Superfund Record of Decision Crossley Farm Hereford Groundwater Hereford Township PA


                                    EPA/ROD/R03-97/057
                                    1997
EPA Superfund
     Record of Decision:
     CROSSLEY FARM
     EPA ID:  PAD981740061
     OU01
     HEREFORD TOWNSHIP, PA
     06/30/1997

-------

RECORD OF DECISION
HEREFORD GROUNDWATER SITE / CROSSLEY FARM

DECLARATION

SITE NAME AND LOCATION

Hereford Groundwater / Crossley Farm Site
Huff's Church
Berks County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

This decision document presents the interim remedial action for the Hereford Groundwater/
Crossley Farm Site ("Site") in Huffs Church, Berks County, Pennsylvania. The interim
remedial action was chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 ("CERCLA"), as amended by the
Superfund Amendments and Reauthorization Act of 1986 ("SARA"), 42 U.S.C. Sections 9601 et seq.;
and to the extent practicable, the National Oil and Hazardous Substances Pollution Continqency
Plan ("NCP"), 40 C.F.R. Part 300. This decision document explains the factual and leqal basis
for selectinq the the interim remedy for this Site. The information supportinq this interim
remedial action decision is contained in the administrative record for this Site.

The Commonwealth of Pennsylvania concurs with the selected interim remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementinq the response action selected in this Record of Decision ("ROD"), may present an
imminent and substantial endanqerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED INTERIM REMEDY

This interim remedy will provide Point Of entry treatment systems to the residents who are
impacted by contamination from the Site and provide the potential for additional residential
point of entry systems if needed in the area of the Site. The filter treatment units will be
maintained and residential wells would be periodically monitored. Water pumped from the
private wells Would be passed throuqh the treatment systems at the point of entry into the
homes. Each typical treatment system would be composed of a prefilter to remove suspended
solids, dual in-series activated-carbon units to remove VOCs, and an ultraviolet (UV) radiation
unit to provide disinfection. Dependinq on the contaminants identified at specific residences,
additional treatment components may be required, such as pH adjustment or a water-softeninq
unit to remove manqanese and iron. The activated carbon would be replaced on a periodic basis
or when breakthrouqh is identified. Throuqh the provision of these treatment systems,
contaminant concentrations would be reduced to below the drinkinq water criteria.

This remedy is an interim action to address the potential risk to residences throuqh drinkinq
water from their wells which are contaminated with volatile orqanic compounds. Currently a
study known as a Remedial Investiqation and Feasibility Study (RI/FS) is underway to define the
nature and extent of contamination in the soil, sediment, surface water and qround water media.
The results of the study will aide EPA's evaluation of the current and future potential risk to
humans and the environment associated with contaminants found in soil, sediment, surface water

-------
and ground water. The study will continue through the summer of 1997 with final reports
available by the Summer or Fall of 1998. Once the reports are finalized, EPA will propose a
final remedy for the entire Site.

At that time, EPA will issue a proposed plan which will include some of the alternatives
outlined in this ROD as well as some new alternatives that would address contaminated media
which currently or in the future would pose an unacceptable risk to humans or the environment.
Therefore this interim remedy is considered temporary until the RI/FS is completed.

DECLARATION OF STATUTORY DETERMINATIONS

This interim action is protective of human health and the environment, complies with federal and
State applicable or relevant and appropriate reguirements for this limited-scope action and is
cost-effective. Although this interim action is not intended to address fully the statutory
mandate for permanence and treatment to the maximum extent practicable, this interim action does
utilize treatment and thus is in furtherance of that statutory mandate. Because this action
does not constitute the final remedy for the Hereford Groundwater / Crossley Farm Site, the
statutory preference is only partially addressed in this interim remedy. Subseguent actions are
planned to address fully the threats posed by the conditions at this Site.

Because this interim remedy will result in hazardous substances remaining on Site above health-
based levels, a review under Section 121(c) of CERCLA, 42 U.S.C. °9621 (c) will be conducted
to ensure that the interim remedy continues to provide adeguate protection of human health and
the environment within five years after commencement of the remedial action. Because this is
an interim Record Of Decision, review of this site and of this remedy will be ongoing as EPA
continues to develop final remedial alternatives for the Site

-------
                           TABLE  OF  CONTENTS

                                                                    PAGE

I.    SITE NAME, LOCATION AND  DESCRIPTION                             1
II.   SITE HISTORY                                                     1
III.  ENFORCEMENT HISTORY                                              5
IV.   HIGHLIGHTS OF COMMUNITY  PARTICIPATION                           5
V.    SCOPE AND ROLE OF THIS INTERIM REMEDIAL ACTION                  6
VI.   SUMMARY OF SITE CHARACTERISTICS                                 6
VII.  SUMMARY OF SITE RISKS                                            7
VIII. SUMMARY OF REMEDIAL ALTERNATIVES                                 9
      A.   ALTERNATIVE 1:  NO  ACTION                                  9
      B.   ALTERNATIVE 2:  DELIVERED WATER                            9
      C.   ALTERNATIVE 3:  POINT-OF-ENTRY TREATMENT                  10
      D.   ALTERNATIVE 4:  WATER  LINE                                11
IX.   SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES                13
      A.   OVERALL PROTECTION  OF  HUMAN  HEALTH AND THE
           ENVIRONMENT                                                13
      B.   COMPLIANCE WITH ARARS                                      13
      C.   LONG-TERM EFFECTIVENESS AND  PERMANENCE                    13
      D.   REDUCTION OF MOBILITY, TOXICITY OR VOLUME                 13
      E.   SHORT-TERM EFFECTIVENESS                                   13
      F.   IMPLEMENTABILITY                                           14
      G.   COST                                                       14
      H.   STATE ACCEPTANCE                                           14
      I.   COMMUNITY ACCEPTANCE                                       15
X.    EPA'S SELECTED INTERIM REMEDY                                   15
XI.   STATUTORY DETERMINATIONS                                       16
      A.   PROTECTION OF HUMAN HEALTH AND ENVIRONMENT                16
      B.   COMPLIANCE WITH AN  ATTAINMENT OF APPLICABLE OR
           RELEVANT AND-APPROPRIATE  REQUIREMENTS ("ARARS")            16
           1.   CONTAMINANT-SPECIFIC ARARS                           16
           2.   LOCATION-SPECIFIC ARARS,                              17
           3.   ACTION-SPECIFIC ARARS                                17
      C.   COST EFFECTIVENESS                                         17
      D.   UTILIZATION OF PERMANENT  SOLUTIONS AND ALTERNATIVE
           TREATMENT  (OR RESOURCE RECOVERY) TECHNOLOGIES
           TO THE MAXIMUM EXTENT  PRACTICABLE                          17
      E.   PREFERENCE FOR TREATMENT  AS  A PRINCIPLE ELEMENT           18
XII.  DOCUMENTATION OF SIGNIFICANT CHANGES                           18
XIII. RESPONSIVENESS SUMMARY                                          19

-------
RECORD OF DECISION
HEREFORD GROUNDWATER / CROSSLEY FARM SITE

DECISION SUMMARY

I. SITE NAME, LOCATION AND DESCRIPTION

The Hereford Groundwater / Crossley Farm Site is located approximately 7 miles southwest of
Allentown in the Huffs Church community of Hereford Township, Berks County, Pennsylvania
shown in Figure 1. The site is located along the southern side of Huffs Church Road,
approximately 3 miles west-northwest of State Route 100 and northwest of the borough of Bally.
The general Site features are shown on Figure 2.

The Site is located in the Reading Prong Physiographic Province. The topography reflects the
complex underlying bedrock geology and consists of high hills and ridges underlain by bedrock.
The most prominent highland within the study area occurs at the Site and is known locally as
Blackhead Hill. The hill is very steeply sloped to the west and south of its crest. To the
north and east of its crest, the hill is fairly level or flat and supports a working farm over
much of its area. The crest of Blackhead Hill is underlain by the Hardyston Quartzite, which
makes an attractive building stone. A small guarry at the crest of the hill has had some
limited activity for nearly 50 years.

From the mid-1960s to the mid-1970s, a local plant reportedly sent numerous drums to the
Crossley Farm for disposal. These drums contained mostly liguid waste and were described as
having a distinctive "solvent" odor. The plant was believed to have used trichloroethene (TCE)
as a degreaser from at least the mid-1960s until 1973 and tetracholorethene (PCE) from at least
the early 1960s until 1980.

