Superfund Record of Decision Avco Lycoming W illiamsport Division) Williamsport PA


                                    EPA/ROD/R03-97/012
                                    1997
EPA Superfund
     Record of Decision:
     AVCO LYCOMING (WILLIAMSPORT DIVISION)
     EPA ID: PAD003053709
     OU02
     WILLIAMSPORT, PA
     12/30/1996

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(IMG SRC 970120)
RECORD OF DECISION
AVCO LYCOMING SUPERFUND SITE
LYCOMING COUNTY, PENNSYLVANIA

DECLARATION

SITE NAME AND LOCATION
Avco Lycoming Superfund Site
Williamsport, Lycoming County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

This Record of Decision modifies the selected remedy described in the 1991 Record of Decision for the Avco
Lycoming Superfund Site ("Site") issued by the U.S. Environmental Protection Agency ("EPA") on June 28, 1991
("1991 ROD"). In the 1991 ROD, EPA selected a groundwater extraction and treatment remedy for contaminated
groundwater beneath the facility property. On May 7, 1992 EPA issued a Unilateral Administrative Order to
the Responsible Parties ("RPs") for the implementation of the 1991 ROD. Activities for the remedial design
of the groundwater extraction and treatment system began in December, 1992. A delay in the issuance of a
National Pollution Discharge Elimination System ("NPDES") permit, necessary for the design, caused the
remedial design to be suspended from May, 1993 until the permit was issued in July, 1995. It was at this
time that the RPs made a formal reguest to EPA to perform a pilot study at the site for an in-situ remedy
that could be used in place of the groundwater recovery and treatment remedy called for in the 1991 ROD.
This decision document presents the selected remedial action for the contaminated groundwater in the
overburden aguifer beneath the facility property at the Avco Lycoming Site. The selected remedial action was
chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
as amended, ("CERCLA") and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP").

This decision is based on the Administrative Record for the Site.

The Commonwealth of Pennsylvania concurs with the selected remedy for the Avco Lycoming Superfund Site
described in this ROD.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

This response action addresses contaminated groundwater in the overburden aguifer beneath the Avco Lycoming
facility property. The 1991 ROD selected a groundwater extraction and recovery system to address the
contaminated groundwater. That remedy was never implemented, as described in the Statement of Basis and
Purpose.

At the Avco Lycoming Site, the contaminated groundwater presents a principal threat to human health through
the ingestion pathway. EPA therefore plans to mitigate this potential threat by remediating the contaminated
groundwater in place without extraction.

The selected remedy includes the following major components:

* Installation of a molasses injection system in the western
portion of the facility property to address groundwater
contaminated with hexavalent chromium. The system will
include a series of molasses injection wells, mixing tanks
for molasses solution, pumps and piping for molasses
injection and a programmable logic controller.

* Installation of an air sparging/soil vacuum extraction
system in the central and eastern portions of the facility
property to address shallow groundwater contaminated with
organics. The system will include a series of air

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          sparing and SVE wells, air compressors, blowers and
          associated piping and vapor-phase carbon for off-gas treatment.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with Federal and State
reguirements that are legally applicable or relevant and appropriate, and is cost effective.  This remedy
utilizes permanent solutions and alternative treatment (or resource recovery) technology to the extent
practicable, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.

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DECISION SUMMARY
AVCO LYCOMING SUPERFUND SITE

INTRODUCTION

The Avco Lycoming Site is an active manufacturing facility located at 652 Oliver Street in Williamsport,
Lycoming County, Pennsylvania (see Site Location Map). The U.S. Environmental Protection Agency (EPA),
following consultation with the Pennsylvania Department of Environmental Protection (PADEP), is issuing this
Record of Decision ("1996 ROD") to address shallow contaminated groundwater beneath the facility property.
The selected remedy described in this ROD was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization
Act of 1986, U.S.A. °° 9601 et al. (CERCLA), and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).

On June 28, 1991 EPA issued a Record of Decision (ROD) for the contaminated site groundwater. The 1991 ROD
called for the site contaminated groundwater under the plant property to be extracted, treated, and
discharged to nearby Lycoming Creek. The chromium contaminated groundwater would be extracted through a
series of extraction wells, pumped to the existing waste water treatment plant and discharged. The organic
contaminated groundwater would be extracted through a separate series of extraction wells, pumped to on-site
air strippers for treatment and discharged. On May 7, 1992 EPA issued a Unilateral Administrative Order to
the Responsible Party (RP) for the implementation of the 1991 ROD. The remedial design of the groundwater
extraction and treatment system began in December, 1992.

