PB96-963119
                                 EPA/ESD/R03-96/232
                                 December 1996
EPA   Superfund
       Explanation of Significant Difference
       for the Record of Decision:
       Bendix Flight Systems Division,
       Bridgewater Township, PA
       12/1996

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           EXPLANATION OF SIGNIFICANT DIFFERENCES
            BENDIX FLIGHT SYSTEMS DIVISION SUPERFUND SITE
        SOUTH MONTROSE, SUSQUEHANNA COUNTY, PENNSYLVANIA
A.    Introduction

    The Environmental Protection Agency, Region III (EPA) is issuing this Explanation of
Significant  Differences  (ESD),  pursuant to its  authority in Section  117(c)  of  the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended  (CERCLA), 42  U.S.C.  §  9617(c), and  the  National  Oil and Hazardous
Substances Pollution Contingency Plan (NCP), at 40 C.F.R. § 300.435(c)(2)(i), for the
September 30,1988, Record of Decision (ROD) (no. 197, Section III, in the Administrative
Record Index for the Site) issued for the Bendix Flight Systems Division Superfund Site
(Site) in South Montrose, Pennsylvania. EPA is the lead agency for the Site and the
Pennsylvania Department of Environmental Protection (PADEP) is the support agency.
EPA has identified an aspect of the Site remedy that is  appropriate to change through
this ESD. EPA has determined that this change does not fundamentally alter the remedy
selected in the ROD with respect to scope, performance, or cost. This ESD will become
part of the administrative record file located in EPA Region III and the  offices of the
Susquehanna Planning Commission at the addresses listed  below in Section F.
B.    Summary of Site History. Contamination Problems, and Selected Remedy
   The Bendix Superfund Site is an active aircraft instrument manufacturing plant. From
1952 to 1978, solvents used in degreasing operations were disposed into the onsite
wastewater treatment system, into a series of earthen trenches and onto  the ground
surrounding the plant. The disposal practices resulted in contamination of the soil and
groundwater,  with  chemicals  including trichloroethylene  ("TCE"),  perchloroethylene
("PCE"), 1,1,1-trichloroethylene ("TCA"), vinyl chloride, benzene, and xylene (hereinafter
collectively referred to as "VOCs").  The contaminants are  "hazardous substances" as
defined in Section 101(14) of CERCLA.

For a more detailed summary of site history, and contamination problems, see Sections
III (page 1) and V (page 2) of the ROD. For a description of the remedy as set forth in
the ROD, see Section XII (page 24).
C.    Significant Differences; Rationale

      Selected Remedy for the Contaminated Soil Areas.

      There are two majors areas of VOC contaminated soils at the Site; the area to the
east of the Bendix plant, and the area to the west of the plant. The selected remedial

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 alternative for the soils on the east side of the plant was excavation and mechanical
 aeration, and for the soils on the west side of the plant the selected remedy was vacuum
 extraction. One of the main reasons vacuum extraction was selected for the west side
 of the plant was because there were numerous buried utilities in this area making soils
 excavation and  aeration  (as  selected for  the east side)  both hazardous and
 environmentally inefficient.  In 1991 a vacuum extraction and soil dewatering pilot study
 was performed to assess the effectiveness of this technology and to gather information
 for designing the site remedies.  This study and other remedial work at the Site found
 vacuum extraction to be technically and  physically impractical due to the nature of the
 soils in this area (glacial till).  Furthermore, the impediments to excavation and soil
 aeration, i.e. the buried utility lines, were removed by relocating them overhead.

 Therefore, the reponsible party requested that the remedy be changed to provide for soil
 excavation and aeration on the west side  of the plant instead of vacuum extraction. EPA
 has decided that  it is appropriate to make this change. This ESD modifies the Record
 of Decision; however, the attainment levels and levels of protection remain unchanged.

 In summary, this ESD allows for the same remedial action (i.e mechanical soils aeration)
 to occur for soils on the west side of the plant as was specified in the Record of Decision
 for the east side of the plant.

 D.    Affirmation of Statutory Determinations

    Considering the new information that has been developed and the changes that have
 been made to the selected  remedy, EPA believes that the remedy, as modified by this
 ESD,  remains protective of  human  health and  the environment, complies with  Federal
and State requirements that are applicable or relevant and appropriate to this remedial
action, and is cost-effective.  In addition, the revised remedy utilizes permanent solutions
and alternative treatment technologies to the maximum  extent practicable for this Site.

