United States        Office of
           Environmental Protection   Emergency and
           Agency           Remedial Response
EPA/ROD/R03-93/167
June 1993
©EPA   Superfund
          Record of Decision:
          Recticon/Allied Steel, PA

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50272-101
REPORT DOCUMENTATION
PAGE
4.
7.
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12
1. REPORT NO.
EPA/ROD/R03-93/167
2
TWa and SuMttto
SUPERFUND RECORD OF DECISION
Recticon/Allied Steel, PA
First Remedial Action - Final
Authors)


Performing Organization Nama and Address

U.S. Environmental Pr
401 M Street, S.W.
Washington, D.C. 204
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1S SupptamanUry Notaa
                    PB94-963908
1& Abstract (Umtt: 200 worts)

  The 4.7-acre Recticon/Allied Steel site is comprised of  two former manufacturing
  facilities located in Parker Ford, Chester County, Pennsylvania.   Land use in the area
  is  predominantly industrial and commercial, with mixed agricultural and residential
  areas. The site is situated near two surface water bodies,  the Schuylkill River and
  Pigeon Creek, a floodplain,  .wetlands, and sparse woodlands.  Ground water is the
  principal source of drinking water for the area residences  and offices.  From 1974 to
  1981,  Recticon manufactured silicon wafers far the semiconductor  industry on 1.8 acres
  of  the site.  Until 1975,  facility operations included using and  storing TCE and other
  solvents onsite.  Spent  TCE was stored in drums in the interior of the facility, which
  were periodically removed.   The cutting and polishing  areas,  where the TCE was used,
  contained unbermed, recessed floor drains that were connected to  process waste lines
  that discharged to the surface water drainage pipes and  ditches.   From 1979 to 1988,
  State sampling of soil,  ground water, and surface water  revealed  the presence of VOCs,
  including TCE and DCE.   In  1981,  the State required Recticon to undertake ground water
  pumping, treatment, and  monitoring activities.  From 1970 to 1988,  Allied Steel
  fabricated customized, pressurized steel vessels on the  other 2.9 acres. Allied Steel
  reportedly used solvents,  including TCE, TCA, and high-flash naphtha to clean a

  (See Attached Page)
17.  Documanl Analysis    a. DMcrlpton
   Record of Decision  - Recticon/Allied Steel, PA
   First Remedial Action - Final
   Contaminated Media:  soil,  gw
   Key Contaminants: VOCs (PCE, TCE), other organics

   b.  IdantlfianVOpan-EndadTanns
      COSATI Raid/Group
                                                       (PAHs), metals  (arsenic)
ia AvaUabittyStotamanl
11 SacwttyCtanfThisRapoit)
None
20. SacurttyCtaMfTMaPaga)
None
21. N&ofPagM
118
22. Me*
(SaaANSl-239.18)
                                 $•• Inttruetiont on R*mn»
                                                                          OPTIONAL FORM 272 (4-77)
                                                                          (Formally NTB45)
                                                                          Dapartmart of Commarea

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EPA/ROD/R03-93/167
Recticon/Allied Steel, PA
Final Remedial Action  - Final

Abstract  (Continued)

generator and other miscellaneous parts and equipment; and spread waste solvent on the
ground surface to control dust.  In  1984, Allied Steel conducted soil sampling that
revealed TCE-contaminated soil,  which the company subsequently excavated and removed.
Because the recovery and treatment  process implemented in 1981 did not resolve the
contamination problems, the  State required Recticon to remove TCE-contaminated soil. In
1988, the State required Allied  Steel.to plan for the remediation of ground water
contamination and to implement a ground water recovery system, including construction of a
stripping tower for the treatment of ground water.  In 1990, EPA required the PRPs to
install activated carbon filtration units in the homes and businesses near the site where
VOCs were detected at  or above MCLs.  This ROD addresses a final action source control for
the contaminated soil  and ground water.  The primary contaminants of concern affecting the
soil and ground water  are VOCs,  including PCE and TCE; other organics, including PAHs; and
metals, including arsenic.

The selected remedial  action for this site includes excavating contaminated soil to a
depth of 9 feet, storing the soil temporarily onsite, and disposing of the contaminated
soil offsite; backfilling the excavated areas with the soil if analyses show that this
soil meets the cleanup standard  of  less than 320 ug/kg of TCE; extracting and treating
contaminated ground water onsite using granulated activated carbon to remove VOCs, with
offsite discharge to the Schuylkill River, preceded by a predesign hydrogeologic
investigation and well abandonment  to eliminate the possibility that the existing pumping
and monitoring wells act as  a conduit for future ground water contamination; providing an
alternate water supply by installing a municipal water line; monitoring the ground water;
sampling the drainage  ditch  sediment to determine the source and extent of copper and zinc
contamination; and performing a  Phase I archaeological survey.  The estimated present
worth cost for this remedial action is $4,096,516, which includes an annual O&M cost of
$172,141 over 30 years.

PERFORMANCE STANDARDS  OR GOALS:

Soil cleanup goals will be based on removing all soil with concentrations of TCE >320
ug/kg.  Ground water cleanup goals  are based on the more stringent of SDWA MCLs or
background levels, and include 1,2-DCA 5 ug/1; 1,1-DCE 7 ug/1; cis-l,2-DCE 70 ug/1; PCE 5
ug/1; TCE 5 ug/1; and  vinyl  chloride 2 ug/1.

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                       RECORD, OF DECISION
                      RECTICON/ALLIED STEEL

                           DECLARATION
Site Name and Location

Recticon/Allied Steel
Parker Ford, East Coventry Township, Chester County, Pennsylvania

Statement of Basis and Purpose

This decision document presents the final selected remedial
action for the Recticon/Allied Steel site in Parker Ford, East
Coventry Township, Chester County, Pennsylvania which was chosen
in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution-
Contingency Plan (NCP), 40 C.F.R. Part 300.  This decision
document explains the factual and legal basis for selecting the  ?
remedy for this site.

The Commonwealth of Pennsylvania concurs on the selected remedy.
The information supporting this remedial action decision is
contained in the Administrative Record for this site.

Assessment of the Site

Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. S 9606, that actual
or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in
this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.

Description of the Selected Remedy

This is the only planned response action for the site.  This
remedy addresses source control of contaminated soil, groundwater
remediation and an alternative water supply.  Groundwater
contamination represents a primary threat; therefore, the
extraction and treatment of groundwater and an alternative water
supply will be required.  Soils on-site represent a low-level
threat that-may potentially impact groundwater quality;
therefore, an excavation and off-site disposal remedy for source
control will be required.

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The selected remedy  includes the following major components:

     -Installation of a municipal water line;

     -Excavation and off-site disposal of contaminated soils;

     -Extraction and treatment of groundwater with discharge to
      the Schuylkill River following a predesign hydrogeologic
      investigation  and well abandonment;

     -Long-term groundwater monitoring;

     -Verification sampling to determine the source and extent of
      the copper and zinc found in drainage ditch sediments; and

     -Performance of a Phase I archaeological survey.

statutory Determinations

The selected remedy  is protective of human health and the
environment, complies with federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective.  This remedy utilizes
permanent solutions  and alternative treatment (or resource
recovery) technologies to the maximum extent practicable, and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element.

Because this remedy  will result in hazardous substances above
health-based levels  remaining on-site (in the groundwater), a
review will be conducted within five years after commencement of
remedial action and  every five years thereafter, as required by
Section 121(c)  of CERCLA, 42 U.S.C. S 9621 (c), to ensure that
the remedy continues to provide adequate protection of human
health and the environment.
Stanley L. Laskowski                          Date
Regional Administrator
Region III
           V

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                      RECORD OF DECISION

                   RECTICON/ALLIED STEEL SITE

                        TABLE OF CONTENTS



I.     SITE NAME, LOCATION AND DESCRIPTION   	 1

II.    SITE HISTORY AND ENFORCEMENT ACTIVITIES   	 2

III.  -.HIGHLIGHTS OF COMMUNITY PARTICIPATION	4

IV.    SCOPE AND ROLE OF THE ACTION	5

V.     SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
       CONTAMINATION  	 6

VI.    SUMMARY OF SITE RISKS	10

VII.   DESCRIPTION OF ALTERNATIVES	14
                                                                 T*
VIII.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES  ...  2l"

IX.    THE SELECTED REMEDY	28

X.     STATUTORY DETERMINATIONS 	  36

XI.    DOCUMENTATION OF SIGNIFICANT CHANGES  ...	  40


       APPENDIX A    FIGURES

       APPENDIX B    TABLES

       APPENDIX C    RESPONSIVENESS SUMMARY

       APPENDIX D    ADMINISTRATIVE RECORD INDEX

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                        RECORD OP DECISION
                      RECTICON/ALLIBD STEEL

                         DECISION SUMMARY
I. SITE NAME, LOCATION. AND DESCRIPTION

The Recticon/Allied Steel site (the "Site") is located in Parker
Ford, East Coventry Township, Chester County, Pennsylvania. The
Site consists of two properties and the areal extent of
contamination which includes the contaminated groundwater plume.
The two properties are comprised of 4.7 acres located on the
northwest and southeast corners of the intersection of Route 724
and Wells Road in Parker Ford (see Figures 1 and 2) .  The former
Recticon facility consists of a one-story building with
manufacturing and office areas,  a southeast parking lot with a
loading area, and a driveway that extends from Wells Road to a
second parking lot northwest of the building.  Sanitary sewage is
disposed of through the on-site septic system.  Water is supplied
by on-site production well W-3.   The Allied Steel facility has
been vacant since approximately 1988.  The facility includes two
buildings; a fabrication shop and an office.  The office and a
parking area lie west of the fabrication shop.  Outside the
northwest corner of the fabrication shop is an air compressor
area.  A former scale for weighing steel products is located
southeast of the office.  To the southeast is the debris-filled
crane area.  An aboveground water tank and air stripping tower
are situated along the exterior of the eastern wall of the
fabrication shop.  An aboveground storage tank, reportedly used
to store heating oil, is located along the exterior of the
western wall of the office building.  The tank was empty during
the site investigations.  Northeast of the fabrication shop is a
drainage ditch and a railroad track.  North of the fabrication
shop are two drainage ditches.  A septic system lies southwest of
the fabrication shop.  Three groundwater production wells exist
at the Allied Steel facility; PW1 (south of the fabrication
shop), PW2 (housed within the fabrication shop), and PW3
(southwest of the fabrication shop).

The Site is located approximately 8 miles northwest of
Phoenixville and 3.2 miles southeast of Pottstown.  The land
surrounding the Site is sparsely wooded.  Industrial and
commercial establishments, farms, and single-unit residential
areas exist within 0.5 mile of the Site.  Two surface water
bodies are situated in the vicinity of the Site: the Schuylkill
River, approximately 0.5 mile east of the Site, and Pigeon Creek,
approximately 0.25 mile south of the Site.  There are no known
federally listed endangered species or critical habitats within
the immediate vicinity of the Site.   A wetlands area is located
near the confluence of Pigeon Creek and the Schuylkill River.

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 The Recticon portion of the Srte lies outside the 500-year and
 100-year flood hazard area.   Tne eastern and southeastern
 portions of the Allied Steel property lie within the 500-year
 flood hazard area and the drainage  ditch and southeastern portion
 of  the property lie within the 100-year  flood hazard area.

 The Site is napped in the Phoenixviile 7.5-ninute United  States
 Geological  Survey (USGS)  topographic  quadrangle  at an approximate
 elevation of 130 feet above mean sea  level (MSL).   The topography
 at  the site gently slopes from west to east.   The site is
 situated within the Lowlands Physiographic Province (Sloto,
 1987),  which is characterized by low  rolling hills that consist
 of  Triassic sedimentary and igneous rocks.   This  province is the
 result of the erosion of sandstone  and shale units,  which are
 less resistant than the crystalline rocks of the  uplands  that  lie
 to  the south and southwest.

 Groundwater is the primary source of  water for the businesses  and
 homes  surrounding the site.   Private  wells pump groundwater from
 the Hammer  Creek Formation.   Groundwater generally flows  from  the
 west to the east.   The nearest public water and sewerage  systems
 are located in East Vincent  Township  which is serviced by
 Citizens Utility Home Water  Company.


 II.  SITE HISTORY AMP ENFORCEMENT ACTIVITY

 The 1.8  acre Recticon portion of the  Site has been owned  by
 Highview Gardens Inc.  since  September 11,  1969.   This property
 was leased  to Varadyne Industries,  Inc.  on March  1,  1971.
 Beginning in April 1,  1974,  Recticon  Corporation  ("Recticon"), a
 subsidiary  of Rockwell International  Corporation  ("Rockwell"),
 operated on the property,  manufacturing  silicon wafers for the
 semiconductor industry.   Recticon ceased manufacturing operations
 at  the  Site in 1981.

 The other portion of the  Site,  consisting of  2.9 acres, has been
 owned by Allied Steel  Products  Corporation  ("Allied  Steel") since
 1970.  A subsidiary of Allied Steel, Allied Steel  Products
 Corporation of  Pennsylvania  ("Allied Steel-PA") operated  on the
property fabricating customized,  pressurized  steel vessels until
 they ceased operations in 1988.

Analytical  results  for samples  collected from groundwater,
 surface  water and soil at various points at the Site  from 1979
through  1988  by the Pennsylvania  Department of Environmental
Resources ("PADER")  and contractors retained  by Rockwell  and
Allied Steel  revealed  the presence of  several volatile organic
compounds (."VOCs").  The  contaminants with  the highest observed
concentrations  were trichloroethene ("TCE") and cis-1,2-
dichloroethene  ("DCE").

The compound  TCE,  specifically Reagent Grade  - ACS

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 Trichloroethene,  was used at the Recticon facility until 1975.
 TCE and other solvents were shipped and stored in 55-gallon
 drums.   The drums were stored in a small room adjacent to the
 loading dock, in another small room between the polishing room
 and an  exit door near Well 1, in the loading dock area (within
 the facility),  and "outside of the plant."  The location of the
 exterior drum storage area is not known.  Use of TCE was
 generally restricted to the cutting and polishing areas of the
 facility.  When TCE was needed in these areas,  1-quart dipping
 vats were filled from the drums and transported.   Spent TCE was
 returned to the drum storage area and stored in drums,  which were
 periodically removed.  The flooring of the storage,  cutting,  and
 polishing areas reportedly was not bermed.   Also,  the cutting and
 polishing areas contained unbermed,  recessed floor drains that
 were connected  to process waste lines that discharged to the
 surface water drainage pipes and ditches.

 In October 1981,  Recticon and PADER entered into a Consent Order
 and Agreement.   In accordance with the terms of the Agreement,
 Recticon undertook groundwater pumping,  treatment,  and monitoring
 activities.   However, the recovery and treatment process did not
 resolve the contamination problem at the Site.   Other cleanup
 activities on the Recticon property involved the removal of TCE
 contaminated soils in May,  1981.

 Allied  Steel-PA reportedly used solvents to clean a generator and
 other miscellaneous parts and equipment.   According to an August
 1979 PADER Waste  Discharge Inspection Report,  the SAF-T-SOLVENT
 used by Allied  Steel-PA contained 10 percent TCE,  30 percent
 1,1,1-trichloroethane ("TCA"),  and 60 percent high-flash naphtha.
 In July 1982, the PADER sampled the solvent and found it to
 contain 38 percent TCE.   A drum storage area for waste solvents
 was formerly located near the air compressor area.   A PADER Waste
 Discharge Inspection Report dated August 22,  1980,  reported that
 waste solvent was historically spread on the ground surface to
 control dust.

 In 1984,  a contractor retained by Allied Steel  found TCE in soils
 near the compressor room on their property.   The  contaminated
 soil was subsequently excavated and removed.   In  1988,
 Pennsylvania's  Environmental Hearing Board ordered  Allied Steel
 to plan for the remediation of groundwater contamination and to
 implement a groundwater recovery system.   Allied  Steel
 subsequently planned for and constructed a stripping tower for
.the treatment of  groundwater.   This remediation program however,
 was never implemented and Allied Steel-PA subsequently filed a
 petition for bankruptcy.

 EPA placed "-the  Site on the National  Priorities  List  ("NPL")  on
 October 4,  1989.   Rockwell,  Allied Steel  and Highview Gardens
 Inc.  were sent  notifications that they were identified  by EPA as
 potentially responsible for the Site contamination.   Rockwell and
 EPA signed a Consent Order in March 1990  to conduct  a Remedial

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 Investigation/Feasibility  Study  ("RI/FS")  to  identify  the types,
 quantities and locations of  contaminants  and  to  develop ways  of
 addressing the contamination problems.  Field work for the first
 phase  of  the  RI was  conducted from January to November 1991.   The
 field  work for the second  phase  of the  RI was conducted from  June
 to  October 1992.  The  RI/FS  for  the Recticon/Allied Steel Site
 was completed in May 1993.

 On  May 11,  1990,  EPA and Rockwell entered into an  additional
 Consent Order to install activated carbon filtration units in
 each of the homes and  businesses near the Site where VOCs have
 been detected at or  above  Maximum Contaminant Levels ("MCLs").
 Rockwell  was  required  to install filtration units  to treat the
 well water supplies  at five  businesses  and one duplex  residence
 and monitor those systems  and other surrounding  residential wells
 under  that Consent Order.

 On  May 20,  1993,  EPA released the RI/FS reports  and the Proposed
 Plan for  the  Site.   The Proposed Plan provided a 30-day comment
 period ending June 19,  1993.

 III.   HIGHLIGHTS  OF  COMMUNITY PARTICIPATION

 Community relation interviews of local  residents,  businesses  and**-
 officials were conducted from August 13 to August  16,  1990 in
 order  to  ascertain the community's concerns.  The  results of
 those  interviews  were  documented in a Community  Relations Plan
 dated  December 12, 1990.  This document lists contacts and
 interested  parties throughout government  and  the local community.
 It  also establishes  communication pathways to ensure timely
 dissemination of  pertinent information.

 The  Site's  Administrative Record and Site  Repository were
 initially established  prior to a public meeting  which  was held on
 January 9,  1991 to communicate the plans  for  the RI/FS field
 work.   Fact Sheets were mailed to those on the contact list
 during August  1990, January 1991 and May  1992 providing
 information on RI/FS plans and progress.   An  informal  meeting was
 held on March  17, 1993  with residents and  businesses currently
 having activated  carbon filtration units or having wells
 potentially affected by groundwater contamination to solicit
 their  concerns regarding alternative water supply options.  The
RI/FS  reports  and the  Proposed Plan were released to the  public
 on May 20,  1993.  All  of these documents were made available  in
 both the Administrative Record at EPA Region  Ill's office in
 Philadelphia,  PA  and at the Site Repository in the East Coventry
Township  building.  A  public  comment period was  held from May 20,
 1993 to June  19,  1993.   In addition, a  public meeting  was held on
May 27, 199*3-, to  discuss the  results of the RI/FS and  the
preferred alternative  as presented in the  Proposed Plan for the
 Site.   Notice of  the Proposed Plan and  public meeting  was
published in the  Pottstown Mercury on May  20, 1993.  All  comments
which were  received by EPA prior to the end of the public comment

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period, including those expressed verbally at the public meeting,
are addressed in the Responsiveness Summary which is attached to
this Record of Decision.

IV.  SCOPE AMP ROLE OP RESPONSE ACTION WITHIN SITE STRATEGY

The remedy selected in this ROD addresses treatment of the
contaminated groundwater emanating from the Site, provision of a
potable source of water for the affected and potentially affected
residents and excavation and off-site disposal of the
contaminated soil on the Recticon property.  This is the only
planned response action for this Site.

The selected remedy will comprehensively address the threats
posed by the release of hazardous substances at the Site.  The
principal threats posed by the Site are due to VOC contamination
in the groundwater.  Since this groundwater aquifer is a Class
IIA aquifer, the beneficial use for groundwater is a drinking
water supply.  The primary risk to human health and the
environment is from ingestion and inhalation of, and contact
with, groundwater from wells that contain contaminants above the
MCLs established by the Safe Drinking Water Act ("SDWA").  One  ~-
area of soil on the Recticon portion of the Site also is
contaminated with VOCs and therefore represents a low-level      ^
threat due to the potential for the VOCs to migrate into the
groundwater.  In addition, the levels of copper and zinc in
sediment samples from the on-site drainage ditch represent a
potential threat to the environment since the levels are greater
than literature levels indicative of ecological affects.
Consequently, EPA plans to address these threats by meeting the
following goals: 1) to prevent human exposure to contaminants in
the groundwater; 2) to restore groundwater to its beneficial use
and to background levels of contaminants, if technically
practicable; 3) to protect uncontaminated groundwater and surface
water for current and future use, and environmental receptors.

The first goal, to prevent human exposure to contaminants in the
groundwater, will be accomplished by providing a potable source
of drinking water via the municipal water line.  The second goal
of this remedial action is to restore contaminated groundwater to
its beneficial use and to background concentrations, if
technically practicable, or MCLs, whichever is more stringent.
This will be accomplished by extracting the contaminated
groundwater, treating it with a granulated activated carbon
("GAG") adsorption system, and discharging the treated effluent
to the Schuylkill River.

The second goal will further be met by source control of
contaminated soils.  The purpose of this action is to prevent the
transport of soil contaminants into the groundwater in order to
protect groundwater for its beneficial uses and meet applicable
or relevant and appropriate requirements ("ARARS") for the
groundwater.  The RI Report indicates that the contaminated soils

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 are located nine to eleven feet below the ground surface and  are
 at levels that do not pose a risk based on direct dermal contact
 and ingestion.  No principal threats/  such as  areas of highly
 toxic  or highly mobile hazardous substances, were found.
 Therefore,  EPA has determined that contaminated soils  are a low-
 level  threat and not a principal threat.   However,  rainfall
 infiltration into the soils can cause hazardous substances to
 continue to leach into the groundwater above background levels
 and possibly HCLs.   Therefore,  the selected remedial alternative
 requires excavation and off-site disposal of the contaminated
 soil into a permitted landfill.

 Treatment of contaminated  groundwater and removal of the
 contaminated soil will assist in accomplishing the  third  goal of
 protecting  uncontaminated  groundwater and surface water for
 current  and future use,  and environmental receptors.   However,
 the source  and extent of the levels of copper  and zinc found  in
 the sediment samples in the on-site drainage ditch  must be
 further  characterized during a  verification study in order to
 ensure that environmental  receptors are protected.

 V.   SUMMARY OF SITE CHARACTERISTICS AMP EXTENT OF CONTAMINATION •"

 Site Characteristics

 The site  is underlain by an overburden and bedrock  aquifer.   The
 overburden  aquifer  is composed  of weathered and reworked  bedrock
 material.   This material consists of  clay to gravel-size  material
 that has  been  eroded and redeposited  in meandering  stream
 deposits  that  make-up the  Schuylkill  River floodplain.  These
 deposits  thin  towards the  borders of  the  river valley.  Ground
 water flow  within the overburden aquifer  occurs though the
 intergranular  porespace.   The amount of porespace is controlled
 by  the grain-size and the  degree of sorting of the  material.

 The  underlying bedrock aquifer  is composed of  interbedded
 conglomerates,  sandstone,  siltstone, and  shale units and  are
 collectively referred to as  the  Gettysburg Formation.   These  rock
 units were  laid-down in  an ancient meandering  stream and  river
 environment.   Sedimentary  layers within the Gettysburg Formation
 are divided by bedding planes.   The sedimentary layers over time
 have been rotated into an  east-west orientation with a northward
dip between 12  and  20  degrees.   Some of the bedding planes have
 separated into what  are  referred to as bedding plane fractures.
Oriented perpendicular to  and connecting  the bedding planes
 fractures to various  degrees are joint fractures.   The degree of
 jointing  is dependent on the thickness and brittleness of  the
 sedimentary, layers.   Ground water flow in  the  bedrock  aquifer is
 restricted  to  movement along the bedding plane  fractures  and
 joints.  The intergranular porosity, where  present, also
contributes to ground water movement.  Intergranular porosity
 contributes more  to  the  storativity of the  aquifer  than to flow
though the  aquifer.

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The general horizontal  flow direction in both the overburden and
bedrock aquifer  is  to the east.  Vertically the flow direction in
both aquifers  is generally downward on the Recticon and Allied
Steel properties and upward closer to the Schuylkill River.

The distribution of contamination in this setting is controlled
by the above constraints.  Contaminants have been found in the
unsaturated overburden  beneath the parking lot on the northwest
portion of the former Recticon facility.  This suggests the
possibility of a source area  in the unsaturated overburden on the
Recticon property.

This conclusion  is  further supported by the distribution of
contaminants in  the overburden aquifer, and the seasonal
fluctuation in contaminant levels seen in some overburden wells.
The highest concentration of  contaminants occurs along an east-
west trend encompassing the overburden ("OB") wells OB-2, OB-5,
and OB-8 (see  Figures 5 and 6).  OB-3 also lies along this trend,
but does not monitor the ground water within the gravel layer
monitored in the other  wells.  Seasonally high contaminant levels
were found during times of corresponding high seasonal water
table elevations.   This suggests seasonal contact between the
ground water and a  residual source.  Evidence for this source
area has been  given above.  Elevated contaminant levels in OB-5 rv--
and -8 may be  the result of their position down-gradient from the
possible source  area.

Bedrock contamination trends  follow the same east-west trend seen
in the overburden aquifer.  Contamination extends along a trend
from around deep bedrock ("DBR") well DBR-12 to past DBR-9.
Monitoring well  DBR-12  and the bedrock ("BR") veil BR-2 are
located near suspected  source areas discussed above and in areas
affected by local pumping.  The affects of local pumping can be
seen by the cone of depression developed around production well
W-3 and by the pump test recovery data.  DBR-11, while appearing
to be located  along side gradient from the site, monitors water-
bearing zones  that  rise to the south and surface beneath the
Recticon property.  The downward vertical gradient could easily
have carried contamination downward in the direction of DBR-11.
The affects of local pumping  in the area of DBR-11 are unknown.

Mature and Extent of Contamination

The nature and extent of contamination at the Site was
characterized  through a soil  gas survey, sampling of surface
soils, subsurface soils, sediments, surface water, groundwater
monitoring wells and residential drinking water wells.

Subsurface Soils

A soil vapor survey was performed to scan for potential source
areas of chlorinated hydrocarbons, using this relatively rapid
survey mechanism to provide sufficient information to select

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 subsurface soil boring locations.   The  soil  vapor survey was
 performed using a grid system established  for  each of  the  sites.
 A total of 110 soil vapor samples  were  collected and analyzed  in
 the field.  TCE,  TCA,  and toluene,  were detected above a
 concentration of 0.1 ug/1 in the soil vapor  samples collected.
 The contaminant found at the highest concentrations was TCE.   The
 highest amount of TCE was 170 ppb  detected in  the northwest
 portion of the former Recticon facility.   Based on the TCE soil
 vapor results, subsurface sampling locations were selected.  Five
 soil boring sample locations were  selected at  the former Recticon
 facility and four soil boring locations were selected  on the
 Allied Steel facility.   Three additional soil  boring locations
 were sampled to further define the soil contamination  on the
 northwest portion of the former Recticon facility.   A  total of
 sixteen samples were analyzed from these locations.  The soil
 boring locations are shown on Figure 3.

 The soil borings were analyzed for volatile  and semivolatile
 organic compounds and for inorganic compounds.   Only VOCs  were
 detected at levels significantly above  either  background sample
 concentrations or reference background  levels  (Shields, 1985). ~
 The area with the greatest concentrations  of VOCs in soil  was
 identified in the northwest portion of  the parking lot of  the
 former Recticon facility.   The concentrations  of TCE and DCE in
 that soil sample  (R/A7)  were 1,400  ppb  and 48  ppb respectively.
 Additional soil sampling and the soil vapor  data suggest that the
 TCE and DCE concentrations in R/A7  represent an isolated soil
 impact.   Table 1  summarizes the chemicals  detected in  the
 subsurface soil samples.

 During the RI/FS,  the  Summers model for groundwater  contamination
 transport was used to  estimate the  concentration of  TCE in soils
 that would impact groundwater above background levels.  TCE was
 used in the model because  it represents the  highest  VOC
 contaminant concentration  in both soil  and groundwater.  Based on
 this model,  EPA has determined that the clean-up level for the
 contaminated soils is  320  ppb of TCE.  This  level is based on the
 amount of residual contamination that,  if  left in the soil, would
 not  cause the groundwater  to be contaminated above background
 levels.

