC Package, 12/19/88.
P. 300645-300645.
45.
Memo~andum to Mr. Christopher (sic) Pilla, U.S.
EPA, from Ms. Theresa A. Simpson, U.S. E?A, re:
Transmittal of the organic data review package,
:/4/89. P. 300646-300726. A memorandum
rega~ding the organic data validation results
and the organic data review are attached.
46.
Letter to Mr. Christopher B. Pilla, U.S. EPA,
from Dr. Albert C. Gray, JACA Corp., re: List
of proposed soil, surface water & stream
sediment sampling' locations, 1/9/89. P.
300727-300729. The list of soil & sediment
sampling locations is attached.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
Progress report, 1/13/89. P. 300730-300731.
Report: Quality Assurance Project Plan,
prepared by U.S. EPA, 1/16/89. P. 300732-
300769.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: List of
proposed soil, surface water & stream sediment
sampling locations, 1/25/89. P. 300770-300772.
The list is attached.
Letter to Dr. Albert C. Gray, JACA Corporation, f=8~
Mr. Christopher B. Pilla, U.S. EPA, re: Proposal
for soil, sediment, and surface water sampling,
2/1/89. P. 300773-300773.
Memorandum to Mr. Christopher Pilla, U.S. EPA, fr~~
Ms. Theresa A. Simpson, U.S. EPA, re: Inorganic
Data Validation for the Cryochem Site, 2/2/89. P.
300774-300790. The data validation is attached.
Telephone Record Log to Mr. Sam Hamner, Versar
Environmental Systems of Maryland, from Ms.
Annette Lage, U.S. EPA, re: Questions about
sampling data, 2/6/89. P. 300791-300791.
14
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59.
60.
61.
62.
63.
53.
Letter to Christopher Pilla, U.S. EPA, from Dr.
Albert C,. Gray, JACA Corp., re: Monthly
progress reports, 2/13/89. P. 300792-300793.
54.
Report: Site Visit Tr:p Report - Oversight &
Slit SamDlin Activities, Cr ochem Site,
prepared by U.S. ~PA, 2/24/89. P. 300794-
300820.
55.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp, re: Monthly
progress report, 3/13/89. P. 300821-300822.
56.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Mr. Philip S. Getty, JACA Corp, re: Phase II
Subsurface Exploration, 3/14/89. P. 300823-
30.0824.
57.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Mr. Michael A. Johnson, PRC Environmental
Management, Inc., re: Summary of unresolved
RI/FS issues, 3/20/89. P. 300825-300828.
58.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Mr. Philip S. Getty, JACA Corp., re:
Amendments to proposed exploration plan,
3/27/89. P. 300829-300830.
Letter to Dr. Albert C. Gray, JACA Corp., from
Mr. Christopher B. Pilla, U.S. EPA, re: JACA's
proposal for soil & bedrock boring for the
RI/FS, 3/29/89. P. 300831-300831.
Memorandum to Mr. Chris Pilla, from Ms. Theresa
A. Simpson, re: Organic data review, 4/4/89.
P. 300832-300943. The Organic Data Validation
report is attached.

Analytical Results Summary Residential Well
Sampling, 4/8/89. P. 300944-300956.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, J~A Corp, re: Monthly
progress report, 4/14/89. P. 300957-300957.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re: Organic
data review, 5/2/89. P. 300958-301086. The
report is attached.
15
-------
69.
70.
71.
72.
64.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re:
Inorganic data validation, 5/12/89. P. 301887-
301121. The Inorganic Data Validation report
is attached.
~-
-~.
Let:er to Mr. Christopher Pilla, U.S. EPA, from
8r. Albert C. Gray, JACA Corp., re: Monthly
progress reports, 5/15/89. P. 301122-301123.
66.
Handwritten Telephone Record Log to Mike
Brennen, U.S. EPA, from Annette Lage, U.S. EPA,
re: Receipt of a broken container, 5/19/89.
P. 301124-301124.
67.
Letter to Ms. Rose Harrell, U.S. EPA, from Mr.