Known and alleged waste disposal areas include a household dump, the guarry, and a borrow pit
area. The dump is located approximately 2,000 feet south of Huffs Church Road and reportedly
consists chiefly of household trash. The guarry is located approximately 3,000 feet south of
Huffs Church Road and is allegedly a former site of unregulated disposal of hazardous waste,
chiefly chlorinated solvents. The borrow area is located approximately 400 feet east of the
guarry and is allegedly a former unregulated staging and/or disposal area of hazardous wastes,
chiefly chlorinated solvents. All of these suspected source areas are being investigated by the
ongoing remedial investigation.

II. SITE HISTORY

Regulatory involvement at this Site began in 1983, when local residents complained to the
Pennsylvania Department of Environmental Protection (PADEP) about odors in private water supply
wells. A PADEP sampling program of local wells conducted in September 1983 revealed
concentrations of TCE as high as 8,500 micrograms/liter (ug/L) and PCE as high as 110 ug/L.

-------
bottled water where TCE concentrations exceeded 45 ug/L. Shortly thereafter, a temporary water
supply was provided by the Pennsylvania National Guard through the Pennsylvania Emergency
Management Agency. This supply was terminated in mid-1985.

After the health advisory was issued, local residents began to voice concerns about Crossley
Farm and alleged dumping of wastes there. In response to these concerns, EPA conducted a
preliminary assessment (PA) of the property. The PA, completed in June 1984, concluded that
insufficient information existed to identify the source of the groundwater contamination and
suggested that a regional groundwater study be conducted.

Further citizen complaints in August 1986 prompted additional rounds of sampling by EPA in
September 1986. TCE levels detected during these rounds ranged up to 19,000 ug/L. Additional
well sampling in November 1986 detected TCE at a maximum level of 22,857 ug/L.

EPA initiated an emergency response in December 1986 and, in January 1987, EPA began installing
carbon filtration units on the most severely impacted private wells. A contaminant
concentration level of 180 ug/L of TCE or greater was used as the criterion for installing a
filter for any particular well. This criterion for the emergency response action in 1987 was
developed in consultation with the Agency for Toxic Substances and Disease Registry (ATSDR) and
was based on one-half of the Drinking Water Eguivalent Level (DWEL). A total of 15 carbon
filter units have been installed and are maintained by EPA. A contractor services the units
approximately every 2 months, and the carbon units are rotated about every 6 months. EPA is
still monitoring the operation of these treatment units.

In the spring of 1987, EPA initiated a regional hydrogeological investigation to include the
installation and sampling of on-site and off-site monitoring wells and the sampling of
residential well supplies. This investigation, completed in August 1988, concluded that the
source of the TCE in the groundwater was near the crest of Blackhead Hill. The abandoned guarry
and the borrow pit area were cited as the presumed source areas. The investigation delineated a
contaminated groundwater plume extending approximately 7,000 feet downgradient from
Blackhead Hill and along Dale Road.

Concurrent with and independent of the EPA study, residential wells near Dale Road were sampled
and analyzed for polychlorinated biphenyls (PCBs) and other contaminants as part of a PADEP
investigation of the Texas Eastern - Bechtelsville compressor station. One residential well
located on Forgedale Road contained TCE at levels greater than 200 ug/L, suggesting that the TCE
plume associated with the Crossley Farm Site extended even farther to the south than mapped,
since TCE was determined not to be a common waste product from compressor station operations.
This result prompted additional sampling by EPA along Forgedale Road, south to Old Route 100, as
part of the Crossley Farm investigation. These analytical data indicated that the plume extended
south of the compressor station and Forgedale Road and about 9,000 feet downgradient from
Blackhead Hill.

In February 1991, EPA issued the final Hazard Ranking System (HRS) package for the Crossley Farm
Site in preparation for the Site's proposal for the National Priorities List (NPL). In July
1991, the site was proposed for the NPL. The Site was formally listed on the NPL in October,
1992.

In September 1994, EPA initiated a remedial investigation and feasibility study (RI/FS) for the
Site to evaluate existing data, collect additional data as necessary and consider appropriate
actions. EPA decided to expedite evaluation of alternatives to address the contaminated
residential well supply problem by preparing a focused feasibility study (FFS) prior to
completion of the remaining Site investigation activities.
-------
III. ENFORCEMENT HISTORY

Before initiating the work plan for the Remedial Investigation and Feasibility Study for this
site, EPA conducted interviews and sent out 104e letters reguesting information from individuals
who may have been involved in the disposal activities at the Site. Some reports indicated that
drums of "solvent wastes" were picked up at the Bally Case and Cooler plant in Bally and taken
to the Crossley Farm. Others have contacted EPA during some of the early removal activities
on-site in 1986 indicating that they knew where drums were buried on the farm. However at this
time there has not been any physical evidence of uncovered drums to substantiate these
allegations. The remedial investigation is expected to look for any buried drums and may then
lead us to the identity of responsible parties.

IV. HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Focused Feasibility Study and the Proposed Plan for the Hereford Groundwater / Crossley
Farm Site were released to the public on February 10, 1997. These two documents were made
available to the public in both the administrative record and an information repository
maintained at the EPA Docket Room in Region III, the Hereford Township and the Washington
Township offices. The notice of availability for these two documents was published in the
Allentown Morning Call on February 10, and February 26, 1997. A public comment period on the
documents was held from February 10 to March 12, 1997. In addition, a public meeting was held
on March 5, 1997. At this meeting, representatives from EPA and its contractors answered
guestions about problems at the site and the remedial alternatives under consideration. A
response to the comments received during this period is included in the Responsiveness Summary,
which is part of this Record of Decision. This decision document presents the selected interim
remedial action for the Site chosen in accordance with CERCLA as amended by SARA and to the
extent practicable, the National Contingency Plan. The decision for this Site is Based on the
Administrative Record.

V. SCOPE AND ROLE OF THIS INTERIM REMEDIAL ACTION

EPA's Interim Remedial Action for this Site is to provide point of entry treatment systems to
the residents who are impacted by contamination from the Site and to provide the potential for
additional residential point of entry systems if needed in the area of the Site. The filter
treatment units will be maintained and residential wells would be periodically monitored.

This interim action would continue to address the immediate threat to residences who have
drinking water wells which are contaminated with volatile organic compounds until the remedial
investigation and feasibility study (RI/FS) are complete and a final remedy is selected as well
as implemented. Currently, EPA is in the process of conducting an RI/FS to define the type and
degree of contamination in soil, sediment, surface water and ground water. Once the RI/FS is
complete, EPA will propose a final remedy for the Site and will solicit input from the public
and community as part of the process to ultimately make a decision on a final remedy for the
Site. The RI/FS is expected to continue through the Summer and Fall of 1997 and final reports
should be available by the Summer and Fall of 1998.

VI. SUMMARY OF SITE CHARACTERISTICS

The full nature and extent of contamination in all media associated with the disposal of
hazardous wastes on the Crossley Farm Site is unknown at this time and will be delineated by the
remedial investigation. At present, significant data exists regarding the nature and lateral
extent of volatile organic compounds in groundwater, and limited data exists regarding the
nature of semivolatile and inorganic compounds in groundwater.
-------
Volatile Organic Compounds

Volatile organic compounds (VOCs) have been detected at significant levels in groundwater
through the multiple sampling of 21 monitoring wells and numerous home wells. During the last
sampling round (November/December 1995), nearly all potable wells and springs within the study
area (a total of 104 different groundwater sources) were sampled for VOCs in support of the FFS,
and to gather data to aid in the scoping of the remedial investigation. The analytical results
from all sampling rounds indicate that a large plume of contaminated groundwater originates near
the crest of Blackhead Hill and is migrating southward and downgradient approximately 9,000 feet
into the Dale Valley. The principal chemical components of this plume are the VOCs
trichloroethene (TCE) and tetrachloroethene (PCE), though a few other compounds also appear, but
much less consistently, and at lower concentrations. Neither the precise source location(s),
nor the vertical distribution of the extent of the contamination is known at this time.

Semivolatile Organic Compounds

Limited data exists concerning the nature and extent of semivolatile organic compounds (SVOCs)
at the Site. Based on the close proximity to the suspected source and the historically high
concentrations of VOCs, 14 residential wells were analyzed during the September 1995 and/or the
November/December 1995 sampling rounds for these compounds. No other wells or media have been
analyzed for SVOCs. The limited data suggest that the groundwater is not significantly impacted
by SVOCs. The wells selected for analysis are either located closest to the Site or
historically have had the highest levels of VOCs in their groundwater. Therefore, they would be
considered the wells most likely to contain SVOCs. The analyses, however, indicate that the
distribution of SVOCs is irregular and their concentrations are very low (egual to or less than
1 ug/L).