 Surface Boil,  Sediment and  surface Water

A review of  historic operational practices at the Recticon
 facility indicates that waste water was occasionally discharged
to surface drainage ditches.  Historical sampling results
revealed the presence of chlorinated hydrocarbons in culverts;
TCE  concentrations ranged  from  less than 1 ug/1 to 229 ug/1.
Eight  locations were selected  in the surface drainage ditches
adjacent to  the facilities  and a railroad track to evaluate the
presence of  chlorinated hydrocarbons and metals  in the surface
soil,  sediment and surface water.  Three of these locations (SS-
7A,7B,7C) were surface soil  samples selected as background

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 reference  samples.   These background samples were taken from a
 grass covered  area  at  the furthest upgradient  location on the
 former Recticon  property.  The remaining  locations were sampled
 for sediments  in the drainage ditch  (SS-3 - SS-6), and in one
 instance,  a stormwater drainpipe  (SS-2).  Surface water was only
 available  at locations SS-3  and SS-4 (SW-1 and SW-2
 respectively).   Figure 4 presents the sampling locations.  The
 surface soil/sediment  and surface water samples were analyzed for
 volatile organics,  semivolatile organics, and  metals and cyanide.
 Table 2 and 3  summarize the  chemicals detected in the surface
 soil, sediment and  surface water samples.  Surface water samples
 contained  levels of cadmium  and copper exceeding acute ambient
 surface water  quality  criteria.  However, the  concentrations of
 the compounds  found in the downstream surface  water location (SW-
 2) were generally less than  or equal to the concentrations found
 in the upstream  sampling location (SW-1).  Only low levels of
 vocs were  detected  in  some surface soil/sediment samples.  The
 sediment samples did contain significant  levels of copper (43.3-
 211 ppm) and zinc (123-772 ppm), at levels that were 5 to 10
 times higher than background levels.  Several  base/neutral
 extractable compounds,  particularly the polycyclic aromatic
 hydrocarbons ("PAHs")  were also detected at levels above the
 background concentrations.   The PAHs, however, are commonly found,
 in tar derivatives  from road surfaces.  In addition, the         -
 downgradient samples were taken from drainage  ditches and pipes
 that had accumulated sediments from surface water runoff from the
 asphalt roads and the  adjacent railroad tracks, whereas the
 background sample locations  were from a grassy location that does
 not accumulate sediments.

 Grouadvater

 In order to evaluate the hydrogeology and groundwater quality of
 the aquifer that underlies the site, eight overburden wells and
 eight shallow bedrock wells  were installed on  the former Recticon
 and Allied Steel  properties  during Phase I of  the RI.  The
 overburden and shallow  bedrock wells were constructed as paired
well clusters to  evaluate groundwater quality  in the
 unconsolidated and bedrock aquifers and the vertical hydraulic
 gradient.   The overburden wells were installed to a depth of
 approximately 30  feet below  ground surface, and the shallow
 bedrock wells were  installed to a depth of approximately 65 feet
 below ground surface.   During Phase II of the RI, eight
 additional monitoring wells  were completed both on and off the
Recticon and Allied  Steel properties to monitor deeper bedrock
 zones and  shallow zones at the edges of the plume.  The well
 locations  are shown  on  Figure 5.   The general horizontal flow
 direction  in both the overburden and bedrock aquifer is to the
 east.   Vertically the flow direction in both aquifers is
 generally  downward based on  flows in the wells located on the
 Recticon and Allied  Steel properties and upward based on the
 flows measured in the wells  closer to the Schuylkill River.

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 The Phase I  groundwater monitoring wells  were  sampled on four
 occasions during the Phase I of  the  RI  and once  again along with
 the Phase II wells.   During the  first sampling round,  samples
 were analyzed for volatile and semivolatile organics,  metals,  and
 inorganic compounds.  Only low levels of  semivolatile organics,
 metals,  and  inorganic compounds  were detected  during the first
 sampling round and therefore,  subsequent  rounds  were analyzed  for
 VOCs only.   Tables 4A and 4B present a  summary of  the chemicals
 detected during groundwater sampling.   Contaminants  were found in
 groundwater  at concentrations  that exceed background levels and
 MCLs under the SDWA.  TCE and  DCE accounts for approximately
 ninety percent of the total VOC  concentrations.  The maximum
 concentration detected for TCE was 1900 ppb and  for  DCE  it  was
 730 ppb.

 Groundwater  monitoring at the  Site indicates that  the VOCs  have
 moved through groundwater both vertically and  off  the former
 Recticon and Allied  Steel properties toward the  Schuylkill  River
 at  levels that exceed MCLs.  Figure  6 shows the  approximate
 location of  the contaminant plume.   The concentration of VOCs  in
 wells decreased between the properties  and the River,  indicating
 that dispersion and  dilution is  occurring.   The  outer boundaries'.
 of  the groundwater plume were  not fully delineated during the  RI.
 EPA believes,  however,  that sufficient  information regarding
 groundwater  movement and contamination  was collected during the
 RI  to select a remedy for the  site.   The  extent  of the
 groundwater  plume will be. studied further during the design phase
 of  remedy implementation.

 VI.   SUMMARY Of SITE RISKS

 As  part  of the RI/FS,  a baseline risk assessment was conducted to
 characterize the current and potential  future  threats  to human
 health and the environment posed by  contaminants in  the
 groundwater,  soil, sediments,  subsurface  soil  and  the  leaching of
 contaminants from soil to groundwater,  in the  absence  of remedial
 action.   Table 5 provides a discussion  of  the  key  terms  used in
 the  risk  assessment  described  in the ROD.  The risk  assessment
 consisted of identification of contaminants  of concern,  exposure
 assessment,  toxicity assessment,  risk characterization and  an
 environmental  evaluation.

      inants of  Concern
The risk assessment compiled a list of contaminants from the
results of the various sampling activities at the Site and
chemical contaminants of concern were identified by media for the
various exposure routes.

The specific contaminants of concern in the surface soil include
the PAHs.
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The specific contaminants of ccncern in groundwater include cis-
1,2-dichloroethylene,  1,1-dichloroethylene, TCE,
tetrachloroethylene,  1,2-dichloroethane, vinyl chloride,
beryllium, and arsenic.

Exposure Assessment

Current land use  in the  vicinity of the Site is residential,
commercial and agricultural.  Groundwater beneath the Site is
classified as a Class  IIA aquifer, a current source of drinking
water.  Numerous  residential wells in the area of the site are
used for drinking water  and other domestic uses.  The residential
wells were sampled during the RI/FS and those residences and
commercial establishments having wells with levels of
contaminants above MCLs  were provided individual carbon treatment
units.  During performance of the base line risk assessment both
the former Recticon and  Allied Steel properties were vacant.

The exposure assessment  identified potential exposure pathways.
Four exposure scenarios  were examined under current and future
land use assumptions.  Exposure of receptors to chemicals in
potentially impacted media (surface soil, groundwater, and air)
were examined under Reasonable Maximum Exposure ("RME")
assumptions.

The four scenarios were: l) trespassers and 2) offsite residents
under the current land use assumption, and; 3) onsite worker and
onsite resident under the future land use assumption.

Use of an exposure scenario based on future residential use is
consistent with EPA Risk Assessment Guidance which requires
consideration of hypothetical residential use.  The NCP requires
that groundwater which is suitable for use as a water supply be
protected and restored to its beneficial use.

Potential exposure routes considered for the purpose of
evaluating Site risks included: ingestion, dermal contact and
vapor inhalation of contaminated groundwater; inhalation of
volatiles and particulates in outdoor/indoor air; and ingestion
and dermal contact with  surface soil and water.  The potential
exposure routes chosen for each of the exposed populations are
listed in Table 6.

The next step in the exposure assessment process involved the
quantification of the magnitude, frequency, and duration of
exposure for the populations and exposure routes selected for
evaluation.  The contaminant intake equations and intake
parameters were derived  from standard literature equations and
data from EPA guidance documents.  Average Daily Doses ("ADD")
and Lifetime Average Daily Doses ("LADD") were estimated for
contaminants of concern  in the baseline risk assessment.
                                11

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 Toxicitv Assessment

 The  Reference  Dose  (RfD)  for  a  substance represents  the  level of
 intake  which is  unlikely  to result  in adverse non-carcinogenic
 health  effects in individuals exposed for a chronic  period  of
 time.   For  carcinogens, the slope factor is used  to  estimate an
 upper-bound probability of an individual developing  cancer  as a
 result  of exposure  to  a particular  level of a potential
 carcinogen.

 Vinyl chloride,  beryllium and arsenic are classified as  human
 carcinogens based on epidemiological studies.  Trichloroethylene,
 1,2-dichloroethane  and tetrachloroethylene are classified as
 probable human carcinogens based on toxicological studies
 performed on laboratory animals.  Scientific data collected to
 date is not sufficient to classify cis-l,2-dichloroethylene as a
 carcinogen.

 Risk Character!eation

 The  baseline risk assessment  in the RI/FS quantified the
 potential carcinogenic and non-carcinogenic risks to human  health
 posed by contaminants  of  concern in several exposure media.  For
 the  Site, the  carcinogenic and  non-carcinogenic risks were
 determined  for soil, air  and  groundwater.

 Carcinogenic risk is presented  as the incremental probability of
 an individual  contracting some  form of cancer over a lifetime as
 the  result  of  exposure to the carcinogen.  Risk standards for
 non-carcinogenic  compounds are  established at acceptable levels
 and  criteria considered protective of human populations  from the
 possible  adverse  effect from  human exposure.  The ratio  of  the
 ADO  to  the  RfD values, defined  as the hazard quotient, provides
 an indication  of  the potential  for systemic toxicity to  occur.
 If the  sum  of  the aggregate hazard quotients does not exceed one,
 there is  not a concern for a  non-carcinogenic public health
 threat.   The carcinogenic and non-carcinogenic risks are
 summarized  on  Tables 7, 8 and 9.  The risk evaluation of the site
 indicated the  following:

Current Land Dae

     On-site Trespasser   The  hazard index did not exceed one.
Total cancer risks were estimated at 3 x 10~7.

     Off-site  Resident The hazard index did not exceed  one.
Total cancer risks were estimated at 4 x 10~7.

Future Land*- Use

     C-n-Site Worker  The  hazard index for all pathways exceeded
one.   Total  cancer risks  were estimated at 3 x 10~*.
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      on-site  Resident   The hazard  index for one target organ
 (blood)  exceeded  one.   One chemical cis-l,2-dichloroethene  (in
 groundwater)  contributed the greatest amount.  All other  indices
 were  well below the  health-based criteria.  The hazard index  for
 all pathways  was  estimated at  3.643.  Total cancer risks  were
 estimated at  6 x  10~4.

 Because  the hazard indices exceeded 1 and the baseline
 carcinogenic  risk exceeds the  risk range of 10~4 to 10~6,  and
 because  MCLs  are  exceeded, remedial action for groundwater will
 be taken at this  Site.

              Evaluation
Based on consultation with U.S. Department of the Interior, Fish
and Wildlife Service, there are no known federally listed or
proposed endangered or threatened species within the immediate
vicinity of the site.  The only State-listed endangered or
threatened species is the transient blue heron.

Based on the site vegetation, soils, and degree of development,
the site does not appear to include substantial wildlife habitat.*
The vegetation on the majority of the Site is disturbed on a
semi-regular basis by activities associated with normal property
maintenance.  The Phoenixville, Pennsylvania, National Wetlands
Inventory indicates that no wetlands have been mapped on the
site.  The primary drainage feature of the site is related to the
ditches that drain the areas upgradient of the former Recticon
and Allied Steel facilities to the tributary of Pigeon Creek
located south of the Allied Steel property.  The closest stream
(Pigeon Creek) lies approximately 1,800 feet southeast of the
site and has wetlands associated with it.  The closest
inventoried wetland lies approximately 2,500 feet to the east
(along the Schuylkill River) .

Due to the nature of contamination and the lack of. substantial
habitat on the former Recticon and Allied Steel portions of the
Site, the Baseline Risk Assessment only qualitatively assessed
potential ecological effects and identified potential data gaps.

The major contaminants of concern, VOCs, were not detected in the
surface water above ambient water quality criteria or in
sediments at levels that could have adverse ecological impacts.
Downstream drainage ditch sediment samples, however, contained
significant levels of copper (43.3-211 ppm), zinc (123-772 ppm)
that were 5 to 10 times higher than background levels.  The
levels of these contaminants are above levels causing biological
effects when compared to literature sediment levels (e.g., Long
and Morgan,' 1990).  The Effects Range-Low ("ER-L"), is a
concentration at the low end of the range in which biological
effects have been observed.  The ER-L for copper is 70 ppm and
for zinc, it is 120 ppm.  A data gap exists concerning the source
and extent of copper and zinc due to the small number and limited
                                13

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 spatial distribution of samples.   Although  it  is  possible  that
 the copper and zinc in the sediments  are  related  to site
 activities,  it appears that the elevated  levels could  also be
 related to road surface runoff due to tire  wear.   Several
 base/neutral extractable compounds, particularly  the polycyclic
 aromatic hydrocarbons (PAHs)  were  also detected at levels  above
 their  ER-Ls.   The  PAHs are commonly found in tar  derivatives from
 road surfaces,  however,  and these  sediments were  sampled from
 drainage ditches that receive surface water runoff from the
 asphalt roads and  some of the locations receive runoff from
 adjacent railroad  tracks.

 Since. a data gap exists regarding  the source and  extent of copper
 and zinc,  additional sediment and  surface soil sampling will be
 required during the remedial  design phase.  If sampling shows
 that the site is the source of these  metal  contaminants,
 additional samples will be taken in the direction of Pigeon Creek
 and the Schuylkill in order to determine  the extent of
 contamination and  evaluate the potential  for adverse effects
 associated with copper and zinc.
An unacceptable level of risk is presented by the groundwater  in
the vicinity of the Site property in a future land use scenario
involving an onsite worker or resident's ingestion, inhalation
and dermal contact with the groundwater contaminants.  Actual  or
threatened releases of hazardous substances from this Site, if
not addressed by implementing the response action selected in
this ROD, may present a substantial endangerment to public
health, welfare, or the environment.

The levels of copper and zinc are above levels which may cause
biological effects.  Since a data gap exists regarding the source
and extent of copper and zinc, additional sediment and surface
soil sampling will be required during the remedial design phase.

VII.  DESCRIPTION OT ALTERNATIVES

A feasibility study was conducted to identify and evaluate
remedial alternatives for remediation of groundwater and
contaminated soils on the former Recticon property and the
provision of an alternative water supply.  Applicable remediation
technologies were initially screened in the feasibility study
based on effectiveness, implementability, and cost.  The
alternatives meeting these criteria were then evaluated and
compared to nine criteria required by the National Contingency
Plan ("NCPm,) .  The NCP requires that no action alternatives be
evaluated as a point of comparison for other alternatives.  The
alternatives evaluated for water supply, soil and groundwater  are
described below.
                                14

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watar  Supply

981  No Action

Estimated Capital Costs: $0
Estimated Annual O&M Costs: $69,077
Estimated Present-Worth Costs: $1,263,555
Estimated Implementation Time: Immediate
Monitoring Time: 30 years

The NCP requires that EPA consider a "No Action" alternative for
every  site to establish a baseline for comparison to alternatives
that do require action.  Under this alternative, no action would
be taken at the Site to provide a potable source of water for
residents within the area of concern.  This alternative only
includes ongoing private water supply well monitoring.  The
Chester County Health Department has existing well permitting
requirements applicable to all of these alternatives that control
the installation of new wells within the plume.

W82  Community Well

Estimated Capital Costs: $696,306
Estimated Annual O&M Costs: $63,464
Estimated Present-Worth Costs: $1,857,199
Estimated Implementation Time: 6-12 Months

A new well, 270 feet deep, would be installed outside the plume
with a storage tank, well pump, disinfection system, distribution
pump, and distribution system to connect the new
water supply to affected homes.  The average water consumption
per affected well is assumed to be 300 gallons per day (1,800
gallons per day total).  To provide capacity to meet peak
demands, a 10,000-gallon storage tank and a 4,000-gallon
hydropneumatic tank will be included in this system.
Disinfection will be by ultra violet ("UV") light.  Three 4 inch
by 270 foot deep monitoring wells will be installed between the
contaminant plume and the supply well to detect if contamination
begins to migrate towards the proposed well.  Groundwater
monitoring will be implemented to identify other users that may
require connection to the system.

W83     Municipal Water Line

Estimated Capital Costs: $293,177
Estimated Annual O&M Costs: $2,661
Estimated Present-Worth Costs: $317,421
Estimated Implementation Time: 3 Months

This alternative will provide a source of potable water to the
affected and potentially affected residents by extending a
municipal water line to the area in the vicinity of the Site.
The Citizen's Home Utility Water Company currently supplies water
                                15

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 to East Vincent Township,  and has sufficient  capacity at this
 time to provide water.   A wate** main is located approximately  1/4
 mile south of the Site,  at the intersection of  Shady Lane and  Old
 Schuylkill Road.   Under  this alternative,  a water line will  be
 installed from the main  to the Site  and the affected well users
 will be connected to the line.   The  line will be installed in  a
 trench below the freeze  line along and across Old Schuylkill Road
 and brought into the area of concern.   Independent connections
 will then be brought into each of the  affected  residences and
 businesses.   Fire hydrants will be installed  at 500 foot
 intervals along the water line.   Only  those users currently
 impacted or potentially  impacted by  the contamination in the
 groundwater will  be connected to the municipal  water system.   A
 determination concerning which wells may be potentially impacted
 will be made once the outer boundaries of  the contaminated
 groundwater plume has been further delineated based on the
 results of the predesign hydrogeologic investigation.

 W84       individual Rom* Treatment (Carbon) Units

 Estimated Capital Costs:  $21,678
 Estimated Annual  O&M Costs:  $27,238
 Estimated Present-Worth  Costs:  $519,909
 Estimated Implementation Time:  0  Months

 Currently,  six water supply wells in the vicinity of the Site  are
 equipped  with individual carbon treatment  units.   Each unit
 consists  of  two adsorption units  (each using  approximately 2
 pounds  of carbon)  in series,  with an UV light disinfection
 system.   The units  are leased.  This alternative includes
 purchasing the leased units and possibly installing new units  for
 additional residential wells.  The carbon  units and the UV lamp
 would be  replaced annually.   The  treated water  from each home
 would be  sampled  and analyzed twice  a  year.   Groundwater
 monitoring will be  implemented to identify other users that may
 require connection  to the  system.

 Boil Alternatives

 81   Ho Action

 Estimated Capital Costs: $0
 Estimated Annual O&M Costs:  $0
 Estimated Present-Worth Costs: $0
 Estimated Implementation Time: Immediate

The NCP requires that EPA  consider a "No Action"  alternative for
 every site to  establish a  baseline for  comparison to alternatives
that do require action.   Under this alternative,  no action would
be taken at'the Site to remove, remediate,  contain, or otherwise
address the area with soil contamination.
                                16

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 82    Asphalt  cap

 Estimated  Capital  Costs:  $43,243
 Estimated  Annual O&M  Costs:  $3,300
 Estimated  Present-Worth Costs: $103,607
 Estimated  Implementation  Time: 3 Months

 The  area in question  is currently isolated by an asphalt parking
 lot.   However,  for the purposes of alternative development and
 cost evaluation, it has been assumed that the existing parking
 lot  will be removed and replaced.  The actual extent of
 replacement required  will be determined after a field inspection
 has  been performed.   It is estimated that the area of soil
 contamination is approximately 25 feet by 20 feet, or 500 square
 feet.  There  are currently no structures in the parking lot, so
 site preparation will involve mobilizing equipment and removing
 the  existing  asphalt  layer.  The excess material will be
 stockpiled on-site for disposal as construction debris, or could
 be recycled into the  asphalt mixer for reuse.  The underlying
 gravel base will be removed, and the native soil will be
 recompacted to minimize the  potential for subsidence over time. -
 A 4-inch gravel subbase will be installed and compacted over the'
 Site.  A 3.5-inch  layer of asphalt will then be installed over
 the  gravel subbase.   The  site will be graded to direct surface
 water off  the site, and will be bermed around the perimeter to
 minimize surface water runon and runoff.  Institutional controls,
 such  as deed  restrictions on excavation of the area will be
 implemented to ensure the integrity of the cap.

 S3       Bxcavation/Offsite  Incineration

 Estimated Capital  Costs:  $147,014
 Estimated Annual O&M  Costs:  $0
 Estimated Present-Worth Costs: $147,014
 Estimated  Implementation  Time: 3 Months

Alternative S3 includes excavation and offsite incineration of
the contaminated soils.   Sample analyses indicate that the
vertical extent of contamination extends from approximately 9 to
 11 feet below grade.  Based  on this information, an estimated 37
cubic yards,  or approximately 50 tons, of material will require
excavation.   As the excavation occurs, the material will be
sampled until the results indicate that the soils do not contain
TCE above the clean-up level of 320 ppb.  Once the excavation is
complete,  additional  clean borrow material will be brought in to
restore the excavation to original grade, and the existing
asphalt surface will  be repaired.
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 84        Bxcavation/Offait* Landfill

 Estimated Capital Costs:  $40,261
 Estimated Annual O&N Costs: $0
 Estimated Present-Worth Costs:  $40,261
 Estimated Implementation  Time:  3 Months
                               i
 Alternative  S4  includes excavation and off-site disposal of the
 contaminated soils  from the Site at an approved RCRA  landfill.
 Sample analyses indicate  that the vertical extent of
 contamination extends from approximately 9 to 11 feet below
 grade.  Based on this information, an estimated 37 cubic yards,
 or approximately 50 tons, of material will require excavation.
 As the excavation occurs, the material will be sampled until the
 results indicate that the soils do not contain TCE above 320 ppb.
 Once the  excavation is complete, additional clean borrow material
 will be brought in to restore the excavation to original grade,
 and the existing asphalt  surface will be repaired.

 85     In Situ  Vacuum Extraction

 Estimated Capital Costs:  $46,888
 Estimated Annual O&M Costs: $42,073
 Estimated Present-Worth Costs: $78,961
 Estimated Implementation  Time: 2 Months
 Estimated Operation Time: 1 year

 Vacuum Extraction ("VE")  is an in-situ process that requires
 minimal site disturbance  prior to and during implementation.
 Under this alternative, a VE well would be installed  to
 approximately 11 feet below grade in the area of concern.  The
 well will  be connected to a vacuum.  The organic constituents in
 the subsurface  will  volatilize and be drawn to the extraction
 well because of the induced vacuum.  The vapor discharge from the
 VE system would pass through an off-gas treatment unit, such as
 vapor-phase  GAG or a thermal treatment unit, to reduce
 contaminant  concentrations in the air stream to acceptable levels
 prior to discharge.  If contaminant concentrations in the off-gas
 remain constant during the cycle phase, the VE unit will be
 turned off,  and post-treatment sampling will be performed to
 confirm that  the treatment was successful.

Qroundwater Alternative*

Common Components

All of the treatment systems except the No Action alternative
will be designed to reduce or remove the Site-related VOCs in the
 extracted groundwater,  unattended, on a continuous, 24-hour-per-
day performance basis.   The ultimate objective of these
groundwater pump and treat alternatives is to comply, if
technically practicable, with the Commonwealth of Pennsylvania's
standards requiring that groundwater containing hazardous
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substances be remediated to "ouckground" quality as set forth in
25 Pa. Code SS264.97(i) and (j), and 264.100(a)(9) or the MCL,
whichever is more stringent.  The combined recovery well pumping
rate that will capture the estimated groundwater contaminant
plume is approximately 225 gallons per minute  ("gprn").  All the
treatment systems will be designed to handle raw groundwater at a
rate of approximately 250 gpm.  The systems will also have the
flexibility to respond to varying concentrations and flow rates.
The final combined pumping rate will be determined by EPA during
design based on the size and number of wells necessary to
hydraulically control the contaminated groundwater plume.  Since
the effluent from the selected system will be discharged to the
Schuylkill river, the system will be designed to remove 98% of
the VOCs in order to comply with the State's discharge
requirements.  If variations occur, such as increased contaminant
concentration or increased flow rate, the selected system may not
be capable of attaining the required effluent concentration
limits.  Options to address these potential variations will be
evaluated as necessary during the detailed system design.

Other common components include:

•  Performance of a predesign hydrogeologic investigation
including aquifer pumping tests to further delineate the outer
boundaries of the contaminated groundwater plume and provide
sufficient data to design an extraction system that will meet, to
the extent technically practicable, the objective to restore the
contaminated groundwater plume to background levels or MCLs,
whichever is more stringent.

•  Abandonment of wells which serve no useful purpose in order to
eliminate the possibility of these wells acting as a conduit for
future groundwater contamination.  Wells which may be abandoned
include the pumping wells on the Allied Steel property and any
well not used or considered for practical use as part of a long-
term groundwater monitoring network.

•  Performance of a Phase I archaeological survey prior to any
intrusive remedial activities.

•  Periodic monitoring of groundwater to determine the
effectiveness of the selected alternative.

GWl     NO Action

Estimated Capital Costs: $0
Estimated Annual O&N Costs: $69,077
Estimated Present-Worth Costs: $1,263,555
Estimated Implementation Time: Immediate

The NCP requires that EPA consider a "No Action" alternative for
every site to establish a baseline for comparison to alternatives
that do require action.  Under this alternative, no action would
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 be taken at the Site to remove  remediate,  contain,  or otherwise
 address the groundwater contamination.   This alternative only
 includes ongoing private water supply well  monitoring for 30
 years.

 GW2     Extraction/Air stripping/Discharge  to Schuylkill River

 Estimated Capital Costs:  $413,400
 Estimated Annual O&M Costs:  $246,400
 Estimated Present-Worth Costs:  $4,920,557
 Estimated Implementation Time:  30  years

 It is anticipated that the air stripping system will include a
 treatment building,  dual bag filters, controls,  and  an air
 stripping tower with a blower,  discharge pump,  instrumentation
 and controls,  and emission control equipment.   The treatment
 building will  have space reserved  for additional process
 equipment,  as  needed.   Groundwater will  be  pumped from recovery
 wells through  buried pipelines to  the treatment building.   The
 piping  will transfer water from the tank, through a  dual bag
 filter,  to an  air stripping tower.  The  filtered groundwater will
 be introduced  at the top of an air stripping tower,  and will flow
 countercurrent to a  clean air stream  introduced at the base of
 the stripping  tower.   The tower will  be  designed to  remove VOCs •*..
 from groundwater to  meet effluent  requirements.   The vapor stream
 will be exhausted to a vapor treatment system while  the treated
 groundwater will be  discharged to  the Schuylkill.

 GW3      Extraction/OAC Treatment/Discharge  to Schuylkill River

 Estimated Capital Costs:  $638,700
 Estimated Annual O&M Costs:  $169,480
 Estimated Present-Worth Costs:  $3,738,834
 Estimated Implementation  Time:  30  years

 A  system to treat contaminated  groundvater  with  GAG  would include
 water conditioning,  solids filtration and handling,  and GAC
 adsorption.  The groundwater will  be  pumped to the filters for
 solids removal,  and  then  to  GAC columns  for adsorption of  VOCs.
 The  solids  from  the  filters  will be characterized  for proper
 disposal.   The effluent will be discharged  to the  Schuylkill
 River.

 OW4      Extraction/  OV/Oxidation /Discharge to Sohuylkill  River

 Estimated Capital  Costs:  $808,900
 Estimated Annual O&M Costs:  $165,900
 Estimated Present-Worth Costs:  $3,843,548
 Estimated implementation  Time:  30 years

A system to treat  contaminated  groundwater  with  UV/oxidation
would include water  conditioning, solids filtration,  air
compression, ozone generation,  a hydrogen peroxide metering


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system, the UV/ oxidation reactor, and the catalytic ozone
decomposer..

The UV/ oxidation process uses a combination of UV radiation,
ozone, and hydrogen peroxide to destroy organic compounds in
water by oxidizing them.  The final reaction products include
salts, water, carbon dioxide, and possibly some organic acids.

Groundwater pretreatment is required to reduce the concentration
of metals that will hinder the operation of the system.
Pretreated groundwater  is mixed with hydrogen peroxide before
entering the UV/oxidation reactor.  In the reactor, ozone and
hydrogen peroxide oxidize the organic contaminants.

