United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/078
September 1989
&EPA
Superfund
Record of Decision
CryoChem, PA
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50272-101
REP()RT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R03-89/078
2.
3. Recipient. Acce88lon No.
4. TItle and Subtitle
SUPERFUND RECORD OF DECISION
CryoChem, PA
First Remedial Action
7. Author(a)
5. Report Date
09/29/89
8.
8. P8rf0rmlng Organization Rapt. No.
8. Performing Orgalnlzation Name and ~
10. ProjectlTaaklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
.
(G)
.
12. Sponaorlng Organization Name and Addr8a8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Raport . Period Co_ad
Agency
800/000
14.
15. Supplementary No...
16. Abalract (Umlt: 200 worda)
The 19-acre CryoChem facility is a metal fabricating facility in the village of Worman,
Earl Township, Berks County, Pennsylvania. The facility consists of a workshop area, a
warehouse, and an office building which are all located in the southern four acres of
the site. Between 1970 and 1982, Cryochem reportedly used chemical solvents to clean
dye from metal welds at a rate of two to three 55-gallon drums per year. The facility
also reported that a solvent spill had occurred at some unspecified time in the past.
Spilled solvent is suspected to have collected in the workshop drains and flowed,
through underground channels, towards a stream that flows across the site. Spilled
solvent has also migrated through the soil column and has contaminated the ground water
underlying the site. Ground water samples, collected between 1981 and 1985 by the State
and EPA, revealed that an on site production well, nearby residential wells, and onsite
soil have been contaminated. As a result of drinking water contamination, EPA installed
activated carbon filters in 13 homes in 1987. This Record of Decision, the first of two
operable units, addresses the distribution of clean water to residents whose water
supply is affected or potentially affected by ground water contamination. The primary
contaminants of concern affecting the ground water are VOCs including TCA, DCA, TCE,
DCE, and PCE. (See Attached Sheet)
17. Document Analyala L D88crIptors
Record of Decision - CryoChem, PA
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, PCE)
b. Identifier8l0pen-Ended Terma
c. COSA TI ReIdIGroup
18. AvaJlabifity Statement
18. Securtty CI- (Th\8 Report)
None
20. Securtty Cia.. (Thl. Page)
NonA
21. No. 01 Page.
85
22. PrIce
(See ANSI-Z38.18)
See Instructions on RSllflfN
272 (4.77)
(Formel1y NTIS-35)
D8p8rtment 01 Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
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ANSI Z39.18-1974 available from American National Standards Institute, 1430 Broadway, New York, New York 10018. Each separately
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1. Report Number. Each Individually bound report shall carry a unique alphanumeric designation assigned by the performing orga.
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uppercaoelonera, Arabic numerala, slashea, and hyphens only, as In the following examples: FASEBINS--75/87 and FAA!
RD-75/09. .
2. Leave blank.
3. Recipient's Accession Number. Reserved for use by each report recipient.
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an organizational hlerachy. Display the name of the organization exactly as It should appear In Government Indexes such as
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10. ProJectlTaskIWork Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
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15. Supplementary Notes. Enter Information not Included elsewhere but useful, such as: Prepared In cooperation with. .. Translation
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16. Abstract. Include a brief (200 words or leas) factual summary of the most significant Information contained In the report. It the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis. (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific end precise to be used as Index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names. equipment designators, etc. Use open.
ended terms wrlnen In descriptor form for those subjects for which no descriptor exists.
(c). COSATI Field/Group. Field and Group assignments are to be taken form the 1964 COSATI Subject Category Ust. Since the
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22. Price. Enter price In paper copy (PC) and/or microfiche (MF) If known.
"/:( GPO: 1983 0 - 381-526 (8393)
OPTIONAL FORM 272 BACK
(4-71)
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EPA/ROD/R03-89/078
CryoChem, PA
First Remedial Action
16.
Abstract (continued)
The selected remedial action for this first operable unit includes installation of
dual-activated carbon adsorption units or continued maintenance of existing carbon units
at affected homes until a permanent clean water supply is developed; implementation of
periodic sampling at potentially affected homes; construction of anew uncontaminated
water supply to serve affected .and potentially affected residences and businesses; and
periodic sampling of residents outside the affected area. The estimated present worth
cost for this remedial action is $1,260,000 which includes annual O&M costs of $80,000.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
CryoChem site, Drinking Water Supply Operable Unit
Earl Township, Berks County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
operable Unit 1 of the Cryochem site, 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 action is
based on the Administrative Record for the site.
The Commonwealth of Pennsylvania concurs with the selected
remedy.
ASSESSMENT OF THE SITE
Actual releases of hazardous substances from this site have
presented a substantial endangerment to the public health. If
the releases of hazardous substances are not addressed by the
remedy selected in this Record of Decision (ROD), the public
health, welfare or the environment may continue to be endangered. .
DESCRIPTION OF THE REMEDY
This Operable Unit is the first of two operable units for the
site. The Operable Unit will provide a clean water supply for
the residents whose ground water has been contaminated by the
site.
The major components of the selected remedy include:
1. continued operation and maintenance, until a permanent
clean water supply is developed, of dual activated-carbon
units installed at 13 homes affected by the cryoChem
site. .
2. Installation and maintenance, until a permanent clean ~ater
supply is developed, of dual activated-carbon units at
homes affected by contamination from the site that are not
currently equipped with carbon units.
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3. Periodic chemical sampling of 13 currently unaffected homes
and businesses which could potentially be affected by
contamination from the site due to their location near the
site. .
;
4. Installation, operation, and maintenance of dual activated-
carbon units at residential wells which become affected by
contamination. from the CryoChem site.
5. Development and construction of a new clean water supply
well and distribution system to provide clean water to
affected and potentially affected homes and businesses.
. The new water supply well will include treatment units if
necessary.
6. Operation of a new clean water supply well and distribution
system to provide clean water to affected homes and
businesses.
Operable unit 2 will address the contamination of soil and ground
water at the site.
.
DECLARATION
This action is protective of human health and the environment,
complies with Federal and state requirements applicable or
relevant and appropriate to this action, and is cost-effective.
This action employs permanent solutions to the extent practicable
given the limited scope of the action. subsequent response
actions are planned to address each of the risks posed by the
site. To the extent practicable, subsequent response actions
will be consistent with the action selected in this ROD.
Because this action does not constitute the final remedy for the
site, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a p~incipal element
will be addressed at the time of the final response action, i.e.,
during Operable Unit 2.
~ C)'
.~C~-
Edwin B. Erickson
Regional Administrator
q /)."/ /~
Date
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SECTION
II.
III.
IV.
VI.
VII.
VIII.
IX.
XI.
-3-.
Table of Contents
. for the
Decision Summary
A.
INTRODUCTION
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
B.
DEFINITIONS
. . . . . . e.. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
I.
SITE NAME, LOCATION, AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITY
. . . . . . . . . . .
. . . . . . . . . .
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF OPERABLE UNIT 1
. . . . . . . . . .
. . . . . . . . . . . . . .
V.
SUMMARY OF SITE CHARACTERISTICS
. . . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS
. . . . . . . . . . . . . . . . . . . . . . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . . . . . . . .
ALTERNATIVES
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
X. 'SELECTED REMEDY
. . . . . . . . . . . . . . . . . . .-. . . . . . . . . . . . .
STATUTORY DETERMINATIONS
. . . . . . . . . . . . . . . . . . . . . . .
APPENDIX A. - RESPONSIVENESS SUMMARY
APPENDIX B. - SUMMARY OF ANALYTICAL DATA
APPENDIX C. - ADMINISTRATIVE RECORD INDEX
APPENDIX D. - LETTER OF CONCURRENCE FROM
COMMONWEALTH OF PENNSYLVANIA
~
4
5
6
7
12
13
13
\ \
15 .
16 '
22
36
46
48
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A.
INTRODUCTION
The cryoChem site is located in the village of Worman, Earl
Township, Berks~'County, Pennsylvania. The site is approximately
19 acres in size although site operations are confined to the
southern 4 acres. Past operations at the site involved the use
of solvents when checking the integrity of metal welds. Volatile
organic compounds have been detected by EPA and PADER at the site
and ih residential wells near. the CryoChem site. The site was
proposed for the National Priorities List in June 1985 based on
an observed release of hazardous substances to the environment.
EPA is currently overseeing a remedial investigation and
feasibility study of the site which is being conducted by
potentially responsible parties. The investigation and study
are currently scheduled to be completed in the fall of 1989.
Because several residential wells have become contaminated above
applicable federal and state standards, carbon adsorbtion units
have been installed at 13 of the most contaminated wells by EPA's
Superfund removal program. EPA has separated the site into two.
operable units to focus on the contamination of the drinking \
water supply at an early stage in the remedial process.
This Record of Decision (ROD) selects a remedial alternative to ,
ensure that clean water is supplied to residents affected or
potentially affected by contamination from the cryoChem site.
This ROD addresses Operable Unit 1, Drinking Water supply. After
the remedial investigation and feasibility study are completed,
EPA will select a remedial alternative to addres.s operable Unit
. 2, Area Wide Ground Water and Sourc~ Area.
To the maximum extent practicable, the remedy selected for
operable Unit 2 will be consistent with the remedy selected for
Operable unit 1. In addition, the remedy selected in this ROD is
flexible and can be integrated into the remedy selected for
Operable unit 2.
This decision document presents the selected remedial action for
Opera~le Unit 1 of the CryoChem site in Earl Township, Berks
County, Pennsylvania, chosen in accordance with CERCLA, as
amended by SARA, and, to the extent practicable, the National
Contingency Plan. The decision for this site is supported by the
administrative record file for this site and by comments received
by EPA during the public comment period for the proposed plan.
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B.
DEFINITIONS
Hazard Ranking system (HRS) - A document which assigns a
score baseQ on the relative degree of risk posed by each
site. A score of 28.5 places a site on the National
Priorities List. .
National Priorities List (NPL) - EPA's list of the nation's
.top priority hazardous waste sites that are eligible to
receive federal money for response action under Superfund.
National contingency Plan (NCP) - contains the regulations
,that govern the Superfund program.
Remedial Investigation (RI) - An investigation to determine
the nature and extent of contamination at a Superfund site
and to evaluate the risks associated with the contamination.
Feasibility Study (FS) - A study which identifies and
develops remedial alternatives to address contamination at a
Superfund $ite.
Focused Feasibility study (FFS) - A study which identifies
and develops remedial alternatives to address a specific
medium or risk.
,
Proposed Plan - A document related to the EPA Record of
Decision identifying the remedial alternat~ve preferred by
EPA.
Record of Decision (ROD) - A document identifiying the
remedial alternative selected by EPA.
Maximum Contaminant Level (MCL) - The maximum amount of
contaminant allowable in drinking water to minimize or
eliminate dangerous health effects under the provisions
of the Safe Drinking ~ater Act.
Cancer Risk of 1X10.6 - 1 excess cancer in one million people
based on the consumption of 2 liters of water per day by a 70
kilogram (approximately 155 pounds) person with a life
expectancy of 70 years.
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I.
site Name, Location~ and Description
The cryoChem site is located in the village of Worman, Earl
Township, Berk~.County, Pennsylvania, approximately 3 miles west
of Boyertown, Pennsylvania. The CryoChem site is approximately.
19 acres in size and is situated along Route 562 in a semi-rural
area of Berks County (Figure 1) .
The cryoChem facility is located on gently sloping ground at the
base of a forested hill with nearly 90 feet of relief to the
northeast of the site. A small stream flows south across the
site, through a residential area, and eventually to Ironstone
. Creek. Several farms and a residential area are located to the
south of the site. Surface runoff from the hill behind the site
is combined with shop drainage and is channeled to the small
stream on the site through underground conduits.
The site consists of a workshop area (fabrication building and
Quonset hut), a warehouse, and an office building all located on
the southern 4 acres of the site (Figure 2).
Based upon available information, the ground water flows from
northwest to southeast beneath the site and is controlled
predominantly by fractures. Ground water beneath the site flows
towards several residential wells in Earl and Douglass Townships,
II.
site History and Enforcement Activity
CryoChem, Inc. has been manufacturing metal products, primarily
pressure vessels, at the site since 1962. The metal fabrication
process included the use of a chemical solvent, Chlorethane, to
wipe away dye used to check for faulty welds. Between 1970 and
1982, CryoChem reportedly used Chlorethane, which contains
trichloroethane, at a rate of two to three 55-gallon drums per
year.
A series of environmental samples collected between 1981 and 1985
by the pennsylvania Department of Environmental Resources
(PADER), Cryochem, Inc., and EPA have revealed the presence of
trichloroethene (TCE), trichloroethane (TCA), tetrachloroethene
(PCE), 1,1-dichloroethene (DCE), and 1,1-dichloroethane (DCA) in
an on-site production well and in nearby residential wells.
These field investigations also detected the presence of TCA in
on-site soils.
In September 1987, EPA sampled water from residential wells
within 1/4 mile of the site. Due to the detection of elevated
levels of DCE and other compounds, EPA's removal program
installed activated carbon filters in 13 homes. Figure 3 depicts
residential wells currently equipped with activated carbon
fil~ers. The levels of DCE in these 13 homes exceeded the action
level of 23 ug/liter set by EPA's removal program.
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1.
SITE LOCATION MAP
"igure
B()YFHTII\Jr~. 1'/\
-------
Badioch Ouiciop
— Undeigiound
"" Culweilt
Open GiMes to
Conci«M Basin
— — Prop«il»
Wrt
PW • Pioducbon W«H
M W • MomMM WeM
COM f EOCRA1 CHOGIIAMS CORPORATION
I NAt IMS WUflK II AN AUUUS1 1987
00
I
I; i guru 2.
lAP
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J
N
NOT TO SCALE
f":!.i:"i1 = HOME WITH CARBON UNIT
NUMBERS REPRESENT
P.O. BOX NUMBERS
K - KOUNTRY KITCHEN RESTAURANT
M - MOBIL GASOLINE STATION
Source: u.s. EPI'. 19ft
I
I
-9-
Figure 3.
RESIDENTIAL WELLS CURRE:"4TL Y
TREATED BY CARBON FILTERS
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, ~~9/
I ,.., ~$.
,/ "
f.,../
CRYOCHEM INC.
. !
1haut,- 474
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The CryoChem site was proposed for inclusion on the National
Priorities List (NPL) in June 1985 based upon an observed release
of hazardous substances into the environment. The site received
a Hazard Rankin~ System score .of 28.58. To simplify and expedite
remedial action at the site, EPA has divided the CryoChem site
into two areas or operable units. The two operable units are:
1. Operable Unit 1 - Drinking Water Supply; and
2. Operable Unit 2 - Area Wide Ground Water and Source Area.
EPA conducted a focused feasibility study (FFS) in the spring of
1989. for Operable Unit 1 to evaluate remedial alternatives for
providing an alternate supply of clean drinking water to homes
affected by the CryoChem site. The FFS included the 13 homes
where carbon units were already installed and an additional 7
homes where levels of contaminants exceeded an established
Maximum Contaminant Level (MCL), set by EPA, or an excess cancer
risk level of 1X10.6. The MCL is an enforceable drinking water
standard established within the Safe Drinking Water Act. If a
chemical did not have an MCL, e.g., tetrachloroethane, EPA
developed a 1X10.6 level which may result in one excess cancer
among one million people exposed to the contaminant. Figure 4
depicts 20 residences where remedial action levels, i.e., MCLs o~
1X10.6 cancer risk levels, were exceeded. .
EPA prepared a proposed plan which described the remedy EPA
preferred to implement for Operable Unit 1, as well as 3 other
remeQial alternatives. The remedy EPA preferred to implement was
a connection to an existing municipal water system. The proposed
plan was released to the public on July 14, 1989. After a 30-day
public comment period, EPA reevaluated the 4 alternatives within
the proposed plan based upon comments received from several
sources. This record of decision (ROD) selects a remedial
alternative for Operable Unit 1 which is different than the
preferred alternative outlined within the proposed plan.
Currently a remedial investigation (RI) and a comprehensive
feasibility study (FS) are being completed by the potentially
responsible parties for the site which address remedial
strategies for Operable Unit 2. The RI/FS for the CryoChem site
is expected to be completed in the Fall of 1989.
.
A "special notice" letter was sent to each of the potentially
responsible parties on July 14, 1989. The letters indicated that
EPA would not begin the remedial design or remedial action for
Operable Unit 1 until 120 days from the date of the special
notice letter provided that the potentially responsible parties
agreed to implement the remedial design and remedial action. The
potentially responsible parties, while having expressed an
interest in implementing the remedial design and remedial action,
have not responded to the special notice letter with a specific
offer to do so.