In April, 1992, the RP submitted an application to PADEP for a National Pollution Discharge Elimination
System (NPDES) permit to discharge treated groundwater to Lycoming Creek. The design of the groundwater
recovery and treatment system was at the treatability study phase and could not proceed until the NPDES
permit was issued. During the time the application was submitted, PADEP was modifying the procedures by
which NPDES permit applications were being evaluated. As a result, the NPDES permit process took longer than
anticipated and the permit was issued in July, 1995.

After the NPDES permit was issued EPA notified the RP that the design workplan should continue with the
implementation of the treatability study. It was at this time that the RP made a formal reguest to EPA to
perform a pilot study at the site for an in-situ remedy that could be used in place of the groundwater
recovery and treatment remedy called for in the 1991 ROD. EPA and PADEP evaluated the RP proposal and
granted an approval for a 6 month pilot study to be implemented at the site. The design work plan for the
groundwater recovery and treatment system was suspended pending the results of the pilot study.

The work plan for the pilot study was submitted in August, 1995. Groundwater contamination beneath the plant
property includes a plume of chromium contaminated groundwater in the western portion of the plant property
and a plume of organic contaminated groundwater beneath the central and eastern portions of the plant
property. Because of these different plumes of contamination, the work plan included a field design test to
be performed at these respective locations within the facility. The first field design test was implemented
in October, 1995 and consisted of air sparing and soil vacuum extraction at three separate locations in the
eastern and central areas of the facility. The second field design test was implemented in November, 1995
and consisted of a metals-precipitation test in the western portion of the facility. This field design test
concluded in May, 1996. The results of the air sparging/SVE and in-situ metals precipitation pilot tests
were reported to EPA in April and June, 1996 respectively. The results indicated that each test was
successful. As a result, the RP conducted a Focused Feasibility Study (FFS) comparing these technologies to
the conventional pump and treat remedy selected in the 1991 ROD. This 1996 ROD addresses site contaminated
groundwater within the boundaries of the facility property. This ROD does not address site contaminated
groundwater that is present in the shallow aguifer beyond the facility boundary and in the deep aguifer
beneath and beyond the facility boundary. Contaminated groundwater in those areas will be addressed in a
future ROD.

In accordance with Section 117 of CIRCLE, 42 U.S.A. ° 117, the FFS, Proposed Plan, and background
documentation for the Avco Lycoming Superfund Site were made available to the public on September 20, 1996 in
the local information and administrative record repository at the James V. Brown library, Williamsport,
Pennsylvania. In accordance with Section 300.825 (a) (2) of the NCP, this 1996 ROD will become part of the
Administrative Record File. The Administrative Record File is available for review at the following
locations:

James V. Brown library of U.S. EPA Region III

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Williamsport and Lycoming County 841 Chestnut Bldg.
Williamsport, Pennsylvania Philadelphia, PA 19107

For a detailed description of the Site background and Site characteristics, refer to the 1991 ROD, the
September 1996 FFS, and the Proposed Plan dated September 20, 1996 for this ROD.

REASONS FOR ISSUING THE 1996 ROD

As described above, the remedy selected in the June 28, 1991 ROD called for the extraction and treatment of
contaminated groundwater. The time frame to achieve cleanup goals using this remedy was estimated to be at
least 30 years. During the design of this remedy a two year delay was encountered when AVCO applied for a
NPDES permit. During the delay, AVCO evaluated alternate remedies which are suitable to the site, more
effective at cleanup, and allow for less exposure of contaminants which could endanger human health and the
environment in comparison to the pump and treat remedy.

