PB96-963917
                                 EPA/ROD/R03-96/238
                                 April 1997
EPA  Superfund
       Record of Decision:
       Austin Avenue Radiation Site,
       Delaware County, PA
       9/27/1996

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                        RECORD  OP DECISION
                  AUSTIN AVENUE RADIATION SITE

                           DECLARATION
SITE NAME AND LOCATION

Austin Avenue Radiation Site
Delaware County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

     This Record of Decision (ROD) presents the selected remedy
for Operable Unit No. 2, ground water,  at the Austin Avenue
Radiation Site, Delaware County, Pennsylvania (Site).   The remedy
was developed in accordance with the requirements of the
Comprehensive Environmental Response,  Compensation, and Liability
Act of 1980, as amended (CERCLA),  42 U.S.C. §§ 9601 et. seq..  and
is consistent with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP),  40 C.F.R. Part 300.   This
remedy decision is based on an Administrative Record compiled for
this Operable Unit (an index to this Administrative Record is
attached).  The^Commonwealth of Pennsylvania concurs with this
remedy.  A copy"of the Commonwealth's concurrence letter is
attached.

DESCRIPTION OF THE SELECTED REMEDY

     No Action.

DECLARATION STATEMENT

     EPA has determined that no remedial action is necessary  to
ensure protection of human health and the environment.   No five-
year review pursuant to Section 121(c)  of CERCLA, 42 U.S.C. §
9621 (c), is required for this remedy since no hazardous
substances or pollutants or contaminants remain at this Operable
Unit above levels that allow for unlimited use and unrestricted
exposure.
                                                        fa
Tnomas C. Voltaggio>-alpecTor                      Date
Hazardous Waste Mana^%ment Division
EPA, Region III
                                             AR300677

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         REMEDIAL ALTERNATIVE  RECORD OF DECISION  SUMMARY
                AUSTIN AVENUE RADIATION SITE
                1.  SITE LOCATION AND DESCRIPTION

     The Austin Avenue Radiation Site consists of approximately
40 properties in the municipalities of Lansdowne Borough, 'Aldan
Borough, East Lansdowne Borough, Darby Borough, Yeadon Borough
and Upper Darby Township, in Delaware County, Pennsylvania.  All
of the properties are within a two-mile radius of the
intersection of South Union Avenue and Austin Avenue in Lansdowne
Borough (see Figure 1).  Situated at the northwest corner of that
intersection is a lot which was the site of the former W.L.
Cummings Chemical Company (Cummings) warehouse.  From
approximately 1915 to 1922,  Cummings conducted a radium
processing operation at the warehouse.  The Cummings operation is
the suspected source of radium and thorium-contaminated tailings
which contaminated the other Austin Avenue Radiation Site
properties.  EPA also suspects that uranium-contaminated waste
waters were discharged to'the soil via cesspools near the former.
warehouse.
             .,' *=''
     Included-in EPA's evaluation of the Site was an area of
ground water, suspected of having been contaminated with Site-
related radionuclides, located at and near the site of the former
Cummings processing facility.

                         2.   SITE HISTORY

     The history of the Austin Avenue Radiation Site is
intertwined with that of a former Superfund site, the Lansdowne
Radiation Site,  which was a twin house located at 105-107 East
Stratford Avenue in Lansdowne, Pennsylvania.  A former University
of Pennsylvania professor,  Dr. Dicran Hadjy Kabakjian, owned the
house at 105 East Stratford Avenue, and also worked for Cummings
while the company conducted its radium refining operation at the
warehouse.

     While a professor at the University of Pennsylvania, Dr.
Kabakjian developed a crystallization process for the refining of
radium, and then sold the process to Cummings.  He worked as a
consultant to Cummings until 1924,  when he set up his own radium
processing business in the basement of his home at 105 East
Stratford Avenue.  The major product of his home business was
radium-filled implant needles which were sold to medical
professionals for the treatment of cancer.

     The radium refining process developed by Dr. Kabakjian and
practiced at Cummings' warehouse used a yellowish, shale-like
material known as carnotite ore which was mined from deposits in
Utah and Colorado.  One ton of carnotite ore could produce
approximately one-tenth of a grain of radium.  During Cummings'
                                                AR300678

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years of operation at the Union Avenue warehouse,  its radium
output is estimated to have been three grams per year. The radium
extraction process generated waste tailings.  These tailings
contained two residual radionuclides--radium 226 and thorium 230.
The tailings, which were sand-like waste materials, were either
given or sold to local building contractors and others.  During
the seven years that Cummings operated at the warehouse, those
persons used the tailings irf mortar, stucco, plaster, and
concrete used to build or renovate houses in the area.  The ore
processing also produced waste liquids containing uranium 238.
These liquids were apparently dumped into cesspool systems in the
immediate vicinity of the Cummings facility.

