Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Raymark
Hatboro, Pennsylvania
EPA Region III
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Solid Waste and EPA 542-R-06-006f
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Raymark
Hatboro, Pennsylvania
EPA Region III
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Site Optimization Tracker
Raymark
Hatboro, Pennsylvania
EPA Region III
December 30, 2005
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SECTION 1:
CURRENT SITE INFORMATION FORM
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AN UPDATED SITE INFORMATION FORM HAS NOT BEEN PROVIDED
BECAUSE THE SITE IS NOW MANAGED AND FUNDED BY THE
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION.
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SECTION 2:
FOLLOW-UP HISTORY AND SUMMARIES
Note: Follow-up summaries are provided in reverse chronological order and include updated
and/or new recommendations.
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FOLLOW-UP HISTORY
Date of Original Optimization Evaluation
June 7-8, 2001 (site visit)
December 19, 2001 (report)
Meeting Date
May 8, 2002
January 21,2004
December 16, 2004
October 18, 2005
Report Date
Item
May 21,2002 Follow-Up A* (part of nationwide opt. effort)
April 12, 2004 Follow-Up B* (part of nationwide opt. effort)
March 7, 2005 Follow-Up #1 (conducted as part of pilot project)
December 30, 2005 Follow-Up #2 (conducted as part of pilot project)
Follow-Up #3
Follow-Up #4
Follow-Up #5
Follow-Up #6
"x" in box indicates the item has been completed
* Follow-up A and B were performed as part of a nationwide optimization effort, separate from
the pilot project under which Follow-up #1 and #2 were conducted.
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SUMMARY OF FOLLOW-UP #2
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
Raymark
December 30, 2005
October 18, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Peter Rich
Rob Greenwald
Doug Sutton
Kathy Yager
Chuck Sands
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3315
410-990-4607
732-409-0344
732-409-0344
617-918-8362
703-603-8857
Email
kuluj ian. norm@epa. gov
davies.kathyfg.epa.gov
prich(g),geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
vager.kathleentgiepa. gov
sands.charles(g),epamail.epa.gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Deanna Moultrie
Bruce Rundell
Affiliation
EPA Region 3 (RPM)
EPA Region 3 (Hydro.)
Phone
215-814-5125
215-814-3317
Email
moultrie . deanna(g),epa. gov
rundell.bruce(g),epa.gov
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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-6.1.5 Properly Seal Abandoned Wells
Effectiveness
Implementation
Status
Not implemented
Comments: The wells have not been abandoned. The RPM did not have the necessary funding and did not
realize that additional funding for optimization-related work could be requested from headquarters. The site team
does not plan to abandon the wells prior to transferring the site to the State.
Recommendation
Recommendation
Reason
E-6.1.7 Sample Air in Buildings for TCE
Effectiveness
Implementation
Status
Alternative Under
Consideration
Comments: Indoor air sampling in buildings and homes surrounding Superfund Sites has become a national
issue, and Regional management is pursuing this topic at the policy level. Implementation of this RSE
recommendation will hinge on Regional policy, and the time frame for devising that policy is unknown to the site
manager and project liaison at this time. Work on this recommendation lias been delayed until Regional policy is
in place; however, the site team acknowledges that it is appropriate to conduct at least a preliminary evaluation.
As part of this most recent follow-up meeting, the ROET has recommended that the soil gas survey that is
planned at the site for locating a potential source area be modified to preliminarily evaluate soil gas
concentrations between the source area and potential receptors for vapor intrusion.
Key for recommendation numbers:
E denotes a recommendation from the original optimization evaluation
Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
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RECOMMENDATIONS PREVIOUSLY IMPLEMENTED OR THAT WILL NOT BE IMPLEMENTED
Recommendation
Recommendation
Reason
E-6.1.1 Survey Site-Related Wells
Effectiveness
Implementation
Status
Implemented
Comments: Site surveying was added to the 5-year review work assignment in 2003. In addition, downhole
camera work was done in 2003 to determine problems with a pump in one of the onsite extraction wells. The
work was completed and is documented in the July 2003 Annual Ground Water Monitoring Report.
Recommendation
Recommendation
Reason
E-6.1.2 Measure Water Levels and Develop Potentiometric Surfaces
Effectiveness
Implementation
Status
Implemented
Comments: The water levels have been collected annually and potentiometric surface maps have been generated
both in plan-view and as cross-sections and are included in the July 2003 Annual Ground Water Monitoring
Report. The report suggests that capture is adequate, but EPA will be installing an additional extraction well to
target additional mass removal and source control nearPF-lS.
Recommendation
Recommendation
Reason
E-6.1.3 Delineate On-Site Plume
Effectiveness
Implementation
Status
Alternative implemented
Comments: Annual sampling has continued but additional monitoring points have not been installed. The site
team will use soil vapor samples to help locate the source area and place the new extraction well. The soil gas
survey is planned for 2006.
Recommendation
Recommendation
Reason
E-6.1.4 Analyze Capture Zone
Effectiveness
Implementation
Status
Implemented
Comments: A capture zone analysis was completed by the site contractor and included in the July 2003 Annual
Ground Water Monitoring Report. The site team is considering installing an additional recovery well near PF-1S
to augment mass removal and capture. The site team has proceeded with plans to install the new extraction well.
Installation is planned for 2006.
Recommendation
Recommendation
Reason
E-6.1.6 Evaluate TCE Impact to Pennypack Creek
Effectiveness
Implementation
Status
Will not be implemented
Comments: This recommendation will not be pursued. EPA's hydrogeologist has reviewed the recommendation
and has determined that the sampling will not yield any useful information for operations at the Raymark Site.
This is primarily due to the presence of other contaminant sources in the area that are unrelated to the Raymark
Site. It was noted that there is little concern that the creek is adversely impacted by volatile organic compounds
that are associated with the Site or its immediate neighbors.
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Recommendation
Recommendation
Reason
E-6.3.1 Complete O&M Manual
Technical Improvement
Implementation
Status
Implemented
Comments: The O&M manual lias been prepared by the existing site contractors. The O&M manual reflects
current operating procedures at the plant. Development of this O&M manual was funded through the existing site
O&M budget.
Recommendation
Recommendation
Reason
E-6.3.2 Compile and Organize Site Data and Documents
Technical Improvement
Implementation
Status
Implemented
Comments: The RPM has pursued this recommendation but has not been successful in locating
historical site information. The existing data and documents have been organized.
and compiling
Recommendation
Recommendation
Reason
E-6.3.3 Rename and Label Site
Technical Improvement
Wells
Implementation
Status
Implemented
Comments: The former MW-3D, which served as a recovery well, has been renamed to RW-3D to distinguish it
from another MW-3D, which serves as a monitoring well. This name change is apparent in the July 2003 Annual
Ground Water Monitoring Report.
Key for recommendation numbers:
* E denotes a recommendation from the original optimization evaluation
* Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
As mentioned in the previous follow-up summary, the site has officially been transferred to
Pennsylvania Department of Environmental Protection (PADEP). EPA is implementing the
recommendations and pursuing the activities it intended to do prior to the transfer. These
activities include conducting the soil gas survey, installing the new recovery well, and modifying
the treatment plant to accommodate the additional flow from the new recovery well. The
estimated cost for all of the remaining work is $270,000. The work was not conducted in 2005
as originally planned. The work is now scheduled for 2006
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
1. The ROET notes that the potential for vapor intrusion has not been evaluated for
potential receptors but also acknowledges that EPA has limited work left to complete at
the site. Part of the remaining work includes a soil gas survey to help identify the source
area so that ground water extraction could be appropriately targeted. The ROET suggests
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modifying the soil gas survey plan to include some sample locations between the source
area and potential receptors to determine if there is a reasonable potential for vapor
intrusion. If the soil gas sampling does indicate a potential concern, then EPA could
notify the State so that additional follow-up evaluations can be conducted. The ROET
believes that this modification to the soil gas survey can be made without a change in the
cost.
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SUMMARY OF FOLLOW-UP #1
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
Raymark
March 7, 2005
December 16, 2004 -
Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Peter Schaul
Peter Rich
Rob Greenwald
Doug Sutton
Jean Balent (by phone)
Chuck Sands
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S.EPAOSRTI
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3183
410-990-4607
732-409-0344
732-409-0344
703-603-9924
703-603-8857
Email
kului ian. nornngjepa. gov
schaul.peter@epa. gov
prich@geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
balent.jean(@,epamail.epa.gov
sands.charles(@,epamail.epa.gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Deanna Moultrie
Bruce Rundell
Affiliation
EPA Region 3 (RPM)
EPA Region 3 (Hydro.)