Bruce R. Pluta, CDM Federal Programs
Corporation, re: Letter report for oversight
and split sampling, 5/26/89. P. 301125-301163.
68.
Letter to Ms. Rose Harrell, U.S. EPA, from Mr.
Bruce R. Pluta, CDM Federal Programs
Corporation, re: Letter report for oversight
and split sampling, 6/7/89. P. 301164-301179.
The report is attached.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re:
Inorganic Data Validation, 6/13/89. P. 301180-
301280. The Inorganic Data Review Report is
attached.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Jr. Albert C. Gray, JACA Corporation, re:
Monthly progress report, 6/15/89. P. 301281-
301282.
Letter to Ms. Rose Harrell, U.S. EPA, from Mr.
Bruce R. Pluta, CDM FPC, re: Oversight Trip
Report, 6/29/89. P. 301283-301283. The report
is attached.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Mr. Philip S. Getty, JACA Corp., re: Proposed
modification to confirmation round of monitor
well sampling, 7/5/89. P. 301289-301289.
16
-------
79.
80.
81 .
82.
73.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. TheIesa A. Simpson, U.S. EPA, re:
Inorganic Data Review, 7/13/89. P. 301290-
301316. The report is attached.
74.
Let t e r toO r. . Al be r t C. G ray, J ACA Cor p ., from
Mr. Christopher B. Pilla, U.S. SPA, re:
Proposal for the confirmation round of
groundwater monitoring well sampling and
residential well sampling, 7/13/89. P. 301317~
301317.
75.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re: Organic
Data Validation~ 7/17/89. P. 301318-301383.
The Organic Data Review is attached.
76.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
progress report, 7/19/89. P. 301384-301385.
77.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re:
Inorganic Data Review, 7/21/89. P. 301386-
301401. The report is attached.
78.
Letter to Mr. Christopher Pilla, U.S. EPA, from
Dr. Albert C. Gray, JACA Corp., re: Monthly
progress report, 8/15/89. P. 301402-301403.
Memorandum to Mr. Chris Pilla, U.S. EPA, from
Ms. Theresa A. Simpson, U.S. EPA, re: Organic
Data Review, 8/15/89. P. 301404-301488. The
report is attached.
Handwritten Telephone Record Log to Ms. Rita
McNeish from Ms. Annette Lage, re: Laboratory
samples, 8/22/89. P. 301489-301489.
Letter to Dr. Albert C. Gray, JACA Corp., from
Mr. Christopher B. Pilla, U.S. EPA, re: Change
in EPA project manager for RI/FS, 9/1/89. P.
301490-301490.
Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly
progress report, 9/11/89. P. 301491-301492.
17
-------
88.
89.
90.
91.
92.
83.
Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly
progress' report, 10/12/89. P. 301493-301494.
84.
Memorandum to Mr. Chris
Ms. Theresa A. Simpson,
Data Review, 10/17/89.
report is attached.
Pilla, U.S. EPA, from
U.S. EPA, re: Organic
P. 301495-30:544. The
85.
Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Request for
data from EPA on past residential well sampling
results, 10/30/89. P. 301545-301545.
86.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Bruce Beach, Dynamac Corp., re: Split Sampling
Letter Report, 11/6/89. P. 301546-301560. A
letter (with attachments) is attached.
87.
Letter to Dr. Albert Gray, JACA Corp., from Mr.
Michael Towle, U.S. EPA, re: EPA's enforcement
of penalties if draft Cryochem RI Report is
received late, 11/9/89. P. 301561-301561.
Letter to Mr. Ronald Putt, Cryochem Inc., from
Mr. Michael Towle, U.S. EPA, re: RI Report,
11/9/89. P. 301562-301564. Two certified mail
receipts are attached.
Letter to Mr. Ronald Putt, Cryochem, IncorpOrated,
from Mr. Michael Towle, U.S. EPA, re: Comments on
RI report, 1/4/90. P. 301565-301565.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Brian K. Boyd, PADER, re: Questions and
comments regarding the Draft Remedial
Investigation Report for the Cryochem Superfund
Site, 1/10/90. P. 301566-301568.