E.    Support Agency Comments

      The above changes to the remedy  have been coordinated with representatives of
PADEP  pursuant  to 40  C.F.R. §  300.435(c)(2)(i).  PADEP  verbally concurred  on
November 13,  1995 with changes to the selected remedy as described in this ESD.

F.    Public  Participation Activities

   As required  by 40 C.F.R.§ 300.435(c)(2)(i), notice of this ESD will be published in the
local newspaper.  This ESD is part of the administrative record file and is available for
review at the two locations identified below:

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                  United States Environmental Protection Agency
                                   Region III
                             841 Chestnut Building
                         Philadelphia, Pennsylvania 19107
                                (215) 597-3037
                          Hours: 8:30 a.m. to 5:00 p.m.
                             Monday through Friday
                   Susquehanna County Planning Commission
                               31 Public Avenue
                              Montrose, PA 18801
                                (717) 278-4600
                          Hours: 8:00 a.m. to 5:00 p.m.
                             Monday through Friday
Date' c f^                          Thomas C. Voltaggio, Director
                                    Hazardous Waste Management Division
                     The above hand-written note was typed for legibility.
                     Note: EPA can not locate a "signed'.' copy of the ESD.
                     Based on internal information and the attached newspaper
                     notice, I think the ESD went into effect in 1/96.

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 sylvania Council of Churches,
-will be guest speaker duririsfthei
 annual Week of Praye»Chris4
 tiah Unity service mSt Peter's'
 Cathedral

  The service, themed "Listen! I
 Stand at the Door and Knock," is
 scheduled Thursday, beginning
                            ix.v,i«xlt^m1feic^ffeTformea by
                            choristers from numerous local
                            congregations. The service choir
                            will be directed by Stephen Bar-
                            ton, the cathedral's director of
                            liturgical music..   ..,.; .I4r
                                      1LS. EPA TO ALTER
                               MEfflOD FOR (MING DP
                            CONTAMNATD SODS AT THE
                                  BMILX Hjwrr svs™
  The U.S. Environmental Protection Agency, Region ,JII, will
  change  one aspect of its cleanup  remedy for: • the -'Bendix
  Plight System Sup£ffund site in South rMontrose,- Siisque-
  hanna County, PA: The change will modify the way con-
  taminated soils will1 be cleaned up in  an area west-of, the
  plant. The Bendix  Superfund site is  an ;,ac£ye,-^cility
  where aircraft instrumentation is manufactured.,',".. ,
  In September 1988, the EPA selected a cleanup -remedy to
  deal with two areas of soils at the site which were contami-
  nated with chemicals including tyrichloroethylene (TCE),
  perchloroethylene (PCE), vinyl chloride  and other volatile
  organic  compounds. EPA's remedy called for a  vacuum
  extraction method to remove contaminants from soils west
  of the plant. For an  area east of the  plant, EPA  required
  the excavation of soils followed by  mechanical aeration to
  remove contaminants.
  Now, based on a pilot study  which began in  1991, EPA's
  remedy  has been changed to allow use of the excavation
  and  mechanical aeration method  for  soils  west of the
  plant. Allied-Signal Inc., the party liable for contamination
  at the site, performed  the pilot study to determine the
  effectiveness of the . vacuum extraction technology. The
  study concluded that the method does not work well in the
  west- area. Therefore, Allied requested that EPA change the
  remedy. EPA has decided that the change is appropriate
  and  more  importantly, it  remains protective of human
  health and the environment.  In addition, the  change does
  not fundamentally alter the 1988  remedy with respect to
  scope, performance or cost.
  This change to the  remedy  is described in  a document
  called   "Explanation  of Significant  Difference" (ESD).
  Anyone interested in reviewing the ESD and other docu-
  ments pertaining to the cleanup of this site can visit the
  following locations:
U.S. ENVIRONMENTAL PROTECTION AGENCY
841 CHESTNUT STREET
PHILADELPHIA, PA 19107
(215) 597-3037
HOURS: M-F/8:30-5K)0
                                     SUSQUEHANNA COUNTY
                                     PLANNING COMMISSION
                                     31 PUBLIC AVENUE
                                     MONTROSE, PA 18801
                                     (717)2784600
                                     HOURS: M-F/8:00-5:00
  FOR MORE INFORMATION ABOUT THE BENDIX FLIGHT SYS-
  TEMS SUPERFUND SITE, CALL: TERRI WHITE, EPA COMMUNI-
  TY INVOLVEMENT COORDINATOR, (800) 553-2509.

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