Ozone discharged to the environment is corrosive to electrical
components, many metals, and foliage.  To avoid ozone discharge
to the atmosphere, a catalytic ozone decomposer is included in
the system design.  The catalytic ozone decomposer achieves ozone
destruction efficiencies greater than 99.99 percent.

VIII.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The remedial action alternatives for the water supply, soil and
groundwater described above were evaluated using nine evaluation
criteria.  The resulting strengths and weaknesses of the
alternatives were then  weighed to identify the alternative
providing the best balance among the nine criteria.  A summary of
these nine criteria is  provided below.

        of Nine Criteria
In selecting EPA's preferred alternatives EPA evaluated each
proposed remedy against the nine criteria specified in the
National Contingency Plan.  The alternative must first satisfy
the threshold criteria.  Next the primary balancing criteria are
used to weigh the tradeoffs or advantages and disadvantages of
the alternatives.  Finally after public comment has been obtained
the modifying criteria are considered.  Below is a summary of the
nine criteria used to evaluate the remedial alternatives.

Threshold  Criteria

     • overall protection of hUBflP health, and the environment f
       Whether the remedy provides adequate protection and how
risks posed through each pathway are eliminated, reduced or
controlled through treatment, engineering controls, or
institutional controls.
           .1
     • Compliance with ARARs:
       Whether or not a remedy will meet all applicable or
relevant and appropriate requirements ("ARARs") of Federal and
State environmental statutes and/or whether there are grounds for
invoking a waiver.
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 Primary  Balancing Criteria

      • Lona-Term effectiveness and permanence;
       The  ability of  the remedy to afford  long term,  effective
 and  permanent  protection to  human health and the  environment
 along with  the degree  of certainty that the alternative will
 prove successful.

      • Reduction of toxicitv. mobility or volume:
       The  extent to which the alternative  will reduce the
 toxicity, mobility,  or volume of the contaminants causing the
 site risks.

      » Short term effectiveness:
       The  time  until  protection is achieved and the short term
 risk or  impact to the  community, onsite workers and the
 environment that may be posed during the construction  and
 implementation of  the  alternative.

      • Implementabilitv:
       The  technical and administrative feasibility of a remedyr
 including the  availability of materials and services needed to
 implement that remedy.

      • Cost;
       Includes  estimated capital, operation and maintenance, and
 net  present worth  costs.

Modifying Criteria

      • State Acceptance;
       Whether the Commonwealth concurs with, opposes, or has no
comment on  the selected remedy.  Based on FADER comments, the
Commonwealth concurs with the remedy and therefore this criteria
will  not be discussed  further.

      • Community Acceptance;
       Whether the public agrees with the selected remedy.  A
public meeting on  the  Proposed Plan was held May 27, 1993 in
Pottstown, Pennsylvania.  Comments received from the public
meeting and comments received in writing during the public
comment period are referenced in the Responsiveness Summary
attached to this Record of Decision.  The community favors the
selected remedy and  therefore this criteria will not be discussed
further.


Comparative^ Analysis of Alternatives
Water Supply Alternatives

Overall Protection.  Since WS1 (No Action)  would neither
eliminate nor  reduce to acceptable levels the threats  to human
health presented by  contamination at the Site, it will not be
                                22

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discussed  in the  remainder o2 chis analysis.  Alternatives WS2,
WS3 and WS4. would all protect human health because they
significantly reduce the risk associated with the ingestion and
inhalation of contaminated groundwater by providing a potable
source of  drinking water to the affected residents.
The preferred alternative WS3 provides the highest level of long
term effectiveness and permanence because a permanent source of
potable water will be provided by an existing water authority
that is regulated under State lav.

Compliance with ARARs.  ARARs will be met by all the remedial
alternatives with the exception of the No Action alternative.
Alternatives WS2, WS3 and WS4 will provide the affected residents
with a source of  potable water, which is in compliance with
currently  promulgated MCLs, as presented in 40 C.F.R. Part 141
and, to the extent that the requirements are more stringent, in
25 PA Code $109.202(a) and (b).

Long Term  Effectiveness and Permanence.  Alternative WS3 provides
the highest level of long term effectiveness and permanence
because a  permanent source of potable water will be provided by.
an existing water authority that is regulated under State law.
Alternatives WS2  and WS4 will require continual long term
monitoring of the contaminated groundwater to ensure
effectiveness.

Reduction  of Toxicity, Mobility, or Volume through Treatment.
Alternatives WS2, WS3 and WS4 will not reduce the toxicity,
mobility,  or volume of the contaminants detected in the Site
groundwater except through natural attenuation, dispersion, or
degradation.  These alternatives will, however, eliminate the
exposure of affected water users to site-related groundwater
contaminants by providing an alternate water supply.  Since WS4
includes treatment of individual well water, it affords a very
minor reduction in the toxicity and volume of the impacted
groundwater by treating the portion used as a potable water
source.

Short T«rm Bff«ctiv«n«««.  Alternatives WS2, WS3 and WS4 all have
minimal short term impacts and can all be implemented in a
relatively short time frame.  The risks to workers and the
community  during  implementation are very minimal for all the
alternatives because there is no contact required with
contaminated groundwater or soils.

implementability.  There are no technical constraints on
implementing any of these alternatives.  Commercially available
equipment  and materials can be used for all phases of these
alternatives.  Alternatives WS2 and WS4 will require long-term
monitoring to gage the migration of the contaminant plume.
Periodic long-term monitoring will also be required, however,
under the  groundwater alternatives.  Access issues will need to
be addressed for  installing the community well (WS2) and the


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 municipal  line  (WS3).  Administratively, Alternative WS2  may  be
 difficult  to  implement since  a  permanent authority would  have to
 be established  to  administer  and  maintain  the system.

 Costs.   Capital and  operation and maintenance costs are
 summarized in Table  10.   The  Municipal Line Alternative (WS3)
 would have the  lowest net present-worth costs at  $317,421.

 Comparative Analysis Of Alternatives
 Soil Alternatives

 Overall  Protection.  EPA  developed a soil  cleanup level (320  ppb
 of TCE)  with  the objective of removing contaminated soil  that has
 the potential to cause groundwater contamination  above  background
 levels.  SI (No Action) and 52  (Asphalt Cap) would neither
 eliminate  nor reduce the  soil  contamination to acceptable
 levels,  except  by  natural attenuation.  Therefore, they  will not
 be discussed  further.  Alternatives S3, S4 and S5 provide the
 highest  levels  of  overall protectiveness because  they will result
 in the permanent removal  of the contaminants of concern from  the
 soils at the  Site.   There could be potential short-term impacts -
 associated with the  two excavation alternatives (S3 and S4),  but'
 these are  very  minimal since  the  levels of VOCs are below health
 based risk levels.   S3 and S4 have an advantage over alternative
 S5 in regards to long-term effectiveness and permanence because
 the post-excavation  sampling  method is more reliable than the
 post-treatment  sampling method.

 Compliance with ARARs.  There are  no ARARs that are pertinent for
 the development of clean-up levels for the contaminated soil  at
 the Site.   The  equations  used to develop soil cleanup criteria
 for TCE  in soil  for  the site  require use of an acceptable
 standard for  groundwater.  The  groundwater criteria are used  to
 back calculate  the soil criteria.  Section 264.97(i) and  (j)  and
 264.100(a)(9)  of Title 25  of  the PA Code sets forth standards
 that are ARARs  for groundwater.  These regulations were used  in
 the development  of soil cleanup criteria.  Alternatives S3, S4
 and S5 will meet the soil  clean-up criteria.  Since contaminants
will exist  in the soil excavated under Alternatives S3  and S4,
the soil will be tested to determine if it is a RCRA
characteristic waste in accordance with 40 C.F.R. $261.24 by  the
Toxic Characteristic Leaching Procedure ("TCLP").  If it  is
determined to be hazardous waste,  the remedy will be implemented
consistently with the substantive  requirements, which are
relevant and appropriate,  of  25 Pa. Code SS262.11 and 262.12
 (relating to hazardous waste determination and identification
numbers),  25 Pa. Code SS262.20-262.23 (relating to manifesting
requirements for off-site  shipments of spent carbon or  other
hazardous wastes),  and 25  Pa.  Code 55262.30-262.34 (relating to
pretransport requirements); 25 Pa. Code $$263.10-263.31 (relating
to transporters of hazardous wastes); and with respect  to the
operations at the Site generally, with the substantive
requirements of 25 Pa.  Code $$264.10-264.56 and 264.170-264.178
                                24

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 (in  the event that  hazardous waste generated  as part of the
 remedy is  managed in containers), 25 Pa. Code SS264.190-264.199
 (in  the event that  hazardous waste is managed, treated or stored
 in tanks);  and if prohibited by  land disposal restrictions,  40
 CFR  SS268.7,  268.9  and  268.35  (although 40  CFR $268.32(e)(2) was
 cited  as an ARAR in the Proposed Plan for this Site, EPA does not
 presently  have sufficient  information to determine whether the
 constituents  are hazardous wastes; however, as noted above,  EPA
 shall  require the performance  of TCLP testing to address this)
 and  40 CFR $268.50  (prohibitions on storage of hazardous waste),
 which  are  relevant  and  appropriate.

 Long Term  Effectiveness and Permanence.  Alternatives S3, S4 and
 S5 provide a  high level of long  term effectiveness and permanence
 because they  will result in the  permanent removal of the
 contaminants  of concern from the soils at the Site.  The degree
 of effectiveness attained  by S5, however, must be verified by a
 post-treatment soil sampling method which is  less reliable than
 the  post-excavation soil sampling method associated with S3  and
 S4.  S3  and S5 permanently destroy the contaminants through
 treatment.  However,  EPA's preference to use  treatment to address
 the  principle threats is met by  the treatment of groundwater as
 discussed  under the groundwater  alternatives.

 Reduction  of  Toxicity,  Mobility, or Volume  through Treatment.
 Alternatives  S3,  S4 and S5 will  result in a permanent reduction
 in the toxicity,  mobility, and volume of the  contaminants of
 concern at  the Site because the  contaminants  will either be
 permanently destroyed or removed from the Site.  Alternative S4
 will not treat the  contaminants  but EPA's. preference to use
 treatment  to  address  the principle threats  is met by the
 treatment of  groundwater.

 Short  Term  Effectiveness.  Alternative S5 will have the least
 short-term  impacts  associated  with Site disturbance.  Short-term
 impacts  associated  with alternatives S3 and S4 include the
disruption  of  the Site  associated with removing and replacing
soil and the  existing asphalt  layer and physical risks involved
 in any activities where heavy  equipment is  used..  The risks
associated  with  the two excavation alternatives (S3 and S4),
however, are  very minimal  since  the levels  of VOCs are below
health-based  risk levels.  The off-gas froa the Vacuum Extraction
system will require monitoring to ensure that it complies with
relevant health-based standards.

 Implementability.   The  excavation alternatives (S3 and S4) do not
require  specialized equipment, but will require personnel
experienced in hazardous material handling  and transport.
Experienced transporters are readily available to convey the
material to the  appropriate facility.  Vacuum Extraction (S5)
requires experienced  personnel and specialized equipment.  A
pilot  study should  be performed  to confirm  the operating
parameters  of  the system.  VE  has, however, been effective for
                                25

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 removing the contaminants of concern in similar subsurface
 environments.

 Costs.   Capital and operation and maintenance costs are
 summarized in Table 10.   The Excavation/Offsite Landfill
 alternative (S4)  would have the lowest net present-worth  costs  at
 $40,261.

 Comparative Analysis Of Alternatives
 Groundwater Alternatives

 Overall  Protection.   Since GW1 (No Action)  would neither
 eliminate nor reduce to acceptable levels  the threats  to  human
 health or the  environment presented by contamination  at  the
 Site, it will  not be discussed in the remainder of  this analysis.
 Alternatives GW2,  GW3 and GW4 would  all protect human  health
 because  they significantly reduce the risk associated  with the
 ingestion and  inhalation of contaminated groundwater by treating
 the plume.

 Compliance with ARARs.   ARARs will be met  by  all the remedial
 alternatives with the exception of the No  Action alternative.
 Alternatives GW2,  GW3 and GW4 will comply  if  technically
 practicable, with the Commonwealth of Pennsylvania's standards
 requiring that groundwater containing hazardous substances be
 remediated to  "background11 quality as set  forth in  25  Pa. Code
 SS264.97(i)  and (j),  and 264.100(a)(9),  or MCLs,  whichever are
 more stringent.   Any surface water discharge  of treated effluent
 will comply with  the substantive requirements of the National
 Pollutant Discharge  Elimination System ("NPDES")  discharge
 regulations set forth in 25 Pa.  Code $92.31,  and the Pennsylvania
 Water Quality  Standards  (25 Pa.  Code S93.1-93.9).

 Long Term Effectiveness  and Permanence.  Once clean-up goals have
 been met,  contaminant concentrations in the groundwater aquifer
 will be permanently  reduced to acceptable  levels by alternatives
 GW2, GW3  and GW4.

Reduction of Toxieity, Mobility,  or  Volume  through  Treatment.
Alternatives GW2, GW3 and GW4  all include recovery  and treatment
 of the contaminated  groundwater and  will therefore  significantly
 reduce the  toxicity,  and volume of the  contaminants of concern by
 removing them.  The  volatile organics recovered in  GW2  will be
removed from the groundwater in the  air  stripping tower, and will
be treated  by the off-gas control system.   The  volatile organics
recovered  in GW3 will be removed from the groundwater  by the GAC.
The contaminants of  concern recovered in GW4 will be treated by
oxidizing them  to carbon dioxide,  water, and salts.
                                26

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 Short T«m Effectiveness.   Alternatives GW2,  GW3  and GW4 all have
 similar short-term impacts related to dermal  hazards associated
 with workers contacting the contaminated groundwater, physical
 hazards associated with installing the recovery well and effluent
 distribution piping and potential  hazards to  on-site personnel.
 Potential dermal contact hazards can be minimized using
 appropriate personnel protective equipment when contact with
 contaminated groundwater is possible.   Physical hazards will be
 minimized by using experienced field personnel  and good field
 practices.   Short-term impacts resulting from stripper emissions
 (GW2)  will be controlled by using  the appropriate off-gas
 treatment.   The hazards associated with UV/Oxidation (GW4)  are
 greater than those associated  with air stripping  and GAC due to
 the hydrogen peroxide and  ozone handling requirements.

 Implemantability.   Alternatives GW2,  GW3 and  GW4  can be readily
 implemented at the Site.   Sufficient information  is currently
 available for preliminary  sizing of the treatment systems'
 components,  however,  these components are subject to modification
 during the final design of the alternative.  Groundwater
 extraction using recovery  wells and treatment by  air stripping -
 (GW2)  and GAC (GW3)  are proven technologies for treating
 contaminated groundwater whereas treatment by UV/oxidation  is
 still  considered an innovative technology for contaminated
 groundwater treatment,  but has proven effective in numerous
 industrial  wastewater treatment applications  for  similar
 contaminants.   Consequently, UV/Oxidation will  require a
 treatability study to accurately determine all  the operating
 parameters  of the  system.   Periodic sampling  of the effluent from
 the all of  the alternatives will also be required to ensure that
 the discharge complies  with ARARs.   Likewise, all of the
 alternatives will  require  long-term monitoring  to determine the
 effectiveness of the  systems to contain and remediate the
 contaminant plume.

 The distribution pipeline  from the treatment  facility to the
 Schuylkill  River can  be installed  using readily available
 equipment.   It will be  necessary to address access issues with
 landowners  in connection with  the  installation  of the piping
 along  the proposed discharge line.   Since this  portion of the
 remedy will  be implemented entirely on-site,  only the substantive
 requirements of PADER's NPDES  discharge permit  must be met.

 Costa.   Capital and operation  and  maintenance costs are
 summarized  in Table 10.  The Excavation/Offsite Landfill
'alternative  (S4) has  the lowest net present-worth costs at
 $40,261.
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 IX.  SELECTED REMEDY

 EPA has selected Alternatives WS3,  S4 and GW3 as the remedy for
 the Recticon/Allled Steel Site.   This remedy shall also include
 verification sampling of soil/sediment for copper and zinc and
 performance of a Phase I archaeological survey.   This remedy is
 protective of human health and the environment,  cost-effective,
 shall meet ARARs, and utilizes treatment technologies to the
 maximum extent practicable.   The selected remedy includes the
 following components:

      -Installation of a municipal water line;

      -Excavation and off-site disposal of contaminated soils;

      -Extraction and treatment of groundwater with discharge to
       the Schuylkill River following a predesign hydrogeologic
       investigation and well  abandonment;

      -Long-term groundwater monitoring;

      -Verification sampling to determine the source and extent of
       the copper and zinc found  in  drainage  ditch sediments;  and

      -Performance of a Phase  I archaeological survey.

 Each  component of the  remedy  and its performance standard(s)  will
 be  described in turn.

      Municipal Water Lin*

      A.    Description  of the  Component of the Remedy

 This  portion of the  remedy will  provide  a source of potable water
 to  the affected and  potentially  affected residents by  extending a
 municipal  water line to the area of  concern  in the vicinity of
 the Site  (see Figure 6).   The Citizen's  Home Utility Water
 Company currently supplies water to  East Vincent Township, and
 has sufficient capacity at this  time to  provide  water.  A water
 supply pump  station  and main  is  located  southeast of the  Site in
 East  Vincent Township  on Shady Lane.   A  water line will be
 installed  from the pumping station or main to the Site and the
 affected well users  will be connected to the line.   The line  will
 be  installed in a  trench below the freeze line along and  across
 Old Schuylkill  Road  and brought  into the area  of concern.
 Independent  connections will  then be brought into each of  the
 affected residences  and businesses.   Fire hydrants will be
 installed  at  500  foot  intervals  along the water  line.  Only those
 users currently impacted or potentially  impacted by the
 contamination in the groundwater will be connected to the
municipal water system.   All  areas impacted  by the construction
 activities during  remedy implementation  and  operation and
maintenance shall  be graded,  restored and  revegetated, as


                                28

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necessary.  The  existing residential wells shall be abandoned, if
appropriate..

     B.    Performance Standards

The water supply system shall be constructed in compliance with
the requirements of the Citizens Utility Home Water Company and
local and State  requirements.  Connections shall be offered and
provided to the  residences and businesses currently served by
individual carbon filtration units (see Table 11) and any other
residence determined by EPA during the Remedial Design to be
affected or potentially affected by the plume of contamination.
Potentially impacted wells include those that are within or near
the boundaries of the contaminated groundwater plume and those
that are hydraulically impacted by the remedial action.  A
determination concerning which wells may be potentially impacted
will be made once the outer boundaries of the contaminated
groundwater plume has been further delineated based on the
results of the predesign hydrogeologic investigation.  All areas
impacted by the  construction activities during remedy
implementation and operation and maintenance shall be restored to
preexisting conditions.  When the affected and potentially
affected parties are connected into the public water supply
system, all wells shall be abandoned by the party implementing
the remedy, unless the well is selected as a sampling location
for long-term groundwater monitoring.  Such abandonment shall be
performed in compliance with the requirements of 25 PA Code
109.602(c) and consistent with PADER's Public Water Supply
Manual, Part II, Section 3.3.5.11

To the extent that the implementation of this portion of the
remedy impacts floodplains and wetlands (e.g., installation of
the municipal water line), the performance standard will be
compliance with  Executive Order No. 11983 and 40 CFR Part 6,
Appendix A (regarding avoidance, minimization and mitigation of
impacts on floodplains), and Executive Order No. 11990 and 40 CFR
Part 6, Appendix A (regarding avoidance, minimization and
mitigation of impacts on wetlands).

2.   Bxovation  and off—Bite Disposal of contaminated Boil

     A.   Description of the Component of the Remedy

This portion of  the remedy consists of excavation and off-site
disposal of the  impacted soil located beneath the parking lot on
the northwest portion of the former Recticon facility to a
permitted RCRA landfill.  Excavation will continue until the soil
left in place meets the soil clean-up level of 320 ppb of TCE.

The asphalt and  subbase in the excavation area described above
will be removed  and staged for off-site disposal as construction
debris.  Excavation will then begin using a backhoe, and the
sides of the excavation area will be cut back to a minimum 2 to 1
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 slope to prevent side wall failure.   Excavation will continue  to
 a depth of 9 feet.   Soil removed during this phase of the
 excavation will be  stockpiled at a location approved by EPA
 pending sample analyses and,  if analyses show that this soil has
 less than 320 ppb of TCE,  it  will be utilized for replacement
 material after excavation activities are complete.

 All soil from the 9 to 11 foot depth interval,  and any additional
 soil containing TCE greater than 320 ppb,  will  be removed  in
 lifts and loaded onto vehicles for transport to a permitted, off-
 site RCRA landfill  facility.   Sediment and erosion controls and
 temporary covers will be installed to protect exposed soil from
 the effects of weather consistent with the FADER Bureau of Soil
 and Water Conservation's Erosion and Sediment Pollution Control
 Manual.

 Post-excavation sampling will be performed after the excavation
 has progressed to 11 feet.  Post-excavation samples will be
 obtained from the base and the sidewalls of the excavation to
 ensure that contamination is  not present above  the clean-up
 level.   The location of the post-excavation samples will be
 selected based on visual observation of lithology and screening
 for VOCs using an appropriate organic vapor detector.   The
 samples  will be analyzed for  VOCs on a quick turnaround basis
 using a  method approved by EPA.   If  the post-excavation sample
 concentrations are  below the  clean-up level,  the excavation will
 be  backfilled using the stockpiled clean soil.   Additional clean
 borrow material will be brought in to restore the excavation to
 original grade,  and the asphalt surface will be repaired.
 Backfilling will be performed in 6-to-12 inch lifts,  and the
 material will be compacted to minimize the potential for
 subsidence.

 If  TCE is detected  above 320  ppb in  the post-excavation samples,
 additional  material will be removed  from the excavation area,  and
 new samples will be obtained  for analysis  as discussed above.
 Excavation  and sampling activities will continue until the
 results  indicate that the  soils  do not contain  TCE above the
 clean-up level.   The excavation  area will  then  be restored as
described in the preceding paragraph.

     B.     Performance Standards

The performance standard for  the excavation of  soils  from  the
area of  excavation  is  to remove  all  soil with concentrations of
TCE greater than 320 ppb, which  is the soil clean-up  level.

The performance standard to protect  exposed soil from the  effects
of weather  sJiall  be compliance with  the PADER Bureau  of  Soil and
Water Conservation's Erosion  and Sediment  Pollution Control
Manual.
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 3.    Extraction and Treatment of Qroundwater

      A.    Description of the Component of the Remedy

 Groundwater shall be treated using an on-site treatment  system.
 The treatment system will be designed to reduce the Site-related
 VOCs in  the extracted groundwater, unattended, on a continuous,
 24-hour-per-day performance basis.  Groundwater shall be
 collected using multiple extraction wells.  The exact location,
 size and number of wells shall be determined during the  design of
 the groundwater recovery system following a predesign
 hydrogeologic investigation.  The predesign study is necessary to
 further  define the outer boundaries of the groundwater plume and
 the hydraulic properties within the aquifer and the contact zone
 with the Schuylkill River.  A system to treat contaminated
 groundwater with GAC shall include water conditioning, solids
 filtration and handling,  and GAC adsorption.  The groundwater
 will be  pumped to filters for solids removal, and then to GAC
 columns  for adsorption of VOCs.  Spent solids from the solids
 filtration system will be characterized in accordance with 40
 C.F.R. S261.24 by the Toxic Characteristic Leaching Procedure
 ("TCLP")  for proper disposal.  The treated groundwater effluent
 will be  discharged to the Schuylkill River through a new outfall
 pipe that shall be constructed as part of the remedial action.
 The treatment system will be designed to achieve 98 percent
 removal  of VOCs in compliance with the substantive requirements
 of  PADER's NPDES regulations.  Final flow rates arid GAC  system
 dimensions will be determined by EPA during remedial design.  The
 final combined pumping rate and the exact location, size and
 number of wells shall be based on the ability to hydraulically
 control  the contaminated groundwater plume as determined by EPA.
 The  pumping rate will be designed not to impact the water table
 elevation in the remaining operating private wells in the area.
 Extraction and treatment will continue until EPA, in consultation
 with the  Commonwealth of Pennsylvania, determines that the
 performance standard for each contaminant of concern in  the
 groundwater has been achieved, to the extent technically
 practicable,  throughout the entire contaminated groundwater
 plume, including both the groundwater contamination in the area
 of the former Recticon and Allied Steel facilities and the area
 of groundwater contamination located beyond the facilities'
 property  boundaries.   Figure 6 shows the approximate area
presented in the RI.

 In addition,  existing pumping and monitoring wells which serve no
useful purpose shall be properly plugged and abandoned consistent
with PADER's Public Water Supply Manual, Part II, Section
 3.3.5.11  in order to eliminate the possibility of these  wells
 acting as  a conduit for future groundwater contamination.  Wells
which may be plugged and abandoned include the pumping wells on
 the  Allied  Steel property and any well not used or considered by
 EPA  for practical use as  part of a long-term groundwater
monitoring  network.   Periodic monitoring of groundwater  will
                                31

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 occur to determine the performance of the  pump and treat system
 and the effectiveness of the relected remedy in meeting the
 performance standards.

      B.    Performance Standards

 The performance standard for each contaminant of concern in the
 groundwater in the area of groundwater  contamination shall be the
 MCL for that contaminant [40 c.F.R. Part 141 and, to the extent
 that the MCLs more stringent, in 25 PA  Code 5109.202(a)] or the
 background concentration of that contaminant [25 PA Code
 SS264.97(i), (j), and 264.100(a)(9)], whichever is more
 stringent.  The background concentrations  for each contaminant of
 concern shall be established in accordance with the procedures
 for groundwater monitoring outlined in  25  PA Code §264.97 before
 groundwater treatment begins.  In the event that a contaminant of
 concern is not detected in samples taken for the establishment of
 background concentrations, the detection limit for the method of
 analysis utilized with respect to that  contaminant shall
 constitute the "background" concentration  of the contaminant.
 The area of groundwater contamination (the area in which these
 performance standards are to be met) is the entire contaminated
 groundwater plume, including the groundwater contamination in the.
 area of the former Recticon and Allied  Steel properties and the
 area of groundwater contamination beyond those property
 boundaries.  MCLs, detection limits, and appropriate analytical
 detection methods for these contaminants of concern are listed
 below.

 Contaminant       MCLfuo/n         Detection Limit (uo/n            Method'

 Tetrachloroethylene    5                       0.03             601/602
 Trichtoroetnytene     5                       0.12             601/602
 Vinyl Chloride        2                       0.18             601/602
 1,1-Dfchtoroethylene   7                       0.13             601/602
 1,2-Dichloroethane    5                       0.03             601/602
 Dtehloroethylene     70                       0.12             524.2
 (cis-1.2-)

 'Method 601/602 40 C.F.R. Part 136
 Method 524.2 40 C.F.R. Part 141

 The performance standard for the treated groundwater prior to
 discharge  to the Schuylkill River shall be compliance with the
 substantive requirements of the NPDES discharge regulations set
 forth in 25 Pa. Code $92.31,  and the Pennsylvania Water Quality
 Standards  (25 Pa. Code SS93.1-93.9).  Pursuant to the
Pennsylvania Department of Environmental Resources'
determination,   98 percent removal of trichloroethylene and cis-
 1,2-dichloroethylene shall be required  prior to discharge to the
 Schuylkill.   Monitoring for all the other  contaminants of concern
 shall also be required.
                                 32

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The performance  standard for well abandonment shall be compliance
with PADER's Public  Water Supply Manual, Part II, section
3.3.5.11.

To the extent that the  implementation of this portion of the
remedy impacts floodplains and wetlands  (e.g., installation of
the wells, piping, buildings and the outfall pipe), the
performance standard will be compliance with Executive Order No.
11983 and  40 C.F.R.  Part 6, Appendix A  (regarding avoidance,
minimization and mitigation of impacts on floodplains), and
Executive  Order  No.  11990 and 40 C.F.R. Part 6, Appendix A
(regarding avoidance, minimization and mitigation of impacts on
wetlands).
           «.