Phone
215-814-5125
215-814-3317
Email
moultrie . deannafg.epa. gov
rundell.bruce(@,epa.gov
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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
6.1.1 Survey Site-Related Wells
Effectiveness
Implementation
Status
Implemented
Comments: Site surveying was added to the 5-year review work assignment in 2003. In addition, downhole
camera work was done in 2003 to determine problems with a pump in one of the onsite extraction wells. The
work was completed and is documented in the July 2003 Annual Ground Water Monitoring Report.
Recommendation
Recommendation
Reason
6.1.2 Measure Water Levels and Develop Potentiometric Surfaces
Effectiveness
Implementation
Status
Implemented
Comments: The water levels have been collected annually and potentiometric surface maps have been generated
both in plan-view and as cross-sections and are included in the July 2003 Annual Ground Water Monitoring
Report. The report suggests that capture is adequate, but EPA will be installing an additional extraction well to
target additional mass removal and source control nearPF-lS.
Recommendation
Recommendation
Reason
6.1.3 Delineate On-Site Plume
Effectiveness
Implementation
Status
Alternative implemented
Comments: Annual sampling has continued but additional monitoring points have not been installed. The site
team will use soil vapor samples to help locate the source area and place the new extraction well.
Recommendation
Recommendation
Reason
6.1.4 Analyze Capture Zone
Effectiveness
Implementation
Status
Implemented
Comments: A capture zone analysis was completed by the site contractor and included in the July 2003 Annual
Ground Water Monitoring Report. The site team is considering installing an additional recovery well near PF-1S
to augment mass removal and capture.
Recommendation
Recommendation
Reason
6.1.5 Properly Seal Abandoned Wells
Effectiveness
Implementation
Status
Not implemented
Comments: The wells have not been abandoned. The RPM did not have the necessary funding and did not
realize that additional funding for optimization-related work could be requested from headquarters. The site team
does plan to abandon the wells.
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Recommendation
Recommendation
Reason
6.1.6 Evaluate TCE Impact to Pennypack Creek
Effectiveness
Implementation
Status
Will not be implemented
Comments: This recommendation will not be pursued. EPA's hydrogeologist has reviewed the recommendation
and has determined that the sampling will not yield any useful information for operations at the Raymark Site.
This is primarily due to the presence of other contaminant sources in the area that are unrelated to the Raymark
Site. It was noted that there is little concern that the creek is adversely impacted by volatile organic compounds
that are associated with the Site or its immediate neighbors.
Recommendation
Recommendation
Reason
6.1.7 Sample Air in Buildings for TCE
Effectiveness
Implementation
Status
Not implemented
Comments: Indoor air sampling in buildings and homes surrounding Superfund Sites has become a national
issue, and Regional management is pursuing this topic at the policy level. Implementation of this RSE
recommendation will hinge on Regional policy, and the time frame for devising that policy is unknown to the site
manager and project liaison at this time. Work on this recommendation will be delayed until Regional policy is in
place.
Recommendation
Recommendation
Reason
6.3.1 Complete O&M Manual
Technical Improvement
Implementation
Status
Implemented
Comments: The O&M manual lias been prepared by the existing site contractors. The O&M manual reflects
current operating procedures at the plant. Development of this O&M manual was funded through the existing site
O&M budget.
Recommendation
Recommendation
Reason
6.3.2 Compile and Organize Site Data and Documents
Technical Improvement
Implementation
Status
Implemented
Comments: The RPM has pursued this recommendation but has not been successful in locating and compiling
historical site information. The existing data and documents have been organized.
Recommendation
Recommendation
Reason
6.3.3 Rename and Label Site Wells
Technical Improvement
Implementation
Status
Implemented
Comments: The former MW-3D, which served as a recovery well, has been renamed to RW-3D to distinguish it
from another MW-3D, which serves as a monitoring well. This name change is apparent in the July 2003 Annual
Ground Water Monitoring Report.
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
The site has officially been transferred to Pennsylvania Department of Environmental Protection
(PADEP). EPA is implementing the recommendations and pursuing the activities it intended to
do prior to the transfer. These activities include conducting the soil gas survey, abandoning the
wells, installing the new recovery well, and modifying the treatment plant to accommodate the
additional flow from the new recovery well. The estimated cost for all of the remaining work,
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which will be conducted in FY05, is $270,000.
EPA is working on an Explanation of Significant Differences to remove treatment at the two
public wells from the remedy.
Because this site is no longer under the management of EPA, it is recommended that follow up at
this site be discontinued. If technical assistance is requested in association with EPA's
implementation of planned activities during the term of this project, the ROET can provide this
assistance.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
None.
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Updated Cost Summary Table
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs ($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
(S/yr)
Actual Change in
Annual Costs
($/vr)
Original Optimization Evaluation Recommendations
6.1.1 Survey site-related
wells
6.1.2 Measure water levels
and develop potentiometric
surfaces
6.1.3 Delineate onsite
plume
6.1.4 Analyze capture zone
6.1.5 Properly seal
abandoned wells
6.1.6 Evaluate TCE impact
on Pennypack Creek
6.1.7 Sample air in
buildings for TCE
6.3.1 Complete O&M
manual
6.3.2 Compile and organize
site data and documents
6.3.3 Rename and label site
wells
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Technical
Improvement
Technical
Improvement
Technical
Improvement
Implemented
Implemented
Implemented
Implemented
Not
implemented
Will not be
implemented
Alternative
under
consideration
Implemented
Implemented
Implemented
$10,000
$87,000
$4,000
$0
$15.000
$0
$5,000
$10,000
$10,000
$10,000
Not quantified*
Not quantified*
Not quantified*
Not quantified*
Not implemented
Will not be
implemented
Not implemented
Not quantified*
Not quantified*
Not quantified*
$0
$2,000
$4,000
$4,000
$0
$1,000
$1,000
$0
$0
$0
Not quantified*
Not quantified*
Not quantified*
Not quantified*
Not implemented
Will not be
implemented
Not implemented
Not quantified*
Not quantified*
Not quantified*
New or Updated Recommendations from Follow-up A, May 8, 2002
None.
New or Updated Recommendations from Follow-up B, January 21, 2004
None.
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New or Updated Recommendations from Follow-up #1, December 16, 2004
None.
New or Updated Recommendations from Follow-up #2, October 18, 2005
1. Modify soil gas survey
plan to preliminarily
evaluate potential for vapor
intrusion
Effectiveness
No additional costs beyond those already allocated for other activities.
Costs in parentheses imply cost reductions.
* Actual costs for indicated items have not been recorded, but the site team has been implementing the recommendations and conducting other activities (such as a soil
gas survey and installation of another extraction well) for $270,000.
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APPENDIX A:
ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET
Note: Technical assistance items are provided in reverse chronological order.
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Technical assistance has not been provided by the ROET to date.
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APPENDIX B:
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
Note: The attached information sheet was generated during an original nationwide screening effort in
2000 and 2001 and has a different format than the currently used information sheet included in Section 1
of this document. The attached optimization evaluation report is the original Remediation System
Evaluation (RSE) conducted during the nationwide pilot optimization project funded by EPA
Headquarters.
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Raymark
Hatboro, PA (Region 3)
CERCLIS ID 0300894
Contact Information
RPM
Deanna Moultrie
1650 Arch Street
Philadelphia, PA 19103
215-814-5125 (phone)
215-814-3002 (fax)
moultrie.deanna@epa.gov
State Regulator
David Minsker
PADEP
Lee Park Suite 6010 555 North Lane
Conshohocken, PA 19428
610-832-6193 (phone)
610-832-6143 (fax)
Minsker.David@dep.state.pa.us
Contractor
Andy Hopton
COM Federal Programs
993 Old Eagle School Road
Wayne, PA 19083
610-293-0450 (phone)
610-293-1920 (fax)
HoptonAP@cdm.com
System Information and Data
Type of Fund-lead Site:
Date original ROD was signed:
Date of last modification to ROD:
Type of ROD:
Status of P&T system:
Primary goal of system:
Presence of NAPLs
Approximate annual O&M costs:
Costs related to monitoring:
Approximate pumping rate:
Result of previous evaluation of
peformance/effectiveness:
EPA-lead
9/28/90
Final
Operational
Containment & Restoration
Not present
$155,711
$140,000
62gpm
Not evaluated
Number of extraction wells:
Date of construction completion:
Date of operational and functional:
Expected date of turnover to state:
Expected date of completion:
Approximate downtime per year:
Number of monitoring wells used:
Frequency of sampling:
Is plume migration controlled?