     In 1963, the Pennsylvania Department of Health inspected the
house at 105 East Stratford Avenue and found extremely high
levels of radiation.  In 1964, the U.S. Public Health Service and
the Pennsylvania Department of Health, aided by the U.S. Air
Force, attempted to decontaminate the house.  In 1984, sampling
and monitoring of the structure by EPA and the Pennsylvania
Department of Environmental Resources  (PADER) showed high
residual radiation contamination levels.  An extensive evaluation
of the house wag? conducted by the U.S. Department of Energy's
Argonne National Laboratory.  In 1986, EPA issued a Record of
Decision (ROD) which called for the dismantlement .and offsite
disposal of the house and contaminated soils.  It was at this
time that the location of other tailings from the operation
became an issue as the government suspected that the tailings
would contain residual radiation contamination.  No records
relating to the ultimate disposition of those tailings were
available'.

     In May 1991, PADER visited the South Union Avenue/Austin
Avenue location to monitor for radon because radiation
contamination had previously been discovered in the back yard of
133 Austin Avenue, the property adjacent the warehouse.  During
this visit, radiation survey instruments indicated the presence
of significant levels of radioactive contamination within the
house at that location.  PADER obtained soil and wipe samples for
further analysis.

     On June 7, 1991, PADER notified EPA of its findings and
requested*assistance.  A joint PADER-EPA site assessment
confirmed the presence of radiological contamination at 133
Austin Avenue at levels that warranted immediate action.  Based
on the data provided by the PADER analyses and the results of the
joint survey, the U.S. Agency for Toxic Substances and Disease
Registry (ATSDR) recommended the relocation of the residents of
the house at 133 Austin Avenue and the dismantlement of the
warehouse.

     On June 19, 1991, a team of radiation specialists from the
EPA National Air and Radiation Environmental Laboratory (NAREL)
                                               AR300679

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                               • 3

in Montgomery, Alabama, arrived to conduct an assessment.  The
warehouse and the adjacent residential dwelling (133 Austin
Avenue) were found to be heavily contaminated with radioactive
materials.  In November and December of 1991, EPA used a special
radiation-detection van to conduct a 12.5 square mile search in
Delaware County and a small portion of the adjacent City of
Philadelphia.  EPA also conducted radiological surveys of.the
properties which were suspected to be contaminated.  The EPA
testing showed that approximately 40 properties within a two-mile
radius of the site of the former Cummings radium processing
facility had become contaminated with radium 226 and thorium 230.

     EPA conducted Removal Actions at a number of the
contaminated properties.  Removal Actions were selected for those
properties that posed an immediate endangerment and/or which
could be addressed using Removal Action authorities within the
constraints of available funding.  These Removal Actions included
the temporary relocation of residents of several of the
properties; complete dismantlement of the warehouse at South
Union and Austin Avenues;'dismantlement of 133 Austin Avenue;
soil removals at a number of the properties; and removals of
plaster, -stucco^-and concrete at selected properties.  The
Removal Actions resulted in the complete cleanup of 19 of the
identified properties.  Relocated residents of those properties
returned to their homes following the Removal Action cleanups.

     On July 1, 1993, EPA issued a Proposed Remedial Action Plan
describing five alternatives considered as possible remedial
actions at the Site.  That Plan also designated EPA's preferred
alternative for each of the properties.  In response to that
Plan, EPA received numerous letters from citizens and public
officials requesting that certain alternatives be considered or
reconsidered.  In addition, EPA gathered additional information
useful in the evaluation of the remedial alternatives for the
properties.  As a result, a Revised Proposed Remedial Action Plan
was developed and was offered for public comment on March' 2,
1994.  Subsequent to that second Plan> a Record of Decision (ROD)
was issued on June 27, 1994.  That ROD delineated the selected
remedies for buildings and soil, but deferred any decision on
Site ground water to a later Record of Decision.

     In April 1994, an abbreviated study of the ground water was
conducted at the Site.  During March and April of 1995, EPA
conducted more extensive soil and ground water sampling in the
vicinity of the former Cummings facility to characterize the
extent, degree, and impact of the Site-related contamination and
for the purpose of developing and evaluating effective remedial
alternatives.  A report on this study was finalized in July 1995.
                                             AR300680

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                   3.  COMMUNITY PARTICIPATION

     The Proposed Remedial Action Plan for this Operable Unit,
together with documents supporting that plan (the administrative
record file),  were placed by EPA in a public information
repository located near the Site at the Lansdowne Borough Public
Library, Lansdowne, Pennsylvania and have been available for
public review since July 7, 1996.  In addition, Site-related
documents have been maintained at the Region III office.  Notice
of the availability of these documents and a brief description of
EPA's Proposed Remedial Action Plan was published in the
PHILADELPHIA INQUIRER and the DELAWARE COUNTY DAILY TIMES on July
7, 1996.  In both the Proposed Remedial Action Plan and the
newspaper notifications, the public was advised of the
opportunity for a public meeting.  A public comment period was
held from July 7, 1996 to September 5, 1996.  A public meeting
was held on July 31, 1996 at the Lansdowne Borough Hall,
Lansdowne, Delaware County, Pennsylvania.  Approximately fifteen
persons attended that meeting.  EPA received three letters in
response to the Proposed Remedial Action Plan.

     The community participation procedures outlined above were
conducted in compliance with sections 113(k) and 117 of CERCLA,
42 U.S.C. §§ 9613(k) and 9617.  EPA has had extensive contact
with community members from the commencement of response actions
at the Site through the present, and has carefully considered all
community concerns.