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A
N
NOT TO SCALE
fj~ c::J . HOME AFFECtED BY SItE
,
NUt8ERS REPRESENT
P.O. BOX NUWlERS
K . KOUNtRY KItCHEN REStAURANT
M . MOBIL GASOLINE StAtION
s--= u.s. EPa. ,""
-11-
Figure 4.
RESIDENtIAL WELLS EXCEEDING
REMEDIAL ACtION LEVELS
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The cryoChea site will be finalized on the National Priorities
List in October, 1989.
~
III.
Highlights of Community Participation
The proposed plan and the focused feasibility study for Operable
unit 1 were released to the public on July 14, 1989. These two
documents were made available to the public in the administrative
record file for this site and the information repository
maintained at the Earl Township Building. The notice of
availability of these documents was published in The Mercury and
The Readina Times/Eaale on July 14, 1989. In addition, a copy of
the proposed plan was mailed to each resident near the site in
July, 1989. The 30-day public comment period began on July 14,
1989 and was concluded August 14, 1989. The public was given
additional opportunity to comment on the proposed plan and
focused feasibility study at a public meeting held at the Earli
Township Municipal Building on August 9, 1989. At this meeting \
rep~esentatives from EPA answered questions and received comments
about the site and the remedial alternatives under consideration
and the proposed remedy. A stenographic report of the public'
meeting was prepared by EPA. A response to the comments received
during the 30-daycomment period is included as part of this ROD
in the Responsiveness Summary (APPENDIX A).
A significant number of the comments received by EPA contained
objections to the remedy initially proposed by EPA in the
proposed plan. Many of the residents and the Borough of
Boyertown expressed their reservations about the quality of water
made available by a water line connection into the Boyertown
municipal system. Because the total number of service
connections would be relatively small and the length of the dead-
end line relatively large, the Borough expressed concern that the
water in the line would be sluggish and would become stagnant.
The Borough of Boyertown also questioned the ability of the
system to provide adequate fire protection and its lack of
flexibility. Furthermore, the Borough felt that the cost
estimate. in the proposed plan did not include necessary design
features which caused the estimates to be low.
Residents who would be connected into the extension of
Boyertown's municipal water system objected to the high cost of
service. Although some residents near the site felt that
Alternative 2, Connection to an Existing Municipal Water Supply,
was an adequate means to supply clean water to homes near the
site, the majority of the commentors indicated an unwillingness
to pay for this water service and felt that a better alternative
existed. Many of the residents indicated that Alternative 3,
Treatment of the Contaminated Water with Air Stripping or Carbon
Adsorption, would suit the drinking water needs of the homeowners
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and assist with the cleanup of the site.
The index for" the administrative record, upon which this decision
document is ba~ed, is contained within APPENDIX C. This
decision document is also based upon comments contained within a
stenographic report of the public meeting on August 9, 1989 and
other comments received by EPA, which are also included in the
site file. .
IV.
Scope and Role of Operable Unit 1
This record of decision (ROD) addresses the first of two operable
units and two planned remedial actions at the site. The ROD for
this operable unit addresses drinking water and the provision of
an alternate water supply for homes affected and potentially
affected by the site. Figure 5 depicts 33 homes affected or
potentially affected by contamination from the CryoChem site
based upon chemical analyses of drinking water or proximity to
other affected homes and to the site. The ROD for the second
operable unit will address the remediation of all media
contaminated by the site. The contamination of the drinking
water aquifer beneath the site poses the principal threat to
human health via contamination of residential wells.
The primary objective of this response is to supply clean water
to residents living near the CryoChem site. The wa~er supply
must meet federal and state standards and must be" able to satisfy
present and future water needs. The response will address
distribution of clean water to residents whose water supply is
affected or potentially affected by contamination from the site.
The remedy described in this ROD is only part of the total remedy
for the site. The remainder of the site is being investigated as
part of a remedial investigation and feasibility study, the
results of which will be presented at a later date and used to
select a remedy for the entire site. The remedial alternative
selected in this ROD is adaptable and can be integrated into the
remedy selected for the entire site.
V.
Summary of Site Characteristics
All characteristics of the CryoChem site will be fully described
and discussed after the remedial investigation and feasibility
study have been completed and a report of the investigation and
study are approved by EPA. .
During former operations at the cryoChem facility, chemical
solvents were used to clean dye from metal welds. The amount of
solvent used between 1970 and 1982 amounted to approximately 2 to
3 55-gallon drums per year. The facility also reporte~ that a
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Figure 5.
RESIDENTIAL WELLS AFFECTED OR
POTENTIALLY AFFECTED BY THE SITE
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/ CRYOCHEM INC.
NOT TO SCALE
= HOME AFFECTED BY OR
E3 D POTENTIALL Y AFFECTED BY
. J THE SITE
NUMBERS REPRESENT
P.O. BOX NUMBERS
K . KOUNTRY KITCHEN RESTAURANT
M . MOBIL GASOLINE STATION
s-c US EPi'. 'tit.
.....,.. 474
-------
-15-
spill of solvent had occurred at some unspecified time in the
past. spilled solvent would have collected in the shop drains
and flowed, through underground channels, towards an unnamed
stream which f~ows across the property. Trichloroethane, a
component of the chemical solvent used at the facility, has also
been detected in the soils at the cryoChem site. .
The amount of solvent spilled or otherwise released into the
envtronment at the CryoChem site is unknown. However, some of
the chemical solvent has mig~ated through the soil column and has
entered the ground-water system beneath the facility. Chemical
sampling of ground water from wells on the cryoChem site and from
wells near the CryoChem site indicate that volatile organic
chemicals, including trichloroethane, exist in the ground water.
The bedrock beneath the cryoChem site consists of fractured
quartzite and crystalline limestone. Ground water moves
predominantly through the fracture system. Therefore,
residential or other wells penetrating the same fractures or
fracture systems containing ground water contaminated from the
CryoChem site may themselves become contaminated. Some. .
residential wells are now contaminated by volatile organic \ \
chemicals similar to those found at the CryoChem site, including;
trichloroethane. EPA has installed dual activated carbon units
in 13 homes with the highest levels of contaminants to reduce
levels of volatile organic chemicals to safe levels, but
contamination exists at other homes as well. Thus, EPA has
decided to develop and screen remedial alternatives to provide a
permanent supply of clean water to residences near the site and
to select a remedial alternative for an alternate supply of
drinking water in this Record of Decision.
.
VI.
Summary of site Risks
Volatile organic compounds have been detected in residential
wells near the CryoChem site. The five compounds posing the
greatest risk to ground water users near the site are
tetrachloroethene (PCE), trichloroethene (TCE), 1,1-
dichloroethene (DCE), trichloroethane (TCA) and, 1,1-
dichloroethane (DCA).
The MCL, or Maximum contaminant Level, is an enforceable drinking
water standard established within the Safe Drinking Water Act.
EPA will initiate a remedial action if ground water contains a
particular chemical above the standard, or MCL, for that
chemical. If an MCL has not been developed for a particular
chemical, EPA will use other criteria when considering the need
for remedial action. For this operable unit, EPA has used an
"excess cancer risk level of lxlO-6" criterion, i.e., one excess
cancer in one million people, to determine if remedial action is
necessary. The criteria, i.e., remedial action levels, used by
EPA which would trigger the need for remedial action for this
-------
-16-
operable unit are described in Table 1.
A summary of analytical data from residential wells is contained
within APPENDIX'B. Table 2 depicts the levels of volatile
organic chemicals found in 13 homes near the site where carbon
units have been installed. Table 3 depicts the levels of
volatile organic chemicals in 7 additional homes near the site.
Tables 2 and 3 also 'compare the levels of volatile organic
chemicals found in the 20 homes to the criteria established by
EPA. The MCL or lx10.6 level nas been exceeded for at least one
of the chemicals at 20 homes near the cryoChem site. Therefore,
remedial action is justified.
VII.
Documentation of Significant Changes
The proposed plan was released for public comment on July 14,
1989 and described 4 alternatives for addressing the drinking
water contamination at homes near the cryoChem site. The
proposed plan identified Alternative 2, Connection to an Exist~ng
Municipal Water Supply, as the preferred alternative. During the
public comment period, EPA received several comments objecting to
the quality of the water supplied by the Boyertown municipal'
water system, the time to implement the proposed alternative, an9
the cost of the proposed alternative.
The Borough of Boyertown believed that the quality of the water
delivered through the long dead-end water line to affected
residents may be poor. Because the length of the water main was
relatively long and the number of service connections relatively
small, the Borough felt that the water would stagnate and become
dirty before it was used by residents. The Borough of Boyertown
also suggested that the capacity of their water system might be
overly stressed by the new connections near the cryoChem site and
by 'other future connections~
The Borough of Boyertown also questioned the ability of the
proposed extension of the water system to provide adequate fire
protection for residents and questioned the flexibility of the
proposed alternative, e.g., could the new water system
accommodate new development along the main line. In addition,
the Borough of Boyertown expressed concern that EPA's cost
estimate of Alternative 2 may not have considered significant
conditions which could affect the total cost, e.g. topography,
causing the cost estimates in the proposed plan to be low. As a
result of these and other public concerns, EPA has reevaluated
the four alternatives and has selected a combination of
Alternative 3, Treatment of contaminated Water, and Alternative
4, Development of a New Uncontaminated Water Supply, as the
remedy for this operable unit.
During the public comment period the cost figures for each
alternative were revised to include 11 additional homes and 2
-------
-17-
TABLE 1
RE~IEDIAL ACTION LEVELS
;
Contaminant
1,I,I-Trichloroethane (TCA)
Trichloroethene (TCE)
Tetrachloroethene (PCE)
l,l-Dichloroethene (DCE)
1,1- Dichloroethane (DCA)
Notes:
.
b
Maximum contaminant level.
Concentration that poses a 10-6
cancer risk (one cancer per one
million people exposed).
Remedial Action
Level (U2/l)
200.
5.
0.66b
78
O.3Sb
t
-------
TABLE
2
COMPARISON 01' RI!NIIIDIAI. AnION 1J!VI!lS ANn ANAI.YI1«:AI. UATA Ij!OR J) RI!SIUlWI1AI. WI!lJ-S WflU (:ARIION 11J1:I1!RS -
SAMPIJ!S nUJJ!.el1!D IN NARall9B9
C-IInrc:nlralion in Rc:sidc:nlial Wdl (Ill/I.}
AtI.Jrc:~ I,I,I-Trichloroelhane Trichloroelhene Telrachloroelbene I,I-Oichloroelhene I,I-Oichloroeahane
I),n, llox (TCA} frCm . (rem mcm (DCA}
MCa.: 200 MCa.: S 10-6 = 0.668 MCa.: 1 10-6 ,. 0.]88
t.
n 369 16 1 99 26
7] 460 14 6 132 ]S
74 NO NO NO NO NI)
118 28 8 ] 64 13
89 143 S 2 ]9 II
101 161 S 2 34 II
102 197 6 2 42 III
......
103 IS7 S 2 ]8 I) 00
I
104 129 S 2 28 II
80S IS8 NO 2 ]2 II
106 17S 6 2 43 9
107 196 b 3 43 10
116 6S 3 18 S
NoIc:5:
NO ,. NO! deluled,
8 Concenlralion Ihal pmes a cancer ri~k or 10-6 (one cancer per one million people exposed).
Analyliral re~ulls In Ihis lable are ror samples collecled prior 10 Irealmenl wilh in-house carbon rlilers.
Sourre: U S I:I'A. CryllCllem Ground-Waler Silc:, Analyllral Reliulili Summary, Rcsidc:n..al Wc:1I Sampling.
..n..lyIK... .1..... wllerlc:d bC:lwc:c:n July 1'J87 and Mardi 1989)
Apnl 8. 19111), (I 'his tlocumc:nl i~ a wmpulU pnmllul III... ~U",",.UlLC:~
-------
TABLE
3
U)MrAIUSON UI'IU!MI!UlAI.ACI10N U!VI!lS ANn ANAI.YI1CAI.UA"'A I'UR SI!VI!N AUlUI10Nl\I. RIISIUI!NI1AI. WI!JJS-
. SAMI'U!S (nUJ!(~I1!1) IN 1'M7
('unee/llralion in Rc:sidenlial Well I.
Addre" I.I.I-Triehloruelhane T..,.hl"r.oe:lhene Telrarhh ,rl>c:lhene 1.1-1 )iehh 'r<>c:lhcne I.I-I)iehlnruelhanc
(1'.0 n...) nale Sampled n ("A) nn~1 (1'('1') (l)n~) (l)CA)
M('I: 2110 MI'I. S IU'6 ~ 0/",8 M('I.: 7 10'6 = OJR8
/.8 7/27/87 NI) Nil NI) NI) 7
Il/IS/81 H Nil NI) S II
71 7/27187 7 Nil NI) I NI>
9/1S/81 10 Nil I 7 NI)
H2 'l/IS/H7 41 3/. 2
II.' 7/2H/H1 II. Nil NI) 2 NI)
Il/IS/81 8 Nil NI) II. NI) I
......
11111 7/27/H1 .H Nil NI) ') I \0
I
IJ/IS/81 11 ! I S M
"4 7/27/H1 4 NI) NI) NI) NI)
')11<'/81 1 Nil I ] NI>
4S1 7/27181 2 Nil NI) NI) 2
9/1S/81 NI) Nil NI) NI) NI>
NnleS:
NI) = N"I de leeled
8
Coneenlralinn Ihal I""e~ . canrer ri~~ uf 111-6 (one ra..rci per une nulh"n ('Cul'le cxl".ud),
Snurre:
U,S I:I'A. ('ryn('flem (ilUundWaler Slle, Anal)'I".al Itc~ul" Summary, Itu.,lenlial Well Sanlpling, April 8, 1'111'1, Obis dueumen' is a enmpuler pnnl"ul 1";11 ~ummari/n
andlyliral dald ...,lIcHed helween July l'IK1 an'" MMd. I'IH'/I
---
.
-------
-20-
businesses which potentially could be affected by the CryoChem
site. These cost figures have been summarized in Table 4 and
have been considered, along with other criteria and issues
discussed above, in the selection of the remedy for operable
Unit 1. ~
The remedy for Operable unit 1 includes treatment and/or sampling
of 33 homes and businesses. This ROD selects carbon treatment
units for each of 20 homes affected, but not already equipped
with such units, by the CryoChem site as part of the remedy for
this operable unit. A residence is considered to be affected if
levels of volatile organic chemicals in the drinking water supply
exceed EPA's remedial action criteria. For this site, EPA's
remedial action criteria are Maximum contaminant Levels for
trichloroethene (TCE), 1,1-dichloroethene (DCE), and 1,1,1-
trichloroethane (TCA) and 1x10.6 cancer risk levels for
tetrachloroethene (PCE) and 1,1-dichloroethane (DCA). The dual
activated carbon units would be installed and maintained until a
long-term clean water supply has'been developed and affected
homes are connected.
The remedy for Operable Unit 1 also includes periodic, e.g.,
quarterly, sampling of drinking water at 11 additional homes and'
2 businesses, which potentially could be affected by the CryoChem
site due to their location. These homes would be sampled until a
long-term clean water supply is developed and the potentially .
affected homes are connected. If any of the 13 additional
sampling points should become contaminated above the MCL or
lx10.6 cancer risk level for any of the contaminants associated
with this site before a clean water supply is developed, a carbon
unit would be installed on the affected drinking water supply.
In addition, this remedy includes periodic sampling of additional
homes, which are not affected or potentially affected by
contamination from the Cryochem site. Additional homes would be
included in a sampling program if analytical data from any of the
33 homes addressed in this ROD suggests that additional homes ~ay .
require sampling to ensure that public health is protected.
The installation of carbon units at affected homes and the
periodic sampling of other homes is considered to be an interim
measure until a permanent clean water supply system has been
developed. The installation of dual activated carbon units at
affected homes is the quickest, easiest and most adaptable remedy
to implement, which is protective of human health, until the new
water supply is developed. This alternative was favored by much
of the public.
This ROD also provides for the concurrent development of a new
uncontaminated water supply for residents near the site. After a
new water supply well has been drilled, or an existing suitable
well located, a pump would be installed and a distribution system
would be constructed to supply clean water to affected and
potentially affected residents on a long-term basis. This
-------
TABLE 4
Rl:MEDlAL ALTERNATIVES CDST SU~1ARY
(31 RESWENCES AND 2 BUSINESS)
ALTERNATIVE CAPITAL COOT ANNUAL o&M PRESENT ~>OlmI
1. No Action ..
2. Connection to an Existing
Municipal Water Supply $ 950,000 $ 21,000 $ 1,100,000
3. Treatment of the
Contaminated Water
A- Central Well with I
IV
Air Stripper $ 480,00 $ 26,000 $ 720,000 ......
