United States
           Environmental Protection
           Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-91/112
June 1991
&EPA   Superfund
           Record of Decision:
           AVCO Lycoming-Williamsport
           Division, PA

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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2,
PAGE EPA/ROD/R03-91/112
4. Tin* and Subtitle
SUPERFUND RECORD OF DECISION
VCO Lycoming-Williamsport Division, PA
.rst Remedial Action
i. Author)*)
9. Performing Organization Name ind Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.w.
Washington, D.C. 20460
3. Recipient" • Accession No.
5. Report Date
06/28/91
6.
8. Performing Organization RepL No.
10. ProjecVTask/Worli Unit No.
11. Contnct(C) or Grsnt(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
 15. Supplementary Note*
 18. Abstract (Limit: 200 word!)
   The 28-acre  AVCO Lycoming-Williamsport  Division site  is  an  active manufacturing
   facility  in  Williamsport,  Pennsylvania.   Surrounding  land use is primarily
   residential.   The site overlies  a  surficial glacial aquifer and a deeper bedrock
   aquifer that  are used as seasonal  sources of drinking water.   Ground water  is  pumped
   from the  Williamsport Municipal  Water Authority (WMWA) well field located 3,000  feet
    outh of  the  site.   Wetlands are located near the site in the 100-year floodplain  of
    ycoming  Creek and the Susquehanna River.  From 1929  until  present,  various
   manufacturing  companies including  a bicycle and sewing machine manufacturing plant,  a
   sandpaper plant, a tool and die  shop,  a silk plant, and  aircraft engine manufacturing
   plant have been located onsite.   Possible sources of  onsite contamination include
   improper-waste disposal in a "dry  well",  laboratory chemical disposal in a  coolant
   well, spillage and dumping in metal plating areas, a  sludge holding lagoon, cutting
   oils from a  metal chipster sump,  degreasing areas, and chemical storage areas.   The
   site also contains approximately 40 underground storage  tanks that are presently
   being abandoned or upgraded.  In 1984,  the State identified VOC contamination  in  the
   WMWA well field.  In 1985, monitoring and recovery wells were installed onsite and

   (See Attached  Page)
  17. Document An*ly»ii a. Descriptors
    Record of Decision -  AVCO Lycoming-Williamsport  Division,  PA
    First  Remedial Action
    Contaminated Medium:  gw
    Key Contaminants: VOCs  (TCE),  metals  (chromium)

    b. ktentiflers/Open-Ended Terms
   c. COSAT1 Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
152
22. Price
 (See ANSI-Z39.18)
                                     See Instruction* on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
Department of Commerce

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SPA/RCD/R02-91/112
AVCO Lycoming-Wiiliamsport Division, ?A
First Remedial Action

Absr-act (Cor.tir.ued)

of.  te to identify t.-.e source of contamination, which was determined to be  the  AVCO
plant.   In 1386,  the State approved the AVCO remedial action plan, which included
installation of an air stripping system to treat water from three onsite and two
ijffsite recovery wells, and discharge to Lycoming Creek.  This  remedial action  remains
in effect.  Between 1989 and 1991, a RI/FS study was conducted to  further characterize
the contamination and source areas.  This Record of Decision  (ROD) addresses management
jf migration of contaminated ground water from the onsite area.   Remediation of  offsite
ground water will be addressed in a subsequent ROD.  The primary  contaminants of
concern affecting the ground water are VGCs including TCE and metals including
chromium.

The selected remedial action fcr this site includes pumping and treatment  of
contaminated ground water using an onsite treatment facility that utilizes
precipitation,  coagulation,  flocculation, and air stripping; treating air  stripper
off-gases  using Best Available Technology (BAT), possibly granular activated carbon or
fume incineration; dewatering and offsite disposal of residual  precipitation sludge and
spent carbon filters; discharging treated water onsite to surface water; monitoring
ground water;  and implementing institutional controls including land use restrictions.
The estimated present worth cost for this remedial action is 39,300,000, which  includes
an annual  CsM cost of :-;-;Z,300 for  30 years.

?£PFCP.MA::C£ STA::2A?i; :=. ""A12:   jrcund water cleanup standards are based  on the more
stringent  of Federal xCLs or non-zero XCLGs, or background  levels.  Chemical-specific
gr  - were net provided.

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                        RECORD 07 DECISION
                        AVCO  LYCOMING SITE

                           DECLARATION
SITE NAME AND LOCATION

AVCO Lycoming Site
williamsport, Lycoming County, Pennsylvania

STATEMENT O? BASIS AND PURPOSE

This decision document presents the selected remedial action plan
for Operable Unit One at the AVCO Lycoming Site (the site) in
Williamsport, Lycoming County, Pennsylvania which was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization act of 1986, U.S.C.
Section 9601 (CERCLA), and, to the ext'ent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan.
This decision is based upon and documented in the contents of the
Administrative Record.  The attached index identifies the items
which comprise the Administrative Record.

The Commonwealth of Pennsylvania has reviewed, commented upon,
and concurred in this decision.

ASSESSMENT OF THE SITE

Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, that actual or threatened
releases of hazardous substances from this Site, as discussed
under Summary of Site Risks  in this document, if not addressed
by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.

DESCRIPTZOM OF TEX REMEDY

The remedial action plan in this document for Operable Unit One
is presented as the permanent remedy for containing, recovering
and treating the onsite ground water contamination at the Site.
Under this remedy, ground water recovery veils would be  installed
on the downgradient side of the facility to contain contaminated
ground water and thus control further offsite migration.  The
contaminated ground water will be recovered through a series of
existing and newly installed recovery wells, with the long-term
goal of returning the ground water to its most beneficial use.
This remedy also provides for additional protection by

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implementing institutional centrals in the form of limiting
future property use to these activities compatible with site


This remedy is for Operable Unit One and only addresses the
onsite contaminated ground water.  The offsite contaminated
ground water plume will continue to be remediated through the
existing offsite reccvery-ar.d-treatment systems, as required by
the Consent Order and Agreement between AVCO and the Common-
wealth of Pennsylvania.  This offsite plume will be discussed in
a separate operable unit.  Additional studies will be performed
for this offsite operable unit to determine the most appropriate
action to be taken by EPA in a future Record of Decision.

STATUTORY DETERMINATIONS

     Pursuant to duly delegated authority, I hereby determine
that the selected remedy is protective of human health and the
environment, complies with Federal and State retirements that
legally are applicable or relevant and appropriate to the
remedial action, and is cost-effective as required under Section
121(d)  of CERCLA, 42 U.S.C. Section 9621(d).  With respect to a
principal threat at the site, the contaminated ground water, the
remedy satisfies the statutory preference, as set forth  in
Section 121(b) of CERCLA, 42 U.S.C. Section 9621(b), for remedia
actions in which treatment that reduces toxicity, mobility, or
volume is a principal element.  Finally, it is determined that
this remedy utilizes permanent solutions and alternative
technologies to the maximum extent practicable.

     Because this remedy will result in hazardous substances
remaining onsite above health-based levels, a review will be
conducted within five years after the commencement of the
remedial action to ensure that human health and the environment
continue to be adequately protected by the remedy.
Edwin B. EricJcson                   Date
Regional Administrator
Region III

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                        RECORD OF DECISION
                        TABLE OF CONTENTS
                                                       Page

I    SITE NAME, DESCRIPTION, AND LOCATION               1

     A.   Site Name and Location                        1
     B.   Site History and Enforcement Activities       l
     C.   Highlights of Community Participation         3
     D.   Scope and Role of Operable Units              9
     E.   Site Characteristics                          9
     F.   Nature and Extent of Contamination           23


II.  SUMMARY OF SITE RISKS                             45

III. DESCRIPTION OF ALTERNATIVES                       68

IV.  COMPARATIVE ANALYSIS OF ALTERNATIVES              73

V.   DESCRIPTION OF THE SELECTION REMEDY               78

VI.  STATUTORY DETERMINATIONS                          80


                           ATTACHMENTS

     A. Responsiveness Summary

     B. Administrative Record Index

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  Sire Description ar.ci Sur-T.ary of Remedial  Alternative  Selection
               for the AVCO Ly com ing Superfur.d Site
           Wi Ilia-sport , lyccr.ir.g County, Pennsylvania
     The  AVCC  Lyooning Site  is  an  active manufacturing facility
located  at 552  Oliver Street in Williamsport,  Lyconing County,
Pennsylvania (Figure 1) .   Williamsport is situated in a valley that
is  located in  the Valley and  Ridge  Physiographic  Province.   The
site is approximately 23  acres in size with about 35 percent of the
property  covered  by buildings  or pavement.  The ziajor topographic
feature  in the vicinity of the site  is a  steep ridge to  the north
that rises to  a  height of approximately 210 feet above  the site.
The elevation of the site is approximately 545  feet above mean sea
level  (MSL) .   The  elevation of  the Susquehanna  River,  which is
about 5,000 feet south of the site,  is approximately 510  feet MSL.
The 35-foot change  in  elevation  between the site and the river is
gradual,  with a  grade  of  approximately 0.7 percent.

     The  area surrounding the  site  is primarily residential.  Two
public  parks,  Memorial Park and Elm Park,  are located  south and
southwest  of the site, within the  residential area.  These parks
contain  baseball  fields,  a  public  swimming pool,  skateboard park
and playground.   Along the  southern boundary of the park area is
the Conrail  Railroad  track  which runs  east-west across Lyconing
Creek.   Lycoming Creek flows  south  and is located  approximately
2,000  feet southwest  of  the  site.   The creek drains  into the
Susquehanna  River.    The  Williamsport  Municipal  Water  Authority
(WMWA) well field is approximately  3,000  feet  south  of the site.

     Surface water in the vicinity  of the  site,  including Lycoming
Creek and  the Susquehanna River, is  used  for recreation  and water
supply.   In the  Williamsport area,  the primary supplier of water
is  the  WMWA  which  obtains  most  of  its water  from surface water
reservoirs located  on  the opposite  side of the Susquehanna River
south of  Williamsport.  The WMWA also  uses a well  field, located
east and vest of  Lycoming Creek,  as a water supply.  The veil  field
consists  of nine  veils dug  into  the  glacial and alluvial deposits
in the Lycooing Creek Valley.  The  veil  field is used primarily in
the summer months as  a backup supply vhen the reservoir yield is
low.


Site History and  Enforcement Activities
          t
          The Aviation Corporation  vas  incorporated in  1929.  In
1935,  the Aviation Manufacturing  Corporation, a subsidiary company,
was established under which the Williamsport Lycoming Division was
formed.    By  1939,   the   Aviation  Corporation  had purchased the
majority  of the  present site property.

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               Figure   1
          Site Location Map
Textron Lycoming, Williamsport, Pennsylvania
                      TEXTRON
                       PLANT
                  SOUICB: U3QS TooogripMe Quadringto. 7.5 Mktut* S«i«s;
                      SUM.  VWI W M-Md -9«
                                   ORIGINAL

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     In July  1344,  during  Wcrld  War  II,  part of the facility was
constructed conjunctively by the  Cefer.se  Plant Corporation and the
Aviation Corporation  for use as an  experimental "laboratory.   On •
January  22,  1947,   the  Aviation  Corporation granted part  of the
property  to   Reconstruction  Finance   Corporation,   the  parent
Corporation of Defense Plant  Corporation, in exchange for financial
aid for further facility expansion.  This property was subsequently
acquired by  the United States of America  by quitclaim  deed from
Reconstruction  Finance  Corporation on May 25, 1943.  In November,
1950,  an Air Force contract was negotiated  between AVCO and the
U.S. Government to  consolidate  the use of various machine tools and
the laboratory  test building.  At this time, part of the facility
was owned by the U.S. Government who leased  it to AVCO.

     On April 23,  1947,  the  Aviation Corporation changed its name
to AVCO Manufacturing Corporation, which subsequently changed its
name to AVCO Corporation on April 20,  1954..  On  December  15,  1961,
the property  and plant  were  determined to be surplus property by
the General Services Administration and were granted back to AVCO
Corporation.

     In  February  1935, AVCO  Corporation,  which  included AVCO
Lycoming, Williamsport  Division, was acquired by Textron, Inc.,  a
Delaware corporation based  in  Rhode  Island.    AVCO  Corporation
maintains the status of  a wholly-owned subsidiary of Textron.

     Portions  of  the  AVCO  Lycoming  Site  were  first  used for
manufacturing   purposes   around  the   turn  of   the   century.
Manufacturing operations consisted of a bicycle  and  sewing machine
manufacturing facility, a sandpaper plant,  a tool  and die shop and
a silk plant.  During the 1920s, the property was purchased by AVCO
Corporation and operations  focused primarily on the manufacture and
repair of aircraft engines.    Prior  to 1940, automobile and boat
engines were also  produced at  the facility.

     Past  waste disposal  practices  at  the site  are  not well
documented.   Several potential  areas  of  concern or source  areas
were identified through employee  interviews,  employees' general
knowledge of plant history and aerial photographs.   These areas of
concern  include a  "dry wall",  coolant water  wall,  past plating
areas,  a temporary sludge  holding lagoon, chipster (metal  chips)
sump, degraaaing areas  and chemical  storage  areas  and underground
storage  tanJca  (Figure  2,  Tabla 1).   These  areas are  described
briefly in tha  following paragraphs.

     The dry wall,  it is believed, consisted  of an old septic basin
from a house that  may have existed on  tha  property  at the  turn of
the century.  The  dry wall was located in  the  center  of  the plant
property and its depth is unknown.  It has been reported that waste
disposal in this well was a common practice until it was sealed in
the 1950s.   The well  has sinca been  covered over with a roadway.

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              Figure  2
     Potential Areas of Concern
Textron Lycomlng, Wllilamaport, Pennsylvania
                                                     14
                                                  	I
                                                           ,n*f


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                            index
        PotsntUI Artas of Concam, T«xtron  Lycommg,
                 Wllllimtoort.  Pennsylvania
                        723-01-01-01
      Location of past or present iegreaser unit.
 2.    Waste-water  treatment area and location of former lagoon
      ;since closed).
 3.    Former plating and heat treatment area, dirt Qoor in past.
      Nltrtter  and cyanide furnaces located  here in  tie  past.
      Chrome,  cadmium,  nitrnter furnaces,  cyanide  base
      solutions.
 4.    Former  drum and  chemical storage  areas  for oil  and
      chemicals.
 5.    Location of 1.000-galion ammonia tank,  -ince removed.
 6.    TCE distilling area, possible spillage in past plating area.
 7.    Paint spraying booth.
 8.    Area of engine  and  engine part  washing  and  steam
      cleaning.
 9.    Drums of carbon tetrachionde stored here in past.
 10.   Former heat-treating and plating area.
 11.   Past impregnating room • 1940s.
 12.   Former area of transformer, oil drained once in 1950s.
 13.   Plant deep well, drilled in  1929 (approximately )  and used
      for cooling water, and presently as Recovery Well  RW-2.
 14.   Former gunk room, earty 1950s.
 15.   Put porous chrome plating area.
 16.   Former coolant wen location, where waste residuals from
      the lab an reportad to haw been washed down.  Drilled  in
      1930s and sealed tn the 1950s.
 17.   Former "dry wtfl": sump  of unknown  depth into  which
      wasts  materials were reportedly disposed.
 18.   Past  area of perforated  concrete  floor  for drainage  •
      possdbijr drained, onto dirt.
 *9*   s^BflC 4%
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     During  the   1930s,   a  coolant  water  well   was   drilled
approximately 200  feet  north  of the dry well.   Although  no well
leg exists to verify  its depth, this well  is  suspected to have been
about 100 to 150 feet deep.  Due to its proximity to the chemical
laboratory, it  has been  reported that waste  residuals from the lab
may  have  been  washed  down the  well.    This  coolant  well  was
abandoned and sealed in the 1950s.

     The past plating areas are  of concern as a result of cadmium,
chromium, copper,  tin,  lead,  nickel  and  black  oxide plating that
took  place over  the  years.   The plating  process  at  the  plant
involves three steps.   First  the engine  parts  are degreased with
a solvent [usually trichloroethylene (TCE)],  then the parts undergo
an acid rinse,  and finally each part undergoes a specific plating
process.  The acid rinse waters and plating wastes are then treated
in the on-site Waste Water Treatment  Plant  (WWTP).   In the past,
plating operations took place mainly  in  the northwest portion of
the plant.   In  one plating area there was  a dirt floor for many
years.   This floor was  paved in  the  early 1950s.   The  plating
operations in this area ended in the late 1960s.

     The  temporary  sludge holding  lagoon  was  located  in  the
northwest section of the property.  For approximately 3 or 4 years
during the 1950s,  this lagoon was used to hold sludge from the WWTP
located in the same area.   The  lagoon was  lined with plastic and
was approximately 25 feet wide and 10  feet deep.  Sludge from this
lagoon was eventually shipped off-site for disposal  and the  lagoon
was filled with native materials.  Present plant  operations, which
involve plating,  waste water treatment and sludge handling,  are in
accordance with state and federal regulations.  Plating operations
have since moved  to  a  new area of the plant and the old WWTP is
being phased out while a new WWTP  is being  phased into operation.
Sludges  from  the  WWTP,   used   solvents and  other  wastes  are
transported off-site for disposal  or reclamation.

     The  concrete chipster sump  is being used  for  collecting
cutting  oils from metal  scraps  stored  for recycling.    It is
approximately 200  feet  vest of  Monitoring  Well  5 (MW-5),  and may
be a past source area for organics as at  one time it was also used
to evaporate solvents.

     Other potential source areas are locations where degreasing
took  place and  areas  of chemical  storage.   Solvents  used in
previous degreasing locations are  known to  have  leaked or spilled
on the  plant floor possibly  entering the  plant sever system or
other areas of the plant.   Chemical storage existed primarily in
areas vhere they vere used for manufacturing processes.  Temporary
chemical storage  areas  vere also  located in the east end  of the
plant, and near the experimental laboratory  in the north end of the
plant.

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                                                    Many of these*
tanks  have  been taken cut of  service  and  are  being abandoned or
upgraded  in   accordance  with  underground  Storage  Tank  (UST)
regulations.   The  AVCO Lvcoaing Site is a generator of hazardous
waste  in  accordance with the  Resource Conservation and Recovery
Act (RCRA).   However,  because the waste generated is  stored on site
for less  than  90 days  a RCRA Part 3 permit is not required.

     In 1934,  volatile organic  compounds  (VOCs), specifically TCE
and 1,2-trans-dichloroethylene  (CCE),  were discovered in the'wMWA
water  supply  well  field located south  of  Third Street.   After a
sore comprehensive analysis of the ground water by the WMWA for an
expanded  list  of VCCs, it was  confirmed  that TCE and DCE were the
primary compounds of concern in the well field.   The WMWA notified
the Pennsylvania Department of  Environmental Resources  (PADER) of
the  situation  and'   in  November   1984,   PADER   informed  site
representatives  of the problem.   In  December  1984,  and January
1985,  an investigation was conducted by PADER and included ground-
water  sampling from wells in the WMWA well  field, other accessible
wells  in the area and a well on the site property.   The  results of
this investigation led PADER  to  suspect that  the  source  of VOC
contamination  was  the  AVCO Lycoming Site property.

     During   1935,  Chester   Engineers  conducted  a  remedial
investigation  at the  request  of AVCO Lycoming representatives.
This investigation included  the installation of on-site and off-
site monitoring wells  and  on-site ground-water recovery wells.
During the  investigation,  reports were  submitted to  PADER.   The
results of  this investigation  revealed  that contaminants in the
overburden aquifer beneath  the site were migrating from the site
in a southerly direction.

     In November 1985, a Consent Order and Agreement (COA)  was
entered between  PADER and the  AVCO  Corporation through its AVCO
Lycoming  Division.  The  COA required that a Remedial Action Plan
be developed  to  continue the remedial investigation to determine
the extent of contamination, identify and implement the appropriate
remedial action in contaminated areas and to  continue ground-water
monitoring to  define the progress of  the remedial activities.  In
May 1986, PADER  approved the Remedial Action Plan  which included
ground-water recovery  from 3 on-site recovery wells  and 2 off-site
recovery wells.  Treatment of this recovered ground  water is being
performed through air stripping.    The treated ground water is
discharged to  Lycoming Creek under a  National  Pollution Discharge
Elimination' System Permit.   The emissions from the air stripping
towers are In compliance with the criteria deemed acceptable at the
time they were reviewed.  The approval of the Remedial  Action  Plan
also includes quarterly  ground-water monitoring.   The  remedial
action as required by  the COA  remains in effect.

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     On January 22,  1987,  EPA  proposed  the AVCO Lycoming site en
the sixth update of  the  National  Priorities List.   Textron Inc.,
the parent  corporation  of AVCO Lycoming,  was  notified  by letter
from EPA on July is, 1987, that the Agency intended to conduct or
oversee a Remedial Investigation and Feasibility Study (RI/FS) at
the AVCO Lycoming Site.   Through this general notification letter,
EPA also requested  information pursuant to provisions of Section
104(e) of CERCLA, 42 U.S.C.9604(e),  and/or Section 3007  of RCRA,
42  U.S.C.   6927.    On  October  2,  1987,  a  response  to  the
notification/104(e)   information  request letter  was sent  by  the
Textron  Lycoming  Division  (formerly  AVCO  Lycoming)   of  AVCO
Corporation to EPA expressing a willingness to participate in the
RI/FS.  A second response  was  submitted on October 5, 1987,  that
included referenced  documents  in response  to  EPA's questions in
the letter.

     The AVCO Lycoming Site was placed  on  the National Priorities
List (NPL)  on February 12,  1990,  having  a score  of  42.24.  Between
1989 and 1991, an RI/FS was conducted by AVCO Corporation through
its Textron  Lycoming Division,  under the guidance of EPA and PADER.
The RI/FS was  performed  in accordance  with  a  COA  signed in June
1988,  between AVCO and EPA.  The RI/FS  was conducted to  identify
the types,  quantities and locations of contaminants and to develop
ways of addressing the contamination problems.  The RI included  a
risk assessment that determined which of the contaminants  detected
posed  a  risk  to human  health  or the  environment.    A Summary
Chronology  of  activities and enforcement  history  at  the site is
presented in the RI.


Highlights of Community  Participation

     The RI/FS, Proposed Plan and background documentation for the
AVCO Lycoming Site were made available  to  the public  on April 17,
1991,  in the local information and administrative record repository
at the James V. Brown Library  of williamsport and  Lycoming County
located in williamsport,  Pennsylvania.   Notice  of the  availability
of  these documents,  of  a  public comment period, and  a public
meeting was published in The williamsport Sun-Gazette  on April 17,
1991.    The  public  comment period was  held from  April  17,   1991
through May 16, 1991.  Additionally, a  public meeting was held at
7:00 P.M. on May 2,  1991,  at the Sheraton Hotel in Williamsport.
At  this meeting representatives  from EPA  and  PADER  answered
questions   about  the   AVCO   Lycoming   Site  and  the   remedial
alternatives under  consideration and accepted comments  from the
attendees.'  A  transcript of the  public meeting was maintained in
accordance'  with  §117(a)(2)  of  CERCLA,  42 U.S.C.  §9617(a)(2).
Written  comments  received  during  the   public  comment period are
addressed in the Responsiveness Summary which  is an attachment to
this  Record of Decision (ROD).    The   above actions  satisfy the
requirements of Sections 113(k)(2)(B)(i-v) and 117 of CERCLA, 42
U.S.C. §§9613(k)(2)(i-v)  and §9617.   All  documents that  form the

                                8

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basis for the selection cf the remedial decisions contained  in this
ROD are included in the Administrative Record for this site  and car
be reviewed  cr  referred to for additional information.
Sccce
     This  is the first remedy proposed by EPA for the AVCO Lycoming
Site.  However,  contaminated  ground water on-site and off-site is
currently  being recovered,  treated and monitored in accordance with
a  November 1935,  CCA between PADER  and AVCO Lyconing.   The scope
cf  the  remedy in this RCD  for Operable  Unit  1 (OU-l)  will be to
address  the  en-site contaminated  ground  water.   There  was  no
principal  threat  identified at the AVCO  Lycoming  Site.

     Ground-water contamination is the media of concern at the AVCO
Lyccning Site.   Contaminated ground water exists on-site and has
migrated off-site as far  south  as the  WMWA well field.  The goal
of the remedial action described  in this  ROD will be  to  recover on-
site contaminated ground water and restore the ground water  to its
beneficial  use,  which is  a potential drinJcing-water source.  The
off-site contaminated ground water  will continue to be  recovered
and  treated through  the existing system installed  in accordance
with  the  COA  between  PADER and  AVCO  Lycoming.    However,  the
existing off-site ground-water recovery and treatment system needs
rr.cdif ications to recover a  greater portion of the contamination and
reduce the remediation time frame, as well as  to provide  a greater
level of protection to the WMWA well field.  Therefore, the off-
site ground-water contamination  will be a separate operable unit
(OC-2) to  be  addressed by  EPA in a  future  ROD.  This future ROD
will be based on additional studies.
Summary of Site Characteristics


     Geology

     The geology in the area of the AVCO Lycoming Site consists of
unconsolidated  valley  fill  deposits  of  Quaternary  Age  and
consolidated bedrock of Devonian Age.  A description of these units
is provided below.


     Unconsolidated Valley  Fill  Deposits

     The AVCO Lycoming Site is located at the northeastern edge of
the glacial  floodplain formed along  Lycoming Creek and the  west
branch  of the  Susquehanna  River.    Unconsolidated alluvial and
glacial deposits  (consisting of sand, gravel, cobbles,  and small
boulders  with  relatively  minor  amounts  of   silt   and clay,
collectively termed "overburden")  underlie the floodplain and lie

-------
on bedrock.   Some clayey sands and silts were  noted  in isolated
areas of the  site at the time the drilling  was performed during
the RI.  The  thickness of the overburden ranges  from  16.5  to  30
feet beneath the AVCO Lycoming Site and thickens as the topography
slopes  toward Lycoming  Creek and  the  Susquehanna  River.    The
overburden thickness is related to the elevation of the underlying
bedrock.  In general, the plant is situated at the base of steeply
sloped  terrain to the north and  is located  on  top  of  a "bedrock
high,"  that  "drops-off"  to the southwest, south,  and  southeast.
This bedrock high extends from the southwestern section  of the Site
to the  Elm Park Area.  The southwestward extension of the bedrock
high forms a  "ridge" oriented northeast/southwest.

     Because  of  the  configuration  of  the  bedrock  surface,  the
thinnest  overburden  is   found  at  the  north  end  of   the  plant
(approximately 16 to 20 feet thick),  and  in Elm  Park along the top
of the northeast, southwest-trending ridge (approximately  14 to 18
feet  thick).     The  presence  of  the  bedrock  high   results  in
overburden thicknesses that are somewhat uniform beneath the Site
ranging  from  25  to  35  feet beneath most of the property.   The
overburden thickens considerably along  the eastern  and  western
edges of the  study area,  and towards the Susquehanna River to the
south.  The thickness of the overburden varies somewhat across the
site property.  The thinnest section of the overburden  beneath the
plant was 16.5 feet in soil boring SB-1  at the  far west end of the
site.   The thickest  section is 37.5 feet observed in MW-9 in the
eastern end of the Site.

     In the western  portion of the  site,  overburden was found to
increase in thickness in  a southwesterly direction towards Lycoming
Creek,  from  a minimum  of  16.5  feet near SB-1 on the far west
portion of the site  property to  a maximum of 48 feet  in MW-71 in
Memorial Park.  In the eastern section of  the site, the overburden
is thickest towards  the  southeast from the plant  facility ranging
from approximately  30 feet (near MW-8, MW-7 and MW-6) along the
site's south and  southeastern boundaries to 60 feet in the vicinity
of MW-66 and  MW-67.   This thickening is a result of a rather abrupt
drop  in bedrock elevation  in  this area.    Continuing  in  the
southeasterly direction,  the overburden thins  to 40  feet in the
vicinity of KW-73.   This area southeast of the site,  between MW-
66 and MW-73, is apparently a trough-like elongated  (low) area in
the bedrock with  the result that overburden thicknesses are greater
in this area.

     The overburden  beneath the  site consists of unsorted  (well-
graded) alluvial  and glacial deposits.   The material  ranges  from
silty  fine1 sand  to large,  rounded to sub-rounded  boulders and
displays a'high variability  in grain size of the matrix material.
The overburden appears to become more uniform  in the south  end of
the site, but the distribution and  frequency of pebbles and large
boulders increases.   In the vicinity of  the old Human Resources
building, borings  indicated well-sorted  (poorly  graded),  uniform

                                10

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aediua grained sand and silt,  to a depth of up to 7 feet indicating
that  fill  aaterial was probably used  during the  construction  of
this building.   in addition,  fill aaterial was evident in aany  ct
the  upper  portions   (less  than  3   feet)  of  the soil  borings,
consisting of brick,  concrete, asphalt and "factory fill aaterial."

     The overburden deposits south of the site become more unifora
and  less  variable  in coapcsition.    The  deposits  consist  of
unconsolidated fine to coarse  sands and gravels with some sandstone
and shale pebbles. Closer to the Susquehanna River, acre clays and
silts are  evident in boring logs  obtained from  U.S.  Aray Corp  of
Engineers.   In some  cases,  the  clays were  reported  to  have the
appearance of glacial  tills, but did not appear to be continuous.


     Bedrock

     Bedrock  strata   in  the study  area are  units  of  the  Upper
Devonian Period.  From oldest to youngest, they are the Marcellus
Formation,  the  Mahantango  Formation,  the  Harrell Formation, and
the  Brallier  Formation.   The Marcellus  Formation  underlies the
lower portion of  the WMWA  well  field,  near the northern boundary
of the Susquehanna River.  The formation consists of carbonaceous
shales  with thin  beds of  soft  clay.    The  Mahantango Formation
underlies the area east and south of the site.  With the exception
of the Tully Member of this  formation,  the Mahantango  Formation is
comprised  primarily   of  interbedded   silty  shales  and  shaley
siltstones.  The lime-rich units of the Tully member mark the upper
200 feet of the  Mahantango Formation and are the  units  of principal
concern  in terms of  ground-water conditions in  the  study area.
This unit underlies approximately  60 percent of the plant property.
The Tully  Member consists  of variable thicknesses of interbedded
limestone and shale.   The Harrell Formation  underlies the western
most portion  of  the  site  area and  is a  homogeneous shale with
scattered  thin  beds  of  laminated  silty shale.   The  Brallier
Formation   underlies the  area  northwest  of  the  site.    This
formation consists of  interbedded siltstones and  silty shales.   A
generalized geologic section for the site is presented in Table 2.
The configuration of the buried bedrock surface based upon the RI
and previous investigations is presented  in  Figure 3.

     The  most distinct  features  are  the  presence  of  a  buried
bedrock  ridge,  generally oriented parallel  to  the  strike of the
limestone  in the  Tully Member and an adjacent bedrock low toward
the south  also  paralleling strike.   Soft,  black clayey shale of
the  Harre^l  Formation  overlies  (stratigraphically)   the   Tully
Limestone  to  the northwest, and Mahantango  gray  shale  is the
underlying' lithology which  occurs  in  the  subsurface toward the
southeast.  The bedrock, high beneath the site and the bedrock ridge
extending  southwest  from the plant  is the result of the greater
resistance to weathering and erosion exhibited by the  limestone in


                                11

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                                                                   Tahle  2
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-------
                Figure  3
            Bedrock Topography
               Textron Lycoming
               Williamaport, PA
                                  I   [AM SPORT
Coraur (T««)
                              POOR QUALlT
                                 ORIGINAL

-------
contrast to  the  surrounding shales.   The  buried  bedrock surface
slopes downward to the west  and  southeast from the limestone high.

     The bedrock geology in  the  Elin Park area, as interpreted from
the bedrock  well  legs  and core  logs,  consists  of  a  thin layer of
weathered  lime-rich  shale,  approximately  5  to  10 feet  thick,
overlying the  dense shaley  limestone of the Tully  Member  of  the
Mahantango Formation.  Soft  zones in the  limestone were encountered
during drilling of both MW-59 and MW-60.  These are consistent with
the presence of thin shale units which are  often encountered in the
Tully  Member.   These  shale zones were  often  water bearing  and
tended to decrease  in number with depth.


     Hydrogeology

     There  are  two  primary  aquifers   in the  site  area;  the
overburden and bedrock aquifer systems.   The  shallow  overburden
aquifer  is  comprised of the Quaternary  unconsolidated deposits.
The overburden is  a water-table aquifer.   There are currently 45
monitoring wells  completed  in this aquifer in  the site area,  and
3 recovery wells.   Recovery  Wells RW-3 (Acid Waste)  and RW-l (Tank
Building) are  completed  across  the overburden/bedrock interface.
The  Third  Street  Recovery Well  is  screened entirely  in  the
overburden.

