United St?»es Office of
Environmental Protection ' Emergency and
Agency . Remedial Response
EPA/ROD/R03-90/100
September 1990
EPA Superfund
Record of Decision
Raymark, PA
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50272-101
REPORT DOCUMENTATION 11. REPORTNO. 12.
. PAGE EPA/ROD/R03~90/100
3. Recipienh Acceulon No.
4. TIlle 8nd Sl.t»tltIe
SUPERFUND RECORD OF DECISION
Raymark, PA
First Remedial Action
7. Aulhor(e)
5. Report Date
09/28/90
6.
8. "-'forming Organlzetlon Rept. No.
I. Pwformlng Org8InIze1Ion Name and Add....
10.' l'tojectlTuklWorIt UnIt No.
11. ConIract(C) or Gr8nt(G) No.
(C)
(G)
12. 8pon8orIng Org8JUatlon Name and Addreu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . PerIod Cowrec:l
Agency
.
800/000
14.
15. Supplementary No..
16. Ab81rac:t(Umlt:200_rde)
The 7-acre Raymark site .is an active metal manufacturing and electroplating plant in the
Borough of Hatboro, Montgomery County, Pennsylvania. The site is in an industrial area
and is approximately 100 feet from the nearest residence. The nearest surface water is
Pennypack Creek, which flows 4,000 feet southwest of the site. As part of the rivet
manufacturing process at the plant, VOCs, including 30 to 40 gallons of TCE, were used
iaily at the site to clean and degrease metal parts. In 1979, when EPA discovered TCE
in the Hatboro public water supply wells, the Hatboro Borough Water Authority removed
these wells from operation, and supplemented .the water supply using an interconnection
with a neighboring water company. Further EPA site investigations from 1980 to 1987
identified TCE in soil and other wells onsite and adjacent to the property and seem to
indicate that contaminants from the site may have been at least a contributing source of
contamination in the downgradient public water supply wells. Other chemical
contaminants identified in samples from the public water supply wells, including TCA,
did not seem to originate at the site, thus indicating several distinct sources for this
contamination. In 1987, the site owners agreed to install ground water treatment units
with air stripping towers, and, as necessary, air emission control uni~s, at two Hatboro
(See Attached Page)
17. Doa8MntAn8ly8la .. DMcrIpIo..
Record of Decision - Rayroark, PA
First Remedial Action
Contaminated Medium: gw.
Key Contaminants: VOCs (TCE, PCE)
.
b. Iden1IIIer8ICpen.EndId T-
Co COSA 11 FI8IdIGroup
18. AVlllIabIIty St8I8ment
11. Sec:urIty CI- (thill Report)
None
20. Sec:urIty CI- (1hIe Page)
}Jnn~
21. No. of Pagee
170
22. PI'Iat
I
(See A~Z38.18)
See m.trucfI- on "--
(Formerly NT1S-35)
Department of Co-
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EPA/ROD/R03-90/100
Raymark, PA
First Remedial Action
d
Abstract (Continued)
"
public supply wells to return these to routine operation. This Record of Decision (ROD)
addresses contaminat~d drinking water and ground water, which are referred to as
Operable Units 2 and 3 (OU2 & OU3), respectively. The soil/source contamination (OU1), "
will be addressed in a subsequent ROD. The primary contaminants of concern affecting
th~ ground water are VOCs including TCE and PCE.
The selected remedial action for this site includes continuing the operation and
maintenance of the Hatboro public supply and the existing air stripping towers at the
wells and the installation of new vapor phase carbon adsorption units; completing a
ground water remedial design study to determine the number, location, and construction
of new extraction wells with corresponding installation and implementation; onsite
pumping and treatment of ground water with air stripping and vapor phase carbon
adsorption units with onsite discharge to Pennypack Creek; and implementing
institutional controls. The estimated present worth cost for this remedial action is
$2,700,000, which includes an annual O&M cost of $125,000.
'.
PERFORMANCE STANDARDS OR GOALS: The ground water will be remediated until contaminant
levels reach SDWA MCLs, non-zero MCLGs, or background levels, whichever are more
restrictive. The residual excess cancer risk resulting from site-related contamination
will be reduced to a 10-6 level and non-carcinogenic levels will be reduced to a Hazard.
Index = 1. Chemical-specific standards for ground water include TCE 5 ug/l (MCL) and
PCE 5 ug/l (proposed MCL). Additional still-undefined, aquifer contamination at the
site may ma~e it technically impracticable to attain these levels, and if so, an ARAR
~aiver will be enacted and the ROD amended.
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DECLARATION FOR THE RECORD OF DECISION
. .
SITE NAME AND LOCATION
Raymark site
Hatboro Borough, Montgomery County, Pennsylvania
Operable Units 2 and 3
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for Operable units 2 and 3 for the Raymark Site (Site),
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended, and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This action is based on the Administrative Record. file for the
Site.
'.
The Commonwealth of Pennsylvania concurs with the selected
remedy. A copy of the letter of concurrence is. contained within
Appendix E of this ROD~ .
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. 9 9606, that actual
or threatened releases of hazardous substances from this Site, as
discussed. in "Summary of Site Risks", Section VI, if not
addressed by implementing the response actions selected in this
ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
Operable units 2 and 3 are the second and third of three operable
units for the Site. Operable Units 2 and 3 address contaminated
drinking water and ground water which are the principal threats
posed by the site. The selected remedy provides clean drinking
water for the public and protection from further site-related
ground water contamination. Operable Unit 1 will address the
area of soil co~tam~nation at the Site.
The major components of the selected remedy include:
1.
Completion of a ground water remedial design study to
determine the most efficient design of a ground water
extraction and treatment system. .
2.
continued operation and maintenance of publie water
supply wells by the Hatboro Borough Water Authority.
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3.
4.
5.
6.
7.
8.
9.
10.
continued operation and maintenance of air' 'stripping
towers installed at contaminated public water supply
wells by the Hatboro Borough Water Authority.
Installation, operation, and maintenance of vapor phase
carbon adsorption units at public water supply wells
equipped with air stripping towers.
Installation, operatiQn, and maintenance of onsite
ground water extraction wells to remove contaminated
ground water from beneath the Site and to prevent
contaminants from migrating offsite.
Installation, operation, and maintenance of air
stripping treatment at onsite ground water extraction
wells to treat ground water to required levels. .
Installation, operation, and maintenance ,of vapor phase
carbon adsorption units on onsite air stripping towers.
Construction, operation, and maintenance of a pipeline
from the onsite ground water treatment plant to the
storm sewer system to discharge treated ground water
into the storm sewer system and then offsite to the
Pennypack Creek.
Periodic sampling of ground water and treated water
to ensure treatment components are effective and ground
water remediation is progressing towards the cleanup
goals. '
Institutional controls to ensure that the Hatboro Water
Authority continues to operate public water supply
wells equipped with treatment systems. '
STATUTORY DETERMINATIONS
This action is protective of human health and the environment
and complies with Federal and State requirements applicable or
relevant and appropriate to this action~ A waiver may be
considered for certain Federal and State applicable or relevant
and appropriate requirements that may not be met. In addition,
this action is cost-effective. It employs permanent solutions to
the maximum extent practicable and satisfies the statutory
preference for remedies that e~ploy.treatment that reduces
toxicity, mobility, or volume as a principal element.
. .
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Because the sele~ted remedy addresses contamination related only
to the Raymark Site, the cleanup goals may not be me~ within the
entire aquifer beneath Hatboro since other sources of
contamination to groun~ water beneath Hatboro have been
identified. ,The Commonwealth of Pennsylvania requires that
contaminated 'ground water be remediated to background levels
pursuant to 25 PA Code section 264.90 through 264.100. If
implementation of the selected remedy demonstrates 'in
corroboration with hydrogeological and chemical evidence that it
will be technically impracticab~ to achieve and maintain the
remediaton goals throughout the area of attainment, the EPA, in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative ground water goals.
'.
Because this remedy does not address the source of contamination,
hazardous substances would remain onsite. A five-year review,
required by section 121(c) of CERCLA, 42 U.S.C Section 9621(c),
will be conducted to ensure that the selected remedy continues to
provide adequate protection of human health and the environment.
A five-year review will apply to this action at least until
hazardous substances no longer remain onsite above health-based
levels. .
"
~~6'
Edwin B. Erickson
Regional Administrator
Region III
SEP 281990
Date
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SECTION
A.
B.
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
Table of Contents
for the
Decision Summary
INTRODUCTION
. . . . . . . . . . . . . . . . . . . . . . . . . . . .
PAGE
1
3
5
8
17
21
25
32
45
60
73
77
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - ADMINISTRATIVE RECORD INDEX
APPENDIX C -'SUMMARY OF ANALYTICAL DATA FOR onsite WELL PF-1
AND R-SERIES WELLS
APPENDIX D - SUMMARY OF ANALYTICAL DATA FOR HATBORO PUBLIC SUPPLY
WELLS
APPENDIX E - LETTER OF CONCURRENCE
. DEFINITIONS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SITE NAME, LOCATION, AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITY
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF OPERABLE UNITS 2 , 3
SUMMARY OF SITE CHARACTERISTICS
. . . . . . . . .
SUMMARY OF SITE RISKS
. . . . . . . . . . . . . . . . . . .
ALTERNATIVES
. . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMPARATIVE ANALYSIS OF ALTERNATIVES
SELECTED REMEDY
. . . . . . . . . . . . . . . . . . . . . . . . .
STATUTORY DETERMINATIONS FOR THE
SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . .
.'
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List of Figures
1. site Location Map
2. Site Map
3. Public Supply Well Locations
4. Monitoring Well Locations
5. Extent of Ground Water contamination
6. Water Level Hydrograph for Well PF-1
7. 'Geologic Cross section
List of Tables
statistical Summary of Analytical Data
Remedial Response Objectives
Results of Packer Testing at Well PF-1
Contaminants of Concern in Ground Water
Summary of Exposure Pathways
Exposure Assessment Assumptions
Cancer Potency Factor (CPFs) and Reference Doses (RfDs) for
contaminants of Concern
Off-Site No Action Scenario: Reasonable Maximum Exposure
Excess Lifetime Cancer Risks
Off-Site No Further Action Scenario: Reasonable Maximum
Exposure Excess Lifetime Cancer Risks
10. On-site Future Action Scenario: More Probable Exposure
Excess Lifetime Cancer Risks
11. On-Site Future Action Scenario: More Probable Exposure.
Excess Lifetime Cancer Risks
12. On-site N~ Action Scenario: Reasonable Maximum Exposure
Noncarcinogenic Exposure .
13. On-Site Future Action Scenario: Reasonable Maximum Exposure
Noncarcinogenic Effects .
14. Results of Initial and Secondary Screening of Applicable
Ground Water Remedial Technologies and Process Options
RaYmark Focused FS
15. Descriptions of Remedial Alternatives
16.' Alternative: Off-Site Pumping with Air Stripping Treatment
and Discharge to Water Supply
17. Alternative: On- and Off-Site Pumping with Air Stripping
Treatment and Discharge to Water Supply and Water Supply
System, Respectively
18. Alternative: On- and Off-site Pumping with Air Stripping
Treatment and Re-Injection and Discharge to Water Supply,
Respectively
19~ Applicable or Relevant and Appropriate Requirements (ARARs)
and To-Be-Considered (TBC) Requirements
20. RaYmark Superfund Site Summary of Estimated Costs
1.
2.
3.
4.
5.
6.
7.
8.
9.
,!
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A.
INTRODUCTION
The Raymark Site (Site) is located on jacksonville Road in the
Borough of Hatboro, Montgomery County, Pennsylvania. The Site,
which consists of approximately 7 acres of relatively flat land,
is located in' an industrial area. The Borough of Hatboro
(Hatboro) has a population of nearly 7600 people (U.S. Census
Bureau, 1980) and the site is located approximately 100 feet from
the nearest residence.
The Site has been the location ~f a metal fabrication shop since
1948 and is currently operated by Penn Fasteners, Inc. Solvent
containing trichloroethene (TCE), which is a hazardous substance
as defined in CERCLA section 101(14) 42 U.S.C. ~ 9601(14), was
historically used in the manufacturing process to clean and
degrease metal parts at the site. Volatile organic compounds
(VOCs), primarily TCE, have been detected by the USEPA at the
Site and in several public water supply wells operated by the
Hatboro Borough Water Authority. TCE was first discovered in
public supply wells in 1979. The site was placed on the National
Priorities List (NPL) in October 1989 making the Site eligible to
receive Superfund monies for cleanup.
The United States and Hatboro filed a complaint against past and
current owners and operators of the Raymark site in 1985. A
trial was conducted in 1987 which resulted in a settlement
between USEPA, Hatboro, and several defendants. The requirements
of the settlement, which include treatment at contaminated public
water supply wells, are contained in a Consent Decree entered by
and between USEPA, Hatboro, and several settling defendants. The
Consent Decree was judicially 'entered in February 1989.
To expedite remedial response at the Raymark Site and in an
effort to better manage the cleanup of the Site, USEPA divided
response actions into operable un~ts. The operable units are:
1. Operable Unit 1 (OU1) - Soil/Source Control
2. Operable Unit 2 (OU2) - Drinking Water Supply
3. Operable unit 3 (OU3) - Ground Water
This Record of Decision (ROD) addresses the response actions for
OU2 and OU3. This ROD selects a remedial alternative to pump and
treat contaminated-ground water at public water supply wells and
from an onsite location.
Typically a Remedial Investigation and Feasibility Study (RI/FS)
is performed at Superfund sites to characterize the nature and
extent of site-related contamination and to evaluate potential
,risks posed by a site and potential remedial alternatives.
Because the Raymark Site has a long history of environmental and
chemical characterization studies, an exhaustive RI for ground
water was not conducted. Instead, USEPA relied upon tqe results
1
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of several previous investigations to identify the nature and
. extent of groundwater contamination. USEPA utilized the results
of the previous investigations to assess risks posed' by
contaminated ground water and to develop potential remedial
alternatives for contaminated ground water. USEPA believes that
the results of the previous investigations adequately
characterizes the extent of contaminated ground water at the
site.
'.
Because the existing database contained information which enabled
USEPA to adequately assess risks posed only by contaminated
ground water and to develop remedial alternatives only for
contaminated ground water, the contaminated soil and bedrock at
the site will be addressed later as part of OU1. An RI/FS is
currently underway to identify the extent of soil and bedrock
(source) contamination at the Raymark site. In addition,
pennypack Creek will also be sampled to determine if Site-related
contaminants are impacting this surface water body. .
",
A pilot-scale soil treatability test is currently planned to be
initiated in the Fall of 1990 to evaluate the effectiveness of a
potential soil and weathered bedrock treatment alternative (soil
vapor extraction) for the Site. If the pilot-scale test is
successful, soil vapor extraction may be implemented as a full-
scale remedial alternative for the site. OU1 will address the
remedial response action for the source of contamination to
ground water oLce the RI/FS and treatability study is completed
and a ROD for OU1 is signed by USEPA. USEPA currently
anticipates completing the RI/FS and preparing. the ROD for OU1 in
the Fall of 1991.
To the maximum extent practicable, the remedy(ies) selected for
OU1 will be consistent and compatible with the remedies selected
for OU2 and OU3. USEPA believes that the remedies for OU2 and
OU3 selected in this ROD are flexible. enough to accommodate any
possible modifications required by the remedy to be selected for
OU1. In addition, USEPA believes that components of the remedies
selected for OU2 and OU3 would be necessary to efficiently
address the contaminated source area, e.g., components of OU2 or
OU3 would enhance remediation of the source area, if needed. For
example, the remedies implemented for OU2 and OU3 would lower the
water table at the Site, thus allowing the contaminants within
the soil and bedrock previously saturated by ground water to be
removed by the soil vapor extraction system.
This decision document presents the selected remedial action for
Operable Units 2 and 3 of the Raymark Site in Hatboro Borough,
Montgomery County, Pennsylvania, chosen in accordance with
CERCLA, as amended, and, to the extent practicable, the NCP. The
Administrative Record file for this Site and comments received by
USEPA during the public comment period for the Proposed Plan
provide the basis for USEPA's decision.
..,
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B.
DEFINITIONS
Hazard Ranking system (HRS) - A document which assigns a score
based on the relative degree of risk posed by each site. A score
of 28.5 places a site on the National Priorities List.
National Priorities List (NPL) - USEPA's list established under
section 105 of CERCLA, 42 U.S.C. section 9605, of the nation's
top priority hazardous waste si~s that are eligible to receive
federal money for response action under Superfund.
Superfund or CERCLA - The Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)~
This Act established a trust fund, known as the Superfund, to
investigate and clean up uncontrolled hazardous waste sites.
National oil and Hazardous Substances Contingency Plan (NCP) -
Contains the regulations that govern the Superfund program.
The NCP is codified at 40 C.F.R. Part 300, amended at 55 Fed.
Reg. 8666-8865 (March 8, 1990). .
Remedial Investigation (RI) - An investigation to determine the
nature and extent of contamination ata Superfund site and to
develop information to support the assessment of risks posed by a
site and the development of remedial alternatives.
Feasibility Study (FS) - A study which identifies and develops
remedial alternatives to address contamination at a Superfund
site.
Baseline Risk Assessment - an assessment of the risks posed by a
Superfund site if no remedial action were taken.
Proposed Plan - A document that predates the USEPA Record of
Decision which identifies the remedial alternative preferred by
EPA. EPA is required by Section 117(a) of CERCLA, 42 U.S.C.
Sec~ion 9617(a), to prepare a Proposed Plan for public comment
describing EPA's preferred remedial action at a Superfund site.
Administrative Record file - A compilation of documents, required
by section 113 of CERCLA, 42 U.S.C. Section 9613, which USEPA
relied upon in its selection of a remedy.
Maximum Contaminant Level (MCL) - The maximum amount of
contaminant allowable in public drinking water to minimize or
eliminate dangerous health effects under the provisions of the
Safe Drinking Water Act, 40 C.F.R. sections 141.11 through
141.;16.
"
3
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Applicable or Relevant and Appropriate Requirements (ARARs) -
Requirements of federal and state environmental law~ which
(unless a statutory waiver is appropriate) should be'met by the
remedial actions selected for a Superfund site as required by
Section 121 of CERCLA, 42 U.S.C. Section 9621.
Cancer Risk of 1X10.6 - Chance of one (1) excess person in one
million (1,000,000) people contracting cancer from their exposure
to contaminants from a Superfund site.
Information Repository - A loca~ion near a Superfund site which
contains the documents generated by USEPA during the course of a
RI/FS and response action. The information repository also
contains the Administrative Record file.
Part per billion (ppb) - One in one billion. By convention ppb
is also expressed as ug/l (aqueous media) or ug/kg (solid media).
Volatile organic Compound (VOC) - A group of organic compounds
characterized by their greater tendency to change to a gaseous
state at room temperature and pressure.
[
I
I .
I
I
Record of Decision (ROD) - A formal decision document which
discusses the selected remedial alternative for a Superfund site
and describes the rationale for making that selection. Once the
ROD is signed the design of the remedy can begin.
Responsiveness Summary - A part of the ROD which contains a
summary of public comments on the remedial alternatives for a
particular site and USEPA's response to those comments.
Land Disposal Restrictions (LDRs) - provisions restricting the
land disposal of hazardous wastes identified under the Resource
Conservation and Recovery Act (RCRA), as amended, and codified at
40 C.F.R. Part 268.
, .
4
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I. Site Name, Location, and Description
The Raymark Superfund Site (Raymark Site or Site) is "located on
Jacksonville Road in Hatboro Borough, Montgomery County,
Pennsylvania (Figure 1). Hatboro Borough (Hatboro) had a
population of'nearly 7600 in 1980 (U.S. Census Bureau, 1980).
The site is located at the perimeter of an industrial area
approximately 100 feet from the nearest residence.
The area surrounding the Site is zoned primarily for industrial
use. However, residential area& are located within one quarter
mile east, west, north and south of the Site.
The Site is located on approximately 7 acres of relatively flat
ground. The nearest surface water body is the Pennypack Creek
which flows generally northwest to southeast through Hatboro.
The Pennypack Creek is approximately 4000 feet southwest of the
site (see Figure 1). A small tributary to the Pennypack Creek
flows generally from north to south through Hatboro. The site is
not located within the floodplain of Pennypack Creek. The .
Pennypack Creek is used for recreation; several park areas are
located along its banks. Several buildings of potential
historical significance were identified in Hatboro, but none were
on or near the site itself. No historic or archeological
properties near the site are eligible for or listed on the
National Register of Historic Places.
The residents of Hatboro rely upon ground water within the
Stockton Formation beneath the Borough for their drinking water
supply. The Stockton Formation consists of interbedded
sandstones, siltstones, and shales which imperfectly separate the
Stockton Formation into several different aquifers. For example,
at least three separate water-producing zones have been
identified beneath the Raymark Site, but the fractured nature of
the bedrock may allow the zones to be connected. The public
water supply is operated by the Hatboro Borough Water Authority
which currently pumps ground water from 12 large capacity wells.
The Authority ,owns 16 supply wells which are identified on Figure
3 in section II, "Site History and Enforcement Activity", of this
ROD. The Stockton Formation is one of the most important
aquifers in southeastern Pennsylvania. The Formation contains
the water supply for more than 920,000 residents.
The site consists of a manufacturing building, which also
contains office space, and a waste water treatment building,
which was historically used to treat electroplating wastes. A
metal cleaningjdegreasing operation is located in the rear (east)
section of the manufacturing building and a solvent storage tank
was historically located immediately outside this area. A septic
tank is located near the waste water treatment building. Four
small lagoons were located in the rear of the property, but were
removed in the early 1970's (Figure 2).
5
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PENNSYLVANIA
7.5 MINUTE SERIES (TOPOGRAPHIC)
I
1 MlU
1000
1000
2000 3000 «000 MOO MOO 7000
r-
QUADRANGLE LOCATION
Figure 1.
SITE LOCATION MAP
N
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JAOCSONVLL.E
. ROAD
\
AVENUE
@ 5TORM SEWE~
FIGURE 2
SITE MAP
"\
WOOD STREET
UNPAVED
= ANGLE BORINGS
= STRA I GHT BOR: " ~ S
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'1- --
II.
site History 'and Enforcement Activity
"
Metal fabrication operations, including rivet manufacturing and
electroplating, began at the site in 1948. The Milford Rivet &
Machine Company, under two separate ownerships, operated the
facility from 1948 to 1969 (Milford I) and from 1969 to 1980
(Milford II). In 1982, the Milford Rivet & Machine Company
(Milford II) currently operating the Site, merged with RMFPC,
which changed its name to Raymark Formed Products, Inc.
Previously, Milford I had merge~ with Raybestos-Manhattan, Inc.,
which then merged into Raymark Industries, Inc. in June 1982.
Raymark entities ceased operations at the Site in 1980 when the
facility was sold to Penn Fasteners, Inc. which is the current
operator of the manufacturing facility on the site. The Site,
however, is called the Raymark site.
Manufacturing operations included the use of a degreasing unit
which utilized TCE to clean metal parts during the rivet
manufacturing process. After TCE and other volatile organic
compounds (VOCs) were discovered in public water supply wells in
1979, USEPA sent Toxic Substances Control Act (TSCA) subpoenas to
local industries requesting information on their use of TCE. In
response to the TSCA subpoena and on November 27, 1979, the then
current operator of the Raymark Site, Milford II, stated that it
used 30 to 40 gallons of TCE per day~
"
"
'.
A series of environmental samples collected in late 1979 and 1980
by USEPA, the Pennsylvania Department of Environmental Resources
(PADER), and Hatboro revealed the presence of TCE and several
other VOCs in 8 of 16 public supply wells pumping in 1979. TCE
was detected in Hatboro wells H1, H2, H3, H7, H12, H14, H16, and
H17 (Figure 3). Subsequent to the discovery of TCE and other
VOCs in the public supply wells, Hatboro Borough Water Authority
removed the affected wells from routine operation and began to
supplement its water needs from an interconnection with a
neighboring water company.
USEPA installed a monitoring well (identified as PF-1) on the
Raymark Site in 1981 as part of an effort to investigate regional
ground water contamination (refer to Figure 2). Ground water
samples collected from this well contained high concentrations of
TCE. The highest concentration of TCE detected in well PF-1 was
19,900 ug/l.
A pump test was conducted on well PF-1 in
test, ground water samples were collected
discharge. USEPA detected 37,000 ug/l of
the pumping began and over 4000 ug/l from
after pumping began.
19.82 . Dur ing the pu1!'P
from the pump
TCE in well PF-1 before
most samples collected
In 1983, USEPA sampled well PF-1 and detected 7600 ug/l'of TCE.
"
8
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v . yj I__
PENNSYLVANIA
7.5 MINUTE SERIES (TOPOGRAPHIC)
SCALE 1.24000
o
1000
1000
2000
3000 4QOQ MOO MOO
OL*DR»NGLE LOCATION
FIGURE 3 HATBORO PUBLIC SUPPLY
WELL LOCATIONS
IN
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In June 1983, USEPA conducted a Site Investigation for the
Raymark Site. The information collected was used to determine
the relative hazards posed by the Site, e.g., the type of
contaminants and routes of contaminant migration, in a subsequent
Hazard Ranking System (HRS) report. The HRS, completed in July
1983, calculated a score which portrayed the relative risks posed
by the Site according to available information. The Raymark site
scored 26.08 in 1983.
In the Fall of 1984, USEPA installed an additional 5 monitoring
wells (R-series) along the Southeastern Pennsylvania
Transportation Authority (SEPTA) railroad tracks located west of
the site (see Figure 4). These wells, well PF-1, and other
nearby monitoring wells or abandoned water supply wells, e.g.,
well MS-10 which is an abandoned water supply well located
immediately north of the Raymark Site, were sampled in October.