     C.    Groundwater Remedy Implementation

Because the selected remedy will result in contaminants remaining
on-site, 5-year  Site reviews under Section 121(c) of CERCLA will
be required.

An operation and maintenance plan for the groundwater extraction,
and treatment system, including long-term groundwater monitoring,
shall also be required.   The performance of the groundwater
extraction and treatment system shall be carefully monitored on a'
regular basis, as described in the long-term groundwater
monitoring component in  4.A. below, and the system may be
modified,  as warranted by the performance data collected during
operation.  These modifications may include, for example,
alternate  pumping of extraction wells and the addition or
elimination of certain extraction wells.  In addition, all of the
extraction/treatment alternatives (GW2, GW3 and GW4) rated
relatively evenly against all of the criteria except the cost
criterion.  Consequently,  if, based on more detailed information
gathered during  remedy implementation or operation, variations
occur,  such as a change  in the contaminant concentration or flow
rate,  the  selected system may no longer be cost-effective when
compared to one, or  a combination, of the other
extraction/treatment alternatives.  In that case, based on the
final design parameters,  EPA may consider the utilization of a
combination of any of the groundwater treatment technologies
under GW2, GW3 or GW4.

It may become apparent during implementation or operation of the
groundwater extraction system and its modifications, that
contaminant levels have  ceased to decline and are remaining
constant at levels higher than the performance standards over
some portion of the  contaminated plume.  If EPA, in consultation
with the Commonwealth of Pennsylvania, determines that
implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will be technically  impracticable to achieve and maintain the
performance standards throughout the entire area of groundwater
contamination, EPA,  in consultation with the Commonwealth may
                                33

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 require that any or all of the following measures be taken,  for
 an indefinite period of time,  as further modification(s)  of  the
 existing system:

 a)   long-term gradient control provided by low level pumping,  as
 a containment measure;

 b)   chemical-specific ARARs may be waived for  those  portions of
 the aquifer that EPA,  in consultation with the Commonwealth
 determine that it is technically impracticable to achieve further
 contaminant reduction;

 c)   institutional controls may be provided/maintained to  restrict
 access  to those portions of the aquifer where  contaminants remain
 above performance standards; and

 d)   remedial technologies for  groundwater restoration may be
 reevaluated.

 The decision to invoke any or  all of  these measures  may be made
 during  implementation or operation of the remedy  or  during the 5-
 year reviews of the remedial action.  If such  a decision  is  made,'
 EPA shall amend the ROD or issue an Explanation of Significant
 Differences.

 4.   Long-Term Qroundvater Monitoring

     A.    Description  of the Component  of the  Remedy

 A long-term groundwater monitoring program shall  be  implemented
 to  evaluate the effectiveness  of the  groundwater  pumping  and
 treatment system.   A plan for  the long-term groundwater
 monitoring program  shall be included  in the operation and
 maintenance plan for the groundwater  extraction and  treatment
 system.   Numbers and locations of these monitoring wells  shall be
 approved  by EPA during the remedial design, in consultation  with
 the Commonwealth of Pennsylvania.   The  wells shall be installed
 in the area of  groundwater contamination and sampled quarterly
 for the first three years and  semi-annually thereafter.   Sampling
 and operation and maintenance  shall continue until such time as
 EPA, in consultation with the  Commonwealth of  Pennsylvania,
 determine that  the  performance standard for each  contaminant of
 concern has been achieved to the extent technically  practicable
 throughout the  entire  area of  groundwater  contamination.   If EPA
 and the Commomwealth make such a determination, the  veils shall
 be sampled for  twelve  consecutive quarters throughout the entire
 plume and if contaminants remain at or  below the  performance
 standards, the  operation of the  extraction system shall be shut
down.

Semi-annual monitoring of the  groundwater  shall continue  for five
years after the system is shutdown.   If  subsequent to an
extraction  system shutdown, monitoring  shows that groundwater
                                34

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concentrations of any contaminant of concern are above the
performance standard, the system shall be restarted and continued
until the performance standards have once more been attained for
twelve consecutive quarters.  Semi-annual monitoring shall
continue until EPA determines, in consultation with the
Commonwealth of Pennsylvania, that the performance standard for
each contaminant of concern can be achieved on a continuing
basis.

     B.    Performance Standards

Implementation of the component of the remedy described in 4.A.,
above is the performance standard.

5.   Verification Sampling of Copper and Zinc

     A.   Description of the Component of the Remedy

During the conduct of the RI/FS, levels of copper and zinc in
upgradient and downgradient soil and sediment samples located in
the drainage areas on-site may be capable of causing adverse
ecological effects.  However, the source and extent of these
compounds in soil from surface drainages are not well
characterized.  It is possible that the copper and zinc
concentrations detected in downgradient soil samples are related
to site activities or the elevated levels may be related to road
surface runoff from Route 724 or Wells Road.  Further downstream,
Pigeon Creek and the adjacent wetland area may also be
potentially affected by the migration of copper and zinc with
drainage ditch sediments.  Additional sampling and investigation
are required to determine the source and extent of the copper and
zinc detected in the drainage ditch sediments.  The design and
construction of the groundwater pump and treatment system shall
be coordinated with this investigation so that design and
implementation schedules are compatible.  If necessary, as
determined by EPA, a program to protect sensitive environmental
receptors or habitats shall be implemented.

     B.    Performance Standards

Implementation of the component of the remedy described in 5.A.,
above is the performance standard.


     Phase X Archaeological Survey

     A.   Description of the Component of the Remedy
          V
Performance of a Phase I archaeological survey prior to any
remedial activities is also required in accordance with the
National Historic Preservation Act (Chapters 106 and 110(f) and
36 CFR Part 800) and the Archaeological and Historic Preservation
Act (16 U.S.C. S 469a-l).
                                35

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      B.     Performance  Standards

 Implementation of  the component of  the  remedy  described  in  6.A.,
 above is  the performance standard.

 X.   STATUTORY DETERMINATIONS

 EPA's primary responsibility  at Superfund  sites  is to  select
 remedial  actions that are protective  of human  health and the
 environment.   Section 121 of  CERCLA also requires that the
 selected  remedial  action comply with  ARARs, be cost-effective,
 and  utilize permanent treatment technologies to  the maximum
 extent practicable.  The following  sections discuss how  the
 selected  remedy meets these statutory requirements.
Based on the baseline risk assessment for the Site, potential
exposure to VOCs  in drinking water through  ingest ion,  inhalation,
and dermal contact, was  identified as the principal risk at the
Site.  Potential  exposure to soils was not  determined  to be a
principal threat  based on the depth and  level of contaminants in'
soil.

The selected remedy protects human health and the environment by
reducing levels of contaminants  in the groundwater to  ARARs
through extraction and treatment and providing a potable source
of drinking water through the municipal  water line.  The risk
level will be reduced to the 10~4 - 10"6  level or  less. The  soil
remedy will also  protect human health and the environment by
removing the contaminated soil,  thereby  eliminating the potential
for contaminant migration to the groundwater and preventing
exposure through  inhalation, ingestion,  and dermal contact.

Implementation of the selected remedy will  not pose any
unacceptable short-term risks or cross-media impacts to the Site
or the community.

Attainment of Applicable or Relevant mnd Appropriate Requirements
of EnviroT>tt>T*'*l  Laws
The selected remedy will comply with all applicable or relevant
and appropriate chemical-specific, location-specific, action-
specific ARARs.

Chemical Specific ARARs

The remedy .will provide the affected residents with a source of
potable water, which is in compliance with currently promulgated
MCLs, as presented in 40 C.F.R. Part 141 and, to the extent that
the requirements are more stringent, in 25 PA Code $109. 202 (a)
and (b) .
                                36

-------
 MCLs shall be achieved throughout the  entire contaminated
 groundwater plume in accordance with 40  C.F.R.  Part  141  and, to
 the extent that the requirements are more  stringent,  in  25  PA
 Code §109.202(a).  To the extent that  they are  more  stringent
 than these MCLs,  the Commonwealth of Pennsylvania  standards,
 which specify that all groundwater containing hazardous
 substances must be remediated to "background" quality pursuant to
 25  PA Code §S264.97(i),  (j), and 264.100(a)(9).  These background
 levels shall be attained as part of this remedial  action unless
 EPA,  in consultation with the Commonwealth of Pennsylvania,
 determines that attaining such levels  is technically
 impracticable,  or they are waived under  CERCLA  Section 121(d).

 Action-Specific ARARs

 Since the  treated groundwater will be  discharged to Schuylkill
 River,  the  National Pollutant Discharge  Elimination System
 ("NPDES")  requirements and the State water quality criteria under
 the Pennsylvania  Clean Streams Law specified below are ARARs for
 this  action.  Any surface water discharge  of treated  effluent
 will  comply with  the substantive requirements of the  NPDES
 discharge regulations set forth in 25  Pa.  Code  $92.31, and the
 Pennsylvania Water Quality Standards (25 Pa. Code  SS93.1-93.9).

 Since residuals will be  generated in the solids filtration
 portion of  the  treatment.system and the  spent GAC  carbon filters
 and contaminants  will exist in the excavated soil, these will be
 tested to determine if they are RCRA characteristic wastes in
 accordance  with 40 C.F.R.  $261.24 by the Toxic Characteristic
 Leaching Procedure ("TCLP").  If any of these are  determined to
 be  hazardous waste,  the  remedy will be implemented consistent
 with  the substantive requirements,  which are relevant and
 appropriate,  of 25 Pa. Code $$262.11 and 262.12 (relating to
 hazardous waste determination and identification numbers), 25 Pa.
 Code  $$262.20-262.23  (relating to manifesting requirements for
 off-site shipments of spent carbon or  other hazardous wastes),
and 25  Pa.  Code $$262.30-262.34 (relating  to pretransport
requirements);  25 Pa.  Code $$263.10-263.31  (relating to
transporters  of hazardous  wastes);  and with respect to the
operations  at the Site generally, with the substantive
requirements  of 25 Pa. Code $$264.10-264.56 and 264.170-264.178
 (in the  event that hazardous waste generated as part of  the
remedy  is managed in  containers), 25 Pa. Code $$264.190-264.199
 (in the  event that hazardous waste is  managed,  treated or stored
 in tanks);  and  if prohibited by land disposal restrictions,  40
CFR $$268.7,  268.9 and 268.35 (although 40 CFR $268.32(e)(2) was
cited  as an ARAR  in the  Proposed Plan  for  this Site, EPA does not
presently have  sufficient  information  to determine whether the
constituents  are  hazardous wastes;  however, as noted above,  EPA
shall require the performance of TCLP  testing to address this)
and 40  CFR  $268.50 (prohibitions on storage of hazardous waste),
which are relevant and appropriate to  this action.
                                37

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 Location Specific ARARfi

 This remedy will comply with the substantive requirements of the
 Delaware River Basin Commission Ground Water Protected Area
 Regulations regarding construction of water extraction wells (No.
 (6}(f);  Water Code of the Basin,  Section 2.50.2),  metering of
 surface  water intakes (No.  9;  Water Code of the Basin,  Section
 2.50.2),  non-interference with domestic or other existing wells
 (No.  10)  and non-impact on ground water levels,  ground water
 storage  capacity,  or low flows of perennial streams  (No.  4; Water
 Code of  the Basin,  Section 2.20.4).

 To Be Considered (TBC)  Standards

 Pennsylvania's Ground Water Quality Protection  Strategy,  dated
 February 1992 and EPA's Ground Water Protection Strategy,  dated
 July  1991 are TBCs.

 Existing pumping and monitoring wells which serve  no useful
 purpose  will be properly plugged  and abandoned  consistent with
 PADER's  Public Water Supply Manual,  Part II,  Section 3.3.5.11.

 With  respect to Site remedial  activities (e.g.,  installation of
 the municipal water  line,  placement of new wells and the
 treatment plant,  and the laying of pipelines from  the  wells to
 the treatment plant  and from the  plant to the Schuylkill  River),
 Executive Order No.  11983  and  40  C.F.R.  Part 6,  Appendix  A
 (regarding avoidance,  minimization and mitigation  of impacts on
 floodplains),  and  Executive Order No.  11990 and 40 C.F.R.  Part 6,
 Appendix  A (regarding avoidance,  minimization and  mitigation of
 impacts on wetlands).

 Sediment  and erosion controls  and temporary covers will be
 installed to protect exposed soil from the effects of weather in
 accordance with PADER,  Bureau  of  Soil and Water  Conservation's
 Erosion and Sediment Pollution Control Manual.

 EPA OSWER Directive  9834.11  which prohibits the  disposal  of
 Superfund Site  waste at a  facility not in compliance with  $3004
 and S3005  of  RCRA and all applicable  State requirements is  a  TBC.

 Coat Effectiveness

 The selected  remedy  is  cost-effective in providing overall
 protection in proportion to  cost,  and meets all  other
 requirements  of CERCLA.  Section  300.430(f)(ii)(0) of the NCP
 requires  EPA  to evaluate cost-effectiveness by comparing all  the
 alternatives  which meet the  threshold criteria - protection of
 human health  and environment and  compliance with ARARs - against
 three additional balancing criteria:   long-term  effectiveness and
permanence; reduction of toxicity, mobility or volume through
 treatment; and  short-term effectiveness.   The selected remedy
meets these criteria  and provides  for  overall effectiveness in
                                38

-------
proportion to its cost.  The combined estimated present worth
cost for the selected remedy is $4,096,516.  Detailed capital and
O&M cost estimates for the alternatives included in the selected
remedy are shown in Tables 12A - 12D.

Utilization of Permanent Solutions and Alternative Treatment


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

Under the selected remedy, treatment of groundwater using GAC
(GW3) is more cost-effective than the other alternatives
evaluated.  It also will be easier to implement and have less
short-term impacts than UV/Oxidation option.  Alternative GW3
will reduce contaminant levels in groundwater and reduce the
risks associated with the potential ingestion of the groundwater
to the maximum extent practicable, as well as provide long-term
effectiveness.  All options provide similar degrees of long-term
effectiveness and reduction of toxicity, mobility, or volume
through treatment.

The municipal water line (WS3) provides the highest degree of
long-term effectiveness among the water supply options and is the
most cost-effective.  It also will be the easiest to implement
over the life of the project since long-term monitoring will not
be required as in the other options.  This option is also favored
by the residents and officials of East Coventry Township.

The selection of S4, the excavation and off-site disposal of
contaminated soils, is consistent with Superfund program policy
regarding principal and low level threat wastes in that it
utilizes engineering controls for low level threat wastes.  The
remedy provides the highest degree of long-term effectiveness and
permanence, is the most cost-effective, reduces mobility and
reduces risk to human health and the environment.
The selected remedy satisfies, in part, the statutory preference
for treatment as a principal element.  Alternative GW3 addresses
the primary threat of future direct contact, inhalation and
ingestion of contaminated groundwater through treatment using a
GAC system.  Since the contaminated so.;. I does not constitute a
principal threat, treatment is not required.
                                39

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XI.  DOCUMENTATION OF 8IGNIFICMTT CHANGES

The Proposed Plan for the Recticon/Allied Steel Site was released
for public comment on May 20, 1993.  The Proposed Plan identified
the selected remedies as the preferred remedies.  EPA reviewed
all written and verbal comments submitted during the public
comment period.  No significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
                                40

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APPENDIX A     FIGURES

-------
                                                                                            •^
                                  LOCATION
                                   Allied St««l
 REFERENCE: USGS 7.5 MnuM Quadrangle; Pho«ruxviH«, Pennsylvania, 1983.
_  DAMES * MOORE
SUE LOCATION MAP
       Rccfeon / AJtod StMl »•
       Parker Ford. Pmnsy^anla
            OCTOBER 1992
10839-126-032 SJR 9/28^2 SITE. 1
                                   Figure  1

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    DIMES* MOORE
                                                                                                                                           SITE LAYOUT
                                                                                                                                         Ptrtmfvi.
                                                                                                                                                MWKM1M3
tW»l2»4CB 8JR W2W IAWJUT

-------
                                                                                                                                   t

                                                                                                                                   i
                                                                                                                                  t^
                                                                                                                                  u
DAMES* MOORE
                                                                                                            SOIL BORING LOCATIONS
                                                                                                                          IMMCMtfO

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EXPLANATION
SS-2 •  Surfaca Sediment Sample

SW-1Surface Water Sample
NOTES.
1. THE APPROXftlATE BASE MAP 18 DERIVED
 FROM:
 • SMC. MARTM. MC., HVOftOOCOLOQCAt
 STUOr REPORT. MARCH 1M«.
 - ROV F. WESTON. MC.. HVOROOECtOQICAL
 SURVEY REPORT. NOVEMBER 11.1SSO.
 • AERIAL PHOTOORAPHV. IMS.
 • SS-1 WAS PROPOSED M PHASE I WORK
 PLAN. HOWEVER THE SAMPLE WAS NOT
 COLLECTED DUE TO FELD CONDITIONS.
   DAMES & MOORE
SURFACE SOIL AND SURFACE WATER
                  SAMPLING LOCATIONS
                           ftefeoit/AIMStMlSit*
                           Part* Ford. Pennsylvania
                                   MARCH 1993

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1  Is
                                                                                                     !«..<,•  MINiroRINC WCLL LOCATION
                                                                                                      SITE MAP
                                                                                         SHOWING MON'K)R'NG  WELL LOCATIONS
                                                                                                 RECTICON/ALLIED  SITE
                                                                                              PARKER  FORD. PENNSYLVANIA	
                                                                                                   DAMES & MOORE
OAMMIC «• M« Swrt' I. (WltO rrtWlMMt *. (9f
                                                                                          AS SHOWN
                                                                                          10/16/92
 EM'
J.C.V.
                                                                                                                   10839-126
             5-1

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tmx
           TCE  CONCENTRATION  MAP
  GROUND WATER  -  SHALLOW BEDROCK WELLS
                                                                                                                     N
               RECTICON/ALLIED  SITE
          PARKFR  FORD  PFNNSYLVANIA
                                                                                                                           \o
                                                                                                                           fi
                                                                                                                           3
      0  100  200  300 FEET


        GRAPHIC SCALE
                .    .
    •two Mfusi » IHJ M(I>MU i> MMI y n»«n.'>c  '
     -
   ncPlANATKX
08M-M9  MONITORING WEIL LOCATION

       OUANTITATION rS APPROXIUATC
       DUE TO LIMITATIONS IDENTIFIED
       DURING THE QUALITY CONTROL
       REVIEW

    NS  NOT SAMPLED

 ••»	 ISOCONCENTRATtON CONTOUR
       DASHED WHERE INFERRED Or*)

 Interpretation by U.S. EPA

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APPENDIX B     TABLES

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                          Summary of Chemicals Detected in Subsurface Soil Samples at the Recticon

                          and Allied Steel Facilities
H


I
(P*
"' ' "^lllHPil^*
• '^''^^^•^^^

' '•*'•* .* ISBSrtSoa^'i^v^lll-.*
METAU On Mfjkel
Aluminum
Araanie
Barium
Beryttum
Chromium
Cobalt
Copper
Uad
Manganaaa
Nickel
Vanadium
Zinc
aVOCa an uaAaj
BantoioAoM

Oi-ivbutytphthaiate
VOCe (In ueAeJ

Acetone
Mothytona Chloride
TricMoroethene
- \.V; .. "ABfedeieef
fraajoxicy ;. - RafMjeef
"|VJ, 4* ^.- > p>Uc<
(?MH>a that did not contain detectable concentietiona.

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                                    Summary of Chemicals Detected in Surface Water Samples from Upgradient
                                    and Dovmgradient Drainage Locations at the Recticon/Allied Steel Site
                                         METALS (total)
                                    Aluminum
                                    Barium
                                    Cadmium
                                    Chromium
                                    Coppw
5"
O*
CD*
N)
Vanadfem
Zhw

    METALS |dbaoh«4)
Aluminum
Barium
                                    Vi
                                    Zlne
                                             •voc*
                                             VOO§
                                    Ac«teo«
2 of 2
2 of 2
lot
2 of
2 of
2 of
2 of
tot
2 of
2 of
1 of
2 of
2 of
2 of
lot 2
2 of 2
                                                                 lot 2
                                                                 lof 2
                                                                 2 of 2
                                                                              Unit**
                           ConMntr«n
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 Summary of Chemicals Detected in Surface Soil Samples from Upgradient and Downgradient
 Drainage Locations at the Recticon/Allied Steel Site
Chemical
METAU (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobelt
Copper
Lead
Manganese
Nickel
Venedium
Zinc
PAHe (ug/kgl
2-Methytnaphthalene
Acanaphthylana
Anthracene
Banzo(a)anthracena
8anxo(a)pyrana
Banio(b)fluoranthene
Benzo(g.h,i|parylane
Beiuoiklfluoranthene
Chryaena
Dibonzla.hlanthracene
Oibenzofuran
Fluoranthene
Fluorene
Indenod ,2.3-cdlpyrene
Naphthalene
Phenanthrene
Pyrene
•VOCa (ug/kgl
Benzoic Acid
bis(2-ethylhexvl)phthalate
Butyfeenzytphthalate
Di-n-butylphthalate
VOCa (ug/kgl
Acetone
Trichloroethena
Altta* Steal
v;:: of
Detection

4 of 4
4 of 4
4 of 4
3 of 4
1 of 4
4 of 4
4 Of 4
4 Of 4
4 of 4
4 of 4
4 or 4
4 of 4
4 of 4

2 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
Oof 4
4 of 4
2 of 4
2 of 4
4 of 4
1 of 4
4 of 4
2 of 4
4 of 4
4 of 4

1 of 4
4 of 4
3 of 4
1 of4

1 of 4
2 of 4
Ranavoi
Unto*

-
•
•
0.66
1.2- 1.4
•
.
-
-
-
•
-
-

590-1100
•
.
.
.
-
-
550-1100
-
550-1100
590-1100
-
550-1100
-
590-1100
.
-

2700 • 5600
.
950
590-1100

14-33
7-9
2Z2 .

9870-11500
2-6
115- 178
1 -2.8
1.4
19.9-80.7
10.8- 15.7
43.3-211
60.7- 151
356- 1500
15.9-28.7
24.9 - 30.2
111-772

2SO-70O
230 - 33O
150-320
300-900
490-900
1200 - 2000
250 • 610
•
S20-10OO
63-230
110-300
720- 16OO
120
260-1100
110-400
29O-16OO
100-16OO

260
220-930
14O-39O
73

25
2-5

'• J*

4 of 4
2 of 4
4 of 4
3 Of 4
Oof 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4

Oof 4
2 Of 4
2 of 4
2 of 4
2 of 4
3 of 4
1 of 4
1 of 4
3 of 4
Oof 4
Oof4
3 of 4
Oof 4
Oof 4
Oof 4
2 of 4
2of4

1 of 4
3 of 4
1 of 4
1 of 4

2of4
Oof 4
Ure*i» ..-.<

•
0.48- 1.4
•
0.52
0.97 • 1
-
-
•
-
-
-
-
•

410-44O
430-440
43O-44O
430-44O
430-440
430
430-440
43O-44O
430
410-44O
410-44O
430
410-44O
410-44O
410-44O
430-440
430

2000-2100
43O
430-44O
- 430-440

13
6-7
if ,' ', PSanje of
Oateettd

6290- 11600
2.1 - 2.6
92.5- 139
0.68 - 0.83
-
9.5-75.4
9.8-14.1
4.3-92.1
30.2 - 74
642- 1310
10.5- 18.4
16.9-27.1
38'- 123
• ^_
."*".-
140 -35O'
77 - 210
200-1000
250-1200
110- 1400
690
950
60- 1000
-
-
68-1300
-
-
-
94-330
98-1200

250
46-560
92
99

18-140
-
Data eummarized from Table 4^ of the Rl (Oamaa & Moore. 19921.

* Range of aampla quanbtation limitt ia ahown for sampiee that did not contain datactaWa coneantraliona.

Note: Sampiee coVaetad downgradient of the AJNed Steal fadBty are aiao downg/adiem of the Maetfcon facOty.
                                            Table 3

-------
Summary Statistics for Bedrock Monitoring Wed Samples at the Rectkon/AHied Steel Site

METAtS (total)
Aluminum
Araanfc
Barium
BaryMum
Chromium
Cobalt
Cmmav
•••••»•••*•

Nicfcal
Vanadium
MCTAL8 MaaohwdC
Amwnofvy
Barium
CtrtMtl
Coppor
Laad
Manganaaa
Niokat
Zinc
SVOCa
Dimatttvtpltfhalata
TIG*
1 . 1 .2-TricMoio- 1 .2.2-tiMuorocthMM
CartMm PtauHMi
tOft-Mltykltafn^patnOf
voc«
1* T J • fcia •• ••>» •••
• • • i imofOTtnawiw
ta> V.4^U4uHh^fk«Ma4k
. «* • 1 nonOnMVnMW
fl .mftAafctd^MBftfttflMBa*
• • "•MBtWWejWiajVW
1 fill Uni nalJMMM
• I ^JmwUWWlWIV
.2.3-TrieMorabaniana
.2.4-Trimatm«Mniana


8 of 8 • 80.4 • 2290
2 of 8 2 2.1-2.4
8 of 8 • 118-361
1of8 1 1.2
3 of 8 6 6.4 - 6.7
• eta 4 4.3-9.1
a of a - 7.3 10.8
8 of 8 • 205-1420
7 of 8 7 8.1 - 19.7 •
1 of a 4 8
•
1o»8 16 19.1
8ofS - 20-318
1 of 8 4 4.6
3 of 8 10 10.1-12.9
1 of a 1 4.5
aota • 159-1200
a of a 7 7-16.1
a of 8 - 27.8-56.7

lofS .10 2

1 of 1 • 3
• of • - 0.08 - 660
7 of 7 - 0.25-1.5

21 of 32 0.5 -60 0.1 - 2.5
1 of 32 O.5 - 50 0.3
18 of 32 0.5-60 0.12-2.7
10 of 32 0.6 - 50 0.08 • 2.9
1 of 32 0.5-60 0.19
1 of 32 0.5-50 O.OS
^•' - - -:'^AiHhiiiaii6>:; ^- •
:; X^V >: :T-*: >:'>::: : :;':::: ::•• V. : ::;.'?::
":-;S.-r:A*««f*a»:-w-::-

523.55
1.31
253.63
0.59
4.31
5.68
9.34
557.25
10.80
2.75

9.39
194.25
2.33
7.29
1.00
470.25
8.51
13.54

4.63

•
-
-

0.97
0.25
1.02
0.99
0.75
0.24,
It^&d^l/^
*;;:"-:?Oa«l«tlon-.:.t:^':;

729.11
0.58
75.33
0.25
1.81
2.72
1.37
392.68
4.96
2.12

3.92
95.07
0.92
3.27
1.41
352.85
3.86
21.48

1.06

-
-
•

0.85
O.OO
0.93
1.07
O.01
0.02
•;•';•; f.'-' 96% UCLofV?-' .::;:f
ly-1-' of Arithmatio ' "'

1012.12
1.70
304.10
0.75
5.53
7.50
10.26
820.31
14.12
4.17

12.02
257.95
2.94
9.48
1.95
7O6.69
11.10
27.94

5.34


-
•

1.54
0.25
1.65
1.71
0.2S
0.26

-------
00
          Summary Statistics for Bedrock Monitoring Well Samples at the Rectkon/AHied Steel She
**M
1.2-DtoMoroothon*
ete-1 ,2-OteMoro«tnorM
MM- 1 , 2-DteMoroathoM
1.3-OioMoroboruono
Baruano
Corbon Tatrochlorida
CMoroboniono
CMoroathona
CMocotonvi
CMoromathona
DtohtoodHluorofnothono
M*thy4ona Chiorida
TotrooMoroothorM
Trichtoroothono
TricMorofluorafMthara
Vinyl CMorUo
m.p-Xvlono
»S§?^ ?* ,^**ri«8i» ^" '
PlllSiw, , :LMM« ..
6 of 32 0.5-50
27 of 32 O.S
• of 32 O.S - SO
2 of 32 O.S • 50
7 of 32 0.5-50
1 of 32 O.S - 50
1 of 32 0.5-50
6 of 32 O.S SO
17 of 32 0.5 - SO
1 of 32 0.5-60
6 of 32 O.S - SO
17 0132 0.5-50
11 of 32 O.S • SO
31 of 32 0.6
3 of 32 0.5 - 50
8 of 32 0.6 • 60
1 of 32 0.5 - 50
•tEL
0.52 - 2.6
0.38 • 730
0.24 - 8.4
0.05 - 0.07
O.08 - 0.36
0.93
0.19
0.16 - 0.47
0.06 1.3
1
O.14-O.84
0.16-14
0.11 -8.8
0.3 - 19OO
0.06 • 7.5
0.42 - 2.2
0.07
ArfcMwti*
0.49
221.38
0.86
0.24
0.23
0.27
0.25
0.28
0.25
0.28
0.31
0.18
1.48
627.26
0.27
0.56
0.24
4
Btondord
Deviation '
0.61
287.16
1.50
0.02
0.03
0.06
0.01
O.07
0.11
0.09
0.11
0.02
2.S7
648.65
0.06
0.37
0.02
8G% UCt «lvp;:r
0.9O
413.81
1.87
0.25
0.25
0.31
0.25
0.33
0.33
O.34
0.38
0.20
3.20
1061.91
0.31
0.81
0.26
          0«U MO oummoiUod from Rl (Oomos & Moor*. 18821.