Progress of aquifer restoration:
Difficulty (due to social/political factors) of
implementing minor/major changes:
2
1/1994
6/1995
1/2004
1/2014
2 weeks
0
0 times per year
Don't know
Don't know
minor/minor
Contaminants of Concern:
Treatment Processes:
Carbozol
Trichlorobenzene
Metals precipitation
Air stripping
Biological treatment
UV oxidation
Carbon adsorption
Filtration
Ion Exchange
Reverse Osmosis
Off-gas treatment
other/not sure
yes
yes
Comments:
Originally, the time frame for aquifer restoration was 20 years from system startup but we are currently re-evaluating the effectiveness of the remedy and
that time frame may change.
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REMEDIATION SYSTEM EVALUATION
RAYMARK SUPERFUND SITE
HATBORO, PENNSYLVANIA
Report of the Remediation System Evaluation,
Site Visit Conducted at the Raymark Superfund Site
June 7-8, 2001
Final Report
December 19, 2001
US Army
Corps of Engineers
US Environmental
Protection Agency
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EXECUTIVE SUMMARY
The Raymark site occupies 7 acres off Jacksonville Road in an industrial part of Hatboro, Pennsylvania.
The pump-and-treat system addresses ground water contamination, primarily trichloroethylene (TCE),
associated with the operations of various manufacturers of rivets and other metal manufacturers, including
the Penn Rivet and Machine Company that occupied the site from 1947 through 1954. The site has been
divided into the following three operable units:
OU1, completed in October 1995, addressed the soil contamination with excavation of a former
storage tank location, an asphalt cap, a multi-layer synthetic cap, and soil vapor extraction;
OU2 addressed the local drinking water supply by installing air strippers on select public wells to
treat contaminated ground water and vapor phase carbon to treat the off gas from the air strippers;
and
OU3 continues to address the onsite ground water contamination by extracting ground water,
treating it with an air stripper (equipped with vapor phase carbon to treat the off gas), and
discharging the treated water through a storm drain to nearby Pennypack Creek.
Hatboro water supply wells H-14 and H-17 are the only two remaining public water supply wells to
operate. The only costs associated with operation of these wells and treatment of the extracted water that
are associated with the Raymark site are for regular replacement of the vapor phase carbon.
The RSE team focused on OU3 and found a well-operated treatment system. However, possibly due to the
high turnover rate among EPA Remedial Project Managers for this site and changes in contractors, site
information and background, especially related to system design, is difficult to access or is unavailable. In
addition the recent sampling event in April and May 2000, was the only aquifer monitoring conducted
onsite in over half a decade. Recommendations to improve system effectiveness include the following:
The site-related wells require surveying and downhole camera work to determine the elevations of
the tops of the well casings and the screened intervals of the wells. Without this information
reliable potentiometric surfaces indicating ground water flow cannot be generated. In addition, this
information is necessary for plume delineation and evaluation of the capture zone.
Once this information is obtained for the site-related wells, water level elevations should be
measured and potentiometric surfaces should be generated for pumping and non-pumping
scenarios. This may require the installation of piezometers in each of the underlying stratigraphic
units. In addition, previously collected depth-to-water measurements can be converted to water
elevations for further evaluation.
The plume should also be better delineated. This can be accomplished through continuing with the
new annual sampling program and adding additional monitoring points in each of the underlying
stratigraphic units.
Once the potentiometric surfaces are generated and the plume is better delineated, the capture
zones for the extraction wells should be analyzed. This is especially pertinent given the
discrepancy between the extraction rate of 285 gpm suggested in the 1990 Feasibility Study, which
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was based on a preliminary capture zone analysis, and the current average extraction rate of 48
gpm. If onsite TCE contamination is not captured by the current pumping program, increased
pumping rates and additional extraction wells will be required.
Wells associated with the site, including a former extraction well, screen multiple stratigraphic
units, but are no longer used for pumping. These wells should be properly sealed to prevent cross
contamination of the stratigraphic units.
Samples should be taken of the sediments and surface water of Pennypack Creek, which is located
within a mile downgradient of the Raymark site. Figures in the 1990 Feasibility Study indicate
that the ground water plume may impact the creek. In addition, the creek is the discharge location
for the treatment plant effluent which, according to a consent decree, may have TCE
concentrations as high as 73 ppb.
Finally, TCE concentrations in the shallow subsurface underlying the eastern portion of the site
indicate that soil gas may have significant concentrations of TCE. This could adversely impact
onsite and nearby buildings. Air sampling in these buildings should be conducted.
These recommendations will likely require approximately $120,000 in capital costs and might increase
annual costs by more than $12,000.
The RSE team also found that site-related costs are reasonable, and the team has no current
recommendations for cost reduction. Rather, the focus of the site activities should address the above-
mentioned effectiveness concerns and the continued operation of the treatment plant. In addition, site-
related data and documents should be organized and made easily accessible to the site managers. Current
efforts to develop new site documents, compile existing documents, and organizing current information will
likely cost $30,000.
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response
(OERR). The objective of this project is to conduct Remediation System Evaluations (RSEs) of pump-
and-treat systems at Superfund sites that are "Fund-lead" (i.e., financed by USEPA). RSEs are to be
conducted for up to two systems in each EPA Region with the exception of Regions 4 and 5, which already
had similar evaluations in a pilot project.
The following organizations are implementing this project.
Organization
Key Contact
Contact Information
USEPA Technology Innovation
Office
(USEPA TIO)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax: 617-918-8417
yager.kathleen@epa.gov
USEPA Office of Emergency and
Remedial Response
(OERR)
Paul Nadeau
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Mail Code 5201G
phone: 703-603-8794
fax:703-603-9112
nadeau.paul@epa.gov
GeoTrans, Inc.
(Contractor to USEPA TIO)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
Army Corp of Engineers:
Hazardous, Toxic, and Radioactive
Waste Center of Expertise
(USAGE HTRW CX)
Dave Becker
12565 W. Center Road
Omaha, NE 68144-3869
(402) 697-2655
Fax: (402) 691-2673
dave j .becker@nwd02 .usace .army .mil
in
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The project team is grateful for the help provided by the following EPA Project Liaisons.
Regionl Darryl Luce and Larry Brill
Region 2 Diana Curt
Region 3 Kathy Davies
Region 4 Kay Wischkaemper
Region 5 Dion Novak
Region 6 Vincent Malott
Region 7 Mary Peterson
Region 8 Armando Saenz and Richard Muza
Region 9 Herb Levine
Region 10 Bernie Zavala
They were vital in selecting the Fund-lead P&T systems to be evaluated and facilitating communication
between the project team and the Remedial Project Managers (RPM's).
IV
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TABLE OF CONTENTS
EXECUTIVE i
PREFACE iii
TABLE OF CONTENTS v
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 1
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 4
1.5.3 HYDROGEOLOGIC SETTING 4
1.5.4 DESCRIPTION OF GROUND WATER PLUME 5
2.0 SYSTEM DESCRIPTION 6
2.1 SYSTEM OVERVIEW 6
2.2 EXTRACTION SYSTEM 6
2.3 TREATMENT SYSTEM 6
2.4 MONITORING SYSTEM 6
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 7
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 7
3.2 TREATMENT PLANT OPERATION GOALS 7
3.3 ACTION LEVELS 7
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 8
4.1 FINDINGS 8
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 8
4.2.1 WATER LEVELS 8
4.2.2 CAPTURE ZONES 8
4.2.3 CONTAMINANT LEVELS 8
4.3 COMPONENT PERFORMANCE 9
4.3.1 WELL PUMPS AND TRANSDUCERS 9
4.3.2 BLOWERS 9
4.3.3 VAPORPHASE GRANULAR ACTIVATED CARBON 9
4.3.4 CONTROLS 9
4.3.5 TRAY AERATORS 9
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS 10
4.4.1 UTILITIES 10
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 10
4.4.3 LABOR 10
4.4.4 CHEMICAL ANALYSIS 10
4.5 RECURRING PROBLEMS OR ISSUES 10
4.6 REGULATORY COMPLIANCE 10
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT
RELEASES 11
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4.8
SAFETY RECORD 11
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT . 12
5.1 GROUND WATER 12
5.2 SURFACE WATER 12
5.3 AIR 12
5.4 SOILS 12
5.5 WETLANDS AND SEDIMENTS 13
6.0 RECOMMENDATIONS 14
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS 14
6.1.1 SURVEY AND EVALUATE WELL CONSTRUCTION FOR ALL SITE RELATED MONITOR AND
EXTRACTION WELLS 14
6.1.2 CREATE A POTENTIOMETRIC SURFACE MAP FOR GROUND WATER AND ESTIMATE FLOW
DIRECTIONS AND MAGNITUDES 15
6.1.3 DELINEATE CONTAMINANT PLUME 15
6.1.4 EVALUATE CAPTURE OF THE ONSITE TCE PLUME 16
6.1.5 ENSURE THAT ABANDONED WELLS ARE PROPERLY SEALED 16
6.1.6 EVALUATE IMPACT OF GROUND WATER AND TREATED WATER DISCHARGE TO
PENNYPACK CREEK 16
6.1.7 SAMPLE AIR IN NEARBY BUILDINGS FOR TCE 17
6.2 RECOMMENDED CHANGES TO REDUCE COSTS 17
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 17
6.3.1 COMPLETE THE O&MMANUAL 17
6.3.2 ORGANIZE/COMPILE DOCUMENTS AND DATA ASSOCIATED WITH SITE 17
6.3.3 LABEL ALL WELLS AND RENAME WELLS TO AVOID CONFLICTS 17
List of Tables
Table 3-1.