            4.   SCOPE AND ROLE OP THE RESPONSE ACTION

     This Record of Decision addresses the remedial alternative
selected for ground water near the former Cummings processing
facility  (Operable Unit No. 2).  It was only in the immediate
vicinity of the former processing facility that Site-related
ground water contamination was considered to be possible.  That
area includes small portions of both Upper Darby Township and the
Borough of Lansdowne in Delaware County, Pennsylvania.

               5.  SUMMARY OF SITE CHARACTERISTICS

     Geologically, the Austin Avenue Radiation Site is located in
the piedmont physiographic province.  The portion of the Site in
the vicinity of the former Cummings processing facility is
underlain by approximately 10 to 20 feet of soil and
unconsolidated material overlying gneiss and schist rock.  The
topography is generally level, with no obvious drainage
direction.  Drainage has been altered by storm drains and
property development.  The area is essentially urban residential
and commercial/industrial.  A large percentage of the land
surface in the area around the former Cummings facility is paved
or is built upon.
                                              AR30068I

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                    6.  SUMMARY OF SITE RISKS
              *
     EPA's investigation of the former Cummings facility, during
the Removal Action, included soil borings and sample analysis of
soils for Site-related radionuclides during February and June
1993.  Ground water was not sampled as part of that effort.  A
study of the ground water was conducted in April 1994 under the
auspices of the U.S. Army Co*rps of Engineers as part of the
Remedial Design process.  For the purposes of that study, four
(4) borings were made into the soil near the former Cummings
facility.  'This effort revealed contamination in excess of
proposed and existing Maximum Contaminant Levels (MCLs) for
uranium, radium and thorium in the immediate vicinity of the
former Cummings facility. [MCLs are the maximum concentrations of
drinking water contaminants permissible in public water supplies
under Section 1412 of the federal Safe Drinking Water Act, 42
U.S.C. § 300g-l, and federal regulations at 40 C.F.R. Part 141,
Subpart B.]  Specifically, the field investigation report
documented radium 226 concentrations ranging to 62 picocuries per
liter (pCi/1); total uranium concentrations ranging to 3640
pCi/1; and a thorium 230 concentration of 18 pCi/1 in the ground
water.  Further^investigation was required, in part to determine
if the ground- water samples that had been collected were
representative of the ground water conditions in that area.

     In late March and early April of 1995, EPA conducted a field
investigation in the vicinity of the former Cummings processing
facility in part to address concerns raised by the results of the
previous sampling efforts, and to determine the impact of Site-
related radionuclides on the ground water.  During that field
work, 17 soil bore holes and temporary well points were installed
(Figure 2).  Ground water samples were obtained from 16 of these
locations  (sampling location SB-10 yielded no'ground water).   The
samples were analyzed, both non-filtered and filtered, for Site-
related radionuclides.  Non-filtered samples showed slightly
higher levels of radionuclides than the filtered samples.
Filtered samples are believed to be the most representative of .
the ground water that moves in the aquifer.  This is because
filtering removes suspended matter, such as soil particles,
leaving only dissolved materials in the water samples.  These
filtered samples were used for risk assessment purposes.

     No filtered ground water sample obtained during the
investigation exceeded the MCL for any of the Site-related
radionuclides.  The proposed MCL for uranium in drinking water is
30 picocuries per liter  (pCi/1).  The.highest uranium
concentration found in a filtered ground water sample during the
investigation was 9.1 pCi/1 in ground water obtained from
sampling location SB-6  (Table 1).  The MCL for combined radium
226 and radium 228 is 5 pCi/1.  The highest radium 226
concentration detected in a filtered ground water sample was 1.3
pCi/1 obtained from sampling location SB-14. (Radium 228 is much
                                          AR300682

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more rare than radium 226,  and although not analyzed for
specifically, would, in any event,  contribute insignificantly to
the total radium concentration.)   There is  no current standard
for thorium in drinking water; however,  the MCL for alpha
emitters (of which thorium 230 is one),  excluding radon and
uranium, is 15 pCi/1.  No filtered ground water sample exceeded
this limit for thorium 230.  The differences in radionuclide
concentrations between the April 1994 samples and the April 1995
samples are very likely due to natural attenuation of these
radioactive elements, and to the soil flushing which resulted
when the former Cummings facility (the warehouse)  and the% house
(formerly)  at 133 Austin were dismantled, thereby leaving a
substantial area of soil open to the penetration of
precipitation.

     There are no known users of the ground water aquifer in the •
area covered by this investigation.   All drinking water in the
area is furnished via waterline from municipal water sources
which are located miles from the Site.