I
B- Central Well with
Carbon unit $ 520,000 $ 53,000 $ 1,000,000
C- In-House Carbon units $ 57,000 $ 60,000 $ 620,000
4. New uncontaninated
Water Suppl y $ 450,000 $ 20,000 $ 640,000
-------
-22-
alternative may be developed further into part of a permanent
remedy for the cryoChem site selected in the ROD for Operable
unit 2. .
The combinatio~ of alternatives selected in this ROD may be
implemented before the RI/FS for Operable Unit 2 is completed and
the remedy for the entire site is chosen. The remedy selected in
this ROD is adaptable and can be designed, if necessary, to be
integrated into the permanent. remedy for the entire site, which
will be selected in the ROD for Operable unit 2.
VIII.
Alternatives
This section of the ROD describes the process of screening and
developing remedial alternatives and discusses in detail each of
the four alternatives evaluated in the proposed plan.
A.
screening of Alternatives
Table 5 identifies each of the remedial technologies and
management or process options which were screened in the focused
feasibility study and considered in the development of remedial
alternatives. The significance of the screening exercise is to
determine which technologies and options can best satisfy the
primary objective- i.e., to provide a clean water supply. Each
of the technologies and options are evaluated on the basis of
their effectiveness and their ability to be implemented
considering site-specific conditions. Only those measures which
can be used to provide clean water to residents near the CryoChem
site were evaluated and further developed into remedial action
alternatives. Remedial action alternatives identified are
limited to proven technologies and process options which have
been used successfully at other sites.
B.
Description of Alternatives
Based upon the screening and evaluation of potentially applicable
remedial technologies and management or process options and the
requirement within the National contingency Plan to evaluate a
"No Action" alternative, the following remedial action
alternatives have been selected for further development and
detailed evaluation:
1.
2.
3 .
4.
No Action
Connection to an
Treatment of the
Development of a
Existing Municipal Water Supply
contaminated Water
New Uncontaminated Water Supply
-------
loener-..I l{ePIedial Al'linn,
No AClion
Conneci 10
bu.line Supply
Oevelop New
UnconlamlRaled
Wille, Supply
T,cal (~nlamlRilled
Wille' from
I.:llslanl Well~
'l'ABL~
5
SUMMARY OF PRI.!I.IMINARY SCREENINH OP RHMHDIAL ACTION PROCESS OPTIONS
(Ililge: I of 2)
Proceii «)(IIIUII.
None
Conacclioft 10
BoycnUWII
MUAicipiol
Supply
Surface Wille'
Supply
New Well ()ul~idc
Plume of
Conla.i.alioa
l!aiuine Well
OUI" I'lume
of C..onlaminillion
New Well, in
I>ecpc, Aquller
AcliV'..led
Calbon
SY'lem'
UncriPlions
Remove lemporilry ilclavaled cattloA '1'lems. I{e~iden" would be
"'Iul,ed 10 "fink conlilmiflilled -Ier or oblillR aile mille 5Upply,
In~I..1I new plplnl. conneci 10 Boycnown municipal lup(lly. anol
du.uibule new wiater .upply 10 bomca,
Idenlafy unconlilminilled iurfilce Willer lUPIlly and dl.lnbule 10 hOIll".
Initilll new well oubide plume of coniaminilllon. I>illribule Willer 10
hom" willioul "nlme AI.
U" uilliae well OR C.S. Guber A Sons propcny 10 lUpply waler 10
hom".
UnO a new well ill eilch tMHnc Ihroue' ZORe ol cORlaminalioA ialo II
dce pc' iI'Iuller.
M..lRlilln IRdl\flduill ilcllllilled carbon 51'Ieml ill elKh home.
Conl..lIIlRaled ....Ier l'a~I Ihroueh II column of aclivaled carboA where
u'I.mc conl"minilnb adwrb on carbon iurfilce.
C:Ofl1lRcn15
Nul ill)pllcilble. PfCKn.. a Ih,nl 10
humiln hCilII" Ihroveh CORiUmpllon of
ClinlilffilRaleoi Willer.
I'olellll..lly iI('I,lIcilble.
Surf",'e w.ler IR ilreil ., conl.mlR..lcd
AdctjuillC 'url.ce W.IC r ,up(lly Ii 11..1
ilVilllable.
I
N
W
I
l'Olenllilllyal'phl...llle.
M..y nUl be uUhlde plume. Add'lI"n..1
CiI~IR& of well rcquiled.
Verll"..1 e11C1l1 "f "onl"mlnallun nul
Lnown. Aquifer ,'h"r..clerilllC1. h..ve lIul
been ev"lualed Wells may cru~.
conl..ffilR..le iltjulfen
I'olenll..lly "1'I'h"..lIle.
-------
SUMMAR V ()1'1.'U~UMINAR V SCREENING OF REMEDIAL AcnON PROCESS (W'fIONS
(Page 2 ol2)
"ener", Remedial Ar.iOOl
TrCil. Con...min..ed
W...u I:rom
New Well
Procelo$ Op.i()l1~
Air Sa "Win,
PcStriPliClns
Commen.s
Saca.. Sarippill'
I:&arilc' Wil'er lrom new -II i. .be plume 01 coo...min...ioo, mi. wllb
..ir .0 . JW.:hd columo '0 promote 'filiUilu ul voa...ilc ulJ.oic
compouo"s lrom w...u '0 Ii" Ind dil'ribu.e '0 bomn.
.. .
I'...eo'i,ally "pphc..ble.
I~II"CI wa'u lrum new -II in 'he plume 01 con'..min...ion lod aru. by
..e..m "opl"n,. Slmill"o Ii, "rippin, eacepl "um i5 pumped in.o
"riPPIR, columo '0 add bu. Ind promoce .be .,aosle, of Ie" \/01OI.ilc
or,aoic: compuuods.
MOIre ('(I.\"y ,1ft" ""'II:ull '0 Implemenl
'h..o iIIir s.oppinl. Addillooa'
eUcl'IilleocWi pl\NJdcd 001 'require" ill'
'his si.e.
Ac:.iV'a.cd
c..bon
S,..em
1:&11....-. w...u lrom oew -II io .be plume of coo...mina.ioo. pau i.
.hruulh .. column of ac.iva.ed carbon, 101.1 dlillibu.e i. '0 humC5.
l'o.eRII..II)' iIIl'l"II:..blc,
OIend Coo'.mioil.ed
and Uoroo'ilmina.ed
Wa.er
WiI.er lrom E..islIlI,
Weill Bleoded
wi.h W..er FlOm
New Well
Ulend WiI'U lrom . oew -II ou'iide .he plume 01 coo.amio..ion wi'h
Wil'er lrom t'oo...nlloa.ed -iii '0 dilu.e ",uo'..mm.ol5 '0 accepcable
conceoll...iuni.
I:u'essllle mClnlloonl required hi cnsUlc
ill'Cep'able wa.er qu..llly.
I
N
+--
I
-------
-25-
ALTERNATIW 1
-
No Action
The National Contingency Plan (NCP) requires thatEPA consider a
"No Action" alternative for each site. This alternative does not
supply an alternate' water supply for affected homes near the
CrY0Chem site and does not provide for sampling to ensure that
other homes are not affected.' Activated carbon filters already
installed at homes by EPA would be removed if this alternative
were selected. As a result, residents near the site would drink
and ~tilize water contaminated with volatile organic compounds
from the site. Because volatile organic compounds exist at
levels above the MCL and/or cancer risk level of lXlO.6, public
health would not be protected under the "No Action" alternative.
Alternative 1 does not satisfy the primary objective of this ROD.
ALTERNATIVE 2
connection to an Ezistinq Municipal Water
Supply
The general components of this alternative are:
A.
Connecting affected and potentially affected homes
into an extension of the Boyertown municipal water
system.
B.
Removing existing carbon units from affected homes.
C.
Abandoning affected and potentially affected wells
within the plume of contamination and/or implementing
institutional controls on the development and use of
private wells within the plume of contamination.
D.
Conducting periodic sampling
connected into the Boyertown
homes do not become affected
site.
and monitoring at homes not
system to ensure that these
by contamination from the
The Borough of Boyertown operates a municipal water supply
system. Although the homes with contaminated water supplies are
outside the Borough boundaries, they could be connected to an
extension of the Borough's water system. The nearest point of
interconnection to Boyertown's water system is approximately 3.5
miles east of the cryoChem site near Route 562.
Extending water service from Boyertown to the residents near the
cryoChem site would require approximately 4 miles of minimum 4-
inch diameter water main. Due to the length of the water main,
topography, and probable pressure losses, at least one booster
pump station would be required. The project would be technically
feasible and implementable, but would take the longest time and
would be the most difficult of the alternatives to implement. An
-------
-26-
agreement would have to be arranged between the Borough of
Boyertown and the party implementing this alternative to fund,
operate and maintain the water line.
~
Extra storage capacity at the end .of the water line extension may
be necessary to provide fire protection commensurate with that
received by other Borough residents and to provide water service
while the main is being repaired. Extra storage capacity was not
considered in the FFS. This alternative does not provide
additional fire protection, i.e., more protection than residents
currently have. This alternative does not include provisions for
addi~ional system capacity to serve new development in the area
not affected or potentially affected by the site.
Alternatively, the dead-end water line could be looped, i.e.,
connected back into the main water line network at a different
location, to enable the Borough to supply water while the line is
being repaired. A Of loop" feature was not considered in the
design of Alternative 2.
After homes are connected to the municipal system, the private
wells which could act to exacerbate the spread of contaminants
within the affected or potentially affected area should be
plugged and abandoned to prevent the further spread of the
contamination through the well bore. This alternative would
provide no additional protection of the environment and
downgradient users of ground water unless significant pathways
for contaminant migration, such as private wells, are sealed..
After the alternative is implemented, further construction and
pumping of private wells within the plume area must be
controlled.
The Borough of Boyertown has procedures for review of plans to
extend their water system. These review procedures would be
followed. The Borough would routinely sample their water to
ensure that all criteria identified within the Safe Drinking
Water Act, e.g., MCLs, and criteria within Pennsylvania's Safe
Drinking Water Regulations are met.
The costs for this alternative are presented in Table 6. The
costs assume that each of the 33 homes and businesses affected or
potentially affected by contamination from the CryoChem site
would be connected into the water main.
ALTERNATIVE 3
Treatment of the contaminated Water
Under this general alternative, two treatment technologies and
two management or process options have been considered by EPA.
The treatment technologies are air stripping and carbon
adsorption. The management or process options are treatment and
distribution from a central well and treatment at individual
private wells. The various technologies and options have been
developed into three specific alternatives. The options under
Alternative 3 are:
-------
,t\'..~;,\ '.
-27-
TABLE 6
ESTIMATED COST TO CONNECT TO BOYERTOWN MUNICIPAL SYSTE~t
Annual
Caoital ~
Force Main $450,000
House Service and Meters 67,000
Booster Pump Station 50,000 $14.000
Electrical Service 10,000
Miscellaneous 10,000
Connection Fees 25,000
Water Use Charges 7.000
In-House Carbon System Removal 6.000
$620,000 521.000
Bid Contingency (15%) .93,000
Scope Contingency (10%1 62.000
Construction Subtotal S770,OOO
Permitting and Legal (5%) S 39,000
Engineering Design (10%) 77 .000
Service During Construction (8%) 62.000
Total Capital Cost S950,OOO
Present worth at 10% discount rate and 30 years.
S 1. 100.000
-------
-28-
Alternative 3A - Treatment by Air Stripping and Distribution
from a Central Well within the Plume
~
Alternative 3B - Treatment by Carbon Adsorption and
Distribution from a Central Well within the
Plume
Alternative 3C - Treatment by Carbon Adsorption at Individual
Private Wells
The general components of Alternative 3, option 3A, are:
A.
Installing, operating and maintaining an air stripper to
remove volatile organic chemicals from ground water
withdrawn from a central well.
\ .
B.
connecting affected and potentially affected homes to a
water distribution system fed by water cleaned by the air
stripper. t
C.
Removing activat~d carbon units from affected homes.
D.
Abandoning affected
and/or implementing
development and use
of contamination.
and potentially affected private wells
institutional controls on the
of private wells within the plume
E.
conducting periodic sampling of the air stripper water
discharge and air stream to ensure that all standards are
met.
F.
Conducting periodic sampling and monitoring at homes not
connected to the new water system to ensure that these
homes do not become affected by contamination from the
site.
The general components of Alternative 3, option 3B, are similar
to those for Alternative 3, option 3A, except that carbon
adsorption units, and not an air stripper, will be used to treat
contaminated ground water.
The general components of Alternative 3, option 3C, are:
A.
Installing and maintaining dual activated carbon units at
homes affected by contamination: from the cryoChem site and
continuing maintenance of dual carbon units currently
-------
-29-
installed at 13 homes affected by contamination from the
site. . .
B.
conducting periodic sampling to ensure that filters are
operatirlg properly.
conducting periodic sampling to ensure that homes
potentially affected by the site do not become impacted.
c.
E.
"Installing and maintaining carbon units at homes which
become affected by the site.
conducting sampling at homes outside of the plume of
contamination to ensure that these homes do not become
affected by the site.
D.
options 3A and 3B both involve pumping ground water from a
central well within the contaminated aquifer, treating the ground
water by removing volatile organic compounds, and distributing
the treated water to residents affected or potentially affected
by contamination from the CryoChem site.
An existing well would be prepared or a new well would be drillea
within the plume of contamination and a water pump installed. .
The pump would deliver water to: 1) a series of carbon units,
2) an air stripper, or 3) a combination of both, and then to a
storage tank at the required system pressure. The operation of
the pump would be controlled by the level of water within the
storage tank. After the water is treated, it could be
distributed to residents at a rate and system pressure which
could meet or exceed peak demand.
The operation and maintenance of the pump, carbon adsorption
units and/or air stripper, storage tank and distribution system
would have to be placed under the responsibility of an as yet to
be determined authority. .
The actual design and maintenance schedule of the carbon units
would depend upon ground water samples collected from the plume
of contamination and other testing. An ultraviolet disinfection
system would also be installed. The equipment would be housed in
a heated structure to protect it from freezing.
A packed tower air stripper with countercurrent flow would be
used in option 3A to treat the contaminated ground water. The
air stripper may result in 99% removal of volatile organic
chemicals from the water. The volatile organic chemicals would,
however, be discharged to the air. option 3A assumes that carbon
adsorption units will not be necessary to further treat the
effluent from the air stripper. If necessary, a carbon
adsorption unit can be installed to further treat the effluent
from the air stripper.
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-30-
A pilot test would be performed to ensure that appropriate
effluent levels, as they are established within applicable
federal and state guidelines, can be attained and that air
emissions will pot exceed applicable standards.
The distribution system would consist of a minimum 4-inch
diameter water main connecting the storage tank and carbon units
and/or air stripper" to the homes. Each of the homes currently
affected or potentially affected by the cryoChem site would be
connected into the distribution system. The system would be
designed to accept additional connections should additional homes
become contaminated. The system capacity would not be designed
to serve new development in the area. A storage tank would be
necessary to provide water during times of pump failure or
maintenance. This option does not provide for additional fire
protection, i.e., more protection than residents currently have.
The existing carbon units at the homes would be removed. the
affected and potentially affected residential wells should be
abandoned to retard further migration of contamination through
the well bore. Institutional controls would be necessary to "
ensure that no additional private wells are drilled within the \
contamination plume which may exacerbate the spread of
contamination.
Periodic sampling would be required to ensure that the carbon
units and/or air stripper are working effectively and that the
schedule for carbon replacement or air stripping tower
maintenance is sufficient. Sampling of the effluent would be
required until remediation of the ground water aquifer is
completed.
In option 3C, dual activated carbon units would be installed and
maintained at each of the homes affected by the cryoChem site.
An ultraviolet disinfection system would also be installed and
maintained at these homes.
Thirteen homes currently are equipped with carbon units. Based
on performance history, the first carbon unit would be replaced
every 6 months and a verification sample collected twice a year.
This schedule would be adjusted, if necessary, based upon further
review of performance and additional sampling results.
Maintenanco of the carbon units at each house would be required
until ground water remediation is completed or a permanent remedy
is selected which would provide clean water for the homes.