     The underlying bedrock aquifer   consists of  upper to middle
Devonian-age rocks,  including shales, siltstones,  and limestones.
Ground-water occurrence  and movement is  controlled by secondary
porosity  (e.g.  fractures,  bedding planes).   Eighteen  monitoring
wells and eight rock cores  have been drilled within the bedrock.
The plant deep well (RW-2),  located  in  the test cell area of the
eastern portion of  the site has a measured depth  of 390 feet and
is presently used as a recovery veil.  The  Elm Park recovery well
recovers ground water from  the  shallow bedrock in Elm Park.

     The following  sections describe  the physical characteristics
of the overburden and bedrock  aquifers.   Because  the  units have
differing characteristics,  the  mechanisms governing ground-water
flow and contaminant migration  are different.   Each unit acts as
a  separata  aquifer,  although  they  are  hydraulically  connected.
The locations  of  the wells  described above are in Figure 4.  The
construction details of these veils  are summarized  in Table 3.
     Overburden Aquifer
          i

     Ground water  in  the shallow aquifer occurs under unconfined
conditions.  The depth  to ground water ranges from 10 to 27  feet
below grade at the site (August 1990),  and 9 to 25 feet near the
WMWA well  field.    The  system is  recharged by precipitation and
snowmelt.  Seasonal fluctuations of up to approximately 5 feet have

                                14

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        Figure
Monitoring Weil Locations
      Textron Lycoming
      Wllliamaport, Pa
                     POOR QUALITY
                       ORIGINAL

-------
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been  observed  in the  water  table  beneath the site at  veil  w-i
where  -he  overburden unit is thin.  Ground  water  in  the shallow,,
aquifer flews through interstitial voids in the sedi-ent, primarily^
in a southerly direction with =inor components toward the southwest
and southeast  /Figure  5).  The hydraulic gradient in this area is
largely controlled by the  surface and underlying bedrock topography
'see  Figure  2;.

      Weil  yields  in  the valley  fill deposits in the williansport
region average  300 gallons per minute  (gpn).   The highest yields,
up  to  2 , 300  gpm,   are  obtained  from  wells drilled  near  the
confluence  of   south-flowing  streans  and  the  Susquehar.na  River,
where  overburden deposits are  relatively thick.   The hydraulic
gradient has been measured at approximately  0.02 feet/foot in the
vicinity of  the plant,  but  this gradient flattens to  the south
before reaching the Susquehanna River due  to the  presence  of a
bedrock high in  the  subsurface beneath the plant.

      The  point  of   lowest  hydraulic  head  in  the  area  is  the
Susquehanna  River.   Lycoming Creek and the  Susquehanna River are
the boundaries  of the  hydraulic  systems and  tend to act as points
of  ground-water  discharge  in  the  regional ground-water   flow
pattern.    Ground water in the overburden aquifer moves primarily
south toward the Susquehanna  River.  The ground-water flow velocity
increases as it approaches the river as indicated by data obtained
from recovery well aquifer testing.  Lower hydraulic conductivities
near  the plant  probably limit the  natural ground-water flow  rate
to less than one foot per day.   Hydraulic conductivity is higher
at the WMWA  well  field, where natural  ground-water flow rates are
on the order of  five  to ten  feet per day.


      Relationship between Lycoming  CreeJc  and Overburden Aquifer

      During  the RI  investigation,  efforts  were made  to  better
understand  the  hydrologic   relationship  between  the overburden
aquifer and  Lycoming  Creek  in  the site  area.   A  total  of  five
piezometers  were  installed  in Lycoming Creek, one at each of the
five  surface water  and sediment sampling stations.   Streamflow
measurements ware takan at each of the stations to obtain discharge
measurements along various portions of the stream.  Elevations on
five  of   tha  bridges  vara   also  surveyed  and  marked for  the
collection of stream  alavations  along  Lycoming Creek.

     The stream flow and piezometer data generally indicate  that
the upper' portion of tha stream,  abova the  High  Street Bridge
(Station  5), is  a   gaining  stream  (i.a.,   receives  ground-water
discharge).   In contrast,  between Station  4,  near tha Memorial
Avenue bridge,  and  Station  2, near Third Street,  Lycoming Creek
appears to be  a losing  stream  (i.e.,  recharges  the  overburden
aquifer) .    This change  is  a response to  pumping  from the Third
Street recovery well which  pumps continuously at an  average  rate

                                19

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    Figure 5
Water Table Surface
Overburden Aquifer
    August 1990
   Textron Lycoming
                       WILLIAMSPORT
            POOR QUALITY
              ORIGINAL
                                     800

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of  900  to 1CCC crpa.   Since the overburden aquifer  north  of thf
Third  Street Recover/  Well cannot provide  the total  voluae ~c:
ground water puaped  oy  this well, the additional water flowing to
the  well  comes frcm Lyccair.g  Creek and  the  overburden deposits
located northwest of this well.  Lyccair.g Creek becoaes a gaining
stream again south  of Station  2 as  it leaves the area influenced
by the recovery well and approaches the Susquehanna River.

     Water  levels  in the  lower  portion of  Lyccming  Creek are
affected when the WMWA wells are pumping,  as interpreted fron past
WMWA water  level  data.   This  suggests  that  the lower segr.ent of
Lycoaing Creek becor.es  a losing streaa  in response to the pur.ping
of  the WMWA  wells.    The WMWA  wells were  not  in operation  at the
tir.e that the streaaflow and piezcaeter measurements were taken.


     Bedrock Aquifer

     Ground-water flow through the bedrock aquifer  is  important in
developing an understanding of contaminant  migration in the site
area.  Ground-water  movement  in the bedrock is not controlled by
shallow hydraulic gradients as in the  overburden, but  by secondary
features  such  as  solution  features,  jointing,  fracturing, and
orientation of bedding  planes.  Though  southeast is the direction
of the hydraulic gradient within the bedrock aquifer,  the direction
of ground-water flow is primarily southwest,  along the strike of
the bedrock.   This   is based on both  the  recovery test and  water
quality data.  Water-level measurements for  the  bedrock monitoring
wells from August 1990,  are presented in Figure 6.  The depth to
ground water  for  the bedrock  wells on  and  off the site property
(October 1990)  ranges from  17  to 28 feet  below  grade.

     Ground  water yields  in  the  bedrock aquifer  are variable,
ranging from less than  1  gpm  to  about 40 gpm from the bedrock
beneath  Elm Park.    Area  wells  drilled  in the  shales  of the
Marcellus,  Mahantango,  and  Harrell   Formations  tend to   yield
moderate supplies of water.  Wells  are  typically constructed with
shallow casings  and  large,  open intervals to  intercept  as many
water-bearing zones  as  possible.  Yields  range  from  12 to 355 gpm
in  industrial  and public supply wells  in the area.   The average
yield is  52  gpm.   The  median  well  depth  for these formations  is
137 feet.   Siltstones,  which include  the  Brallier  Formation, tend
to be the  area's  poorest aquifers, with  a  median yield of  6 gpm
and median depths of 153 feet  for domestic wells and  400 feet for
non-domestic wells.
          t
     The Tully Member of Mahantango formation,  which  underlies  60
percent  of  the  plant,  consists  of  variable   thicknesses   of
interbedded  limestone  and  calcareous  shale.   These  units are
relatively impermeable  due  to  their fine-grained,  compact  nature,
however,  the  lime-rich units  are  susceptible  to dissolution and
exhibit numerous solution features, especially  within the  upper

                                21

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                       Figure  6
         Bedrock Aquifer Ground Water Levels
                   27 August, 1990
                    T«xtron Lycoming
                    WHIIamsport, PA
                                    WILLIAMSPORT
                                                  800
NHVKI
POOR QUALITY
  ORIGINAL

-------
weathered  zcr.e.   This weathered  zone  exists  where the lime-rich
units  cf  the  Tully  underlie,   ar.d  are  in   contact  with,  tht
overburden.  The solution features present within the Tully member
do  not  occur  in  the adjacent  ncn-calcareous shale  ur.i'ts,  but
fracturing,  jointing,  and bedding planes  are cordon to both types
cf bedrock and can  be  primary routes of ground-water flow.
     During   the   Chester  investigations,   packer  testing  was
conducted on boring 55A to determine permeability at varying depths
within  the  upper 50  feet cf  the Tully member  cf  the Mahantango
Formation.   These tests  indicated  that hydraulic conductivities
range from  1.0  <  10'3 centimeters per second close to the bedrock
surface to less than 1.0 x 10'* centimeters per second  deeper  in the
bedrock .


     Relationship between Overburden and Bedrock Aquifers

     Vertical head relationships between the overburden and bedrock
aquifers  were  examined  from  water-level  data  collected  during
November  1939,  August  1990,  and the recovery  test  conducted  in
September 1990.  The overall vertical head differences in the study
area were small with  the  exception of the wells  in Elm  Park area.
An upward vertical gradient is  consistently measured  at  well nest
MW-60 and MW-32.  This suggests  that the bedrock aquifer  discharges
into the overburden aquifer in the vicinity of the wells. The fef
overburden  wells along  the  bedrock  high  limit  the  ability   t~
further delineate this discharge area,  however,  contaminant- trends
indicate that ground water most likely discharges from the bedrock
high into the overburden beneath Elm Park.   The operation of the
Elm Park Recovery Well may also help induce the upward gradient  in
this area, though it  is not possible to evaluate  this effect with
the data  collected  to  date.   However,  the  concept fits with the
interpretation  developed  for ground-water  flow  from  the  bedrock.


Nature and Extent of  Contamination

     Since  1985 whan VOCs were first identified  in  ground water,
numerous  sampling events have  been  completed beginning with the
investigation by Chester, followed  by  bi-monthly sampling until
1933, at which time quarterly sampling was initiated  and continues
to the present.  The  two  RI sampling events were completed  during
the routine quarterly sampling  program.
         t
     The comprehensive ground-water sampling and analysis conducted
during the Chester investigations indicated the presence of certain
vocs and metals  in  the ground  water  near  the  old WWTP.   Chester's
initial ground-water sampling event included Priority Pollutant VOC
analysis  by  GC/MS  analytical  methods  and  selected  inorganic
compounds.  The  primary compounds of  VOC  contamination found  wer


                                23

-------
TCE and DCE.  Subsequently, the quarterly ground-water monitoring
focused on these compounds.

     The November 1939, sampling  event  conducted  for  the  Phase  I
RI included the Target Compound List (TCL)  of VOCs and semi-VOCs,
Target Analyte List  (TAL) Metals, Pesticides,  PCBs  and Cyanide with
Contract Laboratory  Data  packages.   This  sampling  confirmed  the
original findings.   Since  TCE,  DCE  and  to  a  limited extent vinyl
chloride and hexavalent chromium have been confirmed  as the primary
contaminants of concern, the Phase II RI  sampling  (August 1990)  and
quarterly monitoring events include analyses for these compounds.

     The voluminous ground-water quality data base identifies the
presence of a combined  TCE-DCE plume in the  overburden aquifer that
has maintained a stable configuration since  it was  first identified
in 1985.  Additional overburden monitoring wells  installed during
the Phase  II RI  have  helped to  establish the perimeter  of  the
affected  area.    Surface-water  sampling  of  Lycoming Creek  has
identified no discernible  impact on surface-water quality.

     The Phase I RI  included a comprehensive ground-water sampling
event conducted in November 1989.  Ground water from  all monitoring
wells  installed during the Phase I RI, and 15  of  the  existing
monitoring  wells  was  analyzed   for  the  full  TCL/TAL   list  of
compounds  including  PCBs/Pesticides and Cyanide, and  all of the
remaining wells were analyzed  for the identified contaminants of
concern; TCE, DCE, and vinyl  chloride.   Samples  for TAL analyses
were both filtered and non-filtered.

     The Phase  II RI included the sampling of 49  monitoring wells
and was conducted  after   the  completion  of  the Phase  II field
investigation.  Ground water  from all monitoring wells installed
for the  Phase II  RI,  all  bedrock monitoring wells, and selected
overburden wells were analyzed by EPA Method 601 for  the identified
contaminants  of  concern   (TCE,  DCE,  and  vinyl  chloride).    In
addition, dissolved hexavalent chromium  was added to the analysis
for monitoring  wells MW-3R, MW-4,  MW-5,  MW-18, MW-31, MW-32, MW-
33 and MW-34.  MW-3R and MW-18  were analyzed  for both  filtered and
unfiltered hexavalent  chromium.

     Tables 4 and 5  present the results of the Phase I and Phase
II ground-water sampling events for TCE, DCE  and  vinyl chloride.


     Ground-Water Quality  in Overburden  Aquifer
         i
     The evaluation  of data  from the Phase I  (comprehensive) and
Phase  II  (abbreviated) sampling events  confirms  that the  primary
organic contaminants of concern in  the overburden aquifer are TCE
and DCE.   Vinyl chloride  is  present beneath  the site and,  to a
lesser extent total  chromium  and hexavalent chromium are  present
                                24

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beneath the western end of  the site.  A few ether organic comcour.ds
were detected  in a  few wells at trace concentrations.

     The conf iguraticr. cf the cer_bir.ed TCE-DCE plur.e as interpreted
fro- the NcverJ:er  1339  (Phase I RI) ar.d August 1990 (Phase II Rl)
sanplir.g  data,  are  presented  in  Figures  7 and  3  respectively.
These  figures  identify  3  areas on  the  site that  have  elevated
concentrations cf  these  compounds.

     The  first area shewing elevated concentrations  is  the area
around monitoring wells MW-9 and MW-20,  located at the eastern end
of the site.   Both  cf these wells were sampled in 1985 by Chester
and the ground water contained combined TCE-DCE concentrations of
approximately  1,000 ppb  to 2,000  ppb.    These  wells have been
sampled guarterly since 1933.  In early 1939, increased TCE and DCE
concentrations were observed in both wells.   Concentrations  in MW-
9 have increased to  17,000  ppb TCE and in MW-20 to 8,300 ppb TCE.
Concentrations of  DCE have  also increased  in MW-9 from 138 ppb to
310 ppb and  in MW-20 from  116 ppb to  360 ppb.  No explanation for
this increase in concentrations is apparent, since these wells, in
particular MW-20,  are  not  downgradient  from any suspected  source
area at  the site.   MW-9  is located  close to a  former  drum and
bottle storage area and the former  rail line.  It is  noted that the
downgradient off-site  ground water monitored by wells MW-12, MW-
29, MW-35 and  Phase II  well MW-74  shows little or no effect from
this high  concentration area,   indicating  that the contamination
from this area  has  not migrated off site in the southeast direction
to any significant  extent.

     The second  area showing  higher concentrations is located in
the central  portion of the site in  the  vicinity of MW-5,  MW-21,
and MW-50.  This area is near several  identified  areas  of concern,
including  the  "dry  well"   and  the chipster  sump.    The TCE-DCE
concentrations  in  ground water  in MW-5 were detected  at  a peak
concentration  of  67,200  ppb  in  August  1985.    The  combined
concentrations  of  TCE  and DCE  in  ground water  at MW-5 have
decreased  since  the  recovery  veil  began  operation  in  1936,  to
combined TCE-DCE  concentrations of 1,520  ppb  in the August 1990
sampling.  MW-21 data has shown wide fluctuations of combined TCE-
DCE concentrations  since the peak  combined  value of 12,350  ppb in
May 1985.  The data for this well indicate an overall decreasing
trend in th« concentration of  TCE (11,100  ppb in May  1985  to 830
ppb in Nov«mb«r 1989) and an increasing  trend in  the concentration
of DCE (1,750 ppb May 1985 to 7,000 ppb  in November  1989).   Ground
water  in monitoring well  MW-50  on  the other  hand  had  a peak
combined yalue of  53,000  ppb  in  October 1987;  present combined
values are 16,400  ppb.

     The third area of  higher  concentrations is located beneath
the western  portion of the site near the old WWTP, the  old Human
Resources  Building  and  the  Oliver  Street  storm  sewer.    The
monitoring wells with  the  highest  TCE and DCE concentrations in

                                31

-------
1.4OO
                                            Figure 7
                                TCE-DCE Overburden Plume
                                 ,. Concentration in ppb
                                          November 1989
                                         Textron Lycoming

 W«ft Third StTMl \  I
                                           Rccowry W«
-------
                     Figure 8
             TCE-DCE Overburden Plume
                 Concentration in ppb
                     August 1990
                    Textron Lycoming
                                                  SCO
, rcz-oca
                      POOR QUALITY
                              A I

-------
this area are MW-3 and MW-13.  Samples from MW-ia show decreasing
concentrations of TCE (high of 60,400 ppb in June 1985 decreasing
to 1,300 ppb  in  August  1990),  and DCE (436 ppb  high  in May 1935
decreasing  to  less   than  20  ppb  in August  1990),  since  the
initiation of ground-water recovery at RW-3 in this area in 1936.
The 1935 peak TCE-DCE combined concentration of 60,856 ppb in MW-
13 has decreased (August 1990)  to a combined TCE-DCE concentration
of  1,300 ppb.    Concentrations  of  each compound  in MW-3  have
fluctuated over time.  The  concentration  fluctuations  in this well
appear to be  seasonal,  with the highest concentration typically
reported in  the winter quarter.  Ground water in MW-4,  located less
than 200 feet east of MW-13 shows lower TCE-DCE concentrations in
comparison with MW-13 (e.g.  August  1990,  MW-4  at 135  ppb).   This
is possibly due to the configuration of the bedrock surface beneath
this portion of the  site which  may affect the direction of ground-
water flow and contaminant migration in this area.

     These three  areas  can be thought of  as  separate areas from
which  the   contaminants  would   migrate.     However,   further
downgradient in the overburden aquifer, where the  bedrock elevation
decreases and the aquifer thickens, the three  plumes  commingle.

     The TCE-DCE  plume  in  the overburden,  depicted in Figures  7
and 8,  shows  that  the  off-site  portion . of   the  plume migrates
southward from the central  and eastern portions of the site.  This
plume extends  toward the  south  where it is  intercepted  by the
capture  zone  of  the  Third Street  recovery well.   However,  low
levels  of  these  contaminants have  been  detected   in  samples
collected from the public supply wells that are located on the west
side of Lycoming Creek.

     As  part  of the  Phase  II  RI,  six  additional overburden
monitoring  wells were  installed  to  help  better  delineate  the
perimeter of the overburden plume.   Based on the  August 1990 data,
upgradient wells MW-36,  MW-2 and MW-11 represent background water
quality  levels since  TCE-DCE and  vinyl chloride  are  not reported
above method detection  limits.  The eastern edge of  the plume is
monitored by MW-35  (54.1 ppb)  which is  250  feet due  east of the
site property line, MW-12 (2  ppb) located 450 feet southeast  of MW-
9, MW-74 (less than 0.5 ppb) located on Memorial Avenue and MW-73
(4.5 ppb) located north of the railroad  tracks approximately 1000
feet southeast of the site.

     The western  perimeter of  the  plume  is defined by MW-69  (0.9
ppb)  located  at  the  far west end  of the  site,  MW-70 (0.7 ppb)
located  500 feet  west-southwest of  the site,   and MW-71  (1.2 ppb)
in Memorial Parfc, approximately 1000  feet southwest of the  site.

     The configuration of TCE and DCZ plumes in the  overburden are
similar,  but differ in detail in specific areas of the plant.  The
general  shape  of plumes for  these  individual  contaminants has


                                34

-------
remained  similar between  the  Phase I  and  Phase II  RI  samel ir.cj
events.

     Figure  9  shews the  overburden  TCZ plume from  the  Phase if
August  1990  sazpii.-.g  event.    As  discussed above,  elevated  TCZ
concentrations are present at three distinct areas beneath the site
boundary.   These occur around:  1)  the old WVTTP;  2)  the  central
portion  of  the  site  around  MW-50 and  MW-21;  and  3)  in  the
southeastern corner of the eastern-most parking lot centered around
MW-9.   The three areas of  elevated  TCE concentrations appear to
correspond to suspected contaminant  source areas at the site with
the exception of  the area  around MW-9,   the source of which is not
known.   The  eastern-aost  zone  appears  to  be  associated  with TCE
detected  in  MW-15,  MW-52,  and  MW-25.   The plume  from this area
extends to the  south.

     DCE  is  a   degradation product of  TCE,  and  as such  the
configuration of  the  DCE  plume  mimics  the TCE plume to a certain
extent, as depicted in Figure  10  from  the  Phase II ground-water
sampling event.   Though  similar to the pattern observed for TCE,
the  DCE plume  is subdivided into  two distinct  regions  of high
concentration beneath  the site. . One  area  is  in the vicinity of
the old WWTP, centered around MW-3  (now MW-3R)  to the north of the
old WWTP location.  The other area of higher DCE  concentration is
in the central  area of the  site around  MW-50 and  MW-21.

     .The zone of  high concentration  of  54 ppb  around MW-3 is  inucv
more localized  than the  zone of TCE in the same  area and  is OL
limited extent.   The zone  of high  DCE concentration  in the center
of the site extends  to the east-southeast,  possibly connecting with
a  zone  of high  DCE levels in  MW-8  adjacent  to  Building  2,  and
further eastward  in the vicinity of  MW-9.

     DCE  concentrations  are  primarily limited  to  the  central
portion of the   overburden plume,  and  do not extend to the outer
fringes, as evidenced by  the results from the  Phase  II monitoring
wells.

     Vinyl chloride was detected at  elevated  levels  in six of the
on-site overburden  wells  during the Phase I  RI sampling event.
The highest  values  were detected  beneath  the  center of the  site
property in  ground  water  from  wells MW-50,  MW-21 and MW-5,  with
concentrations  of 520  ppb, 170 ppb and  310  ppb,  respectively.
Ground water from MW-3, located on the  west side of  the site, had
a concentration of  150  ppb.  Vinyl  chloride was  also  detected at
50 ppb  and 28  ppb at monitoring wells  MW-6 and MW-8.  Figure 11
shows the. configuration  of the vinyl  chloride  component of the
contaminant  plume from the Phase  I  RI  data.   Vinyl chloride was
not detected in  any off-site overburden wells.

     Analysis of ground-water samples from the  Phase II RI  sampling
event (August 1990) showed vinyl chloride  in  monitoring wells

                                35

-------
       Figure 9
TCE Plume Configuration
   Overburden Aquifer
        August 1990
      Textron Lycoming
                      wi  IAMSPORT
               POOR QUALITY
                  ORIGINAL

-------
       Figure 1 Q
DCE Plume Configuration
   Overburden Aquifer
       August 1990
     Textron Lycoming
               POOR QUALITY
                 ORIGINAL

-------
                      Figure 11
   Vinyl Chloride in Overburden Monitoring Wells
                  7-10 November 1989
                   Textron Lycoming
                    Wllllamsport, PA
                                         WILLIAMSPORT
* AMM AMBMry VIM
                                                        80C
                                POOR QUALITY
                                  ORIGINAL

-------
5 and MW-6 at concentrations of 170 ppb and 37 ppb, respectively.
Mo other  samples  from the overburden shoved concentrations above
     Very few additional VCCs were detected in either the on-site
or off-site  wells sampled for the TCL/TAL  list.   Twenty samples
from the Phase I ground-water sampling  event were analyzed for'the
entire TCL/TAL  list  of  compounds  to  determine whether there were
other  compounds  of  concern  present.    The  compounds,  1,1,1-
trichlcrcethane,    toluene,    1,1-dichloroethylene    and    1,1-
iichioroethane, were  detected  at  low concentrations ranging from
3 ppb to 35 ppb in en-site monitoring wells MW-6 and MW-3.

     Ground-water  samples  from MW-3  and MW-13,  located  near the
old VV~WT?, were  the only en-site  wells  to contain elevated levels
of dissolved metals.   MW-3  contained levels of cadmium  (959 ppb)
and total chromium (4,500 ppb) and hexavalent chromium (5,000 ppb) ;
MW-13 showed concentrations of both total chromium  (9,250 ppb) and
hexavalent chromium  (10,000  ppb).    Off-site  well  MW-32, located
north of Fourth Street  in  Elm Park,  contained a concentration of
lead at 74 ppb.

     Hexavalent chromium  (dissolved) was  analyzed in subsequent
sampling events to better delineate the extent of this  compound  in
ground water.  Samples from MW-3R  (replacement well for MW-3), MW-
4, and MW-13  showed hexavalent chromium at 6,900, 18,  and 9,200
ppb,   respectively,   during   the   August   1990  sampling  event.
Monitoring well MW-31,  located  off-site approximately  500 feet
south of the  old WWTP, showed hexavalent chromium at 102 ppb during
the August 1990 sampling event.


     Ground-Water  Quality in Bedrock Aquifer

     As  with the  overburden  aquifer,  the  primary VOCs  in the
bedrock aquifer are  TCE,  DCE and  vinyl chloride.    Figures 12 and
13 show the combined TCE and DCE concentrations detected  in ground
water  from  the bedrock wells  for  the  Phase I and II sampling
events, respectively.

     The highest concentration of these compounds has been detected
in the on-«ite  bedrock monitoring well MW-62  located  adjacent  to
the southeastern  plant  property along Memorial Avenue.   This well
is  nested  with  overburden  monitoring  well  MW-8  and bedrock
monitoring well MW-8D.   The August  1990 sample from MW-62  showed
a TCE congentration of 13,000 ppb,  and DCE at 8,400 ppb; a decrease
from  levels  for   the  compounds  of  19,000  ppb and  13,000 ppb,
respectively, from the  November  1989 sampling event.  Other VOCs
detected in this  on-site well  in November  of  1989, included  vinyl
chloride  at  250  ppb,   1,1-dichloroethylene  at   71   ppb,   1,1-
dichloroethane  at  47  ppb, and  1,1,1-trichloroethane at 62 ppb.


                                39

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        Figure 1 2
TCE - DCE in Bedrock Wells
      7-1 ONov«mb«r 1989
       Ttxtron Lycoming
       Williamsport, PA

                         WI  IAMSPORT
              400 200  0    400   800
                          POOR QUALITY
                            ORIGINAL

-------
                      Figure 1 3
              TCE-DCE In Bedrock Wells
                 Concentration in ppb
                     August 1990
                  Textron Lycoming
litl) rca-oca
        Scat« fi
POOR QUALITY
  ORIGINAL

-------
     MW-8D monitors  a shallower  bedrock interval  than  adjacent
monitoring  well MW-62.    In  November   1989,  most  of  the  same
compounds detected in MW-3D  were  detected  in MW-62,  but  at lower
concentrations.  TCE was detected at a concentration of 3,600 ppb
and DCE at a concentration 3,400 ppb.  TCE was detected during the
Phase II sampling event  at a  concentration of  3,800 ppb and DCE at
a concentration of 2,600 ppb.

     The August 1990  sample from on-site  bedrock well MW-23 (which
is constructed  similar to  MW-3D)  contained  low concentrations of
TCE and DCE, at  210  ppb  and  9.9 ppb,  respectively.   This well is
located 350 feet west of the MW-8D well nest.  TCE and DCE levels
have also  remained generally consistent in  this  well  since  late
1987,  after reaching a peak  in December  1986.

     The August 1990  ground-water  sample  from on-site bedrock well
MW-63  contained TCE and  DCE at  concentrations of 2,900 ppb and 230
ppb,  an increase from values of 800 ppb and 61 ppb, respectively,
detected in the wells during the  first sampling event in November
1989.    Lew  concentrations  of only a  few  other  compounds  were
detected  it  that time.    This well  is   located roughly  400  feet
northwest (downdip)  of MW-23.

     Analysis of samples from the  off-site bedrock wells showed no
anomalous values with the exception of MW-53  which is located near
the Third Street Recovery well  and nested with MW-25.  The highest
TCE and DCE concentrations in this well were  recorded in November
1989,  at  37  ppb and  15  ppb, respectively.   These concentrations
decreased to previous levels  by the January 1990 sampling event and
have since increased.   Contamination in the bedrock continues to
be detected  in the  Elm  Park monitoring  wells.   Samples  from the
newly installed bedrock wells in this  area  screened  at  a lower
elevation  show  low  to   non-detectable  concentrations  of  the
compounds of concern.  MW-59 shows no compounds above the method
detection limit, and MW-60 has a  concentration of TCE at 0.9 ppb
and DCE  at  1.6 ppb.  This  indicates that  contaminants  have not
appreciably migrated to the  deeper bedrock in the  Elm Park area.

     The  installation of the Phase  II  bedrock wells have helped
delineate the  extent of the bedrock  contamination.   TCE and DCE
were detected  in MW-65,  at 50 ppb and 61 ppb,  respectively.  This
well was  drilled off-site  along  the line of strike from MW-62.
This was the highest  concentration of TCE-DCE detected in any of
the Phase II bedrock wells, and is consistent with, and lower than,
the concentrations of TCE-DCE  found  in upstrike bedrock wells MW-
80, MW-23, and MW-62.  Bedrock monitoring wells MW-64, MW-66, MW-
67 showedi TCE-DCE levels less than the analytical  method detection
level of  1.0  ppb  for the August 1990  sampling.   This  provides
evidence  that  detectable  levels  of  these  compounds  have not
migrated  within the  bedrock aquifer south  and  southeast of the
site.
                                42

-------
     Dissolved petals concentrations in the bedrock wells were not
elevated  (relative  to the other wells  saspled) with the excect'-'c-
of barium,  detected at  3,500  ppb  and 930 pcb in MW-59 and MW-22*'
respectively, in Ncveaber 1939.


     Dense  Non-Aqueous  Phase  Liquid  (DNAPL)

     No evidence of DNAPL contaaination was observed during either
the  Phase  I  or Phase  II drilling  programs.    Sediaent  samples
collected  with  a  Xeaaerer   saapler   from  the  bottom  of  three
monitoring wells (MW-61, MW-62, and RW-2) showed no visual evidence
of a DNAPL.  3y observing the  bottom sediments  after they had been
allowed to  sit  for a period  of  tiae,  DNAPL,  if  present,  aay be
observed  as  beads  of  product  in  the sediment.   These three wells
were selected because they were either open-hole wells located in
an area were  DNAPL could occur or were wells where past sampling
events had indicated high concentrations of TCE and DCE.  MW-62 is
also the deepest accessible monitoring well on site.

     A review of past concentration data from all monitoring wells
was conducted.   The concentration of  TCE  in well  nest MW-8, MW-
3D, and MW-62 increases  with depth.  MW-62,  one the deepest bedrock
wells  in  the study area, shows  the  highest  TCE concentrations
detected.    The  concentrations   of  dissolved  DNAPL components
relative to their  solubility  are often used  as  indicators for the
presence of a DNAPL.  Concentrations on the order of  10 percent of
the solobility are typically expected if a DNAPL were  present.  The
solubility  of TCE  in  water   is  1,100,000  ppb.   The  highest TCE
concentration presently detected is  19,000  ppb  in monitoring well
MW-62; less than 5  percent of the solubility of TCE.

     Thus, the evidence does  not indicate  that there  is a mobile-
phase DNAPL that is potentially recoverable.  It appears more than
likely that if  non-aqueous phase  liquids  are  present,  they are
located on-site  and represent a  residual contaminant source, but
one that is immobile and containable.
Community Well Investigation

     An  inventory of  the  identifiable  residential, commercial,
industrial, and public-supply water wells within an approximate  3-
mile radius of the study  area was  conducted  to  identify  potential
ground-water  receptors.   Available  information concerning  well
owners, well depth, use of the well and the location, the geologic
formation ^n which the well  was finished, date drilled, and whether
the well  is presently  in use,  was obtained and is  presented  in
Table 6.

     A total of 35 wells  were identified within an approximate  3-
mile radius of the  AVCO Lycoming Site.   Eleven  are identified  as

                                43

-------
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-------
 Su.Tjr.arv of Site Risks

      The objective of  this  section  is to estimate the  potential
 for adverse health or  environmental effects incurred by human or
 ecological  receptors   exposed  under   the   exposure  scenario
 established in  the RI.  This  section summarizes the Risk Assessment
 report.

      In  order   to  estimate  the  human  health  risk,   the  risk
 assessment focused on the following:   (1) the contaminants detected
 during the RI at the Site;  (2) the potential environmental pathways
 by which populations might be  exposed to  compounds released  from
 the Site;  (3)  the estimated exposure  point concentrations  of  the
 compounds of concern;  (4)  applicable  or  relevant  and  appropriate
 requirements (AJRARs), criteria, and  advisories;  (5) the estimated
•intake levels of the  compounds of  concern; and  (6) the toxicity
 values of the compounds of  concern.   The level of risk that  the
 Site poses to human health was  then  quantified.


 Human Health Risks


      Indicator  Compound Selection

      The contaminants  identified in  the  RI  are  comprised of  a
 diverse group of compounds  with  different toxicological properties.
 The extent  of  contamination varied  widely in concentration  and
 occurrence  throughout  the  site   property.      Moreover,   some
 contaminants represent a greater potential for  risk to human health
 and the  environment  than others because  of  the differences  in
 toxicity, capacity  to migrate to receptors, concentrations  present
 and likelihood  of exposure concentrations at levels high enough to
 pose human health  and environmental  risks.

