EPA  Superfund
       Record of Decision:
                                 PB96-963903
                                 EPA/ROD/R03-96/219
                                 June 1996
       Tyler Refrigeration Pit,
       Smyrna, DE
       5/10/1996

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      Tyler Refrigeration Pit Site
         Smyrna, Delaware
  RECORD OF DECISION


           PREPARED BY
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
            MAY 1996

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                         TABLE  OF CONTENTS

                       PART I - DECLARATION

1.  SITE NAME AND  LOCATION	1

2.  STATEMENT OF BASIS AND  PURPOSE   	  1

3.  DESCRIPTION OF THE SELECTED  REMEDY   	  1

4.  DECLARATION STATEMENT	1


                    PART II - DECISION SUMMARY

1.  SITE NAME, LOCATION, AND DESCRIPTION   	  2

2.  SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  2

3.  HIGHLIGHTS OF  COMMUNITY PARTICIPATION 	  	  4

4 .  SCOPE AND ROLE OF THE RESPONSE ACTION	5

5.  SUMMARY OF SITE CHARACTERISTICS	5

6.  NATURE AND EXTENT OF CONTAMINATION  	  6

7.  SUMMARY OF SITE RISKS   	8

       7.1.  Human Health Risk Assessment  	  8
       7.2.  Ecological Risk Assessment	15

8.  DESCRIPTION OF THE SELECTED REMEDY	15

9.  DOCUMENTATION OF NO SIGNIFICANT CHANGE	16


                PART III - RESPONSIVENESS SUMMARY

1.  SUMMARY OF WRITTEN COMMENTS RECEIVED DURING THE PUBLIC
    COMMENT PERIOD  	  17

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                          LIST OF TABLES

Table 1   -      STATISTICAL ANALYSIS OF GW DATA  FOR  COCs  ...   10

Table 2   -      EXPOSURE ASSESSMENT PARAMETERS	11

Table 3   -      TOXICITY CRITERIA & CARCINOGENIC WEIGHT OF
                EVIDENCE	12

Table 4   -      CUMULATIVE RISKS TO CHILD RESIDENT	14

Table 5   -      CUMULATIVE RISKS TO ADULT RESIDENT	14

Table 6   -      COMBINED RISKS TO CHILD & ADULT  RESIDENT  ...   15


                         LIST OF FIGURES

Figure 1  -  SITE LOCATION MAP	20

Figure 2  -  SITE PLAN	21

Figure 3  -  GROUND WATER MANAGEMENT ZONES   	   22

Figure 4  -  SURFACE SOIL SAMPLE LOCATIONS   	   23

Figure 5  -  SUBSURFACE SOIL SAMPLE LOCATIONS 	   24

Figure 6  -  MONITORING WELL LOCATIONS	25

Figure 7  -  LOCATION OF SOURCE AREAS
             DNREC REMEDIAL INVESTIGATION	26

Figure 8  -  SOIL RESULTS
             DNREC REMEDIAL INVESTIGATION	27

Figure 9  -  GROUND WATER RESULTS
             DNREC REMEDIAL INVESTIGATION	28
                            Appendix

                   STATE LETTER OF CONCURRENCE

                   ADMINISTRATIVE RECORD INDEX
                                11

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                        RECORD OF DECISION
                   TYLER REFRIGERATION PIT SITE

                            DECLARATION
 SITE  NAME  AND LOCATION

 Tyler Refrigeration Pit Site
 Smyrna,  De1aware

 STATEMENT  OF  BASIS  AND PURPOSE

 This  decision document presents  the  Environmental Protection Agency's
 selected remedial action for the Tyler Refrigeration Pit Site (Site)
 in Smyrna, Delaware 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).  This decision document  explains the
 factual  and legal basis  for  selecting the  remedy for this  Site.   The
 information supporting this  remedial action decision is contained in
 the Administrative  Record for this Site.

 The Delaware  Department  of Natural Resources  and Environmental  Control
 (DNREC)  has concurred with the selected no action remedy (see attached
 letter).

 DESCRIPTION OF THE  SELECTED  REMEDY

 The selected  remedy for  the  Tyler  Refrigeration  Pit  Site is  No Action.
 Ground water  monitoring  shall be  conducted to ensure the
 protectiveness of the  no  action remedy  in  the future.   A review of the
 conditions at the Site will  be conducted within  five years,  in
 accordance with Section  121(c) of  CERCLA,  42 U.S.C.  §9621(c), and 40
 C.F.R. Section 300.430 (f) (4) (ii)  of  the NCP,  to verify  that  no
 unacceptable  hazards are  posed by  conditions which then exist at the
 Site.

DECLARATION STATEMENT

EPA has determined  that no remedial  action is necessary at the Site to
 ensure protection of human health  and the environment.   Since EPA's
 future response at  this Site does  not require physical  construction,
the Site now qualifies for inclusion on the Construction Completion
                                                      sL frt
Thomas C. Voltaggio7T~Direc|/6r                     Date
Hazardous Waste Hanagemertt Division
Region III

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                         DECISION SUMMARY

 1.   Site  Name.  Location and  Description

 The  Tyler Refrigeration Pit  Site  (Site)  is  located on  a  3-acre
 parcel  of property at  655 Glenwood Avenue,  Smyrna, Delaware.
 This property is  currently owned by the  State of Delaware and
 occupied  by the Metal  Masters Food Service  Equipment Company,
 Inc.  (Metal Masters),  but was formerly owned by the Tyler
 Refrigeration Corporation and the Clark  Equipment Company.  The
 Site is approximately  1/2 miles southwest of the center  of  the
 town of Smyrna (Figure 1).

 The  Site  includes an area which formerly contained two wastewater
 lagoons in the northeast portion of the  property  (Figure 2).
 Based on  aerial photographs, the two lagoons are approximately 70
 feet x  70 feet  and 60  feet x 60 feet and existed on the property
 from as early as  1954.  The  lagoons received wastewater  from
 manufacturing operations at  the property.   Sometime between 1973
 and  1975,  Clark Equipment Company excavated and removed the
 contents  of the lagoons.  The lagoons were  then backfilled and
 regraded  and are  currently maintained as parts of a lawn and an
 asphalt parking lot.

 The  land  use in the area surrounding the Site is predominantly
 residential with  some  light  industry and farming.   Properties to
 the  north of the  Site  across Glenwood Avenue include commercial
 properties,  several residences and agricultural lands.   To the
 west-northwest  of  the  Site are several residences along Glenwood
 Avenue.   To the south  and southwest of the  lagoons is  the Metal
 Masters building  and property and a grain elevator/silo
 structure.   The area to the  south-southeast of the Site is mainly
 residential.  Surface  water bodies in the general area include
 Greens  Branch,  Duck Creek, Lake Como and Mill Creek.    The potable
 water supplies  in  the  vicinity of the Site are obtained entirely
 from ground water  and  are provided primarily through municipal
 well systems.


 2.   Site History and Enforcement Activities

 In the  late  1940s, a plant was constructed on the  property to
 manufacture  refrigerators by Wilson Refrigeration,  Inc.  Prior to
 this time  the property was owned by the John E.  Wilson, Jr.  and
 Bertha  M.  Wilson and Wilson Cabinet Company.  In 1951,  Tyler
 Refrigeration Corporation (Tyler)  leased the property from the
Wilsons until 1956 when the title of the property was passed to
Tyler.  Based on existing aerial photographs,  the  two lagoons
were constructed in the northeast portion of the property
 sometime prior  to  1954.  These lagoons were apparently
 constructed  to  receive wastewater from the refrigeration
manufacturing operations at the Site,  although little information

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 is available  as  to  their operation.    The  wastewater reportedly
 contained paints, paint-related waste,  and solvents  including
 trichloroethylene  (TCE).   In  1963, Tyler became  part of  the
 refrigeration division of Clark Equipment  Company (Clark).   Clark
 manufactured  refrigeration equipment  at the property until 1976.
 Wastewater discharges from the  manufacturing operation were
 connected to  a municipal  sewage system in  1969.   Sometime between
 1973 and 1975, Clark excavated  and removed the contents  of the
 lagoons, and  then backfilled  the lagoons.   In 1978,  the  Metal
 Masters Food  Service Equipment  Co.  (Metal  Masters) took
 possession of the property.   At approximately the same time,
 pursuant to a financing arrangement in connection with this
 transaction,  the Delaware Department  of Community Affairs and
 Economic Development took title to the property.

 In 1977, during routine monitoring, the Town of  Smyrna's two
 municipal water supply wells  were found to contain
 trichloroethene  (TCE).  Investigations  by  the Delaware Department
 of Natural Resources and  Environmental  Control (DNREC),  the
 Delaware Division of Public Health and the  Town  of Smyrna
 identified a  number of potential sources of TCE  in the Smyrna
 area, including the Site.   In 1982, Smyrna  installed Granular
 Activated Carbon (GAG)  units  on its two municipal  water  supply
 wells.  The GAC units effectively reduced  TCE concentrations in
 the drinking  water supplies to  safe levels.

 The EPA, in 1982, performed a Preliminary Assessment/Site
 Inspection at  the Site.   Low  levels of  trichloroethane (TCA)  and
 dichloroethane (DCA) were detected in one  soil sample and toluene
was detected  in another soil  sample.   In December  1983,  DNREC
performed a Preliminary Site Assessment and concluded that TCE
 concentrations in the Smyrna wells appeared to be decreasing.

 In June 1985,  EPA reviewed the available information for the Site
 and concluded that it was one of several possible sources of the
TCE found in  the Smyrna municipal wells.  On May 7, 1986, EPA
 collected a total of 10 ground water samples from domestic wells
 in the vicinity of the Site.  The samples were analyzed for
volatile organic compounds  (VOCs). The only VOCs  detected were
 low levels of chloroform  in two of the samples.