Inorganic Compounds

Limited data exists concerning the nature and extent of metals at the Site. A total of 14
residential wells were analyzed for metals during the September 1995 and/or the November/
December 1995 sampling rounds. No other wells or media have been analyzed for metals. The
limited data suggest that off-site groundwater may be impacted by metals. Based on their
concentrations relative to EPA Region III Risk Based Concentration Tables - 1996, the metals,
cadmium, copper, iron, lead and manganese, were all selected as chemicals of concern during the
preliminary risk assessment conducted for the FFS. The concentrations of these metals in the
monitoring wells are not known at this time. It is also not known what the naturally occurring
background levels of these metals may be or to what extent plumbing may be contributing to the
concentration levels of some of the metals (principally lead and copper) through the leaching of
these metals from the pipes by acidic groundwater. These data gaps will be investigated during
the remedial investigation.

VII. SUMMARY OF SITE RISKS

The basis for EPA's risk determination is The National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP") which establishes acceptable levels of carcinogenic risk for Superfund
sites ranging from one excess cancer case per 10,000 people exposed to one excess cancer case
per one million people exposed. This translates to a risk range of between one in 10,000 and
one in one million additional cancer cases. Expressed as scientific notation, this risk range
is between l.OE-04 and l.OE-06. Remedial action is warranted at a site when the calculated
cancer risk level for a potentially exposed individual exceeds l.OE-04. However, since EPA's
cleanup goal is generally to reduce the risk to l.OE-06 or less, EPA also may take action where
the risk is within the range between l.OE-04 and l.OE-06.
-------
The NCP also provides that sites should not pose a health threat due to a non-carcinogenic, but
otherwise hazardous, chemical. EPA defines a non-carcinogenic threat by the ratio of the
contaminant concentration at the site that a person may encounter to the established safe
concentration. If this ratio, known as the Hazard Index (HI), exceeds one (1.0), there may be
concern for the potential non-carcinogenic health effects associated with exposure to the
chemicals. The HI identifies the potential for the most sensitive individuals to be adversely
affected by the noncarcinogenic effects of chemicals. As a rule, the greater the value of the
HIabove 1.0, the greater the level of concern.

A Draft Preliminary Risk Assessment (PRA) was completed in October 1996 to assess the
potential risks to human health that could result from using contaminated groundwater
underlying the Site. The PRA was developed using analytical results from the historical
sampling of residential wells (VOCs, only) and from the September, November, and December 1995
sampling rounds (VOCs, SVOCs, and inorganic compounds). The PRA reviewed and screened the
analytical results from all the wells and springs within the study area for which data are
available, a total of 136 different groundwater sources.

The PRA also identified TCE as the major contributor to noncarcinogenic risk, with an individual
HQ exceeding 1.0. Manganese, PCE, and cis-1,2-dichloroethene have HQs exceeding 1.0 for
children, and trichlorofluoromethane has an HQ exceeding 1.0 for adults.

The NCP Section 300.430 reguires EPA to evaluate whether the proposed action meets the
Applicable or Relevant and Appropriate Reguirements (ARARs). These reguirements are
promulgated, enforceable federal and state environmental, or public health reguirements that are
determined to be legally applicable or relevant and appropriate to the hazardous substances,
remedial actions, or other circumstances at a CERCLA site.

In evaluating the risks for the Crossley Farm Site, ARARs identified include: the federal Safe
Drinking Water Act (SDWA) , MCLs and state standards which regulate the guality of treated water
produced by a public water supply. MCLs are promulgated numerical values that specify the
maximum permissible levels of contaminants that can be delivered to a user of public water
supplies. MCLs have been promulgated by both the federal government and the Commonwealth of
Pennsylvania. For the Agency's remedy selection decision, MCLs are considered relevant and
appropriate in evaluating the risk from contaminated drinking water supplies for the residents
living near the Crossley Farm Site.

Since the preliminary risk assessment indicates that TCE is the main contributor for both the
carcinogenic and non-carcinogenic risk, the MCL of 5 micrograms per liter (ug/1) was also
important for identification of the affected residents.

Upon review of the analytical data for the residential drinking water well, a total of 31 wells
have had at least one historical detection of a contaminant of concern above the MCL for TCE.
Two of the wells are considered public supply wells and are currently being treated with
granular activated carbon. Therefore, a total of 29 wells have been identified as reguiring
remediation because their water exceeds the MCL for TCE, PCE or methylene chloride. The
residents who currently have EPA maintained treatment units in their homes are included as part
of these 29 affected residences.

VIII. SUMMARY OF REMEDIAL ALTERNATIVES

A. Alternative 1: No Action

The no-action alternative was developed, as reguired by the NCP, as a baseline to which other
alternatives may be compared. Periodic reviews of Site conditions, typically every 5 years, and
-------
long-term groundwater monitoring would be the only activities conducted under this alternative.

There are no ARARs pertinent to the no-action alternative.

No capital costs are associated with the no-action alternative. The average annual cost for
long- term monitoring is estimated to be $44,120 and 5-year reviews are $23,000 per event. Over
a 30-year period, the net present-worth cost is $597,117.

B. Alternative 2: Delivered Water

Under this alternative, bottled or bulk water would be regularly provided to each of the 29
residences that have a water supply contaminated in excess of the federal or state primary
drinking water criteria (MCLs) for TCE or one of the other chemicals.

Institutional controls such as ordinances or deed restrictions might be enacted to prohibit the
use of contaminated groundwater for drinking water. Existing residential supply wells and
selected monitoring wells would be incorporated into a long-term monitoring network.
Groundwater would be monitored annually for VOCs and metals to assess the contaminant plume
status and to assess whether additional homes may be at risk from contaminated water supplies.
Because contaminants remain in the underlying aguifer and would continue to pose threats to
groundwater users, 5-year reviews would be conducted to assess Site conditions and whether
additional response actions would be necessary.

Two scenarios are viable under Alternative 2:

6 Alternative 2A - All 29 currently affected residents would be provided with new
storage tanks and delivered bulk water.

6 Alternative 2B - The five homes with either an individual or cumulative risk for skin
contact and breathing exposure pathways of greater than 1E-4 for a cancer related
risk or an individual or cumulative HI greater than 1.0 for a non-cancer related risk
would be provided with bulk water to prevent contact with contaminants through
these pathways, and the remaining 24 affected homes would be provided with bottled
water to prevent drinking of water in excess of MCLs.

Alternative 2 would be consistent with the federal and state chemical-specific ARARs for
drinking water since bottled or bulk water that complies with MCLs would be provided to
residences.

Alternative 2 would comply with the action-specific reguirements under Title 29 of the Code of
Federal Regulations for occupational safety and health since workers who perform the long-term
monitoring wells or deliver bottled or bulk water would conform with these reguirements.

The cost estimates developed for the two Alternative 2 scenarios are

Alternative 2A:
Capital costs: $120,420
Average annual operation and
maintenance (O&M) costs: $314,440 (years 1 through 30)
Five-year reviews: $23,000 per event
Over a 30-year period, the net present-worth cost of Alternative 2A is $4,071,951.

Alternative 2B
Capital costs: $22,270
-------
Average annual O&M costs: $140,200 (years 1 through 30)
Five-year reviews: $23,000 per event
Over a 30-year period, the net present-worth cost of Alternative 2B is $1,811,645.

C. Alternative 3: Point-of-Entry Treatment

This alternative calls for the use of point-of-entry treatment units to treat the extracted
groundwater at each affected residence. Under this alternative, all 29 which exceed the MCL for
TCE or some other chemical would be provided with point-of-entry treatment units. Water pumped
from the private wells would be passed through the treatment systems at the point of entry into
the homes. Each typical treatment system would be composed of a prefilter to remove suspended
solids, dual in-series activated-carbon units to remove VOCs, and an ultraviolet (UV) radiation
unit to provide disinfection. Depending on the contaminants identified at specific residences,
additional treatment components may be reguired, such as pH adjustment or a water-softening unit
to remove manganese and iron. The activated carbon would be replaced on a periodic basis or
when breakthrough is identified. Through the provision of these treatment systems, contaminant
concentrations would be reduced to below the drinking water criteria (MCLs).