      The considered compounds  (contaminants of  concern) selected
 for each scenario or medium at the AVCO Lycoming Site are presented
 in Table 7.  These compounds are believed to represent the majority
 of carcinogenic and non-carcinogenic risks associated with the AVCO
 Lycoming  Site.     TCZ,  DCS,   vinyl  chloride,  toluene,   and
 tetrachloroethylene  were  the  compounds  considered  in the  Risk
 Assessment's evaluation of exposure  from  the  air strippers.   The
 rationale for the selection of the  above  considered  compounds is
 presented in the Risk Assessment Report for the AVCO Lycoming Site.
                                 45

-------
                                                                  T.ible 7
                                                      Summary ol Considered Compounds
                                                                In Each Area
                                                              Textron Lycomlng
                                                          WUIIamsport, Pennsylvania
                Scenario A
         Effluent WMWA Wefl Field
               Ground Water
              Wefte
      Scenario B*
      Third Street
     Ground Watar
          Untreated
    Scenario C
Off-Site Overburden
  Ground Water -
   Elm Part Area
    Scenario O
On-SJte Overburden
Ground Waler - Plant
Southern Boundary
   Scenario E

Off-SJie Bedrock
 Ground Water
               Mona Detected
1.2 Dtttooetiytone (total)  1.2 Dirtitoroethytene (total)  1.2 Dichloroelhylene (total)  1.2 Dfchloroeihylene (total)
    Trfcttofoelhytana         Trichtofoelhvtene          Trichtoroethylena         Trichkxoelhylena
                                                                   Lead
                                                                  Barium
                                                                  BeryMum
                                                                 Manganefte
                                                    Vinyl Chtonde
                                                      Cadmium
                                                  Vinyl Chloride
                                                     Qarium

1
Scenario F
Oo-StU Bedrock
Ground Water
.2 Dtchtofoethytene (total)
TricMoroethytene
.^ny) Chtonde
Scenario G
Chromium Area
In Ground Water
Hexavatent Chromium
Soto
(0-6 tee* beneath
paving)
Toluene
Trichloroelhylene
Lycomlng Creek
Surface Water'*
1.2 Dichloroelhylene (total)
Trichtoroelhytene
Manganese
Lycomlng Creek
Sediment
Lead
Ren/o(a)pyrene equivalent
08
15:0
OO
         •Indudjaajinfluenl data tor WMWA well lield
         "IncMHk storm sewer sample coHecled on site

-------
     Exposure Pathways

     This step in the risk assessment process involves determininc
the  potential  routes  of  exposure to  the human  population,  the
estimated concentrations  to  which the  population is exposed,  and
the population at risk.  Based on  the information collected during
the RI, the Risk Assessment identified  11  exposures scenarios that
were associated  with ground water, soil,  surface  water,  air  and
sediment at and  around the AVCO Lycoming  site.

     The RI shewed that en-site soils and  ground  water at the AVCC
Lycoming  Site  contain  moderate  to  high  levels of organic  and
inorganic contaminants. The  two major inorganic constituents found
in  the  soils  are   lead  and  chromium.    Lead  was detected  at
concentrations of  169  ppm and 135 ppm at the  eastern  end of the
site property.   The  highest  chromium concentrations detected were
437 ppm near the  center of the site and 1,120 ppm  beneath the Human
Resources building,  which no longer stands.   The shallow ground
water in the overburden in the western section of  the site contains
total chromium and hexavalent chromium at concentrations of 9,250
ppb and 10,000 ppb,  respectively.

     The  primary VOCs  found  in   the  ground  water at  the  AVCO
Lycoming Site  include  TCE,  DCS and vinyl chloride.   The shallow
ground water in  the  overburden on-site contains  concentrations of
TCE up to 17,000 ppb and  DCE up to 7,000  ppb.  Vinyl chloride was
also detected in  the  shallow  ground water on-site  at concentrations'
of  520  ppb.   The  ground  water  in the bedrock  on-site contains
concentrations of TCE up  to  13,000 ppb and DCE up  to 8,400 ppb.

     The direction of ground-water flow at the AVCO Lycoming Site
is generally to  the  south toward  Lycoming Creek  and the WMWA well
field.    Contaminated  ground  water  has  migrated  from  the  AVCO
facility in the  direction of the  well  field.  The  shallow ground
water in the overburden off-site contains  concentrations  of TCE at
2,900 ppb and DCE at  980 ppb. The ground water in the bedrock off-
site contains concentrations of TCE at 730 ppb and DCE at  170 ppb.

     Currently,  carcinogenic risks resulting  from analysis  of  6
exposure scenarios (i.e.,  treated water provided by the WMWA, on-
site soils,  Lycoaing Creek  surface  water and  sediment,  and air
emissions from the air strippers  on-site and off-site)  are at or
below the acceptable level of 10'6.  This  level is equivalent to  1
extra chance in 1,000,000 of contracting cancer due to exposure to
site-related contaminants.

     However, the on-site and off-site contaminated ground water
contributes future  risks for potential  ground-water  users.   The
following 5  scenarios describe  conservative  risks due to these
hypothetical exposures to site-related contaminants.
                                47

-------
     The untreated  ground  water in the  WMWA well field  and  the
ground  water  in  the monitoring  wells  located  on Third  Street
present an excess human cancer  risk presently  estimated  to range
from 3 to 8 x 10'  .   This risk is primarily due to TCE present at
a maximum concentration of  19,000  ppb  in  1988 in a monitoring well
near Third Street.   The range of  values  for  this  scenario is  0.2
ppb and  1,900  ppb with an average value of  317 ppb.  This risk
evaluation  represents  a  highly conservative  estimate of  human
health risk and means that individuals exposed to ground  water in
this area have a maximum of 800 extra  chances out of  1,000,000 of
contracting  cancer.    Due  to  the  conservative  nature  of  this
assessment, however,  the  actual  health  risks  will   probably  be
lower.

     The off-site overburden  ground  water  in  the Elm Park area
presents an excess human cancer risk presently estimated to range
from 3 to 6 x  10"A.   The risk is primarily due to beryllium and TCE
present  at  maximum  concentrations   of   3.5  ppb  and  860  ppb,
respectively.   The  range  of  values for  beryllium  is  0.4  ppb and
3.5 ppb,  and  for TCE,  the range  is  1.1 ppb  and 860 ppb.   The
evaluation  represents  a  highly conservative  estimate of human
health risk and means that individuals exposed to ground water in
this area have a maximum of 600 extra chances out of  1,000,000 of
contracting  cancer.    Due  to  the  conservative  nature   of this
assessment, however,  the  actual  health  risks  will  probably be
lower.

     The on-site overburden ground water presents an  excess human
cancer risk presently estimated to range  from 0.6  to 5 x 10"2.  The
risk  is primarily  due to vinyl  chloride present at a  maximum
concentration of  1,100 ppb in  1988  in a sample  from an on-site
monitoring well.  The  range of  values for this scenario  is 1 ppb
and  1,100  ppb  with an  average  value  of  126 ppb.   This risk
evaluation  represents  a  highly  conservative  estimate  of human
health risk and means that individuals exposed to ground water in
this area have a maximum of 50,000 extra chances out  of 1,000,000
of contracting  cancer.  Due to the  conservative  nature  of this
assessment, however,  the  actual  health  risks will  probably be
lower.

     The off-site bedrock  ground water  presents  an  excess human
cancer  risk presently  estimated to range from 3  to  6 x  10' . The
risk is primarily due to TCE present at a maximum  concentration of
1,200 ppb in a sample from a monitoring well located south  of Third
Street.  The range of values for this scenario is 0.5  ppb and 1,200
ppb with an average  of 439 ppb.   This risk evaluation represents
a highly conservative estimate of human health risk and means  that
individuals exposed to ground water in this area have a maximum of
600 extra chances out of 1,000,000 of contracting  cancer.   Due to
the conservative  nature of this  assessment,  however, the  actual
health risks will probably be lover.


                                48

-------
     The  en-site bedrock ground  water presents an  excess  hur.ar
cancer risk presently estimated to range from  0.3 to 2 x 10"2.  Thl
risk is primarily due to vinyl chloride and TCE present at maximum
concentrations of 250 ppb and 19,000  ppb,  respectively.  The range
of values for vinyl chloride is  1.0 ppb and 250 ppb with an average
of 52 ppb.   The  range of values of TCE is 0.5 ppb and 19,000 ppb
with an average  of  2,333 ppb.   This  risk evaluation represents" a
highly conservative  estimate  of human  health  risk and means that
individuals exposed to ground water in  this area have a maximum of
20,000 extra chances  cut of 1,000,000  of contracting cancer.  Due
to the conservative nature of this assessment,  however, the actual
health risks will probably  be lower.


     Toxicity Assessment

     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
chemicals.  CPFs, which  are expressed  in units of  (mg/kg-day) -1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day,  to provide  an  upper-bound estimate  of  the excess
lifetime cancer risk associated  with  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.  Cance;
potency   factors  are   derived   from  the    results   of  human
epidemiological  studies or chronic animal bioassay to which animal-
to-human  extrapolation  and  uncertainty factors have been  applied.

     As   described   above,   excess  lifetime  cancer  risks  are
determined by multiplying the intake level with the  cancer potency
factor.   The resulting  risks are  probabilities that are generally
expressed in scientific notation (e.g., 1 x 10"* or IE"6).  An excess
lifetime  cancer  risk  of IE'6 indicates that,  as a plausible upper
bound,  an individual has a one in one million  chance of developing
cancer as a  result  of site-related exposure to a carcinogen over
a 70-year lifetime under  the specific exposure  conditions at  a
site.

     Reference   doses   (RfOs)  have  been  developed  by   EPA for
indicating the potential for adverse health effects from  exposure
to chemicals exhibiting noncarcinogenic effects.  RfDs are  exposure
levels for humans,  including sensitive  individuals, that are likely
to be  without  an  appreciable  risk of adverse  health  effects.
Estimated1,intakes of chemicals from environmental media  (e.g., the
amount of a chemical  ingested from contaminated drinking water) 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 hel'
                                49

-------
to  ensure  that  the RfDs  will not  underestimate the  potential
occurrence of adverse noncarcinogenic effects.

     Potential  concern  for noncarcinogenic  effects  of  a  single
contaminant in a single  medium is expressed as the hazard quotient
(HQ) (or the ratio of the  estimated intake to the reference dose).
By adding the HQs  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 significance of multiple
contaminant exposures within a single medium or across media.

     A summary  of  quantitative toxicological information for the
considered  compounds selected for  the AVCO  Lycoming  Site are
presented in Table 8.


     Risk Characterization

     The potential  carcinogenic  risks  associated  with this site
were  calculated  by multiplying  chronic  daily  intakes by the
appropriate carcinogenic potency  factors.   It is the  policy of the
EPA to present a conservative  estimate  of site risk as represented
by reasonable maximum exposure (RME) scenarios, rather than by risk
ranges.  This  approach  may be explained as  the highest exposure
that  is  reasonably  expected  to  occur  at  a  site.    It includes
consideration  of  both  exposure  parameters  and  exposure   point
concentrations for their relevance as reasonable maximums. Despite
the conservative nature of the AVCO Lycoming  Site risk assessment
(an approach that is in accordance with EPA policy), reevaluating
site risk according to specific EPA methodology  would still result
in a  value  greater  than  1 x  10"4  from the  corresponding media.
Thus,   both  approaches  conclude   that  similar  media-specific
remediation is required.

     In this  respect,  both reasonable  and  worst-case risks were
calculated using reasonable and worst-case chronic intakes rather
than presenting risk in  terms  of the  RME.  The resultant  potential
risks  are  presented in  Tables 9  through   17.   The  resulting
carcinogenic risk provided an  estimation of  the  excess  probability
of an individual developing an excess cancer  over a  lifetime as  a
result of exposure to a particular  compound or set of  compounds
under the assumed  conditions  of the  exposure.  This estimate was
also sometimes referred to as  the incremental or excess individual
cancer risk of 20 to 25  percent.  Risk  associated with  exposure to
a set of .compounds was  estimated by  summing  risks associated with
exposure to each compound.

     Calculated  ranges  of  lifetime  carcinogenic risks for the
combined feasible scenarios are presented in Table 18.
                                50

-------
                                                                         l.tl.lc 8
                                                       Summary ol Qu»nUUlWa ToilcoJoglcaJ Inlurmallon
                                                                     Tailron lycominfl
                                                                 WlUtamaporl, PannaylwanU
Campound
1.2 DkNofoatoyiarw (lolal)
IfkMMOatrytana
loluaoa
Vtnyt Chkxlda
Ba4uo{a)pyiana
Barium
Cadmium
Uanpanaia
BatyMuni
laad
lia*avalanl QuooOum
Oral RID'
{!******
240641
NA
400641
NA
NA
640642
600643—
640641
600643
144642
240642
')
Chronic
200642
NA
200641
NA
NA
740642
640644
100641
640643
140643
640643
Inhalation
(mp/kg/d
Sobchfonlc
NA
NA
200£,OO
NA
NA
NV
NA
NV
NA
NA
NA
RID*
*y)
Chronic
NA
NA
2006 »40
NA
NA
NV
NA
NV
NA
NA
NA
Oral SF"
(l/mtyfcg/day)
NA
1 IDE 02
NA
230E.OO
1 ISE.OI
NA
NA
NA
4304E.OO
NA
NA
InfuUtfon
NA
1 70E 02
NA
2 Bit 01
6 106,00
NA
NV
NA
NV
NA
NV
Cuclnoganlc
NO
U2
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A
02
NC
Ul (1)
O
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IMIU/III ASI
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MtASI  EPA a HaaMi ENacta A*aa*amart Summary Tatta* TWrd Quarts FY IM0(JUy
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RIO  Ralatanca doM
SF Sk>p*Wto<
Nola: QiaT&CVSF valuat ww a uMd hi fU« ctta
-------
                                                                   Table  9
                                                   Aaaeeemenl el Carcinogenic Rltfc* • Scenario B
                                                      Monitoring Won* Located on Third Sueel
                                                               ToiUon Lycomlnfl
                                                            MNMlMMaod.
ROUTE OF
EXPOSURE
                              EXPOSED
                                               COMPOUNDS
                          BCI
                M»t4    1.2 DtchfcwoetVeno (total)
                             TrkttoraotiytoiM
                             CMUaga«-l2   1.2 OkM
                                               TrkMomoeSyteM
                                         i (total)
                                           1 J
               (tolaQ
  77E03
I4AEOJ
OOOE.OO
967E03
246E03
OOOE.OO
40OEO3
SOCEO3
000£,00
                                 Jj
 wca
JOflMnlm]
                       Slope Factor
                                   4
                                   000£»00
                                   33IEO2
                                   7J7EO3
                                   OOOE.OO
                                                                              NC
                                                                            1 70C02
                                                                              NC
                                                                              NC
                                                                            1 70E02
                                                                              NC
                                                                              NC
                                                                            1 70E02
                                                                              NC
                                       HCI • SF     wca • SF
                            0 E.OO
                            3 £06
                            0 E.OO
                            0 E.OO
                            4 EO6
                            0 E.OO
                            0 E.OO
                            ft £46
                            0 EiOQ
 Donne!      Chlda0*24    U Dkfctaot*y*em (total)


            ChiUae»§-l2   1.2 DKttOfOOtftytene (total)


               Aduta       1.2



Ingouon
                                                                   2 ME 06
                                                                   4 ME 06
TikMoiaottyta
                                                                   2S2EO6
                                                                   364E06
                                                                   • OOE06
                                                                   IOIE05
                                   44IE06
                                   7 JOE 06
                                   490E-O6
                                   3»l£06
                                   904E-06
                           NC
                         1 IOE 02
                           NC
                           NC
                         I lOt 02
                           NC
                           NC
                         1 IOE 02
                           NC
                                                                                                              .OO
                                                                                          2
                                                                                          0 E.
                                                                                          3
                                                                                          0 E.OO
                                                                                          0 E.OO
                             GMdau»2«   !.24*e«ofBOtVeoe (total)
                                               T»ichtefoo*V»«ona
                             CMda0a6l2   I
                                                 Manjanaia
                                Adult*
   likMoraoeSytoM
     Uanpanaia
1.2 OkMoioottytano (totel)
                                                .Mono****
• 77E 03
I48E03
279E02
• 67EO3
246E03
3 07E 02
400EO3
SOflEOJ
1.2 7 1 02
                                   274EO6
                                   326E-06
                                   2.9IE05
                                                               300E02         NC
                                                               4 76£ 03       I IOE 02
                                                               3 I9E02         NC
                                                               33IE02         NC
                                                               787E03       I IOE 02
                                                               352EO2         NC
                                                               I37E02         NC
                                                               I 63E O2       I IOE 02
                                                               I 46€ 02         NC
                                                                     faUHMMltonrWaifl
                                                                                            Eoa
                                                                                            E.OO
                                                                                            E.OO
                                                                                            L07
                                                                                            LiOO
                                                               0 E.
                                                               0
                            1 W
                            0 E.OO
                            2 £06
                               .00
                              E.OO
                            3 £06
                            0 E.OO
                            0 E.OO
                            6 E06
                           .0 E.IM
                                                                                                          1 B44
08
              NC • Noncafcmoojn
              RCI • Reatonatote chtonic mlaha bated on aweo* conoantrauon
              WCCI • Wotti «a«« chiomc otafc* baaadon maitoum coneenkaaon
00

                                                                                                                      0 E.OO
                                                                         £06
                                                                         £.00
                                                                         E.OO
                                                                         E O4
                                                                         E.OO
                                                                       0 E.OO
                                                                       3 E
-------
                                                  l.llile  10
                                                  Uno0**Oc fttek*
                                        Oft-Stt* OvwtturtMi MoAMoring ttMM
    o
00
•2 -3-1
00
 ROUTE Of
 EXKMUAE
                        EXFOAEO
                      fOrULATtOM
COMPOUNDS
    ACt
(Mft*»*«y)
                                WCQ
              cuMi«»ft-ia    i>i
<^li!kfcfc*^.44i»iifty»fcfi.it
                    300EO4
                   OOOE.OO
                   OOOE.OO
                   OOOE.OO
                   OOOE.OO
                    I&OE43
                    4»7E04
                   OOOE.OO
                   OOOE.OO
                   OOOE.OO
                   OOOE.OO
                                                   OOOE.OO
                                                   OOOE.OO
                                                   20ȣXW
                                                    I ME 00
                                                    I20EO4
                                                    544E04
              CMUag»*l2   1.21
                                                   .(Ml)
                    I JSEOi

                    l«7EOa
                                    LMd
                    442EO*
                    I24EO*
                    206E04
                    SMEOO
                    7 IOE 06
                    3 24E 04
                    3 IBE06
             2 I6E03
             OOOE.OO
             OOOE.OO
             OOOE.OO
             OOOE.OO
                                                              OOOE.OO
                                                              OOOE.OO
                                                              OOOE.OO
                                                              OOOE.OO
                                                                       OOOE.OO
                                                                       OOOE^M
                                                                       OOOE^X)
                                                                       OOOE^O
                                                                       JW^
                                                                        I20E04
                                                                        644E04
              2UE06
              4O8EO*
              I«7EO«
              442E06
              I«7E06
              I47EO6

              7 IOE 06
              324E04
              3 I6EO6
        NC
      I 70E02
        NV
        NC
        NC
        NC
        NC
      I 70E02
        NV
        NC
        NC
        NC
        NC
      I TOE 02
        NV
        NC
        NC
        NC
        NC
      I IOE 02
      430E.OO
        NC
        NC
        NC
        NC
      I IOE 02
      430E.OO
        NC
        NC
        NC
        NC
      I IOE 02
      430E.OO
        NC
        NC
        NC
foW P~m*l ftttn
BCl'Sf
0 £.00
4 £06
0 E.OO
0 E.OO
0 E.OO
0 E.OO
0 E.OO
• to*
0 £.00
0 E.OO
  £.00
  £.00
0 £.00
2 £04
0 £.00
•O E.OO
0 £.00
0 E.OO
                                                                                                   0
                                                                                                   0
                                                          0
                                                          0
I
0 £.00
6 £0*
• £04
0 £.00
  £.00
  £.00
0 E.OO
• £0*
7 £0*
0 £.00
0 £.00
0 £.00
0 E.OO
2 £0«
3 £07
0 £.00
0 £.00
0 (  .<«>
WCCj^Sf
 0 E.OO
 4 EO4
 0 E.OO
 0 £.00
 0 £.00
 0 t .OO
 0 E.OO
 • £ 04
   E.OO
   E.OO
   £.00
   E.OO
   £.00
 I £04
 0 E.OO
 0 E.OO
 0 E.OO
 0 E.OO
                                                                                         4 £47
 0 £.00
 4 £0*
 • £0«
 0 E.OO
 0 E.OO
 0 E.OO
 0 £.00
 6 £ 0»
 1 E0«
 0 E.OO
 0 E.OO
 0 £.00
 0 £.00
 2 £ 07
 3 t 01
 0 £.00
 0 £.00
 0 J .00_
.._ —.
                                        RUE CfxoMlc   HUE • a
                                                        **f
                                                                                                                4 23£ O4
                                                                                                                                     • ME 0*
                                                                                                                • 6M O4
                                                                                                                                     I 4/E O6
                                                                                                                 1 Tttt 03
                                                                                                                                     3 04E 04
                                                                                                                • oat o/     »»3£oa
                                                                                                                a »afc 01
                                                                                                                     06
i oiȣ oa
7 I6EOC
                                                                                                                                    3t»3£ Oa
                                                                                                                                    2S/EO/
                                                                                                                                    4 46^07

-------
                                                   Table  10 (cnittM)
                                        AMMJMMH! of Cwctoogmlc M»h« - Scwurio C
                                            CMMIto O*«*u«tfMi Uonftoiteg MMte
                                                   T*itran LycMHtno
     BCI
     WGC4
• E-04
3 £44
00
    30
>>

-------
                                                                   T.I hi i-  II
                                                                            Hl»k» - Sc«rwirto
                                                         On-&ll« Ov*rt»urd«« Monitoring W*««
08
OD
PI
ROUTE OF
turoauflE
EXPOSED
   JUIIttL
                                                 CQMPQUHM
                                                                      RCI
                                                  WCC4
                                                            (k>uJ)
              1.2
                               QMWa9»*l2    1.2 Dk**»o*t*tMW (toUQ
                                                IrtcttanwAtytMM
                                                 \Any4Chfanto
                                             1.2 OMA»«>ti»*»«»« (to*W)
                    DMM!
                                     ., .  .  • - - •<•« •« r          :
                                -  '  ..•-';!.'•  ;_i. j .  s. i . _ ..'i,  .     ;
CMd«o»4 12   1.2 DK**»D«««vi*n« (tout)

                   VWtyl CMamte
                                             t.24)KMoM>«4hytan* (total)
                                                TfkttOT***^
                                                     Otfarttfe
                                             1.2
                 Iritt
                                                               NC
                                                             I  IOC 02
                                                             230C.OO
                                                               NC
                                                               NC
                                                             I  IOC 02
                                                             230C.OO
                                                               NC

                                                             I  IOC 02
                                                             230C.OO
                                                               NC
   £07
   E 06
 0 t .00
 0 E.OO
 2 £07
 I E 06
   £.00
   E.oo
   £07
   £ 06
_fl Lital
 t E-O*
   E.OO
 8 EOS
 7 £04
 0 E.OO
   E.OO
 2 E 04
 I E 03
 0 E.OO
 0 E.OO
 3 £04
 2 £03
_fl L»WI
.LLM
                NC
                HC4
                WCCI
                                          Reasonable Carcinogenic Rlsh=   6  £03
                                                             Cas« Carcinogenic
                                                                                                   5 £02

-------
                                                                 Table  12
                                                   Aaiaaamanl ol Carcinogenic RUk» • Scenario E
                                                        CXI SIM Bedrock Monitoring Well*
                                                              TeiUon LycoMlng
                                                           WttUmtpofl. Pennsylvania
    -o
08
OO
II
               NC - NoncaidnogMt
               RCI Rc.ison.ibto cruoruc Nil.tki! b.i:-i!d on a«;i Jijc cont^itnalKin
               WCCl  Wo4klca*u cntomc uttaku basutl on niawmum coitomUaiMxi
Reasonablo Carcinogenic Risk =    3

            Worst-Case Carcinogenic Risk;
ROUTE OF EXPOSED
EXPOSURE POPUtAIIOM COUPOUMOS
lnnala>an CMMag§24 1.2 O«*»o«oe*Vene (total)
TntMonweSylena
VAoylChtonde
Barium
CfaUag*>«-l2 1.2 DKttoMM**iane (total)
Tnchkxoe4hytene
VtaytCMond*
Aduto t.24kftkMMlMMM> (total)
Ukwl ^jtinaArW
""" ' O*m*"' CtMktao»24 1.2 Dkitooe^tene (total) ' '
Vinyl CMomto
Ch«dag*6l2 1^4Nc»*Moe*vleM (total)
VtojCMandB
AduU 1.2 Oid*MM«vfa«M (total)
>»- * /**kiw— rf4W
vVM I4v0nai
" lng»»l»n"X''""CfU«a^a24 *l*2 DicMoioetftylanti (total) "
VtnylChtonde
Banum
Chad age 6 12 1.2 DtcManMlhytena (total)
Vinyl Chtoode
Banum
Adult* 1.2 Dchtoroetftytene (total)
Tncttoroetoytene
VkiylCMonde
RCI
6 IOEO3
1 IOE 03
75OE 06
OOOE.OO
*72E 03
182EO3
I24E06
OOOE.OO
27BE03
376E03
2S7E06
iilft.'^;pf-. ..;
A36E06
1 ISEOa
iaiE04
775E06
209C06
1 43E oa
I50E04
SS6E06
7SIE06
&!3COa
I.09E04
6 IOE 03
1 IOE 03
7SOE06
1 I8EOI
672EO3
ia2E 03
1 24E 06
1 30E 01
2 7BE 03
376E03
2S7E 06
&ME.02
WCCI
ma/lut/di)
22SE02
300E03
2SOE06
OOOE.OO
246E02
497EO3
4 MEO6
OOOC.OO
I03C02
I03CO2
8S7EO6
OOOCfOO
Ji^STW
346EOS
46IE06
384E09
636E04
266C06
57IE06
4 76EO9
526EO4
205C05
206EOS
1 7IE043
300E03
2SOE06
4 ME 01
24SEO2
4 07EO3
4 ME 06
4S7EOI
1 03E 02
I03E02
8S7E06
I89EOI
	 la.
Slope Factor
NC
I 70E02
20SEOI
NC
NC
1 70C02
29SEOI
NC
NC
1 70C02
295EOI
NC
»< tnbMttltaa ftM »
NC
1 IOC 02
230C»OO
NC
NC
1 IOC 02
230C^M
NC
NC
1 IOC 02
230E.OO
NC
r«H/Jr«»M/AMr<
NC
1 IOC O2
230E.OO
NC
NC
1 IOC 02
230E.OO
NC
NC
1 IOC 02
230E.OO
NC
ttlltxnMtm flfiim
HC| * SF
0 E.OO
2 EOS
2 £06
0 E.OO
0 £.00
3 EOS
4 £06
0 E.OO
0 E.OO
6 EOS
B £06
0 f ,00
0 E.OO
2 £08
3 £08
0 £.00
0 E.OO
2 E08
3 Eoa
0 E.OO
0 E.OO
8 EO8
1 £07
0 EiOD
9 f-97 ...
0 £.00
1 EOS
2 EOS
0 £.00
0 E.OO
2 £05
3 EOS
0 E.OO
0 E.OO
4 EOS
6 EOS
0 £.00

WoiiiCase
SI'SF
0 £.00
b £05
7 £ 07
0 £.00
0 £.00
a E os
1 £06
O E.OO
0 E.OO
2 E O4
3 £06
0 f.fOQ
) £44
0 E.OO
S £08
9 £09
0 E.OO
0 E.OO
6 E 08
i Eoa
0 E.OO
0 E.OO
2 £ O7
4 £08
0 E.OQ
4 £~07
0 E.OO
3 i OS
6 E 06
0 E.OO
0 £.00
5 EOS
1 £ OS
0 E.OO
0 I .00
1 £ 04
2 £ OS
0 E.OO

6 £04

-------
                                                             T.I Me II
                                              AtM«am«nl ol Cafdnoganlc Al»ks - Scenario F
                                                   On SIU Bedrock Monitoring W*Jls
                                                        Tailron Eycomlng
                                                      WUUarnapoil. Pcnnayrvanta
08
ROUTE OF EXPOSED
tnhalatoon Chlda*«24


Chadag«ai2


Addis


• •' •:-VWiiiiiill^^r'^
Da «ri • *;F
NC
1 704:4)2
29iE 01
NC
1 70E 02
29SE 01
NC
1 70£ 02
29i£ 01
0 E.OO
1 t 04
4 E OS
0 t.OO
2 E 04
6 E OS
0 E.OO
4 E 04
1 E 04
.; . : : TntirimiiiiMtn mil t £~oi
1 44E O4
I09E-OS
2 (ME 07
1 I9£ 04
1 3S£ OS
2S2E 07
6 S3E OS
485£ 05
906E 07

935E 02
7 IOC 03
1 33E 04
1 03E 01
t I7E 02
2 I9f 04
427E02
243E 02
4S4E 04

936E 04
730E OS
960E 07
775E04
904E OS
1 I9E^)6
SS6E 04
32b£ 04
426E 06
..:-.'• 1
6 lOE 01
4 75£ 02
625E 04
672E 01
767E02
1 04E 03
2.76E-OI
1 &3EOI
2. ME 03
Tot
NC
1 106 02
230t«00
NC
1 lot 02
23O4.00
NC
1 I0£ 02
230C.OO

NC
1 tOt 02
230C.OO
NC
1 lOt 02
230t«00
NC
1 tOt 02
230E.OO
0 E.OO
1 E 07
S E 07
0 E.OO
1 E 07
6 E 07
0 £.00
S E 07
2 LQfi
A* 4 £40
0 E.OO
a E os
3 E 04
0 E.OO
1 E 04
S E04
0 E.OO
3 E 04
1 E 03

•/irtaiirton ft/iii 	 i-t^u —
wrrt • SF
DLilil iJI
0 E.OO
6 .04
2 04
0 ,00
t 03
:i . 04
0 1 , 00
3 1 03
fi Lfli
6 £ -01
0 ,OO
tt ()/
2 O6
0 ,()O
1 06
3 06
0 ,00
4 06
1 LQi
t £45
0 .00
b 04
1 03
0 .00
9 O4
2 E 03
0 E.OO
2 E 03
5 1 03

1 £02 	
00
ii
NC
FtCI -IUa«onab*achionicinta»i«b4»^lonaw«i«o«conc«ntiatk>n  *''»
              chionic mta»* bu«d on roajiimum conconiiauon
Reasonable Carcinogenic Rlsk=   3 E 03

            Worst-Case Carcinogenic Risk:
2 E 02

-------
                                                           Tabto  14
                                           AtMMflMftl ol C«rcino0anic Rli«* • Scenario G
                                            HeMvatml Chromium AIM In Ground Water
                                                       Taiuon Lycomlng
                        EXPOtEO
                                        CtvoirrfumVI
                                        ChromluniVI
RQ
             wcci
Slop* Factor
                                                                                                  HCI'Sf
     OOOE.OO
     OOOEtOO
     OpO£.»qO
>-:'2:^iti
     3.I0E-04
     2A4E-04
208E-OI
2.29E-OI
            OOOEiOO
            0006*00
            OOOEtOO
                          NC
                          NC
                          NC
                0 E.OO
                0 E»00
                Q E.QQ
                                                                                             «  e.
          7.20E04
          S.ME04
          4.60E^)I
          SITE 01
                                                                                       NC
                                                                                       NC
                                                                                       NC
                                                                                       NC
                                                                                       NC
                0 E.OO
                0 E.OO
                Q EjQQ
                 999*^9 i,
                0 E.OO
                0 E.OO
                Q E.(
        fca^
        NU -
        RCI • AMMMM* ctoonte InU** iMMd on a
               Caiclnoo«nlc Rlaka    0 E*00

                Wor»l-CaM Carcinogenic
0 E.OO
0 E.OO
Q EtQQ
0 E.OO
0 E.OO
Q
 ,<
0 E.OO
0 E.OO
  L±flQ_
                                                                                                             0  E»00
    "D
08
OQ