1984. High levels of TCE were detected in each well.
In March 1985, USEPA prepared a Focused Feasibility Study (FFS).',
Potential remedial alternatives for contaminated ground water at
the Raymark Site were developed and evaluated in the FFS. The
FFS was based upon data collected in October 1984 and previously
collected data. The wells sampled in October 1984 were sampled
again in November 1985. Again, high levels of TCE were detected
in the wells. "
Each time the monitoring wells on or near the Site were sampled,
high concentrations of TCE were detected in the wells. Other
VOCs, e.g., cis 1,2-dichloroethene (cis 1,2-DCE), which are
degradation products of TCE and hazardous substances as defined"
in CERCLA, were detected in the R-series wells and other wells,
but were detected infrequently in well PF-1. In addition,
contaminants, which are most likely unrelated to the Raymark
Site, e.g., 1,1,1-trichloroethane (TCA)~ have been identified in
monitoring wells located offsite.
The information obtained by USEPA by 1985 was sufficient for the
United States to file a CERCLA and RCRA complaint against Raymark
Industries, Inc., et. al., in accordance with Sections 104, 106,
and 107 of CERCLA, 42 U.S.C. Sections 9604, 9606, and 9607, and
section 7003 of RCRA, 42 U.S.C. Section 6973. The complaint was
filed by the United states Department of Justice (USDOJ) on
behalf of USEPA and requested reimbursement of USEPA's costs,
injunctive relief, and declaratory relief for future remedial
action and an "e"xtent of contamination" survey.
In May 1986, a new HRS score was calculated for the Raymark Site.
The new HRS used information collected since the 1983 HRS score
was calculated, e.g., revised population estimates and new
contaminant types and concentrations detected in the soil and
ground water. The 1986 HRS score was 53.47.
10
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~"'....~
~ ~
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I '.
~
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~a
~ ..T....
.
HATIOIIO W[LLS
.
MOtUTOIt\W" \Heu..:.
FIGCRE 4
LOCATION MA~'" "AYIIIIMK IITI.
NAT8CIIO _LLI AM) 'MItIMITP HII8HTI WILLS
"0' TO SCAL.I
. .
.
. -"c E".ICEItINQ
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In 1986 and 1987, USEPA prepared for trial stemming from the
complaint filed in 1985. .. In November 1986, USEPA conducted an
extensive inves~igation of the soils and bedrock at the Raymark
Site. USEPA's samples indicated that high levels of'TCE existed
in the soil and weathered bedrock at the Raymark Site. The
highest TCE concentration detected in a soil sample was 3,100,000
ug/kg (ppb) from location A3 (refer to piqure 2-for soil boring
locations). It is important to note, however, that the soil
sample was submerged in methanol, a solvent, before analysis.
Since all of the TCE that was in the soil would move into the
methanol, the analytical result-depicts the total concentration
of TCE in the sample and not necessarily the amount of TCE that
would leach to the water table or the amount that could be
remediated.
'.
In January 1987, the PF-1 well, the R-series of wells, and other
nearby monitoring wells were again sampled by USEPA. The sample
results indicated that high levels of TCE existed in well PF-1.
The data also indicated th~t high levels of TCE, degradation
products of TCE, e.g., cis 1,2-DCE, and other VOCs existed in th~
R-series of monitoring wells and other wells located near the
Site. -
The case was tried in the united states District Court for the
Eastern District of Pennsylvania in May 1987. Before a decision
was rendered, and in late 1988, a settlement was reached between
the United States (USEPA) (Plaintiff), Hatboro Borough Authority
(Plaintif~-Intervenor), and Raymark Industries, Inc., Raymark
Formed Products Company, Penn Fasteners, Inc. and two individual
Site owners (defendants). The terms of the settlement were
eventually embodied within a Consent Decree judicially entered in
February 1989. The Consent Decree obligated the defendants to
pay for treatment units to be installed at Hatboro wells #16 and
#2 (H16 and H2) respectively located along Earl Lane and
Montgomery Avenue in Hatboro (refer to Piqure 3).
The Consent Decree required Hatboro Borough Authority to
implement a work plan which was attached to the Consent Decree.
The work plan included tasks which would provide the necessary
information to properly design treatment units at public supply
. wells. Currently, Hatboro Borough Authority is performing the
remedial design components of the work plan.
Once the work plan is fully implemented, wells H16 and H2, which
are not currently operated by the Hatboro Borough Water
Authority, would be equipped with air stripping towers and could
be returned to routine operation. The air stripping towers would
reduce ground water contaminant levels below enforceable
standards under the Safe Drinking Water Act. The standards
(Maximum contaminant Levels or MCLs) are set at levels which
eliminate or reduce dangerous health effects from exposure to the
contaminants. For example, the MCL for TCE is 5 ug/l (ppb). In
1:
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addition, under the Consent Decree, air emissions controls may be
installed on the air stripping towers at wells H16 and H2 if the
risks posed by the air emissions present an unacceptable risk to
the nearby population as estimated by modelling.
The Hatboro Borough Water Authority has no current plans to
utilize the water pumped and treated at well H2. This well is
actually located in the Hatboro Borough Building. Thus, since
this well would be pumped under the terms of the Consent Decree,
well H2 would be operated solely to contribute to the restoration
of the contaminated ground watep system and to provide some
protection for other downgradient wells. .
USEPA currently believes, based upon data collected since the
Consent Decree was entered, that the objectives of pumping and
treating at well H2 would be better served at a location closer
to or on the Penn Fasteners, Inc. property. USEPA believes that
pumping and. treating closer to the actual source of contamination
would serve to reduce the spread of contaminants from the site
and reduce the time frame for remediation of the aquifer. USEPA
also believes that locating the well closer to the source area
would still provide protection to downgradient public supply
wells equivalent to pumping at location H2. Thus, USEPA is now
considering modifying the Consent Decree to change the location
of the pump and treat system from well H2 to a well near or on
the property of Penn Fasteners, Inc.
The Raymark Site was proposed on the NPL in June 1988 and
promulgated on the NPL in October 1989. USEPA prepared a work
plan to conduct a Remedial Investigation and Feasibility Study
(RI/FS) in January 1990. The RI/FS is now'in progress.
..
To simplify and expedite Remedial Action at the Site, EPA divided
the Site into three manageable components or operable units. The
three operable units are:
1. Operable Unit 1 (OU1) - soil/Source Control:
2. operable Unit 2 (OU2) - Drinking Water: and,
3. Operable Unit 3 (OU3) - Ground Water.
Limited ground water monitoring wells have already been installed
onsite during the source control RI/FS to determine the effects
of the contaminated soil on shallow and deep ground water. The
welles) remaining to be installed during the RI/FS will also
serve to collect additional information needed to design an
efficient groundwater pump and treat system, e.g.,
identification of specific water producing zones beneath the site
and their respective transmissivity (ability to transmit water).
USEPA did not specifically conduct a Remedial Investigation of
contaminated ground water at the Raymark site. Instead, USEPA
relied upon the results of several previous investigat~ons to
13
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characterize the nature and extent of ground water contamination
at the Raymark Site and therefore. substitutes this information
for the Remedial Investigation. The investigation reports upon
which USEPA relied to characterize the Raymark site are
specifically identified in the Administrative Record'file. These
reports are:'. '.
1. ReDort on Plasti-seal Monitorina Wells. Montaomerv
County. PA which describes the installation and
sampling of the Penn Fastener monitoring well (PF-1)
(USEPA, January 1981).
2. HYdroaeoloaic Field ReDort on Well DeveloDment &
SteD Test at the Ravmark site. Hatboro. PA which
describes the installation and testing of the R-series
of monitoring wells (GMC Associates, Inc. for USEPA,
September, 1984).
3. A Field TriD ReDort for Ravmark which describes
installation and testing of the R-series of monitoring
wells (NUS. Corp. for USEPA, February, 1985).
4. Soil SamDlina and Ground Water SamDlina ReDort which
contains the results of soil and ground water sampling
conducted in October, 1985 (NUS Corp. for USEPA,
January, 1986).
5. Contamination bY TrichloroethYlene of a Portion of
the Stockton Aauifer Under the Community of Hatboro.
PennsYlvania which summarizes the extent of the ground
water contamination (Dr. R. Giegengack for USEPA,
February, 1986).
6. Review and Recommendations for Future
Investiaations. Ravmark site which summarizes previous
soil sampling data and recommends additional
characterization work to be performed (Zenon
Environmental, Inc. for USEPA, September, 1986)
7. Results for Soil Borinas from Wells A2 and A3 at
Hatboro. PA which describes contaminant levels in soil
samples collected beneath the Raymark site in November,
1986 (Walter B. Satterthwaite Associates, Inc. for
USEPA, December, 1986). .
8. A Field TriD ReDort for Ravmark which describes
soil/bedrock sample collection activities of November,
1986 (NUS Corp. for USEPA, January, 1987). .
..
14
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9. A Field Trip Report for Ravmark which describes ground
water sample results from 10 monitoring wells located
on and near the Raymark site collected in January, 1987
(NUS Corp. for USEPA, March, 1987).
10. Draft Letter Report Data Screeninq For Ravmark
site. Hatboro. PA which provides a quality
assurance/quality control review and validation of
selected samples collected at the Raymark Site (CDM for
USEPA, May, 1987). . .
In addition, USEPA relied upon ground water sampling results from
activities which are not summarized in specific reports, but the
results of which are contained within the Administrative Record,
e.g., October 1984 sampling of ground water. wells near the Site,
USGS and USEPA geophysical and packer test investigations of
1989, and results of the water-level monitoring performed by
Hatboro Borough Water Authority during implementation of the
Consent Decree work plan. The results of the previous
investigations are sufficient to determine that the Raymark site
is a significant source of contamination to ground water pursuant
to NCP Section ~ 300.430(a) (2), as will be discussed in section
V, "Summary of site Characteristics", of this ROD. The results
of the previous investigations also provide sufficient
information to determine that sources other than Raymark have
contributed similar, as well as different, types of contaminants
to the ground water system.
USEPA conducted a baseline risk assessment for ground water in
June 1990. The document was still in draft status when it was
placed in the Administrative Record file. However, USEPA
believes that the draft risk assessment adequately assessed risks
posed by contaminated ground water at the Raymark Site.
Additional information about offsite risks, which result from
exposures to Site-related, and other, contaminants, was.
subsequently developed by USEPA and added to the Administrative
Record file on August 23, 1990. The newly developed information
did not modify the assessment of risk posed by contaminated
ground water at the Site, but provided a more detailed evaluation
of the offsite risks and also provided additional justification
for the calculated risk values, e.g., assumptions were provided.
The draft document. evaluated offsite risks from exposure to
ground water at public wells based upon sampling data for a nine
month period.
USEPA completed a Focused Feasibility Study (FFS) in June 1990.
The FFS evaluated alternatives to clean up contaminated ground
water. The FFS updated and expanded upon the FFS prepared by
USEPA in 1985 since the requirements for evaluating remedial
alternatives were modified by EPA in 1986 in the Superfund
Amendments and Reauthorization Act (SARA) amendment to ,CERCLA, or
15
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Superfund, making the 1985 FFS somewhat obsolete. The 1990 FFS
was still in draft status when it was placed in the
Administrative Record file. However, USEPA believes'. that the
draft FFS adequately developed and evaluated remedial
alternatives in accordance with the requirements of section 121
of CERCLA, as amended, 42 U.S.C. Section 9621, Which requires
that Superfund remedial actions comply with applicable or
relevant and appropriate requirements of all federal and state
environmental laws, and the NCP (40 C.F.R. Section
300.430(e)(9)(iii», which requires that each remedial
alternative be evaluated agains~ nine criteria. The draft FFS
required only editorial and grammatical revisions as well as
factual revisions which do not materially affect the selection of
the remedy. USEPA believes that the extent and quality of ground
water data collected between 1979 and 1989 are sufficient to
support the development and evaluation of remedial alternatives
for contaminated ground water.
'.
A Proposed Plan for OU2 and OU3, which described USEPA's
preferred alternative for remediating ground water and addressing
the contaminated drinking water, was released to the public on
August 15, 1990. The Proposed Plan described the remedy USEPA
preferred to implement for OU2 and OU3 as well as other remedial
alternatives and associated options. The remedy USEPA preferred
to implement included pump and treatment of contaminated ground
water at the public supply wells and from an onsite location. The
water would be treated by air stripping and discharged to the
public water system (from public supply wells) and to nearby
surface water (from the onsite location). Treatment of public
supply ¥ells is presently occurring. The emissions from the air
stripping towers would be controlled through the use of vapor
phase carbon adsorption units which collect the contaminants
before they would be vented into the atmosphere.
The Proposed Plan was sent to the information repository, Union
Library of Hatboro, on August 15, 1990. In addition, a minimum
30-day comment period was conducted from August 15, 1990 to
September 17, 1990, and a public meeting was held August 30, 1990
to provide the public with an opportunity to comment on the
remedial alternatives for OU2 and OU3.
In addition to the RaYmark Site, USEPA identified other suspected
sources which potentially caused contamination of the ground
water in the St~ckton Formation which is utilized by the Hatboro
Borough Water Authority. Thus, there is more than one source of
contamination to the public supply wells in Hatboro. The precise
limits of contamination originating from the RaYmark Site are
unknown and may be impossible to determine given the nature of
the aquifer, the existence. of many pumping wells, and the
. existence of multiple source areas. contamination within ground
water beneath the Penn Fastener, Inc. property originates from
the RaYmark site and upgradient sources. contaminatioq within
16
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the R-series of wells located west of Penn Fastener most likely
originates from the Raymark site and other sources.
The Fischer & Porter Company, located along County Line Road in
Warminster, Bucks County, pennsylvania, was identified as a .
source of TCE contamination to the stockton Formation and the
Hatboro public water supply system. In November 1984, USEPA and
Fischer & Porter Company entered into a Consent Decree which
obligated Fischer & Porter Company to pay for the installation,
operation and maintenance of air stripping towers on Hatboro
public supply wells #14 and #17_(H14 and H17) respectively
located along Linden Avenue and Windsor Avenue in Hatboro (refer
to Fiqure 3.
A statistical summary of ground water sampling results, based
upon information contained within APPEHDXX C and APPENDIX D, is
contained within Table 1. This table depicts the mean
concentration and the 95th percentile concentration of specific
contaminants detected in contaminated public supply wells (H-
series), and the R-series of wells.
'.
III. . Highlights of Community Participation
USEPA has several public participation requirements that are
defined dn Sections 113(k)(2)(B), 117(a), and 121(f) (1)(G) of
CERCLA, 42 U.S.C. Sections 9613(k) (2).(B), 9617(a), and
9621(f) (1) (G).
The Proposed Plan for OU2 and OU3 was released to the public on
August 15, 1990. The Proposed Plan defined a 30-day peripd
during which the public had the opportunity to comment on the
Proposed Plan and the remedial alternatives considered for OU2.
The 30-day public comment period defined in the Proposed Plan
started August 15, 1990 and ended'September 17, 1990.
The documents which USEPA utilized to develop, evaluate, and
select a remedial alternative for the RaYmark Site were sent to
the information repository, located at the Union Library of
Hatboro on August 15, 1990. The availability of these documents
was stated in the Proposed Plan. These documents make up the
Administrative Record file for the Site. The Administrative
Record is a compilation of documents, required by section 113 of
CERCLA, 42 V.S.C. Section 9613, which USEPA used to support the
selection of a remedy for the RaYmark Site. .
On August 15, 1990, USEPA published a notice of availability of
the Proposed Plan and Administrative Record file in two Hatboro
local newspapers; Todav'sScirit and the Montaomerv County
Record. .
The public was encouraged to review the Proposed Plan and
17
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Tobie J
Result.. 01 f:tatl!itlcal AnaIY!iI!!
Contaminant 01 Concern
Vinyl
TCE PCE I,I,I-TCA ds-l,l-nCF. trans-l,l-nCE Chloride
WeiLt 111,112, II.'
Numhcr or Dala Points 69 61 NA NA NA NA
Arilhmetic Mcan : 49.4 0.9 NA NA NA NA
Coerricicnl or Variation 1.70 1.27 NA NA NA NA
Gcomctric Mean 33.11 0.33 NA NA NA NA
Gcomctric Slandard Deviation 2.24 5.74 NA NA NA NA
95% Upper Confidcnce Limit 36.79 9.78 NA NA NA NA
Well II?
Numher or Dala Points 51 4,1 1.1 ND 'ND ND
Arithmetk Mean 13.96 1.17 n.25 ND ND ND
Codfic.:icnl or Varialion 4.55 1.08 74.77 ND ND ND
Geomctrk Mean 3.71 n.59 U..17 ND ND ND
Gcometric Standard Deviation 4.03 4.33 4.7U ND ND ND
95% Upper Cnnfidence Limit 10.33 7.71 8.1() ND' ND ND
Well 1112
Numher nr Data Points 24 2:\' ND ND ND ND'
. Arflhmelk Mean J.JI 0,53 ND ND ND
ND
Codfident or Varialion 0.74 1.82 ND ND ND ND
Gcometrk Mean 1.87 n,I2 ND ND ND ND
Geometric Siandard Devialion 5.49 6,13 ND ND ND ND
l.I'if~ l'rper lonridcncc Limit 10.89 10.20 ND ND ND ND
.'
"
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'Cable I
Results of Statistical Analysis
Contaminant of Concern
Vinyl
TCE PCE I,I,I-TCA cls-I,Z-DCE trans-I,Z-DCE Chloride
"'eU 1114
Number of Data Points 145 144 92 ND 96 10
Arithmctic Mean 291.10 2.30 2.83 ND 7.74 0.50
Coefficient of Variation' 0.49 6.01 2.13 ND 1.31 0.55
Geometric Mean 236.74 0.83 1.36 ND 5.95 0.44
Geometric Standard Deviation 2.55 2.59 3.04 ND 2.04 1.61
95% Upper Conndence Limit 240.93 5.10 6.36 ND 9.30 3.10
"'ell II US
Numher uf Data Puints 40 36 4 ND 'ND ND
Arithmetic Mean 30.91 4.00 2.00 ND ND ND
Cocrricicnt of Variation 0.60 1.79 1.01 ND ND ND
Gcomctric Mean 24.47 2.72 0.97 ND ND ND
Geometric Standard Deviation 2.49 2.00 4.77 ND. ND ND
95% Upper Conndence Limit 28.56 6.00 8.82 ND ND ND
WeU 1117
Numher uf Data Points 121 lit 45 ND ND 9
. Arithmetic Mean 273.30 6.20 2n.05 ND ND 0.19
Coefficient of Variation n.63 0.56 0.42 ND ND 0.60
Gcometric Mean 118.98 4.77 5.24 ND ND 0.1111
Geometric Standard Deviation 1.31 1.(J6 8.46 ND ND 2.45
...
'}""~ II ppt'r ('lInfidcnl'C 181.13 6.50 19.15 ND ND 4.n
. --.--.
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Tobie ,
Resulls 01 Statistical Analysis
Contaminant 01 Concern
Vinyl
TCE PCE I,I,I-TCA ds-I,l-DCE trans-I,l-DCE Chloride
Wells R I, RZ, RJ, R4, R5
Number of Data Points " 15 15 15 15 15 NA
Arithmetic Mean 2819 99 81 107 liS NA
Coefficient of Variation 1.1 0.9 1.2 1.1 1.0 NA
Geomelric Mean 1,323 SS 27 32 41 NA
GeomeUic Standard Deviation 4 4 6 8 7 NA
95% Upper Confidence Limit 1,330 61 36 45 S3 NA
All concentrations in uglL or ppb.
NA. Nul available. II is nol known whether compound was analyzed for.
ND - Nol detected.
,"
".
"
.'
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Administrative Record file and to submit comments on any remedial
alternative and USEPA's preferred remedial alternative. The
public was given additional opportunity to comment on the
Proposed Plan and Administrative Record file at a public meeting
held at the Hatboro Borough Building on August 30,1990. At this
meeting representatives from USEPA answered questions and
received comments about the site and the remedial alternatives
under consideration and the proposed remedy. Community concerns
with the selected remedy are contained within the Comparative
Analysis of Alternative's section of this ROD and the
Responsiveness Summary. A stenographic report of the public
meeting was prepared by USEPA. A response to the comments
received during the 30-day public comment period and the August
30, 1990 public meeting is included as part of this ROD in the
Responsiveness Summary (Appendix A).
The index for the Administrative Record, upon which this decision
document is based, is contained within Appendix B. This decision
document is also based upon comments contained within the .
stenographic report of the public meeting on August 30, 1990 and
other comments received by USEPA during the pUblic comment
period, which are included in the Site file maintained at USEPA's
offices in Philadelphia and will be added to Administrative
Record file.
- IV. Scope and Role of Operable units 2 and 3
To simplify and expedite Remedial Action at the Site, USEPA has
divided the Raymark site into three manageable components or
operable units. The three operable units are:
1. Operable unit 1 (OU1) - Soil/Source Control
2. Operable unit 2 (OU2) ~ Drinking Water Supply
3. Operable Unit 3 (OU3) - Ground Water
This Record of Decision (ROD) addresses OU2 and OU3. The ROD for
OU2 and OU3 addresses remediation of contaminated ground water
and addresses the drinking water supply affected by the Raymark
Site. Figure 5 depicts the approximate extent of ground water
contamination defined by previous USEPA investigations.
Contaminants within the plume of contaminated ground water may
also originate from sources other than the Raymark site.
Contaminated ground water migrates from the Site towards public
supply wells generally located west of the Site. The
concentrations of contaminants in the ground water are well above
appropriate federal standards such as the Maximum Contaminant
Levels (MCLs) which are enforceable, health-based drinking water
standards under the Safe Drinking Water Act. For example, the
MCL for TCE is 5 ug/l (5 ppb). The concentrations of
contaminants in the affected public supply wells are also above
the MCLs, but the affected wells are equipped with, or will be
'.
21
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HATBORO QUADRANGLE
PENNSYLVANIA
7-5 MINUTE SERIES (TOPOGRAPHIC)
SCALE 1 24000
o
1000
1000
2000 3000 4000 MOO
6000
7000 rcn
PENNSYLVANIA
J>
FIGURE 5 APPARENT EXTENT OF ICE
CONTAMINATION IN GROL'N:
WATER
-------
equipped with, air stripping towers which reduce the levels below
the MCL before distribution into the public water sy~tem.
The NCP (40 CFR Part 300.430) states that the general goal of the
remedy selection process is to select remedies that are
protective of. human health and the environment, that maintain
protection over time, and that minimize untreated waste. In
addition, Section 121 of CERCLA, 42 U.S.C. Section 9621, includes
general goals for remedial actions at all Superfund sites. The
goals include; aChieving a degree of cleanup which assures
protection of human health and the environment (Section 121(d)),
preference for selecting remedial actions in which treatment that
permanently and significantly reduces the volume, toxicity, or
mobility of contaminants is a principal element (Section 121(b)),
and requiring that the selected remedy comply with or attain the
level of any applicable or relevant and appropriate requirements
of federal or state environmental laws (Section 121(d) (2) (A)).
The Site-specific remedial response objectives, which take into ..
consideration the level of contamination and the risks posed by
the contamination, are identified in Table 2. The Site-specific
remedial response objectives are based on the baseline conditions
at the Site, e.g., the remedial response objectives assume that
no remedial action has taken place to date.
TABLE 2
SITE SPECIFIC REMEDIAL OBJECTIVES
FOR OPERABLE UNIT 2 AND OPERABLE UNIT 3
1. Protect public health and the environment
2. Reduce further migration of contaminated
ground water from the site towards public
supply wells
3. contain the contamination within the currently
affected area
4. Reduce the risk resulting from release of
contam~nants into the air from treatment
devices .
5. contribute to the restoration of the
aquifer to its beneficial use, and further to
background quality, if practicable
23
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In order to restore the aquifer to its beneficial use, the
remediation system implemented in each of the alternatives would
operate until Site-specific remediation goals are achieved. Thus
the aquifer would be remediated until the contaminate levels
reach the MCLs, Non-zero MCLGs, or background, whichever are
lower. . .
'.
If implementation of the selected remedy 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, the USEPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals.
USEPA believes that background levels, defined using upgradient
concentrations, may be higher than health-based levels due to the
presence of other source areas and regional TCE contamination.
Due to the existence of other sources of contamination near the '.
RaYmark Site, it may be technically impracticable to achieve the
cleanup goals until the other sources are addressed.
Ideally, USEPA would achieve cleanup goals within the Area of
Attainment (plume). However, the Area of Attainment includes
contaminants which originate from sources other than the Site.
Thus, it is unclear, but unlikely, that cleanup goals would be
achieved throughout the Area of Attainment until all sources of
contamination to the aquifer beneath Hatboro are addressed.
Because contaminants from the Site most likely mix with similar
contaminants from other sources within the aquifer, it would very
difficult, if not improbable to distinguish between contaminants
which originate from the Site and contaminants from other
sources.
Although the remedy selected in this ROD may. not achieve clean up
goals throughout the contaminated aquifer, the ground water
extraction and treatment components of the remedy could be used
to continue to pump and treat ground water to contribute to the
restoration of the aquifer. Once the Site no longer contributes
contaminants to the aquifer, the ground water pump and treat
components of the remedy would be used to remove contaminants
from the aquifer which have already migrated from the Site. In
addition, these components serve to contain the plume within its
current boundary..
The remedies selected in this ROD address each of these
objectives. To the maximum extent practicable, the remedy (ies)
selected for OUl will be consistent and compatible with the
remedies selected for OU2 and OU3. USEPA believes that the
remedies for OU2 and OU3 selected in this ROD are flexible enough
to accommodate any possible modifications that may be required by
the remedy selected for OUl. In addition, USEPA believ~~ that
24
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components of the remedies selected for OU2 and OU3 would be
necessary to efficiently address the contaminated source area,
e.g., components of OU2 or OU3 would enhance remediation of the
source area, if needed.
The RI/FS for" OU1 is scheduled to be completed in the Fall of
1991. At that time, USEPA will prepare a ROD which addresses
remediation of contaminated soil and bedrock as well as
environmental media, other than ground water, potentially
affected by the Site, e.g., surface water.
v.
Summary of Site Characteristics
All Hatboro residents connected into the public water supply
system, nearly 7500, could be potentially exposed to ground water
contaminated by the Raymark site. The approximate extent of
ground water contaminated by the Rayroark site and other sources
is depicted on Figure s. The vertical depth of contamination
related to the Raymark site is difficult to establish. Once
shallow ground water from beneath the Site moves deeper into the
aquifer, it may mix with ground water which may have already been
contaminated by sources other than the Raymark site. Once this
ground water moves offsite it may again mix with ground water
contaminated by other sources.