Table 3-2.
Table 3-3.
Table 7-1.
List of Figures
Figure 1-1
Figure 1-2
Figure 1-3
Discharge criteria for Outfall 001
Discharge criteria for Outfall 002
Discharge criteria for air.
Cost summary table
The area surrounding the Ray mark Superfund Site including Hatboro wells H-14 and H-17
Site layout showing the locations of the monitoring and extraction wells
Cross section of geology underlying the Raymark Site
VI
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1.0 INTRODUCTION
1.1 PURPOSE
In the OSWER Directive No. 9200.0-33, Transmitted of Final FYOO - FY01 Superfund Reforms Strategy,
dated July 7,2000, the Office of Solid Waste and Emergency Response outlined a commitment to optimize
Fund-lead pump-and-treat systems. To fulfill this commitment, the US Environmental Protection Agency
(USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response (OERR),
through a nationwide project, is assisting the ten EPA Regions in evaluating their Fund-lead operating
pump-and-treat systems. This nationwide project is a continuation of a demonstration project in which the
Fund-lead pump-and-treat systems in Regions 4 and 5 were screened and two sites from each of the two
Regions were evaluated. It is also part of a larger effort by TIO to provide USEPA Regions with various
means for optimization, including screening tools for identifying sites likely to benefit from optimization
and computer modeling optimization tools for pump and treat systems.
This nationwide project identifies all Fund-lead pump-and-treat systems in EPA Regions 1 through 3 and 6
through 10, collects and reports baseline cost and performance data, and evaluates up to two sites per
Region. The site evaluations are conducted by EPA-TIO contractors, GeoTrans, Inc. and the United States
Army Corps of Engineers (USAGE), using a process called a Remediation System Evaluation (RSE),
which was developed by USAGE. The RSE process is meant to evaluate performance and effectiveness (as
required under the NCP, i.e., and "five-year" review), identify cost savings through changes in operation
and technology, assure clear and realistic remediation goals and an exit strategy, and verify adequate
maintenance of Government owned equipment.
The Raymark Superfund Site was chosen based on initial screening of the pump-and-treat systems
managed by USEPA Region 3 as well as discussions with the EPA Remedal Project Manager for the site
and the Superfund Reform Initiative Project Liaison for that Region. This site has a long projected
operating life and complicated hydrogeology. This report provides a brief background on the site and
current operations, a summary of the observations made during a site visit, and recommendations for
changes and additional studies. The cost impacts of the recommendations are also discussed.
A report on the overall results from the RSEs conducted for this system and other Fund-lead P&T systems
nationwide will also be prepared and will identify lessons learned and typical costs savings.
1.2 TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Frank Bales, Chemical Engineer, USAGE, Kansas City District
Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
Lindsey Lien, Environmental Engineer,USACE, HTRW CX
Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
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1.3
DOCUMENTS REVIEWED
Author
US EPA
CH2M Hill, Inc.
CH2M Hill, Inc.
ERM-Enviroclean, Inc.
CH2M Hill, Inc.
CH2M Hill, Inc.
US EPA
US EPA
Philadelphia Suburban
Gilmore & Associates, Inc.
Gilmore & Associates, Inc.
CDM Federal Programs
Corporation
Date
3/24/1988
9/1990
7/1991
6/28/1993
9/14/1993
9/30/1994
9/12/1995
4/16/1996
1997 - 2000
2/5/1997
7/17/2000
2/18/1999
5/21/1999
Title/Description
Record of Decision, Raymark Site, Hatboro Borough,
Montgomery County, Pennsylvania, AR, Sept. 28,
1990
Draft Final Focused Feasibility Study for Ground
Water Remediation, Raymark Site
Raymark Site RI/FS Final Soil/Source Area Remedial
Investigation Report, Operable Unit No. 1
Request for Determination of Requirement for Plan
Approval/Operating Permit Application for
Groundwater Treatment/Soil Vapor Extraction
Remedial Action Report, Raymark Superfund Site,
Hatboro, Pennsylvania, Operable Unit 2.
Raymark Remedial Action, Operable Units 1 and 3
Superfund Preliminary Site Close Out Report, Raymark
Superfund Site, Hatboro, Pennsylvania
Amended Work Plan for Hatboro Well H16 and the
Raymark Site
Hatboro Well Monitoring Report, 1997, 1st & 2nd
Quarter 1998, 3rd Quarter 1998, 2nd Quarter 1999, 3rd
Quarter 1999, 4th Quarter 1999, 1st Quarter 2000, 2nd
Quarter 2000, 3rd Quarter 2000
Raymark Site Groundwater Treatment System
Quarterly Progress Report for November-December
1996, January-March 1997, April-June 1997, July-
September 1997, January-March 1998, April- June
1998, July-September 1998, October-December 1998,
January-March 1999, April -June 1999, July-September
1999, October-December 1999, January-March 2000,
April-June 2000
Communication: TCE concentrations in Wells H14 and
H17 from 1983 through September 1996
Groundwater Data Trend Analysis Report for Raymark
Site, Hatboro, Montgomery County, Pennsylvania
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Author
CDM Federal Programs
Corporation
CDM Federal Programs
Corporation
CDM Federal Programs
Corporation
Date
6/8/1999
10/10/2000
12/22/2000
Title/Description
Well Survey Letter Report, Raymark Superfund Site,
Hatboro, PA
Sampling Summary Report for Raymark Superfund
Site, Hatboro, Pennsylvania
Quarterly Cleanup Status Report, Raymark Site -
Operation and Maintenance, November-December
1999, July-October 2000,
1.4
PERSONS CONTACTED
The following individuals were present for the site visit:
Frank Bales (USAGE) 816-983-3591 francis.e.bales@usace.army.mil
Kathy Davies (USEPA Reg. 3) 215-814-3315 davies.kathy@epa.gov
Rob Greenwald (GeoTrans) 732-409-0344 rgreenwald@geotransinc.com
Andy Hopton (CDM Federal) 610-293-0450 hoptonap@cdm.com
Lindsey Lien (USAGE) 402-697-2580 lindsey.k.lien@usace.army.mil
David Minsker (PAPED) 610-832-6193 minsker.david@dep.state.pa.us
Deanna Moultrie (USEPA Reg. 3) 215-814-5125 moultrie.deanna@epa.gov
Jerry O'Hara, Plant Operator, 215-343-2538johara@buckswater-sewer.org
Jim Romig (CDM Federal) 610-293-0450 romigjm@cdm.com
Bruce Rundell (USEPA Reg. 3) 215-814-3317 rundell.bruce@epa.gov
Doug Sutton (GeoTrans) 732-409-0344 dsutton@geotransinc.com
Yan Zhang (GeoTrans) 732-409-0344 yzhang@geotransinc.com
Bob Smauck (Gilmore Engineering, 215-345-4330) was contacted by phone after the RSE visit.
1.5
1.5.1
SITE LOCATION, HISTORY, AND CHARACTERISTICS
LOCATION
The Raymark Superfund Site, located on Jacksonville Road in Hatboro, Montgomery County,
Pennsylvania, occupies 7 acres. Between 1947 and 1954 the Penn Rivet and Machine Company owned
and operated a plant for manufacturing rivets. Various businesses have occupied the area since 1954, and
the site is currently owned and operated by Penn Fasteners, Inc., manufacturers of rivets and other
fasteners. Remedies at the site now address contamination from trichloroethylene (TCE) and other solvents
resulting from waste disposal associated with degreasing and electroplating activities. The area
surrounding the Raymark Site is shown in Figure 1-1 and the site layout is shown in Figure 1-2.
TCE contamination of the ground water in the Stockton formation, which supplies Hatboro with drinking
water, was first discovered in 1979, and investigations of groundw ater contamination began in 1981. In
1985 the EPA and the Borough of Hatboro filed suit against the owners and operators (former and current
as of 1985) associated with the Raymark Site. A resulting Consent Decree was issued in 1989. The site
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was divided into three operable units OU1 to address soil contamination, OU2 to address the drinking
water supply, and OU3 to address ground water contamination.