-------
                                                     Table IS
                             Assessment of Carcinogenic Risks lor Soils (0-6II. below pavement)
                                                  Texlron Lycomlng
                                              WUUamspon, Pennsylvania
        ROUTE OF
        EXPOSURE
 EXPOSED
    ULAJJML
COMPOUNDS OF
   CONCERN
  RCI
 wcci
(mgAg/dflv)   (mo/ka/djvl
Slope Factor
(l/mo/ha/div)
                                       HCI • SF
                                      WCCI • SF
         Inhalation
          mo/m3
    lagsM

Chid aoe 0-12

   Adutts
    Toluene
TrtcfOoroetiytefte
    Toluene
Tftchloroetiytone
    Toluene
630E02
121E04
471E02
135E04
144E02
B.78E 01
682E44
655£01
759E04
201EOI
    NC
  1.70E-02
    NC
  1.70E-02
    NC
  170602
                                         0 E*00
                                         2 E 06
                                         0 E.OO
                                         2 E 06
                                         0 E«00
                                         4 E06
      NC - Noncardnogefl
      RCI - noeionahte chrenlc Intahe based on average conoeniratton
      WCCI - Worst-case chronic Intake based on maximum concentration
0 E«00
 1 E 05
0 EiOO
 1 E 05
0 E«00
2 £05
                                       Reasonable Carcinogenic Rlsk=   8 E-O6

                                                    Worst-Case Carcinogenic Rlsk=  4  E-05
   -a
08
OO

>>

-------
                                                                TabU 16
                                       Assessment ol Carcinogenic Risks • Lycomlng Creek Surface Water
                                                            TsKlron Lycoming
                                                         Wllllemsporl, Pennsylvania
          ROUTE OF
         UPQSURE
          Wialalion
            mg/rn3
 EXPOSED
POPUiannM
 Chid age 24


Child age 6- 12
COMPOUNDS
1.2-Dichloroelhylene (total)
    ThchkMoethylene
      Manganese
U-DichkMoelhylene (total)
    TrichkMoettytene
      Manganese
1.2-OichkMoethyiene (total)
   RQ
(ma/fco/da-vl
524E-08
9.46E-10
  NV
   WCCI
(tnft/io/div)
                                          TftctUMoetfiyten*
             .  .,  . ^
           Dermal     Chid age 6 12
                           Adufts
                                         2.DE49
                                            NV
                                         120E-06
                                         340E-09
                                            NV
                                  226E07
                                  2.9IE09
                                    NV
                                  340C07
                                  650£^9
                                    NV
                                  523E08
                                  1.0SE-08
                                    HY
                                                  Slope Factor
                                                  (1/mgVkg/day)
               UJfehtoroethylene (total)
                   Trfchtofoetiylene
                     Manganese
               UOicMoroathybna (total)
                   Trichloroertiytene
                          S6SE47
                          1S3£-0«
                          7J6E06
                                  246E06
                                  470E08
                                  34IEOS
                                  456E07
                                  1.46E06
                              NC
                           I70E02
                              NC
                              NC
                           1 70E02
                              NC
                              NC
                           I70E02
                              NC
                                MM *
                              NC
                           1 10602
                              NC
                              NC
                           I.IOE02
                                                                                  HCI' SF
                              0 £,00
                              2 Ell
                              0 E»00
                              0 E*00
                              4 til
                              0 E.OO
                              0 E«00
                              6 E It
                              0 EtOO
                             . 1 &10
                              0 E»00
                              2 E 10
                              0 E«00
                              0 EtOO
                              5 Ell
         "i^eHiofl" "  Chad age 6 12
                                          TricMoioalhytMM
                                            ManganaMi
                                      UOicMoio^hyisna (total)
                                                                4.07E4M
                                                                1 HE^S
                                                      190E05
                                                      363E07
                                                      263E04
                                                      393E06
                                                      I.25E07
                                                      545E05
                                                  NC
                                                 IOE02
                                                  NC
                                                  NC
                                                .IOE02
                                                  NC
                                          0 EtOO
                                          I E 09
                                          0 EtOO
                                          0 EtOO
                                          4 E 10
                                          0 £iOQ
WCCI • SF
 0 EtOO
 5 Ell
 0 EtOO
 0 EtOO
 1 E 10
 0 EtOO
 0 EtOO
 2 E 10
 0 EiOO
                                                     9 £10
                                                     0 EtOO
                                                     5 E  10
                                                     0 EtOO
                                                     0 EtOO
                                                     2 E  10
                                                    _fl_£iOO_
                                          7 £^ia
                                          0 EtOO
                                          4 E 09
                                          0 EtOO
                                          0 EtOO
                                          I E 09
                                          0 EiOO
O
_
^^^^ *^^*^
oo
       NC - Noncarcinogan
       NV - Not voiatte
       RCI - Raasonabla chronic inlaka basad on avataga concanliaikm
       WCCI - Wofkl-casa chronic inlaka basad on maximum concanti alion
                                              Reasonable Carcinogenic Rlsk=    2 E-09

                                                           Worst-Case Carcinogenic Rlsk=   6 E-09

-------
                                                            Table | 7
                                      A»Mstm«nl ol Carcinogenic Risks - Lycomlny CiMk
                                                        Tcilron Lycomlng
                                                    Wllllamtport,
       ROUTE OF
 EXPOSED
 >QPtJLAHQ
Ch*Jag*ft-l2


   Adult
                                         Bwyftum
  RCI
 lAtfd
663E 06
I 06t 08
76«E 09
I Obt 06
260£ 09
202E 09
        WCCI
       89lt 06
       I 6/t Ofl
       I S2L 0«
       I 411 06
       440L 09
       40OC 09
Slop*
    NC
  430t.OO
  I Ibt.OI
    N<;
  4 JOt.OO
   »U .01
     NC - Noncaicinogan
     ItCI • R««tonat*U ctuonk: inltk* b««4Ml on aw«iag« canocnbalion
     WCCI  Woi»l<«M ctMomc miak* b*MMt on mMiamm oono»nli«Uon
HCILJ
 0 t.OO
 s t. oa
 9 I 00
 0 t ,00
 i I. ua
_.2.L.Utt.
 1 £01
0 I. ,00
/ t. Ott
:• » o/
0 I ,01)
'I I OU
Reasonable Carcinogenic Risk-    2 E 07

             Worst-Case Carclnogonic Risk
                                                     3 t 07
    O
00

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        f-J
08
oo
fi
                                                                   Table  11>
                                                      Summary of Lifetime Carcinogenic Risk
                                                               Tailron Lycomlng
                                                            WllUamsporl. Pennsylvania
GROUND WATER

   Treated WMWA Production Wei teld  Scenario A

   Third Sveet Monitoring WeeV - Scenario B

   Oil Ska Overburden - Scenario C (Elm Park Area)

   On Sfce Overburden • Scenario 0 (Plan! Southern Boundary)

   ON-Sto Bedrock-Scenario E

   On-Sfte Bedrock-Scenario F

   Heiavalent Chromium Area • Scenario O

ON-SITE SOILS

LVCOMtNO CREEK SURFACE WATER

LVOOMUM CREEK SEDIMENT

EXPOSURE FROM AIR STRIPPERS

TOTAL FEASIBLE EXPOSURES
   (Scenario A. sols, surface water, air. sediments only)
                                                                             Scenario
                                                                              Typ.
                                                                        RaaaonabUfl)
                                                                         Carcinogenic
                                                                             Rl*k
                                                                                          Wor*l Ca»a (2)
                                                                                          Carcinogenic
                                                                                              Hl*k
                                                                             Faasltoi*
                                                                              0"
                                                                                                                 0"

                                                                                                              •E44 |B2J
                                                                           HypotfMtcal
                                                                           HypotfwttcaJ
                                                                                                            •E-04 [A « BJJ
                                                                                                            ;!. ..-..,  '-.   • '.
                                                          Feasible

                                                          Feasible
   0"

SE 08 (B2|

2£ 00 (B2|
   o"

4E OS (B2|

6E Ofl (B2|
                                                                                          2E 07 (A. Bl. B2|   3E^)7 (A. Bl. B2|

                                                                                               lE^flf           IE 05ft

                                                                                               9E-06            SE05
Note: USEPA guWeUnea kv evaluaJton of caidnogenk: riak apedly a laigei range of acceptable ritfc between lE^ and IE 4.
Shaded value* btolcale ••dmaled polanlaJ risk* whkii exceed ihU guideline.
•  And Infiuenldau Horn WMWAwei laid.
* *  Risk to negHglbie. and therefore rapraaenied as iero.
(I) Based on average concanlraton of compounds In medium.
(2) Based on maximum concenliation ol compounds In medium.
A • Class A (known human) carcinogen
B2 • Class B2 (probabla human) carcinogen
t  Based on reasonable case scenario lot Group 1 (population pietlicitxt in au modeling wheie the maximum r.oncunit aitoo
   should occur).
t f Based on worst-case scenario lor Group I (populanon ptetiicted in an modeling wheia iha maiimum
   should occur).

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     Ncncarcir.cgenic Risk

     The nor.carci-ccer.ic hazard index is  the  ratio of the excected
potential dose to acceptable exposure levels.  Values of less than
unity  .'i.o)  indicate  that  no hazard exists.   The r.oncarcincgenic
hazard indices were obtained by dividing  the chronic daily intakes
by  the appropriate  reference  doses.    Tvo  hazard  indices  were
calculated for the AVCO Lyccming Site:

          reasonable chronic hazard  index (reasonable chronic
          intake/reference dose), and

          worst-case chronic hazard  index (worst-case chronic
          intake/reference dose).

     The  noncarcinogenic  hazard   indices  including  the  total
lifetime  hazard  associated   with   simultaneous  exposure  under
multiple feasible scenario is  summarized in Table 19.


Environmental Risk Assessment

     The environmental assessment represents  a characterization of
risks completed  by  identifying potential exposures to ecological
receptors  and estimating  possible  effects associated  with such
exposures.  The principal ecosystem  of the AVCO Lycoming Site and
surrounding   environment   was   divided . into  three  components:
terrestrial,  aquatic  and wetlands.   There are  no  historical or
archeological sites within the area  surrounding the AVCO Lycoming
Site.


     Terrestrial Community

     The AVCO Lycoming Site property and  surrounding  study area is
in Williamsport, an  urban  area of Lycoming County, Pennsylvania.
Most of  the  plant  property  is developed with  buildings,  paved
surfaces, roads and parking lots.  The small, remaining open areas
consist of maintained lawns consisting of small grass  strips around
a few buildings.  Th« laclc of  an established plant community, the
day-to-day   industrial   activities,   and  the  chain-link  fence
surrounding th« majority of the property impede wildlife from using
the limited cita resources.

     The area surrounding the  facility is characteristic of urban
commercial  and  residential  properties.   Much  is  developed by
buildings,' parking lots, roads, and houses.  Vegetation within  this
urban area is limited to noncontiguous ornamental trees and shrubs.
The residential and commercial  area would appear to provide limited
habitat suitable for various song birds  and  small mammals such as
mice, squirrels, chipmunks,  rabbits,  and groundhogs.  No endangerej


                                63

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                                                                             POOR QUALITY
                                                                                 ORIGINAL
                                           Tabla 19
                         Summary at UfXIm* Kioncarcinog«njc Hazard lndlc«*
                                        T«itron Lyeomlng
                                    Wllllamaport, Pannayrvania
                                                    Scanano       R*ason«oi«'(i)   Wont-Ota'(2)
                                                      Typa	Chronic Hazard   Chronic Hazard
 GROUND WATER
I
    '•eatee WMWA WtH fl«d - Scanano A

|    "hira STBWI Monitoring Wads'" • Scaoano 3
i
                                                                       0"
                                                                                       0"
                                          OCf
                                                                      TE-Of
                                                                                      3E-01
    :«-S:a Cvarouroan • Scanano C (Em Park Ana)
                                                   Hypotf»oc»J
                                          OCf
                                        darru/n
   On-Siv Ov*rourowfl • Scanasio 0
   .P'ant Souinam 3oo"0*ry)
                                         Lttti
                                          OCf
                                                                                      *¥•«*
                                                                                      fltMT
   Crt-Sits Badrock • Scanano E




   On-Sita Badrodt • Scanano F

   Haxavalant Chromium Ana • Scanano G

ON-SITE SOILS

LYCOMING CREEK SURFACE WATER

LYCOMING CREEK SEDIMENT

EXPOSURE TO AIM STWP»tft»
TOTAL PEASUlf OFO6UIV
   (Sccnano A, idto. Mtea w»ar. air,
                                          CCf
96-03

1E-03

SE-03

iE-oat

7E-02
 9E-01

 3E-03

 7E-03

56-03TT

 9€-01
                                        only)
Noe»: EPA quBjaino lor r^amien ol nonoitinoganic ^xard jnde» apaofy « vHu« o< 1
       .ojicaa ftiidi «ie**d 1 irxfcui txct flw« ia fw poMntt tar •dxafu hsalft
       txpoat^ oondien*. Huard indon grMitr 9tn 1 m
•in eases wtwra etuorae hazard it gnmm tfian on*, tw hazard
 Th«*t groupino* ara pravidad oVaedy baiew tf» total hazard
••Hazards rapratantad «• zare tinea eompeunda vara not
  WMWA at fw v*l flaid.
                                                                               witi »• drfrwd
                                                                         on targat organ*.
                                                    in tfia •ffluant ground waaw tamptoa
         anafy«eal r»aUt» for WMWA wal IMd Mluant ground waaw aamptoa,
OCE • i.2-0icfaoroa»y)ana (Btafl
{ i ) - Basad on avaraga cancan rattan o( eompounda in a madkjm
(2) • Basad on mawnurn conoantraton of comooundt in a madun
   snould occur).
   Basad on worsj-caaa scanano for Gnxaj 1 (popUaton
                                                           ar modalnQ whara *>a ma»murti conBadWSort

                                                     n ar medasng whara tha maonum conesnnaon

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species have beer,  identified within the area surrounding the AVCD
Lyccaing Site.


     Aquatic Ccar:ur.ity

     Lycoaing   Creek,   the  closest  watervay  to  the  site,  is
approximately  1,500  feet east and southwest of the site.  Much of
the  natural ecology  of the Lycoming  Creek study area  has been
repeatedly  altered in the past  by  logging  activities,  levee and
flood wail  construction, and road construction.  within the study
area, six autcncbiie bridges and  two railroad bridges  span Lycor.ir.g
Creek.  The natural  flocdplain of Lycoaing  Creek has been changed
by a flood protection levee systea along the east and west shores.
The  levee  systea was built by the  U.S.  Aray Corps of Engineers'
3altiaore District in 1955.

     Today, the ecology along Lycoming Creek is fairly stable with
the only streaa and floodplain alterations occurring froa naturally
high waters due to spring  thaws  or heavy rains.  Aquatic habitat
in the study area of Lycoaing Creek is coaposed of  riffle and pool
areas.  The substrate of  the stream is predominantly coaposed of
equal amounts  of boulders and rubble with the  interstitial  spaces
filled with sand and gravel.  Soae small-, narrow strips of emergent
vegetation  also exist along the  edges  of the stream.

     Pennsylvania  Department of  Environmental Resources  (PADER;
classifies  streams in Chapter  93 of their  rules and regulations.
Sections  93.3  and  93.4 define  protected  and  statewide  uses of
streams.  From the confluence of Long Run (north of the village of
Cogan Station, 5.5 miles upstream of Williamsport)  to the Lycoming
Creek mouth at the West Branch Susquehanna River, Lycoming Creek
is classified  by Chapter 93 as a warm  water fishery.  Upstream of
Long Run, the  stream is classified as a cold water  fishery.  The
Pennsylvania Fish Commission stocks Lycoming Creek with  trout  from
Cogan Station  upstream  to tha Lycoming County  line.

     As part of tha RI,  qualitative kick-net and semi-quantitative
aultiplate  macroinvertebrate  samples  were collected  from  five
stations along Lycoming Creek.   Conclusions from the qualitative
sampling results indicate good water  and sediment  quality  at  four
of   the   five  stations   based   on   the   diverse,   healthy,
aacroinvertebrate  communities  observed  at  these  stations.   The
lower diversity and numbers observed  at  one of the stations may
have been due to the generally poor physical habitat  available for
colonizatipn and/or high stormwater  surges from the storm  sewer
which scout the substrate  and cause unstable  habitat conditions.
Conclusions from the semi-quantitative multiplate sampling  results
indicate  good  water   quality   based   on   the diverse,   healthy
macroinvertebrate  communities at all  stations.
                                65

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     Wetland Community

     A field  investigation  of the study  area  identified  several
wetland areas along the banks of Lycoming Creek.   These areas are
confined to  the  loo-year floodplain within the  flood  protection
levee system that parallels  the  east  and  west  shores  of Lycoming
Creek.    Wetland  systems  along  the  stream's   shores  include
palustrine emergent,  scrub/shrub, and  forested wetlands.  Emergent
and  scrub/shrub  wetlands exist  along most  of  Lycoming  Creek's
banks.  The forested wetland areas exist near the  mouth of Lycoming
Creek and  along the  north  bank  of  the West  Branch  Susquehanna
River.  Both Lycoming Creek and the West Branch Susquehanna River
are classified by the  National Wetland Inventory Map  as riverine
wetland systems.


     Identification of Potential Receptors

     The potential receptors for possible site-related impacts to
the  surrounding  ecosystems   are  populations  of  aquatic  and
terrestrial organisms  inhabiting Lycoming Creek  and the forested
and shrub wetlands along  Lycoming Creek.   The potential receptor
populations are  characterized below in terms  of terrestrial and
aquatic organisms.

     wildlife populations along  the stream appear to  be healthy
for an urban area.  Wildlife and  signs  of  wildlife  observed within
the  forested  and  shrub areas   along Lycoming  Creek  included
groundhog,  rabbit,   raccoon,  gray  squirrel,   garter   snake,  and
various species of birds.

     The Lycoming Creek supports a diverse population of warm and
cold water fish.   Fish  species that are known to occur in the Lower
West Branch of the Susquehanna River are listed in  the  RA for this
site.   Many of  these species would  also occur within Lycoming
Creek.  Game  fish most likely to  inhabit Lycoming Creek include
small mouth bass, rock bass, bluegill, brown and yellow bullhead,
yellow perch,  chain pickerel, and brown trout.   Other wildlife
species that may inhabit Lycoming Creek include several species of
snakes,  turtles, and amphibians.


     Exposure Assessment

     Exposure assessment is the process of measuring or estimating
the intensity, frequency, and duration of exposures to  a compound.
The purpose of this  assessment is to determine  the potential for
exposure   to  site-related   compounds   by   potential  receptor
populations  inhabiting Lycoming Creek and the  surrounding  study
area.  Chemical  analysis of the surface  water  and sediments, as
well as the  collection of macroinvertebrates  from Lycoming  Creek
during the remedial  investigation was the basis for the exposure

                                66

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assessment:.  These data provide a direct assessment of the stream's
physical and biological features.

     Very few VOCs were detected in the  sediment samples.  TCE was
detected in SD-4 at a  trace concentration of a ppb and in SD-3 at
a quantitatively estimated concentration of  1 ppb.  Chloroform and
toluene   were   also   detected   at    quantitatively   estimated
concentrations in SD-3. Mo pesticides or PCBs were detected in any
sediment samples.

     A number of semi-VCCs, all polyaromatic hydrocarbons (PAKs),
were detected  in  the sediments at Stations 2 and 3.   Eight PAHs
were  quantitatively  detected  at  Station  3  and only  two  were
detected  at  Station  2.     PAHs   are   formed  during  incomplete
combustion of organic  matter  in industrial  furnaces,  residential
heating units, motor vehicles, and fires, and are found primarily
in particulates in air, soil, and sediments.  These compounds are
also typically associated  with  asphalt/tar  based materials.   The
presence of these  compounds  in  the sediments  at Stations 2 and 3
are not  believed  to be related  to the site since  most of these
compounds have  not been detected  in either groundwater or soil
samples collected from the  facility.  The Oliver  Street  storm sewer
travels 2,300 feet through Williamsport prior to discharging into
Lycoming  Creek   immediately   upstream   from   Station  3.    The
concentrations detected in the  sediments at  Station  3  are most
likely caused  by stormwater  runoff  from the western  portion of
Williamsport.


     Risk Characterization «

     The  risk characterization  integrates  information  from the
ecological  characterization,  exposure  assessment,  and  toxicity
evaluation to  produce  an  estimate of  risk.    The  surface water
results shoved no exposure of any  site-related compounds.   Good
water quality  is  also  indicated by  the semiquantitative Hester-
Dendy results.  The macroinvertebrate communities which  colonized
the multiplate samplers at all stations  were diverse and  consisted
of sensitive species such as stoneflies,  caddisflies, and mayflies.

     The sediment data  indicated the presence of a  number of  PAHs
at Station 3 and a few  at Station  2.  all of these  concentrations
were below the available  sediment  criteria for the protection of
aquatic life.  In addition, the source  of the PAHs  is  most  likely
the result  of the  stormwater runoff  from the  roads  within the
western section of Williamsport and not  a  result of the Textron
Lycoming  facility.    The  inorganic  analyses   of  the  sediment
indicated  the presence of  inorganics  in  the  sediments  at all
stations.   Most  inorganics  are  naturally occurring  and  their
concentrations are influenced by a watershed's geology, soils, and
industrial  discharges.    Six  of  the  12 inorganics   detected
(aluminum,  barium,  cobalt,   iron,  magnesium,  and  nickel)   were

                                67

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present at higher concentrations at the background Station 5 than
the other  downstream  stations.   The remainder  of  the inorganics
detected  were  below   the   average  Apparent  Effect  Threshold
Concentration.    Cadmium  and  lead  were  also  well  below  the
individual    biota    indicator's   Apparent    Effect   Threshold
Concentrations.   The  criteria  proposed  by   the  New York  State
Department of Environmental Conservation  (NYSDEC)  were  exceeded
for cadmium,  chromium,  lead,  iron, and nickel,  however one of these
concentrations was  above the NYSDEC  Limit of  Tolerance  values.
Chromium,  iron,  and lead were  also  below the  NYSDEC background
concentration.  Chromium, a  site-related  compound  is also at the
average concentration found  in eastern U.S. soils.   Therefore, it
is possible  that  the  elevated level of chromium  in the sediment
from Station  3 may be the result of soil erosion and discharge to
Lycoming  Creek  from   the  Oliver  Street  storm  sewer  outfall.
Considering the above,  it  is unlikely  that exposure to sediment-
related compounds is  significant.  The sediment quality does not
appear  to  be  impacting the  macroinvertebrate  community  or the
aquatic system at any of the stations.


Conclusion of Summary of Site Risks

     Actual  or threatened releases of  hazardous  substances  from
the 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.  The
Risk Assessment did  not identify any threats due to  exposure to the
air or  direct contact.   The only media  of   concern  at  the  AVCO
Lycoming Site is through exposure to contaminated ground water.


Description of Alternatives

     The  Superfund  statute  and  regulations  require  that the
alternative chosen to  clean up a hazardous waste site meet several
criteria.   The  alternative must  protect human  health  and the
environment,   meet the  requirements of  environmental  regulations,
and  be  cost  effective.   Permanent  solutions to  contamination
problems should  be  developed wherever possible.    The solutions
should  reduce   the  volume,   toxicity,   or   mobility   of  the
contaminant*.  Emphasis is  also placed on treating the waters at
the site,  whenever  this is  possible,  and on applying innovative
technologies to clean up the contaminants.

     In accordance  with  40  C.F.R. §300.430  a list of  remedial
response actions  and  representative  technologies were identified
and screened to meet the remedial action objectives at this  site.
The FS  studied a variety  of  technologies  to  see  if  they  were
applicable for  addressing  the  contamination  at  the Site.   The
technologies  determined to  be most applicable to these materials
were developed into remedial alternatives.   In addition, the EPA

                                68

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has added the Mo Action Alternative (Alternative  i) as required by
the  National  Contingency  Plan  (NC?).    These  alternatives  ar^
presented and  discussed below.  All costs and implementation tiai
frames provided  for the alternatives below are estimates.

Ccmr.on Elener.ts:   All  of  the alternatives being considered would
include common components.  Each alternative except the "no action"
alternative  would  include the continued operation of the existing
ground-water recovery wells and continued ground-water monitoring
to measure concentrations of site  related  constituents.  EPA would
review the Site every five years to ensure continued protection to
human  health and  the  environment for each  of  the alternatives,
including the  "no  action"  alternative.   Alternatives GW-3, GW-4,
and  GW-5 include  additional on-site  ground-water  recovery  and
treatment.    Also,  institutional controls  have  been   added  to
alternatives GW-3, GW-4, and GW-5.


     Alternative 1:   Mo Action

          Capital  Cost:         $  - 0 -
          Annual O&M Cost:      $  - '0 -
          Present  Worth:        $  - 0 -
          Months to Implement:     - 0 -

     The NCP requires that a "no  action"  alternative be  evaluated
as a  baseline  for comparison to  other  alternatives.   Under thi
alternative, no  remedial  action would be  talcen at the site.  The
existing ground-water  extraction  and  treatment systems would not
be  operated,  however,  ground-water  monitoring  would   continue.
There are no ARARs associated with this alternative.  Alternative
1 would  not  comply with the CERCLA preferences for a remedy that
employs  treatment to  reduce toxicity, mobility or volume  as a
principal threat.

     At the AVCO Lycoming Site,  remedial actions have already been
undertaken,  pursuant to a COA with PADER.  Thus, a true Hno  action"
alternative  is not possible.   The  best  approximation  of a "no
action"  alternative  is  ceasing  current actions, that is shutting
off the on-site  and off-site ground-water extraction system.  The
no-action  alternative   would  include   ground-water  monitoring
consisting of sampling and analysis in accordance with the existing
PADER COA.
     Alternative GW-1;   No  Further  Action

          Capital Cost:           $ - 0  -
          Annual O&M  Cost         $ 10,100
          Present Worth:          $160,000
          Months to Implement:     - 0  -
                                69

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     Under this  alternative,  EPA  would take  no further  action
beyond the continued operation  of  existing  ground-water  recovery
and  treatment  on-site and  off-site to  prevent  exposure to  the
contaminated media or to reduce  risk at the  site.


     Alternative GW-2;    Institutional Controls

          Capital Cost:          $ 48,000
          Annual O&M Cost:        $ 11,300
          Present Worth:          $220,000
          Months to Implement:     6-9


     This alternative consists of  institutional controls including
deed,  zoning,   and/or  ownership   restrictions   to  limit  future
property use to those activities compatible with site conditions.
This  alternative   would   also   involve  the   construction  and
maintenance of a fence around the  western portion of the site to
prevent unauthorized entrance in this area.

     There are no ARARs associated with this alternative,  and it
would not  comply with the  CERCLA preferences for  a  remedy that
employs  treatment  to  reduce  toxicity,  mobility or volume  as  a
principal threat.


     Alternative GW-3;   Ground-water recovery, chemical treatment
                         for  metals,  air  stripping,  emissions
                         controls, discharge of  treated water

          Capital Cost:          $2,500,000
          Annual O&M Cost:        $  442,900
          Present Worth:         $9,300,000
          Months to Implement:     18-21

     This alternative  consists  of a ground-water recovery system
to  contain  and collect   contaminated  ground  water  on-site.
Approximately  33 recovery  wells  would  be  installed  around the
downgradient perimeter of the site to prevent any further off-site
migration of contaminants.   The recovered  ground water would be
pumped at 66 gallons per minute (gpm)  froa the western site area
and piped to a  dedicated on-site treatment facility  and treated to
reduce chromium and subsequently precipitate  it  and other metals.
This ground-water stream would then be combined with the remainder
of the  recovered ground water  being pumped at  177 gpm from the
eastern  and  central portion  of the site.   The entire recovered
ground-water stream would then be pumped to an air stripper for VOC
removal.  The off-gas from the air stripper would be treated by the
best available technology which includes carbon  treatment or  fume
incineration.   The treated  ground water would  be discharged to
Lycoming  Creek.   In  addition,  institutional  controls have  been

                                70

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added to this alternative  in the fora of limiting future property
use to those activities compatible with site conditions prevent any
potential  for direct contact with contaminated soils.

     The metals treatment facility  would consist of the following:

           a modular chromium reduction and chemical precipitation
           system  (coagulation,   flocculation,  and settling)  for
           metals precipitation, and

           use of  the  existing  en-site WWTP for solids dewatering
           via a piate-and-frame  filter.

     An  iron  coprecipitation system  would be used  for chromium
reduction  and dissolved metals removal, using  ferrous sulfate and
polymer, at a pH  of  9.   It is  assumed that the sulfuric acid and
caustic  (used  for pH  adjustment) , and ferrous  sulfate  will be
stored and fed from the indoor tanks  for the existing system.

     Sludge will  be  recirculated through  the  process to improve
metals removal.  The sludge will be dewatered  and is estimated to
contain 30 percent solids  after dewatering.  The  sludge will  then
be transported  off-site to an approved hazardous waste disposal
facility.

     The air stripping system  would include feed pumps, a blower
(1,300 cfm), and a packed  tower 4  feet  in  diameter with a 20-foot
packed depth and an air-to-water ratio of 40:1. Effluent  from the"
air strippers would be discharged to the Oliver Street storm sewer
and thereafter to  Lycoming Creek.   Effluent limitations would be
determined in coordination with  PADER during  the remedial design
phase.  PADER limitations will likely require VOC removal, chromium
reduction, and metals removal.  This overall treatment system would
operate until the  ground-water  cleanup ARARs were achieved or as
long as technically practicable.

     The major ARARs associated with  this  alternative include the
Safe Drinking Water Act, the Clean Air  Act and the PADER ARAR for
ground water for hazardous substances.


     Alternative GW-4;   Ground-water recovery, chemical treatment
                         for metals, chemical oxidation, discharge
                         of treated water

         'Capital Cost:          $  2,400,000
         'Annual O&M Cost:       $   526,000
           Present Worth:         $10,000,000
          Months to Implement:      13-21

     This  alternative  is  equivalent  to Alternative GW-3,  except
for the use of chemical oxidation for  organics removal,  instead  o

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air stripping.  As in Alternative GW-3,  the sludge generated from
the metals'  removal  process will  be  transported off-site  to  an
approved hazardous waste disposal facility. The chemical oxidation
process is most likely to include hydrogen peroxide addition to the
combined ground-water flow to oxidize organics.  Catalysis of this
process  would  use ultraviolet  light  to hasten  the  oxidation
reaction and to carry the reaction to completion to carbon dioxide,
hydrochloric  acid, and  water.   Prefiltration will be  needed for
gross suspended solids and iron removal before chemical oxidation
for that portion  of  flow  not treated  via chemical precipitation.
In  addition,  institutional  controls  have  been added  to  this
alternative  in  the form of  limiting future property  use to those
activities compatible with site conditions.

     The oxidation unit proposed would be sized for 243 gpm.  The
effluent  from  the unit  would  be discharged   as  described  in
Alternative GW-3 above.

     The major ARARs associated with this alternative include the
Safe Drinking Water Act, the Clean Air Act and the PADER ARAR for
ground water for hazardous substances.


     Alternative GW-5:   Ground-water recovery, chemical treatment
                         for  metals.   air  stripping,  emissions
                         controls,  reiniection  and  discharge  of
                         treated  water,   and  in  situ  biological
                         treatment

          Capital Cost:           $ 3,300,000
          Annual O&M Cst:         $   650,500
          Present Worth:         $13,000,000
          Months to Implement:       18-21

     This  alternative  would   consist   of   the  components  of
Alternative GW-3 plus in situ biological treatment for ground water
beneath the  Site.  The  recovery well  system for this alternative
would be the  same  as  that described in Alternative GW-3, but the
discharge  scheme would differ due to  the  need  for upgradient
reinjection of ground water to facilitate  in situ bioremediation.
The ground  water from the western portion of the  site would be
treated  for metals,  and  the  entire recovered  stream  would be
treated for  organics,  as  in Alternative  GW-3.   Also,  the  sludge
generated from the metals' removal process will be transported off-
site to an approved hazardous waste disposal facility.

     The fair  stripper used  in  this alternative has been sized to
meet the  more stringent water  quality  criteria for reinjection.
The air  stripping system would  have  a  packed  tower  4  feet in
diameter with a 30-foot packed depth and  an air-to-water ratio of
80:1.   The off-gas from the  air stripper would be treated  by the
best available technology which would include carbon treatment or

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fume  incineration.   An  estimated  195 gpm of  the  treated ground
water would be discharged as described in Alternative GW-3 above
and  the  remaining 43 gpm would  be reinjected.  The  water  to  L
reinjected would be treated in an upflow  filtration unit to remove
suspended  solids and  metals  and would  then be  dosed  with  an
oxidizing  agent  such  as  hydrogen   peroxide   (at  an  estimated
concentration of 500 ppm) and nutrients  (nitrogen and phosphorus)
before discharge to the injection wells.   Eight reinjection wells,
each recharging at 6 gpm for a total  of approximately  48 gpm being
reinjected, are  proposed for  this alternative.   The  locations  of
these wells  will be  based on  the need  to  distribute nutrients
evenly within the overburden  VOC plume  to enable the bacteria  to
efficiently degrade the VOCs.   In addition, institutional  controls
have been added to this alternative in the form of limiting future
property use to those activities compatible with site conditions.