The complexity of the aquifer, i.e., the existence of several
water zones, extensive pumping at public wells, differential
weathering of bedrock, and fractured bedrock, makes it extremely
difficult to separate contamination and determine its source.
Thus, it may not be possible to track a "plume" from the Rayroark
site for significant distances beyond the Site's source areas.
However, since water level studies indicate that public wells
most likely pump ground water that originated beneath the Raymark
site (discussed in this section), USEPA has determined that the
Site is a source of contamination to Hatboro's public wells.
All residents within approximately 100 meters of an operating air
stripping tower could be potentially exposed to contaminated
emissions from the air strippers. currently Hatboro wells H12,
H14 and H17 are equipped with air stripping devices. Air
stripping towers are proposed for Hatboro wells H2 and H16.
Three areas of the Raymark site have been identified as sources
of TCE contamination to the ground water. These areas are: 1)
the lagoon area," 2) the sol vent storage tank area, and 3) the
degreaser area (refer to Pigure 2). The solvent tanks, which
were historically located outside the manufacturing building, are
adjacent to the area inside the manufacturing building where
degreasing operations occurred. Thus, the solvent storage tank
area and the degreasing area can be considered to be the same.
The results of the November, 1986 sampling of soil and bedrock
beneath the Site confirmed these source areas. The locations of
.'
25
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soil borings completed in. November, 1986 are depicted on Piqure
2.
The highest level of TCE identified in the soil was detected in a
sample collected from a soil boring which angled beneath the
manufacturing building in the degreasing area/solvent storage
tank area. The amount of TCE detected in this sample (identified
as 'A3-5'-7') was 3,100,000 ug/kg (ppb). It is important to note,
however, that the soil sample was submerged in methanol before
analysis. Since all of the TCE that was in the soil would then
move into the methanol, the anaLytical result depicts the total
(absolute) concentration of TCE in the sample and not necessarily
the amount of TCE that would leach to ground water or the amount
that could be remediated. At this time USEP~ is uncertain about
the amount of TCE that may have or could leach to ground water;
this data will be collected during the RI/FS for OU1. Elevated
levels of TCE were also identified in a sample collected from the
center of the four backfilled lagoons. In addition to TCE, other
VOCs and semivolatile organic compounds, including PCBs, were.
identified in the soil at low concentrations. Soil samples were
also analyzed for. metallic elements, but available results are of
little value since the samples were composited over several
intervals and did not include surface samples.
TCE was also identified in some of the bedrock samples collected
beneath the Raymark site. The detection of TCE in the bedrock'
indicates that TCE has migrated from the soil beneath the Raymark
Site down into the underlying bedrock. Since the ground water
table, which can be anywhere from 15 to 60 feet below the ground
surface at Raymark depending on the season and pumping status of
public water supply weils, is within the bedrock beneath the.
Site, and no protective layer, e.g., clay, exists between the
soil and ground water table, TCE has migrated into the ground
water system beneath the Site. In fact, high levels of TCE have
been detected in the monitoring well installed at the site (well
PF-1) .
TCE. in the unsaturated zone beneath the Raymark site migrates
downward with infiltrating precipitation. Although ~ome of the
contaminant may adsorb onto organic matter in the soil, some of
the contaminant migrates to the water table either dissolved in
infiltrating precipitation or as a free product. Once in ground
water, TCE moves w.ith local or regional ground water flow and may
flow offsite.
In 1989, USEPA, in cooperation with the united States Geological
Survey (USGS) conducted testing on well PF-1 which showed that
the TCE was coming from the Raymark Site. At least three water
zones were identified in well PF-1 and isolated using inflatable
rubber packers. When a packer is lowered to ~ predetermined
depth in the well and inflated, the ground water zones above and
below the packer are separated, although the ground water zones
'.
26
"
-------
may still be connected through 'fractures in the bedrock. After
the top zone was isolated"from the lower portion of the well, a
sample was collected from the ground water between 44 and 75
feet. The sample was analyzed and 11,000 ug/l (ppb) 'of TCE were
detected in the sample. When the middle and lower zones were
isolated and sampled, 500 ug/l and 1100 ug/l of TCE,
respectively,"were detected in each zone. The different zones
and the concentrations of TCE identified in each zone are
depicted in Table 3.
TABLE 3
RESULTS OF PACKER TESTING AT WELL PF-1
ZONE DEPTH TCE CONCENTRATION
1 44-75 11,000 ug/l
2 75-95 530 ug/l
3 125-150 1,100 ug/l
The analytical results indicate that the most contaminated ground
water beneath the Raymark Site is in the shallow zones. TCE
migrating through the soil column and through the fractures or
weathered areas of the Stockton Formation bedrock would enter the
ground water system at the water table, i.e., the most shallow
ground water zone. Since the shallow ground water zone at the
Raymark Site was contaminated at levels which were one to two
orders of magnitude higher than deeper zones, it follows that the
soil and unsaturated bedrock, i.e., bedrock above the water
table, is a source of TCE contamination to the ground water
within the Stockton Formation beneath the Site.
The packer tests conducted at well PF-1 indicate that the ground
water zones beneath the Site are imperfectly separated by zones
which do not produce water to the well. These zones most likely
preclude a significant amount of contaminant from migrating from
the shallo~ ground water zones into the deeper zones. The
analytical results from samples collected from discrete zones
within well PF-1 support this conclusion.
During the investigation of well PF-1 in 1989, USEPA also
determined that ground water in the well was not stagnant.
Ground water in the well continually flowed down the well and
then out into the Stockton Formation near the bottom of the well.
This internal well flow occurred even under ambient (non-pumping)
conditions. All identified ground water flow zones within a well
would theoretically produce, or contribute, water to the well
27
-------
when they were pumped. However, under non-pumping conditions
some zones contriQute water to the well which then flows out of
the well through other zones called thieving zones. ..This type of
internal well flow under ambient conditions is common within the
stockton Formation in wells that connect more than one water zone
such as well. .PF-l. This phenomenon would also explain the reason
that TCE concentrations in the lower zone were higher than levels
in. the middle zone. Conceptually, TCE from the upper
contaminated ground water zone flows down the well, bypasses the
middle zone, which produces water to the well, and then out of
the well in the lower zone which removes water.
Contaminated ground water at the Raymark site flows towards
Hatboro's pUblic water supply wells. A water-level monitoring
study completed in 1987 demonstrated that Hatboro public water.
supply wells #2 and #14 (H2 and H14) lowered the water table
beneath the Raymark site during their operation (Fiqure 6).
Ground water flows preferentially through fractures and zones of
weathered bedrock. The results of investigations completed at
the site, e.g., USGS, 1989, indicate that ground water moves off-'
the site at approximate depths of 125 to 150 feet in a high yield
flow zone. This zone correlates with a thick sandstone unit and
a thieving zone within well PF-l.
The contaminant detected most frequently and at the highest
concentrations onsite in weIIPF-l, located on the property of
Penn Fasteners, Inc., is TCE. TCE is a volatile organic compound
which USEPA considers to be a class B2 probable human carcinogen.
The classification means that animal, and not human, data were
used to determine that TCE is carcinogenic. TCE tends to
breakdown or degrade over time into other VOCs including cis 1,2-
dichloroethene (cis 1,2-DCE), trans 1,2-dichloroethene (trans
'1,2-DCE), l,l-dichloroethene (l,l-DCE) which is a Class C,
possible human carcinogen, and vinyl chloride (VC) which is a
Class A, known human carcinogen. cis 1,2-DCE and trans 1,2 DCE
were also identified in well PF-l. .
One sample collected from well PF-l contained elevated levels of
lead (47 ug/l), but an additional sample collected the same day
contained no detectable lead. No other metals were detected in
ground water from well PF-1 at levels of concern.
TCE was also the compound which was detected most frequently and
at the highest concentrations in the R-series of monitoring wells
and other monitoring wells located offsite.. However, many other
VOCs, which do not appear to be related to the Raymark site were
also identified in these monitoring wells. Specifically, (TCA),
1,1,2-trichloroethane (1,1,2-TCA), 1,1-DCA, carbon tetrachloride,
tetrachloroethene (Perchloroethene) (PCE), and chloroform were
detected in the R-series of monitoring wells and other nearby
monitoring wells.
28
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An abandoned water well', (MS-I0) located near the Penn Fasteners,
Inc. property contained high concentrations of leaq (513 ug/l)
and barium (2,290 ug/l). The source of the elevated inorganic
constituents in this well is unknown.
TCE was als'o the compound which was detected m6s~ frequently and
at the highest concentrations in the public supply wells located
offsite. However, TCA, t-butyl methyl ether, and benzene, which
may not be related to the Raymark Site were also detected in the
public water supply wells.
Upon review of the sampling data, consideration of the
industrialized nature of the area, and the identification of at
least one other source of contamination to ground water and other
suspected source areas within the Stockton Formation, it is
apparent to USEPA that sources other than the Raymark Site have
contributed to the contamination of Hatboro's public water supply
system. In fact, TCE, which is a Site-related contaminant, also
comes from other sources within the immediate area, e.g., Fischer
& Porter Company. .
'.
The bedrock beneath the Raymark Site consists of fractured
sandstones, siltstones, and shales of the Stockton Formation.
Figure 7 is a geologic cross section depicting the types of rock
found beneath the Raymark Site. A fracture can be considered to
be any linear break in the rock. Ground water moves
predominantly through the fracture system and through areas of
bedrock in which the matrix which holds the individual minerals
together, has weathered or dissolved leaving a large amount of
intergranular pore spaces through which ground water may flow.
Therefore, public supply wells penetrating the same fractures,
fracture systems, or weathered zones containing ground water
contaminated from the Raymark Site may themselves become
contaminated.
During the previous investigations, several ground water
monitoring wells were installed at and near the Raymark Site
(refer to Figures 2 and 4). The main objective of installing
monitoring wells was to determine the extent of ground water
contamination from the Raymark Site. The results of ground water
sampling during the previous USEPA investigations indicate that
the area of ground water contamination includes the Raymark Site
and Hatboro public supply wells HI, H2, H3, H7, H9, H12, H14,
H16, and H17. The area is nearly 1.5 square miles and includes
approximately 4.9 billion gallons of contaminated ground water
(Figure 5).
A tributary to Pennypack Creek runs from north to south through
Hatboro adjacent to public supply wells H16, H17, H7, H14 and H12
(see Figure 1). The plume of contaminated ground water would
most likely discharge to this tributary to Pennypack Creek if the
public supply wells were not pumping. However, when the public
30
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Waste Treatment
Bu
X
Lagoons
i
N
I
Solvent
Tank Storage ATM
ShaJe and alttatona
tal Fine sandstone
A1 Boring location
PF1 Monitoring wan
Sourc*: A lUioetfttigrapfcy/tiydrogaologlc analysis of the
Stockton Formation naar Hatboro, Montgomery County, PA.
Meha*4 Taylor Towie, 1007.
i
F1I
Vartlcal/ Horizontal
Sea*: Feet
10 30 50
Rgura 7
LTTHOSTRATIGRAPHY OF THE
MIDDLE ARKOSE MEMBER OF THE
STOCKTON FORMATION NEAR
MONITORING WELL PF-1
RAYMARK FOCUSED FS
-------
1-
supply wells are pumping,.. the water table is lowered well below
Creek level, evidenced by periodic dry reaches near operating
wells in summer months and the deep pumping level of.. the public
supply wells. Therefore, contaminated ground water would not
discharge to the Creek. Since the public supply wells are
frequently operated, it is unlikely that a significant amount of
contaminated ground water would discharge to the Pennypack Creek
or .flow beneath it.
'.
The bed and banks of the Pennypack Creek contain jurisdictional
wetland areas. obligate and faQUltative wetland species were
identified by USEPA in the Pennypack Creek bed and immediate
floodplain. The majority of the wetland areas were located
downstream (south) of Hatboro since the streams run primarily
through residential yards, commercial properties, and/or
developed park areas within the Borough. No wetland areas were
identified on or near .the site. .
VI.
Summary of Site Risks
Contaminants from the Site migrate towards public water supply
wells through the ground water system. Potentially, all users of
Hatboro's public water supply system, approximately 7500 people,
could be thus be exposed to Site-related contaminants.
contaminated ground water may discharge to the Pennypack Creek
when certain public wells (H7 and H14) are not pumping for
extended time periods.
A baseline risk assessment was conducted by USEPA which.
quantified the risks posed by contaminated ground water beneath
Hatboro if no response action were taken to address Site-related
contamination. The focus of the risk assessment was to determine
human health effects that could result from exposure to the
contaminants of concern in the ground water associated with the
Site.
contaminants which: 1) present a potential.risk to human health
and the .environment at the detected concentrations; 2) originated
from the RaYmark site or could have originated from the Raymark
Site, e.g., degradation products of TCE; and 3) were above
background levels (assumed zero), are considered to be
contaminants of concern for the RaYmark Site. A contaminant
presents a potential risk to human health if its concentration
exceeds the 1xlO-6 (1 in 1,000,000) excess cancer risk level for
cancer-causing compounds or the maximum safe dose for non-cancer
effects. In other words, there is one extra chance in one
million of contracting cancer due to a lifetime of exposure to
Site contaminants at the 1x10-6 level. This risk exists in
addition to the risk posed by all other sources, e.g., a 30,000
3:
-------
chance out of 1,000,000 ~f contracting cancer from smoking.
. .
In addition, USEPA estimated the risk resulting from..exposure to
ground water from contaminated public wells (assuming no
treatment) and monitoring wells located beyond the property
boundary even. though the risk most likely results from exposure
to contaminants from multiple sources (including Raymark site).
The contaminants of concern in the ground water beneath Hatboro
are identified in Table 4. Contaminants in Table 4 identified by
an asterisk (*) were detected at least once in well PF-l and are
therefore considered to be contaminants of concern related to the
Site. Vinyl chloride, l,l-DCE, cis 1,2-DCE, and trans l,2-DCE
are potential degradation products of TCE. Although l,l-DCE and
vinyl chloride were not detected at the Site, they may be
considered to be contaminants of concern because they are
degradation products of TCE and have been detected in nearby
offsite wells. TCA, PCE, and carbon tetrachloride are not known
to be related to the Raymark Site, but were detected in offsite
wells and contribute to the risks posed by exposure to ground
water pumped from those wells. . Since contaminants from the
Raymark Site may add to the total risk posed by exposure to
ground water pumped from offsite public wells, the risk
assessment considered potential exposures to all contaminants.
..
TABLE 4
CONTAMINANTS OF CONCERN
IN GROUND WATER
TCE*
PCE .
l,l-DCE
cis l,2-DCE*
trans l,2-DCE*
l,l,l-TCA
vinyl chloride
carbon tetrachloride
* Identified in well PF-l
An individual may be exposed to contaminants of concern via
several different exposure pathways. Table 5 identifies the
exposure pathways associated with the contaminated ground water.
33
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TAaLE 5 -
SUMMARY OF EXPOSURE PATHWAYS
INGESTION (DRINKING)
INHALATION (SHOWERING)
INHALATION (AIR STRIPPERS)
'.
'.
It 'is important to consider that contaminants in addition to
those identified in well PF-l were identified in public supply
wells and monitoring wells located beyond the property line.
Some of the contaminants detected in public wells and monitoring
wells beyond the property line appear to be unrelated to
operations conducted at the RaYmark Site or appear to result from
the degradation of TCE. Thus, the risks posed by potential
exposure to ground water from contaminated public wells or
monitoring wells other than PF-l most likely results from
multiple sources and from compounds resulting from the
degradation of TCE as it moves beyond the property boundary. In
the risk assessment, EPA separated exposures into onsite and
offsite exposures. Potential onsite exposures resulted from well
PF-l and the R-series of wells (the R-series of wells are
considered onsite for the purposes of the risk assessment due to
their proximity and because they most likely contain degradation
products of TCE originating from the RaYmark Site), although some
of the contaminants in some of the R wells may be unrelated to
the RaYmark site. Potential offsite exposures stem from ground
water pumped from public supply wells.
Potential exposures can be further separated into current and
future exposures. Current exposure to contaminated ground water
results only from air stripper emissions since water from the
public wells is first treated to enforceable, health-based levels
before it enters the d~stribution system. Potential future
exposures may result from ingestion or inhalation of contaminated
ground water from public wells (if treatment is discontinued or
if the air stripping units malfunction), ingestion and inhalation
of ground water from a new residential well installed within the
area of the plume (calculated from data obtained from well PF-l
and the R-series of wells), and inhalation of air stripper
emissions. However, USEPA assumes that the area will continue to
be zoned industrial. The risk from individual public wells' is
evaluated separately. The total risk posed by the site is
calculated as the combined risk from potential current and future
exposures. USEPA bases its decision to remediate the Site upon
the risks posed by the site.
The assessment of risk involves many assumptions about the amount
of exposure to contaminants. USEPA strives to select protective
remedies and thus utilizes risk estimating assumptions which are
somewhat conservative, e.g., USEPA uses the upper bound estimates
of the mean values of certain parameters. For example, USEPA
assumes that an individual lives at the same residence for 30
.
34
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years which represents the 90th percentile value from a national
database for residential permanence. Table 6 lists each of the
assumptions USEPA used to calculate exposure to contaminants of
concern at the Raymark site. The exposure scenario which is
developed using the assumptions identified below is a reasonable
maximum exposure scenario. .
TABLE 6
EXPOSURE ASSESSMENT ASSUMPTIONS
Adult Mass (kg) : 70
Length of Lifetime (yrs). 70
Length of Adult Exposure (yrs): 30
Number of days/year exposed: 350/365*
Tap Water Consumed**(l/d) 2
" .
* carcinogenic effects/non-carcinogenic
effects
** Tap Water Concentration is equal
to the 95 percentile concentration
Chemical intakes are calculated by combining the amount of
chemical with the duration of the exposure to the environmental
media contaminated by the contaminants of concern.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
(cancer-causing) chemicals. CPFs, which are expressed in
units of (mg/kg-day)-', are multiplied by the estimated chemical
intake of a potential carcinogen, in mg/kg-day, to provide an
upper bound estimate of the excess lifetime cancer risk
associated with the exposure at that intake level. The term
"upper bound" reflects the conservative estimate of the risks
calculated from the CPF. The term "upper bound" is a statistical
term and is related to the degree of certainty of the data used
to calculate the"CPF. Use of this approach makes underestimation
of the actual cancer risk highly unlikely. CPFs are derived from
the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. CPFs for the contaminants of concern
are depicted in Table 7.
Reference doses (RfDs) have been developed by EPA for indicating
35
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the potential for adverse. health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g. the
amount of chemical ingested from contaminated dr.inking water) can
be compared to the RfD. -RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (to account for the use of animal data
to predict effects on humans). These uncertainty factors help to
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur. RfDs for the
contaminants of concern are depicted in Table 7.
TABLE 7
CANCER POTENCY FACTORS (CPFs) AND
REFERENCE DOSES (RfDs) FOR CONTAMINANTS
OF CONCERN
CONTAMINANT ORAL INHALED ORAL INHALED
RfD RfD CPF CPF
(mg/kg/d) (mg/kg/d) .1
TCA 9xlO-l NA NA NA
PCE lX10-2 NA 5.1X10.2 3. 3X10.3
TCE NA NA 1.lX10.2 1.3X10'2
cis 1,2 DCE 1X10.2 NA NA NA
trans 1, 2 DCE 2X10.2 NA NA NA
Vinyl chloride NA NA 2.3 2. 95X10.1
1,1 DCE 9X10.3 NA 6x10-1 1.2
carbon
tetrachloride 7X10.4 NA 1.3X10.1 1.3x10.1
Excess lifetime cancer risks are determined by mUltiplying the
intake' level with the CPF. These risks are probabilities that
are generally expressed in scientific notation (e.g. 1X10.6, or 1
million). An excess lifetime cancer risk of lX10-6 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 their entire lifetime. Excess
..
36
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lifetime cancer risks associated with site-related exposures and
offsite exposures are depicted in Tables 8 through 11. The R-
series of wells are considered to be "onsite" in Tabl.e 10 since
the scenario (onsite residential use) assumes that the Site area
is zoned residential. Presumably, a residential well could then
be drilled on-or near the site. Including the R~series of wells
in an "onsite" scenario -does not imply that the contaminants in
theR-series of wells originate entirely from the site.
Tables 10 and 11 estimate risk based upon a "more probable
"exposure to contaminants pumped. from well PF-1. This exposure
considers a weighted average of concentrations of TCE detected in
three fracture zones, weighted by the flow rate in each zone.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminants'
RfD). By adding the hazard quotient for all contaminants within.
a medium or across all media to which a given population may.
reasonably be exposed, the Hazard Index (HI) can be generated.
The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a
single medium or across all media. The HIs associated with Site-
related exposures and offsite exposures are depicted in Tables 12
and 13. The R-series of wells are considered to be "onsite" in
Table 13 since the scenario (onsite residential use) assumes that
the site area is zoned residential. Presumably, a residential
well could then be drilled on or near the site. Including the R-
series of wells in an "onsite" scenario does not imply that the
contaminants in the R-series of wells originate entirely from the
site.
The excess cancer risk which may result from exposure to ground
water from contaminated public wells ranges from a low of 3x10-6
(3 in 1,000,000) for wells H7 and H12 to a high of 3X10.4 (3 in
10,000 or 300 in 1,000,000) for wells H14 and H17. These
estimates assume that the untreated water is distributed to
residents, the water is not diluted in the distribution system,
the water from a particular well is delivered to residents living
near the well, the risks from individual chemicals is additive,
and the risks from ingestion and inhalation are additive in
addition to the assumptions previously stated in Table 6. The
hazard indexes range from a low of 0.06 (well H16) to a high of
0.09 (well H14).
The excess cancer risks which may result from potential exposures
to contaminated ground water obtained from wells located on or
near the RaYmark Site are 9x10-4 (9 in 10,000 or 900 in
1,000,000) from well PF-1 and 2X10-3 (2 in 1,000 or 2,000 in
1,000,000) from the R-series of wells.
37
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Table ct'
OFF-SITE NO FURmER AcrION SCENARIO;
REASONABLE MAXIMUM EXPOSURE EXCESS UFETIME CANCER RISKSLb
Total Excess Lifetime Cancer Riskc
..... ' Distance From Air Stripper
Well No. (meters)
toct - 500
100
H12 2 x 10-8 2 X 10-7 1 X 10-8
H14 5 x 10-5 2 x 10~ 2 x 10.7
H16 7 x 10~ 2 X 10-7 3 X 10-8
H17 1 x 10-8 2 X 10-7 1 X 10-7
-Off-Site No Further Action Scenario Assumptions:
1.
95th percentile concentration of contaminants of concern.
2.
Residential exposure to emissions from existing and proposed air
strippers without vapor phase carbon treatment.
3.
Exposure parameters:
Number of hours per day
N umber of days per year
Number of years
14
350
30
~12, H14, H16, and H17 are the only wells for which air stripper design parameters
are available.
~epresents total risks from TCE and PCE. Although vinyl chloride was present
sporadically in wells H14, H16, and H17. the inhalation risks could not be
calculated because no inhalation carcinogenic potency factor or unit risk
factor is currently available.
dApproximate distance of nearest'receptors (homes or apartment buildings). Impact
calculated at elevated heights typical of receptor height, rather than at ground level.
..
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Table 10
ON-SITE FUTURE ACTION SCENARIO: MORE PROBABLE EXPOSURE.
EXCESS LIFETIME CANCER RISKS
'- Estimated Excess Lifetime Cancer Riskb
Wen No. Ingestion Inhalationc Totald
PF1e 3 x 10-4 6 X 10-4 . 9 x 10'"
R1-R5' 4 x 10-4 8 X 10'" 1 X 10-3
-On-Site Future Action:
1.
No treatment of wells.
'.
2.
Residential use of wells with contamination comparable to that in wells
PF1 and R1-R5.
3.
No blending with water from non-contaminated wells.
4.
Geometric mean concentration of contaminants of concern.
5.
Exposure parameters:
Daily water intake
Body weight
No. of days/year exposed
No. of years exposed
2 liters/day
70 kg
350
30
bRepresents total risk from TCE vinyl chloride in drinking water.
c=Intake from inhalation exposures assumed to be two times that from ingestion
of drinking water. .
. dSum of ingestion and inhalation risks.
eIncludes value for TCE only. Concentration of TCE is a weighted average of
concentration detected on one sampling occasion in three fracture zones, weighted by
th~ flow rate in each zone.
'Data from wells RI-R5 combined into one data set.
-------
Table 11
ON.SITE FUTURE ACfION SCENARIO:
MORE PROBABLE EXPOSUREa.b
EXCESS LU't:nME CANCER RISKS
. .
-.' . Excess Lifetime Cancer Risk
Distance from Air Strippers
Well No. - (meters)
10 Iocr 500
PF1 6 x 104 2 x 10-5 2 x 10~
. .
-On-Site Future Action Scenario Assumptions:
. .
1.
Residential exposure to emissions from an air stripper installed at well .
PF1 on the Raymark property.
2.
Exposure parameters:
Number of hours per day
Number of days per year
Number of years
14
350
30
bCalculated for TCE only. Concentration in well PF1 used in the analysis is a
weighted average of concentrations detected in three fracture zones, weighted by
flow rate in each zone.
CApproximate distance of nearest receptor. Impact calculated at elevated height
typical of receptor height, rather than ground level.
. .
-------
Table 12.
OFF-SITE NO ACfION SCENARIO: REASONABLE MAXIMUM EXPOS1JRE8ob
NONCARCINOGENIC EFFECI'S
Hazard Indexc
-~ Inhalationd
Well No. Ingestion Totale
HI, H2, H3r 0.028 - 0.056 0.084
H7 0.025 0.05 0.075
H12 0.029 0.058 0.087
H14 0.03 0.06 0.09
Hl6 0.02 0.04 0.06
Hl7 0.055 0.110 0.165
-off-site No Action Scenario Assumptions:
1.