         7.  Description of The "No Action" Alternative

     The No Action alternative, which EPA is required to consider
under the NCP, involves no remedial action  for the ground water.
This alternative would not require the expenditure of additional
funds for remedial action at the Site for ground water
remediation.  A "No Action" alternative generally requires no
consideration of applicable or relevant and appropriate
requirements  (ARARs) unless EPA has selected a remedial action
for a different portion  (e.g., operable unit) of a site.  As EPA
has in fact previously selected a remedial  action for the non-
ground water portion of the Austin Avenue Site (the June 27, 1994
Record of Decision), the Agency identifies  the following as
ARARs:

     •  Maximum Contaminant Levels established under the Safe
        Drinking Water Act, 42 U.S.C. § 300-1, for radium 226,
        radium 228, and gross alpha particle radioactivity in
        community water systems  (40 C.F.R.  § 141.15).  The ground
        water at the Site does not exceed the MCLs for these
        contaminants.

     •  The Commonwealth of Pennsysvania, Department of
        Environmental Protection, has identified Pennsylvania's
        Land Recycling and Environmental Remediation Standards
        Act  (Act 2 of 1995) as an ARAR.  EPA has determined that
        Act 2 does not, under the circumstances at the Site,
        impose any requirements that are more stringent than the
        federal standards.

     ARARs for the remainder of the Site were addressed in the
                                            AR300683

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June 27, 1994 ROD.

     Because EPA's investigation of ground water revealed no
risks to human health or welfare or the environment, other
alternatives were not evaluated.

                   8.  RESPONSIVENESS SUMMARY

     In compliance with sections 113(k) and 117 of CERCLA, 42
U.S.C. §§ 9613(k) and 9617, the Proposed Remedial Action Plan for
Operable Unit No. 2  (ground water) and the Administrative Record
file were placed for public inspection at the Lansdowne Borough
Public Library,  Lansdowne, Delaware County, Pennsylvania.  An
announcement of the availability of these documents was placed in
two locally-available newspapers on July 7, 1995, and a public
comment period was held from July 7, 1996 through September 5,
1996.  Additionally, a public meeting was held on July 31, 1996
at the Lansdowne Borough Hall, Lansdowne, Delaware County,
Pennsylvania.

     EPA received three letters responding to the Proposed
Remedial Actio.h^Plan during the public comment period.  The
following is a summary of the significant comments to the
Proposed Remedial Action Plan and EPA's responses to those
comments:

Comment:  Three commenters, one verbally during the public
meeting and two by letter, requested that the public comment
period for the Proposed Remedial Action Plan be extended.

Response:  EPA extended the public comment period for an
additional 30 days.

Comment:  A commenter suggested that a thorough understanding of
the local hydrogeology is necessary in order to support the No
Action alternative.

Response:  EPA acknowledges that the understanding of
hydrogeologic conditions at the Site is incomplete.  However,
EPA's No Action alternative is based upon the finding that
maximum contaminant levels ("MCLs") for dissolved Site-related
radionuclides in the ground water have not been exceeded.  EPA
has concluded that no unacceptable risk to potential ground-water
users would result from ingestion of ground water containing the
levels of the Site-related radionuclides found during the field
investigation.  Additional investigation of the Site hydrogeology
would not produce information useful in evaluating risks
associated with this Site.

Comment:  A commenter suggested that the downward vertical
component of ground water might be significant.
                                             AR300681*

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                                8

Response:  The water table at the Site is at approximately 12
feet and is found in unconsolidated weathered material.   The
weathered material overlies the gneissic bedrock,  which was
generally encountered during drilling at about 16  to 24  feet.
It. is EPA's conclusion that ground-water movement  is
predominantly along this interface, with minimal vertical
migration.  It is likely that horizontal flow through the'
saprolite is the major compo'nent for ground-water  movement.  A
vertical component would involve ground-water movement from the
more permeable saprolite into the gneiss bedrock.   Limited
migration of contaminants is expected in a horizontal or vertical
direction because of adherence to clay material present  at the
site.

Comment:  A' commenter suggested that an understanding of why the
1994 investigation appeared to indicate elevated levels  of Site-
related radionuclides, as compared to the 1995 field
investigation, is necessary.

Response:  Several suggestions have been considered by EPA to
explain the difference in contamination levels between the
studies.  The,^explanation may involve a difference in sampling
method and sample quality or a change because of hydrogeologic
conditions.  Sampling methods were not adequately recorded during
the 1994 investigation; turbidity was not evaluated. It  is likely
that these initial samples contained high quantities of
particulates.  EPA believes it is also possible that the reduced
levels of contaminants in the 1995 field investigation samples
may have resulted because of soil flushing, dilution, and natural
attenuation over the one-year period between the sampling events.
These processes would be enhanced by the demolition of the former
warehouse and creation of a local area for recharge.

Comment:  A commenter expressed concern for worker exposure to
ground water and to the discharge of ground water to sewers or
surface waters.

Response:  The ground water poses no unacceptable  risks from
Site-related radionuiclides.

Comment:  A commenter expressed concern that the unfiltered
sample analytical results for radium from the 1995 field
investigation might indicate that EPA's sampling effort found'the
trailing edge of a contaminant plume.

Response:  EPA relies upon the results of filtered, rather than
unfiltered, samples to indicate contaminant levels in ground
water.  Although two somewhat elevated concentrations of radium
were found in unfiltered samples to the southeast, filtered
samples did not support this pattern.  Based on the data, EPA
concludes that the occurence of Site-related radionuclides
exceeding MCLs beyond the area sampled during the 1995 field
                                            AR300685

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investigation is not likely.