Institutional controls such as ordinances or deed restrictions may be enacted to prohibit the
use of contaminated groundwater for drinking water use, if treatment is not employed. Existing
residential wells and selected monitoring wells would be incorporated into a long-term
monitoring network to determine whether the water supplies of other residences may be affected
and the status of groundwater contamination. Groundwater would be monitored annually for VOCs
and metals. Because contaminants remain in the aguifer and would continue to pose threats to
groundwater users, 5-year reviews would be conducted to assess site conditions and whether
additional response actions are necessary.

Alternative 3 would be consistent with the federal and state chemical-specific ARARs since the
point-of-entry treatment systems would be designed to produce potable water that meets the
numerical limits (MCLs) identified in the primary drinking water criteria.

Alternative 3 would comply with the action-specific reguirements under Title 29 of the Code of
Federal Regulations for occupational safety and health since workers who install and perform
periodic maintenance of the treatment systems and workers who sample the long-term monitoring
wells would conform with these reguirements. The transport and disposal of spent activated
carbon would be in compliance with the applicable portions of Resource Conservation and Recovery
Act reguirements (40 CFR Parts 262 and 263) and the applicable portions of the Hazardous
Materials Transportation reguirements (49 CFR 107,171-179). All measures would be taken to
safely remove and transport the spent carbon to a facility for regeneration.
The cost estimates developed for the Alternative 3 for the 29 residences are
Capital costs: $172,230
Average annual O&M costs: $117,240 (years 1 through 30)
Five-year reviews: $23,000 per event
Over a 30-year period, the net present-worth cost of Alternative 3 is $1,676,700.

If more residences are provided point of entry treatment units, costs will increase.
Capital costs for each additional residential filter are $6,000 and O&M cost would increase
approximately $735 for each additional sample and analysis.

D. Alternative 4: Water Line
-------
Under this alternative, the existing water distribution main from the nearby borough of Bally
would be extended through Hereford and Washington Townships so that service lines could be
provided to the 29 residences which exceed the MCL for TCE. Two construction scenarios were
used in the cost estimating. One is called a branch system that would reach far enough to serve
the 29 residences and the other is a looped system which would pass by the affected residents
and continue along the roads in the vicinity of the Site. The extension would reguire
excavations in or along public roadways, installation of the underground piping for the
distribution main, installation of service lines to the property lines of affected residences,
and connection of the service lines to the plumbing system within each household. Four booster
pumping stations would be established to provide sufficient hydraulic head in the water supply
in this area of very steep terrain. During construction of the water line extension, residences
with contaminated groundwater in excess of MCLs or risk-based action levels would be provided
temporarily with an alternate water supply (either bottled water or point-of-entry treatment
systems).

It is anticipated that the Washington Township Municipal Authority would be the appropriate
authority to operate and maintain the water distribution system. It currently has an agreement
with the Bally Municipal Water Department to obtain water which could be used in this
alternative. The Borough of Bally currently uses one of two supply wells to provide potable
water to residential, commercial, and industrial customers. The water department is interested
in coordinating with the Washington Township Municipal Authority to expand its service by
providing potable water to other customers. Bally obtains its water supply from the bedrock
aguifer underlying the Borough. This aguifer appears to have been contaminated as the result of
separate disposal activities associated with the Bally Superfund Site. Bally treats the water
to meet drinking water guality criteria and sends the finished water into its distribution
system.

Coordination among EPA, the Pennsylvania Department of Environmental Protection (PADEP), the
Washington Township Municipal Authority, the borough of Bally, Hereford Township and
Washington Township would be reguired for the construction of the water line extension and for
administration and management of the extended water supply service. It is presumed that the
administration, management, and long-term operation and maintenance of the supply well and
treatment would remain the responsibility of the borough of Bally.

Institutional controls such as ordinances or deed restrictions may be employed to prohibit the
use of contaminated groundwater for drinking water, if treatment is not employed. Existing
residential supply wells and selected monitoring wells would be incorporated into a long-term
monitoring network to determine whether the water supplies of other residences may be affected
by groundwater contamination. Groundwater would be monitored annually for VOCs and metals.
Because contaminants would remain in the aguifer and would continue to pose threats to
groundwater users, 5-year reviews would be conducted to assess the status of Site conditions and
to review risks.

Alternative 4 would comply with federal and state chemical-specific ARARs since the water line
would furnish water that has been treated by the municipal water supplier to meet the primary
drinking water criteria (MCLs).

During the implementation of Alternative 4, all reasonable measures would be taken during
excavation and installation of the water line to comply with the federal and state ARARs.
Measures would be implemented to avoid disturbance of any wetlands or impairment of the storage
capacity of any flood plains. Prior to the initiation of construction, a review would be
conducted to identify any endangered species or sensitive habitats that may be encroached by the
installation of the water line. Should any historic or archeological artifacts or objects be
encountered during construction, the appropriate federal and state agencies would be notified to
-------
coordinate measures that would preserve or mitigate any adverse effects that might be
identified.

Alternative 4 would comply with the reguirements under Title 29 of the Code of Federal
Regulations for occupational safety and health since workers who install and perform periodic
maintenance of the water line and workers who perform the sampling of the long-term monitoring
wells would conform with these reguirements. During excavation and construction, erosion
control measures would be implemented, as appropriate, to minimize sediment discharges into
surface water bodies. Erosion control measures include silt fences, runoff collection and
sedimentation ponds, surface water diversions, stabilization of slopes, channels, and ditches,
and minimization of the exposed areas for earth-moving activities.

The cost estimate for implementation of Alternative 4 is
Capital costs: $7,324,000
Average annual O&M costs: $117,240 (years 1 through 4)
$102,740 (year 5)
$88,240 (years 6 through 30)
Five-year reviews: $23,000 per event

Over a 30-year period, the net present-worth cost of Alternative 4 is $8,566,383 for a branched
distribution system or $11,140,151 for a looped distribution system.
Note: This alternative would not pay for residential water bills and these costs do not include
the cost for service after installation.

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

The following summary profiles the performance of the alternatives in terms of the nine
criteria, noting how each compares to the other alternatives under consideration.

A. Overall Protection of Human Health and the Environment
Alternatives 2, 3, and 4 would all prevent exposure to groundwater that is contaminated in
excess of drinking water criteria or risk-based limits.

B. Compliance with ARARs
Alternatives 2, 3, and 4 would comply with chemical-, location-, and action-specific ARARs.

C. Long-Term Effectiveness and Permanence
Alternatives 2, 3, and 4 would all reduce carcinogenic and noncarcinogenic risks to below or
within the acceptable risk range for the long term. Under Alternative 2, increases in the
levels of groundwater contaminants could potentially expose the drinkers of bottled water to
unacceptable risks through the dermal contact or inhalation exposure pathways. Alternative 3
would be effective and reliable if the treatment system is properly operated and maintained.
Alternative 4 would be effective and reliable and increases in groundwater contaminant
concentrations would not affect the protection afforded by the new supply line.

D. Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 2 would not treat the groundwater and would not reduce the toxicity, mobility, or
volume of contaminated groundwater. Alternative 3 would treat an estimated 125 gallons of
groundwater per person per day. The VOCs captured by the treatment would be disposed off-site.
Alternative 4 would not treat water from the aguifer beneath the Crossley Farm Site. The
contaminated groundwater that would be treated is associated with another NPL site in Bally
Borough. The VOCs captured through this treatment would be vented to ambient air.

E. Short-Term Effectiveness
-------
Alternative 2 can be completed within 6 months. Alternative 2 is reliable, and no difficulties
are expected through the construction and operation of the systems. Additional actions can be
readily implemented if required after the 5-year review. Long-term monitoring would identify
any additional homes with contaminated water supplies; bottled water could rapidly be provided
to these homes on short notice.

Alternative 3 can be completed within 6 months. Alternative 3 would be slightly more difficult
to construct than Alternative 2 and would require water deliveries in the near term until all
the treatment units are installed. Additional actions can be readily implemented if required
after the 5-year review. Long-term monitoring would identify any additional homes with
contaminated water supplies. Point-of-entry treatment systems could be installed in these
homes. However, bottled water would need to be provided until the systems were installed.

Alternative 4 can be completed within 2 to 4 years. Alternative 4 would be the most difficult
to construct Extensive excavations and construction would be required. In addition,
considerable lead time would be needed for ordering and purchasing pumps and piping. Additional
actions can be readily implemented if required after the 5-year review. Long-term monitoring
would identify any additional homes with contaminated water supplies. These homes could be
readily connected to the public water line, since the main distribution network would already be
established. However, bottled water would need to be provided until the connections were made.