The 1990 Record of Decision (ROD) specified both onsite and offsite extraction and treatment of
ground water. Onsite extraction and treatment would require the installation of an extraction system and a
treatment system that includes treatment of the water by air stripping and treatment of the offgas with
vapor phase carbon. Offsite extraction would be achieved by pumping from local water supply wells H-14,
H-16, and H-17. Treatment of water extracted from these wells would be accomplished via air stripping
with vapor phase carbon used to treat the offgas. Wells H-14 and H-17 were outfitted with air strippers in
1984 and 1986 as part of a settlement with the Fischer and Porter Company located to the northwest of the
Raymark Site. As part of the Raymark remedy H-16 was to be outfitted with an air stripper and the offgas
from treatment at all three wells would be addressed with vapor phase carbon. Currently, only wells H-14
and H-17 are operating.
A separate ROD required a soil vapor extraction (SVE) system and two caps to address soil contamination.
The SVE system began operation in March 1994 and was shut off in October 1995 when soil cleanup
levels were reportedly met. A multilayer low permeability cap covers a soil pile over the former lagoon
area. The soil pile, resulting from spoils from drilling and excavations for site piping, and cap rise to a
height of approximately 10 to 15 feet over the rest of the site. An asphalt cap, which currently serves as a
parking lot, covers the remainder of the site not occupied by building.
1.5.2 POTENTIAL SOURCES
From 1948 to 1972 wastes, including TCE, from degreasing and electroplating activities were discharged
into four onsite, unlined lagoons. Other potential sources of contamination included possible leaks from
aboveground storage tanks and possible discharges through building drains. Sludge from the lagoons was
removed in 1972 and the lagoons were backfilled with clean soil. Soil contamination was addressed by the
SVE system in from March 1994 to October 1995 and the multilayer and asphalt caps.
TCE concentrations in ground water during the initial investigations were as high as 47,000 parts per billion
(ug/L). Samples of the surface soils during the Remedial Investigation yielded only 18 ug/kg of TCE,
however, subsurface soil samples taken near the former lagoons yielded concentrations of TCE as high as
7,000 ug/kg. Soil gas concentrations for TCE were highest in the soils underlying former storage-tank
area. Freephase solvents were not discovered during the Remedial Investigation, but discussions during the
RSE visit indicated anecdotes of freephase being discovered during the installation of a well in 1992 by the
USGS.
It is important to note that other industrial sources of ground water contamination exist in the area and may
have contributed to the regional ground water plume including the Fisher and Porter Company located to the
northwest of the Raymark site that financed the installation of the air strippers on wells H-14 and H-17.
1.5.3 HYDROGEOLOGIC SETTING
Soil thickness at the site varies from 4 to 10 feet and consists of fine sands and silts. Beneath this soil lies
bedrock from the Stockton formation consisting of various layers of sandstone and siltstone which are
depicted in Figure 1-3. According to the Remedial Investigation, the bedding of these units shows no
particular pattern or order. The 1990 Feasibility Study considers the following four stratigraphic zones
based on the logs of well PF-1 and a packer test conducted in that well.
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Zone 1 above 75 feet below ground surface (bgs) is poorly transmissive and yields 0.1 gpm per
foot of drawdown.
Zone 2 extends from 75 to 95 feet bgs and is also poorly transmissive, yielding 0.36 gpm per foot
of drawdown.
Zone 3 extends from 95 to 125 feet, and was described, as a result of the packer test (USGS report
dated July 20, 1989), as a zone that does not contribute water to the well.
Zone 4 extends below 125 feet, is highly transmissive, and yields 5.4 gpm per foot of drawdown.
The site hydrogeology is otherwise not well documented or understood based on the documents reviewed by
the RSE team. Ground water depths have been recorded as part of the site activities, but with the absence of
elevations for the tops of the well casings, these depths could not be converted to water elevations. Thus,
no potentiometric surface of ground water at the site is available. In general, water elevations are estimated
to vary from 205 to 225 feet above mean sea level (MSL) with the highest levels occurring in the winter
and early spring. Given a site elevation of 265 feet MSL, this translates to water depths of 40 to 60 feet
below ground surface, depending on the season.
Pennypack Creek passes within a mile of the site to the west and southwest. While regional ground water
flow is expected to flow in this direction, the large number operating wells in the area could significantly
affect the speed and direction of ground water. Actual ground water flow directions are not known. The
average yield for a well in the area is approximately 130 gpm.
1.5.4 DESCRIPTION OF GROUND WATER PLUME
The Feasibility Study conducted in 1990 depicts the TCE ground water contamination as extending nearly a
mile west of the site toward Pennypack Creek as well as 2,000 or more feet to the north of the site.
Sampling conducted in April and May 2000 show TCE concentrations onsite as high as 2,300 ppb. In
addition, offsite wells have TCE concentrations as high as 1,000 ppb and Hatboro well H-14, over a half
mile to the west of the site, has a TCE concentration of approximately 150 ppb. Likely due to the complex
nature of the fractured bedrock subsurface, concentrations vary significantly with location. For example,
offsite wells R-3 and R-4 are 400 feet apart horizontally and 10 feet apart vertically, but R-3 (located
closer to the site than R-4) has a TCE concentration of 7 ppb while R-4 has a concentration of 680 ppb.
The TCE concentration data from the 21 monitoring wells sampled in April and May 2000 and from the
two public wells (H-14 and H-17) that are sampled quarterly are insufficient to completely delineate the
plume and insufficient information is available to determine the directions in which the plume may be
spreading.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
The current onsite system began extracting and treating ground water in November 1996. Extracted
ground water is pumped directly from two extraction wells into two tray aerators located in the treatment
building and is then discharged via below grade piping and a storm sewer to a creek approximately one half
mile southwest of the plant. The exhaust from the tray aerators is vented through a single GAC unit.
Two of the Hatboro water supply wells, H-14 and H-17, have continued to operate both as a ground water
remedy (independent of the Raymark site) and for water supply, especially during peak usage. H-14 is
located approximately 3,500 feet to the west of the site and H-17 is located approximately 2,000 feet to the
northwest of the site. Air strippers are used to treat the water and the Raymark remedy funds the
replacement of vapor phase carbon used to treat the off gas.
2.2 EXTRACTION SYSTEM
The extraction system is comprised of two wells (RW-1R and MW-3D). RW-1R was reconstructed in
1999 to replace RW-1 that collapsed. The pump size is 2 horsepower (hp) and pumps at a constant rate of
37 gallons per minute (gpm). The extraction well MW-3D uses a 1 hp pump to extract water on 90-second
cycles at a rate of approximately 23 gpm. During the RSE, this pumping rate and cycling corresponded to
maintaining water levels between set points of 41 and 60 feet below ground surface. Given these extraction
rates, on average the extraction systems pumps approximately 48 gpm.
2.3 TREATMENT SYSTEM
The treatment system includes two tray aerators in series with air supplied by up to five blowers. In an
effort to reduce energy consumption, the use of four blowers (one spare) was cut to two blowers in
November 1998. While this increased the plant effluent concentrations from less than 5 ppb to 30 or 40
ppb, these concentrations are still below the discharge concentration of 73 ppb. A blower is used to feed
the off gas from the air strippers to a single vapor phase carbon unit. The treated water is discharged
through a storm drain to Pennypack Creek approximately a half mile from the site.
2.4 MONITORING SYSTEM
The monitoring system consists of 23 sampling points, including 12 offsite wells and 11 onsite wells. The
offsite wells include five of the Hatboro wells (H-2, H-7, H-10, H-14, and H-17). While concentrations
had been measured regularly from H-14, H-17, and the two onsite extraction wells, samples from the other
wells had not been taken in approximately 8 years until the April and May 2000 sampling which was the
first event of a new annual sampling program. Another event is planned for June or July of 2001.
Water levels were also measured during the April and May 2000 sampling event; however, because the
elevations for the tops of the well casings are unknown, a water level map cannot be constructed.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The ROD specifies the following site-specific remedial objectives for OU2 and OU3:
Protect public health and the environment
Reduce further migration of contaminated ground water from the site towards public supply wells
Contain the contamination within the currently affected area
Reduce the risk resulting from release of contaminants into the air from treatment devices
Contribute to the restoration of the aquifer to its beneficial use, and further to background quality,
if practicable
3.2 TREATMENT PLANT OPERATION GOALS
As specified in the consent decree, the discharge criteria for the treatment plant is 73 ug/L (ppb) of TCE
and 7.3 ug/L (ppb) of carbon tetrachloride. Given plant influent concentrations of TCE, this requires
approximately 93% removal efficiency of the plant. Historically, the treatment plant has operated well
below this 73 ug/L discharge limit. With four of five blowers operating for the air strippers, effluent
concentrations are typically less than 5 ug/L, and with two of five blowers operating, effluent
concentrations are typically around 30 ug/L. The system currently operates with two blowers. The
remaining TCE in the effluent is likely transferred to the atmosphere as the effluent travels from the site to
Pennypack Creek through the storm drain.