Comment:  A commenter expressed concern  that the results of
analyses  for uranium in unfiltered samples show lower
concentrations near the former Cummings warehouse  site than
further away.

Response:   In comparing uranium concentrations for samples
collected near the former Cummings warehouse  for the purposes of
the 1995  field investigation,  it should be noted that uranium was
not detected in either filtered or unfiltered ground water
collected from the borehole nearest the former warehouse.  In
filtered and unfiltered samples,  uranium  concentrations ranged
from non-detectable in several locations  to the highest
measurement of 9.1 pCi/L;  no pattern is evident.
                                           AR300686

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FIGURES
          AR300687

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            FIGURE 2
    WELL POINT LOCATION MAP
AUSTIN AVENUE RADIATION SITE
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           JULY 1095      i

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TABLE
         AR300690

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                           TABLE 1
         Radiological Analyses—Filtered Ground Water
                 Austin Avenue Radiation Site
                          July  1995
Sample
Location
SB- IF
SB-2F
SB-3F
SB-4F
SB-5F
SB-6F
SB-7F
SB-8F
SB-9F
SB-10F
SB-11F
SB-12F
SB-13F
SB-14F
SB-15F
SB-16F
SB-17F
U-238
(pCi/L)
• n/a
027 ± 0.12
0.41 ± 0.14
3.0 ± 0.4
n/a
4.1 ± 0.6
0.25 ±0.15
0.11 ± 0.07
0.13 ± 0.03
U-234
>
(pCi/L)
n/a
022 ± 0.11
0.79 ± 020
3.5 ±0.5
n/a
5.0 ± 0.6
037 ± 0.17
0.11 ± 0.07
0.13 ± 0.10
Th-230
(PCW.)
0.12 ± 0.10
<0.1
<0.06
<0.07

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STATE CONCURRENCE LETTER
                 ftR300692 '

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  30iriui  iv-ui
                       nun i / twr
                                                    ILU-01UOJ/0140
                                                                                     r. uiu
                           Pennsylvania  Department of Environmental Protection

                                            Lee Park, Suite 6010
                                               555 North Lane
                                          Conshohocken, PA  19428
                                             September 26,1996
 Southeast Regional Office
 Mr. Thomas Voitaggio
 Hazardous Waste Division Director
 US EPA Region m
 841 Chestnut Building
 Philadelphia, PA 19107
                                                      610-832-6028
                                                 Fax 610-832.6022
                                                 Re:   Record of Decision.
                                                       Operable Unit No. 2 - Ground water
                                                       Austin Avenue NPL Site
                                                       Delaware County
                                                       Pennsylvania
 Dear Mr. Voitaggio,

     The Operable Unit No. 2 (OU2 - ground water) Record of Decision (ROD) for the Austin Avenue
 NPL Site, received by this office September 9,1996. has been reviewed by the Pennsylvania Department
 of Environmental Protection (the "Department").

       The US Environmental Protection Agency's ("EPA") selected remedy for ground water at the
 site is no action.

     The Department hereby concurs with the US Environmental Protection Agency's ("EPA") proposed
 remedy with the following conditions:

     *     The Department reserves its right and responsibility to take independent enforcement actions
           pursuant to state law.
           This
           pursuant to CERCLA Section 104 (c) (3), 42 U.S.C. Section 9604 (c) (3).
nee with the selected remedial action is not intended to provide any assurances
V -ciwl Opportunity Amnrumr *n>nn tmpiotrr
 SEP-27-1996  10:07
                 Illlp w»
                                     6108326143
                                                                       • n\ta on b<\ilcd Pipff
                                                 &R300693
                                                                      95*
                                                               P. 02

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Mr. Thomas Voltaggio                      • 2 •                         September 26,1996
       This letter documents the Department's position with regard to the EPA's chosen remedy for the
ground water Operable Unit (OU2) at the Austin Avenue NFL Site and requests that it be made pan of
the Administrative Record. Should you have* any questions regarding the matter of this letter, please feel
free to contact me at this office.

                                                 Sincerely,

                                                           "  tf.  C&M&r

                                                 Carol R. Collier
                                                 Regional Director
                                                 Southeast Regional Office

cc    Mr. Becker
       Mr.Beitler
       Mr. Danyliw  i.V**7
       Mr.Sheehan •"".'•
       Mr.Ung
       Mr. Hess
       Mr. Hartzell
       Ms.Tremont
       Re 30 QCAL)270.11
   SEP-27-1996  10:08                  6108326143                ft R ^ Ms*             P.03

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ADMINISTRATIVE RECORD INDEX
                      AR300695

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                   AUSTIN AVENUE RADIATION OU2
                   ADMINISTRATIVE RECORD FILE * **
                       INDEX OF DOCUMENTS

III.  REMEDIAL RESPONSE PLANNING

     1.    U.S.  EPA sampling plan for groundwater uranium
          contamination at the  Austin Avenue site,  6/94.
          P.  300001-300003.