          •Hong* of ••n^to ojuwttltolion Bmltt to shown for Mmpto* ih*t did not contoin doucUMo conconUotion*.
          (II AVMOQ* ond UCt eoneonttoltoM for VOCa worn eoteulotod DMod on in* •voion* conoontrolion dotoctod ov«r lima in ••eh w«U. SVOC« «nd mctalt w«c«
            iMtod to only ono MmpUng ovont.
          121
                                       , nondotoetod ooneonuotiOM woro OMumod to bo onfrtiolf tho Mmpto quantitMion limit.  Ho««v«r. nond*t«ct*d i«*ult« w«<* •xclud*d
            from H» oeloulrtnn to OMM whoro ttw Mmplo ojuenDwion Imlt oxcoodod Iho mmlmum dotootod concontrotion f or ih* w«i.

-------
                                        KEY RISK TERMS

 Average Daily Dose (Add):  The average amount of a chemical in contact with an individual on a daily
 basis.

 Carcinogen:  A substance that increases the incidence of cancer.

 Chronic Exposure:  A persistent, recurring, or long-term exposure. Chronic exposure may result in health
 effect (such as cancer) that are delayed in onset, occurring long after exposure ceased.

 Exposure:  The opportunity to receive a dose through direct contact with a chemical or medium
 containing a chemical

 Exposure Assessment:  The process of describing, for a population at risk, the amounts of chemicals to
 which individuals are exposed or the distribution of exposures within a population, or the average exposure
 of an entire population.

 Hazard Index (HI)/ An EPA method to assess the potential noncardnogenic risk. The ratio of the ADD.
 to the chronic RFD (or other suitable toxidty value for noncartinogens) is calculated.  If it is less than
 one, then the exposure represented by the ADD is judged likely to produce an adverse                 *-
 noncarcinogeniceffect  A cumulative endpoint-spetific HI can also be calulated to evaluate the risks posed"
 by exposure to more than one chemical  by summing the ADD/RFD ratios for all the chemicals of interest
 that exert a similar effect on a particular organ. This approach assumes that multiple subthreshold
 exposures could result in an adverse effect on a particular organ and that the magnitudeof the adverse
 effect will be proportional to the sum of the ratios of the subthreshold exposure.  If the cumulative HI is
 greater than one, then there may be concern for public health risk.

 Reference Dose (RFD): The EPA's preferred toxidty value for evaluating noncardnogenic effects.

 Risk:  The nature and probability of occurrence of an unwanted, adverse effect on human life or health,
 or on the environment.

 Risk Assessment   The characterization of the potential adverse effect on human life or health, or on the
environment  According to the National Research Council's Committee on the Institutional Means for
Assessment of Health Risk, human health risk assessment indudes: description of the potential adverse
health effects based on an evaluation of results of epidemiologic, critical, toxkologic, and environmental
research: extrapolation from those results to predict the types and estimate the extent of health effects of
humans under given conditions of exposure: judgements as to the number and characteristics of persons
exposed at various intensities and durations: summary judgements on the existence and overall magnitude
of the public-health program; and characterization of the uncertainties inherent in the  process of inferring
risk.

Slope Factor  The statistical 95% upper confidence limit oa the slope of the dose response relationship
at tow doses for a carcinogen. Values can range from about 0.0001 to about 100,000, in units of lifetime
risk per unit dose' (mg/kg-day). The larger the value the more potent is the carcinogen, it, a smaller dose
is sufficient to increase the risk of cancer.
                                        Table  5

-------
                         MATRIX OF POTENTIAL EXPOSURE ROUTES
                           FOR THE RECTICON/ALLIED STEEL SITE

EXPOSURE MEDIUM/
EXPOSURE ROUTE


Groundwatef
Ingestion
Dermal Contact
Vapor Inhalation
Surface Water
Ingestion
Dermal Contact
Sediment
Incidental Ingestion
Dermal Contact
Ail
Inhalation of Vapors
Indoors
Outdoors
Inhalation of Participates
Soj|/Pust
Incidental Ingestion
Dermal Contact
Food
Ingestion

CURRENT
ONSITE
TRESPASSER


—
—
-

I
I

—
-

•
-
I
I

I
I

—
CURRENT/FUTURE
OFFSTTE
RESIDENTIAL
POPULATION


L
L
L

—
-

—
—


L
L
-

—
—

—
FUTURE ONSITE
COMMERCIAL/
INDUSTRIAL
POPULATION


A
A
A

-
-

—
-


A
A
A

A
A

—
FUTURE
POTENTIAL
ONSITE
RESIDENTIAL
POPULATION

L
L
L

I
I

__ •%•_
—


L
L
L

L,I
L.I

—
   L
   A
Lifetime exposure.
Exposure to adults (highest exposure is likely to occur during occupational activities).
Exposure of this population via this route is not likely to occur.
Intermittent exposure.
RECnCON/ALLIED STEEL SITE
MAKCMII. 1993
                                         Table 6

-------
SUMMARY OF HAZARD QUOTIENTS AND HAZARD MDICES BASED ON CRITICAL EFFECT FOR THE
• *r • w««*k MOW* • •* ww^^«w^w«» • • i •• *>»v •-• • w w « • «• ™ • vwvv*i !••*••*•• «•>• a*^^ w«* •*
klllPP?^
METAL*
Amrio
B«tum
BcryMum
Chromium
Coppw

Ntakcl
V«Mdkm
TIC»
Carbon DlwMd*
VOte
1 . 1 .2-TrteNorotthMM
1.1-neMoroMhMW
d*-1.2-OtoMoroMnMM
	 • < rMnhl 	 ••!!••!•
•fir 1 .A^^NOTHOnMIIMIIV
Cwbon TotrMMoiWo
T«frMMoro«lhMM
HAZARD MOEX FOR ALL
NOME - NOM OfaMnmd
I1^?.|011*(?TIP^"J' TOTAL FROM {TOTAL FROM ; 1 OROUNOWATER 1 TOTAL FROM v
itf^lWWef^f BOIL PATHWAY* 1 VAPOR PATHWAY* 1 •NOtSTWH 1 ALL PATHWAYS

8
Cv
NONE
NONE 0.005
Gl 
-------
SUMMARY OF HAZARD QUOTIENTS AND HAZARD INDICES BASED ON CRITICAL EFFECT FOR THE
FUTURE ONSTTE RESIDENTIAL SCENARIO
/'}0W'^
Noncardnogenie effects

METALS
Arsenic
Barium
Ben/Mum
CnfOfnum
Copper
Menganess
Nickel
Vanadium
TWa

VOCa
1.1,2-TricNoroethana
1 ,2.3-TricMofotaaniena
. ~ rtintjn«rt«f* 	
ois- 1 ,2-DkMoroathana
Uana-1.2-DicMoroathana
Carbon Tetreohtorida
CMorobenzone
CMovofofm
T • tilnitfufti
HAZARD MDCX F6Ti £*4

• •^••M • • 	 _ L _ , _ la .4
I CRITICAL 1 TOTALfROM 1 TOTAL FROM 1
1 EFFECT <""• 1 ! 80*1 PATHWAYS I VAPOR PATHWAYS t

,ut

S
C* - - '
NONE
NONE 0.021
Gl 
-------
SUMMARY OF CARCINOGENIC RISKS FOR THE
      RECnCON/ALLIED STEEL SITE
      PARKER FORD, PENNSYLVANIA
SCENARIO/PATHWAY
CANCER RISK ESTIMATE
CURRENT
Trespasser
Dermal Contact (Soil)
Soil' Ingestion
Paniculate Inhalation
Vapor Inhalation (Outdoor)
Total Risk:
OfTsite Resident
Vapor Inhalation (Outdoor)
Groundwater Ingestion
Total Risk:
FUTURE
Onsite Worker
Dermal Contact (Soil)
Soil Ingestion
Paniculate Inhalation
Vapor Inhalation (Outdoor)
Vapor Inhalation (Indoor)
Groundwater Ingestion
Total Risk:
Onsite Resident
Dermal Contact (Soil)
Soil Ingestion
Paniculate Inhalation
Vapor Inhalation (Outdoor)
Vapor Inhalation (Indoor)
Dermal Contact (Showering/Bathing)
Groundwater Ingestion
Vapor Inhalation (Showering)
Total Risk:
2.5 x ia7
4.7 x 10*
1.0 x 10-'°
4,7 * Iff"
3 x 10-'
3.8 x 10*
3.$ x W
4 x Ifr7

1.4 x 10*
1.3 x ia7
4.3 x ia10
1.9 x 10W
3.4 x 10*
2,9 x 1Q*
3 x 104
2.9 x 10*
6.1 x 107
2.3 x 10*
4.0 x 10*
2.4 x 10*
6.8 x 104
2.9 x 104
2JLK 10*
6 x 104
                 Table 9

-------
 WATER SUPPLY ALTERNATIVES
S4
Excavation/Offsite Landfill
 WS1    No Action

 Estimated Capital Costs: $0
 Estimated Annual O&M Costs: $69,077
 Estimated Present-Worth Costs: $1,263,555
 Estimated Implementation Time: Immediate

 WS2    Community Well

 Estimated Capital Costs: $696,306
 Estimated Annual O&M Costs: $63,464
 Estimated Present-Worth Costs: $1,857,199
 Estimated Implementation Time: 6-12 Months

 WS3    Municipal Water Line

 Estimated Capital Costs: $293,177
 Estimated Annual O&M Costs: $2,661
 Estimated Present-Worth Costs:  $317,421
 Estimated Implementation Time: 3 Months

 WS4    Individual Home Treatment (carbon)
 Units

 Estimated Capital Costs: $21.678
 Estimated Annual O&M Costs: $27.238
 Estimated Present-Worth Costs:  $519.909
 Estimated Implementation Time: 0 Months

 SOIL ALTERNATIVES

 S1  No Action

 Estimated Capital Costs: $0
 Estimated Annual O&M Costs: $0
 Estimated Present-Worth Costs:  $0
 Estimated Implementation Time:  Immediate

S2  Asphalt Can

 Estimated Capital Costs: $43,243
 Estimated AnnuaJ O&M Costs: $3.300
 Estimated Present-Worth Costs:  $103,607
 Estimated Implementation Time:  3 Months

S3     Excavation/Offsite Incineration

Estimated Capital Costs: $147,014
Estimated Annual O&M Costs: $0
Estimated Present-Worth Costs:  $147,014
Estimated Implementation Time:  3 Months
Estimated Capital Costs: $40,261
Estimated Annual O&M Costs: $0
Estimated Present-Worth Costs: $40,261
Estimated Implementation Time: 3 Months

SS   In Situ Vacuum Extraction

Estimated Capital Costs: $46.888
Estimated Annual O&M Costs: $42.073
Estimated Present-Worth Costs: $78.961
Estimates Implementation Time: 2 Months
QROUNOWATER ALTERNATIVES

GW1    No Action

Estimated Capital Costs: $0
Estimated Annual O&M Costs: $69,077
Estimated Present-Worth Costs: $1.263.555
Estimated Implementation Time: Immediate
GW2    Extraction/Air striDDino/Dfecharae to
Schuvlkill River

Estimated Capital Costs: $413,400
Estimated Annual O&M Costs: $246,400
Estimated Present-Worth Costs: $4,920,557
Estimated Implementation Time: 30 years

GW3    Extraction/GAC Treatment/Discharge
to Schuvlkill River

Estimated Capital Costs: $638,700
Estimated Annual O&M Costs: $169,480
Estimated Present-Worth Costs: $3,738,834
Estimated Implementation Time: 30 years
OW4    Extraction/ UV/Oxidatton /Discharge to
Schuvlkill River

Estimated Capital Costs: $808,900
Estimated Annual O&M Costs: $165.900
Estimated Present-Worth Costs: $3,843,548
Estimated Implementation Time: 30 years
                                   Table 10

-------
                           RESIDENT UST

                     RECTICON/ALUED STEEL SITE
                    PARKER FORD. PENNSYLVANIA
KflMMNT/LANOOWmiM
Quarterfy 8 emoting*

(formerly Total Recovery, hie.)
Keyttone Auto Canter. Inc.
Adam OeFranceeco
Laiaura Equipment, inc.
•tuJladerer
VM Tefcpnone
Gembone tree.. Owner
Fritz Hanabarry. Owner
(ScMchter ft On. tenanta)
AutoOuaat
Tony Oulee. Owner
STATION
1A
UA
1»A
22A
32A
WA
AOOMM
Bte. 724 and Wale M.
Mta. 724 and Wale Md.
Mta. 724
Mta. 724
UnfteMMd.
2B7« Mta. 724
•  Wata that hava activated cartoon fltration unit*.
                        Table 11

-------
 Preliminary Cost Estimate
 Recticon/Allted Steel Site
Alternative WS3 - Extension of the Municipal Water Supply Line

Capital Costs
Item
Quantity
Units
Cost/Unit
($)
Total Cost
($)
.'. . : :. ••;'•'"•*•?•??*:"::• • "•> .•-:•.-. . . ; -.• - .. • .' .
1 . Installation of municipal
water line (12 inch ductile
iron, in place)
2. Installation of fire hydrants
(1 required every 500 feet)
3. User connections
1320
6
11
If
hydrants
connections
SO
2000
5500
66.000
12.000
60.500
*
Dinct Cost Subtotal:
Utility Tax (40%)
Utility Review Cost (7%)

RMS/ onct cons.
Engineering &
Supervision (+20%)
Subtotal
Contractors Fees (+5%)
Contingency (+1 5 %)
TOTAL
138.500
55,400*
9.695
209,595
40,719
244.314
12.216
36,647
$293,177
Operations & Maintenance
/<•' , ,
• <; /S -<,->.,
• , ' fi ••"
\ ' .
Subtotal:
Contingency (+10%)
Administration (+7%)
ANNUAL TOTAL:
$2.274
S227
$159
$2.661
                        Table 12A

-------
Preliminary Cost Estimate
Rectteon/Allied Steel Site
Alternative S4 - Excavation/Offsite Disposal

Capital Costs
Item
Quantity
Units
Cost/Unit
(S)
Total Cost
(S)
• ' -- .•.::•.-.,-•.-••>;>.;-, •••••:..;-r -7=7 . ':• :' .,'.-. :. ^ ".' :0? ,, ..; ' .:'..- :-:: . .-
1 .Preliminary Site Preparation
(Existing asphalt removal)
2. Excavation to 9 feet below
grade - dean material
3. Excavation 9 to 11 feet
contaminated material
4. Post-Excavation sampling
(5 samples - 1 base, 2
sidewalls for VOCs: 3
day turnaround)
5. Backfill and compaction of
dean material
6. Backfill and compaction of
borrow material
7. Bank run gravel
(In-place ft compacted to
98 per cent - 4 Inches}
8. Asphalt placement
(4 inch base and wearing
course)
9. Existing asphalt disposal
10 Contaminated soil disposal
at an approved facility
•. / x, v(j>,;/ ^i^- ;%%'•', -.,>,'*,£-,,
'^^^fe^^rft^^'^
'/»' <,*•-,&<* ^^fy^ia^."." >\ VZ. '• "t? s ' "•
v „, , ff/f Stffy.'l?'f' , V/> lv ^ .. ,.Vvrfv
,"<-//;S4?^*^i ^ v , - " '4?f,,
V4*PA'- «"„ -s 5>'x - •* •S'v' sV' '•• ' ?
, ' >; ,,y,»'^*f} •' ',"<*.',»,:•' " » ' -
1 s 'X*;'^,,^ - ,.\,s" ' *'?<% * /%
' *•?/" -,¥"$.• ^^'' ^Jv
2300
450
40
5
450
50
46
2300
57
50
"" «.• "•
i. * -, '' A '*/
-* #-^,x ^^^ ,
' ~i i - - ,
•,' f t
••','• '•:
," ' , f'"< <
''"' - "- «, <'
sf
cy
cy
samples
cy
tons
tons
sf
tons
tons

0.3
10
10
500
5
16
12.5
1.11
30
300
Subtotal:
Contingency (+20%)
Engineering A
Administration (+10 H)
TOTAL:
690
4.500
400
2.500
-w
^w . '
2.250
800
575
2.553
1.702
. 15.000
$30,970
$6.194
$3,097
$40361
Operations & Maintenance

There is no long-term Operations ft Maintenance cost associated with this alternative.
                            Table 12B

-------
Preliminary Cost Estimate
Recticon/Allied Steel Site
Alternative GW3 - Extractton/GAC Treatment/
          Discharge to SchuylkJll River

Capital Costs
Page i of 2
Item
Quantity
Units
Cost/Unit
($)
Total Cost
(S)

1 . Installation of recovery well
(200 feet. 6 inch PVC casing)
2. Recovery well pump
- 25 gpm @ 3OO feet TDH
- 100 gpm & 4OO feet 7DH
3. Dual Bag Filter
4. Well pump distribution piping
- 3-inch diameter PVC
-2-inch dimeter PVC
5. Liquid-Phase GAC Purchase
6. Effluent distribution
piping (6 inch PVC)
7. Road connections (3 required,
SO foot connections)
8. Equipment building
% v.<.
, ,,' -* ' ..' L '
*/*''' >:%
200
1
2
1
1700
100
1
2000
150
900
•"V .. '"'•. ' f
-'v^
-------
Preliminary Cost Estimate
Recticon/AHied Steel Site
Alternative GW3 - Extractton/GAC Treatment/
          Discharge to Schuylkill River

Operations & Maintenance
Page 2 of 2
Item
Quantity
Units
Cost/Unit
($)
Total Cost
W
*. ' *
1 . Electrical Power
2. System Operation and
mechanical maintenance (3 hrs/
day, 7 d/wK @ $60/hr)
3. Maintenance materials (1% of
total capital investment
4. Semiannual GAG replacement
5. Quarterly ground water
monitoring (VOCs, standard
turnaround)
6. Sampling labor (32 hrs/qtr)
(VOCs. standard turnaround)
7. Reporting (20 hrs/qtr)
.-'•: '• ' •>• , s,
* * *, "*, /
^-•""j-V-, ; '^
''* '>>: ;\''-;
431000
1092
1
2
24
128
80
«• ^y. -.
t > :
X% >f^»
f ' :f '.
f f "• ?
kw-hr
hours
Is
ea.
samples
hours
hours

0.08
60
6400
10000
250
60
60
Subtotal:
Contingency (+10 %)
Administration j+7%)
ANNUAL TOTAL:
34.480
65,520
6,400
20.000
6,000
7.680
4.800
$144,880
$14,488
$10.142
$169,480
                      Table 12D

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APPENDIX C     RESPONSIVENESS SUMMARY

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                     RBCTICON/ALLIED STEEL SITE
             Parkerford, Chester County, Pennsylvania

                      RESPONSIVENESS SUMMARY
                            June 1993


This Responsiveness  Summary documents public comments received by
EPA during the public comment period on the Proposed Plan
("Plan")  for the Recticon/Allied Steel Site ("the Site") and
provides  EPA's responses to those comments.  The Responsiveness
Summary is organized as follows:
           •.
     1. Overview

     2. Summary of Citizens' Comments Received During
        the public Meeting and EPA's Responses

     3. summary of Written Comments Received
        and BPA's Responses

1.  OVERVIEW

The public comment period on the Proposed Plan  for the
Recticon/Allied Steel Site began on May 20, 1993 and ended on
June 19,  1993.  EPA  held a public meeting at the East Coventry
Township Municipal Building in Pottstown, PA on May 27, 1993.

At the meeting, EPA  representatives summarized the results of the
Remedial Investigation  ("RI"), the Feasibility Study ("FS") and
the Baseline Risk Assessment ("BRA") performed for the Site.
They then  presented EPA's preferred remedial alternatives for
mitigating the public health and environmental threats posed by
contamination at the Site.  They explained that the Proposed Plan
addresses contamination in the ground water in the vicinity of
the Site,  contamination in the soil on the former Recticon
property and provision of a public water supply system for the
affected and potentially affected residences and commercial
establishments.

Local residents offered comments on the Plan.  Comments and
questions related to results of the RI and details on the
proposed remedy.  The transcript of the public meeting is
contained in the Administrative Record for the Site.  In
addition,  EPA received one set of written comments during the
public comment period which are addressed below in Section 3.

2.  SUMMARY OF CITIZENS' COMMENTS RECEIVED DURINO
    THE PUBLIC MEETING AND BPA'8 RESPONSES

Comments and questions raised during the public meeting can be
grouped into the following categories:

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      A.         RI  Results

      B.         Soil  Excavation and  Disposal

      C.         Groundvater Extraction and  Treatment

      D.         Water Supply System

      E.         Costs

      F.         Superfund  Process

Comment.s  made  during the  public meeting and EPA's responses are
summarized below:

A.        RI Results

•     Citizens  asked  whether all of  the wells  in the Parker Ford
area  have been tested, which wells  have been  resampled and
whether any are still sampled?

EPA Response:   All of the homes and businesses shown on the map
in Figure 4-38 of the RI  had their  wells sampled and tested
during EPA's residential  well  survey in January 1990.  Based on
the results of that  survey,  the wells noted with an asterisk on
Table 4-19 of  the RI have been treated with activated carbon
filtration units and sampled on a quarterly basis.  Table 4-19
also  lists the wells that are used  for monitoring and the
frequency of sampling for those wells.

•     A citizen asked what the highest concentrations of
contaminants were, whether the concentration  of TCE is increasing
or decreasing  and how much variation occurred during the water
table elevation measurements.

EPA Response:   Trichloroethylene ("TCE") is the contaminant that
has been  detected at the  highest concentration which was 1900
ppb.  The sample results  indicate that when the water level
rises, the contaminant levels generally rise  also.  In months
when  we sampled that had  less precipitation,  the contaminant
levels decreased.  However,  there is not sufficient data to
indicate  whether the average concentration of TCE is decreasing
over  time.  There are wells  that are in the unconsolidated
portion above  the bedrock and there are also  bedrock wells.  The
wells that are in the unconsolidated aquifer have the greatest
fluctuation in water table levels which is in the order of a few
feet.  The bedrock wells'  water table levels have stayed at
approximately  the the same levels.

B.        Soil  Excavation and Disposal

•     Citizens  asked  questions regarding the location, source,
depth and approximate volume of soil planned  for excavation.

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EPA Response:   The  only significant soil contamination  found
during  the  RI was on  the  former Recticon facility underneath the
parking lot on  the  northwest side of the building.   It  was
detected from 9-11  feet below grade and it is estimated to be 37
cubic yards or  about  50 tons of material.  The source of this
contamination is not  definitely known, however, not  far from that
location (see Figure  4-2  of the RI), is an area that was used as
a drum  storage  area and a nearby gravel pad area was remediated
in the  past due to  occurrence of high levels of contamination.
It is possible  that the remaining soil contamination could have
been caused by  the  migration of contaminants from the gravel pad
area.

•    A  citizen  asked  about the location of the permitted RCRA
landfill where  the  contaminated soil would be disposed.

EPA Response:   There  are  a number of landfills that can accept
the contaminated soil and the final location will not be chosen
until the remedial  design phase.  Examples of potential landfills
are the Delaware Container Company in Coatesville, PA and Waste
Conversion, Inc. in Hatfield, PA.

•    A  citizen  commented  that the cost estimate of $40,261 seemed
excessive for the amount  of material that had to be remediated
and disposed.

EPA Response:   The  soil is contaminated and it must be  treated as
a hazardous waste,  since  it has not been characterized  yet, to
protect the workers that  will come in contact with it.  Also,
when it is  disposed of in a RCRA permitted landfill, that
landfill  has more extensive monitoring requirements than a solid
waste landfill, and consequently the landfill charges
considerably more money to dispose of contaminated soil, than
uncontaminated  soil.

C.        Oroundwater Extraction and Treatment

•    Citizens asked questions concerning the flow rate  and depth
of the  extraction system  and expressed concerns that the system
may negatively  impact the  surrounding private wells.

EPA Response:   The  estimated flow rate used in the FS for costing
purposes was 225 gallons per minute ("gpm").  However,  as stated
in the  Plan, further  hydrogeologic data is necessary to delineate
the boundaries  of the plume prior to final design of the
extraction  system.  The depth of the extraction wells will vary,
but must be designed  to hydraulically control the contaminated
groundwater plume.  Therefore,  since the deepest monitoring wells
at the  Site exhibited some contamination at 200 feet below the
ground  surface, the deepest extraction wells must be screened at
a depths that enable  the  system to capture that portion of the
contaminated plume.

In regards  to impacts to  surrounding public wells, EPA  is

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 required to design the extraction system in a manner that does
 not negatively impact groundwater levels.   To further address
 this concern,  the remedy description in the Record of Decision
 ("ROD11)  has been revised from that in the Plan to state that the
 pumping rate will be designed not to impact the water table
 elevation in the remaining operating private wells in the area.

 D.         water Supply System

 •     A citizen asked questions regarding who will pay for the
 waterline coming from Citizens Utility Home Water Company
 ("Citizens"),  whether the Township Supervisors support the water
 line,  what is  the size of the water main,  and whether Citizens
 wil-i install a water line with sufficient capacity to service the
 entire Parker  Ford area in the future.

 EPA Response:   Since EPA has  identified Potentially Responsible
 Parties  ("PRPs")  for the remediation of the Site,  one enforcement
 option is for  EPA to enter into a consent  decree with the PRPs to
 implement and  pay for the remedy,  including the municipal water
 supply portion of the remedy.   In addition,  if EPA is unable to
 negotiate a consent decree, another option would be a unilateral
 administrative order,  which would order the parties to implement
 the remedy or,  if the PRPs do not implement the remedy,   EPA has
 the additional option of using the Superfund to pay for the costs
 and seek reimburement- of its  cost from the PRPs in a cost-
 recovery action.

 Based  on EPA's coordination with the Township Supervisors to
 date,  the Supervisors have stated that  they favor the municipal
 water  line option,  but that the water line would require final
 Township approval by resolution.

 EPA cannot state  for certain  whether other parties plan to
 install  a water line with sufficient capacity to service the
 entire Parker  Ford  area  in the future.   EPA's authority at the
 Site is  limited to  protecting human health and the environment
 from exposure  to  site-related risks.  That is why the Plan and
 the ROD  state  that  the water  line  will  be  provided to those
 residences and  businesses impacted or potentially impacted by the
 contaminated groundwater.   EPA has selected  this remedy partly
 because  Citizens  has assured  EPA that they have the capacity to
 service  these  residences  and  businesses.   Rockwell's contractor,
 however,  has stated  in the Site's  FS, that "a 12-inch water line
 will be  installed...sized to permit future development...".   EPA
will coordinate the  design of  the  system with Citizens,  the
Township  and possibly the PRPs,  and the  final design of  the
 system will be  based on the results of  this  coordination.

 •    A citizen asked what the  estimated  flow would be to service
the impacted people with  a supply  of  drinking water.

EPA Response:  Currently  six businesses and  residences are known
to be impacted.  The FS has calculated  that  1,800  gallons of

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 water would  be  necessary  to  replace  these  wells  based  on an
 assumed average consumption.of  300 gallons per well.   From this
 information,  the FS  stated that the  peak water supply  rate for
 those 6 wells is estimated at 18 gpm.