Each of the options considered under Alternative 3 must supply
water which meets all criteria established in the Safe Drinking
Water Act or Pennsylvania's Safe Drinking Water Regulations. In
addition, any alternative involving the use of an air stripper
must ensure that the air effluent meets criteria established
under the Clean Air Act and Pennsylvania's Air Resource
Regulations. Any alternative requiring the disposal of spent
carbon requires that applicable regulations in the Resource
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-31-
Conservation and Recovery Act (RCRA) are followed.
The costs for Alternative 3 are presented in Tables 7, 8, and 9.
The costs depicted in Tables 7 (option 3A) and 8 (Option 3B)
assume that 33 ~omes and businesses will be connected to a new
water supply. This ROD addresses a total of 33 homes and
businesses which are affected or potentially affected by
contamination from the cryoChem site.
The costs depicted in Table ~ (option 3C) assume that 33
additional homes and businesses will be equipped with carbon
filters. The costs depicted in Table 9A include costs for carbon
units on 20 homes affected by contamination from the CryoChem
site. Potentially affected homes are not included in cost
figures depicted in Table 9A.
ALTERNATIVE 4
Development of a New Uncontaminated Water
supply
This alternative involves construction of a new water supply
well, or preparation of an existing water supply well, and i
construction of a distribution system to provide clean water to \
the affected and potentially affected homes and businesses. The'
location of the new well would be determined during the remedial.
design phase of the project. Based upon current information, a
possible location for the new well is approximately 200 feet west
of Fancy Vale Avenue along Route 562. As additional data are
. collected during the investigation and study being completed for
Operable Unit 2, the well location and co~struction details may
be verified or modified.
A pump, which would deliver water to a storage tank on an as
needed basis, would be installed in the new well. The storage
tank would be constructed to provide backup capacity in the event
of pump failure or during pump maintenance. The storage tank
would also enable a pump with a lower capacity to be installed
which would operate in response to specified tank water levels.
This alternative does not provide for additional fire protection,
i.e., more protection than residents currently have.
Water from the storage tank would be delivered to affected and
potentially affected residents and businesses through a minimum
4-inch diameter water main. The water system would be capable of
serving affected and potentially affected residents at a rate and
pressure suitable to meet or exceed peak demands. The capacity
of the new water system would not be designed to serve new
development in the area.
The operation and maintenance of the newly installed water system
would be placed under the direction of an as yet to be determined
authority. Periodic monitoring of the water, in accordance with
applicable state and/or federal requirements, is necessary to
ensure its quality. .
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-32-
TABLE 7
.; ESTIMATED COST TO TREAT WATER FROM
NEW WEI,.L IN PLUME BY AIR STRIPPING
Construction Subtotal
Annual
CaDital Cost ~
S 2,000
5,000 5,000
78,000 6,000
23,000 6,000
10,000
20,000 2,000
91,000 1,000
67,000 2,000
10,000
4,000
6.000
S 310,000 S:6,OOO
46,000
~
$ 390,000
. Well Installation
Well Pump and Controls
Structure and Storage Tanks
Distribution Pumps
Electrical Service
Air Stripper
Force Main
House Service & Meters
Miscellaneous
Lab Analysis
In-House Carbon Removal System
Bid Contingency ( 15%)
Scope Contingency ( 10%)
Permitting and Legal (5%)
Engineering Design (10%)
19,000
39,000
Services During Construction (8%)
Total Capital Cost
li...QQ2
S 480,000
Present worth at 10% discount rate and 30 years.
S 720.000
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-33-
TABLE 8
;. ESTIMATED COST TO TREAT WATER FROM
NEW WELL IN PLUME WITH ACTIVATED CARBON
Total Capital Cost
Annual
CaDi tal Cost ~
$ 2.000
5.000 5.000
88.000 6.000
23.000 7,000
10.000
36,000 27,000
\ \
91.000 1,000
67.000 2.000 t
10,000
5,000
6.000
S 340,000 $53.000
50.000
34.000
$ 420.000
21.000
42.000
34.000
$ 520.000
Well Installation
Well Pump and Controls
Structure and Storage Tanks
Distribution Pumps
Electrical Service
Activated Carbon System
Force Main
Hou~e Service & Meters
Miscellaneous
Lab Analysis
In-House Carbon System Removal
Bid Contingency (15%)
Scope Contingency (10%)
Construction Subtotal
Permitting and Legal (5%)
Engineering DesilD (10%)
Services During Construction (8%)
Present worth at 10% discount rate and 30 years.
S t .000.000
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-34-
TABLE 9
ESTIMATED COST TO TREAT WATER FROM.
RESIDENTIAL WELLS WITH ACTIVATED CARBON
33 AFFECTED ~~D POTE~TIALLY AFFECTED HOMES
Total Capital Cost
Annual
CaDital Cost ~
S 9,100
28,000
S 42,000
18.000
S 37,000 S 60,000
5,000
4.000
46,000
2,000
5,000
4.000
S 57,000
Purchase of Carbon Systems
13 Presently in Homes
20 New Systems
Sampling and Analysis
Carbon and UV Replacement
Bid Contingency (15%)
Scope Contingency (10%)
Construction Subtotal
Permitting and Legal (5%)
Engineering Design (10%)
Services During Construction (8%)
Present worth at 10% discount rate and 30 years.
S 620.000
-------
-35-
TABLE 9A
ESTIMATED COST TO TREAT WATER FROM RESIDE:'JTIAL WELLS
. WITH ACTIVATED CARBON
20 AFFECTED HO~S
-
CaDital Cost
Annual
~
Purchase of Carbon Systems
13 Presently in Homes
7 ~ew Systems
Sampling and Analysis
S 9, 1 00
8,400
S 25,000
S 18,000
10.000
S 35,000
Carbon and UV Replacement
Bid Contingency (15%)
Scope Contingency (10~)
3,000
2.000
Conscruction Subtotal
23,000
Permitting and Legal (5%)
Engineering Design (10%)
1,100
:,300
Services During Construction (8%)
Total Capital Cost
I. 8 00
S 28,000
Present worth at 10% discount rate and 30 ye:us.
5 360.000
-------
-36-
More than one attempt at drilling a new well is possible. Since
the rate of withdrawal from the new well would be small, there
would be littl~'effect on the migration behavior of the
contaminant plume. If an uncontaminated well outside the plume
cannot be suitably located, treatment technologies similar to
those described in Alternative 3 may be employed to provide clean
water to affected and potentially affected residents.
The water distributed to residents in this alternative would need
to meet all criteria within the Safe Drinking Water Act and
Pennsylvania's Safe Drinking Water Regulations.
The costs associated with this alternative are shown in Table 10.
This alternative assumes that 20 homes currently affected by the
CryoChem site would be connected to the new water system. This
alternative also assumes that 11 additional homes and 2
businesses would also be connected into the new water system.
-IX.
Summary of the Comparative Analysis of Alternatives
Each of the 4 remedial alternatives for this operable unit are
compared and evaluated against 9 criteria to determine which
remedial alternative and combination of technologies and
management or process options will best meet the primary
objective of this ROD. The 9 evaluation criteria are:
1. Overall Protection of Human Health and the Environment:
Whether or not the remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with ARARs:
Whether or not the remedy will meet all applicable or
relevant and appropriate requirements (ARARs) of federal
and state environmental statutes and/or provides grounds
for invoking a waiver. Whether or not the remedy complies
with advisories, criteria and guidance that EPA and PADER
have agreed to follow.
3. Long-term Effectiveness and Permanence:
The ability of the remedy to maintain reliable protection
of human health and the environment over time once the
cleanup goals have been met.
-------
-37-
TABLE
10
ESTI~tATED COST TO INSTALL NEW WELL OUTSIDE PLUME
Annual
CaDital ~
Well Installation S 4,000
Well Pump and Controls 5,000 5 5.000
Structure and Storage Tanks 85,000 6.000
Distribution Pumps 23,000 5.000
Electrical Service 10,000
Force Main 86,000 1.000
House Service and Meters 67,000 2.000
Miscellaneous 10,000
Lab Analysis 1.000
In-House Carbon System Removal 6.000
5300.000 520.000
Bid Contingency (15%) 44,000
Scope Contingency (10%) 30.000
Construction Subtotal 5370,000
Permitting and Legal (5%) 18 ,000
Engineering Design (10%) 37,000
Service During Construction (8%) 30.000
Total Capital Cost 5450,000
Present worth at 10% discount rate and 30 years
5640.000
-------
-38-
4. Roduction of Toxicity, Mobility and Volume:
The anti~pated performance of the treatment technologies
the remedy may employ.
5. Short-term Effectiveness:
The period of time needed to achieve protection, and any
adverse impacts on human health and the environment that
may be posed during the construction and implementation,
until cleanup goals have been achieved.
6. Ability to bo Implemented:
The technical and administrative feasibility of a remedy,
including the availability of materials and services needed
to implement a particular option.
7. Cost:
Includes estimated capital, operation and maintenance, and
net present worth costs.
8. Stato Acceptance:
Indicates whether, based on its review of the focused
feasibility study, the proposed plan, and the Record of
Decision, the State concurs with, opposes, or has no
comment on the preferred and selected alternatives.
9. Community Acceptance:
Indicates whether, based on its review of the focused
feasibility study and the proposed plan, the community
agrees with, opposes, or has no comment on the preferred
alternative.
The following section compares each of the 4 remedial alter-
natives developed in this ROD against each of the 9 evaluation
criteria.
A.
Overall Protection of Human Health and the Environment
Alternatives 2, 3 and 4 are each protective of human health. The
water which would ultimately be distributed to the affected and
potentially affected homes would meet or exceed all federal and
state drinking water standards. Drinking water standards are
established within the Safe Drinking Water Act. Furthermore,
Alternative 2 would provide protection' of human health without
monitoring because the Boyertown municipal water system does not
-------
-39-
contain any of the volatile organic chemicals originating from
the cryoChem site. The Borough is also required to sample their
water to ensure that standards contained within the Safe Drinking
Water Act and ~ennsylvania's Safe Drinking Water Regulations are
met. Thus, Alternative 2 would be the most protective of human
health~ .
When properly designed and sufficiently tested, a new water
supply developed outside of the plume of contamination would not
contain volatile organic chemicals originating from the cryoChem
site. However, periodic water sampling would be employed as part
of Alternative 4 to ensure the protection of public health.
When properly designed and sufficiently tested, a new water
supply developed within the plume of contamination would
discharge water into the distribution system which would meet
or exceed all federal and state drinking water standards. The
discharge from carbon units at individual homes would also meet
applicable standards. However, periodic water sampling would be
employed as part of Alternative 3 to ensure the protection of
public health.
Alternative 1 would not be protective of human health. The.
carbon units installed at homes would be removed under the no
action alternative.
\ \
.
Alternative 3 would be most protective of the environment because
the treatment employed in this alternative would reduce the
amount of volatile organic chemicals already in the environment.
Management or process options 3A and 3B would remove contaminants
near the source area. option 3C would also remove contaminants
from the within the plume.
Unless existing private wells are plugged and abandoned as part
of Alternatives 1, 2, 3A, 3B and 4, these alternatives would not
satisfactorily inhibit the further downgradient migration of
contaminants. Should the plume spread further, additional homes
and wells downgradient from the site could be affected. since
private wells at the edge of the contaminant plume would be
pumped intermittently during implementation of Alternative 3,
option 3C, this alternative would have the added benefit of
providing some protection for downgradient users of ground water.
Alternative 3 is the alternative which best combines protection
of human health and the environment and consistency with the
remediation of the entire site. Thirteen homes affected by the
cryoChem site currently have carbon units installed. Sampling
data indicates that human health has been protected by these
units.
B.
compliance with ARARs
Table 11 identifies Applicable and Relevant or Appropriate
Requirements for the alternatives developed in this ROD.
-------
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-------
-42-
Alternatives 2, 3 and 4 should each comply with Applicable,
Relevant and -Appropriate Requirements (ARARs) and guidance
criteria. The water supplied under Alternative 2 would
consistently me~t federal and state standards. Periodic sampling
would be required of the Borough of Boyertown to ensure that
standards contained within the Safe Drinking Water Act and
Pennsylvania's Safe Drinking Water Regulations are met. Since
the Borough water supply does not contain volatile organic
chemicals from the CryoChem, .the standards would be met.
The Borough of Boyertown has review procedures applicable to
extensions to their water system. The Borough currently has
several objections to the implementation of Alternative 2. If
the Borough does not approve of the water line extension,
Alternative 2 may not comply with this ARAR.
Alternative 4 would meet federal and state standards, but would
need to be periodically checked to ensure that the water supply
does not become degraded should volatile organic chemicals from
the site migrate into the well. Periodic sampling would be .
required to ensure that the water distributed to residents woulti
meet standards contained within the Safe Drinking Water Act and
Pennsylvania's Safe Drinking Water Regulations.
.
Water supplied under Alternative 3 would meet federal and state
standards, but because the water supply is contaminated by
volatile organic chemic~ls from the CryoChem site, periodic
monitoring of the effluent would be required. The water
distributed to residents would need to meet all standards
contained within the Safe Drinking Water Act and Pennsylvania's
safe Drinking Water Regulations. In addition, the air stream
effluent from the air stripper would need to meet criteria
established within the Clean Air Act and Pennsylvania's Air
Resource Regulations. Alternatives involving the use of carbon
adsorption also would need to comply with guidelines contained
within the Resource Conservation and Recovery Act.
Alternative 1 would not meet federal and state standards since
the pUblic would be supplied with water which does not currently
meet federal and state standards.
C.
Long-torm Bffoct~venoss and Permanence
Alternative 2 is the most permanent remedy for Operable Unit 1.
Once the system is installed, the water supplied would not
contain volatile organic chemicals from the CryoChem site.
Alternative 4 is a permanent remedy if hydraulic and chemical
testing completed during the RI/FS for Operable Unit 2 and during
the design of this alternative indicate that the well would not
be degraded by volatile organic chemicals from the CryoChem site
based on the hydraulic gradient and the new well's capture zone.
Once the remedy is implemented, periodic sampling would be
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required to ensure the long-term effectiveness of the remedy.
Alternative 3 is not a permanent remedy since the source of
ground water supplied is contaminated. After the RI/FS is
completed, a remedy for the site will be selected. If the
results of the RI/FS indicate that ground water extraction at the
site will be necessary, an alternative similar to Alternative 3
may be developed as a permanent remedy for Operable Unit 2.
Alternative 3 can be conside+ed an interim remedy for Operable
Unit 1.
Alternatives 2, 3 and 4 each require long-term maintenance, but
this maintenance would be most critical to Alternative 3 since a
breakdown would result in the distribution of contaminated water
to residents.
Alternatives 3 or 4 are the most consistent with the long-term
remediation of the cryoChem site. The treatment options which
are part of Alternative 3 would help to reduce the amount of
volatile organic chemicals in the environment. Sampling and
monitoring required in Alternatives 3 and 4 could be- integrated
into the remedy employed for the entire site. \
D.' Reduc~ion of Toxicity, Mobili~y, or Volume through Treatment
.
Only Alterna~ive 3 would result in a reduction in the volume of
volatile organic chemicals in the aquifer. Management or process
option 3A simply would transfer the volatile organic chemicals
from the aqueous phase to the vapor phase and would discharge
them into the air. Management or process options 38 or 3C would
remove contaminants from the immediate environment, although
disposal of the residual (spent carbon) in a safe and effective
manner would be required.
Alternatives 1, 2 and 4 would not act to reduce the volume,
toxicity, or mobility of contaminants in the aquifer.
only Alternative 3 would reduce the mobility of the contaminant
plume. options 3A and 38 would inhibit the further migration of
contaminants off the cryoChem site, but would be ineffective at
inhibiting the further spread of contaminants at the edge of the
plume. option 3C would be the most effective means of inhibiting
the further downgradient migration of the contaminants since
private wells near the edge of the plume would remove
contaminants from the aquifer.
Unless private residential wells are plugged and abandoned under
Alternatives 1, 2, 3A, 38 and 4, these alternatives would do
little to reduce the mobility of contaminants which have aiready
migrated beyond the site boundary.
Alternative 3, option 3C, has already been proven to reduce the
volume of contaminants at 13 homes affected by the cryoChem site.
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-44-
E.
Short-torm Effectiveness
EPA has divided the site into two operable units to enable prompt
provision of a clean water supply to residents as part of the
first operable unit. The remediation of the entire site would be
addressed under Operable unit 2.
Alternative 3, option 3C, would be the quickest remedy to
implement and is the one which would least impact the environment
during construction and implementation. Alternative 3 would be
the quickest means to protect public health, although
Alternatives 2 and 4 would also be protective of public health.
Alternative 3, option 3C, would provide immediate protection of
human health at the 13 homes with the most serious contamination
since these homes are currently equipped with carbon units.