     The major ARARs associated with  this alternative include the
Safe Drinking Water Act, the Clean Air Act and the PADER  ARAR for
ground water for hazardous  substances.


Sununarv of Comparative Analysis of Alternatives

     A detailed  analysis was  performed  on  the  six  alternatives
using the nine evaluation criteria specified  in the NCP 40 C.F.R.
§300.430(e)(a) in order to select a final remedy  for Operable Uni^
(OU-l) .    The following  is  a summary of the  comparison  of ear
alternative's strengths  and weaknesses with  respect  to the nin
evaluation criteria.   These nine  evaluation criteria,  which are
listed in Exhibit A, can be categorized  into  3 groups; threshold
criteria, primary balancing criteria, and modifying criteria.

     THRESHOLD CRITERIA

     - Overall protection of human health and  the environment
     - Compliance with  applicable or relevant and appropriate
     requirements (ARARs)

     PRIMARY BALANCING CRITERIA

     - Long-term effectiveness
     - Reduction of  toxicity, mobility, or volume through treatment
     - Short-term effectiveness
     - Implementability
     - Cost
        i
     MODITYING CRITERIA

     - Community acceptance
     - State acceptance
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           EXHIBIT A. DMCRIPTIOM OF IVMOATIOM CXITIHIA



addresses whether or not a remedy will:  cleanup a site to within
the risfc rang*; result in any unacceptable impacts; control the
inherent hazard (e.g., toxicity and mobility) associated with a
sits; and minimize the short-term impacts associated with
cleaning up -the site.

Compliance with AJAR 'a - addresses whether or not a remedy will
meet all the applicable or relevant and appropriate requirements
of other environmental statues and/or provide grounds for
invoicing a waiver.

Long-term Effectiveness and Permanence - refers to the ability of
a remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met.
Reduction of Toxicity. Mobility, or V«?i^** through Treatment -
refers to the anticipated performance of the treatment
technologies that may be employed in a remedy.

Short-term Effectiveness -  refers to the period of time needed
to achieve protection, and any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.

Impleaentability - describes the technical and administrative
feasibility of a remedy, including the availability of materials
and services] needed to implement the chosen solution.

Cost - includes the capital for materials, equipment, etc. and
the operation and maintenance cost.

Support Agency Acceptance - indicates whether, based on its
review of the RX,PS and £he Proposed Plan, the State concurs
with, opposes, or has no comment on the preferred alternative.

          Acceptance - will b« assessed in the Record of Decision
following a review of the public comments received on the RI, FS,
and the Proposed Plan.


                                              POOR QUALITY
                                                 ORIGINAL
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     These evaluation criteria relate directly to requirements in
Section  121 of CZHCLA,  42 U.S.C. Section 9621, which determines
the overall feasibility and  acceptability of the remedy.  Thresho'
criteria must be satisfied in order for a remedy to be eligible fo
selection.   Primary balancing criteria are  used  to weight major
trade-offs between  remedies.   State  and community acceptance are
r.cdifying  criteria that  are  formally  taken into  account after
public corrjr.er.t is received  on the Proposed Plan.  The evaluations
are as follows.


     Overall Protection of  Human Health and  the Environment

     Due to  contaminant migration  and contaminant concentrations
that  exceed  health-based  levels,  Alternative  1  would  not  be
protective of human health  or  the  environment.   Since protection
of human health  and the environment  is  a  threshold criteria for
any Superfund  action,  this alternative will not  be selected and
thus need not be evaluated  further.

     Alternatives GW-i and GW-2 would continue to recover  and treat
the contaminated ground water utilizing the  existing recovery and
treatment  system.    These alternatives   would  provide   limited
protection.  Alternatives  GW-3,  GW-4,  and GW-5 minimize off-site
migration  of  contaminants  in ground  water  flowing  beneath the
plant.   These  alternatives would provide  adequate  protection by
controlling and reducing risk through a combination of containment-
treatment  and  institutional  controls.   Alternative  GW-3 wou..
contain and treat the contaminated ground water on-site while the
off-site contaminant  plume is recovered and treated through the
existing ground-water  treatment  system.   The effluent limits for
the discharge or  treated ground water would be met  for alternatives
GW-3,  GW-4, and GW-5.


     Compliance with ARARs

     CERCLA  requires  that  remedial  actions meet  applicable or
relevant and appropriate requirements (ARARs) of other  federal and
state environmental laws,  or  that  there are grounds for invoking
a waiver.  These laws may  include, but  are not limited to:  the
Toxic  Substances  Control  Act,  the  Clean  Water  Act,  the  Safe
Drinking Water Act,  and  the  Resource Conservation and Recovery Act.

     A "legally applicable" requirement is one which would  legally
apply to the  response  action if that action were not  taken pursuant
to  Sections  104,   106,  or  122  of  CERCLA.    A  "relevant and
appropriate" requirement  is one that, while not  "applicable",  is
designed to  apply  to  problems  sufficiently  similar  that  their
application is appropriate.
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     All the alternatives, except for the "no.action" alternative
(Alternative 1),  will meet their  respective ARARs as referenced in
the FS.  These include compliance with the Clean Air Act and PADER
Air Quality Standards for emissions  from  the Site.  All discharges
of treated ground water  to Lycoming Creek  from Alternatives GW-l
through GW-5 should meet National Pollution Discharge Elimination
System (NPDES) requirements developed pursuant to the Clean Water
Act and PADER Bureau of Water Quality Management Standards.

     The  goal of  the  ground-water  remediation  is  to  achieve
background ground-water quality as required by PADER.  Alternatives
GW-l and GW-2 would  probably not  achieve  the Pennsylvania ARAR for
ground water in a reasonable time period.


     Short-term Effectiveness

     Alternatives GW-l  and GW-2  consist of pumping and treating
ground  water.    These  alternatives would  utilize  the existing
ground-water recovery and  treatment system.  The remediation time
frame associated with these alternatives  is difficult to determine
but is expected to exceed that required for Alternatives GW-3, GW-
4 and GW-5  since no additional recovery wells would  be constructed.
Short-term risks would be  associated with the construction of the
ground-water   treatment   facilities  and  the   installation  of
additional ground-water recovery wells for Alternatives GW-3, GW-
4,  and GW-5.   These  risks  include potential  exposure  to VOC
releases during  well installation  and  worker  injury  during the
construction of the  associated ground-water treatment system.  The
risks could  be minimized  by the  use of personnel protective gear
by these  workers.    Also,  the community will  be  protected from
potential VOC releases by continuous air monitoring during the well
installation.


     Long-Term Effectiveness

     For each  of  the alternatives,  long-term  management  will be
required, including  monitoring of the effectiveness of the recovery
and treatment  system.   During  operation  of the treatment  system,
monitoring of  surface water, ground water,  and treated effluent
will be  required.   The potential for contaminants to  exist as  a
separate,  dense  phase in  the  bedrock aquifer  will require that
ground-water recovery be conducted for a  prolonged  period,  and can
be evaluated at each of the  five-year effectiveness reviews.
         i
         (
     Reduction of Toxicity, Mobility or  Volume

     Alternatives  GW-l  and  GW-2  provide  little  reduction  of
toxicity, mobility and volume as neither alternative contains the
contamination on-site.   This allows only for the  existing volume

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of contaminated ground water with its inherent toxicity, mobility
and  volume to  be  collected  and treated.   Alternative  GW-5  is
expected  to  provide the highest degree  of  toxicity,  mobility  or
voiurr.e reduction because of the additional reduction in VOC level
in  the aquifer  by bioreaediation.   The ground-water  treatment
systems in Alternatives  GW-3  and GW-4  are anticipated to provide
fairly equal reduction in VCC  levels as compared to Alternative
GW-5.
     Implementability

     Implementation   of  Alternative  GW-5   presents  potential
obstacles  relative to  technical  feasibility.   This alternative
requires a substantial degree of permitting,  and bioremediation is
an   innovative   technology   with  associated  uncertainties  for
reliability,  ease of  adding  additional  remedial  measures,  and
construction/operation.     Potential  problems  associated  with
Alternatives  GW-3  and GW-4  are not expected  to  be  significant.
Alternative GW-4  is  a  less  widely used method.  Alternative GW-3
is  expected  to  be the  most  reliable  of the  treatment systems
considered.
     Cost

     Alternative GW-3 provides the most favorable costs  (relative
to  Alternatives GW-4  and GW-5)  and provides  essentially equa
benefits relative to Alternative GW-4 and  somewhat lesser benefits
than Alternative GW-5, which costs substantially more.  The costs
for each alternative are  better defined in the FS.
     State Acceptance

     The  Commonwealth  of  Pennsylvania  has  concurred  with the
selected remedy.


     Community Acceptance

     A public meeting on the Proposed Plan was held on May 2,  1991,
in Willieuuport, Pennsylvania.  Several comments were  received  at
the meeting.   Community acceptance is  more fully assessed in the
attached  Responsiveness  Summary.   The   Responsiveness Summary
provides a thorough review  of the  public comments received on the
RI/FS and the  Proposed Plan, and EPA's responses to the comments
received.
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Selected Remedy

     Based upon the  consideration  of  the  requirements of CERCLA,
the  findings  of  the   RI/FS,   the   detailed   analysis  of  the
alternatives, public  comments, and other documents set  forth  in the
index  for the  Administrative  Record,  the  remedy selected  for
implementation at  the  AVCO Lycoming  Site for Operable  Unit 1 is
Alternative  GW-3,  ground-water  recovery,  chemical  treatment  for
metals, air stripping, emissions controls,  and discharge of treated
water.   Alternative GW-3  represents the best  balance among the nine
evaluation criteria.
     Goal

     The goal  of  the selected remedy  is  to restore contaminated
ground water  to its  beneficial  use, which  is,  at this  Site,  a
potential  drinking-water supply.    Thus,  ground  water  will  be
treated until  contaminant levels  reach background,  MCLs,  or non-
zero MCLGs, whichever are lower.   Based  on information obtained
during the RI, and the analysis of all remedial alternatives, EPA
and  the  Commonwealth of  Pennsylvania  believe that  the selected
remedy may be  able to achieve this goal.

     The selected remedy will include ground-water extraction for
at least 30 years,  during which time  the system's performance will
be carefully monitored on a regular basis and adjusted as warranted
by the performance data collected  during operation.  Modifications
may include any or all of the following:

     a) at individual wells where cleanup goals have been attained,
    pumping may be discontinued;

     b)  alternating  pumping at  wells  to  eliminate  stagnation
     points;

     c) pulse  pumping to allow  equilibration of the ground-water
     system and  to encourage absorbed  contaminants  to partition
     into ground water; and

     d) installation of additional recovery wells to facilitate or
     accelerate cleanup of the plume.

     To ensure that  cleanup  goals continue to be maintained, the
ground water  will  be monitored at those  wells where pumping has
ceased eyery five years following discontinuation of pumping.
         i

     Performance Standards

     In  order  to  restore  contaminated  ground  water   to  its
beneficial  use,   the remediation system  implemented  under the

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selected remedy shall operate until Site-specific remediation goals
are  achieved.    Thus, ground  water  would  be  treated until  the
contaminant  levels  reach  background,  MCLs,  or  non-zero  MCLG-
whichever are  lower.

     Background concentrations for the contaminants  of concern will
be determined  by complying with the procedures  for ground-water
monitoring as  outlined in  25  PA  Code S264.97.   In  the event that
a contaminant  is  not detected in samples taken for determination
of background concentration, the  detection limit for the method of
analysis utilized with respect to that contaminant shall constitute
the "background" concentration of the contaminant.  As of the date
of this ROD,  the  appropriate methods and their detection limits are
as follows.

Contaminant                    Method                Detection
                                                     Limit(ug/1)

Trichloroethylene              601/602                    0.12
1,2-Dichloroethylene              "                       0.10
vinyl Chloride                    "                       0.18
Barium                   SW-346/7000 (Furnace)            2
Beryllium                         "                       0.2
Cadmium                           "                       0.1
Lead                              "                       1
Manganese                         "                       0.2
Hexavalent Chromium               "                       1


     If  implementation of  the  selected  remedy  demonstrates,  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 (which will be
the edge  of the  site property  where  contamination  is  furthest
detected),   the  EPA  in  consultation  with  the  Commonwealth  of
Pennsylvania,  will  amend  the  ROD or  issue  an  Explanation  of
Significant  Differences  to  inform the  public   of  alternative
remediation goals.

     The discharge levels  for contaminants  in  the  treated ground-
water effluent will be determined by EPA in consultation with PADER
as part  of  remedial design  in  accordance  with  the substantive
requirements of Pennsylvania's NPDES program.


Summary of the Selected Remedy
         r
     As discussed  under  the Description of  Alternatives section,
the selected remedy  consists of  on-site  ground-water  containment,
recovery and treatment.  Under   this   alternative,   ground-water
recovery wells shall  be installed on the downgradient side  of  the
facility to contain  contaminated ground  vater  and  control  further

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off-site  migration.    The  contaminated  ground water  shall  be
recovered through a series of existing and newly  installed recovery
wells.  The recovered ground water  shall  be chemically treated for
metals and  air  stripped  for VOCs.   The  vapor phase  from  the air
stripper shall be treated by the best available control technology
and the treated  ground water shall be discharged  to Lycoming Creek.
In  addition,  institutional controls  have  been added  to  this
alternative  to  limit  future property use.

     The  selected  remedy will only  address  that portion  of the
contaminated ground  water  that exists on-site  (Figure  14) .   The
off-site  contaminated ground water  will continue to  be  treated
through the  existing  off-site ground-water recovery and treatment
system in accordance  with the COA between PADER  and AVCO Lycoming.
The selected remedy will  not address  contaminated soil at the Site
because it does  not pose  a risk to human health or the environment,
but the fact that  it  will  remain  and is considered  a waste means
that there  is  a statutory  requirement to review  this situation
every five years.


Statutory Determinations

     Section 121 of CERCLA requires that  the selected remedy:

        be protective of human health and the environment;
        comply with ARARs;
        be cost-effective;
        utilize  permanent  solutions  and alternative treatment
        technologies  or  resource recovery technologies to the
        maximum extent practicable; and
        address  whether  the preference for treatment as  a
        principal element is satisfied.

     A description of how the selected  remedy  satisfies  each of
the above statutory requirements is provided below.


     Protection of Human Health and the  Environment

     Based on the risk assessment, this  remedy  will be protective
of human  health and  the environment  over time as  ground  water
containing site-related contaminants would not move across  the Site
boundary.  Recovery and  treatment  of ground water at the  southern
site boundary  will  permanently  remove  contaminants  from ground
water  beneath  the site.   The treatment system is  expected to
provide adequate treatment  to  achieve ARARs for discharge.   This
alternative  will  reduce   the  concentrations  of  site-related
compounds  in the  ground water  beneath  the site;  however,  the
ability to attain ARARs  in the two aquifers via long-term ground-
water recovery  and treatment is  not Known.  A  more comprehensive
ground-water recovery system is proposed in this remedy,  in

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comparison with current recovery efforts.  Therefore, the mass of
contaminants that is currently  leaving  the  plant property in the
ground  water,  and  the  risk  associated with  these  contaminants
(assuming   future  hypothetical   ground-water   use)   will   be
significantly  reduced.    This remedy will  achieve  the  remedial
action  objectives  over   time   via   ground-water  recovery  and
treatment.  No unacceptable short form risks or cross-media impact
will be caused by implementing the remedy.


     Compliance with Applicable  or Relevant and Appropriate
     Requirements

     The selected remedy of recovery  and treatment of ground water
will comply  with all  chemical-,   location-,  and action-specific
ARARs pertinent to this action.   Except where specifically noted,
the  site-specific  limitations  to the   following  ARARs  will  be
identified in the remedial design phase.

     1.  Chemical-Specific ARARs

          a.    Chapter  123  (25  Pa.  Code SS123.1  et.seg.)  - This
     chapter   on   "Standards  for   Contaminants"  sets  forth
     requirements for fugitive  emissions,  including open burning
     and   demolition   activities;   specific   limitations   for
     particulate  matter   sulfur  dioxide,   odor,   and  visible
     emissions.

          b.    Chapter  127  (25  Pa Code SS127.1 et.seq.)  - This
     chapter  on  "Construction,   Modification,   Reactivation  and
     Operation  of Sources"  requires the  use of  Best Available
     Technology  (BAT)  for control of new  sources,  plan approval
     and operating  permit requirements, and special requirements
     for sources in nonattainment areas.

          c.   Chapter 92   (25 Pa. Code  SS92.1 et.seq.)  - This
     chapter sets forth provisions for  the administration of the
     NPOES program  within Pennsylvania, and establishes criteria
     for  the  content   of  NPDES  permit applications,  effluent
     standards, monitoring requirements, standard permit
     conditions, public notification  procedures,  and other related
     requirements.

          d.  Chapter 93  (25 Pa  Code  SS93.1  et.seq.)  This chapter
     sets forth general and specific  standards for the quality of
     Pennsylvania's waters and  includes specific  water quality
     criteria and designated water use  protection for each stream
     in Pennsylvania.  It is reviewed and updated, as necessary,
     at least once every three years.

          e.    The  Safe  DrinJcing  Water Act  Maximum Contaminant-
     Levels  (40 CFR  Part  141) .    This  sets forth the Federal

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Standards  for  several  chemicals  including  the RCRA  MCLs,
adopted to protect public drinking water systems.  Standards
will be  considered and used  in  characterizing  human healt
risks associated with possible contaminated groundwater usec.
for public consumption.

     f.  The Pennsylvania Safe Drinking  Water Act of  1984 (25
PA Code  109  et. sea;.) State  Act  which  established drinking
water standards at least as stringent as Federal Standards.

     g.  The Pennsylvania ARAR for ground water for hazardous
substances  is that all  ground water must be  remediated to
"background"  quality  as specified  by 25  Pa.  Code  Sections
264.90  through 254.100,  and   in  particular,  by  25  Pa.Code
Sections 264.97(1), (j) and 264.100(a)(9).  The Commonwealth
of  Pennsylvania  also maintains  that  the requirements  to
remediate  to   background  is  also   found  in  other   legal
authorities.   The  method by which background levels will be
determined is  set  forth  in the Performance Standards section
of this ROD.   Such  background  levels shall be attained as part
of  the  Selected   Remedy,  unless  it  is  demonstrated  that
attaining  such levels is infeasible,  or otherwise  waivable
under CERCLA  Section  I21(d),  42 U.S.C.  Section 9621(d).

     h.  The  National Emissions  Standards for Hazardous Air
Pollutants  (NESHAPs)  set forth  at 40  C.F.R.  §61-64(b) and
promulgated under the Clean  Air Act,  42  U.S.C. §7401, contaj-*
an  emission   standard   for   air   stripping  vinyl   chloric^
manufacturing  plants  that is  relevant and  appropriate to the
air stripping-.  The vinyl chloride emission standard is  10 ppm
(average for  3-hour period).

2.  Location-Specific ARARs

No location-specific  ARARs have been  identified with respect
to this Site.

3.  Action—Specific ARARs

     a.  To  the extent  that  new point-source air emissions
result from the implementation of the  remedial  alternative,
25 Pa. Code  Section  127.12(a)(5)  will apply, requiring that
emissions b« reduced to the  minimum obtainable  levels through
the use of best available technology  (BAT), as defined  in  25
Pa. Code Section 121.1.

    1 b.  Treatment and discharge of contaminated ground water
to   Lycoming   Creek   will    cause   the   requirements   of
Pennsylvania's NPDES program to apply. Those  requirements,  as
set forth  in  25 Pa. Code Sections 93.1  through  93.9, include
design, discharge, and monitoring requirements  which will  be
met in implementing the  selected  remedy.

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     c. The ground-water extraction and treatment operations
at  the Site  will  constitute  treatment  of hazardous  waste
(i.e., the ground water containing hazardous waste), and will
result in the generation of  hazardous wastes derived from the
treatment of the contaminated groundwater  (i.e., spent carbon
filters from  the air  stripping operation).  The remedy will
be  implemented  consistently  with the  requirements  of  25 Pa.
Code  Part  262   Subparts A  (relating  to  hazardous  waste
determination and  identification numbers),  B  (relating  to
manifesting  requirements for  off-site  shipments  of  spent
carbon  or  other  hazardous wastes),  and  C   (relating  to
pretransport requirements; 25 Pa. Code Part 263 (relating to
transporters  of  hazardous  wastes);  and with  respect  to the
operations  at  the  site generally,  with  the  substantive
requirements of 25 Pa. Code Part 264 Subparts B-E,  F (in the
event hazardous  waste  generated as part of the Selected Remedy
is managed in a  surface impoundment),  G,  I  (in the event that
hazardous waste generated as part  of  the Selected Remedy is
managed  in containers),  J  (in the  event hazardous  waste
generated as part of  the Selected Remedy  is treated or stored
in tanks), and  K  (in  the event hazardous waste generated as
part of the Selected  Remedy is treated or stored in surface
impoundments).

     d. The land disposal restrictions set forth at 40 C.F.R.
Part 268 are applicable to the  management  of hazardous wastes
(including  spent  carbon  filters   from   the  air  stripping
operation) generated as part of the Selected Remedy.

     e.     29  C.F.R.   S1910.170   sets   forth  applicable
requirements  regarding  worker safety  in  the handling  of
hazardous substances.

     f.    49 C.F.R.   5171.1-171.16  sets forth  applicable
requirements  regarding off-site transportation of hazardous
waste.

     g.    The  requirements  of Subpart  AA   (Air  Emission
Standards for Process Vents)  and BB (Air Emission Standards
for  Equipment Leaks)  of the  federal RCRA  regulations,  40
C.F.R. Sections  1030  and 1050, are relevant and appropriate
(and, depending upon  the levels of  organics in  the extracted
ground water  and treatment residuals) may be applicable to
the air stripping operations under the Selected Remedy.   These
regulations require that total organic emissions from the  air
strapping process vents must be less than 1.4  kg/hr (3  Ib/hr)
and '2.8 mg/hr (3.1 tons/yr).
                           84

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      4. ether  Criteria. Advisories, or Guidance TO Be Considered

           In determining the selected remedy in  this ROD, EPA use<
      the  site-specific  guidance  documents  set  forth  in the index
      to the Administrative Record accompanying the Declaration to
      this  ROD.                                 i
     Cost  Effectiveness

     Alternative  GW-3  is cost effective  as  the selected remedy,
when compared to the other alternatives.  A detailed cost breakdown
for all components  of  the alternative  is  presented in Table 20.


     Preference for  Treatment as a Principal Element

     The  selected remedy satisfies  the  statutory preference  for
remedies   that  employ . treatment   as  a  principal  element  to
permanently  reduce  toxicity,  mobility,   or  volume  of  hazardous
substances.  The  selected remedy addresses the  risks posed by  the
ground  water associated with  the  Site through  use  of treatment
technologies.


     Utilization  of  Permanent Solutions and Alternative Treatment
     Technologies to the Maximum Extent Practicable

     EPA  has determined that the  selected remedy represents  the
maximum   extent   to  which   permanent  solutions  and  treatment
technologies can be utilized while providing the best  balance among
the  other evaluation  criteria.    Of  the alternatives  that  are
protective of human health and the environment,  the selected remedy
provides  the best  balance  in  terms  of  long-term and short-term
effectiveness and permanence; cost; implementability; reduction in
toxicity,  mobility, or  volume  of hazardous  substances through
treatment;  state  and community  acceptance;  and  the  statutory
preference for treatment as  a principal element.

     The selected remedy utilizes the technology of extraction  and
treatment to reduce the volume and toxicity of hazardous substances
in ground water.    In  the  short-term, the risks posed by direct
contact  with  contaminated  materials present  during   remedial
activates  and  afterwards,  and the  potential ingestion of ground
water will be avoided  through the  implementation of  institutional
controls.,   For  the long-term,  the  ground-water extraction  and
treatment- will return the ground water to levels that meet federal
and state criteria.   The treatment component of the Selected Remedy
is easily  implemented.
                                85

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                                                                      T.bU  20
                                      Alternative GW-3:  Ground Water  ColUclion, Chemical Treatment lot
                                           Air Stripping. Fume Incineration. Mid (Mscharga or  Traalad Walar
                                Item
                                                               Estimated Capital  Coil
                                                    Description
                 Recovery Watts
oo
cr>
       O
  00
  go 33
  OO
                 Recovery Pump*
                CenkaJ and Eastern
                  Plant Areas
                 Cental and Eastern
                   Plant Areas
Recovery Wees •  Western  Plan! Area
Recovery Pumps - Western Plant AIM
Bedrock Recovery  Wefts
Bwtrocft Recovery Pumps
SMa PiepwsMon
WMIMR InNusnl EquaNzalton  Tank
East and Cent IntuarM EquaNiaaon Tank
Piocesa Pumps
Process Pumps
Metals Removal/Recovery TiealabUly
Chemical PieciplUtton System
Sampler
Flow Meier
Plpmg  «woogh lacNMy to  EquaUiallon
       Tanks
Plptng  kom WWTP to OMver Sfeeel
Manholes
Horizontal Boring  of Piping
Horizontal Boring  Pits (6)
Pipe Bedding
Trench trough plan! lacttly to WWTP
InslaM 22
30 N deep
22 pumps and conkoto.6 gpm ea. 0 5 HP
bislal It weas.  30 It
II pumps and conkofa. • gpmea. 05 HP
(ratal 3 deep weas
3 pumps and confeolB. IS gpm ea. I 0 HP
MobHUatton/DemoMllzallon
200Ogafton cap. I FHP w/30 mm  ret  wne
SOOOoaBon cap. I FHP w/30 mai  ret  ante
2 TO gpm • 60 N head. 20 HP
2 250 gpm 9 60 N head. 75 HP
TrealabMly  study
M gpm system as manufactured by Andco
(SCO or Sigma
Vonlurt Now measuring device
3710 N of 4 In dU PVC pipe

500 N of  12 to dU gravity  sow RCP
2 precast concrete 4N«4lti4N w/cover
ISO N of pipe bored under  or uM
• Ni«Ni4n AM .  totasng 75 cy
10 to deep tod  sprtogHne of pipe  M 400 B.lftcy
4 N deep. 2  It wide. 3S6O  ft long
  Unit Cost (I)

   S.ftOOes

   6.000M

   S.BOOee.
   e.OOOes
  36.700es
   6.600es
Lump Sum
   e.OOOes
  l&.OOOes
   a.OOOes
   6.300es
  IOO.OOO esl
Lump Sum
Lump Sum
Lump Sum
      IS/11

      13/11
   1.7SOes
     40O/II
      30/cy
      23/cy
     4 50/cy
Insulted Cost (|)

    120.800

    132.000

     84.800
     00.000
    110.100
     10.500
     20.000
      a. ooo
     15.000
     12.000
     12.800
    too.ooo
    318.000
      2.000
      2.000
     55.650

      8.500
      3.500
     60.000
      2.300
        400
      4.750
                                                                         Paqu t ol 2

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                                                                     -'> conl'd
                                            OW-3: Ground Wat* CotUOton. Chemical  lr««im*4il |o« aUUIi.
                                       AW Stripping. Fu»« IncliMiatto*. a*d DUcft«*9« ol  Ti**u4 W*Ui
OO
               Tianch kom WWTP to Obvar Start      4 • d»*p. 3 H wtda. 4OO ft long                    4 M> /cr                000
               Ti«nch BacfcliMng and Compaction       I ISO ey «nd S% •lal^^* ( p^« vo*  A bed )           2S /cy              28 /io
               Fllliailon ~-                       3 batk«l Mtois                               4 ooo M               12.000
               Ait SklppM                         I 4 H dU 2O H p*dkM<  S**n                 68 000
               Fum« Inckwiatton                    I »kid mounted to« 1300 C!M  oMgM            lu«np St«n                227.400
               Pi«tob«kc«lMl  BuMding                Con*oi«. lab. and MTM* aooMtoitM. MO »l         37M/*I              21000
                     Pumpc                       t pump and  I tp«i*                          «5OO 00 ••               13.000
                     Piping                       2ft i ol 4 In dla PVC pip*                          15/11     _ 400
303.100
               Total Dtret CMMtntctt«« CM! (1DCC)                                                               l.33a.40«

               EngtMMttng. Laoat. HaaMi a Sat»ty, ami
               Comhuctton Man apt mart • 26% al TOCC                                                          _
               BualoUl                                                                                         l.»l«.00«

               Total E*UM«to4) M«U«*d C«»l w/3Tfc CMHte««Mcy (»OM»<»< la I •«*•••)
            *!lie estimated capital  cost  in  the  Feasibility  study u.is  lia.scd on  tlie use i>l  I IIIIIL-  i nr I m:i .11 Ion  ,i:.
             a  method of  emissions  control  from  the air strippers.  Th I s  tost  may change-  II   l(  Is del t:i mliu-il
             th.it a  different  method of  emissions control  is more stilt.ihle based on  the  llest Demonstrated Av.i I l.il> I
     Q      Technology  (BDAT).
 00
 00
                                                                  I'aqo 2 ol 2

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                                                                   TabU  2(}  (ci)iitM)
                                      Alurnallv* GW-3: Ground WtUi Collection. Chemical Iraaimanl lot  kUlala.
                                           All Stripping. FUM* Inclnaiallon. and CMtchaig* ol Traalad Walar
                                                               lallmalad OAU Coal
                               Hum
                 FtMl
                 Power
                 Iron Predptaton Opwatton
                 Labor
                 ClMintcate
                 SoMtta DtapoMl
                 Ouutd*  Analy** VariNcatton
                 Ftv« Yaai PartMn
                 Equipment MaMananca
                                                         	      UnM Co»l (|)
                                    21.000 gal/yr                                   | 00/gal
                                   274.300  kwtt/yr                                  0 10 /kwh
                                   34.669.000 oaJkMM                                0 40 /IOOO
                                   6240 hour*                                     30 00/hi
                                   Lump Sum tor mala* lamoval                     IO.OOO
                                   40 lona/yr                                       324 /ion
                                   12 tamptaa                                     1,200/tamp
                                   Annual ooal aqutvatanl ol 6 y»ar raviaw •>            7.800
                                    $20.000 aadi tor 30 yaara
                                   3%otTDCC
                  Tola! EaMaMla4 AMMW! O4M Coal «/3t% ConllM«aMcy

                  Piaaanl Wartk al OMI Ceal (M yaan 6> •%)
     Annual OtM Coil (|)

            21.000
            27.4OO
gal          13.000
           167.200
            10.000
            13,000
            14.400
             7.800

   	48.000

           44*.M6
CO
oo
Tola! PraaMl War* - CaaMal Coal aa4 OaM Caat (36 yaara •> »%)
         t.Ml.llt
     -a
 08
 OO

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 tccur.er.tation of significant Changes from the Proposed Plan

     The Proposed Plan for the AVCO  Lycoming  Site was released foi.
public comment on April 17,  1991.  The Proposed Plan described the
alternatives studied in detail in  the Feasibility Study, presented
to EPA in March,  1991.  In the Proposed Plan,  EPA selected a remedy
that  included   additional   on-site  and  off-site  ground-water
remediation.   During  the  public  comment  period,  EPA  received
numerous comments in support of not  performing additional off-site
ground-water recovery  as  part  of  this  ROD.   After careful review
of these comments,  which included a hydrogeologic evaluation of the
off-site  ground-water  plume,   EPA  has  decided   not  to  include
additional off-site ground-water remediation as part of this ROD,
as originally set forth in the  FS.  This decision  is based on the
need  for additional  studies  to  determine   the  most  appropriate
action  to further  recover   and  treat  the  off-site contaminated
ground water.  Therefore,  the off-site contaminated ground water
will be  a separate operable  unit  (OU-2)  that will  be addressed in
a future ROD.
                               39

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                    ?.E S ? 2 N" 5 IVE>:ESS S L'MXAR Y
                            FCR. THE
                 PRCPCSEZ  REMEDIAL ACTICN PLAN
Cut-ine 	    1

Background  	    2

Part I: Summary of Corrj7.er.tors'  Major  Issues
        and Cor.cerr.s  	    3
     A. Health Concerns	    3
     3. Remedial Alternatives	    4
     C . Ground Water  Cleanup	    6
     D . Administrative  Record  F lie	    6
     E. Technical Assistance Grant Process 	    T

Part II: Comprehensive, Technical  and Legal  Response to
         Significant  Comments	    3

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3 •"* '^ ** ~ w " ° '^ — s s  — *^.n c *5 s c c n H3  " ^ ~rcss  rH^s^
                                      .e  r.ur. i z ipa
                   " s c r1. r. i c 3 1  r^sccr. ss  iccurr.sr. ".