 •     A citizen  made  a  comment that he didn't  think  EPA has
 studied or evaluated the  water  line  enough or given the Township
 enough information regarding the type of public  water  system,  how
 much  of an area it will cover,  what  is going  to  be  the recurring
 cost  (i.e.,  users fees and hook up costs)  to  all the people
 involved and what provisions are there if  the plume was to spread
 unexpectedly.

 EPA Response:   EPA has properly followed the  guidance  and
 regulations  in  studying and  evaluating the options  available to
 provide an alternative public water  supply to the affected
 residences and  businesses.   EPA has  selected  the municipal water
 line  from four  possible water supply alternatives as the remedy
 that  best meets the  nine  criteria that EPA utilizes for
 comparative  analysis purposes,  as documented  in  the Plan and the
 ROD.

 Regarding the area served, the  water line  shall  be  extended to
 those residents and  businesses  that  are affected or potentially •»-..
 affected by  the plume.  The  affected wells are those that
 currently have  activated  carbon filters.   As  stated in the Plan
 and the ROD,  however,  the determination regarding which residents
 are potentially affected  cannot be made until the outer
 boundaries of the plume are  further  characterized.  The
 definition of "potentially affected" has been further  defined  in
 the ROD to address this concern.

 Regarding users'  fees  and hook-up costs, EPA's authority is
 limited to providing an alternative  source of drinking water,  and
 will  ensure that  the water line is hooked  up  to  the impacted
 residences and  businesses.   Therefore, there  are no hook-up costs
 to be paid by the users.  EPA cannot, however, pay  recurring user
 fees  if  it was  to implement  the remedy.  Rockwell's contractor,
 however,  included several years of user fees  as  operating and
 maintenance costs in the  FS.

 As part  of the  remedy, the plume shall be  controlled,  treated  and
 monitored on a  regular basis, as defined in the  ROD.   Therefore,
 if for  some unexpected reason,  the plume was  to  spread,  EPA will
 detect  this event and take appropriate actions to protect human
 health  and the  environment from site-related  contaminants.

 B.        Costa

 •    A citizen  asked what the project costs have been  to date.

 EPA Response:   EPA does not  have information  on  the RI/FS costs
 to date  because the  majority of  the  work was  performed by
Rockwell, and they are not required  to submit any cost

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 information to EPA.

 F.         Super fund  Process

 •     A citizen asked when the information from the public meeting
 will  be published in the public record?

 EPA Response:   A copy of the transcript  from the meeting is  in
 the Administrative Record and a copy of  that is in the  Site
 repository at  the Township building.

 •      A citizen asked whether a public meeting on EPA's final
 determination  will be held before  it is  made effective  and
 whether EPA would notify the Township supervisors directly.

 EPA Response:   The purpose of the  public meeting held on May 27,
 1993,  was  to propose EPA's preferred remedy and to take comments
 prior to selecting the final remedy.  EPA will notify the
 Township supervisors of the selected remedy.

 •      A citizen commented that it  seemed that EPA already
 unilaterally made the final decision and selected the final
 remedies.

 EPA Response:   The purpose of the  public meeting held on May 27,
 1993,  was  to propose EPA's preferred alternative and to take
 comments on the preferred alternative, as well as the other
 alternatives,  prior  to selecting the final remedy.

 3.  SUMMARY OF WRITTEN COMMENTS RECEIVED AMD BPA'8 RESPONSES

 Only  one written comment letter was  received by EPA.  In a  four
 page  document  dated  June 17,  1993, Jerome C.  Muys,  Jr.,  commented
 on  the  Plan for the  Site on behalf of the Rockwell International
 Corporation.   A copy of this document is contained in the
 Administrative Record for the Site.   The written comments and
 EPA's responses are  summarized below:

 Conent:        Recticon is not currently a subsidiary of Rockwell
                International;  it is  a former  subsidiary.

 EPA Response:   EPA agrees  with this  comment.   Neither the Plan or
                the ROD,  however, contradicts  this fact.

CoBMat:        In  addition to road surface runoff,  elevated
                levels  of copper and  zinc at the Site may reflect
                the elevated levels of these metals commonly  found
            ,    in  soil samples in  southeastern Pennsylvania.  See
                United  States Geological  Service,  Professional
                Paper No.  1270,  Element Concentrations in Soils
                and Other Surficial Materials  of the Conterminous
                United  States (1984).

EPA Response:   EPA agrees  that levels of these elements  are

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 Comment:
EPA Response:
Comment:
EPA Response:
Cement:  A)
 commonly found  in  soil samples  in southeastern  PA.
 This  fact,  however, does not explain why  the  data
 for zinc shows  a definite trend of  increasing
 concentrations  further from the background  samples
 and why the concentrations of both  elements are
 much  greater  in the downgradient samples  than in
 the background  samples.  A gap  remains  in the data
 for these elements which shall  be addressed by
 performing  a  verification study as  required by  the
 Record  of Decision.

 The second  sentence in the first paragraph  on page
 5  should be changed to read "Consumption  of
 untreat'ed groundwater..."

 The first full  paragraph on page 4  of the Plan
 specifies that  the Site risks are posed by  the  use
 of untreated  groundwater.  Use  of untreated
 groundwater when calculating future risks is  a
 given assumption since the National Contingency
 Plan  ("NCP")  requires that groundwater be restored
 to its  benificial  use, which at this Site is  a
 drinking water  supply, as noted in  the ROD.

 The Plan should define which residents are
 "potentially  affected" by the contaminant plume.
 The extension of the water line should only be  to
 those residents that could reasonably be  expected
 to be affected by  the plume.

 EPA agrees  that the water line  should only  be
 extended to those  residents and businesses  that
 could reasonably be expected to be  affected by  the
 plume.   As  stated  in the Plan and the ROD,
 however,  the  determination regarding which
 residents are potentially affected  cannot be made
 until the outer boundaries of the plume are
 further  characterized.   The definition of
 "potentially  affected" residences and businesses
 has been further defined in the ROD to address
 this concern.

The Plan does not  identify how the  "background"
 level of  groundwater contamination will be
determined.  There are potential upgradient
 sources  of  groundwater contamination in the area
 of the Site.  For  example,  Taylor Industries,
 located  approximately 1/4 mile upgradient of the
 Site has  had  3 ppb to 6.8 ppb of TCE in its
production  well.  The contribution  of these
 sources  to  the Site groundwater contaminant plume
must be  taken into account in identifying
 "background"  levels of contamination.  It is
Rockwell's  understanding that EPA has taken the

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                position  that  the  residential  wells  southwest  of
                the  Site  reflect background.   As  discussed in
                Rockwell's  FS  and  Response  to  Comments,  Rockwell
                does not  believe that  these wells accurately
                reflect the background levels  of  contamination in
                the  area  of the site.   Because the background
                level will  be  one  of the primary  factors
                influencing the scope  and extent  of  the
                groundwater and soil cleanup,  EPA must provide a
                reasonable  opportunity for  comment on the  Agency's
                identification of  background.   See 40 C. F. R.  §
                300.430(f)(2).

          B)    The  Plan  states that the objective of the
                groundwater treatment  alternatives is to restore
                the  plume to background levels, "if  technically
                practicable."  EPA should define  the meaning of
                "if  technically practicable1* and  provide an
                opportunity to comment on this  issue.

          C)    The  Plan  states that the combined recovery well "
                pumping rate "that will capture the  estimated
                groundwater contaminant plume  is  approximately 225*.
                gallons per minute ('gpm')."  This statement fails ~
                to reflect  the fact that virtually all of  the
                critical  variables influencing  the design  of the
                groundwater remediation system  (e.g.. size of
                plume, flow rate,  contaminant concentrations)  are
                at this time to some extent unknown.  The  225  gpm
                number was  used in the  FS simply  as  a means for
                comparing different treatment technologies and
                does  not  reflect an actual estimate  of the
                necessary pumping  rate, since that rate  cannot be
                even  roughly estimated  at this time.

          D)    See comments on page 14, 2nd J. regarding  the
                applicable  effluent limitations.

          E)   This  paragraph should be changed  to  state  that
                further evaluation of the groundwater treatment
                option will  be necessary prior to  implementation.
EPA Response:
          A)   To address this comment, which substantially
               repeats comments made by Rockwell in the
               Administrative Record, the ROD contains a
            1   performance standard for the groundwater
               extraction/treatment portion of the remedy that
               defines how background shall be determined.  The
               background concentrations for each contaminant of
               concern shall be established in accordance with
               the procedures for groundwater monitoring outlined
               in 25 PA Code $264.97 before groundwater treatment

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     begins.  (The specific chapter containing this
     provision was cited by Rockwell's contractor in
     the FS,  including Table 2.1 in connection with
     state hazardous waste regulations for ground
     water.)  In the event that a contaminant of
     concern  is not detected in samples taken for the
     establishment of background concentrations, the
     detection limit for the method of analysis
     utilized with respect to that contaminant shall
     constitute the "background11 concentration of the
     contaminant.  We note also that no contaminants
     were found in the well on the Taylor Industries
     property during EPA's residential well sampling
     activity in January 1990.  Those results are
     reported in the Site Administrative Record ("AR")
     on pages AR400001-AR400052.

     EPA's responsibilities to provide reasonable
     opportunity for comment are set forth in 40 C.F.R.
     § 300.430(f)(2), which has been cited throughout  -
     this comment letter, and in 40 C.F.R. § 300.
     430(f)(3)(i)(C).  The latter section of the
     National Contingency Plan ("NCP") provides, in
     part, the following:

     "Provide a reasonable opportunity, not less than
     30 calendar days, for submission of written and
     oral comments on the proposed plan and information
     located in the information repository,..."

     EPA has complied with the NCP by providing a
     reasonable opportunty to comment, including a 30-
     day public comment period after issuance of the
     Plan [which complied with the requirements of 40
     C.F.R. S 300.  430(f)(2)] along with the supporting
     documentation, including the RI/FS, and by
     considering the public comments received in the
     ROD.

B)   EPA has further defined the meaning of "if
     technically practicable1* in the ROD.  It may
     become apparent during implementation or operation
     of the groundwater extraction system and its
     modifications, that contaminant levels have ceased
     to decline and are remaining constant at levels
     higher than the performance standards over some
  ,   portion of the contaminated plume.  In that case,
     EPA, in consultation with the Commonwealth of
     Pennsylvania,  may determine that implementation of
     the selected remedy demonstrates, in corroboration
     with hydrogeological and chemical evidence, that
     it will be technically impracticable to achieve
     and maintain the performance standards throughout
     the entire area of groundwater contamination.

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          C)
          D)
          E)
Comment:
EPA Response:
Comment:
 EPA  utilized the  combined  recovery well  pumping
 rate estimated  in the  FS by  Rockwell's contractor
 for  the  Plan.   EPA, however,  clearly stated  in the
 Plan that  further hydrogeologic  data is  necessary
 to design  the extraction system.   To further
 address  this concern,  the  remedy description in
 the  ROD  has  been  revised to  include  the  following
 language:

 Final flow rates  and GAC system  dimensions will be
 determined by EPA during remedial design.  The
 final combined  pumping rate  will  be  determined by
 EPA  based  on the  size  and  number  of  wells
 necessary  to hydraulically control the
 contaminated groundwater plume.

 See  response to comments on  page  14,  2nd f.
 regarding  the applicable effluent limitations.

 The  Plan and the  ROD clearly state that  further
 hydrogeologic data is  necessary to design the
 extraction system and  that EPA may consider  the
 use  of the other  groundwater treatment options
 based on the results of the  predesign
 hydrogeologic investigation  which is required
 prior to construction  of the remedy.

 The  Plan states that "periodic monitoring" will be
 required to  determine  the  effectiveness  of the
 selected alternative.  The Plan should specify how
 frequently this monitoring will take place.
 Rockwell submits  that, once  the treatment system
 is in place, annual monitoring will  be sufficient
 to determine the  effectiveness of the system.

 EPA  has  considered this comment in preparation of
 the  ROD.   Rockwell's contractor specified
 quarterly  groundwater monitoring  under the
 operation  and maintenance  costs in the FS.  The
 ROD  specifies that the wells  shall be sampled
 quarterly  for the  first three years  and  semi-
 annual ly thereafter.

 The  Plan states that, based on additional
 information, "the selected system may no longer be
 cost-effective when compared to one,  or a
 combination, of the other  extraction/treatment
 alternatives.   In that case, based or the final
design parameters, EPA may consider  the
utilization of  any of the groundwater treatment
technologies presented in  the Proposed Plan that
 is determined to be the most cost-effective."
Rockwell appreciates EPA's efforts to provide some

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EPA Response:
Comment:


EPA Response:


Convent:



EPA Response:


Comment:  A)


          B)
flexibility in the determination of the
appropriate remedy in light of the limited data
currently available, and believes that, once the
pre-design work is completed, it is very possible
that another treatment option, such as air
strippng, will prove to be the most cost-
effective.  However, if the treatment option
ultimately selected departs in any significant
manner, such as increased cost or design, from the
options evaluated in the proposed remedial action
plan, we believe that EPA should provide Rockwell
and other interested parties a meaningful
opportunity to comment on that treatment option.

The ROD states, as required by the National
Contingency Plan ("NC~ ') that, if such a decision
is made, EPA shall amend the ROD or issue an
Explanation of Significant Differences.  EPA shall
then comply with the applicable community relation
requirements found under 40 C.F.R. §300.435(c)(2).

See comments on page 9, 1st \, with respect to the
determination of "background."

See response to comments on page 9, 1st f, with
respect to the determination of "background."

The Plan incorrectly states that permits will be
required from RCRA facilities that accept soil
from the Site for incineration or land disposal.

EPA agrees. The ROD now addresses this comment by
deleting that reference.

See comment on page 9, 1st J, regarding the
meaning of "if technically practicable."

See comment on page 9, 1st f, regarding the
identification of "background" levels of
contamination.
          C)   The Plan does not provide an opportunity for
               meaningful comment on the effluent limitations
               that will be applied to the discharges from the
               Site to the Schuylkill River.  The Plan refers to
               the State NPDES regulations and water quality
           •    standards.  Those regulations and standards,
               however, do not provide effluent limitations
               applicable to the Site discharges.  The Plan
               states that the State has made a preliminary
               determination that the Site discharges will
               require 98% removal of the VOCs "based on
               Technology Based Effluent Limits."  EPA has

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EPA Response:
               provided no basis for this statement.  It is not
               known what technology-based limits are being
               relied upon by the State,  it is also unclear
               whether the 98% removal will be a design
               specification or an efficiency limitation that
               must be met by the treatment process.  It is
               further unclear whether this 98% removal refers to
               total VOCs.  EPA must provide a reasonable
               opportunity for comment on the discharge
               limitations.   See 40 C. F. R. S 300.430(f)(2).
          A)    See response to comment on page 9,  1st J,
               regarding the meaning of "if technically
               practicable."

          B)    See response to comment on page 9,  1st \,
               regarding the identification of "background"
               levels of contamination.

          C)    As stated above,  EPA's responsibilities to provide
               reasonable opportunity for comment,  in accordance
               with 40 C.F.R.  S300.430(f)(2)  and 40 C.F.R.
               S300.430(f)(3)(i)(C), is,  as set forth in part in
               the latter section,  to:

               "Provide a reasonable opportunity,  not less than
               30 calendar days,  for submission of  written and
               oral comments on the proposed plan and information
               located in the information repository,..."

               The information repository contains  the FS
               prepared by Rockwell's contractor, the Plan and a
               letter (see AR304243-AR304245)  containing the
               Commonwealth of Pennsylvania's' NPDES determination
               dated April 9,  1993.   That letter states that
               Technology Based Effluent  Limits ("TBELs")  based
               on 98 percent removal must be achieved for
               trichloroethene,  cis-1,2,-dichloroethene and
               cyanide and that all other parameters of concern
               should be monitored  for.  This determination was
               based on water  quality data from Table 7-3 of the
               draft FS.   (Please note  that the table incorrectly
               reported cyanide  as  a compound that  was expected
               to be in the extracted groundwater at 0.2  ppm.
               Cyanide was  never  detected in any groundwater
               sample but Rockwell's contractor incorrectly
               reported the detection limit of 0.2  ppm as an
               actual result.  Also note  that PADER explained
               during a telephone communication on  June 24,  1993,
               that the term TBELs  was  incorrectly  referenced in
               their letter.   The correct term is BOAT, as
               defined under 25 PA  Code 595.4(g), which is also a

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regulation cited in the FS.)  The FS identified
NPDES regulations and water quality standards (see
Table 2-5} as being potential action-specific
ARARs for the Site's discharges.  EPA has complied
with the requirement to provide reasonable
opportunity for comment by; including the
information it utilized to formulate the Plan,
providing a 30 day public comment period after
issuance of the Plan and considering the public
comments received on the Plan in the ROD.

The ROD further addresses this comment by
including the 98 percent removal requirement as a
performance standard that must be achieved in the
treated groundwater prior to discharge.

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APPENDIX D     ADMINISTRATIVE RECORD INDEX

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                       RECTICQN/ALLIED STEEL
                    ADMINISTRATIVE RECORD FILE *
                        INDEX OF DOCUMENTS
 I.    SITE IDENTIFICATION

      1.    Letter to Mr.  Richard N.  Snyder,  Allied Steel  Products
           Corporation,  from Mr.  Dennis  Pennington,  SMC Martin
           Inc.,  re:  TCE investigation  report,  3/7/84.
           P.  100001-100014.   The report is  attached.

      2.    Report:   Report on Groundwater Contamination bv Organic
          'Solvents  at Allied Steel  Corporation's  Parker  Ford.
           Pennsylvania Manufacturing  Facility,  prepared  by R.E.
           Wright Associates,  Inc.,  5/85.  P.  100015-100074.

      3.    Report:   Target Population  Study  Report.  Rockwell
           International  - Recticon. prepared  by NUS Corporation,
           1/10/86.   P. 100075-100117.

      4.    Report:   Preliminary Assessment,  prepared by
           Pennsylvania Department of  Environmental  Resources
           (PADER),  (undated).  P. 100118-100230.
*    Administrative Record File available 8/10/89, updated
     1/7/91, 7/29/91, 6/1/92, 5/20/93, and 6/30/93.

Note:     Company or organizational affiliation  is identified in
          the index only when it appears in  the  file.

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II.  REMEDIAL. ENFORCEMENT PLANNING
Allied Steel

     1.   Letter to Mr. Richard Snyder, Allied Steel Products
          Corporation, from Mr. Bruce P. Smith, U.S. EPA, re:
          104 (e) request for information, 3/27/87.  P. 200001-
          200003.

     2.   Letter to Mr. William Early, U.S. EPA, from Ms. Vicki
          Jan Isler, Budd, Lamer, Gross, Picillo, Rosenbaum,
          Greenberg & Sade, re:  Extension for 104(e) response,
          4/6/87.  P. 200004-200005.

     3.   Letter to Ms. Vicki Isler, Budd,  Larner, Gross,
          Picillo,  Rosenbaum, Greenberg & Sade, from Mr. William
          C. Early, U.S.  EPA, re:  Location map, 4/23/87.
          P. 200006-200008.  Two copies of the map are attached.

     4.   Letter to Mr. Sudhir R. Patel, U.S. EPA, from Mr.
          Richard N. Snyder,  Budd, Larner,  Gross, Picillo,
          Rosenbaum, Greenberg & Sade, re:   Terminology
          clarification,  6/29/87.  P. 200009-200010.

     5.   Letter to Ms. Laura Boornazian, U.S. EPA,  from Ms.
          Vicki Jan Isler, Budd,  Larner, Gross, Picillo,
          Rosenbaum, Greenberg & Sade, re:   Delineation of the
          Parkerford TCE site,  8/19/87.  P. 200011-200012.

     6-   Letter to Ms. Laura Boornazian, U.S. EPA,  from Ms.
          Vicki Jan Isler, Budd,  Larner, Gross, Picillo,
          Rosenbaum, Greenberg & Sade, re:   Inclusion of Allied
          Steel property in site, 8/27/87.   P. 200013-200090.
          Supporting non-privileged documents are attached.

     7.   Letter to Mr. John Van Dzura, Sr.,  Allied Steel
          Products  Corporation,  from Mr. Stephen R.  Wassersug,
          U.S. EPA, re:  Notification of potential
          responsibility,  5/2/89.  P. 200091-200095.

     8.   Letter to Mr. David G.  Byro, U.S. EPA, from Mr. H.
          Frank Pettit, re:  Response to request for information,
          5/16/89.   P.  200096-200097.

     9.   Letter to Mr. H. Frank Pettit, from Mr. Joseph J.C,
          Donovan,  U.S. EPA,  re:   "Innocent Landowner" policy,
          7/6/89.  P. 200098-200098.

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      10.   Letter to Mr. David G.  Byro,  U.S.  EPA,  from Mr.  H.
           Frank Pettit, Counselor at Law,  re:   Supplemental
           information,  7/18/89.   P.  200099-200102.   A letter
           regarding insurance benefits  is  attached.

      11.   Letter to Mr. John Van  Dzura,  Sr., Allied  Steel
           Products Corporation, from Mr. Thomas C. Voltaggio,
           U.S.  EPA,  re:  Special  notice letter,  10/19/89.
           P.  200103-200106.   Two  certified mail receipts are
           attached.

      12.   Letter to Mr. John Van  Dzura,  Sr., Allied  Steel
           Products Corporation, from Ms. Sarah  E. Peachey,
           U.S.  EPA,  re:  Good Faith  proposal for  RI/FS, 11/9/89.
           P.  200107-200108.

Hiahview Gardens

      13.   Letter to Mr. David G.  Byro,  U.S. EPA,  from Ms.
           Catherine M.  Harper, Hamburg,  Rubin,  Mullin and
           Maxwell,  5/18/89.   P. 200109-200110.

      14.   Letter to Mr. David G.  Byro,  U.S. EPA,  from Ms.
           Catherine M.  Harper, Hamburg,  Rubin,  Mullin and
           Maxwell,  re:   Response  to  104(e) inquiry,  5/30/89.
           P.  200111-200155.

      15.   Letter to Ms. Catherine M.  Harper from  Mr.  Joseph J.C.
           Donovan, U.S.  EPA,  re:  "Innocent Landowner" policy,
           7/6/89.   P. 200156-200156.

      16.   Letter to  Mr.  John  Gambone, Highview  Gardens, Inc.,
           from Mr. Thomas C.  Voltaggio, U.S. EPA, re:  Special
           notice letter, 10/19/89.   P.  200157-200158.

      17.   Letter to  Mr.  John  Gambone, Highview  Gardens, Inc.,
           from Ms. Sarah E. Peachey,  U.S. EPA,  re:  Good Faith
           proposal  for  RI/FS,  11/9/89.  P. 200159-200160.

      18.   Letter to  Mr.  David G.  Byro, U.S. EPA,  from Ms.
           Catherine  M.  Harper, Hamburg, Rubin,  Mullin & Maxwell,
           re:  RI/FS negotiations, 12/15/89.  P.  200161-200163.


Rockwell International

      19.   Latter to  Mr.  Harry E.  Pappas, Recticon Corporation,
           from Mr. Richard L.  Hinckle, East Coventry  Township,
           re:  Industrial waste discharge, 7/31/73.   P. 200164-
           200174.  The  following  are  attached:

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           a)    a letter concerning  Recticon Preliminary
                Report;

           b)    a letter concerning  pH  and conductivity;

           c)    a Recticon  Corporation  pH  record;

           d)    a Recticon  Corporation  TDS by Conductivity
                Record;

           e)    a letter concerning  a permit for  industrial
                waste waters;

           £)    a PADER  Waste Discharge Inspection Report;

           g)    a letter regarding violation of the Clean
                Streams  Law.

20.  Letter to  Mr. James A. Vlahos, Rockwell International-
     Recticon,  from Mr.  Richard L.  Hinkle,  PADER,  re:
     Effluent limitations  for waste water discharge,
     2/14/78.   P. 200175-200180.  The  following  are
     attached:

           a)    a letter regarding waste water;

           b)    a letter regarding unpermitted industrial
                waste;

           c)    a waste  discharge inspection report;

           d)    a letter regarding industrial  waste
                discharges.

21.  Letter to  Mr. Rae  Houke, Rockwell International, from
     Mr. Dan Yost, Rockwell International,  re:   Proposed
     response to Ms. Shupe's [sic] March  11,  1980  letter,
     3/28/80.   P. 200181-200187.  The  following  are
     attached:

          a)    Ms. Shup's letter;

          b)    a  letter regarding PADER inspection;

          c)    a PADER  Waste Discharge Inspection  Report;

      $   d)    a letter regarding application for  permit to
                discharge waste water;

          e)    a Wastex Industries  Incorporated  Sample
               Analysis sheet;

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          f)   a second Wastex Industries Incorporated
               Sample Analysis sheet.

22.  Letter to Ms. Marilyn Shup, PADER, from L.W. Slaven,
     Rockwell International, re:  Application for a NPDES
     permit, 3/31/80.  P. 200188-200188.

23.  Letter to Mr. David W. Stevenson, Rockwell
     International, from Mr. Michael R. Ruser, Highview
     Gardens, Inc., re:  Contaminated wells, 4/1/80.
     P. 200189-200191.  A letter regarding a well located on
     Highview Garden property is attached.

24.  PADER Bureau of Water Quality Management Water or Waste
     Quality Report - Special Analyses, 4/17/80.  P. 200192-
     200193.

25.  List of Actions Taken, April/May, 1980.  P. 200194-
     200198.  The following are attached:

          a)   a list of Planned Near Term Actions;
          b)   a list of Planned Corrective Actions;
          c)   a list of Alternative Planned Actions;
          d)   a list.of waste effluents.

26.  Letter to Mr. L.W. Slaven, Rockwell International-
     Recticon, from Ms. Marilyn Shup, PADER,  re:
     Industrial waste, 5/2/80.  P. 200199-200201.  A
     parameter and effluent chart and a list of detected
     chemicals are attached.

27.  Letter to Recticon Corporation from Mr. James P.
     Ridolfi, PADER, re:  Draft Water Quality Management
     Permit, 5/6/80.  P. 200202-200223.  The permit is
     attached.

28.  Letter to L.H. Slaven, Rockwell International-
     Recticon, from Mr. William H. Jolly, III, PADER, re:
     Groundwater contamination, 5/22/80.  P. 200224-200230.
     The following are attached:

          a)   a list of sampling sites;
          b)   a TCE Contamination in Parkerford map;
          c)   a second list of sampling sites;
          d)   a location map.

29.  Letter to Ms. Marilyn Shup, PADER, from L.W. Slaven,
     Rockwell International, re:  Facility Pollution
     Incident Prevention Plan, 5/29/80.  P. 200231-200252.
     The plan is attached.

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 30.   Handwritten outline  from Rockwell  International/Allied
      Steel  Company meeting,  6/9/80.   P.  200253-200257.
      A list of  attendees  is  attached.

 31.   Handwritten attendance  list  from Rockwell
      International/Allied Steel Company meeting,  6/9/80.
      P.  200258-200266.  Notes from the  meeting  are  attached.

 32.   Handwritten Recticon-Parkerford, PA,  information sheet,
      6/9/80.  P.  200267-200267.

;33.   Handwritten list of  chemicals at polymeric storage
      area,  6/10/80.  P. 200268-200268.

 34.   Letter to  Mr.  William H.  Jolly,  III,  from  R.E. Houke,
      Rockwell International,  re:  List  of  hydrogeologists,
      6/12/80.   P.  200269-200272.  A copy of a business card
      and a  list of consulting firms are  attached.

 35.   Handwritten notes on Recticon, Parkerford,  PA, 6/19/80.-
      P.  200273-200277.

 36.   Letter to  Mr.  Arnold W.  Canfield,  Rockwell
      International, from  Mr.  Randall  J.  Brubaker, PADER,  re:
      Transmittal  of a Proposal Consent Order and Agreement,
      6/20/80.   P.  200278-200289.  The Proposal  Consent Order
      In  The Matter Of Rockwell International-Recticon and a
      Groundwater  Contamination Investigation in Parkerford
      are attached.

 37.   Letter to  Mr.  James  P. Ridolfi,  PADER, from Mr. Roy  J.
      Bestland,  Rockwell International,  re:  Discharge
      monitoring,  7/9/80.   P.  200290-200290.

38.   Letter to  Mr.  James  P. Ridolfi,  PADER, from Rockwell
      International, re:   NPDES permit,  7/10/80.  P. 200291-
      200292.