On June 10,  1986, the EPA formally proposed adding the Site to
the National Priorities List  (NPL).   Significant  comments were
then submitted to EPA regarding the Hazard Ranking System (HRS)
score (29.41)  and opposing the inclusion of the  Site onto the
NPL.   As a result,  EPA commissioned DNREC to perform a follow-up
 inspection of the Site.    Under this investigation, DNREC
 installed and sampled six  (6)  monitoring wells located across
Glenwood Avenue from the Site.  Based on the ground water
sampling results, three substances of concern were identified in
connection with the Site: 1,1,1-TCA,  1,1-dichloroethene  (1,1-DCE)
and chromium.   Using the ground water sampling data collected by

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 DNREC,  EPA revised the HRS score  for  the  Site  in 1989,  increasing
 the  score  to 33.94.   The Site  was formally added to  the NPL on
 February 20,  1990.

 In March 1991,  EPA and Clark,  the previous owner and operator  at
 the  Site,  entered into a Administrative Order  on Consent whereby
 Clark agreed to perform a Remedial Investigation (RI) and
 Feasibility Study at  the Site.

 In the  spring of 1995,  Metal Masters  ceased operations  and  the
 property is currently for sale.

 3.   Highlights  of Community Participation

 In October 1993,  EPA  issued a  fact sheet  to the  public  and  on
 November 10,  1993, held a public  meeting  to discuss  the  findings
 of the  RI  performed by Clark which concluded that the lagoons
 were not the  primary  source of the ground water  contamination.
 During  the public meeting,  EPA and DNREC  explained that  DNREC
 would conduct a separate RI under the Delaware Hazardous
 Substance  Control Act  (HSCA) for  the adjacent Metal  Master's
 plant area which was  suspected to be the  primary source  of  the
 ground  water  contamination.  During this  time, the RI Report
 prepared by Clark was  placed in the Administrative Record for
 public  review.

 In September  1995, following completion of  an RI performed  by
 Metal Masters for the  adjacent Metal Masters'  plant  area, DNREC
 solicited  public  comment on its finding that no  action was
 necessary  to  protect human  health and the environment.  No
 comments were received from the public.   In October  1995, DNREC
 issued  its  no action decision in  a Final  Proposed Plan of
 Remedial Action.

 EPA  released  its  Proposed Plan for the Tyler Refrigeration  Pit
 Site to  the public for  comment on February 21,  1996.   In
 accordance with Section 117(a)  of the Comprehensive Environmental
 Response,  Compensation  and  Liability Act  (CERCLA) of 1980,  as
 amended by  the Superfund Amendments and Reauthorization Act of
 1986, EPA made this document available to the  public in the
Administrative Record maintained at the EPA Docket Room in Region
 III,  and in the Smyrna  Public Library in Smyrna,  Delaware.   The
notice of availability  of this document was published in the
Smyrna-Clayton Sun Times  and the Wilmington News Journal on
February 21,  1996.  A public comment period on the documents was
held from February 21,  1996 to March 22,  1996.   A response to the
comments received during  this period is included in the
Responsiveness Summary, which is part of this  Record of Decision
 (ROD).

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 4.   Scope  and Role of the Response  Action Within Site Strategy

 EPA  has  determined that  the Site does  not pose  an unacceptable
 threat to  human health and the  environment and  that  no remedial
 action is  required.   The only environmental medium of concern at
 the  Site is  the ground water.   Because the ground water in the
 immediate  vicinity of the Site  is not  used as a potable water
 source,  there are  no  current risks  associated with the Site.   The
 risks calculated under a future use scenario (see Section  7}  are
 slightly above EPA's  generally  acceptable risk  range.   However,
 the  State  has instituted a Ground Water Management Zone (GMZ)
 which prohibits well  installation on the  entire Metal Masters'
 property (see Figure  3).   The GMZ will provide  continued
 assurance  that there  is  no direct contact with  any contaminated
 ground water inside the  property boundaries.  In addition,  an
 EPA-approved ground water monitoring program shall be implemented
 to determine whether  contaminants are  migrating off-site at
 levels which would cause a future threat  to human health and  the
 environment,  and,  hence,  require actions  to abate such a threat.


 5.   Summary  of Site Characteristics

 Geology:   The  Site lies  within  the Atlantic  Coastal  Plain
 physiographic  province.   The sedimentary  beds of  this  province
 dip  gently to  the  southeast  and consist of  a wedge of  sedimentary
 deposits thickening down-dip.   The sedimentary wedge  is
 approximately  2200 feet  thick in northwest  Kent County.  Directly
 underlying the Site are  sediments of the  Pleistoncene-aged
 Columbia Formation.   The  Columbia Formation  sediments  in the
 vicinity of  the  Site  are  comprised of  light brown  to orange brown
 colored coarse to  fine grained  sand with  some gravel and gravel
 layers.   Underlying the  Columbia  Formation beneath the Site are
 the Miocene  age  sediments  of the  Chesapeake Group which consist
 of dark gray silty clay.

 The Columbia Formation sediments underlying the Site form a
 productive regional water  table  aquifer.  The Chesapeake Group
 sediments  form a confining layer beneath the water table aquifer.
 Potable water  supplies in  the vicinity of the Site are obtained
 from ground water and are provided primarily through municipal
 water systems.  The Town of Smyrna operates two public water
 supply wells.  Well numbers 1 and 2 are 1600 feet and 4600 feet
 east of the Site, respectively.   The town of Clayton operates
 three public water supply wells.  The closest of these wells,
Well number  3, is located approximately 3300 feet southwest of
 the Site.  All three of the Clayton wells are located in the
upgradient ground water flow direction from the Site.  The Smyrna
municipal wells draw water from the Columbia Formation aquifer
while the Clayton municipal wells draw water from the deeper
 Rancocas aquifer.  In the Smyrna area,  the Columbia and Rancocas
 aquifer are separated by the Calvert and Nanjemoy formations.

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 These  formations  are  200  feet  thick  in the  Smyrna  area  and  act  as
 a  confining unit  above the Rancocas  aquifer.

 Based  on  the well inventory  conducted during  the RI,  several
 wells  in  the Smyrna-Clayton  area are classified as domestic water
 wells.  However,  none of  these wells is located in a  down
 gradient  ground water flow direction from the Site.

 Ground water flow direction  in the Columbia Aquifer was
 determined  based  on a four-month water level  study conducted
 during the  RI.  The ground water flow direction from  the Site is
 generally to the  northeast.  An eight-day water level study
 conducted during  the  RI indicated that pumping at  Smyrna Well No.
 1  does not  influence  the  water levels at the Site,  although the
 Site may  be within the capture zone  of Smyrna Well  No.  1 under
 steady-state, long-term conditions.

 Surface Drainage:  The topography at the Site is nearly level.
 The entire  Site is at an  elevation of approximately 40  feet above
 sea level.   Surface drainage from the parking lot  area at and
 adjacent  to the Site  is conveyed via storm drains  to a shallow
 drainage  ditch  and retention basin, with no outlet, located east
 of the Site.  The  drainage ditch and retention basin were
 constructed by Metal  Masters after the closure of  the lagoons in
 conjunction with  the  construction of the parking lot.  A
 scrub/shrub-emergent  wetland area is located within the retention
 basin.  Since this area is only intermittently saturated as a
 result of stormwater  runoff from blacktop areas and building
 roofs, it is  not  considered to be a functional wetland.

 Surface water bodies  in the general area include Greens Branch,
 Duck Creek,  Lake  Como, and Mill Creek.   Greens Branch is located
 approximately 1500 feet west of the Site and flows in a
 northeasterly direction into Duck Creek.   Duck Creek is located
 approximately 4000 feet to the north of the Site and flows east
 to its confluence  with the Smyrna River.   The Smyrna River flows
 to the northeast and  discharges to the Delaware Bay.  Lake Como
 is located  approximately 4000  feet to the southeast of the Site
 and is used for recreational purposes.

 6.  Nature  and Extent  of Contamination

 Soil:  Three  distinct  layers were encountered in the soil borings
 taken  during  the RI in the locations of the former lagoons:  1)  a
 surficial material consisting predominantly of silty sand to
 sandy  silt, probable  backfill material;   2)  a soft, dark gray
 colored silt  to sandy silt material containing,  some organic
material.    This most  likely marks the bottom of the lagoons; and
 3)  native Columbia Formation sediments.   Former Lagoon I is
 approximately 11.5 feet deep at its deepest point.   The  sandy
 silt material in Former Lagoon 1 is approximately 2 to 5.5 feet
 thick.  In  Former  Lagoon 2, .the sandy silt material is thinner

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 and  less  aerially extensive.

 As part of  the  RI,  surface soil  samples  were collected from nine
 (9)  locations  from the surface to a depth of one  foot (see Figure
 4) .   In general,  the surface  soil samples did not show the
 presence  of elevated concentrations of contaminants of concern.
 No VOCs were detected in the  surface soil samples other than
 methylene chloride,  which is  most likely an analytical laboratory
 contaminant, and  no semivolatile organic compounds (SVOCs)  were
 found.  In  addition,  no inorganic substances were detected in any
 of the surface  soil samples at concentrations significantly above
 background  levels.   One of the surface soil samples,  however,
 contained several pesticides  (0.93  ug/kg dieldrin,  0.49 ug/kg
 lindane,  0.57 ug/kg Heptachlor,  0.38 ug/kg DDE, 1.4 ug/kg  DDT,
 and  0.91  ug/kg  endrin).   The  presence of pesticides at this
 location  may be attributable  to  the use  of fill that  was
 deposited on the  property from a neighboring agricultural  area.
 Several of  the  pesticides detected,  including DDT,  have been
 banned for  as long as  twenty  years,  indicating that the
 pesticides  have resided in the soils for a considerable amount of
 time.