-------
the Avco  '—'<' — C.T.Ir.~ Site has ceer.  li.~i.~2ci.

      To  obtain public input  or.  the Proposed Remedial  Action Plan

1", 1391  to  Xay 15,  1991.  lr. May 2,  1951, EPA held a  public meet;
to present,  the plan,  answer  questions,  ar.d receive oral  oor-.-er.ts 2
cruesticr.s .   E?A also crovided cublio meetir.c resccr.se  cards wr.io'r.
allowed rr.eetir.g atter.oees to rr.ake cc~rr;er.ts or. tr.e cards  ar.d ser.d "
to EPA.   Tr.cse ir. atter.car.oe at  tr.e rr.eetir.c ir.c —uded  loca_ arsa
residents,  state and Izoal officials,  news rr.edia representatives,
'"oc*"os*=in""a"" ; v-^s -^^.—« Z~~"  a*"d *^°cr°sentatives from T-^xtron I-'/corr.ir

      EPA  notified looal rr.edia,  area residents and  Federal, state,
and local officials  of the May  2,  1991 public meeting  through a
oub1i ~ no~io°  ann oun o °~an~ cub1i s hed in the AD r i1  17   1991 edi t i cr
of the siilliaKSpcr-  S<~~ Gazette.   In addition, EPA  established  a
site  information repository  at  the James V. Brown  Library in
Williamsport.   The repository contains EPA's Administrative Recorc
File  for  the  site as well as all  documents used in  the selection

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PART  I:    SUMMARY  OF  CCMMENTORS '  MAJOR  ISSUES AND CONCERNS

      This  secti" prcvi^ec = 3u.--T.ary cf  r cm-enters '  ~a~cr  i33ues
ir. i 7 : r. ce rr. 3  ar.c, -sxc r-=33 ly ii.ir.ewlez-es  ar.z  resc ;.-. ds  to t.~. C3^
                                   -2 ma " r  -33u^3  ar.::  ~
                                   • a — s
     A.   Health  Concerns
     3.   Remedial   Alternatives
     C.   Ground  Water  Cleanup
     3.   Administrative  Record File
     E.   Technical  Assistance  Grant  Process.



A.  Health  Concerns

•  A citizen askec.  if  the  Avco lyccming Site is  an -exception  to  tr.e
   perception tr.at  when  people think of a Superfund  site  they thin<
   of  some risk to  tr.e  environment,  to public health,  and safety.

       ".-._-•? :   :.'o,  the S-perfur.o. program mandates I?A to also

       - * _ — .   ..•'ci^'^.w~^/  — " ."A ... ^* o — ^.. ^ '/'*•.» ^ *. ^* --»S — — —..i — ..£  _..tcj
   ccter. tial ris<3  of  ar.  ir. ii'/iiual oor. tract ir. -  oar. oer,  f;r
   13 x a rr. c . *^  c o *" ri  a **  ~ r.~*  c r a s ^ ^. *  a r*. i i. r*. *" 't ° f u r u r °

  A  citizen  as
-------
   a  sensitive perscr. such as  an  individual  who  -ay  have  asth.-.a,
   for example,  the elderly,  and  some  sensitive  sub-popuiat icr.s .

   A  citizen asked if there .-.as ever been  an epidemiological  studv
   - ~ cancer rates ~ ~. ~ h e  3 i ~ a a*"aa .
        "nsg :  ..-.ere is current.-/ a health study assessment being
   acne by  t.-.e Pennsylvania Zepartment  cf  Health which  involves
   epidemiologists.   This  survey  will be  available  for  public
   • review as  soon as  it  is  released.


   intake of  the  area residents.

Z?A Response :  The  air  rr.cdelin-  has  taken this  into  account  in
   evaluating the maximum  areas where concentrations  would occur.

•  A citizen  asked if an ecidemioiogicai  studv or a health
   assessment will be conducted at the  site,  and if this testing
   will be  completed prior  to the Record  of decision.

EPA Response:  An epidemoiogicai study will  not be conducted at
   the  site,  however, a  health assessment  will be conducted.   The
   main difference between  an epidemological  study and a health
   assessment is  that the  study develops  new  data from interviews,
   biological samples,  demographical  data, etc.   A health
   assessment only uses  data already  available from EPA's studies
   of the site.

•  A citizen  asked if there is a  technology available to accomplish
   air  stripping  that does  not vent chemicals into the air.

EPA Response:  Air  emissions control will be part  of the
   remediation; no harmful  levels of  VOCs  will be vented to the
   air.

B.  Remedial  Alternatives

•  A citizen  asked EPA to  define  the  ultimate objectives of the
   thirty-year cleanup process .

EPA Response:  EPA intends  to  achieve  the cleanup  goals  which will
   be identified  in the  Record of Decision.  EPA will issue a
   Record of  Decision at the end of June  which will require a
   contaminant concentration equal to that of background ground
•  A citizen asked if the off-site cleanup would affect the
   residents.

EPA Response:  No, the off-site  cleanup  will  not  affect  the  area
   residents other than potential for releases of volatile organic
   compounds during the installation of wells.  This will be

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                                  • a •
              .-• exposure  2:  loxicity ir.rc rr.at icr.,  tr.er. we r.ave
                                      a — -" a
           : _3sue  of  c rote ot iver.es s  is re-addressee at that
     o i t 12 e r. a 3 .< e o  11  ^ r.-.  2 c r. o, u c ~ e d a r. i r. z e c s r. i e r. ~ a c c r a i s a
     c- .as--— * - ^
                . n  o o n n e c 11 o r.  w 11 n  issuing its .-. e c o r o. or _ e c i s i o r
                .oteo an  ir.cecer.oent oost estimate to confirm the
£r A Pespcr.se:   Z?A sr.culi  have  ar.  operaticr.al grour.i wa^er
   reccverv ar.i treacr.er.i  S'/sterr, ir. clace wichir. acp ro.xima _e -'.'  ~w
   '•'ears cf "r. e ?. e — c r d  cf  Zecisicr*..

•  A citicer. asked if a.-.y  ctr.er  a.i err.az ives were ceir.g ccr.siiere-
   to  prciect tr.e  air as well  as tr.e wa-er.

EPA Respcr.se:   Yes,  EPA is  rcr.cerr.ed wi-h air quali.y as well  as
   water quality ir. tr.e site area.   EPA will tr.erefcre, place son
   ccr. trols c r. too cf "he  air  striccers tr.at will crevep.c
                 *     »^.—.      j—fc               fc
   volatilization  of the ccr.pcuncls  during the stripping process.

•  A citizen asked if any  study  had been conducted  regarding  the
   synergistic effect of acditicr.ai toxics released by air
   stripping, the  Avco  facility, and the other industries  in  the
   area .

EPA Response:   No, it  is  not  necessary to evaluate synergism.  A
   emissions controls will be  part  of the remedial  action  for
   operable unit one of the Avco Lycoming Site.
        i
•  A citizen asked if the  duties of the Community Relations
   Coordinator and the  Remedial  Project Manager  will  continue to
   reside in Pennsylvania.

Z?A Respor.go:   The duties  of  the Community Relations Coordinate'
   have been assumed by Mr.  Patrick Gaughan in Wheeling  West

-------
   Virginia,  however,  Eugene 3er.r.is will continue to carry cut the
   duties of  the Remedial Prefect Manacer in Philadeiohia.

   A citizen  asked if tr.s crcccssd rerr.eci'.' is selected from
   alternatives studies cy Avcc cr cy an independent E?A studv.
•  A citizen asked if proposals were considered
   affected earth.
                                                       ;a soi- was
     a*"*^if ^^"> *^-**r~v ••-• « ..... ^^«<^.^_V'...,.'^*lvt

C.  Ground  Water  Cleanup

• -A citizen as
-------

                      • • — ;S -• — — -» — —« £3 ••« W ' " ~ ~ ~ O  -» ' ^ a — • . «  .3'

                      ~- -1 r^cruire the ACJT. in ist rat ive  ?.ec:
                     zz cur.er.t 3 tr.at were -sei in  tr.e  ~a!<.
                        3 3 rr. s r*. ~ w n i. c n i*. 3 s  3 i. r1* c s
   A c*"^.z*ar'.  — s V. ^^ ci  wp. */ "ns A ^i rr. * n • 5 c ^ 2 ~ i. v °  ?-^cc^i F" — • *^ s^^^^s *""
   alternative tr.ree is preferred, while ar.  April 1", 1391 news
   ar^i^le  *'*3i'*a""':ai " n a " a 1 " ** r r1. a t i v *  ^c*ur is  cr0*0^'*'0'^
                      is a  i i s c r e c a r. c v c e t w e e n the AcLrr. 1 r. i s t r a 1 1 v e
   P.eccrd File  ar.a  tr.e Acril l~th r.ews  article  regarding the .".•_: .rJ:er

   -~ c "j^o — S»-O<;Q»"'-O.^' ^"••^'"^^••••/ia^.p^taACfa  ^ ** •" «^vf^  •••^•v..^  »•>»  •  ** 1* f  ~*. v .*a^
                                       is  ~ '~ &  sarr. e
   and onl  the  nurriers are

•  A citizen  as
-------
are applied for and awarded  during  the  Remedial  Investigation.
feasibility Study stage at the  site,  however,  there  have  been  no-
formal limits set against awarding  TAGs  after  the  stage has
passed.

•     A citizen asked  how  Icr.j  the  TAG ace 11 cat ion  crocedure  takes.

Z?A Pqspc.-.sg :    The  TAG acclicaticn orocess can take uc to five or
six mcr.ths .

•    A citizen  asked  if  there  is  ar.y  r.etwcr:< cf TAGs withir.
? e r. r. s v 1 v a r. 1 a or the ?. e c i o r.
                "^he*"0 '~avo b0£ap. less than tar^' ""AGs awsr-ded in EPA
r.eaion III, and there  are  several  for  Sucerfund sites in
Pennsylvania, specifically  the  Paimerton  Zinc Site,  the C i D
                    "        frcre  Sit.
Part  II:  Comprehensive,   Technical  and  Legal  Response  to
     Significant   Comments

     Please  refer  to  technical  resoonse document.

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                        PART II
                 R2SPON8IVZNES8 SUMMARY
                  (technical raaponse)

                   TABLZ 07 CONTENTS

  ION;                                                  PAGE
May 1, 1991 letter from ERM to U.S. EPA	   1

May 2, 1991 Public Meeting Transcript	10



May 16, 1991 letter from ERM to U.S. EPA	14

May 14, 1991 letter from Williamsport Municipal Water
Authority  (WMWA) to U.S. EPA and May 16,  1991  letter
from ERM to U.S. EPA in response to the WMWA letter     16

May 10, 1991 Letter from ERM to U.S. EPA    	20

Response to U.S. EPA and PADER Comments:
15 January 1991 Draft Remedial Investigation Report for
the Textron Lycoming Williamsport  Facility  	  22

Response to U.S. EPA and PADER Comments:
31 January 1991 Draft RisJc Assessment Report for the
TexHron Lycoming Williamsport Facility  	  31

Response to U.S. EPA and PADER Comments:
15 March 1991 Draft Feasibility Study Report for the
Textron Lycoming Williamsport Facility  	  ...  36

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AVCO LYCOMING (TEXTRON LYCOMING),  WILLIAMSPORT,  PA
2.0  RESPONSIVENESS SUMMARY


Source Document:  May l, 1991 Letter from ERM to U.S.  EPA


Ground-Water Use/Risk Assessment

1. The RP expressed concern that insufficient emphasis was
   made regarding the fact that current users of ground water
   pumped from the Williamsport Municipal Water Authority
   (WMWA)  wells do not face any additional potential risks,
   as this water is treated before introduction into the
   water supply system.  The emphasis should be placed on the
   fact that the risks discussed in the Proposed Plan are for
   a hypothetical scenario that does not presently exist
   (i.e.,  drinking untreated ground water over an extended
   time period).

 EPA  acknowledges this concern.  It will be noted in the
 Record of Decision (ROD)that siterisks are due to
 hypothical  exposures.

2. The RP suggested that EPA express a range of values for
   the hypothetical future risks and corresponding estimated
   increased incidence of cancer in the Proposed Plan and
   subsequent revised pages. The RP provided Table 1 which
   lists the correct hypothetical cancer rates based on the
   correct hypothetical risks.

 EPA  acknowledges receipt of the Table and the changes are
 reflected in the ROD.

3. The RP states that there is no current threat to public
   health or welfare, because the WMWA well field has been
   provided with treatment and the plume has been contained
   by the Third Street recovery well.  The RP further states
   that due to these  factors, the statement in the Proposed
   Plan (page 8, paragraph 1) "Actual or threatened
   releases...present a current or potential threat to public
   health, welfare, or the environment11 should be corrected.

 At this time.  BPA diaaareea that there i« no current or

 envir*7riB^pt«   Until additional data from Monitoring are
 obtained  ^nd Modeling i» performed* BPA cannot modify the
 statement.

4. The RP requests that the first sentence on page 8,
   paragraph 2 of the Proposed Plan be modified to read  "At
   this site the most significant potential future risk...,"

-------
   rather than "At this site the most significant risk...."
   The RP argues that a risk to surrounding populations under
   current conditions (i.e., treated water) is"not
   applicable.

 5PA notaa that "aoat significant"  is used  in  this  sentence
 to mean "primary" vith  respect to  riafca  posed bv the  site.
 No reference to the tiae  the risfc  aav be posed  is  implied.

5. The RP notes that page 8, paragraph 5 of the Proposed Plan
   should be modified to state that institutional controls
   should encompass future land use and untreated ground-
   water use rather than only  implementing institutional
   controls  for exposure to contaminated soil.

 SPA recognises the need for institutional  controls for
 future land use and untreated ground-water use  and shall
 incorporate the addition  to the ROD.

Feasibility  Study

5. The RP requests clarification of page 2, paragraph  1 of
   the Proposed Plan regarding whether a third edition of the
   Feasibility Study (FS)  report would be  retired or  in fact
   the revised FS pages already submitted  to  EPA would be
   sufficient.
     doeg not require a revised edition of! the Feasibility
 Study report.   The revised pages will besufficient to
 satisfy BPA's  requirement.

Ground-WaJ^er... Recovery

7. The RP commented on the Proposed Plan statement  (page  15,
   item 3) that "the additional recovery and treatment of the
   contaminated off-site ground water will help in  restoring
   the quality of off-site ground water  in the overburden and
   bedrock."  The RP does  not concur with the assumption  that
   additional off-site ground-water recovery and treatment
   can be implemented  in a technically sound manner without
   further study of the performance of the proposed on-site
   recovery system.  However, the RP states that since there
   is no risk to ground-water users, the plume is stabilized,
   th« WMWA well field is  protected by the Third Street well,
   the WMWA system is  treated, additional off-site  recovery
   will not change or  decrease the hypothetical risJc  in the
   shbrt term, and off-site  institutional controls  can
   control future hypothetical risk scenarios.

         treat the off-site  olmif *,§  * separate Operable  Unit

                                          additional  data

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will be needed to confirm tha statement, but, believes the
ongoing off-site plume containment and contaminant mass
recovery ia effective.  Baaed on the results of tha Remedial
investigation and the Feasibility Study, additional  off-
site around-vater recovery may be required to mitigate riafca
posed by the ee>n+-»minant plume.


8. The RP commented that the statements (page 8,  paragraph 3,
   last sentence; page 11, paragraph 2 and page 13, paragraph
   2) regarding the need for additional off-site ground-
   water recovery of the Proposed Plan are inaccurate.  The
   Proposed Plan states that "the off-site contaminated
   ground water...recovery and treatment systems...will be
   enhanced by additional recovery."  The RP stated that
   there are insufficient data presently available to support
   this statement and there has been no opportunity to '
   evaluate the effect of pumping the on-site recovery system
   proposed in the Feasibility Study on off-site ground-
   water quality over time.

 The RP further states that the there are presently
 insufficient data from the aquifer system to determine the
 need for an upgraded scheme or to optimize well
 configuration,  should additional off-site recovery be
 required in the future.

EPA will treat the off-ai^t Pl"pi* >a » separate operable unit
which will be addressed in m furture ROD and based en
additional studies.  BPft understands that additional data
will be needed to confirm the statement, but believes the

recovery is effective.  Based oa the results of the Remedial
Investigation and the Feasibility Study and data from similar
sites* additional off-site ground-water recovery may be
                             >aed bv the conti
it affects the off-aite aquifers.
Contamination

9. Th« RP requests that the statement that "the ground water
   in tha bedrock on-site and off-site is contaminated with
   TCE, DCE, and Vinyl Chloride" be clarified to reflect the
   limited nature of the bedrock contamination.
 statement needs clarification at this time.

10.  The  RP states that  on  page 6,  the last paragraph of the
     Proposed  Plan,  the  value of 19,000 parts per billion
     (ppb) should be corrected to 1,900 ppb.

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     acfcaoirladgaa  the  transcriotional arror.  Tha chance will
 ba  reflected  in  the Summary of  Site Characteristics section
 of  the  ROD.

Other Cc
11.   The RP states that page 2, paragraph 5 of the Proposed
     Plan should be corrected to state that AVCO was
     acquired by Textron on February 28, 1985, not in 1980.

 EPA  acknowledges  this  comment  and  notes  the change.  Tha
 correction  will ba  raflactad in  taa  8ita Name.  Location, and
 Description section of the  ROD.

12.   The RP states that page 5, item 4 of the Proposed Plan
     should be corrected as lead is not  present above
     background levels  in soil.  In addition,  the RP noted
     on page 6, paragraph 1 of the Proposed Plan that the
     concentrations of  lead actually found in the eastern
     end of the property were 16.0 and 18.5 parts per
     million (ppm), not 169 and 185 ppm, respectively.
     This is based on  incorrect laboratory results which the
     RP rectified in the April 15, 1991  revised Remedial
     Investigation report.

 EPA  acknowledges  and  nota*  this  change.  The  correction  wii:
 be reflected in the Summary of Site  Characteristics  section
 of the  ROD.

13.   The RP stated that the sentence on  page  6, paragraph  3
     of the Proposed Plan should be revised to  read  "The
     direction of overburden ground-water flow  is to the
     south."  The RP noted that the bedrock ground-water
     flow is to the southwest.

 The  Reaedial Investigation  report  states that ground water
 in the  shallow aquifer (overburden)  floir a  oriMarilv in a
 southerly direction with  Minor components  toward the
 southwest and  •outhaast.  Tioruraa  within the  Remedial

 bedrock aquifer is  predominantly to  the) southwest.   EPA
            • and  notaa this chance.   The revision will be
 the  ROD.
     (
14.   The RP states that page 7, paragraph  1  of  the  Proposed
     Plan contains an error regarding beryllium values  of
     samples collected in Elm  Parfc.  There was  only one
     sample reported for Elm ParX  (MW-32)  and the
     concentration was 3.5 ppb.  Therefore,  there is no
     range of values as indicated  in the Proposed Plan.

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 EPA acknowledges  and  notes  this  change.  The  correction will
 be  reflected  in the fl»mnt«T-y Of site  Characteristics section
 of  the  ROD.

Remediation

15.   The RP recommends that EPA  include in the paragraph on
     page 5, Scope and Role of Operable Units, language
     indicating that  "extensive  remedial actions carried out
     by Textron under the Pennsylvania Department of
     Environmental Resources  (PADER) direction, both on- and
     off-site."  The  RP suggests that a listing of the
     remedial actions (i.e.,  installation of  five recovery
     well systems with air  strippers, extensive quarterly
     monitoring, installation of air strippers at the WMWA
     well field, and  remediation in the old wastewater
     treatment area)  be included in the plan.

 As  part of  the Administrative Record,  this  information  is
 included  for  public review.  Baaed on  the  scope  off  the

 remediation should  be included in  the  Proposed Plan.

16.   The RP states that on  page  9, paragraph  2 of the
     Proposed Plan, EPA has developed a monitoring
     alternative rather than  a true  "No Action" alternative.
     The RP further states  that  "Because there is no short-
     term ground water cleanup under this option, there is
     also a need for  five-year effectiveness  reviews, which
     is not costed by EPA in  the Proposed Plan."

 EPA*s "Guidance for Conducting Remedial  Investigations  and
 Feasibility studies Under CBRCIA"  (EPA/540/Q-89/004.  October
 1988) states  "that  «  no-action alternative aav include  some


 EPA has not estimated a  coat for the five-year effectiveness
 reviews in  the Proposed  Plan and but will  discuss them in
 the Remedial  Alternatives section of the ROD.

17.   The RP states that Alternative  GW-1, on  page 10 of the
     Proposed Plan, includes  the existing monitoring program
     required under PADER's auspices.  The  comment  suggests
     that the Proposed Plan should be modified to reflect
     this.
     i

 monitoring  i» a component of this alternative.  The change
 will be reflected in  the Remedial Alternatives section of
 the ROD.

18.   The RP notes that Alternative GW-2  on  page  10  of  the

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     Proposed Plan should include proposed restrictions on
     future untreated ground-water use in the area overlying
     the piuae.

 SPA aotas  and acknowledges  this  comment.  The change vill be
 reflected  in  the Remedial Alternatives section of  the  ROD.

19.  The R? notes that the annual O&M cost for Alternative
     GW-3, on page 10 of the Proposed Plan,  should be
     $442,900, as noted in the 15 April 1991 submittal, not
     3442,700.   The extra cost reflects the change in
     monitoring  well configuration to encompass the eastern
     end of the  facility requested by PADER.

 In addition,  the description of  this  alternative  includes
 institutional controls  but  does  not  include  the cost  for
 these  controls.   The  RP states that  in order for  this
 alternative to  be effective, institutional  controls should
 include  limitations on  property  access and  future untreated
 ground-water  use,  not just  future property  use.

 EPA notes  and acknowledges  thi,?  comment.  The change  vill  be
 reflected  in  the Remedial Alternatives auction  of the  ROD.

20.  The RP notes that the annual O&M cost for Alternative
     GW-4, on page 10 of the Proposed Plan,  should be
     $526,000, as noted in the 15 April 1991  FS revision
     package, not $525,700.  The  extra cost  reflects the
     change in monitoring well configuration  to encompass
     the eastern end of the facility requested by  PADER.
 EPA notes
«nt vill
 be  reflected in the Remedial Alternatives section of the
21.  The RP notes  that  the  annual O&M  cost  for  Alternative
     GW-5, on page 11 of the  Proposed  Plan,  for this  option
     should be  $650,500, as noted in the  15  April  1991  FS
     revision package,  not  $650,000.   The extra cost
     reflects the  change in monitoring well  configuration to
     encompass  the eastern  end  of the  facility  requested by
     PADER.
 reflected in the R<
22.  the RP  states  that  on  page  11,  paragraph 2  of the
     Proposed  Plan,the statement,"the  recovered  ground water
     would be.  recovered  through  a  series of existing and
     newly installed  recovery  wells" is not completely
     accurate.   The RP states  that the proposed  on-site
     recovery  system  was not designed  to incorporate

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     existing recovery wells.  The RP further clarifies this
     by stating that this does not mean that the existing
     well system would be discontinued.

 EPA notes and  acknowledges  tb*«  eammant.  The chance vill ba
 reflected in Remedial  Alternatives  section  of the ROD.

23.  The RP suggests that EPA revise the statement on page
     11, paragraph 2 of the Proposed Plan to allow for a
     determination of the need for air emissions controls
     after actual recovered ground-water concentrations are
     known.   The RP states that the wording  ("the vapor
     phase from the air stripper would be treated by the
     best available control technology") implies that fume
     incineration would be required.  The RP believes that
     if the recovered volatile organic contaminant (VOC)
     concentrations are sufficiently low and there is no
     unacceptable risk from uncontrolled stripper emissions
     from the treatment process, emissions  controls may not
     be required.  The RP suggests that EPA modify the
     wording to allow a determination of the need for air
     emissions controls after actual recovered ground-water
     concentrations are known.

 EPA notes that  the  RP  indicated  in  the Descriptions  of  the
 Alternatives in the Proposed Plan describing air strippers
 that air emission control*  are  a component  of the
 alternative.   No cflimt  has been made  at  this time.  An
 evaluation of  the type of emissions control will be  made
 during remedial design.  At this tin*,  it appears that  some
 type of emissions control will be needed.

24.  The RP suggests that EPA modify the last line of
     paragraph  2, page 11 of the Proposed Plan where
     institutional controls are discussed to  include future
     property access and untreated ground-water  use  in
     addition to future property use.

                                                   re will be
 reflected in the Remedial  Alternatives section of the ROD.

25.  The RP  suggests that  the Alternative GW-2, as discussed
     on page 13, paragraph 1 of the Proposed  Plan, be
     carried through the evaluation process since component
     parts of it could be  incorporated in the selected
     remedy  for the site.  The components include the
     Institutional controls such as fencing and ground-
     water,  access, and land use controls.

 EPA  agrees that  institutional  controls are needed in the

 selected  remedy  as described  in the Remedial Alternatives

-------
 gaction of the ROD.

25.  The R?  suggests that the language in paragraph 2, page
     13 of the  Proposed  Plan be modified to state that the
     ability of  the alternatives to meet effluent limits
     will  have  to  be reviewed after actual implementation.
     The RP  states that  contrary to EPA's statement,  it
     cannot  be  determined with certainty that the effluent
     limits  for  the treated ground-water discharge can be
     met.  This  is because effluent limits have not yet been
     set by  PADER  for this discharge.

 SPA notes  this comment  hovever.  the  effluent  linita will  set
 be by  PAD2R  during the  desicrn  stage  and  will  be  evaluated
 for tfteir  efficiency*

27.  The RP  suggests that the language in paragraph 3, page
     13 of the  Proposed  Plan, which states "the goal  of the
     ground  water  remediation is to achieve background
     ground  water  quality as required by the  PADER,"  be
     modified.   The wording should state "..if it is
     demonstrated  that ground water contamination
     asymptotically approaches concentrations above the
     cleanup levels, EPA shall modify the cleanup levels
     consistent  with that determination. "

 EPA believes,  that it  implementation of  the  selected  remedy
 demonstrates,  in corroboration  with  gyflroqeological and
 cheaical  evidence, that it  will  f« technically  impracticable
 to achieve and Maintain the remediation  goals throughout  the
 area of a
 contaainat
 with
        h will be the edge of the aite where
        t detected).  the EPA in consultation
•alth of
 ROD or issue an Explanation of Significant Differences to
                              Lye aroun
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     to be consistent with the Feasibility Study  report.

 EPA  notes  and  acfcnowledges  this  ce""»«"»    The change vill be
 reflected  in the  RiaX  Characterization section of the ROD.

30.   The RP requests that the language of paragraph  1,  page
     14 of the Proposed Plan be modified.  Surface water  is
     not a medium which will be monitored.  The RP requests
     that surface water be removed  from the second sentence.
 EPA  not
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Source Document:  May 2, 1991 Public Meeting Transcript

21.  will off-sire ground-water recovery and treatment be
     chosen at  the time of the final decision?  (See page 9,
     lines 5-20.)

 Additional  off-site  ground-water  recovery  and  treatment  of
 the corn-*™-i,nant pluaa will be  considered as  a  separata
 operable unit  and addressed  by BPA  in  a  future ROD.

22.  What is the  basis of the  estimate for the cost of the
     proposed twenty- to- thirty-year ground-water
     remediation?  (See page 10,  lines 4-17.)  Will the
     estimate of  cost be based solely on the AVCO consultant
     estimate,  or will an independent appraisal be made?
     (See page  13, lines 9-10.)

 The costs were  estiaated  by  the AVCO Lycoainq  consultant
 based  on years  of experience and  practice  in the  field.

 In angver to  the second Question.. EPA  has  recently  made  an
 independent  cost estimate and confirmed  the  estimated cost.

33.  What is the  ultimate objective  regarding  contamination
     at  the end of the thirty-year period?   (See page  10,
     lines 24 and 25  and page  11, lines 1-9.)

 EPA expects  the ground-water contamination levels  to  be
 equivalent  to  those  concentrations  that  have not  been
 impacted by  contamination ffroa AVCO Lvcomina (i.e.,
 background)  or  Majciaua Contaainant  Levels  (MCLs)  as defined
 bv BPA or risk  level! (whichever  is the  lowest).

34.  Are there  any data available as to the  length of  time
     groundwater  was  contaminated prior to treatment being
     implemented, and could  residents have consumed
     untreated,  possibly contaminated, water?   (See page 13,
     lines 11-25  and  page 19,  lines  1-25.)

 The riifca posed in  the past  were  not evaluated prior to  the
 extension of  public  water line* or  the construction of air
 stripping towera. The riafc  assess«ent evaluates  current and
 futura water  use. The water drawn  fro« the contaminated
 yell field  is  treated to  non-detectaJJl* levels before it is
 put into the Municipal water supply for drinXinq.   However,
 priop  to treatment being  implemented,  since the well field
 is al*BO the  reserve  water «7»ttB  ff?P the city, past
 consumption  of  non-treated water  was a possibility.

35.  Will Best  Available Technology  be used  regarding the
     air stripping controls  and would  money  be available if
     better technology became  available?   (See page 24,

                              10

-------
     lines 6-25 and page 25, lines 1-6.).

 EPA believes  that  there  is  always the option of using a
 better  technology  should it become available.  The
 performance standards to be met will be identified in the
 Record  of  Decision (ROD) and the Remedial Design.  These
 standards  would apply for future use, unless it is found
 that health effects  are  a greater concern than previously
 determined.   New exposure or new tozicity information vould
 allow the  ability  to re-exanine the current controls in
 place in addition  to the standard design process.  Limits of
 the stripping tower  controls would also be examined.  There
 is also, a built-in  five-year  review period in which at or
 after five years of  operation, BPA re-«^«V"«a the entire
 site  to  determine  if  the  remediation  is  still protective.
 If  it is no  longer protective,  it  is  re-evaluated.
with  regard  to money  being  avt
addressed  during  the  remedial  Phase.
issue wi:
36.   What is the situation regarding some residents who have
     their own wells and are consuming or using water for
     food processing from the contaminated well field?  (See
     page 30, lines 24-25 and page 31, lines 1-20.)

 Based  on  the remedial  investigation.  a thorough  survey  has
 been completed which identified  any users within  the  three-
 mile radius  of the  facility.  Baaed on this  survey EPA
 believes  that there are  no private wells currently in use

 AVCO.

37.   Explain what is meant by limiting of future property
     use?  (See page 32, lines 1-15.)

 Limits on future property u«e relate  to  limitations to  those
 activities compatible  with site  conditions.

38.   Regarding the  consideration by EPA for  the need  of
     additional off-site remediation, pending an evaluation
     of the  effectiveness of the on-site containment, will
     the  evaluation take into consideration  the mass  of
     contaminants in the bedrock members between the  plant
     site and Third Street and the approximate travel time
     and  contamination of the material in that area?  What
     period  of time would be sufficient to evaluate that
     strategy?  (See page 32, lines 19-25 and page 33,  lines
     1-14.)
                                                 be used to
 boundary and Third Btreet and provide some information as to
                              11

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 tha aaaa of contaminants.   This  procaaa  la vary  difficult.
 but tha information gathered  as  vail  as  additional  riafc
 asaeaaaant off-aita would  allov  tha  formulation  of  a plan to
 moat affactivaly eaotura.  racovar  and traat  tha  off-aita
 contaainatad plume.  Tha tiaa gram*  conaidarad for
 evaluating this procaaa J3 approximately tiro vaara.

39.  Will  additional  studies  be cost-effective relative to
     actual  additional  off-site cleanup?  (See page 33,
     lines  16-25  and  page  34,  lines 1-7.)

 Additional studies should  ba  banaficial  la pinpointing exact
 placement of additional off-ait* recovery valla  for
 effective racovary of tha  pluma  and  •nhancenent  of  the
 cleanup tia« frana.

40.  Would  it be  advisable  to consider the expansion of
     monitoring  the wells  to  include  more points  in and
     around  the  public  water  supply well  field?   (See  page
     34,  lines  16-25  and page 35,  lines  1-6.)

 Expansion of th« monitoring valla  will b« t*X«n  undar  strong
 consideration.   This includes not  only additional nonitorinq
 in tha vicinity of 81a Parfc or Third 8traat  a»  a result of
 additional  studias but also evaluation of how far bavond
41.  The off-site pumping  from the Third Street  recovery
     well  is presently pumping at a thousand gallons a
     minute.  Has any consideration or study been given to
     the potential of actually pulling more contaminants
     into  the immediate well  field area due to the high
     pumping rate?   (See page 37, lines 1-5.)

 The futura evaluation of  tha «ffactivanass of tha on-sita
 around-vatar racovary and traitaant  systam should provide
 inforaation to  «aXa  this  dataraination.