     2.    Preliminary Report of Analysis,  prepared by Teledyne
          Brown Engineering,  6/3/94.   P.  300004-300007.

     3.    Memorandum to Mr.  Thomas  C.  Voltaggio, U.S.  EPA,  from
          Mr. Victor J.  Janosik,  U.S.  EPA,  re:   Summary  of  ground
          water analysis at the Austin Avenue Radiation  Site,
          6/14/94.   P.  300008-300009.   A  hand-drawn map  of  the
          site area is attached.

     4.    Letter to Mayor John  J. Rankin,  Borough  of Lansdowne,
          from Mr.  Victor J.  Janosik,  U.S.  EPA,  re:   Request  for
          Borough of Lansdowne's assistance in locating  any
          ground water wells that exist in the vicinity  of  the
          site,  6/20/94.   P.  300010-300011.

     5.    Letter to Mayor Margaret  Murdoch,  Upper  Darby  Township,
          from Mr.  Victor J.  Janosik,  U.S.  EPA,  re:   Request  for
          Upper Darby Township's assistance in locating  any
          ground water wells that exist in the vicinity  of  the
         .site,  6/20/94.   P.  300012-300013.

     6.    Memorandum to the file from Mr.  Victor J.  Janosik,  U.S.
          EPA,  re:   Summary a June  21,  1994,  meeting held in  the
          Borough of Lansdowne  to discuss  uranium  contamination
          in  the vicinity of the former Cummings processing
          facility,  6/21/94.  P.  300014-300015.  A sign-in  sheet
          for the meeting is attached.

     7.    Memorandum to the file from Mr.  Victor J.  Janosik,  U.S.
          EPA,  re:   Summary of  a June  23,  1994,  meeting held  in
          Upper Darby Township  to discuss  uranium  contamination
          in  the vicinity of the former Cummings processing
         .facility,  6/23/94.  P. 300016-300016.
*    Administrative Record File available  7/5/96,  updated 10/3/96.

**   This index hereby incorporates by reference the Administrative
     Record File  for  the Austin Avenue Radiation  Site OU1.
                                       AR300696

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8.   Letter to Mr.  Michael Pfarr,  U.S.  Army Corps of
     Engineers (USAGE),  from Mr.  Gregory Daloisio,  Roy F.
     Weston, Inc.,  re:   Transmittal  of  the preliminary draft
     field investigation report,  documenting the results of
     field investigation at the warehouse property,  6/23/94.
     P.  300017-300017.

9.   Letter to Mr.-Victor J. Janosik, U.S. EPA,  from Mr.
     R.J. Robinson,  Borough of Lansdowne,  re:   Response to
     request for ground  water well locations in the Borough
     of Lansdowne,  6/23/94.  P. 300018-300018.

10.  Letter to Mr.  Greg  Powell, U.S.  EPA,  from Mr.  Victor J.
     Janosik,  U.S.  EPA,  re:  Transmittal of U.S. EPA's
     Record of Decision  (ROD)  for the Austin Avenue
     Radiation Site and  the preliminary draft field
     investigation report, 7/7/94.  P.  300019-300020.

11.  Report:  Field Investigation Report for Environmental
     and Geotechnical Sampling at Warehouse Property Austin
     Avenue Radiation Site, prepared by Roy F.  Weston, Inc.,
     9/94.  P. 300021-300102.

12.  Memorandum to Mr. Bill Belanger, U.S. EPA,  from Mr.
     John Griggs, U.S. EPA, re:   Transmittal of
     radiochemical results .for a  water  sample,  9/9/94.
     P.  300103-300106.   The results  are attached.

13.  Report:  Draft Quality Assurance Work Plan for the
     Austin Avenue Radiation Site. 1/6/95.  P.  300107-
     300124.  A transmittal letter and  a January 10,  1995,
     EPA routing and transmittal  slip are attached.

14.  Letter to Mr.  Victor J. Janosik, U.S. EPA,  from Ms.
     Dawn A. loven,  U.S.  EPA,  re:  Transmittal  of comments
     pertaining to the draft work plan,  1/22/95.'  P.  300125-
     300126.

15.  Memorandum to Ms. Leanne Nurse,  Mr. Anthony Dappalone,
     and Ms. Barbara Rudnick,  U.S. EPA,  from Mr. Victor J.
     Janosik,  U.S.  EPA,  re:  Notification of the February 2,
     1995, start date for the ground water contamination
    ,investigation,  1/27/95.  P.  300127-300128.   A site map
     is attached.

16.  Report:  Quality Assurance Work Plan for the Austin
     Avenue Radiation Site. 2/9/95.   P.  300129-300150.  A
     February 9,  1995, transmittal letter is attached.
                                AR300697

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17.  Memorandum to Mr.  Victor J.  Janosik,  U.S.  EPA,  from Mr.
     George R. Prince,  U.S.  EPA,  re:   Transmittal of the
     preliminary report on Environmental Response Team (ERT)
     activities at the  Austin Avenue  Radiation  Site 5/30/95.
     P. 300151-300152.   A June 2,  1995,  transmittal
     memorandum is attached.