 A total of  23 subsurface  soil samples were collected  from  10 soil
 borings to  assess subsurface  soil quality in the  area within,
 adjacent  to and below  the former lagoons (see  Figure  5) .
 Volatile  organic  compounds were  detected in 4  of  the  23
 subsurface  soil samples analyzed.   These compounds  included
 acetone (10  to  46 ug/kg),  xylene (6  to 950  ug/kg),  carbon
 disulfide (8 ug/kg), 1,1,2-TCA (8 ug/kg),  2-butanone  (22 ug/kg),
 and ethylbenzene  (140  ug/kg).  None  of the  VOCs of  concern  in the
 ground water (1,1-TCE,  1,1,1-TCA and 1,1-DCE)  was detected.
 Semivolatile organic compounds were  detected in 3 of  the 23
 samples.  These compounds  are 2-ethylhexyl  phthalate  (56 to 130
 ug/kg) and  diethyl phthalate  (330 ug/kg).   Pesticides were
 detected  in 3 of  the 23 samples  including dieldrin  (0.28 ug/kg),
 DDE  (0.26 to 0.86 ug/kg),  DDT (0.75  ug/kg),  and ODD  (0.38 ug/kg).
 Finally,  chromium and  zinc were  detected at  levels above
 background  samples from 2  of the borings.   Chromium
 concentrations ranged  from 159 to 385 ug/kg  and zinc
 concentrations ranged  from 628 to 982 ug/kg.

 Ground Water:  Ground water samples were collected from 12
 monitoring wells  in the vicinity of  the Site  (see Figure 6  for
 locations).   Volatile organic compounds were detected in 5  of the
 12 wells sampled.   The highest concentrations of VOCs were  1,1,1-
 TCA and 1,1-DCE which were detected  in monitoring well S-l  at 720
ug/1 and 33  ug/1,  respectively.   TCE was not detected in any of
 the ground water  samples.  In addition,  no vinyl chloride was
 detected.   Low levels of SVOCs were detected in samples from 5 of
 the 12 wells.  Low levels of pesticides were also detected  in
 samples from 5 of the 12 wells during the RI, including dieldrin,
 lindane,  endrin ketone.  Chromium was detected at  levels above

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 background levels in four of  the  twelve wells.   The  highest  total
 chromium concentration was detected  at 87.2  ug/1.  Zinc  was  not
 detected above  background levels  in  any ground  water samples
 collected.

 Conclusions:  The ground water  and soils data presented  in the RI
 indicate that the lagoons are not the primary source of  the
 1,1,1-TCA and the l,.l-DCE detected in monitoring well S-l.
 Neither  of  these  contaminants were detected  in  any of the soils
 within or below the  former lagoons.  In addition, the pattern of
 contaminants detected in the  ground  water suggests the existence
 of a source unrelated to the  Site and located south  of the former
 lagoons  and upgradient of well  S-l.   Finally,  the increase  in
 1,1,1-TCA concentrations in the samples from well S-l collected
 in 1988  and 1992  indicates that a release of 1,1,1-TCA may have
 recently occurred from a source upgradient of well S-l or
 recently migrated from such an  upgradient source.  Since 1,1-DCE
 is a breakdown  product of 1,1,1-TCA, the same source is most
 likely responsible for the presence  of both  contaminants.

 These conclusions are  further supported by the  findings of the
 Metal Masters'  Remedial  Investigation1  conducted pursuant to  an
 order with  DNREC.  The Metal  Masters' Remedial  Investigation
 identified  three  possible source areas:  1)  a loading dock where
 drums of  TCA were received, 2)  a TCA Storage Area and 3)  an
 underground sanitary  sewer holding tank (see Figure  7).  Surface
 and subsurface  soil samples were taken from  these areas.   Three
 additional  monitoring  wells were installed downgradient of these
 areas to  study  the ground water.  The distribution of
 contamination in  the  soil  and ground water indicated  that the
 historic  source of the  1,1,1-TCA and 1,1-DCE was near  the TCA
 Storage Area (see Figures  8 and 9).   The Metal Masters' Remedial
 Investigation concluded  that  the TCA Storage Area,  however,  does
 not likely  represent a  continuing potential  source because little
 contamination remains  in  the  soil and Metal Masters discontinued
 operations  in Spring 1995.


 7.0  Summary of Site Risks

 7.1  Human Health Risk Assessment

The Baseline Risk Assessment  (BLRA)  for the Tyler Refrigeration
 Pit Site quantifies the potential human health risks  associated
with exposure to  contaminated environmental media.   The BLRA was
prepared in conjunction with available EPA guidelines for
conducting Superfund Risk Assessments and utilized the data
collected during  EPA's Remedial Investigation of the  Site.   The
     1  Metal  Masters Food Services  CO.,  Inc., Remedial
Investigation Report  (Groundwater Technology,  June 1995)

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 risk  assessment  first  evaluated and selected the contaminants of
 concern  based on the following considerations:  1)  site history
 and operations;  2)  detected concentrations  in excess  of risk-
 based levels  and 3) typical background  concentrations of chemical
 constituents  in  the vicinity of the site  or in  unpolluted soils
 of the Eastern United  States.   The  risk assessment then evaluated
 Site-related  exposures to  these chemicals.   In  the final step,
 the concentrations  of  the  chemicals at  the  point of exposure  were
 used  to  estimate the potential for  an adverse effect  on human
 health or  the environment.

 Contaminants  of  Concern:   The  three contaminants of concern that
 were  evaluated in the  risk assessment are 1,1,1-TCA ,  1,1-DCE and
 a pesticide,  dieldrin,  all of  which were detected in  the ground
 water.   In addition to exceeding health based levels,  the 1,1,1-
 TCA and  1,1-DCE  also exceeded  their respective  Maximum
 Contaminants  Levels (MCLs)  of  200 ppb and 7 ppb.

 Exposure Assessment:   Several  environmental media  at  the Site
 were  assessed for the  presence  of contamination  including surface
 soil,  subsurface soil  gas  and  ground water.   Based on the
 findings of the  RI  the  only environmental medium of concern at
 the Site is ground water.   Since potable water  in  the  area of the
 Site  is provided by municipal  systems,  it was not  necessary to
 evaluate the  current land-use  scenario.  However,  under  the
 future potential  land-use  scenario,  theoretical  exposure  to
 residents, via contaminated private  or municipal wells,  was
 assessed.  The primary  routes of exposure to ground water at  the
 Site  under this  scenario involve drinking (ingestion)   by children
 and adults, breathing  (inhalation)  while showering by  adults,  and
 dermal (or skin)   contact by children.

 Since a different pattern of contamination was observed  for
 dieldrin as compared to the  1,1,1-TCA and 1,1-DCE contamination,
 two separate well clusters were evaluated.  Cluster A  includes
 monitoring wells  S-l and S-6 which contained 1,1-DCE and 1,1,1-
 TCA in excess of  health-based levels and Cluster B includes
monitoring wells  S-2,  S-3,  D-2 and D-4 which contained dieldrin
 in excess of health-based levels.  The data used in the BLRA
 conforms to EPA guidance which recommends choosing monitoring
 wells located in  the apparent center of the ground water plume,
 since it is conceivable that future potable wells may be
developed in this area.

The exposure point concentrations used in the risk calculations
 are defined as the 95th percent upper confidence limit (UCL)
value of the arithmetic mean of the data for the Site.  In cases
where the exposure point concentration value exceeds the maximum
 reported concentration  for a given contaminant,  or in cases where
 the data set is not sufficient for the calculation of  an exposure
point concentration, the maximum reported value  is used for
 exposure point calculations.  If a contaminant has been

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determined  to  be  present  in  samples for a given medium, but  is
reported  as a  non-detect  for a given sample, one-half of the
detection limit is  used in the exposure point calculation for
that  contaminant.   Table  1 provides the 95th UCL value for each
contaminant of concern.   In  every instance, the 95th UCL exceeded
the maximum observed concentration of ground water contaminants;
therefore,  the maximum detected concentration of each contaminant
was used  in the risk calculations.

Exposure  parameters applied  in the BLRA are presented in Table 2.
These values reflect the  default exposure parameters defined by
EPA guidance2.
Table 1:  Statistical Analysis of Ground Water Data for
Contaminants of Concern
Contaminant
(ug/1)
1,1 -DCE
1,1,1-TCA
Dieldrin
Mean
12.00
187.75
0.08
95th% UCL
3672.52
1.08E+14
0.59
Maximum
33.00
720.00
0.26
     2 Environmental Protection Agency.   Human Health Evaluation
Manual, Supplemental Guidance: Standard Default  Exposure Factors.
OSWER Directive 9285.6-03.  March 25,  1991.
                                10

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Table 2 • Exposure Assessment Parameters
Exposure Factors
Future Child Resident
Future Adult Resident
INGESTION EXPOSURE PATHWAY - Ground Water
Inqestion Rate:

Exposure Freauencv:

1 liter/day
350 days/year
2 liter/day
350 days/year
INHALATION OF VAPORS WHILE SHOWERING EXPOSURE PATHWAY
Inhalation Rate:

Shower Duration:

Exposure Freauencv:

N/A
N/A
N/A
0.0138889 rtrYmin
12 min/day
350 days/year
DERMAL CONTACT WHILE BATHING EXPOSURE PATHWAY
Skin Surface Area
Exposed:

Bath Duration:

Permeability Constant:

Exposure Frequency:

7200 cm3
0.33 hours/day
1 .60 E-02 cm/hour (1 ,1 -DCE)
1.70 E-02 cm/hour (1,1,1-TCA)
1 .60 E-02 cm/hour (dieldrin)
350 days/yr
N/A
N/A
N/A
N/A
EXPOSURE ASSESSMENT CONSTANTS
Exposure Duration
Body Weight
Averaqinq Time:
Carcinogens
Noncarcinogens
6 years
15kg
25550 days
2190 days
24 years
70kg
25550 days
8760 days
Toxicity Assessment:  Toxicity criteria for assessing potential
carcinogenic risks and noncarcinogenic threats for the selected
contaminants of concern are presented in Table 3.