Letter to Mr. Ronald Putt, Cryochem,
IncorpOrated, from Mr. Michael Towle, U.S. EPA,
re: Draft RI Report, 1/18/90. P. 301569-
301600. EPA comments-and rationale for
disapproving the RI Report are attached.
Letter to Mr. Ronald Putt, Cryochem, Inc., from
Mr. Michael Towle, U.S. EPA, re: Feasibility
Study Report, 1/25/90. P. 301601-301601.
18
-------
95.
96.
g7.
98.
99.
93.
Letter to Hr. Michael Towle, U.S. EPA, fram Dr.
Albert C,. Gray, JACA Corp., re: Cryochem
RI/FS Mont1y Progress Report, 1/29/90. P.
301602-301602.
94.
Setter to Hr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Cryochem
:easibility Study, 1/30/90. P. 301603-301603.
Cryochem Feasibility Study Alternatives Under
Consideration, 2/8/90. P. 301604-301604.
Handwritten Cryochem Meeting Attendance sheet,
2/8/90. P. 301605-301605
. .
Memorandum to Mr. Roy Smith, U.S. EPA, from Mr.
Michael Towle, U.S. EPA, re: Cryochem
Superfund Site Risk Assessment, 2/16/90. P.
301606-301606.
Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Cryochem RI/FS
Monthly Progress Report, 2/22/90. P. 301607-
301607.
Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Alb~rt C. Gray, JACA Corp., re: Cryochem
Monthly Progress Report, 3/13/90. P. 301608-
301608.
100. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Richard L. Zambito, JACA Corp., re: Cryochem
Site - Draft RI Report, 3/23/90. P. 301609-
301609.
101. Letter to Dr. Al Gray, JACA Corp., from Mr.
Brian K. Boyd, PADER, re: Applicable or
Relevant and Appropriate Rules (ARAR's) and
Regulations for the Cryochem Site, 3/26/90.
301610-301613. A desk memorandum and a
tracking slip are attached.
P.
102. Memorandum to Distribution, U.S. EPA, from Mr.
Michael Towle, U.S. EPA, re: Cryochem
Superfund Site Final Remedial Investigation and
Draft Feasibility Study, 4/5/90. P. 301614-
301614.
19
-------
103. Letter to Mr. Brian Boyd, PADER, from Mr.
Michael Towle, U.S. EPA, re: Review and
comment on Final Remedial Investigation Report
and Draft Feasibility Study Report for Cryochem
Site, 4/5/90. P. 301615-301615.
:04. Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Cryochem RI/FS
monthly progress report, 4/20/90. P. 301616-
301616.
105. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Harold L. Nettles, re: Request for a hearing
prior to the next meeting between EPA and the
PRP group, 5/3/90. P. 301617-301620. A
certified mail receipt is attached.
106. Letter to Mr. Ronald L. Putt, Cryochem, Inc.,
from Mr. Michael Towle, U.S. EPA, re:
Requirement of two additional weeks to review
the Final RI Report and the Draft FS Study,
5/8/90. P. 301621-301621.
107. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Brian K. Boyd, PADER, re: Cryochem Site Draft
FS Review, 5/8/90. P. 301622-301625.
108. Fax Cover Sheet to Mr. Michael Towle, U.S. EPA,
from A. L. Duffy, PADER, 5/21/90. P. 301626-
301629. A letter concerning draft FS Review
and a memorandum regarding hydrogeologic
comments are attached.
109. Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Cryochem RI/FS
Monthly Progress Report, 5/21/90. P. 301630-
301630.
110. Phone conversation record to Dr. Albert Cimorelli,
EPA-AMD, from Mr. Michael Towle, 5/22/90. P.
301631-301631.
111. Letter to Mr. Ronald Putt, Cryochem, Inc., from Mr.
Michael Towle, U.S. EPA, re: Remedial Investigation
Report, Feasibility Study Report, 5/22/90. P.
