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.
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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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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.
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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
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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.
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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
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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.
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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).
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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
-------
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
-------
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
-------
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
-------
DIMES* MOORE
SITE LAYOUT
Ptrtmfvi.
MWKM1M3
tW»l2»4CB 8JR W2W IAWJUT
-------
t
i
t^
u
DAMES* MOORE
SOIL BORING LOCATIONS
IMMCMtfO
-------
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
-------
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
-------
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
-------
APPENDIX B TABLES
-------
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.
-------
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
-------
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
-------
APPENDIX C RESPONSIVENESS SUMMARY
-------
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:
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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:
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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
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