The Carcinogenic Slope Factor is the plausible upper-bound
estimate of  the probability of a response per unit intake of a.
chemical over a lifetime.   The Carcinogenic Slope  Factor is used
to estimate an upper-bound probability of an individual
                               11

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 developing cancer as a result  of exposure  to a particular  level
 of  a  potentially carcinogenic  contaminant  of concern.
 Reference  doses  (RfDs)  have been developed by EPA  for  indicating
 the potential  for adverse  health effects from exposure to
 chemicals  exhibiting noncarcinogenic effects.  RfDs, which  are
 expressed  in units of mg/kg-day, are estimates of  lifetime  daily
 exposure levels  for humans, including sensitive  individuals,  that
 are not likely to result in an appreciable risk  of adverse  health
 effects.   Estimated intakes of chemicals from environmental media
 (i.e., the amount of a  chemical ingested from contaminated
 drinking water)  can be  compared to the RfD.  RfDs  are  derived
 from human epidemiological studies or animal studies to which
 uncertainty factors have been applied (i.e., to  account for the
 use of animal  data to predict effects on humans).  These
 uncertainty factors help ensure that the RfDs will not
 underestimate  the potential for adverse noncarcinogenic effects
 to occur.

 In addition to providing toxicity criteria, Table  3 also provides
 the carcinogenic  Weight of Evidence for each contaminant of
 concern.

 Table 3:   Toxicity Criteria and Carcinogenic Weight of Evidence

Contaminant
1,1-DCE
1,1,1-TCA
Dieldrin
Carcin-
ogenic
Weight
of
Evidence
C
D
B2
Carcinogenic
Slope Factor
(mg/kg/day) "1
Oral
6.00E-01
N/A
1.60E+01
Inhala-
tion
1.75E-01
N/A
1.61E+01
Reference Dose
(mg/kg/day)
Oral
9.00E-03
9.00E-02
5.00E-05
Inhala-
tion
ND
2.86E-01
ND
C =  Possible Human Carcinogen.  Limited evidence in animals
and/or carcinogenic properties in short-term studies.

D =  Not Classified.  Inadequate evidence in animals.
B2 = Possible Human Carcinogen.
inadequate evidence in humans.
Sufficient evidence in animals,
                               12

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Risk Characterization:   Exposure  estimates  and  toxicity  criteria
for the contaminants of  concern were  combined to  estimate
potential carcinogenic risks and  noncarcinogenic  effects for  the
pathways and routes identified for the Site.  These estimates
characterize the potential  for human  health impacts associated
with exposure  to contaminated ground  water.

The upper bound estimate of the carcinogenic risk is expressed in
terms of the number of excess cancers over  a lifetime in an
exposed population under a  specific exposure scenario.   For
instance, a carcinogenic risk of  1.0 x 10"6  is defined as 1
additional cancer per 1 million exposed individuals.  In general,
EPA defines incremental carcinogenic risk within  the 1.0 x 10"6
to 1.0 x 10"4 range as being acceptable, with 1  x  10"6 being  the
point of departure or goal.

The numerical value used to evaluate noncarcinogenic risk is the
Hazard Quotient (HQ).  An HQ is the ratio between the dose of a
single substance over a specified period of time  to the RfD for
that substance.  The Hazard Index (HI) is the sum of more than
one HQ for multiple substances or multiple exposure routes and
pathways.  When the HQ or the HI exceeds unity,  there may be
concern for potential noncancer health effects.

The carcinogenic risks and noncarcinogenic threats associated
with exposure to contaminated ground water across all routes
(ingestion,  inhalation and dermal absorption) were summed,  as
appropriate,  for each potential receptor.   The cumulative risks
and threats for child and adult receptors are presented in Tables
4 and 5,  respectively.   The combined carcinogenic risk and
noncarcinogenic threats over a 30 year residential exposure
duration (6  years as a child resident plus 24 years as  an adult
resident)  are presented in Table 6.
                               13

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TABLE 4:  Cumulative Potential Carcinogenic Risk and
Noncarcinogenic Threat  - Child Resident - Ingestion of and Dermal
Contact with Ground Water
Monitoring Well Clusters
S-l, S-6
S-2, S-3, D-2, D-4
Cumulative
Carcinogenic
Risk
1.12 X 10'4
2.37 X 10'5
Cumulative
Noncarcinogenic
Threat
(Hazard Index)
0.775
0.345
*  In monitoring wells S-l and S-6, the cumulative carcinogenic
risk is due to ingestion of and dermal contact with 1,1-DCE.  The
cumulative noncarcinogenic threat is due to ingestion of and
dermal contact with 1,1-DCE and 1,1,1-TCA.

*  In monitoring wells S-2, S-3, D-2 and D-4, the cumulative
carcinogenic risk is due to ingestion of and dermal contact with
dieldrin.  The noncarcinogenic threat is due to ingestion of and
dermal contact with dieldrin.
TABLE 5:  Cumulative Potential Carcinogenic Risk and
Noncarcinogenic Threat - Adult Resident - Ingestion and
Inhalation of Ground Water
Monitoring Well Clusters
S-l, S-6
S-2, S-3, D-2, D-4
Cumulative
Carcinogenic
Risk
2.65 X 10'4
3.92 x 10'5
Cumulative
Noncarcinogenic
Threat
(Hazard Index)
0.326
0.142
*  In monitoring wells S-l and S-6,  the cumulative carcinogenic
risk is due to ingestion and inhalation of 1,1-DCE.   The
cumulative noncarcinogenic threat is due to ingestion of
1,1-DCE and 1,1,1-TCA, and inhalation of 1,1,1-TCA.

*  In monitoring wells S-2,  S-3,  D-2,  and D-4,  the cumulative
carcinogenic risk is due to ingestion and inhalation of dieldrin.
The cumulative noncarcinogenic threat is due to ingestion of
dieldrin.
                                14

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TABLE  6:  Combined  Potential  Carcinogenic  Risk and
Noncarcinogenic Threat  Child  Resident  (6 years)  & Adult Resident
 (24 years)
Monitoring Well Clusters
S-l, S-6
S-2, S-3, D-2, D-4
Combined
Carcinogenic
Risk
3.77 x 10'4
6.28 x 1CT5
Combined
Noncarcinogenic
Threat
(Hazard Index)
1.10
0.49
*  The values presented in this table represent the combined
carcinogenic risks and combined noncarcinogenic threats posed by
exposure  (via ingestion, inhalation, and dermal contact) to
contaminated ground water over a 30 year period  (6 years as a
child + 24 years as an adult).

7.2  Ecological Risk Assessment

An Ecological Risk Assessment  (ERA) was performed to determine if
there is an actual or potential ecological risk as a result of
exposure to Site-associated contaminants of concern.   The ERA
identified chromium as a contaminant of concern in the soil.
However, few ecological receptors  (e.g., animals, birds) were
observed on, or in the vicinity of, the Site.  In addition, there
are no apparent ecological exposure pathways at the Site.
Therefore, the ERA concluded that little or no ecological risk
can be associated with the Site.
8.   Description of the Selected Remedy

Under the Superfund Program, studies were conducted at the Site
to characterize the nature and extent of contamination.  These
studies and other information which EPA used in choosing the
selected remedy are contained in the Administrative Record for
the Site (see Administrative Record Index in attached Appendix).
The studies have indicated that exposure to ground water is the
only potential concern.  Because the ground water in the
immediate vicinity of the Site is not used as a potable water
source, there are no current risks associated with the Site.  The
risks calculated under a future use scenario are slightly above
EPA's generally acceptable risk range.  However, the State has
instituted a Ground Water Management Zone (GMZ)  which prohibits
well installation on the entire Metal Masters'  property.  The GMZ
will provide continued assurance that there is no direct contact
with any contaminated ground water inside the property
boundaries.  In addition, an EPA-approved ground water monitoring
program shall be implemented to ensure that contaminants do not
migrate off-site at levels which would pose a threat to human
                                15

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health and the environment in the future.  Therefore, EPA has
determined that no action is required at this time to protect
human health and the environment.

EPA has determined that it is appropriate to monitor this
situation and will conduct a periodic review of the conditions at
the Site to verify that the No Action remedy remains protective
of human health and the environment in accordance with Section
121(c) of CERCLA and 40 C.F.R. Section 300.430(f)(4)(ii) of the
NCP.
9.   Documentation of No Significant Change

The Proposed Plan for the Tyler Refrigeration Pit Site was
released for public comment on February 21,  1996.  The public
comment period closed on March 22,  1996.   EPA reviewed all
written comments submitted during the public comment period.  A
summary of the comments received during the  public comment period
is included in the Responsiveness Summary section of this Record
of Decision.  Based on these comments,  it was determined that no
significant change to EPA's proposed remedy, as originally
identified in the Proposed Plan,  was necessary.
                               16

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                      Responsiveness Summary

                   Tyler Refrigeration Pit Site
                         Smyrna,  Delaware


This  Responsiveness  Summary documents  public  comments received by
the U.S.  Environmental  Protection  Agency (EPA)  during the  public
comment period  on  the Proposed Remedial  Action  Plan (Proposed
Plan)  for the Tyler  Refrigeration  Pit  Site.   It also provides
EPA's responses to those comments.