301632-301685. The following are attached:
20
-------
a)
Final Remedial Investigation Report
,Carr.me n t s;
com~ents on the Draft FeaSibility
St:;dy;
calculations indicating that "soil"
xay require remediation;
additional environmental/chemical
characterization;
a "pre-design" study outline;
and a Cryochem Site Risk Assessment
conducted by EPA.
b)
c)
d)
e)
f)
112. Letter to Mr. Harold L. Nettles from Mr.
Michael Towle, U.S. EPA, re: Meeting arranged
for June 14, 1990" 5/22/90. P. 301686-301686.
113. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Robert D. Fox, Manko, Gold, and Katcher, re:
Remedial Investigation Report, Feasibility
Report; Cryochem Site, 5/25/90. P. 301687-
301688.
114. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Ronald L. Putt, Cryochem, Inc., re: PRP
response and notification extension, 5/29/90.
P. 301689-301689.
115. Memorandum to Mr. Bohdan Mykijewycz, U.S. EPA,
from Mr. Michael Towle, U.S. EPA, re:
Potential hazardous sites, Berks County,
5/31/90. P. 301690-301691.
116. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Richard L. Zambito, JACA Corp., re: Cryochem
Site - Final RI Report, 6/6/90. P. 301692-
301692.
117. Report: Final Remedial Investigation Report
for the Cryochem Site, Volume 1, prepared by
JACA Corp., 6/6/90. P. 301693-301950.
118. Report: Final Remedial Investigation Report
for the Cryochem Site; Volume II, prepared by
JACA Corp., 6/6/90. P. 301951-302311.
119. Report: Final Remedial Investigation Report
for the Cryochem Site, Volume III, prepared by
JACA Corp., 6/6/90. P. 302312-302709.
21
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120. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Robert Fox, Manko, Gold, and Katcher, re:
Remedial Investigation Report, Feasibility
Study Report, Cryochem Site, 6/8/90. P.
302710-302711.
121. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Richard L. Zambito, JACA Corp., re: Cryochem
Site - Final Draft FS Report, 6/13/90. P.
302712-302712.
122. Letter to Mr. Michael Towle, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Cryochem RI/FS
Monthly Progress Report, 6/19/90. P. 302713-
302713.
123. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Richard L. Zambito, JACA Corp., re: Cryochem
Site Final FS Report, 6/21/90. P. 302714-
302714.
124. Memorandum to File from Mr. Michael Towle, U.S.
EPA, re: Cryochem Superfund Site Additional
RI/FS Work, 6/22/90. P. 302715-302715.
125. Letter to Mr. Ronald Putt, Cryochem, Inc., from
Mr. ~ichael Towle, U.S. EPA, re: Cryochem
Superfund Site Remedial Investigation/
Feasibility Study, 6/22/90. P. 302716-302718.
A certified mail receipt is attached.
126. Letter to C.S. Garber Inc. from Mr. Michael
Towle, U.S. EPA, re: Location or water supply
well, 7/22/90. P. 302719-302720.
127. Report: Final Feasibility Study for the
Cryochem Site, prepared by JACA Corp., 6/22/90.
P. 302721-302763.
128. Letter to Mr. Kenneth Snyder, C.S. Garber,
Inc., from Mr. Michael Towle, U.S. EPA, re:
Identification of property boundaries near a
proposed water well location, 6/29/90. P.
302764-302964.
129. Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Bruce Beach, Dynamac Corporation, re: Draft letter
report, 8/15/90. P. 302965-302981. The report is
attached.
22
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*
*
*
*
*
v.
.
*
*
*
7 .
8 .
9 .
CCMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
I~GERY
1 .
Report: Sire Analysis Cryochem Co~pany,
Worman, Pennsylvania, prepared by Tr.e Bionefics
Corporation, 10/87. P. 500001-500028
2 .
:etter to Mr. Paul O'Lock from Mr. Christopher
9. Pilla, U.S. EPA, re: Results of residential
well sampling, 1/11/89.