2.
3.
4.
No treatment of wells.
Residential use of ground water directly from Hatboro wells.
No blending with non-contaminated wells.
95th percentile concentration of contaminants of concern.
'Exposure Assumptions:
Daily water intake 2 liters/day
Body weight 70 kg
No. of days/year exposed 350
Cfiazard Index = t Daily intake,,_(mg/kg/day)- where n = individual chemical
x= 1 Reference DoseD (mg/kg/day)
dIntake from inhalation exposures assumed to be two times that from ingestion of .
drinking water (see text).
esum of ingestion and inhalation risks.
'Data for wells Hl, H2, and H3 were combined into one data set.
. .
.'
-------
Table 13
ON-SITE FUTURE ACTION SCENARIO: REASONABLE
MAXIMUM EXPOSUREAoB NONCARCINOGENIC EFFECTS
'.
....'
-
Hazard Index&:
WeD No. Ingestion Inhalationd Totale
PF1' 0.15 0.30 0.45
R1-R5 0.48 0.95 1.43
-On-site Future Action Scenario Assumptions:
1.
No treatment of wells.
2.
Residential use of wells with contamination comparable to that in
wells PF1 and R1-RS.
3.
No blending with water from non-contaminated wells.
4.
95th percentile concentration of contaminants of concern.
~osure Assumptions:
Daily water intake 2 liters/day
Body weight 70 kg
No. of days/year exposed 365
CJiazard Index = t Daily intake".Jmg/kg/day)- where n = individual chemical
x= 1 Reference Dosen (mg/kglday)
dIn take from inhalation exposure "assumed to be two times that from ingestion of
drinking water (see text).
esum of ingestion and inhalation risks.
'Based on presence of cis- and trans-l,2-DCE, maximum values only.
-------
Because receptor populations could reasonably be exposed via
different routes evaluated in particular scenarios, ~he excess
cancer risks from each exposure route could be combined to
represent a reasonable maximum exposure scenario for the most
exposed individual. Since exposure to more than one chemical
could occur through any of the exposure pathways~ carcinogenic
risks for each chemical could be added to obtain the total risk
for any particular exposure pathway. The most exposed individual
would obtain domestic water from a well located on or near the
Site and would be concurrently exposed to untreated air stripper
emissions from air strippers currently operating in Hatboro. The
excess cancer risk posed to the most exposed individual would be
1.5x10-3. This means that there is approximately one extra
chance in one thousand (1,000 in 1,000,000) to contract cancer
from exposure to site-related contaminants. In deriving this
risk number USEPA used calculations for well PF-1 to represent
residential ground water contaminated by the site and
calculations from the air stripper at H14 to represent air
stripper emissions since USEPA has d~termined that well H14 is --
hydraulically connected to well PF-1 and therefore most likely
contaminated by the Raymark Site.
There are several important caveats to consider:
1. Nearly all the risk was associated with ingestion of
untreated ground water, which is currently being treated with air
stripping towers before distribution to the public. This risk is
therefore not presently occurring.
2. The HI for inhalation may be artificially low or high since
inhalation RfDs were not available for some of the compounds.
The following factors contributed elements of uncertainty in the
risk assessment: 1) some carcinogenic contaminants at the Raymark
site have been found to cause cancer in animals only, 2) CPFs
were extrapolated from high doses given to animals to low doses
received from environmental exposures, 3) carcinogenic potency
was extrapolated from animals to humans on the basis of dose per
surface area, 4) non-cancer effects were extrapolated from
animals to humans by a set of protective 10-fold uncertainty
factors, and 5) data on synergism or antagonism among the
contaminants were not available.
In addition, water pumped from the public supply wells is pumped
into the distribution system where it most likely mixes with
uncontaminated water before consumption. Therefore, the
contaminant levels used in the assessment of risk from ingestion
of contaminated drinking water, if no treatment were installed,
are most likely overestimated. However, the majority of the risk
posed by the Site results from contaminated ground water which
has an extensive sampling database.
44
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In addition to human health risks, the contaminated ground water
at the Raymark Site poses a potential threat to the 'environment
as well. Wetland areas were identified downstream from an area
where contaminated ground water may occasionally discharge to the
surface water. No endangered or threatened species were.
identified. The existence of sensitive environments would be
considered during the design stage of the remedy.
"
Actual or threatened releases of hazardous substances from the
Raymark 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
environment.
VII.
Alternatives
'.
This section of the ROD describes the process of screening and
developing remedial alternatives and discusses in detail each of
the alternatives evaluated in the Proposed Plan. Remedial
alternatives are developed which meet the remedial objectives of
this response action. .
Screenina of Alternatives
Table 14 identifies each of the remedial technologies and process
options considered for contaminated ground water. A total of 10
possible alternatives were developed from the remedial
technologies and process options identified in Table 14 which
were screened by USEPA in accordance with the NCP. Table 15
identifies each of the 10 alternatives developed in the. FFS to
address contaminated ground water. Appendix D in the draft FFS
details each of the remedial technologies and management or
process options which were screened in the FFS and considered in
the development of remedial alternatives for contaminated ground
water. .
The significance of the screening exercise is to determine which
technologies and options can best satisfy the remedial
objectives. Each of the technologies and options are evaluated
on the basis of their effectiveness and their ability to be
implemented considering Site-specific conditions. Only those
measures which could conceivably meet the remedial action
objectives, or the majority of them, were further developed into
remedial alternatives. Remedial action alternatives are further
limited to proven and/or innovative technologies and process
options which have been used successfully at other sites.
45
- . '. '-"-' ~-- ........., .-.
-------
ConIwrWfMt«l
Mtd.
QAO(.N) WAfER
I"
.---;- -,~"-'-;-----'
(Hrwlll R.6pOn..
Action
NO ACTION
1NST11UT1CNAL
canRCl8
canA.1NMEHT
REMOVAL
TREATMENT
DISP06AL
R.m«IlII
T«hnology
QAOtH) WATER
MONITORNI
RESTRICT
ACCESS' USE
~~W1~::::
Pt&.1C
AWARENE88
------~-
Pror:.u qxton
OOt1.ECTIOH
PHY&ICAL
TREATMENT
;.':.:::!:..,==r',:":::,:!((,
VAPOR-PHASE
TREATMENT
,::::::::\~:::,;:::::::j::i,':,
Dl&aMROE Of OHSITE
GRCItJNI) WATER
Of OfFSlT
OROtHJWATER
. '. .." ,'."'," ,.',,' ...
. .",'."."." ."','. ',' ..
.. ..", ...
;..,.;. '.:',.:...:.::..'
..
TABLE 14
RESUL 1S Of ItITIAL AND
SECONDARY SCREENNO Of
APPLICABLE GROUND WATER
REMEDIAL TECHNOlOGIES
AND PROCESS OPTIONS
RAYIlARK FOCUSED FS
,,::,,::::::,t:::-/ I ~-===-~q.b1
-------
Table 15
Descriptions of Remedial Alternatives
.. ... . ,. .....:..<
AlternatiVe. NUmber.. .. ,...,.::.;::;:.. .". .. . Desaiption:
.. .
1 The no action alternative calls for doing nothing about the problem.
There would be no pumping and treatment at off-site supply wells. This
option is included to provide a baseline amdition for comparison with the
developed remedial .alternatives. Monitoring of the site would conunue.
2 The second alternative includes pumping ground water on-site and
treatment by an air stripping system with vapor carbon treatment for
specified air stripper. The treated water is then discharged to a surface
water. The vapor phase from tbe air stripper is treated with activated
carbon.
3 In the third alternative, the ground water that is pumped on-site is treated
by air stripping. However, instead of discharging to surface water, the
treated water is reinjected off-site into the aquifer. The vapor phase from
the air stripper is treated with activated carbon.
4 This alternative calls for pumping the ground water off-site at the
Hatboro wells and providing treatment by air stripping with subsequent
discharge to the existing water distribution system. The vapor phase from
specified air strippers is treated with activated carbon.
5 Alternative five calls for treatment of the ground water both on-site and
off-site. This required pumping on-site and off-site is followed by air
stripping treatment. The on-site and off-site treated water is then
discharged to surface water and tbe existing water distribution system,
respectively. The vapor phase from specified air Strippers is treated witb
aCtivated carbon. .
6 Unlike alternative five, the on-site treated water is reinjected into the
ground, while the treated water from the off-site treatment is discharged
to the existing water distribution system. At botb sites, air stripping
constitutes the method of treatment. The vapor phase from specified air
stripers is treated with activated carbon.
7 Alternative seven includes on-site pumping of ground water followed by.
carbon adsorption. The treated water is then discharged to surface water.
S Alternative eight is similar to alternative seven except tbat the treated
water is reinjected into the aquifer.
9 In alternative nine, ground water is pumped on-site and off-site. Pumping
on-site is followed by treatment by activated carbon and tbe treated water
is discharged to surface water. The contaminated water from the off-site
wells.is treated by air stripping and then discharged to the existing water
distribution system. The vapor phase from specified off-site air strippers
is treated with activated carbon.
".
-------
." AltemativeNamber.".
10
Table 15
Descriptions of Remedial Alternatives
""Description"
In this alternative, ground water is pumped out on-site and off-site and is
treated separately by carbon adsorption and air stripping, respectively-
Following treatment. the on-site treated water is injected intO the aquifer
while the off-site treated water is discharged into the existing water
distribution system.- The vapor phase from specified off-site air strippers
is treated with activated carbon.
..
-------
DescriDtion of Alternatives
Based upon the screening and evaluation- of potentially applicable
remedial technologies and management or process options and the
requirement within the NCP (Section 300.430(e) (6» -to evaluate a
"No Action" Alternative or a "No Further Action"-Alternative, the
following remedial action alternatives have been selected for
further development and detailed evaluation:
1. No Action / No Further Action
2. Offsite Ground Water Control (FFS #4)
3. Offsite and Onsite Ground Water Control
4. Offsite and Onsite Ground Water Control
Reinjection (FFS #6)
'.
(FFS #5)
with
Alternatives 2, 3, and 4 have many common components. The common
components are: 1) continued operation of public supply wells, 2)
Ground Water Remedial Design Study, 3) ground water extraction,
and 4) periodic monitoring. These common components will be
discussed before individual alternatives are described.
Continued ODeration of Public SUDDlv Wells
The Hatboro Borough Water Authority currently operates the public
water supply system in Hatboro.Several of the Authority's wells
would become components of the ground water remediation. Since
the wells are routinely operated to deliver water to the pUblic,
they could also serve to pump and treat the ground water.
Alternatives 2, 3, and 4 each require that the Hatboro Borough
Water Authority continue to operate the public water supply.
Air stripping towers are currently operated by Hatboro on wells
H14 and H17. An aeration device is also operated on well H12.
Air stripping towers will be operated on wells H2 andH16
pursuant to the consent decree.
Ground Water Remedial Desian Studv
A Ground Water Remedial Design Study would be necessary before a
ground water remedy is fully designed. It would be difficult to
determine the construction specifics of ground water extraction
wells and the number of extraction wells needed to meet the
remedial objectiyes and cleanup goals until more information on
the distribution of contaminants at the site and the aquifer
characteristics beneath the site have been obtained. Therefore,
a Ground Water Remedial Design Study will be completed before any
of the remedial alternatives under consideration is fully
implemented. In order to develop costs to adequately compare
alternatives, the FFS made assumptions about the number of
extraction wells and the depth of the wells and the pumping rate.
49
-------
In addition, the location and frequency of periodic monitoring
and sampling to ensure that the cleanup is progressing towards
the cleanup goals will be determined during the Gro~d Water
Remedial Design study.
Ground Water Extraction
Alternatives 3 and 4 each involve pumping contaminated ground
water from beneath the RaYmark Site to prevent further migration
of contaminants in the soil and~edrock at the site towards
public supply wells.
The plume of contamination currently includes a 1.5 square mile
area depicted in Fiqure 5 and contains approximately 4.8 billion
gallons of water. Since the aquifer is a Class IIA aquifer,
which means that the aquifer is currently a drinking water
aquifer, EPA's cleanup goals would include restoration of the
aquifer to its beneficial use, if practicable. In addition, the
cleanup would continue until background quality is achieved,
pursuant to requirements of PADER, if practicable. USEPA
estimates that the ground water beneath the site could be
remediated within 20 years, but the aquifer would not be cleaned
until all sources of contamination are satisfactorily addressed.
Each alternative would rely in whole or in part upon natural
recharge of clean water (infiltrating precipitation and flow of
clean upgradient ground water) into the area of attainment (the
plume or the area in which the cleanup goals would be met, if
practicable). since other sources of TCE and other VOCs have
been identified and since upgradient contamination has been
identified, the cleanup goals may not be achieved within the
aquifer until the other sources are addressed.
It may not be practical, or possible, to precisely define
area of attainment or the area of ground water above MCLs
background without first making some assumptions, such as
lateral dispersion of the plume and that Site-related
contamination does not exist in wells beyond those within the
area of contamination depicted in Fiqure s. otherwise, an
extraordinary number of monitoring wells would 'need to be
installed. Therefore, because the plume is not precisely
defined, the remedy would include ground water monitoring to
ensure that the plume does not spread to unaffected areas, i.e.,
towards Hatboro wells which are not contaminated. Existing
wells, e.g., H21, beyond the current plume area would be
monitored.
the
or
minimal
The ground water pump and treat would continue until the.cleanup
goals are achieved, if practicable. Once cleanup goals are
achieved, the risk posed by the ground water would be reduced
from the 10-4 excess cancer risk range to the 10-6 excess cancer
"
50
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risk range, at minimum. .
'.
Periodic Monitoring
Samples of t~eated ground water would be collected periodically,
e.g., monthly or quarterly, to ensure that the treatment
technologies employed are reducing contaminant levels to required
standards. Samples would also be collected from selected
monitoring locations to ensure that the remediation is
progressing towards the cleanup-goals. In addition, samples
would be collected from currently unaffected wells, e.g., well
H21, to ensure that the plume does not expand to this area. The
location and frequency of periodic monitoring will be determined
during the Ground Water Remedial Design Study. The samples will
be analyzed for a list of indicator contaminants to include, at
minimum, TCE and its degradation products discussed earlier.
Each remedial alternative is detailed below. The estimated costs
and implementation timeframes are included in the discussion of
each alternative.
'.
51
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ALTERNATIVE 1
NO ACTION / NO FURTHER ACTION
Capital Cost
Annual O&M
Present Worth
Implementation
o
: $11,600
:$145,000
N/A
The National Contingency Plan (NCP) (40 C.F.R. Section
300.430(e) (6» requires that EPA. consider a "No Action"
Alternative for each site. This alternative provides only for
sampling and periodic reviews to monitor the movement of the
plume of contaminated ground water. This alternative does not
provide for ground water remediation nor does it reduce the
further spread of contamination from the Site. The plume of
contaminated ground water would continue to migrate towards the
public supply wells. The future risks posed by the Site would not
be reduced, except by natural processes, e.g., degradation, and
the remedial objectives would not be met. This alternative
serves only as a baseline against which the other alternatives
should be compared.
The NCP also provides for evaluation of a "No Further Action"
Alternative which considers remedial actions or removal actions
previously taken at a specific site. Since public supply wells
are equipped with air stripping towers, which eliminate the
current risk from exposure to contaminated ground water, this ROD
also considers the "No Further Action" Alternative, which is
actually more appropriate for the Raymark Site. The operation of
the air stripping towers at affected public supply wells is
required under the Consent Decrees by and between USEPA, Hatboro
and settling defendants. To simplify the discussion of
alternatives within the ROD, only the "No Action" Alternative is
detailed since the'components of the "No Action" Alternative and
the "No Further Action" Alternative are the same, namely
monitoring and sampling. The "No Further Action" alternative is
similar to Alternative 2 except without air emission controls
which are a component of Alternative 2.
According to the risk assessment, the lifetime excess cancer risk
to potential future ground water users is in the range of 10.4
which means that between 100 and 999 people out of 1,000,000
people drinking contaminated water for a l.ifetime, at exposure
levels discussed.. above, could contract cancer. This risk is
associated with ground water beneath the Raymark site. USEPA
strives to reduce the lifetime excess cancer risk to the 1x10-6
level. Thus, neither the "No Action" Alternative nor the "No
Further Action" Alternative provide acceptable protection from
cancer risks posed by the Site.
Since contaminants from the source area would continue to migrate
..
52
-------
towards the public wells, the timeframe for aquifer remediation.
would be exceedingly long. The ARARs or cleanup goals would not
be met since contaminants would remain in ground water above the
MCLs. In the "No Action" or "No Further Action" Alternatives,
the air emissions from the air stripping towers would not be
addressed po~ing an additional risk in the 10-5 ~ifetime excess
cancer risk range. .
ALTERNATIVE 2
Offsite GROUND WATER CONTROL
Capital Cost
Annual O&M
Present Worth
Implementation
: $288,000
$25,000
: $600,000
: 4-10 months
In addition to the common components discussed above, Alternative
2 includes installation, operation and maintenance of vapor phase
carbon adsorption units at public supply wells where air
stripping towers are installed without emissions controls (H14
and H17). Institutional controls would be used to ensure the
continued operation of the public supply wells and treatment
units to remediate the aquifer. For example, Hatboro must agree
to operate the wells and treat the ground water for the duration
of the remediation pursuant to a consent decree. The treatment
devices would treat ground water to meet the MCLs and .
requirements of the Safe Drinking Water Act, 40 C.F.R. Sections
141.11 through 141.16, before entering the Hatboro Distribution
system. The treated water from H14 and H17 will continue to be
sampled in accordance with pennsylvania's Safe Drinking Water
Act. Hatboro currently samples its wells in accordance with
Pennsylvania's Safe Drinking Water Act.
An air stripping tower is an effective technology which reduces
the levels of contaminant in water. Air stripping towers are
currently installed at wells H14 and H17. contaminated ground
water is pumped to the top of an air stripping tower and
discharged into a column of plastic spheres with large surface
area. At the same time, air is forced up through the
contam~nated ground water in the tower. Since the contaminants
are volatile organic compounds, which tend to leave water and
move into air, the air stripping tower. efficiently removes
contaminants from the water. The air stream leaving the top of
the air stripping tower contains the contaminants which are then
vented into the atmosphere. The air stripping towers currently
installed on affected Hatboro wells have demonstrated that they
reduce contaminant levels below the MCLs. .
Preliminary calculations suggest that the total VOC emissions
from the air stripping towers would be well below federal and
state standards, e.g., National Ambient Air Quality Standards
.'
53
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(NAAQS) regulated under the Clean Air Act (40 CFR Part 50) which
are translated into source specific emission limitations by the
Commonwealth of Pennsylvania.
'.
A more stringent emission rate to be considered is EPA's policy
of installing air controls on treatment units which emit more
than 3 lbs.jhour or 15 lbs.jday of total VOCs in ozone non-
attainment areas (USEPA OSWER Directive 9355.0-28). An ozone
non-attainment area is an area in which the NAAQS for ozone is
not met. EPA's policy was developed since.most VOCs treated at
Superfund sites are precursors ~o the formation of ground level
ozone. However, current calculations of air emissions from the
air stripping towers suggest that total emission rates would be
less than the most stringent standard.
Due to the operation of several air stripping towers within and
near Hatboro, and due to a calculated lifetime excess cancer risk
resulting from exposure to air stripping tower emissions that is
in the 10-5 risk range, Alternative 2 would include treatment of
the air discharged from the tower. A vapor phase carbon .
adsorption unit would be installed on each air stripping tower on
Hatboro's wells. As the contaminated air stream exits the air
stripping tower it would pass through a bed of activated carbon.
As the air moves through the carbon, the contaminants adsorb onto
the polar surfaces of the carbon. The air exiting the carbon
adsorption unit would then be free of contaminants. Thus, the
combination of the air stripping tower and carbon adsorption unit
on each of Hatboro's affected wells, would effectively remove
contaminants from the ground water and contain them within the
bed of activated carbon.
When the carbon is saturated with contaminants, i.e.,
contaminants have adsorbed onto all available surface area,
additional contaminants are not removed from air which passes
through. The spent carbon, i.e., carbon saturated with
contaminants, must be removed, regenerated, and replaced. During
the regeneration process, the carbon vendor (the company
supplying the carbon) typically heats the carbon to drive off the
contaminants and then collects the contaminants. The
contaminants could then be completely destroyed or otherwise
reused. The spent carbon would be subject to the Land Disposal
Restrictions (LDRs) within the Resource Conservation and Recovery
Act (RCRA) , as amended (40 C.F.R. Part 268). Transportand
handling of spent carbon would comply with all requirements of
RCRA and PADER's regulations pertinent to generation,
transportation, storage and handling of hazardous waste and
residual waste pursuant to 25 PA Code Chapters 260 through 265
and 270 and 25 PA Code Sections 75.21 through 75.38.
A detailed summary of the estimated capital and annual operation
and maintenance (O&M) costs of Alternative 2 are depicted in
Table 16. Alternative 2 costs assume that the Hatboro Borough
~
- .
~~
-------
Water Authority continues to pay for the operation and
maintenance of the air stripping towers pursuant to the Consent
Decrees. The implementation timeframe is expected to be within 4
to 10 months.
ALTERNATIVE 3
OFFSITE AND ONSITE GROUND WATER CONTROL
Capital Cost
Annual O&M
Present Worth
Implementation
: $1,140,000
$125,000
: $2,700,000
: 10-16 months
In addition to all the components of Alternative.2 and the common
components discussed above, Alternative 3 includes installation, .
operation, and maintenance of ground water extraction wells to
reduce the further offsite migration of contaminants from the
Raymark Site towards the public .supply wells. The timeframe for
aquifer remediation would be shortened since the source area
would be isolated by pumping and treating, by air stripping and
vapor phase carbon adsorption, near the source area such that
contaminants would not travel long distances to be treated at
public supply wells. The pumping and treating would continue to
maintain the ground water plume within Hatboro. The ground water
treated near the site would be discharged to the storm sewer (see
Fiqure 2). Treated water would eventually flow to the Pennypack
Creek near the Fulmor train station (see Fiqure 1).
The actual flow rate and VOC loading rate (amount of contaminant
per unit time) for the additional treatment location would not be
known until the Ground Water Remedial Design Study is completed
and the extraction system is operational. Afterwards, the air
stripping towers would be tested to ensure that they perform
satisfactorily and the emissions tested to ensure that the
appropriate amount of vapor phase carbon has been installed. The
testing would include periodic sampling to ensure that the
treatment units satisfactorily reduce VOC levels in treated
ground water and thus meet the required levels: requirements of a
National Pollutant Discharge Elimination System (NPDES) permit.
Stream samples would be collected to ensure that the discharge
does not result in contaminant levels within the receiving stream
to be above the ambient water quality criteria under the Clean
Water Act or water quality standards contained within 25 PA Code
Chapter 93. The water quality criteria and NPDES discharge
requirements are based upon the desiqnated use of the receiving
stream requlated by 25 PA Code Chapter 93.
The Commonwealth of Pennsylvania requires a "Request for
Determination of Requirement for Plan ApprovaljOperatinq Permit
55
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Application" be submitted for approval before a new air stripping
unit is operated as part of this alternative. PADER would then
determine from the information provided on the form whether a
plan approval or permit is required, and if so, what""emission
limits will be established.
A pipeline woUld be constructed from the treatment units to the
storm sewer. The discharge flow path is a combination of steel
and' 'concrete pipes and cuI verts as well as open ditches. The
discharge pathway would be carefully evaluated before use. The
pipeline would be sized to accommodate the maximum flow from the
treatment units. The construction of the pipeline and the
discharge point would consider the location of any identified
wetlands or other sensitive habitats. Prior to full operation of
the treatment units, appropriate testing of the treated water
would be completed to ensure that no impacts to sensitive
downstream environments would result from the discharge of
treated water into the stream. In addition, pre- and post-
discharge samples of stream water and biota would be collected to
determine potential effects of the discharge. ~
The amount of contaminants discharged from the treatment unit
into the stream would comply with the requirements of a National
Pollutant Discharge Elimination System (NPDES) permit pursuant to
Pennsylvania's Clean Streams Law (25 PA Code section 92.1 et.
sea.) and the Clean Water Act (33 U.S.C. ~ 1251). Requirements
of an NPDES permit are contained within 25 PA Code Chapter 92.
Substantive requirements of a NPDES permit would include Water
Quality criteria and standards established by EPA and the
Commonwealth of Pennsylvania under Sections 303 and 304 of the
Clean Water Act. Since the discharge would be located in an
lIoffsite" area, i.e., into an area of the stream which is not
considered part of the Raymark Site, the administrative ,
requirements of the permitting prpcess would be met and an actual
NPDES permit would be obtained. '
A detailed summary of the estimated capital and annual operation
and maintenance costs of Alternative 3 are depicted in Table 17.
If USEPA, Hatboro and settling defendants modify the Consent
Decree to change the treatment location from H2 (as specified in
the Consent Decree) to the Penn Fastener property (or nearby),
Hatboro would assume much of the costs of operation and
maintenance since the Borough already received this money
pursuant to the Consent Decree. The implementation timeframe for
Alternative 3 is_10 to 16 months. '
:.r
"
"
,
-------
Table \b
Alternative : Off-Site Pumping With
Air Stripping Treatment and Discharge to Water Supply
CAP IT AL COSTS
Vapor Phase Carbon - Off-Site $200,000
SUBTOTAL 200,000
-
CONTINGENCY (20%) 40,000
SUBTOTAL 240,000
ENGINEERING, ADMINISTRATION, AND 48,000
CONTRACTOR FEES (20%)
CAPITAL COSTS SUBTOTAL 288,000
. OPERATION AND MAINTENANCE (O&M) COSTS
Vapor phase carbon effluent sampling (30 samples @ 12, 000
$400NOA sample)
Power (@ $0.10/kW-hr) 4,000
Off-site vapor phase carbon replacement (@ $2.00/lb) 5,000
SUBTOTAL 21,000
O&M CONTINGENCY (20%). 4,000
O&M SUBTOTAL 25,000
PRESENT WORTH O&M COSTS (20 YEARS AT 5%) 312,000
TOTAL PRESENT WORTH VALUE $600,000
(Capital and O&M Costs)
Note: Only those costs for off-site treatment components not already in place are
included.