A public  comment period was held from  February  21,  1996  through
March 22,  1996  to  receive  comments  from  the public  on the
Proposed  Remedial  Action Plan  and  the  remedial  alternative for
the Tyler Refrigeration Pit Site preferred by EPA.   All  comments
received  during the  public comment  period and corresponding
responses are summarized below.

On behalf of Metal Masters Food Service  Equipment Company,  Inc.
(Metal Masters), Groundwater Technology, Inc. submitted  the
following comments.  Metal Masters  concurs with the  proposed  no
action remedial  alternative but does not agree  that  the  proposed
ground water monitoring program is  necessary  to evaluate off-site
levels of contamination based  on the following  reasons.

1.  Groundwater  quality data beginning in April  1988  to  February
7, 1995 have shown decreasing  concentrations.

Response:  EPA agrees that  the concentrations of Volatile Organic
Compounds  (VOCs) in wells  S-2, S-3, S-4 and S-5 have  decreased  as
depicted  by three rounds of data {April 1988, September  1992,  and
February  1995).  However,   the  concentrations of two of the main
contaminants of  concern (1,1-dichloroethene,  1,1,1-
trichloroethane) have shown the opposite trend and have  actually
increased  since April 1988  in wells S-l and S-6.  Furthermore,
there is  only one round of data for wells MM-1,  MM-2, and MM-3.
In the latest round of sampling (February 1995), the
concentrations of 1-1-dichloroethene and 1,1,1-trichloroethane  in
MM-2 are  still above their respective Maximum Contaminant Limits
(MCLs) .

2.  Volatile organic compound concentrations in all three
sampling events are extremely low and there is no active source
area where groundwater quality is in question.

Response;   EPA has established that the concentration of 1,1-
dichloroethene,  one of the contaminants that  contributes to the
carcinogenic risk at the Site,  exceeded its MCL of 7 ppb in all
three rounds.  The concentrations of 1,1,1-trichloroethane which
is also a contaminant of concern exceeded its MCL of 200 ppb in

                               17

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 the  last  two  rounds  of  sampling.  Regarding the  issue of an
 active  source area,  the suspected source based on the DNREC
 Proposed  Plan of  Remedial Action was the TCA Storage Area  (refer
 to Figure 7).   DNREC concluded that the TCA Storage Area does not
 likely  represent  a continuing source because Metal Masters is no
 longer  operating  its plant at this location and  little
 contamination remains in the soil.  However, existing
 contamination in  the ground water can still migrate whether or
 not  an  active source area exists.

 3.   Monitoring well  S-l which originally was the well that
 exhibited the highest concentrations was reported in the February
 1995 sampling event  to  be non-detectable for trichloroethane and
 1,1-dichloroethene.

 Response:  EPA agrees that the Metal Masters Food Service
 Equipment  Co., Inc.  Remedial Investigation Report (June 1995)
 reported  non-detectable concentrations of all contaminants in
 well S-l.  However,  EPA is surprised that the concentrations in
 this well  would have declined so dramatically in this time frame.
 Therefore, the collection of additional data from this well is
 particularly  important  within the monitoring program.

 4.   Natural attenuation will continue to reduce the already
 extremely low levels present in the groundwater at the site.

 Response;  While natural attenuation of the contaminants of
 concern through dilution or biodegradation may occur, many
 factors such  as the  rate at which this may or may not occur have
 not  been  determined.  In addition,  while organic chemicals
 degrade in the natural  environment,  studies have shown very
 little or  no  degradation for chemicals such as 1,1,1-
 trichloroethane or dieldrin in natural waters (Klecka,  G.M. 1990.
 Biotransformations of 1,1,1-trichloroethane in ground water.
 Environmental  Toxicology & Chemistry) .   One way to be certain
 that natural  attenuation is actually occurring is through a
monitoring program.


 5.  The State  of Delaware is currently in the process of
 instituting a  Groundwater Management Zone (GMZ)  which will
restrict well  installation on the entire site property.   This GMZ
will provide  continued  assurance that no direct contact  with  the
Site groundwater will occur.

Response:   EPA acknowledges that on February 20,  1996,  the State
of Delaware instituted  a GMZ which should prevent contact with
any contaminated groundwater within the Metal Master's  property
boundaries.  However, EPA believes that it is important  to
monitor the levels of contamination that may be migrating beyond
the property boundaries and beyond the boundaries of  the GMZ  to
ensure that there is  no  threat to human health or the environment

                               18

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downgradient of the GMZ.  Additionally, it should be noted that
the wells with the highest concentrations of contaminants in the
latest sampling round  (wells MM-2 and S-6) lie at the Site
boundary and beyond the site boundary, respectively, in the
direction of groundwater flow.

6.  There is a town ordinance that prohibits the future
installation of private drinking wells.  This will assure that no
future ground water wells immediately downgradient of the Site
are installed for groundwater ingestion.

Response:   According to EPA's conversations with the Smyrna Water
Supply Operator, there is no town ordinance which prohibits the
future installation of private drinking water wells on or
downgradient of the Site.  Additionally, with the exception of a
small portion of the Site which lies in the northeast corner of
the property,  the Site actually lies outside the town boundaries.
However,  the State GMZ will prohibit well installation on-site.
                               19

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FIGURES

-------
                                           Figure 1
                                     Site Location Map
                         ,0- Tyler Refrigeration Pit Super-fund Site
                        "            Smyrna, Delaware
  1000    0    1000  2000
         •       •
        Scale in Feet

 Source:  USGS Topographic Quadrangle. Smyrna. OE
Location d Smyrna or
Qayton Municipal Well
THE ERM CROUP
                                                                     C27DZ10.01/ DC 1-14-93 I ESl-l*-93
                                          20

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• • tOllf/OH CM OP MVUO-MOC 11/tO 10 101»
                  Ajopunog
      OJDMB|OQ '
      ojis punjjedns
      uo||BieB|J|eu
              oils tti
            Z

-------
N
O
 N>
 K)
                           .20-01-
                               OF COMMON,TV
                                 IOMIC  oev/.
                                                                                                              (O
                            (O
                                                                                                   .oa.000
'fax I'arccl Mii|> Showing Ground
Water  Management  Zone QnundarIcs

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              Figure 4
Surface  Soil Sample Location  Map
       Tyler  Refrigeration Pit
           Superfund Site
           omyrna, Delaware
                Approximote
                Locolion of
                 Lagoon 2
                        Approximote
                        Location of
                        Lagoon 1
               SS-1
Property Line/Fence

Surface Soil Sample  Location

-------
o
b
                                                  Figure 5
                                         Soil Boring  Location  Map
                                          Tyler  Refrigeration  Pit
                                               Superfund  Site
                                               Smyrna, Delaware
                                                    Approximote
                                                    Locolion
                                                     Logoon 2
                                                            Approximole
                                                            Locotion o(
                                                             Lagoon 1
                                                            Property Line/Fence

                                                     B-l •  Soil Boring Locotion
                                                                                       Scale in Feel

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                                                                                                                               HI Monitoring W*ll
                                                                                                                                  Location Map
                                                                                                                             Tyl«r Refrigeration Pll
                                                                                                                                 Stiperlund 8IU
                                                                                                                                 •myrw.
                                                                                                                                                        (Q
                                                                                                                                                        C
                                                                                                                                                        (P
                                                                                                                                                        o>
                                                                                                                              w«« A>iociui«a ..in tM

                                                                                                                       OII-Sil* Iwnliving Wwl ACIOM
                                                                                                                              Av*nu«
Scow in f»«l

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S3
ON
                                                                                           STORMWATER
                                                                                        3E7ENTION PONO
                                        PARKING J
                                         AREA
                               APPROXIMATE LOCATION OF UNDERGROUND
                                   HOLDING TANK FOR  SANITARY SCWER
                                                                                         WAfCR   i MM- )
                                                                                         AST
                                        TCA STORAGE AREA
                              METAL  MASTERS
                              SMYRNA PLANT
                                                                                                0-6,
                                                                                                      S-6
                                                                                                               Figure 7
                                                                                                              LOCATION OF SOURCE  AREAi
                                                                                                          DNREC REMEDIAL INVESTIGATION

-------
                                                                             SIOHUWMCH

                                                                          RCUNIION PONO
                        OPPROKUUIC LOCAllOH OF UNOCHCROJNO
                           HOLOINC IANK rOR SUIIIMIir SCWR
               MM-3/CT-J
                                                                 DEPTHl SURFACE  10-IB'
                                                               s I TCA K1.100JI  BDL
METAL  MASTERS
SMYRNA PLANT
                                                          DEPTH SURFACE  10-12'
                                                            TCA r<1.ipOj|  BDL
DEPTH
TCA
ICE.
SURFACE

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METAL MASTERS
SMYRNA PLANT
                                        f(NCC
MM -2
TCA
I.I-DCE
l.t-DCA
ICE
PCE
1.1.2-TCA
CIS 1.2
260
26
13
5.7
8.7
<0.5J
<0.bJ
5-6
TCA
I.I-OCE
1.1 -OCA
TCE
PCE
CIS 1.2
33
5.8
o:> •••
2.8
<05J
<0.5J
                                                                                                                  UGJUD