F.
Ability to Implement
Table 12 indicates the implementation time for each alternativ~.
Each of the alternatives consists of proven remedial technologie~
and management or process options. Each technology has been
effective at treating volatile organic chemicals at other sites.,
Each ,management or process option consists of a reliable strategy
to distribute clean water to residents.
TABLE 12
IMPLEMENTATION TIME
Alternative
Time
1
2
3A
3B
3C
4
12-18
9-15
9-15
<6
6-12
months
months
months
months
months
Alternative 2 would be the most difficult remedy to implement and
would take the longest time to implement. Alternative 3 would
require pilot testing and/or periodic sampling to ensure
efficient operation, but would be only moderately difficult to
implement. Alternative 4 would require initial testing and
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-45-
analysis to ensure an adequate and safe water supply, but would
be only moderately difficult to implement. Each remedy could be
constructed from readily available parts and components.
-
Alternatives 3 .and 4 would require periodic monitoring and
sampling to ensure that public health was being protected.
Alternatives 3A, 3B and 4 would requ-ire sample collection from a
central location. .Alternative 3, option 3C, would require
periodic sampling at several. locations, i.e., residential homes.
All sampling schedules would be determined during the design
phase.
Alternative 2 would require significant coordination and
cooperation from the Borough of Boyertown and communities along
the right-of-way for the water line. Alternative 4 and
Alternative 3, options 3A and 3B, would require the cooperation
of the Borough of Boyertown, a public utility or a newly
developed authority to operate and maintain the new water supply
system. These plans would be determined during the design of the
alternative. Alternative 3, option 3C, and each of the other
alternatives, would require the cooperation of individual.
homeowners.
Alternative 4 and Alternative 3, options 3A and 3B, would require
additional storage capacity to ensure uninterrupted service. '
During periods of increased demand or periods when a pump is
being repaired or maintained, water could be distributed from the
storage tank. Alternative 2 might also require storage capacity
to ensure adeqqate fire protection or uninterrupted service
during line maintenance. No storage facility would be required
in Alternative 3, option 3C, since pump maintenance would be the
responsibiity of the homeowner.
The implementation of Alternative 3, option 3C, would be
simplified by the current existence of carbon filter units on 13
affected homes. The fact that sampling data from these 13 carbon
units show that the levels of volatile organic chemicals have
been reduced below MCLs or lxlO.6 cancer risk levels demonstrates
that technology employed under Alternative 3, option 3C, was
proven to be effective.
Alternatives 2, 3 and 4 would need to be adaptable to accomodate
new connections into. the water systems. Alternative 3, option
3C, would be the most adaptable alternative. other alternatives
would require significant modifications to accomodate new
connections unless provisions for new connections are designed up
front.
G.
Cos~
The costs for implementation of each alternative are shown in
Tables 6, 7, 8, 9, and 10. The costs assume that 33 connections
into a new water line would be made. The costs for Alternative
3, option 3C, are also presented in Table 9A with the assumption
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-46-
that only 20 carbon units (at affected homes) would be installed
and/or maintained. Additional carbon units or service
connections would be installed or completed as necessary.
=
H.
stato Acceptance
The Commonwealth of pennsylvania has reviewed the Record of
Decision and has concurred with the selected remedy.
I.
community Acceptance
Durinq the public comment period, the Borouqh of Boyertown and
community members objected to Alternative 2 indicatinq that a
connection to the" Boyertown municipal system miqht cause poor
quality water to be distributed to homes near the CryoChem site.
other concerns with Alternative 2 included lack of flexibility,
siqnificant cost, inadequate fire protection, increased
development alonq the water line, and time of implementation.
Some community members favored the new water line as the most
effective means of distributinq safe drinkinq water to the
public, but expressed an unwillinqness to bear any costs
associated with water service.
Alternative 3 was favorably received by the public since this
remedy could be promptly implemented and would help to reduce
total site contamination.
x.
Selected Remedy
The remedial action alternatives included in the final analysis
were No Action, Connection to an Existinq Municipal Water supply,
Treatment of the contaminated Water and, Development of a New
Uncontaminated Water Supply. This operable unit addresses
provision of clean water to residents near the CryoChem site.
After the RI/FS is completed, a remedy for the entire site will
be developed. To the extent practicable, the remedy selected for
Operable Unit 2 will be consistent with Operable Unit 1. Any
remedial alternative not selected for operable Unit 1 may be
considered for Operable Unit 2 if it will achieve the qoals for
remediation of the media contaminated by the site.
The selected remedial alternative is a combination of Alternative
3 and Alternative 4. Specifically, this ROD selects installation
of dual activated carbon adsorption units or continued
maintenance of existinq carbon units at affected homes until a
permanent clean water supply is developed, implementation of
periodic samplinq a~ potentially affected homes, and construction
of a new uncontaminated water supply to serve affected and
potentially affected homes and businesses. This ROD also
provides for periodic samplinq to ensure that additional homes do
no~ become impacted before a final remedy for the CryoChem site
is selected and implemented.
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-47-
The components of the selected remedial alternative are:
;
A.
Installation and maintenance of dual activated carbon
units and ultraviolet disinfection systems at 7 homes
affected by the CryoChem site.
B.
continued maintenance of 13 dual carbon units currently
installed at 13 homes. affected by the CryoChem site.
Periodic sampling at 20 homes affected by the CryoChem
site to ensure that the carbon filters are working
properly.
C.
D.
Periodic sampling at 11 additional homes and 2
businesses to ensure that they do not become affected by
contamination from the CryoChem site.
Installation and maintenance of dual carbon units at homes
which become contaminated by contamination from the
CryoChem site. .
E.
F.
Periodic sampling of homes outside the affected area to
ensure that no additional homes become affected by
contamination from the CryoChem site.
Locating and/or drilling a new water supply well.
G.
H.
Pump testing and well sampling to determine optimal
yield and water quality.
I.
Design and construction of a water storage tank and
distribution system to deliver clean water to residents.
Design and construction of an air stripper or carbon
adsorption unit(s) to treat the water if necessary.
J.
Alternative 3, option 3C, is the most adaptable, timely, and most
easily implemented alternative which is protective of human
health and the environment and satisfies the primary objective of
this operable unit. Because Alternative 3, option 3C, is only an
interim remedy, this ROD also selects development of a new water
supply to provide clean water to affected homes and potentially
affected homes and businesses on a permanent basis.
The location and construction details of the new water supply
well will be finalized during the design stage of the selected
remedial alternative. If necessary, based upon results of
chemical sampling, an air stripper(s) and/or carbon adsorption
unit(s) will be designed and installed on the new well to ensure
that the water delivered to residents is free of volatile organic
contamination.
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-48-
After the RI/FS is completed and a remedy selected for the entire
CryoChem site, the remedy for this operable unit may be revisited
and revised to fit into the remedial strategy for the entire
site. After the RI/FS is completed, additional information which
becomes available may direct EPA to reevaluate the remedial
alternative selected for Operable unit 1 and modify it, if
necessary, to become as cons{stent as possible with the overall
remediation of the Cryochem site.
The costs for the selected remedial alternative are indicated in
Tables 9A and 10.
XI.
Statutory Determinations
Protection of Human Health and the Environment
A.
The selected alternative is protective of human health. The
interim remedy, i.e., installation of dual activated carbon
units, would reduce the volume and mObility of volatile organic
chemicals in the environment while it is implemented. No
unacceptable short-term or long-term risks will be caused by
implementation of this remedy. The remedial technologies
employed in the selected remedy are proven to reduce the
concentrations of volatile organic chemicals to acceptable
levels.
B.
Attainment of ARARs
Given the limited scope of this operable unit, the selected
remedy will attain applicable or relevant and appropriate
requirements by preventing current and future ingestion of
water containing unacceptable levels of volatile organic
chemicals.
ground
The selected remedy for Operable Unit 1 will not effectively
restore the ground-water aquifer to its designated class. The
restoration of the aquifer will be addressed in Operable Unit 2.
C.
Cost-effectiveness
The selected remedy is cost-effective. The health of the public
will be protected and clean water distributed to residents on an
interim and permanent basis for less money than other
combinations of alternatives.
D.
utilization of Permanent Solutions Employing Alternative
Technologies to the Maximum Extent 'Practicable
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-49-
Because of the limited scope of this operable unit, a permanent
remediation of the ground-water aquifer was not considered.
However, a permanent source of clean drinking water to residents
affected by the site will be developed. The remedy selected in
Operable unit 2 will employ permanent solutions to the maximum
extent practicable. ..
E.
Preference for 'Treatment as a Principle Element
The selected interim remedy employs a treatment technology which
is proven to reduce the volume of volatile organic chemicals.
The preference for treatment of all site related contamination
will be considered when selecting a remedial strategy for the
entire site.
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APPENDIX A
-------
RESPONSIVENESS SUMMARY
CryoChem Superfund Site
Worman, Earl Tow~ship, Pennsylvania
A.
Overview
EPA's preferred alternative, i.e., Connection to an Existing
Municipal Water Supply, for Operable Unit 1, was outlined in the
proposed plan and released to the public on July 14, 1989.
During the 30-day public comment period and public meeting, the
potentially responsible parties, the Borough of Boyertown, and
several residents objected to that preferred alternative. In
general, the public comments suggested that EPA's preferred.
alternative would not provide residents with suitable drinking \
water, was non-adaptable, and too costly. At least 4 res idents, .
however, favored EPA's preferred alternative.
.
The potentially responsible parties preferred a remedy involvi~g
the treatment of contaminated water at individual residences ~r
from a central location. In general, the commu~ity preferr~d a
r~medy involving tr~atment of the contaminated water at the s~:=.
and/or at i~dividual homes, but some residents did feel that t~e
best alternative involved a connection into the municipal ~atar
:5ystem. The Borough of 30yertown objected to the extans ion ,):
i':s water' system (iue to antici;?ated ;?roblems '~/ith watec ~udl~':'",
water service, and subsequent Jevelopment.
Based upon the comments ~eceived, EP~ has reevaluated the
~emedial al~:rnatives :n the ~roposed plan and has sel~ct:G ~~
3lternative di~ferent than that outlined in the proposed ~13~.
The Record of Decision (ROD) details the remedial alternatlve
selected by EPA. Specifically, EPA selects a combination of
Alternative 3, Treatment of the Contaminated Water, and
Alternative 4, Development of a New Uncontaminated Water Supplj,
as the remedial strategy for Operable Unit 1 of the CryoChem
site.
B.
Summary of Comments Received During Public Comment Peri.,)~
The public comment period was held from July 14, 1989 to AU(;'~3':.
14, 1989. A public meeting was held on August 9, 1989. A
stenographic report of the public meeting was prepared by S?A.
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2
EPA reviewed, evaluated, and considered comments contained wit~in
several sources. The sources include:
A.
Stenographic Report of'Public Hearing held at the Earl
Township Municipal Building, R.D. 3, Boyertown, PA,
August 9, 1989.
B.
Susan P. LeGros (Montgomery, McCracken, Walker & Rhoads)
letter to Christopher Pilla (U.S. EPA) , including
comments from JACA Corporation, submitted on behalf of
potentially responsible parties, August 14, 1989.
C.
Raymond C. Schlegel (Roland & Schlegel) letter to
Christopher pilla (U.S. EPA), submitted on behalf of the
Borough of Boyertown, August 14, 1989.
Borough of Boyertown letter to U.S. EPA, including
comments from G. Edwin Pidcock Co., August 7, 1989.
D.
E.
Kermit E. Bohn letters to Christopher Pilla (U.S. EPA)
July 21, 1989 and August 10, 1989.
E' .
Setty Burdan letter to Christopher Pilla (U.S. SP~)
August 21, 1989.
G.
William C. and Frances L. E'leck letter to ChristopheL
Pilla (U.S. EPA), August 3,1989.
:I.
~~. ~ ~rs. Wal~er s. Reigner latter to Christopher
(U.S. EPA), undated.
-- . , .
=":.....:..~
Comments raised during the public =omment ~eriod on the prJ~8s~:
plan and focused feasibility study are summarized below.
Following each comment summary is EPA's response.
COST/FUNDING ISSUES
I
1. EPA received significant comments concerning who would ~di
for the remedy which EPA selected. Several individual3 ex~r~s32;
a belief that, to the extent possible, CryoChem should be
responsible for providing clean water. Others, including
affected residents and officials of the Borough of Boyertow~,
were concerned about who would bear the costs of constructin~ 1~:
maintaining the system, annual water consumption costs, and :.~;,1:
fees for obtaining rights-of-way. .
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3
EPA RESPONSE: Under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended, EPA has the
authority to require respons~ble parties to pay for environmental
cleanup or to reimburse EPA for costs the government incurs in
responding to environmental contamination. In this case the
potentially responsible parties are the past and present owners
of the CryoChem site. EPA will give these entities the
opportunity to implement and pay for the selected remedy. If the
potentially responsible parties choose not to implement the
remedy, EPA will implement the remedy and attempt to recover its
costs from these parties.
The costs of the remedy include capital costs and fees associated
with obtaining rights-of-way. Before a remedy is designed and
implemented, a party would have to be designated and charged with
the responsibility for operating and maintaining a new water \
system.
REMEDIAL ALTERNATIVE PREFERENCES
1. The potentially responsible parties suggested that EPA
preferred the connection to 8oyertown's water ~upply over other
remedial alternatives due to the existence of a reliable
authority which would operate and maintain the new water line.
The comments further indicated that an authority would have to be
established to oper~te and maintain any of the alternatives ~hich
include development of a new water system, thus, the existence of
an authority should not be considered an evaluation criterion by
EPA.
EPA RESPONSE: EPA must evaluate each remedial alternative based
upon long-term effectiveness and administrative implementability.
Because the Borough of Boyertown already has a responsible
authority to operate and maintain the Borough's water system, a
connection to an extension of the municipal system could be
considered to be the most reliable long-term remedy in terms of
administrative implementation.
Implementation .of other remedial alternatives involving
development of a new water supply system require the development
of a new authority. A new authority responsible for the
operation and maintenance of a new water supply will be developed
before a remedy including a new water supply is implemented.
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4
2. The potentially responsible parties and other individuals
observed that some ~lternatives, e.g., Alternative 3, Treatment
of the Contaminated Water, provided two benefits. First,
residents would be provided with clean water (after treatment)
and second, the ground water contamination would be addresed.
EPA RESPONSE: EPA agrees with this comment. However, the
primary objective of Operable Unit I is to supply residents
clean water as early as possible. EPA has reevaluated the
remedial alternatives and has selected a combination of
alternatives which will be more flexible and thus can be
integrated into the remedial strategy for the entire site.
with
The use of a ground
may not be suit~ble
provide clean water
maintenance.
water treatment well as a public supply well
unless adequate backup can be designed to i
should the treatment system fail or require
DECISION PROCESS
1. The potentially responsible parties and some residents
indicated that EPA should wait until the RIfFS for the CryoChem
site is completed before selecting an alternate water supply for
affected residents. The comments suggest that contaminated
ground water beneath the site will be pumped and treated by
reliable technologies and that after the contaminated ground
water is treated, it could be distributed to affected residents.
The potentially responsible parties indicated further that the
RIfFS, which would be used by EPA to select a remedy for the
entire site, is scheduled to be completed in the fall of 1989.
EPA RESPONSE: EPA has separated the CryoChem site into two
operable units because residential wells near the CryoChem site
contain elevated levels of carcinogenic chemicals. The remedy
for Operable Unit 1, Drinking Water Supply, provides affected
residents with alternate water, thereby eliminating the risk to
public health. Based on the levels of volatile organic chemicals
in residential wells, EPA believes an early response to provide
clean drinking water is needed.
EPA is concerned by the possibility that clean water may not be
provided to residents hooked up to a treatment system should the
treatment system fail or require maintenance. Thus, EPA has not
elected to combine treatment of the site with provision of clean
water.
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;
5
The remedy selected in the Record of Decision would be flexible
so that it can be integrated into the remedy selected for
Operable Unit 2. The remedy selected in Operable Unit 2 will be
consistent with the remedy in Operable Unit 1. .
2. Several individuals expressed interest in EPA's decision-
making process. Questions from the public concerned how the
final decision would be made and whether EPA's final decision can
be appealed. One resident wanted to know if the public voted on
the remedy. Another resident wanted to know how the public would
be informed of the selected remedy.
EPA RESPONSE: EPA has evaluated public comments and has
reevaluated the remedial alternatives for Operable Unit 1. As
a result, EPA has selected an alternative different than that
outlined in the proposed plan and believes this alternative will
be acceptable to both EPA and the public. The public does not'
vote on various remedies, but is able to submit comments on the
remedial alternatives. EPA decides upon the selection of a
remedial alternative. The Record of Decision will be made
available to the public in the administrative record. The
availability of the ROD will be publicized.