F. Implementability
The technologies and equipment needed for the implementation of Alternatives 2, 3, and 4 are
readily available. The deed restrictions associated with each alternative may be difficult to
implement. For Alternative 2, coordination among agencies may be required for the delivery of
water. For Alternative 3, coordination among agencies may be required for the installation and
service of the treatment systems. For Alternative 4, coordination among various agencies and
local municipalities would be required for the construction and administration of the water
distribution system, including the maintenance of the water lines and pump, the collection of
fees, and service.
G. Cost
The costs for each alternative are summarized in the following table.
$23,000 is for reviews, which would occur every 5 years.
For each alternative,
Cost Criteria
Capital Cost
Annual O&M
Present-Worth
Cost
Alternative 1:
No Action

$0
$44,120
$597,117
Alternative 2:
Delivered Water

Alt. 2A:
$120,420
Alt. 2B:
$22,270
Alt. 2A:
$314,440
Alt. 2B:
$140,200

Alt. 2A:
$4,071,951 Alt.
2B: $1,811,645
Alternative 3:
Point-of-Entry
Treatment
$172,230 for
$117,240 for
$1,676,700
H. State Acceptance
PADEP supports EPA's selected remedy for point of entry treatment systems.
Alternative 4:
Water Line

$7,324,000
branched
$9,887,000
looped
$117,240
years 1-4
$102,740 year 5
$88,240
years 6-30
$8,566,383
branched
$11,140,151
looped
-------
I. Community Acceptance
Generally the community is supportive of the selected remedy for point of entry treatment
systems. There was also a lot of concern about the proposed water line alternatives. Most of
the organized groups representing environmental interests and several individuals did not want
the water line to pass though the lower part of Forgedale Road by the creek because they felt
this was an environmentally sensitive area and should not be disturbed. Some voiced support for
the alternative to construct a new well field closer to the affected homes and then build a
water line in only the affected area.

X. THE SELECTED INTERIM REMEDY

EPA's selected interim remedy for addressing the contamination at the Site is similar to
Alternative 3, point of entry treatment systems, with some variations to the components of this
alternative. As in Alternative 3, the point of entry treatment units will be provided to the 15
homes which are currently treated with filtration units under the EPA removal program and an
additional 14 homes where the detected groundwater contamination exceed an MCL. Unlike
Alternative 3, the point of entry treatment units may also be provided to other residences whose
sampled well water detected contamination below a MCL, and those who may be potentially impacted
by the Site. Another variation is an increase in the periodic sampling freguency from one year
to every six months.

This remedy is consistent with the preferred alternative discussed in the text of the proposed
plan and EPA has made some assumptions for costing purposes. At this time there may be as many
as 70 residences that could be provided filtration units for their home wells. This is based on
water samples showing at least one detection of contamination in any of the previous sampling
and analyses. The cost calculations below also assume that 50 other residences in the study
area will not need filtration units. The 120 residences will be sampled every 6 months to
determine if any changes in the filtration units should be made and if any additional units
should be installed. The sampling program will also include selected monitoring wells and
springs. The installation of the filtration units will be installed by EPA. Once the
filtration units are operational and functional for purposes of 40 C.F.R. Section 300.435(f),
PADEP will maintain the units. The sampling program would be implemented by EPA during the
interim action and then by PADEP when the O&M period begins. To the extent the interim remedy
will reguire transportation, regeneration or disposal of carbon, all off site actions must
comply with federal and state laws and regulations.

For estimating the potential cost of the remedial alternative, the duration of the interim
remedy will be for 5 years. EPA expects a final remedy, which may be different from this
interim remedy, to be selected by the fall of 1998. However, the five years used for this cost
estimate is expected to be sufficient to protect the residents until the final remedy is
implemented.
Capital costs: $425,473
Average annual O&M costs: $305,920
Five-year reviews: $23,000 per event
Over a 5-year period, the net present-worth cost of this Alternative is $1,679,745

This interim remedial action will proceed into the next step which is the design stage for the
point of entry treatment systems. The exact number of homes and any possible variation in the
treatment systems may be reviewed an changed, if appropriate.

EPA must also contact any of the potentially responsible parties for this site to review their
-------
liability and their capability and or willingness to implement the design and construction of
the selected remedy.

XI. STATUTORY DETERMINATIONS

CERCLA directs EPA to select remedial actions that are protective of human health and the
environment. Section 121 of CERCLA also requires that the selected remedial action comply with
ARARs, be cost effective and utilize permanent treatment technologies to the maximum extent
practicable. The following sections discuss how the selected remedy for the Hereford
Groundwater/Crossley Farm Site meets these statutory requirements.

A. Protection of Human Health and the Environment

The selected interim remedy is protective of human health in that it provides for the treatment
of the contaminated home wells for the residents who are actually and potentially affected. The
water will meet the drinking water quality standards as long as the filters are maintained. The
remedy is also protective of the environment by limiting the construction activities to
individual home wells and by providing some removal of the contaminated groundwater for
treatment before it is discharged into the area springs and streams.

B. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

Section 121(d)(1) of CERCLA provides that remedial actions shall meet all federal and state
environmental requirements that are applicable or relevant and appropriate.

ARARs fall into three categories, depending on the manner by which they are applied to a site.
The characterization of an ARAR may not be unique, as some ARARs are combinations of the
following three categories:

1. Contaminant-Specific: Health- or risk-based numerical values or methodologies that
establish clean-up levels or discharge limits for particular contaminants.

Federal Safe Drinking Water Act (SDWA) and Maximum Contaminant Levels (MCLs)
40 C.F.R., Section 141.60 For.005 mg/1 of Trichloroethene (TCE).

The Pennsylvania Safe Drinking Water Act of May 1, 1984, P.L. 206, 35 P.S. Section
721.4(a).

2. Location-Specific: Restrictions based on the concentration of hazardous substances or
the conduct of activities at specific locations. These may limit or preclude certain remedial
actions or may apply to portions of a site.

There are no location-specific ARARs.

3. Action-Specific: Technology- or activity-based controls or restrictions on activities
related to the management of hazardous waste.

There are no action-specific ARARs.

PADEP has identified Act II as an ARAR for this interim remedy; EPA has determined that Act II
does not, on the facts and circumstances of this remedy, impose any requirements more stringent
than the federal standard.

C. Cost Effectiveness
-------
The selected remedy is cost effective in providing overall protection in proportion to cost, and
meets all other requirements of CERCLA. The point of entry treatment units will meet the
contaminant-specific ARARs and in conjunction with the continued monitoring program will provide
the appropriate level of protection to affected residents and those who are potentially
affected.

D. Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable (MEP)

EPA has determined that this remedial action is only an interim solution for the Site to remain
in force until the full RI/FS is completed.

E. Preference for Treatment as a Principal Element

The selected remedy does use treatment that will help to remove contaminated water from the
vicinity of the plume but it does not fully address the entire plume area. Since this is only
an interim remedy, the full scope of the remedy for the site will evaluate source removal as
well as groundwater extraction for removal and or containment of the contaminated plume.

XII. DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Crossley Farm Site was released for public comment on February 10,
1997. The Plan identified Alternative 3, Point of Entry Treatment as the preferred alternative.
EPA reviewed all written and oral comments submitted during the public comment period, It was
determined that no significant changes be made to the remedy as it was originally identified in
the Proposed Plan.
RESPONSIVENESS SUMMARY
HEREFORD GROUNDWATER / CROSSLEY FARM SITE
HEREFORD TOWNSHIP, BERKS COUNTY, PENNSYLVANIA

This community relations responsiveness summary is divided into the following sections:

Overview: This section discusses EPA's preferred alternative for remedial action.

Background: This section provides a brief history of community interest and concerns raised
during remedial planning at the Crossley Farm Site.

Part I: This section provides a summary of commentors' major issues and concerns and
expressly acknowledges and responds to those raised by the local community. "Local
community" may include local homeowners, businesses, the municipality, and potentially
responsible parties (PRPs).
OVERVIEW

On February 10, 1997, EPA announced the public comment period and published its
preferred alternative for Operable Unit 1 for the Crossley Farm Site, located in Hereford
Township, Berks County, Pennsylvania. EPA screened four possible alternatives to remediate
residential drinking water contamination, giving consideration to nine key evaluation criteria:
-------
BACKGROUND

EPA has divided the Crossley Farm Site into two components: Operable Units 1 and 2. Operable
Unit 1 (OU1) consists of the Site's contaminated residential drinking water supplies. Operable
Unit 2 (OU2) consists of the soil, sediment, surface water, and regional ground water
contamination.