'.
'.
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Table 17
Alternative :. On- and Off-Site Pumping With Air Stripping, Treatment
and Discharge to Surface Water and Water Supply System, Respectively
CAP IT AL COSTS
Ground Water Extraction S 230,000
Air Stripper - On-Site 200,000
-
Vapor Phase Carbon - On-Site 100,000
Vapor Phase Carbon - Off-Site 200,000
Discharge to Surface Water* 250,000
SUBTOTAL 980,000
CONTINGENCY (20%) 196,000 .
SUBTOTAL 1,176,000
ENGINEERING, ADMINISTRATION, AND . 235,000
CONTRAcrOR FEES (20%)
CAPITAL COSTS SUBTOTAL 1,141,000
OPERATION AND MAINTENANCE (O&M) COSTS
Labor @ S25/hour . . 11,000
On-Site air stripper influer.tleffiuent monitoring (30 samples 9,000
@ S3OONOA sample)
On-Site vapor phase carbon effiuent sampling (15 samples @ 6,000
S400NOA sample)
Off-site vapor phase carbon effiuent sampling (30 samples @ 12,000
S400NOA sample)
Power (@ SO.101k W-hr) '. 41,000
On-Site vapor phase carbon replacement (@ S2.00 per Ib) 20,000
Off-Site vapor phase 'carbon replacement (@ S2.oo per lb) 5,000
SUBTOTAL 104,000
O&M CONTINGENCY (20%) 21,000
-------
Table r7
Alternative : On- and Off-Site Pumping With Air Stripping. Treatment
and Discharge to Surface Water and Water Supply System, Respectively
O&M SUBTOTAL 125,000
PRESENT WORTH O&M COSTS (20 YEARS AT 5%) 1,558,000
TOTAL PRESENT WORTH VALUE S2,969,000
(Capital and O&M Costs) -
.(For cost purposes only, discharge to nearby creek rather than to storm sewer
was assumed.)
Note: Only those costs for off-site treatment components not already in place are
included.
'.
'.
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Table /8
Alternative: On- and Off-Site Pumping With Air Stripping Treatment
and Re-InjeCtion and Discharge to the Water Supply, Respectively
CAPITAL COSTS
Ground Water Extraction $ 230,000
Air Stripper - On-Site 200,000
Vapor Phase Carbon - On-Site 100,000
Vapor Phase Carbon - Off-Site - 200,000
ReinjeCtion 240,000
SUBTOTAL 970,000
CONTINGENCY (20%) 194,000
SUBTOTAL 1,164,000
ENGINEERING, ADMINISTRATION, AND 233,000 .
CONTRACTOR FEES (20%) .
CAPITAL COSTS SUBTOTAL 1,397,000
OPERATION AND MAINTENANCE (O&M) COSTS
Labor @ S25/hour 11,000
On-Site air stripper influent/effluent monitoring (30 samples 9,000
@ S3OONOA sample)
On-Site vapor phase carbon effluent sampling (15 samples @ 6,000
S400NOA sample)
Off-site vapor phase carbon effluent sampling (30 samples @ 12,000
S4ooNOA sample) . .
Power (@ SO.101k W-hr) 46,000
On-site vapor phase carbon replacement (@ $2.00 per lb) 20,000
Off-site vapor phase carbon replacement (@ S2.oo per lb) 5,000
SUBTOTAL 109.000
O&M CONTINGENCY (20%) 22.000
O&M SUBTOTAL 131.000
PRESENT WORTH O&M COSTS (20 YEARS AT 5%) 1.633,000
TOTAL PRESENT WORTH VALUE S3,030,000
(Capital and O&M Costs)
Note: Only those costs for off-site treatment components not already in place are
included.
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ALTERNATIVE 4
OFFSITE AND ONSITE GROUND" WATER CONTROL WITH REINJECTION
",
'.
Capital Cost
Annual O&M
Present Worth
Implementation
: $1,400,000
$131,000
: $3,030,000
: 10-16 months
'.
Alternative 4 includes all the components of Alternative 3,
except discharge to surface water, and the common components
discussed above. In addition, Alternative 4 utilizes recharge
wells to inject treated water back into the aquifer.
A recharge well injects water back into the aquifer under
pressure. The water would be injected outside the boundary of
the Penn Fastener property to conceptually raise the elevation of
the water table and prevent contaminants from migrating offsite.
Because the recharge wells would increase hydraulic gradients,
they could also decrease the remediation timeframe by causing
contaminants to move towards the extraction wells more quickly. ",
" A detailed summary of the estimated capital and annual O&M costs
for Alternative 4 are depicted in Table 18. The implementation
timeframe is expected to be 10-16 months.
VIII.
Summary of the Comparative Analysis of Alternatives
Each of the remedial alternatives for OU2 and OU3 was compared
and evaluated against nine criteria to determine which remedial
alternative and combination of technologies and process options
would best meet the remedial objectives of this response action.
The evaluation of remedial alternatives against the nine criteria
is required by the NCP (40 CFR, section 300.430(e) (9)(iii». The
nine criteria are:
Overall Protection of Human Health and the Environment: whether
each alternative provides adequate protection of human health and
the environment and describes how risks posed through each
exposure pathway are el~minated, reduced or controlled through
treatment, engineering controls, or institutional controls.
ComDliance with ARARs: whether each alternative will meet all of
the Applicable or Relevant and Appropriate Requirements (ARARs)
"of Federal and S"tate environmental laws and/or justifies invoking
a waiver; whether a remedy complies with advisories, criteria and
guidance that EPA and PADER have agreed to follow.
Lonq-term Effectiveness and Permanence: the ability of each
alternative to maintain reliable protection of human health and
the environment over time, once clean-up goals have been met.
61
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Reduction of Toxicity. Mobility. or Volume throuqh Treatment:
addresses the statutory preference for selecting remedial actions
that employ treatment technologies that permanently and
significantly reduce the toxicity, mobility or volume of
hazardous substances.
Short-term Effectiveness: the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period, until clean-up goals are achieved.
-
ImDlementability: the technical and administrative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular option.
Cost: estimated capital, operation and maintenance (O&M) , and net
present worth costs.
State/SuDDort Aqency Acceptance: whether the State concurs with,
opposes, or has no comment regarding the preferred alternative. .
Community AcceDtance: the pUblic's general response to the
alternatives.
The following section of the ROD compares each of the remedial
alternatives developed in this ROD against each of the nine
evaluation criteria.
A. Overall Protection of Human Health and the Environment
The air stripping tower emissions which would result from
implementation of Alternative 1 would not exceed required
emissions standards, but could result in risk to public health.
The contaminants would be vented into the atmosphere. The
nearest residents are within 100 feet of the stripper exhaust
outlet. The expected contaminant emission levels would be well
below standards under the Clean Air Act and would also be below
EPA's more stringent levels to be considered under EPA's air
emission control policy (which considers reductions in ground
level ozone). However, the emissions still p'resent a risk to
nearby residents (which is greater than 1X10.6) which makes vapor
phase carbon adsorption units, which are treatment components
under Alternatives 2, 3, and 4, more protective.
Alternatives 2, 3, and 4 are equally protective of human health.
Risks posed by contaminated ground water are addressed by air
stripping towers. Risks' posed by air stripping tower emissions
are addressed by vapor phase carbon adsorption units. Since
treated water that would be discharged to the Pennypack Creek
would meet the requirements of a NPDES permit, the stream would
be protected since the permit limits consider the designated use
of the receiving stream.
62
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I --
I
B. compliance with-ARARs
"
Table 19 identifies Applicable or Relevant or Appropriate
Requirements _(ARARS) for the alternatives developed in this ROD.
Under section 121(d) of CERCLA, 42 U.S.C. Section 9621(d), -and
according to USEPA guidance, remedial actions at CERCLA sites
must a~tain legally applicable or relevant and appropriate
Federal and State environmental~tandards, requirements,
criteria, and limitations ("ARARs"). Applicable requirements are
those substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State law
that specifically address hazardous material found at the site,
the remedial action to be implemented, the location of the site,
or other special circumstances. Relevant and appropriate
requirements are those substantive environmental protection
requirements, criteria, or limitations promulgated under Federal
or State law which, while not applicable to the hazardous
substances at the site, the remedial action, site location, or
other circumstances, nevertheless address problems or situations
sufficiently similar to those encountered at the site that their
use is well suited to that site.
"
"
The Commonwealth of Pennsylvania's ARAR for ground water is that
all ground water must be remediated to "background" quality as
specified by 25 PA Code Section 264.90 through 264.100. The
Commonwealth of Pennsylvania also maintains that the requirement
to remediate to background is also found in other legal
authorities. Due to the presence of other sources near the
Raymark site and regional aquifer contamination, USEPA believes
that the background level may be above pertinent health-based
levels, e.g., MCLs.
In order to restore the aquifer to its beneficial use, EPA would
continue aquifer remediation until MCLs, established under the
Safe Drinking Water Act (40 CFR, sections 141.11 through 141.16)
are met, if practicable. In order to comply with Pennsylvania's
requirement to remediate to background quality, the pump and
treat system would continue to operate until background levels
are met, if practicable. The ground water cleanup ARAR includes
MCLs and/or "background" quality, whichever is lower or more
protective. However, the cleanup goals may not be met until
other sources of contamination to the Stockton Formation are
addressed. Thus, the cleanup goal may be met only beneath the
site which is consistent with the remedial objectives. The clean
up of the entire aquifer would be considered at the time of the
final ROD for the site and after other sources of contamination
to the aquifer are addressed.
63
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TABLE
19
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
and TO-BE-CONSIDERED (TBC) REQUIREMENTS
CHEMICAL SPECIFIC
*** Safe Drinkinq Water Act (42 U.S.C. 300(f)}
Maximum Cont~minant Levels (MCLs)
(40 CPR ,141.11-141.16)
TCE .005 mg/l *
1,1-DCE .007 mg/l *
cis 1,2-DCE .070 mg/l *
transl,2-DCE .070 mg/1 *
VC .002 mg/l *
TCA .200 mg/l
carbon tete .005 mg/l
For water that is to be used.
for drinking, the MCLs are.
relevant and appropriate
standards. The aquifer should
be cleaned to these levels, if
practicable, in order to return
to beneficial use. .
Proposed Maximum contaminant Levels (PMCLs)
PCE
.005 mg/l
For water that is to be used
for drinking and an MCL is not
yet established, a PMCL may be
relevant and appropriate.
.'
. ,
* Contaminants of concern which are or may be related to the site.
MCLs for other contaminants is provided since these contaminants
are found within the area of the plume. However, these contaminants
are most likely unrelated to the site.
"
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*** Clean Water Act (33 U.S.C. 1251)
Federal Water Quality criteria (FWQC)
(Qualitv criteria for Water, 1986, 51 CFR 43665)
protection of human health
Water and Fish
Ingestion
DCE
PCE
TCA
TCE
VC
CT
-" .000033
- .0008
18.4
- .0027
- .002
.0004
Fish Consumption
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
.0019
.0089
1000
.0081
.525
.0069
PennsYlvania Chemical-Specific ARARs
*** Clean Streams Law
(25 PA Code Section 93.1 et. ~)
Water Quality Standards
ACTION SPECIFIC
mg/l
mg/l
mg/l
mg/l
mg/l
mg/ 1
*** Clean Air Act (Part D) (42 USC sections 7401-7642)
National Ambient Air Quality Standards (NAAQS)
(40 CFR Part 50)
Ozone - 0.12 ppm (1 hour)
Federal standards which must be
met in the stream adjacent to
the Raymark Site. These
standards are relevant and
appropriate since the stream
may be used for recre~tional
purposes.
State standards for the quality
of Pennsylvania's surface
water.
The NAAQS for ozone should not
be exceeded more than 1 time per
u
year. VOCs are precursors to
the development of ground-level
ozone. Pertains to use of air
..strippers.
-------
*** Resource Conservation and Recoverv Act (42 U.S.C. 6901)
Land Disposal Restrictions
(40 CFR 268.1~268.50)
Requires use of specific technology to
treat specific hazardous wastes. Spent
carbon from carbon adsorption units is
most likely a characteristic RCRA waste.
General handling, transportation
of hazardous waste
(40 CFR Parts 262, 263)
Transportation and handling of,charac-
teristic hazardous wastes to comply with
all requirements of RCRA. 'The spent
carbon from the carbon adsorption units
would most likely be a characteristic
RCRA hazardous waste.
Underqround Iniectiori Control Requlations
(40 CFR Parts 144, 145, 146, 147)
Provides regulations governing injection
of treated water back into the aquifer
(Class IV well). Injected water could
not exceed drinking wat~r standards.
Pennsylvania Action-Specific ARARs
*** 25 PA Code sections 127.1 et. seq.
Requires that air emissions from new
sources, such as air stripping towers,
be controlled with best available
technology. In addition approval is
required for any air stripping/soil
venting plan. '
-------
*** 25 PA Code
Sections 92.1 et.
Average Monthly
Limit
73 ug/l
no limit
no limit
730 ug/l
~
Sets forth provisions for the NPDES
program administration within Penna.
PAD~R would set discharge limitations
based upon the designated uses of the
receiving stream and Site-specific
parameters related to the design of the
proposed treatment system.
carbon tetra.
PCE
trans 1,2-DCE
TCE
*** 25 PA Code'Section 264.90 through 264.100
Requires that all ground water must
be remediated to background quality.
*** 25 PA Code Chapters 260 through
265 and Chapter 270
Regulates generation, transportation,
storage, and treatment of hazardous
waste.
*** 25 PA Code Sections 75.21 through 75.38
Regulates generation, transportation,
storage, and treatment of residual waste.
, .
*** 25 PA Code 123.1 et ~
Regulates fugitive emissions during
construction activities.
*** REQUIREMENTS TO-BE-CONSIDERED
EPA OSWER Directive 9355.0-28
Air Stripper Control Policy
Suggests that total VOC releases from
air strippers should not exceed 3 lbs/hr.
*** 'rhese ARARs are ~pecific to the selected remedial action
-------
No alternative would exceed National Ambient Air Quality
standards (NAAQS) .established under the Clean Air Act (40 C.F.R.
Part 50) and regulated by the Commonwealth of Pennsy~vania.
However, EPA has established a more stringent policy to be
considered in Superfund cleanups which occur in ozone non-
attainment areas. The most stringent emission rate from all
sources employed in a Superfund cleanup would be3 lbs./hour or
15 lbs./day of total VOCs (USEPA OSWER Directive 9355.0-28).
Current calculations suggest that total emissions from the air
stripp~rs would not exceed 15 lbs./day.
-
The Commonwealth of Pennsylvania requires a "Request for
Determination of Requirement for Plan Approval/Operating Permit
Application" be submitted for approval before a new air stripping
unit is operated as part of this alternative. PADER would then
determine from the information provided whether a plan approval
or permit is required, and if so, what emission limits will be
established.
Alternatives 2, 3, and 4, which employ vapor phase carbon
adsorption units, would not cause release of contaminants into
the air. The spent carbon, however, would require regeneration
or disposal which would be subject to Land Disposal Restrictions
contained within the Resource Conservation and Recovery Act
(RCRA), as amended (40 C.F.R. Part 268) and other applicable
requirements of RCRA (transportation and handling requirements at
40 CFR Parts 262 and 263). The Commonwealth of Pennsylvania
requires that hazardous waste and residual waste be handled,
transported, and treated pursuant to 25 PA Code Chapters 260
through 265 and Chapter 270 (hazardous waste) and Sections 75.21
through 75.38 (residual waste). The spent carbon, which is
saturated with volatile organic compounds, would be a
characteristic RCRA hazardous waste. Thus, the spent carbon
would be subject to the Land Disposal Restrictions. Typically,
the carbon vendor, who would have appropriate RCRA permits,
regenerates the carbon and destroys or recycles the volatile
organic compounds in accordance with applicable RCRA regulations.
..
Alternative 4, which relies upon aquifer recharge wells, would
need to comply with the substantive requirements of an
underground injection control program permit under the Safe
Drinking Water Act (40 C.F.R. Parts 144, 146 and 147).
Alternative 3, which relies upon discharging treated ground water
into a nearby sur£ace water body, would comply with the
requirements of, and would obtain, a National Pollutant Discharge
Elimination System (NPDES) permit which is regulated by the
Commonwealth of Pennsylvania under the Clean Streams Law (25 PA
Code Chapter 92). In addition, the contaminant levels in the
stream would comply with ambient water quality criteria
established under the Clean Water Act (Section 303) and
Pennsylvania water quality criteria established under the Clean
67
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streams Act (25 PA Code Chapter 93). The treatment technologies
in each of the al~ernatives can be designed to meet required
standards.
"
C. Long-term ..Effectiveness and Permanence
"
Alternative 3 employs reliable treatment technologies. Since
carbon adsorption units would be used to treat air emissions, the
contaminants would not be vented into the atmosphere. The levels
of contaminants in the ground w~ter would be reduced to drinking
water standards or background, if practicable. Long-term
periodic sampling would be required to ensure that the air
stripping towers and carbon adsorption units are properly
maintained and are operating according to performance standards.
Alternative 3 is therefore a permanent remedy which is the most
effective over the long term..
Alternative'l, which relies upon air stripping towers currently
operating within Hatboro has fewer operation and maintenance
requirements than other alternatives, but may need additional
controls installed if emission rates exceed required standards.
Alternatives which include vapor phase carbon adsorption units to
air stripper emissions may require increased sampling frequency
to ensure that contaminants do not break through the carbon.
However, if contaminants break through the carbon unit, the
resultant release would'not exceed any required standards.
Alternatives which employ carbon treatment units would result in
the destruction of contaminants whereas alternatives which employ
air stripping towers only would result in uncontrolled releases
of contaminants into the atmosphere (at levels which are
considered to present a risk to nearby residents).
Alternative 4, which employs aquifer recharge wells is sUbject to
potential failure if recharge wells are not properly maintained.
Recharge wells tend to clog over time necessitating continued
maintenance. In addition, recharge wells could cause
contaminants to migrate outside the capture zone of the
extraction wells resulting in residual risk remaining within the
ground water system.
.)
D. Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 3 provides the greatest reduction in contaminant
volume, toxicity, and mobility. The contaminants, which were
dispersed throughout the ground water would be adsorbed onto
activated carbon and collected for appropriate disposal or
destruction. Treated water woul~ no longer contain toxic levels
of contaminants. Aquifer recharge wells could potentially result
in the movement of contaminants outside the capture zone of the
ground water extraction. system.
68
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Table 8
OFF.SITE NO AcnON SCENARIO: REASONABLE MAXIMUM EXPOSURE.
EXCESS UFETIME CANCER RISKS'.
. Estimated Excess Lifetime Cancer Ris~
Well No. Ingestion Inhalation' Totald
HI, H2, H3e 5 x 10-6 - 1 x 10-5 2 x 10-5
H7 1 x 10-6 2 x 10-6 3 X 10-6
H12 1 x 10-6 2 x 10-6 3 x 10-6
H14 1 x 10-4 2 x 10-4 3 X 10-4
H16 4 x 10-6 8 x 10-6 1 x 10-5
H17 1 x 10-4 2 X 10-4 3 x 10-4
-off-site No Action Scenario Assumptions:
1.
No treatment of wells.
2.
Residential use of ground water directly from Hatboro wells.
3.
No blending with non-contaminated wells.
4.
Exposure parameters:
Daily water intake
Body weight
No. of days/year exposed
No. of years exposed
2 liters/day
70 kg
350
30
5.
95th percentile concentration of contaminants of concern.
. bRepresents total risk from TCE and vinyl chloride in drinking water.
'Intake from inhalation exposures assumed to be two times that from ingestion of
drinking water.
~um of ingestion and inhalation risks..
~ata for wells HI, H2, and H3 were combined into one data set.
-------
Alternative 1, which employs air stripping towers without vapor
phase controls would reduce contaminant toxicity, but would then
vent the contaminants into the atmosphere. The ground water risk
posed by the Site (Well PF-1) is in the range of 10.'. The risk
posed by the.emissions from the air stripping towers to nearby
residents is in the range of 10.5.
'.
E.
Short-term Effectiveness
USEPA anticipates that implementation of any of the alternatives
would not result in increased exposure to contaminants. However,
if contaminants continue to migrate from the Site towards the
public supply wells, the contaminant levels at the public supply
wells could increase.
Since the timeframe for aquifer remediation determines the time
it takes to achieve the cleanup goals, any steps to decrease the
remediation timeframe (Alternatives 3 and 4) helps to increase
the short-term effectiveness of the remedy.
F.
Implementability
Additional fieldwork must be completed before an efficient remedy
can be designed and constructed. Therefore, actual construction
requirements, and associated implementation requirements, are
unknown, but estimated, at this time. However, the technologies
considered in each alternative are generally easily constructed
from readily available components. EPA has extensive experience
implementing ground water pump and treat remedies.
Alternative 4, which employs aquifer recharge wells rather than
surface water discharge, may be unreliable since recharge wells
may be difficult to locate and construct to efficiently inject
treated water back into the aquifer. Each alternative requires
coordination with the Pennsylvania Department of Environmental
Resources. Surface water discharge requires development of .
discharge requirements, aquifer recharge wells require
development of permit requirements, and air stripping towers
require development of operation and management plans. .
G.
Cost
The estimated cost of each alternative is depicted in Table 20.
Alternative 3 provides the most protection and the shortest
remediation timeframe for a reasonable cost. Alternative 2 is
less costly, but would not address contaminants at the Raymark
Site, thus the remediation timeframe would be increased.
Alternative 4 is more. costly, yet subject to potential failure
69
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ALTERNATIVE
CAPITAL
COST
TABLE 20
RAYMARK SUPERFUND SITE
SUMMARY OF ESTIMATED COSTS
ANNUAL O'M
COST
PRESENT WORTH
COST
IMPLEMENTATION
TIME
(MONTHS)
1. NO ACTION /
NO FURTHER ACTION
2. OFF-SITE GW
CONTROL
3. OFF- AND ON-
SITE GW
CONTROL
4. OFF- AND ON-
SITE GW
CONTROL AND
REINJECTION
o
288,000
1,140,000
1,400,000
11,600 145,000
25,000 600,000
125,000 2,700,000
o
4-10
10-16
131,000
3,030,000
10-16
.'
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and the possibility of s~reading the contaminants into currently
unaffected areas.
. .
. .
H. state/support Agency Acceptance
The Commonwealth of Pennsylvania concurs with EPA's selection of
Alternative 3.
. .
I. Community Acceptance
A pUblic comment period was held from August 15, 1990 to
september 17, 1990. A public meeting was also conducted on
August 30, 1990. The public expressed a great deal of interest
and concern about the RaYmark site and the contaminated aquifer.
The primary issues revolved around the characteristics of the.
site and the extent and nature of the contamination. Nearly all
of the public comments focused on technical issues which were not
specific to the selection of a remedy for the Site, but requested'
clarification and additional information on Site-related issues.
In general, the public agrees with EPA's selection of ~lternative
3 to remediate contaminated ground water from th~ RaYmark Site.
The PRPs for the RaYmark site submitted comments indicating that
they disagree with USEPA's conclusion that Alternative 3 is the
best alternative for the site. Instead, the PRPs indicate that
the remediation should proceed in accordance with the consent
decree already entered between USEPA, Hatboro and settling
defendants. USEPA's response to public comments is contained
within the Responsiveness Summary of this ROD (Appendix A).
IX. Selected Remedy
The remedial action alternatives included in the final analysis
for OU2 and OU3 of the RaYmark Site were:
1. No Action / No Further Action,
2. Offsite Ground Water Control,
3. Offsite and Onsite Ground Water Control, and
4. Offsite and Onsite Ground Water Control with
Reinjection.
71
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The selected remedial alternative for OU2 and OU3 of the Raymark
site is Alternative 3. specifically, this ROD selects:
1. Completion of a ground water remedial design 'study to
determine the most efficient design of a ground water
extractipn and treatment system.
2. continued operation and maintenance of public water
supply wells by the Hatboro Borough Water Authority.
3. Continued operation and~aintenance of air stripping
towers installed at contaminated public water supply wells
by the Hatboro Borough Water Authority.
4. Installation, operation, and maintenance of vapor phase
carbon adsorption units at public water supply_wells
equipped with air stripping towers.
5. Installation, operation, and maintenance of onsite ground
water extraction wells to remove contaminated ground water:
from beneath the site and to prevent contaminants from
migrating offsite.
6. Installation, operation, and maintenance of air stripping
treatment at onsite ground water extraction wells to treat
ground water to required levels.
7. Installation, operation, and maintenance of vapor phase
carbon adsorption units on onsite air stripping towers.
8. Construction, operation, and maintenance of a pipeline
from the onsite ground water treatment plant to the storm
sewer system to discharge treated ground water into the
storm sewer system and then offsite to the Pennypack ,Creek.
9. Periodic sampling of ground water and treated water
to ensure treatment components are effective and ground
water remediation is progressing towards the cleanup goals.
10. Institutional controls to ensure that the Hatboro Water
Authority continues to operate public water supply wells
equipped with treatment systems.
The number, location, and construction specifics of the onsite
ground water extraction well system would be determined upon
completion of the Ground Water Remedial Design study. USEPA
anticipates completing this study in the Fall of 1990.
Similarly, the design specifications and performance criteria for
the treatment units (and associated pumps and piping) to be
installed at the Site would be determined once the extraction
wells are located and ground water flow rates and contaminant
"
72
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loading rates for the treatment units are established.
.. D
In addition to the components of the remedial altern~tive
discussed above, a pre-discharge evaluation of the stream biota
would be conducted for the purpose of providing a baseline
against which. any potential impacts of the discharge or treated
ground water upon the receiving stream could be evaluated. An
effluent toxicity test would also be performed on the treated
discharge. In addition, post-discharge downstream sampling would
be conducted to evaluate the persistence of toxicants potentially
discharged from the treatment units. During pre- and post-
discharge sampling of the receiving stream, potentially sensitive
environments, e.g., limited wetland areas within the stream
channel and floodplain, would be monitored and evaluated to
ensure that no potentially adverse impacts result from the
discharge of treated ground water into the Pennypack Creek.