The alternate remedy (air sparging/SVE and metals precipitation) will achieve cleanup in less time than the
1991 ROD selected remedy, since treatment of the groundwater with the presence of a continuing source of
contamination in the soils makes complete remediation difficult with conventional pump and treatment
technology. The physical conditions of the AVCO site are amenable to air sparging/SVE and in-situ metals
precipitation technology. Although the air sparging/SVE technology is oxygen enhanced and the metals
precipitation technology reguires an oxygen depleted environment, these technologies do not need to be
implemented in the same area of the site. Metals reduction is reguired in the western portion of the
facility, while air sparging/SVE is more critical in the central and eastern portions of the facility. In
addition, air sparging/SVE will be conducted in groundwater that is downgradient of the metals reduction
technology. This allows for the removal of the VOC's in the groundwater in the western portion of the
facility after the metals are removed. Once metals are precipitated as metallic sulfides they will adhere to
the soil particles and will not redissolve under normal groundwater conditions. Once implemented, the air
sparging/SVE and metals precipitation technologies will take place almost entirely beneath the ground, and
will pose no risk during it's operation.

DESCRIPTION OF THE NEW ALTERNATIVES

CERCLA and the NCP reguire that the remedy chosen to cleanup a hazardous waste site meet several criteria.
The remedy must protect human health and the environment, meet the reguirements of environmental laws and
regulations, and be cost-effective. Permanent solutions to contamination problems should be developed
wherever possible. The solutions should reduce the volume, toxicity, or mobility of the contaminants, to the
extent practicable. Emphasis is also placed on treating the contaminants at the site, whenever this is
possible, and on applying innovative technologies to clean up the contaminants.

In accordance with Section 300.430 of the NCP, a list of remedial response actions and representative
technologies were screened to meet the remedial action objectives at the Avco Lycoming Site. The FFS studied
the technologies that proved to be successful during the pilot study to see if they met the above criteria
and were applicable for addressing the contamination at the Site. These technologies were then developed
into remedial alternatives. In addition, EPA has evaluated the No Action Alternative.

No Action Alternative

Time to Implement; 0 months
Capital Costs: $ 0
Annual O&M Costs: $ 0
Present Worth: $ 0

The Superfund program is reguired to evaluate the "No Action" Alternative. Under this alternative, no
remedial action would be taken at the site. At the Avco Lycoming Site, remedial actions have already been
undertaken pursuant to a Consent Order and Agreement between PADEP and Avco-Lycoming. This ROD does not
relieve the RP from any obligation under that agreement. Thus, a true no-action alternative is not possible.
The best approximation of a no-action alternative would be to take no further steps in remediating the
groundwater contamination at the Site. This alternative would be selected only if the Site posed little or
no risk to public health or the environment. There are no capital costs or operation and Maintenance (O&M)
costs associated with the No Action Alternative.

Alternative 1: Groundwater Recovery, Chemical Treatment for
Metals, Air Stripping, Emissions Control and
Discharge of Treated Water

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             Time to Implement:               21 months
             Capital Costs:                   $ 2,900,000
             Annual O&M Costs:                $   517,000
             Present Worth:                   $ 10,000,000

This alternative was selected as the remedial alternative in the 1991 ROD.  This alternative consists of a
groundwater recovery system to contain contaminated groundwater on-site.  The portion of the recovered
groundwater containing elevated levels of chromium and other metals would be chemically treated.  Recovered
groundwater would be air stripped for VOC removal and the off-gas from the air stripper would be treated by
the best available control technology.  The treated groundwater would be discharged to Lycoming Creek.  In
addition, institutional controls to limit the future use of this property are part of this remedy.


         Alternative 2:  Air Sparging/Soil Vapor Extraction and In-
                         Situ Metals Precipitation

              Time to Implement:               12 months
              Capital Costs:                   $ 1,600,000
              Annual O&M Costs:                $   357,500
              Present Worth:                   $ 4,200,000

This alternative consists of air sparging combined with soil vapor extraction to be used for the remediation
of VOC-contaminated groundwater at the site.  Compressed air is injected through air sparging wells that are
screened in the saturated zone.  The injected air travels upward in channels, creating    turbulence that
causes an increase in desorption of the VOCs from the soil and volatilizes the VOCs in groundwater.  After
injection, the air, which contains the volatilized contaminants, moves upward into the unsaturated zone where
it can be captured and removed using an SVE system.