                                                                                                     -f    MONITORING WELL
                                                                                                     ©    SOIL BORING
                                                                                                     TCA    1 I  1-lRICHLOROElMANE
                                                                                                            CONCENTRATION  (ug/l)

                                                                                                   1.1-OCE  1.1-OICHLOROETMENE
                                                                                                            CONCENTRATION  (ug/l)
                                                                                                   1.1-OCA  1.1-OlCHLOROETHANt
                                                                                                            CONCENTRATION  (ug/l)

                                                                                                     TCE    IRlCHLOROHHENE
                                                                                                            CONCENT«A:IO::  1.3/1)
                                                                                                     PCE    TETRACHLOEOJTMiNE
                                                                                                            CONCENTRATION  (ug/i)

                                                                                                  1.1.2 - TCA 1 Jj2-!RjCHI.pRpE]HANE
                                                                                                   CIS  1.2


                                                                                                     VOC

                                                                                                      J


                                                                                                     BOL
         CIS-1,2-DlCHLOROETHENE
          CONCENTRATION (ug/l)

         VOLATILE ORGANIC COMPOUNDS

         LESS  THAN DETECTION  LIMIT
          BUT  GREATER THAN ZERO
         BELOW DETECTION LIMIT

         MICROCRAMS  PER LITER

__	*_  fENCE

	PROPERTY BOUNDARY
                                                                                                    0


                                                                                                    SCALE
           100
                       200
                                                                                                                       FEET
                                                                                                          Figure  9

                                                                                                 GROUND WATER RESULTS
                                                                                                 DNREC REMEDIAL  INVESTIGATION

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Appendix

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                                        STATE OF DELAWARE
                                 DEPARTMENT OF NATURAL RESOURCES
                                   AND ENVIRONMENTAL CONTROL
                            DIVISION OF AIR AND WASTE MANAGEMENT
                                         71 5 GRANTHAM LANE
WASTE MANAGEMENT SECTION                 NEW CASTLE. DELAWARE 1972O-48O1                 TELEPHONE: (302) 323 • 454O
   SUPERFUND BRANCH                                                             FAX:     (3O21323 • 4561
             April 11, 1996
             Ms. Lisa Marino (3HW42)
             US EPA Region III
             841 Chestnut Building
             Philadelphia, PA 19107

             RE:   Tyler Refrigeration Site Record of Decision

             Dear Ms. Marino:

             The Department of Natural Resources and Environmental Control is pleased to
             offer concurrence with the above referenced Record of Decision of behalf of the
             State of Delaware.
            Sincerely,
            Stephen F. Johnson
            Environmental Engineer

            SFJ:dmg
            SFJ96030

            cc:    Jamie H. Rutherford
                   File:  DE-043.11.1.5

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                     TYLER REFRIGERATION PIT
                   ADMINISTRATIVE RECORD FILE *
                        INDEX  OF  DOCUMENTS
I.    SITE IDENTIFICATION

     1.   Memorandum to Mr. Mike Apgar from Mr. Ron Stoufer, re:
          Chemical data on ground water samples collected from
          wells in Smyrna, 4/18/78.  P. 100001-100013.  The
          following are attached:

               a)    Table 1, Concentrations in Water Collected
                    from Wells in Smyrna on March 14, 1978;

               b)    Table 2, Data on Smyrna Well #2 when the Well
                    was Constructed in 1958;

               c)    a memorandum regarding a summary report on
                    the trichloroethylene contamination
                    investigation in Smyrna, dated May 31,  1978;

               d)    three site location maps;

               e)    a memorandum regarding information about
                    Tyler Refrigeration Waste Pit in relation to
                    the trichloroethylene problem in Smyrna's
                    wells, dated May 1, 1979.

     2.   U.S.  EPA Potential Hazardous Waste Site Identification
          and Preliminary Assessment,  Tyler Refrigeration,
          10/25/82.  P. 100014-100042.  Two Site Inspection
          reports,  a letter regarding information about domestic
          wells in the vicinity of the site dated June 28,  1985,
          and a site location map are attached.

     3.   Report:   Preliminary Assessment and Site Inspection of
          Tyler Refrigeration,  prepared by Ecology and
          Environment,  Inc., 10/28/82.  P.  100043-100146.

     4.   Report:   A Preliminary Assessment of Tyler
          Refrigeration,  prepared by Delaware Department of
          Natural  Resources and Environmental Control (DNREC),
          12/83.  P. 100147-100180.

     5.   Report:   Non-Sampling Site Inspection Using Available
          Information of  Tyler Refrigeration,  prepared by NUS
          Corporation,  6/10/85.   P.  100181-100428.
     Administrative Record File available 8/26/92, updated 9/9/93,
     11/11/93,  12/6/93,  12/1/95,  2/12/96,  and 3/15/96.

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Report:  A Field  Trip  Report  for  Tyler Refrigeration,
prepared by NUS Corporation,  8/15/86.   P.  100429-
100473.  Two cover  letters and a  memorandum dated  July
21,  1986 requesting assistance from  the Field
Investigation Team  (FIT) office are  attached.

Letter to  Ms. Stephanie L. Papa,  U.S.  EPA,  from Mr.
David J. Carlson, Dames & Moore,  re:   Transmittal  of
sampling and groundwater investigation documents,
9/25/89.   P. 100474-100570..   The  following are
attached:

     a)    a letter  regarding  analytical laboratory
           results,  dated December 28,  1988;

     b)    Table 1,  Summary of  Analytical Laboratory
           Data, Tyler Refrigeration, Smyrna,  Delaware;

     c)    Table 2,  Summary of  Analytical Laboratory
           Data, Tyler Refrigeration, Smyrna,  Delaware,-

     d)    a Plot  Plan Showing  Monitoring Well Locations
           and Ground Water Flow Direction;

     e)    a letter  regarding the  assessment of  the
           direction of groundwater flow, dated  May 2,
           1989;

     f)    a Clark Equipment Company table  containing
           information on water  levels;

     g)    a Ground Water Flow map;

     h)   Appendix A,  Stevens Recorder Charts;

     i)    an Analytical Report prepared by National
           Environmental Testing,  Inc.

Report:  A Follow-Up Site Inspection of Tyler
Refrigeration,  prepared by DNREC,  (undated).
P. 100571-100970.

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II.   REMEDIAL ENFORCEMENT PLANNING

     1.    Administrative Order On Consent For Remedial
          Investigation/Feasibility Study In The Matter Of:
          Tyler Refrigeration Pit,  Clark Equipment Company,
          Respondent, Docket No.  III-91-33-DC,  3/28/91.
          P. 200001-200036.   Exhibit A,  Summary Statement of
          Work, and Exhibit  B,  List of Documents,  are attached.

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III.  REMEDIAL RESPONSE PLANNING

     1.    Report:   Preliminary Health Assessment for Tyler
          Refrigeration Pit,  Smyrna, Delaware, prepared by the
          Agency for Toxic Substances and Disease Registry
          (ATSDR),  11/15/88.   P. 300001-300004.

     2.    Report:   Draft Remedial Investigation/Feasibility Study
          (RI/F5)  Work Plan.  Tyler Refrigeration Pit Superfund
          Site.  Smyrna,  Delaware, prepared by Environmental
          Resources Management,  Inc., 7/15/91.  P.  300005-300319.
          A cover  letter is attached.

     3.    Letter to Mr.  David P. Steele,  Environmental Resources
          Management,  Inc., from Ms. Stephanie Dehnhard, U.S.
          EPA,  re:   Comments  on the draft RI/FS Work Plan,
          10/1/91.   P. 300320-300347.  Specific Comments on the
          RI/FS,  a Quality Assurance Project Plan Review
          checklist,  and Appendix A to the checklist are
          attached.

     4.    Memorandum to file  from Ms. Stephanie Dehnhard,  U.S.
          EPA,  re:   Conference call to discuss EPA's comments on
          the RI/FS Work Plan,  10/24/91.   P.  300348-300350.

     5.    Letter to Ms.  Stephanie Dehnhard,  U.S.  EPA,  from Mr.
          David P.  Steele,  Environmental  Resources  Management,
          Inc.,  re:   Summary  of  a conference call concerning the
          draft  RI/FS  Work Plan,  10/29/91.   P.  300351-300354.

     6.    Report:   RI/FS Work Plan,  Tyler Refrigeration Pit
          Superfund Site,  Smyrna.  Delaware,  prepared by
          Environmental  Resources Management,  Inc.,  11/12/91.
          P.  300355-300700.   A cover letter  is attached.

     7.    Letter to Ms.  Stephanie Dehnhard,  U.S.  EPA,  from Mr.
          David  P.  Steele,  Environmental  Resources  Management,
          Inc.,  re:   Information to aid in reviewing the revised
          draft  RI/FS  Work Plan,  12/5/91.  P.  300701-300793.
          A table  summarizing contents of the  Work  Plan and  its
          components and the  response to  EPA's comments on the
          RI/FS  Quality  Assurance Project Plan are  attached.

     8.    Memorandum to  Ms. Stephanie Dehnhard, U.S.  EPA,  from
          Mr.  Jeffrey  A.  Dodd, U.S.  EPA,  re:   Review comments  on
          the revised  Quality Assurance Project Plan,  12/17/91.
          P.  300794-300817.   The Field Filtration Policy for
          Monitoring Well Groundwater Samples  Requiring Metals
          Analysis,  a  Quality Assurance Project Plan Review
          checklist, and Appendix A to the checklist are
          attached.

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9.   Letter to Mr. David P. Steele, Environmental Resources
     Management, Inc., from Ms. Stephanie Dehnhard, U.S.
     EPA, re:  Comments on the revised RI/FS Work Plan,
     2/11/92.  P. 300818-300824.  The comments are attached.