3.3 ACTION LEVELS
Concurrent with remedial objective #5, the ROD specifies a cleanup level of 5 ug/L or background if
practicable. However, the main objectives of the site pertain to containment of onsite ground water
contamination.
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
In general, the RSE team found the treatment system well operated and well maintained. However,
possibly due to the high turnover rate among EPA Remedial Project Managers for this site and changes in
contractors, site information and background, especially related to system design, is difficult to access.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 WATER LEVELS
Although water depths have been recorded as recently as April and May 2000, unknown elevations for the
tops of the well casings prevent this information from being used to generate a potentiometic surface of
ground water beneath the site. Thus, the hydraulic gradients and ground water flow remain unknown.
Given the location of Pennypack Creek and several pumping wells to the west as well as the extent of the
plume to the west, it is likely that ground water in the area of the Raymark site flows to the west.
4.2.2 CAPTURE ZONES
Due to a lack of reliable water-level measurements and only one recent sampling of ground water
concentrations the capture zones associated with the two onsite extraction wells cannot be determined.
A preliminary capture zone analysis, however, was conducted as part of the 1990 Feasibility Study. This
analysis and the subsequent remedy alternatives described in that report suggested onsite pumping of 285
gpm five wells in Zone 4 (i.e., below 125 feet bgs) would each extract 50 gpm and seven wells in Zone 1
(i.e., above 75 feet bgs) would each extract 5 gpm. These recommended wells in Zone 1 and Zone 4 were
to be aligned along the downgradient boundary of the site. The designed treatment capacity of the
treatment plant of 100 gpm as stated in the 1994 Construction Report and the current extraction rate of
approximately 48 gpm from two wells differs significantly from this original analysis. As many of the
design documents were inaccessible to the site managers and the RSE team, justifications for this decrease
in the extraction could not be found.
4.2.3 CONTAMINANT LEVELS
Contaminant levels at the site vary with location and depth. In the April and May 2000, TCE
concentrations above 1,000 ppb were measured in onsite wells PF-ls, MW-2I, and MW-3I, which have
depths of 69, 146, and 142 feet below ground surface (bgs), respectively. Both MW-2I and MW-3I are
located on the western portion of the property where other ground water samples suggest contamination as
deep as 205 feet bgs and as shallow as 56 feet bgs. PF-ls is located on the eastern portion of the site where
the former lagoons were located and where the SVE system operated. This location is now occupied by the
multilayer low permeability cap covering the pile of excavated soil. The other high TCE concentration
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recorded on the eastern portion of the site is in MW-1S, which screens the shallow subsurface in the area of
the former lagoons.
4.3 COMPONENT PERFORMANCE
4.3.1 WELL PUMPS AND TRANSDUCERS
Well RW-1R replaced the original RW-1 well which had collapsed around the pump. This replacement well
is completed to a depth of 200 feet bgs with the transducer placed at 190 bgs. The screened interval currently
is unknown. The pump is 2 hp and pumps continuously at 37 gpm. The well and pump have functioned
without incident since installation in 1999.
Extraction well MW-3D (which differs from monitoring well MW-3D) is completed to a depth of 145 bgs with
the transducer at 135 bgs. The screened interval is not currently know. The pump is 1 hp and cycles on 90-
second intervals at a rate of 23 gpm.
The average total pumping rate overtime from both wells is approximately 48 gpm.
4.3.2 BLOWERS
There are five blowers capable of providing compressed air to the two tray aerators. The fifth blower has
historically been used as a reserve unit and is generally not operated. In November 1998, the number of
utilized blowers was decreased from four to two in order to save electricity. This practice still continues and
results in TCE effluent concentrations of approximately 30 ppb, which is well below the discharge criteria of
73 ppb. A separate blower is used to move the exhaust from the tray aerator through the vapor phase GAC
unit.
4.3.3 VAPOR PHASE GRANULAR ACTIVATED CARBON
A single vapor phase GAC unit is located outside of the treatment building. The unit contains approximately
1,000 pounds of GAC. The air is heated to lower than 40% relative humidity prior to entering the GAC to
minimize moisture within the unit. The current operation includes monitoring the exhaust with a PID. If the
PID registers a reading of greater than 2 ppm, the GAC is replaced. The site operators estimate that the GAC
is replaced three times per year.
4.3.4 CONTROLS
The plant operates remotely. The control system includes an autodialer to warn the plant engineer when the
system has shutdown. The operator can reach the site within 45 minutes.
4.3.5 TRAY AERATORS
Two dual tray (i.e., trays on both the top and bottom) aerators manufactured by Lowry Engineering, Inc. of
Durham, North Carolina are operated in series and utilize perforated piping to transfer VOCs to the air exhaust
stream. The perforated piping with 1/16-inch diameter perforations was clogging; therefore, the piping was
replaced with 1/8-inch diameter perforations. Even though this decreases the surface/transfer area of the air
that enters the aerators, the plant has continued to meet effluent requirements and the efficiency has increased
due to increased air flow. The second aerator must maintain a lid pressure of 5-6 inches of water to achieve
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treatment goals. Because of delicate balance between the aerator and the 5 hp vacuum blower that feeds the
vapor GAC unit, the system requires seasonal adjustments by the operator.
The two aerators, with four blowers operating, are designed to handle 100 gpm with a water temperature of
50 degrees Fahrenheit and TCE concentrations of 3,250 ppb.
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
MONTHLY COSTS
Annual costs of the system, excluding those associated with analytical work, are likely less than $100,000 but
will increase in the future with additional monitoring and characterization.
4.4.1 UTILITIES
The ground water treatment building has a phone and electricity but no natural gas. With two of the five
blowers feeding air to the tray aerators, the electric bill is approximately $800 per month or $10,000 per year.
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
Costs for non-utility consumables and disposal associated with the site include materials necessary for sampling
and replacement of the onsite vapor phase carbon each year. These costs are approximately $5,000 per year.
The costs for replacement of the vapor phase carbon units on wells H-14 and H-17 are not included in this
estimate.
4.4.3 LABOR
Labor involves the annual sampling event, project management, and weekly visits to the site by the plant
operator. Labor costs are under $50,000 per year.
4.4.4 CHEMICAL ANALYSIS
Analyses are performed under the CLP program, and those costs are not directly assigned to the site.
4.5 RECURRING PROBLEMS OR ISSUES
The operations of the plant have not reported major upsets in plant operations other than occasional weather
related power outages.
4.6 REGULATORY COMPLIANCE
The plant has not exceeded the effluent TCE concentration standards of 73 ppb.
10
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4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
The system has been operated with no major upsets or releases.
4.8 SAFETY RECORD
No accidents have been reported.
11
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Ground water in the region surrounding the Raymark site has historically been used for the public water supply.
Figure 1-6 of the 1990 Feasibility Study indicates that nine public wells are within the area or on the border
of the estimated TCE plume (H-l, H-2, H-3, H-9, H-12, H-14, H-15, H-16, and H-17). Operation of all of
these wells except H-14 and H-17 has been discontinued. Air stripping towers and vapor phase carbon units
have been installed on H-14 and H-17 and treat the water that is used for the public.
A lack of monitoring since the Remedial Investigation and the absence of reliable water-level measurements
make delineating the plume (horizontally and vertically) and forecasting its transport impossible. Thus, TCE
contamination of the ground water in this area likely continues to pose a hazard for the public water supply if
it is not properly treated. In addition, the RSE team and site managers cannot assess whether the primary
objectives of the ROD are being satisfied.
5.2 SURFACE WATER
Pennypack Creek to the west and southwest of the site represents the only surface water potentially impacted
by the ground water contamination and the treatment operations. Based on the estimated plume provided in
the 1990 Feasibility Study it appears the contamination has reached the creek. In addition, the effluent from
the onsite treatment plant, which may reach concentrations as high as 73 ppb, is discharged to the creek. The
creek is used for fishing and therefore represents a potential exposure pathway to the public. The RSE team
is unaware of any recent sampling of the creek water.