In-situ metals precipitation will be used for the remediation of chromium-contaminated-groundwater.  In-situ
precipitation of chromium is based on the microbial reduction of hexavalent chromium to trivalent chromium.
The reduction process yields significant remedial benefits because trivalent chromium is less toxic, less
mobile, and precipitates from solution more readily than hexavalent chromium.  To promote the in-situ
microbial reduction of hexavalent chromium to trivalent chromium, a dilute molasses solution is injected into
the impacted aguifer through a series of injection wells.  The carbohydrates in the  molasses, which consist
mostly of sucrose, are degraded by the indigenous heterophic microorganisms present in the aguifer.  The
degradation of the carbohydrates by the microorganisms in the aguifer depletes the aguifer of it's dissolved
oxygen content. Reducing the amount of dissolved oxygen in the groundwater causes the hexavalent chromium to
reduce to the less toxic trivalent form.

The components of the air sparging/soil vapor extraction system will include the following; a series of air
sparing and soil vapor extraction wells along the perimeter of the site; air compressors, blowers and
associated piping and eguipment; and vapor-phase carbon for off-gas treatment.  The components of the
in-situ metals precipitation system will include the following:  a series of molasses injection wells; mixing
tanks for molasses solution; pumps, piping and associated eguipment for molasses injection; and a
programmable logic controller to automatically control the amount of solution injected.

EVALUATION OF ALTERNATIVES

In evaluating remedial alternatives for Superfund Sites, EPA considers nine specific criteria (see Table 1).
These nine criteria are categorized into the following three groups:

         Threshold Criteria

             Overall protection of human health and the environment

             Compliance with applicable or relevant and appropriate reguirements (ARARs)

         Primary Balancing Criteria

             Reduction of toxicity, mobility, or volume through treatment

             Short-term effectiveness

             Long-term effectiveness and permanence

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             Implementability

             Cost

         Modifying Criteria

             Community acceptance

             State acceptance

These evaluation criteria relate directly to requirements of Section 121 of CERCLA,  42 U.S.A.  ° 9621,  for
determining the overall feasibility and acceptability of a remedy.   Threshold criteria must be satisfied in
order for a remedy to be eligible for selection.   Primary balancing criteria are used to weigh major
trade-offs between remedies.  The modifying criteria are formally taken into account after public comment is
received on the Proposed Plan.

The following paragraphs summarize how the newly selected alternatives for the Avco Lycoming Site compare to
the original alternative selected in the 1991 ROD with respect to the nine criteria.

Protection of Human Health and the Environment

For overall protection of human health and the environment,  no unacceptable risks are associated with current
groundwater use in the area, because of the treatment system at the Williamsport Municipal Water Authority
(WMWA)  well field.  Alternatives 1 and 2 minimize migration of contaminants in groundwater flowing from the
site to the WMWA well field.

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                           TABLE I

               DESCRIPTION OF EVALUATION CRITERIA

Overall protection of human health and the environment -
Addresses whether a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.

Compliance with applicable or relevant and appropriate
requirements  (ARARs)  - Addresses whether a remedy will meet all
of the ARARs of other Federal and State environmental laws and/or
justifies a waiver.

Long-term effectiveness and permanence - Addresses expected
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
cleanup goals have been met.

Reduction of toxicity, mobility, or volume through treatment -
Addresses the anticipated performance of the treatment
technologies a remedy may employ.

Short-term effectiveness - Addresses 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 period, until cleanup goals are achieved.

Implementability   Addresses the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.

Cost - Includes estimated capital and operation and maintenance
costs, as well as present worth costs.

State/Support Agency Acceptance - Indicates the  support agency's
comments.  Where the State or Federal agency is  the lead for the
ROD, EPA's acceptance of the selected remedy is addressed under
this criterion.

Community Acceptance - Summarizes the public's general response
to the alternatives described in the Proposed Plan and Remedial
Investigation/Feasibility Study Report.  The specific responses
to public comments are addressed in the Responsiveness Summary
section of the Record of Decision.

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Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

CERCLA requires that remedial actions meet ARARs of other federal and state environmental laws, or that there
be qrounds for invokinq a waiver. A "legally applicable" requirement is one which would legally apply to the
response action if that action were not taken pursuant to Sections 104, 106, and or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while not "applicable", is desiqned to apply to problems
sufficiently similar that their application is appropriate.

The potential Federal and State ARARs for this 1996 ROD are presented in Table 2. Alternatives 1 and 2 can
be desiqned and implemented with the objective of satisfyinq the ARARs.