10.  Memorandum to file from Ms. Stephanie Dehnhard, U.S.
     EPA, re:  Conference call to discuss EPA comments on
     the revised RI/FS Work Plan, 3/4/92.  P. 300825-300827.

11.  Letter to Mr. David P. Steele, Environmental Resources
     Management, Inc., from Ms. Stephanie Dehnhard, U.S.
     EPA, re:  Off-site shipment of hazardous substances,
     3/10/92.  P. 300828-300829.

12.  Letter to Ms. Shawne Rodgers,  Environmental Resources
     Management, Inc., from Mr. Jeffrey A. Dodd, U.S. EPA,
     re:  Example copies of EPA's Special Analytical Service
     (SAS)  Requests for analytical methods, technical, and
     quality control requirements,  3/13/92.  P. 300830-
     300847.  Three SAS Requests and an article entitled
     "Procedures in Sedimentary Petrology" are attached.

13.  Report:  RI/FS Work Plan,  Tyler Refrigeration Pit
     Superfund Site.  Smyrna.  Delaware,  prepared by
     Environmental Resources Management,  Inc., 3/16/92.
     P. 300848-301296.

14.  Letter to Ms. Stephanie Dehnhard,  U.S. EPA, from Mr.
     David P. Steele,  Environmental Resources Management,
     Inc.,  re:  Amended version of the RI/FS Work Plan,
     3/16/92.  P. 301297-301385.  The amended version of the
     Work Plan and information concerning the Flooding Basin
     Used for Measuring Infiltration are attached.

15.  Letter to Mr. Jeffrey A.  Dodd, U.S.  EPA, from Ms.
     Shawne M. Rodgers, Environmental Resources Management,
     Inc.,  re:  Environmental  Resources Management,  Inc.'s
     response to EPA's comments on the Quality Assurance
     Project Plan for the RI/FS, 3/25/92.  P. 301386-301416.
     The following are attached:

          a)    Response to EPA Comments Regarding the
               Quality Assurance Project Plan for the
               Remedial Investigation/Feasibility Study at
               the Tyler Refrigeration Pit Superfund Site
               (Revision 1);

          b)    Table  4-1,  Containers,  Preservatives,  and
               Holding Times;

          c)    Figure 13-1,  Corrective Action Form;

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          d)   Table 12-2, Validation  of Vinyl  Chloride  Data
               by Method  8010;

          e)   ERM's Laboratory Data Quality Assurance
               information;

          f)   a Job Summary Sheet  for Laboratory  ID  numbers
               34-001 to  -004;

          g)   Tuning Procedures for Gas Chromatography/Mass
               Spectrometry  (GC/MS) Analyses -  3/90 SOW;

          h)   Table 5-4, Criteria  for Instrument
               Performance Check;

          i)   Laboratory Method Blanks information;

          j)   Sample Analyses information;

          k)   Scoring Qualifier Explanation information;

          1)   two Organic Preaward Evaluation  Sample
               Individual Laboratory Summary Reports;

          m)   two Preaward Performance Evaluation Sample
               Score Sheets.

16.  Memorandum to Ms.  Stephanie Dehnhard,  U.S. EPA, from
     Mr. Jeffrey A.  Dodd, U.S.  EPA, re:  Review comments on
     the second revision of the Quality Assurance Project
     Plan,  3/31/92.   P.  301417-301436.   A Quality Assurance
     Project Plan Review checklist and Appendix A,  Data
     Reduction, Validation,  and Reporting,  are attached.

17.  Letter to Ms.  Stephanie  Dehnhard,  U.S. EPA, from Mr.
     John Gysling,  DNREC, re:  Review of the RI/FS Work Plan
     revision, 5/7/92.   P. 301437-301437.

18.  Letter to Mr.  David P.  Steele, Environmental Resources
     Management,  Inc.,  from Ms. Stephanie  Dehnhard, U.S.
     EPA, re:  Review of the  March 16,  1992 RI/FS work plan,
     6/9/92.  P.  301438-301450.  A memorandum dated March
     31, 1992 regarding review comments on  the second
     revision of the Quality  Assurance  Project Plan, a
     Quality Assurance  Project  Plan Review  checklist,  and
     Appendix A,  Data Reduction,  Validation,  and Reporting,
     are attached.

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19.  Letter to Ms. Stephanie Dehnhard, U.S. EPA, from Mr.
     David P. Steele, Environmental Resources Management,
     Inc., re:  Amended sections to the Work Plan for the
     RI/FS, 6/26/92.  P. 301451-301537.  The amended
     sections are attached.

20.  Letter to Mr. Jeffrey A. Dodd, U.S. EPA, from Ms.
     Shawne M. Rodgers, Environmental Resources Management,
     Inc., re:  Response to EPA comments concerning the
     second revision to the RI/FS Quality Assurance Project
     Plan, 6/26/92.  P. 301538-301543.  The response is
     attached.

21.  Memorandum to Ms. Stephanie Dehnhard, U.S. EPA, from
     Mr. Jeffrey A. Dodd, U.S. EPA, re:  Review comments on
     the second revision of the Quality Assurance Project
     Plan, 7/8/92.  P. 301544-301546.

22.  Letter to Ms. Stephanie Dehnhard, U.S. EPA, from Mr.
     David P. Steele, Environmental Resources Management,
     Inc., re:  Monthly progress report on activities in
     June 1992 for the RI/FS, 7/15/92.  P. 301547-301548.

23.  Letter to Mr. David P. Steele, Environmental Resources
     Management, Inc., from Ms. Stephanie Dehnhard,  U.S.
     EPA, re:  Review of the revised sections of the RI/FS
     Work Plan and the Field Sampling Plan, 7/21/92.
     P. 301549-301552.  A memorandum dated July 8,  1992
     regarding Mr. Jeff Dodd's comments on the revised
     Quality Assurance Project Plan and the Geotechnical
     Analysis Comprehensive Quality Assurance Plan is
     attached.

24.  Letter to Ms. Stephanie Dehnhard, U.S. EPA, from Ms.
     Shawne M. Rodgers, Environmental Resources Management,
     Inc., re:  Revised sections of the Quality Assurance
     Project Plan, 8/5/92.   P. 301553-301553.

25.  Letter to Mr. David P. Steele, Environmental Resources
     Management, Inc., from Ms. Stephanie Dehnhard,  U.S.
     EPA, re:  Review of the response to comments on the
     Quality Assurance Project Plan,  8/13/92.   P. 301554-
     301554.

26.  Facsimile transmittal  sheet to Ms.  Stephanie Dehnhard,
     U.S. EPA, from Mr. Jeff Dodd,  U.S.  EPA,  re:  Review of
     information sent by Environmental Resources Management,
     Inc. in response to EPA's comments on July 8,  1992,
     (undated).   P.  301555-301558.   A memorandum dated July
     8, 1992 regarding review comments on the Quality
     Assurance Project Plan is attached.

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27.  Report:  Trip Report  for RI/FS  Oversicrht  at  the  Tvler
     Refrigeration Pit Site. Smyrna, Delaware, prepared  by
     Dynamac Corporation,  9/30/92.   P.  301559-301717.

28.  Letter to Mr. David L. Jones, Clark Equipment Company,
     from Ms. Lisa Marino, U.S. EPA, re:  Request for
     submittal of an amendment to the RI/FS Work  Plan
     describing the additional investigative tasks necessary
     for the assessment, 12/23/92.   P.  301718-301719.

29.  Report:  Tyler Refrigeration Pit Superfund Site
     Remedial Investigation, Clark Equipment Company.
     prepared by Environmental Resources Management,  Inc.,
     1/19/93.  P. 301720-302004.

30.  Report:  Comments on  the Remedial  Investigation  Report,
     Tyler Refrigeration Pit Site. Smyrna.  Delaware,
     prepared by Dynamac Corporation, 2/10/93.  P. 302005-
     302018.

31.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. David L.
     Jones, Clark Equipment Company, re:  Data, information,
     and circumstances relating to the detection of TCA in
     monitoring well S-l,  2/11/93.  P.  302019-302022.

32.  Letter to Ms. Lisa Marino, U.S. EPA, from Ms. M. Margie
     Zhang, DNREC, re:  Comments and suggestions on the
     draft Remedial Investigation Report, 2/22/93.
     P. 302023-302026.  Figure 1,  Calculation of zone of
     pumping influence,  and a graph of quality v.  time for
     Smyrna Well #1 are attached.

33.  Letter to Ms. Lisa Marino,  U.S.  EPA, from Ms. M. Margie
     Zhang, DNREC, re:  Comments and suggestions on the
     review of Mr. David Jones'  letter dated February 11,
     1993,  3/1/93.  P. 302027-302031.  Figure 1,
     Distribution pattern of TCA concentration, and a graph
     of quality v. time for Smyrna Well #1  are attached.

34.  Letter to Mr. David L. Jones,  Clark Equipment Company,
     from Ms.  Lisa Marino,  U.S.  EPA,  re:  Comments on the
     draft Remedial Investigation Report,  3/4/93.
     P. 302032-302049.  The comments are attached.

35.  Letter to Ms. Margie Zhang,  DNREC,  from Ms.  Lisa
     Marino,  U.S.  EPA,  re:   Review of proposal outlined in
     the letter dated March l,  1993  and request for
     clarification on some  points  made  by DNREC,  3/18/93.
     P. 302050-302051.

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36.  Letter to Ms. Lisa Marino, U.S. EPA, from Ms. M. Margie
     Zhang, DNREC, re:  Answers to questions asked in the
     letter dated March 18, 1993, 4/1/93.  P. 302052-302058.
     Figure 1, Distribution pattern of TCA concentration;
     Figure 19.10, Capture-zone type curves for one, two,
     three and four wells; and handwritten notes on the
     calculation of the pumping rate for a recovery well are
     attached.