18.  Report:  Austin Avenue  Radiation Site Soil and
     Groundwater Sampling Results.  7/95.  P.  300153-300554.
     An August 1,  1995, transmittal letter,  an  August 1,
     1995, transmittal  memorandum,  and a September 12,  1995
     memorandum to the  file  noting that PADEP does not have
     any comments on the report are attached.

19.  Memorandum to Mr.  Victor J.  Janosik,  U.S.  EPA,  from Ms.
     Barbara Rudnick, U.S. EPA,  re:  Transmittal of comments
     pertaining to the  Austin Avenue  Radiation  Site
     preliminary ground water report,  7/6/95.  P. 300555-
     300557.  A July 11, 1995, facsimile transmittal page
     and a June 2, 1995, transmittal  letter are attached.

20.  Memorandum to Mr.  Victor J.  Janosik,  U.S.  EPA,  from Mr.
     Bill Belanger,  U.S. EPA,  re:   Review of  the Austin
     Avenue Radiation Site final  report, 9/11/95.
     P. 300558-300562.   A September 5,  1995,  memorandum,  a
     September 1,  1995, memorandum, and a September 12,
     1995, memorandum to the  file  are attached.

21.  Memorandum to Mr.  Victor J.  Janosik,.U.S.  EPA,  from Ms.
     Dawn A. loven,  U.S. EPA,  re:   Recommendation that
     ground water remediation at  the  Austin Avenue Radiation
     Site is unnecessary,  10/12/95.  P.  300563-300564.

22.  Letter to Mayor Margaret M.  Murdoch,  Upper Darby
     Township, from Mr. Victor J.  Janosik,  U.S.  EPA,  re:
     Transmittal and summary  of the final  soil  and
     groundwater sampling results  report,  10/17/95.
     P. 300565-300565.

23.  Letter to Mayor John J.  Rankin,  Borough  of  Lansdowne,
     from Mr. Victor J. Janosik, U.S.  EPA,  re:   Transmittal
     and summary of  the final soil  and ground water  sampling
    .results report,  10/17/95. P.  300566-300566.
                                 AR300698

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24.   Memorandum to U.S.  EPA Region III Reviewers from Mr.
     Victor J. Janosik,  U.S.  EPA,  re:   Trarismittal of a
     draft Proposed Remedial Action Plan (PRAP)  for the
     ground water operable unit of the Austin Avenue
     Radiation Site and request for comments, 4/23/96.
     P.  300567-300580.   The following are attached:

          a)   the draft PRAP;

          b)   a May 1,  1996,  memorandum containing Ms.  Dawn
               loven's  comments on the PRAP;

          c)   a May 8,  1996,  memorandum containing Mr.  Bill
               Belanger's comments on the PRAP;

          d)   a May 10,  1996,  memorandum containing Ms.
               Barbara  Rudnick's comments on  the draft  PRAP,-

          e)   a May 13,  1996,  memorandum containing Mr.
               David Cooper's comments on the draft PRAP.

25.   Letter to Mr. Donald Becker,  PADEP,  from Mr.  Victor J.
     Janosik,  U.S. EPA,  re:  Transmittal of the  draft PRAP
     and request for comments,  4/23/96.  P. 300581-300581.

26.   Letter to Mr. Victor J.  Janosik,  U.S.  EPA,  from Mr.
     Kevin J.  Hess, PADEP,  re:   Notification  of  PADEP's
     agreement with U.S.  EPA's selection of the  no action
     alternative for ground water,  5/22/96.  P.  300582-
     300582.

27.   Proposed Remedial  Action Plan,  Austin Avenue Radiation
     Site, 7/96.  P. 300583-300591.

28.   Minutes of a public meeting held on July 31,  1996,  at
     the Lansdowne Borough Hall,  12  East Baltimore Avenue,
     Lansdowne, Pennsylvania,  to discuss the  PRAP for ground
     water at the site,  7/31/96.   P.  300592-300659.

29.   Letter to Mr. Michael Coll,  from Mr.  Victor J. Janosik,
     U.S.  EPA, re:  Transmittal of an excerpt from the  Final
     Report, Austin Avenue Site,  Soil and Ground Water
    ,Sampling Results,  regarding background concentrations
     of  radionuclide, 8/2/96.   P.  300660-300662.  The
     excerpt is attached.

30.   Letter to Ms. Carrie Deitzel,  U.S. EPA,  from Mr. Mark
     DuFrayne, Lansdowne Borough Council,  re: Request  for
     an  extension to the public comment period until October
     7,  1996,  8/5/96.   P.  300663-300663.
                                   AR300699

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31.  Letter to Mr. Mark DuFrayne, Lansdowne Borough Council,
     from Ms. Carrie Deitzel, U.S. EPA, re:  Grant of an
     extension to the public comment period until midnight,
     September 5, 1996, 8/6/96.  P. 300664-300664.

32.  Letter to Ms. Carrie Deitzel, U.S. EPA,  from Mr. J.
     Anthony Sauder and Mr. James Gallagher,  Pennoni
     Associates, Inc., re:  Comments on behalf of the
     Borough of Lansdowne regarding proposed remediation
     activities at the site, 8/6/96.  P. 300665-300667.