"
As part of Alternative 3, background concentrations of each
contaminant will be determined through ground water monitoring at
upgradient wells. Remediation of ground water will proceed unti~
background quality is achieved unless attainment of background is
determined to be infeasible or is otherwise waived under Section
121(d) (4) of CERCLA, 42 U.S.C. Section 9621(d) (4).
Additionally, based upon information obtained by USEPA during
onsite investigations and upon a careful analysis of all the
remedial alternatives and knowledge that the source of
contamination at the Site will be addressed in OU1, USEPA
believes that the selected alternative for ground water would
reduce contaminant levels in ground water migrating from the site
to health-based levels thereby contributing to the restoration of
the aquifer to its beneficial use. It remains unclear, however,
. if the selected remedial alternative would reduce contaminant
levels to backgro~nd levels as required. by PADER, especially if
those levels are considered to be zero. It may become apparent,
during implementation or operation of the ground water extraction
system, that contaminant levels beneath the site have ceased to
decline and are remaining constant at levels which are higher
than the cleanup goals, which are considered to be MCLs and/or
background levels, whichever is lower or more protective. In
such a case, the system performance standards and/or the ground
water remedy may be reevaluated.
The selected remedy includes ground water extraction, treatment,
and discharge for an estimated period of 20 years. The entire
aquifer tapped by the Hatboro public well system would not be
remediated within 20 years, due to the existence of contamination
sources other than the RaYmark Site, but USEPA anticipates that
contaminant levels within the source area (i.e., beneath RaYmark)
could be reduced to health-based levels, within 20 years provided
that the source area itself is treated (under OU1). - Thus, the
RaYmark Site would no longer contribute contamination to the
73
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aquifer beneath Hatboro presenting an unacceptable risk.
The remediation systeml~ performance would be carefully monitored
on a regular basis and adjusted, as warranted, throughout the
period of remediation. For example, certain extraction wells
could be removed from service, pumped at higher or lower levels,
or pumped intermittently to improve the performance of the
extraction system.
The point of compliance, or the point at which the cleanup goals
would be met, if practicable, far this ROD is the downgradient
boundary of the Penn Fastener, Inc. property. This ensures that
the site no longer contributes to aquifer contamination.
The area of attainment (the plume) contains contaminants from
multiple sources, including the site. The selected alternative
in this ROD would not meet cleanup goals throughout the aquifer
until such time that all sources of contamination to the aquifer
are addressed.
In order to restore the aquifer to its beneficial use, the
remediation system implemented in each of the alternatives would.
operate until Site-specific remediation goals are achieved. Thus
the aquifer would be remediated until the contaminate levels
reach the MCLs, Non-zero MCLGs, or background, whichever are
lower.
If implementation of the selected remedy 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, the USEPA in
consultation with the Commonwealth of Pennsylvania, intends to
amend the ROD or issue an Explanation of Significant Differences
to inform the Public of alternative groundwater goals.
If it is determined, on the basis of the preceding criteria and
the system performance data, that certain portions of the aquifer
cannot be restored to their beneficial use, all of the following
measures involving long-term management may occur, for an
indefinite period of time, as a modification of the existing
system:
a) low level pumping would be implemented as a long-term gradient
control, or containment, measure:
b) institutional controls would be provided/maintained to
restrict access to those portions of the aquifer which remain
above health-based goals and to ensure that public wells are
routinely monitored and treated as necessary.
The decision to invoke any or all of these measures may be made
during a periodic review of the remedial action, which would
. ..
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occur at 5-year intervals.
After the remediation is completed, the lifetime excess cancer
risk levels posed by the Site would be within the 10"4 to 10'6
excess cancer risk range consistent with the NCP.
X. Statutory Determinations for the Selected Remedy
The selected remedy which was outlined in Section X satisfies the
remedy selection requirements ot section 121 of CERCLA (42 U.S.C.
Se~tion 9621) and the NCP (40 C.F.R. Section 300.430(e». The
remedy provides protection of human health and the environment,
achieves compliance with ARARs, utilizes permanent solutions to
the maximum extent practicable, contains treatment as a princip~l
element, and is cost effective.
A. Protection of Human Health and the Environment
The selec~ed alternative is protective of human health and the
environment. The ground water remediation would reduce
contaminant levels beneath the site to MCLs, non-zero MCLGs, or
background levels, whichever is lower, and would reduce the
further migration of Site-related contaminants toward public
supply wells. The ground water discharged from the treatment
units into the Pennypack Creek would be treated to levels
protective of the receiving stream. The residual lifetime excess
cancer risk restilting from site-related contamination is expected
to be reduced below the 1x10.6 risk level, but would certainly be
reduced within the acceptable range defined within the NCP (i.e.,
10'4 to 10.6). The residual risk resulting from Site-related non-
carcinogenic compounds is expected to be less than 1.
USEPA expects to meet the ground w~ter cleanup goal at the
downgradient boundary of the Penn Fastener, Inc. property, if
practicable. Thus, the Site would not contribute further
contamination to the aquifer tapped by the Hatboro public well
system. After Site remediation is completed, contaminants would
not continue to migrate from the Site towards public wells.
The cleanup goal may not be met beyond the property line due to
the presence of other contamination sources and regional
contamination. This ROD provides for control of the entire plume
via pumping and treating at public wells, but does not provide
for remediation of the plume to cleanup goals. The ground water
pump and treatment components of this ROD may be used to
remediate the entire plume.
Because contamination currently within public wells originated in
part from the RaYmark Site, treatment at public wells is a
necessary component of remedial alternatives considered for OU2
and OU3. USEPA would meet drinking water treatment requirements
75
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at the location of individual public wells. Thus, the ground
water would be treated to'MCLs before entering the distribution
system. Each of the drinking water wells is equippe~ with a
sampling tap which allows samples to be obtained as water is
pumped from the ground.
USEPA expects'to meet the NPDES discharge requirements at the
point of discharge into the storm sewer system near the site.
The 'remedy would not rely upon further dilution within the storm
sewer system.
-
USEPA expects to meet ambient water quality criteria and water
quality standards downstream of the point of discharge into the
Pennypack Creek. Thus, potential impacts to the Pennypack Creek
would be minimized.
No unacceptable short-term risks or cross media impacts would
result from implementation of the selected remedial alternative.
B. Compliance with ARARs
i
i '
It is expected that the selected remedy will comply with all
ARARs, which are identified in Table 19. If EPA determines that
it is not technically practicable to reach the chemical specific
ARARs, EPA may choose to waive the ARARs in accordance with
Section 121 of CERCLA.
C. Cost Effectiveness
The selected remedy is cost effective. Alternative 4is more
costly and provides no additional protection of human health.
Alternative 2 is less costly, but does not address the continued
migration of contamination from the Raymark Site towards the'
public supply wells. Vapor phase carbon adsorption units would
be installed even though the estimated lifetime excess cancer
risk levels resulting from air emission would be within the
acceptable risk range defined within the NCP (i.e., 10.4 to
10"6) and the anticipated emission rates would be below ARAR
levels. The installation of the air treatment at all wells is
justified by the proximity of residents to the air stripping
towers and the large amount of uncertainty involved in modelling
actual risks to receptors within 100 meters of the air stripping
towers. Additionally, the presence of at least 5 existing and
proposed air strippers within and near Hatboro justifies the use
of air controls to minimize combined risks from all air
strippers. Carbon adsorption is less expensive than other
remedial technologies considered to treat air emissions from the
air stripping towers.
, , The selected remedy provides the highest level of protection for
reasonable cost. The selected remedy provides overall
effectiveness proportionate to its costs, such that it represents
76
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a reasonable value for the money to be spent.
The estimated capital cost of Alternative 3 is $1,140,000. The
estimated annual operation and maintenance cost is $i2S,000.
D. utilization of Permanent Solutions to the Maximum "Extent
Practicable"
'.
The selected" remedy employs p~rmanent solutions employing
" treatment of hazardous substances released from the Raymark Site.
- "
Those criteria potentially affecting the long-term operation and
maintenance and the effectiveness of the remedy (e.g., long-term
effectiveness, implementability, and cost) were most critical in
the selection decision. A surface water discharge is easier to
implement and maintain than aquifer recharge wells. In addition,
surface water discharge is less costly than aquifer recharge
wells and should not be subject to failure.
The combination of air stripping and vapor phase carbon
adsorption would result in the complete destruction of the
contaminants upon regeneration of the spent carbon. Thus, the
contaminants would no longer pose a risk to human health and the
environment.
The Commonwealth of Pennsylvania and the public supported EPA's
selection of Alternative 3.
E. Preference for Treatment as a Principal Element
The selected remedy utilizes proven and readily available
treatment technologies to reduce ground water risks posed by
site-related contaminants. The remedy employs treatment as its
principal element. "
77
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"
"
APPENDIX A
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
Raymark Superfund site
Hatboro, Montgomery County, Pennsylvania
'.
A. Overview
USEPA's preferred remedial alternative, i.e., on-Site and off-
Site Ground Water Control, for Operable Units 2 and 3, was
outlined in the Proposed Plan and released to the public on
August 15, 1990. During the 3D-day comment period (August 15,
1990 through september 17, 1990) and public meeting (August 30,
1990), comments were received from 3 residents and from
representatives of the potentially responsible parties. In
general, the comments from residents living in Hatboro supported
USEPA's selection of Alternative 3.
In general, the potentially responsible parties disagreed with
USEPA's decision to remediate ground water at or near the source
of the contamination. Instead, they believe that the remediation
should continue as specified in the Consent Decree between USEPA
and Raymark, et. ale . .
Based upon the comparative analysis of alternatives discussed
within the Record of Decision (ROD), and after review of the
comments received during the public comment period, USEPA has
selected Alternative'3, Off-Site and On-site Ground Water
Control, to address Operable units 2 and 3 of the Raymark Site.
B. Summary of Comments Received During Public Comment Period
The public comment period was held from August 15, 1990 through
September 17, 1990. A public meeting was held August 30, 1990.
A stenographic report of the public meeting was prepared by
USEPA. USEPA reviewed, evaluated, and considered comments
contained within several sources. The sources include:
A. Stenographic Report of the pUblic meeting prepared by
USEPA, August 30, 1990.
B. Nolan Hare letter to Michael Towle (USEPA) September 14,
1990.
C. Thomas Rotchford letter to Michael Towle (USEPA)
September 13, 1990.
D. Bradford Whitman (Dechert Price & Rhoads) letter to
Michael Towle (USEPA), submitted on behalf of Richard Walker
(owner) and Penn Fasteners (operator) of the Site, September
17, 1990.
-------
E. Brendan Collins (~allard, Spahr, Andrews & Ingersoll)
letter to Michael Towle (USEPA), submitted on b~half of
Raymark Industries, Inc., including comments from BCM
Engineers, September 17, 1990.
Comments raised during the public comment period on the Proposed
Plan are summarized below. Following each comment summary is
USEPA's response.
COST/FUNDING ISSUES
1~ EPA received comments concerning who would pay for
. implementing the remedial alternative for OU2 and aU3.
EPA RESPONSE - EPA 'would offer the opportunity to implement the
remedial alternative to the potentially responsible parties
(PRPs). If the PRPs choose to implement the alternative, they
would pay for the costs of implementation and yearly operation
and maintenance costs. If the PRPs do not commit to implementing
the remedy, EPA would pay for the costs of remediation and would
reserve the right to institute a cost recovery action against the
PRPs. The money to pay for the remedy would come from the'
Superfund which comes from a tax on chemical companies.
Currently, Raymark Industries, Inc. and Penn Fasteners, Inc. have
agreed to pay for the operation and maintenance of two treatment
units on Hatboro public wells pursuant to the Consent Decree.
DECISION MAKING PROCESS
1. EPA received comments suggesting that the Proposed Plan is
inconsistent with the National Contingency Plan (NCP) because EPA
has not conducted a Remedial Investigation (RI) ~t the site
pursuant to the NCP (40 C.F.R. Section 300.430). Specifically,
the commentator suggests that the existing studies, which EPA
substituted for an RI Report, were not designed to adequately
determine the nature and extent of contamination at the site
pursuant to 40 C.F.R. section 300.430(d) (l)(iv) of the NCP. In
addition, one commentator felt that the RI for the site was
inconsistent with the NCP since it did not address the source of
contamination, i.e., soil.
EPA RESPONSE - EPA believes that the Proposed Plan was developed
from information which is consistent with the NCP. The NCP
requires that an RI/FS be conducted to assess Site conditions and
evaluate alternatives to the extent necessary to select a remedy.
The purpose of the RI is to collect data necessary to adequately
characterize the site for the purpose of developing and
evaluating effective remedial alternatives (NCP at 40 C.F.R.
2
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section 300.430(d». In conducting an RI for Operable Units 2
and 3, EPA has completed.field investigations intended to assess
the extent to which the source can be adequately identified and
characterized pursuant to the NCP (40 C.F.R. Section'
300.430(d) (2) (iv». An RI/FS for the source area (OU1) is
ongoing. At this time, the extent of the ground water data and
information is adequate.to allow EPA to develop .and evaluate
appropriate remedial alternatives for contaminated ground water.
The. contaminated soil (source area) will be addressed by the
response action selected for OU1.
"
. -
2. One commentator states that the Proposed Plan is inconsistent
with the NCP because the ground water. operable unit (OU3) can not
be effectively treated prior to remediation of the soil/source
control operable unit (OU1) since contaminants will continue to
migrate into ground water while remediation is ongoing. In .
addition, the commentator suggests that the Proposed Plan is
inconsistent with the NCP since proceeding with ground water
remediation before the source is addressed would impair the
effectiveness of the remedy (40 C.F.R.Section 300.430(e){9) (C)-~
(E). Other commentators agreed that remediation of ground water
before remediation of the source area is not logical.
EPA RESPONSE - Addressing the remediation of ground water before
remediation of ~oil (source) .is not inconsistent with the NCP.
The site was separated into operable units primarily to achieve
significant risk reduction from exposure to contaminated ground
water and to expedite total site cleanup consistent with the NCP
(40 C.F.R. section 300.430(a) (l) (ii». In addition, the
implementation of a soil remediation alternative in OUl would be
enhanced by operation of components of OU3. Specifically, a
ground water remediation system will lower the water table
beneath the Site and thus increase the depth of the unsaturated
zone which could be remediated, since most of the innovative
and/or proven soil remediation technologies, including the remedy
to be pilot-tested at the RaYmark Site, are hindered by saturated
soil conditions. Implementation of OU2 and OU3 before the source
remediation alternative is implemented would not preclude or be
inconsistent with final Site remediation.
3. EPA received comments suggesting that since TCE remains in the
soil, and is possibly leaching into the ground water, that EPA
should address the soil contamination.
EPA RESPONSE - EPA does not currently have sufficient data for
selecting a remedy for the soil. Rather than wait the additional
time to address the soil and the ground water .together, EPA has
.opted to remediate the groundwater.
3
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REMEDIAL ALTERNATIVE PREFERENCES
1. Comments received questioned why USEPA did not elect to pump
ground water from the Raymark site (e.g., well PF-1);' but chose
instead to pump ground water from the Hatboro H1, H2, H3 .
location. One commentator suggests that the off-Site pumping
location, e.g~., H1, H2, H3, has advantages over on-Site pumping
which include preventing contaminants from migrating to Hatboro
public supply wells.
EPA RESPONSE - Based upon data existing at the time of the trial
and Consent Decree, the H1, H2, H3 location appeared to be
hydraulically connected to the PF-1 well and could thus
substitute as a remediation location. In addition, USEPA
believed, at that time, that operation of a well at H1, H2, H3
(rather than PF-1) would be more implementable since facilities
required to operate and maintain the well were already in
existence. Based upon information collected in 1989 during
performance of the work plan attached to Consent Decree, USEPA
determined that remediation at H1, H2, H3 may not remediate
shallow ground water (which is the most contaminated) beneath the
site. .
2. EPA received. comments which questioned the preference for
installing air emission controls from air strippers when the air
emissions do not present a significant risk to the community and
do not exceed applicable standards.
EPA RESPONSE - The risk assessment conducted by EPA indicated
that the emissions from the air stripping towers currently
operating in Hatboro could result in an excess lifetime cancer
risk which is in the 10-5 risk range. In other words, there may
be an extra 10 to 99 chances in 1,000,000 of contracting cancer
from a lifetime of exposure to air stripper emissions. The NCP
provides that an acceptable risk range is between 10.4 and 10.6.
However, EPA strives to reduce risk to the 1x10.6 level (1 in
1,000,000) and thus uses this level as the point of departure as
provided within the NCP. A response action for uncontrolled
emissions from air strippers within Hatboro is justified by the
risk posed by these emissions.
TECHNICAL CONCERNS
1. Comments received suggested that the hydrogeology beneath the
Site has not changed, yet USEPA evaluated alternatives which
differ from the remedy contained within the Consent Decree.
Vertical or horizontal ground water flow in the shallow aquifer
may be impossible to define due to joints and fractures in the
bedrock. The shallow aquifer is poorly transmissive. The deeper
aquifer, greater than 125 feet, is highly transmissive and thus
ground water remediation should focus on this depth.
'.
4
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EPA RESPONSE - USEPA agrees that the hydrogeology beneath the
site has not changed since the Consent Decree between USEPA and
settling defendants was entered. Since the Consent Decree was
entered, however, USEPA has obtained additional information about
the aquifer during the course of the work plan implemented by the
Consent Decree. The information indicates that the shallow
ground water is highly contaminated and a zone between the
shallow zone and deeper (greater than 125 feet) zone is poorly
transmissive and not highly contaminated. USEPA now believes
that remediation proceeding solely at existing public wells would
not efficiently remediate ground water beneath the site.
Contamination in the shallow zone (above an approximate depth of
125 feet) would first be "pulled" through a zone of poorly
transmissive bedrock, which is not highly contaminated, and then
would need to travel long distances for treatment at existing
public wells. USEPA believes, based upon current information,
that remediation of ground water beneath the Site should include
pumping from the shallow ground water zones to prevent the
contaminants from migrating down into the deeper zones' which are--
tapped by the public supply wells. Additionally, based upon"
information collected in 1989, the public wells draw ground water
primarily from depths greater than 125 feet, thus, the public
wells could "drag" Site contaminants, which have not already
migrated from the Site deeper into the aquifer. .
2. Comments received indicated that TCE would most
migrated through the shallow ground water into the
water over the ten years that passed since TCE use
discontinued at the Site.
likely have
deeper ground
was
EPA RESPONSE - The results of packer tests conducted in 1989
indicate that the shallow ground water zones are significantly
more contaminated than the deeper ground water zones. Thus, the
data indicates that although TCE is migrating into deeper ground'
water, the shallow system is still most impacted.
3." Comments received questioned EPA's delineation of the 'extent
of the plume of contamination. Commentators believed that it may
be impossible to define the plume at the site. Another.
commentator suggested that an off-site RI be' conducted or that
the RI for the site include evaluation of off-site sources. In
addition, one commentator questioned EPA's selection of the Site
boundary to define-the plume. "
EPA RESPONSE - USEPA agrees that once TCE has migrated from the
Raymark site it most likely mixes with area wide contamination.
site-related contaminants may be indistinguishable from similar
contaminants released from other potential sources. EPA does not
assume, however, that the Raymark Site boundaries delineate. the
targeted plume. The plume beneath Hatboro may result from b
several sources. The remedial alternatives evaluated by EPA
'5
'.
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would prevent contaminants from the Raymark site from further
contaminating the aquifer. Typically, an RI/FS focuses on the
extent of contamination from a single Site. The extent to which
the contaminants from a single site mix with contami~ants from
other sources of contamination to the aquifer are difficult to
determine and beyond the scope of a site-specific RI/FS.
However, background contamination is considered in the
development and selection of remedies to address site-related
contamination. since the contamination which originates from the
site may mix with contamination from other sources within the
aquifer once it migrates beyond~he Site boundary, EPA may use
the site boundary to define the point at which the cleanup goals
would be met. . .
4. Comments received questioned whether EPA could meet its
cleanup goals and questioned expenditure of funds to remediate
the aquifer if cleanup or remedial goals could not be achieved.
The 20-year remediation timeframe was also questioned as it
pertained to achieving cleanup goals. In addition, one
commentator indicated that on-Site pumping may not prevent.
contaminants from migrating off-Site. Another,commentator
suggested that without an RI, EPA can not state that the Site is
a major source of contamination to the aquifer.
. .
EPA RESPONSE - EPA would remediate ground water, and continue to
remediate ground water, until the cleanup goals are met, if
practicable. The cleanup goals are determined by applicable or
relevant and a~propriate requirements (ARARs) of Federal and
State environmental laws. For example, ground water remediation
would continue until "background" ground water quality is
achieved pursuant to 25 PA Code Section 264.90 through 264.100,
i.e., until the Site no longer contributes contamination to the
aquifer above background levels, if practicable. If EPA
determines, during the course of remediation that the cleanup
goals may not be achieved, a waiver of the ARAR may be invoked.
For comparison purposes, EPA calculated the remediation timeframe
to be 20 years. Within 20 years, the ground water beneath the
site may be cleaned to ARAR levels, but the ground water beneath
Hatboro may not. EPA expects to design a remedy which would
enable cleanup goals to be achieved. It certainly is possible
that the remedy designed may not prevent all contaminants from
migrating from the site. However, if the remedy is not working,
as determined by EPA, the operation or design may be modified
such that the cleanup goals may be achieved. The results of
water level recording in 1987 and 1989, and packer testing and
geophysical logging conducted at well PF-1 and/or well H2 in
1989, indicate that the Site is a significant source of
contamination to the aquifer and that ground water from the site
flows towards contaminated public wells..
6
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5. A citizen inquired whether the carbon filter units to be
installed on the ~ir stripping towers would be similar to
granular activated-carbon water filter systems simil~r to those
that could be purchased by homeowners. Do the filters remove TCE
from water?
'. . .
EPA RESPONSE - The units are the same in principle. The
con~aminants are removed from the media (air or water) passing
through the filter. The units to be installed on the air
strippers will remove TCE from the air. A homeowner's unit
should remove TCE from water.
'.
6. One commentator suggested that the air emissions from the air
stripper be routinely tested and that the surface water be tested
to determine effects from the discharge of treated water into the
Creek. . .
EPA RESPONSE - The selected remedy includes periodic sampling to .
ensure that the treatment units are functioning properly. The
air emissions from the air strippers would be treated by vapor '.
phase carbon adsorption units. Stream sampling will be conducted
both before and after the remedy is implemented.
ENFORCEMENT ISSUES
1. Comments received suggested that the.'remedial alternatives
outlined in the Proposed Plan were inconsistent with the remedy
contained within the Consent Decree. The. Consent Decree required
one air stripper to be installed at Hatboro well H1, H2 and/or H3
and one air stripper at Hatboro well H16. The FFS now proposes
to construct extraction wells at the Site.
EPA RESPONSE - USEPA has included the provisions of the Consent
Decree in the remedial alternatives discussed in the FFS and the
Proposed Plan. Alternatives which include off-Site ground water
control include pumping and treating at Hatboro public supply
wells to contain the plume within its current boundary. In.
addition, the FFS evaluated remedial alternatives which included
. on-Site ground water pumping. USEPA believes, based upon
information obtained after.the Consent Decree was entered, e.g.,
packer testing and geophysical logging at well PF-1 and/or H2,
that pumping ground water contaminated by the site solely at
Hatboro public wells would not satisfactorily remediate the
aquifer. Thus, the FFS and Proposed Plan contain alternatives
which provide for control of the Raymark Site, i.e., prevent
contaminants from further migrating off-Site, and provide for
aquifer remediation. The on-site extraction wells discussed in
the FFS may not necessarily be installed for the purpose of
ground water remediation. The FFS evaluates methods of
remediating on-Site ground water and preventing ground water
beneath the Site from migrating towards public wells.
7
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I
I
OTHER
'.
1. One commentator suggested that the shallow ground water at the
Site does no~ pose a threat to public health because the Hatboro
public wells are treated. Consequently, the commentator
suggests, there is no reason to proceed with remediation of
ground water until the source of the contamination is addressed.
EPA RESPONSE - The ground water-at the site continues to pose an
unacceptable risk. Ground water beneath the Site, which is
contaminated at unacceptable levels (e.g., 10-4 excess lifetime
cancer risk range) migrates towards public wells. without.
implementation of the remedial alternatives developed for OU2 and
OUJ, the contaminants would continue to migrate towards the
public wells and pose an unacceptable health risk to potential
future users of the aquifer.
8
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'.
'.
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
RAYMARK
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
"
I..
SITE IDENTIFICATION
1.
"
2 .
3.
4 .
5.
6.
7 .
8.
Report: Report of Study & Investigation, Industrial
Waste Treatment, Penn Rivet and Machine Co.,
prepared by W. H. & L. D. Betz, 3/10/47. P. 100001-
100009. A certificate of analysis is attached.
Application Relative to Treatment of Discharge of
Industrial Wastes, 1/26/48. P. 100010-100012.
Notes on the
Machine Co.;
set of notes
the Sanitary
Office Conference for Penn Rivet &
2/10/48. P. 100013-100015. Another
on the conference and a "Resolution of
Water Board" are attached.
"
Report: . Revised Engineering Report, Industrial
Waste Treatment, prepared by W. H. & L.' D. Betz,
2/20/48. P. 100016-100028.
Letter to Mr. Charles B. Marks, Jr., Borough of
Hatboro, from Mr. Max U. Priester, W. H. & L. D.
Betz, re: Application for permission to discharge
treated wastes, 2/24/48. P. 100029-100030.
Agreement between the Borough of Hatboro and Penn
Rivet & Machine Co., 9/7/48. P. 100031-100033.
Report of Chemical Analysis for Treatment Tank
Effluent, 6/9/4~. P. 100034-100038.
Letter to Mr. Wesley Benzee, Milford Rivet & Machine
Co., from Mr. Max. U. Priester, Betz Laboratories
Inc., re: . Supervisory Contract, 2/29/60.