42.  Has any consideration been given to the use of any
     other off-site  wells  which might cause the  point of
     depression  to be less extended?   (See page  37, lines 6-
     10.)

 Tha future •valuation of  tha affactivanaaa of th< on-aita

             to  »*Jca  this  dataraination.
43.  Do you have  any  information  update  on when air
     inversion  occurs in  this  valley?   (See page 38,  lines
     13-25 and  page 39, line  1.)
                              12

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     air Modeling  has  taXan  this  into  account  in   the  maximum
 areas where  concentrations  would occur  and  in that  respect
 vould have considered any processes auch  as air  inversions.

44.   How far beyond Lycoming Creek does the contaminant
     plume extend?

 The  future evaluation of the  effectiveness  of the on-site
 ground-water recovery and treataent system  should provide
 information  to  mafce  this determination.
                              13

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Source Document: May 16, 1991 latter froa ZRM to U.S. BPA

43.  The RP provided a letter summarizing their rationale for
     proposing an intensive On-Site Ground-Water Recovery and
     Treatment System as the best remedial alternative.

     According to a letter submitted by the RP,  "Textron  Lycoiaing
     wants to see an effective remedial program for the site based
     on sufficient information to make  an informed remedy choice.
     From the time of discovery of contaminants in the ground  water
     beneath the facility and off-site, Textron Lycoming  has
     responded by completing an intensive hydrological
     investigation of the aquifer system, continuing routine
     ground-water monitoring and initiating ground-water  recovery
     and treatment en-site, and at the  Williamsport Municipal  Water
     Authority (WMWA)  municipal well field.  The extensive data
     gathering and evaluation process that culminated in  the
     completion of the remedial investigation (RI), the  risk
     assessment (RA),  and the feasibility study (FS) combined  with
     the routine ground-water monitoring, from the existing
     database from which to make a remedial decision. The data
     collected indicate that the existing remedial system has
     achieved a measurable level of control on the ground-water
     system."

     The RP proposes to conduct numerical analytical modeling.  The
     additional technical data resulting from this modeling,  in
     combination with the selection criteria established  by the
     regulations,  will allow EPA to make an informed decision  on
     the performance of the system and  an assessment of  the need
     for additional off-site ground-water recovery.

     The RP requests that the ROD provide a mechanism, based  on the
     monitoring data and modeling results, that will evaluate  the
     need for additional off-site remediation.

     At this tim« EPA agrees with the RP tnat the existing and
     proposed groundwater recovery «y»to will achieve a
                      on cont^aia^nt Migration*  The off-site
                       will be treated  as * separate operable  unit
     and addressed by BPA in a future ROD.

46.  The RP requests that the performance of the ground-water
     remediation system be evaluated based on technically
     achievable goals.   The RP requests that the ROD reflect EPA's
     recognition of limitations on cleanup strategies and the need
     to base cleanup goals on best demonstrated technology.  In
     other words,  the ROD should be worded to state that "if it is
     demonstrated that ground-water contamination asymptotically
     approaches concentrations above cleanup levels, EPA will
     modify the cleanup levels consistent with that determination.


                                 14

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     EPA does  not  agree  with  the  proposed  change  at  this  time.
     CSRCLA requires  that  remedial  actions meat applicable  or
     relevant  and  appropriate requirements (ARARal of  other
     Federal and state env* Torin*ntal  laws.  These lavs include
     but are not limited to;   The Toxic  Substances control  Act.
     the Clean Water  Act,  the Safe  Printing Water Act, and  the
     Resource  conservation and Recovery  Act.

     All discharges of treated ground water to Lycominq Creole
     should aeet National  Pollution Discharge Elimination systani
     (NPDB8) requirements  developed pursuant to PAPER  Bureau of
     Water Quality Management standards.   The goal of  the ground-
     water remediation is  to  achieve  background groundwater
     quality as required by the Pa. Code Sections 264.90  through
     264.100.   See comments 128 and *7l  of this Responsiveness
            for further details.
47.   The  RP requests that the off-site institutional controls
     recommended in the FS be made part of the ROD since the
     potential  risk to a hypothetical ground-water user exists
     and  will exist until remediation is completed.

     EPA  agrees that institutional controls are needed in the
     final  selected remedy and will incorporate them into the
     selected remedy as described in the ROD.
                                15

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Source Docuaent: May 14, 1991 letter froa Williaasport Municipal
                 Water Authority (WMWA) to U.S. BPA and
                 May 16, 1991 Letter fron BRM to U.S.  EPA in
                 Response to the WMWA Letter

43.  The  WMWA submitted a comment regarding  whether  the  present
     two-stage air stripping system is  a  limiting  factor with
     regard to increasing the well-field  capacity  from 6 million
     gallons per day (MGD)  to 9  MGD.  (See WMWA  Comments  l &  2.)

     The  RP responded to this comment and believes that
     nicdif ication of the air stripping  system will not have  an
     impact on the available yield.   The  RP  further  indicates
     available records  do not exhibit that the  well  field has
     ever been used at  even its  current 6 MGD capacity.

     The  two-stage air  stripping system limits  the rate at which
     well water can be  treated to remove  VOCs to 6 MGD,  but  does
     not  limit the rate at which the well field can be pumped.
     Current plans are  to increase the capacity of the stripper
     system to 9 MGD by modifying it to a one-stage system.   Once
     the  air stripper can handle 9 MGD, and  provided the well
     field yields 9 MGD,  the WMWA will  be assured of this rate  of
     supply.

     BPA  cannot respond fully to this commen.t until certain
     questionsareanswered.The WMWA »uat  provide data
     demonstrating that the wall field canreach * yield of  9
     MGD.  Alao. at a withdrawal rate of  9 MOD,, the impact on  the
     qroundwater flow regime is  liXely to be significant if
     pumping_continues  over in extended tiae period.  The WMWA

     These factors will become more evident  and important when
     the  off-site qrouadirmter recovery and treatment la addressed
     in the second operable unit in a future ROD.
49.  The WMWA noted that the Third Street recovery well pumping
     appears to successfully control additional contaminant
     migration into the WMWA well field,  but expressed concern
     that the Third Street recovery well may significantly affect
     the recharge capacity of the well field when used for
     extended periods of time at rates of 6 MGD or higher.  (See
     WMWA Comment 3.)

     The RP agrees that the Third Street recovery well is
     effective in controlling the contamination into the WMWA
     well 'field.   The RP states that the maximum effect of the
     Third Street Recovery Well on the WMWA supply wells could
     theoretically be as high as 1 to 1.4 MGD if the Third Street
     well is pumped at 700 to 1,000 gallons per minute.  The RP
     also notes that the water in the Third Street and WMWA wells
     is  induced recharge from Lycoming Creefc and the Susguehanna

                                16

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    River.  Therefore,  it  is unlikely that the Third Street well
    has or will have any measurable impact on the WMWA well-
    field yields.

    EPA believes  that  the  ability of the Third Street veil to
    intercept  contamination and  its impact on the yield of the
    WMWA veil  field depend on the pumping schedule and pumping
     rates  from  the WMWA wall  field.
            umping scenarios
    a clear picture  of
      WMWA,   it  is not
    possible  to predict the  interaction between the Third street
    and WMWA  walla  or  to  adequately evaluate the rate and extent
    of induced recharge from surface water bodies.

50.  The WMWA  stated that  an  additional off-site recovery well
    should be constructed north  of Third Street.  This well will
    allow a decrease in pumping  from the Third Street Well
    during heavy usage periods.  The RP states it is unlikely
    that replacing  the Third Street recovery well with a well
    400 to 500 feet further  north  (based on WMWA's suggested
    location) that  pumps  1 to 1.4 MGD would measurably change
    the available yield in the WMWA well field.   (See WMWA
    Comment 4.)

    WMWA believes an additional  benefit of locating an
    additional recovery well would be to minimize additional
    ground-water contamination migration from east of the well
    field.  The contamination would normally have flowed
    southeast, prior to being influenced by the flow lines of
    the WMWA  well-field cone of  depression.  WMWA also believes
    while the Third Street well  operates effectively as a
    contaminant migration interference well, it greatly enlarges
    the cone  of depression of the WMWA well field, which would
    potentially enhance contaminant migration from the east  into
    the well-field  area.   The RP disagrees with "replacing"  the
    Third Street Recovery well.  The RP states that the amount
    of water  coming from  the east to the well field, which is
    beyond the contaminant plume, would not measurably change.
    The RP states that numerical ground-water modeling will  be
    performed to better evaluate the effect of off-site pumping.
     icenarioe  for  both the RP
are provided, and until a
    recovery well  cannot  be evaluated*
         t
    EPA a'areea with WMWX'e  pceition that the Third Street yell
    can alter the  source  of water to wella in the well field.

    without acre data  and until an evaluation through Modeling
    ia conducted.  The future evaluation of the effectiveness  of
                                17

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     provide this input information.

51.  The WMWA states that an assessment  of  the  extent of the
     contaminant migration around  and  into  the  WMWA well field  is
     not addressed in the HP's  Risk Assessment  or  Remedial
     Investigation Report.   The WMWA data  indicate that the 10
     parts per billion (ppb)  trichloroethylene  (TCE) isopleth
     extends west of Lycoming CreeJc toward  WMWA Well 47, and on
     the east and south toward  WMWA wells  43,6,9 and 10.  The
     WMWA states that additional monitoring of  the plume in and
     around the WMWA well field during pumping  and non-pumping
     periods would provide an indication of off-site remedial
     action as it relates to the well-field operations.  (See WMWA
     Comment 5).

     The RP responds by stating that the effectiveness  of the
     ground-water program will  be  monitored by  quarterly sampling
     of  existing monitoring wells  as well  as WMWA's water quality
     sampling of their own wells.  The RP  questions how much
     additional monitoring would be needed to demonstrate whether
     or  not ground-water quality is improving.

     SPA believes that the need for additional  grouadvater
     monitoring cannot be rul«d out at this tiae baaed  on the
     data presented by the RP and  WMWA.  As Bore data become
     available over tiae. *nd with the construction and
     validation of a computer «o<3«l. the qroundifater development
     and recovery scenario* will provide the information needed
     to  decide on additional Monitoring.

52.  The WMWA states that the goal of  the  proposed plan should  be
     to  restore the WMWA well field to its original water
     "quality and quantity" potential  without the  need  for  the
     WMWA to treat for VOCs. The  WMWA comment  states that  an
     interim goal during the remedial  action period should  be to
     contain the contaminant plume in  such a way as to  avoid
     impacting the WMWA pumping capacity as well as the need  for
     any additional treatment of VOCs, including off-gas or other
     forms of additional VOC treatment by  the WMWA.   (See WMWA
     Comment 6.)

     The RP responded that the  water quality in the WMWA well
     field has already improved to levels  generally below MCLs  as
     a result of the Third Street  Recovery veil operation.   In
     addition, controlling the  source  of contaminants  at the
     Textron property boundary  should  result in cleanup of  the
     off-site ground water with the help of the Third  Street
     Recovery Well, such that this well  can eventually be  shut
     down.  The RP states that  there  is  no indication that
     recharge to the WMWA well  field has been affected by the
     Third Street Recovery Well.


                                13

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EPA acknowledges both the RP's and WMwy T ^«««enta.  One
goal of the remedial action is to aininise off-site
migration of contaminants in ground vater flowing beneath
the AVCO Lvcomina site.  The action will provide adequate
protection by controlling and reducing riafc through a
^rtmEH nation of cont*inmant. treatment, and inatitutional
controls.  The action will contain and treat the
contaminated ground water on-site while the off-aite ground-
water plume is recovered ^n^ Created through the existing
ground-water treatment systea.  with regard to the reduction
in recharge to the WMWA well field. BPA does not currently
have evidence that a reduction in recharge to the WMWA veil
field la occurring or may occur.  According to the data and
available information, significant recharge occurs from
Lvcomina CreeX and the Susouehanna River.
                            19

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Source Docuaant: May 10, 1991 L«tt«r fro» BRM to U.S.  SPA

32.   The  R?  presented information  to  substantiate their rationale
     for  not conducting additional  off-site ground-water  recovery
     at this tiae.   provided:                   '

     o    "The present  off-site risk to ground-water users is
         within the  acceptable range because the water from the
         VMWA supply wells is treated.  Only under hypothetical
         situations  of  untreated ground-water use does any
         unacceptable  risk exist to potential users."

     o    "The limits of the overburden pluae are well-defined,
         and the plume  has been effectively contained by the
         present remedial system.  The plume is presently in a
         steady state  condition, and no further deterioration of
         the aquifer is evident based on routine quarterly
         monitoring  over the past  two to four years."

     o    "The on-site  system will  be expanded by implementing
         the proposed  remedy*  This will increase the
         contaminant mass removal  on-site, block additional off-
         site migration (both overburden and bedrock) and help
         to  improve  the effectiveness of the off-site system."

     o    "The present  off-site ground-water recovery system has
         significantly  reduced the concentrations in all of the
         WMWA production wells, demonstrating the effectiveness
         of the Third  Street well  as a blocking/recovery well.
         As shown  in the Remedial  Investigation  (RI), on-site
         and off-site  monitoring wells and the WMWA wells show
         decreases  in  contaminant  concentrations since
         installation  of the existing recovery systems."

     o    "The overburden plume is  being captured by the  pumping
         of the Third  Street Recovery Well.  This was
         demonstrated  by a two-dimensional streamline model
         completed by  E£M.  This model uses the same basic Theis
         assumptions as the DREAMS or RESSQ models.  The model
         was used  to demonstrate the capture area of the Third
         Street Recovery Well when this veil is pumping  at 500
         GPM.  In  addition, each of the WMWA production  wells
         was simulated  in the model to pump 100 GPM, and the
         recharge  boundary of Lycoming Creek was simulated using
         the image veil theory to  present a vorst-case scenario.
         The model demonstrated that vhen pumping at the rate  of
         500 GPM,  with  all of the  WMWA veils operating,  the
         Third Street  Recovery Well  effectively captures the
         entire off-site overburden  contaminant plume."

     The  RP  further states  that they "agree with the PADER that
     it is prudent  to operate the proposed on-site recovery

                                20

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system for a minimum of two years and a maximum of five
years to collect accurate operating data on the system."
These data will be used to determine the effectiveness of
the present off-site recovery system at reducing the off-
site plume mass.  During this time period, a ground-water
flow and transport model will be calibrated, run, and
continually upgraded with site data to more reliably predict
cleanup times and the effectiveness of the off-site recovery
system.  Based on these monitoring data and modeling
results, the need for additional off-site recovery will be
evaluated to determine whether additional off-site
remediation would be required and if so what the specific
requirements would be.

EPA agrees that tha •xistino and proposed aroundvater

short t«na, and is accepting th« rational* for not
finalizing tha decision on th« •act^nt off  off-sit«
groundwatar r«cov«ry at this tia«.  Hov«v«r. EPA will ba
evaluating th< mtf baaia of a  future
Racord of Decision for OU-2.
                           21

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Source Document: Response to U.S. SPX and FADER Comments:
                 15 January 1991 Draft Remedial Investigation
                 Report for the Textron Lycoming Williamsport
                 Facility

54.  The  EPA requested that  the RP  discuss  other potential
     sources of contamination  or provide  that  a review of all
     other potential sources (through interviews and  reviews  of
     file material  from other  hazardous waste  generators in the
     vicinity)  have been identified.   As  noted during the site
     visit,  there was an odor  which may have been a volatile
     contaminant .

     The  RP stated  that according to their  interviews with plant
     personnel  and  review of the Textron  file  material,  no other
     continuing sources to ground-water contamination were
     identified.  The RP stated that they do not have the
     authority  to obtain records from industries active  in the
     area to review operations and  disposal practices.   The RP
     was  not able to respond to the statement  regarding  the odors
     noted during the site visit because  they  did not know where
     in the study area the EPA noticed odors of volatile
     organics .
     EPA aareea that the RP did a thorough review of the
     potential on-aite sources of the crroundvate
     In response to obtaining information regarding hazardous
     vaate generation and disposal practices of other Indus-tries,

     that the source has been adequately characterised and no
     further research is requested fro« the RP.  with regard to
     the source of the odors, it appears that the odors were
     originating fro« outside of the AVCO Lycoaino: facility.

55.   EPA requested that the RP provide modeling in the RI in
     order to define the volume of soil to be remediated and the
     length of time necessary for operation of the ground-water
     treatment system.  EPA noted that if this modeling would be
     included in the FS or RA then the comment could be deleted.

     The RP responded that the modeling is discussed in detail in
     the responses to the draft Feasibility Study.  The RP
     reiterates that once the planned on-site remedial system is
     installed and operating, data will be collected to check its
     performance.   The RP states that "After the system has been
     operating as designed for two to three years, sufficient
     data Would be available to initiate reliable modeling to
     evaluate cleanup times.  This would provide a better basis
     to determine whether additional remedial measures are
     warranted. "
                                22

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         accaots  tha  deference to the modeling presentation in
     the  response to  the Feasibility atudv comments.  BPA doaa
     not  accept aa •valuation of tha system in tiro to three
     years.   The  on-aite remedial svsten will be evaluated after
     approximately tvo years operation.  Baaed on this
     evaluation,  and  additional studies, BPA will then evaluate
     the  effectiveness and  develop plans for future off-site  (00-
     2) remediation.


56.   EPA  requested that the RP provide a detailed description of
     the  chemicals used at  the site  in order to perform a more
     thorough characterization.  EPA also requested that the  RP
     provide  a list of compounds other than TCE which may have
     been disposed of in the dry well.  With regards to the
     presence of  semi-volatile compounds found in the outfall of
     the  Oliver Street storm sewer at concentrations above
     background,   EPA requested that the RP provide a list of all
     chemicals associated with the plant to demonstrate that
     there are or never have been semi-volatiles associated with
     the  plant.

     The  RP responded with  a summary of the operations and
     provided a list  of chemicals presently used at the facility.
     The  RP also  reiterated that during the RI, expanded chemical
     analyses (Target Compound List  and Target Analyte List)  were
     conducted on ground-water and soil samples. Based on these
     data,  the RP believes  that the  type of chemical compounds  in
     the  environmental media in the  study area have been
     adequately characterized through the analytical work
     completed and that no  unknown compounds are present.
57.   EPA  expressed concern that the RP has not adequately
     evaluated  the ground-water contamination with regard to
     separate phases,  specifically Dense Non-Aqueous Phase
     Liquids  (DNAPLs).   Consideration should be given to the
     positioning of the screen intervals in order to best detect
     DNAPLs.  Trichloroethylene (TCE)  has been observed to
     increase with depth in the well nest containing MW-8, MW-
     8D,  and MW-62 which may be an indication of a DNAPL
     contaainant source.   The RP should provide an assessment of
     the  DNAPLs as they potentially reach and contaminate the
     bedrock.
         i
     The  RP provided evidence that consideration was given to
     placement  of the well screens in the overburden to evaluate
     the  potential for DNAPL.  The RP has utilized a Kemmerer
     sampler to obtain samples from the bottom of the wells and
     no DNAPL was observed.
                                23

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53.
The RP states that the DNAPL may exist as a residual source
which is difficult to remediate and there is no current
technology available for this remediation.  To date, the
cest available technology is to control the source.

The RP concluded that the data indicate that if a residual
source of TCE exists, it appears to be restricted to the on-
site area and feeds TCE to the ground water in a dissolved
phase.  The data do not indicate that there is mobile DNAPL
and suggests that if non-aqueous phase liquids are present,
they are located on-site, most likely as an immobile
residual .

SPA agrees that th« data collected to <3at« indicate that the
DNAPL aa? not b« mobile.  However, thera «ay ba DNAPL
residual sine* thara ara increasing concentrations of TCE
with 4«oth.  Further •valuation of th« potential for and
occurrence of DNAPL will b« conducted during the design of
the on-sita recovery system.

EPA identified certain deficiencies in the RI and requested
that the RP provide tables, data, additional information, or
clarification.  The topics are stated briefly below and
acknowledgement of EPA's receipt of requested information  is
identified.  The requested information was also made
available for public comment during the public comment
period for the Proposed Plan.
     a)
     b)
     c)
     d)
     e)
     f)
     References in the RI.

              to and accepted by
     Correction on Section 3.8:  Regional Hydrology.

     Provided to and accepted bv SPA.

     Section 3.9:  Pages 3-17 and 3-18.



     Section 4.6.1: Collection of Groundwater Samples

     Provided     nd acc^ttd b  BPA.
     Section 4.6.1.1:  Field parameter collection.
     i
     Provided to and accepted bv SPA.

     Section 4.6.4: Page 4-25; Use of immiscible interface
     probe.

     Provided to and acc»t«d
                           24

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g)   Section 5.0:  Consistency  in  labeling  figures  and
     plates.
     Provided to and accepted  bv  BPA.
h)   Section 5.1.2.1:  Past Plant  Operations
     Provided to and accepted  by  BPA.  See  response to
     f?r»ma^nt 54  of this Responsiveness 8nB""arv.
i)   Section 5.3.2.3:  Page 5-17;  Background  soil  data  and
     transcriptional errors.
     Provided to and accepted  by  BPA.
j)   Section 5.3.5:  Comparison of laboratory VOC  analysis to
     Petrex Soil Gas Results
     Provided to and accepted  by  BPA.
k)   Section 5.4:  Figure for overburden thickness isopachs.
     Provided to and accepted  by  BPA.
1)   Section 5.4:  Inclusion of recovery wells on  Plates 3,4,
     and 5 and locations of potential  areas  of concern.
     Provided to aad accepted  by  BPA.
m)   Figure 5-32:  Connect the  hot spot around MW-3R to the
     rest of the plume configuration.
     Provided to and accepted  by  BPA.
n)   Section 5.7.2.8:  Estimate the total mass of
     contaminants present in  the  saturated zone,  both in the
     liquid phase and sorbed  to the solid phase.
     Provided to and accepted  by  BPA.
o)   Section 6,  Page 6-2: Clarify the meaning of "low" in
     the statement "overall VOC concentration in the soil
     samples were low."
     Provided to and accepted bv BPA.
p)   Appendix 0: Remedial Investigation Quality
     Assurance/Quality Control Review Report: Definition of
     the "B" qualifier.
     Provided to and accepted by BPA.
                           25

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33.  FADER requested that the  R?  provide  information  regarding
     the isolated occurrence of Arochlor-1254  (polychlorinated
     biphenyl - i.e.,  ?C3)  in  soil  boring SB-14B.

     The RP provided information  to substantiate  that PC3s were
     not used or disposed of at the site.   The  RP stated that the
     soil sample was collected in conjunction with the
     underground storage tank  investigation being conducted  in
     cooperation with the PADER.

     EPA acXaovladqaa the raaponae.   In  addition,  BP* received
     tha Underground 3torag« TanX raport  ajd is currently
     conducting a raviair and evaluation  of tha  document.

60.  EPA questioned the unidentified.recharge boundary that
     apparently exists 500 to  1,000 feet  east of  RW-2.  EPA
     requested information regarding regional geologic
     information to support the apparent  increase in  the
     thickness of the overburden  east of  the site.

     The RP stated that the apparent recharge boundary is  an
     observation from the recovery  test  data discussed in  the RI.
     The RP stated that there  is  no known "regional geologic
     data" to support the thickening of  sediments east of  RW-2,
     but indicated that the site-specific data  indicate
     overburden thickness in this direction.

     EPA acknowledges ind «cc«Pt» this response,  .at this  time.
                                               f>
61.  EPA requested that the RP provide information regarding the
     potential for contaminants to  migrate in the bedrock  at Elm
     Park and beneath Lycoming Creek.  It appears that the water
     level elevations at HW-60 and  MW-32  appear to indicate  an
     upward hydraulic gradient but  this  is contradicted by the
     fact that little if any of the overburden  appears to  be
     saturated near the "bedrock  ridge1*  at Lycoming Creek.  The
     water level elevations in MW-14B and MW-72 indicate a
     downward gradient.  Presumably this  reflects the impact of
     pumping at the Ela Park recovery veil.  Although operation
     of  this recovery veil might  appear  to affect Lycoming Creek
     here,  it is not clear that contaminants would also discharge
     upvard given their apparent  propensity to  move southvest
     along strike in the bedrock.  EPA is concerned that the data
     available regarding TCE-DCE  concentrations in bedrock wells
     provide little assurance  that  contaminants have  not migrated
     beneath Lycoming Creek.

     The RP argues that there  is  a  bedrock high in an area of
     thicker saturated overburden sediments where MW-60 and  MW-
     32  are located.  Therefore the upvard gradient at Elm Park
     is  an accurate observation of  the hydrogeologic  conditions.

                               26

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     The  RP  indicates  that  it was  not their intent to imply or
     state in  the  Rl that all of the contaminants or ground water
     in the  bedrock at Elm  Park discharge to the overburden
     sediments.

      EPA is not convinced  that contaminants have not migrated
     across  Lvcomina Creek  at Elm  Park and will evaluate this
     possibility with  the second operable unit.

62.  EPA  requested that the RP provide further data
     interpretation or analysis to explain the presence or
     absence of vinyl  chloride in  the ground water from wells at
     the  perimeter of  the plume.   This information would provide
     information relevant to the design  of a ground-water
     biorestoration remedial alternative.

     The  RP  provided the hypothesis that the TCE to vinyl
     chloride  biodegradation is primarily through a  reductive
     dechlorination pathway, caused by anaerobic conditions
     enhanced  by the plant  paving  (approximately 85% is paved or
     covered with  buildings) .  In  addition, ethene can be the end
     point from the abiotic degradation  of the vinyl chloride.
     The  RP  reviewed data from the wells at the perimeter of the
     plume and concluded that the  vinyl  chloride concentrations
     were below the detection limits of  less than 1 ppb.

     EPA  notes and acknowledges the response.  At this time the
     hypothesis seeas  plausible; however, additional aonitoring
     for  the degradation products  of TCB will be substantive.
     The  science of biorestoration/bioremediation is still in its
     infancy and information froa  sites  such as these will build
     on the  liaited existing <
63.   EPA  requested that the  RP clarify the reason for the higher
     pH in  monitoring wells  MW-64  and MW-66.   EPA suggested that
     these  wells  may need to be abandoned since they may be
     grout-contaminated .

     The  RP responded that the reason for the high pH in these
     wells  is  not clear.   The RP indicated that they will
     redevelop each of the wells with high pH and reevaluate the
     integrity of the veils.   The  RP stated that pH is not a
     factor affecting the concentration of the contaminant of
     concern in the study area or  the ability to detect these
     compounds .
         i

     wells  are needed.   BPA disagrees that the oH will not
     affect the ^bjljtv to detect  the coapounda of interest.  The
               * (chlorinated hydrocarbons)  are not directly
     affected  by elevated pH;  the fact that the well aay not be
     orooerly  developed indicates that saaples collected from the

                                27

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     va\T.3 aay not ba representative of  tha  aonitored  aquifer.

64.  ?ADER requested that the RP change  the  direction  of  the
     arrows indicating ground-water flow in  the  bedrock so  that
     they are perpendicular to the ground-water  contour lines.

     The RP indicated that the flow conditions  in  the  bedrock  are
     anisotropic,  based on recovery test results.   Therefore,
     under anisotropic conditions, the direction of groundwater
     flow is not necessarily perpendicular to the  contours  of  the
     pctentiometric surface as expected  in isotropic flow
     conditions.  The RP stated that the direction of  ground-
     water flow, as depicted by the flow arrows  are correct.

     gPA acXnoirladqas and accepts th« r«3Dona«.

55.  EPA stated that ground water appears to flow  to the
     Susquehanna River, which is about a mile south of the  site;
     however,  no information could be found  regarding a ground-
     water discharge investigation.  EPA suggested that the
     discharge points be located and tested  for any contamination
     that might be entering the Susquehanna. This concern
     revolves around the ultimate fate of the  1,1-
     dichloroethylene as well as several metal  contaminants
     associated with the' site.

     The RP indicated that ground-water  flow from  the overburden
     beneath the Textron Lycoming facility should  be captured  by
     the Third Street Recovery Well; and therefore, no discharge
     to the Susquehanna River would occur.  The RP also stated
     that if contaminants were to discharge  to  the river  from  the
     overburden aquifer, the contaminants would be diluted,
     resulting in concentrations below detection limit. The RP
     states that the bedrock aquifer in  the  vicinity of Third
     Street does not contain contaminants of concern above  the
     analytical method detection limits.
v
                                              w
                                                         should
     be captured by the Third Street Recovery Well.  However. as
     stated in the 8ite Characteristics lection of the ROD, in
     DCB concentrations of 37 pob and IS ppp« respectively.

     do«s not *rl»t ia th< vicinity of Third 8tr««t.  BPA
         that th< ••t«la ar> attanuatad bv
                                                    aoil and may
not ti« of concern
                         At this tim«. tn« RP*« r<»pon»» ia
66.   PADER requested information regarding the type of cooling
     process used,  especially with regard to the types of
     chemicals used to treat the water.
                                28

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     The  RP  responded  that  little  is Icnown about the cooling
     system,  but  it  is believed to have been an air-water heat
     exchanger  in which air flows  around coils containing water
     which was  not recirculated.

     At thi3  time, the response ia adequate.

67.   PADER requested that the RP clarify the reason for the
     variation  in detection limits used for vinyl chloride.

     The  RP  stated that the analytical protocols used require
     dilution of  the samples where high concentrations of
     contaminants are  evident.  TCE was the high concentration
     contaminant  that  required the sample to be diluted.  These
     dilutions  drive the final detection limits for all non-
     detected compounds in  the diluted analyses.

     EPA  acknowledges  and accepts  this response.

68.   PADER requested information regarding an anomaly that the
     concentrations  of hexavalent  chromium are greater than the
     total chromium  concentrations in wells MW-3 and MW-18.

     The  RP  states that these two  parameters are analyzed using
     different  methods,  and the results for the two different
     compounds  in each well were below the permissible EPA error
     range for  laboratory analysis.

     EPA  notes  and acknowledges this response.

69.   EPA  requested that the RP provide evidence and assurance
     that chromium will not eventually migrate to the WMWA well
     field.   Based on  data  for MW-31, which is located south
     (downgradient)  of the  old wastewater treatment plant, it
     appears  that off-site  chromium migration  is occurring.  EPA
     states  that  isoconcentration  maps depicting chromium  levels
     should  be  included in  the RI  report.  The EPA states  that
     the  FS  report should include  remedial alternatives which
     address  the  chromium as well  as the organic contaminants.

     The  RP  stated that there was  no  intention to de-emphasize
     the  occurrence  of hexavalent  chromium  in  the ground water
     beneath the  western portion of the plant.  The primary  focus
     of the  contaminants in the ground water are TCE,  DCE, and
     vinyl chloride.  The RP states that the RI report  indicated
     that 'migration  of hexavalent  chromium beyond the  plant
     boundary is  occurring. The RP provided an  isoconcentration
     map  presenting  the hexavalent chromium contaminant  plume.

     The  RP  states that effort was placed  in the  FS  concerning
     the  remediation and treatment of  the hexavalent  chromium
     portion of the  contaminant plume.  The RP conducts  ongoing

                               29

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collection of samples and analyses for hexavalent and total
chroaiua.

At this tiaa 3PA doas not discount that remediation of the
3ourc« of the chromium gay b< naadad.  Otherwise, BPA
acKnovladgaa and accapta this
The EPA stated that the Pennsylvania ARAR for ground water
for hazardous substances is that all ground water must be
remediated to "background" quality as specified by 25 Pa.
Cede §§264 .97 (i) ,  ( j) and 264 . 100 (a) (9) .   The Commonwealth of
Pennsylvania also maintains that the requirement to
remediate to background is found in other legal authorities.

The RP does not agree that EPA should consider the
Pennsylvania ground-water "background standard" specified in
25 Pa. §§264.97(i) ,  (j) and 264. 100 (a) (9) to be an ARAR.  The
RP argues that these standards are applicable to RCRA sites
not CERCLA sites.    In addition, the standard is not relevant
and appropriate since it does not address problems or
situations sufficiently similar to those encountered at  the
site and that their use is well suited to the site.  The RP
argues that the RCRA standard is intended as a "prospective
detection and reaediation standard," and it is inappropriate
to apply such a standard to the situation at the Textron
Lycoaing facility where long-term historical contaaination
caused a ground water plume.

BPA disagree* that  thi« r
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Source Document: Response to U.S. EPA and PADBR Comments:
                 31 January 1991 Draft Risk Assessment (RA)
                 Report for the Textron Lycoming Williamsport
                 Facility

71.  In  the  RI  review,  EPA  requested  more  information  concerning
     the impact of  ground-water and soil contamination on
     toxicity.   The environmental risk assessment  relating to the
     contaminants vinyl chloride,  1, 1-dichloroethylene, and
     hexavalent chromium should be addressed.