33.  Letter to Mr. Michael McCabe, U.S. EPA,  from Mr.
     Michael Burns,  Southeastern Pennsylvania Transportation
     Authority  (SEPTA), re:  Request for an extension to the
     public comment period until August 31, 1996, and
     request for a meeting between SEPTA and U.S. EPA,
     8/7/96.  P. 300668-300669.

34.  Letter to Mr. Victor J. Janosik,  U.S.  EPA,  from Mr.
     Kevin J. Hess,  PADEP, re:   Comments regarding the  Draft
     ROD for ground water for Austin Avenue Operable Unit 2
     (OU2), 8/8/96.   P. 300670-300671.
35.  Letter to Mr. Michael Burns,  SEPTA,  from Mr.  Victor J.
     Janosik, U.S. EPA,  re:  Notification of the extension
     to the public comment period and agreement to schedule
     a meeting between Mr. David Turner,  U.S.  EPA,  and Mr.
     John Rankin,  SEPTA,  8/20/96.   P.  300672-300673.

36.  Letter to Mr. Kevin Hess,  PADEP,  from Mr.  Victor J.
     Janosik, U.S. EPA,  re:  Transmittal  of the Record of
     Decision (ROD)  for the site,  9/6/96.   P.  300674-300674.

37.  Letter to Mr. Thomas Voltaggio,  U.S.  EPA,  from Ms.
     Carol Collier,  PADEP, re:   Comments  regarding the ROD,
     9/26/96.  P.  300675-300676.

38.  Record of Decision,  Austin Avenue Site OU2,  9/27/96.
     P. 300677-300702.

39.  Letter to Mayor Daniel Devlin,  Darby Borough,  from Ms.
    t Carrie Deitzel, U.S. EPA,  re:   Transmittal of the PRAP
     for the site  and a copy of the text  of a July 7,  1996,
     advertisement announcing the July 31,  1996,  public
     meeting, (undated).   P.  300703-300703.

40.  Letter to Mr. Mark Dufrayne,  Lansdowne Borough Council,
     from Ms.,Carrie Deitzel,  U.S.  EPA, re:  Transmittal of
     the PRAP for  the site and a copy of  the text  of  a July
     7, 1996, advertisement announcing the July 31, 1996,
     public meeting, (undated).  P.  300704-300704.
                                      AR300700

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41.  Letter to Mayor Margaret Murdoch, Upper Darby Township,
     from Ms.  Carrie Deitzel, U.S. EPA, re:  Transmittal of
     the PRAP for the site  and a copy  of  the text of a July
     7, 1996,  advertisement announcing the July 31, 1996,
     public meeting,  (undated).  P. 300705-300705.

42.  Letter to Mayor John J. Rankin, Borough of Lansdowne,
     from Ms.  Carrie Deitzel, U.S. EPA, re:  Transmittal of
     the PRAP for the site  and a copy  of  the text of a July
     7, 1996,  advertisement announcing the July 31, 1996,
     public meeting,  (undated).  P. 300706-300706.

43.  Letter to Mr.  F. Raymond Shay, Upper-Darby Township,
     from Ms.  Carrie Deitzel, U.S. EPA, re:  Transmittal of
     the PRAP for the site  and a copy  of  the text of a July
     7, 1996,  advertisement announcing the July 31, 1996,
     public meeting,  (undated).  P. 300707-300707.
                                    AR30070!

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V.  COMMUNITY INVOLEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY

     1.   Advertisement  announcing the public comment period and
          a public meeting  regarding the site, 7/7/96.  P.
          500001-500001.

     2.   Advertisement  announcing an extension to the public
          comment period until September 5, 1996, The
          Philadelphia Inquirer and the Delaware County Daily
          Times.  8/9/96.  P.
                                           AR300702

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       REGION III
                                  841 Chestnut Building
                          Philadelphia, Pennsylvania 19107-4431
Mr. Daniel Devlin, Mayor
Darby Borough
821 Summit Street
Darby, Pennsylvania 19023
       Subject:
Dear Mr. Devlin:
Proposed Remedial Action Plan for Ground Water
& Ad Copy for Public Notice
Austin Avenue Superfund Site        J
       Enclosed is a copy of the Proposed Remedial Action Plan and a copy of the text for the
public meeting ad which will run in the Sunday Daily Times and Inquirer (DelCo edition) on July
7,1996. Information about the meeting is also included in the Jury update for the site which will
be mailed on Friday, July 5.

       The plans enclosed are printed in a single-sided format for your convenience should you
desire to make additional copies. I trust that you will provide this information to any other
officials who may want or need to see it prior to the July 31st meeting. Please note, however,
that there is no-indication that the plume of contaminated ground water extends into any portion
of your community.  It is limited to the areas of Upper Darby and Lansdowne in the immediate
vicinity of the former warehouse at Austin and Union Avenues.

       Please contact me at 215/566-5525 or 1-800/553-2509, if I can be of any further help to
you or answer any questions you may have regarding the Austin Avenue Superfund Site.
                                        Sincerely,
                                        Carrie Deitzel
                                        Community Involvement Coordinator
cc:    V.Janosik
       G.Crystall
                        Celebrating 25 Years of Environmental Progress


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