39.   PADER  Waste  Discharge Inspection Report, 7/15/80.
      P. 200293-200295.  An internal letter concerning short-
      term environmental compliance and a list of soil
      samples analytical results are attached.

40.   Letter to  Mr.  Randall J. Brubaker,  PADER,  from Mr.
     Arnold W.  Canfield,  Rockwell International, re:
     Extension  for  hydrogeologic study,  7/17/90.  P. 200296-
      2\J0298.  A waste discharge inspection report and an
      internal letter regarding the relocation occupancy
     design package are attached.

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 41.   Memorandum to Mr.  Roy Bestland  from Ms. Marilyn  Shup,
      PADER,  re:   The  results of  well  water  after  filter,
      7/18/80.   P.  200299-200299.

 42.   Letter  to  Mr.  Randall F. Brubaker,  PADER,  from Mr.  Roy
      J.  Bestland,  Rockwell International, re:   Scope  of  Work
      for ground water,  7/25/80.  P.  200300-200307.  The
      proposed Scope of  Work is attached.

 43.   Letter  to  Mr.  Roy  J.  Bestland, Rockwell International-
      Recticon,  from Mr. James P. Ridolfi, PADER,  re:  Draft
      effluent limits, 8/21/80.   P. 200308-200309.  A  list of
      effluent limitations  and monitoring requirements is
      attached.

 44.   Letter  to  Mr.  Roy  J.  Bestland, Recticon, from Mr.
      Randall J.  Brubaker,  PADER, re:  TCE Contamination  of
      groundwater,  8/26/80.  P. 200310-200310.

 45.   Letter  to  Mr.  Roy  J.  Bestland, Rockwell International--
      Recticon,  from Mr. James P. Ridolfi, PADER,  re:  Draft
      Effluent Limits, 9/8/80.  P. 200311-200312.  The Draft
      Effluent Limits  are attached.

 46.   Letter  to  C.T. Beechwood, PADER, from  Mr.  Joseph Davis,
      U.S. EPA,  re:  Approval of  revised  draft permit,
      9/25/80.   P.  200313-200313.

 47.   Letter to Mr.  Roy  J.  Bestland, Rockwell International-
      Recticon,  from Mr. James P. Ridolfi, PADER,  re:
      Written comments on Draft Effluent  Limits, 10/9/80.
      P.  200314-200314.

48.   Wastex Industries, Inc. Effluent (Waste Sample) Sheet,
      10/10/80.   P.  200315-200315.

49.   Letter to Mr.  Roy  Bestland, Rockwell International,
      from Mr. Frederick Bopp III, Roy F. Weston Inc., re:
     Draft findings Phase  I, 10/17/80.   P.  200316-200342.
     The Phase I Report -  Working Draft  is  attached.

 50.   Project Engineering Work Schedule for  Building No.  802,
      10/20/80.   P.  200343-200345.  A handwritten  Suspended
      Solids Sheet is attached.

 51.   Letter to Mr.  James P. Ridolfi, PADER, from  Mr. Roy J.
      Bastland, Rockwell International, re:  NPDES
     Application, 10/22/80.  P. 200346-200348.  A list of
      soil sample analytical results and  a letter  concerning
      the TCE Contamination Proposal are  attached.

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 52.   Recticon Corporation Written Consent  of  Board of
      Directors,  10/29/80.   P.  200349-200350.

 53.   Letter to Ms.  Marilyn Shup,  FADER,  from  Mr.  Daniel M.
      Yost  and Mr.  Roy J.  Bestland,  Rockwell International,
      re:   Pollution Incident  Prevention  Plan,  11/4/80.
      P.  200351-200356.   Revised  copies of  Page 8  and a  list
      of  companies  that  specialize in oil spill clean-up are
      attached.

 54.   Handwritten Recticon  Progress  Report, 11/5/80.
      P.  200357-200359.

,B5.   Handwritten D.E.R.  Norristown  notes,  11/6/80.
      P.  200360-200361.

 56.   Letter to Mr.  Roy  J.  Bestland,  Rockwell  International-
      Recticon,  from C.T. Beechwood,  PADER, re:  Pollution
      Incident  Prevention Plan, 11/13/80.   P.  200362-200363.
      A graph is  attached.

 57.   Handwritten notes  from meeting with D.E.R, 11/25/80.
      P. 200364-200368.  A  list of attendees is attached.

 58.   Parkerford  Well  #1 Monitoring  Log, 1981.   P.  200369-
      200378.  The following are attached:

          a)   Figure 1, TCE Concentration Levels, No.  1
               Well;

          b)   Figure 2, 1,2, Dichloroethene  Concentration
               Levels;

          c)   Parkerford  Sample Locations TCE
               Concentrations;

          d)   two Wastex  Industries, Inc. Analysis  sheets;

          e)   a sample map;

          f)   a map  of TCE Contamination in  Parkerford;

          g)   a list of sample sites.

59.   Letter  to PADER, from R.J. Bestland, re:   Modifications
     to the  Pollution Incident Prevention Plan, 1/7/81.
     P. 200379-200380.

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 60.   Letter  to R.J. Bestland, Rockwell  International,  from
      C.T. Beechwood, PADER, re:  Pollution Incident
      Prevention Plan, 1/23/81.  P. 200381-200383.  A  letter
      concerning modification to the Pollution  Incident
      Prevention Plan is attached.

 61.   Handwritten Recticon Status Report, 1/29/81.
      P. 200384-200385.

 62.   Handwritten Recticon-Parkerford, ' PA, Composite Sampling
      list, 2/2/81.  P. 200386-200386.

 63.   Consent Order and Agreement In The Matter Of:  Recticon
      Corporation, 2/19/81.  P. 200387-200397.

 64.   PADER Bureau of Water Quality Management Water or Waste
      Quality Report, 2/24/81.  P. 200398-200399.

 65.   PADER Bureau of Water Quality Management Water or Waste
      Quality Report, 2/25/81.  P. 200400-200400.

 66.   Letter to Mr. Randall J. Brubaker, PADER, from Mr.     •»..
      Arnold W. Canf ield, Rockwell International Corporation, "*"•
      re:  Settlement Proposal for unpermitted industrial
      waste discharges, 3/3/81.  P. 200401-200404.  A
      handwritten Recticon Progress Report is attached.

 67.   Notification of Hazardous Waste Site,  U.S. EPA,
      4/15/81.  P. 200405-200407.

68.   Letter to Mr. Roy Bestland, Rockwell International-
      Recticon, from Mr.  Frederick Bopp III, re:  Contract
      with Delaware Container Company, Inc., 4/28/81.
      P. 200408-200417.  An information copy of the contract
      is attached.

69.   PADER Hazardous Waste Manifest,  5/13/81.  P. 200418-
      200425.   Seven Hazardous Waste Manifests are attached.

70.  Handwritten Parkerford Sampling list,  5/21/81.
      P. 200426-200428.  A PADER Water or Waste Quality
     Report - Special Analyses Report is attached.

71.  Handwritten Recticon notes, 6/8/81.  P.  200429-200433.

72.   Letter to Mr. Arnold W. Canfield,  Rockwell
      International,  from Mr. James D. Morris, PADER, re:
      Consent Decree letter, 8/28/81.   P. 200434-200436.
     A letter concerning consent decree guidelines is
      attached.

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 73.  Letter  to Mr. Arnold W.  Canfield, Rockwell
     International,  from Mr.  James D. Morris,  PADER,
     re:  Other sources of groundwater pollution,  9/9/81.
     P. 200437-200438.  A letter regarding  the revised
     Recticon Consent Order and Agreement is attached.

 74.  AGES Laboratories Certificate of Analysis,  9/28/81.
     P. 200439-200446.  Seven pages of sampling  data are
     attached.

 75.  Letter  to Rae Houke, Rockwell International,  from Mr.
     Dan Yost, Rockwell International, re:  Parkerford Well
     Monitoring Log, 10/2/81.  P. 200447-200448.   The well
     monitoring log  is attached.

 76.  Letter  to Wastex Industries, from Mr.  Joseph  J. Strug,
     Jr., Dalare Associates,  re:  Sample Analysis, 10/8/81.
     P. 200449-200449.

 77.  Letter  to Mr. Roy Bestland, Rockwell International,
     from Mr. Frederick Bopp  III, Roy F. Weston, Inc., re:
     Report  on soil  excavation operations,  10/13/81.        -
     P. 200450-200468.  The following are attached:

          a)    Figures 1-10, photographs and a map;

          b)    Attachment No. 1, U.S. EPA Priority Pollutant
               List, Volatile Organics Fraction;

          c)    Attachment No. 2, a letter regarding volatile
               priority pollutant analysis;

          d)    Attachment No. 3, a letter regarding analysis
               of fill material.

78.  Wastex  Industries,  Inc. Before Filter  and After Filter
     Sample Analysis sheet,  10/16/61.  P. 200469-200475.
     Five sample analysis sheets and one TCE Monitoring Well
     page are attached.

79.  Letter to Mr. John Gambone, Highview Gardens, Inc.,
     from Mr. Arnold W.  Canfield, Rockwell  International,
     re:  Consent Order and Agreement between PADER and
     Recticon, 10/21/81.   P. 200476-200478.

80.  Letter to A.W. Canfield,  Rockwell International, from
     R*E.  Houke,  Rockwell International,  re:  Weston Soil
     Excavation Report,  10/28/81.  P. 200479-200479.
                           10

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81.  Letter  to Bureau of Water Quality Management  from Mr.
     Roy J.  Bestland, Rockwell International, re:  Check
     pursuant to  the Consent Order and Agreement,  11/3/81.
     P. 200480-200492.  A Consent Order  In The Matter Of
     Recticon Corporation is attached.

82.  Letter  to Mr. Christian T. Beechwood, III, Rockwell
     International from Mr. Daniel M. Yost, Rockwell
     International, re:  October monitoring activity,
     11/23/81.  P. 200493-200497.  Three Parkerford Well
     Monitoring Operation sheets are attached.

83.  Wastex  Industries, Inc. Before Filter and After Filter
     Sample  Analysis sheet, 12/2/81.  P. 200498-200503.
     Handwritten  notes on wells one and two, three Before
     Filter  and After Filter sheets, and a handwritten page
     on the  TCE Monitor Well are attached.

84.  Letter  to Mr. Christian T. Beechwood, III, PADER, from
     Mr. Dan Yost, Rockwell International, re:  Sample
     Units,  12/4/81.  P. 200504-200507.  Parkerford Well
     Monitoring Operation Sheets dated 11/6/81, 10/30/81,
     and 10/16/81, respectively,  are attached.

85.  Letter  to Mr. Christian T. Beechwood, III, PADER, from
     Mr. Dan Yost, Rockwell International, re:  November
     well water pumping and monitoring activity at
     Parkerford,   12/22/81.   P.  200508-200510.  Two
     Parkerford Well Monitoring Operation sheets are
     attached.

86.  Letter to Rae Houke,  Rockwell International,  from Mr.
     Dan Yost, Rockwell International, re:  Parkerford well
     monitoring for November 12/22/81.  P. 200511-200511.

87.  Handwritten  Parkerford Well Monitoring Information
     sheet, 12/23/81.   P.  200512-200517.  Two Wastex
     Industries,   Inc.  Before Filter and After Filter Sample
     Analysis sheets,  two Parkerford Well Monitoring lists,
     and a Wastex Industries,  Inc.,  After Filter Sample
     Analysis sheet are attached.

88.  Parkerford Well Monitoring list, 1/8/82.  P.  200518-
     200523.   Two Wastex Industries, Inc. Before Filter and
     After Filter sheets,  two Parkerford Well Monitoring
     lists, and a Wastex Industries, Inc. After Filter sheet
     ake attached.

89.  Letter to Mr. Christian T. Beechwood, III, PADER, from
     D.M.  Yost,  Rockwell International, re:  December
     Groundwater  Pumping and Monitoring report, 1/22/82.
     P. 200524-200527.   The report is attached.

                           11

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 90.  Parkerford Well Monitoring List, 2/4/82.  P. 200528-
     200532.  Two Parkerford Well Monitoring lists and two
     Wastex Industries, Inc. sheets are attached.

 91.  Parkerford Well Monitoring Operation list, 2/9/82.
     P. 200533-200537.  The following are attached:

          a)   a letter concerning well water pumping and
               monitoring;

          b)   a Parkerford Well Monitoring Operation list,
               sample date 1/8/82;

          c)   a Parkerford Well Monitoring Operation list,
               sample date 1/27/82;

          d)   an internal letter concerning the Consent
               Order and Agreement between Recticon and
               PADER.

92.  Letter to Mr. Roy J.  Bestland, Rockwell International,
     from R.E. Houke, Rockwell International, re:  Consent
     Order and Agreement between Recticon and PADER,
     2/18/82.   P. 200538-200538.

93.  PADER Bureau of Water Quality Management Water or Waste
     Quality Report - Special Analyses,  lab number 3243,
     2/24/82.   P. 200539-200539.

94.  PADER Bureau of Water Quality Management Water or Waste
     Quality Report - Special Analyses,  lab number 3245,
     2/24/82.   P. 200540-200540.

95.  PADER Bureau of Water Quality Management Water or Waste
     Quality Report - Special Analyses,  lab number 3246,
     2/24/82.   P. 200541-200541.

96.  Parkerford Well Monitoring information package, 3/3/82,
     P. 200542-200554.

97.  Letter to Mr. Christian T. Beechwood, III, PADER, from
     Mr. Dan Yost, Rockwell International, re:   Groundwater
     recovery operation, 3/29/82.   P. 200555-200560.  Four
     Parkerford Well Monitoring Operation sheets and a
     letter regarding the well water pumping and monitoring
     operation report for January 1982 are attached.
      %
98.  Letter to Mr. Christian T. Beechwood, III, from
     Rockwell International, re:  Recticon's Interim
     Evaluation Report, 4/22/82.  P. 200561-200564.
     The report is attached.
                           12

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 99.  Letter  to D. Yost, Rockwell International,  from R.E.
     Houke,  Rockwell International, re:  Rewritten report,
     4/22/82.  P. 200565-200565.

 100. Memorandum  to Mr. Dan Yost, PADER, from Ms. Marilyn
     Shup, PADER, re:  Sample results for Parkerford,
     4/28/82.  P. 200566-200574.  Two Hazardous  Waste
     Manifests,  three transporter receipts, and  three
     Generator Manifest Documents are attached.

 101. Letter  to Mr. Christian T. Beechwood, III,  PADER, from
     Mr. Dan Yost, Rockwell International, re:   Parkerford
     ..Well Monitoring Operation, 4/28/82.  P. 200575-200577.
     ''Two Parkerford Well Monitoring Operation sheets are
     attached.

 102. Parkerford Well Monitoring information package,
     4/30/82.  P. 200578-200583.

 103. Letter  to Mr. Frank S. Shuklis, Rockwell Internationalr
     from R.E. Houke, Rockwell International, re:  Interim
     Evaluation Report, 5/6/82.  P. 200584-200595.  A letter^
     regarding the report and the report itself  are
     attached.

 104. Parkerford Well Monitoring information package,
     5/27/82.  P. 200596-200601.

 105. Parkerford Well Monitoring information package, 6/9/82.
     P. 200602-200609.

 106. Letter  to Mr. Christian T. Beechwood, III,  PADER, from
     Mr. Dan Yost, Rockwell International, re:   Parkerford
     Well Monitoring Operation, 6/17/82.  P. 200610-200614.
     Four Parkerford Well Monitoring Operation sheets are
     attached.

107. Parkerford Well Monitoring information sheet, 7/16/82.
     P. 200615-200616.   A Wastex Before Filter and After
     Filter sheet is attached.

108. Letter to Mr. Christian T. Beechwood III, PADER, from
     R.A. Bedley, Rockwell International, re:  Recticon
     Corporation's Final Report on the Groundwater Recovery
     Operation, 7/22/82.  P.  200617-200618.  A graph is
     attached.
       V
109. Le'tter to Mr. Christian T. Beechwood III, PADER, from
     R.A. Bedley, Rockwell International, re:  Final Report
     on Groundwater Recovery Operation, 7/22/82.  P. 200619-
     200619.
                           13

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 110.  Report:   Final Report.  Review of Groundwater Monitoring
      Data,  prepared by Roy F.  Weston,  Inc.,  7/26/82.
      P.  200620-200639.

 111.  Letter to Mr.  Ronald Leslie,  Rockwell  International
      Corp.,  from Mr.  James D.  Morris,  PADER,  re:   Meeting
      between  Rockwell/Recticon representatives  and PADER,
      8/16/82.   P.  200640-200641.

 112.  Letter to Mr.  James  D.  Morris,  PADER,  from Mr. Ronald
      Leslie,  Rockwell International,  re:  Legal
      coordination,  8/24/82.  P. 200642-200643.

 113.  Handwritten letter to Bob from Dan,  re:  Call from Ms.
      Marilyn  Shupe  [sic],  1/13/83.   P.  200644-200649.
      The  following  are  attached:

          a)    a letter concerning the  Final  Groundwater
                Report;

          b)    a letter requesting a meeting  between
                Recticon and  PADER;

          c)    a letter concerning a return phone call;

          d)    a letter concerning review of  groundwater
                monitoring  data;

          e)    a letter regarding  a groundwater report.

114. Letter to  Ma. Laura Boomazian, U.S. EPA,  from R.R.
     Kenski, Rockwell International, re:  104(e)
     information, 7/16/85.   P. 200650-200656.   Information
     on silicon is attached.

115. Letter to  Ms. Laura Boomazian, U.S. EPA,  from R.R.
     Kenski, Rockwell International, re:  Groundwater Study
     reports,  3/20/86.  P. 200657-200701.  The  two reports
     are attached.

116. Letter to  R.R. Kenski, Rockwell International
     Corporation, from Mr. Harold G. Byer, U.S. EPA, re:
     FOIA request, 8/13/86.  P. 200702-200703.

117. Letter to  U.S. EPA, from R.R. Kenski, Rockwell
     International, re:  Recticon Corporation,  9/3/86.
     P-i 200704-200704.

118. Letter to Mr. Al Sheets, Recticon Corporation, from
     R.R. Kenski, Rockwell International, re:  Claim of
     business confidentiality,  9/5/86.  P. 200705-200705.
                           14

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119. Letter to Ms. Lorie Acker, U.S. EPA, from Mr. Al
     Sheets, Recticon'Corporation, re:  Freedom of
     Information Act  (FOIA) release, 9/15/86.  P. 200706-
     200706.

120. Letter to Mr. Rae Houke, Rockwell International
     Corporation, from Mr. Bruce P. Smith, U.S. EPA, re:
     104(e) request for information, 4/3/87.  P. 200707-
     200709.

121. Letter to Mr. Sudhir R. Patel, U.S. EPA, from Rae E.
     Houke, Rockwell International, re:  104 (e) extension,
     4/9/87.  P. 200710-200713.  A list of chemicals used at
    ; Recticon and a letter concerning the 104(e) response is
     attached.

122. Letter to Mr. Donald Beall, Rockwell International
     Corporation, from Mr. Stephen R. Wassersug, U.S. EPA,
     re:  General notification of potential responsibility
     at the Recticon/Allied Site,, 5/2/89.  P. 200714-
     100717.

123. Letter to Mr. David G. Byro, U.S. EPA,  from Mr. John R.
     Stocker,  Rockwell International, re:  Participation in
     contamination investigation, 5/22/89.  P. 200718-
     200719.

124. Letter to Mr. Scott L. Holden, Rockwell International,
     from Mr.  Joseph J.C. Donovan, U.S. EPA, re:  "Innocent
     Landowner" policy,  7/6/89.  P. 200720-200720.

125. Letter to Mr. Robert K. Beck, Rockwell International,
     from Mr.  Thomas C.  Voltaggio, U.S. EPA, re:  Special
     notice letter,  10/19/89.  P. 200721-200722.

126. Letter to Mr. Robert K. Beck, Rockwell International,
     from Ms.  Sarah E. Peachey, U.S. EPA, re:  Good Faith
     Proposal for RI/FS, U/S/89.  P. 200723-200724.

127. Letter to Mr. David G. Byro, U.S. EPA,  from Mr. Robert
     K. Beck,  Rockwell International, re:  Interest in
     participating in RI/FS, 11/15/89.  P. 200725-200725.

128. Letter to Mr. David G. Byro, U.S. EPA,  from Mr. Robert
     K. Beck,  Rockwell International, re:  Good Faith
     proposal to perform the RI/FS, 12/21/89.  P. 200726-
     2Q0729.
     •j
129. Letter to Mr. James Snyder, PADER, from Mr. Stephen
     R. Wassersug, U.S.  EPA, re:  Administrative Order by
     Consent,  5/17/90.  P. 200730-200758.  The
     Administrative Order by Consent is attached.

                           15

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 130. Administrative  Order  by  Consent  In The Matter Of:
     Recticon/Allied Steel Site,  5/29/90.   P.  200759-200783.
     Appendix A,  RI/FS  Scope  of Work,  Recticon/Allied Steel
     Site,  is attached.

 131. Handwritten  notes  on  Recticon Hazardous Waste
     Manifests,  (undated).  P.  200784-200785.

 132. Handwritten  Table  1,  Groundwater  Pumping,  (undated).
     P.  200786-200792.  The following  are attached:

          a)    Figure 1, TCE  Concentration  Levels  -  No.  1
                well;

          b)    Figure 2, 1,2,  Dichloroethene Concentration
                Levels;

          c)    Figure 3, TCE  Sample Locations  -  Feb.  1982,
                Parkerford  Area;

          d)    Table  2, Parkerford Sample Locations;

          e)    Figure 4, TCE  Sample Locations  -  1979/1980,
                Parkerford  Area;

          f)    Table 3, Sample list.

133. Handwritten Recticon  Well information,  (undated).
     P. 200793-200793.

134. Recticon Implementation  Schedule  for Effluent Treatment
     Facilities,  (undated).   P. 200794-200795.

135. Hand-drawn Recticon (existing) Plan map,  (undated).
     P. 200796-200796.

136. Hand-drawn Recticon (proposed) Plan, (undated).
     P. 200797-200797.

137. Handwritten Insert A,  Phase I work initiation,
     (undated).   P. 200798-200798.

138. Hand-drawn map of TCE levels, (undated).  P.  200799-
     200799.
                           16

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 Updated Material

 Allied  Steel

      139.  Letter to Mr.  John Van  Dzura,  Allied Steel Products
           Corp.,  from Mr.  Peter W.  Schaul,  U.S.  EPA,  re:   104(e)
           request for information,  11/2/90.   P.  200800-200805.

      140.  Letter to Mr.  John Van  Dzura,  Allied Steel  Products
           Corp.,  from Mr.  Peter W.  Schaul,  U.S.  EPA,  re:   Request
           for  information,  1/7/91.  P. 200806-200807.

      141./.-Letter to Mr.  Irving Hirsch, Allied  Steel,  from Mr.
           Harry  R.  Steinmetz, U.S.  EPA,  re:  Mr. Van  Dzura's
           failure to respond to 104(e) letters,  4/30/91.
           P. 200808-200808.

      142.  Letter  to Mr.  Irving Hirsch, Allied  Steel,  from Ms.
           Mary E.  Rugala, U.S. EPA, re:  Confirmation of
           telephone conversation  regarding Mr. Van Dzura,
           5/15/91.   P. 200809-200809.

Hiahview Gardens

     143. Letter  to Ms. Mary Rugala, U.S. EPA, from Mr. David C.
          Noker,  Hamburg, Rubin,  Mullin & Maxwell, re:  Addition
          to building on site, 4/16/91.  P. 200810-200810.
                               17

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III.  REMEDIAL RESPONSE PLANNING

     1.    Report:   Preliminary Health Assessment for
          Recticon/Allied Steel Corporation,  prepared by the
          Agency for Toxic Substances and Disease Registry
          (ATSDR),  1/22/90.   P. 300001-300010.

     2.    Memorandum to Mr.  Charles J.  Walters,  Department of
          Health and Human Services,  from Ms. Lynn C.  Wilder,
          Department of Health and Human Services,  re:   Addendum
          to Health Assessment, 3/2/90.   P.  300011-300015.   The
          addendum  is attached.

     3.    Report:   Remedial  Investigation/Feasibility Study Work
          Plan.  Recticon/Allied Steel Superfund  Site.  Parker
          Ford.  Pennsylvania,  prepared by Dames  & Moore,  12/3/90.
          P.  300016-300457.

     4.    Letter to Mr.  David G.  Byro,  U.S.  EPA,  from Mr.  Michael
          Edelman,  Dames & Moore,  re:   Monthly progress  report   ".
          for the remedial investigation,  1/3/91.   P.  300458-
          300459.

     5.    Letter to Mr.  Bruce  Rundell,  U.S.  EPA,  from Mr.  Michael
          Edelman and Ms.  Rosann  Park-Jones, Dames  & Moore,  re:
          Preliminary TCE  Soil Gas Survey results,  1/31/91.
          P.  300460-300462.  Two  maps are attached.

     6.    Letter to Mr.  David  G.  Byro,  U.S.  EPA,  from Mr.  Michael
          Edelman,  Dames & Moore,  re:   Remedial  Investigation
          monthly progress report,  2/6/91.   P. 300463-300465.
          Table  1,  Recticon/Allied Steel  Remedial  Investigation
          Field  Schedule,  is attached.

     7.    Letter to Mr.  Michael B.  Whaley, Rockwell  International
          Corporation,  from Mr. David G.  Byro, U.S.  EPA, re:
          Revision  to  PADER's  Applicable  or Relevant  and
          Appropriate  Requirements  (ARARs), 2/28/91.   P. 300466-
          300473.   Three letters  regarding PADER ARARs are
          attached.

     8.    Letter to Mr.  David  G.  Byro, U.S. EPA, from Mr. Michael
          Edelman,  Dames & Moore,  re:  Monthly progress report
          for the remedial investigation, 3/8/91.  P.  300474-
          300476.   Table 1, Recticon/Allied Steel Remedial
          Investigation  Field  Schedule, is attached.
                               18

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9.   Letter  to Mr. Michael Edelman, Dames & Moore, from
     Mr. David G. Byro, U.S. EPA, re:  Transmittal of
     correspondence, 3/19/91.  P. 300477-300500.  Four
     letters regarding Applicable or Relevant and
     Appropriate Requirements  (ARARs) and PADER's ARARs
     are attached.

10.  Letter  to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Monthly progress report
     for the remedial investigation, 4/22/91.  P. 300501-
     300503.  Table 1, Recticon/Allied Steel Remedial
     Investigation Field Schedule, is attached.

11.  Letter  to Mr. David Byro, U.S. EPA, from Mr. Ralph T.
     Golia and Mr. Michael Edelman, Dames & Moore, re:
     PADER ARARs, 5/1/91.  P. 300504-300505.

12.  Letter  to Mr. David Byro, U.S. EPA, from Mr. Bruce
     Beach,  Dynamac Corp., re:  Analytical results report,
     5/1/91.  P. 300506-300524.  The report is attached.

13.  Letter  to Mr. David Byro, U.S. EPA, from Mr. Michael J
     Edelman, Dames & Moore, re:  Disposal of monitoring
     well purge and development water, 5/9/91.  P. 300525-
     300525.

14.  Letter  to Mr. David Byro, U.S. EPA, from Mr. David J.
     Carlson, Dames & Moore, re:  Quality assurance audit,
     5/10/91.  P. 300526-300527.

15.  Letter  to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Monthly progress report
     for the remedial investigation, 5/28/91.  P. 300528-
     300530.  Table 1, Recticon/Allied Steel Remedial
     Investigation Field Schedule, is attached.

16.  Memorandum to Mr. David Byro, U.S.  EPA, from Ms.
     Theresa A. Simpson,  U.S. EPA, re:  Correction to
     inorganic data validation report, 5/30/91.  P. 300531-
     300553.  A memorandum regarding the Region III Data
     Quality Assurance (QA) Review and the inorganic data
     review  are attached.

17.  Letter  to Mr. David G. Byro, U.S. EPA, from Mr. M.B.
     Whaley, Rockwell International, re;  Replacement
     project manager, 6/3/91.  P. 300554-300554.

18.  Letter  to Mr. Phil Edmunds, U.S. Fish and Wildlife
     Service, from Mr. David G. Byro, U.S. EPA, re:
     Endangered or threatened species in the study area,
     6/4/91.  P. 300555-300556.
                           19

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 19.  .Letter to Mr. David Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Transmittal of data
     summary tables and quality assurance review reports,
     6/4/91.  P. 300557-300609.  The reports are attached.