To obtain public input on the Proposed Remedial Action Plan (Proposed Plan or PRAP) for OU1, EPA
held a public comment period from February 10, 1997, to March 12, 1997. A public meeting on the
Proposed Plan was held on March 5, 1997.

Those in attendance at the meeting included local area residents and officials, news media
representatives, representatives from EPA and the Agency for Toxic Substances and Disease
Registry (ATSDR), and representatives from companies interested in Site activities and clean-up
decisions. EPA briefed local officials prior to the public meeting.

EPA notified the public of the March 5, 1997 public meeting and announced the public comment
period in a display ad placed in the February 10 and 24, 1997, editions of the Allentown Morning
Call.

In addition, EPA established Site information repositories at the Hereford Township Municipal
Building and the Washington Township Municipal Building. The repositories contain the
Focused Feasibility Study Report, the PRAP, and other relevant documents. EPA's
Administrative Record for the Site, which encompasses the key documents the Agency uses in
selecting the Site remedy, also is housed at the repositories.

EPA also prepared a fact sheet and distributed it to individuals on the Site mailing list and in
attendance at the public meeting. The fact sheet included a summary of the Proposed Plan.

PART I: SUMMARY OF COMMENTORS' MAJOR ISSUES AND CONCERNS

This section provides a summary of commentors' major issues and concerns, and expressly
acknowledges and responds to those raised by the local community. The major issues and concerns
about the proposed remedy for the Crossley Farm Site received at the public meeting on March 5,
1997, and written responses received during the public comment period, can be grouped into seven
categories:

A. Support or Rejection of Alternatives
B. Human Health Concerns
C. Schedule
D. Previous Sampling
E. Remedial Alternatives for OU1
F. Remedial Investigation/Feasibility Study for OU2
G. Property Values/Superfund Issues

The guestions, comments, and responses are summarized below.

A. Support or Rejection of Alternatives

6 The majority of written received indicated support for the Point of Entry Treatment
Systems Nine of the thirteen commentors supported the Agency's preferred alternative.
Several of them expressed that Alternative 3 provides the "greatest level of health
safety and practicality, with the lowest level of environmental disturbance".
-------
6 Five of the commentors expressed a strong rejection of the Waterline alternative.
Their reasons included the destruction of the environment along Perkiomen Creek and
opposition to development. Some suggested that the developers or the water authority
should bear the costs instead of the Superfund remedy. Others suggested that if a
Waterline should actually be built an alternative route would be shorter and less
damaging to the creek environment.

6 Five of the commentors expressed a preference for an alternative to drill a new well
field closer to the affected homes and set up a new distribution system for them. This
alternative was not pursued in the FFS because the Agency does not have enough
information on the groundwater flow to determine where this new well field should be
located so that it would be remain free from contamination.

EPA Response: The Agency also cannot identify any municipal authority that would be able to
operate the system which would primarily be located in Hereford Township.

6 Two of the commentors also suggested that the Agency buy the homes of those affected.

EPA Response: This is not an alternative that was presented in the FFS and is not one that
the Agency can select. The Superfund program does not buy and move property owners when a
protective remedy can be provided for the individual home owners.

B. Human Health Concerns

6 One resident commented that EPA has not proven that the contamination levels detected in
the ground water at the Site are harmful to human health.

EPA Response: EPA is currently reviewing the toxic effects of trichloroethylene, the most
prevalent contaminant detected in the ground water at the Site. EPA is not stating that
because trichloroethylene is under review that it is not toxic, but that EPA is unsure how
toxic trichloroethylene really is. EPA will issue more information on the subject next
year.

However, EPA is charged by Congress to clean up the contaminated drinking water supplies at
the Site to Maximum Contaminant Levels. Maximum Contaminant Levels are levels at which
contaminants do not pose an immediate threat to human health or the environment.

6 A resident asked about the risks to human health from using the existing treatment
systems currently in place at several residences or the water treatment system EPA
proposes for use under Alternative 3.

EPA Response: The carbon filtration units currently installed are designed to remove the
contaminants detected at the Site. EPA has continued to sample and analyze drinking water
in those homes and has periodically replaced the carbon filtration units. When these
treatment systems are maintained, the residents are protected from the human health effects
from Site related contaminants.

6 A resident asked about the adverse health effects of trichloroethylene.

EPA Response: Trichloroethylene may cause nausea and abdominal pain from acute exposure at
levels well above the Maximum Contaminant Level of 5 parts per billion. Short term exposure
at a high dose can lead to unconsciousness and possibly death. Trichloroethylene has the
potential to cause liver damage from a lifetime exposure at levels above the Maximum
-------
Contaminant Level. There is some evidence that trichloroethylene may cause a slight
increase the potential for cancer from a lifetime exposure at levels above the Maximum
Contaminant Level of 5 ul/L. Increases in the concentration of exposure over a lifetime may
also increase the potential for cancer.

6 A resident asked whether trichloroethylene can affect other media, such as soil or air,
or livestock.

EPA Response: Trichloroethylene can affect other media at the Site. EPA will investigate
the soil, sediment and surface water in the vicinity of the Site. If a source of
contamination is found that source will be removed. It would be appropriate to assume that
drinking the contaminated groundwater could pose a threat to livestock, but specific effects
are not known. EPA's major concern at the Crossley Farm Site is trichloroethylene detected
in the residential drinking water supplies. The Agency has documentation about health risks
Trichloroethylene may pose to residents using contaminated water for drinking, showering, or
bathing.

6 A resident asked about the risks to residents drinking contaminated ground water.

EPA Response: EPA's acceptable level of cancer risk for Superfund sites ranges from one
excess cancer case per 10,000 people exposed to one excess cancer case per one million
people exposed. This translates to a risk range of between one in 10,000 and one in one
million additional cancer cases. Expressed in scientific notation, this risk range is
between l.OE-04 and l.OE-6. Because ground water contamination levels vary from residential
well to residential well, the risk to residents drinking the ground water at the Crossley
Farm / Hereford Groundwater Site also varies. In general, the risk range for the wells is
between l.OE-03 and l.OE-06. Remedial action is warranted at a site when the calculated
cancer risk level for potentially exposed individuals exceeds l.OE-04. Since this is the
case for several wells at this Site, EPA proposed implementing the interim remedy to reduce
the risk to residents. Specific risk values for individual wells can be found in the
Focused Feasibility Study for OU1 located at the information repositories.

6 Several residents were concerned about being allowed to drill drinking water supply
wells during the last five to eight years without knowing about ground water
contamination at the Site.

EPA Response: EPA does not have any authority to regulate home owner development and use
of the groundwater from the property. As far as the Agency knows, the township has informed
applicants for the permit necessary for a new groundwater well.

6 One resident has been experiencing skin irritation, smell, bacteria, and discoloration.
They also want new well due to septic tank location on their property.

EPA Response: EPA has investigated the bacterial contamination for these residents and
samples have revealed bacterial contamination at the tap, but not at the well. The tap was
subseguently cleaned and then sampling results showed the tap water to be clean. There is
no obvious explanation for these problems. The Remedial Design will consider the possible
installation of a new well since the current well does not meet Township regulations.

C. Schedule

6 Several residents asked about the schedule for Site cleanup.

EPA Response: EPA considers Alternative 3, installing water treatment units to treat ground
-------
water upon entry into affected homes, an interim remedy. EPA is considering this remedy for
all homeowners in the area who are affected by Site contamination. This type of treatment
system is very effective in removing trichloroethylene from ground water. EPA estimates
that installation of the units in the homes of affected residents could begin in
approximately nine to twelve months.

EPA is currently investigating soil, sediment, surface water, and ground water contamination
as part of the Remedial Investigation for OU2. When EPA completes the Remedial
Investigation and Feasibility Study in the spring or summer of 1998, EPA will propose a
final remedy for the entire Site. Then, EPA will issue another proposed plan which will
include some alternatives included in the Proposed Plan for OU1 and some new alternatives
for cleanup of the regional ground water contamination. Therefore, this remedy is
considered interim until the Remedial Investigation and Feasibility Study for OU2 are
completed and the clean-up plan for OU2 is selected.

D. Previous Sampling

6 A resident asked about the location of the farthest point that EPA sampled from the
suspected origin of ground water contamination.

EPA Response: The farthest point EPA sampled from the suspected origin of ground water
contamination (near the crest of Blackhead Hill) is a well located near the intersection of
Forgedale and Dale Roads.

6 A resident asked whether EPA sampled the spring located at Forgedale Road and Old Route
100. If so, the resident wanted to know why that spring was sampled since it is located
far from the Crossley Farm Site.