     The RP  stated  that this is addressed  in the response
     comments on the draft  Risk Assessment.

     EPA notes  and  accepts  this response.

72.  EPA noted  that it  is the policy  of the EPA to present a
     conservative estimate  of site risk as represented by
     reasonable maximum exposure (RME)  scenarios.   This approach
     may be  explained as the highest  exposure that is  reasonably
     expected to occur  at a site.  It includes consideration  of
     both exposure  parameters and exposure point concentrations
     for their  relevance as reasonable maximums.  EPA  states  that
     the RP's RA report has presented a risk range rather  than
     calculating the RME.

     The RP  states  that the RA report was  prepared in  accordance
     with the interim final "Risk Assessment Guidance  for
     Superfund,  volume  1, Human Health Evaluation Manual  (EPA
     540/1-89-002)." The carcinogenic risk for the RME scenario
     equaled the reasonable risk scenario.  Similarly, the hazard
     for the RME was almost identical to  the reasonable hazard.
     Therefore,  the RP  requests approval  to leave the
     calculations as a  range.

     In  addition, the RP noted that the RA guidance document
     recommends the use of  total unfiltered metals as  a
     conservative,  worst-case approach to  risk calculations.  The
     RP  states  that Region  III has required full detection limits
     in  the  calculation of  averages for metals for other NPL
     sites.  The RP noted that all of the  EPA recommendations
     could b« included  in the report, but  the conclusions  to  the
     RA  and  the media requiring remediation would remain the
     same.   Therefore,  the  RP requests EPA approval to leave  the
     calculations as reported in the  RA.
         acknowledges  the  re»pooif^ ^fld agrees that both
    approaches  conclude that siailar Media-specific remediation
    is  required.
                                31

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72.  EPA noted that there vere transcriptional  data  errors  in the
     RA which should be corrected.   in addition,  the definitions
     of exposure tiae (ET) ,  exposure frequency  (EF) ,  and  exposure
     duration (ED)  on page 5-16 do  not coincide with the
     calculations presented  on page E-10  of  the RA report.

     The RP  states that the ET,  EF,  and  ED  values on pages  5-16
     and E-10 were given for different scenarios.  the values on
     page 5-16 reference VOC emissions from  the air  strippers
     which were modeled to the nearest population, while  the
     values on page E-10 reference  the inhalation of volatiles
     from soil at source without modeling.   Therefore,  the
     exposure values were different.

     SPA acKnovlodcroa and accepts the response.

74.  The EPA noted that the  incorrect version of the "Risk
     Assessment Guidance for Superfund Volume 1,  Human Health
     Evaluation Manual" was  cited.   The RA is to use the  December
     1989 version rather than the September  29, 1989 version.

     The RP stated that the  correct version  was used in
     preparation of the RA report.

     SPA acknowledges and accepts the response.

75.  EPA states that the risks were calculated  using the
     arithmetic mean of the  constituent concentrations and
     calculated again using  the maximum concentrations.
     According to the "Risk  Assessment Guidance for  Superfund
     Volume 1,  Human Health  Evaluation Manual", the  95%
     confidence interval of  the arithmetic mean should be used
     with other considerations to quantify the  reasonable maximum
     exposure (RME).   The RME should be used in quantifying the
     risks unless the deviations from the approach  are approved
     by EPA.

     The RP noted that the modification was  baaed on the
     knowledge that ground-water risks calculated in the
     preliminary risk assessment (ERM, 1988)  exceeded EPA's
     recommended carcinogenic risk  range. The  RP notes that the
     ground-water data collected after submission has not shown
     concentrations significantly different  from the previous
     levels.   The RP requests EPA's approval for the deviation
     based on the facts presented and the use of similar
     conservative approaches on previous  RA  submittals made to
     the agency.

     BPA accepts the RP*> approach  used to quantify site risks
     based on the fact that  « revaluation of the risks in
     accordance with approved SPA aethodology would also result
     in a Talue greater than 1 x 10   from the  corresponding

                                32

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    madia.  Thus, bcth  approaches conclude that similar media-
    apecific  remediation  ia  required, although in some instances
    the  ria*  numfr^rs presented by the RPa are overly
    conservative.   The  conservative nature of the PII»>S«T-«I
    results from  the use  of  several philosophical approaches to
    the  data  that are inconsistent with EPA policy, including
    the  use of  a  riafc range  rather than tha RMB. the use of
    unfiltered  natal3 data,  and  the use of full detection  limits
    for  non-detect  metals.   BPA  notes that the HP's request for
    approval  of this methodology, which ia based on tha fact
    that similar  conservative approaches have been used by tha
    RP in prior submittals to the Agency, ia not a valid
    argument  for  Agency acceptance.

76.  The  EPA noted that  11 of the 35 wells within the three-mile
    radius of the site  were  identified as domestic water supply
    wells.  EPA requested that the RP provide justification for
    not  considering these wells  as potential receptors.  Ground-
      water sampling data  may be  necessary to determine  if  these
    wells have  been impacted by  the contaminant plume.

    The  RP stated that  none  of these wells are within  the
    defined plume boundaries, nor during the RI were any
    migration pathways  defined toward these wells.

    EPA  ackaovledaea the  response and notes that  in  the future,
    efforts shall be made to verify the existence  of these
    veils.

77.  The  EPA requested clarification of the statement that  the
    WMWA supplies five- to eight- percent of the  water for
    Williamsport.  EPA  is concerned whether this  percentage  is  a
    yearly average. EPA  requested the seasonal percentages
    rather than the yearly average.

    The  RP revised  and  submitted Table 2-2 which  includes  a
    breakdown of  the water usage from the two  reservoirs  and  the
    WMWA production well  field during the months  that  the  well
    field was used.
78.  EPA requested a text change for Section 2.5.1, Page 2-14 due
     to inconsistencies between this report and the RI.

     The HP submitted the revised page which was changed to be
     consistent with the RI.

     BPA acknowledges and accepts the response.

79.  The EPA was concerned that the underground storage tanks may
     be a contributing source due to elevated VOCs in the soil in

                                33

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     the central section of  the  plant.

     The RP noted that the Underground  Storage Tank  (UST) report
     provides information regarding  the soils  investigation  in
     this area.

     The 08T report has bean received by BPA and  ia  currently
     being reviewed and evaluatad.

30.  The EPA noted concern regarding the statements  the  "source
     of the bedrock contamination is unclear"  and "the primary
     migration pathway for contaminants in  the bedrock aquifer
     corresponds to the primary  ground-water  flow direction."
     The EPA is  concerned with the migratory patterns of DNAPLs,
     which do not necessarily follow the same  flow paths as
     ground water.

     The RP stated that this comment has been  addressed  in the RI
     response to EPA comments.

          »A r»3Pons« to Conaant 57  of  thia Responsiveness
31.   EPA requested clarification of the conversion of the
     reported chronic reference dose (RfD)  to the subchronic RfD
     listed in the Table for cadmium.

     The RP removed the subchronic RfD for cadmium and noted that
     the removal had no impact on the  conclusions.

     B7A acknowledges and acc«ot« the  response.

32.   EPA requested that the eleven scenarios be  presented in
     terms of current and future land  uses. EPA  indicates that
     the data and/or calculations should be presented to
     characterize the likelihood that  exposures  might actually
     occur.   EPA states that if it is  unlikely that exposures
     will occur, the scenario may be excluded from further
     consideration provided there is sufficient  justification
     including review and comment from the EPA and PADER regional
     project managers.

     The RP requests that the changes  in terminology from
     "feasible" to "actual" and "hypothetical" to "future" not be
     made in that the text, tables, and appendices would require
     significant revisions.  The RP requests that rather than
     change the document, EPA should approve that an additional
     page be inserted prior to the Executive Summary that defines
     the terminology under the old (EPA, 1986) and final (EPA,
     1989)  guidance documents.
                                34

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    acfcnoirl edges receipt of the page  and  accepts  the
response.
                            35

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Source Document: Response to U.S. BPA and PXDBR Comments:
                 15 March 1991 Draft Feasibility study Report for
                 the Textron Lycoaing williamsport Facility

33.  EPA questioned the lead concentrations  in  Appendix  B  of  the
     FS and stated  that lead in soil should  be  remediated  to  less
     than 200 parts per million (ppm)  in residential  areas.

     The RP indicated that the maximum lead  concentration
     detected in site soils  was 13.5 mg/kg;  thus remediation  of
     the 'soil for lead is not required.

     SPA notes and  acknowledges this response.   See additional
     comment 112 of this Reaponaivene***  ?»"narv for details.

34.  EPA suggested  that additional remedial  measures should be
     considered in  the FS for off-site ground water in the
     vicinity of Elm Park.  It is not adequate  for the RP  to
     conclude that  additional remedial measures are unnecessary
     in the Elm Park Area, based on the  statement that the Elm
     Park well "is  thought to intercept  that portion of the
     bedrock flow in the Tully member that is contaminated."

     The RP states  that remedial measures have  been considered
     but were not deemed necessary in the vicinity o-f Elm  Park
     for various reasons.  The RP reiterated that the on-site
     ground-water recovery system proposed in the FS should be
     evaluated through data collection and evaluation after the
     system is operational.   The effectiveness  of on-site  and
     off-site remediation will be evaluated  two to three years
     after start-up.


     three veara.  The off-tit* ground-water oluae irill be
     treated as a separate operable unit and addreaaed by BPA in
     a future ROD.   See c 10 fl 51 of this
                         F"? for More detail.
35.  EPA requested that the RP provide an estimate rather than an
     assumed value of 30 years,  using one of the three methods
     provided in  "Guidance on Remedial Actions for Contaminated
     Groundwater at Superfund Sites'1 (EPA/540/G-88/003) to
     determine the time frame for remediation of contaminated
     ground water.  EPA requested that the time frame for
     restoration of both on-site and off-site ground water be
     estimated.
          i

     The RP indicated that use of the 30-year time frame was for
     the purpose of costing.  The RP provided output from the
     three methods as well as a slug transport model. The RP
     indicated that since there appears to be a residual
     contaminant source on-site, and because the mass of this

                                36

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     source cannot be  accurately  determined,  estimating cleanup
     time for the on-site  overburden  and  bedrock  cannot be
     defensibly performed  at  present.   The  continuous  flushing
     model and a slug  transport model  assumes that  there will be
     no migration of contaminants from the  site once the on-site
     recovery system is  in place.   The RP estimated the time for
     remediation of the  off-site  overburden ground  water, after
     the installation  of the  system proposed in the FS, to  range
     from ten to 420 years.

     This range is of  a  large magnitude because of  the
     uncertainty of the  estimate.   The RP states  that  "until the
     apparent on-site  source  of contaminants is contained  (the
     goal of the recovery  system  proposed in the  FS),  and a trend
     in the water quality  response off-site is observed, an
     accurate estimate of  the cleanup time  cannot be determined."
     The RP reiterates that the progress  of remediation on-site
     and off-site is expected to  require  at least two  to three
     years due to the  trend in water  quality in response to the
     remedial efforts  undertaken  to be observable.

     The RP states that  within the above  range of remedy
     duration,  a reasonable estimate  of cleanup time  for the off-
     site overburden ground water is  13 years with  the operation
     of the recovery system proposed  in the FS.   This  estimate
     assumes that the  off-site plume  will migrate as  a slug to
     the Third Street  well at a retarded  ground water  velocity of
     135 ft/day due to the partitioning of  TCE between aquifer
     materials and water.

     EPA acknowledges  receipt of  the  clean-up tin*  estimates and
     at this time accepts  the RP*« response.

86.   EPA indicated that  perhaps the on-site clean-up  times  could
     be shortened or enhanced by  additional measures  in the off-
     site areas.

     The RP does not believe  that expanding off-site  ground-
     water recovery will enhance  on-site  ground-water recovery.
     The reason for this is that  remediating on-site  ground water
     via off-site recovery would  require  pulling  ground-water
     contaminants that have not yet left  the site into an  off-
     site area of lover  contamination. The RP believes that  on-
     site source control allows the remediation of  off-site
     ground-water by reducing contaminant loadings  on the  off-
     site -aquifers.
          i
     At this time* BPA believes that  expanding off-site ground-

     recovery.   However. SPA  will consider  allowing the on-site
     system to be operational to  provide  information as  to the
     exact placement of  additional off-site recovery veils is

                               37

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     Bade.
37.  PADER stated that the FS references  the  cleanup  level  as  the
     maximum contaminant level.   Pennsylvania's  position  is that
     all ground-water cleanups should be  to background  quality if
     technically feasible.

     The RP presented the same arguments  regarding the  validity
     of the Pennsylvania requirements as  an ARAR.   See  comments
     23 and 71 of this Responsiveness Summary for  further
     information.

     The RP believes that using the risk-based MCLs is  a
     reasonable approach. The RP does not believe  that  it is
     feasible to reach background (or even MCLs)  in a reasonable
     time (less than 20 to 30 years)  for  sites with conditions
     similar to Textron Lycoming's on-site aquifers,  nor  has it
     been demonstrated.

     EPA believes that background la the  remediation cleanup
     goal.   B7A has selected the remedy in order to achieve this
     requirement standard.  At this ti»e  BPA  disagrees  that this
     requirement is not *a XRXR. and *t this  tiae  there la no

     criterion.  8«« responses 127 and 170 of thia Reponslveneaa
             for Bore details*
38.  EPA and PADER expressed concern that it may be too early in
     the remediation phase to determine air stripper tower sizes.
     The size of the tower will be a function of the effluent
     limits set by the facility's NPDES permit.    Based on the
     increased discharge volumes, a permit modification may will
     be required.

     The RP responded that preliminary sizing was conducted in
     order to facilitate the cost estimation.  The RP sized the
     process equipment to conform to an assumed influent-effluent
     basis, in the absence of final discharge limits from PAOER.
     The FS notes that "effluent limitations will be determined
     in coordination with PADER during the design phase.1*

     EPA agrees that the specific tower siies will be determined
     during the reaedial design phase.

89.  The PADER noted that the proposed system of recovery wells
     only stretches as far east as the area of MW-9 and MW-22.
     These two wells are areas of high concentrations of TCE and
     DCE.  Any proposed recovery system must be aJble to prevent
     contamination from leaving the site to the east of the area
     of MW-9 and MW-22.
                                38

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     The  RP  provided  a  revised  figure  illustrating the revised
     location  of  the  wells.  The  locations were changed to ensure
     no migration from  the eastern end of the plant will occur.
     The  RP  provided  an additional cost  for this modification in
     the  three FS alternatives  involving treatment.  The RP
     indicated that the final number of wells, spacing and
     pumping rates may  be modified to  account for field
     conditions.   The RP noted  that in addition to natural
     variability  within the  overburden aquifer, well access for
     drilling  and subsurface utilities interference may influence
     the  final placement of  the wells.

     EPA  accepts  the  revised spacing as  response to this comment.
     Hovevar.  the proposed recovery system should ba designed to

     3Jt«.

90.   PADER states that  the current off-site remediation is not
     adequate  as  far  as the  complete ground-water resource is
     concerned.   PADER  feels that additional  recovery  in the Elm
     Park area is needed to  increase the ongoing ground-water
     cleanup efficiency.  The PADER feels that  interception of
     the  more  significantly  contaminated ground water  within the
     sand and  gravel  aquifer can  be undertaken.

     The  RP  agrees that additional remedial efforts should be
     focused at the Textron  facility.  The contaminants migrating
     beneath the  plant  are resupplying the mass to the existing
     off-site  plume,  at a rate  of approximately equal  to the rate
     of mass removal  by off-site  recovery wells.  The  RP believes
     that the  proposed  on-site  ground-water recovery system will
     eliminate off-site migration of contaminants  in the
     overburden aquifers.  Based  on the  overburden system modeled
     by Chester Engineers, the  former  consultants, the Third
     Street  well  could  effectively contain the  overburden plume
     by pumping at a  rate of 500  gpm.  The well has pumped at
     rates of  1,000 gpm in the  past and  is presently pumping at
     650  gpm.

     The  RP  states that there  is  no unacceptable  risk  to
     municipal water  users in the area and there  are no other
     known ground-water users  in  the area overlying the plume.
     The  RP  indicates that adequate time will be  needed to
     properly  evaluate  the need for  further off-site ground-
     water recovery.
         i
     The  RP  developed and provided as  an attachment,  a
     hypothetical off-site ground-water  recovery option to  assist
     EPA  and PADER in their  consideration  of  the benefits of
     installing additional off-site  recovery  versus  the cost of
     such measures.   Two pumping  wells and  three injection wells
     would be  located approximately midway  between the plant,  the

                                39

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     Elm Park recovery well,  and the  Third  Street  recovery well,
     in the approximate center of the off-site  plume.  -Given the
     location of the hypothetical system  the  RP estimates that  i
     could reduce the off-site remediation  time by about a factor
     of two.   The RP states "however,  additional off-site
     recovery provides no additional  reduction  in  risk or
     protection of the WMWA well field compared to the existing
     system."  The estimated cost would result  in  an  increase of
     50% of the estimated cost over that  for  the on-site system.
     The RP provided the revised cost as  an attachment.

     The RP estimates the time for cleanup, assuming  the ground-
     water remedial scenario presented in the FS ,  to  be
     approximately 13 years,  based on the assumed  slug transport
     model.  The RP indicated that the future evaluation of  off-
     site remedial alternatives to complement the  existing off-
     site recovery program can be performed once these data  are
     collected.

     EPA is not only concerned with ris*  reduction or protection
     of the WMWA wall fitld but believes  that remediation  should
     be  conducted in the shortest tiae ffraae possible.  BPA does
     realise that there i» 4 need to  evaluate the  effectiveness
     of the -on-site recover? »y3tm and the results of additional
     studies prior to d+velopinq and  improving the existing  off-
     site  round-water rtcov^r  s»t»«.
91.  PADER requested that the RP change the wording on page 3-13
     regarding State Acceptance.

     The RP provided the corrected wording.

     EPA accepts th< chano*.

92.  The EPA requested clarification of the third and fourth
     sentences on page 3-33:   Administrative Feasibility.

     The RP provided an explanation for these sentences by
     explaining the reinjection step in Alternative GW-5.

     EPA accepts the explanation 
-------
     Geothermal  Fluid  Release",  Summers,  K.S., Gherini and C.
     Chen,  Tetra Tech,  Inc.,  (EPA/600/7-80-117,  1980) as modified
     by  EPA Region  IV.   Descriptions of the  Summers model and NPL
     sites  where it has been  applied are  documented in
     "Determining Soil  Response  Action Levels  Based on Potential
     Contaminant Migration  to Ground Water:  A  Compendium of
     Examples",  EPA/540/2-89/057,  EPA, 1989.

     EPA notes that tha Bunnars  model us«s th< linear equilibrium
     relationship batvean the soil/vast*  «nd th« leaching fluid.
     EPA acknowledges  and accepts  th« r«3pona«.

94.   PADER  questioned  the desirability of using  fume incineration
     for air-stripper  off-gas controls.

     The RP notes that  two  technologies,  fume  incineration and
     vapor  phase carbon, can  be  employed  for control of  air
     stripper emissions.  Vapor  phase carbon alone is not an
     appropriate technology for  removal of vinyl chloride and
     1,2-dichloroethylene.  vinyl  chloride and 1,2-
     dichloroethylene  are very poorly absorbed on vapor-phase
     carbon and  breaks  through the carbon bed  quickly.
     Therefore,  fume incineration  is a much  more appropriate
     technology  for the compounds  of concern at  Textron.

     The RP notes that  process control  is much easier with  fume
     incineration for  the constituents present in the off-gas.
     This is because the fume incinerator operation  can  be  linked
     to  the recovery system.   This way, should the fume
     incinerator fall  below its  design temperature range (as
     determined  during  system design)  for destroying the VOCs
     present in  the off-gas,  no  untreated air  emissions  will be
     released.   The RP concludes that  fume  incineration  provides
     efficient destruction  of the  vinyl chloride over the long
     term,  whereas  vapor-phase carbon will  not adsorb significant
     quantities  of  vinyl chloride.
     incinerator.   How«v«r.  th« ROD «p«cifi«« that this
     information will  b* conaid«r«d during th< •valuation for the
     final  dMion  of th« r«m
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     ri6_u .ric iU.T-T.2ry .-.-peri,  prepared  cv rer.r.sv_var.ia

     Ie-ar~.T.er.~ cf  £r.virtr.~er.~ al Resources (PACER),


                «'«:~'    ^   lr.     ~~           °" ~ ~* •   "
A<±nir.ist:ra-ive   Record  File   available   4/15/91,   update^
^- , ^i >*• / *•* ••
C / ^ C / 'i> i .

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REMEDIAL ENFCRCIMENT rlAMNIMG

1.    Administrative Order cy Consent In the Matter of:
     Avco Corporation site,  6/'2~/33.  ?. 200001-20001".

2.    letter to Ms.  Beverly F.  Doian, Textron,  Inc., fro~
     Mr.  Stechen R. Wassersug,  U.S. EPA, re: 104 (e)
     request" for inforr.aticn,  7/17/33.  ?. 200018-200026
     A certified receiot is attached.

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            "• ^ ~~ A J~."" ~ ~ ^  ™*^ MM .—• A /-< - a "

           i-n •'Feas ib i lity Stuay wcrk plan by EPA,

       ii_  letter frcm Environmental Resource

             tne wor.< clan is attached.
 Ls""~sr  ~3  !'1r.  Zucrsr.s 3sr.r.is  U.S. Z?A  frcn Mr. Lss
 H.  Trefsaer,  Tsxircr. Lyccrr.ir.g,  re: ERM's prepared
 preli.~ir.ary responses fcr Textron Lycorr.ir.g 10 E?A's
 ccr.r.er.ts  rr. t'r.e P.I/FS wor< clar.,  2/2/39.  ?. 200011
 Letter  to  Mr.  Eugene Cer.r.is,  U.S. EPA, from Mr.
 Richard T.  Wroblews
-------
9.   Letter to Mr.  Lee H,  Trefsger,  Textron  Lvcoming,
     from Mr.  Eugene Dennis,  U.S.  EPA,  re:   Additional
     comments  on the RI/?S work plan,  6/13/39.
     P.  200579-300551.

10.  Report:   Remedial Investigation Site Operations
     Plan,  crepared bv ERM,  Inc.,  7/12/89.   P.  300532-
     300623.

11.  Letter to Mr.  Lee H.  Trefsger,  Textron  Lvcoming,
     from,Mr.  Eugene Dennis,  U.S.  EPA,  re:   EPA's
     conditional acprcvai  for the  revised RI/FS work
     plan,  7/25/39"."  P.  300624-300624.

12.  Letter to Mr.  Eugene  Dennis,  U.S.  EPA,  from Mr.
     Larry S.  Newcomer,  PADER,  re:   Confirmation of
     change of PADER project  officers for the Textron
     Lycoming  site,  8/8/99.   P. 300625-300626.   A letter
     to  Mr.  Lee Trefsger of Textron Lycoming concerning
     the project officer change is  attached.

13.  Letter to'Mr.  Eugene  Dennis,  U.S.  EPA,  from Mr.
     Randy Farmerie,  re:  A completed review of the
     second revision of the RI/FS  work plan  and the
     Remedial  Investigation. Site Operation Plan (RISOP),
     8/15/89.   P.  300627-300627.

14.  Letter to Mr.  Lee H.  Trefsger,  Textron  Lycoming,
     from Mr.  Eugene Dennis,  U.S.  EPA,  re:  Final
     approval  of the revised RI/FS  work plan, 8/15/89.
     P.  300628-300628.

15.  Report:   Draft Remedial Investigation Report,  Volume
     I,  prepared by ERM, Inc.,  1/15/91.  P.  300629-
     300964K.   A letter regarding  the report is attached.

16.  Report:   Draft Remedial Investigation Report,  Volume
     II  Appendices,  prepared by by  ERM, Inc., 1/15/91.
     P.  300965-301863.

17.  Report:   Draft Remedial Investigation Report,  Volume
     III Appendices,  prepared by ERM, Inc.,1/15/91.
    •P.  301864-302539.
    I

18.  Letter to Mr.  Eugene  Dennis,  U.S. EPA,  from Mr.
     Randy Farmerie,  PADER,  re:  Comments on the draft
     Remedial  Investigation report, 2/12/91.  P. 302540-
     302540.

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^ . .  _~tter ~.~ Mr. _ee .rersger, .extron Lvcoming, rrom
     :-'r.  Eugene Zennis, U.S. EPA, re:  Comments regarii:
     the review of the draft Ris< Assessment reoort,


21.  Letter to Mr. E u — e n e Zer. r. is/  *.S. ~ - A,
                     evera  we
22.  le""~er i^ Mr. Ise Tr05s^er  Tex^rcn L,'/corr;r.G   ^**^m
     Mr.  Euger.e Zer.r.is, U.S. EPA, re:  Ccrr.ment:s on  the
     craf" Re.T.edial Ir.ves'igaticr. ar.d Risk Assessment cv
     PACER, 2/7/31.  ?. 302556-302553.  A facsimile
     " rar.srr. is s ion cover letter is attached.

22.  P.eccrt:   3raft Ris< Assessment Report,  prepared bv
     Textron  lycoming, 1/21/31.  ?.' 2C2259-30312 1 .  A
     transmittal cover letter is attached.

24.  Report:   Draft Feasibility Study Report,  prepared c\
     Textron  Lycoming, 3/15/91.  P. 203122-303343*.  A
     transmittal cover letter is attached.

25.  Letter to Mr. Eugene Dennis, U.S. EPA,  from  Mr.
     Randy Farmerie,  PADER,  re:  Comments to  the  draft
     Feasibility Study, 3/27/91.  ?.  303349-303350.

26.  Letter to Mr. Lee Trefsger, Textron Lycoming,  from
     Mr.  Eugene Dennis, U.S. EPA, re:  Comments from the
     EPA on the draft Feasibility Study, 3/27/91.
     P.  303351-303353.

27.  Letter to Mr. Eugene Dennis, U.S. EPA,  from  Mr.
     Richard  T. Wroblewsici and Mr. Charles Bandoian, ERM,
     Inc., re:  Transmittal of responses to  comments on
     the draft Remedial Investigation, Risk  Assessment
     ,and Feasibility Study reports, 4/10/90.   P.  303354-
     '303419.   The responses are attached.

29.  U.S. EPA Proposed Plan, AVCO Lycoming Site,  4/91.
     P.  303420-303435.  A memorandum  and corrected  pages
     are attached.

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29.  Letter to Mr. Eugene Der.r.is, U.S. E?A,  from Mr.
     Richard T. Wrobiewski and Dr. Charles A.  3randoiar.,
     Enviror.rr.er.tal Resources Management,  Inc.,  re:
     Further off-site ground water recovery,  5/1/91.
     ?. 202435-303446.  A letter regarding comments on
     the Proposed Plan is attached.

30.  letter to Mr. Eugene Dennis, U.S. EPA,  from Mr.
     Richard T. Wrobiewski,  Environmental Resources
     Management,  Inc., re:  Textror./ERM (Environmental
     Resources Management, Inc.)  presentation to FADER
     (Pennsylvania Department of Environmental
     Resources)/EPA,  5/10/91.  P. 303447-303451.  A
     summary of the Textror./ERM presentation is attached.

31.  Letter to Mr. Eugene Dennis, U.S. EPA,  from Mr.
     Richard T. Wrobiewski,  Environmental Resources
     Management,  Inc., re: Correspondence to be
     considered as comments on the Proposed Plan,
     5/14/91.   P. 303452-303453.

32.  Letter to Mr. Eugene Dennis, U.S. EPA,  from Mr.
     James M.  Luppert, Williamsport Municipal Water
     Authority, re:  Comments on the Proposed Plan,
     5/14/91.   P. 303454-303456.

33.  Letter to Mr. Eugene Dennis, U.S. EPA,  from Mr.
     Richard T. Wroblewski and Dr. Charles A. Bandoian,
     Environmental Resources management,  Inc.,  re:
     Summary of Textron Lycoming's position regarding the
     planned remedial action, 5/16/91.  P. 303457-303459.

34. -Letter to Mr. Eugene Dennis, U.S. EPA,  from Mr.
     Richard T. Wroblewski and Dr. Charles A. Bandoian,
     Environmental Resources Management,  Inc.,  re:
     Williamsport Municipal Water Authority's  (WMWA)
     comments  on the Proposed Plan,  5/16/91.  P. 303460-
     303462.

35.  Report:  Independent Cost Estimate of Remedial
     Action (CORA), 6/25/91.

36.  Letter to Mr. Edwin B.  Erickson,  U.S. EPA,  from Mr.
    ,A. Paul Franklin, PADER, re:  State concurrence with
    'the U.S.  EPA's proposed remedy, 6/28/91.

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lues

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       BIBLIOGRAPHY OF SITE SPECIFIC GUIDANCE DOCUMENTS

Risk Assessment Guidance for Superfur.d, Volume 1,  Human
Health Evaluation Manual (Part A), Interim Final,  prepared bv
U.S. I?A, 12/39.
EPA 540  1-39 002.

Ground-Water Protection Strategy, prepared by Office of
Ground-Water Protection, August  1, 1934.
EPA-440/6-34-002

Guidelines for Ground-Water Classification Under the
EPA Ground-water Protection Strategy, prepared by Office
of Ground-Water Protection, December 1, 1986.

CERCLA Corr.pliance with Other Environmental Statutes,
prepared by J.W. Porter, OSWER,  October 2, 1935.
OSWER #9234.0-2
Attachments:  Potentially Applicable or Relevant and
              Appropriate Requirements

RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document  (T£CD~(Secondary^Reference),prepared
by EPA,  September 1, 1986.
OSWER #9950.1

Final Guidance for the Coordination of ATSDR Health
Assessment Activities with the Superfund  Remedial
Process, prepared by J.W. Porter, OSWER/OERR and ATSDR, May
14, 1987.
OSWER #9285.4-02
Attachment:  Same Title, Dated 4/22/87.

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     .e i - :   .-. - r c cr.e ,  .-.rser.i_,  -
                                      ica- rrcri.es)
                                 sees ccs, Bariu.r.,  Benzene,
  er.z- < A; Pyrer.e,  3 = ±r.iu~,  Career. Teirachlcr ide,  Chlcrcber.zer.e,


                                        er,  C res els,  Cyanide,
                  echar.e ,  1 , 2-C ichlcrcechyler.e ;  Volurr.e 29:
                  er.e,  1, 2-C ich lor ce chyle r.e,  CIS-1, 2-
Hexacr.lorccer.zer.e, r.exacr.lcrcbucaciier.e ,
H e x a c rt 1 c r o c v c 1 c c e r*. ™ a ci i a r. e   H e x a v a 1 e r. c C h r -T* ; u *">   "" ** o n ( a **. d
ccr.pcur.as),  lead Lir.dar.e,  Magar.ese (ar.d ccrr;pcur.ds ) ,  Mercury,
Mecr.vl Zir.'/l Keicr.e, rr.eir. vler. e Cr.lc-ride, N'accr.aler.e, N'ic^>.v  \ . . . * . O y ^  - y_v..*~,  ^- C — ^ . 4 *, «, * . I  \ d * * ^*  t— -™/
3yar..de,  Sulfuric  Acid,  2 , 2 , ^ , 5-Tet racr.lcrcdiber.zc-p-Dioxiri,
1, 1, 2 , 2-Tetrac." Icrcecr.ar.e,  Tecrachloroechyler.e,  Toluene,
1 , 1 , 2-7ncr.lcrce~r.ar.e,  1, 1, 1-Trichlorce'har.e
Tricr.lcrcetir.yler.e,  2 , 4 , 5-Tr ichlorophenol ,  2,4,6-
Tricr.lorcpr.er.ol,   Trivalent:  Chromiun, Vinyl  Chloride, Xylene,
Zinc  (and ccr.pounds),  prepared by ORD/OHEA/ZCAO and
GSWER/CE?.?.,  Septie.r.ber 1,  1934.
EPA- 5 4 0 / 1 - 3 6 / GO 1 -C 5 8

Integrated Risk Inf orma -ion Systems (IRIS)  (A
Ccr.puter-3ased Risk  Ir.f crrr.atiiGn Sysrem
Available Through  E-Mail--3rochure on Access is
Included) ,  prepared  by  CKEA,  (undated) .

HEAST  Tables - Health Assessment Summary Tables.

Superfund Exposure  Assessment Manual, prepared by OERR,
April  1,  1993.
OSWER  #9285.5-1

Superfund Public  Health  Evaluation Manual,  prepared by  OERR
and OSWER,  October  1,  1986.
OSWER  #9285.4-1
                                •s,  r
Endar.g.erment "Assessment  Guidanae,  (Secondary Reference) ,
prepared  by. J:W.  Porter,  OSWER, November 22, 195.
OSWER  #9850.0-1

ATSSR  Tox*icity' Profiles,  ATSDR/TP-88/xxx .

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