 20.  Letter to Mr. David Byro, U.S. EPA, from Mr. Ralph T.
     Golia and Mr. Michael Edelman, Dames & Moore, re;
     Transmittal of ground water sampling analytical
     results, 6/18/91.  P. 300610-300630.  The inorganic
     analysis - analytical results are attached.

 21.  Letter to Mr. David G. Byro, U.S. EPA, from Ms. Cynthia
     L. Rice, U.S. Fish and Wildlife Service, re:
     Endangered or threatened species, 6/20/91.  P. 300631-
     300633.  A Federal list of endangered and threatened
     species in Pennsylvania is attached.

 22.  Letter to Mr. David Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Ground water monitoring,
     7/10/91.  P. 300634-300634.

 23.  Letter to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Progress report for June
     1991, 8/8/91.  P. 300635-300637.  Table 1, Field
     Schedule, is attached.

 24.  Letter to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Progress report for May
     1991, 8/8/91.  P. 300638-300639.

25.  Letter to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames & Moore, re:  Progress report for July
     1991, 8/19/91.  P.  300640-300656.  Table 1, Field
     Schedule, Attachment A, Purge and Development Water
     Disposal Documentation, and Attachment B,  Analytical
     Data for the Second Ground Water Sampling Round (July
     1991),  are attached.

26.  Letter to Dr. Richard Reisenweber,  Rockwell
     International Corporation, from Mr. David G. Byro,  U.S.
     EPA,  re:  Transmittal of letters concerning the
     presence of endangered or threatened species within the
     area affected by the site, 8/30/91.  P. 300657-300664.
     The following are attached:

          a)    a letter from the U.S. Fish and Wildlife
      «        Services regarding a request for information
      ''••'        concerning the presence of endangered and
               threatened species near the site;

          b)    a list of Federally Listed Endangered and
               Threatened Species In Pennsylvania;

                           20

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           c)    a  letter 'from PADER  regarding  a  request  for
                information concerning  the  presence  of
                endangered and threatened species  near the
                site;

           d)    a  Pennsylvania Natural  Diversity Inventory
                Species List.

27.  Memorandum to Mr. David Byro,  U.S. EPA,  from Mr.
     Frederick  Dreisch, U.S. EPA, re:  Transmittal  of the
     Volatile Organic Analysis  (VOA) report,  9/3/91.
     P. 300665-300676.  The following  are  attached:

           a)    the VOA report;
           b)    Appendix A, Glossary of Data Qualifier Codes;
           c)    Appendix B, Data Summary;
           d)    a  Chain of Custody Record.

28.  Letter to  Mr. David G. Byro, U.S. EPA, from  Mr. Michael
     Edelman, Dames & Moore, re:  Progress report for August
     1991, 9/10/91.  P. 300677-300686.  Attachment  A,
     Aquifer Test Procedures, and Attachment  B, Ground Water,
     Elevation  Data for the First Ground Water  Sampling
     Round (April 1991), are attached.

29.  Memorandum to Mr. David Byro, U.S. EPA,  from Mr.
     Frederick  Dreisch, U.S. EPA, re:  Transmittal  of the
     revised metals report, 10/18/91.  P.  300687-300712.
     The following are attached:

           a)     the revised metals report;

           b)     a memorandum regarding  a report  to make
                laboratory information  easier  to understand;

           c)     a Metals and Inorganic  Nominal Quantitation
                Limits and Test Names listing;

          d)     sample results;

          e)     a listing of qualifier  codes.

30.  Letter to  Ms. Debbie Whitehawk, East  Coventry Township,
     from Mr. David G. Byro, U.S. EPA, re:  Evaluation of
     soil  samples, 10/21/91.  P. 300713-300714.

31.  R'sport:   Phase I Remedial Investigation  Draft Report.
     Recticon/Allied Steel Site. Parker Ford. Pennsylvania.
     Volume i of 3. prepared by Dames  & Moore,  1/2/92.
     P. 300715-300970.  A cover letter is  attached.
                           21

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32.  Report:  Phase  I'Remedial Investigation Draft Report.
     Recticon/Allled Steel Site. Parker Ford. Pennsylvania.
     Volume 2 of 3,  prepared by Dames & Moore, 1/2/92.
     P. 300971-301408.

33.  Report:  Phase  I Remedial Investigation Draft Report.
     Recticon/Allied Steel Site. Parker Ford. Pennsylvania,
     Volume 3 of 3.  prepared by Dames & Moore, 1/2/92.
     P. 301409-301772.

34.  Letter to Mr. David G. Byro, U.S. EPA, from Mr. Michael
     Edelman, Dames  & Moore, re:  Progress report for
     October 1991, 1/2/92.  P. 301773-301781.  A letter
     regarding the progress report for November 1991 dated
     January 1, 1992, a letter regarding the progress report
     for October 1991 dated November 11, 1991, and Table 1,
     Field Schedule, are attached.

35.  Memorandum to Mr. David Byro, U.S. EPA, from Mr.
     Theresa A. Simpson, U.S. EPA, re:  Transmittal of the  -
     organic data review, 1/13/92.  P. 301782-301788.  The
     organic data validation, and Appendix A:  Glossary of
     Data Qualifier  Codes, and Appendix B:  Data Summary
     Forms are attached.

36.  Letter to Mr. David G. Byro, U.S. EPA, from Mr. Ralph
     T. Golia and Mr. Michael Edelman, Dames & Moore, re:
     Suggestion that Rockwell International consider *
     installing an interim ground water containment system
     at the site,  1/31/92.  P. 301789-301790.

37.  Letter to Dr. Richard Reisenweber, Rockwell
     International Corporation, from Mr. David G. Byro, U.S.
     EPA,  re:  Review and transmittal of comments concerning
     the Phase I Remedial Investigation Draft Report,
     2/7/92.  P. 301791-301814.  The following are attached:

          a)   the review comments on the RI;

          b)   Table 1,  GAC Lifetime Predictions (Revised)
               for the Six Units Considered by Dames &
               Moore;

          c)   five site maps;

          d)   a letter regarding PADER's comments on the
     ',,        draft RI ;

          e)   two certified mail receipts.
                           22

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 38.  Letter  to  Mr. David G. Byro, U.S. EPA,  from Mr. Michael
     Edelman, Dames  & Moore, re:  Progress report  for
     January 1991, 3/31/92.  P. 301815-301818.  A  letter
     regarding  the progress report for February 1992 is
     attached.

 39.  Letter  to  Mr. David G. Byro, U.S. EPA,  from Mr. Ralph
     T. Golia and Mr. Michael J. Edelman, Dames &  Moore, re:
     Submittal  of the third revision of the  Phase  II Work
     Plan, 5/12/92.  P. 301819-301829.  The  revised Work
     Plan  is attached.

 40.  -Letter  to  Dr. Richard Reisenweber, Rockwell
     'International Corporation, from Mr. David G.  Byro, U.S.
     EPA,  re:   Review of the revised Phase II Work Plan,
     5/13/92.   P. 301830-301833.  A certified mail receipt
     is attached.

 41.  Letter  to  Mr. Michael B. Whaley, Rockwell International
     Corporation, from Mr. David G. Byro, U.S. EPA, re:
     Project team members comments to the RI/FS Work Plan
     dated June 17,  1990, 8/3/90.  P. 301834-301847.  The
     comments are attached.

 42.  Letter  to  Dr. Richard Reisenweber, Rockwell
     International Corporation, from Mr. David G.  Byro, U.S.
     EPA,  re:   Comments on the revised Phase II Work Plan,
     Revision 1, 4/3/92.  P. 301848-301852.  The comments
     and two certified mail receipts are attached.

 43.  Letter  to  Dr. Richard Reisenweber, Rockwell
     International Corporation, from Mr. David G. Byro, U.S.
     EPA,  re:   Comments on the revised Phase II Work Plan,
     Revision 2, 4/20/92.  P. 301853-301860.   A letter
     regarding  the proposed on-site disposal of contaminated
     ground  water, a letter containing comments on the Phase
     I Work  Plan, and two certified mail receipts are
     attached.

44.  Letter  to  Dr. Richard Reisenweber, Rockwell
     International Corporation, from Mr. David G. Byro, U.S.
     EPA,  re:   Comments on the Evaluation of VOC
     Concentrations  in Soil at the Recticon/Allied Steel
     Site  report, 6/19/92.  P. 301861-301867.  The comments
     and two certified mail receipts are attached.

45.  Letter  to  Mr. David G. Byro,  U.S. EPA,  from Mr. Michael
     Edelman, Dames  & Moore, re:  Remedial Investigation
     Progress Report for March 1992,  7/2/92.   P. 301868-
     301885.  The following are attached:
                           23

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           a)    Remedial  Investigation Progress Report for
                April  1992;

           b)    Remedial  Investigation Progress Report for
                May 1992;

           c)    a  letter  regarding  the submittal of  the
                revised Phase  II Work  Plan;

           d)    the revised  Phase II Work  Plan;

           e)    Table  6-1, Summary  of  Phase  II  Scope of Work;

           f)    Figure 6-1,  Proposed Phase II  "Deep"
                Monitoring Well Locations;

           g)    Figure 6-2,  Project Schedule,  Phase  II
                Investigation.

46.  Letter to  Dr.  Richard  Reisenweber, Rockwell
     International  Corporation, from  Mr.  David G. Byro,  U.S."
     EPA,  re:   Well Schedule, 7/7/92.  P. 301886-301892.
     Two Well Schedules, Figure 5, Ground Water Well
     Location Map,  and two  certified  mail receipts  are
     attached.

47.  Letter to  Mr.  David G. Byro, U.S. EPA, from Mr.  Charles
     R. Wood, United  States Department of the  Interior,  re:
     Information on the geophysical logs, 7/13/92.
     P. 301893-301894.

48.  Letter to  Mr.  John Van Dzura,  Jr., Allied  Steel
     Products Corporation,  from Mr. David G. Byro,  U.S. EPA,
     re:  Notification of EPA's plan  to begin implementing
     the characterization and/or modification of existing
     pumping wells, 8/31/92.  P. 301895-301898.  Two
     certified mail receipts are attached.

49.  Letter to Mr.  David G. Byro, U.S. EPA,  from Mr. Michael
     Edelman, Dames & Moore, re:  Remedial Investigation
     Progress Report  for June 1992, 9/4/92.   P. 301899-
     301900.

50.  Letter to Mr. David G. Byro, U.S. EPA,  from Mr. Michael
     Edelman, Dames & Moore, re:  Remedial Investigation
     Progress Report  for July 1992, 9/4/92=   P. 301901-
     ,301902.

51.  Letter to Mr. David G. Byro, U.S. EPA,  from Mr. Michael
     Edelman, Dames & Moore, re:  Remedial Investigation
     Progress Report  for August 1992,  9/4/92.   P. 301903-
     301904.

                           24

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52.  Letter to Mr. David Byro, U.S. EPA, from Mr. Kevin J.
     Hess, PADER, re:  Review of the June 5, 1992 Work Plan
     for temporary discharge, 9/10/92.  P. 301905-301907.
     A memorandum regarding temporary discharge is attached.

53.  Letter to Mr. David Byro, U.S. EPA, from Mr. Anthony
     Vellios, Dynamac Corporation, re:  Split sampling
     results for the four ground water sampling rounds of
     Phase I of the Remedial Investigation, 10/28/92.
     P. 301908-301914.  The split sampling results are
     attached.

54. --Letter to Mr. David G. Byro, U.S. EPA, from Mr. Ralph
     T. Golia and Mr. Michael J. Edelman,  Dames & Moore, re:
     The results of the step-test portior of the aquifer
     test for the Phase II investigation  10/29/92.
     P. 301915-301915.

55.  Letter to Mr. Kevin Hess, PADER,  from Mr. David G.
     Byro, U.S. EPA, re:  Request for identification of the.
     potential chemical-,  location-,  and action-specific
     state ARARs for the site, 12/7/92.  P. 301916-301917.

56.  Letter to Dr. Richard Reisenweber, Rockwell
     International Corporation,  from Mr. David G. Byro, U.S.
     EPA,  re:  Comments on the draft Phase I Feasibility
     Study Interim Report dated December 4, 1992, 12/23/92.
     P. 301918-301924.  The comments and two certified mail
     receipts are attached.

57.  Memorandum to Mr. Don Henne, Office of Environmental
     Affairs, Mr.  Peter Knight,  U.S.  EPA,  Mr. Anthony R.
     Conte,  USDI,  and Ms.  Kirsten L.  Erickson, NOAA General
     Counsel's Office, from Mr.  David G. Byro, U.S. EPA, re:
     Notification of Federal Natural Resource Trustees,
     1/13/93.  P.  301925-301925.

58.  Letter to Mr. Kevin Hess, PADER,  from Mr. David G.
     Byro, U.S. EPA, re:  Reiteration of request that PADER
     identify the potential chemical-, location-, and
     action-specific state ARARs for the site, 2/8/93.
     P. 301926-301927.

59.  Letter to Dr. Richard Reisenweber, Rockwell
     International Corporation,  from Mr. David G. Byro, U.S.
     EPA,  re:  EPA's and PADER's review comments on the
     November 25,  1992 Phase I and Phase II Remedial
     investigation Draft Report, 2/12/93.   P. 301928-301941.
     The comments are attached.
                           25

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 60.   Letter  to Dr.  Richard  Reisenweber, Rockwell
      International  Corporation,  from Mr. David G. Byro,  U.S.
      EPA,  re:  EPA's  and PADER's review comments on  the
      January 8,  1993  draft  Feasibility Study Report,  3/8/93.
      P.  301942-301960.   The comments and a  certified mail
      receipts are attached.

 61.   Report:  Phase I and Phase  II Remedial  Investigation
      Final Report.  Recticon/Allied Steel Site. Parker Ford.
      Pennsylvania.  Volume 1 of 4. prepared by Dames  & Moore,
      3/29/93.  P. 301961-302296.

 62.   Report:  Phase I and Phase  II Remedial  Investigation
      Final Report.  Recticon/Allied Steel Site. Parker Ford.
      Pennsylvania.  Volume 2  of 4. prepared by Dames  & Moore,
      3/29/93.  P. 302297-302763.

 63.   Report:  Phase I and Phase  II Remedial  Investigation
      Final Report.  Recticon/Allied Steel Site. Parker Ford.
      Pennsylvania.  Volume 3  of 4. prepared by Dames  & Moorefc
      3/29/93.  P. 302764-303156.
                                                           •*-.
 64.   Report:  Phase I and Phase  II Remedial  Investigation
      Final Report.  Recticon/Allied Steel Site. Parker Ford.
      Pennsylvania.  Volume 4  of 4. prepared by Dames  & Moore,
      3/29/93.  P. 303157-303938.

 65.   Report:  Phase I and Phase  II Remedial  Investigation
      Final Report.  Recticon/Allied Steel Site. Parker Ford.
      Pennsylvania. Appendix  W. prepared by Dames & Moore,
      3/29/93.  P. 303939-304242.

66.   Letter to Mr. David  Byro, U.S. EPA, from Mr. Kevin J.
      Hess, PADER, re:  ARAR  identification,  4/9/93.
      P. 304243-304245.

67.  Report:   Draft Feasibility  Study.  Recticon/Allied Steel
      Site. Parker Ford.  Pennsylvania,  prepared by Dames &
     Moore, 4/14/93.  P.   304246-304551.

68.  Letter to Mr. David  Byro, U.S. EPA, from Mr. Kevin J.
     Hess, PADER, re:  Comments  on draft Proposed Plan,
      5/7/93.   P.  304552-304553.

69.  Letter to Mr. David  G.  Byro, U.S.  EPA,  from Mr.
     Richard L.  Zambito,   Dames & Moore, re:   Corrected pages
     ^fgr the draft Feasibility Study,  5/12/93.  P. 304553a-
      3d4560.   The revised pages  (8-11,  8-22,  8-28, 8-32,
      8-33, 8-37,  and 8-38) are attached.
                           26

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70.  Letter  to  Ms. Mary Rugala, U.S. EPA, from Mr. Richard
     L. Zambito,  Dames & Moore, re:  Comparative Analysis of
     Alternatives, 5/14/93.  P. 304561-304572.  The
     Comparative  Analysis of Alternatives and a revised
     Table of Contents are attached.

71.  Letter  to  Mr. David Byro, U.S. EPA, from Mr. David A.
     Sherwin, Dames & Moore, re:  Revisions to pages 4-22
     and 5-7 of the Baseline Risk Assessment, 5/14/93.
     P. 304573-304581.  The revisions are attached.

72.  Letter  to  Dr. Richard Reisenweber, Rockwell
    ;, International Corporation, from Mr. David G. Byro, U.S.
     EPA, re:   Approval of the RI/FS Reports and comments on
     their review, 5/19/93.  P. 304582-304583.

73.  Proposed Plan, Recticon/Allied Steel Site,  Parker Ford,
     Chester County, PA, May 1993.  P. 304584-304600.

74.  Letter to  Mr. David Leinbach, East Coventry Township,"-
     from Mr. David G. Byro, U.S. EPA, re:  Documentation of
     telephone  conversation on June 2, 1993 concerning
     information  on the proposed remedial action for the
     site,  6/3/93.  P. 304601-304601.

75.  Letter to  Mr. David G. Byro, U.S. EPA, from Mr. Jerome
     C. Muys, Jr., Swidler & Berlin, re:  Comments on the
     Proposed Remedial Action Plan, 6/17/93.  P. 304602-
     304605.

76.  Report:  The Potential for Biological Effects of
     Sediment-Sorbed Contaminants Tested in the National
     Status and Trends Program, prepared by National Oceanic
     and Atmospheric Administration, (undated).   P. 304606-
     304634.
                           27

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IV.   REMOVAL -RESPONSE PROJECTS

     1.   Letter to Mr. Philip C.  Younis,  U.S. EPA, from Ms.
          Deborah Kopsick,  Ecology and Environment, Inc, re:
          Trip report for residential well sampling,  4/15/90.
          P. 400001-400052.   The report is attached.

     2.   Report:   Work Plan Removal Action Recticon/Allied Steel
          Site,  prepared by Dames  and Moore,  5/23/90.   P.  400053-
          400085.

     3.   Report:   Analytical Results Report:   Water  Supply
   •'      Sampling Survey.  Removal Action.  Recticon/Allied Steel
          Site,  prepared by Dames  & Moore,  10/29/90.   P. 400086-
          400158.   A transmittal letter is attached.

     4.    Report:   Analytical Results Report:   Water  Supply
          Sampling Survey.  Removal Action.  Recticon/Allied Steel
          Site,  prepared by Dames  & Moore,  3/29/91.  P.  400159-
          400312.   A transmittal letter is attached.
                               28

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V.    COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
     1.   Press Release from the U.S.  EPA Environmental News
          entitled,  "Rockwell International Corporation and EPA
          Sign Consent Order for Removal Activities at the
          Recticon/Allied Steel Superfund Site,"  5/14/90.
          P.  500001-500003.

     2.   U.S. EPA Fact Sheet:   Recticon/Allied Steel Corporation
          Superfund Site,  8/90.   P.  500004-500009.

     3.  .'Letter to Mr. William & Mrs.  Mildred Overfield from Mr.
          David G.  Byro,  U.S. EPA,  re:   Transmittal of well
          sampling results,  9/19/90.   P.  500010-500014.  An EPA
          drinking water fact sheet  on Trichloroethylene,  an
          analytical report  on volatile organics  analysis,  and a
          lab report on water samples  are attached.

     4.   Letter to Mr. Herbert Landis  and Mr.  Paul LeDerer,
          Leisure Equipment,  Inc.,  from Mr.  David G.  Byro,  U.S.
          EPA,  re:   Transmittal of well sampling  results,
          9/19/90.   P.  500015-500023.   Sampling results and EPA
          drinking water fact sheets on Trichloroethylene,  CIS-
          1,2-Dichloroethylene,  and  1,1,1,  Trichloroethane are
          attached.

     5.   Letter to Mrs.  Esther Hetrick from Mr.  David G.  Byro,
          U.S.  EPA,  re:  Transmittal of well sampling results,
          9/19/90.   P.  500024-500026.   The sampling results are
          attached.

     6.   Letter to  Mr. Joseph  and Mrs.  Rose Gelete from Mr.
          DaVid G.  Byro,  U.S. EPA, re:   Transmittal of well
          sampling  results,  9/19/90.   P.  500027-500031.  Sampling
          results and an EPA drinking water fact  sheet on 1,1,1-
          Trichloroethane are attached.

     7.   Letter to  Mr. Karl  LeDerer from Mr.  David G.  Byro,  U.S.
          EPA,  re:   Transmittal  of well sampling  results,
          9/19/90.   P.  500032-500036.   Sampling results and an
          EPA drinking water fact sheet on Trichloroethylene are
          attached.

     8.   Letter to  Mr. Tony Deluea, Autoquest, from Mr.  David G.
          Byro,  U.S. EPA,  re:  Transmittal of well  sampling
          results,  9/19/90.   P.  500037-500043.  Sampling results
          and EPA drinking water fact  sheets on Trans-1,2-
          Dichloroethylene and  Trichloroethylene  are attached.
                               29

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 9.    Letter to Mr.  Wilbert  and Mrs.  Ruth Letter from Mr.
      David G.  Byro,  re:   Transmittal of  well  sampling
      results,  9/19/90.   P.  500044-500046.   Sampling results
      are attached.

 10.   Letter to Mr.  Adam  and Mrs. Mary DeFrancesco,  Keystone
      Auto Center,  Inc.,  from Mr. David G.  Byro,  U.S.  EPA,
      re:   Transmittal of well sampling results,  9/19/90.
      P.  500047-500053.

 11.   Letter to Mr.  Robert Elliot from Mr.  David G.  Byro,
      U.S.  EPA,  re:   Transmittal of well  sampling results,
      9/19/90.   P. 500054-500056.

 12.   Letter to Mr.  John  and Mrs. Dorothy Weaver from Mr.
      David G.  Byro,  U.S.  EPA,  re:  Transmittal  of well
      sampling  results, 9/19/90.  P.  500057-500059.
      Sampling  results are attached.

 13.   Letter to Mr. Thomas and Mrs. Marian  Orosz  from Mr.    -
      David G.  Byro,  U.S..EPA,  re:  Transmittal  of well
      sampling  results, 9/19/90.  P.  500060-500064.   Sampling-..
      results and an  EPA  drinking water fact sheet on 1,1,1-
      Trichloroethane are  attached.

 14.   Letter to  Mr. Tom Lewis,  Sr., Total Recovery,  Inc.,
      from  Mr.  David  G. Byro,  U.S. EPA, re:  Transmittal of
     well  sampling results,  9/19/90.  P. 500065-500071.
      Sampling  results and EPA drinking water  fact sheets on
     Trichloroeteylene and  CIS-1,2,-Dichloroeteylene  are
     attached.

15.  Letter to Mr. Richard  Heylmun, Longstreth Company, from
     Mr. David G. Byro,  U.S.  EPA, re:  Transmittal of well
     sampling results, 9/19/90.  P. 500072-500074.   Sampling
     results are attached.

16.  Letter to Mrs.  Edith Northacker from Mr. David G. Byro,
     U.S. EPA, re:   Transmittal of well sampling results,
     9/19/90.  P. 500075-500077.  Sampling results are
     attached.

17.  Report:  Community Relations Plan for the Recticon/
     Allied Steel Corporation Site, prepared bv Dynamac
     Corporation, 12/12/90.   P. 500078-500107."

18.  U-S. EPA Fact Sheet, Recticon/Allied Steel Corporation
     Superfund Site, 1/91.  P. 500108-500109.

19.  Newspaper article entitled "Superfund Site in Parker
     Ford to be studied," The Reporter. 1/2/91.  P.  500110-
     500110.

                          30

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20.  U.S. EPA-Attendance Sheet, Recticon/Allied Steel
     Corporation, 1/9/91.  P. 500111-500113.

21.  Newspaper article entitled "EPA to hold meeting on
     Superfund site," The Mercury. 1/9/91.  P. 500114-
     500114.

22.  Newspaper article entitled "EPA expects to find tainted
     water," The Mercury. 1/10/91.  P. 500115-500115.

23.  Newspaper article entitled "Tests to pinpoint Recticon
    •/contamination," The Philadelphia Inquirer. 1/13/91.
     P. 500116-500116.

24.  Newspaper article entitled "Testing begins at Parker
     Ford Superfund site," The Reporter. 1/16/91.
     P. 500117-500117.

25.  U.S. EPA Meeting Agenda, Public Meeting, Recticon/
     Allied Steel Superfund Site,  (undated).  P.  500118-
     500118.

26.  Letter to Mr. Palmer and Mrs. Juanita Williamson from
     Mr. David G. Byro, U.S. EPA,  re:   Transmittal of well
     sampling results, (undated).   P.  500119-500121.
     Sampling results are attached.

27.  Report:  Community Relations Plan for the Recticon/
     Allied Steel Corporation Site,  prepared by Dynamac
     Corporation and PRC Environmental Management, Inc.,
     10/30/91.  P. 500122-500150.

28.  U.S. EPA Fact Sheet, Recticon/Allied Steel Corporation
     Superfund Site, Remedial Investigation and Feasibility
     Study,  Parkerford [sic], Pennsylvania, 8/90.
     P. 500151-500154.

29.  U.S. EPA Superfund Fact Sheet,  Recticon/Allied Steel
     Corporation Site, 5/92.  P.  500155-500156.

30.  U.S. EPA Public Notice entitled "The United States
     Environmental Protection Agency Invites the Public to
     Comment on the Proposed Plan for Cleanup of the
     Recticon/Allied Steel Superfund Site, Parker Ford,
     Chester County, PA," Mercury. 5/20/93.  P. 500157-
     500158.  A transmittal letter is  attached.
       »
31.  Transcript of public meeting, Recticon/Allied Steel
     Site,  5/27/93.   P. 500159-500233.
                           31

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    BIBLIOGRAPHY OF SITE SPECIFIC GUIDANCE DOCUMENTS
 1.    Guidance  for Conducting  Remedial  Investigations  and
      Feasibility Studies  Under  CERCIA. prepared  by
      OSWER/OERR,  10/1/88.
      OSWER  9355.3-01

 2.    Superfund Remedial Design  and Remedial Action Guidance.
      prepared  by OERR, 6/1/86.
      OSWER  9355.0-4A

 3.    The  Feasibility  Study  -  Development and  Screening  of
      Remedial  Action  Alternatives  [Quick Reference Fact
      Sheet!. prepared by  OSWER, 11/1/89.
      OSWER  9355.3-01FS3

 4.    The  Feasibility  Study.   Detailed Analysis of  Remedial
      Action Alternatives  [Quick Reference Fact Sheet!.
      prepared  by  OSWER, 3/1/90.
      OSWER  9355.3-01FS4

 5.    A Compendium of  Superfund  Field Operations  Methods.
      prepared  by  OERR/OWPE, 12/1/87.
      OSWER  9355.0-14  .

 6.    Superfund LDR Guide  #5.  Determining When Land Disposal
      Restrictions  (LDRs)  are  Applicable to CERCIA  Response
      Actions,  prepared by OERR, 7/1/89.
      OSWER  9347.3-05FS

7.    A Guide on Remedial Actions for Contaminated  Ground
     Water  [Quick Reference Fact Sheet!. prepared  by OSWER,
     4/1/89.
     OSWER  9283.1-2FS

8.    Guidance  on Remedial Actions for Contaminated Ground
     Water at  Superfund Sites, prepared by OERR,  12/1/88.
     OSWER  9283.1-2

9.    CERCIA Compliance With Other Laws Manual (Draft).
     prepared  by OERR, 8/8/88.
     OSWER #9234.1-01

10.   CERCIA Compliance with Other Laws Manual -  CERCIA
     Cpmoliance with State Requirements fOuick Reference
     FApt Sheet! . prepared by OSWER,  12/1/89.
     OSWER 9234.2-05FS
                           32

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11.   Interim Guidance on Potentially Responsible Party
     Participation in Remedial Investigations and
     Feasibility Studies,  prepared by J.W.  Porter/OSWER,
     5/16/88.
     OSWER 9835.13
                          33

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