EPA's final decision is embodiad withi~ the Record of Decision.
The public comment period was the opportunity for concerned
residents to comment on EPA's proposed plan. There is no appeal
process.
3. One resident asked about the stat~s of th~ 3 alcar~ati~es not
chosen ~y SPA.
EPA RESPONSE: The alternative outlined in the proposed plan and
discussed at the public meeting was preferred by SPA. ~he ~ther
3 alternatives were reevaluated in light of comments received by
EPA and reconsidered for implementation. In fact, EPA selected
an alternative different than the one outlined in the proposed
plan.
TECHNICAL CONCERNS REGARDING REMEDIAL ALTERNATIVES
1. Boyertown Borough officials and several other individuals
were concerned about whether Boyertown's water system cOuld
provide enough capacity to service the homas.affected by th~
CryoChem site and others that may hook up to the system in the
future. Several individuals also questioned the size of the
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6
proposed water main from Boyertown's municipal water system.
They questioned the ability of a 4 inch water line to provide
adequate fire protection and .to accept new hookups.
EPA RESPONSE: The scope of the focused feasibility study
included 20 homes affected by the CryoChem site. Therefore, the
municipal supply system was sized according to expected water
consumption within these homes. Boyertown officials initially
indicated that the water system had the capacity to add these
homes.
The pipe was not sized to allot for future development in the
area for two reasons. First, it would be difficult to estimate
the amount and type of future development along the 3 1/2 mile~
between Boyertown and the site~ Second, EPA does not believe \
that it would be equitable to have the potentially responsible
parties or Superfund pay for a system that would be designed to
include potential future hookups to the system not related to th~
CryoChem site. An entity other than EPA or the potentially
responsible parties would have to pay for the cost differential
between constructing a 4-inch pipeline and constructing a larger
pipeline. For the same reasons, the new ~ater supply would not
include provisions for. more fi~e protection than the residents
currently have.
2. 80th homeowners and 30yertown officials were concernec about
the quality of water that ;oul.~ ~e ~c~vidad t~ the homes t~ac !r~
affected by the CryoChem 51te. ~r. Sayman, a Borough official,
stated that ?ADER was ur~i~g aoyer~)wn to complete it5 dead ands.
qe also stated that, based ~n Jthdr ex~eridnces ~ith dead d~ds t~
the Boyertown water system, ~e ~eli~ves that the water i~ the
extension to the residents near CryoChem will stagnate in t~e
li~e. The Borough also indicated that it may not be feasible to
provide a loop between Boyertown and the affected area.
EPA RESPONSE: EPA acknowledges that avoiding dead ends is always
good practice and will provide better water quality. A loop
feature, if feasible, could be considered in the design of the
remedy. Considering the number of connections and the length of
the line, a loop feature may not be cost effective. Based on
these and other concerns, EPA has opted to select a remedy other
than connecting the affected homes into an extension of the
Borough's water system.
3. One i~dividua1 pointed out the fact that 30yertown's wat2r
has been chlorinated thereby necessitating the use of carbon
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7
filters at homes to be connected into the municipal water system.
Another individual 'inquired whether the carbon filters provide
adequate protection to residents.
EPA RESPONSE: Typically, a municipal water supplier adds
chlorine, which breaks down to chloroform, to rid the water of
disease-carrying organisms. EPA ~ccepts the small risk
associated with drinking the small amount of chloroform in
typical city tap water because of the large benefit of drinking
water which is free from disease. The carbon filters are
effective. They will provide residents with clean drinking
water, provided the filters are changed according to schedule.
4. Several individuals questioned how EPA's proposed remedy
would affect the ground water contamination at the site. Two
individuals noted that by not pumping the individual wells at th~
homes, contamination could spread downgradient quicker.
EPA RESPONSE: The remediation of the entire CryoChem site will;
be completed under Operable Unit 2, Area Wide Ground Water and
Source Area. The primary objective of Operable Unit 1, Drinking
Water Supply, is to provide clean water to residents. Once
private wells cease being operated, and the ground water
contamination is being addressed in Operable Unit 2, the private
residential wells should be plugged and abandoned to prevent
further migration of contaminants through the well bore.
If ground water water were pumped .from a well outside of the
plume of contamination, EPA believes it will have little effect
on the contaminant plume due to the relatively small amount of
water extracted and the probable high transmissivity of the
aquifer. The effects of not pumping residential wells near the
site are not known, but are probably not significant.
5. A number of individuals at the public meeting had questions
concerning the extent of a new water supply system. One
homeowner, located near other homes with carbon filters,
questioned why his water was not tested. Another individual
questioned why local businesses were not included in the focused
feasibility study. Other residents had questions concerning the
limit of the new water line and why residents with TCE detections
in 1982 are not considered.
EPA RESPONSE: EPA and the potentially responsible parties
continue to sample the ground water in the vicinity of the site
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8
in an effort to determine the extent of the contamination. The
remedy selected in this Reco~d of Decision includes homes and
businesses affected or potentially affected by the CryoChem site
based upon currently available data. The selected remedy also
provides for sampling at homes outside the affected or
potentially affected area to ensure other homes do not become
affected by the site.
6. The Borough of Boyertown and at leas~ one resident commented
on the length of time to implement EPA's preferred alternative.
It was suggested that it may take longer than anticipated. EPA
was also asked what would be done in the interim period before a
remedy was implemented.
\
EPA RESPONSE: EPA acknowledges that implementing the connection~
to Boyertown municipal supply will require the greatest amount o~
construction time and that it will take considerable time to
obtain appropriate legal agreements. The appropriate agreements.
and review processes will be obtained and followed in
implementing the connection into the municipal water supply and
all other alternatives. Carbon ~nits will be installed at
affected homes in the interim period before a remedy is
implemented. .
7. The potentially responsible parties and residents questioned
the potential for increased environmental impacts created by
implementation of an alternative which includes construction of a
new well outside the plume of contamination. The potentially
responsible parties also expressed concern that a well outside
the plu~e of contamination may interfere with remediation of the
site.
EPA RESPONSE: EPA assumes that a new well drilled in an
uncontaminated area will not affect long-term remediation of
site since the well's projected capacity will be small. The
well will not discharge enough water to significantly effect
contaminant plume. The well will be located and constructed
manner to ensure that the new water supply will not affect
remediation of the contaminated ground water.
the
new
the
in a
8. Two residents had comments related to the construction of
monitoring wells and residential wells. One individual
questioned if it wasn't possible to case residential wells deeper
to keep out contamination. Another individual wondered why
monitoring wells were drilled so close to one another at
different depths. .
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9
EPA RESPONSE: Several monitoring wells are installed for the
purpose of sampling ground water from the contaminated aquifer.
Because the depth of the contamination is not known, some
monitoring wells are intended to monitor deep ground water, while
others are intended to monitor shallow water. If the wells are
close together, i.e., well clusters, they allow EPA to determine
the'amount of contamination in shallow and deep ground water.
One way to prevent shallow contamination from entering a well is
to extend steel casing below the contaminated level. At this
time, EPA does not know the depth of the contamination, thus,
deeper casing on residential wells may not keep contamination out
of the well bore.
9. The Borough of Boyertown suggested that a second source ofi
water be provided for residents to be used when the water main
was being repaired.
EPA RESPONSE: EPA will include consideration for adequate
storage capability in each alternative.
.
10. One resident commented on the probable need for an
additional booster pump to deliver water to her home which is
topographically higher than route 562.
EPA RESPONSE: During the design phase of any remedial
alternative, EPA will consider proper engineering options
necessary to deliver clean water to all affected and potentially
affected residents.
11. A Borough official noted that two hills existed between the
Borough's reservoirs and the affected residents. EPA was asked
if the estimated costs for the preferred alternative included
costs for pumps to move water over two hills.
EPA RESPONSEs The design specifics of a remedial alternative
will be worked out during the remedial design phase.
ENFORCEMENT ISSUES
1. The current site owner corrected an EPA official and
indicated that the site currently had a proposed status on the
National priorities List.
-------
10
EPA RESPOR..: The cryoChem site vill be fiDalized OD the
NatioDal priorities List iD october, 1989. EPA CaD iDitiate
respoDse actioD. vhile the .ite ha. a proposed statu. OD the
NatioDal priori tie. List.
2. Two residents asked how the listing of the site on the
National Priorities List would affect cryoChem's finances and
operations.
EPA RBSPO.SB: EPAI. primary concern i. to r..ediate
eDvironmeDtal cODtaaiDation cau.ed by activities at the cryoChem
site. cryoCh.. mu.t operate iD accordaDce with all applicable
regulatioD.. The poteDtiallY re.poD.ible partie. are poteDtially
liable for co.t. incurred addre..iDg the cODtaaiDation at the
site.
3. One resident inquired as to whether the cryoChem facility was
being monitored to determine if they are still polluting the
ground water.
\
EPA RBSPO.SB: A a..edial IDve.tigation i. curreDtly underway at.
the .ite. Thi. iDve.tigation iDclude. ...pling of grouDd vater
at and near the .ite. The potentially re.poD.ible partie. are'
potentially liable for all co.t. incurred in addre..iDg the cleaD
up of environmeDtal media contaaiDated by the .ite. The remedial
alternative .elected for the .ite will addre.. all pathway. of
eDvironmeDtal cODtaaiDatioD. The OVDer. of CryoCh.. are
curreDtly involved with the peDDsylvania Departaent of
Environmental ae.ource. (PADBa) on various peraitting i.sue..
4. The previous site owner requested to know about the degree of
contamination in the area.
BPA RBSPO.SB: BPAls goal in aost cleanup actions is to achieve a
risk level that will result in no aore than one cancer death per
million expo.ed people in a lifetiae. The level. of ch..ical. iD
some of the re.idential well. are approaching 1000 times this
risk level.
5. The previous site owner requested to know which chemical
presented the most risk and why EPA did not go after the chemical
manufacturer.
BPA RBSPOBSB: Diehloroethene i. the eh..ical driving the ri.k at
the CryoCh.. site. BVA doe. Dot go after the ch..ical
manufacturer because they are .upplyiDg raw product. CBaCLA
enfore..ent doe. not provide a aeans to include raw product, only
waste.
-------
APPENDIX B
SUMMARY OF ANALYTICAL DATA
-------
Cnnl'enlralinn (111:./1.)
1'.0.
Name ~ Sallll)le n.lle --lli.1L . ..1DL -1:!1L ...1!QL --IDL S;lIn111c It,unl
Gonzales 49 IO/IJ/1lti8 NI) NO NI> NI> NI)
12/07/1Iti8 NI) NO NO NO NO
I.S.C., Inc. 62 10/ 1J/1lti8 NI) NO NI) NO NO
R&R Garber, Inc. 61 IO/IJ/1lti8 NI> NO NO NO NO
Dowell 64 06/02/H2c NO NI> NI)
07/lH/S-f NI> NO NO NO 0.68
10/13/888 NI> NO NO NO NI>
Moore 6S 07/lH/87c NI> NI> NO NO NI> ,.
Miller, K. 67 07/28/8-f NO NI> NO NO ND
tleek .68 07/27/87 NO NI> NI> 7 NI>
07/28/8-f 1.4 NO NO 7.4 NI>
rD/IS/81 S NO ND II 8
Rei&ner, Waller 69 OS/OS/82c NO NO 16.0
rD/2O/83c NO 17.8
12/01/Uc NO NO 19.0
IO/)J)/84c 10.2
OS/II/8-f NO 0.13
07/27/87 NO NO NI> NO NO
07/27/87 W
Romich, Elwood 71 1 NO NO NO 7 ~
07/28/8-f 1 NO NO NO NO
rD/15/81 1 . NO 1 NO 10
Weidner, Paul 12 rD/15/87 44 32 15 20 129 1
0)/2)/88 2S2 18 8 54 642 )
04/27/88 314 13 12 ~ 146 3
06/rD/88 39 3 2 S 114 )
07/27/88 288 14 9 14 666 )
12/01/88 121 6 3 16 186 ]
01/17/89 10) 14 8 20 276 ]
0)/rD/89 99 16 1 26 369 3
Greenly, Leiter 73 09/20/83c NO
12/01/83c 60.0 14.0 NO 15.0 560
OS/II/87c 92.45 10.76 5.19 15.11 366
07/27/1'.7 1)J) 12 NO 1)J) 19
07/lH/H-f I)J) 12 NO 19.0 510
fJJ/IS/H7 471 37 12 70 IDS2 I
10/06/1'.7 1734 14 12 2S 571 3
I2/UIi/H1 24S 1 6 13 384 )
-------
C '..nn:nlrall..n 11l:,'1 I
I'll
N,IIHC ~ S,IIH~~ - !!Lt...... --ILL- --1:!..:L ~ ~ ~~.~~
tircenl), Ic_IC.' (t "IIII'J) 1.\ 111/ II/f.f. 1-1\ S 4 III 2101i \
1I1/211/f.1I .\.111 1 1 II 117 ,
11I1/I1')/HII US 12 1 12 III') ,
117 j!1I/HII 121 1 2 2 SI,) \
12/111/1111 1111 III I. 21 1:1) \
111/17/11') 12.\ It. t. 43 :1C.2 .\
"VU'J/K') Ii! 14 (. ]5 ,11oU .\
SlrilUbc, tiunlen 74 (1)/11:'1/1120:. I~"I
I~Jj!II/H ,C 2011 'J.II 1117
12/1I1/1I1l: 10 12 ):'111
1Uf.\1I/1i IC 11211 .,
16/ II/I'. 7l: 111.:1.\ 04 NU 1')11
11112K/H7 27 I NU Ii 21111 ,
m/IS/H7 1')2 III 5 11 IUI. ,
IO/Ui./II 7 ~I'J ND Nil H 251 \
12/1~)/1I1 ')7 NU ND 11. ns ,
IOfI1/HII ]I) NU NU I 'JII 1
IH/!II/IIII 14 NU NU 7 112 .,
1>"/1)')/1111 tl2 I I 7 IH') 1
117/21'./1111 !1I3 II ) 10 712 ,
12/111/111'. 12 ,2 <2 ] 1411 ,
111/ It./H') 14 NU NU Ii 112 ,
111/0')/'0') NU NU NU NU NU 1
CryuChcm, In.. 14A 1II/II/b'O.i Ii NU NI> 12 1411 ro
N
C.S. (iiuhcr. In... 75 10/1 JlIIII" NU ND ND NU NU
(iilrhcr 111 I~/!)/III'- 11111
111/ 2'J/K20:. 1]11
OJ/IIS/Klc NU NU NU
(~I/ !II/K \1. ')II
1"'/ II/H/L .1117 227
01/2b/II/'- H NU ND 47 71
111/ D/bb" NU NU NU ND NU
Miller. It"hen 7') 117/21/H7 NU NU NU NU Nil
Diu/en. AI.III IiIIA tJlj!7/hl NU NU NU ND Nil
(iilrhcr. CW 112 WI/ !II/t! 10:. I-III
12/111/11-'1.. ND Nil ND ND
0)/ II/K7c NU ND NU NU Nil
(,."IoCl, ~I, (" 112 II'I/I)/hl 1/0 2 41
'..JI....I ' W NI 0"/ I ):h I I, Nil NU .. !S
..
-------
(""11"':1111";1""11 111:'/1 ,
1'1).
N.IIII&: ~ S.IIII..k~ - !!!.li..-. -1!JL --1TI:.- ...lli.:!L --1ll. ~,"Hpk 1"'11"
I h~n",hll, J.1II1; Iili UI/'I:Ii~' 1 II 1111
h'l/ 211/1i It 111 -1H
12/1i1/1i 1'- "IIi II 1111 Nil WII
111/ III/Ii II .I'I~
11'1/ II/Ii" .1\ .11 '11..1 ! II 11.71 .!IH.