3 .
Letter to Mr. Raymond Moyer from Mr.
Christopher B. Pilla, U.S. EPA, re:
residential well sampling, 1/11/89.
letter is attached..
Results of
A copy of
4 .
Letter to Mr. Greg Breidegam from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 1/11/89. A copy of
the letter is attached.
5 .
Letter to Mr. Charles L. Byler from
Christopher B. Pilla, U.S. EPA, re:
residential well sampling, 1/11/89.
the letter is attached.
Mr.
Results of
A copy of
6 .
Letter to Ms. Shelly Heimbach and Mr. Michael
Hoffman from Mr. Christopher B. Pilla, U.S.
EPA, re: Results of residential well sampling,
1/11/89. A copy of the letter is attached.
Letter to Mr. Greg Breidegam from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
the parameters analyzed in residential wells
and a fact sheet on lead are attached.
Letter to Mr. Charles Byer from Mr. Christopher
B. Pilla, U.S. EPA, re: Results of residential
well sampling, 2/23/89. A list of the
parameters analyzed in residential wells and a
fact sheet on lead are attached.
Letter to Mr. Paul O'Lock from Mr. Christopher
B. Pilla, U.S. EPA, re: Results of residential
well sampling, 2/23/89. A list of parameters
analyzed in residential wells and a fact sheet
on lead are attached.
Document is found in the Administrative Record for
Cryochem OU1.
-------
*
10.
*
. .
~~.
*
12.
*
13.
*
14.
*
15.
*
16.
*
17.
Letter to Ms. Shelly Heimbach and Mr. Michael
Hoffman from Mr. Christopher B. Pilla, U.S.
EPA, re: Results of residential well sampling,
2/23/89. A list of parameters analyzed ln
residential ~ells is attached..
~etter to The Selfinger Residence from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential ~ell sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Paul Wills from Mr. Christopher
B. Pilla, U.S. EPA, re: Results of residential
well sampling, 2/23/89. A list of parameters
analyzed in residential wells is attached.

Letter to The Bowers Residence from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Raymond Moyer from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. F. Daniel Miller from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells and a
fact sheet on lead are attached.
Letter to Mr. Edward Schomley from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells and a
fact sheet on lead are attached.
Letter to Mr. Winfield KecK from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
*
Document is found in the Administrative Record for
Cryochem OU1.
-------
..
""
*
.
.
..
..
..
22.
""
23.
24.
25.
18.
Letter to Mr. John Tarins from Mr. Christopher
B. Pilla, U.S. EPA, re: Results of residential
well sampling, 2/23/89. A list of parameters
analyzed in residential wells and a fact sheet
on lead are attached.
l 9.
Letter to Mr. Bernard J. Yeager from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
res:dential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
20.
Letter to The Iezzi ~esidence from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of .
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
21.
Letter to Ms. Joan Gonzales from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Peter Riviello from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Claude Garber from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Peter Willing from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Letter to Mr. Theodor~ Hinaman from Mr.
Christopher B. Pilla, U.S. EPA, re: Results of
residential well sampling, 2/23/89. A list of
parameters analyzed in residential wells is
attached.
Document is found in the Administrative Record for
Cryochem OU1.
-------
*
'"
2 6.
-...,
L ' .
Let ter to Mr. and Mrs. John Drabinsky, re:
Residential well sampling results 3/23/89.
memorandum regarding the residential water
results is attached.
A
samp:e
Fi~a: Craft Co~munity Re:ations Plan, CryoChe~
S~per:~nd Site, prepared by the U.S. EPA, 7/~6/9J.
P. 500029-500056.
Document is found in the Administrative Record for
Cryochem OU1.
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APPENDIX C
SUMMARY OF SITE SAMPLING DATA
-------
        Table 7-1         
       CryoChem Site RI        
     CtiEMICAI.S DETECTED DURING THE REMEDIAL INVESTIGATION      
      IN-VARIOUS ENVIRONMENTAL MEDIA        
 :hemlca I       Concentrations In parts per billion (ppb)     
 (CAS NO.)  Groundwater  Surface Water    Soil    Sediment 
     , Analyzed!    , Analyzed!    , Analyzed!    , Analyzed!