P. 100039-100041. Some sampling data sheets, a
letter and another sampling data sheet are attached.
*
Administrative Record file available 8/16/90.
Note: Company or organizational affiliation is identified in
the index only when it appears in the file.
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9. Letter to Mr. Franklin Sahm, Milford Rivet & Machine
Co., from Mr. Max U. Priester, Betz Laboratories,
Inc., re: Industrial Waste Plant Supervisory
Contract, 8/25/64. P. 100042-100061. Supporting
data and five monthly visit letters with sampling
data are attached.
10. Waste Inspection Report for Milford Rivet at
Jacksonville Road, 7/15/70. P. 100062-100062.
o
11. Hand sketch by C. Peterson, Milford Rivet & Machine
Co., 7/26/70. P. 100063-100064. Another sketch of
a fence is attached.
12. Handwritten Waste Inspection Report for Milford
Rivet & Machine Co., 9/10/71. P. 100065-100065.
13. Letter to Miss Charlotte E. Peterson, PADER, from
Mr. Richard J. Walker, Milford Rivet & Machine Co.,
re: Application for a permit, 12/8/71. P. 100066-
100066.
14. Letter to Miss Charlotte E. Peterson, PADER, from T.
F. Sahm, Milford Rivet & Machine Co., re: Violation
notice received, 1/24/72. P. 100067-100067.
15. Report: Plating Room Wastes, Milford Rivet &
Machine Co., prepared by William E. Graul, 4/7/72.
P. 100068-100076. Another report with two sketchs
are attached.
16. Letter to Mr. Terry Fabian, PADER, from Mr. William
E. Graul, re: Milford Rivef & Machine Co. Remedial
Action, 6/1/72. P. 100077-100077.
17. Letter to Mr. William E. Graul from Mr. John F.
Daly, Jr., re: Elimination of waste impoundments,
6/9/72. P. 100078-100078.
18. Letter to Mr. John F. Daly, Jr., PADER, from Mr.
William E. Graul, re: Industrial wastes at Milford
Rivet &.Machine Co., 6/19/72. P. 100079-100079.
19. Waste Discharge Inspection Report, 7/10/72.
P. 100080-100080.
-------
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
Letter to Mr. p. Mangialardi, PADER, from Mr. Carl
L. Meyers, William F. Lotz Inc., re: Confirmation
of verbal agreement, 11/7/72. P. 100081~100081.
Waste Discharge Inspection Report, 11/3/72.
P...100082-100082.
'.
Letter to Mr. Car~ L. Meyers, William F. Lotz,
from Mr. John F. Daly Jr., re: Status of the
impoupdments, 12/19/72. P. 100083-100083.
I nc . ,
Report: Operating Manual for H-VW-M Cyanide Waste
Treatment Unit, Milford Rivet & Machine Co.,
1/17/73. P. 100084-100093.
Waste Discharge Inspection Report, 3/7/73.
P. 100094-100094.
Letter to Mr. Don Mangialardi, PADER, from Mr. Carl--
L. Meyers, William F. Lotz, Inc., re: Status of
impoundments and sewage treatment plant, 3/15/73.
P. 100095-100095.
Letter to Mr. Carl L. Meyers, William F. Lutz [sic],
Inc., from Mr. Richard W. Pfaehler, re: Status of
impoundments, 4/5/73. P. 100096-100096.
Letter to Mr. Richard W. Pfaehler, PADER, from Mr.
Carl L. Meyers, William F. Lotz, Inc., re:
Elimination of impoundments, 4/13/73. P. 100097-
100097.
Letter to Mr. Carl L. Meyers, William S. Lutz [sic],
Inc., from Mr. Richard W. Pfaehler, re: Elimination
of Industrial Waste Impoundments, 5/18/73. P.
100098-100098.
Letter to Mr. Richard W. Pfaehler, PADER, from Mr.
Carl L. Meyers, William F. Lotz, Inc., re: Removal
of sludge from lagoons, 5/25/73. P. 100099-100099.
Letter to Mr. Carl L. Meyers, William S. Lutz [sic],
Inc., .from Mr. Richard W. Pfaehler, re: Complete
removal of sludge, 6/25/73. P. 100100-100100.
Letter to Mr. Richard W. Pfaehler, PADER, from Mr.
Carl L. Meyers, William F. Lotz, Inc., re:
Completion of sludge removal, 7/20/73. P. 100101-
100101.
3
-------
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
Letter to Mr. C~r1 L. Meyers, William S. Lutz [sic],
from Mr. Richard W. Pfaeh1er, PADER, re: Complete
destruction of the sludge impoundments, '8/16/73.
P. 100102-100102.
Letter to Mr. Richard W. Pfaehler, PADER, from Mr.
Carl L. Meyers, William F. Lotz, Inc., re:
Completion of grading & seeding, 10/16/73.
P. 100103-100103.
Waste Discharge Inspection Report, 12/7/73.
P. 100104-100104.
Memorandum to Mr. Michael Musheno from Mr. Ben Lacy,
re: Sampling program for general scan for TCE and
PCE, 11/7/79. P. 100105-100106.
Memorandum to Mr. Michael Musheno from Mr. Ben
Lacey, re: Obtaining of a map, TCE analysis and
identification of potential groundwater polluters,
11/7/79. P. 100107-100108.
. .
Memorandum to Mr. Walter Lee, U.S. EPA, from Mr.
Daniel K. Donnelly, U.S. EPA, re: Analyst's report
for FID screens, 11/13/79. P. 100109-100109.
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. Frederick Dreisch, U.S. EPA, re: TCE Screens on
FID, 11/13/79. P. 100110-100110.
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. Frederick Dreisch, U.S. EPA; re: Screening of
samples, 11/26/79. P. 100111-100111.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Analysis results, 11/27/79. P. 100112-
100112.
Memorandum to Mr. Larry A. Parker, U.S. EPA, from
Mr. William F. Gersting, U.S. EPA, re: Volatiles
data for ~CE & PCE for samples #79112901-79113010,
12/21/79. P. 100113-100134. An Analysis Request
and Result Form for each sample is attached.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Bucks County Groundwater Contamination
Investigation, 12/14/79. P. 100135-100138.
4
-------
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
Memorandum to Mr. Daniel Donnelly, u.s. EPA, from
Mr. Frederick .Dreisch, U.S. EPA, re: TCE & PCE
report,.. 12/14/79. P. 100139-100140. TC~ & PCE
results are attached.
Memorandum to Mr. Daniel Donnelly, U..S. EPA, from
Mr'- Rick Dreisch, U.S. EPA, re: Table of sample
results, 12/17/79. P. 100141-100143. Two pages of
sample results are attached.
Memorandum to Mr. Daniel Donnelly, U.S. EPA, from
Mr. Frederick Dreisch and Ms. Marilyn Gower, U.S.
EPA, re: TCE Screens, 12/27/79. P. 100144-100146.
Two pages of sample results are attached.
"
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Continuation of Bucks County
Investigation, 1/3/80. P. 100147-100148.
'.
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. Frederick Dreisch and Ms. Marilyn Gower, U.S.
EPA, re: Warminster Hatboro Sample TCE Analysis,
1/16/80. P. 100149-100149. .
Letter to Mr. Stephen W. Saul, SMC Martin, from Dr.
Gerald R. Umbreit, Greenwood Labdratories, re:
Examination of water samples for trichloroethylene
content, 2/5/80. P. 100150-100150.
Final Strategy Determination Form for Hatboro Site,
prepared by W. Lee, 2/10/80. P. 100151-100152.
Memorandum to Mr. Jeff Haas, U.S. EPA, from Mr.
Ramon G. Lee, U.S. EPA, re: Monitoring of Hatboro
Municipal Authority for Sources of TCE
Contamination, 3/19/80. P. 100153-100153.
Letter to Mr. Ramon G. Lee, U.S. EPA, from Mr.
Robert C. Schmauk, Hatboro Borough Authority, re:
Sampling results, 3/19/80. P. 100154-100155.
Letter to Mr. Newton Finney, Hatboro Borough
Authority, from Mr. Albert F. Zimmerman, Quality
Control Laboratory Division, re: Raw Sewage
Samples, 4/2/80. P. 100156-100158. Two pages of
previous sampling data are attached.
"
5
-------
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
Letter to Mr. Newton Finney, Hatboro Borough
Authority, from Mr. Albert F. Zimmerman, Quality
Control Laboratory Division, re: Water ..sampling
data, 4/2/80. P. 100159-100159.
Letter to Mr. C. Newton Finney, Hatboro Borough
Authority, from Mr. Albert F. Zimmerman, Quality
Control Laboratory, re: Water sampling results.
4/16/80. P. 100160-100160.
Letter to Mr. Newton~Finney, Hatboro Borough
Authority, from Mr. Albert Zimmerman, Quality
Control Laboratory, re: Well sampling data,
4/29/80. P. 100161-100161.
Letter to Mr. C. Newton Finney, Hatboro Borough
Authority, from Mr. Albert F. Zimmerman, Quality
Control Lab, re: Bacteriological Water Analysis
Report, 4/29/80. P. 100162-100162.
Letter to Mr. C. Newton Finney, Hatboro Borough
Authority, from Mr. Albert Zimmerman, Quality
Control Lab, re: Well sampling data, 6/13/80.
P. 100163-100163.
Letter to Mr. Ramon G. Lee, U.S. EPA, from Mr. C.
Newton Finney, Hatboro Borough Authority, re:
TCE/PCE Contamination, 7/17/80. P. 100164-100165.
Technical Direction Document prepared by Ecology and
Environment Inc. for Plasti Seal Corp., re: Water
and Soil Sampling, 8/15/80. P. 100166-100166.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Telephone conversation with Dick Walker of
Milford Rivet, 9/15/80. P. 100167-100167.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Sampling data from Mander Stove Well,
9/23/80. P. 100168-100169.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Analytical results, 9/25/80. P. 100170-
100170.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Continued investigation, 10/1/80.
P. 100171-100171. -
6
-------
68.
69.
70.
71.
72.
64.
Memorandum to .Fi1e from Mr. Michael Musheno, U.S.
EPA, re: Bi-month1y TCE monitoring, 10/2/80.
P. 100172-100172. "
65.
Memorandum to File from Mr. Michael Musheno, U.S.
EPA, re: Graph summarizing sample results, 10/7/80.
P. 100173-100174.
66.
Technical Direction Document No. F3-8006-11A,
Ecology & and Enviro~ment Inc. for Plasti Seal Well
Drilling, 1/14/81. P. 100175-100175.
67.
Letter to Mr. Ron Namon, Ecology & Environment, from
Mr. William Jefferys, A.C. Schultes & Sons Inc., re:
Well Drilling Report, 2/26/81. P. 100176-100197.
The following are attached:
a)
b)
the Drilling Report;
a letter regarding the Monitor Wells
project; .
five Single Case Well Log sheets;
two Sample Log sheets;
two tables;
four Preparation Parameter Results &
Extracts sheets;
a sketch of Well #5;
three sample analysis results.
c)
d)
e)
f)
g)
h)
Acknowledgement of completion for TDD, 3/26/81.
P. 100198-100198.
Notification of Hazardous Waste. Site, U.S. EPA, to
Milford Rivet & Machine Co., 6/12/81. P. 100199-
100200.
Report: Investigation of Test Well Sites, Hatboro
Borough, Montgomery County, PennsYlvania, prepared
by Walter B. Satterthwaite Associates, Inc., 7/81.
P. 100201-100217.
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. James Jerpe, U.S. EPA, re: Ha1oform Analysis in
Drinking Water, 10/19/81. P. 100218-100220. Two
tables of sampling .data are attached.
Memorandum to File from Mr. Robin Aitken, U.S. EPA,
re: Field activities, 9/28/81. P. 100221-100221.
"
7
-------
73.
74.
75.
76.
77.
78.
79.
80.
81.
.
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. James Jerpe, U.S. EPA, re: Analyses of water
samples, 12/24/81. P. 100222-100247. '~he
following are attached:
fifteen Analysis Request and Result Forms;
five pages of handwritten notes;
a replacement parts list;
the Operating Procedure & Technique for
Kemmerer W~ter Samplers.
Memorandum to File from Mr. Robin Aitken~ U.S. EPA,
re: Field activities, 5/7/82. P. 100248-100248.
a)
b)
c)
d)
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. James Jerpe, U.S. EPA, re: Haloform Analyses,
5/11/82. P~ 100249-100250. A Chain of Custody
Report is attached.
Memorandum to Mr. Robin Aitken, U.S. EPA, from Mr.
Daniel K. Donnelly, U.S. EPA, re: Penn Fastener
report, 5/21/82. P. 100251-100253. The report is
attached.
Letter to Ms. Susan L. Gordon, Morgan, Lewis &
Bockjus, from Mr. John R. Ousey Jr., Betz, Conversr
" .
& Murdoch Inc., re: Results of Evaluation of Pum~
Test, 6/10/82. P. 100254-100258. .
Letter to Ms. S~san L. Gordon, Morgan, Lewis &
Bockius, from Mr. John R. Ousey Jr., Betz, Converse
& Murdoch, Inc., re: Results and Evaluation of Soil
Sampling for TCE, 6/30/82. P. 100259-100261.
Letter to Ms. Susan L. Gordon, Morgan, Lewis &
Bockius, from Mr. John R. Ousey, Jr., BCM Inc., re:
Review of Trend Clauses, 7/26/82. P. 100262-100265.
Site Inspection Report for Jacksonville Road Site,
6/9/83. P. 100266-100276.
Memorandum to File frcm Mr. Howard o. Wilson, U.S.
EPA, re: Multi-depth Sampling of Penn Fastener Inc.
and Mander Stove Company Wells, 9/19/83. P. 100277-
100281. Tables A through D of sampling results are
attached. .
8
-------
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
Memorandum to Raymark File from Mr. Robin Aitken,
U.S. EPA, re: ..Summary of meeting, 10/25/83. P.
100282-100282.
Memorandum to Mr. Robin Aitken from Mr. S. Stephen
Platt, U.S. EPA, re: Drilling and Sampling
Specifications, 12/5/83. P. 100283-100285.
'.
Letter to Mr. John D. Cooper, U.S. EPA, from Mr.
Eugene N. Cipriani, SEPTA, re: SEPTA Right-of-Way
Agreement, 4/26/84. -Po 100286-100292. The
agreement is attached.
Letter to Mr. Robin Aitken, U.S. EPA, from Mr.
Richard M. Cromer, NUS Corp., re: Drilling
Operations, 4/27/84. P. 100293-100320. A report on
technical specifications for the drilling of
boreholes is attached.
Letter to Mr. Robin Aitken, U.S. EPA, from Mr. David
L. Woglom, Borough of Hatboro, re: Granting of
permission to drill monitoring wells, 4/28/84.
P. 100321-100321.
Memorandum to Mr. Garth Glenn, u.S. EPA, from S.
Stephen Platt, U.S. EPA, re: Recommended
Alternative for Raymark Enforcement Case, 9/13/84.
P. 100322-100324. . .
Letter to Mr. Martin Howe, NUS Corp., from Mr.
Daniel K. Donnelly, U.S. EPA, re: Organic Analysis
Report, 11/26/84. P. 100325-100333. The report is
attached. .
Report: Focused Feasibility Study - Final Report,
prepared by PRC Environmental Management, Inc.,
3/20/85. P. 100334-100434 .
Letter to Ms. Paula Luborsky, U.S.
Eric Lee Edelstein, GCA Corp., re:
Site, 9/12/85. P. 100435-100438~
attached.
EPA, from Mr.
Maps for Raymark
Three maps are
Memorandum to File from Ms. Paula Luborsky, U.S.
EPA, re: Ground Water [sic] and Soil Sampling,
10/29/85. P. 100439-100439.
'.
9
-------
92.
93.
94.
95.
96.
97.
98.
99.
Report: Plan for the Removal of TCE from Authority
Wells 1,2,3,7,' 12 & 16, prepared by Robert D.
Gilmore & Associates, Inc., 1/86. P. 10P440-100447.
Report: Review of TCE Contamination Site, Hatboro,
Pennsylvania, prepared by John R. Ousey, Jr., 2/86.
P. 100448-100472.
Report: Raymark Corporation Focused Feasibility
Study - Addendum, prepared by PRC Environmental
Management, Inc., 3/11/86. P. 100473-100521.
Letter to Ms. Paula Luborsky, U.S. EPA, from Mr.
Daniel T. Chow, PRC Engineering, re: EP Toxicity
Calculation, ~/28/86. P. 100522-100523.
Site Inspection Report, 6/19/86.
P. 100524-100536.
Report: Focused Feasibility Study - Final Addendumi-
prepared by PRC Environmental Management, Inc.,
11/11/86. P. 100537-100587.
Chain of Custody Documentation, 11/21/86.
P. 100588-100588.
Hand-sketch of locations of drill sites, 11/19-
22/86. P. 100589-100598. Sampling result data are
attached.
100. Memorandum to File from Ms. Paula Luborsky, U.S.
EPA, re: Off-site Remediation Proposal, 12/9/86.
P. 100599-100599.
101. Letter to Mr. David Street, Department of Justice,
from Dr'. Michael C. Hadka, Walter B. Satterthwaite
Associates, Inc., re: Results for soil borings from
Wells A2 & A3, 12/10/86. P. 100600-100685. A
report of the samples is attached.
102. Letter to Ms. Susan Dein Bricklin, U.S. Department
of Justice, from Mr. Stan Feenstra, Zenon
Environmental Inc., re: Soil sampling procedures,
12/12/86. P. 100686-100689.
103. Memorandum to Ms. Paula Luborsky,u.s. EPA, from Mr.
John Austin, U.S. EPA, re: Metals Report, 12/16/86.
P. 100690-100700. The report is attached.
10
-------
104. Memorandum to Mr. Jim Vickery, U.S. EPA, from Mr.
John Austin, U'~S. EPA, re: Soil Analysis for
Volatile Organics, 12/22/86. P. 100701-100702.
105. Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Edward R. Schuessler, PRC Environmental Management,
Inc'., re: Draft Letter Report on Remedial
Alternatives, 1/22/87. P. 100703-100707.
"
106. Letter to, Ms. Gerallyn Valls, U.S. EPA, from Mr.
Edward R. Schuessler; PRC Environmental Management,
Inc., re: . Historical Summary of Environmental
Sampling, 1/23/87. P. 100708-100714. The
Historical Summary is attached.
107. Memorandum to Mr. John Austin, U.S. EPA, from Mr.
Ronald H. Altman, U.S. EPA, re: Mercury
determination of samples, 1/27/87. P. 100715-
100720. Five Chain of Custody Records are
attached.
108. Memorandum to Ms. Gerallyn Valls, U.S. EPA, from Mr.
John Austin, U.S. EPA, re: Analytical reports,
1/28/87. P. 100721-100772. The reports are
attached.
109. Letter to Mrs. Susan Dein Bricklin, U.S. Department
of 'Justice, from Mr. Stan Feenstra, Zenon
Environmental Inc., re: Results of Site
Investigation, 1/30/87. P. 100773-100794. Table A,
Table B, and Appendices A & B are attached.
110. Memorandum to Mr. John Austin, U.S. EPA, from Mr.
Stephen E. Buchanan, U.S. EPA, re: Dissolved Metals
Determinations, 1/30/87. P. 100795-100799. The
sample data and a groundwater sample location map
are attached.
111. Memorandum to Mr. John Austin, U.S. EPA, from Mr.
Stephen E. Buchanan, U.S. EPA, re: Total Metals
Determinations, 1/30/87. P. 100800-100807. The
sample data results are attached.
112. Report: Conceptual Design & Preliminary Cost
Estimate for Removal of Trichloroethylene, prepared'
by Camp Dresser & McKee, 2/27/87. P. 100808-100827.
"
11
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113. Memorandum to Ms. Gerallyn Valls, from Mr. James
Barron~ re: ~~ratum for VOA report, 3/3/87.
P. 100828-100829. A copy of another memorandum is
attached. .
114. Report: Evaluation of the Penn Fasteners Site,
Hatboro, PA, prepared by Triegel Associates, Inc.,
3/17/87. P. 100830-100849.
115. Report: Report Concerning the Use of Degreasers &
Trichloroethylene and the Use of Degreasers At the
Plant in Hatboro, Pennsylvania, prepared by Dr.
Ralph G. Smith, 3/19/87. P. 100850-100863.
116. Facsimile transmittal cover page
Valls from Ms. Diana Baldi, re:
procedure for Volatile Organics,
100864-100865. .
to Ms. Gerallyn
Modified sampling
10/16/87. P.
117. Letter to Ms. Gerallyn Downs-Valls, U.S. EPA, from
Mr. Stephen J. Medlar, CDM, re: Air pollution
control system, 5/12/87. P. 100866-100868.
118. Letter to Ms. Gerallyn Downs-Valls, U.S. EPA, from
Mr. Stewart Abrams, CDM, re: Updated Air Pollution
Control Costs, 6/24/87. P. 100869-100871.
119. Memorandum to File from Mr. 'Michael Musheno, U.S.
EPA, re: Sampling program for groundwater.
contamination, (undated). P. 100872-100873.
120. Hand-drawn sketch of Batch Treatment Plants,
(undated). P. 100874-100874. '
121. Water or Waste Quality Report, (undated).
P. '100875-100876.
122. Certified mail receipt to Mr. Carl L. Meyers,
(undated). P. 100877-100877.
123. Certified mail receipt to the Bureau of Water
Quality Management, (undated). P. 100878-100879.
124. Report: Trichloroethylene Analyses in Soil and
Groundwater Samples Taken in the Vicinity of the
Penn Fasteners Site, Hatboro, Pennsylvania,
(undated). P. 100880-100885.
"
12
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II.
REMEDIAL ENFORCEMENT PLANNING
2 .
3.
. 4 .
5.
1.
Letter to Mr. Milford Rivet from Mr. "Jac"k J.
Schramm, U.S. EPA, re: Request for information on
TCE presence, 11/19/79. P. 200001-200005.
Letter to Mr. Joseph Armoa, U.S. EPA, from Mr.
Richard Walker, Milford Rivet & Machine Co., re:
Response to request for information, 11/27/79.
P. 200006-200007.
".
Letter to Mr. Robert Brook, from Mr. James Sheehan,
U.S. Department of Justice, re: Transmittal of the
Consent Decree, 11/29/84. P. 200008-200033. A
Remedial Action Plan is attached.
Letter to Ms. Paula Luborsky, u.S. EPA, from Mr."
Eric Lee Edelstein, GCA Corporation, re: Site Deeds
for Parcel 3 (Road's Van Service), 1/16/86.
P. 200034-200100. The deeds are attached.
Consent Decree between Hatboro Borough Authority and
Raymark Industries, Inc., 1/25/89. P. 200101-
200146.
'.
13
-------
III. REMEDIAL RESPONSE PLANNING
1.
2.
3.
4.
5.
6.
7 .
8.
9.
10.
11.
Report: Preliminary Summary of Availabl~ Soil Data
for the Raymark Site, prepared by CH2M Hill,
2/21/89. P. 300001-300063. .
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Charles R. Wood, U.S. Department of the Interior,
re: Work Plans, 3/20/89. P. 300064-300066.
Letter to Mr. J. NewDold, PADER, from Ms. Gerallyn
Valls, U.S. EPA, re: A ten-hour packer test,
3/22/89. P. 300067-300068.
Report: Final Sampling & Analysis Plan, prepared by
CH2M Hill, 4/89. P. 300069-300141.
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Joseph A. Feola, PADER, re: Response regarding ten~.
hour packer test, 4/7/89. P. 300142~300142.
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Charles R. Wood, U.S. Department of the Interior,
re: Quality Assurance plan for the packer testing,
4/11/89. P. 300143-300153. The work plan and
geophysical logs are attached.
Letter to Ms. Bonnie Guy Gross, U.S. EPA, from Mr.
Jay Newbaker, PADER, re: Comments on RI/FS Draft
Work Plan, 4/21/89. P. 300154-300155.
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Charles R. Wood, U.S. Department of Interior, re:
u.S. Geological Survey's Geophysical Log, 5/2/89.
P. 300156-300157.
Letter to Ms. Gerallyn Valls, u.S. EPA, from Mr.
Charles R. Wood, u.S. Department of the Interior,
re: Replotted Temperature Log, 5/12/89. P. 300158-
300167. . The logs are attached.
Memorandum regarding geophysical logs, 5/12/89.
P. 300168-300174. The logs are attached.
Report: Raymark Remedial Design Final-Enforcement
Support Work Plan, prepared by CH2M Hill, 5/17/89.
P. 300175-300195. .
14
-------
12.
13.
14.
15.
16.
17.
18.
Memorandum to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Michael.Towle, .U.S. EPA, re: Hydrogeologic Analysis
of Diagnostic Testing, 5/23/89. P. 3001~6-300213.
A Field Report is attached.
Handwritten memorandum to Raymark File from Ms.
Bonnie Gross, U.S. EPA, re: Analytic Method for VOA
Analysis of Soil Samples, 5/25/89. P. 300214-
300215..
"
Letter to Mr. Joseph-Cleary, CH2M Hill, from Ms.
Bonnie Guy Gross, U.S. EPA, re: Testing for dense
non-aqueous phase liquids in unsaturated fractured
bedrock, 5/30/89. P. 300216-300234. The following
are attached:
a)
a letter regarding a Draft RI/FS Work
Plan;
a page from a report with changes made on
it;
a report on Field Aqueous Stabilization of
Volatile Organics in Solids;
a Surface Water & Sediment Investigation;
a Well Questionnaire;
a Horne Well Survey;
a letter regarding Dra!t RI/FS Work Plan
comments. .
b)
c)
d)
e)
f)
g)
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Albert L. Herrmann, Hatboro Borough Authority, re:
Discontinued use of Well #2, 6/20/89. P. 300235-
300235.
Letter to Ms. Bonnie Guy Gross, U.S. EPA, from Mr.
Joseph G. Cleary, CH2M Hill, re: Statistical
Analysis of Well Point Sampling Program, 6/29/89.
P. 300236-300237.
Letter to Ms. Bonnie Guy Gross, U.S. EPA, from Mr.