IIl/!II/Ii/ 101 (, I III :!'/Il I
m/I'>/Kl 1-1 II .. 41, ]111; .1
Ill/I/I../lil 111 I) 3 2-1 111.1 .\
12/1111/11 7 IH '} 5 15 1.1(. .\
II\! 17 /Ii!! 1111 1 2 9 !21 \
HI/17 llill IS] -1 ] Ij '/II . \
III../Ir)/lill 7.. .1 2 I. 1/./, 1
IIl/!/ /11'1 11. \ I S lid! .\
11/111/111; 511 (, .1 III 1'}2 \
IH/1rJ /'}Ii M II ] 11 !II I
1I."'Lr, IL..II....1 II') 111 I:?', /1\ 7 5 ] Nil 1\ H,! I
11)/1)/1;.7 1'13 7 .\ ](I 211 I
12/1I1I/1i 7 117 \ ] 'J :!-111 I
II 1/17 /III! (.2 .. 2 1 122 1
UII:? 7/1111 57 2 I (. '11, I
1/I../II'l/hli 1.1 5 2 1 H.! \
IIl/! "11111 "') :! I ] NU I
I 2/1I1;1i:\ .0 .. .\ 1 . III! \
111/17/11'1 .\5 I 2 7 III'} I
U I/II'I/Ii'} 3'} 5 2 II 1.11 I
ID
111/ !Ii/Ii' 2 NU Nil Vol
IloAllllloAlI, KLn 11111 NU 110
IrI / ",>/,II 1 H. NU NU Nt> II
MlnlllngLr, n""Lrl 101 "'/~1I/1i1 32 .1 Nil S I,IU I
111/15/111 7-1 .. NU OJ I'}! I
IIJ/II(./Ill 115 -1 2 (. 171} I
I !/Ilk/ll 1 III, ] 2 ] 2011 \
111/n/1i1l 19 .. 2 OJ 1-17 I
1~1/!7/"11 1211 .. I II 5'} I
1/1../11'1/1111 t.') 3 I (, 1!5 \
07/!7/IIK S4 I I S ml .1
12/111/1111 31) 3 2 4 I-I'} \
lIl/ It./III} 32 .. 2 1 III! \
lI1/II')/II') 3-1 5 2 II 1101 I
"nLrun, (in:cn IU! lllif:?'>/Ii,t NU I'....
HI/I \!K2C '/II
1'}1I1.I'JII~C '1.\ !tj)
IJ')/ 211/11 1'- 2\ I
u-;/II/Ii I Nil
III,' !Ii/Ii 1 .l1i Nil I. 11111
..
-------
('''11''''1111.111'''' 11A::~1 I
I'll
Name ~ S.lIn..k 1I",,, ...l!L!i...- -l!1L -1.:!.L ..1lliL ~ :'\.IIHI,k 1"lluI
1\IILmn, (ireclI (("11111'01) 1111 m/ls/.,7 Nil to .j 5 ")\ J
III/ilt./ll 1 12~ I> 2 III !10I I
11/1111/1'.7 15 I Nil .j 117 1
111/21/111\ St. 7 1 25 hi .1
HI/.!]/.,I\ 11.1 'I .1 I, 'i.1 1
111./,1') /HH to) .j 2 12 !II/i .1
117/27/I\H II' J .. 'II .1
12/III/HI! IK .. 7 1'1 J
III/II./H') ..4 NI> Nil II 1.12 ]
"3111')/11') 42 t. 2 10 1'J7 .J
I\lIlIer, Chll~lIlIe 10] 1111/1)/.,1 71.
117/27/H7 41 4 1"11 7 1711 " I
'1')/IS/67 17 4 J II 1!1I I
1II/llt./117 7') 5 J 7 17') 1
12/11H/1I7 1115 7 2 7 221 ,
O]/IIi/1III 511 4 2 I) 11,(, 1
114/27/MII 139 4 I II 1.1 ,
0(./0')/l1li 5t. ] I 4 ]1) 1
11./01/l1li 211 J 1 5 112 1
01/16/1i9 ]1 4 2 7 lUll ,
0]/11) /II~ J8 5 2 ~ 157 1
IIlelll:r, l\ugu~I"~ 111-1 1')1'.1-1")1;2 1117
117/27/117 17 ND Nil ] 'J] 1
'1')/15/117 17 5 1 7 112 I
11./OH/H7 1112 5 2 7 I').'i ' OJ
11]/111/l1li 1>1 2 I 7 II,') 1 ~
01/27/l1li 65 2 1. II ~.S J
111./10/l1li 6] I 1 2 511 I
07/1.7/l1li 4'.1 NI> NU 6 122 I
12/01/1111 2') 2 I 4 1110 1
01/16/Ii') ~ 4 2 7 'J(, ,
0]/'1')/11') :?Ii" 5 2 II 12') I
l>avlo1~on, Eva 1U.'i 117/17/1'.7 ]] .1 ND t. 1111
0')/ I 5/1i 7 7K 4 J 10 1~2
IO/Ut./1I7 t.] 5 2 ND 1111
12/111'./117 ex. 7 ] 5 IK)
II 1/1 H/IiK t.4 ] I t. nil
'14/27 /lill II.S 2 2 12 4')
Ut./ lII/llli 44 ] I I 121;
117/27/lill NI> NI> Nil ND Nil
11/III/till 2t. 2 2 .. Itll
UI/III/Ii') ]2 Nil Nil 7 111.,
11]/11)/1'.') J2 NI> 2 II I.'"
-------
('.,nn:nlr,III.", 111::/1 I
I'll
N,lIne ~ ~,IIn..1c II.IIe -.lli.:L Jill... ~ ..JlliL ...J.L:L ~.IIHJlk 1~'.lnl
(iel~m&u, Am..IJ IOC. 1)'//1)/117 7) .. 2 II !INI I
12/1111/117 1111 7 II t. 2U'J \
0\/111/1111 n I I NU 77 \
IHJ27/1I11 'H 2 .\ II 1'1 \
oc./ 111/1111 71 .1 2 .. 11111 .\
U7/n/1IK 211') 2 I Nt) "" \
1!J02/11K 311 4 2 '6 IU .\
01/1(./11') ]1 4 2 6 'n ]
0'0/11')/11') 4) 6 2 ') 175 ,
Ilcny..., Alhen 107 11K/!5/1i1' 90
117/27/117 511 5 NU 10 2211 " I
I~J/15/1i7 90 5 ) 14 21i2 I
10/114,/117 lit. (. ] III 31M I \
12/.,,/117 117 III 2 (t 211] .\
IIVIII/IIK St 4 :\ 10 177 . \
01/211/l1li I~ ] ] ] tli. \
Ilt./ 111/l1li w 4 2 (. 11.1 .\
117/27/1111 1]2 5 2 (. ](,7 .\
12/02/11K 21 2 2 ] 1)2 .\
01/1(./l1li 41 S 2 II 12.'1 .\
O)/~)/II') 4J 6 ) 10 !'JIt \
(;uuJholll, I..ury 1011 11II/25/1i1 ' 511.11
07/27/M7 ') ND Nil I :\.\
~)/IS/87 5. 2 I 001 ]1
!XI
1'J1I1.1'}82' ,d ND ND NU ND U\
Yeager, Ik:rnalJ IIN 5h
07/27/117 ND ND NU ND NU
10/13/l1li8 NO ND ND NI) NI>
Nyman, Mrs. 110/ 04/11/82' NO
110" OS/IIS/1I2' Nt) Nt)
07/27/87 ND ND ND ND NU
Garber. Jr., Itus~ell 112 04/2'}/1I2' ND Nt) ND
07/27/117 NU NO ND NU Nt)
Ucrgman, RichanS 11.1 07/27/117 NU NU ND ND ..
0')/15/87 ] NO I ND 7
(iarbcr, ItanJeli 115 04/2'J//:!2c -- ND
0l./02/112' NO
07/211/117 NU ND NU NU NO
11111011110111 II'> IO/Il/ilila NU ND NU Nt) Nil
-------
(',,",'c"lr,,""" (11::11 I
I'll
N,II"C ~ S,IIII!,k !.!:!t.. . -1.!!.L -1DL -1:..!.l- -1!!..1L ~ '.III,ph: 1',,"11
(;lllIell, Lury 1110 II)/I!)/II! NU NU NU
1I<./1I1/K1 ~h
UI/ 1'I/K2 1111
11//1 I /Ii 7 ~ NU NU I 1'/ I
1rI/1)/K7 ,11 2 I " l.? 1
UIo/I~j/KK Nil NU Nil NU !~ :\
117/11/IIK II NI> NU NI> Nil :\
111/11/11'/ 110 2 I 4 4'1 :\
m/I~J/K'/ III ] 1 S I.~ :\
I\ed., I,,,,,hey 124 III/I I< ,/Ii 7 Nil NI> Nil NU Nil
111/ I :\flili" Nil NU NU NU Nil
" ,
It..um:h, lI.ury/Selllllj;er 1:\1. 1II/IN./1i 7 Nil NU Nil NU Nil
111/ I :\filii" Nil NU r-:II NU Nil
UcuJler, I );Ivul 137 III/Ik./b 1 Nil NU Nil NU r-:II
J)r.lhin)l.y, h..nl. I.W hl/lk./IS 7 NU NU Nil NU Nil I
Cenilj;lia, Rulh 1411 III/II<./Ii 1 Nil NU NU NU Nil
leul 1')1 11/1l1/1I1i" NU NU Nil NI> 1\111
Itunu.h, Itullal.! ~I)! IIl/11/Ii"l NU NU NU NU Nil
Vrumall, I'r.llli. ,:!t)c. 1rI/1'J/1i7 NU NU Nil NU Nil OJ
0'1
Care, SU)..u JIM, Ifl /11/11 1 NU NI> Nil NI> Nil
McCur..her ]1.11 IH/I.VIi1!: NI> NU Nil
I1J/15/'d1 NU NU NU NI> NU
SIC en. Ven.cnl 3Ik. 07/ 11!/K7 NU NI> NU NI> NU
G..bcl, W,lhdnl 3117 11)/15/111 NU NI> Nil NI> Nil
ScuJcI, M..na 31 iii 07/17/1>1 NU NI> NU NU Nil
1'Il'I., I>unna ]111 W/17/K7 NU NI> NU NU. Nil
Uraben)I.)', Juhn :\H 117n"l/1i7 NU NI> Nil NU Nil
111/ Illllli NU NI> NU NU NU
Shlfey. U..llici 11.. IfI/L'I/lil Nil NI> NU NU Nil
Shellllall, 1'.!w"l.! ,117 1171! 'Iii I Nil NU NU Nil ,n
Ir'll '/1;/ NU NU NU NU Nil
-------
('unl'C:nlr,,11I1II IjI~/11
I'.()
Namc ~ S,IIII,,'" l!:!!~ .i!LL .-lDL --1:!.L --1!!1L -1.!jL S.uul'k i'IHUI
(.1111. Wllhdlll :111 11'1/1)/1'. I NU NU NU Nil Nil
ScIJcI, Itnn..IJ J.!I III/!i/KI Nil NJ> Nil Nil r-;U
Itcmh...., (.CIIC HI III/! '/1'. 1 NU NU Nil Nil Nil
Ituyc r, 1 ..arry US 01/.!J/IH NU NU NU NJ> Nil
nreulegam 130 111/ U/tiHiJ NU 17 Nt> NU Nil
Ilorfnian/llemba,'h 331 1.!/IiI/ljJ' NU
US/II/Ill' NU '.1.10 ND r-;u
10/ U/Hlli. b NU Nt> NU "
III -III
Remerl 33S 10/ U/llb'* NU Nt> Nt> NJ> Nil
St:homlcy 336 10/13/1111'* NU NI> NU NU Nil
Mn)'e r ~] 0i./1I!'/1I2 NU
1')111-1'1112 2].2
111/ I J/lIKi Nil St. NU NU Nil
Il...dlu ](,I) 10/ U/bb<1 Nil NJ> NU NJ> NU
W, II onj; JIll 111/ I ~/I!t)d Nil NI> NU NU Nil
to)
Wllh~ -13') 111/ n/lilld Nil NI> ND NI) Nil "
Hyler 4-1-1 10/ IJ/lllli NU NU Nt> NI) Nil
Miller, 1'.1> -HII 07/n/lll NI> NU NU NU NU
10/ n/Hlla NU NU NU NU Nil
'r'eaj;cr 4-1') 01/H/1'.1 NU Nt> NU Nt> Nil
Uran~flclJ 4S0 111/21/1'.1 NU Nt> NU NU Nil
117/211/lllc NU NU Nt> NU NU h.)
nod, -IS" 01/211/1'. I' NU NU NI> NI> ND
l'U~l.h .aSS I*>/!)/III' Nt>
117 /2K/tHC Nil Nt> Nil 1.7 ! I
(lIud, I'"ul ..SI II II! 1/1'. 1 Nil NI> Nil 2 !
11'1/1)/1'.7 Nil Nt> NU NU Nil
'11/ I \/h"" NU NU NU S 15
-------
('IIII.'eIlU;,1I1I1I 111::/11 .
I'.CI
N.lllle !b S.IIIII.I.. 11.'1.. --1!!.:L -K!L -1:!L. --1!DL ~ ~.lIullk ,t,unl
Mi.:hcUclt!cr Troul hlrlll .n-~ IIX/!S/Xlc Nil
II~/II)/K!c ND Nil
11I../I1!/K!c ND Nil KII
III/IN./X 1 Nil Nil Nil Nil Nil
III/ii/liliil Nil NU NU Nil Nil
I 1..lIercr. licurt;c 01711 11l/IN./1i1 Nil NU Nil Nil Nil
CryuChcnl Monlluring Well #1 NI. II)/! 1/1i \c ND Nil Nil
l~)/ !II/II \c ND ND
n/UI/K3c NU NU NU NU
I~I/! 1/115c Nil ".
II1/Ul/K/,c Nil
115/ 1I/1I7c ND NU ND NU
CryoChclII MUnIlOrillt; Well #2 NI. 113/B/1I3c ND NU 131.
I~)/ !O/K3c Nil Nil
12/111 /1I3c NU Nil NU
117/ )II/Ii IC !15
1II/)lI/II-1c 1111
11)/ I-I/K5c 1-12
m/B/K~c 11101 .
117/11 l/K/,c 171
115/ II/K7c bll/. Nil 10/.7 I-IK
l 'ryul 'hem l'rut!ul'll'UI Well NI m/!II/K3c NU NU 2!1I 3;
12/01/li3c b.t. NU NU nu 3SU
07/30/K-1 175
111/311/11-1 311
US/10I/1I5 2.U.
~)/B/IIS 537
07/111/KI. 230
115/II/K7c 22')7 ND ND n.n 211
Uarlholumcw NI 1!/UI/K3c NU NU NU
J)r;ahlP~~Y NI III!/!S/Klc NU NI> Nil
117/!K/K7c NU NU
Muh,l (Arw) NI 1!/!I/IiIC nil
1~)/!II/K3C !..!
li,amhromc NI I!/!I/Klc Nil Nil
1 I"..., ,11..,hl NI I!/I!/l'ilc Nil Nil 1\
11"/ !II/"" Nil Nil 5:>
-------
(",lIll"enlr;olllln 1Il1:./1 I
I',(),
Namc ~ Sillll,,'" 11,'Il' ~ -lllL --ITL.- -lli:!L -1.LL :--'.lIul'k '-till.'
Ithudc~ NI. I'JIII-I')!i!c 1(,5
We... NI 1')III,I')Ii!C :?II
h'-'I, Inl". NI, llki!!"/lil NIJ NIJ Nil
Nllle~,
.,
,\11 dala IS (Will Ihc Cl)'o Chcm Groundwalcr Sile Analyl'l'al Itoul!. ~unllnal)' Itc'l,Jcnl...1 \Vcll Si'lIIl'lInl; CUlllpUIC.' IIIIIII"UI dalcd Al'nlli, 1')Ii') unle" IIllIcl""C 1II''','"lnl
.- ~ No lIala ava.lahlc.
NI : 1',0, JI,,~ numhcr wa~ nOI lisle:1I wilh Ihe rcsidcnllal well "..'ner'~ nallle,
a
Sample. wllcflcd by JACA dUring I'ha~c I or ltemcJI.,1 In\'c.llg;olllln Siully 0,\( ',\. 1')lItIh),
b
In a !cUcr h"m JACA 10 C:hri~ l'llia dalcll Nllvcmher I), I')lill, Ihe name ""r Ih.. enll)' i~ 1I.leli as Moyer anJ Ihc 1',0, II". Nil, .~ '],13, II""'CVCI, M..ycr .,1 1',11 II.., If U \ " II,,,,,,
IWlfC, I'lte bellcve~ Ihi~ I. an crr,.r 10 Ihe Icller,
..
noli.. Wol. rcpllllcJ III "l:voIluollion "I' J:n\'lwnmcnl.,I,\u"I)',c. l'crl"rmcJ lI1.hc \'lnnllY 0" ("1)'0 ChclII "'''1'," I'rcl'oIrc" hy JA("A ("orl", "'.llc", I'chruolry !I, l'/lili (,I:\l'.\, 1'/1\:\.1)
OJ
\D
II
~oIml'lc wa~ I"cnllllcli as Yeaager hul no 1',( I, II". "'''lIloer ..'... J:lVcn, 1'ltC a"umn III.. .. Ihe .ame Ye.'l;c, al I',() Bu. '1111, 'I hcre " "lIlIllIc I' \' c"1:el ..1 I' (I II.., If 11'1
-------
APPENDIX C
INDEX FOR ADMINISTRATIVE RECORD
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Cl
'CRYOCHEM GROUNDWATER CONTAMINATION SITE
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
I.