  Min. Max. Rep. , Detected Min. Max. Rep. , Detected Min. Max. Rep. , Detected Min. Max. Rep. , Detected
 \cetone          0 3500 1082 37/35    
 [61-64-1)                 
 :h10robenzene              0 5 5 6/1
 (108-90-1)                 
 :h 10ro'o",          0 23 23 31/22    
I (66-61-3) 0 54 9.9 2581215 0  3.5          
 1,l-Dlchloroethane 5 13/4 0 4200 2101 31/2    
 :15-34-3)'                 
 1,l-Dlcnloroethene 0 11~4 81 258/199 0 1 4.2 13/5 0 15 15 37/1    
 :75-35-4)                 
I :thy1benzene          0 920 920 37/1 0 5 3.5 6/2
 : 100-41-4)                 
 ~thylene Ch10rlde          0 310 231.5 31/ 36    
 15-09-2)                 
 ~thyl Ethy1 ketone          0 300 35.5 37/14    
 18-93-3)                 
 i-Methy1-2-Pentlnone          0 15 1.6 31/13    
 108-10-1)                 
 .tyrene              0 5 5 6/1
 100-42-5)                4 6/1
I, ,I,2,2-Tetrach1oroethane              0 4
19-34-5)                 
1 etrachloroethene 0 12 2.8 258/114      0 460 256.6 31/9 0 6 6 6/1
I 121-18-4)          0 7 2.3 31/21 0 6 3.3 6/3
oluene         
 108-88-3)    258/229 0 150 45.4 13/6 0 210 581 31/3 0 13 IJ 6/1
I ,1 ,I-Trichloroethane  0 1582 189
 11-55-6)   6.6 258/184      0 61 11.1 37/3 0 3 3 6/1
 rlchloroethene 0 11     
I 79-01-6)                 
-------
        Table 7-1            
        (Continued)            
mtcal        Concentra t ton!> In part!> per bIllIon (ppb)       
S NO.)   Groundwater  Surface Water     5011      SedIment 
     , Analyzed/     , Analyzed/    , Analyzed/     . ~nalY2edl
  "tn. Max. Rep. , Detected "tn. Max. Rep. , Detected Mtn. Max. Rep. , Detected MIn. Max. Rep. , Detected
enes      0 4 3.5  13/2      0  6 4 6/2
]0-20-7)                      
(2-Ethylhexyl)Phthalate 0 10 6.5 13/6        56 150 114 4/4  0.46 2100 1280 2/2
1-81-7)                      
n-butylphthalate     0 2 2  2/1           
-74-2)                      
Drdlne             13 14 13.5 37/1  0    2/1
-74-9)                      
etal        Concentrattons In mg/1         
» MD.)  GrOundVattr   Surface Water     S01l mg/kg     SedIment 
.tn.. 0 0.47 0.47 3/1 0 0.229 0.229  3/1  19,600 47,600 33,600 212 1,550 7,020 4,285 2/2
~9-90.5)          3/0            
\ Il80ny                0.072 0.14  0.11 2/2
10- ]6-0)    26/1      3/0  0 42.3  8.86 31/30 0.58  5.5  2.31 
!ntc 0 0.03 0.03          7/7
, 10-38-2)   0.23 43/3 0.201 0.391 0.256  13/6  0 112  118.31 31/29 1.9  89.8  55.6 1/7
11&111 0 0.36     
10-39-3)       0.0   3/0  0 9.3  9.3 2/1 0.36  0.63  0.50 2/2
/11 hn            
10-41-7)     0.011 0.235 0.125  13/8  0 22.8  3.84 31/27 0.36  2.4  1.03 7/7
.t...         