There are no additional chemical-specific or location-specific ARAR's of concern identified. Also, all
alternatives include the appropriate measures to ensure that all action-specific ARAR's are satisfied. Thus,
all remedial alternatives considered in this 1996 ROD will comply with all ARAR's.

Lonq-Term Effectiveness and Permanence

With respect to lonq-term effectiveness, both Alternatives 1 and 2 are expected to provide a hiqh deqree of
permanence. Alternative 2, however, may provide more lonq-term effectiveness and permanence than Alternative
1 because the in-situ technoloqies address the source of the contaminants (i.e., the soil), as well as
contain the contaminated qroundwater from miqratinq off-site. Alternative 1 does not focus on remediation of
the source of the contaminants.

Short-Term Effectiveness

With respect to short-term effectiveness, there are minimal potential risks associated with the construction
of either alternative.

Reduction of Toxicity, Mobility or Volume

Alternative 2 is expected to provide the hiqher deqree of toxicity, mobility, or volume reduction. The
reduction in the volume of orqanics will be afforded by the removal of contaminants from the saturated zone
as a result of the operation of the air sparqinq/SVE technoloqy. The toxicity and mobility of the chromium
present in the qroundwater will also be reduced as a result of the metals precipitation technoloqy. In
addition, a siqnificant amount of contaminated waste would continually be qenerated by Alternative 1 throuqh
the operation of the system, due to the need to treat recovered qroundwater. The amount of waste qenerated by
Alternative 2 is insiqnificant compared to the amount that would be qenerated by Alternative 1.

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                            TABLE 2

Potential Action-Specific ARARs

Federal Action Specific ARARs

  Citation                  Requirement              Status

* 40 CPR °144.24   Regulations for the Underground   Relevant &
                   Injection Control (UIC)  Program   Appropriate


Pennsylvania Action Specific ARARs

 Citation                   Requirement              Status

* Pennsylvania Air       Regulates fugitive air     Applicable
  Pollution Regulations  emissions for remedial
  25 Pa. Code °°123.1,    actions.  Fugitive
  123.2                  emissions prohibited
                         unless:
                         a)   "of minor significance"
                         b)   "not interferring with
                             ambient air quality"
                         may require PADEP permit
*25 Pa.  Code °127.1      Regulates new air          Applicable
                         contamination sources
                         be controlled to the
                         maximim extent and
                         consistent with beat
                         available technology
                         (PADEP approval)

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                            TABLE 2 (cont'd)

Potential Chemical-Specific ARARs

Federal Chemical-Specific ARARs

 Citation                   Requirement              Status
 *40 CFR °141.61          Maximum Contaminant        Applicable
  and °141.62             Levels (MCLs) for organic
                          and inorganic chemicals

Pennsylvania Chemical-Specific ARARs

 Citation                   Requirement              Status
 *25 Pa. Code °109.202    Incorporates by reference  Relevant
 (b)(2)                   EPA secondary MCLs as      Appropriate
                          State MCLs

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Implementability

Both Alternatives 1 and 2 are implementable. Although Alternative 2 includes innovative technologies with
associated uncertainties for 0 & M, the pilot tests performed at the site demonstrate that the technologies
are effective at remediation and applicable to the site.

Costs

The present worth cost for Alternative 2 is $4,200,000, which is considerably less than the cost for
Alternative 1 which is $10,000,000.

State Acceptance

The Commonwealth of Pennsylvania has verbally concurred with the selected remedy described in this ROD.

Community Acceptance

A public meeting on the Proposed Plan was held on October 2, 1996 in Williamsport, Pennsylvania. Citizens
who attended the meeting raised some significant concerns about the selected remedy. Community acceptance is
more fully assessed in the attached Responsiveness Summary, which provides a through review of the public
comments received on the FFS and Proposed Plan, and EPA's responses to the comments received.

SELECTED REMEDY

After carefully considering the reguirements of CERCLA, the findings of the FFS, the detailed analysis of the
alternatives, public comments, and other documents contained in the Administrative Record, EPA has selected
Alternative 2, Air Sparging/SVE and in-situ metals precipitation, as the remedy for amending the 1991 ROD
with respect to the contaminated groundwater beneath the facility property at the Avco Lycoming Site.