37.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. David P.
     Steele, Environmental Resources Management, Inc., re:
     Summary of responses to comments by EPA on the draft
     Remedial Investigation Report,  4/6/93.  P. 302059-
     302078.  The summary of responses to comments is
     attached.

38.  Letter to Ms. Lisa Marino, U.S. EPA, from Sathya
     Yalvigi and Mr. Camille Costa,  Dynamac Corporation, re:
     Review and comments of the PRP's response to EPA
     comments on the draft Remedial Investigation Report,
     4/15/93.  P. 302079-302080.

39.  Memorandum to file from Ms. Lisa Marino,  U.S. EPA,  re:
     Summary of a meeting discussing the hydrogeological
     issues of the site, 4/19/93.  P. 302081-302081.

40.  Letter to Mr. David L. Jones,  Clark Equipment Company,
     from Ms. Lisa M.  Marino,  U.S.  EPA, re:  Ecological
     issues which should be addressed in the final Remedial
     Investigation Report, 4/19/93.   P. 302082-302082.

41.  Memorandum to Ms. Lisa Marino,  U.S.  EPA,  from Ms. Dawn
     A. loven, U.S. EPA, re:   Information on the Baseline
     Risk Assessment,  4/20/93.   P.  302083-302114.   Fourteen
     tables and three toxicity profiles relating to the
     Baseline Risk Assessment  are attached.

42.  Memorandum to file from Ms. Lisa Marino,  U.S.  EPA,  re:
     Dynamac's remaining issue with the Remedial
     Investigation Report concerning the source of TCA/DCE
     contamination, 4/22/93.   P. 302115-302115.

43.  Letter to Ms. Margie Zhang, DNREC, from Ms.  Lisa M.
     Marino,  U.S. EPA, re:  Determination that there is  not
     enough evidence to require additional investigation of
     the former lagoons and concurrence with the submitted
     proposal for remediation  of the plume of  the  TCA/DCE
     contamination, 4/23/93.   P. 302116-302116.

44.  Memorandum to Ms. M.  Margie Zhang, DNREC,  from Ms.  Lisa
     M. Marino,  U.S.  EPA,  re:   Comments on the Baseline  Risk
     Assessment,  5/20/93.   P.  302117-302122.

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45.  Letter to Ms. Lisa M. Marino, U.S. EPA,  from Mr.  David
     P. Steele and Ms. Robin Streeter, Environmental
     Resources Management, Inc., re:  Comments on the  draft
     Baseline Risk Assessment,  5/21/93.  P.  302123-302128.

46.  Letter to Mr. David L. Jones, Clark Equipment Company,
     from Ms. Lisa M. Marino, U.S. EPA, re:   Notice to Mr.
     Clark that the Feasibility Study does not need to be
     presented or developed, 5/26/93..  P. 302129-302129.

47.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. David P.
     Steele, Environmental Resources Management, Inc., re:
     Final edits to the Remedial Investigation Report,
     5/27/93.  P. 302130-302145.  The edits  are attached.

48.  Letter to Mr. David L. Jones, Clark Equipment Company,
     from Ms. Lisa M. Marino, U.S. EPA, re:   EPA's
     incorporation of comments  on the Baseline Risk
     Assessment as an addendum  and inquiry on the comment of
     the Location of Ground Water Sampling Locations,
     6/2/93.  P. 302146-302146.

49.  Memorandum to Ms. Lisa Marino,  U.S.  EPA, from Ms. Dawn
     loven, U.S. EPA, re:  Summary of DNREC's comments and
     EPA's response to the comments,  6/3/93.  P. 302147-
     302148.

50.  Letter to Mr. Robert Davis, U.S. EPA,  from Mr.  Robert
     Foley, U.S. Fish and Wildlife Service,  re:   Technical
     comments on the Ecological Risk Assessment, 6/1/93.
     P. 302149-302151.

51.  Letter to Ms. Lisa Marino,  U.S.  EPA,  from David P.
     Steele,  Environmental Resources Management,  Inc.,  re:
     Preliminary comments on the Ecological Risk Assessment,
     6/2/93.   P. 302152-302155.

52.  Memorandum to Ms. Margie Zhang,  DNREC,  from Mr.  Rob
     Allen, U.S.  EPA,  re:   Review of  the  Ecological  Risk
     Assessment,  6/4/93.   P.  302156-302156.

53.  Memorandum to Mr. Bob Davis,  U.S.  EPA,  from Ms.  Lisa
     Marino,  U.S.  EPA, re:   Comments  on the Environmental
     Risk Assessment,  7/21/93.   P.  302157-302158.  A
     memorandum regarding a review of Environmental
     Resources Management's responses on  the Remedial
     Investigation is attached.
                          10

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54.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. David L.
     Jones, Clark Equipment Company, re:  Summary of
     Environmental Resources Management's comments on the
     Ecological Risk Assessment, 10/7/93.  P. 302159-302167.
     A letter regarding Environmental Resources Management's
     comments on the Ecological Risk Assessment is attached.

55.  Report:  Tyler Refrigeration Ecological Risk
     Assessment, prepared by U.S. EPA, 10/27/93.  P. 302168-
     302178.

56.  Letter to Mr. David L. Jones,  Clark Equipment Company,
     from Ms. Lisa M. Marino, U.S.  EPA, re:  Responses to
     Environmental Resources Management's comments on the
     Ecological Risk Assessment, 10/28/93.  P. 302179-
     302180.

57.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. David P.
     Steele, Environmental Resources Management, re:
     Comments on review of the final Ecological Risk
     Assessment, 11/29/93.  P. 302181-302182.

58.  Report:  Remedial Investigation Report.  Metal Masters
     Food Services Co.. Inc.. Smyrna. Delaware.  Volume I.
     prepared by Groundwater Technology Inc., 6/2/95.
     P.  302183-302459.  A transmittal letter dated August
     14,  1995,  is attached.

59.  Report:  Remedial Investigation Report.  Metal Masters
     Food Services Co.. Inc.. Smyrna. Delaware.  Volume II.
     prepared by Groundwater Technology Inc., 6/2/95.
     P.  302460-303465.

60.  Final Plan of Remedial Action,  Metal Masters Site,
     Smyrna, Delaware, prepared by Department of Natural
     Resources & Environmental Control, 10/95.  P. 303466-
     303480.  A facsimile cover sheet dated October 25,
     1995, is attached.

61.  Proposed Plan,  Tyler Refrigeration Pit Superfund Site,
     2/96.  P.' 303481-303490.

62.  Letter to Ms. Lisa Marino, U.S. EPA, from Mr. Stephen
     F.  Johnson, DNREC, re:  DNREC's concurrence with the
     proposed plan except for EPA's decision to require
     future groundwater monitoring  at the site,  2/7/96.
     P.  303491-303491.
                          11

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63.  Memorandum of agreement between DNREC's Division of Air
     and Waste Management and Division of Water Resources
     for the Tyler Refrigeration Site Ground Water
     Management Zone, 2/96.  P. 303492-303498.  The
     following are attached:

          a)   Attachment 1, site location map;
          b)
          c)
          d)
Attachment 2,
wells;
site layout and monitoring
Attachment 3, VOC concentrations in ground
water;

Attachment 4, tax parcel map showing ground
water management zone boundaries.
                          12

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V.   COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY

     1.   Newspaper article entitled "McAllister, Wilson say site
          clean," Smyrna/Clayton Sun. 5/28/86.  P. 500001-500001.

     2.   Newspaper article entitled "Superfund location
          questioned," Smyrna Times. 2/26/87.  P. 500002-500002.

     3.   Newspaper article entitled "Metal Masters faces EPA in
          pollution responsibility," Wilmington News Journal.
          9/25/90.  P. 500003-500004.

     4.   Letter to Concerned Citizen or Official from Ms. Amy J.
          Burrage, U.S. EPA,  re:  Error contained in September
          1990 fact sheet,  10/5/90.  P.  500005-500005.

     5.   U.S. EPA Fact Sheet,  re:  Tyler Refrigeration Site,
          Smyrna, Delaware, 3/91.   P. 500006-500009.

     6.   EPA Environmental News entitled "EPA Executes a Consent
          Order with Clark Equipment Company to Conduct
          Investigations at the Tyler Refrigeration Superfund
          Site," 4/1/91.  P.  500010-500011.

     7.   U.S. EPA Fact Sheet,  re:  Tyler Refrigeration Site,
          Smyrna, Delaware, 9/91.   P. 500012-500013.

     8.   U.S. EPA Public Notice,  re:  Announcement of a public
          meeting for the Tyler Refrigeration Superfund Site,
          (undated).  P. 500014-500014.

     9.   U.S. EPA Fact Sheet,  re:  Completion of the Remedial
          Investigation for the Tyler Refrigeration Site,  Smyrna,
          Delaware,  10/93.   P.  500015-500016.
                               13

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BIBLIOGRAPHY OF SITE SPECIFIC GUIDANCE DOCUMENTS

1.    Guidance For Conducting Remedial Investigations and
     Feasibility Studies Under CERCLA. prepared by
     OSWER/OERR,  10/1/88.
     OSWER #9355.3-01

2.    CERCLA Compliance With Other Environmental Statutes.
     prepared by J.W. Porter/OSWER,  10/2/85.
     OSWER #9234.0-2

3.    CERCLA Compliance With Other Laws Manual (Draft).
     prepared by OERR, 8/8/88.
     OSWER #9234.1-012
                          14

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