Joseph G. Cleary, CH2M Hill, re: Statistical
Analysis of Well Points Sampling Program, 6/30/89.
P. 300238-300242. A table and an Area of DNAPL
Investigation are attached.
Letter to Ms. Bonnie Guy Gross, U.S. EPA, from Mr.
Joseph G. Cleary, CH2M Hill, re: Water
stabilization method comments, 7/6/89. P. 300243-
300244.
15
-------
19.
20.
21.
*
22.
23.
24.
25.
26.
Letter to Ms. Bonnie Guy Gross, U.S. EPA, from Mr.
Joseph G. Cleary, CH2M Hill, re: X-ray Fluorescence
Method comments, 7/18/89. P. 300245-300248.
Letter to Ms. Gerallyn Valls, U.S. EPA, from Mr.
Charles R. Wood, U.S. Department of the Interior,
rei Data and graphs for packer testing, 7/20/89.
P. 300249-300307. The data & graphs are attached.
Letter to Mr. Robert Todd, Hatboro Water Authority,
from Ms. Gerallyn Valls, U.S. EPA, re: Proposed
Scope of Work for pumping test, 7/21/89. P. 300308-
300312. A memorandum and a Proposed Scope of Work
for pumping tests are attached.
Letter to Mr. Mike Towle, U.S. EPA, from Mr.
Wood, U.S. Department of the Interior, re:
Transmittal of geophysical logs, 7/26/89.
P.300313-300315.
Charles
Memorandum to Mr. Mike Towle, U.S.
Claudia P. Walters, U.S. EPA, re:
VOC Preservation Method, 10/30/89.
300331. A report is attached.
EPA, from Ms.
QA Review of Soil
P. 300316-
Letter to Mr. Mike Towle, U.S. EPA, from Mr. Joseph
[sic] G. Cleary, CH2M Hill, re: Minutes of Raymark
RI/FS Rescoping Meeting on October 30, 1989,
11/3/89. P. 300332-300338. The minutes are
attached. .
Letter to Mike Towle, U.S. EPA, from Ms. Jan
Valeriano, Gilmore & Associates~ Inc., re: Air
Stripper Design Parameters, 11/21/89. P. 300339-
300589. The Sample Analysis History for Well #16 is
attached.
Report: Sampling and Analysis Plan for Soil Gas
Survey for the Raymark Source Control RI/FS,
prepared by CH2M Hill, 12/1/89. P. 300590-300623.
*
The geophysical logs can be found at U.S. EPA Region III
Headquarters in Philadelphia.
16
-------
32.
33.
34.
35.
36.
37.
27.
Letter to Mr...Michael Towle, U.S. EPA from Mrs. Dawn
DeBiasse, CH2M Hill, re: Surface Soil Sampling for
the Remedial Investigation and Feasibility Study,
1/3/90. P. 300624-300631. A Surface Soil Sample
Locations graph, two Chain of Custody reports and,
two Sample Shipping Logs are attached.
'.
28.
Memorandum to .Distribution from Mr. Michael Towle,
U.S. EPA, re: Final draft of the work plan,
1/29/90. P. 300632-~00774. The report is attached.
29.
Report: Final Field Trip Report for Groundwater
Sampling, prepared by CH2M Hill 2/12/90. P. 300775~
300839.
30.
Memorandum to Ms. Carla Dempsey, U.S. EPA, from Ms.
Patricia J. Krantz, U.S. EPA, re: Data Review,
3/13/90. P. 300840-300873. The Data Review is
attached.
'.
31.
Letter to Mr. Mike Towle, U.S. EPA, from Ms. Jan A.
Valeriano, Gilmore & Associates Inc., re: Well H-16
Air Stripper Design, 3/23/90. ~. 300874-300875.
Letter to Ms. Bonnie Scully, PADER, from Mr. Michael
Towl~, U.S. EPA, re: Focused Feasiblity Study and
its Addendum, 3/26/90. P. 300876-300877.
Letter to Mr. Michael Towle, U.S. EPA, from Ms.
Bonnie T. Scully, PADER, re: Comments on the RI/FS
Draft Final Work ,Plan, 3/27/90. P. 300878-300880.
Letter to Ms. Bonnie Scully, PADER, from Mr. Michael
Towle, U.S. EPA, re: Reviewing of Sampling &
Analysis Plan, 4/4/90. P. 300881-300881.
Letter to Mr. Michael Towle, U.S. EPA, from
Ms. Bonnie J. Scully, PADER, re: PADER approvals
for proposed pump test, packer tests and soil vapor
extraction pilot study, 4/13/90. P. 300882-300883.
Letter to Mr. Joseph Cleary, CH2M Hill, from Mr.
Michael Towle, U.S. EPA, re: Comments to the
Sampling and Analysis Plan, 4/20/90. P. 300884-
300885.
Letter to Ms. Bonnie Scully, PADER, from Mr. Michael
Towle, U.S. EPA, re: Focused Feasibility Study &
Final Addendum, 4/20/90. P. 300886-300887.
17
-------
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
Letter to Mr. joseph Cleary, CH2M Hill, from Mr.
Michael Towle, U.S. EPA, re: Treated anQ raw water
sampling data, 4/25/90. P. 300888-300916. The
sampling data is attached. .
Letter to Ms. Bonnie Scully, PADER, from Mr. Michael
Towle, U.S. EPA, re: Information related to PADER
approvals, 4/25/90. P. 300917-300928.
Letter to Ms. Mindi Snoparski, U.S. EPA, from Mr.
Albert E. Becher, U.S. Department of the Interior,
re: The Work Plan for the new geophysical, 4/26/90.
P. 300929-300931.
.
Letter to Mr. Michael Towle, U.S. EPA, from Ms.
Bonnie J. Scully, PADER, re: PADER review of
Hatboro Borough Authority Well H-16 air stripper
design bid and specification documents, 5/8/90.
P. 300932-300934.
Letter to Mr. Michael Towle, U.S. EPA, from Ms.-
Bonnie J. Scully, PADER, re: Sampling and Analysis
Plan Review, 5/10/90. P. 300935-300937.
Letter to Mr. Joseph Cleary, CH2M Hill, from Mr.
Michael Towle, U.S. EPA, re: Draft Sampling and
Analysis Plan, 5/21/90. P. 300938-300939.
Letter to Mr. Joseph Cleary, CH2M Hill, from Mr.
Michael Towle, U.S. EPA, re: Approval of Draft
Technical Memorandum on the Soil Gas Survey Results,
5/21/90. P. 300940-300940. .
Letter to Mr. Michael Towle, U.S. EPA, from Mr. Joe
Cleary, CH2M Hill, re: Field Meeting Notes,
5/30/90. P. 300941-300943.
Report: Addendum to Sampling and Analysis Plan for
Raymark Site Remedial, prepared by CH2M Hill,
6/7/90. P. 300944-300983.
Letter.to Mr. Michael Towle, U.S. EPA, from Ms.
Bonnie J. Scully, PADER, re: Department approval
for packer pump and soil vapor tests, 6/11/90.
P. 300984-300985.
18
-------
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
Memorandum to. File from Mr. Michael Towle, U.S. EPA,
re: Site visit, Raymark, 6/14/90. P. 3~0986-
.300986. ...
Letter to Mr. Robert Todd, Hatboro Water Authority,
from Mr. Michael Towle, U.S. EPA, r~: Air emissions
from air stripper, 6/15/90. P. 300987-300988.
..
Report: Preliminary Health Assessment for Raymark
Site, prepared by Ag~ncy for Toxic Substances and
Disease Registry, 6/18/90. P. 300989-301002.
Letter to Ms. Bonnie Scully, PADER, from Mr. Michael
Towle, U.S. EPA, re: PADER review of Draft Ground
Water Risk Assessment and Draft Groundwater Focused
Feasibility Study, 6/22/90. P. 301003-301003.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Joseph G. Cleary, CH2M Hill, re: Criteria for
selecting soil sample, 6/26/90~ P. 301004-301005.
..
Report: Final Technical Memorandum for Soil Gas
Survey Results, Raymark Site RI/FS, prepared by CH2M
Hill, 7/90. P. 301006-301052.
Report: Addenda No.1 & No.2 Sampling & Analysis
Plan for Raymark Site Remedial Investigation & .
Feasibility Study, prepared by CH2M Hill, 7/17/90.
P. 301053-301093.
Letter to Mr~ Michael Towle, U.S. EPA, from Mr.
Joseph.G. Cleary, CH2M Hill, re: Submittal of Final
Sampling and Analysis. Plan including Addendum 1 & 2,
7/20/90. P. 301094-301589. The Final Sampling &
Analysis Plan for the RI/FS is attached.
Letter to Mr. Robert Todd, Hatboro Water Authority,
from Mr. Michael Towle, U.S. EPA, re: Potential
risks to residents, 7/27/90. P. 301590-301591.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Charles Kulp, U.S. Department of the Interior, re:
Transmittal of Endangered Species in Pennsylvania,
8/3/90. P. 301592-301593. A table of federally
listed endangered and threatened species in
Pennsylvania is attached.
19
-------
58.
59.
Letter to Mr. Michael Towle, U.S. EPA, from Mr.
Clark Shiffer,. Pennsylvania Fish Commission, re:
Transmittal of information on Endangered. Species,
8/3/90. P. 301594-301630. A brochure on endangered
and threatened species of Pennsylvania .is attached.
Requested information from the Montgomery County
Planning Commission, (undated). P. 301631-301653.
The following are attached:
a)
b)
c)
1980 consensus of population;
six zoning maps;
a comprehensive plan of Hatboro.
The following were relied upon for the Remedial
Investigation/Feasibility Study:
60.
61.
62.
63.
64.
65.
Report: Report on Plasti-Seal Monitoring Wells,
Montgomery County, PA, prepared by C. K. Lee &
Ronald M. Naman, Ecology & Environment, Inc., 1/81.
P. 301654-301671.
Report: Hydrogeologic Field Report on Well
Development & Step Test At the Raymark Site,
Hatboro, PA, prepared by GMC Associates, Inc.,
9/7/84. P. 301672-301723. .
Report: A Field Trip Report, prepared by NUS
Cprporation, 2/20/85. P. 301724-301855.
Report: Soil Sa~ling and Groundwater Sampling
Report, prepared by NUS Corporation, 1/28/86.
P. 301856-302218.
Report: Contamination by Trichloroethylene of a
Portion of the Stockton Aquifer Under the Community
of Hatboro, Pennsylvania, prepared by Robert
Giegengack, University of Pennsylvania, 2/21/86. P.
302219-302239.
Letter to Ms. Susan Dein Bricklin, U.S. EPA, from
Mr. Stan Feenstra, Zenon Environmental Inc., re:
"Review and Recommendations for Future
Investigations, Rayrnark Site", 9/26/86. P. 302240-
302286. The review is attached.
20
-------
66.
67.
68.
69.
70.
71.
72.
Letter to Mr. .David Street, Department of Justice,
from Dr. Michael C. Hadka, Walter B. Satterthwaite
Associates, Inc., re: Results of Soil Borings from
Wells A2 & A3, 12/24/86. P. 302287-302304. The
results are attached. .
Report: A Field Trip Report, prepared by NUS
Corporation, 3/11/87. P. 302305-302626.
'.
Report: Draft Lette~ Report, Data Screening for
Raymark Site, Hatboro, Pennsylvania, prepared by
PRC, 5/12/87. P. 302627-302679.
Report: A Field Trip Re?ort for Raymark, prepared
by NUS Corporation, 1/20 87. P. 302680-302815.
"
Report: Draft Focused Feasibility Study for
Groundwater Remediation, Raymark Site, prepared by .
CH2M Hill, 6/90. P. 302816-303040. .
Report: Raymark Site Draft Risk Assessment for
Contaminated Ground Water, prepared by CH2M Hill,
6/11/90. P. 303041-303092.
Letter to Mr. Joseph Cleary, CH2M Hill, from Mr.
Michael Towle, U.S. EPA, re: EPA comments on Draft
Focused Feasibility Study and Draft Risk Assessment
Report, 7/31/90. P. 303093-303100.
General Remedial Response Planning Documents
73.
Report: Proposed Plan, Raymark Superfund Site,
(undated). P. 303101-303119.
21
-------
*
V.
*
*
*
*
*
*
9.
10.
.11.
12.
...
COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
IMAGERY
1 .
Press Release entitled "Parties Associated with
Raymark Superfund Site Agree to $1,125,000
Settlement" 1/31/89. P. 500001-500002.
2.
Report: Site Analysis, Raymark, Hatboro,
Pennsylvania, prepared by Bionetics Corporation,
8/89. P. 500003-500919.
3.
Map of Proposed Aeration System, Hatboro Well No.16,
prepared by Gilmore & Associates, 1/90.
4.
Site Plan of Well No.16, prepared by Gilmore &
Associates, 1/8/90.
5.
Site Plan - Existing Conditions & Demolition Work o~
Well No. 16 Aeration System, prepared by Gilmore & .
Associates, 1/8/90.
6.
Site Plan - Proposed Facilities of Well No.16
Aeration System, prepared by Gilmore & Associates,
1/8/90. .
7 .
Section & Detail of Weli ~o. 16 Aeration System,
prepared by Gilmore & Associates, 1/8/90.
8.
1000 PPB Air Stripper & Carbon Adsorber (Retro-fit)
Well No.16 Aeration System, prepared by Gilmore &
Associates Inc., 1/8/90.
Letter to Mr. Richard J. Walker from Mr. Michael
Towle, U.S. EPA, re: Completion of RI/FS, 6/14/90.
P. 500020-500021.
Newspaper article entitled, "Hatboro To Reopen Two
Weeks," Montgomery County Record, 6/20/90.
P. 500022-500022.
Letter from Mr. Michael Towle, U.S. EPA, re:
Transmittal of the draft Proposed Plan, 7/11/90.
500023-500024. Two Airborne Express receipts are
attached.
P.
Memorandum from U.S. EPA, re: Copies of water level
graphs from Wells H2, RI, MS-10, 7/20/90.
P. 500025-500068.
This document can be found at U.S. EPA Region III-
Headquarters.
-------
i.
i
*
*
13.
*
14.
Struct~ral det~ils of Well No.16 Aeration System,
(undated) . '.
100 ppb Stripping Tower & Details of Well No.16
Aeration System, prepared by ~ilmor~ & Associates,
(undated) .
'.
This document can be found at U.S. EPA Region ITI
Headquarters.
-------
APPENDIX C
SUMMARY OF ANALYTICAL DATA FROM WELL PF-l AND
THE R-SERIES OF WELLS
'.
'.
-------
Appendix C
R Monitoring Wells
"
If a contaminant of concern was detected once in any of the R wells, a statistical
analysis was performed for this contaminant. Because all contaminants of concern
were detected at least once, a statistical analysis was performed for all contaminants
of concern. In calculating the mean and upper 9S percentile concentrations, the
following assumptiOns were made:
"
.
Results of questionable qualitative significance based upon the quality
assurance review of the data (u and "qualifiers) were assumed to be
present at half the value. .
.
For all samples where the compound was analyzed for but was not
detected, a concentration of half the detection limit was assumed.
.
Compounds that were measured below the limit of accurate
quantitation (J qualifier), were assumed to be present at the
approximate concentration measured.
On-Site Well PFI
The available data for this well was treated differently than the R wells and the off-
site H wells because the number of data points for welI PFI was limited. Specifically,
there were only three analyses on samples from this well for all contaminants of
concern except TCE. Data on TCE were available from the three sampling events
and a packer test on the well. Therefore, a meaningful statistical evaluation could not
be performed for this well. The following values were used instead in the risk
assessment: .
NJRSMU ORS6.S}
.
For cis- and trans-l,2-DCE, the maximum concentration from the three
sampling events was used. This concentration also represents the only
positive detection of the compound.
.
Vinyl chloride, PeE, and 1,1.1-TCA were not de~ected in well PFI and
therefore were not included in analyzing the risks from this well.
.
For TCE, the 1990 packer test data were used to calculate a flow
weighted average TCE concentration. This is explained in the Focused
Feasibility Study.
c.}
-------
TABLES
C-l
C-2
Conceinrations of Volatile Chemicals of Concern in Well PF1
1984-1987 Concentrations of Volatile Chemicals of Concern
in R Wells
RA YMARK3IOO8.51/4
Page
"
-------
'.
T IIIIl£ C -1 198H990
CQIICDITRRTlDIIS or UOJITIL£ CDIITIlUIIRIIT or
cmmH IN uw. Pr1
. SII1Pl£
LOCRTIDll/DftTE
Cis-l,Z-!ltE trens-1,Z-ocE
(Ppb) (ppb )
PC[
(pp!I )
l,l,l-Tes
(ppb )
TCE
rnb)
Prl/TIItRI.
1981 6 3SOO
1985 91 1500
1987 1300
19911 8700
1990 11000
1990 7100
1990 130
1990 530
1990 1110
1990 1000
--
, HOTEl This table includes only COIICen~r8tions M8sured after purging the well
for 1981, 1985, and 1987.
The 1990 data WilS obtained by pecker atpling.
- Conpound WilS analyted for, but WilS not detected.
-------
TR8l£ C-2
198H9B7 CllllCOORRTIOHS or IWlTIL£ COHTIII1HRHT
or CQHCCRH 1H R uw.S
. SII1PL£
lOCRTIOH/DRTr Cis-l,Z-Ot[ trans-1.2-DCt PC!: 1,I,HC8 TCr
(ppb) (ppb) (ppb ) (Ppb) (ppb)
----- -- --
RH1HRl
199i 5 5 5 5 3300
1985 115 125 125 115 8550
1987 250 250 250 ZSO fioo
RHIKRL
1981 5 5 5 7 120
1985 25 29 200 125 8900
1987 250 250 250 2SO 800
RHIKRL
1981 0.5 0.5 36 16 2550
1985 15 25 19 19 1600
1987 250 250 250 12 1500
RH111111.
1981 5 195 98 5 3800
1985 ZS Z8 39 3.9 520
1987 250 250 65 110 1100
RHIHRL
1981 130 5 83 5 3SO
1985 2.5 61 32 Z.5 180
1987 150 250 28 ZSO 110
-...---------.... --
This table includes only concentrations I'ltasUfed after purging the wells.
"
-------
.----
I
"
APPENDIX D
SUMMARY OF ANALYTICAL DATA FROM HATBORO PUBLIC SUPPLY WELLS
, .
"
-------
Appendix D
"
If a contaminapt of concern was detected once in a wel~ the s~atistical analysis was
performed for this contaminant. The following assumptions were made in calculating
the mean and upper 95th percentile concentrations:
"
.
For all samples where th~compound was analyzed for but was not
detected, a concentration of half the detection limit was assumed.
.
If the detection limit was unknown, as with the 1979 through 1984 data
and some of the later data, a concentration of half the Contract
Laboratory Program (CLP) detection limit was used. The CLP
detection limit is 0.5 ppb.
.
If it was not known whether the contaminant was analyzed for in a
sample, the sample was not used in the statistical evaluation (1979
through 1984 data and QC Inc. analyses). .
"
,
. NJR561011R56.S1
D-l
-------
L n_-
I
TABLES
D-l
.D-2
D-3
D-4
D-S
D-6
D~7
D-8
D-9
'.
Chemjcal of Concern Concentrations in Wells HI, H2, and H3
Chemical of Concern Concentrations in Well H7
Chemical of Concern Concentrations in Well HI2
- 6
Chemical of Concern Concentrations in Well HI4
Chemical of Concern Concentrations in Well HI6
Chemical of Concern Concentrations in Well HI7
Chemical of Concern Concentrations in Well HI2
- Treated Water .
Chemical of Concern Concentrations in Well HI4
- Treated Water
Chemical of Concern Concentrations in Well HI7
- Treated Water
RA YMARK3IOO8.SlIS
-------
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C!IOO CBlI TC£ I. Pa:. I SIIfl£ 10 I REnRnS I
-
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TABLr 0-2 CHDIICRL or COHerE"' COKCD!T2RTlntlS IN uru. 117
CHDIICHLI Tet I Pet IUlN ,OIL I n,m 11,1,HCR ISIIIPU: IOIRHRlVSIS I REl!R£IIC£ I LRBORRT Dri I ROmS
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T IIB1l 0- Z OOIICRI. or CDImII COIII:OO RRTIOIIS I H uru. K7
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1980 I I I I I I I I I
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DLC I I I I I I I I I I I
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APPENDIX E
LETTER OF CONCURRENCE
COMMONWEALTH OF PENNSYLVANIA
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D&
'INNSYLVANIA
COMMONWEALTH OF. PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
1875 Nw Hope Stt_t
!lXrietoN\, PA 19401
215 270-1923
. .
septEIIiJer 28,. .1990
'.
Hr. atId.n B. £d.c:Jc8a1
R8gianalldnini8tmtar
U.S. SPA R8gicm III
841 08I'tf1ut Build1J1g
Pf'\11~1pua, PA 19107
RB. L8ttar of Ca1cur%81c8
~ SUp8r£und Site
Hatlxn'O Borough, McntgaIm:y County
R8caI:d of DIc18ion (RD)..q.rab1e Unit 2, Dr1n1dng water Supply
. ~e thit 3, GJ:cund ~ter .
C8IIr Mr. Br1cJc8c::l1.
'D18 RIIocG1 ot Deoi81cm for the Dd.nJd.nq Matar SUpply Opemble OUt 8I1d
GrouIXI Water Operable thLt at the ~ Superf\DS 811:8 has b8m
~ by th8 DllpartDB\t.
..
'lbe -jar n~....nta of the 88l8ct8d .L..-dy include.
*
*
*
I .
I I
In8t1t:ut.icmal cxntrol1l to fm8UDt cxnt1nuecI oper:atJ.a1 and
1llUnter\8nC8 by the H8.tb:D:o Barough water Autbar:1ty of th8
off-e1te pmuc supply ...'J. 8l1~~ with -u-8Uipp1nq
tz8'aumt 8Y8t8I8. TrMted _tar.will be d18p8'881 to tb8
Hattxn'c d18tdbut1an ByBttII. p~ 8MLly I tmaUlI&~L at
Hatmro 1I81l8 .14 and,17 i8 ccnducted pmIU8Dt to a
0cn88tt DeceM bet....Mb SPA, Hatlxst'o, ani !'18C:h8r , Parter,
o..'{'A'-ay. TJ:8atD8\t at Hattm:o 1Iall .16 and. Q¥t add1~
1cc:et1Q\ w1ll be cxn:mctecl pmNInt to a CaIS8It ~-
b8ttlla'l BPA, Hatbaro, and Raymaxk Indu8tri88, :me., et.
ale
CCIIIpl.et.tm of a gmund _tar r--tt4 A 1 "'49'\ study to
dIIt:8z:iD1r8 the 1IC8t eff1ci81t d881gn of a ground _tar
tma=-t 8y8t:8D.
In8tallat1cn, opez:atian, and D8iJ\t8Mmce of ~~tLcn .us
81'11 ~ tDatllB1t 8Y8t8I8 cm-811:8 to tnat ga;uI1
18t8r to nqu1Dd l8v8l8 and to ~".I1"t. furtb8r aff~te
m9l8tJ.cm of CCI\taIdnatsd ground _ter taer.d the public
8Upply _118.
.'
..
.'
~18d PIper ~
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Mr. Bdwin B. Erickaon
September 26, 1990
-2-
* Construction, operation, and maintenance of a pipeline
fron the en-Bite ground water treatment plant to the storm
sewer system for eventual discharge of treated ground
water to Pennypack Creek.
* Installation, operation, and maintenance of vapor phase
carbon adsorption units on air-stripping towers at public
supply wells and at en-site ground voter extraction wells .
* Periodic monitoring of ground water and treated ground
water to ensure that the treatment components employed are
effective and that ground water remediation is progressing
townrdo tho cleanup gooloi
I hereby concur with the EPA's proposed remedy/ with the following
The Pennsylvania ARAR for groundwater for hazardous
substances is that all groundwater mast be remediated to
"background" quality at a minimum as specified by 25 PA
Code Sections 264.90 through 264.100, and in particular,
by 25 PA Code Sections 264.97(1), (j) and 264.100 (a)(9).
Ihe Commonwealth of Pennsylvania also maintains that the
requirement to remediate to background is found in other
legal authoriti
The Department will be afforded an opportunity to
provide modified effluent discharge Units based on
future wasteload allocation reassessments in the
Pennypack Creek watershed as they become available.
The Department will be given the opportunity to concur
with decisions related to subsequent operable units and
the future Rmfriinl Investigation and Feasibility Study,
which will address soil/source control, and to evaluate
appropriate remedial alternatives to ensure carpi iance
with Pennsylvania ARARs.
EPA will assure that the Department is provided an .
opportunity to fully participate in any negotiations with
responsible parties.
The Department will be given the opportunity to concur
with decisions related to the design of the Remedial
Action, to ensure compliance with Pennsylvania clennup
ARARs and design-specific ARARs.
The Department's position is that its design standards are
ARARs pursuant to CERCLA Section 121 as amended by SARA ,
and we will reserve cur right to enforce those design
standards.
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?:
Mr. ~ B. Erickscr1
Sept:enDrr 28, 1990
-3-
'. ,.- "'..,,,.
;"
: !
'lM C8part::aent will .L8881::ve. the right and ~1bility
to take irQIpendent enfOr:C8a1.~t acticna ~t to State
. law.
..'1hi.8 ocnc:urmnoe with the eelected rEII811.8l action 18 not
in1:a'XB1 to provide any U8\.1r8nC88 pmroant to cmCI.A
Section 104 (c) ( 3) as amended by SARA.
'!hank ycu for the opporbmity to cxw:ur with this EPA Recom of Decis1a1.
It :ycu have any queetiaw regarding this matter pleaae do not hesitate to
. oontact me.
.
.
.,
Sinceatly,
~~
Uecm T. Gon8hor
Regic.rW Director
OCI
Mr. McClellan
Mr.~
Me. }t)fnIn
Mr. Danyliw
Hr. BObek
. Mr. Mat1.oQ;
M8. SCUlly
Norristown HSCP File
Re 30 (BJS) RAYUX:
£
. . -.---
L
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