GOAL

The goal of the selected remedy is to restore contaminated groundwater to levels that are protective of human
health. Thus, groundwater will be treated until contaminant levels reach the concentrations listed below,
which will be protective for adult and child residential receptors. Based on information obtained during
the pilot studies, and the analysis of the remedial alternatives, EPA and the Commonwealth of Pennsylvania
believe that the selected remedy will be able to achieve these concentrations within the facility property.

CHEMICAL CONCENTRATION LIMITS SOURCE
(ug/1)

1,2- DICHLOROETHENE 70 MCL, NON-ZERO MCLG

CADMIUM 3 RISKED BASED

CHROMIUM VI 32 RISKED BASED

TRICHLOROETHENE 5 MCL

VINYL CHLORIDE 2 MCL

MANGANESE 50 STATE MCL

There are an infinite number of combinations of chemical concentrations that could result in risks at or
below the NCP target risks. These concentrations were derived using MCLs as a starting point and derives
risk-based concentrations for chemicals that may act additively on the same target organ (cadmium and
chromium). Manganese is an EPA secondary MCL and is incorporated by reference as a State MCL.

The selected remedy will include groundwater extraction for at least 15 years, during which time the system's
performance will be carefully monitored on a regular basis and adjusted as warranted by the performance data
collected during operation. Monitoring will include groundwater sampling on a schedule to be determined
during the Remedial Design. The sampling points will be strategically placed around the air sparging/SVE,and
metals precipitation systems.

DESCRIPTION OF THE SELECTED REMEDY

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The components of the air sparging/soil vapor extraction system will include the following; a series of air
sparging and soil vapor extraction wells along the perimeter of the site; air compressors, blowers and
associated piping and eguipment; and vapor-phase carbon for off-gas treatment. The components of the
in-situ metals precipitation system will include the following: a series of molasses injection wells; mixing
tanks for molasses solution; pumps, piping and associated eguipment for molasses injection; and a
programmable logic controller to automatically control the amount of solution injected. The molasses
application rate and schedule will be defined during the Remedial Design.

As part of the Remedial Action implementation, data will be collected to evaluate the performance of the Air
Sparging/SVE and in-situ metals precipitation. Monitoring plans, schedules and decision points for the
operation of these systems will be established in the Remedial Design.

SIGNIFICANT DIFFERENCE FROM PROPOSED PLAN

The cleanup standards established in the 1991 ROD stated that the contaminated groundwater would be
remediated until background, MCLs or MCLGs, whichever was lower, were achieved. The National Contingency Plan
allows flexibility in selecting remedial goals, including a range of possible cancer risks (1E-6 to 1E-4).
MCLs may also be used as remedial goals unless they are found not to be protective because of risk
additivity. The cleanup standards for this ROD have been changed to include MCLs and risk based levels for
the contaminants of concern. These levels are protective of human health and the environment and are
achievable.

STATUTORY DETERMINATIONS

Section 121 of CERCLA, 42 U.S.A. ° 9621, reguires that the selected remedy accomplish all of the following:
be protective of human health and the environment; comply with ARARs; be cost effective; utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable; and address whether the preference for treatment as a principal element is satisfied.

The selected remedy in this ROD Amendment will be protective of human health and the environment and will
comply with all chemical-, location-, and action-specific ARARs pertinent to this action.

The Commonwealth of Pennsylvania has identified the Land Recycling and Environmental Remediation Standards
Act, the Act of May 19, 1995, P.L. 4, No. 1995.2, 35 P.S. °° 6018.101 et. seg.("Act 2") as an ARAR for this
remedy; EPA has determined that Act 2 does not, on the facts and circumstances of this remedy, impose any
reguirements more stringent than the federal standards. Section 121 of CERCLA , 42 U.S.A. ° 9621, reguires
that the selected remedy accomplish all of the following: be protective of human health and the environment;
comply with ARARs; be cost effective; utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable; and address whether the preference for
treatment as a principal element is satisfied.

The selected remedy is the most cost-effective of the alternatives and addresses the Site-related risks posed
by the contaminated groundwater by reducing those risks to acceptable levels.

EPA has determined that the selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized while providing the best balance among the other evaluation criteria.
Alternatives 1 and 2 are protective of human health and the environment, but the selected remedy
(alternative 2) provides the best balance in terms of the eight other evaluation criteria.

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