EPA Response: EPA did test the spring located at Forgedale Road and Old Route 100. Testing
by EPA showed no trichloroethylene contamination in the spring water. EPA tests this spring
because ground water which flows through the fractured bedrock likely flows from the Site
towards the spring. EPA also feels that the spring water should be tested because many
people in the area use the spring water for various purposes, and EPA wants to make sure the
water is not contaminated with trichloroethylene.

6 A resident asked why EPA removes the aerator from the faucet prior to sampling.

EPA Response: EPA removes the aerator from the faucet prior to sampling in order to get an
accurate reading of the volatile organic compounds, compounds that easily evaporate at room
temperature, in the tap water. An aerator is designed to disperse volatile compounds into
the air and thereby lessen the amount of volatile compounds that remain trapped in the tap
water. If the aerator remained on the faucet during sampling, less of the volatile organic
compounds would be detected in the tap water than actually exist.

6 A resident asked how many residents had ground water detections of trichloroethylene
below the action level of 5 parts per billion.

EPA Response: There are 29 home wells in the area and two wells that are considered public
supply wells at the trailer park located on Dale Road that show historical detections of
trichloroethylene greater than 5 parts per billion. EPA estimates that up to an additional
40 homes may have detections below 5 parts per billion and therefore, will be considered for
receiving water treatment units.
6 A resident wanted to know the location of the ground water plume.
-------
EPA Response: The contaminated ground water plume originates at the top of black head hill
and extends downwards toward the intersection of Dale and Forgedale Road. Further
investigation of the extent of contamination will be conducted and a more comprehensive map
will be prepared.

6 A resident asked if the same contaminants found at this Site were also detected at the
nearby Berks Sand Pit Superfund Site, located in Longswamp Township.

EPA Response: The most prevalent contaminant detected the Crossley Farm Site,
trichloroethylene, was not detected at the Berks Sand Pit Site. Trichloroethane is the
contaminant of concern detected at Berks Sand Pit. Both compounds behave similarly and have
similar human health effects but are not the same compound.

6 A resident wanted to know if Bally Case and Cooler, a local manufacturer located near the
Crossley Farm Site, used trichloroethylene and trichloroethane in its operations.

EPA Response: In correspondence from Bally Engineered Structures, Inc., the successor to
Bally Case and Cooler, they have acknowledged use of trichloroethylene. Trichloroethane was
not specifically mentioned in their correspondence.

6 A resident asked whether EPA was sampling and analyzing a nearby well associated with the
Bally Municipal System. The ground water extracted from the Bally well is contaminated
with the same compound associated with the Crossley Farm Site, trichloroethylene.

EPA Response: The site is known as the Bally Ground Water Contamination Site, located in
Bally, Pennsylvania. Ground water at this Superfund Site, which is used as a public
drinking water supply for residents of Bally and neighboring towns, is contaminated with
various volatile organic compounds including trichloroethylene. Treatment of the Bally
ground water includes air stripping which removes the volatile organic compounds and makes
the ground water suitable for public drinking water consumption.

6 Several residents asked about the possibility of the land farming operations at the
Crossley Farm Site contributing to the Site's contamination.

EPA Response: EPA reviewed the analytical results of the land-farmed sludge. The results
showed no detections of trichloroethylene or any of the volatile organic contaminants
associated with the Crossley Farm Site.

6 A resident asked EPA if ground water contamination could exist even if all contaminants
are reported as non-detects.

EPA Response: Yes it is a possibility. All analytical methods have a detection limits
associated with specific compounds. However, the residential well analysis performed at the
EPA laboratory used a very low detection limit for this Site

E. Remedial Alternatives for OU1

6 Several residents asked EPA to describe Alternative 3, water treatment units installed
upon entry into the homes of affected residents.

EPA Response: EPA plans to use a dual carbon system treatment unit for treating
contaminated ground water under this alternative. As the ground water enters each affected
home, the water will initially flow through a pre-filter to remove small particles. The
water will then enter the first ora primary activated carbon unit where most of the
-------
contaminants are removed. As a safety measure, EPA designed this alternative to include a
second activated carbon unit to capture any contaminants that might break though the first
unit. Any contaminant that might break through the first unit would be in very low
concentrations, because the first unit would remove most of the compound. The second unit
would definitely remove any remaining contamination. After the water passes through these
units, it travels through an ultraviolet system which destroys any bacteria in the water.
Once the water is disinfected, it is stored in a holding tank until it ultimately flows to
the user through the home's indoor plumbing system. Sample ports are located along the
entire system so that samples can be taken at any point prior, during, or after treatment.

6 A resident asked how often would EPA replace the activated carbon units under Alternative
3.

EPA Response: EPA plans to sample residents' wells every six months. If the sampling
results reveal that an activated carbon unit needs replacement, EPA would replace the unit
promptly. However, EPA designed the units so that they should last one year before the
activated carbon needs replacement.

6 A resident asked for the dimensions of a typical activated carbon unit under Alternative
3.

EPA Response: The dimensions of a typical activated carbon unit are one foot in diameter by
four feet tall.

6 A resident asked whether EPA identified potential residences to receive treatment though
sampling conducted more than 15 months ago. If so, how do residents who were identified
then as uncontaminated know that they are not contaminated now?

EPA Response: As part of the Remedial Investigation currently being conducted at the Site,
EPA plans to resample all residential wells and springs in the study area. Therefore, even
if a resident's well had no history of contamination, a resident would be eligible to
receive the water treatment unit specified under Alternative 3 if the resampling revealed
contamination.

6 A resident expressed concern over the adequacy of Alternative 3, water treatment units
installed in homes of affected residents, to treat his ground water, since the
contamination in his ground water continues to rise.

EPA Response: Under Alternative 3, EPA will design the water treatment units to remove
contaminants detected at high levels from the ground water. EPA will also design the units
to last one year before the activated carbon needs replacement. EPA plans to sample ground
water every six months to ensure the adequacy of the units. If the sampling results reveal
that a unit needs replacement, then EPA will promptly replace the unit.

6 Several residents expressed concerns about not being included under Alternative 3 if
their properties do not have wells installed presently.

EPA Response: Any new residential well installed will also be sampled for the protection of
the homeowner when the Agency is sampling the other home at the Site. If the sampling
results reveal that the drinking water is contaminated the home will be considered for the
point of entry treatment units under Alternative 3.

6 A resident asked if EPA plans to install treatment units at all properties that border
the Site, even if detected levels of trichloroethylene are below the action level of 5
-------
parts per billion.

EPA Response: Under Alternative 3, EPA proposes to install water treatment units on all
residential wells which have historical detections of contamination, even if detection
levels are below action levels.

6 Several residents asked if EPA plans to install water treatment units on wells with no
history of past contamination.

EPA Response: EPA will consider a property a candidate for receiving a water treatment unit
when the resident's ground water has no historical detections of contamination if that home
is in the pathway of migration for the plume.

6 Several residents commented that the only viable alternative to address the contaminated
ground water is Alternative 4, extending an existing water line from the nearby Borough
of Bally to the affected residents' homes.

EPA Response: EPA considered several different criteria during the process of evaluating
the alternatives for the Site. These criteria are described in the Comparative Analysis
section of this Record of Decision. Alternative 3, installing water treatment units,
provides the most reasonable balance between the various criteria. Alternative 3 is also an
interim remedy, which means that when the Remedial Investigation and Feasibility Study are
completed in a few years, EPA will reevaluate the regional ground water contamination in the
area and possibly select Alternative 4 or another alternative as the final remedy for the
Site.

6 A resident commented that, under Alternative 4, the closest route from the municipal
provider's supply line to affected residents is via Crow Road.

EPA Response: EPA acknowledges this and will take this comment into consideration if
Alternative 4 is reconsidered for addressing regional ground water contamination after the
Remedial Investigation is completed.

6 A resident asked about the monthly cost of receiving municipal water under Alternative 4.

EPA Response: Under Alternative 4, EPA estimated that the cost of receiving municipal water
would be approximately $35 to $40 per month payable by the homeowner. EPA would pay for the
water line hook-up to the home.

6 A resident commented that, under Alternative 4, Water Line, it would appear more cost-
effective to locate a municipal well near the Site and treat and distribute the ground
water from there rather than pump water to the affected residents from the existing Bally
Municipal supply wells located four miles away.

EPA Response: Locating a municipal well near the Site and pumping and treating the ground
water would still be very expensive. However, when the Remedial Investigation is completed
in a few years, EPA will evaluate the regional ground water contamination in the area and
select a remedy that effectively addresses the ground water contamination in the area. At
this time, EPA will consider all possible alternatives, including those suggested by the
local community.