5.3 AIR
Off gas from the onsite tray aerators (and Hatboro water supply wells H-14 and H-17) is treated with vapor
phase carbon. Thus, TCE emissions from these treatment operations are negligible. The majority of the
contamination associated with the western portion of the Raymark site occurs at a depth of approximately 100
feet; therefore, elevated TCE concentrations in the soil gas in this part of the site are likely low. However,
relatively high TCE concentrations in ground water (in excess of 1,000 ppb) have been found in shallow
monitoring wells on the eastern portion of the site. This could lead to elevated soil gas concentrations in this
portion of the site and possibly in some of the onsite or nearby buildings.
5.4 SOILS
The contaminated soils have been excavated, piled on site, capped with a synthetic liner, and treated with an
SVE system. Operation of the SVE system was discontinued in October 1995 after cleanup levels were
reportedly met. The RSE team did not see any data from the operation of the SVE system or any subsequent
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data regarding soil contamination. The site has been covered with an asphalt cap that now serves as a parking
lot: thus, if contaminated soils did remain, access to them would be limited.
5.5 WETLANDS AND SEDIMENTS
The RSE team is not aware of any recent sampling of the Pennypack Creek sediments. As with the creek itself,
these sediments could potentially be impacted either by discharge of contaminated ground water or treated water
(with TCE concentrations allowed up to 73 ppb) to the creek.
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6.0 RECOMMENDATIONS
Cost estimates provided have levels of certainty comparable to those done for CERCLA Feasibility Studies
(-307+50%), and these cost estimates have been prepared in a manner consistent with EPA 540-R-00-002, A
Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July 2000.
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS
6.1.1 SURVEY AND EVALUATE WELL CONSTRUCTION FOR ALL SITE RELATED MONITOR AND
EXTRACTION WELLS
Well construction logs and pertinent information from those logs is not readily available to EPA site managers,
site contractors, or the RSE team. Therefore, information such as the screened intervals and elevations of the
tops of the well casings for the monitoring and extraction wells are not known. Without the screened intervals
of the extraction wells it cannot easily be determined from which portions of the aquifer water is being
extracted. Also, although the depths of monitoring wells indicate the approximate depth being sampled, without
knowledge of the screened interval, it cannot be determined if water is coming from a vertical interval of 10
feet, 20 feet, or more. Thus, it is not known if a given monitoring well is sampling from a single stratigraphic
unit or from two separate units. Without the elevations for the tops of the well casings, water levels cannot
be determined, and without these water levels, a potentiometric surface cannot be generated to indicate
directions and magnitudes of ground water flow. With unknown screened intervals for the extraction and
monitoring wells and without a potentiometric surface the extent of contaminant containment or capture cannot
be evaluated. Thus, it cannot be determined if the current remedy is consistent with the ROD in containing
contamination and reducing migration of TCE offsite.
The RSE team recommends a thorough investigation of the well construction data. This would involve tracking
down and evaluating the well construction logs. However, it is strongly advised that the site managers also hire
a survey crew to accurately determine the elevations of the well-casing tops. Downhole camera work should
also be conducted to determine the condition of each of the wells, but more importantly to determine the
screened intervals of each well.
Accurate, up-to-date information may be available for some of the Hatboro water supply wells within a mile
of the Raymark Site. If the screened intervals of the wells are known and a known reference elevation is
available for accurate water-level measurements, then surveying and downhole camera work is not needed for
these wells.
It appears that 21 wells (including Hatboro wells H-2, H-7, H-10, H-14, and H-17) are available for sampling
and measuring water levels. Excluding the Hatboro wells, there are 16 wells. Adding the two extraction wells,
the surveying and downhole camera work would need to be done for 18 (excluding the Hatboro wells) to 23
wells. The studies could likely be conducted for approximately $10,000.
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6.1.2 CREATE A POTENTIOMETRIC SURFACE MAP FOR GROUND WATER AND ESTIMATE FLOW
DIRECTIONS AND MAGNITUDES
Once the screened intervals and tops of casings are known for each of the 23 wells (including H-14 and H-17),
water levels should be measured and used to generate potentiometrics surfaces for ground water underlying the
Raymark site for a variety of pumping conditions including the following scenarios:
no pumping;
pumping from the onsite extraction wells at the current average extraction rate of 48 gpm but no
pumping from Hatboro wells H-14 and H-17; and
pumping from the onsite extraction wells at 48 gpm and from Hatboro wells H-14 and H-17.
The potentiometric surfaces generated for the pumping scenarios should not include the water level
measurements from the extraction wells as this will bias any analysis in favor of capture. The potentiometric
surfaces should have sufficient resolution to determine the likely portions of the site boundary from which
contaminants are most likely to migrate offsite and in which stratigraphic units this migration would likely
occur. Given the limited number of points for measuring water levels and the vertical variation in the Stockton
formation, additional piezometers placed at various locations and depths, are likely required to yield informative
potentiometric surfaces. The specific locations of these additional piezometers may be better determined once
water levels are measured and analyzed from the current measurement points.
Water levels are currently measured as part of the new annual sampling program; thus, the actual
measurements will not add to the annual costs. The analysis of the potentiometric surfaces generated from the
water levels (plus from previous depth-to-water measurements) would require an initial cost of approximately
$15,000 for initial work (such as developing a CADD site map and creating historical potentiometric surface
maps), and approximately $2,000 per year in the future for developing the potentiometric surfaces. Installation
of an additional shallow piezometer (less than 100 feet deep) would require approximately two days of drilling
and would cost approximately $7,000. Installation of an additional deep piezometer (approximately 200 feet
deep) would cost approximately $11,000. The addition of eight piezometers screening various depths would
therefore require a one time expenditure of approximately $72,000.
6.1.3 DELINEATE CONTAMINANT PLUME
The extent of ground water TCE contamination onsite should be further investigated as well, especially along
the site boundaries. A cluster of sampling points each independently screening the stratigraphic units shown
in Figure 1-3 and located midway between the MW-3 and MW-2 clusters would help delineate the plume on
the western boundary of the site. This is significant given that ground water likely flows to the west toward
Pennypack Creek and Hatboro wells H-14 and H-17. Another cluster of sampling points each screening the
stratigraphic units shown in Figure 1-3 and located midway between the MW-3 cluster and the rear end of the
property (to the east) would help delineate the plume on the southern/western site boundary. This is also
significant because Pennypack Creek turns and passes within a mile to the southwest of the site and
ground water could be flowing in that direction. These points should be added to the annual sampling program
and analyzed for volatile organic compounds (VOCs).
The locations of some of the piezometers installed to generate potentiometric surfaces may coincide with the
locations of these recommended sampling points. In such cases, monitoring wells should be installed in place
of the recommended piezometers. The cost of monitoring well would exceed the cost of a piezometer by up
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to $500 due to a difference in the cost of materials. Sampling and analysis at an independent laboratory of the
new wells, assuming one sampling event per year, might cost $4,000 per year.
6.1.4 EVALUATE CAPTURE OF THE ONSITE TCE PLUME
Once the ground water flow and plume extent onsite is better understood, the capture zones of the onsite
extraction wells should be evaluated. This is especially pertinent given the discrepancy between the extraction
rate of 285 gpm suggested in the 1990 Feasibility Study, which was based on a preliminary capture zone
analysis, and the current average extraction rate of 48 gpm. The first step is to examine the onsite contaminant
plume and determine a target capture zone (i.e., a theoretical capture zone that prevents the offsite migration
of contamination). The second step is to compare the target capture zone with the actual one as determined
by the potentiometric surface interpreted from water levels measured during onsite pumping. Also, site
managers should overlay the plume map interpreted from ground water sampling with the potentiometric surface
interpreted from water levels measured during onsite pumping. If the potentiometric surface has sufficient
resolution, this will give a general idea as to the portions of the contamination that are and are not captured by
these extraction wells. It may be evident from this evaluation that capture of onsite contamination requires
increased pumping from the existing wells, or possibly additional wells as suggested in the Feasibility Study.
For capture to be achieved, hydraulic gradients measured from water levels taken from surrounding
piezometers and monitoring wells (and not the extraction wells) must indicate ground water flow in the direction
of the extraction well. Due to regional/background ground water flow, capture is not necessarily achieved when
a well or piezometer indicates drawdown from nearby pumping.
Given the complexity of the fractured bedrock and the stratigraphy underlying the site, it may be impracticable
to develop a potentiometric surface map that indicates capture with adequate confidence. Thus, downgradient,
offsite wells will require continued monitoring to ensure that concentrations downgradient of the site are
decreasing. If these concentrations do not decrease over time, then it is likely that contamination is migrating
offsite and contributing to contamination in these offsite wells.
The capture zones should be evaluated at least once per year by analyzing the potentiometric surface and the
trends in TCE concentration in the downgradient sentinel wells. The extraction rates, and possibly the addition
of new extraction wells, should be adjusted accordingly to prevent migration of contaminants offsite. The
analysis of the capture zones in the various stratigraphic units and a written summary of the results should
result in a cost increase of approximately $4,000 per year.