SITE IDENTIFICATION
1)
Report: Site Inspection of Cryochem, Incorporated,
prepared by NUS Corporation, 5/13/85. P. 100001-100263.
2)
Report: A Hazard Ranking System for Cryochem,
. Incorporated, prepared by NUS Corporation, 6/26/85.
P e. 1002 64-10037 4 e
*
Administ~ative Record File available 7/14/89.
Note:
Company or organizational affiliation is identi::~~
the index only when it appears in the file.
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II.
1)
C2
REMEDIAL ENFORCEMENT PLANNING
Administrative Order by Consent In The Matter of-The
Cryochem~Site, 2/14/88. P. 200001-200034.
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C3
III. REMEDIAL RESPONSE PLANNING
1)
2)
3)
5)
6)
8)
7)
9)
10)
11)
12)
Report: Cryochem, Incorporated Final Letter Report,
prepared by NUS Corporation, 4/14/87. P. 300001-300093.
Report: Evaluation of Environmental Analyses Performed
in the Vicinity of Cryochem Corp. [sic], Worman, PA,
prepared by JACA Corp., 2/24/88. P. 300094-300142.
Report: Scope of Work for CryoChem (sic1 RI/FS, prepared
by JACA Corp., 4/14/88. P. 300143-300197.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
6/28/88. P. 300198-300198.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
7/14/88. P. 300199-300199.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report;
8/17/88. P. 300200-300201.
Report: Sampling and Analysis Plan for CryoChem [sic]
Site, Earl Township, PA, prepared by JACA Corp., 8/88.
P. 300202-300342.
Letter to Mr. Christopher Pilla, U.S. EPA, from Mr.
Philip S. Getty, JACA Corp., re: CryoChem(sic)
residential well sampling program, 9/18/88. P. 300343-
300345.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
9/9/88. P. 300346-300346.
Letter to Dr. Albert C. Gray, JACA Corp., from Mr.
Christopher B. Pilla, U.S. EPA, re: Receipt of Cryochem
Revised Quality Assurance Project Plan Phase I
Residential Well Sampling Proposed Location and SAP
Revision, 9/23/88. P. 300347-300366. Residential
Sampling Results are att~ched.
Letter to Mr. Christopher B. Pilla, u.s. EPA, from Mr.
Philip S. Getty, JACA Corp., re: CryoChem(sic) Remedial
Investigation/Feasibility Study (RI/FS), 10/6/88. P.
300367-300370. The compiled data from the residential
well questionnaire is attached.
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13)
C4
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
10/18/88. P. 300371-300372.
.
Letter ta Mr. Christopher Pilla, U.S. EPA, from Mr.
Michael A. Johnson, PRC Environmental Management, Inc.,
re: Activities during residential well split sampling,
. .10/26/88. P. 300373-300382. An Inorganic Traffic
Report, an Organic Traffic Report, four Chain of Custody
Records, and an EPA Sample Shipping Log are attached.
15). Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
11/15/88. P. 300383-300385. A data table is attached.
14)
16)
17)
18)
19)
2 0)
21)
22)
Letter to Dr. Albert C. Gray, JACA Corp., from Mr.
Christopher B. Pilla, U.S. EPA, re: Residential well
sample results, 11/18/88. P. 300386-300388.
Report: Preliminary Health Assessment for Cryochem, .
Inc., prepared by the Agency for Toxic Substances and \
Disease Registry (ATDSR), 12/2/88. P. 300389-300393.
Memorandum to Mr. Chris Pilla, U.S. EPA, from Ms.
Michelle Fox, Roy F. Weston, Inc., re: Cryochem
Groundwater5ite Sampling Results, 12/2/88. P. 300394-
300414. Sample results are attached.
.
Letter to Mr. Christopher Pilla, U.5. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report,
12/14/88. P. 300415-300416. .
Report: Results of Phase I of Remedial Investigat~on
Study for Cryochem Site, Earl Township, PA, 12/88. =
300417-300516.
Memorandum to Mr. Christoper [sic] Pilla, U.5. EPA, from
Ms. Theresa A. Simpson, U.5. EPA, re: transmittal of the
organic data review package, 1/4/88. P. 300517-300598.
A memorandum regarding the organic data validation
results and the organic data review package are attached.
Letter to Mr.
U.S. EPA, re:
1/11/89. P.
attached.
Paul O'Lock from Mr. Christopher B. Pilla,
Results of residential well sampling,
300599-300600. A copy of the letter is
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23 )
24)
25)
26)
27)
28)
29)
30)
31 )
~5
Letter to Mr. Raymond Moyer from Mr. Christopher B.
Pilla, U.5; EPA, re: Results of residential well
sampling, 1/11/89. P. 300601-300602. A copy of the
letter is" attached.
~
Letter to Mr. Greg Breidegam from Mr. Christopher B.
Pilla, U.5. EPA, re:Results of residential well
sampling, 1/11/89. P. 300603-300604. A copy of the
letter is attached.
Letter to Mr. Charles L. Byler from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
"sampling, 1/11/89. P. 300605-300606. A copy of the
letter is attached.
Letter to Ms. 5helly Heimbach and Mr. Michael Hoffman
from Mr. Christopher B. Pilla, U.5. EPA, re: Results of
residential well sampling, 1/11/89. P. 300607-300608. A
copy of the letter is attached.
Letter to Mr. Christopher Pilla, U.5. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress report}
1/13/89. P. 300609-300610.
Memorandum to Mr. Christopher Pilla, U.5. EPA, from Ms.
Theresa A. Simpson, U.5. EPA, re: transmittal of the
inorganic data review package, 2/2/39. P. 300611-30C62i.
A memorandum regarding the inorganic data validation
results and the inorganic data review package are
attached.
Letter to Mr. Christopher Pilla, U.s. EPA, from 0=.
Albert C. Gray, JACA Corp., re: Mont~ll progress repor:,
2/13/89. P. 300628-300629.
Letter to Mr. Greg Breidegam from Mr. Chr~st~pr.er 3.
Pilla, U.S. EPA, re: Results of residential wel:
sampling, 2/23/89. P. 300630-300634. A list of the
parameters analyzed in residential wells and a fact
on lead are attached.
sheet
Letter to Mr. Charles Byler from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300665-300639. A list of t~e
parameters analyzed in residential wells and a fac: s~ee:
on lead are attached.
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C6
32)
Letter to Mr. Paul O'Lock from Mr. Christopher B. Pilla,
U.5. EPA, re: Results of residential well sampling,
2/23/89.. P~. 300640-300644. A list of parameters"
analyzed in residential wells and a fact sheet on lead
are attas;:hed.
33 )
Letter to Ms. 5helly Heimbach and Mr. Michael Hoffman
from Mr. Christopher B. Pilla, U.5. EPA, re: Results of
residential well sampling, 2/23/89. P. 300645-300649. A
list of parameteIs analyzed in residential wells is
attached.
Letter to The 5elfinger Residence from Mr. Christopher B.
. Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300650-300652. A list of
parameters analyzed in residential wells is attached.
34 )
35)
Letter to Mr. Paul Wills from Mr. Christopher B. Pilla,
U.5. EPA, re: Results of residential well sampling,
2/23/89. P. 300653-300655. A list of parameters
analyzed in residential wells is attached.
\ "
\
36)
Letter to The Bowers Residence from Mr. Christopher B. .
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300656-300658. A list of
parameters analyzed in residential wells is attached.
;
37)
Letter to Mr. Raymond Moyer from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300659-300661. A list of
parameters analyzed in residential wells is attached.
38 )
Letter to Mr. F. Daniel Miller from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300662-300666." A list of
parameters analyzed in residential wells and a fact sheet
on lead are attached.
39)
Letter to Mr. Edward 5chomley from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300667-300671. A list of
parameters analyzed in residential wells and a fact sheet
on lead are attached.
40)
Letter to Mr. Winfield Keck from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300672-300674. A list of
parameters analyzed in residential wells is attached.
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41)
42)
C7
Letter to Mr. John Tarins from Mr. Christopher B. Pilla,
U.5. EPA, re: Results of residential well sampling,
2/23/89. P'~ 300675-300679. A list of parameters
analyzed 'in residential wells and a fact sheet on lead
are attached.
Letter to Mr~ Bernard J. Yeager from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling" 2/23/89. P.. 300680-300682. A list of
parameters analyzed in residential wells is attached.
43), Letter to The Iezzi Residence from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300683-300685. A list of
parameters analyzed in residential wells is attached.
44)
45)
46)
47)
48)
49)
50 )
Letter to Ms. Joan Gonzales from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300686-300689. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Peter Riviello from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300690-300692. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Linwood Reinert from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300693-300695. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Claude Garber from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300696-300698. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Peter Willing from Mr. Christopher B.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300699-300701. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Theodore Hinaman from Mr. Christopher 3.
Pilla, U.5. EPA, re: Results of residential well
sampling, 2/23/89. P. 300702-300704. A list of
parameters analyzed in residential wells is attached.
Letter to Mr. Christopher Pilla, U.5. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress
reports, 3/13/89. P. 300705-300706.
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51)
52)
53)
54)
55)
56)
57)
C8
Letter to Mr. Christopher Pilla, U.S. EPA, from Mr.
Michael.A. Johnson, PRC Environmental Management; Inc.,
re: Summary of unresolved RI/FS Issues, 3/20/89. P.
300707-3Q0710.
Letter to Mr. and Mrs. John Drabinsky, re: Residential
well sampling results, 3/23/89. P. 300711-300713. A.
memorandum regarding the residential water sample results
is attached.
Analytical Results Summary Residential Well Sampling,
4/8/89. P. 300714-300725a.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress
reports, 4/14/89. P. 300726-300726.
Letter to Mr. Christopher Pilla, U.S. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress
reports, 5/15/89. P. 300727-300728.
Letter to Mr. Christopher Pilla, 0.5. EPA, from Dr.
Albert C. Gray, JACA Corp., re: Monthly progress
reports, 5/15/89. P. 300729-300730.
Report: Cryochem Site Focused Feasibility Study for
Alternate Water SUDoly, prepared by PRC Environmen~3:
Management, Inc., 6/30/89. P. 300731-300804.
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4)
5)
6)
7)
8)
9)
10)
11 )
12)
13 )
14)
15 )
16)
17)
C9
IV.
REMOVAL
Memorandum to Mr. James M. Seif, U.S. EPA, from Mr.
Gerald D~ Heston, U.S. EPA, and Mr. Charles Dispoto, U.S.
EPA, re: CERCLAFunding Request for the Cryochem
Groundwater Cqntamination Site, 9/16/87. P. 400001-
400010. An enforcement status, analytical results and a
site map are attached.
1)
Memorandum to Dr. J. Winston Porter, U.5. EPA, from Mr.
James M. 5eif, U.5. EPA, re: Justification for Approval
. of a Removal Action at the Cryochem Groundwater
Contamination 5ite, 9/16/87. P. 400011-400011.
2)
3)
Memorandum to Dr. J. Winston Porter, U.5. EPA, from Mr.
James M. Seif, U.5. EPA, re: transmittal of the CERCLA
request for a 12-month exemption, 11/10/88. P. 400012-
400016. The CERCLA request is attached.
Pollution Report #1, 8/17/87.
Pollution Report #2, 9/3/87.
Pollution Report #3, 9/4/87.
Pollution Report #4, 9/4/87.
Pollution Report #5, 9/8/87.
Pollution Report #6, 9/21/87.
Pollution Report #7, 9/25/87.
Pollution aeport #8,
9/25/87.
Pollution Report #9, 10/2/89.
Pollution Report #10, 10/9/87.
Pollution Report #11, 11/11/87.
Pollution Report #12, 11/12/87.
Pollution Report #13, 12/4/87.
Pollution Report #14, 1/28/88.
P. 400017-400018.
P. 400019~400019.
P. 400020-400020.
P. 400021-400022.
P. 400023-400023.
P. 400024-400024.
P. 400025-400026.
P. 400027-400027.
P. 400028-400029.
P. 400030-400031.
P. 400032-400033.
P. 400034-400035.
P. 400036-400037.
P. 400038-400039.
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CIO
v. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1)
A list of residences with EPA installed carbon filtration
systems (no author cited), (undated). P. 500001-500001.
-
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ell
GENERAL GUI~E !XX:UMENl'S *
1)
2)
"PranulQati?, of ~ites fran Updates 1-4," Federal Register, dated 6/10/86.
"Proposal of Update 4," Federal Register, dated 9/18/85.
3) Menorandum to U. S. EPA frcm Mr. Gene Lucero reqardinq ccmnunity relations
at Supert~nd Enforcement sites, dated 8/28/85.
4)
Groundwater Contamination and Protection, undated by Mr. ronald V.
. Feliciano on A/28/85.
5) MerDrandum to Toxic Waste ManaQement Divisiat Directors Regions I-X fran
Mr. William Hedeman and Mr. Gene Lucero re: Policy at Floodplains and
Wetlands Assessments for CERCtA Actiats, 8/6/85.
6) Guidance on Remedial Investiqations under CElCtA, dated 6/85.
7) G1idance on Feasibility Studies under CElCtA, dated 6/85.
8)
"Proposal of UDdate 3," Federal ReQister, dated 4/10/85.
9') MenDrandum to Mr. Jack McGra\1 entitled "Cannunity Relations Activites
at Suparfund Sites - Interbt Guidance, II dated 3/22185.
10)
11)
"Proposal of Ucdate 2,. Federal ~ister, dated 10/15/84
EPA Groundwater Protectiat Strategy, dated 9/84.
12) Memranchln to u.s. EPA fran'Mr. William Heclanan, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2,. dated 8/20/84.
13)
14)
"Proposal of Ucdate 1," Federal ReQister, dated 9/8/83.
Catmunity Re1atiats in Superfund: A Handbook (interim versiat), dated
9/83.
15)
"Pr(XX)salof First Natiatal Priority List," Federal ~ister, dated
12/30/82.
16)
17)
"ExD£nd:d Eliqibility List," Federal Register, dated 7/23/82.
"Interim Priorities List,. Federal Reqister, dated 10/23/Rl.
18)
~controlled Hazardous Waste Site Ranking System: A User's Manual
( undated) .
19)
20)
Field Standard COerating Procedures - Air Surveillance (undated).
Field Standard ~ratino Procedures - Site Safety Plan (undated).
* Located in EPA Reqiat III office.
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~PPENDIX D
LETTER OF CONCURRENCE FROM
COMMONWEALTH OF PENNSYLVANIA.
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D
'ENNSYLVANIA
~
.:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
Deputy Secretary for
EnvirQnmental Protection
September 29, 1989
~;'. . . . . --:.... ~
n~.. . ~. y
717-787-5028
Mr. Edwin B. Erickson
Regional Administrator
USEPA Region III
841 Chestnut Building
Philadelphia, PA 19107
OCT 0 S 1989
Ei.1, . . : I L
. . I ~
Ili~ :,. ~tI;l"11li. All.... II~rHAfQI
Re:
CryoChem Superfund Site
Operable Unit 1, Alternative Water Supply
draft Record Of Decision (ROD)
Dear Mr. Erickson:
The draft Record of Decision (as
1989) for the CryoChem site, Operable Unit
by the Department. It is my understandinq
Decision will be submitted to you for your
received September l~
1, has been reviewed
that this Record of
approval.
The proposed remedy for the Operable Unit 1,
Alternative Water Supply, would include the installation of
carbon treatment units as an interim measure, and construction of
a permanent replacement water supply system for the affected area
(20-30 homes).
I hereby concur with the EPA's proposed remedy, with
the following conditions:
.
.
.
.
EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DER design specific
ARARs .
The Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
The Department will reserve our riqht and
responsibility to take independent enforcement actions
pursuant to state and federal law.
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".;,
'---------'"~ -~..: ,.. '
----- ~
-'-
,,-
Mr. Edwin B~ Erickson
Regional Admi~istrator
- 2 -
September 29, 1989
*
This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section 104 (C) (3)..
If you have any questions regarding this matter please
do' not hesitate to contact me. .
i~.r;~Jl?;gl~
~MCC1.llan
.:- / Deputy Secretary
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