6 A resident asked what agency determined the layout of the water line as shown under
Alternative 4.
-------
EPA Response: EPA determined the present layout of the water line under Alternative 4.
However,if EPA selected this alternative as the preferred alternative to address
contaminated drinking water supplies, EPA would consult with the water authority proposed to
operate the water line and with local communities concerning where the water line would be 1
located.

6 A resident wanted EPA to dispel rumors that Washington Township Municipal Authority, the
authority that would most likely operate and maintain the water line proposed under
Alternative 4, lobbied EPA to select this alternative so that the authority could install
sewer pipe as it installs the water line at no cost to the authority.

EPA Response: No authority or agency has lobbied EPA for any of these alternatives
specified in the Proposed Plan. EPA did approach Washington Township Municipal Authority
regarding Alternative 4. Prior to providing Alternative 4 as a feasible alternative to
address contaminated public drinking water supplies, EPA needed to make sure that the
authority was interested in providing water to the public.

6 A written comment asked why The Agency did not consider a small type of air stripper to
treat The drinking water at individual domestic wells.

EPA Response: Residential air stripping units were considered in The FFS under alternative
3 (Point of Entry Treatment) but were not chosen. The reasons include The following:
a) A two-tray air stripping unit would be reguired and its operation could be loud
enough to disturb The resident.
b) Carbon and UV treatment units could be necessary after stripping. Which would
increase capital costs.
c) The off gas (stripped volatile organic contaminants) could not be vented to The
atmosphere and would reguire capture by carbon adsorption.

6 A written comments asked why the Agency would place filtration systems in homes that
do not exceed the MCL or other health based criteria since the Agency will be sampling
every 6 months?

EPA Response: Since it is difficult to predict when a residential well could be impacted by
contaminated ground water above an MCL or risk based concentration when it is already
impacted below these concentrations and lies within the plume boundary, EPA believes that it
is reasonable to assume that these wells will likely be impacted above the MCL or risk based
concentration in order to be more protective of these residents.

F. Remedial Investigation/Feasibility Study for OU2

6 A resident commented that EPA's main focus should be on locating sources of contamination
at the Site.

EPA Response: One of EPA's main focuses is locating sources of contamination at the Site.
EPA is currently conducting a Remedial Investigation at the Site to determine the location,
type and amount of contamination at the Site.

6 Residents commented that the Remedial Investigation should be guided by the information
provided by local persons who claim to have knowledge of past dumping activities and
their locations.

EPA Response: EPA conducted a lengthy investigation into determining the past dumping
history of the area. The investigation included reviewing historical aerial photographs and
-------
interviewing local residents and officials. As part of the Remedial Investigation currently
being conducted at the Site, EPA is exploring several locations identified through this
research to determine if they are the source of contamination at the Site.

6 A resident asked if EPA plans to investigate mine shafts located at the Crossley Farm
Site as part of the Remedial Investigation.

EPA Response: EPA will refer the investigation of mine shafts in the vicinity to the
Pre-remedial Investigation Section to determine if the shafts contain any sources of
contamination.

6 A resident asked if EPA tests the head waters in the area as part of the Remedial
Investigation currently being conducted at the Site.

EPA Response: EPA conducted one round of surface water and sediment sampling upgradient
of the Site to determine the guality of water prior to reaching the Site. EPA is currently
evaluating the results. EPA will continue this type of sampling as part of the Remedial
Investigation. EPA will publish the results of all rounds of sampling in the Remedial
Investigation Report.

6 A resident wanted to know, when the Remedial Investigation is finished, whether EPA will
reconsider Alternative 5, Well Field, as a possible alternative for the residential
drinking water supplies.

EPA Response: EPA will reconsider Alternative 5, Well Field, as a possible alternative for
the residential drinking water supplies when the Remedial Investigation is completed. EPA
screened this alternative out of the recommended alternatives in the Focused Feasibility
Study because EPA did not have a location to place the well field nor an agency to operate
it.

6 A resident asked why EPA is drilling deep wells farther away from The Site instead of
close to The Site.

EPA Response: The deep monitoring wells will be used to identify whether ground water
contamination exists deep in the aguifer as well as estimate the rate and direction of
ground water flow. This type of information will allow EPA to better determine the extent
of contamination in the aguifer and identify who may be potentially impacted from
contaminated ground water presently and in the future. EPA has proposed drilling these
wells farther away from the site in order to avoid potentially drilling through a source of
highly concentrated contamination in the form of dense non-agueous phase liguid (DNAPL).
The contaminant concentrations at the site are at high levels indicative of dense
non-agueous phase liguid. DNAPLs are fluids which are heavier than water and do not readily
dissolve in or mix with water. Therefore, when you drill through DNAPL, it has a tendency
to move deeper or farther.

6 A resident asked if there is a possibility of contaminating uncontaminated ground water
via drilling methods used to drill deep wells as EPA proposes in The Remedial
Investigation.

EPA Response: Because the deep monitoring wells are being drilled at locations where there
is lower levels of ground water contamination than on the site in the shallow portion of the
bedrock aguifer, it is unlikely that highly elevated levels of contamination will be brought
deeper into the bedrock aguifer. Also, it is highly unlikely that the deeper aguifer is
uncontaminated to begin with because DNAPLs, which are likely present at the site, tend to
-------
sink as they are heavier than water. However, The deep bedrock wells will be drilled with
every precaution to prevent the contaminated ground water from continually flowing to the
deeper bedrock. While drilling the deep monitoring wells the shallower zone of the bedrock
aguifer will be sealed off from the shallow contaminated ground water through installation
of a solid pipe and the pipe will be set with cement.

G. Property Values/Superfund Issues

6 Several residents expressed concern over the negative impact that the ground water
contamination has on property values in the area.

EPA Response: EPA is not in the position of talking about property values or property
taxes, however, EPA feels that the remedy selected makes the property values in the area the
same as other properties that have uncontaminated well water. EPA will provide the
treatment unit and sample the water periodically to show the residents that the water is
clean, and therefore, increase the homeowner's ability to sell the home.

6 One resident wanted to know why EPA identified the Site using a specific individual's
name if EPA has no clear evidence regarding who the responsible parties are or where the
dumping of hazardous waste occurred.

EPA Response: EPA identified the Site as the Crossley Firm Site when the Site was proposed
for the National Priorities List. The Agency believed that the source was on the farm. The
site is also known as the Hereford Groundwater Site and EPA decided to use both names in
this Record of Decision. The RPM has contacted the appropriate personnel within EPA to
re-evaluate the name changes.
-------
717-657-4592
Southcentral Regional Office FAX 717-540-7492

VIA TELEFAX AND FIRST CLASS MAIL

Mr. Thomas C. Voltaggio, Director
Hazardous Waste Management Division
US EPA, Region III
841 Chestnut Building
Philadelphia, PA 19107

Re: Record of Decision (ROD)
Hereford Groundwater
Crossley Farm Site
Hereford Township, Barks County

Dear Mr. Voltaggio:

The Record of Decision (ROD) for the Hereford Groundwater/Crossley Farm Superfund Site,
Berks County, was received June 18, 1997, with an additional amendment received June 26, 1997.
It has been reviewed by the Department.

The interim remedial action for this site consists of the following:

6 Provide point of entry treatment systems to the residents who are impacted by
contamination from the Site.

6 Depending on the contaminants identified at specific residences, additional treatment
components may be required, such as pH adjustment or a water-softening unit to
remove manganese and iron.

6 Because this action does not constitute the final remedy for the Hereford Ground-
water Crossley Farm Site, the statutory preference is only partially addressed in this
interim remedy.

The Department hereby concurs with EPA' s interim remedial action with the following
conditions:

6 Concurrence with the remedy should not be interpreted as acceptance of
Operation and Maintenance by the Department. This is entered into during design
of the remedy and the completion of a State Superfund Contract.

6 EPA will assure that the Department is provided an opportunity to fully
participate in any negotiations with responsible parties.

6 The Department will be given the opportunity to review and comment on docu-
ments and concur with decisions related to the design and implementation of the
remedial action, to assure compliance with Pennsylvania ARARs.

6 Public comment and the issuance of an Explanation of Significant Differences
(BSD) must occur before any modification of the ROD.

6 This concurrence with the selected remedial action is not intended to provide any
assurances pursuant to SARA ° 104(c)(3).
-------
Thank you for the opportunity to comment on this EPA Record of Decision. If you have
any questions regarding this matter, please do not hesitate to contact me.

-------