10-43 -9)  85.8 41 10/8      3/0  2,560 3,320 2,940 2/2 401  41 ,200 20,801 2/2
'''II 0       
10-70-2)  0.018 0.012 43/5      13/0  0 164  26.51 ]1/29 2.2  58.2  17.] 7/7
filII. V I 0         
0-47-3)                      
-------
        Table 7-1         
        (Conlt nued)         
 Metal        Concentrations In mg/I      
 (CAS No.)  GroundVater   Surface Water    5011 mg/kg   Sediment 
     , Anal./    , Ana 1. /     , Anal./    , Ana 1. /
  M'n. Max. Rep. , Det. Min. Max. Rep. , Det. Min. Max. Rep. ' Det. Min. Max. Rep. ' Det.
 I Coba It        3/0 20.2 21.2 20.7 2/2 3.6 6.3 5.0 2/2
 (7440-48-4)                
 Copper 0 0.071 0.052 10/2    3/0 29.8 49.8 39.8 2/2 1.8 31.2 16.5 2/2
 (7440-50-8)                 
 Iron 0 4.4 0.96 11/11 0.15 0.94 0.55 3/2 93,800 121,000 107,400 2/2 5,360 27,000 16,180 2/2
 (15438-31-0)                 
I lead ('norg.) 0 0.087 0.028 26/9    13/0 4.3 573 57.76 31/31 7.6 76.4 37.4 7/7
I (7439-92-1) 0 29 12.0 8/8 0 18.1 18.1 3/1 3,630       
. Magnes h. 4,930 4,280 2/2   3,210 2/2
I (7439-95-4)                 
 Manganese 0.1 0.456 0.23 3/3 0 0.016 0.016 3/1 1,610 12,800 14,410 2/2 35.4 287 161 2/2
 (7439-96-5)                 
 Mercury ('norg.)        13/0 0.011 0.37 0.091 31131 0.014 0.069 0.036 7/7
 (7439-97-6)        3/0         
 "'ckel 0.11 0.21 0.13 8/8    47.6 68.4 58.0 2/2 2.2 16.1 9.2 2/2
 (7440-02-0)        3.0         
 Potush. 0.76 2.1 1.6 3/3    1,070 1,880 1,475 2/2 49.1 723 386 2/2
 (7440-09-7)     0.007 0.008 0.007 13/3         
 SelenlU11t 0 0.021 0.016 1715 0 39.7 2.43 31129 0.085 1.1 0.66 7/7
 (7182-49-2)        13/0         
 S' her        0 1.0 0.46 31118 0.13 4.0 1.20 7/7
 (7440-22-40)    3/3 0 56.2 56.2 3/1 893 1,280 1,086.5 2/2 71.5 248 163 2/2
I Sodl&lll 3.7 5.9 4.7
 (7440-23-5)    6/6    3/0 107 130 118.5 2/2 3.6 15.1 9.4 2/2
 Vanadh. 0.051 0.24 0.12   
I (7440-62-2)                 
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Table 7-1
(Continued)
MeUl
(CAS No.)
IirounclWater
Concentrattons tn mg/l
Surface Water
Mtn.
Max.
Rep.
, Ana 1 . 1
, Dd.
5011 mg/kg
Sed1.nt
Rep.
, Ana 1 . 1
, Det.
M'n.
MI..
M'n.
  , Anal.1    . Ana 1. 1
Max. Rep. ' Det. Mtn. Mn. Rep. ' DeL
257 204.5 2/2 17.9 173 95.4 2/2
0.41 0.41 2/1 0.072 0.13 0.1 2/2
l'nc
(7440-66-6)
'ha" h.