6.1.5 ENSURE THAT ABANDONED WELLS ARE PROPERLY SEALED
A number of wells near the Raymark site, including the former extraction well (RW-1) that collapsed, are no
longer used for pumping. If these wells have not properly been sealed then they may offer avenues of cross
contamination between stratigraphic units. Therefore, the RSE team recommends sealing unused wells that
have screened intervals intersecting multiple stratigraphic units. This may be problematic for some of the
former water supply wells if the Hatboro Water Authority plans on reusing them. Assuming five wells require
sealing, this would be a one time cost of approximately $15,000.
6.1.6 EVALUATE IMPACT OF GROUND WATER AND TREATED WATER DISCHARGE TO
PENNYPACK CREEK
The RSE team is unaware of any water quality sampling of Pennypack Creek, especially where the plant
effluent is discharged and near H-9 where the plume may be discharging to the creek. Sampling of the stream
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water and sediments in these two location would indicate the extent of TCE contamination, if any. Such
samples could be collected and analyzed annually. Collecting and analyzing these samples as part of the new
annual sampling program should cost an additional $1,000 per year.
6.1.7 SAMPLE AIR IN NEARBY BUILDINGS FOR TCE
Due to the relatively high concentrations of TCE in the ground water, especially at the shallower depths near
the MW-1 and PF-1 clusters, the air in onsite and nearby buildings, especially the residence to the north, should
be sampled for TCE. This should be done quarterly for one year and annually thereafter. Total cost in the first
year would likely be $5,000. If the air sampling is conducted in the future as part of the annual sampling
program the additional cost would be approximately $1,000 per year.
6.2 RECOMMENDED CHANGES TO REDUCE COSTS
The onsite extraction and treatment system currently operate at cost of less than $ 100,000 per year (excluding
analytical work), and the extracted water has concentrations similar to those assumed in the design. Therefore,
the RSE does not have any recommendations that would result in significant cost reductions.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 COMPLETE THE O&M MANUAL
The operator that currently visits the site weekly is the only person familiar with plant operations. He works
from experience and not from a manual. The practices necessary for operating the plant smoothly should be
documented for potential future operators. Discussions during the RSE indicated that this manual is currently
being prepared. A one-time cost of $10,000 is possible for this item.
6.3.2 ORGANIZE/COMPILE DOCUMENTS AND DATA ASSOCIATED WITH SITE
Due to the high turnover rate of the EPA Remedial Project Managers for this site and shift away from the
contractor that designed and originally operated the plant, much of the original design and operation
information is not readily available. This unavailable information includes but is not limited to the screened
intervals of the wells, the elevations of the tops of the well casings, monitoring data from the SVE operation,
design reports, and the as-built drawings. In addition, the site Remedial Investigation, Feasibility Study, and
monitoring results were obtained from the site contractor and may not be easily accessible in the EPA offices.
All of these documents should be readily available to the site manager. The Union Library Company of
Hatboro located at 243 South York Road in Hatboro, is designated as a location for public files associated with
this site. The site managers should visit this location to identify and copy any site-related documents not
currently available in the EPA offices. A one-time cost of $5,000 is possible for these activities.
6.3.3 LABEL ALL WELLS AND RENAME WELLS TO AVOID CONFLICTS
The site-related wells should be named with a consistent nomenclature. At the time of the RSE, the names of
various wells included MS-1, MW-1S, R-l, RW-1, USGS, MW-3D (monitoring), and MW-3D (extraction).
For example, all monitoring wells associated with the site should have the prefix MW and all extraction or
recovery wells should have the prefix RW. Each well could then be given a number and a suffix of S, I, or D
indicating shallow, intermediate, or deep, respectively. A table should be constructed and included in all future
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site documents listing the current names of wells and the recommended names so that wells can easily be
tracked. This table should also include pertinent well construction data including the depths, screened intervals,
and the elevations for the tops of the well casings.
In addition, the wells are not labeled making it difficult to identify each well without a site map. To avoid
confusion and possible errors during sampling and measuring water levels, all of the wells should be clearly
labeled. Over time, cost of these items is estimated at approximately $10,000.
6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT
The RSE team has no recommendations for gaining site close out; rather, the RSE team suggests that the
additional characterization steps outlined in Section 6.1 are of primary importance. However, this
characterization is the first step of a detailed exit strategy that should be developed to ensure that the site does
not operate after ROD goals have been achieved. Of particular importance is to develop the exit strategy based
on the ROD objectives and not on the TCE concentrations found offsite that may have come from other
sources within the region. With regard to onsite contamination, if annual sampling events do not indicate
declines in TCE concentrations, investigations should be conducted to determine if any existing sources exist
either onsite or upgradient. Alternative remedial strategies should be periodically reviewed for potential
application at this site.
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7.0 SUMMARY
In general, the RSE team found a smoothly running treatment system, but a site that was poorly characterized,
possibly due to a high turnover rate of EPA Remedial Project Managers for the site. The observations and
recommendations mentioned are not intended to imply a deficiency in the work of either the designers or
operators but are offered as constructive suggestions in the best interest of the EPA and the public. These
recommendations have the obvious benefit of the operational data unavailable to the original designers.
Several recommendations are made to assure system effectiveness and improve the technical operation of the
system. However, recommendations were not made that are pertinent to cost reduction or gaining site close
out. The recommendations to improve effectiveness include surveys and downhole camera work of existing
wells to determine the elevations of the tops of the well casings and the screened intervals. Once this
information is gained, the RSE team recommends collecting 1) water levels and using them to generate
potentiometric surfaces of the ground water and 2) ground water quality samples and using them to better
delineate the onsite plume. Subsequent to these studies, a capture zone analysis should be conducted and
ground water extraction should be adjusted accordingly. With regard to technical improvement, the RSE team
agrees with the current effort to develop an operations and maintenance plan and recommends that the site
managers compile and organize site related data and documents.
Recommendations, and estimated cost increases/decreases associated with those recommendations, are
presented in Table 7-1.
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Survey site-related
wells
6.1.2 Measure water levels
and develop potentiometric
surfaces (costs include the
addition of eight
piezometers)
6.1.3 Delineate onsite plume
(includes extra costs for
installing monitoring wells
instead of piezometers in
6.1.2)
6.1.4 Analyze capture zone
6.1.5 Properly seal
abandoned wells
6.1.6 Evaluate TCE impact
on Pennypack Creek
6. 1.7 Sample air in buildings
for TCE
6.3.1 Complete O&M
manual
6.3.2 Compile and organize
site data and documents
6.3.3 Rename and label site
wells
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Technical
Improvement
Technical
Improvement
Technical
Improvement
Estimated Change in
Capital
Costs
$10,000
$87,000
$4,000
$0
$15,000
$0
$5,000
$10,000
$10,000
$10 ,000
Annual
Costs
$0
$2,000
$4,000
$4,000
$0
$1,000
$1,000
$0
$0
$0
Lifecycle
Costs*
$10,000
$147,000
$124,000
$120,000
$15,000
$30,000
$35,000
$10,000
$10,000
$10,000
Lifecycle
Costs**
$10,000
$119,200
$68,500
$64,500
$15,000
$16,100
$21,100
$10,000
$10,000
$10,000
Costs in parentheses imply cost reductions.
* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
** assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
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FIGURES
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FIGURE 1-1: THE AREA SURROUNDING THE RAYMARK SUPERFUND SITE INCLUDING HATBORO WELLS H-14 AND H-17
Fischer and
Porter Company
SCALE IN FEET
(Note: This figure is adapted from the 1988 USGS topographical map, Hatboro Quadrangle Pennsylvania, 7.5 minute series.)
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FIGURE 1-2. SITE LAYOUT SHOWING LOCATIONS OF THE MONITORING WELLS AND THE EXTRACTION WELLS.
-1
SCALE IN FEET
A EXTRACTION WELL
MONITORING WELL
o
o
a
m
m
V
*;
(Note: This figure is adapted from Figure 1-2 from the Raymark Site RI/FS Final Soil/Source Area Remedial Investigation Report, Operable Unit No. 1.,
CH2MHU1, 1991.)
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FIGURE 1-3. CROSS SECTION OF THE GEOLOGY UNDERLYING THE RAYMARK SITE.
RED SILTSTONE
- -40
- -60
- -80
- -100
- -120
140
160
180
200
220
- -240
(Note: This figure is taken from Figure 3-2 from the Raymark Site RI/FS Final Soil/Source Area Remedial Investigation Report, Operable Unit No. 1.,
CH2MHill, 1991.)
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