(1440-28-0)
o
0.25
0.069
11/9
0.047
0.115
0.082
3/3
3/0
152
o
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APPENDIX D
LETTER OF CONCURRENCE
COMMONWEALTH OF PENNSYLVANIA
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DA


'ENNSYLVANIA

~
. COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL ReSOURCES
-an-eau of Waste Management
Harrisburg Regional Office
<.X1e .1rarat Boulevard
Harrisburg ) Pennsylvania 17110
717"657~586

September 26) 1990
Mr. Edwin B. Erickson
Regiooal Administrator
US EPA, Region III
841 0'1es~ IiJilding
Philadelphia) PeDDsylvmia 19107
Re: Record of Decision (ROO) Concurrence
Cryoc:hem Super~ Site
Gra.ndwater Containment
Operable Unit II
Earl Towoship, Berks Qulty
~ Mr. Erickson:

'1lia Racord of Decision for Operable Unit II will address the contain-
ment) tr~~'1t, and d1scharge of the contemwted groucdwacer plUDe ~ting'
fran the Cryochem Superf\md Site.
The uajor ().I\~ts of the selected temedy inc11.X3e:
*
~letioo of a Gro.md Water'ReD8dial Design Study to deter1'nine
the exuot of the gt'CU1dwater pl\.lDe and the design ~i ~i catioas
of me 1'88i1&1 alternative.
*
Cawtructicn, loag-texm operat1.on acd uaintenance of
pumpUag/ extraction wells. located in positi.cas to adequately
remove ax1taDdnated grtUKlwater co:i cootai11 the m13ntial of the
cootaninant plUDe.
Ins1:&llal:icn, operacion, mainC8D8nC8 and treatment of the
extracted gromdwater via air stripping tar.vers, 1j:)1lOWRd by c:arboo
adaorpti.a1 as aD a:lditional trea~t step.
Installation and UlBintenance of a discharge pipe £Dr t:he treated
wacar to the oo-siu surface water tri.b&Jta'ry thac drains Sand
Hill, flows across the 'NI!$tern part of the site and eventually
discharges to Ironstone Creek ~ flows into the Manatawny ~.
*
*
1b~rl1 ~ ~~.~/ ~
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~J'= "!bl.:.J..
Mr. Edwin B. Erickson
Sept~r 26. 1990
Page 2
Regular and. periodic JJDnitoring of the treated grOU1dwater to
ensure that the remediatioa is progressing towards established
cleanup goals and that the treated ~ter IIe8C8 all required
standards .

I hereby ccacur with the EPA selecCed/proposed remedy with the folloWing
conditions and stipulatioas:
*
*
'!he Department will be provided the opportunity to oon.cur with
decisions related to subsequent operable \.I1its (OU), review acd
C'~t 00 all s~ies performed aJ: the site, evaluate appropriate
alternatives and participate in my negotiatioas with respocsil)le
parties to assure l1.ance W"ith ~ cleanup ~.

'Ihe Department will be given Che opportunity to concur with deci-
sioQs rel~8d to the design of the Remedial Action, to assure
~liance with DD. cleanup ~ and design ~ific ARARs.

'lhe Department's poseure is that its design Sf- .vyiards are /IBJ&j
pursuant to SARA Section 121, aDd 'oWe will reserve cur right to
enforce those des~ stanJards.
*
*
...
'!he Dt!rparaDmc will reserve o.Jr right and respocsibility to take
independent enforcement actions pzsuatlt to state law.

'Jh1s COI10JIT8I1Ce with the salecced r8mIId1al action f.j rx>t intended
co provide any assurances pursuant to SARA Section l04(c) (3) .
...
lD. agrees with the proposed t8m8diat1a\ wch provides th&t:
''background'' quality is the objective of the grcu1dwater reme-
diAtion plm. In the even%: that EPA modifies its positia1 a1 the
cle.amJP standa:l:d, .md deviates from ~ quality as the
standards IU. will witB:b:aw its concurrence. Ar. that: time, E1>A
D.JSt d&monstrate the impracticability of ach:i.evU1g background
quality, .md give Dm. a meaningD.1l oppottunit:y to reconcur.

Thank )OJ fer t:h8 oppott\mity to concur with this EPA Racord of
Decision. If you. haw any cpestions regarind this matter please Q:) not hesitate
to CXX'lta.ct me.
*
cc: Mark McClellan
Timothy AlexaOOer
Beth ~, Esquire
RaJO RK262. 3
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